RSM 2, Section 1700: Pre-Employment Transition Services

Updated: 6/25

In July 2014, the Workforce Innovation and Opportunity Act (WIOA) was signed into law. WIOA requires a vocational rehabilitation (VR) agency to reserve 15% of its federal funds to provide Pre-Employment Transition Services (Pre-ETS) to students with disabilities. This section includes guidance for providing these services statewide in collaboration with state and local education agencies.

1701 Target Population

Pre-ETS are provided to "students with disabilities" who are:

Eligible for VR services; or
Potentially eligible for VR services (i.e., all students with disabilities, including those who have not applied or been determined eligible for VR services)

A "Student with a Disability" is one who meets all of the following criteria:

Is at least 14 but no more than 21 years of age (has not yet reached 22nd birthday).
Has a disability, and has submitted the required qualifying medical documentation signed by a medical provider or a copy of their Individualized Education Program (IEP) or 504 Plan.
Has documentation confirming enrollment as a student in an educational program, including:
1. Secondary school, including home school and alternative school programs (e.g., those housed within the juvenile justice system)
2. Post-secondary education programs approved by a state’s Higher Education Commission (i.e., Maryland Higher Education Commission)
3. Adult basic educational programs which lead to a recognized educational credential (e.g., GED^® or high school diploma)
4. State, nationally, or industry recognized certificate programs leading to a credential (e.g., Certified Nursing Assistant, Phlebotomy Technician, Microsoft Certification, Commercial Driver’s License Certification, Automotive Service Excellence Certification).
5. Comprehensive Transition Programs (CTP) approved by the United States Department of Education. (See Attachment 1700-4: CTP Desk Reference, for additional guidance.)
Documentation of enrollment may include an IEP, 504 Plan, report card, college acceptance letter, college registration receipt, or other documentation from the educational program, and must be current each time a Pre-ETS Agreement (RS-10c) is initiated to demonstrate that the student continues to qualify for these services.

1702 Required Services and Statewide Availability

The primary purpose of Pre-ETS provided or coordinated by DORS is to help students begin to identify career interests and to learn skills in preparation for transition to employment and/or post-secondary education. DORS will make every effort to provide or coordinate the following services to ensure statewide availability.

Description of Required Services – Pre-ETS may be provided in a group or generalized classroom setting and/or an individualized setting and are limited to any or all of the five services outlined below.

1702.01 Instruction in Self-Advocacy

Instruction in Self-Advocacy may include, but is not limited to:

Learning about their rights and responsibilities.
Learning how to request accommodations, services or supports.
Mentoring with education staff (e.g., principals, nurses, teachers, or office staff).
Peer mentoring with individuals employed by or volunteering for employers; boards, associations, or organizations in integrated community settings.
Participating in youth leadership activities offered in educational or community settings.

1702.02 Workplace Readiness Training

Workplace Readiness Training to develop social skills and independent living skills necessary for employment may include, but is not limited to:

Learning communication and interpersonal skills.
Financial literacy, including benefits planning services.
Orientation and mobility skills to access workplace readiness training or to learn to travel independently.
Job-seeking skills.
Understanding employer expectations for punctuality and performance, as well as other "soft" skills necessary for employment.
On-site workplace readiness training during a work-based learning experience (WBLE).

1702.03 Job Exploration Counseling

Job Exploration Counseling may include, but is not limited to:

Review of information regarding in-demand industry sectors and occupations, as well as nontraditional employment.
Administration of vocational interest inventories and provision of Local labor market information that applies to the student’s particular interests.
Identification of career pathways of interest to the students.

1702.04 Counseling on Opportunities for Enrollment in Comprehensive Transition or Post-Secondary Education Program

Counseling on Opportunities for Enrollment in Comprehensive Transition or Post-Secondary Education Program may include, but is not limited to:

Exploring the types of academic and occupational training needed to succeed in the workplace.
Postsecondary opportunities associated with career fields or pathways.
Self-advocacy skills for the purpose of identifying accommodations and services in an educational program as well as providing resources that may be used to support individual student success in education and training (i.e., disability support services).
Advising students and parents or representatives on academic curricula and course offerings.
Providing information about college application and admissions processes.
Completing the Free Application for Federal Student Aid (FAFSA).

1702.05 Work-Based Learning Experiences

Work-Based Learning Experiences (WBLE)may include opportunities that are available in school, after school, or outside the traditional school setting; however, they must be provided in an integrated setting in the community to the maximum extent possible. DORS and community partners should seek every opportunity to provide work-based learning experiences in integrated settings before providing these services in non-integrated settings. Services may include, but are not limited to:

Coordinating a school-based program of job training and informational interviews to research employers.
Work-site tours to learn about necessary job skills.
Job shadowing.
Mentoring opportunities.
On-site work-based experiences, paid or unpaid (i.e., internships, volunteering, practicums, or service learning opportunities).

1703 Providing Auxiliary Aids and Other Accommodations and Services to Access or Participate in Pre-ETS

DORS will ensure that no qualified student with a disability is denied the benefit of Pre-ETS on the basis of the individual’s disability. Therefore, if a student with a disability requires reasonable accommodations/auxiliary aids or services to access or participate in any of the required Pre-ETS, DORS may pay for such costs when no other public entity is required to provide such aids or services. DORS may use funds reserved for providing Pre-ETS to pay for those auxiliary aids and services for any student who needs them, regardless of whether they have applied and been determined eligible to receive VR services.

1703.01 Reasonable Accommodation/Auxiliary Aids and Services

Accommodations, aids and services for deaf and hard-of-hearing students, including:

Qualified interpreters on-site or through video remote interpreting (VRI) services
Note takers
Real-time computer-aided transcription services
Written materials
Exchange of written notes
Telephone handset amplifiers
Assistive listening devices
Assistive listening systems
Telephones compatible with hearing aids
Closed caption decoders
Open and closed captioning, including real-time captioning
Voice, text, and video-based telecommunications products and systems, including text telephones (TTYs, videophones, and captioned telephones, or equally effective telecommunications devices)
Videotext displays
Accessible electronic and information technology
Other effective methods of making aurally delivered information available to individuals who are deaf or hard of hearing

Accommodations, aids and services for blind, visually impaired and deaf-blind students, including:

Support Services Provider (SSP) for the deaf-blind
Qualified readers
Taped texts
Audio recordings
Brailled materials and displays
Screen reader software
Magnification software
Optical readers
Secondary auditory programs (SAP)
Large print materials
Accessible electronic and information technology
Other effective methods of making visually delivered materials available to individuals who are blind or have low vision

Assistive technology assessments to determine whether modified equipment or devices are needed for a student to participate in Pre-ETS.
Non-adapted or adapted equipment or devices, when needed for a student during participation in Pre-ETS. DORS will retain ownership of the equipment or device and require its return at the conclusion of the service for which it was provided, so that it may be available for use by other students during Pre-ETS.

Pre-ETS funds may not be used to modify a student’s personal equipment or devices, or to provide personal equipment or devices of which students would retain ownership.

Auxiliary aids and services do not include:

Personal devices (e.g., computers, laptops, tablets, etc.)
Prescribed devices (e.g., eyeglasses, hearing aids, wheelchairs)
Readers for personal use or study
Attendant Care or other services of a personal nature
Home or vehicle modifications

1703.02 Provision of Other Necessary Support Services

Funding of services needed shall be determined in collaboration with the local school system and other resources.

Pre-ETS Case Type – When a student requires a personal device to participate in services, DORS may loan the device, contingent on availability. This loan will be documented on the student’s Pre-ETS Agreement (RS-10c), and the student will be required to return the device when no longer required for participation in services.
VR Case Type – For students with disabilities who have been determined eligible for services under the VR program and who have an approved IPE, the following VR services may be provided using funds reserved for providing Pre-ETS should they be determined to be necessary for an eligible student with a disability to benefit from Pre-ETS.
1. Assessment Services – Assessment services may be provided and necessary while engaging in any Pre-ETS to fully benefit from those activities.
2. Counseling and Guidance – Counseling and guidance may be provided to students in order to benefit from Pre-ETS.
3. Referral Services – Referral service may be provided to secure needed services from other agencies to fully participate in one or more Pre-ETS activities.
4. Maintenance – Maintenance must be provided in combination with another Pre-ETS service. Examples of this flexibility include purchase of required clothing for a work-based learning experience or a talking alarm clock to participate in a work readiness service.
5. Transportation – Transportation must be provided in combination with another Pre-ETS service and identified on an approved IPE. DORS must ensure the costs incurred for transportation services are allocable to the Pre-ETS that the eligible student with a disability is receiving, as opposed to other VR services that the eligible student may also be receiving simultaneously.
6. Personal Assistance Services – Personal Assistance Services must be provided in combination with another Pre-ETS service. This Pre-ETS spending flexibility is only available to pay for those services in the event an eligible student with a disability needs them to benefit from Pre-ETS. Additionally, the allocable personal assistance services must be identified on the IPE and directly related to the student's participation in Pre-ETS.
7. Rehabilitation Teaching & Orientation and Mobility Services – Orientation and mobility services are also offered as Pre-ETS (i.e., workplace readiness training) in the event an eligible student with a disability needs them to benefit from Pre-ETS. These services must be included and identified on an approved IPE.
8. Rehabilitation Technology:
  - Rehabilitation technology may be necessary for an eligible student with a disability to benefit from Pre-ETS, particularly those involving work-based learning experiences, workplace readiness training, and self-advocacy training. Without the rehabilitation technology, the eligible student with a disability might not be able to participate in Pre-ETS.
  - DORS must ensure that the costs incurred for rehabilitation teaching & orientation and mobility services are allocable to the Pre-ETS that the eligible student with a disability is receiving, as opposed to other VR services that the eligible student may also be receiving simultaneously.
9. Family Services – Services to the family, by their very nature, must be provided in combination with another VR service, such as Pre-ETS. Examples of this flexibility include transportation services to accompany the eligible student with a disability to their Pre-ETS activities or the parent or guardian may need language interpreter services in order to understand forms.
10. Coaching Services – Job Coaching services if needed by an eligible student with a disability, in accordance with an approved IPE, to participate in Pre-ETS (primarily work-based learning services) are allocable. This Pre-ETS spending flexibility is only available to pay for those services in the event an eligible student with a disability needs them to benefit from Pre-ETS.
11. Vocational and Other Training Services – Vocational and other training services, including books, tools, and other training materials, may be necessary for an eligible student with a disability to benefit from Pre-ETS, and may be provided for eligible individuals in accordance with an approved IPE.
If eligible students with disabilities need additional VR services that are not within the scope of Pre-ETS, DORS may still provide those services in accordance with the terms of the approved IPE, using VR funds not reserved for Pre-ETS.

1704 Outreach and Collaboration Responsibilities

DORS managers, counselors, and Business Service Representatives will make every effort to develop and maintain cooperative working relationships with State and local secondary education staff (including alternative school programs), post-secondary education staff, State-operated programs, and workforce development partners (i.e., American Job Centers, Maryland Department of Labor, etc.) to coordinate Pre-ETS.

Coordination activities include:

Participating in IEP meetings for both eligible and potentially eligible students. Participation may be in person or by teleconference, when invited, pending DORS representative availability.
Making every effort to attend person-centered planning meetings for students with disabilities receiving services under Title XIX of the Social Security Act, when invited.
Working with American Job Centers, other WIOA Programs, and employers to develop work-based learning experiences for students with disabilities.
Encouraging referral sources to refer students with disabilities in secondary education as early as age 14 for Pre-ETS and to check on the status of these referrals.
Providing accurate information to referral sources regarding the timeline and application process for vocational rehabilitation services.

School officials continue to be responsible for providing a free and appropriate public education to include transition services required under IDEA.

1705 Provision of Pre-ETS to Students with Disabilities

Pre-ETS provision to students with disabilities shall be:

Governed by DORS policies and procedures.
In accordance with:

State and federal law and regulation
The statewide educational cooperative agreement developed among the Maryland State Department of Education’s Divisions of Rehabilitation Services, Special Education/Early Intervention Services, Career Technology and Adult Learning, and Student and School Services
Transitioning Students with Disabilities, Education Article 21-305 in the development of Local Cooperative Agreements

Made available to students with disabilities statewide, to include those who are "potentially eligible" for VR services.
Provided based on parental consent to participate in Pre-ETS obtained pursuant to the State law, as well as policies of the educational programs.
Students with disabilities are not exempt from any of the Order of Selection requirements for VR services. A student with a disability who needs individualized VR services, in addition to Pre-ETS, must apply and be determined eligible (see Section 500) for the VR program and have an approved IPE (see Section 604).

1706 Pre-ETS Referral Process

To ensure that requests for Pre-ETS are accepted, assigned, and registered in AWARE™ promptly, referrals of students with disabilities shall be managed as indicated below:

A referral may be submitted by school personnel, family members, guardians, or other interested persons via an online referral form, paper referral form, or phone call. Referral information should include:

Social security number (optional, not included when the online referral process is used)
Date of birth
Race and ethnicity
Disability
10-digit state student identification number for high school students (may be found on student's IEP, if available)

DORS staff shall establish referral procedures with school officials to assure that:

Parent/Guardian consent for DORS collaboration with the school is obtained.
Student referred for Pre-ETS meets the definition of "student with a disability."
Student has medical and/or school documentation substantiating that the individual is a student with a disability (i.e., IEP, 504 plan or doctor’s note) for purposes of providing Pre-ETS.
Referrals from school personnel include pertinent and available school-based assessment information (e.g., psychological evaluations, vocational evaluations, and medical or specialty screenings), in the event that the student applies for VR services.

When a student is referred for DORS services by sources other than the school, the DORS counselor will notify the appropriate school personnel of the referral upon obtaining the appropriate authorization for release of information (Section 200) to promote information sharing and collaboration.
Within no more than 15 working days of the receipt of a referral, DORS staff will provide the student with the following documents and a cover letter requesting required documentation if not already provided:

DORS Intake Form (RS-1c)
Pre-ETS Fact Sheet (RS-10a)
Client Assistance Program
Informed Choice
Professional Disclosure Statement (RS-1m)

Student information shall remain in the referral module until all required documentation (i.e., enrollment, disability, and the DORS Intake Form (RS-1c) signed by the student and, if student is a minor or in high school, the parent/legal guardian) is received.
If all required documentation is not provided or the student or parent/legal guardian does not respond to a minimum of two documented DORS contacts, the referral may be closed.

Contacts will include an initial letter and two additional documented contacts including phone, email, or alternative method of communication as available.
The referred individual, student with disability or parent/legal guardian will be notified in writing, contact indicating reason referral has been closed and provide information about how to re-apply (see Section 1001.05).

When a referral for Pre-ETS is received for a student who will soon no longer qualify for Pre-ETS or who may be automatically eligible for VR services under an open disability priority category, consult with local management regarding how best to process the referral.

1707 Provision of Pre-ETS

Pre-ETS will be provided to students with disabilities with records of service on either a Pre-ETS caseload or a VR caseload type in AWARE™. Provision of services shall be managed as follows, consistent with Attachment 1700-1: Pre-ETS Desk Reference.

1707.01 Provision of Pre-ETS Using the Pre-ETS Case Type

Initiating Pre-ETS Case – When all required documentation listed in Section 1706 above is received, DORS staff will:
1. Enter student’s information in the AWARE™ Participant Module.
2. Select the appropriate Special Program Indicator:
At this point, AWARE™ will generate a 12-digit Unique Identifier for the student, which will be used when reporting Pre-ETS service delivery, as required by federal law.
Initial Pre-ETS Discussion – The assigned counselor will make every effort to discuss Pre-ETS with the student within no more than 30 working days of receiving the required documentation of disability and enrollment and the signed DORS Intake Form (RS-1c). The counselor will discuss service options with the student, in either an individual or group setting, at the school, the DORS office, or a mutually agreed upon location in the community or via phone conversation as appropriate.
During the initial discussion, the DORS counselor shall:

Provide basic job exploration counseling, and document this in an AWARE™ case note by selecting "JEC FOR PRE-ETS" in Section 3 of the case notes page, “Activities Provided Options."
Discuss next steps, including identifying additional appropriate Pre-ETS and providers, consistent with the student’s informed choice and which may be completed before the student no longer qualifies for Pre-ETS.

Pre-ETS Agreement Preparation – As soon as Pre-ETS and providers are identified, the assigned counselor shall:

Prepare a Pre-ETS Agreement (RS-10c) which:

Verifies the student continues to qualify for Pre-ETS.
Lists services, providers, and estimated begin dates.

Select Special Program Indicator: "Step 3: Signed Pre-ETS Agreement" Received (Deselecting Special Program Indicator: "Step 2").

Pre-ETS Agreement Implementation – The Pre-ETS Agreement (RS-10c), signed by student and parent/legal guardian (if student is a minor or in high school), must be received and signed by a DORS representative before future services are authorized. Once all required signatures have been obtained, the assigned counselor shall:

Provide a copy of the Agreement to the student and parent/legal guardian.
Provide services in accordance with the Agreement.
Select Special Program Indicator: "Step 4: Pre-ETS Delivery in Progress" (Deselecting Special Program Indicator: "Step 3").

Pre-ETS Agreement Continuation – As long as the student qualifies to receive Pre-ETS, the Agreement will be effective and new Agreements may be written, as additional services are identified through ongoing coordination activities with the education providers and other interested parties.

1707.02 Provision of Pre-ETS Using the VR Case Type

When a student with a disability has an IPE, provision of Pre-ETS will be included on the IPE (see Section 600).

1708 Initiating VR Services After Beginning Pre-ETS

Students with disabilities are not required to apply or be determined eligible for VR services before receiving Pre-ETS. Students who have provided adequate documentation of their disability and enrollment in a recognized education program shall not have their participation in Pre-ETS delayed by the process of applying for VR services.

DORS counselors will discuss VR services with students and their parent/legal guardian, and will assist interested students to apply for VR employment services by completing an online referral to facilitate a smooth transition into VR services.

Students who do not apply for VR services may continue to receive Pre-ETS under the Pre-ETS case type as long as they continue to satisfy the definition of a "student with a disability."

Students who apply and are determined eligible for VR services with be assigned to an Order of Selection category (see Section 503.06).

1708.01 Assignment to an Open Order of Selection Category

Eligible students assigned to an open order of selection category may have Pre-ETS included on the IPE and provided for as long as the individual continues to meet the definition of a "student with a disability."

If a student is ready to participate in Pre-ETS and is not yet ready to identify a vocational goal on the IPE, enter a projected post-high school goal in the "Custom" field on the Plan, then select "Projected Post-High School Goal in Custom Field-Only Pre-ETS Services Provided" from the job title mini-search. This will print on the plan with the projected goal entered in the custom field along with the statement "Projected Employment Goal Shown Above." The purpose of the services on this Plan will be to support the student in developing and refining a vocational goal. The plan must be revised to indicate a specific vocational goal once the career development process is complete.

1708.02 Assignment to a Closed Order of Selection Category

Eligible students assigned to a closed order of selection category and placed on a waiting list for VR services after receiving Pre-ETS may continue to receive Pre-ETS using the Pre-ETS case type.

Eligible students assigned to a closed order of selection category and placed on a waiting list for VR service before receiving Pre-ETS may not receive Pre-ETS using the Pre-ETS case type. These students will be required to wait for Pre-ETS until they are removed from the waiting list and an IPE can be developed.

1709 Financial Responsibility for Pre-ETS Participation

1709.01 Financial Responsibility Using the Pre-ETS Case Type

DORS’s financial need policy (RSM 3, Section 1400) and the possibility of a family contribution will not apply when the student participates in Pre-ETS or when the student requires reasonable accommodations/auxiliary aids and other necessary support services (see Section 1703.01) to participate.

1709.02 Financial Responsibility Using the VR Case Type

When Pre-ETS or reasonable accommodation/auxiliary aids and services as described in Section 1703.01 are included in the IPE, DORS's financial need policy (RSM 3, Section 1400) and the possibility of a family contribution does not apply to the provision of those services. However, DORS’s financial need policy and the possibility of a family contribution does apply to all other services included on the IPE.

1710 Discontinuation of Pre-ETS and/or Closure of Service Records

1710.01 Discontinuation of Services

Pre-ETS shall be discontinued once an individual no longer satisfies the definition of a "student with a disability," regardless of whether those services were being provided consistent with a Pre-ETS Agreement or an IPE.

Pre-ETS Case Type:

At the time of service discontinuation, the DORS counselor or manager should make every attempt to contact the individual to notify them.
Documentation of discontinuation of services should be provided through the appropriate DORS discontinuation letter.
The record of services shall be closed in AWARE™ when services have been discontinued.

VR Case Type – Pre-ETS shall cease to be provided under an IPE once the individual no longer meets the definition of a "student with a disability" or once the individual has been moved into employed status All other VR services may continue as planned.

Pre-ETS shall not be provided to any student age 22 and beyond.

1710.02 Closure of the Service Record

Pre-ETS Case Type – The records of services for students receiving Pre-ETS under the Pre-ETS case type shall be closed when the individual:

No longer meets the definition of a "student with a disability."
Has become eligible for VR services under an open Order of Selection category and has had an IPE approved.
Chooses not to participate in, or continue participating in Pre-ETS, as confirmed by student and/or guardian either verbally or in writing.

VR Case Type – When closing the record of a student in an open order of selection category receiving Pre-ETS as part of an IPE, refer to Section 1001, Record of Services Closure – Vocational Rehabilitation.

​​​​​​​​​​​​​DORS Official Policy​​​​

Section 1700