Comments on Notice of Proposed Rulemaking
Subject and Citation
7(5)(B) of the Act, as amended by WIOA,- competitive integrated employment
High Level Summary
Summarize and describe the main points of the subject you are reviewing
Description of how definition of “competitive integrated employment” is similar/different from current
definitions
Changes to Current Practice
Describe any changes to current practices that the new rule would require
“Specifically, individuals with disabilities hired by community rehabilitation programs to perform work
under service contracts, either alone or in groups(e.g., landscaping or janitorial crews), whose
interaction with persons without disabilities (other than their supervisors and service providers) is with
persons working in or visiting the work locations (and not with employees of the community
rehabilitation programs without disabilities in similar positions) would not be performing work in an
integrated setting.”
This would change our ability to take some closures that we currently get and will reduce the number of
employment options for consumers.
Implications of Changes
Describe any implications – to policy, fiscal impact, staffing, etc. – that would result from the changes
I think that the paragraph above is saying that if the person is working for a competitive employer but
under contract with a CRP, they would never be considered as working in an integrated setting, even if
the job fit the definition in every other way.
Conclusion
Is the rule change good or bad? Should we support it? Oppose it? Suggest changes?
My initial take is that it is bad. To me, when it is an individual placement, where the person’s interaction
with non-disabled people is the same as it is for other staff working in the same capacity, then it should
be considered integrated, the same as if the person were working for a staffing agency.