Comments on Notice of Proposed Rulemaking
Subject and Citation
Integrated Location, Section 7 (5) (B) of the Act, refer to page 47
High Level Summary
Summarize and describe the main points of the subject you are reviewing
1. Requires that a work location be in a “setting typically found in the community” meaning the
competitive labor market. Sheltered Workshops do not meet the criteria for integrated settings.
2. Individuals with disabilities must have the opportunity to interact with non-disabled co-workers
to the same extent as their non-disabled co-workers have while performing the same work.
Should be based on the interaction between employees with and without disabilities.
3. Self-employment and tele-commuting meet the definition.
4. DSU must determine on case by case basis that a work location meets the definition of an
integrated setting.
Changes to Current Practice
Describe any changes to current practices that the new rule would require
We have done very little in the past to verify if a work setting is integrated or not, we do not have a
consistent mechanism in place currently. We will need to develop a means to evaluate and measure if
work setting meets the new definition. Organizations such as TASKS Unlimited will probably not meet
the definition with their janitorial sites for example.
Implications of Changes
Describe any implications – to policy, fiscal impact, staffing, etc. – that would result from the changes
Policy will need to be developed around this, staff will need to be trained on consistency and that all
costs extra money from what we are currently doing. When organizations disagree with our
determinations that will involve more time and effort sorting that out.
Conclusion
Is the rule change good or bad? Should we support it? Oppose it? Suggest changes?
Good
Support it
No suggested changes