The vocational rehabilitation services portion of the Unified or Combined State Plan must describe the procedures and activities the State agency will undertake to establish and maintain a comprehensive system of personnel development (CSPD) designed to ensure an adequate supply of qualified rehabilitation personnel, including professionals and paraprofessionals, for the Designated State Unit (DSU). The VR agency provides its CSPD in Description I of the VR portion of the Unified or Combined State Plan. The CSPD involves a complex and very detailed set of requirements, and Description I of the State Plan must address each of these requirements.
The CSPD must include:
- collected and analyzed on an annual basis (34 C.F.R. § 361.18(a));
- The plan for recruitment, preparation, and retention of qualified personnel, including personnel from minority backgrounds and personnel who are individuals with disabilities, in coordination with institutions of higher education and professional organizations (34 C.F.R. 361.18(b));
- Personnel standards to ensure staff are adequately trained, including (1) Standards that are consistent with any national or State-approved or recognized certification, licensing, or registration requirements, or, in the absence of these requirements, other comparable requirements (including State personnel requirements) and (2) The establishment and maintenance of education and experience requirements, to ensure that the personnel have a 21st-century understanding of the evolving labor force and the needs of individuals with disabilities, including requirements for individuals with a bachelor's degree in a field reasonably related to vocational rehabilitation and at least one year of relevant experience and requirements for individuals with a master's or doctoral degree in a field listed in the regulations (34 C.F.R. 361.18(c));
- Staff development plan for professionals and paraprofessionals, addressing specific topics listed in the regulations (34 C.F.R. 361.18(d));
- Qualified staff to address communication needs of individuals with disabilities (34 C.F.R. 361.18(e)); and
- Coordination with personnel development under the Individuals with Disabilities Education Act (34 C.F.R. 361.18(f)).
If the State agency has a State Rehabilitation Council, Description I of the State Plan must, at a minimum, specify that the Council has an opportunity to review and comment on the development of plans, policies, and procedures necessary to meet the requirements in 34 C.F.R. § 361.18(a) through § 361.18(d).
The major change in the CSPD requirements in the 2014 Amendments to the Workforce Innovation and Opportunity Act (WIOA), which are reflected in the regulations published in 2016, involves the personnel standards. These personnel standards reflect the language in Section 101(a)(7)(B) of the Rehabilitation Act, as amended by Title IV of WIOA. The statute and regulations now include minimum education and experience requirements for hiring new staff, thus providing VR agencies with flexibility in hiring qualified personnel. The regulations also eliminate the requirement that all existing staff be retrained to meet the VR agency's established personnel standards.
