Arkansas Administrative Code
Agency 172 - Department of Career Education
Rule 172.00.06-002 - Arkansas Rehabilitation Services Department of Workforce Education - Annual State Plan Update
Current through Register Vol. 49, No. 9, September, 2024
I. ATTACHMENTS REQUIRED OF ALL AGENCIES
Attachment 4.11(b): Comprehensive System of Personnel Development
Policies, Procedures and Activities to Establish and Maintain
A Comprehensive System of Personnel Development
Section 101 (a)(7)
Data on Qualified Personnel Needs and Personnel Development
Arkansas Rehabilitation Services (ARS) maintains a comprehensive data system on personnel and personnel development. Data collected includes the following:
* Number and type of personnel employed in each professional and paraprofessional category:
|
Title |
Total |
Staff/ |
acan |
Male |
emal |
White |
Black O |
the |
isability |
|
ACCOUNTANT |
1 |
1 |
0 |
0 |
1 |
1 |
0 |
0 |
0 |
|
ACCOUNTING SUPERVISOR II |
1 |
1 |
0 |
1 |
0 |
1 |
0 |
0 |
0 |
|
ACCOUNTING TECHNICIAN II |
8 |
8 |
0 |
0 |
8 |
8 |
0 |
0 |
1 |
|
ADMINISTRATIVE ASSISTANT II |
7 |
7 |
0 |
0 |
7 |
4 |
3 |
0 |
0 |
|
AGENCY PROGRAM COORDINATO |
5 |
5 |
0 |
3 |
2 |
3 |
2 |
0 |
1 |
|
APPLICATIONS & SYSTEMS ANALY |
1 |
1 |
0 |
1 |
0 |
1 |
0 |
0 |
0 |
|
ASST PERSONNEL MANAGER |
2 |
2 |
0 |
0 |
2 |
1 |
1 |
0 |
0 |
|
BAKER I |
1 |
1 |
0 |
0 |
1 |
0 |
1 |
0 |
0 |
|
BAKER II |
1 |
1 |
0 |
0 |
1 |
0 |
1 |
0 |
1 |
|
BLDG PLANT MAINTENANCE SUPV |
1 |
1 |
0 |
1 |
0 |
0 |
1 |
0 |
0 |
|
BLDG PLANT MAINTENANCE SUPV |
2 |
2 |
0 |
2 |
0 |
2 |
0 |
0 |
0 |
|
CARPENTER SUPERVISOR |
1 |
1 |
0 |
1 |
0 |
1 |
0 |
0 |
0 |
|
CHAPLAIN |
1 |
1 |
0 |
1 |
0 |
1 |
0 |
0 |
0 |
|
CHIEF PHYSICIAN SPECIALIST |
1 |
1 |
0 |
0 |
1 |
1 |
0 |
0 |
0 |
|
CLERICAL ASSISTANT |
3 |
3 |
0 |
0 |
3 |
3 |
0 |
0 |
0 |
|
COMPLIANCE ADMINISTRATOR |
1 |
1 |
0 |
1 |
0 |
0 |
1 |
0 |
0 |
|
COMPUTER APPLICATION MANAG |
1 |
1 |
0 |
0 |
1 |
0 |
1 |
0 |
0 |
|
COOK I |
2 |
2 |
0 |
1 |
1 |
0 |
2 |
0 |
1 |
|
COOK II |
5 |
4 |
1 |
2 |
2 |
2 |
2 |
0 |
1 |
|
COORDINATOR OF INTERPRETIVE |
1 |
1 |
0 |
0 |
1 |
1 |
0 |
0 |
0 |
|
CUSTODIAL WRKR II |
14 |
14 |
0 |
7 |
7 |
7 |
7 |
0 |
5 |
|
DENTIST |
0 |
0 |
0 |
0 |
0 |
0 |
0 |
0 |
0 |
|
DIETARY SERVICES DIRECTOR |
1 |
1 |
0 |
0 |
1 |
1 |
0 |
0 |
0 |
|
DIRECTOR MAINTENANCE |
1 |
1 |
0 |
1 |
0 |
1 |
0 |
0 |
0 |
|
DIRECTOR OOF PHYSICAL THERA |
1 |
1 |
0 |
1 |
0 |
1 |
0 |
0 |
0 |
|
DP PRODUCTION SCHEDULER |
1 |
1 |
0 |
1 |
0 |
1 |
0 |
0 |
0 |
|
ED COORD VOC PLANNING & EVAL |
1 |
1 |
0 |
0 |
1 |
1 |
0 |
0 |
0 |
|
ELECTRICIAN SUPERVISOR |
1 |
1 |
0 |
1 |
0 |
1 |
0 |
0 |
0 |
|
ELEVATOR OPERATOR |
0 |
0 |
0 |
0 |
0 |
0 |
0 |
0 |
3 |
|
ENGINEER PE |
1 |
1 |
0 |
1 |
0 |
1 |
0 |
0 |
0 |
|
EXECUTIVE SECY/ADM INISTRATIV |
13 |
13 |
0 |
0 |
13 |
6 |
7 |
0 |
0 |
|
EXTRA HELP |
8 |
8 |
0 |
8 |
11 |
11 |
8 |
0 |
0 |
|
FOOD PRODUCTION MANAGER II |
2 |
1 |
1 |
1 |
0 |
1 |
0 |
0 |
0 |
|
FOOD PRODUCTION MANAGER |
1 |
1 |
0 |
0 |
1 |
1 |
0 |
0 |
2 |
|
FOOD SERVICE WORKER II |
6 |
6 |
0 |
3 |
3 |
4 |
2 |
0 |
0 |
|
FOOD SERVICE WORKER III |
3 |
3 |
0 |
1 |
2 |
2 |
1 |
0 |
0 |
|
GENERAL PHYSICIAN |
2 |
2 |
0 |
1 |
1 |
1 |
1 |
0 |
0 |
|
GRANTS COORDINATOR |
1 |
1 |
0 |
0 |
1 |
1 |
0 |
0 |
0 |
|
HEATING & A/C MECHANIC |
2 |
2 |
0 |
2 |
0 |
2 |
0 |
0 |
0 |
|
HOUSEKEEPER |
2 |
2 |
0 |
0 |
2 |
1 |
1 |
0 |
3 |
|
HOUSEKEEPER SUPERVISOR |
5 |
5 |
0 |
1 |
4 |
1 |
4 |
0 |
0 |
|
HOUSEPARENT I |
10 |
10 |
0 |
0 |
10 |
7 |
3 |
0 |
0 |
|
HSRC DIR OF PHYSICAL THERAPY |
1 |
1 |
0 |
1 |
0 |
1 |
0 |
0 |
0 |
|
HSRC MEDICAL SERVICES MANAGE R |
1 |
1 |
0 |
1 |
0 |
1 |
0 |
0 |
0 |
|
INFORMATION SYSTEMS ADMINISTRAT |
1 |
1 |
0 |
0 |
1 |
0 |
1 |
0 |
0 |
|
INTERPRETER II |
5 |
5 |
0 |
0 |
5 |
5 |
0 |
0 |
0 |
|
INVENTORY CONTROL CLERK |
1 |
1 |
0 |
0 |
1 |
1 |
0 |
0 |
0 |
|
INVENTORY CONTROL MANAGER |
2 |
2 |
0 |
0 |
2 |
1 |
1 |
0 |
0 |
|
JOURNEYMAN CARPENTER |
3 |
3 |
0 |
3 |
0 |
3 |
0 |
0 |
0 |
|
JOURNEYMAN ELECTRICIAN |
1 |
1 |
0 |
1 |
0 |
1 |
0 |
0 |
0 |
|
JOURNEYMAN PAINTER |
3 |
3 |
0 |
3 |
0 |
3 |
0 |
0 |
0 |
|
JOURNEYMAN PLUMBER |
2 |
2 |
0 |
2 |
0 |
2 |
0 |
0 |
0 |
|
LAUNDRY SUPERVISOR |
1 |
1 |
0 |
0 |
1 |
0 |
1 |
0 |
0 |
|
LAUNDRY WORKER |
1 |
1 |
0 |
1 |
0 |
0 |
1 |
0 |
1 |
|
LEAD PROGRAMMER/ANALYST |
1 |
1 |
0 |
0 |
1 |
1 |
0 |
0 |
0 |
|
LPN II/LPTN II |
7 |
7 |
0 |
0 |
7 |
6 |
1 |
0 |
2 |
|
MANAGEMENT PROJECT ANALYST I |
1 |
1 |
0 |
0 |
1 |
1 |
0 |
0 |
0 |
|
MANAGEMENT PROJECT ANALYST II |
5 |
5 |
0 |
0 |
5 |
5 |
0 |
0 |
0 |
|
MEAT CUTTER II/BUTCHER II |
1 |
0 |
1 |
0 |
0 |
0 |
0 |
0 |
0 |
|
MEDICAL OR LEGAL SECRETARY |
4 |
4 |
0 |
0 |
4 |
4 |
0 |
0 |
0 |
|
MEDICAL RECORDS ADMINISTRAT OR |
1 |
1 |
0 |
0 |
1 |
1 |
0 |
0 |
0 |
|
MEDICAL TECHNOLOGIST |
1 |
1 |
0 |
0 |
1 |
1 |
0 |
0 |
0 |
|
MEDICAL TRANSCRIPTIONIST |
1 |
1 |
0 |
0 |
1 |
1 |
0 |
0 |
0 |
|
MICRO-PHOTOGRAPHER I |
1 |
1 |
0 |
0 |
1 |
1 |
0 |
0 |
0 |
|
MOTOR VEHICLE OPERATOR |
4 |
4 |
0 |
4 |
0 |
1 |
3 |
0 |
1 |
|
NURSE II |
10 |
10 |
0 |
0 |
10 |
10 |
0 |
0 |
0 |
|
NURSE SUPERVISOR |
2 |
2 |
0 |
0 |
2 |
2 |
0 |
0 |
0 |
|
NURSING ASST II |
15 |
15 |
0 |
4 |
11 |
12 |
3 |
0 |
2 |
|
NURSING SERVICES UNIT MANAGER |
1 |
1 |
0 |
0 |
1 |
1 |
0 |
0 |
0 |
|
OCCUPATIONAL THERAPIST II |
4 |
3 |
1 |
0 |
3 |
2 |
1 |
0 |
0 |
|
OCCUPATIONAL THERAPY SUPERVISO |
1 |
1 |
0 |
0 |
1 |
1 |
0 |
0 |
0 |
|
OCCUPATIONAL THERAPY WORKER |
2 |
2 |
0 |
0 |
2 |
2 |
0 |
0 |
0 |
|
OFFICE CLERK |
1 |
1 |
0 |
0 |
1 |
0 |
1 |
0 |
0 |
|
ORTHOTIST AIDE |
2 |
2 |
0 |
0 |
2 |
2 |
0 |
0 |
0 |
|
PAYROLL SERVICES SPECIALIST |
1 |
1 |
0 |
0 |
1 |
1 |
0 |
0 |
0 |
|
PHARMACIST II |
1 |
1 |
0 |
1 |
0 |
1 |
0 |
0 |
0 |
|
PHYSICAL THERAPIST ASSISTANT |
1 |
1 |
0 |
0 |
1 |
1 |
0 |
0 |
0 |
|
PHYSICAL THERAPIST II/PHYSICAL TH |
4 |
3 |
1 |
1 |
2 |
3 |
0 |
0 |
0 |
|
PHYSICIAN SPECIALIST |
8 |
7 |
1 |
4 |
3 |
7 |
0 |
0 |
0 |
|
PROGRAM SUPPORT MANAGER |
7 |
7 |
0 |
4 |
3 |
3 |
4 |
0 |
0 |
|
REHAB FIELD SUPERVISOR |
9 |
6 |
3 |
5 |
1 |
5 |
1 |
0 |
0 |
|
REHAB PROG PLNG & DEVELOP MANAGER |
2 |
2 |
0 |
2 |
0 |
1 |
1 |
0 |
0 |
|
REHAB PROGRAM ADMINISTRATOR |
6 |
5 |
1 |
3 |
2 |
2 |
3 |
0 |
0 |
|
REHAB SERVICES PERSONNEL MANAGER |
1 |
1 |
0 |
1 |
0 |
0 |
1 |
0 |
0 |
|
REHAB SPECIAL PROGRAM ADMINISTRATOR |
4 |
4 |
0 |
2 |
2 |
4 |
0 |
0 |
0 |
|
REHAB SVC FACILITY SPECIALIST |
2 |
2 |
0 |
1 |
1 |
2 |
0 |
0 |
0 |
|
REHAB VOCATIONAL CONSULTANT |
1 |
1 |
0 |
0 |
1 |
1 |
0 |
0 |
0 |
|
SECRETARY I |
2 |
2 |
0 |
0 |
2 |
1 |
1 |
0 |
0 |
|
SECRETARY II |
50 |
50 |
0 |
0 |
50 |
36 |
11 |
0 |
8 |
|
SECURITY OFFICER II |
3 |
3 |
0 |
3 |
0 |
2 |
1 |
0 |
0 |
|
SECURITY OFFICER III |
1 |
1 |
0 |
1 |
0 |
1 |
0 |
0 |
0 |
|
SOCIAL SERVICE AIDE II |
1 |
1 |
0 |
0 |
1 |
0 |
1 |
0 |
0 |
|
SOCIAL SERVICE WORKER II/SOC SVC WK |
1 |
1 |
0 |
0 |
1 |
1 |
0 |
0 |
0 |
|
SOCIAL WORKER II |
1 |
0 |
1 |
0 |
0 |
0 |
0 |
0 |
0 |
|
SPEECH PATHOLOGIST II |
2 |
2 |
0 |
0 |
2 |
2 |
0 |
0 |
0 |
|
SR PRGRAMMER/ ANALYST |
1 |
1 |
0 |
1 |
0 |
0 |
1 |
0 |
0 |
|
SR REHABILITATION COUNSELOR |
29 |
27 |
3 |
18 |
9 |
21 |
6 |
0 |
0 |
|
STAFF DEVELOPMENT COORDINATOR |
1 |
2 |
0 |
1 |
1 |
2 |
0 |
0 |
1 |
|
STATIONARY ENGINEER |
4 |
4 |
0 |
4 |
0 |
3 |
1 |
0 |
0 |
|
STOREROOM SUPV/STORE SUPV |
3 |
3 |
0 |
2 |
1 |
2 |
1 |
0 |
1 |
|
SUPERVISOR OF COOKING |
1 |
1 |
0 |
0 |
1 |
0 |
1 |
0 |
0 |
|
SWITCHBOARD OPERATOR II |
4 |
4 |
0 |
0 |
4 |
4 |
0 |
0 |
1 |
|
SYSTEMS APPLICATIONS SUPERVISOR |
1 |
0 |
1 |
1 |
0 |
1 |
0 |
0 |
0 |
|
SYSTEMS COORDINATION ANALYST I |
1 |
0 |
1 |
0 |
0 |
0 |
0 |
0 |
0 |
|
SYSTEMS COORDINGATION ANLAYST II |
1 |
1 |
0 |
1 |
0 |
0 |
1 |
0 |
0 |
|
VOCATIONAL INSTRUCTOR I |
4 |
4 |
0 |
1 |
3 |
1 |
3 |
0 |
0 |
|
VOCATIONAL INSTRUCTOR II |
4 |
4 |
0 |
2 |
2 |
2 |
2 |
0 |
0 |
|
VOCATIONAL INSTRUCTOR III |
17 |
17 |
0 |
7 |
10 |
14 |
3 |
0 |
2 |
|
VOCATIONAL REHAB EVALUATOR II |
4 |
4 |
0 |
2 |
2 |
3 |
1 |
0 |
1 |
|
VOLUNTEER PROGRAM DEVELOPER II |
1 |
1 |
0 |
0 |
1 |
1 |
0 |
0 |
1 |
|
WELDER |
1 |
1 |
0 |
1 |
0 |
0 |
1 |
0 |
0 |
|
X-RAY TECH SUPV/X-RAY TECH II |
1 |
1 |
0 |
1 |
0 |
1 |
0 |
0 |
0 |
|
TOTALS |
543 |
499 |
44 |
189 |
310 |
315 |
128 |
6 |
50 |
- Existing vacancies are presently at 44. Many vacant positions are not used or ARS is working with OPM to change the classifications or delete the positions because they are no longer relevant to the agency.
- The average yearly ARS turnover rate is 17%.
- Projected yearly separations (including turnover) within ARS is 16%
* Projected client numbers to be served and optimum client/counselor ratio:
86 counselors will serve a target of 21,000 clients. The optimum client/counselor ratio is 244 clients per counselor on average.
* Projected staff requirements for the coming five years:
|
23 Years or More of Service |
Number |
Percent |
|
Management |
44 |
59% |
|
Direct Service Delivery |
22 |
9% |
|
Medical/Allied Health |
5 |
4% |
|
Central Support |
12 |
6% |
|
Direct Service Delivery Support |
24 |
13% |
|
Other Support* |
7 |
3% |
|
TOTALS |
114 |
22% |
*Includes: Housekeeping, Food Service, Elevator Operators, Laundry, Custodial, Maintenance, Drivers, Security.
|
Years of Service |
Number of Staff |
|
OVER 28 |
67 |
|
28 |
10 |
|
27 |
13 |
|
26 |
9 |
|
25 |
11 |
|
24 |
3 |
|
TOTAL |
113 |
Projected ARS staff requirements for the next five years are approximately 22% a year (turnover, retirements and separations). Management and direct service delivery (professional and support) continues to be the main needs within the agency. ARS has received upgrades for support staff upgrades and continues to use the Career Ladder
ARKANSAS REHABILITATION SERVICES
Update of the State Plan
Fiscal Year 2007
Incentive Program to help meet future needs. ARS continues to recruit VR counselors based on the Market Labor Rates for the Vocational Rehabilitation Counselor Series.
As part of the maintenance of offering a program of development, ARS maintains a list of higher education institutions in the state, which prepare rehabilitation professionals. This listing is maintained by type of program and by category of professional development. ARS also monitors students who enroll in rehabilitation and related programs at each of the institutions and programs by category and the number of students who graduated during the prior year, with and without certification or licensure. The Staff Development sections at ARS and DSB have collaborated to develop and disseminate a formal survey of the higher education institutions to assure timely and accurate data for planning proposes. The following is a sample of the yearly survey:
The minimum qualifications for the Counselor III and II are bachelor's degrees in psychology, sociology, or related field with three, two, years of experience, respectively.
The Rehabilitation Counselor III is functionally the entry-level counselor position. Because of the state's salary structure, ARS have had a difficult time recruiting at the lower levels. Hires are being made at the Counselor II level. The Counselor I positions are being used for intern positions. ARS during the last year has been able to raise the counselors' series salary level through Market Labor Rates Standards.
ARS PLAN OUTLINE
Arkansas Rehabilitation Services has implemented the following plan to address the requirements of the CSPD. The initial phase of the plan has focused on rehabilitation counselors. Later phases will address the other VR professionals identified in Section 101(a)(7).
* STANDARD
Because there is no standard established by the State of Arkansas, ARS bases its personnel standards for counselors on the degree needed to meet the national CRC requirements. CRC requires a Master's degree in rehabilitation counseling or a closely related field, as defined by the CRC.
Action(s) taken:
Effective October 1, 2007 ARS will hire vocational rehabilitation counselors only in the position classified as Rehabilitation Counselor III. Vocational rehabilitation counselors must be classified as Rehabilitation Counselor III and meet other qualifications in order to become a Senior Counselor. Effective September 30, 2007 all ARS employees in the classification of Rehabilitation Counselor III or Senior Counselor should meet the standard of having a master's degree and either be CRC certified, or eligible to sit for CRC certification. After September 30, 2007 all ARS employees in the position classified as Rehabilitation Counselor III or Senior Counselor, who do not meet the standard of having a master's degree and either CRC certification, or eligibility to sit for CRC certification, will be cross-graded in classification to the position of Rehabilitation Counselor II. The counselors who do not meet CSPD requirement and are cross graded in classification to the position of Rehabilitation Counselor II will be required to have prior approval on cases where paid for services are planned on their IPE. The District Manager or their designee will provide prior approval.
Action(s) needed:
Formally adopt and communicate the master's degree standard in ARS. The state Office of Personnel Management (OPM) is aware of our efforts to do this. We are preparing to go before the upcoming legislative session to get counselor positions minimum qualification changed. OPM currently does not recognize ARS master's degree level standards in the minimum qualification in the vocational rehabilitation counselors' series.
* NEW STAFF
All personnel hired by ARS in any position classified as a Rehabilitation Counselor III or Senior Counselor will meet the standard of a master's degree and/or be CRC certified. When there is not an applicant with the master's degree, ARS will permit the hiring of a bachelors degreed counselor in a Counselor II position with a condition of employment that the person will seek and obtain a masters degree within three years of employment.
Action(s) taken:
ARS is currently working with the Office of Personnel Management (OPM) on getting them to realign the state class specifications with the state qualification and implementation criteria to read that the minimum education qualification is a Master's Degree rehabilitation counseling for Senior and III Rehabilitation Counselor positions. We are currently working with OPM to make this necessary change. We now advertise for a Counselor II position with the preferred qualification being a Master's Degree in Rehabilitation Counseling and CRC certified.
A request has been made to the Office of Personnel Management (OPM) to change the minimum education qualification for Rehabilitation Counselor III positions to a Master's Degree in rehabilitation counseling two years of experience. We also requested Senior Rehabilitation Counselor positions be changed to a Master's Degree in rehabilitation counseling, three years of experience, and a CRC Certification. OPM is seriously considering these changes. ARS will have to modify classification and job duties to reflect changes that are different from other titles that are similar within other state agencies.
Action(s) taken:
ARS has devised and implemented recruiting strategies to identify potential applicants for vacancies.
* EXISTING STAFF:
ARS currently has 60 out of 86 counselors that meet the national CRC standard. (We presently have 15 unfilled counselor positions.) The priority of training and development within CSPD continues to be emphasized for direct service delivery personnel in ARS. ARS presently has 13 counselors involved in distant learning graduate training programs in order to become eligible to sit for CRC exam. ARS has 13 counselors that are not eligible to sit for CRC or involved in a CSPD program. Of these, 3 is a counselor who has between 16-25 years of career service and 10 are counselors with 25 or more years of service and are eligible to retire. Preference on training is given to the higher priority during the current fiscal year based on availability of training funds.
Priority 1: Counselors with related bachelor's degrees that have completed graduate hours in a rehabilitation-counseling program and/or are currently enrolled or accepted into a program. (10 counselors)
Priority 2. Counselors who have between 16-25 years of career service with the state and are not eligible to sit for CRC or involved in a learning program. (3 counselors)
Priority 3: Counselors who have 25 or more years of career service with the state and are not eligible to sit for CRC or involved in a learning program. (10 counselors)
In all priority categories, counselors who receive educational assistance would be expected to comply with the provisions of the ARS Educational Leave Policy and agree to continue working with the agency for two years for every 9 credit hours completed.
Action(s) taken:
Determined availability of ARS resources to fund training. The Federal In-Service Training Grant FY 2006-2010 has increased tuition and textbook expenditures.
Identified alternative methods of funding for education. We presently have three VR Counselors involved in distance-learning coursework at the University of North Texas, at no cost of tuition to the agency. Other VR counselors who do not meet the requirements of CSPD are encouraged to enter the program at the University of North Texas.
Identified methods and opportunities for training (e.g., traditional classroom, distance learning, etc.). Ten counselors are enrolled at the University of Arkansas at Little Rock. There are two individuals enrolled in the graduate distance-learning program at the University of North Texas. ARS has one counselor enrolled in the masters in rehabilitation program at the University of Arkansas at Fayetteville.
* RECRUITING:
When recruiting for Rehabilitation Counselor vacancies, ARS vacancy announcements state that MRC and CRC are preferred. Applicants who have the preferred qualifications are referred for interview. If a selection cannot be made from those candidates, a candidate with the State minimum qualification may be hired, subject to the condition that the master's degree will be obtained within a specified time.
The Rehabilitation Counselor III is functionally the entry-level counselor position. Because of the state's salary structure, ARS have had a difficult time recruiting at the lower classification levels. ARS is now hiring Counselor II level, with promotion opportunities being made available once the individual meeting the standards for the Counselor III level.
Action(s) taken:
Requested change from OPM to require master's degree in Rehabilitation Counseling for the Rehabilitation Counselor III positions with two years of experience needed. This is still pending.
OPM has approved ARS request to use Extra Help positions for Rehabilitation Counselor Interns, allowing ARS to initiate a paid internship program. The minimum qualifications for the Intern are the same as a Counselor I position - bachelor's level. This program continues to be an effective tool for recruiting new counselors.
Action(s) needed:
A Human Resource Development component of the CSPD team reviews and oversees the current training levels of all personnel in each category. Required standards and evaluation of training needs and timelines are established. The HRD component develops and monitors agency policy and procedure in terms of hiring, training, or retraining personnel to meet standards. This function includes notifying public agencies and all personnel of those steps and timelines.
Personnel Training, Including Staff Development
ARS ensures that all personnel receive appropriate and adequate continuing education. The agency provides for employees to attend classes, seminars, and conferences, and disseminates information through newsletters, in-service training, workshops, etc.
Several innovative efforts are currently in progress in the area of training and staff development.
* Distance Learning - Technology equipment is in place and is being used to present an ongoing series of conferences and courses to virtually all employees through the use of local downlinks and the Internet. The agency has also developed an Intranet system for training all ARS staff called the Able Training System.
* HRD continues to use a series of institutes and training programs that have included every ARS employee.
* Online training is being conducted to address agency needs. These brief training programs include topics that ARS has identified as important to ARS operational effectiveness.
* Performance Evaluation and Training Needs - Each Employee Performance Evaluation addresses training needs. These needs receive priority for funding. In those cases where sufficient common training needs are identified, the agency develops and provides this training to groups.
* Cooperative Relationships - The agency continues to have close relationships with the Arkansas Rehabilitation Continuing Education Center through the University of Arkansas. ARS staff serves on advisory boards and steering committees for those organizations, and are able to influence the type of research, training, development, and consultation provided by these organizations to meet ARS needs.
* Technology Training - The agency offers ongoing training programs for professional and paraprofessional personnel in the area of technology. The ARTEC Lab is being used for ongoing training of staff in the areas of software application training, internet training for Job Placement, ARMIS training for the agency's client training system, etc.
* Workforce Investment Act of 1998 and Rehabilitation Act Amendments of 1998 -The Agency has conducted extensive training on Workforce Investment Act of 1998 and Rehabilitation Act Amendments of 1998, and key components of the Acts are incorporated into new employee orientation and training. Collaboration and cooperation with our partnering state agencies are continuing. The agency is being kept updated with the latest development of the Workforce Investment Act that is before Congress at this writing. ARS continues to provide input into the reauthorization of the Rehab Act and the Workforce Investment Act.
Special Communication Needs Personnel Training
ARS will continue to employee personnel who are able to communicate in the native languages of applicants for service and clients who have limited English speaking ability. ARS also provides special communication modes such as interpreters, captioned videos, specialized telecommunications services and material for individuals who are deaf and deaf-blind as well as other specialized media systems for individuals with disabilities. Whenever possible, people with needed language skills are hired, special equipment is provided as needed. Interpreters are provided in training settings when needed. Sign language skills are included as a minimum qualification for positions providing services to deaf persons. When needed, special entry rates are offered to persons who possess needed special language or communication skills. ARS also is providing training opportunities in Spanish. Arkansas is experiencing a large influx of Spanish speaking citizens into the state and these citizens are now requesting our services. The agency is providing assistance to our employees in order to help them accommodate these needs.
Performance Evaluation System
ARS continues the process of continuously examining and modifying its personnel evaluation system, particularly with rehabilitation counselors, to emphasize serving persons with the most severe disabilities. Performance evaluation focuses on accomplishing the purposes of the Act and Federal Regulations. The Evaluation in no way impeded the accomplishment of the purpose and policy of the Act. The agency's Personnel Performance Evaluation System was just recently updated and approved by OPM. All Managers/Supervisors have been provided training on those approved updates.
Coordination with Personnel Development under IDEA
ARS coordinates its comprehensive system of personnel development with personnel development under IDEA. ARS provides training opportunities for our direct service support personnel in the areas of transition. Key VR counselors are involved with state transition coordinators that are provided by Special Education within the state. ARS VR counselors are involved in annual transition coordination meetings. Information on IDEA is forwarded to all ARS employees including the latest IDEA reauthorization updates. ARS is aware that the latest IDEA legislation has been passed and ARS is providing training for key personnel within the agency who will be dealing with the schools and transition. ARS is presently looking at restructuring the field program in order to effectively utilize personnel that will be doing transition. ARS is fully committed to providing transition services through our agency with collaboration and cooperation with the public schools.
Attachment 4.12 Assessments; Estimates; Goals and Priorities; Strategies; and Progress Reports
Attachment 4.12(a) Results of Comprehensive Statewide Assessment of the Rehabilitation Needs of Individuals with Disabilities
A Statewide Comprehensive Needs Assessment was planned and conducted jointly with representatives of the State Rehabilitation Council (SRC), the State Independent Living Council (SILC), and a contractor known as Dan Hopkins & Associates, hereafter referred to as DHA. The final report was presented to the full Council for their review and approval on March 15, 2006. The Agency will continue to work with the Council to address the recommendations from the assessment and will also work cooperatively for the next assessment due in 2009.
Results
The DHA study utilized a mixed-method research design to collect information from a variety of sources including, the consumers, their family members, consumer advocates, service providers, and from secondary data sources. The study methodology assured attention to the rehabilitation needs of individuals with disabilities residing within the state; particularly the vocational rehabilitation services needs of:
The Summary of Findings and Recommendations noted six particular areas that the Agency, in collaboration with the SRC, will address as objectives for future action Attachment 4.12 (c) (1):
I. Job Development/Placement/Employment Outcomes
II. Independent Living Centers
III. Systems Issues and Concerns
IV. Education and Training
V. Public Relations/Information and Outreach
VI. Transition Services
4.12(b) Annual Estimates of Individuals to be Served and Costs of Services
Estimates Of The Number Of Individuals In The State To Be Served Under Part B, Sec. 110 Of Title I - FY 2007
The U.S. Census Bureau indicates 230,031 individuals with an employment disability in Arkansas ages 16-64. (Source U.S. Census Bureau, Census 2000 Summary File 3.)
|
Eligible individuals who are most significantly disabled. |
COST |
|
|
Priority Category I: |
||
|
Number to be Served - 2,881 |
Number to be |
|
|
Rehabilitated - 381 |
$ 1,884,327.00 |
|
|
Priority Category II: |
Eligible individuals who are significantly disabled. |
|
|
Number to be Served - 17,203 |
Number to be Rehabilitated - 2,019 |
$ 11,950,673.00 |
|
TOTAL TO BE SERVED |
TOTAL TO BE REHABILITATED |
TOTAL COST |
|
20,084 |
2,400 $13,835,000.00 |
|
4.12(c)(3) Goals and Plans for Distribution of Title VI, Part B Funds
Estimates Of The Number Of Individuals In The State To Be Served Under Part B Of Title VI -FY 2007
|
Type of individual to be served |
Number Served |
Rehabilitated |
Supported Employment Model |
|
Mental Illness |
19 |
2 |
Job Coach/Mobile Crew Transition Employment |
|
Mild Mental Retardation |
132 |
25 |
Job Coach/Mobile Crew |
|
Traumatic Head Injury |
6 |
0 |
Job Coach/Mobile Crew |
|
Other |
142 |
27 |
Job Coach/Mobile Crew |
|
TOTAL |
299 |
54 |
Performance-Based Evaluation
While Rehabilitation Services Administration (RSA) performance-based evaluation focuses on a State agency as the unit of analysis, the National Performance Plan and the standards and indicators outlined by RSA are quite useful to State agencies in monitoring the functioning of their offices within the State.
The Arkansas Rehabilitation Services performance on the Standards and Indicators for FY 2005 follows.
The Performance On The Standards And Indicators Established Pursuant To Section 106
ARS Performance Standards and Performance Levels
FY 2005
Standard 1: Employment Outcomes
|
Performance Indicator 1.1 |
The number of individuals exiting the VR program who achieved an employment outcome during the current performance period compared to the number of individuals who exit the VR program after achieving an employment outcome during the previous performance period. [Performance level: DSU's performance in current period must equal or exceed performance in previous period.] |
The data indicates that the number of individuals in Arkansas who achieved an employment outcome slightly decreased during FY 2005 the last year that data is available - from 2,440 in FY 2004 to 2,353 in FY 2005.
|
Performance Indicator 1.2 |
Of all individuals who exit the VR program after receiving services, the percentage who are determined to have achieved an employment outcome. [Performance level: For the general and combined DSUs, the level is 55.8%.] |
The data indicates that 61.0% of the individuals in Arkansas who exited the VR program after receiving services achieved an employment outcome.
|
Performance Indicator 1.3 |
Of all individuals determined to have achieved an employment outcome, the percentage who exit the VR program in competitive, self-, or business enterprise program (BEP) employment with earnings equivalent to at least the minimum wage. [Performance level: For the general and combined DSUs, the level is 72.6%.] |
The data indicates that the percentage of individuals determined to have achieved an employment outcome, who exited the VR program in competitive, self-, or BEP employment with earnings equivalent to at least the minimum wage was 99.62% in Arkansas which exceeds the federal benchmark of 72.6%.
|
Performance Indicator 1.4 |
Of all individuals who exit the VR program in competitive, self-, or BEP employment with earnings equivalent to at least the minimum wage, the percentage who are individuals with significant disabilities. [Performance level: For the general and combined DSUs, the level is 62.4%.] |
The data indicates that of all individuals who exited the VR program in competitive, self-, or BEP employment with earnings equivalent to at least the minimum wage, the percentage who were individuals with significant disabilities in Arkansas was 89.8% which exceeds the federal benchmark of 62.4%.
|
Performance Indicator 1.5 |
The average hourly earnings of all individuals who exit the VR program in competitive, self-, or BEP employment with earnings equivalent to at least the minimum wage as a ratio to the State's average hourly earnings for all individuals in the State who are employed (as derived from the Bureau of Labor Statistics report "State Average Annual Pay" for the most recent available year). [Performance level: For the general and combined DSUs, the level is a ratio of 0.52] |
The data indicates that preliminary results for Performance Indicator 1.5 in Arkansas, the ratio was 0.64, which exceeds the federal benchmark of 0.52.
|
Performance Indicator 1.6 |
Of all individuals who exit the VR program in competitive, self-, or BEP employment with earnings equivalent to at least the minimum wage, the difference between the percentage who report their own income as the largest single source of economic support at the time they exit the VR program and the percentage who report their own income as the largest single source of support at the time they apply for VR services. [Performance level: For the general and combined DSUs, the level is an arithmetic difference of 53.0] |
The data indicates that in Performance Indicator 1.6, the mathematical difference between the percentage who reported their own income as the largest single source of economic support at exit and the percentage who reported their own income as the largest single source of economic support at application was 78.63 in Arkansas which exceeds the federal benchmark of 53.0.
Standard 2: Equal Access to Services
|
Performance Indicator 2.1 |
The service rate for all individuals with disabilities from minority backgrounds as a ratio to the service rate for all individuals with disabilities from non-minority backgrounds. [Performance level: All agencies must attain a ratio level of 0.80.] |
The data indicates that in Performance Indicator 2.1, the service rate for all individuals with disabilities from minority backgrounds, as a ratio to the service rate for all non-minority individuals with disabilities was 0.87 in Arkansas, which exceeds the federal benchmark of 0.80.
Attachment 4.12(c)(1) - Goals and Priorities
The agency has established goals and priorities based on the RSA Standards and Performance Indicators and also the recommendations of the State Wide Needs Assessment. The goals are:
Attachment 4.12(d) - Strategies
Goal 1: Strategy
* Agency will continue to work collaboratively with referral sources to increase referrals and consumer advocates to increase the number of potential recipients of services throughout FY 07.
* Agency will provide in service training and mentoring throughout FY07 to increase utilization of presumptive eligibility and serving individuals within the Order of Selection.
* Considering the decrease in employment outcomes in FY 2005 and the anticipated level number in FY 2006, ARS will make a concentrated effort -through increased referrals, enhanced job development and placement services,
and most importantly, recruitment of qualified rehabilitation counselors to fill vacancies - to meet or exceed performance in employment outcomes in FY 2007.
* Agency will increase performance in Supported Employment as reflected in the table on page 16 entitled 4.12(c)(3) Goals and Plans for Distribution of Title VI, Part B Funds, Estimates Of The Number Of Individuals In The State To Be Served, Under Part B Of Title VI -FY 2007.
Goal 2: Strategy
* As follow up to the Needs Assessment the Agency will collaborate with the SRC to convene a placement Task Force by October 31, 2006, that will evaluate current practices, and provide recommendations for enhancing job development/placement services for customers.
Goal 3: Strategy
* Agency will establish a public relations and outreach work group by October 31, 2006, to evaluate current practices, assess agency needs, and provide recommendations to increase public awareness of rehabilitation programs.
Goal 4: Strategy
* Agency will continue providing Comprehensive System of Personnel Development training opportunities and support throughout FY07 to assure development of qualified staff and seamless succession.
Goal 5: Strategy
* Agency will implement an updated policy manual beginning October 1, 2006 to meet RSA 107 recommendations.
* Agency will implement on October 1, 2006, a revised version of the Arkansas Rehabilitation Integrated Management Information System (ARIMIS) that will include the Standard of Occupational codes, and edits that enhance the reporting requirements.
Goal 6: Strategy
* Agency will implement strategies to strengthen collaboration with Independent Living Centers.
Goal 7: Strategy
* The agency will continue participation throughout FY 07 in the state Transition Task Force to assure collaboration and increase referrals.
* Field services will increase by .05 % the number of counselors available in FY 07 to serve transition cases.
Goal 8: Strategy
* Field Services will continue the Successful Employment through Assistive Technology (S.E.A.T.) program throughout FY 07 to increase the assessments and application of technology equipment and devices for consumers.
* Agency will continue collaboration and referrals to the Increasing Capabilities Access Network (ICAN) to increase awareness and utility of assistive technology.
4.12(e) Evaluation and Reports of Progress
Innovative Approaches To Expand And Improve The Provision Of Vocational Rehabilitation Services
Arkansas Rehabilitation Services (ARS) is the program within the state of Arkansas (along with the DHHS-Division of Services for the Blind) that provides vocational rehabilitation services to assist individuals with significant disabilities in becoming employed and living independently. The state Vocational Rehabilitation programs are funded through the Vocational Rehabilitation Act (Title IV of the Workforce Investment Act of 1998) and have been provided through federal and state matching funds since 1973.
As a result of statewide studies and program evaluation, ARS has implemented the following changes:
* The ARS Policy & Procedure Manual (PPM) is being updated to reflect current policy and is in the promulgation process. The latest revision and promulgation of the PPM was effective October 10, 2002. The PPM draft document was completed by a group of administrators, supervisors, counselors, and rehabilitation assistants from all components of the agency. The State Rehabilitation Council of Arkansas was actively involved as well as the Client Assistance Project. Policy was revised to be in compliance with Federal regulations and improve and expand services to individuals with the most significant disabilities. A permanent Policy and Procedures committee was formed to evaluate policy and procedures on an ongoing basis to assure compliance with state and federal regulations and improve and expand services.
* The agency policy for reimbursing expenditures to Community Rehabilitation Programs is a performance-based system. The system award points to CRP's according to client progress toward employment. As a result of continued emphasis on employment, the performance-based funding system has been revised to place greater rewards on competitive employment outcome and reduce rewards for other steps in the process.
* ARS updated its Arkansas Standards for Community Rehabilitation Program Certification. This resulted in reduced consumer processing type activities and encourages timely transition to competitive employment in integrated settings consistent with the consumers' informed choice.
* The ARS client tracking system, Arkansas Rehabilitation Integrated Management Information System (ARIMIS), was brought on line and in operation since April 2002. The ARIMIS system is internal to ARS and allows tracking for reporting purposes, review of case status history for counselors and administrators, and eventually purchasing and budgeting with case service funds. In addition, ARS has linked with the State information system, Arkansas Administrative Statewide Information System (AASIS). The next phase of ARIMIS has been implemented. This phase includes edits to reduce errors and requirements for data entry with dropdown menus and limited options.
* Arkansas Administrative Statewide Information System (AASIS). This is an external system now required for all state agencies in Arkansas, and includes all purchasing and human resource functions linked into a statewide system. The second phase of the system, which enhances aspects of the system, is being prepared for implementation.
* The Arkansas State Rehabilitation Council of (SRC) has been integrally involved in all aspects of the agency's operations, including planning, personnel policies, and program evaluation studies. The objective of the SRC involvement is to improve and expand services. The SRC has assigned specific members to be involved with the various aspects of the agency. The responsible persons from the SRC coordinate and report to the full SRC at regular meetings.
* A revision of ARS Comprehensive System of Personnel Development as required by Section 101(a)(7) Rehabilitation Act Amendments of 1998 has been approved by RSA and implemented by the agency. Enhancing the professional skills of the staff is also a pathway to expand and improve services.
* One of the primary vehicles for expanding services to individuals with the most severe disabilities continues to be the Agency's order of selection, staff training on severe disability, comprehensive outreach strategies, and special programs to serve groups that have been traditionally unserved or underserved. The Order of Selection places persons with the most significant disabilities as the highest priority for receiving services. Coupling this with performance evaluation criteria has resulted in increased outreach at the local level to identify and provide services to people with the most severe disabilities.
* Policy implementation regarding presumptive eligibility and service delivery for Social Security beneficiaries also tends to expand services individuals with the most severe disabilities. Additional staff and resources have been devoted to the Ticket to Work program that have dramatically increased Ticket assignment to ARS. This will enhance and expand services to individuals with the most significant disabilities in Arkansas.
* Staff will continue to receive special in-service training on issues related to individuals with the most severe disabilities, including technology needs. Emphasis is placed on serving persons with the most severe disabilities at statewide staff meetings, newsletters, and intra-agency correspondence.
* Close working relationships with organizations providing education and vocational preparation will continue. ARS staff will continue to serve on advisory boards for local and state school-to-work programs, and one-stop services programs. In this capacity, they will conduct outreach to persons with the most severe disabilities. Close contact with the network of Centers for Independent Living throughout the state is maintained as an outreach effort.
* Expanded and improved services have resulted from an additional emphasis placed on the Transition of students with disabilities from school to work or post-secondary activities. ARS is involved on the state level in the Arkansas Interagency Transition Partnership (AITP). The AITP is a taskforce made-up of representatives of state agencies including ARS, DHHS-Division of Services for the Blind, Arkansas Department of Higher Education, Special Education-Transition, the Arkansas Workforce Investment Board, DHHS-Division of Mental Health, and parent advocates. The mission of AITP is that it will, through coordination and collaboration, identify critical issues to improve lifelong outcomes for youth and young adults with disabilities. The activities will include evaluation of transition processes and systems, addressing unmet needs, articulating and proposing data-driven system improvement, removing barriers and establishing problem solving local teams.
* On the local level, an initiative on Transition involves ongoing collaboration with ARS, the DHHS-Division of Services for the Blind and the Arkansas Department of Education, Special Education-Transition to improve and expand services throughout the state. A cooperative agreement is in place that outlines collaboration and cooperation between ARS, Services for the Blind and Special Education-Transition. A statewide Transition Summit for educators and rehabilitation professionals was held on April 4-5, 2006 that was co-sponsored by ARS and attended by 35 ARS staff. The outcomes of the Summit included ongoing work-groups based locally to improve and increase Transition Services and work-based experiences at the local community level.
III. ATTACHMENTS CONTINGENT ON OPTIONS SELECTED
Attachment 4.2(c) Summary of Input and Recommendations of the State
Rehabilitation Council; Response of the Designated State Unit; and Explanations for Rejection of Input or Recommendations
Summary of Activities with State Rehabilitation Council of Arkansas
The State Rehabilitation Council (the Council) works in partnership with Arkansas Rehabilitation Services (ARS) according to the requirements of the Workforce Investment Act of 1998. Members are appointed by the Governor and charged with providing review, guidance, and technical assistance in agency activities as outlined in 34 CFR 361.17 of the Act.
During FY 05 the Council held three (3) of their regular quarterly
meetings, and the fourth was cancelled due to inclement weather. Several
members also participated in several special events sponsored by ARS. Minutes
of all meetings are available upon request and may also be reviewed at the ARS
web site:
Consultation and collaboration with ARS by the Council is conducted mostly through standing committees. The list of committees, responsibilities, and 2005 accomplishments are described elsewhere in this report. We are pleased to provide a summary of the significant accomplishments of the council for 2005. We would like to acknowledge the support of designated ARS personnel, Barbara Starks and Barbara Nolen. We also appreciate the hard work of the ARS Communications staff in development of this report.
Activities
Federal and State Audit Review: The council reviewed the RSA audit findings and recommendations and provided input on ARS action plans. The council reviewed and provided input on the Arkansas Legislative Audit report.
Policy and Procedures: ARS Senior Management staff provided reports and solicited input in regard to policy changes and updates for the policy and procedures manual and for the Hot Springs Rehabilitation Center.
Hot Springs Rehabilitation Center: HSRC personnel provided reports on reorganization of training programs, implementation, behavior management program, and capital improvement projects for maintenance and operation.
Agency Updates: Former ARS Commissioner Wyvill and current Commissioner Treviño along with other ARS staff provided progress reports and updates on:
* Legislative updates on federal and state initiatives.
* Review of initial reports of Statewide Needs Assessment
* Progress reports on action plans for legislative audit.
* Development and implementation of counselor qualifications and salary levels.
* Reauthorization of Rehabilitation Act and activities of Council of State Administrators in Vocational Rehabilitation.
* Data collection and RSA 911 report.
* Review of completion of 05 agency goals.
* Review of customer satisfaction surveys for 2004.
* Review and input on Memoranda of Cooperative Agreements with partnering programs.
Special Activities
Regi onal SRC Training: A representative of the SRC and two ARS personnel attended Regional SRC training in Dallas.
Web site Enhancement: The Council provided recommendations and input on additions and changes to the ARS web site and the State of Arkansas web site.
Partnering Activities: Received regular updates and provided input on activities of the Arkansas Independent Living Council; received reports and provided input and recommendations for the Workforce Investment Board; received updates from the state Transition Services Program; received reports from the Governor's Commission on People with Disabilities.
Arkansas Ability Awards: Participated in the third annual Arkansas Ability Awards program recognizing outstanding employers and significant achievements of consumers.
National Conference on RSA Monitoring and Redesign Initiatives: A SRC representative and two ARS personnel attend the RSA Monitoring and Redesign meeting in Washington, D.C.
Resource Plan: The Council prepared resource plan and budget.
Statewide Needs Assessment: Collaborated with ARS personnel to review the plan and progress reports statewide needs assessment for 2005.
ARS Fall Conference: Council members attended annual training conference.
State Rehabilitation Council Plan
Shall be to aid in carrying forward the work and mission of Arkansas Rehabilitation Services (ARS) and to provide feedback to the Commissioner regarding the objectives, for which the Council was organized, including:
The Committee partners with ARS by reviewing, collaborating and providing input regarding all ARS policies and the Arkansas State Plan, and to enhance the goals of ARS. The Committee reviews and provides input on an ongoing basis regarding the development of the State Plan, collaborates with ARS on the State Needs Assessment and reviews and provides input on ARS policies for services.
Response of ARS to Arkansas State Rehabilitation Council was made through the process of committee response to their respective responsibilities. This is an ongoing process that involves collaboration and cooperation between ARS and the SRC. There were no instances of rejection by ARS of input or recommendations by the SRC.
Attachment 4.12(c)(2)(A) Order of Selection
Order of Selection and Justification
Under the Vocational Rehabilitation Act (Title IV of the Workforce Investment Act of 1998) certain state Vocational Rehabilitation agencies are required to have an order of selection. An order of selection requires that a priority is given to individuals with the most significant disabilities in the provision of vocational rehabilitation services. The order of selection is required when a state determines that there are not sufficient funds to serve all the individuals with disabilities within the state including those with disabilities that are considered non-significant.
The current ARS Order of Selection assures the highest priority in provision of services to clients with the most significant disabilities. Services and expenditures are closely monitored to enable the ARS Commissioner to close or open priority categories as deemed appropriate. This will assure services are continued for cases determined eligible and receiving services under an Individualized Plan for Employment. Adequate funds will be conserved to provide diagnostic services for all applicants to determine eligibility and category placement.
The Order of Selection priority categories, justification for each, outcome and service goals are listed below:
ORDER OF SELECTION
ARS will provide services based on an Order of Selection on a statewide basis. The ARS Order of Selection assures clients in Priority I and II will have first priority for the provision of services. * If funds become available, individuals in Priority III and IV may receive services.
Rehabilitation clients who have an Individualized Plan for Employment (IPE) for vocational rehabilitation (VR) services or extended evaluation (EE) services in place prior to the implementation of the Order of Selection policy will receive services as recorded in their IPE.
PRIORITY CATEGORY I - MOST SIGNIFICANTLY DISABLED
An individual with a most significant disability is defined as one who has a significant physical or mental impairment which:
PRIORITY CATEGORY II - SIGNIFICANTLY DISABLED
An individual with a significant disability is defined as one who has a significant physical or mental impairment which:
Priority Category III - Non-Significantly Disabled Needing Multiple Services
An individual with a non-significant disability who is expected to require multiple vocational rehabilitation services.
Priority Category IV - Non-Significantly Disabled
An individual with a non-significant disability not classified in a higher priority.
* Two (2) or more major VR services, i.e. counseling, guidance, assistive technology, physical or mental restoration, training, and placement.
** 90 days or more from the date services are initiated.
