114 Organizations
Endorse NWPC Letter to RSA
A letter from the National Working Positive Coalition, endorsed by
114 organizations, was sent to the Rehabilitation Services Administration in
support of retaining high standards for the vocational rehabilitation
counseling workforce to meet the employment and vocational rehabilitation needs
of eligible individuals with disabilities, including people living with HIV.
In the letter sent February 25, 2015, the National Working
Positive Coalition is partnering with the Council of State Administrators of
Vocational Rehabilitation (CSAVR) to advocate for the regulations now being
developed to implement the Workforce Innovation and Opportunity Act (WIOA) to
maintain standards for a qualified and effective vocational rehabilitation
counseling workforce.
Many people living with HIV, and other disabilities, need to be
able to access effective vocational rehabilitation services to achieve their
goals for employment. The state-federal vocational rehabilitation services
system is the most comprehensive employment resource for people with
disabilities. Services include access to benefits counseling, comprehensive
rehabilitation evaluation to determine skills, interests, and abilities, as
well as case management, vocational counseling, employment services, assistance
with finding and keeping a job, and on the job and other training/education.
Rehabilitation counselors can also authorize medical referrals,
job training, and supportive rehabilitation services, including mental health counseling,
if these services will remove barriers to employment. Individuals with
disabilities, including people living with HIV, often face significant barriers
to employment including dealing with complex medical and psychological aspects
of their diagnosis as well as social, educational, financial, legal, and
vocational factors that can limit their ability to achieve viable employment
outcomes that ensure continued access to care and improved economic and health
outcomes.
This letter calls for regulations to be written based on the understanding
that vocational rehabilitation (VR) counselors need to be appropriately trained
to adequately address the complex and interconnected issues of individuals with
disabilities, including people living with HIV:
February 25, 2015
Commissioner
Janet LaBreck
Rehabilitation
Services Administration
U.S.
Department of Education
400
Maryland Ave., SW
Washington,
DC 20202-2800
Dear
Commissioner LaBreck:
The undersigned
organizations are joining to urge that regulations developed to implement the
Workforce Innovation and Opportunity Act (WIOA) clarify the skill set that
vocational rehabilitation counselors need to have to meet the complex and
diverse employment needs of individuals with disabilities, including people
living with HIV. The National HIV/AIDS Strategy (NHAS) includes a number of
employment-related provisions to help achieve the three primary goals of the
NHAS: 1) increase access
to care and improve health outcomes for people living with HIV, 2) reduce new
HIV infections, and 3) reduce HIV-related health disparities.
The state-federal
vocational rehabilitation services system is the most comprehensive employment
resource for individuals with disabilities, including people
living with HIV. To adequately address the complex and interconnected needs of
this population, we believe that vocational rehabilitation (VR) counselors need
to be appropriately trained and credentialed.
Therefore, we request that the WIOA regulations
specifically require that all vocational rehabilitation counselors have the
skill set identified by the Council of State Administrators of Vocational
Rehabilitation (CSAVR) in the CSPD comments they submitted for consideration
for the federal regulations: (a) knowledge of the medical and psychological aspects of
disability, (b) knowledge and implementation of vocational assessment strategies,
(c) a working knowledge of the
labor market and, d) competence in counseling and guidance, and providing the
services required to develop and implement the individualized career plan that enables
the person to be successfully employed in a competitive, integrated work
environment.
In the states where hiring
efforts fail to identify an individual qualified at the Master’s level, clearly
the skill set identified by the CSAVR should be the preferred standard that a
qualified VR counselor should meet. We continue to believe the ideal standard
for qualified VR counselors is the attainment of a Master’s degree and the
ability to sit for the Certified Rehabilitation Counselor (CRC) exam, as was
defined in the Rehabilitation Act prior to the passage of the WIOA. This level
of knowledge and expertise has been found to be most effective in achieving
successful employment outcomes for individuals with disabilities, including
people living with HIV. We were extremely concerned when these standards were
downgraded in the WIOA.
The training that qualified
VR counselors receive includes a focus on the impact of stigma and
financial/benefits issues along with key medical and psychosocial concerns that
impact the economic well-being and health of many individuals with
disabilities, including people living with HIV. Research findings indicate that
use of VR services by people living with HIV increases the chances of
successful employment among those who use these services, and of achieving the
primary goals of the National HIV/AIDS Strategy. Access to income supports and quality vocational
rehabilitation services that can help improve the economic well-being of people
with HIV are essential to these goals. To achieve this end, the NHAS Federal
Implementation Plan specifically directs federal agencies to “consider ways to
increase supports for employers to hire and maintain employment of people with
HIV and how to integrate them in broader employment initiatives for people with
disabilities” and to “develop a joint initiative to consider ways to help
individuals living with HIV access income supports, including job skills and
employment.”
In summary, in light of the
important role that vocational rehabilitation services can play in addressing
the goals of the National HIV/AIDS Strategy and in increasing access to income
supports and job training, we urge you to ensure that the WIOA regulations
state the requirement that vocational rehabilitation counselors are adequately
trained to address the complex vocational development and employment needs of
individuals with disabilities, including people living with HIV. It is
imperative that these regulations clearly require that vocational
rehabilitation counselors demonstrate the skill set that is known to lead to
improved employment outcomes for people with disabilities.
Sincerely,
30 for 30 Campaign
ActionAIDS, Philadelphia,
PA
ADAP Advocacy Association
(aaa+), Washington, DC
AIDS Action Baltimore,
Inc., Baltimore, MD
AIDS Alabama, Birmingham,
AL
AIDS Connecticut,
Hartford, CT
AIDS Foundation of
Chicago, Chicago, IL
AIDS Legal Council of
Chicago, Chicago, IL
AIDS Project Los Angeles,
Los Angeles, CA
AIDS Resource Center Ohio
AIDS United, Washington,
DC
The Albany &
Schenectady Damien Centers, Albany & Schenectady, NY
Alexian Brothers Housing
and Health Alliance, Chicago, IL
The Alpha Workshops, New
York, NY
American Sexual Health
Association, Research Triangle Park, NC
APLA Health &
Wellness, Los Angeles, CA
ASCNYC, New York, NY
BOOM!Health, Bronx, NY
Boulder County AIDS
Project, Boulder, CO
Cascade AIDS Project,
Portland, OR
Catholic Charities
Community Services of Rochester, Rochester, NY
The Center for Black
Equity-Baltimore, Baltimore, MD
The Center for HIV Law
& Policy, New York, NY
The Center for
Independence of the Disabled, NY, Kew Gardens, NY
CenterLink: The Community
of LGBT Centers
Chicago House and Social
Service Agency, Chicago, IL
CHOICES. Memphis Center
for Reproductive Health, Memphis, TN
Christie’s Place, San
Diego, CA
Coalition of HIV/AIDS
Nonprofits and Governmental Entities (CHANGE), New Orleans, LA
Collaborative Solutions,
Inc., Birmingham, AL
Colorado Organizations
Responding to AIDS (CORA)
Community Access National
Network (CANN), Washington, DC
Community Access Services,
Buffalo, NY
Community Servings,
Boston, MA
Desiree Alliance-USA
Family and Medical
Counseling Service, Inc., Washington, DC
Federation of Protestant
Welfare Agencies, New York, NY
Friends For Life, Memphis,
TN
Gay Men’s Health Crisis
(GMHC), New York, NY
The Global Network of
People Living with HIV, North America (GNP+NA)
The G.R.E.E.N. Foundation,
Santa Ana, CA
HealthHIV, Washington, DC
HIPAtlanta, Atlanta, GA
HIV Alliance, Eugene, OR
HIV Arkansas,
Fayetteville, AR
HIV Prevention Justice
Alliance, Chicago, IL
Housing Works, Brooklyn,
NY
Howard Brown Health
Center, Chicago, IL
I'm Still Josh -
http://imstilljosh.com
International AIDS
Empowerment, Las Cruces, NM; El Paso, TX
International Community of
Women Living with HIV-North America (ICW-NA)
Iowa Unitarian
Universalist Advocacy/Witness Network
Iris House, New York, NY
Knew Choices, Inc.,
Cartersville, GA
Latino Commission on AIDS,
New York, NY
Legal Action Center, New
York, NY
The Lesbian, Gay, Bisexual
& Transgender Community Center, New York, NY
Life Linc Baltimore,
Baltimore, MD
Lifelong, Seattle, WA
The Living Affected
Corporation, Little Rock, AR
Louisiana AIDS Advocacy
Network
Love Alive International
Foundation of New York City, New York, NY
Love Alive International
Sanctuary of Praise Worship Center, New York, NY
Making A Way Housing,
Inc., Atlanta, GA
Moveable Feast, Baltimore,
MD
Nashville CARES,
Nashville, TN
National AIDS Housing
Coalition, Washington, DC
National Alliance of State
& Territorial AIDS Directors (NASTAD), Washington, DC
National Business &
Disability Council (NBDC) at The Viscardi Center, New York, NY
National Center for
Lesbian Rights, Washington, DC
National Council on
Rehabilitation Education
National Coalition for
LGBT Health, Washington, DC
National Minority AIDS
Council, Washington, DC
National Women and AIDS
Collective, Washington, DC
National Working Positive
Coalition
New York City Faith in
Action, New York, NY
New York HIV Employment
Network
Okaloosa AIDS Support and
Informational Services, Inc. (OASIS), Ft. Walton Beach, FL
Ohio AIDS Coalition
One in Four Chronic
Health, Portland, OR
Pediatric AIDS Chicago
Prevention Initiative (PACPI), Chicago, IL
Philadelphia Center,
Shreveport, LA
Positive Opportunities,
Inc., Harrisburg, PA
Positive Resource Center,
San Francisco, CA
Positive Women’s
Network-Colorado
Positive Women’s Network –
USA, Oakland, CA
Pozitively Healthy,
Washington, DC
Poz Vets USA-INTL,
Atlanta, GA
Professional Association
of Social Workers in HIV/AIDS, Birmingham, AL
Project Angel Food, Los
Angeles, CA
Project Inform, San
Francisco, CA
Ribbon Consulting Group,
Washington, DC
The San Francisco EMA HIV
Health Services Planning Council, San Francisco, CA
The San Francisco Mayor's
Disability Council, San Francisco, CA
Sero Project, Milford, PA
SisterLove, Inc., Atlanta,
GA
Southern HIV/AIDS Strategy
Initiative (SASI), Durham, NC
START at Westminster,
Westminster Presbyterian Church, Washington, DC
Street Works, Nashville,
TN
Thresholds, Chicago, IL
TILTT, Inc. (Transgender
Individuals Living Their Truth, Inc.), Atlanta, GA
Transgender Law Center,
Oakland, CA
Treatment Access Expansion
Project, Boston, MA
Treatment Action Group,
New York, NY
Unity Fellowship Church
NYC, Harlem, NY
US PLHIV Caucus
VillageCare, New York, NY
Virage Community Services,
New Orleans, LA
VOCAL-NY, Brooklyn, NY
Watchful Eye, Brooklyn,
New York
Wateree AIDS Task Force,
Sumter, SC
Women Organized to Respond
to Life-threatening Diseases (WORLD), Oakland, CA
The World Foundation for
Medical Research and Prevention, Houston, TX
World Institute on
Disability, Berkeley, CA
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