Students with Disabilities: Additional Information from Education Could Help States Provide Pre-Employment Transition Services

WIOA requires states to reserve at least 15 percent of their total State Vocational Rehabilitation Services program funds to provide pre-employment transition services to help students with disabilities transition from school to work. GAO was asked to review how states were implementing these services.

This report examines (1) steps states reported taking to implement pre-employment transition services, and (2) implementation challenges states reported and how Education has addressed them. GAO reviewed documents and funding data from Education, and federal laws and regulations; surveyed all 79 state VR agencies (74 responded); held discussion groups with representatives of 29 state VR agencies; and interviewed officials from Education and three states (Idaho, Illinois, and Maryland) GAO selected for variety in size and type of agencies, among other factors.

Of the 74 state vocational rehabilitation (VR) agencies that responded to GAO's survey, most reported expanding services to help students with disabilities transition from school to work as required under the Workforce Innovation and Opportunity Act (WIOA), enacted in July 2014. Most state agencies reported serving more students and providing work-based learning experiences and other activities, referred to as pre-employment transition services (see figure).

State VR agencies reported two key challenges with implementing pre-employment transition services for students as required by WIOA.

Spending reserved funds : States reported spending about $357 million out of the $465 million reserved for these services in fiscal year 2016. Education officials said that states had difficulty determining what expenditures were allowable, and some state officials said they would like more detailed information from Education. Education officials said they plan to clarify guidance but have no timeframe for providing further information, which would help states to better plan their use of reserved funds.

Finalizing interagency agreements : Fewer than half the state VR agencies that responded to GAO's survey (34 of 74) reported updating their interagency agreement with their state's educational agency. Interagency agreements can help promote collaboration by, for example, establishing roles and responsibilities of each agency. Although Education offers technical assistance on interagency agreements, without increased efforts to raise awareness about the importance of these agreements and provide assistance to states where needed, Education may miss opportunities to help state VR and educational agencies efficiently and effectively coordinate services.

In addition, WIOA requires Education to highlight best state practices, and most VR agencies responding to GAO's survey (63 of 74) reported this would be useful. Education does not have a written plan or timeframe for identifying and disseminating best practices. As a result, Education may miss opportunities to help more students with disabilities successfully transition from school to work.

GAO is recommending that Education (1) establish timeframes for providing additional information on allowable expenditures, (2) take additional steps to assist states that have not updated and finalized their interagency agreements, and (3) develop a written plan with specific timeframes and activities for identifying and disseminating best practices. Education agreed with the first recommendation and disagreed with the other two. GAO revised the second recommendation and maintains that specific information is needed for the third, as discussed in the report.

The transition from high school to postsecondary education or the  workforce can be a challenging time for students, and particularly for  those with disabilities who may need additional services or guidance to  achieve their goals. We have reported that students with disabilities are  less likely than their peers to transition successfully. In addition, people  with disabilities have historically experienced higher unemployment and  poverty rates than those without disabilities. Students with disabilities  who do not successfully transition from school to the workforce may face  a lifetime of reliance on public assistance, potentially leading to  substantial costs to the government and society. While states provide  transition services through special education in schools and to some  students who apply and are determined eligible for the State Vocational  Rehabilitation Services program, the Workforce Innovation and  Opportunity Act (WIOA) amended the Rehabilitation Act of 1973  (Rehabilitation Act) in 2014 to require states to additionally provide a  defined set of activities called pre-employment transition services. These  services are to be provided both to students who are eligible for the  program as well as to those who are potentially eligible, greatly expanding  the number of students who can be served. Pre-employment transition  services are offered as an early start on job exploration and are designed  to help these students identify their career interests. Specifically, states  are required to offer job exploration counseling and work-based learning  experiences, which may include internships, exposures to local  employment, and other activities.

In fiscal year 2017, the Department of Education (Education) awarded  about $3.1 billion in grants to states for the State Vocational  Rehabilitation Services program. WIOA requires states to reserve at least  15 percent of their vocational rehabilitation (VR) grants to provide pre- employment transition services to all eligible or potentially eligible  students with disabilities who need them. That reserve amounted to  about $468 million across all states in fiscal year 2017.

You asked us to provide information on how states are implementing pre- employment transition services. This report examines (1) the steps states  have reported taking to implement pre-employment transition services,  and (2) the implementation challenges, if any, states have reported  facing, and how Education has addressed them.

To obtain information on both of these objectives, we used the following  methodologies. We reviewed Education’s guidance and technical  assistance documents as well as federal laws and regulations. We  reviewed expenditure data reported by state VR agencies to Education  for fiscal years 2015 and 2016, the most recent full years of data  available, and determined they were reliable for the purposes of this  review by interviewing Education officials about the data’s quality and by  electronically testing the data for any obvious errors. We administered a  web-based survey to all 79 state VR agencies from October through  December 2017, with 74 agencies (94 percent) responding. We  conducted interviews with state VR and educational officials in Idaho,  Illinois, and Maryland. We selected these states based on variety in the  size of the special education population, state agency organization, and  whether the state had a separate agency for serving individuals who are  blind or visually impaired. The information from these interviews is not  generalizable. We interviewed representatives of other relevant  organizations, including the Council of State Administrators of Vocational  Rehabilitation (CSAVR) and the National Council of State Agencies for  the Blind. In addition, we interviewed officials from Education’s Office of  Special Education and Rehabilitation Services, Rehabilitation Services  Administration, Office of Special Education Programs, and the Workforce  Innovation Technical Assistance Center and National Technical  Assistance Center on Transition—two technical assistance centers  funded by Education. We also convened three discussion groups with  state VR agency directors or their designated representatives, with a total  of 39 participants from 29 separate agencies (10 to 12 agencies  represented per discussion group). We invited all state VR agencies to  participate through our survey and through the conference organizer  (CSAVR). To assess how Education addressed challenges reported by  state VR agencies, we compared actions taken by Education to standards  for internal control in the federal government. For further details on our  objectives, scope, and methodology, see appendix I.

We conducted this performance audit from February 2017 to September  2018 in accordance with generally accepted government auditing  standards. Those standards require that we plan and perform the audit to  obtain sufficient, appropriate evidence to provide a reasonable basis for  our findings and conclusions based on our audit objectives. We believe  that the evidence obtained provides a reasonable basis for our findings  and conclusions based on our audit objectives.

The Rehabilitation Act of 1973 (Rehabilitation Act), as amended by  WIOA, authorizes a number of grant programs to support employment  and independent living for persons with disabilities, including the State  Vocational Rehabilitation Services program. This program is the primary  federal government effort to help individuals with disabilities prepare for  and obtain employment. An individual who is deemed eligible works with  state VR agency staff to prepare an individualized plan for employment,  which describes the employment goal and the specific services needed to  achieve that goal. Education’s Rehabilitation Services Administration  (RSA) awards funds to state VR agencies through the program to help  individuals with disabilities engage in gainful employment. States must  provide a 21.3 percent nonfederal match of these funds. In fiscal year  2016, total program funds for VR—including state match funds—were  $3.81 billion.

States, territories, and the District of Columbia generally designate a  single agency to administer the program, although, depending on state  law, states may designate more than one agency. Twenty-three states  have two separate agencies, one that exclusively serves blind and  visually impaired individuals (known as agencies for the blind) and  another that serves individuals who are not blind or visually impaired  (known as general agencies). Twenty-seven states, the District of  Columbia, and the five territories have a single combined agency that  serves both blind and visually impaired individuals and individuals with  other types of impairments (known as combined agencies). In total, there  are 79 state VR agencies.

In 2014, WIOA amended the Rehabilitation Act to require state VR  agencies to provide students with disabilities with pre-employment  transition services. According to information Education provided with its  regulations, WIOA emphasized the provision of services to students with  disabilities to ensure that they have meaningful opportunities to receive  training and other supports and services they need to achieve  employment outcomes. WIOA requires states to make pre-employment  transition services available statewide to all students with disabilities in  need of such services, who are eligible or potentially eligible, regardless  of whether a student has submitted an application for services from a  state VR agency. In this context, students with disabilities include those  with an individualized education program (IEP) for special education  services through the school system, those receiving an accommodation  for their disability, and others. In information provided with the  regulations, Education stated that state VR agencies should work closely  with school systems and others to identify these students.

WIOA requires each state to reserve at least 15 percent of a state’s VR  allotment for a fiscal year for pre-employment transition services for  students with disabilities. If a state cannot use or match all of its VR  funding, it relinquishes funds to the federal government and the state’s  total award amount is then reduced. However, the state must still  reserve 15 percent of what it did not relinquish for the provision of pre- employment transition services.

WIOA established required activities under pre-employment transition  services that states must make available to students with disabilities.

Education has provided states with additional information about each of  the activities (see table 1).

After making the required pre-employment transition services available, if  a state has funding remaining, WIOA lists nine other “authorized”  activities that a state may implement. For example, in providing the  authorized activities, states may, among other things, provide training to  local VR and educational service providers; coordinate transition services  with local educational agencies; and disseminate information about  innovative, effective, and efficient approaches to achieve the goals (see  appendix II for a full listing of authorized activities). Education’s guidance  indicates that such authorized activities should improve the transition of  students with disabilities from school to postsecondary education or an  employment outcome and support the arrangement or provision of the  required activities.

WIOA also requires local offices of state VR agencies to conduct  coordination responsibilities, which includes coordinating with state and  local educational agencies to ensure the provision of pre-employment  transition services. These can be conducted concurrently with the  “required” activities, and states can use the reserved funds for them.  Examples of coordination responsibilities that local offices of state VR  agencies must undertake are attending meetings, when invited, about  IEPs; and working with the local public workforce system and employers  to develop work opportunities for students with disabilities.

In support of this coordination and in recognition that VR and educational  agencies both offer transition services to students, WIOA requires that VR  agencies establish or update their interagency agreements with states  educational agencies. Interagency agreements between the state VR  and educational agencies are intended to describe the steps each agency  will take to implement pre-employment transition services and determine  the roles and responsibilities of each agency, including financial  responsibilities and procedures for identifying students in need of pre- employment transition services.

Federal Guidance, Assistance, and Monitoring

Following the passage of WIOA, Education, through its Rehabilitation  Services Administration (RSA), issued regulations and guidance to  implement pre-employment transition services requirements (see fig. 1).

Education also provided technical assistance to state VR agencies  through webinars, conference calls, and presentations at conferences.  For example, Education presented information to state officials in a series  of webinars about the new programmatic and financial processes and  procedures related to pre-employment transition services just after the  final regulations were issued in 2016. In addition, Education funded  technical assistance centers to help state VR agencies and their partners  answer questions and provide training about WIOA. Two of these centers  are the Workforce Innovation Technical Assistance Center (WINTAC) and  the National Technical Assistance Center on Transition (NTACT). Each  center focuses its efforts on a specific set of issues: WINTAC on helping  state VR agencies implement WIOA requirements, including pre- employment transition services; and NTACT on helping state VR and  educational agencies improve outcomes for students receiving transition  services.

RSA is to conduct periodic monitoring visits to assess state VR agencies’  implementation of the VR program, including pre-employment transition  services. RSA is to monitor states for compliance with the  administrative, financial, and performance requirements of the program,  as well as identify technical assistance needs at individual state VR  agencies. According to Education officials, RSA plans to follow a 5-year  monitoring cycle that began in fiscal year 2017 and will generally include  monitoring visits to 10 states per year through fiscal year 2021. In fiscal  year 2017, Education visited 14 VR agencies in 10 states, and in fiscal  year 2018, Education plans to visit 15 VR agencies in 12 states.

Most States Reported Expanding Their Transition Services to Students and Developing Their Administrative Capacity to Provide These Services

Most State Vocational Rehabilitation Agencies Reported Expanding Their Services for Students with Disabilities

Most state VR agencies that responded to our survey reported expanding  services for students with disabilities since WIOA’s enactment in July  2014 by either serving more students through pre-employment transition  services or by initiating new or additional services. Most state VR  agencies that responded to our survey reported that they provided the  five required activities to more students with disabilities since WIOA’s  enactment (see fig. 2).

State VR agencies indicated in their survey responses that they had  previously provided and continue to provide transition services to  students who apply and are eligible for the VR program, and many of the  activities were not entirely new to state VR agencies. Most agencies that  responded to our survey reported providing each of the required activities  to students with disabilities before the enactment of WIOA, while fewer  reported initiating these services since enactment (see fig. 3).

Of the five required activities, instruction in self-advocacy saw the biggest  expansion during this time. In information provided with the regulations,  Education described instruction in self-advocacy as, for example,  classroom lessons in which students learn about their rights,  responsibilities, and how to request accommodations or services and  supports needed during transition. In written comments on our survey, 10  state VR agencies reported partnering with other organizations, such as  universities or centers for independent living, to provide instruction in self- advocacy. One agency reported on our survey that it offers peer  mentoring as an additional component of self-advocacy services, and  another reported providing self-advocacy and mentoring for deaf-blind  students by deaf-blind adults. In October 2016, based on views of an  expert panel that we convened on autism spectrum disorders and  transitioning youth, we reported that it is critically important that all  transitioning youth, regardless of their level of disability, be given the  opportunity to state their own preferences to the extent of their  capabilities to reach their maximum independence.

State VR agencies reported developing additional programming as a  result of WIOA’s enactment, including expanding programs for more  students, adding new opportunities and experiences, and creating new  partnerships. Officials from all four of the state VR agencies we  interviewed said they had programs in place prior to WIOA that offered  activities similar to pre-employment transition services, but they have  since expanded these services or created additional programs for  students with disabilities. For example, an official we interviewed from the  Idaho Division of Vocational Rehabilitation said the agency had previously  worked to enroll students in the VR program prior to graduation, but has  since begun developing new programming and instruction aimed at  serving larger groups and providing other services, such as a paid work  experience. An official from Maryland’s Division of Rehabilitation Services  said many of the services they previously offered were during school  hours, and students had limited access to these services if they wanted to  stay in class. The agency has since added services after school and  during the summer, such as opportunities for students to meet with  employers, according to Maryland officials. Officials from the Illinois  Department of Human Services, Division of Rehabilitation Services, said  that while the agency had previously provided work-based learning  experiences, it has since expanded the number of spots available for  students in an existing program and created a new work-based learning  program that is a collaboration between school districts, a community  rehabilitation partner, and businesses.

Providing new services with specific requirements to an expanded  population has been a significant change, according to officials in one of  the state VR agencies we interviewed and in all three of our discussion  groups. For example, officials from Maryland’s Division of Rehabilitation  Services said that, while they provided all five required activities before  WIOA, they now provide the activities to a younger population and make  the activities available statewide. State VR officials in all three of our  discussion groups said that providing pre-employment transition services  allows them to provide these services to more students with disabilities or  at an earlier age, which will likely have positive effects on students’  transition from school to work. For example, officials in one discussion  group noted that the provision of pre-employment transition services is  increasing awareness, enhancing services, and increasing the likelihood  that VR program outcomes will improve. In another discussion group,  officials said their agencies had already seen benefits from pre- employment transition services and the services have raised students’  expectations for the types of jobs they might obtain.

While 32 of the state VR agencies responding to our survey reported that  they had identified all potentially eligible students, another 37 reported  that they were currently in the process of identifying these students.  State VR officials in all three of our discussion groups and who we  interviewed in two of four state VR agencies said they have had  challenges finding the population eligible for services. In written  comments on our survey, one agency reported that while statewide  information on students was not readily available, officials worked with the  state educational agency to identify potentially eligible students, including  more than 137,000 students with an IEP and an estimated 13,000  additional students that do not have an IEP. We previously reported on  the difficulties state VR officials faced in obtaining data they could use to  identify other youth with disabilities.

Compared to combined and general agencies, more agencies for the  blind reported in our survey that they did not provide the five required  activities to more students with disabilities, and officials in some of these  agencies said they can serve a much smaller population. For example, 57  percent (12 of 21) of agencies for the blind reported providing job  exploration counseling to more students, compared to 83 percent (25 of  30) of combined agencies and 91 percent (20 of 22) of general agencies  since WIOA enactment. Similarly, 67 percent (14 of 21) of agencies for  the blind reported providing work-based learning experiences to more  students, compared to 83 percent (25 of 30) for combined agencies and  86 percent (19 of 22) for general agencies. Officials in some of these  agencies for the blind and from the National Council of State Agencies for  the Blind (NCSAB) told us in interviews that agencies for the blind have  far fewer potentially eligible students they could serve compared to other  types of agencies. For example, officials we interviewed with Idaho’s  Commission for the Blind and Visually Impaired said that Idaho has only  40 students being provided pre-employment transition services. In  contrast, the Idaho Division of Vocational Rehabilitation reportedly  provided at least one pre-employment transition service to approximately  700 students in a one-year period.

The ability of agencies for the blind to serve more students may also be  restricted because they are not able to provide pre-employment transition  services to younger students in some cases, according to officials with  NCSAB and Idaho’s Commission for the Blind and Visually Impaired.  NCSAB officials told us that state VR agencies have traditionally provided  VR services to youth who are blind or visually impaired at younger ages  compared to general agencies that serve youth with other types of  disabilities. The ages at which students may be provided pre-employment  transition services varied by agency, based on responses to our survey,  but the most common age range reported across all types of agencies  was 14 to 21 years old. According to Education officials, as a result of  WIOA, two agencies in the same state must agree on a common age  range during which students can be provided pre-employment transition  services. Most agencies in states with two VR agencies responding to our  survey (35 of 44) reported agreeing on an age range for receiving pre- employment transition services. NCSAB officials said that in some  cases agencies for the blind have had to raise the minimum age at which  they would begin providing services to students. Officials with Idaho’s  Commission for the Blind and Visually Impaired, for example, said they  would prefer to begin services at younger ages because their agency has  the resources to do so. However, officials with Idaho’s Division of  Vocational Rehabilitation said they do not have the resources to provide  pre-employment transition services to the relatively large number of  students with disabilities at a younger age.

Most State Vocational Rehabilitation Agencies Reported Building Administrative Capacity

State VR agencies reported taking a range of actions to build their  administrative capacity to implement pre-employment transition services.  These actions included building staff capacity and expanding contracts  with services providers.

Building staff capacity. Most state VR agencies reported building  staff capacity to facilitate and carry out the requirements of pre- employment transition services by:

Establishing a new specialist position. More than half (45 of 74) of  VR agencies reported in our survey establishing at least one new  transition specialist position specifically for pre-employment  transition services. For example, the Idaho Division of Vocational  Rehabilitation reported establishing this position and officials told  us that they hired a specialist who was previously the transition  coordinator for the state’s educational agency. In written  comments on our survey, a respondent from another state  commented that their agency has hired 20 pre-employment  transition services specialists to provide the five required activities.  Officials we interviewed from Maryland’s Division of Rehabilitation  Services said they added six salaried positions dedicated to  providing pre-employment transition services. Another agency  responding to our survey reported dedicating a supervisor and 15  percent of their counselors exclusively to this purpose.

Training staff. All 74 state VR agencies reported providing training  on pre-employment transition services to their staff. For example,  in written comments, one agency reported developing training  tools for its counselors, such as answers to frequently asked  questions, posting guidance on its intranet, and having WINTAC  provide training.

Expanding contracts and agreements with service providers. In  addition to being provided by state VR agency staff, pre-employment  services can be offered through a variety of methods and service  providers, and many state VR agencies reported entering into new or  additional contracts with service providers or expanding contracts with  existing providers. Pre-employment transition services can be  provided directly by state VR agency staff or through agreements with  third parties, such as community rehabilitation programs, independent  living agencies, public colleges and universities, and school districts.  In our survey, 62 of 74 agencies reported entering into new or  additional contracts with third-party providers to provide pre- employment transition services. Officials we interviewed from three of  four state VR agencies said they either established or expanded  existing contracts and agreements. For example, officials from the  Illinois Department of Human Service, Division of Rehabilitation  Services told us that after the enactment of WIOA, they expanded  arrangements with independent living centers and initiated a new  program that provides students with work experiences.

Agencies reported several examples of approaches using third  parties: establishing contracts with community rehabilitation programs to partnering with independent living agencies to work with youth on entering into provider agreements with local workforce centers to  assist with providing job preparation and a paid work experience, developing programs with public colleges and universities focused  on financial literacy and self-advocacy, and  contracting with individual school districts to deliver services in the  school environment.

States Reported Challenges Using Reserved Funds, Updating Interagency Agreements, Among Others, and Reported Needing More Assistance from Education

Fewer Than Half of States Reported Using All Reserved Funds, and Some Reported a Need for More Information on Allowable Costs

Twenty-one of 56 states (50 states, 5 territories, and the District of  Columbia) reported using the full amount of grant funds they reserved for  pre-employment transition services for students with disabilities for fiscal  year 2016, according to the most recent full year of data available from  Education (see fig. 4).

In aggregate, states reportedly expended approximately $357 million out  of the approximately $465 million reserved (about $108 million less than  the target) for fiscal year 2016. For fiscal year 2015, states reportedly  expended approximately $324 million on pre-employment transition  services out of the approximately $453 million reserved for that purpose  (about $130 million less than the target).

Results from our 2017 survey of state VR agencies revealed similar  trends: Fewer than half the 74 agencies reported that they used at least  15 percent of their VR grant allotment each year. Thirty-two of the 74  agencies responding to our survey reported using the minimum required  15 percent of federal VR grant funds reserved for the provision of pre- employment transition services for fiscal years 2016 and 2017. For  fiscal year 2015, 25 agencies reported using the required 15 percent  minimum reserved funds.

Officials we interviewed in two of four state VR agencies and officials in  all three discussion groups explained that some of the services they  generally provided to participants in the VR program are not allowable for  the funds reserved for pre-employment transition services. These  expenditures included transportation, tuition, and others associated with  individualized services. For example, officials in Maryland’s Division of  Rehabilitation Services told us that transportation costs for students to get  to the place where the services are provided are not covered. VR agency  officials in two of our discussion groups told us that assistive technology,  such as hearing aids, could not be paid for with the 15 percent of funds  reserved for pre-employment transition services. In another group,  participants said that some expenditures, such as tuition or for the  services of a job coach to help students with the most significant  disabilities, could not be paid with reserved funds. In information provided  with the regulations, Education stated that it does not have the statutory  authority to allow these expenditures to be paid for with the funds  reserved for pre-employment transition services and these services must  be paid with other VR funds.

When it promulgated its final regulations, Education noted that state VR  agencies would experience challenges in using their funds because many  of the services provided to students with disabilities prior to WIOA’s  enactment would not qualify as pre-employment transition services.  Education reviewed past expenditures for a subset of students and  estimated that 82 percent of state VR agencies’ reported purchases for  those students would not meet the statutory definition of pre-employment  services under WIOA. Education concluded that states would have to  reach a larger number of students with disabilities in order to meet the  spending requirement and that state VR agencies would need to develop  and implement aggressive strategies to expend these funds in these  initial years of implementation.

According to WINTAC officials, state VR agency officials are commonly  unclear about what kinds of activities they can provide using the funds  reserved for pre-employment transition services. For instance, they said  that states must make required activities (e.g. work-based learning  experiences and self-advocacy) available to all students with disabilities  before providing authorized activities (e.g. model projects, partnerships),  in accordance with WIOA. However, state officials have commonly  interpreted that to mean that all students must actually receive the  required activities before the agency can begin providing other activities,  according to WINTAC officials. WINTAC officials explained that states  may have been conducting authorized or coordination activities without  knowing these activities could be paid for with the reserved funds.

None of the state VR agency officials we interviewed said they had yet  moved beyond providing required activities to providing authorized  activities. Officials from two of the agencies we interviewed told us they  were in the process of planning authorized activities. For example,  officials with the Idaho Division of Vocational Rehabilitation said they  were completing an assessment of their needs, which would help them  plan authorized activities. Officials we interviewed from the other two  agencies—the Idaho Commission for the Blind and Visually Impaired and  the Illinois Division of Rehabilitation Services—said they did not have the  resources to provide authorized activities or were unsure about how to  properly transition from required to authorized activities under the current  guidance.

Education communicated with states on broad requirements but provided  little detailed information directly to states on the allowable use of funds  reserved for pre-employment transition services. Education provided  information when it promulgated final regulations, in grant award  notifications, on its website, and in presentations at conferences. In each  of these formats, Education described activities on which states could not  spend funds, but provided little detailed information on what expenditures  are allowed.

Regulations: Education’s final regulations restate many provisions in  WIOA, including the prohibition on using any of the reserved funds for  administrative costs. In responding to comments it received on its  proposed regulations, Education provided examples of services that  commenters requested would be considered pre-employment  transition services, such as, postsecondary education, on-the-job  supports, job coaching, travel expenses, and uniforms. In information  provided with the regulations, Education explained that it had no  statutory authority to expand or limit the pre-employment transition  services listed in WIOA. Education stated that a state VR agency can  allocate costs associated with staff time spent providing pre- employment transition services, including an employee’s salary and  fringe benefits, to the funds reserved for pre-employment transition  services. However, Education did not provide additional information  on what specific types of expenditures states were permitted to spend  funds on in providing pre-employment transition services as required  by WIOA.

Grant award notification: The notification that accompanies each  state’s VR grant award lists the three sets of activities for which the  reserved money can be used: required, authorized, and coordination;  it lists each of the activities as they are listed in WIOA. It also  discusses the prohibition on using any of the reserved funds for  administrative costs. It does not list or describe what specific  expenditures the reserved funds can be used for to undertake each of  the listed activities.

Education’s website: A list of frequently asked questions on  Education’s website outlines the requirements of WIOA and explains  that the reserved funds must only be used to provide pre-employment  transition services as listed in WIOA. Similar to the regulations, the  website explains that the total costs of an employee’s salary and  fringe benefits may be allocated to the reserved funds if that  employee is providing only pre-employment transition services to  students with disabilities but does not include additional detail for any  other expenditures.

Presentation materials: In one set of presentation materials,  Education provided an example of a potential allowable expenditure  for one of the required activities, work-based learning. It did not  include information on allowable expenditures for the other four  required activities, or any of the nine authorized activities. In another  set of presentation materials, Education provided examples of  services for each of the five required pre-employment transition  services activities. According to Education officials, these examples  would be allowable expenditures.

Education, however, provided the most detailed information through  WINTAC. WINTAC’s website provided answers to some specific  questions on the use of funds reserved for pre-employment transition  services. In one set of frequently asked questions, WINTAC included a  list of 28 questions with detailed answers, including what specific  expenditures may be charged to the reserved funds. For example, based  upon guidance issued by RSA, the website explains that reserved funds  may be used to pay for auxiliary aids and services, such as interpreters, if  they are directly related to one of the five required pre-employment  transition services activities. However, the reserved funds may not be  used to pay for the costs of foreign language interpreters because they  are not an auxiliary aid or serve that is required due to the individual’s  disability. WINTAC’s website also included answers provided by  Education on 13 other frequently asked questions. Information included  that reserved funds cannot be used to pay for the cost of an assessment  to determine whether a student met the definition of a student with a  disability; they can be used to pay for items required by an employer for  work-based learning activities.

Some state VR agencies we surveyed and those that participated in one  of our three discussion groups said they would like more detailed  information directly from Education. Seven survey respondents reported  that they would like Education to provide answers to their specific  questions. In one discussion group, participants noted that when states  approach WINTAC with a new question, the technical assistance center  sometimes needs to obtain the answer from Education. This process can  be inefficient at times. In addition, the answer may not be broadly shared  with all the states, limiting its benefit, whereas information issued directly  from Education could help communicate the answer more efficiently and  broadly. One survey respondent reported, for example, that guidance  varied by source—training, Education’s RSA staff, or technical assistance  center websites—and said that Education should provide all state VR  agencies with the same information at the same time.

According to standards for federal internal control, management should  communicate externally through reporting lines so that external parties  can help the entity achieve its objectives and address related risks.  Management should also periodically evaluate its methods of  communication so it has the appropriate tools to communicate quality  information throughout and outside of the entity on a timely basis.  Education officials said that during fiscal years 2015 and 2016, states  were unclear about allowable expenditures using reserved funds, and that  they plan to clarify guidance as they learn about the issues from states  during their monitoring. According to Education officials, they respond to  issues that need clarification and provide answers to questions as part of  formal monitoring visits or through other communications with state  agencies. Education officials said they expect to complete a round of  monitoring visits to all states by the end of fiscal year 2021. However, an  Education official said they have no timeframe for providing further  information on allowable costs to states. With better information on  timeframes for when this information will be provided, states would be  able to better plan their use of the remaining funds reserved for pre- employment transition services.

State VR and Educational Agencies Have Begun Collaborating through Joint Training and Guidance, But Fewer Than Half Have Updated Their Interagency Agreements

Most state VR agencies (61 of 74) that responded to our survey reported  providing training on pre-employment transition services along with their  state’s educational agency since WIOA’s enactment in 2014. Joint  training may help coordination between state VR and educational  agencies, as state VR officials participating in our discussion groups said  that some educators were not familiar with pre-employment transition  services. Similarly, an official we interviewed from Idaho’s state  educational agency said it was common in the past for teachers and VR  counselors not to know one another. Joint trainings provided to VR staff  and teachers have improved these relationships, and teachers can invite  VR counselors to students’ IEP meetings, the official said.

Joint training includes staff presentations at conferences and participation  in other training sessions. For example, officials we interviewed from the  Idaho Division of Vocational Rehabilitation said their transition coordinator  has given presentations to education directors around the state about  changes resulting from WIOA and how the inclusion of pre-employment  transition services can affect special education for the school districts. In  written comments on our survey, one agency reported that it co-sponsors  an annual conference with VR, special education, developmental  services, and other public and private entities. During this conference,  they plan how to improve services for students with disabilities.

About one-third of state VR agencies (23 of 74) reported issuing joint  guidance with their state’s educational agency, a recommended practice  according to WINTAC. The other two-thirds of survey respondents  reported that joint guidance was either in progress (27 of 74) or that they  had not issued such guidance (23 of 74). Joint guidance can include  written policies and procedures that are created by and provided to state  VR and educational agency staff. For example, in written comments on  our survey, one agency reported developing written policies and guidance  for transition counselors that the state educational agency endorses and  provides to special education staff. In Maryland, VR and special  education officials told us that they issued guidance through jointly  created materials on pre-employment transition services.

Less than half the state VR agencies that responded to our survey (34 of  74) reported updating their interagency agreement with their state’s  educational agency, which is intended to facilitate collaboration and  coordination on delivery of pre-employment transition services. The  majority of agencies reported that their agreement is either in progress  (37 of 74) or not yet updated (3 of 74). These required agreements outline  how VR agencies and schools will plan and coordinate service provision,  provide for each agency’s responsibilities, including financial  responsibilities, and provide for student outreach procedures, among  other things.

Discussion group participants and CSAVR representatives emphasized  the value of completing their interagency agreements with the state  educational agency. In one group, officials whose agencies had  completed their agreements said they are essential for state VR agencies  to provide services in schools. Participants in another discussion group  explained that once they have a state-level agreement in place, they can  discuss what services school districts need for students and then  determine how to provide those services. According to state educational  agency officials we interviewed, Individuals with Disabilities Education Act  (IDEA) requirements are similar to requirements for pre-employment  transition services, and they need to coordinate with VR officials at both  the state and local levels to agree on each agency’s assigned tasks and  expectations. These officials said state VR and educational agencies  should coordinate funding to make services available where they are  needed and to complement each other’s transition efforts. Illinois’s  agreement, for example, specifies that the state educational agency is  responsible for providing outreach, guidance, and coordination to local  educational agencies regarding the provision of pre-employment  transition services. According to the agreement, Illinois’s VR agency is  responsible for providing pre-employment transition services, both directly  and through cooperative agreements with local educational agencies, and  for providing written information to the state educational agency regarding  services available to students with disabilities. Officials we interviewed  with CSAVR said state VR agencies that have made progress in  developing their interagency agreements with state educational agencies  tend to be more successful in implementing pre-employment transition  services.

According to Education officials, Education provides guidance and  technical assistance on interagency agreements to states as part of  Education’s monitoring or when asked by states. Education officials said  they provide technical assistance during periodic monitoring visits, which  are currently limited to about 10 states per year from fiscal years 2017- 2021; by helping state VR agencies develop policies and procedures; and  by making sure pre-employment transition services are coordinated with  the state educational agency and through interagency agreements.  According to Education officials, there is no statutory provision authorizing  Education to identify states that have not updated their interagency  agreement. Education officials said they do not collect information from  state VR agencies on the status of these agreements except when they  conduct monitoring visits in specific states. In addition, Education officials  said that when monitoring, they may meet with state educational agency  partners to help them understand the new components of pre- employment transition services in an agreement, or they may refer the  state agencies to WINTAC or NTACT resources. Providing assistance  during monitoring may be helpful for some states. However, given that  less than half of state VR agencies we surveyed reported updating and  finalizing their agreements and Education officials say they will take  another three years to complete this round of monitoring, additional action  by Education may be needed to raise awareness among the remaining  states about the importance of these agreements to help states  coordinate services to students with disabilities. Additional action could  include, for example, conducting earlier state outreach or monitoring to  assess state progress on finalizing the interagency agreements and  offering technical assistance when appropriate.

However, Education officials said there is no requirement that state  educational agencies provide pre-employment transition services to meet  their obligations to IDEA-eligible students with disabilities under part B of  the Individuals with Disabilities Education Act. As a result, WINTAC and  participants in our discussion groups explained that it can be difficult to  get state educational agencies to work with state VR agencies to update  interagency agreements. Education officials said that WIOA requires state  VR agencies to update these interagency agreements to include pre- employment transition services but they do not track their completion  because states are not required to report when the agreements are  finalized. Moreover, Education officials said they have heard from states  that some reasons that interagency agreements are not specifically  updated are that the agreements are written broadly enough so that they  can remain in effect when there are additional changes to the law, the  details of actual practices are rarely reflected in the high level of an  interagency agreement, and that modifications to agreements are time- consuming and would not result in changes to the interagency  coordination practice.

Without an updated agreement between the state VR and educational  agencies, efforts to collaborate on pre-employment transition services  may be hindered. Officials with the National Technical Assistance Center  on Transition (NTACT) told us that some of the state agencies for which  they provided in-depth technical assistance were not working closely  together. Officials from two of the three state educational agencies we  interviewed said they viewed pre-employment transition services as  primarily the responsibility of the VR agency. State VR officials in all three  of our discussion groups said they have experienced coordination  challenges, including difficulty determining each agency’s responsibilities  for providing pre-employment transition services, obtaining data needed  to identify and provide services to students, and determining which  agency will pay for which services, among other challenges. Interagency  agreements can help to address these types of issues.

Federal internal controls recommend that management communicate with  and obtain information to identify, analyze, and respond to risks related to  achieving defined objectives, such as those that can arise from new laws  and regulations. Moreover, we found in prior work that it is important to  establish ways to operate across agency boundaries, with measures such  as developing common terminology and fostering open lines of  communication. A lack of collaboration between state VR and  educational agencies increases the risk that some students will not  successfully transition from school to post-school activities. In addition,  our prior work has identified lack of collaboration among and between  federal agencies and state and local governments as a challenge to  effective grant implementation. Interagency agreements are intended to  serve as a mechanism related to collaboration practices, which include  defining a common outcome, establishing joint strategies, and agreeing  on roles and responsibilities of each agency. By taking additional steps,  such as discussing the benefits of finalizing interagency agreements, and  reminding states of existing technical assistance resources pertaining to  updating and finalizing interagency agreements, Education would help  raise awareness about the importance of the agreements and be better  positioned to help states efficiently and effectively coordinate services to  students with disabilities.

States Reported That Best Practices Would Be Useful to Them in Implementing Services and Could Help Them Address Challenges

Most state VR agencies (63 of 74) that responded to our survey reported  that additional assistance with identifying best practices would be useful  to their agencies. Similarly, state VR officials in all three of our  discussion groups spoke to the need for Education to develop and  disseminate best practices to help states, for example, comply with  program requirements. WIOA requires Education to highlight best state  practices on pre-employment transition services. Best practices may  also help states address the challenges they reported facing in  implementing and administering pre-employment transition services for  students with disabilities, such as (1) coordinating with state educational  agencies, (2) using VR resources more efficiently and effectively to help  states balance providing pre-employment services with the full VR  program, and (3) collecting data on services provided, and (4) updating  data tracking systems.

Coordinating service delivery with state educational agencies.

Over half (41 of 74) of state VR agencies reported in our survey that  additional assistance on coordinating with state educational agencies  would be useful for them. Similarly, officials from all three state  educational agencies we interviewed said they would like additional  assistance on interagency collaboration. Officials with NTACT told us  that some of the state agencies for which they provided in-depth  technical assistance were not working closely together. Officials from  two of the three state educational agencies we interviewed said they  viewed pre-employment transition services as primarily the  responsibility of the VR agency. State VR officials in all three of our  discussion groups said they have experienced coordination  challenges, including difficulty determining each agency’s  responsibilities for providing pre-employment transition services,  obtaining data needed to identify and provide services to students,  and determining which agency will pay for which services, among  other challenges. An official we interviewed from the Idaho  Department of Education said it would be helpful to have more clearly  defined roles, obligations, and means of sharing data between the  state-level agencies. In written responses to our survey, one  respondent said having examples of highly successful collaborations  between a state educational agency and state VR agencies would be  helpful. According to Education’s guidance, a student’s transition from  school to post-school activities is a shared responsibility and  coordination and collaboration between the state VR and educational  agencies is essential. However, according to information Education  provided with the regulations, while some have sought clarification  and additional guidance in this area, Education determined that  decisions on agencies’ responsibilities must be made at the state level  to allow states maximum flexibility allowed under the law. In the  absence of more specific guidelines for how state agencies should  collaborate, best practices from other states could provide helpful  examples.

Balancing pre-employment transition services with VR services.

Several state VR agencies in both our written survey responses and  in discussion groups noted that by increasing services mandated for  pre-employment transition services for students, they have had to  reduce VR services to adults, which has made it difficult to balance  the two programs. In issuing its final regulations, Education  acknowledged that reserving funds would decrease amounts available  for the full VR program, resulting in a transfer of benefits from  individuals historically served by VR to students with disabilities in  need of transition services. According to state VR directors with the  National Council of State Agencies for the Blind (NCSAB), agencies  for the blind have had to restrict VR services while also not being able  to use all of the funds reserved for pre-employment transition services  for students with disabilities because VR services cannot be paid with  reserved funds. Most state VR agencies that completed our survey  (50 of 74) reported that balancing pre-employment transition services  with other vocational rehabilitation services was moderately difficult,  very difficult, or extremely difficult during federal fiscal year 2017.

Collecting data. Data collection was one of the top challenges  identified by state VR agencies in our survey, with 48 of 74 reporting  that collecting data on the provision of pre-employment transition  services was moderately difficult, very difficult, or extremely difficult  during fiscal year 2017. Prior to WIOA, agencies collected and  reported data only on individuals who had applied and enrolled in the  VR program. For pre-employment transition services, agencies now  collect data on who provided and received each of the five required  activities, including for individuals who have not submitted a VR  application. State VR officials in two of our three discussion groups  said that they have experienced challenges collecting sensitive  information (such as social security numbers) for minors and  collecting data on individuals for group services. Officials in one of the  three discussion groups also said that these problems are particularly  significant when trying to collect information on potentially eligible  students for whom they do not have open VR cases. These students  could include all those with an IEP and those that receive  accommodations in school based on their disability, among others.

Updating data tracking systems. Updating data systems was also  one of the top challenges reported in our survey, and was cited as an  additional administrative burden by state VR officials in our discussion  groups. Specifically, 53 of 74 state VR agencies reported that it was  moderately difficult, very difficult, or extremely difficult to update  tracking systems to collect and report financial and service data on  pre-employment transition services during fiscal year 2017. According  to a state VR agency official we interviewed, updating that state’s  tracking system is difficult because data collected on pre-employment  transition services—such as the type of service provider and how the  service was provided—do not fit well into a case management system  designed for the full VR program. Updating these tracking systems  also created an additional administrative burden for VR agency staff,  according to officials from all three discussion groups and three of the  four state agencies that we interviewed. Officials in two of our three  discussion groups said that they have one or more full-time staff  members doing only administrative tasks or that they have had to hire  additional staff to handle data tracking.

Education officials said that they plan to document and share best  practices with states; however, they said the agency does not have a final  written plan for managing these efforts because plans are still under  discussion in light of inquiries received. Education officials said they are  collecting information on state VR agencies’ practices through monitoring  and they are sharing this information with WINTAC—information that  could be useful for sharing best practices across states—but a  comprehensive summary of states’ efforts will not be available until after  Education officials conduct monitoring visits of all states by the end of  fiscal year 2021. In addition, in a 2015 technical assistance circular,  Education recommended that state VR agencies consult with other  federal, state, and local agencies to identify best practices for providing  pre-employment transition services to students and youth with a variety of  disabilities. Education officials also said that they are looking for  opportunities, such as webinars and conferences, to share information  with states. However, Education does not have set timeframes and has  not detailed the specific steps and activities for fully leveraging knowledge  to address common challenges, or for finalizing and disseminating best  practices. By doing so, Education would be better positioned to provide  best practices information to state VR agencies to better serve students  with disabilities who are transitioning from high school.

Pre-employment transition services are designed to help students with  disabilities begin to identify career interests and move from high school to  post-secondary education or employment. Using federal funding, state  VR agencies reported that they have generally enhanced their services  and staff capacity and begun to coordinate with state educational  agencies. As a result, state VR agencies generally reported serving an  increased number of students. However, most states reported they have  not used all the funds reserved for pre-employment transition services or  updated interagency agreements between state VR and educational  agencies. Education has developed multiple forms of guidance and made  presentations, either directly or through its technical assistance centers.  Education officials said they plan to issue additional guidance as needed.  However, without clear timeframes for the issuance of this guidance,  states do not know when information will become available to help them  make decisions on allowable expenditures for pre-employment transition  services. As a result, opportunities may be missed to identify and serve  all students who might be eligible, and unserved students could continue  to face difficulties preparing for a future of meaningful post-secondary  education or employment. In addition, agreements between state VR and  educational agencies can help facilitate the effective coordination of and  financial responsibility for services. Finally, WIOA requires Education to  highlight best state practices for implementing pre-employment transition  services. Developing a written plan with specific timeframes would help  Education provide states with information on best practices, such as  balancing service delivery between pre-employment transition services  and other VR services and collecting data that other states may have  successfully addressed.

We are making the following three recommendations to Education:  The Secretary of Education should establish timeframes for providing  states with additional information on allowable expenditures of funds  reserved for pre-employment transition services. (Recommendation 1)

The Secretary of Education should take additional steps to provide states  assistance on updating and finalizing their interagency agreements with  state educational agencies to include pre-employment transition services.  These steps could include, for example, accelerating their efforts to  discuss the benefits of finalizing interagency agreements, and reminding  states of existing technical assistance resources pertaining to updating  and finalizing interagency agreements. (Recommendation 2)

The Secretary of Education should develop a written plan with specific  timeframes and activities for identifying and disseminating best practices  that address, as appropriate, implementation challenges for pre- employment transition services, such as those identified in this report.  (Recommendation 3)

We provided a draft of this report to Education for review and comment.  Education’s written comments are reproduced in appendix III. Education  also provided technical comments, which we incorporated into our report  where appropriate.

Education concurred with recommendation 1 and disagreed with  recommendations 2 and 3 in the draft report.

With regard to recommendation 1, Education stated that it agreed and will  establish projected timeframes for providing states with additional  information on allowable expenditures for the provision of pre- employment transition services. Education also stated that it intends to  provide states with additional information in at least two forums before the  end of calendar year 2018 and to review and analyze previous guidance  provided to states on allowable expenditures.

With regard to the draft report’s recommendation 2, which called for  Education to identify states that have not updated and finalized their  interagency agreements to include pre-employment transition services,  Education stated that it disagreed, in large part, because there is no  statutory provision authorizing the agency to identify such states.  However, Education is taking some steps as part of its ongoing  monitoring of the VR program to provide assistance to states that have  not updated their interagency agreements, which is consistent with the  intention of our recommendation, but more could be done. Education  stated that it will continue to offer and provide technical assistance if it  becomes known through the onsite monitoring of the VR program or  through other means that states have not updated their interagency  agreements between VR agencies and state educational agencies. It also  noted that the Rehabilitation Services Administration (RSA) and its Office  of Special Education Programs will provide information related to sources  of technical assistance, as appropriate, to VR agencies and state  educational agencies. While these steps may be helpful, given the  number of states that have not updated and finalized their agreements  and the length of time Education officials say they will take to complete  this round of monitoring where Education asks state VR agencies about  these agreements, additional action by Education may be needed to help  states more efficiently and effectively coordinate services to students with  disabilities.

Education also wrote that while the Rehabilitation Act requires an  interagency agreement, the Individuals with Disabilities Education Act  does not contain a parallel requirement for state and local educational  agencies with respect to the provision of pre-employment transition  services or the incorporation of such discussion into the interagency  agreement. In light of these differing requirements, as we state in our  report, stakeholders with whom we spoke indicated it can be difficult to  get state educational agencies to work with state VR agencies to update  interagency agreements. Therefore, it is all the more important for  Education to take additional action to engage with VR agencies regarding  interagency agreements and to work closely with VR agencies as  Education becomes aware of states that have not updated their  agreements.

Education suggested a modified recommendation that removed reference  to Education identifying states that have not updated and finalized their  agreements. We modified the recommendation and the report to address  Education’s concerns about its authority to identify states. By taking  additional steps, such as discussing the benefits of finalizing interagency  agreements, and reminding states of existing technical assistance  resources pertaining to updating and finalizing interagency agreements,  Education would help raise awareness about the importance of the  interagency agreements and be better positioned to help states efficiently  and effectively coordinate services to students with disabilities.

With regard to recommendation 3, Education stated that it disagreed  because it is premature to develop a timeline for the dissemination of best  practices. Education stated that the identification of “best” practices,  meaning those that are clearly supported by a body of evidence derived  from valid and reliable research findings, is still emerging as states  implement the requirements. Education suggested a modified  recommendation that included planning for the dissemination of best  practices identified by states as they become available. Education stated  in its comments that as RSA identifies best practices through its  monitoring and technical assistance activities, it will, in collaboration with  its Office of Special Education Programs, consider when and how best to  disseminate this information to state VR and educational agencies. With  regard to including specific timeframes and activities in a written plan, by  detailing the specific steps Education is taking and plans to take along  with the amount of time it expects them to take, Education would be  better positioned to complete those steps in a timely manner and meet  the statutory requirement that Education highlight best state practices and  support state agencies.

As agreed with your office, unless you publicly announce the contents of  this report earlier, we plan no further distribution until 30 days from the  report date. At that time, we will send copies to the appropriate  congressional committees and the Secretary of Education. In addition, the  report will be available at no charge on the GAO website at  http://www.gao.gov.

If you or your staff have any questions about this report, please contact  Elizabeth H. Curda at (202) 512-7215 or curdae@gao.gov. Contact points  for our Offices of Congressional Relations and Public Affairs may be  found on the last page of this report. GAO staff who made key  contributions to this report are listed in appendix IV.

Appendix I: Objectives, Scope, and Methodology

The objectives of this report are to examine (1) the steps states have  reported taking to implement pre-employment transition services, and (2)  the implementation challenges, if any, states reported facing, and how the  Department of Education (Education) has addressed them.

To address these objectives, we reviewed federal laws and regulations,  and Education’s guidance and technical assistance documents, including  circulars, policy directives, and transition guides. We also reviewed  expenditure data reported by state vocational rehabilitation (VR) agencies  to Education for fiscal years 2015 and 2016, the most recent full years of  data available. To assess the reliability of the data, we interviewed  Education officials about their collection of the data and their opinion of  the data’s quality, completeness, and accuracy. We also electronically  tested the data for any obvious errors. We determined that the data were  reliable for the purposes of our review. We interviewed representatives  from the Council of State Administrators of Vocational Rehabilitation  (CSAVR) and the National Council of State Agencies for the Blind. In  addition, we interviewed officials from Education’s Office of Special  Education and Rehabilitation Services, Rehabilitation Services  Administration, Office of Special Education Programs, and the Workforce  Innovation Technical Assistance Center and National Technical  Assistance Center on Transition—two technical assistance centers  funded by Education.

Survey of State Vocational Rehabilitation (VR) Agencies

To address both of the objectives, we conducted a survey of all 79 state  VR agencies from October through December 2017. Seventy-four of the  79 agencies (94 percent) responded. The survey questionnaire included  open-ended and closed-ended questions about agencies’ efforts to train  staff, update interagency agreements, expand services to students with  disabilities, and other issues. We took steps to minimize the potential  errors that may be introduced by the practical difficulties of conducting  any survey. Because we selected the entire population of VR agencies for  our survey, our estimates are not subject to sampling error. We  conducted pretests of the draft questionnaire with three agencies in the  population and made revisions to reduce the possibility of measurement  error from differences in how questions were interpreted and the sources  of information available to respondents.

We reviewed state officials’ submitted survey responses and conducted  follow-up, as necessary, to determine that their responses were complete,  reasonable, and sufficiently reliable for the purposes of this report. A  second independent analyst checked the accuracy of all computer  analyses we performed to minimize the likelihood of errors in data  processing. We made multiple follow-up attempts during the survey with  agencies that had not yet responded. The five agencies that did not  respond had smaller values, on average, on three characteristics related  to size, than those that did respond. The nonrespondents tended to be  smaller than respondent agencies. The sums totals for each of these  three characteristics across the five nonresponding agencies comprised  less than 1 percent of the totals for the population, suggesting a lower  possibility of material error in our results from nonresponse.

Interviews and Discussion Groups with State VR Agencies

For more in-depth information on both of the objectives, we conducted  interviews and held discussion groups. We conducted interviews with  officials in Idaho, Illinois, and Maryland. For each state, we interviewed  state VR officials and state educational agency officials. We selected  these states for variety using the following criteria: size of the special  education population (large, medium, and small); state agency  organization, for example, whether the VR agency was organized under  the state’s educational or other department; and whether the state had a  second agency for serving individuals who are blind or visually impaired.

We convened three discussion groups with state VR agency directors or  their designated officials, with a total of 39 participants from 29 separate  agencies (10 to 12 agencies represented per discussion group). These  discussion groups took place during a conference of state VR directors in  November 2017 in Greenville, South Carolina. To select participants, we  worked with the conference organizer, CSAVR, to send invitations for our  discussion groups to all conference attendees. We additionally included a  question in our survey asking respondents whether they would like to  participate in discussion groups at the conference, and contacted those  who responded affirmatively via phone and email. We moderated each  discussion to keep participants focused on the specified issues within  discussion timeframes.

To assess Education’s efforts to address state VR agencies’ challenges  in providing pre-employment transition services, we applied standards for  internal control in the federal government. Specifically, we applied  principle 15 related to communicating with external parties. In addition,  regarding Education’s assistance to state VR agencies’ efforts to update  interagency agreements with state educational agencies, we also applied  key considerations for implementing interagency collaborative  mechanisms that we have previously identified.

We conducted this performance audit from February 2017 to September  2018 in accordance with generally accepted government auditing  standards. Those standards require that we plan and perform the audit to  obtain sufficient, appropriate evidence to provide a reasonable basis for  our findings and conclusions based on our audit objectives. We believe  that the evidence obtained provides a reasonable basis for our findings  and conclusions based on our audit objectives.

Appendix II: WIOA Authorized Activities for Pre-employment Transition Services

Appendix III: Comments from the United States Department of Education

Appendix IV: GAO Contact and Staff Acknowledgments

Elizabeth H. Curda, (202) 512-7215 or curdae@gao.gov.

In addition to the contact named above, Sara Schibanoff Kelly (Assistant  Director), Paul Schearf (Analyst-In-Charge), Matthew Rabe, and Paul  Wright made key contributions to this report. Also contributing to this  report were James Bennett, Kristy Kennedy, Sheila R. McCoy, Thomas  James, Jessica Orr, Sam Portnow, Carl Ramirez, Monica Savoy, Kate  Van Gelder, Adam Wendel, and James Whitcomb.

Workforce Innovation and Opportunity Act: States and Local Areas  Report Progress in Meeting Youth Program Requirements. GAO-18-475.  Washington, D.C.: June 15, 2018.

Supplemental Security Income: SSA Could Strengthen Its Efforts to  Encourage Employment for Transition-Age Youth. GAO-17-485.  Washington, D.C.: May 17, 2017.

Youth with Autism: Federal Agencies Should Take Additional Action to  Support Transition-Age Youth. GAO-17-352. Washington, D.C.: May 4,  2017.

Youth with Autism: Roundtable Views of Services Needed During the  Transition into Adulthood. GAO-17-109. Washington, D.C.: October 18,  2016.

Students with Disabilities: Better Federal Coordination Could Lessen  Challenges in the Transition from High School. GAO-12-594. Washington,  D.C.: July 12, 2012.