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Disability Coordinator Orientation Kimberly Jones, Regional Disability Coordinator

Disability Coordinator Orientation Kimberly Jones, Regional Disability Coordinator. Objectives. Provide an overview of PRH Disability Program requirements. 1. Review relevant resources and tools available to assist disability coordinators (DCs) in meeting disability-related requirements.

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Disability Coordinator Orientation Kimberly Jones, Regional Disability Coordinator

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  1. DisabilityCoordinator Orientation Kimberly Jones, Regional Disability Coordinator

  2. Objectives Provide an overview of PRH Disability Program requirements 1 Review relevant resources and tools available to assist disability coordinators (DCs) in meeting disability-related requirements 2

  3. Disability Program Requirements Recent Changes • Disability Program is now its own section in PRH, Chapter 6 – Section 6.14 Why? • To change perception of disability as only a health and wellness program and ensure a center wide focus • To clarify and ensure consistency among existing requirements; additional requirements have not been created

  4. PRH 6.14 Disability Requirements

  5. PRH 6.14 Disability Requirements Resource: • Job Corps Disability website – Disability Coordinator Orientation section

  6. PRH 6.14, R1 Disability Coordinators

  7. PRH 6.14, R1 Disability Coordinators Requirements: PRH 6: Section 6.14, R1 (a-b) • Appoint DCs to oversee the program • The health and wellness manager (or a health staff designee) and academic manager (or an academic staff designee) will function as DCs to oversee the program • May choose to a hire full or part time DC rather than appoint DCs in academic and health • The roles and responsibilities of each of the DCs will be defined in an Standard Operating Procedure (SOP)

  8. PRH 6.14, R1 Disability Coordinators As a DC, your responsibilities include: • Ensuring that all required Disability Program components are implemented, monitored, and maintained in an effective manner • Demonstrating commitment and soliciting buy-in to disability initiative (leadership) • Delegating responsibilities • Encouraging all staff to take ownership of the program

  9. PRH 6.14 Disability Requirements Resource: • Job Corps Disability website – Disability Coordinator SOP

  10. PRH 6.14, R2 Applicant File Review

  11. PRH 6.14, R2 Applicant File Review Requirements: PRH 6: Section 6.14, R2 (a-c) • Applicant file review process should be defined in SOP • Applicant files must be processed in 30 days

  12. PRH 6.14, R2 Applicant File Review Requirements: PRH 6: Section 6.14, R2 (a-c) • All center procedures must include: • A file tracking method – Location where files are sent and logged through final disposition • Responsibilities and roles of team members • Process for reviewing files to include denial process • Process for reasonable accommodation • Process for withdrawals • Timeframe to complete the process • Storage, transmission and maintenance of the file (Appendix 607) * Note these requirements are also outlined in (PRH 1:1.4 R1-4 and Appendix 107)

  13. PRH 6.14, R2 Applicant File Review Resources: • Webinar – Center Responsibilities in the Applicant File Review Process (Administrative Process) • Webinar – Center Responsibilities in the Applicant File Review Process (Health Care Needs/Direct Threat)

  14. PRH 6.14, R3 Reasonable Accommodation

  15. PRH 6.14, R3 Reasonable Accommodation Requirements: PRH 6: Section 6.14, R3 (a-c) and Appendix 605 • Defined in an SOP (PRH 5: Exhibit 5-1) a process: • for applicants/students to request and receive reasonable accommodations (RA) and • to ensure applicant/students who request accommodations and/or provide documentation engage in the interactive process to consider/determine functional limitations

  16. Process Then Process Now PRH 6.14, R3 Reasonable Accommodation • Request • Documentation • Reviewing a request • Evaluating a request • Denying a request • Developing an accommodation plan • Notification • Determining accommodation effectiveness • Recordkeeping • Request • Determination of need • Ensuring appropriate documentation • Reviewing a request • Determining reasonableness • Entering the accommodation plan • Notification/Viewing the plan • Documenting the process • Maintain the accommodation file • Storing accommodation and disability documentation

  17. PRH 6.14, R3 Reasonable Accommodation Requirements: PRH 6: Section 6.14, R3 (a-c) and Appendix 605 • The DCs will coordinate the center’s reasonable accommodation process • During Career Transition Readiness all students will receive information about workers rights and responsibilities including reasonable accommodation in the workplace (3.21, R2 (g))

  18. PRH 6.14, R3 Reasonable Accommodation Resources: • PRH – Appendix 605 Job Corps Reasonable Accommodation Guidelines • Webinar – Reasonable Accommodation Process • Job Corps Disability website – Reasonable accommodation section • Job Corps Disability website – The RAC Guide

  19. PRH 6.14, R3 Reasonable Accommodation Resources: Job Corps Disability website – Tools for Staff: Career Transition Counselors

  20. PRH 6.14, R4 Introduction to Center Life

  21. PRH 6.14, R4 Introduction to Center Life Requirements: PRH 6 Section 6.14, R4 (a-c) • Provide new students with information leading to an understanding of opportunities and benefit available with the Disability Program (PRH 2: 2.2, R1 (b11)) • Provide a variety of opportunities to meet and interact with the DCs (PRH 2.2, R1 (d4))

  22. PRH 6.14, R4 Introduction to Center Life Requirements: PRH 6: Section 6.14, R4 (a-c) • The student handbook will include information about the Disability Program (PRH 2: Section 2.2, R2)

  23. PRH 6.14, R4 Introduction to Center Life Resources: • Brochure – Reasonable Accommodation Brochure available on the Job Corps Disability website can be customized for your center • Webinar – Disability Sensitivity Inclusive Environments

  24. PRH 6.14, R4 Introduction to Center Life Resources: • Job Corps Disability website – DC pictures with name and titles • Job Corps Disability website – Sample student handbook language that can be customized for your center

  25. PRH 6.14, R5 CIS Disability Data and Accommodation Plans

  26. PRH 6.14, R5 CIS Disability Data and Accommodation Plans Requirements: PRH 6: Section 6.14, R5 (a-f) • A DC accurately enters the required data in the disability data collection and accommodation plan icons in CIS after student arrives Job Corps is required to collect data on the number and types of participants with disabilities served by the program

  27. PRH 6.14, R5 CIS Disability Data and Accommodation Plans • The ADA, now known as the Americans with Disabilities Act Amendments Act (ADAAA), was reauthorized in 2009, certain changes to this law affect how we determine who is considered a person with a disability. • The requirements that directly affect Job Corps are outlined in the Background section of PRH Appendix 605.

  28. PRH 6.14, R5 CIS Disability Data and Accommodation Plans What is the definition of a disability? • A disability is a physical or mental impairment that substantially limits one or more major life activities…

  29. PRH 6.14, R5 CIS Disability Data and Accommodation Plans What is a physical impairment? • A physical impairment is any physiological disorder or condition, cosmetic disfigurement, or anatomical loss affecting one or more of the following body systems:

  30. PRH 6.14, R5 CIS Disability Data and Accommodation Plans What is a mental impairment? • A mental impairment is any mental or psychological disorder, such as intellectual disability, organic brain syndrome, emotional or mental illness, and specific learning disabilities.

  31. PRH 6.14, R5 CIS Disability Data and Accommodation Plans What are major life activities?

  32. PRH 6.14, R5 CIS Disability Data and Accommodation Plans What is are major life activities? • Other major life activities include the operation of a major bodily function, including functions of the immune system; special sense organs and skin; normal cell growth; and digestive, genitourinary, bowel, bladder, neurological, brain, respiratory, circulatory, cardiovascular, endocrine, hemic, lymphatic, musculoskeletal, and reproductive functions. The operation of a major bodily function includes the operation of an individual organ within a body system.

  33. PRH 6.14, R5 CIS Disability Data and Accommodation Plans Substantial Limitation Determination When making a determination on whether an individual is substantially limited in performing a major life activity: • The term “substantially limits” should be construed broadly in favor of expansive coverage; “substantially limits” is not meant to be a demanding standard and the determination should not require extensive analysis. • The determination requires an individualized assessment.

  34. PRH 6.14, R5 CIS Disability Data and Accommodation Plans Substantial Limitation Determination • An impairment need not prevent, or severely or significantly limit a major life activity in order to be considered substantially limiting. Nonetheless, every impairment does not constitute a disability. • An impairment is a disability if it substantially limits the ability of an individual to perform a major life activity as compared to most people in the general population.

  35. PRH 6.14, R5 CIS Disability Data and Accommodation Plans Substantial Limitation Determination: Mitigating Measures • When determining whether a person is substantially limited in a major life activity, the beneficial effects of mitigating measures, except ordinary eyeglasses or contact lens, will be ignored. • Mitigating measures are things such as medications, medical equipment or supplies, hearing and mobility support devices, prosthetics, assistive technology, therapy, etc.

  36. PRH 6.14, R5 CIS Disability Data and Accommodation Plans Substantial Limitation Determination and Mitigating Measures • This means that someone who is stable on medication can still be considered an individual with a disability. • If the use of mitigating measure causes any limitations, they will be considered • The use of a mitigating measure cannot be required

  37. PRH 6.14, R5 CIS Disability Data and Accommodation Plans Substantial Limitation Determination: Episodic or Remission • An impairment that is episodic or in remission meets the definition of disability if it would be substantially limiting when it is active • Examples of impairments that may be episodic include epilepsy, hypertension, asthma, diabetes, major depressive disorder, bipolar disorder, and schizophrenia

  38. PRH 6.14, R5 CIS Disability Data and Accommodation Plans Substantial Limitation Determination: Temporary Conditions • The effects of an impairment lasting less than six months can be substantially limiting if sufficiently severe. Typically, impairments that last only a short period of time are not covered. • For example, the individual may have a severe injury such as a broken back, etc.

  39. PRH 6.14, R5 CIS Disability Data and Accommodation Plans Impairments That Are Virtually Always Substantially Limiting • Deafness substantially limits hearing • Blindness substantially limits seeing • An intellectual disability substantially limits brain function • Partially or completely missing limbs or mobility impairments requiring the use of a wheelchair substantially limit musculoskeletal function • Autism substantially limits brain function • Cancer substantially limits normal cell growth

  40. PRH 6.14, R5 CIS Disability Data and Accommodation Plans Impairments That Are Virtually Always Substantially Limiting • Cerebral palsy substantially limits brain function • Diabetes substantially limits endocrine function • Epilepsy substantially limits neurological function • Human Immunodeficiency Virus (HIV) infection substantially limits immune function • Multiple sclerosis substantially limits neurological function

  41. PRH 6.14, R5 CIS Disability Data and Accommodation Plans • Get past the definition of disability ‒ Do not spend a lot of time analyzing whether a student meets the definition of disability; the disability assessment should be done quickly and not demand extensive analysis. • The disability data collection process is not an exact science, use your best judgment, be consistent, and be prepared to explain your rationale.

  42. PRH 6.14, R5 CIS Disability Data and Accommodation Plans Questions to consider in determining when to count students as having a disability • Does the student have a physical or mental impairment? • What major life activity(ies) are impacted? • Does the impairment substantially limit the student from performing the major life activity(ies) as compared to most people in the general population? • If the impairment is episodic or in remission; would it be substantially limiting when it is active?

  43. PRH 6.14, R5 CIS Disability Data and Accommodation Plans Questions to consider in determining with to count students as having a disability • Is the impairment one that is considered virtually always substantially limiting? • If the student is taking medication or using some other mitigating measure, • what would his/her condition be like without the benefit of medication or other supports? • what were the symptoms and the student’s condition prior to the benefit of medication or other supports? • Is the use of a mitigating measure causing any limitations?

  44. PRH 6.14, R5 CIS Disability Data and Accommodation Plans • How long are the effects of an impairment expected to last? If fewer than 6 months, how severe is the impairment?

  45. PRH 6.14, R5 CIS Disability Data and Accommodation Plans • A lot more individuals will be substantially limited ‒ Remember, the ADAAA reminds us to interpret the definition of disability in favor of broad coverage; when in doubt enter the disability and move on, the focus should be on the interactive process to determine the need for accommodation.

  46. PRH 6.14, R5 CIS Disability Data and Accommodation Plans Requirements: PRH 6: Section 6.14, R5 (a-f) b) TABE testing accommodations entered prior to the administration of the first TABE test

  47. PRH 6.14, R5 CIS Disability Data and Accommodation Plans Requirements: PRH 6: Section 6.14, R5 (a-f) • Only the DCs will have access to the CIS disability data entry screens • Generally only DCs will have access to the entry screen; however designee can be appointed and given access to enter accommodation plans

  48. PRH 6.14, R5 CIS Disability Data and Accommodation Plans Requirements: PRH 6: Section 6.14, R5 (a-f) • All center staff providing accommodations will have access to the accommodation plan report in CIS * Talk with center POC to ensure appropriate access has been provided to staff

  49. PRH 6.14, R5 CIS Disability Data and Accommodation Plans Requirements: PRH 6: Section 6.14, R5 (a-f) • Accommodation plans will not contain any medical or diagnostic information • This may include: • Disclosure of disability • Reference to types of documentation (IEP, Evaluations) • Prescription information • Psychological or Medical evaluations/test results • Health-related case management notes • References to treating provider or facility (AA meetings, Therapy appts) • Should be maintained in student health record X

  50. PRH 6.14, R5 CIS Disability Data and Accommodation Plans Resources: PRH 6: Section 6.14, R5 (a-f) • Job Corps Community website – CIS Wellness and Accommodation Module Technical Guide • Switched from CIS to CIS 3G as of 5/20/13 • Wellness Accommodation Access Graphic • Webinar – Provided by JCDC

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