Section 503 Readiness Training

1. Section 503 Readiness Training Partnering with American Job Centers, Voluntary Disability Disclosure, and Outreach & Recruitment Requirements January 9, 2014

2. Presenters Kevin Nickerson Technical Assistance Team National Disability Institute knickerson@ndi-inc.org Susan Webb Vice President of Employment Services/Business Development ABIL Employment Services SusanW@abil.org

3. Objectives • Explain what American Job Centers (AJC) are and how you can partner with them • Explain and ensure understanding of the rules for voluntary disability disclosure • Provide an overview of essential components of an Affirmative Action Plan • Provide an overview of required outreach

4. What Employment Networks Should Know about American Job Centers National Disability Institute Kevin Nickerson, Technical Assistance Team

5. Overview • American Job Center (AJC) Resources • Partnering with your AJC • AJC Staffing – Who you should know • Next Steps • Additional Resources

6. Overview: American Job Centers What are American Job Centers? • AJCs are located across the country and provide a variety of services to both employers and job seekers, including individuals with disabilities.

7. Customer-focused Services that AJCs Provide to Job Seekers • Workshops • Training funds, known as Individual Training Accounts (ITA) (based on eligibility) • Resume development • Labor Exchange system – Electronic matching of job seekers with employers • On-the-Job Training funds (based on eligibility) • Labor Market Information • Employer connections

8. AJC History: Serving Customers with Disabilities • The US Department of Labor (DOL) has supported the expansion of services for customers with disabilities through targeted initiatives, since the inception of the Workforce Investment Act of 1998 • Disability Program Navigator Initiative (DPN) – purpose • Focused on partnerships • Improved access to services • Expanded the workforce development system's capacity to serve the needs of customers with disabilities • Disability Employment Initiative (DEI) – purpose • To improve access to services and build collaboration • Operating an Employment Network is a core requirement • Building effective community partnerships that leverage public and private resources to better serve individuals with disabilities

9. Partnering with AJCs • Know the history of the AJC you are approaching – • Has it been involved with previous disability grants? (Check their website to discover this and other information.) • If it was, what results did it have? (i.e. DPN grant, notable activities) • Understand the Workforce Investment Board (WIB) Director, and his/her position on disability and employment. • Know what you bring to the table (i.e. the resources you can offer). • Make sure expectations are clear! (i.e. who will do what) • Are they currently operating as an Employment Network (EN) and who is the EN point of contact? (if AJC is a Disability Employment Initiative (DEI) pilot it is mandatory they operate as an EN)

10. AJC Staffing Structure for Job Seekers • Employment Counselor: Most offices have a staff member who is able to administer assessments, which is often helpful for Ticket Holders who may require a change in career. Additionally, they may assist with coordinating services within the Job Center (with other AJC staff) and interview and resume preparation. • WIA Case Manager: Oversees the services of customers enrolled in intensive case management services and/ or short-term training. The WIA Case Manager may also help identify customers in need of training services and may be the staff person identifying job seekers and employers to utilize on-the-job training. • Targeted Populations : Most offices will have staff dedicated to serving customers with specific needs, such as: • Veterans Representative • Older Worker program • Disability Resource Coordinators (DRC – funded in DEI states)

11. AJC Staffing Structure for Employers • Business Service Representative (BSR) or BSR Team -This staff is the AJC first and single point of contact for businesses. The BSR: • Explains the benefits of the job bank to employers • Serves as the HR liaison (e.g., assists with employment application reviews, provides required labor law information, makes referrals to Federal agencies, etc.) • Conducts outreach to the business sector (and provides information on the benefits of hiring qualified target populations, e.g., tax credits – Work Opportunity Tax Credit (WOTC), Federal Bond Program, recruitment resources, etc.) • Promotes on-the-job training opportunities • Arranges job fairs • Aids employers in writing position descriptions • Advises on job retention issues • Provides information on prevailing  wages and other LMI • Links to targeted programs in the AJC (e.g., DEI, REXO, etc.) 11

12. NYS DEI focused intensely on the Ticket to Work program, and serving beneficiaries, using an individualized assessment process to determine which customers were most “work oriented”, and to determine appropriate services they would require, which often lead to referrals to ACCES-VR, and/or other resources. If the Ticket Holder required a level of service our Job Centers could provide, we assigned the Ticket and worked directly with the customer, often utilizing other partner agency resources as part of the plan (IRT). Additionally, and key to success with our Ticket Holders, is the CWIC, or similar, certification that each Disability Resource Coordinator holds, in order to provide timely, and accurate information about benefits and Work Incentives. NYS DEI EN Efforts in Review

13. KEY TICKET STATISTICS for NYS DEI: Total Tickets assigned by September 30, 2013, by DEI Pilot sites was 407 Total Estimated Revenue produced by DEI Pilot sites, as of September 30, 2013, including money received, and/or due, was $455,974 Total number of unique payments, or, total number of Ticket holders that some form of EN payment is being generated through 9/30/13, was 124 Total number of Ticket Holders in Outcome payment status, and NOT receiving benefits, was 37! (Note: Approximately 8 more cases will achieve Outcome status, according to reports from our DEI Pilot sites, by January, 2014) NYS DEI EN Efforts in Review cont.

14. NYS DEI EN Efforts in Review cont. • Percent of total tickets assigned, that are currently OFF benefits rolls = 9.1% • The Return on Investment: • A Government Accountability Office (GAO) report indicated between 250-300K is saved in taxpayer dollars for each beneficiary we help leave the benefits roles, and in achieving self-sufficiency, over their lifetime • Since our grant was approximately 5 Million dollars, if 17 Ticket holders achieve self-sufficiency, using the 300K figure, we have saved the equivalent of the grant funding we received, and more! • Based on our achievement of 37 customers who achieved self-sufficiency, cost savings could reach over $11,000,000!

15. Note: Iowa is a Round 3 DEI state project, funded in 2012, and is a former recipient of the Disability Program Navigator initiative funding

16. Next Steps in Partnering with AJC’s Research the history of your AJC involvementwith previous and current grantsfocused on improving services for customers with disabilities Discover whothe AJC Manager and EN Coordinator (if applicable) are, and schedule time to meet with them to discuss your interest of working with Federal contractors and access to the Business Services Representative (or team) Understand the ability of your EN to provide qualified job seekers with disabilities to Federal contractors (speak to capacity) With the AJC Business Services Team, developa local process for accessing job leads from Federal contractors, that meets the needs of all parties 16

17. Additional Resources: Have a question? Check these sites. • To review the Final Report on the Disability Program Navigator Initiative: https://disability.workforce3one.org/view/2001103676712177340/info • For more information about DEI: https://disability.workforce3one.org/page/tag/dei_project • To learn more about education and training options available through America’s Job Centers see: http://www.doleta.gov/business/TrainingEducation.cfm

18. Thank you! CONTACT INFORMATION: Kevin Nickerson NDI Technical Assistance TeamPhone: 607-272-7570 Ext. 136 Email: krnickerson@ndi-inc.org

19. Voluntary Disability Disclosure ABIL Employment Services Susan Webb

20. Learning Objectives • Participants will: • Understand the disability disclosure provisions of §60-741.40 • Be aware of how ENs fit into the outreach requirements Federal contractors must conduct

21. Invitation to Self-Identify • Definition of disability can be found at http://www.dol.gov/ofccp/regs/compliance/section503 (See §60-741.2 Definitions) • Incumbent within one year of when contractor is required to do so – each five years after that

22. Ensuring Privacy and Non-Discrimination • Employer can ask if a disability exists but not what it is • Must keep disclosure in a separate file from personnel/medical file • May not compel or coerce an individual to self-identify

23. Disclosure Dilemma • The Americans with Disabilities Act Amendments Act of 2008 (ADAAA) returned the definition to broader function-based criteria • Consequently, it is easier for people to identify as having a disability • Employer cannot ask for proof • How can we avoid people claiming to have a disability when they really do not? • Employers could conceivably offer a “perk” to identify – e.g. gift card

24. Affirmative Action Plan • Policy Statement – post it and designate a specific person as the contact • Shall state that contractor will recruit, hire, train, and promote persons with disabilities in all job titles • Personnel actions are administered without regard to disability • Employment decisions are based only on valid job requirements

25. Affirmative Action Plan continued • Personnel process review • Ensure careful consideration of qualifications of applicants and employees • Schedule regular reviews and updates of job descriptions and personnel practices • Physical and mental qualifications shall not have the effect of screening out Persons with disabilities

26. Required Outreach • Linkage Agreements no longer required • Rules are specific to include ENs, State Vocational Rehabilitation (VR) agencies, and AJCs in outreach activities • “The contractor should take . . . Steps . . . To attract individuals with disabilities not currently in the workforce” (see: §60-741.44 Required contents of affirmative action programs at http://www.dol.gov/ofccp/regs/compliance/section503) • State VR agencies and ENs listed to meet this particular goal • Must consider applicants for all available positions when position applied for is unavailable

27. Internal Dissemination • Outreach not effective without internal supervisory and management cooperation • Include A/A policy statement • Policy Manual • Union notification • All employees and prospective employees • Publicize in company newspaper, magazine, annual report • Conduct special meetings of executive, management, and supervisory personnel • Employee orientation and management training

28. Data Collection • Contractors required to collect and report • Number of applicants who self-identified • Total number of job openings and jobs filled • Total number of applicants for all jobs • Number of applicants with disabilities hired • Total number of applicants hired

29. Thank you! CONTACT INFORMATION: Susan Webb, Director ABIL Employment Services 5025 E. Washington Street Suite 200 Phoenix, AZ 85034 e-mail: SusanW@abil.org

30. Questions?

31. For More Information Contact OFCCP • Visit the OFCCP website: www.dol.gov/ofccp/ • Call OFCCP toll-free: 1-800-397-6251 (TTY: 1-877-889-5627) • Email OFCCP: OFCCP-Public@dol.gov. • Contact or visit the OFCCP field office nearest you. The OFCCP office directory is available at: http://www.dol.gov/ofccp/contacts/ofnation2.htm Visit the Ticket to Work for Service Providers website at: https://yourtickettowork.com/web/ttw/503-resources Attend the OESP monthly Section 503 training series.