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Disability Coordinator Orientation Job Corps

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joanna

2021-9-26 published at Occasions/ Family category

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1.1 Disability Coordinator orientation: Part 1 applicant file review Center Process
2.Disability Coordinator Orientation Series Part 1: Applicant File Review Part 2: Reasonable Accommodation Part 3: General DC Orientation and Remaining Disability Program Requirements 2
3.Objectives Describe the process steps involved in making applicant file recommendations. Describe the responsibilities and roles of File Review Team (FRT) members versus the Reasonable Accommodation Committee (RAC) members. List the allowable reasons for recommending denial of an applicant. List the allowable reasons for returning an applicant file to the Admissions Counselor to process as a withdrawal of application. Describe specific factors that trigger a reasonable accommodation review within the applicant file review assessment process. objectives
4.Applicant file review (AFR)process Policy/ Background ePRH 6.14 (R2) Disability Coordinator Orientation Part 1
5.AFR Standard Operating Procedure (SOP) 5 The AFR SOP must describe how an applicant file is processed from the time it arrives on center until the applicant is either: Each center is required to have a written SOP for AFR. accepted into the program and assigned a start date, or recommended for denial and a final disposition made by the Regional Office.
6.AFR Standard Operating Procedure (SOP) SOP Requirements: Method of tracking and logging of the file from arrival to the center to the final disposition Responsibilities and roles of File Review Team (FRT) members Procedures for reviewing an applicant file to include the allowable reasons for recommending denial of an application (see “Application Outcomes”) Procedures for reviewing and determining reasonable accommodation 6
7.Sample SOP Job Corps Disability Website Disability Frequently Requested Documents Sample Policies 7 Recommendation: Use the sample AFR SOP from the JC Disability Website!!!
8.AFR Policy KEY Points! Policy must include all PRH requirements Policy must be implemented Actual practice must reflect written policy process 8 Appendix 107 Chapter1 Section 1.4; Chapter 6 Section 6.14
9.Enrollment, recommendation of denial Application outcomes Disability Coordinator Orientation Part 1
10.Enrollment Center enrolls applicant. Sample text Hello friends this is a simple and easy to modify the slide which is a fashion trend of the template Hello friends Glad you chose him I wish you a happy life Application Outcomes Health care needs Applicant’s health care needs exceed those of basic health care. Direct threat Applicant poses a direct threat to self or others. eligibility Applicant may no longer be eligible due to new information that the AC could not have reasonably known at the time of eligibility certification. 10
11.“New Information” Recommendation of Denial in Brief Criteria New information disclosed AFTER AC has certified applicant as eligible. New information is related to eligibility criteria in Exhibit 1-1 of the ePRH. Examples: Incarceration after certification of eligibility; conviction of a crime such as sexual assault after certification of eligibility. NOT “New Information” Disclosure of medical or mental health condition(s). Medical or mental health stability or non-compliance with treatment provider regimen including medication non-compliance. 12
12.Disability Status If you receive an applicant file of someone who is older than 25 years of age, review the included medical/educational documentation to determine disability status. If the documentation supports that the individual is a person with a disability, the file review process continues and NO other steps are required. If there is no documentation or the documentation does not support that the individual is a person with a disability, then you must submit the Center Recommendation of Denial Form (Attachment B) from Appendix 107 to your respective Regional Office for Review. 12
13.CRDF – Disability Status 13 Summarize why the center does not believe this applicant to be a person with a disability.
14.Withdrawals of Application 14 The file review team (FRT) and/or the Reasonable Accommodation Committee (RAC) cannot reach the applicant, even with the AC’s assistance, to complete the clinical interview, or complete the required interactive reasonable accommodation process. Center must contact the AC to check for possible new contact info/obtain status information. This contact must be documented. Applicant states or puts in writing that s/he no longer wishes to enroll in the program.
15.Withdrawals of Application while in Regional Review If the applicant file is in regional review and the file has been returned to the center to complete any portion of the AFR process AND If the clinical team then cannot reach the applicant, even with the AC’s assistance, to complete the clinical interview or If the DCs cannot complete the required interactive reasonable accommodation process, then the applicant file must be returned to the person/office that sent the center the file and not back to AC. 15
16.AC Requesting Return of Applicant File in Center Review If the AC requests the center return an applicant’s file, should the center automatically do so? It depends… The center has custody of the applicant file and responsibility for making a decision on that individual’s application to the program. So, the center should only release a file back to the AC when it has been requested via appropriate policy allowances. Obtain written requests for the file via email that you can retain as documentation of why the file was returned. ACs may do the same of you when you return files to them! 16
17.Applicant Hospitalized (Guidance) Center file review team (FRT) and/or the reasonable accommodation committee (RAC) learns that the applicant is hospitalized – what should occur now? FRT and/or the RAC attempt to contact applicant via existing contact numbers on the ETA 652 or updated numbers of current residence. FRT leaves voicemails or message for applicant to call back if unable to reach applicant via these contact numbers. Give applicant reasonable call back timeframe. If applicant does not is not able to return call, the applicant file is returned to the AC to process as a w/drawal (e.g., incomplete application). 17
18.Documenting Contact with the Applicant Maintain a contact log Document the following with each contact attempt: Date of the contact, the medium used such as phone, email, etc. and the outcome of the call Contact the AC and ask to assist if unable to reach the applicant 18 TIP!! Leave a call back by date if you are unable to reach the applicant but can leave a voicemail.
19.For processing applicant files Timelines Disability Coordinator Orientation Part 1
20.Timelines The applicant’s file must be processed within 30 calendar days from receipt by center. If the center reasonably can substantiate needing the file longer than 30 days to complete the file review process, then an extension request may be submitted to the center’s Program Manager. If the file is in Regional Review and has been returned for completion of some process concern or for further clinical review, the file is to be completed and returned to the sender within 10 business days. 20
21.Records department responsibilities Applicant file review (afr) tracking Disability Coordinator Orientation Part 1
22.Responsibilities of Records Staff The records department is the gatekeeper of all applicant files must maintain a single ongoing log that contains all the ePRH requirements that must be tracked 22
23.Applicant File Review Log The log must contain: The date the file arrived on center To whom each file was sent How long a file has been with a particular department or staff member How long the file has been on center Notes/explanation of any delays in the process The start date or an explanation of the disposition of the file/application 23 Attend the “Managing AFR Tracking Webinar” for more detailed information!
24.Technical Assistance Features 24
25.Final Disposition/Meeting Timelines 25 The “Review Completed” date is not the date that triggers the total # of days in review – the “Final Disposition” date does. The day the review is completed typically is also the “Final Disposition” date because the clinician would have made a decision to recommend denial or to enroll with the completion of the review. If the applicant withdraws before the review is completed, then the “Final Disposition” would be the date of the withdrawal and then the comments would include an explanation about the withdrawal.
26.Final Disposition/Comments 26 Date of Assignment: This is the date the applicant is assigned for arrival. Date of Enrollment: This field should indicate the actual date the student arrived/enrolled, not the assigned date. Comments: This is the most important field in the log. It should help tell the story of what happened with the applicant file from the time it arrived on center until the file is processed to a final disposition. This field is used to -- Indicate any details needed to explain the file review process (e.g., reasons for delay, reasons for returns to the AC, etc.). -- Document when an extension is requested w/ the Regional PM for longer than 30 days to process a file. The date the extension is requested, the status of extension, and if the extension is granted how much additional time was approved should be indicated. -- Track the file movement/process/outcome for files sent for Regional Review.
27.Potential Compliance Issues! Not tracking all of the required components that the PRH requires. Failing to clearly document tracking of applicant file review process. Amount of time applicant file is in review. Final disposition of the application process. Returning files to the AC improperly, whether requested by the AC or not. Collateral effects of this action may result in Bypassing the Regional Office review of applicant files. Potentially denying applicants a final adjudication of their application. Applications ending up at other centers requiring other clinical teams to process the applicant’s file. 27
28.Sample Disposition Statements Acceptable or not? File requested to be returned to OA by the AC. File returned to the AC. Applicant has been arrested and is in jail so the file was returned to the AC. File sent to Regional Office (RO) on 11/30/18 as rec. of denial; File received back on 12/15/18 from RO to complete process; FRT could not reach applicant so AC was contacted. AC also could not reach applicant so file is being ret. to AC on 12/20/18 to process as a w/drawal (e.g., incomplete application). 28
29.Sample Disposition Statements Acceptable or not? Applicant sent email dated 1/5/19 and received by M. Wiggins, HWM, stating he no longer wished to enroll in Job Corps. File is being ret. to AC on this date to process as a w/drawal of application. AC informed center that applicant is hospitalized and FRT attempted to contact via contact numbers on the ETA 652. Voicemails were left but applicant did not return calls. File returned to the AC to process as a w/drawal (e.g., incomplete application). Applicant is no longer eligible as he disclosed medical conditions he did not disclose on 653 Health Questionnaire. 29
30.Check-in! Which columns trigger the automatic counting for Days in Review? File Receipt Date and Disposition Date The Disposition Date refers to what? The date the file review is complete and a final decision is made or the date the applicant withdraws from the program, etc. Is it acceptable to delete entries once an applicant is accepted or a file has been returned to the AC or is submitted to the regional office? No! The center must maintain ongoing records of its applicant file tracking documentation. May start a new log each PY but need to keep at least 1 year (but suggest 2-3 years) of records. 30
31.Applicant file review and reasonable accommodation Process teams FRT RAC Disability Coordinator Orientation Part 1
32.Process Teams within AFR There are (2) process teams within the file review process: File Review Team (FRT) Reasonable Accommodation Committee (RAC) May include some of the same individuals on each team Typically fluid in composition Roles and functions are different 32
33.EPrh 1:1.4; Appendix 107 Center applicant File review process Disability Coordinator Orientation Part 1
34.34 Applicant File Review Process 3. File is “received” on center (electronically or otherwise) by the records staff who record the file in the records log and tracks its movement. Records forwards the sealed medical, health, or disability-related information unopened to the Health and Wellness Manager (HWM) if anything is received in hard copy. STEP 1 STEP 2
35.35 3. Applicant File Review Process The HWM completes a review of the “Job Corps Health questionnaire (ETA 653)” and the medically related documentation to determine: The health care needs of the applicant and whether JC can meet those needs, and If the applicant presents a direct threat to self or others. The HWM determines who else may need to review the protected information based upon the determination of “need to know.” This is your File Review Team (FRT)! STEP 3 STEP 4
36.File Review Team (FRT) Review relevant parts of the applicant’s file based upon the Health and Wellness Manager’s (HWM’s) initial triage of the file and based upon a “need to know.” This is your clinical review! Make recommendations to accept or recommend denial of an applicant. Does NOT determine accommodation needs of the applicant. 36 FRT
37.Identification of the File Review Team Who should be the typical participants of the file review team? Center Mental Health Consultant (CMHC) reviews mental health-related information Center Physician/Nurse Practitioner/Physician’s Assistant reviews medical information Center Dentist reviews dental/oral health information TEAP Specialist reviews substance-related information Academic Manager reviews IEPs, 504 plans, educational reports including special education assessments 37
38.38 Applicant File Review Process Applicant File Review Process If there is no health-care needs or a direct-threat assessment necessary, schedule the applicant for enrollment. The members of the FRT determine if a health care needs or a direct threat assessment is necessary or if there is a need to revisit the eligibility factors. STEP 5
39.Health Care Needs (HCN) and Direct Threat (DT) Assessments HCNA – Appendix 610 The HCNA should be completed if there is a concern that the center cannot meet the basic health care needs of the applicant MUST be completed by a clinician MUST use the required form and ensure it is the most current one DTA – Appendix 609 A DTA should be completed whenever center believes that an applicant poses a direct threat to the health or safety of himself or others MUST be completed by a clinician MUST use the required form and ensure it is the most current one 39
40.Reminders from the clinical side of the house! Did the center clinician completing the assessment actually speak with the applicant to complete the clinical interview? What if the applicant is a minor? Did you answer all of the questions on the assessment and record the answer on or within the actual assessment and not on an addendum? Addendums may be added to “supplement” your answers but not in lieu of responding to the question on the assessment. Please contact your respective REGIONAL HEALTH SPECIALIST to discuss any potential concerns or issues related to the completion of the health care needs or direct threat assessment BEFORE submitting the applicant file for review!! 40
41.Policy and process Reasonable accommodation in the assessment process Disability Coordinator Orientation Part 1
42.42 Applicant File Review Process When completing the DTA or HCNA for an applicant with a disability, the reasonable accommodation committee (RAC) must convene to consider reasonable accommodation (RA). STEP 6
43.Reasonable Accommodation Committee (RAC) Reviews and discusses potential accommodations with the applicant as part of the Health Care Needs or Direct Threat Assessments. Recommends accommodations and modifications to the FRT. Does NOT make decisions about enrollment. 43 RAC
44.44
45.Reasonable Accommodation (RA) Process Appendix 605 Who is a person with a disability? Has a physical or mental impairment that substantially limits a major life activity. Some conditions essentially always considered a disability. Term “substantially limits” should be construed broadly in favor of expansive coverage. Does not require extensive documentation. ONLY talking about RA related to the denial assessment process here!! 45
46.RA in the Assessment Process The DC and the applicant MUST be involved in the RA review as per the PRH. The DC is the coordinator of the reasonable accommodation process; therefore, this individual must lead this portion of the assessment process. The clinician completing the assessment should not be leading the RAC; however, s/he may participate/make RA recommendations as time permits. 46
47.Communication Accommodations within the Assessment Process Your obligation to communicate effectively with people with disabilities – whether those people are students, staff, applicants for admission or employment, parents, guardians, or members of the public – is separate from your obligation to provide reasonable accommodations for qualified people with disabilities. Consider communication accommodations for participation in both the clinical interview and the interactive reasonable accommodation process. Examples of applicants who may need communication accommodations (list is not all inclusive): applicants with intellectual disabilities, who are blind or deaf, who are on the autism spectrum, etc. 47
48.What Is a Communication-related Accommodation? Any adjustment or modification, support, and so forth that enables the individual to be able to both receive and express information in a way that is meaningful to them. Examples might include such things as: Simplification of language. Repeated phrases and giving extra time for processing. Interviewing face-to-face in lieu of phone. Using pictures or other symbols to convey meaning. Interpreters, hearing assisted devices, text to speech technology. 48
49.49
50.RAC has been unable to ID any RA When do you think you should be checking this box? (Must always make the determination on a case by case basis) True or False: The DC or RAC is able to identify RA but does not think they will be sufficient? Applicant is experiencing symptoms which impairs his/her judgment such that they could not reasonably participate in the decision-making process to determine RA even if given RA to assist with participation. Applicant has significant history of self-harm or self-harm attempts coupled with recent events that have been increasing in either frequency and severity or both. Applicant has single incident of self-harm with ER visit but no resulting hospitalization and no previous history. 50
51.Review – When Do You Identify RA? Do you consider accommodations if: There is documentation of a disability? The documentation is for a mental health condition? The documentation is for a medical condition? The documentation is for a substance use condition? It depends! The documentation is for an oral health condition? Not typically but some serious conditions/situations may warrant consideration as a temporary disability. General orthodontia related-situations would not qualify. 51
52.How to ID RA! Look at the functional limitations or behaviors in item #3 of the HCNA or in item #1 of the DTA. 52
53.How to ID RA! Now go to item #5 and ID RA related to each functional limitation/behavior checked in item #3 of the HCNA or #1 of the DTA. 53
54.Yes/No Boxes in #5 of Assessment Form Completing the check boxes: Checking “yes” means that the applicant was offered the specific accommodation and accepted it. Checking “no” means that the applicant was offered the specific accommodation and rejected it. Leaving the box blank means the accommodation was not offered and/or discussed because it was not appropriate or necessary. 54
55.55
56.56 Applicant File Review Process Then the licensed clinical professional completing the assessment considers whether or not accommodations would sufficiently remove the barriers to enrollment. The licensed clinical professional makes a final decision based upon the findings of the assessment. STEP 7 STEP 8
57.57
58.Referral to an Alternate Center 58
59.59 Applicant File Review Process Any applicant file recommended for denial is to be forwarded to the Regional Office for review and final determination of the application status. STEP 9 Finish Line!
60.Review and Practice Disability Coordinator Orientation Part 1
61.Case Study #1 - Facts Darren Applicant has seizure disorder and CCMP is completed by outside treating provider. In #5 of the HCNA, center checks that applicant is not a person with a disability; therefore the RAC is not convened and the rest of #5 is left blank. FRT is comprised of the HWM/DC, Academic Manager, Career Technical, Residential Manager, and CSIO. Career Technical says applicant cannot participate in Carpentry trade because he has a seizure disorder and scaffolding and use of power equipment would be unsafe. 61
62.What are some of the process issues in Darren’s scenario, if any? 62
63.Let’s Review Darren’s Case! Does the file need to go back to the center? Yes, but why? What other issues of concern exist with the AFR process? What about the composition of the FRT? It is too broad. Is the applicant a person with a disability? Seizure Disorder is one of the conditions listed in the EEOC Guidelines as almost always considered a disability. So, the RAC should convene and consider accommodations. 63
64.Let’s Review Darren’s Case! Can Darren be denied admission because of his trade interest/choice? Can Darren be refused admission to a particular trade due to a disability? No Can Darren be restricted from certain activities if the center doctor documents the restrictions? There are multiple answers to this: Yes, but… and it depends… The RAC needs to convene and consider reasonable accommodations that may allow participation If temporary restriction, then schedule may need adjusting or other accommodations provided If long term restriction and RA alternatives have been exhausted, career counseling might be needed to explain the impact/repercussions to Darren so that he may make an informed choice 64
65.Case Study #2 – Facts Alexa 653 affirmative for schizophrenia, ADHD, substance addiction. Alexa has completed dual MH and substance treatment and is ready for release. Supporting documentation from the treatment facility has been provided. Alexa is a minor and center clinician has spoken with her mother but not the applicant. 65
66.Case Study #2 – Facts Alexa Alexa has requested accommodation to bring a comfort animal to center which is her cat. She has a letter from her current treating provider regarding the need and benefit of the comfort animal. Her mother says that she may not bring the cat to the center. Center is recommending denial based upon applicant’s health care needs. 66
67.What are some of the process issues in Alexa’s scenario, if any? 67
68.Let’s Review Alexa’s Case! What would you do with each potential consideration posed below? HWM/DC wants to send the file back to the AC since the applicant is hospitalized. Since the applicant is a minor and spoke to the mother, would the center clinician need to speak to the applicant as well? The applicant is not available to speak to the center FRT despite the team’s efforts to set up a call to conduct the necessary interviews. Would the RAC need to consider accommodations for the substance addiction? 68
69.Let’s Review Alexa’s Case! What would you do with each potential consideration posed below? The applicant wants to bring her comfort animal to center despite the disagreement over that with the mother. Do you have to process the applicant’s accommodation request since she is a minor? 69
70.resources Disability Coordinator Orientation Part 1
71.Job Corps Disability Websitehttps://supportservices.jobcorps.gov/disability/Pages/default.aspx 71
72.Job Corps Health & Wellness Websitehttps://supportservices.jobcorps.gov/Health/Pages/default.aspx 72
73.Job Accommodation Networkhttp://askjan.org 73
74.THANKs Questions?

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