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​​​Chapter 7 Contents:

DRS Policy Manual Main

[REVISED: 2/4/21]

  1. Definitions.      

             a. Academic year. DARS accepts the school’s definition.

             b. Cost of attendance (school budget) means:  

tuition and fees, 

room and board, 

books and supplies, 

personal/miscellaneous, and 

travel/transportation needed for school training.

Note: The Higher Education Act permits each school to determine the cost of attendance for the student body.
  

  1. Institutions of higher education means (per 2016 Federal Regulation 34 CFR § 361.48):
     


universities, colleges, community or junior colleges, 

vocational schools, 

technical institutes, or 

hospital schools of nursing. 

Note: Vocational schools and technical institutes may also be called career or trade schools and offer job-specific skills rather than a liberal arts education.
 

  1. School training services means academically accredited education beyond the high school level that leads to occupational certification or licensure or degree/diploma/certificate/courses that satisfy the education requirements of the employment goal. This includes:
     

prerequisite college developmental courses needed during the college freshman year; 

trial college semester as assessment; 

high school/post-secondary school dual enrollment; 

small business development workshops needed for self employment; 

preparation course and testing fee for entrance examination or occupational examination for certification or licensure; 

adult continuing education courses, and 

tutorial services needed as a disability accommodation.

 

2.    Provided Under Employment Plan. 

  1. School training services are provided only under an Employment Plan (per 2016 Federal Regulation 34 CFR § 361.45), and with supervisor approval (see Section D1).  ​Before the counselor authorizes a trial semester as an assessment service, the counselor shall also obtain supervisor approval (see Section A2)​.​
     
  1. Multi-year school training shall be planned annually and authorized school term by term.
     
  1. Workers Compensation cases require special procedures for writing an Employment Plan Training Plan (see Chapter 5 PLAN, Policy 2, Section D6). When the Workers Compensation insurance carrier is paying part or all of the school training costs, the counselor must provide the carrier a written itemization of the costs and the name and address of the person at the school to whom the carrier should send the payments.

 

3.     Criteria for receiving school training service.

  1. The employment goal must maximize the individual’s employment as required in subsection A1(d).
     
  1. The school training must be vocationally necessary (for documentation see subsection A1(e).
     
  1. The individual must demonstrate potential to successfully complete the school training program and achieve employment (for factors to consider, see subsection A1(f).
     
  2. The individual must have applied for Vocational Rehabilitation services at least 90 days in advance of the school term when the FAFSA and RS-25 forms are required in Section D. This allows time to process required documentation, including the FAFSA financial aid application. The supervisor may grant a policy exception when sufficient time exists for the individual to submit the FAFSA to the school, the school to process the FAFSA and financial aid award, the counselor to determine eligibility, the counselor and individual to complete and sign the Employment Plan, and the school and counselor to coordinate financial aid with VR funding.
     
  3. All individuals receiving SSI and all SSDI disabled worker Claimants must be referred to, and participate in, Employment and Benefits Counseling.  For additional information contact the Ticket to Work Coordinator in DARS Central Office.
     
  1. The individual must make satisfactory progress towards meeting all of the school requirements within the school deadline and towards completing the Employment Plan. The counselor shall monitor this progress. DARS shall not support training if the individual will not meet the school deadline. The counselor may assist the individual to advocate for an extension, but shall abide by the decision of the school.
     
  2.  Part-time training may be used only with supervisor written pre-approval when the severity of the disability shall not allow the individual to  training on a full-time basis (per State Regulation 22 VAC 30-20-120). The RS-25 must be used for all training cases and the individual must meet the school’s graduation requirements within the school's timeframes.       
  3. Once in school, the individual must maintain a “C” average for each academic year, or higher if required by the school training program.  If the individual eanrs less than a "C" average for the academic year, DARS finanical assistance may be reinstated only if the individual completes one term, maintains "C" average, and meets all other eligibility criteria for school training services. 

  4. If a graduation extenison is not needed for a current student, the counselor may approve a double major or a change in majors/field of study for any reason. DARS shall not support a double major or changein the major/field of study that requires an extension to the graduation deadline when the school does not grant the extension.

  5. Audited courses are not funded by VR, including all categories in the cost of attendance (school budget). This provision does not apply to Virginia Commonwealth University's ACE-IT in College program.

  6. The individual must provide a copy of the semester's transcripts, with the current semester's grades, copy of degree completion, trade school certificate of completion, etc. and the counselor shall keep the documents in the case record.

 

4.  Graduate degrees.            

​​DARS may assist the client in securing a graduate degree only when it is essential to their achieving an employment goal agreed to by DARS and the individual in the IPE (per State Regulation 22 VAC 30-20- 120). District director approval is required for inclusion of a graduate degree on the client’s IPE (See Section 1D).

   

5.  Maximizing employment.

Maximizing employment means the opportunity to reach employment potential and is not the same as a bigger paycheck. Depending on the occupation and the career potential of the individual, entry level jobs may be the maximum employment level, may be an appropriate first step on the path to upward career mobility, or may be underemployment. The counselor shall not limit the individual to entry level jobs solely to achieve employment of some kind or because the employment plan program will cost less (e.g., only requires placement assistance, job retraining, less education etc.). Client choice by itself shall not be the sole reason for selecting an employment goal. The employment goal must be based, primarily, on the unique strengths, resources, priorities, concerns, abilities, capabilities and reflect career interests and informed choice to the extent that they are consistent with the strengths, resources, etc. as well as other employment factors such as labor market information in the local area or willingness to relocate, job market outlook, etc. These considerations apply to individuals who are not currently employed and individuals seeking to advance in their present careers (per federal policy directive RSA-PD-97-04). For employment goal selection, see Chapter 5, PLAN, Policy 2, Section B1.

Resources: Resources for labor market information include the Virginia Employment Commission's Virginia Occupational Career Resource Guide, Virginia View, O*Net, job descriptions, etc.

6.     Career advancement.

​Career advancement means upward career mobility and a higher level job in the present career path (not just earning more money in the current occupation). Criteria for school training services for career advancement are:         

  1. the individual has a work history, and

  2. the individual has not maximized employment and is capable of advancing in the career path, and

  3. school training is vocationally necessary to achieve career advancement, and

  4. the individual demonstrates potential to successfully complete the school training program. School training services for career advancement shall not be provided to individuals who qualify for higher level jobs with the current education and work experience. Client choice by itself is not sufficient justification for career advancement. For career advancement, see Chapter 5, PLAN, Policy 2, Section B2.
                    

 

7.     Career change. 

Criteria for school training services for career change are:    


  1. the individual has a work history, and
     
  1. the disability is a barrier to performing jobs for which the individual is currently qualified (or such jobs are not available), and
     
  1. disability accommodation or relocation are not feasible. 

 

  1. Client choice or bigger paycheck or non-disability reason are not sufficient justification for a career change. This is an opportunity to provide counseling and guidance to identify job opportunities at the current education level, transferable skills, and abilities.

8. Vocational necessity.

 Vocational necessity is determined by comparing the job qualifications of the employment goal to the current education level, transferable skills, and abilities. If the established employment goal requires certification, licensing, examinatin, degree, or other qualification that is usually obtained through a school trainig program (including a preparation course for an occupational examination) then that school training program is vocationally necessary (e.g. school trainign and license required for employment as a barber, cosmetologist, commerical driver, polygraph examiner, real estate agent, nurse, certain health care and medical occupations).School training is vocationally necessary if the individual needs updated or additional job skills or education to meet the hiring standards. School training may be vocationally necessary if employers do not require, but prefer, more school training than the individual has attained - therefore, consider the competitiveness of the labor pool and hiring standards.

9.     6 "A"s.

Potential to successfully complete all requirements of the school training program and to achieve employment must be demonstrated in the case record.  Factors to consider include, but are not limited to:     

aptitude,
Guidance: Ability to perform at that academic level may be assessed by high school grades, whether a standard or advanced high school diploma was awarded, college board score or SAT score or entrance examination score, vocational evaluation, IQ score, teacher/guidance counselor recommendations, etc. Also consider the disability and functional limitations and ability to handle the demands and stresses of school now and job later.

attitude,
Guidance: When assessing attitude, consider the individual’s attitude, motivation, organizational skills, time management, maturity level, independence, responsibility and follow through, completion of assignments on time, etc.

accommodation,
Guidance: Accommodations may be needed in the classroom. If the individual tried school training in the past, consider if the needed accommodations were provided and whether they were used and if not, why not. Consider what accommodations are needed now and if existing needs assessments are sufficient, or if additional or new information is needed. For transition students, accommodation appropriate for college may be different than for high school, and you may need new needs assessments.

advocacy skills to request reasonable accommodation,
Guidance: Advocacy skills are needed to self-advocate effectively with instructors and campus disability services staff. Unlike high school, accommodations are usually requested course by course. The individual may benefit from career counseling, assertiveness training, etc. For transition students, there is no IEP in college and accommodation rights may differ from high school.

availability of jobs, and 
Guidance: Availability of jobs is a factor. Consider local job market or relocation, occupational growth trends, labor market competitiveness, etc. Resources include Virginia View, and the U.S. Department of Labor Occupational Outlook Handbook.


a
llowances for cost of attendance.  See maximum allowances.

9.     Factors not having to do with maximizing employment, vocational necessity, and potential for successful training and employment do not justify VR support, including, but not limited to (per agency mandate):              

  1. Having only a high school education.
     
  1. Having an interest in or being accepted by or enrolling in a school training program.
     
  1. Having an Individualized Education Program Transition Plan containing postsecondary education.
     
  1. Being offered financial aid or reasonable accommodation by a certain school.
     
  1. Needing VR financial assistance to afford school training.
     
  2. Applying only to out-of-state schools.
     
  3. Not being accepted by a Virginia public university but accepted by a proprietary school or an out-of-state instiution of higher education.
     
  4. Not applying for or receiving financial aid, or missing the financial aid application deadline.

 

11. Consumer Responsibilities

The individual must satisfy all requirements in section B of this policy. 

12.     Disallowed services.   

  1. For an employed individual, DRS shall not develop or fund school training that is available through the employer staff development programs.
     
  2. For a current high school student, DRS shall not provide school training services available through the secondary school system (high school), because it is a comparable benefit.
     
  1. DRS shall request payment only for those services that are part of the Employment Plan. DRS shall not request payment for service unless the service is authorized in writing by the counselor before the service is provided or before the individual incurs the expense (per 2016 Federal Regulation 34 CFR § 361.50(d)).
     
  1. Monetary loans to individuals are strictly prohibited by DARS mandate. Under no circumstances, including supervisory pre-approval, shall DRS make the student loan payment for the individual who accepts a student loan (per federal Higher Education Act).

 

                              Note: Although merit-based aid is not acomparable benefit, this is a resource that may be available to the client and the counselor                                                                           

​e.  Per federal OMB Circular A-87 revised May 10, 2004, DRS shall not pay bad debts, liens or judgments (e.g., defaulted student loans);   entertainment expenses, including costs ​of amusements and social activities (e.g., fraternity or social organization fees); fines, court costs, and similar expenses; or the consumer interest payments (e.g., interest portion of student loan payment).


13.      Financial participation.

School training services, except trial semester as assessment, are subject to consumer financial participation policy (per 2016 Federal Regulation 34 CFR § 361.54) and annual RS-13 Client Financial Statement.  For policy on when FAFSA and RS-25 are also required, See Policy 1: Section D3 of this chapter. For financial participation policy, see Chapter 14.3, FINANCIAL, Policy 1.

14.     Comparable benefits.    
 

  1. School training services in any training program that participates in the financial aid program are subject to comparable benefits policy (per 2016 Federal Regulation 34 CFR § 361.48 and 2016 Federal Regulation 34 CFR § 361.53). This includes proprietary vocational schools and technical institutes. Trial semester as assessment and college developmental course work are exempt from comparable benefits (per agency mandate).
     
  2. Grants are comparable benefit to be used before VR funds (per 2016 Federal Regulation 34 CFR § 361.48(f) and federal policy directive RSA-PD-92-02 issued November 21, 1991). The SCHEV Website at www.schev.edu lists Virginia grant programs available for economic need, areas of study, graduate school, foster care children, etc.
     

 

  1. Veterans benefits are a comparable benefit to be used before VR funds (per 2016 Federal Regulation 34 CFR § 361.5).
     
    1. Merit-based aid and scholarships (i.e., athletic, artistic, academic, essay contest, etc.) are not a comparable benefit, even when accepted (per 2016 Federal Regulation 34 CFR § 361.5). VR shall accept the school’s determination whether the aid is based on merit. The SCHEV Website at www.schev.edu lists some merit-based aid for which the student may apply.

       Note: Although merit-based aid is not acomparable benefit, this is a resource that may be available to the client and the counselor can negotiate with the family to see about covering other costs associated with attendance, such as travel or personal expenses.

    2. Work-study does not have a payback feature and becomes a comparable benefit only if the student accepts it. DARS shall not require an individual to accept work-study. However, if grant assistance and VR funding are unavailable or insufficient, the individual may have no other choice but to accept the work-study (per federal policy directive RSA-PD-92-02 issued November 21, 1991).
       
    3. Student Loans.
       
      1. DARS shall not require an individual to accept a student loan. However, if grant assistance and VR funding are unavailable or insufficient, the individual may have no other choice but to accept the loan (per federal policy directive RSA-PD-92-02 issued November 21, 1991). The counselor must counsel the individual who accepts a student loan on the responsibilities inherent in accepting a loan (per federal policy directive RSA-PD-92-02 issued November 21, 1991). This may include advice that the loan must be paid back with interest, loan payments usually begin upon leaving school, applying for loan deferment option while student is under an Employment Plan, etc. The counselor may refer the individual to the Federal Student Aid Information Center or the school financial aid officer for information and loan counseling.
         
      1. Federal Perkins loans are need-based and shall not be a comparable benefit, even if the individual accepts the loan.
         
      1. Subsidized student loans are need-based and shall not be a comparable benefit, even if the individual accepts the loan. This includes Subsidized Stafford (both Direct and FFEL) and other subsidized student loans. Note: not all Stafford loans are subsidized. Subsidized means the government pays the interest for the student.
         
      1. Unsubsidized student loans are based on credit-worthiness and are not need-based and become a comparable benefit only if the individual accepts the loan. This includes PLUS (both Direct and FFEL) loans and Unsubsidized Stafford (both Direct and FFEL) loans.

      2. Loan repayment. 
        The counselor may assist the individual to apply to the student loan lender to defer (postpone repayment), forbear (lower the monthly payment), or discharge (forgive) the student loan when the payback period starts (for details and application, contact the financial aid officer or lender). DARS shall not fund school training that participates in the financial aid program if the individual does not meet his or her obligations to the lender under the terms of the deferment, forbearance or discharge.

      3. Loan default and clearing loan default status. 
        DARS shall not fund an individual in a school training program that participates in the financial aid program until the loan default status is cleared and the school indicates eligibility to apply for financial aid is restored.


15.     Ineligibility to apply for financial aid prohibits VR funding. 

When the RS-25 is required under Policy 1: Section D1 of this chapter, DARS shall not authorize a training program that participates in the financial aid program for an individual who is ineligible to apply for financial aid for any of the reasons listed here (per U.S. Department of Education Guide to Federal Student Aid).  These individuals have not used maximum efforts to secure grant assistance in whole or in part from other sources (Higher Education Act Title IV; Educational Credit Management Corporation (ECMC) regulations; P.L. 102-569 Rehabilitation Act of 1973 as amended Title I Section 103(a)(3); federal policy directive RSA-PD-92-02 issued November 21, 1991; federal program assistance circular RSA-PAC-88-05 issued September 9, 1988; 2016 Federal Regulation 34 CFR § 361.48). The financial aid program is responsible for determining financial aid application eligibility and DARS shall abide by their decision. Refer the individual to the lender or school’s financial aid office to discuss possible remedies.   

  1. Currently owes a grant refund unless the individual provides documentation from the lender of repayment arrangements.
     

 

  1. Is in default on any federal or state educational loan unless the individual provides documentation from the lender that the individual is no longer in default status.
     
  1. The student loan debt has been canceled by the lender, unless the individual has reestablished eligibility for financial aid under Title IV of the Higher Education Act.
     
  1. Is convicted of a state or federal offense involving possession of or selling illegal drugs, until the established waiting period is over or the person reestablishes eligibility as required under the Higher Education Act and Federal Regulation 34 CFR § 668.40.
     
  1. Did not register for selective service when required.
     
  1. Did not complete the school training program within graduation deadline.
     
  1. Did not maintain satisfactory grades.
     

                 h. not meet eligibility criteria for non-U.S. citizens.                                                                                                                                                                                                               
                  i. Does not have a valid social security number.

16.    Purchasing. 

School training services are subject to DRS established purchasing policies and procedures (see Chapter 14.1, PURCHASING, Policy 1).

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REVISED: 2/4/21

With supervisor approval, the counselor may authorize one trial semester when the counselor is unsure of the individual’s capability to perform academically beyond the high school level. It is an assessment service exempt from the RS-13, FAFSA and RS-25, and may or may not be provided under an Employment Plan at the counselor’s discretion.  The individual must takes courses within the plan of study identified as meeting their established employment goal.Regardless of where the individual enrolls, the maximum allowance (not to exceed the actual cost) is the local community college tuition and fees rate, $0 room and board, cost of attendance (school budget) for books and supplies, one meal per day while on campus, parking permit, and one round trip travel per day spent on campus. The student must earn a minimum “C” average for the semester to continue to receive support for future semesters.  For lowest cost policy, see Chapter 14.1, PURCHASING, Policy 6.
Cross reference: For lowest cost services policy, see Chapter 14.1, PURCHASING, Policy 6.

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REVISED: 2/4/21

The counselor may authorize up to one year of developmental courses required by the school only for entering college freshman whose employment goal requires college coursework or degree. Supervisor’s written pre-approval is required. If the individual is taking only developmental courses, use the RS-13 but not the FAFSA or RS-25. Regardless of where the individual enrolls, the counselor shall authorize no more than the local community college tuition and fees rate, $0 room and board, actual books and supplies, one meal per day while on campus, campus parking permit if needed, and one round trip travel per day spent on campus at the client mileage reimbursement rate (see Chapter 8.20, TRANSPORTATION, Policy 1). The student must earn a minimum “C” average each semester  and make satisfactory progress towards meeting all of the school requirements within the school deadlines to demonstrate college potential.

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REVISED: 2/23/18

  1. Training outside a traditional classroom (excluding required internship, student teaching, practicum, etc.), may be considered only when provided by a Virginia community college or public university or the vocationally-necessary training program is not offered through a Virginia public institution. Exceptions require pre-approval from the Transition Coordinator. Correspondence study training may be authorized only when:


    1. The individual requires specific preliminary training in order to enter a training program or training cannot be arranged by any other method; and
       
    1. Satisfactory progress is maintained (per State Regulation 22 VAC 30-20-120).

  2. The maximum allowances in Section C of this policy shall apply.
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REVISED: 2/23/18

Tutorial services provided by DRS vendors may be authorized if needed for the individual to achieve the established employment goal as indicated by assessment of medical, vocational, psychological and other factors (per State Regulation 22 VAC 30-20-120). Peer tutoring may not be adequate for some consumers who have specific learning needs. In this cae, it is appropriate to use private tutorial services. Refer to the DRS Services Reference Manual for additional information and for maximum allowance.    

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REVISED: 2/23/18

  1. Definition.
    Sectarian means existing primarily for the purposes of providing religious training or theological education, rather than collegiate or graduate education (per Phan v. Virginia 806 F. 2d 516 4th Circuit, 1986). A church-affiliated school is not necessarily a sectarian school, consult the DRS Transition Coordinator when in doubt.
  2. The counselor may agree to a religious vocation as the employment goal (the choice of vendors will affect the maximum allowances on the RS-25, see Policy 1: Section C of this chapter
  3. DARS shall not authorize or approve any payments (reimburse the individual) for religious training or theological education at a seminary or sectarian school for an individual having an established employment goal related to a religious vocation (per Virginia Constitution Article VIII, Section 10). See Policy 1: Sectioin C of this chapter.

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[REVISED: 2/23/18]

Summer school training is subject to the RS-13, and RS-25 when it applies.  See Policy 1: Section D3 of this chapter.

Guidance: Factors to consider when approving summer school include, but are not limited to: required course is offered only in the summer; part-time student needs summer school to graduate within the school’s deadline; student needs less than a full semester to graduate; student will perform well under the faster learning pace with grades based on fewer assignments and tests; school’s attendance policy and whether the student will miss any days due to disability or vacation or other reasons, etc. Summer school may be utilized for consumers to participate in an internship, unpaid work experience, or paid employment within their established employment goal. This builds work experiences and references for the consumer.

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[REVISED: 4/9/18]

  1. Definitions.

    1. CTP (Comprehensive Transition and Postsecondary Programs for Students with Intellectual Disabilities) means a model program receiving a grant under Higher Education Act (HEA) of 1965, as amended (HEA) - Part D - Programs to Provide Students with Disabilities with a Quality Higher Education.
       
    1.  Wrap-around services mean individualized, person-centered supports and services provided by a CTP and focused on academic enrichment, independent living skills, social skills, integrated work experiences, and career skills

  2. Case status.
    The student must have an IPE.  The client must meet the criteria in Policy 1: A1c of this chapter that are applicable to the CTP Program.

  3.  IPE requirements.
    The IPE must require client participation in monthly check-in call or meeting with the counselor - an expectation of self-directed “to do” for clients. The client must consult with the counselor at least twice per year (preferably after each term) to review progress toward training program completion, financial status, and future plans. For non-credit bearing courses, the IPE must specify measurable expectations for class attendance and completing class assignments.   The IPE shall require client participation in on-going employment-focused activities such as career exploration, paid or unpaid work experiences, etc. The client must use the DRS Employment Resource Center as frequently as agreed to by client and counselor and specified on the IPE.

  4. Costs over $5,000 are subject to DARS' Commissioner review procedure.

  5. The counselor shall only authorize the courses that are vocationally necessary. Supervisor and Transition Coordinatore written pre-approval shall be required for all courses. Pre-approval shall be granted case-by-case and based on a thorough review of:  

    1. The availability of comparable benefits including WWRC services and services provided by local service providers (such as Centers for Independent Living, etc.) as required by policy in Chapter 14.2, COMPARABLE, Policy 1;
       
    2. The ability of the individual to fully participate in and complete the courses, leading to employment.

  6. The client must immediately notify the counselor upon withdrawing from any course, dropping below full time student status, or withdrawing from school. 

  7. The client must make satisfactory progress towards completing the training courses as scheduled in the IPE. 

  8. For each course that DRS funds, the client must provide the counselor a copy of the grade report at the end of each school term. The client must maintain a minimum "C" average for the academic year. If the client earns less than a “C” average for the academic year, the counselor shall immediately discontinue financial assistance for additional school terms. Financial assistance may be reinstated only after the client completes one term with the minimum average required by the school. Clients receiving financial aid must maintain a “C” average each semester and meet other requirements to remain eligible for financial aid. 

  9. For a Workers Compensation case, if the carrier is paying part or all of the training costs, the carrier will probably also require the individual to provide confidential information concerning classes taken and grades, progress towards program completion, etc. as a condition of sponsorship.  The client may include the carrier on the DRS release form.

  10. Employment and Benefits Counseling. 
    The client must be referred to, and participate in, Employment and Benefits Counseling regardless of the school training cost to DRS.

  11. Maximum Allowances.         

    1. For a client enrolled in an associate, bachelor or graduate degree program that provides wrap-around services and participates in the federal financial aid program, the maximum allowances for school Cost of Attendance (COA) in Section C1 of this chapter and DRS Training and Facilities Manual shall apply.
       
    2. For a client enrolled at a post-secondary school in a non-degree program with wrap-around services, the maximum allowance for credit-bearing courses is the local community college tuition rate, school COA for books and supplies, school COA for transportation, and room and board shall only be authorized if the vocationally necessary services are only available from a vendor too far away to commute.
       
    3. For CTP, or a client taking only non-credit-bearing courses with the wrap-around services, the maximum allowance for tuition and fees is the cost of the specific pre-approved classes that address the employment goal and serious functional limitations.
       
    1. For client within commuting distance, the maximum allowance for room and board is $0, for transportation is the school Cost of Attendance (COA), for parking, campus meals and other incidentals if the COA for personal and miscellaneous. If the vocationally necessary services are not available within commuting distance, the maximum allowance for room and board are reflected in the COA on the RS-25 and the counselor may authorize incidentals in conjunction with lodging (for lodging and incidentals policy, see Chapter 8.10, MAINTENANCE, Policy 1). For those not under the RS-25, the MAINTENANCE Policy will apply.
    1. DRS shall (per 2016 federal regulation 34 CFR 361.50 (b)) give preference to in-state vendors. If the client chooses an out-of-state service at a higher cost than an in-state service, if either service would meet the client vocational rehabilitation needs, DRS shall not be responsible for the excess cost, regardless of the RS-13.

  12. Financial aid.
    Funding shall (per 2016 federal regulation 34 CFR 361.54) be subject to consumer financial participation policy and RS-13 results, and (per 2016 federal regulation 34 CFR 361.48 (f)) also subject to the RS-25 results. See Chapter 14.3, FINANCIAL PARTICIPATION, Policy 1 for use of the RS-13. See Policy 1: Section D3 of this chapter for use of the RS-25. The client shall be financially responsible for other costs over and above the RS-25, regardless of the RS-13 results or exemption from consumer financial participation.

  13. Qualified CTP Vendor.

    1. The training program must be on the list of CTP programs approved by the U.S. Department of Education.
       
    2. The training program must be provided by a post-secondary school accredited by an accrediting body sanctioned by the U.S. Department of Education.

  14. Encumbering Funds.
    Acceptance and enrollment into a CTP program does not obligate DRS to fund part or all of the program. The client cannot financially obligate DRS funds. For encumbering funds, see Chapter 14.1, PURCHASING.

     
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[REVISED: 2/23/18]

Failure to meet any of the conditions below is sufficient cause for denial or withdrawal of financial assistance for school training. The individual must:

  1. Enroll in a school on the DRS active vendor list. Colleges, universities, proprietary vocational schools, technical institutes, and other institutions of higher education must also be accredited by an accrediting body sanctioned by the U.S. Department of Education. This does not guarantee VR funding.

  2. Take the required training courses to achieve the established employment goal.

  3. Make satisfactory progress towards meeting all graduation/completion requirements within the school’s deadline.

  4. Enroll on a full-time basis unless the DRS supervisor pre-approves part-time status. Immediately notify the VR counselor upon withdrawing from any class, withdrawing from school, or dropping below full-time student status. The school defines what is considered full-time status and DARS accepts the school’s definition.

  5. If receiving SSI or is an SSDI Claimant, participate in Employment and Benefits Counseling. 

  6. If the student is receiving financial aid, each semester maintain a “C” average or higher to remain eligible for financial aid. 

  7. All students must maintain a minimum "C" average for the academic year, or higher if the school training program requires a higher average. If the student earns less than a “C” average for the academic year, the counselor shall immediately discontinue financial assistance for additional school terms. Financial assistance may be reinstated only after the individual completes one term with the minimum average required by the school (State Regulation 22 VAC 30-20-120) and meets all the other eligibility criteria.

  8. Provide the counselor a copy of the grade report at the end of each term. Provide the counselor a copy of the final transcript, certificate of completion, etc.               

    Note: For a Workers Compensation case, if the carrier is paying part or all of the training costs, the carrier will probably also require the individual to provide confidential information concerning classes taken and grades, progress towards program completion, etc. as a condition of sponsorship. The individual can include the carrier on the DRS release form.

  9. Consult with the VR counselor at least twice per year (preferably after each term) to review attendance, grades, progress toward training program completion, financial status, and future plans. Depending on the consumer's needs, more contact may be necessary to ensure success.

  10. If the RS-13 shows 0% — 95% consumer financial participation, and the school training program participates in the financial aid program, and the individual is taking enough credit hours (varies by school) to apply for financial aid, submit an annual Free Application for Federal Student Aid (FAFSA) to the school’s financial aid office and give a copy to the counselor. This requirement to utilize comparable benefits shall apply to all students requesting VR financial assistance, including individuals exempt from consumer financial participation policy. This requirement does not apply if the training program does not participate in the financial aid program. For example, non-credit developmental course work is not eligible for financial aid. Failure to apply for financial aid within the deadline does not exempt the individual from the requirement to apply for federal financial aid.  Determination of VR financial assistance for school-related expenses cannot begin until the school completes the federal financial aid award package and notifies the VR counselor.

  11. Immediately provide the counselor (and to the school financial aid office if the school cannot electronically access the report information) a copy of the Student Aid Report for the VR case file. Four to six weeks after submitting the FAFSA, the individual will receive a Student Aid Report (SAR) which lists the types of aid (grants, loans, etc.) for which the student is eligible. This requirement does not apply if the student is not subject to submitting the FAFSA and RS-25.

  12. For students who are clearing up a student loan default status, make payments to the lender or Educational Credit Management Corporation (ECMC) scheduled in the repayment arrangement and restore eligibility to apply for financial aid.

  13. Follow through on any other student responsibilities as agreed by the individual and counselor.

Guidance 1: The earlier the student applies for aid, the more comparable benefits and financial aid assistance will be available. There are federal, state, and college financial aid deadlines. Check the federal Free Application for Federal Student Aid (FASFA) website to determine how early an individual can apply for aid.

Guidance 2: The individual is encouraged to apply for federal financial aid even if the individual is 100% responsible on the RS-13, in case the individual does qualify for financial aid.

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[REVISED: 2/23/18]

  1. Client choice and VR funding. 
    Under the client informed choice policy, the individual may attend the school of his or her choice, but DRS considers cost when selecting among vendors and services and applies maximum allowances and financial aid comparable benefits (per 2016 Federal Regulation 34 CFR § 361.50) when determining the funding amount. Therefore, individuals, including those exempt from consumer financial participation, who choose a more expensive option shall be financially responsible for the difference in cost. An individual with limited resources may have no other choice but to accept student loans to attend the school of choice or consider schools within the DRS maximum allowances or explore other training options (e.g., on-the-job training, unpaid work experience, etc.).

  2. Actual cost and DRS maximum allowances. 
    DRS has established maximum allowances for each cost of attendance (school budget) category that apply whether the RS-13 stands alone or policy also requires the FAFSA and RS-25.

    1. The counselor may allow less than, but shall not allow more than, the maximum allowance. For example, the counselor may allow $0 for travel/transportation and personal/miscellaneous categories on the RS-25 to avoid exceeding the actual cost to the individual, avoid over- awarding financial aid, or to maximize comparable benefits, etc.
       
    1. The counselor may authorize less than, but not more than, the allowance for the category.


    Example: if the cost of attendance is $5,000 for private school tuition and $1,000 for books, and the DRS maximum allowance is $2,400 for community college tuition and $1,000 for books, the counselor shall not authorize $3,400 ($2,400 + $1,000) for tuition. For example, if the authorized amount for travel/transportation has been exhausted but the authorized amount for books category has not been exhausted, the counselor shall not use the remainder of the books amount for travel.



  3. Trial semester. 
    See Policy 1: Section A2 of this chapter.

  4. College developmental courses. 
    See Policy 1: Section A3 of this chapter.

  5. Tutorial services. 
    See Policy 1: Section A5 of this chapter.

  6. Religious training or theological education provided by a public or non-sectarian school.
    The maximum allowances in this Section apply.  

  7. Religious training or training in sectarian school or seminary.
    DARS shall not authorize or approve any payments (or reimburse the individual) for religious training or theological education at a seminary or sectarian school for an individual having an established employment goal related to a religious vocation (per Virginia Constitution Article VIII, Section 10). The maximum allowances are: $0 for tuition and fees, $0 for school housing and meal plan but cost of attendance for non-school housing and meals allowance, $0 for campus bookstore but cost of attendance for other vendors for books and supplies.  For personal and miscellaneous and travel and transportation maximum allowances, see the categories below.  

  8. School-related disability costs. 
    For disability-related costs needed for school, use the RS-13 alone and report it to the school on the RS-25 because the school may provide financial aid to cover the individual’s portion of the cost. This means anything the individual needs for school due to the disability that a person without a disability would not need for school. Examples of such costs include, but are not limited to: paratransit, mini fridge for disability-related prescriptions that need refrigeration, note-taking, tutors, etc.

  9. Books and Supplies category. 
    The maximum allowance on the RS-25 is the cost of attendance (school budget) at the school attended, except for religious training or theological education provided by a seminary or sectarian school.  Allowing the COA as the maximum allowance does not mean DRS pays for books and supplies because funding also depends on the RS-13 form, and the FAFSA and RS-25 forms when required in Policy 1: Section D3 of this chapter. For invoice requirements, see Policy 1: Section E of this chapter.

  10. Tuition and Fees and Room and Board categories.


    1. For all individuals within commuting distance, the maximum allowance for room and board is $0 because they incur no additional expenses. Commuting student means a student (i) who lives within a 40-mile radius of the school or within one hour of travel time one way, and (ii) for whom adequate transportation to and from school is available.
       
    1. For individuals in proprietary vocational schools, technical institutes, associate degree program, or bachelor degree program before the junior year, the maximum allowance on the RS-25 for tuition and fees is the local community college rate and for room and board is $0 because the training and reasonable accommodation is available at the community college within commuting distance.
       
    1. For individuals in the junior year of college or beyond in a Virginia public university, the maximum allowance on the RS-25 for tuition and fees and room and board is the cost of attendance (school budget) at the school attended.
       
    1. For individuals in the junior year or beyond who choose to attend a proprietary vocational school or technical institute, private college, or out-of-state school even though their academic and disability needs can be met by a Virginia public school, on the RS-25 use the tuition and fees rate published in the DRS Training and Facilities Manual and double occupancy and 21 meals per week plan at the nearest Virginia public university. This includes individuals enrolled at Gallaudet University, The National Technical Institute for the Deaf (NTID) at the Rochester Institute of Technology, Marshall University, St. Andrews Presbyterian College, and other schools offering specialized disability services. This does not apply to religious training or theological education at a seminary or sectarian school.
       

    Exception 1: The supervisor may give written pre-approval for an individual who would normally be considered a commuting student to live away from the pre-enrollment home if the counselor and individual determine that it is in the individual’s best interest to do so. The maximum allowance is the cost of attendance at the school attended, not to exceed the actual cost. Examples include, but are not limited to:
     

    1. The commute is not feasible due to the individual’s disability.
       
    2. The individual lives in an abusive family situation or the home environment is too disruptive to allow the student to study or complete assignments.
       
    1. The individual’s Employment Plan has a strong emphasis on the individual gaining independent living skills and remaining at home would impede the individual from achieving this objective.
       

    Resources: The Transfer Modules published by the State Council of Higher Education ( http://ww.schev.edu) and the Virginia Community College system  (http://www.vccs.edu) will assist you to determine whether community college is comparable to the proprietary vocational school or technical institute training or first two years of the bachelor’s degree. The Chief Transfer Officer at the four-year university can confirm if the university will accept the community college credits. The Academic Common Market Website has a feature to search for majors and which colleges offer it.

  11. Personal and Miscellaneous category.


    1. For individuals in proprietary vocational schools or technical institutes, commuters, associate degree programs, or degree programs before the junior year of college, the maximum allowance on the RS-25 shall not exceed the cost of attendance (school budget) at the school attended. The counselor may allow as little as $0 or may allow cost of campus parking permit and one meal on campus per day (no more than 5 days per week for a maximum of 16 weeks) if the consumer is on campus for at least 4 hours.
    1. For individuals in the junior year of college or beyond, the maximum allowance on the RS-25 will probably be higher for the first year away from home to include one-time costs such as bed and bath linens, hangers, alarm clock, desk lamp, etc. as well as annual costs such as laundry money, toiletries, telephone deposit if required by school, etc. The counselor may allow as little as $0 and shall not exceed the cost of attendance at the school attended.  
       
    1. When the RS-13 but not the RS-25 is required, the maximum allowance is the same as for diagnostics and job placement (see Chapter 8.10, MAINTENANCE, Policy 1).
       
    1. Personal/miscellaneous costs must be costs over and above normal living expenses needed to participate in the school training program, and not for entertainment or fines or bad debts or fraternity dues, social clubs, etc.  
       
    1. For receipts requirement, see Policy 1: Section E of this chapter.

  12. Travel and Transportation category.

    1. For individuals in proprietary vocational schools, technical institutes, commuters, associate degree programs, or degree programs before the junior year of college, the maximum allowance on the RS-25 is the estimated round trip mileage per day on campus multiplied by the client mileage reimbursement rate.  The counselor may allow as little as $0 but shall not exceed the cost of attendance at the school attended.
       
    1. For individuals in the junior year of college and beyond, the maximum allowance is four one-way trips between school and home at the client mileage reimbursement rate (as little as $0 and shall not exceed the cost of attendance at the school attended).
       
    1. For client mileage reimbursement rate, see Chapter 8.20, TRANSPORTATION, Policy 1)
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[REVISED: 2/4/21]

Before the counselor authorizes school training services for inclusion on the client’s Individualized Plan for Employment (IPE), the counselor shall obtain supervisor approval as documented in the form of an actual service note in the case record. District director approval is also required for inclusion of a graduate degree on the client’s IPE.​   

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[REVISED: 1/21/99]

See DRS Services Reference Manual.  Use the Authorization and not the SPCC so if the client drops a course, the counselor can cancel or adjust the Authorization amount (if the SPCC is used, the school refunds the money into the student account and not to DARS).   

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[REVISED: 2/23/18]

  1. Before agreeing to use, or authorizing to, a school not listed in the DRS Training and Facilities Manual, the counselor shall consult with the DRS Transition Coordinator to verify academic accreditation and obtain approval to use the vendor.

  2. When assessing the need to use the cost of attendance (school budget) for a private college, proprietary vocational school, technical institute, or out-of-state school, the counselor or supervisor shall consult with the DRS Transition Coordinator to identify more cost-efficient vendors.

  3. All institutions of higher education, including proprietary vocational schools and technical institutes must be accredited by an accrediting body sanctioned by the U.S. Department of Education. For assistance contact the DRS Transition Coordinator.
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[REVISED: 2/23/18]

  1. RS-13.
     
    1. Each year the individual is receiving school training services, DRS requires an updated Client Financial Statement RS-13 form (including for individuals exempt from consumer financial participation to document the individual meets the criteria for exemption). For procedures, see Chapter 14.3, FINANCIAL, Policy 1
       
    2. When the RS-25 and FAFSA are not required, the RS-13 stands alone to fund school training services.
       
    3. The RS-13 form shall always be used to determine DRS funding for disability-related costs needed for school training services. When the RS-25 is required, use the RS-25 to report the disability-related school costs to the school.

  1. RS-25.
     
    1. The FAFSA and RS-25 shall be used to determine financial aid comparable benefit (per 2016 Federal Regulation 34 CFR § 361.48 (f)) and DRS funding for cost of attendance (school budget) when:
       
      1. the consumer financial participation on the RS-13 is 0% — 95%, and
         
      1. the school training program (including proprietary vocational schools and technical institutes, colleges, universities, and hospital schools of nursing) participates in the financial aid program, (more and more proprietary schools participate) and
         
      2. the individual is taking enough credits to apply for financial aid (varies by school).
         
      3. For training programs at  Wilson Workforce and Rehabilitation Center that participate in the financial aid program, the RS-25 does not apply.  The student shall submit a FAFSA and Client Financial Statement RS-13 form, and shall contribute to the cost of the training according to policy in Chapter 13, WWRC, Policy 3.  
         
    1. For schools that are not part of the Memorandum of Understanding between Virginia Association of Financial Aid Administrators and DRS (i.e., out-of-state schools), the counselor may complete the school’s section of the RS-25 form by obtaining the information from the school financial aid office.
       
    1. EFC. For individuals subject to consumer financial participation, the counselor cannot under any circumstances (including supervisory pre-approval) pay or offset the Estimated Family Contribution amount the financial aid program establishes based on the FAFSA (per agency mandate). For individuals exempt from consumer financial participation, on the RS-25 the counselor must adjust the Estimated Family Contribution to “$0” because federal regulation prohibits these individuals from financially participating in the cost of any Vocational Rehabilitation services (per 2016 Federal Regulation 34 CFR § 361.54).
       
    2. If the result of the RS-25 form is $0 or is insufficient, or the individual is ineligible for financial aid for a reason listed in this policy (See Policy 1: Section A1 of this chapter), DRS shall not revert to the RS-13 form (per agency mandate).

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[REVISED: 2/15/09]

  1. Vendor invoices for textbooks and supplies must itemize the items before the counselor can approve vendor payment (per agency mandate) and the counselor shall approve only those purchases that are appropriate. The individual shall be responsible for the remaining cost.

  2. At the counselor’s discretion, the individual may be reimbursed for pre-approved personal/miscellaneous expenses on a monthly budgeted basis or with a receipt.

  3. Vendor or client payment is also subject to policies and procedures in Chapter 14.4, VENDORS, Policy 3.
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