oversight

Students with Disabilities: Better Federal Coordination Could Lessen Challenges in the Transition from High School

Published by the Government Accountability Office on 2012-07-12.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

             United States Government Accountability Office

GAO          Report to the Ranking Member,
             Committee on Education and the
             Workforce, House of Representatives


July 2012
             STUDENTS WITH
             DISABILITIES
             Better Federal
             Coordination Could
             Lessen Challenges in
             the Transition from
             High School




GAO-12-594
                                                July 2012

                                                STUDENTS WITH DISABILITIES
                                                Better Federal Coordination Could Lessen
                                                Challenges in the Transition from High School
Highlights of GAO-12-594, a report to the
Ranking Member, Committee on Education
and the Workforce, House of Representatives




Why GAO Did This Study                          What GAO Found
The transition out of high school to            Students with disabilities face several longstanding challenges accessing
postsecondary education or the                  services that may assist them as they transition from high school into
workforce can be a challenging time,            postsecondary education or the workforce—services such as tutoring, vocational
especially for students with disabilities.      training, and assistive technology. Eligible students with disabilities are entitled to
Multiple federal agencies fund                  transition planning services during high school, but after leaving high school, to
programs to support these students              receive services that facilitate their transition they must apply as adults and
during their transition. In 2003, GAO           establish eligibility for programs administered by multiple federal agencies.
reported that limited coordination              Students with disabilities may face delays in service and end up on waitlists if
among these programs can hinder a
                                                these programs are full. In addition, while all five states GAO contacted have
successful transition. GAO was asked
                                                taken steps to coordinate their transition services and assist families with the
to provide information on the (1)
challenges students with disabilities
                                                transition process, officials said that it is still difficult for students and their parents
may face accessing federally funded             to navigate and for providers to coordinate services across different programs.
transition services; and (2) extent to          Officials and parents GAO spoke with also noted a lack of sufficient information
which federal agencies coordinate their         or awareness of the full range of service options available after high school on
transition activities. GAO reviewed             the part of students with disabilities, parents, and service providers. In addition,
relevant federal laws, regulations, and         state and local officials said students with disabilities may not be adequately
agency documents from Education,                prepared to successfully transition to life after high school. This may be due, in
HHS, Labor, and SSA, which                      part, to limited opportunities to engage in vocational and life skills training or
administer the key programs that                obtain work experience while in school.
provide transition services. GAO also
administered a data collection                  Students Move from Services Provided through Their High School to Services Delivered
                                                through Multiple Programs
instrument to gather program
information from these agencies.
Finally, GAO interviewed various
stakeholders, including state and local
officials, service providers, parents,
and students with disabilities, in five
states selected based on the number
of federal grants they received to fund
transition services.

What GAO Recommends
                                                The Departments of Education (Education), Health and Human Services (HHS),
To improve the provision of transition          and Labor (Labor), and the Social Security Administration (SSA) coordinate
services for students with disabilities,        transition activities to some degree, but their coordination has limitations and
GAO recommends that Education,
                                                they do not assess the effectiveness of their efforts. One coordinating body
HHS, Labor, and SSA develop an
                                                involves all four agencies and focuses on transition services. However, that
interagency transition strategy that
addresses (1) operating toward                  group’s primary coordination activity is information sharing among staff-level
common outcome goals for                        representatives rather than developing common outcome goals and establishing
transitioning youth; (2) increasing             compatible policies for operating across agencies. Agency officials told GAO that
awareness of available transition               a lack of compatible outcome goals for transitioning students and differences in
services; and (3) assessing the                 statutory eligibility criteria are among the barriers that hinder interagency
effectiveness of their coordination             coordination for this population. While agencies collaborate to some extent, their
efforts. All four agencies agreed with          efforts represent a patchwork approach and there is no single, formal,
the recommendation.                             government-wide strategy for coordinating transition services for students with
                                                disabilities. Moreover, it is unclear what impact coordination has on service
View GAO-12-594. For more information,
contact Revae E. Moran at (202) 512-7215 or    provision because agencies do not assess the effectiveness of their coordination
moranU@gao.gov.                                 activities.

                                                                                             United States Government Accountability Office
Contents


Letter                                                                                        1
                Background                                                                   4
                Students with Disabilities Face Several Longstanding Challenges
                  Accessing Federal Transition Services                                      9
                Federal Agency Coordination of Transition Activities Has
                  Limitations                                                               18
                Conclusions                                                                 27
                Recommendation for Executive Action                                         28
                Agency Comment and Our Evaluation                                           28

Appendix I      Scope and Methodology                                                       31



Appendix II     Federal Programs that Provide Transition Services to Youth with
                Disabilities                                                                37



Appendix III    Other Federal Coordination Efforts that Address Individuals with
                Disabilities, Including Students                                            49



Appendix IV     Comments from the Department of Education                                   51



Appendix V      Comments from the Department of Health and Human Services                   53



Appendix VI     Comments from the Department of Labor                                       60



Appendix VII    Comments from the Social Security Administration                            62



Appendix VIII   GAO Contact and Staff Acknowledgments                                       64




                Page i                                     GAO-12-594 Students with Disabilities
Related GAO Products                                                                                             65



Tables
                       Table 1: Organizations Contacted                                                          33
                       Table 2: Education Programs Providing Transition Services to
                                Youth with Disabilities (Ranked by Funding Level)                                37
                       Table 3: HHS Programs Providing Transition Services to Youth
                                with Disabilities (Ranked by Funding Level)                                      43
                       Table 4: Department of Justice Program Providing Transition
                                Services to Youth with Disabilities                                              45
                       Table 5: Labor Program Providing Transition Services to Youth
                                with Disabilities                                                                46
                       Table 6: SSA Programs Providing Transition Services to Youth with
                                Disabilities (Ranked by Funding Level)                                           47


Figures
                       Figure 1: Key Federal Legislation Providing for Services to
                                Transition-Age Students with Disabilities                                        6
                       Figure 2: Students Move from Services Provided through Their
                                High Schools to Services Delivered through Multiple
                                Programs                                                                         10
                       Figure 3: Federal Coordination Efforts Specific to Transition
                                Services                                                                         21
                       Figure 4: Federal Coordination Efforts That Focus on Individuals
                                with Disabilities or Youth                                                       49




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                       Page ii                                               GAO-12-594 Students with Disabilities
United States Government Accountability Office
Washington, DC 20548




                                   July 12, 2012

                                   The Honorable George Miller
                                   Ranking Member
                                   Committee on Education and the Workforce
                                   House of Representatives

                                   Dear Mr. Miller:

                                   The transition from high school to postsecondary education or the
                                   workforce can be a challenging time for all students, and particularly for
                                   those with disabilities who may need additional services such as tutoring,
                                   vocational training, assistive technology, and other supports to achieve
                                   their goals. This can be a daunting process, and research has
                                   documented that students with disabilities are less likely than their peers
                                   to successfully make the transition. For example, as of February 2012,
                                   the employment rate for young adults ages 20 to 24 with disabilities was
                                   less than half the rate of their peers without disabilities. When young
                                   adults with disabilities do not successfully transition out of high school,
                                   they may face a lifetime of continued reliance on public assistance,
                                   potentially leading to substantial costs to the government and society.
                                   Although the total amount of federal money spent to support students with
                                   disabilities in transitioning out of high school is not known, the federal
                                   investment in educating students with disabilities is substantial. In 2011,
                                   the Department of Education (Education) awarded about $11.5 billion in
                                   federal grants to states to help ensure that 6.6 million students with
                                   disabilities—approximately 2.2 million of whom were of transition-age 1—
                                   received a free appropriate public education, as required by the
                                   Individuals with Disabilities Education Act (IDEA), a key piece of
                                   legislation pertaining to transition. IDEA requires that beginning not later
                                   than the first individualized education program (IEP) to be in effect when
                                   the student turns 16, school officials must include in the IEP




                                   1
                                     In this report, we use the term “transition-age” to refer to youth between the ages of 14
                                   and 25. This age range covers youth served by the key programs we identified as
                                   providing transition services to youth with disabilities.




                                   Page 1                                                 GAO-12-594 Students with Disabilities
postsecondary goals and the transition services needed to assist the
student in reaching those goals. 2

Students remain eligible for transition planning and services, as well as
other IDEA services, until they exit high school. Once students exit high
school, they are no longer entitled to federal transition services under
IDEA. 3 Instead, they may apply and be found eligible for a number of
other separately administered federal programs that are authorized to
provide services that can assist youth with disabilities in their transition to
postsecondary education, employment, and independent living. GAO has
reported on the need for better coordination among federal disability
programs, including those serving students with disabilities. 4 This is one
reason that, as of 2011, federal disability programs remained on GAO’s
high risk list. 5 In light of questions about the accessibility and coordination
of transition services for students with disabilities, you requested we
provide information on: (1) challenges students with disabilities may face



2
  Pub. L. No. 108-446, 118 Stat. 2647, 2676, § 612(a)(1) (codified as amended at 20
U.S.C § 1412(a)(1)). 20 U.S.C. § 1414(d)(1)(A)(i)(VIII).
3
  Students remain eligible for transition planning and services, as well as other IDEA
services, until they graduate from high school with a regular high school diploma or
exceed the earlier of age 21 or the eligibility age for a free appropriate public education
under state law. While federal law authorizes students to receive a free appropriate public
education up until age 22, eligibility for students aged 18-21 is determined by states. 20
U.S.C. § 1412(a)(1) and 34 C.F.R. § 300.102 (2011).
4
  See GAO, People with Disabilities: Federal Programs Could Work Together More
Efficiently to Promote Employment, GAO/HEHS-96-126 (Washington, D.C.: Sept. 3,
1996); Highlights of a Forum: Modernizing Federal Disability Policy, GAO-07-934SP
(Washington, D.C.: August 2007); Special Education: Federal Actions Can Assist States in
Improving Postsecondary Outcomes for Youth, GAO-03-773 (Washington, D.C.: July 31,
2003); Summary of a GAO Conference: Helping California Youth with Disabilities
Transition to Work or Postsecondary Education, GAO-06-759SP (Washington, D.C.: June
20, 2006); Federal Disability Programs: More Strategic Coordination Could Help
Overcome Challenges to Needed Transformation, GAO-08-635 (Washington, D.C.: May
20, 2008); Young Adults with Serious Mental Illness: Some States and Federal Agencies
Are Taking Steps to Address Their Transition Challenges, GAO-08-678 (Washington,
D.C.: June 23, 2008); and High Risk Series: An Update, GAO-11-278 (Washington, D.C.:
February 2011).
5
  GAO publishes a high risk list to focus attention on government operations that it
identifies as high risk due to their greater vulnerabilities to fraud, waste, abuse, and
mismanagement or the need for transformation to address economy, efficiency, or
effectiveness challenges. This list is updated biennially to remove areas where progress
has been made and identify any new areas needing attention by Congress and the
executive branch.




Page 2                                                GAO-12-594 Students with Disabilities
accessing transition services under existing federal programs; and (2) the
extent to which federal agencies coordinate their transition activities.

To identify potential challenges, we reviewed the definitions of disability
and the eligibility criteria in selected federal statutes governing federal
programs that provide transition services. 6 To assess the extent to which
federal agencies coordinate their transition activities, we asked officials
from the four agencies that administer key programs serving students in
their transition out of high school—Education, the Departments of Health
and Human Services (HHS) and Labor (Labor), and the Social Security
Administration (SSA)—to provide information on their coordination efforts
and activities relating to transition services. We compared their responses
and agency documents to our criteria on activities that can enhance and
sustain collaboration among federal agencies. 7 In addition, we consulted
a number of experts in the field of transition and from advocacy
organizations that represent young adults with a wide range of disability
types. Finally, to obtain the perspectives of state and local agencies that
deliver transition services, we selected a nongeneralizable sample of five
states and contacted officials to obtain their views. We selected these
states based on the number of federal grants they received in fiscal year
(FY) 2011 to fund transition services, recommendations of agency
officials and experts, and geographic diversity. 8 Through a combination of
site visits and telephone interviews, we spoke with service providers and
officials from state education, vocational rehabilitation, developmental


6
  In this report, we use the term “transition services” to include educational services such
as tutoring or study skills assistance, school-based work experience programs, assistive
technology or accommodations; employment services such as vocational training, job
search assistance, job coaching, or supported employment; or other support services
such as independent living assistance and skill development, transportation, mentoring,
benefits counseling, information, guidance and referral services, advocacy, or financial
assistance for adaptive equipment or other assistive technology.
7
  In this report we use the term “coordination” broadly to include interagency activities that
others have variously defined as “collaboration,” “cooperation,” “integration,” or
“networking.” Although there is no commonly accepted definition of coordination, we
defined it as any joint activity by two or more organizations that is intended to produce
more public value than could be produced when the organizations act alone. See E.
Bardach, Getting Agencies to Work Together: The Practice and Theory of Managerial
Craftsmanship (Washington, D.C.: Brookings Institution, 1998).
8
 We visited the four states with a relatively large number of grants for programs that
provide transition services (California, Florida, Maryland, and Minnesota) and interviewed
officials by phone in the state with a relatively small number of grants for programs that
provide transition services (Nevada).




Page 3                                                  GAO-12-594 Students with Disabilities
             disability, and workforce agencies. In each state we visited, we also met
             with groups of students with disabilities and parents to discuss the
             challenges they face. Appendix I explains our scope and methodology in
             more detail.

             We conducted this performance audit from July 2011 through July 2012 in
             accordance with generally accepted government auditing standards.
             Those standards require that we plan and perform the audit to obtain
             sufficient, appropriate evidence to provide a reasonable basis for our
             findings and conclusions based on our audit objectives. We believe that
             the evidence obtained provides a reasonable basis for our findings and
             conclusions based on our audit objectives.


             To support the educational needs of children with disabilities, Congress
Background   originally enacted IDEA in 1975. 9 Part B of IDEA authorizes federal
             funding for children aged 3 through 21 with a range of disabilities who
             need special education services. To receive federal funds, states and
             local education agencies must identify and evaluate children who have
             disabilities and provide special education and related services, as well as
             supplementary aids and services when necessary, to those who are
             eligible. Such services and supports are formulated in an IEP, which is
             developed, discussed, and documented by a student’s IEP team. 10 In the
             2004 reauthorization of IDEA, Congress required that, beginning no later
             than age 16, a student’s IEP must include measurable postsecondary
             goals related to training, education, employment, and where appropriate,
             independent living skills. The IEP also must specify the transition




             9
               IDEA was originally enacted as the Education for All Handicapped Children Act. Pub. L.
             No. 94-142, 89 Stat. 773 (codified as amended at 20 U.S.C. §§ 1400-1482) (1975).
             10
                  20 U.S.C. § 1414(d).




             Page 4                                              GAO-12-594 Students with Disabilities
services 11 needed to assist the student in reaching those goals. 12 School
officials are required to invite the student to a meeting where the
transition services detailed in the IEP are discussed. When appropriate,
they also must invite a representative of any participating outside agency
(with the prior consent of the parent or student who has reached the age
of majority). 13

As students with disabilities exit high school, they may apply as adults
and be found eligible for a number of federally funded programs, including
federal disability programs, if they wish to obtain services important to
their transition. There is wide diversity in this population—students with
disabilities can have a range of physical and cognitive disabilities that can
affect their ability to learn. They may also demonstrate varying levels of
academic aptitude and achievement in different areas. Thus, the number
of programs for which each student may be eligible can vary widely based
on their abilities, postsecondary goals, and the types of supportive
services they may need to be successful. We identified a range of
programs that provide services to support students with disabilities in their


11
   Under IDEA, transition services are defined as a coordinated set of activities that (1) is
designed to be within a results-oriented process focused on improving the academic and
functional achievement of a child with a disability to facilitate the child’s movement from
school to post-school activities; (2) is based on the individual child’s needs, strengths,
preferences, and interests; and (3) includes instruction, related services, community
experiences, the development of employment and other post-school adult living
objectives, and when appropriate, acquisition of daily living skills and functional vocational
evaluation. 20 U.S.C. § 1401(34).
12
  Individuals with Disabilities Education Improvement Act of 2004, Pub. L. No. 108-446,
sec. 101, § 614(d)(1)(A)(i)(VIII),118 Stat. 2647, 2709 (codified at 20 U.S.C. §
1414(d)(1)(A)(i)(VIII)).
13
   20 U.S.C. § 1414(d)(1)(B)(vii) and 34 C.F.R. § 300.321(b)(1) and (3) (2011). In addition
to IDEA, other laws support the educational needs of students with disabilities. Section
504 of the Rehabilitation Act of 1973 prohibits entities that receive federal financial
assistance, including public and private schools, from discriminating on the basis of
disability against otherwise qualified individuals with disabilities. Pub. L. No. 93-112, §
504, 87 Stat. 355, 394 (codified as amended at 29 U.S.C. § 794). Regulations
implementing Section 504 are at 34 C.R.F pt 104 (2011). The Americans with Disabilities
Act of 1990 prohibits discrimination on the basis of disability by public entities and public
accommodations, including public and private schools, regardless of whether they receive
federal financial assistance. Pub. L. No 101-336, §§ 201(1), 202, 301(7)(J) and 302, 104
Stat. 337, 354 and 355 (codified at 42 U.S.C. §§ 12131(1), 12132, 12181(7)(J) and
12182). Title II regulations are at 28 C.F.R. part 35 and Title III regulations at 28 C.F.R. pt
36 (2011). The requirements of Section 504 and Titles II and III of the Americans with
Disabilities Act of 1990 and the rights of students with disabilities under them are not
addressed in this study.




Page 5                                                  GAO-12-594 Students with Disabilities
                                          transition out of high school. These programs vary in the target population
                                          served, services provided, grant funding amounts, and other
                                          characteristics. In addition, they are authorized by multiple federal laws
                                          (administered through various federal agencies), each with its own
                                          eligibility requirements and application processes. (See fig. 1). Moreover,
                                          federally funded programs that provide transition services, as defined in
                                          this report, are often delivered through state and local entities that have
                                          flexibility on how to administer services.

Figure 1: Key Federal Legislation Providing for Services to Transition-Age Students with Disabilities




                                          a
                                           Services under the Higher Education Act of 1965, as amended by the Higher Education Opportunity
                                          Act, begin largely when a student enters postsecondary education. Pub.L. No. 110-315, sec. 709(2),
                                          §§ 766-769, 122 Stat. 3078,3365-67 (codified at 20 U.S.C. §§ 1140f-1140i)
                                          b
                                           Students who meet certain criteria may receive SSI benefits prior to age 18; the Social Security
                                          Administration is statutorily required to redetermine the eligibility of all children receiving these
                                          benefits within one year of their 18th birthday. 42 U.S.C. § 1382c(a)(3)(H)(iii).
                                          c
                                           Students who meet certain criteria may receive services through the Workforce Investment Act of
                                          1998 (WIA) youth program between the ages of 14 and 21; services through the WIA adult program
                                          may begin at age 18. 29 U.S.C. § 2801(1) and (13).




                                          Page 6                                                         GAO-12-594 Students with Disabilities
The following four agencies have primary responsibility for administering
federal programs that can provide services to transition-age youth with
disabilities:

•     Education’s Rehabilitation Services Administration awards funds to
      state vocational rehabilitation (VR) agencies in the form of matching
      grants to help individuals with disabilities prepare for and engage in
      gainful employment. 14 VR programs require that an individualized plan
      for employment be developed for eligible students before they leave
      high school. 15 Furthermore, if the student is receiving special
      education services, this plan must be coordinated with the student’s
      IEP in terms of goals, objectives, and services.

•     Labor oversees the one-stop center system, a comprehensive
      workforce investment system created under the Workforce Investment
      Act of 1998 (WIA) that brings together multiple federally funded
      employment and training programs that can help all eligible individuals
      seeking employment and training—including students with
      disabilities. 16 Labor also administers the Disability Employment
      Initiative, which is designed to improve educational, training, and
      employment opportunities and outcomes for youth and adults with
      disabilities who are unemployed, underemployed, and/or receiving
      Social Security disability benefits.

•     SSA provides cash benefits to qualifying individuals with disabilities—
      including transition-age young adults—through its Disability Insurance




14
     29 U.S.C. §§ 702, 706 and 721(a)(2) and (3).
15
   29 U.S.C. § 721(a)(9) and 34 C.F.R. § 361.22(a)(2) (2011). If a state VR agency is
operating under an order of selection, a plan must be developed for students who are
eligible to receive services under the order of selection prior to when they leave school. A
VR agency must implement an order of selection when it anticipates it will not have
sufficient fiscal and/or personnel resources to fully serve all eligible individuals. 29 U.S.C.
§ 721(a)(5) and 34 C.F.R. § 361.36 (2011). An order of selection consists of priority
categories to which eligible individuals are assigned based on the significance of their
disability—individuals with the most significant disabilities are selected first for the
provision of vocational rehabilitation services.
16
     29 U.S.C. § 2841.




Page 7                                                  GAO-12-594 Students with Disabilities
      and Supplemental Security Income (SSI) programs. 17 SSA also
      administers the Ticket to Work program, which is designed to enable
      individuals with disabilities (who are receiving disability insurance or
      SSI benefits and are between the ages of 18 and 64) to obtain
      services needed to find, enter, and retain employment. They obtain
      these services from providers such as VR agencies. 18

•     HHS’s Centers for Medicare & Medicaid Services manages Medicaid,
      the joint federal-state health care financing program for qualifying low-
      income individuals. Within the Medicaid program, states provide home
      and community-based services to individuals with certain types of
      disabilities—which may include young adults—who might otherwise
      be cared for in institutional settings. 19 Because Medicaid usually does
      not cover home and community-based services, states must obtain a
      waiver to provide these services. Services provided in accordance
      with these waivers vary by state, are individualized, and may include,
      for example, case management, personal care attendants, or day or
      residential habilitation. 20

In addition, these and other federal agencies fund a number of other
programs through grants to states, localities, and nongovernmental
organizations that may assist students and young adults during their
transition from high school. Some of these grants explicitly target


17
    Individuals known as “disabled adult children” can receive Disability Insurance benefits
if they are age 18 or older, were disabled before age 22, and have at least one parent who
also receives Social Security payments because of retirement or disability or who is
deceased but worked long enough to be eligible to receive benefits. 20 C.F.R. §
404.350(a) (2011). The SSI program provides financial assistance to eligible individuals
who are age 65 or older, blind, or disabled, and who have limited income and resources.
42 U.S.C. § 1381a. Children under age 18 may qualify for SSI benefits if they meet SSA’s
disability definition and financial eligibility requirements. 20 C.F.R. § 416.906 (2011). SSA
is statutorily required to redetermine the eligibility of all children receiving these benefits
within one year of their 18th birthday. 42 U.S.C. § 1382c(a)(3)(H)(iii).
18
     42 U.S.C. § 1320b-19.
19
     42 U.S.C. § 1396n(c).
20
   “Habilitation services” are defined as “services designed to assist participants in
acquiring, retaining, and improving the self-help, socialization, and adaptive skills
necessary to reside successfully in home and community-based settings.” 42 U.S.C. §
1396n(c)(5). Habilitation services are flexible in nature, they can be day or residential, and
they can be specifically designed to fund services and supports that help an individual
obtain or maintain employment.




Page 8                                                  GAO-12-594 Students with Disabilities
                                 improving postsecondary outcomes for students with disabilities and
                                 others provide a range of support services such as assistive technology,
                                 information and referral, advocacy, transportation, leadership
                                 development, benefits counseling, and independent living services. (See
                                 app. II for more information on federal programs that received federal
                                 funding in FY 2011 to provide transition services to students with
                                 disabilities.)


                                 Students with disabilities face several challenges accessing federally
Students with                    funded programs that can provide transition services as they leave high
Disabilities Face                school for postsecondary education or the workforce. These include
                                 difficulty navigating multiple programs that are not always coordinated;
Several Longstanding             possible delays in service as they wait to be served by adult programs;
Challenges Accessing             limited access to transition services; a lack of adequate information or
Federal Transition               awareness on the part of parents, students, and service providers of
                                 available programs that may provide transition services after high school;
Services                         and a lack of preparedness for postsecondary education or employment.
                                 Prior GAO work identified many of these same challenges, which is
                                 indicative of the longstanding and persistent nature of the challenges
                                 facing students with disabilities as they transition out of high school. 21

Difficulty Navigating Multiple   In each of the five states we contacted, state officials said it can be
Programs that Provide            difficult for students with disabilities and their families to navigate the
Transition Services              multiple federal programs that provide transition services. 22 Some officials
                                 said that the shift from being automatically entitled to services under IDEA
                                 if identified as disabled while in high school to having to apply as adults
                                 and be found eligible for multiple programs after exiting high school is
                                 difficult for students and their parents to understand. (See fig. 2).




                                 21
                                      GAO-08-678; GAO-06-759SP; and GAO-03-773.
                                 22
                                   In this section, we quantified the challenges identified during our interviews as follows:
                                 we used “most” if a challenge was mentioned in more than 85 percent of our interviews;
                                 “many” or “frequently” if a challenge was mentioned in over half; “some” if a challenge was
                                 mentioned in less than half; and “a few” if a challenge was mentioned in less than 25
                                 percent of the interviews.




                                 Page 9                                                GAO-12-594 Students with Disabilities
Figure 2: Students Move from Services Provided through Their High Schools to Services Delivered through Multiple
Programs




                                        Note: Students may also receive services from other federal and nongovernmental programs.
                                        a
                                         States must identify, evaluate, and provide services to children with disabilities. Students with
                                        disabilities remain entitled to services until they graduate from high school with a regular high school
                                        diploma or exceed the earlier of age 21 or the eligibility age for a free appropriate public education
                                        under state law. While federal law authorizes students to receive a free appropriate public education
                                        up until age 22, eligibility for students aged 18-21 is determined by states. 20 U.S.C. § 1412(a)(1)
                                        and 34 C.F.R. § 300.102 (2011).
                                        b
                                            Includes job coaching, job placement, and supported employment.
                                        c
                                         Includes vocational assessment, vocational education, and work-based experiences.
                                        d
                                            Students must disclose their disability to obtain services in college.
                                        e
                                         SSA is statutorily required to redetermine the eligibility of all children receiving SSI benefits within
                                        one year of their 18th birthday. 42 U.S.C. § 1382(a)(3)(H)(iii).


                                        Many of the stakeholders told us that a lack of coordination between
                                        programs was another key challenge for students with disabilities and/or




                                        Page 10                                                           GAO-12-594 Students with Disabilities
their families. 23 For example, staff from a parent training and information
Center in Minnesota said that it is very challenging for parents to navigate
the system and coordinate resources for their children across programs.
In their experience, none of the program officials coordinate with those
from other programs to share information on clients. State officials
suggested that a lack of coordination between programs often arises as
early as during IEP transition planning meetings. IDEA requires high
schools to invite, with parental or student consent, representatives from
adult programs likely to be responsible for providing or paying for
transition services to the student after high school, such as VR, to these
meetings to the extent appropriate. 24 These representatives, however, are
not required to attend, and we heard that they are often not at the table
for transition planning meetings. VR officials from one state
acknowledged this, saying that while they try to attend transition planning
meetings, it is not always possible because of resource and time
constraints. Some of the stakeholders suggested that without the
commitment of local leaders and service providers to coordinate services
between high school and adult programs, there is little to no
communication between programs, which can create difficulty for families
trying to navigate across different programs.

In each of the five states we contacted, some officials said that differing
requirements for adult programs can confuse students and parents. For
example, officials from Florida’s department of VR said that the
requirement for VR clients to have an individualized plan for employment
that identifies an employment goal and the services and supports
necessary to achieve that goal can be confusing for youth who already
included transition plans and identified a career goal in their IEP. In
addition, the amount of documentation each program requires can be
overwhelming for students with disabilities and their parents. According to
a student in Maryland, there is a continuous administrative burden on
applicants to provide the same or similar information to multiple
programs. Officials we interviewed from three of the four federal agencies
acknowledged these challenges.




23
   The term “stakeholders” refers to federal, state, and local officials; students and
parents; and experts on transition.
24
     34 C.F.R. § 300.321(b)(3) (2011).




Page 11                                                 GAO-12-594 Students with Disabilities
                    In each of the states we contacted, officials suggested that it would be
                    helpful to appoint a case manager to coordinate services and guide
                    students and their families through the transition process. Some of the
                    parents and also officials from two of the four federal agencies agreed
                    that a case manager could help students with disabilities and their
                    families navigate across the multiple programs. However, officials from
                    one federal agency cautioned that it could be costly and, given that
                    programs that provide transition services are administered by different
                    federal agencies and implemented at the state and local level,
                    challenging to administer.

Delays in Service   Students with disabilities may also face delays in service upon leaving
                    high school as they wait to obtain services from adult programs or for
                    their eligibility determinations to be finalized. Many stakeholders said that
                    delays in service can be caused by limited financial or program
                    resources, which may leave youth with disabilities on waitlists for
                    services. In particular, states may have waitlists—sometimes with several
                    thousand individuals—for home and community-based waiver services.
                    The departments of VR in four of the five states we contacted were
                    operating under a federally required order of selection, requiring them to
                    serve individuals with the most significant disabilities before serving
                    others. 25 Several parents from Minnesota said that their children had
                    been on waitlists for waiver services or VR services for years. One parent
                    from Florida said that her adult son was living at home with no services or
                    employment options as he waited for waiver services from the state’s
                    department of disability. Officials from Nevada’s department of VR said
                    that delays in service may also occur when students with disabilities,
                    upon leaving high school, must return assistive technology devices on
                    loan from the school, such as software for blind individuals that reads text
                    on a screen in a computer-generated voice. According to officials, some
                    students go without these critical adaptive devices until VR is able to
                    equip them with the same or similar technologies.

                    Service delays can be exacerbated if students with disabilities have to
                    wait until program officials resolve who should provide and pay for
                    services. In addition, some adult programs will not provide services to


                    25
                       29 U.S.C. § 721(a)(5) and 34 C.F.R. 361.36. According to Education officials, 45 VR
                    agencies have implemented an order of selection, as required by federal law, because
                    they are unable to service all eligible individuals in the state due to their lack of financial or
                    staff resources.




                    Page 12                                                   GAO-12-594 Students with Disabilities
                               students who are still eligible to receive services under IDEA. 26 Officials
                               from two states said that, as a result, there has been a shift toward
                               keeping students with disabilities in high school longer so that schools
                               continue paying for services until students graduate or turn 22 years of
                               age. For example, officials from Maryland’s department of VR said that
                               students with developmental disabilities who decide to leave high school
                               before they age out of IDEA services often face a delay in services
                               because the state department of developmental disability will not provide
                               services to students younger than age 21. 27

                               Some of the stakeholders said that differing eligibility criteria, definitions
                               of disability, and assessment requirements for the various adult programs
                               can also result in service delays while youth with disabilities wait for
                               assessments or eligibility determinations. For example, officials in the four
                               states in which we spoke with higher education officials said some
                               colleges require students with disabilities to be reassessed before they
                               can receive accommodations, and that this can cause a delay in service
                               because there are long waitlists for these reassessments or because they
                               are cost prohibitive for some families.

Limited Access to Transition   Limited access to reliable public transportation to and from employment
Services                       programs and service providers—especially in rural areas—was also
                               frequently highlighted as a major challenge. For example, officials from
                               Florida said limited funding for transportation services contributes to the
                               lack of transportation for students with disabilities.

                               Officials in each of the states we contacted also said that certain groups
                               of students with disabilities are more likely to face limited service options
                               or gaps in service because their disabilities may be less visible or



                               26
                                  Young adults with disabilities may not be eligible for some adult services until they
                               graduate from high school with a regular diploma or exceed the age eligibility for a free
                               appropriate public education under state law because of “payer of last resort” provisions,
                               which specify the order in which funding sources or programs should pay for services. For
                               example, both VR and Medicaid function as payers of last resort—if another program or
                               funding source (for example IDEA) is still available to that individual, that other source
                               must be exhausted before VR and Medicaid will pay for services. 29 U.S.C. § 707
                               (regarding nonduplication), and 42 U.S.C. § 1396a(a)(25) and 42 C.F.R. § 433.139(b)
                               (regarding third-party liability) (2011).
                               27
                                  According to HHS officials, Maryland has waivers, Community Pathways and New
                               Directions Independence Plus, that can serve individuals with developmental disabilities
                               who are under the age of 21.




                               Page 13                                              GAO-12-594 Students with Disabilities
                                 because they are less likely to qualify for adult programs. These groups
                                 include students with developmental or cognitive disabilities, learning
                                 disabilities, mental health disabilities, autism, and mild disabilities.
                                 Further, we heard that there may be limited programs for students with
                                 hearing or visual impairments, and that if these students also have other
                                 disabilities, it can be difficult to determine which program (e.g., VR or a
                                 developmental disability agency) should provide services, which can lead
                                 to gaps in service. Similarly, officials said that students with disabilities
                                 who are in the juvenile justice system, are themselves parents, or are
                                 homeless may also be more likely to face gaps in service than other
                                 students with disabilities because they tend not to be aware of or
                                 connected to adult service providers. In addition, some students who
                                 qualified for services under IDEA and/or under Section 504 of the
                                 Rehabilitation Act may not meet the eligibility requirements for adult
                                 programs and may, therefore, have limited or no post-high school service
                                 options. For example, one parent told us that her daughter, who has a
                                 serious physical disability, did not receive any transition planning
                                 assistance and struggled to gain access to services such as personal
                                 care attendants who would help her successfully transition to a college
                                 out of state.

Lack of Adequate Information     A lack of adequate information and awareness of available program
and Awareness of Options after   options on the part of parents, students, and service providers was
High School                      another challenge highlighted during our site visits. Many stakeholders
                                 said that students with disabilities and their parents do not always receive
                                 enough information about the full range of service options after high
                                 school. For example, a parent from California said that she was very
                                 disappointed with the limited information she received from her school
                                 district and that she had no idea what resources were available for her
                                 son after he left high school. A student from Maryland expressed concern
                                 that students with disabilities who do not seek information about transition
                                 services outside of high school may not have access to information, and
                                 consequently, to needed services. In contrast, a few stakeholders said
                                 parents may receive too much information and feel overwhelmed. For
                                 example, a parent from California said that families may receive so much
                                 information that they do not remember everything and do not know where
                                 to seek help when the time comes. A staff member from the California
                                 Department of Education’s Workability program said that, even when
                                 information about transition services is available, it is generally not




                                 Page 14                                       GAO-12-594 Students with Disabilities
compiled and made available in one central place for families to access. 28
She recommended that states or programs develop an accessible, easy
to read transition manual that clearly lays out post-high school service
options.

Sometimes there was an issue with the accuracy of information parents
received. For example, officials in three of the five states we contacted
said that parents may be misinformed about programs, especially about
the ability of their children to retain SSI benefits. Officials from Florida’s
developmental disability agency noted that parents are often misinformed
by teachers or adult program service providers that their children will lose
these benefits entirely if they obtain any paid employment.

Lack of awareness of service options also extended to teachers and other
high school personnel. Many of the stakeholders said that teachers and
other high school personnel may not always be aware of post-high school
service options for students with disabilities. For example, one parent said
that while there are a lot of programs in her community that can aid
students in transition, school personnel are not aware of them and
therefore cannot appropriately guide students with disabilities and their
families. Moreover, some experts and state education officials said that
teacher training and professional development programs do not always
adequately prepare teachers to provide transition services or inform them
about the various agencies and resources available to students with
disabilities. A few of the officials, however, said that teachers in some
school districts are well trained in and aware of adult programs that can
provide transition services, which allows them to disseminate information
to students and their parents.

In addition, some stakeholders said that service providers from adult
programs may not be used to working with this student population or have
limited awareness of other adult programs that can provide
complementary transition services. For example, stakeholders in
Maryland and Nevada said that VR counselors need additional training to
work with transition-age youth with disabilities and officials from
Maryland’s local workforce agencies said that one-stop center staff need
more training to help these students enter the workforce. A representative


28
   California’s Workability program is a school-based work program for students with
disabilities, designed to offer the opportunity to complete high school while obtaining
marketable job skills.




Page 15                                                GAO-12-594 Students with Disabilities
                             from a parent training and information center in Maryland added that the
                             knowledge service providers have about other programs is piecemeal and
                             inconsistent. She suggested the federal government support additional
                             training for all professionals who work with students in transition.

Inadequate Preparation for   Many stakeholders said that high schools do not always adequately
Postsecondary Education or   prepare students with disabilities for college or the workforce, and cited
the Workforce                several contributing factors. According to some officials, the federal
                             requirement to begin transition planning by age 16 is too late. In fact,
                             officials in four of the five states we contacted said that schools are
                             required to start transition planning at an earlier age. 29 In addition, in all
                             five states we heard that schools’ emphasis on academic achievement
                             has left little time for vocational and life skills training, even though these
                             skills may be key to gaining and retaining employment—especially for
                             students with disabilities. Officials from Minnesota’s department of VR
                             said that schools need to pay greater attention to vocational training
                             because students with disabilities are at a distinct disadvantage if they
                             leave high school with no work experience. Further, officials from
                             Maryland’s department of developmental disabilities said that because
                             most jobs require a high school diploma, students with disabilities who
                             receive certificates instead of diplomas could find their employment
                             options significantly curtailed because many employers do not recognize
                             alternative completion documents. 30 As a transition specialist from
                             Maryland noted, many students with non-traditional diplomas end up in




                             29
                                Since the 2004 reauthorization of IDEA, schools have been required, beginning no later
                             than the first IEP that will be in effect when a student turns 16 years of age, to include in
                             the IEP postsecondary goals and the transition services needed to assist the student in
                             reaching those goals. Individuals with Disabilities Education Improvement Act of 2004,
                             Pub. L. No. 108-446, sec. 101, § 414(d)(1)(A)(i)(VIII), 118 Stat. 2647, 2709 (codified at 20
                             U.S.C. § 1414(d)(1)(A)(i)(VIII)). Furthermore, we were told by state officials that some
                             states require that transition planning begin earlier than age 16, including four of the five
                             states we contacted, which required transition planning to begin at age 14.
                             30
                                In some states, some students with disabilities receive a certificate of completion or
                             other alternatives to a high school diploma.




                             Page 16                                                GAO-12-594 Students with Disabilities
sheltered workshops because they are not considered to be qualified for
competitive employment opportunities. 31

In addition, according to some stakeholders, adult programs are not
always designed to meet the needs of transition-age youth with
disabilities in ways that will help them succeed in college or in a job. For
example, a few state officials said that the VR system does not provide
incentives for serving transition-age youth with disabilities because VR’s
performance indicators reward counselors for serving clients who find and
maintain employment for at least 90 days, and youth with disabilities may
take longer to do so. 32 Similarly, we heard from a few officials, including
representatives from California’s workforce agency, that the time frame of
the employment outcome measures under the WIA youth program may
be too short—for example, the employment retention rate at 6 months 33—
and not appropriate for transition-age youth with disabilities who often
require follow-up support longer than 6 months in order to be successful
at a job. 34

Another frequently mentioned challenge was low expectations by parents,
service providers, and even students themselves about what students
with disabilities can achieve. These groups told us that low expectations
often contributed to students with disabilities being unprepared for college
or the workforce because parents, teachers, and others may not have
exposed them to all available options for life after high school.
Consequently, some officials said students may be directed to apply for


31
  To prevent curtailment of employment opportunities for individuals with disabilities,
Labor is authorized under certain conditions to issue certificates permitting employers to
pay them less than the otherwise required minimum wage. 29 U.S.C. § 214(c). Sheltered
workshops, which are also referred to as work centers, exclusively or primarily employ
people with disabilities certified to be paid less than the otherwise required minimum
wage.
32
  We previously reported that Education does not comprehensively measure the
performance of VR for certain key populations, including transition-age youth. See GAO,
Vocational Rehabilitation: Better Measures and Monitoring Could Improve the
Performance of the VR Program, GAO-05-865 (Washington, D.C.: Sept. 23, 2005).
33
     29 U.S.C. § 2871(b)(2)(A)(i)(II).
34
   We previously reported that WIA performance measures can create disincentives for
one-stop centers to serve clients with disabilities. See GAO, Workforce Investment Act:
Labor Has Taken Several Actions to Facilitate Access to One-Stops for Persons with
Disabilities, but These Efforts May Not Be Sufficient, GAO-05-54 (Washington, D.C.: Dec.
14, 2004).




Page 17                                               GAO-12-594 Students with Disabilities
                            social security benefits instead of receiving job training, and that students
                            with more serious disabilities who could benefit from competitive
                            employment (i.e., applying for and getting a job) may be steered instead
                            toward adult day training programs and sheltered workshops.



Federal Agency
Coordination of
Transition Activities
Has Limitations

Federal Agencies            Education, HHS, Labor, and SSA coordinate transition activities to some
Coordinate on Specific      degree, but their coordination has limitations and they do not assess the
Transition Activities but   effectiveness of their efforts. They coordinate on some specific transition
                            activities, but their efforts are primarily focused on information sharing
Face Some Barriers          and lack elements that our prior work identified as enhancing and
                            sustaining effective coordination. 35 We have reported on the importance
                            of developing common outcome goals and of engaging in strategic
                            planning and coordination to address issues that cut across agency
                            boundaries. This can take many forms, ranging from occasional meetings
                            between agency staff to more structured joint policy teams operating over
                            a long period of time. 36

                            One federal coordination effort—the Federal Partners in Transition
                            Workgroup—targets transition services to students with disabilities and
                            involves all four agencies that administer the key programs that provide
                            transition services to youth with disabilities. 37 However, this workgroup is
                            informal and primarily involves information sharing among staff-level
                            representatives, according to agency officials. For example, SSA officials



                            35
                               While some coordination efforts included in this report involve other federal agencies,
                            we focused on Education, HHS, Labor, and SSA because these four agencies administer
                            the key programs serving students in their transition out of high school.
                            36
                                 GAO-06-15.
                            37
                               The Federal Partners in Transition Workgroup focuses on all youth, including students,
                            with disabilities. In this report, we refer to the group’s efforts related to students with
                            disabilities, as appropriate, to be consistent with the focus of our review.




                            Page 18                                               GAO-12-594 Students with Disabilities
told us that in past meetings, their staff presented information about SSI
requirements for the transitioning youth population, including the process
for redetermining eligibility for SSI when youth turn age 18, and
information on the Student Earned Income Exclusion. 38 To a lesser
extent, some workgroup members also reported that they have jointly
developed guidance for students with disabilities and grantees, including
a fact sheet about how students can take advantage of Schedule A hiring
authority for federal jobs. 39 In addition, the workgroup has convened
forums to help students with disabilities develop their leadership and self-
advocacy skills and to discuss action steps to ensure students are
prepared to move successfully to adulthood. This workgroup also
convened a meeting of representatives of technical assistance centers to
discuss coordination among the centers. Agencies involved in the
workgroup reported varying levels of involvement in more extensive
coordination activities, such as policymaking, program planning, and joint
strategic planning. Labor officials leading the effort told us they are in the
process of drafting a strategic plan to identify objectives, activities, and
outcomes for the group.

Education and Labor also participate in the National Community of
Practice in Support of Transition, which was developed by the IDEA
Partnership and focuses on joint efforts among state and local agencies
to coordinate and improve outcomes for youth with disabilities in
transition. Both agencies also have established intra-agency groups to
facilitate collaboration between internal program offices. 40 (See fig. 3.)


38
  The Student Earned Income Exclusion allows SSA to exclude a certain amount of a
beneficiary’s earned income when determining benefits payments. 42 U.S.C. §
1382a(b)(1). This exclusion is one of the incentives SSA offers to encourage work among
SSI recipients. In addition, the Social Security Disability Amendments of 1980 allowed for
continued payments under VR or a similar program to eligible beneficiaries until the
completion of the program, beneficiary participation ends, or continued participation will
not increase the likelihood of exit from the disability benefit rolls. Pub. L .No. 96-265, §
301, 94 Stat. 449-50 (codified as amended at 42 U.S.C. §§ 425(b) and 1383(b)(6)).
Examples of specific programs that trigger this provision include Ticket to Work, VR, and
special education services under IDEA for individuals ages 18 through 21.
39
  Schedule A hiring authority allows individuals with disabilities to apply for a federal
appointment through a noncompetitive hiring process. 5 C.F.R. § 213.3102(u). (2012).
40
   The IDEA Partnership is funded by the Office of Special Education Programs through
the Technical Assistance and Dissemination to Improve Services and Results for Children
with Disabilities program. 20 U.S.C. § 1463. The partnership brings together
representatives from national associations, service providers, and agencies that have a
vested interest in improving results for all students, including those with disabilities.




Page 19                                                GAO-12-594 Students with Disabilities
Education officials also said they recently sponsored a national transition
conference for more than 800 professionals, families, and students to
facilitate collaboration and communication across federal, state, and local
entities. Aside from these efforts, officials said most of their interagency
coordination regarding transition services occurs on an ad hoc basis,
such as sharing white papers and holding informal discussions about
policies, performance measures, and technical assistance to states. In
addition, several federal coordination efforts broadly target disadvantaged
youth or all individuals with disabilities and may address some aspects of
transition. (See app. III).




Page 20                                      GAO-12-594 Students with Disabilities
Figure 3: Federal Coordination Efforts Specific to Transition Services




                                          Note: While some coordination efforts included in this figure involve other federal agencies, we
                                          focused on Education, HHS, Labor, and SSA because they administer the key programs serving
                                          students in their transition out of high school. Key activities coordinated and mechanisms of
                                          coordination were reported by at least half of the reporting member agencies. For efforts with two key
                                          member agencies, only mechanisms and activities reported by both agencies were included.


                                          Some federal agencies are involved in new demonstration projects that
                                          plan to address coordination across systems at the state and local level.
                                          For example, an official from HHS stated that the agency has coordinated
                                          with Education and Labor to develop grants under the new Projects of
                                          National Significance Partnerships in Employment Systems Change. This
                                          initiative will provide resources for state agencies and service providers to
                                          collaborate with other services systems to develop statewide model
                                          demonstration projects that expand competitive employment for youth
                                          with developmental disabilities. In another example, officials at all four



                                          Page 21                                                     GAO-12-594 Students with Disabilities
agencies said they have been involved in early discussions regarding
implementation of the new Promoting Readiness of Minors in
Supplemental Security Income (PROMISE) initiative, which will fund pilot
projects in states to promote positive changes in the outcomes of youth
SSI recipients and their families. 41 Education officials said they are in the
process of holding meetings to gather input on potential projects from
federal partners and stakeholders, including state agency officials, service
providers, researchers, policy experts, and families. As part of the
initiative, Education and SSA officials said they will work collaboratively to
identify legislative barriers to competitive employment and ways to
improve coordination at the state level. In addition to collaborative efforts
across agencies, Education officials said that six grants focusing on
transition and funded by their Rehabilitation Services Administration are
in their fifth and final year of operation. According to Education officials,
these grants demonstrate the use of promising practices of collaborative
transition planning and service delivery to improve the postsecondary
education and employment outcomes of youth with disabilities.

Despite these efforts, federal agency officials identified several barriers
that limit their ability to coordinate. We have reported that federal
agencies face a range of coordination barriers, one of which stems from
goals that are not mutually reinforcing or are potentially conflicting,
making it difficult to reach a consensus on strategies and priorities. 42 We
found interagency coordination is enhanced by having a clear and
compelling rationale for staff to work across agency lines and articulate
the common federal outcomes they are seeking. 43 Indeed, officials
identified a lack of compatible outcome goals for transitioning students
with disabilities as one of the key barriers that hinder their coordination
efforts.

The incompatibility in outcome goals is highlighted in the implementation
of specific programs, according to agency officials. For example, goals for
employment outcomes in VR and workforce programs are in some cases


41
   PROMISE, which was first funded in FY 2012, is a joint initiative of Education, HHS,
Labor, and SSA. Education officials said they are currently in the planning stage of the
initiative.
42
  Mutually reinforcing goals or strategies are designed to help align agency activities,
core processes, and resources to achieve common outcomes.
43
     GAO-06-15.




Page 22                                               GAO-12-594 Students with Disabilities
countered by requirements for students to prove that their disabilities limit
their ability to work in order to receive SSI benefits. 44 Similarly, officials
told us that, in early interagency discussions regarding the PROMISE
initiative, special education officials focused on students’ access to
postsecondary education, while VR and SSA officials were more
concerned about students’ earnings. Officials from all four agencies said
that aligning outcome goals for transition-age students with disabilities
would enhance interagency coordination and help agencies approach
transition in a more integrated way. Some officials suggested establishing
a common agreement on desired outcomes for transitioning students,
such as economic self-sufficiency or engagement in meaningful
employment, volunteer work, or postsecondary education by a certain
age.

Differences in statutory eligibility criteria among programs also limit
federal agencies’ ability to coordinate, according to agency officials. For
example, one official said that special education and SSI programs, in
effect, have different legal definitions of “child” 45 and “transition
services,” 46 making it more difficult to identify potential service recipients
across programs and to share data about individuals served by multiple



44
   42 U.S.C. § 1382c(a)(3) (defining “disabled” in part as “unable to engage in any
substantial gainful activity by reason of any medically determinable physical impairment).
HHS officials said parents’ fear of losing health insurance benefits for their children with
disabilities creates a similar disincentive for these youth to pursue competitive
employment. However, officials said new provisions under the Patient Protection and
Affordable Care Act that allow individuals to remain on their parents’ insurance policies
until age 26 could help mitigate this. Pub. L. No. 111-148, sec. 1001, § 2714, 124 Stat.
119,132 (codified at 42 U.S.C. § 300gg-14).
45
    The age range for children served through special education under IDEA is 3 through
21. 20 U.S.C. § 1412(a)(1)(B). SSI serves children from birth to age 18, (42 U.S.C. §
1382c(c)), at which point there must be a redetermination as to whether or not they are
still eligible for SSI benefits as adults (42 U.S.C. § 1382c(a)(3)(H)(iii)).
46
   Under IDEA, transition services are provided through special education and make up a
coordinated set of activities that (1) is designed to be within a results-oriented process
focused on improving the academic and functional achievement of a child with a disability
to facilitate the child’s movement from school to post-school activities; (2) is based on the
individual child’s needs, strengths, preferences, and interests; and (3) includes instruction,
related services, community experiences, the development of employment and other post-
school adult living objectives, and, when appropriate, acquisition of daily living skills and
functional vocational evaluation. 20 U.S.C. § 1401(34). The definitions of transition
services under IDEA and the Rehabilitation Act of 1973 are very similar and there is no
statutory definition of transition services under SSI.




Page 23                                                GAO-12-594 Students with Disabilities
programs. 47 As a result, agencies are limited in their ability to target
services to recipients who might benefit from them. Moreover, integrating
information about students served by multiple programs over time would
allow agencies to assess the impact of transition services across
programs, according to Education and SSA officials. In addition, officials
said sharing information about common service recipients would help
agencies serve students with disabilities in a more streamlined way. For
instance, SSA could identify students receiving employment and training
services through other federal programs and provide counseling to help
them understand how paid employment affects their SSI benefits and
health insurance, with an eye toward helping students attain greater
economic self-sufficiency. Officials cautioned, however, that privacy
concerns may limit some information sharing and make it difficult to
integrate information from multiple systems. While officials noted that the
Federal Partners in Transition Workgroup has discussed these
information sharing challenges at some of its meetings, one official noted
that there is no substantive effort to address them at the federal level.

Officials also identified a lack of clarity on agencies’ roles and
responsibilities for providing and paying for transition services as another
coordination barrier. For example, each program has its own statutory
authority, permitting it to pay only for certain services or types of services.
This can create confusion, particularly at the state and local levels, about
who is responsible for paying for a particular service. It can also result in
frequent debates about which agency is responsible for funding services,
according to some officials, creating a disincentive for agencies to work
together. While certain state agencies such as educational agencies and
VR agencies are required to articulate roles and responsibilities in
interagency agreements, 48 Education officials suggested that a program’s
authorizing statute should clearly define agency responsibilities to help



47
   Education officials noted that federal agencies have recently begun working to improve
data collection and sharing. Education also updated its regulations on the Family
Educational Rights and Privacy Act and clarified the means by which education entities,
including school districts, can collect and share data with other agencies. 76 Fed. Reg.
75,604 (Dec. 2, 2011) (codified at 34 C.F.R. pt. 99) (2011). We also previously reported
on efforts to develop statewide longitudinal data systems that link education and
employment databases. See GAO, Postsecondary Education: Many States Collect
Graduates’ Employment Information, but Clearer Guidance on Student Privacy
Requirements Is Needed, GAO-10-927 (Washington, D.C.: Sept. 27, 2010), 4.
48
     34 C.F.R. § 300.154 (2011).




Page 24                                              GAO-12-594 Students with Disabilities
                              avoid confusion and minimize potential delays and disruptions in
                              delivering transition services.


Agencies Lack a               Although federal agencies are engaged in some coordination efforts,
Government-wide Strategy      these efforts represent a patchwork approach and officials at all four
or Framework for              agencies indicated there is no single, formal, government-wide strategy
                              for coordinating transition services. While such a strategy is not required,
Coordinating Transition       we have previously cited the need for an overall federal strategy and
Services                      government-wide coordination to align policies, services, and supports
                              among the various disability programs, which include supports for
                              transition-age students. 49 Agency officials acknowledged that coordination
                              specifically on transition services could be improved. For example, one
                              official said agencies could work collaboratively to identify opportunities to
                              address legislative and regulatory barriers to coordinating transition
                              services. Officials added that improved data collection and sharing could
                              help agencies adopt a more coordinated and crosscutting approach to
                              delivering transition services to students with disabilities. Labor officials
                              leading the Federal Partners in Transition Workgroup said that, while an
                              overall plan for transition remains beyond the group’s scope of work, a
                              framework that identifies what is needed for a successful transition could
                              be used at the federal level to review collaboration across systems and to
                              identify definition, service, and funding gaps. 50 Such a framework could
                              also be used at the local level to identify gaps in communities and
                              individual plans.


Federal Agencies Do Not       It is unclear whether existing federal coordination efforts have had a
Assess the Effectiveness of   positive effect on access to transition services because agencies do not
Their Coordination Efforts    assess their coordination efforts. We have reported that developing
                              mechanisms to monitor, evaluate, and report on the results of their
                              coordination efforts can help key decision makers within agencies, as well



                              49
                                   GAO-11-278.
                              50
                                 According to Education and Labor officials, this framework is referred to as the
                              “Guideposts to Success” and was developed by Labor’s Office of Disability Employment
                              Policy, in collaboration with the National Collaborative on Workforce Disability for Youth
                              (http://www.ncwd-youth.info/guideposts). According to Labor officials, the framework
                              currently includes the following components of a successful transition: school-based
                              preparatory experiences, career preparation and work-based learning experiences, youth
                              development and leadership, connecting activities, and family involvement and supports.




                              Page 25                                              GAO-12-594 Students with Disabilities
as clients and stakeholders, obtain feedback for improving both policy
and operational effectiveness. For example, coordinating agencies could
require members with lead responsibilities for a focus area to report on
their progress in achieving defined objectives. 51 Federal officials said that
coordination has helped improve relationships and communication across
agencies administering transition services, yielding an increased
understanding of each other’s research, policy, and evidence-based
practices as a result of their involvement in interagency efforts, including
the Federal Partners in Transition Workgroup. Agency officials also told
us that some coordination efforts have led to increased engagement in
transition policy by students with disabilities and their families and
improved results in achieving career readiness and self-sufficiency.
However, these results are difficult to corroborate because agencies do
not evaluate the impact of their efforts, and in many cases do not track
coordination outcomes at the federal level, according to agency officials. 52
Furthermore, the effectiveness of existing federal coordination efforts is
questionable, as evidenced by persistent challenges students with
disabilities face navigating multiple programs.

Some federal agencies monitor compliance with requirements for
grantees to coordinate with other state and local entities under individual
programs. For example, Part B of IDEA requires state educational
agencies to report annually on their performance using 20 indicators
established by the Secretary. 53 One of the indicators measures the state’s
compliance with the requirement under IDEA to include postsecondary
goals and transition services in the IEPs of students age 16 and above;
and to invite the student and, if appropriate, representatives from other
participating state agencies to the student’s IEP team meetings if
transition services are to be discussed. 54 Similarly, state VR agencies
must report annually to the Rehabilitation Services Administration on


51
     GAO-06-15.
52
  Labor officials said the intra-agency Youth with Disabilities Workgroup tracks progress
toward outcomes through an informal internal work plan. Officials participate in monthly
meetings to discuss status updates on policy guidance issuance, leveraging resources,
upcoming webinars, and innovative initiatives.
53
     20 U.S.C. § 1416(b)(2)(C)(ii)(II).
54
   Part B-SPP/APR Related Requirements,
http://www2.ed.gov/policy/speced/guid/idea/bapr/index.html.




Page 26                                              GAO-12-594 Students with Disabilities
              whether they have identified the responsibilities of other agencies through
              statute, regulation, or written agreements, and to undergo monitoring of
              their coordination activities. 55 These monitoring reviews, however, mainly
              address compliance with programmatic and fiscal requirements, help
              ascertain whether state agencies have in place signed formal interagency
              agreements, and check whether these agreements include key
              components such as providing technical assistance to school districts on
              transition planning. Agency officials noted that there are no quantifiable
              measures to assess how effectively transition services are coordinated,
              and that any assessment is typically based on observation and a review
              of practices and procedures rather than on data. 56


              The current federal approach to assisting students with disabilities in their
Conclusions   transition to postsecondary education or the workforce necessitates that
              students and their parents navigate multiple programs and service
              systems to piece together the supports these students need to achieve
              maximum independence in adulthood. Under this complex structure,
              information dissemination and service coordination are essential. Without
              receiving accurate and timely information about available services,
              students may miss opportunities to access needed services that could
              mean the difference between achieving an optimal level of self-sufficiency
              and relying on public assistance to meet their basic needs. While officials
              report that federal agency coordination efforts, such as the Federal
              Partners in Transition Workgroup, have improved relationships and built
              shared knowledge across participating agencies, they have yet to adopt a
              broader interagency strategic approach to addressing longstanding
              challenges in providing transition services to students with disabilities.
              The transition workgroup, in particular, represents a unique vehicle that
              could provide leadership in developing such a strategy specifically
              focused on students with disabilities who are transitioning out of high
              school. Given the multiple agencies involved in supporting this population,
              in conjunction with multiple eligibility criteria and definitions established in
              statute, the lack of such a strategy is a missed opportunity to break down
              coordination barriers and work across agency boundaries. Only then can



              55
                   20 U.S.C. § 1412(a)(12).
              56
                 Education officials said they are working with SSA to determine how to track outcomes
              of transition interventions, including coordination, in SSA’s planned evaluation of the
              PROMISE initiative.




              Page 27                                             GAO-12-594 Students with Disabilities
                     agencies systemically address persistent transition challenges and
                     improve outcomes for students with disabilities. Furthermore, without
                     assessing the effectiveness of federal coordination efforts, agencies are
                     unable to determine what works well, what needs improvement, and
                     where best to direct increasingly constrained federal resources.


                     To improve the provision of transition services to students with disabilities
Recommendation for   through enhanced coordination among the multiple federal programs that
Executive Action     support this population, we recommend that the Secretaries of Education,
                     HHS, and Labor, and the Commissioner of SSA direct the appropriate
                     program offices to work collaboratively to develop a federal interagency
                     transition strategy. This strategy should address:

                     1. compatible policies, procedures, and other means to operate across
                        agency boundaries towards common outcomes for transitioning youth
                        and their families;
                     2. methods to increase awareness among students, families, high school
                        teachers, and other service providers on the range of available
                        transition services; and
                     3. ways to assess the effectiveness of federal coordination efforts in
                        providing transition services.

                     To the extent that legislative changes are needed to facilitate the
                     implementation of this transition strategy, agencies should identify and
                     communicate them to the Congress.


                     We provided a draft of this report to officials at the Departments of
Agency Comment and   Education, HHS, and Labor, and to SSA for their review and comment.
Our Evaluation       Their responses are reprinted, respectively, in appendixes IV, V, VI, and
                     VII of this report. They also provided technical comments, which we
                     incorporated as appropriate.

                     In their comments, all four agencies agreed with our recommendation and
                     noted that they have been or will be in contact with each other to expedite
                     preliminary discussions on an implementation strategy.

                     Some of the agencies also described coordination efforts beyond those
                     mentioned in our draft report. Specifically, Education said it is currently
                     engaged in numerous transition coordinating activities with HHS, Labor,
                     and SSA related to discretionary grants, legislative proposals, draft
                     regulations, policy positions, and program improvements. Education



                     Page 28                                      GAO-12-594 Students with Disabilities
highlighted the National Transition Conference it hosted in May 2012,
explaining that the four agencies worked together to plan and participate
in all stages of the conference with the goals of raising awareness of
services, sharing promising practices, and creating an action agenda to
improve transition outcomes for youth with disabilities.

HHS noted that it funds the Consortium to Enhance Postsecondary
Education for Individuals with Developmental Disabilities. This consortium
conducts research, provides training and technical assistance, and
disseminates information on promising practices that support individuals
with developmental disabilities to increase their independence,
productivity and inclusion through access to postsecondary education.
Since 2010, HHS has also collaborated with Education and Labor on
Project SEARCH, a program to support local students with disabilities in
their last year of high school to experience work opportunities within these
federal agencies.

Labor stated that it plans to reach out to Education and SSA to explore
ways to formalize its Federal Partners in Transition Workgroup. This
group will work to help align policies, services, and supports provided by
various programs to transition-age youth with disabilities, and to help
identify legislative and regulatory barriers that prevent the coordination of
transition services. Moreover, this group would assess the impact of its
coordination efforts by developing common outcome goals.

Finally, HHS noted that the Developmental Disabilities Assistance and Bill
of Rights Act of 2000 does not provide for direct transition services. In
response, we clarified, in figure 1, that the act provides funding for
activities that support employment and training for youth with disabilities.
HHS also questioned the relevance of several programs included in our
list of federal programs that provide transition services, on the basis that
the programs do not provide direct services. We agree that one of these
programs, Partnership in Employment Systems Change Grants, is
intended to enhance collaboration rather than provide transition services;
therefore, we removed it from the list. However, we disagreed that the
Youth Information, Training and Resources Centers program be omitted
from the list. It provides self-advocacy services that we consider to be a
type of transition service for youth. Similarly, we disagreed that
Developmental Disabilities Protection and Advocacy should be omitted
from the list. This program provides information on transition services and
supports to youth, among other things. Consequently, both programs are
still included.



Page 29                                       GAO-12-594 Students with Disabilities
As agreed with your office, unless you publicly announce the contents of
this report earlier, we plan no further distribution until 30 days from the
report date. At that time, we will send copies of this report to the
Secretaries of Education, HHS, and Labor, as well as the Commissioner
of SSA, and other interested parties. In addition, the report will be
available at no charge on our website at: http://gao.gov.

If you or your staff have any questions concerning this report, please
contact me at (202) 512-7215 or moranr@gao.gov. Contact points for our
Offices of Congressional Relations and Public Affairs may be found on
the last page of this report. Key contributors to this report are listed in
appendix VIII.

Sincerely yours,




Revae Moran
Director, Education, Workforce and
Income Security Issues




Page 30                                      GAO-12-594 Students with Disabilities
Appendix I: Scope and Methodology
             Appendix I: Scope and Methodology




             Our review examined the (1) challenges students with disabilities may
             face accessing federally funded transition services; and (2) extent to
             which federal agencies coordinate their transition activities. To determine
             the challenges students with disabilities may face accessing transition
             services as they leave high school for postsecondary education or the
             workforce, we selected a nongeneralizable sample of five states and
             interviewed state and local officials responsible for administering the key
             federal programs that provide transition services. We visited four states:
             California, Florida, Maryland, and Minnesota, and interviewed officials in
             Nevada by phone. In the four states we visited, we also met with groups
             of parents and students with disabilities to discuss the challenges they
             face. In addition, we met with a number of experts in the field of transition
             and with associations representing young adults with a wide range of
             disability types to obtain their perspectives on challenges students face
             during transition. Finally, we reviewed the definitions of disability and the
             eligibility criteria in selected federal statutes that govern relevant federal
             programs providing transition services to identify any potential legislative
             or regulatory challenges they may pose.

             To assess the extent to which the four key federal agencies that
             administer programs providing transition services—the Departments of
             Education (Education), Health and Human Services (HHS), and Labor
             (Labor), and the Social Security Administration (SSA)—coordinate their
             transition activities, we interviewed agency officials, obtained their written
             responses to questions about their coordination efforts, and reviewed
             agency documents. We analyzed this information based on GAO criteria
             detailing activities that can enhance and sustain collaboration among
             federal agencies. We conducted this performance audit from July 2011 to
             July 2012 in accordance with generally accepted governmental auditing
             standards. Those standards require that we plan and perform the audit to
             obtain sufficient, appropriate evidence to provide a reasonable basis for
             our findings and conclusions based on our audit objectives. We believe
             that the evidence obtained provides a reasonable basis for our findings
             and conclusions based on our audit objectives.

             We selected the five states in our nongeneralizable sample based on the
             number of grants each state received under key federal programs that
             provide transition services, recommendations from agency officials and
             experts, and geographic diversity, to the extent possible. To identify these
             key federal programs that provide grants to states and localities for




             Page 31                                       GAO-12-594 Students with Disabilities
Appendix I: Scope and Methodology




transition services, we searched the Catalog of Federal Domestic
Assistance (CFDA) 1 and asked relevant agency officials to verify this list
of programs and identify any programs that were not captured in our
search results. Based on this search, we identified six federal grant
programs that had a specific focus on improving transition services, and
we looked at the distribution of grants to select states that received a
relatively high number of federal grants for transition services. 2 We also
asked agency officials and experts for their recommendations of states
with model programs or promising practices related to transition services
and/or state-level collaborative efforts to improve transition outcomes. We
did not do an independent legal analysis to verify program information
from the CFDA or agency officials. To identify what additional challenges,
if any, students may face in states with relatively few programs that
provide transition services, we also selected one state with relatively few
federal grant programs to determine if the key challenges identified were
similar to those in other states.

In each state we visited, we met with officials from state departments of
education or special education, higher education, vocational
rehabilitation, developmental disabilities, workforce agencies, 3 and staff
from parent training and information centers. 4 In addition, with the
exception of Nevada, staff from parent training and information centers in



1
  CFDA is a government-wide compendium of federal programs, projects, services, and
activities that provide assistance or benefits to the American public. While the General
Services Administration (GSA) maintains the CFDA system and website, the content of
individual program descriptions is the responsibility of the agency that has issued the
program description. The Office of Management and Budget serves as an intermediary
agent between the federal agencies and GSA and provides oversight to the necessary
collection of federal domestic assistance program data.
2
 The six federal programs were: Education’s Model Comprehensive Transition and
Postsecondary Programs for Students with Intellectual Disabilities, Regional Parent
Training and Information Technical Assistance Centers, and Rehabilitation Services
Administration’s Parent Information and Training Projects; HHS’s Youth Information,
Training and Resource Centers; Labor’s Disability Employment Initiative; and SSA’s Youth
Transition Demonstration Projects.
3
  In a few states we visited, our interviews with workforce agency officials included staff
from WIA one-stop centers.
4
 There were three exceptions: In Florida and California, we did not meet with higher
education officials, although we did meet with two higher education associations in
California; and in Maryland we did not meet with the state workforce agency, although we
obtained written responses to our questions from several local workforce entities.




Page 32                                                GAO-12-594 Students with Disabilities
                                         Appendix I: Scope and Methodology




                                         each state assisted us by organizing discussion groups with parents and
                                         students with disabilities that were in the process of planning their
                                         transition from high school to postsecondary education or employment or
                                         had recently made the transition out of high school. In a few states, we
                                         also met with officials from centers for independent living, other
                                         nongovernmental organizations that received federal grants to provide
                                         transition services, and transition specialists and experts. See table 1 for
                                         a complete list of the organizations and groups we interviewed. During
                                         our interviews, we discussed challenges students with disabilities may
                                         face—including legislative or administrative barriers, potential gaps in
                                         transition services, knowledge of teachers and other service providers
                                         about transition services and options, parent and student awareness of
                                         available transition services and options, and coordination among federal
                                         agencies providing transition services. Finally, we asked officials from the
                                         relevant Education, HHS, Labor, and SSA program offices for their
                                         perspectives on the challenges faced by transitioning students with
                                         disabilities.

Table 1: Organizations Contacted

Stakeholder               Organizations and groups interviewed
California                State Departments of Education, Rehabilitation, Developmental Services, and Employment
                          Development; State Council on Developmental Disabilities; a Workforce Investment Act One-stop
                          Center; the State Foundation for Independent Living Centers; the State Transition Leadership Team and
                          Transition specialists, experts, and coordinators; representatives from Higher Education groups and
                          institutions; representatives from the State Workability Program; representatives from two Parent
                          Training and Information Centers; and parents of and students with disabilities.
Florida                   State Department of Education, Bureau of Exceptional Students and Divisions of Vocational
                          Rehabilitation and Blind Services; State agencies for Persons with Disabilities and Workforce Innovation;
                          Transitions specialists and coordinators; representatives from a Parent Training and Information Center;
                          representative from three non-profit organizations serving transition-age youth; and parents of and
                          students with disabilities.
Minnesota                 State Departments of Special Education, Human Services, and Employment and Economic
                          Development, including the State Services for the Blind; Special Education Directors; a representative
                          from a National Center on Secondary Education and Transition; representatives from higher education
                          groups and institutions; representatives from one Parent Training and Information Center;
                          representatives from one non-profit organization serving transition-age youth; and parents of and
                          students with disabilities.
Maryland                  State Departments of Education, Divisions of Special Education and Rehabilitation Services, and
                          Disabilities; the State Developmental Disability Administration; the State Higher Education Commission;
                          representatives from one Parent Training and Information Center; representatives from one non-profit
                                                                                                       a
                          organization serving transition-age youth; several local workforce agencies ; and parents of and students
                          with disabilities.
Nevada                    State Departments of Special Education and Vocational Rehabilitation; and representatives from one
                          Parent Training and Information Center.




                                         Page 33                                              GAO-12-594 Students with Disabilities
                                            Appendix I: Scope and Methodology




Subject matter experts and   We spoke with 13 experts or groups that focus on transition, including groups representing students with
Associations                 developmental disabilities, students who are deaf or hard of hearing, students with learning disabilities,
                             and students with intellectual and significant developmental disabilities
Federal agencies             Education: Office of Special Education Programs; Rehabilitation Services Administration; and the Office
                             of Postsecondary Education.
                             Labor: Office of Disability Employment Policy; and Employment and Training Administration
                             HHS: Administration on Developmental Disabilities; and Centers for Medicare and Medicaid Services
                             SSA: Office of the Deputy Commissioner, Retirement and Disability Policy
                                            Source: GAO.
                                            a
                                             We received written responses to our interview questions from some of Maryland’s local workforce
                                            agencies, but did not speak with them in person.


                                            To supplement the information collected during our interviews, we
                                            reviewed written responses and documents provided by officials from
                                            state and local organizations; reviewed selected statutory language
                                            related to some of the main legislative challenges identified by federal,
                                            state and local officials; and conducted a limited literature review of recent
                                            research related to transition challenges.

                                            To evaluate the extent to which federal agencies coordinate their
                                            transition activities, we asked officials from Education, HHS, Labor, and
                                            SSA to complete a data collection instrument we developed that
                                            requested information on their coordination efforts and activities relating
                                            to transition services. We reviewed agency officials’ written responses to
                                            determine whether their efforts were formal or informal, targeted towards
                                            transitioning students with disabilities, which agencies were involved, and
                                            which specific activities were coordinated. We also interviewed agency
                                            officials from relevant program offices at each agency to obtain additional
                                            information about ongoing coordination efforts related to transition
                                            services. These interviews also addressed inter- and intra-agency
                                            coordination efforts related to transitioning students with disabilities,
                                            examples of successful outcomes from these coordination efforts, any
                                            agency assessments of their coordination efforts, and potential barriers to
                                            coordination. In addition, we reviewed and analyzed available documents
                                            from each agency, including their strategic plans, performance reports,
                                            and agency performance measures; program websites and descriptions;
                                            and other relevant agency documents, such as joint technical guidance.
                                            We assessed the extent of the agency’s coordination efforts based on




                                            Page 34                                                   GAO-12-594 Students with Disabilities
Appendix I: Scope and Methodology




GAO’s criteria for practices agencies can use to help enhance and
sustain interagency collaboration. 5

To provide an overview of federal programs that provide transition
services to youth with disabilities, we identified 21 such programs
administered by five federal agencies: Education, HHS, the Department
of Justice, Labor, and SSA. 6 (See app. II). To identify these programs, we
first searched the CFDA using key subject terms related to transition
services for students with disabilities. 7 This search produced a preliminary
list of programs that was reviewed independently by two analysts. Each
analyst reviewed the program descriptions in CFDA and from the relevant
program websites, as necessary, and independently determined whether
a program should be excluded due to clear lack of relevance to transition
services for students with disabilities. The analysts then compared and
discussed their decisions to further refine the list of programs.

From this second list, we selected programs that met the following
criteria: they (1) exclusively serve individuals with disabilities, including
students of transition-age (age 14 to 25); (2) provide transition services
directly to youth going from high school to postsecondary education or the
workforce and/or services to their families; and (3) received federal
funding in fiscal year 2011.

We determined CFDA was sufficiently reliable for our purposes by
confirming with federal agency officials that the programs identified met
our criteria and obtaining information from agencies about any additional
programs for our consideration. Specifically, we asked officials to correct
any information we obtained from CFDA and program websites, identify



5
    GAO-06-15.
6
  The 21 programs included in this appendix met the specific selection criteria described in
this appendix. In contrast, the programs described in the background section of this report
are examples of broader programs administered by Education, HHS, Labor, and SSA that
support transition-age students with disabilities, although they may not directly provide
transition services.
7
  We determined key subject terms by inputting basic key words, such as ‘disability,’
‘student,’ and ‘transition,’ into the subject terms field of the CFDA advanced search form.
This field produced a list of searchable subject terms related to each of the basic key
words. From this list, we selected those subject terms that addressed at least two of the
following topic areas: (1) disabilities, (2) youth or students, (3) vocational rehabilitation,
and (4) postsecondary education.




Page 35                                                 GAO-12-594 Students with Disabilities
Appendix I: Scope and Methodology




any programs meeting our selection criteria that were not included in our
search results, and provide additional information on the selected
programs. 8 We followed up with agency officials through teleconferences
and email, as necessary, to clarify program information and make a
decision to include or exclude programs. We reviewed agency
documentation and selected laws and regulations to verify eligibility
criteria, including definitions of disability and funding information. To
assess the reliability of recipient data reported in our tables, we reviewed
agency officials’ responses to questions regarding how they collected the
data, any potential limitations of the data, and the databases and systems
used to maintain the information on program recipients. To assess the
reliability of funding data, we reviewed publicly available and agency-
provided budget documents. In cases where funding amounts for specific
programs were not separately reported, we clarified the information with
agency officials and noted that data were reported by the agency. Based
on our review of agency officials’ responses to our questions and of
budget documentation, we determined that the recipient and funding data
we reported were sufficiently reliable to include in this report.




8
  We obtained information on the program title, purpose, services provided, and eligibility
criteria from CFDA and program websites. We asked officials to verify or correct this
information and provide additional information on funding amounts and recipient data.




Page 36                                               GAO-12-594 Students with Disabilities
Appendix II: Federal Programs that Provide
                                              Appendix II: Federal Programs that Provide
                                              Transition Services to Youth with Disabilities



Transition Services to Youth with Disabilities

                                              Tables 2 to 6 of this appendix contain information on various federal
                                              programs that provide transition services to youth with disabilities.

Table 2: Education Programs Providing Transition Services to Youth with Disabilities (Ranked by Funding Level)

                                                    Types of transition                                  Recipient
                                                                                                              a                    b
Program                Purpose                      services provided         Eligibility criteria       data             Funding
Special Education      Provide free appropriate     •   Instruction           Child with a disability    Total number     Type of funding:
Grants to States       public education to all      •   Community             (i.e., intellectual,       of recipients    Formula grants
                       children with disabilities       experiences           emotional, or learning     served in        and program
                                                                              disabilities; hearing,     school year      technical
                                                    •   Development of
                                                                              speech, language,          2010-11:         assistance to
                                                        employment and
                                                                              visual, or orthopedic      6,558,053        states, fiscal year
                                                        other post-school
                                                                              impairments; autism;                        (FY) 2011
                                                        adult living                                     Number and
                                                                              traumatic brain injury;                     obligations:
                                                        objectives                                       percentage of
                                                                              or other health
                                                    •   Daily living skills   impairments) who           recipients who   $11.5 billion
                                                                              needs special              were             FY 2012
                                                    •   Functional
                                                                              education and related      transition-age   appropriations:
                                                        vocational                                             c
                                                                              services, as               youth in
                                                        evaluation                                                        $11.6 billion
                                                                              determined by a team       school year
                                                    •   Transportation                                   2010-11:
                                                                              of qualified
                                                    •   Physical and          professionals and the      2,198,474
                                                        occupational          child’s parent             (34 percent)
                                                        therapy
Vocational             Assist states in creating    •   Job-related           Individual with a          Total number     Type of funding:
Rehabilitation State   and operating                    services including    disability (i.e., a        of recipients    Formula grants to
Grants                 comprehensive                    job search and        physical or mental         served in FY     states
                       rehabilitation programs          placement             impairment that            2011:
                       to prepare disabled                                    results in a substantial            d       FY 2011
                                                    •   Vocational                                       589,773          obligations:
                       individuals for                  guidance and          impediment to
                       competitive employment                                 employment) who            Number and       $2.9 billion
                                                                                                                                      i
                                                        counseling                                       percentage of
                                                                              requires vocational                         FY 2012
                                                    •   Vocational or other                              recipients who
                                                                              rehabilitation services                     appropriations:
                                                        training services                                were
                                                                              to prepare for, secure,
                                                    •   Assistive and                                    transition-age   $3.1 billion
                                                                              retain, or regain                e
                                                        rehabilitation        employment                 youth in FY
                                                        technology                                       2011:
                                                                                                                  d
                                                    •   Supported                                        179,535
                                                        employment                                       (30 percent)
                                                    •   Transportation




                                              Page 37                                                    GAO-12-594 Students with Disabilities
                                            Appendix II: Federal Programs that Provide
                                            Transition Services to Youth with Disabilities




                                              Types of transition                                      Recipient
                                                                                                            a                    b
Program              Purpose                  services provided             Eligibility criteria       data             Funding
Centers for          Establish, operate, and •    Information and           Individual with a          Total number     Type of funding:
Independent Living   provide financial            referral services         significant disability     of recipients    Grants to
                     assistance to a          •   Independent living        means an individual        served in FY     consumer-
                     statewide network of         skills training           with a severe physical     2011:            controlled,
                     centers for independent                                or mental impairment       238,005          community based,
                                              •   Peer counseling
                     living, designed to                                    whose ability to                            cross-disability,
                     enhance independence     •   Advocacy                  function independently     Number and
                                                                                                       percentage of    nonresidential
                     and productivity of                                    in the family or                            private nonprofit
                     individuals with                                       community or whose         recipients who
                                                                                                       were             agencies
                     significant disabilities                               ability to obtain,
                                                                            maintain, or advance       transition-age   FY 2011
                                                                                                             f
                                                                            in employment is           youth in FY      obligations:
                                                                            substantially limited      2011:            $80.1 million
                                                                            and for whom the           31,703           FY 2012
                                                                            delivery of                (13 percent)     appropriations:
                                                                            independent living
                                                                                                                        $80 million
                                                                            services will improve
                                                                            the ability to function,
                                                                            continue functioning,
                                                                            or move toward
                                                                            functioning
                                                                            independently in the
                                                                            family or community
                                                                            or to continue in
                                                                            employment,
                                                                            respectively
American Indian      Provide vocational           •   Job-related           American Indian (i.e.,     Total number     Type of funding:
Vocational           rehabilitation services to       services including    person who is a            of recipients    Grants to
Rehabilitation       American Indians with            job search and        member of any federal      served in FY     governing bodies
Services             disabilities residing on         placement             or state Indian tribe or   2011:            of Indian tribes or
                     or near Federal or State     •   Vocational            community) with a          8,130            consortia of those
                     reservations and help            guidance and          disability (i.e., a        (approx.)        governing bodies
                     them prepare for and             counseling            physical or mental                          located on federal
                     engage in gainful                                      impairment that            Number and
                                                  •   Vocational or other                              percentage of    and state
                     employment                                             results in a substantial                    reservations
                                                      training services                                recipients who
                                                                            impediment to
                                                  •   Assistive and         employment)                were             FY 2011
                                                      rehabilitation                                   transition-age   obligations:
                                                                                                             e
                                                      technology                                       youth in FY      $43.6 million
                                                                                                       2011:
                                                  •   Supported                                                         FY 2012
                                                      employment                                       Data on age of   appropriations:
                                                                                                       individuals
                                                  •   Transportation                                                    $37.9 million
                                                                                                       served not
                                                                                                       collected




                                            Page 38                                                    GAO-12-594 Students with Disabilities
                                            Appendix II: Federal Programs that Provide
                                            Transition Services to Youth with Disabilities




                                                 Types of transition                                    Recipient
                                                                                                             a                    b
Program                Purpose                   services provided           Eligibility criteria       data             Funding
Supported              Provide supplemental      •   On-the-job and          Individual eligible for    Total number     Type of funding:
Employment             funds to state vocational     systematic training     vocational                 of recipients    Formula grants to
Services for           rehabilitation agencies   •   Job development         rehabilitation services,   served in FY     state vocational
Individuals with the   to help support the cost                              determined to have a       2011:            rehabilitation
                                                 •   Follow-up services
Most Significant       of supported                                          most significant           34,667
                                                                                                                d
                                                                                                                         agencies
Disabilities           employment services for •     Observation and         disability, and for
                       individuals with the most     supervision at          whom supported             Number and       FY 2011
                       significant disabilities      training sites          employment is the          percentage of    obligations:
                       participating in the VR                               rehabilitation objective   recipients who   $29.1 million
                       State Grants program                                  based on a                 were
                                                                                                        transition-age   FY 2012
                                                                             comprehensive                    e          appropriations:
                                                                             assessment of              youth in FY
                                                                                                        2011:            $29.1 million
                                                                             rehabilitation needs               d
                                                                                                        13,454
                                                                                                        (39 percent)
Special Education— Ensure parents of             •    Financial support of   Parent of child or         Total number     Type of funding:
Parent Training and children with disabilities        parent information     youth with a disability    of recipients    Project grants to
Information Centers receive training and              centers and            (i.e., intellectual,       served in FY     parent
                    information to help               community parent       emotional, or learning     2011:            organizations
                    improve results for their         resource centers       disabilities; hearing,     1,498,007
                                                                                                                   g
                    children                                                 speech, language,                           FY 2011
                                                 •    Technical                                         Number and       obligations:
                                                      assistance             visual, or orthopedic
                                                                             impairments; autism;       percentage of    $28 million
                                                                             traumatic brain injury;    recipients who
                                                                                                        were             FY 2012
                                                                             or other health                             appropriations:
                                                                             impairments) or            transition-age
                                                                                                              e
                                                                                                        youth in FY      $28.9 million
                                                                             parent who suspects
                                                                             their child may have a     2011:
                                                                                                                 g
                                                                             disability or has been     107,600
                                                                             inappropriately            (parents of
                                                                             identified as having a     transition-age
                                                                             disability                 youth)
                                                                                                        (7 percent)
Assistive              Maximize access to        •    Assistive          Individual with a              Total number     Type of funding:
Technology State       assistive technology           technology devices disability (as defined         of recipients    Formula grants to
Grants                 devices and assistive          and services       by any federal or              served in FY     states
                       technology services for                           applicable state law)          2011:
                       individuals with                                  who would be enabled                            FY 2011
                                                                                                        1,375,472        obligations:
                       disabilities and their                            by assistive
                       family members                                    technology device or           Number and       $25.6 million
                                                                         service to minimize            percentage of
                                                                                                        recipients who   FY 2012
                                                                         deterioration in                                appropriations:
                                                                         functioning, to                were
                                                                                                        transition-age   $25.6 million
                                                                         maintain a level of
                                                                         functioning, or achieve        youth in FY
                                                                         a greater level of             2011:
                                                                         functioning in any             Data on age of
                                                                         major life activity            individuals
                                                                                                        served not
                                                                                                        collected.




                                            Page 39                                                     GAO-12-594 Students with Disabilities
                                          Appendix II: Federal Programs that Provide
                                          Transition Services to Youth with Disabilities




                                                Types of transition                                  Recipient
                                                                                                          a                    b
Program              Purpose                    services provided         Eligibility criteria       data             Funding
Independent Living   Expand and improve         •   Core independent      Individual with a          Total number     Type of funding:
State Grants         independent living             living services,      significant disability     of recipients    Formula grants to
                     services to individuals        including training    means an individual        served in FY     states
                     with significant           •   Support               with a severe physical     2011:
                     disabilities. Services are                           or mental impairment                        FY 2011
                                                    independent living                               59,391           obligations:
                     intended to promote full       centers operations    whose ability to
                     integration and inclusion                            function independently     Number and       $23.4 million
                                                •   Outreach to                                      percentage of
                     of individuals into                                  in the family or                            FY 2012
                                                    unserved and                                     recipients who
                     mainstream society                                   community or whose                          appropriations:
                                                    underserved                                      were
                                                                          ability to obtain,
                                                    populations                                      transition-age   $23.4 million
                                                                          maintain, or advance             f
                                                                          in employment is           youth in FY
                                                                          substantially limited      2011:
                                                                          and for whom the           4,826
                                                                          delivery of                (8 percent)
                                                                          independent living
                                                                          services will improve
                                                                          the ability to function,
                                                                          continue functioning,
                                                                          or move toward
                                                                          functioning
                                                                          independently in the
                                                                          family or community
                                                                          or to continue in
                                                                          employment,
                                                                          respectively
Protection and       Support systems for       •    Information and       Individual with a          Total number     Type of Funding:
Advocacy of          protection and advocacy        technical             disability (i.e., a        of recipients    Formula grants to
Individual Rights    for the rights of              assistance            physical or mental         served in FY     designated
                     individuals with          •    Advocacy services     impairment that            2011:            protection and
                     disabilities who are                                 results in a substantial   14,739           advocacy
                                               •    Legal
                     ineligible for advocacy                              impediment to                               agencies
                                                    representation,                                  Number and
                     services from other                                  employment) who
                                                    including legal                                  percentage of    FY 2011
                     programs                                             requires vocational
                                                    counsel and                                      recipients who   obligations:
                                                                          rehabilitation services
                                                    litigation services                              were             $17.7 million
                                                                                                                                    h,i
                                                                          to prepare for, secure,
                                                                          retain, or regain          transition-age
                                                                                                     youth in FY      FY 2012
                                                                          employment and who                          appropriations:
                                                                          needs protection and       2011:                          h,i
                                                                                                     Data on age of   $17.7 million
                                                                          advocacy services
                                                                          beyond the scope of        individuals
                                                                          other programs             served not
                                                                                                     collected




                                          Page 40                                                    GAO-12-594 Students with Disabilities
                                              Appendix II: Federal Programs that Provide
                                              Transition Services to Youth with Disabilities




                                                Types of transition                                       Recipient
                                                                                                               a                    b
Program                Purpose                  services provided             Eligibility criteria        data             Funding
Model                  Create or expand model •     Technical                 Student with an             Total number     Type of funding:
Comprehensive          comprehensive                assistance and            intellectual disability     of recipients    Grants to
Transition and         transition and               information               (i.e., cognitive            served in FY     institutions of
Postsecondary          postsecondary            •   Academic                  impairment with             2011:            postsecondary
Programs for           programs for students        enrichment                significant limitations     507              education
Students with          with intellectual                                      in intellectual and
                                                •   Socialization                                         Number and       FY 2011
Intellectual           disabilities. Funds also                               cognitive functioning
Disabilities (TPSID)   support a coordinating   •   Independent living        and adaptive                percentage of    obligations:
                       center that provides         skills, including self-   behavior) who is or         recipients who   $11 million
                                                                                                                                       i

                       related services             advocacy                  was eligible for special    were
                                                                                                          transition-age   FY 2012
                                                •   Integrated work           education and related                        appropriations:
                                                                              services                    youth in FY
                                                    experiences and                                                        $11 million
                                                                                                          2011:
                                                    career skills
                                                                                                          430
                                                •   Individual planning
                                                    for course of study                                   (85 percent)
Helen Keller           Maximize employment      •   Training,                 Individual who is deaf-     Total number     Type of Funding:
National Center for    and independent living       counseling, and           blind (i.e., has a low      of recipients    Non-competitive
Deaf-Blind Youth       opportunities for deaf-      technical                 central visual acuity       served in FY     grant to Helen
and Adults             blind individuals by         assistance                with corrective lenses,     2011:            Keller Services for
                       providing services to    •   Service projects          a visual field defect, or   1,356            the Blind, Inc.
                       those individuals, their                               a progressive visual
                                                •   Work experiences                                      Number and       FY 2011
                       families, and service                                  loss; has a severe
                                                    and internships                                       percentage of    obligations:
                       providers nationwide                                   chronic hearing
                                                •   Vocational and            impairment or               recipients who   $9.1 million
                                                                                                                                        i

                                                    rehabilitation            progressive hearing         were
                                                                                                          transition-age   FY 2012
                                                    services                  loss; and has extreme                        appropriations:
                                                                              difficulty attaining        youth in FY
                                                •   Short-term training                                                    $9.1 million
                                                                              independence in daily       2011:
                                                    for youth in
                                                    secondary                 life activities or          Data on age of
                                                    education                 employment due to           individuals
                                                                              these impairments)          served not
                                                                                                          collected.
Protection and         Support protection and       •   Information           Individual with a           Total number     Type of Funding:
Advocacy for           advocacy services to             services              disability (as defined      of recipients    Formula grants to
Assistive              assist in the acquisition,   •   Advocacy services     by any federal or           served in FY     designated
Technology             utilization, or                                        applicable state law)       2011:            protection and
                                                    •   Legal
                       maintenance of                                         who would be enabled        2,089            advocacy
                                                        representation
                       assistive technology                                   by an assistive                              agencies
                       devices and services for                               technology device or        Number and
                       individuals with                                       service to minimize         percentage of    FY 2011
                       disabilities                                           deterioration in            recipients who   obligations:
                                                                              functioning or achieve      were             $4.3 million
                                                                              a greater level of          transition-age
                                                                                                          youth in FY      FY 2012
                                                                              functioning in any                           appropriations:
                                                                              major life activity         2011:
                                                                                                          Data on age of   $4.3 million
                                                                                                          individuals
                                                                                                          served not
                                                                                                          collected




                                              Page 41                                                     GAO-12-594 Students with Disabilities
                                        Appendix II: Federal Programs that Provide
                                        Transition Services to Youth with Disabilities




                                            Types of transition                                                        Recipient
                                                                                                                            a                           b
Program             Purpose                 services provided                       Eligibility criteria               data                     Funding
Rehabilitation      Provide financial       •   Technical                           Individual with a                  Total number             Type of funding:
Services            assistance to projects      assistance                          disability (i.e., a                of recipients            Grants to states
Demonstration and   and demonstrations that •   Supported                           physical or mental                 served in FY             and public or
Training Programs   expand and improve the      employment                          impairment that                    2011:                    nonprofit
(Transition Model   provision of                                                    results in a substantial           2,096                    organizations
                                            •   Parent information
Demonstration       rehabilitation and                                              impediment to
                                                and training                                                           Number and               FY 2011
Grants)             related services                                                employment) who
                                            •   Career preparatory                  requires vocational                percentage of            obligations:
                                                and pre-                            rehabilitation services            recipients who           $3 million
                                                                                                                                                          i,j

                                                employment                          to prepare for, secure,            were
                                                                                                                       transition-age           FY 2012
                                                experiences                         retain, or regain                                           appropriations:
                                                                                    employment                         youth in FY
                                            •   Youth development                                                                               $0 (funding for
                                                                                                                       2011:
                                                activities                                                                                      program ended in
                                                                                                                       2,096
                                            •   Practices to                                                                                    FY2011)
                                                enhance family                                                         (100 percent)
                                                involvement
                                        Source: Catalog of Federal Domestic Assistance and information provided by Department of Education officials.
                                        a
                                         Data reported on transition-age youth refer to youth ages 14 to 25, unless otherwise noted. All
                                        recipient data reported by agency officials.
                                        b
                                         Funding data obtained from publicly available and agency-provided budget documentation, unless
                                        otherwise noted.
                                        c
                                            Includes youth ages 14 to 22 only; program services end when youth turn 22.
                                        d
                                         Reflects number of recipients whose cases were closed in FY 11. Cases may not have been closed
                                        for all individuals who received services in FY 11, but information on age is only reported at case
                                        closure. For the Vocational Rehabilitation Grants to States program, 1 million individuals were served
                                        in FY 11. 34 C.F.R. § 361.42 (2011).
                                        e
                                            For this program, data reported are for individuals ages 14 to 24.
                                        f
                                        Includes youth ages 5 to 24. However, officials reported the preponderance of recipients is older than
                                        age 14.
                                        g
                                         Reflects the number of instances of services provided. Youth, parents, and professionals may
                                        request information from the centers more than once.
                                        h
                                            Amount includes funds used to support training and technical assistance.
                                        i
                                            Data reported by agency officials.
                                        j
                                        Officials reported that this amount represents obligations for transition model demonstration grants
                                        only.




                                        Page 42                                                                       GAO-12-594 Students with Disabilities
                                            Appendix II: Federal Programs that Provide
                                            Transition Services to Youth with Disabilities




Table 3: HHS Programs Providing Transition Services to Youth with Disabilities (Ranked by Funding Level)

                                                    Types of transition
                                                                                                                       a           b
Program                   Purpose                   services provided        Eligibility criteria      Recipient data      Funding
Medicaid Infrastructure   Develop infrastructure,   •   Removal of           Individual who is         Total number of     Type of funding:
Grant                     including linkages            systemic barriers    eligible for              recipients          Grants to state
                          between Medicaid and          to employment        Supplemental              served in FY        Medicaid
                          other employment-             and                  Security Income           2011:               agencies
                          related service               enhancements to      program or was            Data not
                          agencies, supporting          state Medicaid       previously eligible but                       FY 2011
                                                                                                       collected at        obligations:
                          competitive                   programs and         is determined to have     service recipient               c
                          employment                    services.            medically improved        level               $70 million
                          opportunities for         •   Specific services                                                  FY2012
                          individuals with                                                             Number and
                                                        may include:                                   percentage of       appropriations:
                          disabilities
                                                    •   Personal                                       recipients who      $0 (funding for
                                                        assistance                                     were transition-    program ended in
                                                    •   Supported                                      age youth in FY     FY 2011)
                                                        employment                                     2011:
                                                    •   Benefits                                       Data not
                                                        counseling                                     collected at
                                                                                                       service recipient
                                                                                                       level
Developmental             Support protection of     •   Complaints           Individual with a         Total number of     Type of Funding:
Disabilities Protection   legal and human rights        investigation        developmental             recipients          Formula grants to
and Advocacy              of individuals with       •   Mediation            disability (i.e., a       served in FY        states.
                          developmental                                      severe, chronic           2010:
                                                    •   Alternative                                                        FY 2011
                          disabilities                                       disability attributable   21,155
                                                        dispute resolution                                                 obligations:
                                                                             to a mental and/or
                                                        and litigation                                 Number and          $40.9 million
                                                                                                                                         c
                                                                             physical impairment,
                                                    •   Information on       manifested before         percentage of
                                                                                                       recipients who      FY 2012
                                                        transition           age 22 and likely to                          appropriations:
                                                        services and         continue indefinitely,    were transition-
                                                                                                                  e
                                                        supports, such as                              age youth in FY     $40.9 million
                                                                             resulting in
                                                        benefits             substantial functional    2010:
                                                        counseling           limitations, and          13,750
                                                                             reflecting the need       (65 percent)
                                                                             for lifelong or
                                                                             extended services)




                                            Page 43                                                    GAO-12-594 Students with Disabilities
                                              Appendix II: Federal Programs that Provide
                                              Transition Services to Youth with Disabilities




                                                        Types of transition
                                                                                                                                                 a                b
Program                    Purpose                      services provided                Eligibility criteria             Recipient data             Funding
Developmental              Increase and support         •   Training                     Youth with a                     Total number of            Type of funding:
Disabilities Projects of   the independence,            •   Information                  developmental                    recipients                 Grants to state
National Significance —    productivity, and                dissemination                disability (i.e., a              served in FY               and local
Youth Information,         community integration                                         severe, chronic                  2011:                      agencies and
                                                        •   Outreach
Training and Resource      and inclusion of                                              disability attributable          11,831                     nonprofit
Centers, National Youth    individuals with                                              to a mental and/or                                          organizations.
Information Centers        developmental                                                 physical impairment,             Number and
                           disabilities. Youth                                           manifested before                percentage of              FY 2011
                           projects provide                                              age 22 and likely to             recipients who             obligations:
                           capacity building in self                                     continue indefinitely,           were transition-           $100,000
                                                                                                                                                               c

                           advocacy for                                                  resulting in                     age youth in FY
                                                                                                                          2011:                      FY 2012
                           postsecondary                                                 substantial functional                                      appropriations:
                           education, training,                                          limitations, and                 Data on age of
                                                                                                                          individuals                $0
                           and employment                                                reflecting the need
                                                                                         for lifelong or                  served not
                                                                                         extended services)               collected
Section 1915(c) and (i)    Allow states to provide      •    Case                        Individual that meets            Total number of            Type of funding:
Home and Community         long term care services           management                  targeting criteria for a         recipients                 Matching state-
Based Services             in home and                  •    Independent                 waiver (e.g., age and            served in 2010:            federal
                           community based                   living assistance           condition; a state               274,657
                                                                                                                                  d,f
                                                                                                                                                     partnership
                           settings, as an                                               may have a number
                                                        •    Family training                                              Number and                 FY 2011 federal
                           alternative to                                                of waivers targeting
                           institutional care, under    •    Supported                   different groups) and            percentage of              net expenditures:
                           the Medicaid program              employment                  needs-based criteria             recipients who             $37.1 billion
                                                                                                                                                                   d

                                                                                         (e.g., institutional             were transition-
                                                        •    Environmental                                                                           FY 2012
                                                                                         level of care or other           age youth in
                                                             modifications                                                                           appropriations:
                                                                                         level determined by              2010:
                                                        •    Other services as                                                                       Data not
                                                                                         the state)                       Data on age of
                                                             approved                                                                                available
                                                                                                                          individuals
                                                                                                                          served not
                                                                                                                          collected
                                              Source: Catalog of Federal Domestic Assistance and information provided by Department of Health and Human Services officials.
                                              a
                                               Data reported on transition-age youth refers to youth ages 14 to 25, unless otherwise noted. All
                                              recipient data reported by agency officials.
                                              b
                                               Funding data obtained from publicly available and agency-provided budget documentation, unless
                                              otherwise noted.
                                              c
                                               Data reported by agency officials. FY 11 obligations for the Medicaid Infrastructure Grant include
                                              $23.5 million in carryover funding from previous years.
                                              d
                                              Most recent data available are from FY 10 because state reporting of recipient data to HHS’s
                                              Centers for Medicare & Medicaid Services lags 18 months behind service provision.
                                              e
                                                  Includes youth ages 5 to 25. Data are not collected for the 14 to 25 age group.
                                              f
                                                  Agency officials did not specify whether these data were for the FY.




                                              Page 44                                                                      GAO-12-594 Students with Disabilities
                                          Appendix II: Federal Programs that Provide
                                          Transition Services to Youth with Disabilities




Table 4: Department of Justice Program Providing Transition Services to Youth with Disabilities

                                     Types of transition
                                                                                                                                    a                  b
Program          Purpose             services provided               Eligibility criteria                     Recipient data                  Funding
Juvenile         Provide mentoring   •   Mentoring                   Youth under age 18 with                  Total number of                 Type of funding:
Mentoring        services to youth                                   a disability as defined by               recipients served in            Grants to states,
Program —        with disabilities                                   the Americans with                       FY 2011:                        public and nonprofit
Mentoring for    who are in the                                      Disabilities Act (i.e., a                Data not yet                    organizations, and
Youth with       juvenile justice                                    physical or mental                       available                       postsecondary
Disabilities     system or at risk                                   impairment that                                                          institutions
Initiative       of delinquency to                                   substantially limits the                 Number and
                 ensure they                                         performance of one or                    percentage of                   FY 2011 obligations:
                 develop into                                        more major life activities)              recipients who were             $2.2 million
                 healthy,                                                                                     transition-age youth
                                                                                                              in FY 2011:                     FY 2012
                 productive adults                                                                                                            appropriations:
                                                                                                              Data not yet
                                                                                                              available                       $78 million
                                                                                                                                              appropriated for
                                                                                                                                              youth mentoring; no
                                                                                                                                              separate allocation
                                                                                                                                              for this program
                                          Source: Catalog of Federal Domestic Assistance and information provided by Department of Justice Officials
                                          a
                                           Data reported on transition-age youth refer to youth ages 14 to 25, unless otherwise noted. All
                                          recipient data reported by agency officials.
                                          b
                                           Funding data obtained from publicly available and agency-provided budget documentation, unless
                                          otherwise noted.




                                          Page 45                                                                       GAO-12-594 Students with Disabilities
                                           Appendix II: Federal Programs that Provide
                                           Transition Services to Youth with Disabilities




Table 5: Labor Program Providing Transition Services to Youth with Disabilities

                                       Types of transition
                                                                                                                                       a                 b
Program         Purpose                services provided                Eligibility criteria                    Recipient data                   Funding
Disability      Improve educational,   •   School-based                 Individuals with                        Total number of                  Type of Funding:
Employment      training, and              preparatory                  disabilities who are                    recipients served in             Grants to states
Initiative      employment                 experiences                  eligible for employment                 FY 2011:
                opportunities and                                       and training services                                                    FY 2011
                                       •   Career                                                               Data not yet                     obligations:
                outcomes for youth         preparation and              under the Workforce                     available                                    c
                and adults with            work-based                   Investment Act, Social                                                   $24 million
                disabilities who are                                    Security disability                     Number and
                                           learning                                                             Percentage of                    FY 2012
                unemployed,                experiences                  beneficiaries, and in the                                                appropriations:
                underemployed, and                                      target population of focus              Recipients that were                         c
                                       •   Youth                                                                transition-age youth             $24 million
                or receiving Social                                     as determined by the
                                           development and                                                      in FY 2011:
                Security disability                                     grantee. Projects with a
                                           leadership                                                           Data not yet
                benefits                                                focus on youth target
                                       •   Family                       youth ages 14 to 24                     available
                                           involvement and              (currently, projects in 4
                                           supports                     states serve this specific
                                       •   Connecting                   population)
                                           activities
                                           Source: Catalog of Federal Domestic Assistance and information provided by Department of Labor officials.
                                           a
                                            Data reported on transition-age youth refer to youth ages 14 to 25, unless otherwise noted. All
                                           recipient data reported by agency officials.
                                           b
                                            Funding data obtained from publicly available and agency-provided budget documentation, unless
                                           otherwise noted.
                                           c
                                            Data reported by agency officials.




                                           Page 46                                                                       GAO-12-594 Students with Disabilities
                                           Appendix II: Federal Programs that Provide
                                           Transition Services to Youth with Disabilities




Table 6: SSA Programs Providing Transition Services to Youth with Disabilities (Ranked by Funding Level)

                                                 Types of transition                Eligibility
                                                                                                                                       a                         b
Program             Purpose                      services provided                  criteria                    Recipient data                   Funding
Ticket to Work      Provide additional           •    Vocational                    Individuals ages            Total number of                  Type of funding:
                    choices for employment            rehabilitation                18 to 65                    recipients served in             Contract and
                    services for individuals          services                      receiving Social            2011:                            blanket funding
                    receiving Social             •    Career counseling             Security disability         7,812
                                                                                                                      c,k
                                                                                                                                                 agreements
                    Security disability               and job placement             benefits
                    benefits                                                                                    Number and                       FY 2011 obligations:
                                                 •    Ongoing                                                   percentage of                    $25.7 million
                                                                                                                                                                d,e
                                                      employment                                                recipients who were
                                                      support                                                   transition-age youth             FY 2012
                                                                                                                in 2011:                         appropriations:
                                                                                                                                                            f,e
                                                                                                                    c
                                                                                                                441 (6 percent)                  $39 million

Youth Transition    Assist youth with            •    Individualized                Youth ages 14 to            Total number of                  Type of funding:
Demonstration       disabilities to                   work-based                    25 receiving or             recipients served                Demonstration
                    successfully transition           experiences                   likely to receive           from 2007 to                     grants to states and
                                                                                                                     h,k
                    from school to economic      •    Job development               Social Security             2012 :                           community
                    self-sufficiency                                                disability benefits         4,920                            organizations
                                                 •    Youth
                                                      empowerment and                                           Number and                       FY 2011 obligations:
                                                      family supports                                           percentage of                    $1.6 million
                                                                                                                                                              j

                                                 •    Social and health                                         recipients who were
                                                                                                                transition-age youth             FY 2012
                                                      services                                                                     h             appropriations:
                                                                                                                from 2007 to 2012 :
                                                 •    Benefits                                                        i                          $1.5 million
                                                                                                                                                              j
                                                      counseling                                                2,520 (51 percent)
                                                 •    SSA program
                                                              g
                                                      waivers
                                           Source: Catalog of Federal Domestic Assistance and information provided by Social Security Administration officials
                                           a
                                            Data reported on transition-age youth refer to youth ages 14 to 25, unless otherwise noted. All
                                           recipient data reported by agency officials.
                                           b
                                            Funding data obtained from publicly available and agency-provided budget documentation, unless
                                           otherwise noted.
                                           c
                                            Reflects number of recipients for which SSA paid employment networks due to beneficiaries meeting
                                           program criteria for work and earnings.
                                           d
                                               Reflects amounts SSA paid employment networks.
                                           e
                                               Data reported by agency officials.
                                           f
                                               Reflects amount available for payment to employment networks.
                                           g
                                            The Youth Transition Demonstration (YTD) program removes some disability program rules to
                                           encourage and reward work. For example, YTD participants may take advantage of earned-income
                                           exclusions, which allows SSA to exclude a certain amount of a beneficiary’s earned income when
                                           determining benefits payments. According to SSA officials, this is a rigorous research project with a
                                           random assignment design that will yield real results for this population and help to answer questions
                                           about better outcomes. They noted that this is the only research of its kind on this population
                                           h
                                            Data are reported for the life of the program (2007 through 2012) because it is a demonstration
                                           program.
                                           i
                                           Under the demonstration program, a portion of the participants received services while the remaining
                                           participants were placed in a control group.




                                           Page 47                                                                        GAO-12-594 Students with Disabilities
Appendix II: Federal Programs that Provide
Transition Services to Youth with Disabilities




j
Amounts include project funds from Section 1110 (90 percent of funds) and direct apportionments of
Section 234 funds (10 percent of funds) authorized under the Social Security Act for research and
demonstration projects, which are not part of the annual research appropriations request. Section 234
amounts were reported by agency officials.
    k
    Agency officials did not specify whether these data were for the FY.




Page 48                                                        GAO-12-594 Students with Disabilities
Appendix III: Other Federal Coordination
                                          Appendix III: Other Federal Coordination
                                          Efforts that Address Individuals with
                                          Disabilities, Including Students


Efforts that Address Individuals with
Disabilities, Including Students
                                          Some of the coordination efforts of the Departments of Education
                                          (Education), Health and Human Services (HHS), Labor (Labor), and the
                                          Social Security Administration (SSA) broadly address youth or individuals
                                          with disabilities (see fig. 4). A focus on transition-age students with
                                          disabilities may or may not be explicitly included in these federal
                                          coordination efforts, but agency officials indicated that all of these efforts
                                          include discussions of programs or policy that impact this population in
                                          some manner.

Figure 4: Federal Coordination Efforts That Focus on Individuals with Disabilities or Youth




                                          Note: While some coordination efforts included in this figure involve other federal agencies, we
                                          focused on Education, HHS, Labor, and SSA because they administer the key programs that serve
                                          students in their transition out of high school. Key activities coordinated and mechanisms of
                                          coordination were reported by at least half of the reporting member agencies. For efforts with two key
                                          member agencies, only mechanisms and activities reported by both agencies were included.




                                          Page 49                                                     GAO-12-594 Students with Disabilities
Appendix III: Other Federal Coordination
Efforts that Address Individuals with
Disabilities, Including Students




a
 Participating offices from HHS include the National Institutes of Health, Indian Health Service, and
Centers for Disease Control and Prevention. The Administration on Developmental Disabilities (ADD)
at HHS is planning to re-engage in this effort. Key activities coordinated and mechanisms of
coordination were reported by Education.
b
 The Office of the Assistant Secretary for Planning and Evaluation at HHS leads this effort. Key
activities coordinated and mechanisms of coordination were reported by Labor.
c
 The Department of Transportation leads this council. ADD at HHS is planning to re-engage in this
effort. Key activities coordinated and mechanisms of coordination were reported by Labor.
.




Page 50                                                     GAO-12-594 Students with Disabilities
Appendix IV: Comments from the
             Appendix IV: Comments from the Department
             of Education



Department of Education




             Page 51                                     GAO-12-594 Students with Disabilities
Appendix IV: Comments from the Department
of Education




Page 52                                     GAO-12-594 Students with Disabilities
Appendix V: Comments from the Department
             Appendix V: Comments from the Department
             of Health and Human Services



of Health and Human Services




             Page 53                                    GAO-12-594 Students with Disabilities
Appendix V: Comments from the Department
of Health and Human Services




Page 54                                    GAO-12-594 Students with Disabilities
Appendix V: Comments from the Department
of Health and Human Services




Page 55                                    GAO-12-594 Students with Disabilities
Appendix V: Comments from the Department
of Health and Human Services




Page 56                                    GAO-12-594 Students with Disabilities
Appendix V: Comments from the Department
of Health and Human Services




Page 57                                    GAO-12-594 Students with Disabilities
Appendix V: Comments from the Department
of Health and Human Services




Page 58                                    GAO-12-594 Students with Disabilities
Appendix V: Comments from the Department
of Health and Human Services




Page 59                                    GAO-12-594 Students with Disabilities
Appendix VI: Comments from the
             Appendix VI: Comments from the Department
             of Labor



Department of Labor




             Page 60                                     GAO-12-594 Students with Disabilities
Appendix VI: Comments from the Department
of Labor




Page 61                                     GAO-12-594 Students with Disabilities
Appendix VII: Comments from the Social
         Appendix VII: Comments from the Social Security
         Administration



Security Administration




                      Page 62                              GAO-12-594 Students with Disabilities
Appendix VII: Comments from the Social Security
Administration




             Page 63                              GAO-12-594 Students with Disabilities
Appendix VIII: GAO Contact and Staff
                   Appendix VIII: GAO Contact and Staff
                   Acknowledgments



Acknowledgments

                   Revae E. Moran, (202) 512-7215 or moranr@gao.gov
GAO Contact:
                   In addition to the contact named above, Meeta Engle (Assistant Director),
Staff              Nora Boretti (Analyst-in-Charge), Rachel Batkins, Brenna Guarneros, and
Acknowledgments:   Jennifer McDonald made significant contributions to this report. In
                   addition, assistance, expertise, and guidance were provided by Susan
                   Anthony, James Bennett, Amy Buck, Susannah Compton, Elizabeth
                   Curda, Jill Lacey, Kathy Leslie, Craig Winslow, and Carolyn Yocom.




                   Page 64                                    GAO-12-594 Students with Disabilities
Related GAO Products
             Related GAO Products




             High Risk Series: An Update. GAO-11-278. Washington, D.C.: February
             2011.

             Postsecondary Education: Many States Collect Graduates’ Employment
             Information, but Clearer Guidance on Student Privacy Requirements Is
             Needed. GAO-10-927. Washington, D.C.: September 27, 2010.

             Higher Education and Disability: Education Needs a Coordinated
             Approach to Improve Its Assistance to Schools in Supporting Students.
             GAO-10-33. Washington, D.C.: October 28, 2009.

             Young Adults with Serious Mental Illness: Some States and Federal
             Agencies Are Taking Steps to Address Their Transition Challenges.
             GAO-08-678. Washington, D.C.: June 23, 2008.

             Federal Disability Programs: More Strategic Coordination Could Help
             Overcome Challenges to Needed Transformation. GAO-08-635.
             Washington, D.C.: May 20, 2008.

             Highlights of a Forum: Modernizing Federal Disability Policy.
             GAO-07-934SP. Washington, D.C.: August 2007.

             Summary of a GAO Conference: Helping California Youths with
             Disabilities Transition to Work or Postsecondary Education,
             GAO-06-759SP. Washington, D.C.: June 20, 2006.

             Results-Oriented Government: Practices That Can Help Enhance and
             Sustain Collaboration among Federal Agencies, GAO-06-15. Washington,
             D.C.: October 21, 2005.

             Vocational Rehabilitation: Better Measures and Monitoring Could Improve
             Performance of the VR Program. GAO-05-865. Washington, D.C.:
             September 23, 2005.

             Federal Disability Assistance: Wide Array of Programs Needs to Be
             Examined in Light of 21st Century Challenges. GAO-05-626. Washington,
             D.C.: June 2, 2005.

             Workforce Investment Act: Labor Has Taken Several Actions to Facilitate
             Access to One-Stops for Persons with Disabilities, but These Efforts May
             Not Be Sufficient. GAO-05-54. Washington, D.C.: December 12, 2004.




             Page 65                                     GAO-12-594 Students with Disabilities
           Related GAO Products




           Special Education: Federal Actions Can Assist States in Improving
           Postsecondary Outcomes for Youth. GAO-03-773. Washington, D.C.:
           July 31, 2003.




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           Page 66                                 GAO-12-594 Students with Disabilities
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