Introduction - Colorado Division of Vocational Rehabilitation

The people with disabilities are essential to a working economy that elevates all of Colorado.

The Division of Vocational Rehabilitation assists persons with disabilities to succeed at work and live independently.

The Colorado Department of Labor and Employment values:

● Accountability

● Agility

● Collaboration

● Respect

The Division of Vocational Rehabilitation (DVR) believes in the provision of excellent customer service by adhering to the following concepts and principles as they apply to everyone involved in the rehabilitation experience, including the people DVR serves and DVR staff:

● All people with disabilities can choose a career path leading to meaningful employment and independent living.

● Investing in the knowledge, experience, and professional development of our staff is integral to the success of our mission.

● We are a resource and partner that empowers people with disabilities to reach their highest potential in alignment with the needs of businesses in our communities.

● Continuously improving our practices through active collaboration with people with disabilities, their families, businesses, and national, state, and local organizations is essential to advance our mission.

DVR believes that the quality of our staff is essential to the success of the people we serve and any action taken by our employees has a direct impact on the successful accomplishment of our mission.

The Division of Vocational Rehabilitation is committed to maintaining employees who demonstrate the highest ethical standards at all times and perform their job duties in an independent and impartial manner with integrity and honesty. DVR adheres to the guiding principles of the Colorado Executive Department Code of Ethics (Executive Order D-001-99), the Commission on Rehabilitation Counselor Certification (CRCC) Code of Professional Ethics and the State Personnel System Employee Handbook. As well, the Division of Vocational Rehabilitation complies with and follows all policies and procedures put forth by the Colorado Department of Labor and Employment (CDLE), including the Department’s Code of Conduct, Ethics, and Values (SPP 1053).

All DVR staff shall be mindful of, respectful of, and sensitive to individual differences (e.g., ethnicity, religion, disability, sexual orientation, gender, age) among other staff, recipients of services, and individuals associated with outside agencies with which DVR interacts. 

DVR staff shall help recipients of services develop self-advocacy skills and will advocate for needed services and supports from outside agencies when challenges impede self-advocacy skills.

DVR shall provide and encourage opportunities for staff to participate in training to gain knowledge, skills, and awareness for professional growth and development.

Critical Relationships and Collaboration - Engagement with Individuals Receiving Services

The development of a strong working alliance and supporting the engagement of each individual is critical in the rehabilitation process and to the provision of high quality vocational rehabilitation services, including vocational counseling and guidance. While all DVR staff actions contribute to engagement, the autonomy and informed choice of each applicant and individual receiving services is of equal importance in this relationship. An effective vocational rehabilitation program requires the active participation of each applicant and individual receiving services.

To support engagement, DVR staff shall engage in regular and meaningful contact with each eligible individual. DVR staff will ensure contact, defined as efforts by DVR staff to give or get information via phone, text, email, letter, or in person, with each eligible individual, authorized representative(s), and/or designated individual(s) (e.g., host home provider, resource coordinator, etc.) at least once every two months. When DVR staff can directly engage through appropriate means, this interaction will be documented in the individual’s service record. In situations when DVR staff cannot reach the individual, or an authorized representative as appropriate, the effort to engage the individual will be documented in the individual’s service record. 

Critical Relationships and Collaboration - Engagement with Community Partners

DVR staff shall engage in cooperative relationships with public and private agencies and programs, including local school districts, Boards of Cooperative Educational Services (BOCES), mental health programs, community colleges, universities, human services agencies, programs serving persons with developmental disabilities, workforce development system partners, and other agencies at the state and local levels. The goal shall be to facilitate the provision of services to the primary people served by DVR, reduce the duplication of services, and maximize opportunities for individuals receiving services to obtain their chosen employment outcomes. 

Critical Relationships and Collaboration - Agreements with Other Agencies and Organizations 

DVR staff shall comply with the provisions of agreements between DVR and other agencies and community-based organizations, including other statewide workforce development system partners.

Critical Relationships and Collaboration - Engagement with Employers

DVR staff shall engage in cooperative relationships with federal, state, and local employers for the purposes of:

● Creating competitive integrated employment opportunities for people with disabilities.

● Creating assessment and vocational services for individuals receiving services.

● Informing employers of the existence of DVR and the availability of DVR services.

● Providing employers with information regarding the Americans with Disabilities Act and related amendments.

● Providing employers with information about awareness of disability and the employment of individuals with disabilities.

Critical Relationships and Collaboration - Engagement with the State Rehabilitation Council

DVR shall collaborate with and support the State Rehabilitation Council as the Council performs its duties.

The relationship between individuals receiving services and the DVR Counselor (and other DVR staff with whom the individual works closely) should be dynamic, creative, and individualized. All contacts and communications with the individual shall be purposeful and useful to both the individual and DVR. Communications and meetings shall support the goal of attaining a desirable outcome as well as avoiding an undesirable outcome. 

DVR staff shall make reasonable effort to contact every eligible individual at least once every two months. To the extent feasible, communication and contact will take place in the manner agreed to by the individual and DVR staff member, including through an authorized representative or another designated individual (e.g., host home provider, resource coordinator, etc.). The purpose of regular contact is to promote engagement, an interactive process, and ongoing case progress. When a direct interaction is not essential to effectively communicate the relevant information, taking the individual’s needs into consideration, meaningful contact may still occur through other means (e.g., a voicemail providing a status update, etc.). A summary of each contact shall be documented in the service record.

The DVR Counselor’s primary case management responsibility is to be actively engaged and working with every individual on their caseload. The counselor shall consistently engage each individual and monitor for ongoing and satisfactory case progress. The counselor shall stay informed regarding individual performance and activities that advance the individual toward their goals. 

Through documentation maintained in the DVR service record, the DVR Counselor shall demonstrate that all of the cases for which they are responsible are making continuous forward movement.

Prior to development and implementation of the Individualized Plan for Employment (IPE), the counselor shall ensure that the applicant or eligible individual’s participation in assessment and other necessary activities is adequate to lead toward eligibility and the determination of priority for services, as well as toward the determination of rehabilitation needs and services and the development of an employment outcome that is consistent with the individual’s unique strengths, resources, priorities, concerns, abilities, capabilities, career interests, and informed choice.

After the development of the IPE, the DVR Counselor shall continually monitor to ensure progress. On at least an annual basis, and more frequently if necessary, the individual’s activities and the rehabilitation plan shall be reviewed to ensure:

● The employment outcome remains consistent with the individual’s unique strengths, resources, priorities, concerns, abilities, capabilities, career interests, and informed choice.

● Activities will result, to the extent appropriate, in the achievement of competitive integrated employment.

● All goods and services are still necessary and are leading toward the chosen employment outcome.

● The proposed timelines (date of initiation of services and duration of services) are still on track.

● Selected objective criteria are accurately measuring forward progress.

● Procedures used to measure the objective criteria are doing so.

● The schedule of periodic evaluation and monitoring toward achievement of the employment outcome is working as identified in the IPE.

● The individual has pursued and acquired comparable benefits as described in the service record.

● The individual has paid any required contribution toward the cost of necessary goods and services as described in the service record.

● The individual is meeting their responsibilities as outlined in the service record.

● The individual and DVR staff engage in regular and meaningful communication regarding case progress.

● DVR is meeting its responsibilities as outlined in the case record.

● DVR has provided goods and services as described in the IPE.

● The individual has no new or additional rehabilitation needs that should be addressed.

When the individual’s activities are not sufficient to move them forward toward a successful competitive integrated employment outcome, or when the individual is not making forward progress, the DVR Counselor shall document this in the case record and initiate steps to assist the individual with identifying and resolving the issues which are impeding forward case progress. These activities, their results, and the steps identified to move the case forward shall be documented within the individual case record. If the individual is unable to resume forward progress within a reasonable period of time, the DVR Counselor shall close the case and document the rationale in the service record. A reasonable period of time to resume forward progress is determined by the DVR Counselor given the unique circumstances of each individual’s situation, but is typically defined as 60 to 90 days. Case notes within DVR’s electronic database will document the rationale for a case that will remain open beyond this typical time period.

The purpose of service record documentation is to explain, describe, document, justify, and chronicle the relationship between the DVR Counselor and the individual receiving services throughout the vocational rehabilitation process. The case record has the important role of representing the individual and the DVR Counselor in the absence of either or both.

Readers of documentation may include: Auditors, judges, attorneys, other DVR staff, the individual and their authorized representatives, the Client Assistance Program, fair hearing officers, and others.

Each reader will view service record documentation with different perceptions, different knowledge bases, different understandings, and different agendas. Documentation efforts should consider each possible reader and should consider under what circumstances readers may be reviewing a service record. Documentation should clearly explain, justify, and inform any reader as to decisions, interventions, and resource expenditures made throughout the individual’s rehabilitation process.

Much of the documentation used in the rehabilitation process is contained in DVR forms and in records and reports from sources outside DVR. Essentially, there are two types of documentation which DVR staff are responsible to create:

Bridge rationale documentation links the Rehabilitation Act’s legal and ethical authority to the DVR Counselor’s decisions and determinations. It answers the question “why” and is the logical argument which explains decisions that impact services to applicants and eligible individuals. Bridge rationale must be written by the DVR Counselor and evident in the case record at critical decision points, including:

● Eligibility

● Identification of and commitment by DVR to an employment outcome

● Initial Individualized Plan for Employment (IPE)

● Annual and other IPE reviews

● Case closure

and

Journal documentation is a narrative summary and can include observations, facts, descriptions, and interventions. Journal documentation is the flow of the case record and is used to tell the story of the individual’s VR process. Journal documentation depicts the individual’s progress through the rehabilitation process, always describing the present status and a clear history of the process. Journal documentation can be written by any DVR staff member working with the DVR case record and can include: 

● The identification and addressing of disability and related issues.

● The documentation of rehabilitation counseling issues.

● The documentation of discussions between the individual and the DVR staff.

● Documentation of interventions.

● Description of facts that contribute to future decision points.

● Updates about service provision.

● Updates about overall and specific case progress.

● Updates about progress toward establishing or achieving vocational goals and objectives.

● Evaluation of next steps.

DVR Counselors and staff shall document events, activities, and the rationale for their decisions promptly, so it is clear what was decided and when it was decided. Case narratives shall be kept up to date to accurately reflect the current status of the case and entered into DVR’s electronic case management system as soon as possible following the actual date of the event, activity, or decision.

DVR staff shall ensure the collection and entry of accurate and timely data into DVR’s electronic case management system to facilitate the provision of vocational rehabilitation services to applicants and recipients of services and to ensure accurate federal and state reporting. Additionally, DVR service records shall reflect documented practices that are consistent with federal regulations and agency policy. 

DVR has created, and instituted for agency use, a set of data entry screens and forms that support implementation of the rehabilitation experience for all applicants and individuals receiving services. These provide the means for DVR to document key determinations during the rehabilitation experience including eligibility and severity of disability for all applicants and employment outcome and service needs for all individuals. Rehabilitation Counselors shall use case notes to document counseling, guidance, and all relevant rehabilitation activities.

DVR Supervisors shall use DVR’s agency-defined procedure to regularly review various activities and decisions made during the rehabilitation process. Supervisory review shall take place in the manner and frequency identified by agency administration. DVR Supervisors shall review service records for the purpose of making timely corrections and adjustments that facilitate satisfactory case progress and that improve the performance of staff providing services to DVR applicants and individuals receiving services.

As determined by the DVR agency, certain plans and services require consultation between the DVR Counselors and DVR Supervisor before verbal or written commitments shall be made to an applicant or recipient of services. In these cases, the counselor and the supervisor shall document the approval using the agency-defined process for this purpose.

DVR is committed to providing quality services and supports. DVR uses a quality assurance (QA) process and related review tools which are fully consistent with federal regulation. The purpose of QA is to accurately evaluate the quality of DVR services. DVR does this using a variety of monitoring activities that are designed to provide an objective quality assurance process. Through the evaluation of service records, QA tools measure performance and long term continuous improvement in the delivery of vocational rehabilitation services. 

Objectives of QA are to: Ensure efficient DVR program operations and delivery of quality services, ensure that public funds are expended appropriately, and ensure that applicable federal and state laws, regulations, policies, procedures, and guidelines are met. Quality assurance analyzes trends in excellence statewide. Using these trends, quality assurance guides DVR staff to make improvements through the provision of staff training and guides the need for technical assistance that promotes a continued level of excellence in the delivery of DVR services and supports.

DVR Regional Managers, in consultation with the Assistant Director of Field Services, shall be responsible for overall fraud issues. This includes the need to address prevention, detection, and deterrence, as well as take action when fraud occurs. Fraud matters shall be handled consistently across the state. Regardless of title or position, awareness and reporting of fraud shall be the responsibility of all DVR staff. All DVR staff should be familiar with various improprieties that might occur within their area of responsibility and should be alert for indications of fraudulent activity.

Fraud exists when an individual knowingly and deliberately withholds, conceals, or misrepresents information to obtain, or attempt to obtain, DVR services or funding. Fraud includes intentionally reporting inaccurate income and/or source(s) of income, inappropriately purchasing goods and services, and/or the misuse or theft of items purchased by DVR. 

Examples of fraud on the part of an individual receiving services may include, but are not limited to:

● Misrepresenting personal identifiable information.

● Misreporting mileage.

● Providing authorizations that have been falsified or changed.

● Pawning items that have been purchased with DVR program funds.

● Using DVR funds for purposes not intended or agreed upon by the individual and the counselor.

● Purchasing unauthorized items.

● Providing a falsified receipt or other documentation.

DVR staff are governed by the CDLE Code of Conduct, Ethics and Values (SPP 1053). DVR Vendors are governed by the DVR Vendor Code of Ethics found in DVR’s Fee Schedule. Regardless of title or position, awareness and reporting of fraud shall be the responsibility of all DVR staff. DVR will work closely with CDLE leadership and organizational structure to investigate and resolve all instances of suspected fraud in a timely manner.