Frequently Asked Questions

Competitive Integrated Employment (CIE) – Act 178 Website
2017 Wisconsin Act 178 requires the Department of Workforce Development's Division of Vocational Rehabilitation (DVR), the Department of Health Services (DHS), and the Department of Public Instruction (DPI) to collaborate, with the input of stakeholders, in the development of a joint plan to increase CIE in Wisconsin. The Act 178 Website is an interagency resource for information on CIE.

For additional information about FC/IRIS, consult the Technical Assistance Guide for Adults Seeking Competitive Integrated Employment.

For additional information about county mental health supports and Individual Placement and Support (IPS), consult the IPS website.

DHS Guiding Principles for CIE

DHS Think Possible! Employment Webinar Series

Schools should consult with outside agencies regarding their criteria and timeline for providing services. Consulting with outside agencies as often as possible is best practice to support the successful transition from high school for students with IEPs. Including outside agency supports and service providers prior to the recommended timeline is encouraged.

If it is likely an outside agency will provide or pay for transition services for a particular student, the school is required to invite the outside agency to the IEP meeting after obtaining consent from the parent or adult student.

It is important for schools to collaborate early and often during the transition process. Each outside agency will have recommended timelines for their role/involvement in a student’s transition process. It is important for transition staff to be aware of these timelines and maintain communication between students, families and transition partners. As a student with an IEP moves closer to exit from high school, it is even more critical that transition partners are involved in IEP/transition meetings. The school team and outside agencies should work together to provide services that facilitate a smooth transition from high school to adult life.

Recommended timelines for key agency (transition partners) involvement in the transition process:

Consent must always be obtained prior to inviting any outside agency such as DVR, or the county to an IEP meeting. Consent must also be obtained prior to an outside agency conducting an informational presentation to students within the classroom. Consent is required for informational activities as it can identify a student as receiving special education. Consent is also required for outside agencies who have been court ordered to work with a student.

If a student or their family were to meet individually with an outside agency, consent must be obtained if this meeting was organized by the school, however if the meeting was arranged by the adult student or family, consent would not be required.

Yes. Consent must be obtained before disclosing a student’s disability to an employer.

Do I have to use DPI form I-1-A (Request to Invite Outside Agency Representative(s) to the IEP Meeting)?

No, you are not required to use DPI forms however if you use other forms or modify the DPI forms they must be submitted to and approved by DPI.

Obtaining parent, guardian if appointed, or adult student consent on DPI form I-1-A only allows for the disclosure of personally identifiable information to a participating agency representative at the IEP team meeting to which the individual is invited. Parent or adult student consent on this form would not permit the disclosure of personally identifiable information to a participating agency representative or other individuals in other situations or under other circumstances.

Yes,because of the narrow or limited application of using form DPI I-1-A to obtain parent or adult consent to disclose personally identifiable information, several LEAs have modified their general release of information forms to include inviting outside agency representatives to IEP team meetings. These general releases of information forms should identify the period of time that the consent covers, for example 9/1/20 – 8/31/21.

Under the law there is no specific limitation on the length of time the district may request for release of confidential student information. The Department of Public Instruction recommends that the adult student and parent should be asked to provide consent to release personally identifiable information at least annually.

Consent to exchange information with outside agencies must be obtained from the parent, guardian if appointed, or adult student in writing. Prior to mailing the consent request, the student’s special education teacher will typically communicate with the parent/legal decision maker or adult student to discuss outside agency services and explain why their consent is being requested.

The role of the VR counselor is to provide vocational planning and support. Responsibilities of the VR counselor in the IEP Transition process would include any or all of the following:

*Outreach:
Sharing of information on the Division of Vocational Rehabilitation (DVR) program, its policies and process to educators, parents/legal decision maker, students or any other interested community members. DVR will provide outreach to students that will minimally include:

• Purpose of the Vocational Rehabilitation Program
• Eligibility requirements
• Referral and Application procedures
• Scope of services available to students including Pre-Employment Transition Services (Pre-ETS)

*Employment Planning Consultation:
Providing school districts that have transition students who have not yet applied for vocational rehabilitation services with assistance, strategies and creative ideas for identifying the student’s post-school employment goal, needs for services, and concerns to be addressed in achieving those goals. Topics may include information on disabilities, assessments, assistive technology, accommodations, community resources, labor market and employment.

DVR does not bear any financial or ongoing counseling responsibilities under this definition unless the student has an active individualized plan for employment (IPE) with DVR.

*Information/Referral:
To community programs and services that may assist an individual in reaching their employment and independent living goals.

*Rehabilitation Counseling and Planning:
Occurs when the individual is eligible for DVR and the application has been signed. Rehabilitation counseling will include assistance in the development of employment goals that are appropriate given a consumer’s needs, priorities, strengths, preferences, abilities, capabilities, and interests and will be present throughout the entire VR process.

*Service Provision:
Services provided by DVR are individualized and will be provided according to the specific needs of each student. All services provided by DVR will be directly related to the establishing and achieving a job goal.

Youth enrolled in CLTS have access to a Support and Service Coordinator to support facilitation of access to care and services, including transition preparedness and employment planning services.

Each participant has an individual service plan (ISP) developed to support their outcomes. Programs for Children with Delays and Disabilities: County Contact Information.

An ADRC or tribal ADRS can provide information to students/parents/legal supporters about the array of services available in the ADRC service area, which may be a single county, or a multiple county area. Once the student reaches age 17 years 6 months, ADRCs or tribal ADRSs can assist with learning about and applying for benefits, as well as determine functional eligibility for Long Term Care services. For more information about ADRCs or tribal ADRSs visit: Aging and Disability Resource Centers (ADRCs).

Managed Care Organizations operate the Family Care and Family Care Partnership programs under contract with the Department of Health Services and provide or coordinate services in the Family Care and Family Care Partnership benefit packages. Services are tailored to each individual’s identified outcomes. MCOs work with members who have been determined to be eligible and have chosen to enroll in the Family Care or Family Care Partnership Program. The IDT, which includes the member, develop and fund a Member Centered Plan (MCP) to meet the identified outcomes that will allow a member to live, work and participate in their community. For more information about Family Care or Family Care Partnership visit: Family Care or Family Care Partnership.

The IRIS program is a statewide self-directed support Medicaid Waiver program. Individuals who choose IRIS as their Long-Term Care program receive and Individualized Budget Allocation based on their individual long term care needs. IRIS participants work with an IRIS Consultant to create an Individualized Supports and Services Plan (ISSP) that funds the necessary supports that allow a participant to live and participate in his/her community. For more information about the IRIS program, visit: IRIS (Include, Respect, I Self-Direct).

When youth planning for transition have behavioral health service needs, it is important to consider their age, needs and resources for payment when determining how to involve behavioral health professionals. If a youth utilizes a private behavioral health provider, the youth and parents can sign authorizations for the school to be in contact with that provider.

When a youth is eligible for services through the County, an authorization for exchange of information between the school and the behavioral health system is also necessary. With that in hand, there is often a greater expectation of collaboration than might exist with a traditional private provider. When a therapist from, or contracted by, a county is unable to attend transition planning meetings, etc., it is likely that information can be exchanged in advance of the meeting. When behavioral health services include a wraparound team, the team representative or service facilitator is generally a useful participant in the planning process.

County services to children with a mental health diagnosis are usually provided in the context of a wraparound program that focuses on helping families to cope with their child’s needs for support and services. These services might be provided through a Coordinated Services Team (CST) or, in some counties, through a Comprehensive Community Services program (CCS). CCS programs are available for children, youth and adults who meet eligibility criteria. Where these programs are available, youth who will need services as adults might be able to move from children’s services to adult services with fewer barriers than has been possible in the past. Wraparound teams embrace involvement of everyone who is significantly involved with a child/family and usually includes someone from the school that the child attends. It is true, however, that this requires permission of the youth and parents.

General inquiries about the types of services available to residents of a given county can be made at any time without permission. General inquiries can also include information about the timing and procedures for referral of youth who will need services as adults. Questions regarding the availability of staff to attend IEP or transition planning meetings and/or other ways to share information should be raised with county staff. By establishing mutual understanding of what school and agency staff can and cannot do, it becomes easier to create collaboration.

Confidentiality laws apply only to conversations in which specific individuals are identified.

No, While DVR, and Long-Term Care Professionals cannot be required to attend an IEP, in Wisconsin, DVR and DHS/DMS have an interagency agreement with DPI wherein all agencies have committed to ensuring the involvement of relevant staff in the IEP team meeting process (beginning at age 14).

The student and family can determine the most important people in their lives that can help with planning and support transition activities and invite them to meetings.

Outside agencies may be able to collaborate in other ways such as: email, phone conversations, video conferencing or conference calls about potential services, having a general information session with the student and family on a different day, providing information about the agency services or arranging for a separate meeting with the agency prior to or after the IEP meeting.

A list of the designated VR contact persons can be found on the DVR website. WI School Liaisons.

Youth may be served by CLTS through County Waiver Agencies (CWAs). A list of CLTS county contacts is available on the website: Programs for Children with Delays and Disabilities: County Contact Information.

Contact the ADRC or tribal ADRS, where available, operating in your county/tribe, they are the initial point of contact once the student reaches the age of 17 yrs. 6 months. A list of ADRC and tribal ADRS contacts is available on the website: ADRC: Find Your Local ADRC.

Inquiries regarding behavioral health services should be directed to the county behavioral health program. Mental Health: Provider Information.

The Department of Health Services oversees a county-based community behavioral health system. If you need contact information for your specific county representative, please review the Wisconsin Community Program, Social Service, and Human Service Agencies webpage. If the local program is non-responsive or additional information is needed to supplement what is provided locally, staff from the Wisconsin Division of Care and Treatment Services can be contacted at dhswebmaildcts@dhs.wisconsin.gov for assistance. More information about Wisconsin’s behavioral health system can be found at the Division of Care and Treatment Services website.

Not necessarily. The eligibility of students with IEPs for programs outside of school are dependent on individual disability related needs and program specific criteria. If you believe a student with an IEP would benefit from Behavioral Health Services, reach out to your county representative to request information on the Children’s Long Term Support Screen and/or the Mental Health and Substance Use Disorder Screen.

If you believe a student with an IEP would benefit from Medicaid waiver services from Family Care, Family Care Partnership, CLTS or IRIS contact your local ADRC or tribal ADRS for information on eligibility for Medicaid Long term care programs. A list of ADRC and tribal ADRS contacts is available on the website: ADRC: Find Your Local ADRC.

There are times when DVR does not have enough resources to serve everyone who is eligible for services. To manage this, the names of newly eligible consumers are placed on the waiting list. There will be times when there is no actual waiting period for services. To determine if there is currently a waitlist, contact your local DVR office.

Long-term supports and services are those goods and services funded by DHS programs that will assist eligible people to either maintain or improve functional ability and live and participate in their communities.

For more information about the following DHS programs:

• Children’s Long Term Support Program
• Family Care
• IRIS
• Behavioral Health Programs
• Individualized Placement and Supports (IPS)
• Healthy Transitions Initiative
• Coordinated Services Team Initiative

No, students need to be found eligible for the CLTS Program. Contact the local county for eligibility and enrollment criteria.

No, students need to be found financially and functionally eligible for services in order to receive Long-Term Care. The ADRC or tribal ADRS, where available, determines financial and functional eligibility for Long-Term Care Programs.

Young adults with a behavioral health disorder may be eligible for other community behavioral health programs.

The IEP team must determine the content of the IEP including transition services. The IEP team would include the student, the parents/legal decision-maker, school staff and applicable participating agencies (e.g., DVR, Long Term Care and Behavioral Health Programs). A successful transition depends on all parties working cooperatively to develop and provide the programs, services, and activities in the IEP. However, the school has the ultimate responsibility and authority for ensuring a free, appropriate public education (FAPE).

For a DVR IPE to be written, a job goal must be known. For students the job goal can be less specific (e.g. skilled trades, medical field, etc.). If the student does not have a job goal, DVR and/or the Long-Term Care or Behavioral Health Program may be able to provide assistance in determining an appropriate goal, and/or exploring work experience/training options. School is the time for career exploration, so each student should be encouraged to participate in Pre-Employment Transition Services (Pre-ETS). Temporary Work Experiences in the community are a great way to do career exploration while developing transferrable skills.

To be considered “competitive integrated employment,” a job position must satisfy three criteria related to wages/benefits, integration, and opportunities for advancement (Section 7(5) of the Rehabilitation Act (29 U.S.C. § 705(5)) and 34 C.F.R. § 361.5(c)(9) of WIOA). Specifically, “competitive integrated employment” means full- or part-time work –

• In which the employee with a disability is compensated (including benefits) at a rate of the higher of the Federal, State, or local minimum wage applicable to the place of employment, and not less than the customary rate paid by the employer to employees without disabilities performing the same or similar work and who have similar experience, training, and skills;
• At a location that is
• typically found in the community; and
• Where the individual with a disability interacts, for the purpose of performing the duties of the job position, with other employees within the work unit and at the entire worksite, and, as appropriate for the work performed, with other persons (e.g., customers and vendors) who are not individuals with disabilities (and who are not supervisory personnel or service providers) to the same extent that nondisabled employees interact with these persons; and
• That presents opportunities for advancement for individuals with disabilities that are similar to those available to employees without disabilities in similar positions. Competitive integrated employment also includes work performed by individuals with disabilities who are self-employed.
• For more information see the Wisconsin CIE Website.

DVR will agree to a supported employment outcome when:

• The student's postsecondary education goal is competitive integrated employment. There is a reasonable expectation that the supports needed to maintain long-term employment in an integrated setting will be available when the student needs them. DVR's role in providing for these supports is time limited when the student is stable on the job.
• DVR will work with the student, school, parents/legal supporter, Long Term Care or Behavioral Health professional, and others to determine the amount of supports, funding mechanism and methods of receiving services and supports that will be needed on the job to sustain competitive employment in an integrated setting.

CLTS can fund Discovery and Career Planning and Community/Competitive Integrated Employment services when it is appropriate based on the goals of student and the situation where services are needed. For example, CLTS might fund: supported employment services for a competitive summer job where the student is learning a first job; transportation and supports when a job ends after school-based supports are available; or career-oriented opportunities where a student is exploring different options (i.e. classes or day camps). These decisions would be made with DPI and DVR to determine the most appropriate method of funding available to best support the student in their competitive employment goals.

When the student is eligible and chooses to enroll in Family Care, Family Care Partnership, or IRIS, DHS expects the Managed Care Organization or IRIS Consultant Agency to provide services to that will help maintain competitive integrated employment, based on available community resources and the person’s interests, abilities, and choices.

Students enrolled in any of the Wisconsin Medicaid LTC programs may be able to self direct some of their care. This option can be explored with their program contacts.

The purposes of providing Internship/Temporary Work as a service will vary depending upon the individualized needs of the consumer. For students, Internship/Temporary Work is most often used as a tool for career exploration. The workplace or real work provides students with the knowledge and skills that will help them connect school experiences to real-life work activities and future career opportunities.

The Internship/Temporary Work site must be in an integrated community work site consistent with student’s interests and employment goal. Wages paid to the individual must be commensurate wages paid to others performing the same or similar work.

If temporary work is also needed for the student to achieve his/her IEP goals, a cost sharing arrangement can be made.

DVR can provide services that are determined to be necessary by the individual and the counselor to assist the individual in achieving an appropriate employment goal. When purchasing services DVR has purchasing policies that must be followed (e.g. comparable services, fee schedules, etc.).

When there is overlap of educational goals and employment/rehabilitation goals and services, a cost sharing arrangement may be negotiated between DVR, the school district, and Long-Term Care and/or Behavioral Health programs. To know who will pay for a service, all parties must be involved in transition planning in order to make a determination about appropriate services.

Youth and young adults who are receiving behavioral health services through a county program might be eligible for services considered to be psychosocial rehabilitation, depending upon the severity of their disability and the programs for which they are eligible.

The following are general guidelines to help understand how decisions can be made:

Test 1 - Will the service help to achieve the educational goal of the IEP? If yes, the school is primarily responsible for the service.

Test 2 - Will the service help to achieve the employment goal of the IPE? If yes, DVR is primarily responsible for the service.

Test 3 - If the same service appears on both the IEP and IPE, the school and DVR are responsible for negotiating a cost sharing arrangement (conflicts between schools and DVR are to be resolved utilizing the process outlined in the DPI/DVR/DHS Interagency Agreement).

Test 4 - If the student is over 18 and eligible for Medicaid long-term care services and supports, and is eligible for and chooses to enroll in a Long-Term Care, the three agencies are responsible for negotiating a cost sharing arrangement to determine resources for each individual’s situation. Generally, services relating to Behavioral Health would be the responsibility of either private insurance or Medicaid for eligible individuals.

Consideration of providing/paying for transportation services for jointly served students should be negotiated between transition stakeholders providing services to the student.

All the applicable agencies are responsible for providing transition services. The IEP team in collaboration with outside agencies that support an individual student, determine who provides transition services and when and how those services are provided. The transition teams need to come to a collaborative agreement that braids funding and services to build a meaningful schedule that supports the student in meeting their postsecondary transition goals. While a school district plays a critical role in the transition process, transition services should gradually shift from schools to outside agencies during the final years of a student’s education. As a result, a student may not be served full time by school, but rather may coordinate services that include supports from school, family, outside agencies, etc.

Transition Programing Beyond Age 18

The IPE must be reviewed annually for progress and needed changes. Any concerns or requested changes prior to that time should be brought to the attention of the DVR staff. The DVR counselor, consumer, and parent/legal decision maker, along with other stakeholders as appropriate, review the concern and determine if a change is needed. If a change is needed the updated plan needs to be agreed to and signed by the counselor, consumer, and their legal decision maker. Changes can be made as often as necessary and appropriate.

The IEP is a written plan. It specifies the services to be provided and how often, describes the student's present levels of performance and how the student's disabilities affect academic performance, and specifies accommodations and modifications to be provided for the student. The IEP and placement of the student must be reviewed at least once each year. The IEP is developed by the IEP team at a meeting. An IEP is good for one year (364 days). It can be changed during the year. It may be changed during the year without a meeting if a parent or adult student agrees.

For Family Care or Family Care Partnership, the MCP can be changed throughout the year, but at minimum it is reviewed every six months to ensure all assessed long-term care and behavioral health outcomes are addressed. Anytime a change in need or a new outcome (related to long-term care or behavioral health needs) is identified by the youth and/or their legal decision maker, the plan should be updated.

For IRIS the minimum is to review the ISSP at least annually, but the participant can make changes throughout the year.

For Behavioral Health, the plan is updated at minimum every 6 months. However, if a student or legal supporter believes that the plan needs to be updated sooner, they are able to work with the provider to make changes.

A person’s legal status changes when they turn 18 years old and are legally considered an adult. It is important to consider whether your child is able to make important health and legal decisions or whether they need some assistance and might need a legal decision-maker or power of attorney. Youth with a CLTS Support and Service Coordinator can discuss these questions with their Support and Service Coordinator and can receive their assistance with this process.

What you should know about Wisconsin Law: Your Legal Rights and Responsibilities. (formally known as “On Being 18”) A publication developed by the Wisconsin Bar Association.

To learn about decision making options: Supported Decision-Making and Guardianship Alternatives.

The Transfer of Rights: An Educator’s Role: Supported decision making options and/or guardianship, are important topics that a special educator should have knowledge of in order to best support their students during this time. Regardless of a student’s needs, it is important that an educator always consider their responsibility to provide information on decision making options, but families and students make their own decisions about the best ways to support decisions an adult faces on a day to day basis.

It is also important to consider applying for adult Supplemental Security Income (SSI) because the child’s SSI does not continue into adulthood. Plus, children previously obtaining Medical Assistance through another source want to be sure to maintain their eligibility to keep their health care and related services in adulthood. To learn about and apply for SSI benefits please review: Supplemental Security Income (SSI).

Start with your local team for assistance.

DHS related programs may contact the DHS Clients Rights Office.

A parent/legal decision maker or student can contact the Client Assistance Program for assistance in determining if a service falls under the responsibility of the DVR.

Client Assistance Program (CAP)
1502 W. Broadway, Suite 201,
Madison, WI 53708-8911
Consumer Line: 1-800-362-1290

A parent/legal decision maker or student can contact the Family Care or IRIS Ombudsman for assistance and advocacy.

A parent/legal decision maker or student can contact the Department of Public Instruction for questions regarding the transition planning process.

Wisconsin Department of Public Instruction,
Special Education Team
125 S. Webster Street
P.O. Box 7841
Madison, WI 53707
Phone: 608-266-1781
Toll Free: 800-441-4563

Dispute Resolution options:

Family Care and Family Care Partnership uses a process called the Resource Allocation Decision (RAD) making method to determine which supports and services are the most cost effective way for the member to achieve their CIE outcomes.

For more information about the RAD process.

The IRIS planning process in the IRIS Work Instructions.