Detailed Implementation of VR Program Assessment and Report

1. Level of Current Services

During the assessment, the vocational rehabilitation agency must ask a couple of questions: Are we reaching the hard of hearing and late deafened population of need, or the persons who have a significant impediment to employment? If yes, are we addressing their multiple employment needs beyond hearing aids? Are we providing the full range of services needed to modify these problems and enable employment success?

In order to answer these questions, it will be necessary to retrieve, review and analyze existing data regarding consumers who are hard of hearing or late deafened. Like Alice in Wonderland, the agency cannot plan where to go if it does not know where it is.


Analyze population estimates and RSA-911 data. Each is addressed in the following section:

Population Estimates

Studies indicate a steady increase in the incidence of persons with hearing loss nationally. Current estimates range from 34 to 36 million persons reporting some level of hearing loss.

The National Institute on Deafness and Communication Disorders (NIDCD) in June 2010 reported the following “Quick Statistics”:

The Marke Trak national study, conducted and published by the Better Hearing Institute (BHI), provides powerful information for states to use when considering if persons with hearing loss are an underserved population. It includes estimates, by state, of persons with hearing loss by percent of the total hearing loss population; size of hearing loss population; estimated size of state population; and percentage of hearing loss incidence.

National RSA–911 Data

To determine if a state is consistent with other state VR agencies, look at RSA-911 national successful employment outcomes, cost of services, etc.  The following table, from The Model State Plan, provides data successful outcomes from 1960 – 2008.

Historical Comparison of Successful Rehabilitation Employment Outcomes for Individuals Who Are Deaf and Hard of Hearing with Successful Rehabilitation Employment Outcomes for All Individuals

Year Total Cases Successful Outcomes for All Individuals Successful Outcomes Deaf & HoH Outcomes / % of All Successful Deaf Outcomes / % of All D & HoH Successful HoH Outcomes / % of All D & HoH
2010 . 171964 22243 (12.9%) 5184 (23.3%) 17059 (76.7%)
2009 . 180572 24758 (13.7%) 5662 (22.9%) 19096 (77.1%)
2008 . 205023 28410 (13.9%) 6581 (23.2%)* 21829 (76.8%)
2007 . 205447 25404 (12.4%) 6479 (25.5%)* 18925 (74.5%)
2006 . 205791 24088 (11.7%) 6667 (27.7%)* 17421 (72.3%)
2005 . 206695 22371 (10.8%) 6480 (29.0%)* 15891 (71.0%)
2004 . 213431 21678 (10.2%) 6554 (30.2%)* 15124 (69.8%)
2003 . 217557 21241 (9.8%) 6508 (30.6%)* 14733 (69.4%)
2002 . 221031 20682 (9.4%)* 6791 (32.8%)* 13891 (67.2%)
2001 . 233684 22751 (9.7%)* 7936 (34.9%)* 14815 (65.1%)
2000 . 236218 19394 (8.2%)* 7409 (38.2%)* 11985 (61.8%)
1999 . 231697 18295 (7.9%)* 7157 (39.1%)* 11138 (60.9%)
1998 . 222275 16887 (7.6%) 6750 (40.0%) 10137 (60.0%)
1997 . 211576 15243 (7.2%) 6134 (40.2%) 9109 (59.8%)
1996 . 213780 15718 (7.4%) 6238 (39.7%) 9480 (60.3%)
1995 . 209600 15187 (7.2%) 5990 (39.4%) 9197 (60.6%)
1994 . 202824 16029 (7.9%) 6022 (37.6%) 10007 (62.4%)
1993 . 193918 15901 (8.2%) 5830 (36.7%) 10071 (63.3%)
1992 . 191821 16094 (8.4%) 5881 (36.5%) 10213 (63.5%)
1991 . 202831 16832 (8.3%) 5958 (35.4%) 10874 (64.6%)
1990 . 214874 19335 (9.0%) 6820 (35.3%) 12515 (64.7%)
1989 . 220408 20184 (9.2%) 7075 (35.1%) 13109 (64.9%)
1988 . 218241 19693 (9.0%) 7130 (36.2%) 12563 (63.8%)
1987 . 219616 —— —— ——
1986 . 223354 18568 (8.3%) 7021 (37.8%) 11547 (62.2%)
1985 . 227652 —— —— ——
1984 . 225772 16626 (7.4%) 6296 (37.9%) 10330 (62.1%)
1983 . 216231 15585 (7.2%) 6127 (39.3%) 9458 (60.7%)
1982 . 226924 15519 (6.8%) 6423 (41.4%) 9096 (58.6%)
1981 . 255881 17298 (6.8%) 7212 (41.7%) 10086 (58.3%)
1980 . 277136 18679 (6.7%) 7630 (40.8%) 11049 (59.2%)
1979 . 288325 17540 (6.1%) 7308 (41.7%) 10232 (58.3%)
1978 . 294396 16859 (5.7%) 6877 (40.8%) 9982 (59.2%)
1977 . 291202 16223 (5.6%) 6135 (37.8%) 10088 (62.2%)
1976 . 303328 16015 (5.3%) 5936 (37.1%) 10079 (62.9%)
1975 . 324039 15887 (4.9%) 6066 (38.2%)  9821 (61.8%)
1974 . 361138 16675 (4.6%) 6689 (40.1%) 9986 (59.9%)
1973 . 360726 16869 (4.7%) 6728 (39.9%) 10141 (60.1%)
1972 . 326138 16429 (5.0%) 6412 (39.0%) 10017 (61.0%)
1971 . 291272 13735 (4.7%) 5566 (40.5%) 8169 (59.5%)
1970 . 266975 14334 (5.4%) 5915 (41.3%) 8419 (58.7%)
1969 . 241390 12769 (5.3%) 5598 (43.8%) 7171 (56.2%)
1968 . 207918 12269 (6.9%) 5523 (45.0%) 6746 (55.0%)
1967 . 173594 10363 (6.0%) 4923 (47.5%) 5440 (52.5%)
1966 . 154279 9015 (5.8%) 2731 (30.3%) 6284 (69.7%)
1965 . 134859 8130 (6.0%) 2560 (31.5%) 5570 (68.5%)
1964 . 119708 7376 (6.2%) 2243 (30.4%) 5133 (69.6%)
1963 . 110136 6767 (6.1%) 2077 (30.7%) 4690 (69.3%)
1962 . 102377 6328 (6.2%) 1866 (29.5%) 4462 (70.5%)
1961 . 92501 5438 (5.9%) 1595 (29.3%) 3843 (70.7%)
1960 . 88275 5410 (6.1%) 1617 (29.9%) 3793 (70.1%)

State RSA–911 Data

To identify trends, strengths and weaknesses in a particular state agency’s program and services for hard of hearing and late deafened consumers, look at the state agency’s data. For the purposes of this assessment, when collecting RSA-911 data, use RSA codes in these groupings:

RSA Codes

In 2003, the RSA coding for disability or impairment type shifted focus to the “functional” aspects of hearing loss, primarily related to the person’s functional communication and its impact at work. The current coding includes:

For a snapshot of the program and services being provided to consumers who are hard of hearing and late deafened, look at the state’s RSA-911 data from the most recently completed fiscal year. Collect and analyze the state data to determine the hard of hearing and late deafened consumer profile and trends in services. Look at the following:

If in an order of selection for services (OSS) compare numbers served pre and post OSS imposition (two years may be necessary to see the full impact).

Once assessment data has been compiled, it will need to be analyzed to see trends andto determine what it means. Usually assessment data raises more questions than it answers. These questions become the “red flags” the agency needs to further explore. For example, were there physical restoration cases with a total case cost that roughly equals the cost of hearing aids? If the answer is yes, the agency may need to conduct a targeted case review to determine how many, if any, were single service hearing aid cases, and in need of other unidentified services.

2. Quality of Current Services and Practices

In order to determine if consumers who are hard of hearing and late deafened are receiving the full range of services needed to reach their employment goal, the following assessments should be conducted. All are addressed in the following section.

a. Individual case analysis

b. Counselor assignments

c. Counselor accessibility

d. Office accessibility

e. Policy compliance

a. Individual Case Analysis (targeted case reviews)

To answer many questions that will be raised in the analysis of the agency’s assessment data, a case review should be conducted that looks at “red flag” issues.

The agency should do a random sample of its field offices with both general and deaf specialist counselors’ caseloads represented (and identified as such) in the sample. Questions to ask might include:

See a sample case review form

In one state VR agency where such a review was conducted by the quality assurance unit and the State Coordinator for Hard of Hearing and Late Deafened (SC/HH/LD), it was found that:

As a result of the case review, the agency assigned specific counselors to serve consumers who are hard of hearing and provided in-depth training to them on how to appropriately serve this disability group.

b. Counselor Assignments 

This portion of the assessment answers the question- Are consumers who are hard of hearing and late deafened being served by counselors who understand their communication and psychosocial needs?

Who serves consumers who are hard of hearing and late deafened in the agency? In most state VR agencies, rehabilitation counselors for the deaf (RCDs) serve signing deaf consumers, while both RCDs and general counselors serve non-signing consumers who have a hearing loss. In most states, both are equally in need of information and training to understand that the employment needs of these consumers may be multiple and severe. The counselor must be able to recognize those needs in consumers who, for the most part, cannot (or will not) pinpoint the problem(s) themselves, and are not aware of available services that could greatly assist them.

Many states have specialized counselors serving hard of hearing and late deafened consumers. They are commonly called “Rehabilitation Counselor for the Hard of Hearing and Late Deafened (RC/HH/LD).” or in some states, “Communication Specialists.”


Using the data system, determine which counselors are currently serving consumers who are hard of hearing and late deafened.

From RSA-911 data, determine:

This information can be used to drive strategic plan recommendations for assignment of counselors to whom hard of hearing and late deafened referrals will be made. It will also drive training plan recommendations, which are more time and cost-effective if provided to targeted counselors, as opposed to a shotgun approach to training all counselors.

c. Counselor Accessibility 

To be effective in working with consumers who are hard of hearing or late deafened, it is essential for counselors to have specialized knowledge concerning:

It is essential that a counselor for a consumer who is hard of hearing or late deafened have the knowledge and ability to draw information from a consumer who may not be able to pinpoint his or her own communication problems and solutions. Do not assume that a counselor is an expert in the above knowledge and skills simply because he or she is deaf or hard of hearing.

It is important that the counselor have clear speech and pronunciation so that the best use of a consumer’s residual hearing and lip reading ability can be made. Counselors who have speech articulation problems — some deaf, cerebral palsied, multiple sclerosis, stroke, foreign accents, etc. — or distorted facial and/or lip movements will not be readily understood by the consumer who is hard of hearing or late deafened. Word processing, writing and typing skills are sometimes helpful in difficult communication situations.

Finally, it is essential that all staff – from the receptionist to the office manager – who come into contact with consumers who are hard of hearing and late deafened  be sensitized to effective oral and written communication behaviors.

For recommended knowledge, skills and abilities for counselors for hard of hearing and late deafened, see Model State Plan for Vocational Rehabilitation Services to Persons who are Deaf, Deaf-Blind, Hard of Hearing, and Late-Deafened, pages 43-45.

d. Office Accessibility 

In addition to assessing counselor accessibility, it is necessary to determine accessibility of offices in which these consumers will be served and to target and authorize purchase of assistive technology to ensure appropriate office accommodations.

These accommodations are both reasonable and necessary for both the staff and consumers, who are hard of hearing and late deafened. Staff and office accommodation needs can be established through a survey or through interviews with field office staff.

e. Policy Compliance 

It is important to conduct a policy review to ensure that policy is consistent with the intent of the Rehabilitation Act as applied to consumers who are hard of hearing and late deafened.

Policy issues to consider, relating to serving consumers who are hard of hearing and late deafened, are addressed in this section. Each issue addressed is followed by the associated citation(s) from the Rehabilitation Act Amendments of 1998. Policy overall must facilitate, not impede, consumers being active participants in their own rehabilitation program development, based upon informed choice about the selection of services that they receive, assisted by qualified VR counselors. This basic premise must be kept in mind when reviewing all policy and related practices. Carefully go through policy and practices manual(s) and make recommendations for modification/ addition if indicated.

This section is arranged in the following order:

Personnel Development, Standards and Training

It is mandated that minimum communication standards be set for counselors to ensure that they will be able to communicate in their consumer’s preferred mode of communication. With consumers who are hard of hearing and late deafened, this usually means a mode other than American Sign Language. Training will assist counselors who serve consumers who are hard of hearing and late deafened to use a combination of practices, physical settings, assistive listening devices and other technology for assisting consumers to (perhaps for the first time) use their best communication assets, and adapt their environment to the best communication advantage. Learning to communicate with an individual who is hard of hearing or late deafened is in many ways more challenging than using American Sign Language with a consumer who is deaf.

Because of the communication complexities, agencies might want to look at their existing staffing structure to determine if consumers who are hard of hearing and late deafened might be better served if specific counselors are designated and trained to serve them.

Related Mandate:

Section 101(a)(7)(C) requires the state plan to contain provisions relating to the establishment and maintenance of minimum standards to ensure the availability of personnel, to the maximum extent feasible, trained to communicate in the native language or preferred mode of communication of an applicant or eligible individual.

The Rehabilitation Act requires state plans to include a description, a procedure and activities they will undertake to ensure that all of their personnel are appropriately and adequately trained and prepared.

When counselors work with individuals who are hard of hearing or late deafened, they face unique challenges in building relationships. Communication factors are also crucial in developing relationships with other professionals involved with the case. Often misunderstanding and misconceptions about consumers who are hard of hearing and late deafened need to be overcome. A counselor’s partnership with an individual who is hard of hearing or late deafened is a role that requires specific knowledge, skills and ability. As in working with any underserved population this role may at times feel a bit like playing “The Lone Ranger.”

Training is therefore generally needed to sensitize counselors, supervisors and service providers assigned to work with individuals who are hard of hearing and late deafened to the needs of these target populations and to increase their knowledge of the service options available. Ongoing continuing education is also needed to upgrade knowledge and skills and to keep abreast of constantly changing technology.

Related Mandates:

Section 101(a)(7)(A)(v) requires the state plan to include a description of the procedures and activities that will be undertaken to ensure that all personnel they employ are appropriately and adequately trained and prepared including a system for continuing education of rehabilitation professionals and paraprofessionals, particularly in respect to rehabilitation technology.

Section 103(a)(1) requires that needed assessments for determining eligibility and vocational rehabilitation needs be conducted by qualified personnel, including, if appropriate, an assessment by personnel skilled in rehabilitation technology.

Consumer Assistance Project (CAP) staff should be included in staff development and training relative to individuals who are hard of hearing and late deafened so that they will better understand appeals lodged by consumers with these disabilities and more effectively provide information to them concerning vocational rehabilitation services and the Americans with Disabilities Act.

Related Mandate:

Section 112(a) requires the consumer assistance program to provide information on the available services and benefits under the Rehabilitation Act and Title I of the Americans with Disabilities Act of 1990 to individuals with disabilities in the State, especially in regard to individuals with disabilities who have traditionally been unserved or underserved by vocational rehabilitation programs.

The Vocational Rehabilitation Process

Creative outreach is needed to identify persons who are hard of hearing and late deafened who do not self-identify and who have not been traditionally recognized and served by VR.

Related Mandate:

101(a)(15)(D)(ii) requires the state plan to contain a description of the strategies they will use to address the needs identified in the statewide needs assessment, including … outreach procedures to identify and serve individuals with disabilities who are individuals with disabilities who have been unserved or underserved by the vocational rehabilitation program.

VR agencies should promote outreach to students with hearing loss in secondary school programs, those being served under an IEP or 504 plan, as well as those without any special identification in the education system. Many states have designated transition counselors who are the point of contact with the schools. These transition counselors must be trained to recognize the hard of hearing students who have not self-identified and have not been identified by the school, and therefore are falling through the cracks. The transition counselor should transfer hard of hearing and late deafened referrals to communication specialists or RCHHs if such a position exists. If they retain these students in their caseload, they should be trained in related communication and other issues needed to appropriately serve these students.

Related Mandates:

Section 101 (a)(11)(D) requires the state plan to contain procedures for coordination between the VR agency and education officials designed to facilitate the transition of students with disabilities to the receipt of vocational rehabilitation.

Section 7(37) – The term “transition” means a coordinated set of activities for a student, designed within an outcome oriented process, that promotes movement from school to post school activities, including postsecondary education, vocational training, integrated employment (including supported employment), continuing and adult education, adult services, independent living, or community participation. The coordinated activities shall be based upon the individual student’s preferences and interests.

If a consumer does not meet eligibility criteria or priority category under an order of selection, they must be provided information about, and referral to, other state or federal programs for needed employment assistance.

Section 101(a)(20)(A)(B) requires the state plan to include an assurance that they will implement an information and referral system adequate to ensure that individuals with disabilities will be provided accurate vocational information and guidance, using appropriate modes of communication, to assist individuals in preparing for, securing, retaining, or regaining employment, and will be appropriately referred to Federal and State programs.. including other components of the statewide workforce investment system.


After application, the counselor interviews the consumer and collects information to determine if eligibility is met and to begin identification of employment and related service and counseling needs. Because of the mandate to make eligibility decisions quickly, and to the extent possible on existing information, it is essential that a counselor of a consumer who is hard of hearing or late deafened know specifically what information to gather to determine the severity of the employment impediment and substantiality of services needed. Many problems of consumers who are hard of hearing and late deafened are not visible or reported by consumers or associated professionals. It is therefore extremely important that the counselor know what to look for and what questions to ask to gain the needed objective, e.g., medical, psychological, other formal assessment, and subjective, e.g., consumer/family reported or counselor observed, data.

Often, professionals authorized to conduct assessments do not have a complete understanding of the impact a hearing loss can have. When arranging an evaluation or assessment, it is therefore extremely important that the counselor include, in the referral information, the individual consumer’s communication mode and needs, along with communication issues that the counselor would like to have addressed in the report. How well a counselor asks questions of an evaluator, and how well the response comes back in functional terms, will significantly influence whether or not consumers who are hard of hearing or late deafened receive the full scope of services of which they are in need to gain or maintain employment.

Effective two–way communication in the evaluation/assessment setting is critical to the reliability of information in the resulting reports to the counselor. If technology is required to achieve the best communication environment, it should be provided in the assessment situation.

Audiograms available at the time of referral may be appropriate for the purpose of establishing the presence of a disability. However, new audiological information is often needed after eligibility has been determined and VR services are being planned to ensure that up-to-date recommendations for hearing aids and other related technology are obtained.

Related Mandates

Section 7(2)(A) defines “assessment for determining eligibility and vocational rehabilitation needs” to mean, as appropriate in each case — a review of existing data to determine whether an individual is eligible for services, to assign priority for an order of selection, and to the extent necessary, the provision of appropriate assessment activities to obtain necessary additional data to make such determination and assignment.

Section 102(a)(4) mandates, that, to the maximum extent appropriate, for purposes of determining the eligibility of an individual for vocational rehabilitation services and developing the individualized plan for employment for the individual, the counselor must use information that is existing and current (as of the date of the determination of eligibility or of the development of the individualized plan for employment), including information available from other programs and providers, particularly information used by education officials and the Social Security Administration, information provided by the individual and the family of the individual, and information obtained under the assessment for determining eligibility and rehabilitation needs.

Section 101(a)(15)(D)(i) requires the state plan to contain a description of the methods to be used to expand and improve services to individuals with disabilities, including how a broad range of assistive technology services and assistive technology devices will be provided to individuals at each stage of the rehabilitation process.


Eligibility (see definition in following related mandate) determination must be made as soon as possible, but within 60 days unless there are circumstances beyond the control of VR and the consumer agrees to an extension.

The most important and unique function of the VR counselor is analyzing all of the diagnostic and case finding information, analyzing it as a whole, and determining what specific disability related problems are interfering with the consumer’s ability to get or to keep a job. VR services can be provided for only those disability related problems that specifically impact the consumer’s employment or ability to gain employment. The VR counselor for consumers who are hard of hearing and late deafened therefore must clearly understand the unique psychosocial, communication and technology needs of this population in order to make informed eligibility decisions.

Many consumers who are hard of hearing or late deafened are employed at the time of application, but at risk of losing employment due to hearing loss related stresses and needs. Some may be in a “crisis” situation on their job and in need of immediate intervention. In these situations, the counselor may expedite the application process. Other consumers might be underemployed or unable to gain a promotion for which they are qualified and capable, if provided with counseling, coping strategies, technology, and the like. Others may be “older” workers, even part-time, with aging-related hearing loss, who want or need to work to supplement their income. VR counselors must not wrongly assume that since consumers are working, they are not eligible for VR services,

Related Mandate

Section 102(a)(1)- Criterion for Eligibility

An individual is eligible if the individual is:

  1. An individual with a disability. This is defined as a person with a physical or mental impairment which constitutes or results in a substantial impediment to employment, and who can benefit in terms of an employment outcome from VR services.
  2. Requires VR services to prepare for, secure, retain, or regain employment.

Section 102(a)(6)(A) mandates that eligibility for vocational rehabilitation services be determined within a reasonable period of time, not to exceed 60 days, unless there are exceptional and unforeseen circumstances, beyond the control of VR, and the individual agrees to a specific extension of time. 

The Order of Selection for VR Services

If a VR agency cannot serve all eligible consumers, they must by law enter into an order of selection for services, under which consumers who are determined to be the most severely disabled must be served before other eligible consumers. Priority categories differ among states, but are usually based on extent of functional limitations. It is therefore extremely important to understand that the functional impediments to employment of an individual who is hard of hearing or late deafened can be multiple, severe, vocationally debilitating, and may have no correlation to the level of their decibel loss.

As an increasing number of agencies enter into an order of selection for services, concern is being expressed about where consumers who are hard of hearing and late deafened fall on the order of selection priority list.

Degree or severity of hearing loss on communication is only one functional factor to be considered when determining the impact of a hearing loss on employment. There are many consumers who qualify as an “individual with a significant disability” if all of their problems and needs for services are recognized by their VR counselor. Many would meet the definition if their functional limitations in areas of communication, self–direction, interpersonal skills, work tolerance, work skills, self-care and mobility are recognized. Multiple VR services over an extended period of time are often required to benefit an individual who is hard of hearing or late deafened in terms of an employment outcome.

It is, therefore, critical that the counselor of a consumer who is hard of hearing or late deafened be able to recognize the variety of substantial functional impediments that impact the individual consumer’s employment, plus the multiple services that should be provided to remediate these limitations. Truly eligible persons who are hard of hearing and late deafened who should meet the definition of “individual with the most significant disability” will otherwise be denied service under an Order of Selection or, under normal circumstances may receive services that are less than adequate in meeting their needs.

Link to Counselor Module functional limitation chart. – Add link

Related Mandates:

Section 101(a)(5)(A) In the event that vocational rehabilitation services cannot be provided to all eligible individuals with disabilities in the State who apply for the services, the state plan shall- show the order to be followed in selecting eligible individuals to be provided vocational rehabilitation services; provide the justification for the order of selection; include an assurance that, in accordance with criteria established by the State for the order of selection, individuals with the most significant disabilities  will be selected first for the provision of vocational rehabilitation services; and provide that eligible individuals, who do not meet the order of selection criteria, shall have access to services provided through the information and referral system.

Section 7(21) The term “individual with a significant disability” means an individual with a disability (i) who has a severe physical or mental impairment which seriously limits one or more functional capacities, such as mobility, communication, self-care, self–direction, interpersonal skills, work tolerance, or work skills, in terms of an employment outcome; (ii) whose vocational rehabilitation can be expected to require multiple vocational rehabilitation services over an extended period of time; and(iii) who has one or more physical or mental disabilities resulting from or another disability or combination of disabilities determined on the basis of an assessment for determining eligibility and vocational rehabilitation needs to cause comparable substantial functional limitation.

Comprehensive Assessment

Once eligibility has been established, additional information and data must often be obtained to pinpoint the full range and options of services needed to overcome employment impediments. It is incumbent upon the counselor at this point in the rehabilitation process to explain to the consumer the full range of service needs and options available to modify or remediate his/her impediments to employment and maximize employment opportunities. The consumer then can make informed choices in concert with the counselor on what goals, services, service providers and employment outcomes should be included in the IPE.

Evaluations that might be considered in a comprehensive assessment include:

Related Mandates:

Section 7(2)(B) – To the extent additional data is necessary (beyond a review of existing data) to make a determination of the employment outcomes, and the objectives, nature, and scope of vocational rehabilitation services to be included in the individualized plan for employment of an eligible individual, a comprehensive assessment to determine the unique strengths, resources, priorities, concerns, abilities, capabilities, interests, and informed choice, including the need for supported employment, of the eligible individual which comprehensive assessment:

Section 7(2)(C) includes referral, for the provision of rehabilitation technology services to the individual, to assess and develop the capacities of the individual to perform in a work environment.

The Individualized Plan for Employment (IPE)

After a comprehensive diagnostic study and analysis and identification of problems that are interfering with employment, the counselor and the consumer together determine an employment goal and services needed to enable the consumer to gain or maintain an employment goal consistent with his or her strengths, resources, priorities, concerns, abilities, capabilities, interests and informed choice. This forms the basis for the IPE or written plan of service.

The IPE planning session must be conducted in the consumer’s preferred mode of communication in order that he or she can fully participate in the planning, fully understand options for employment and related services and vendors, and be able to make informed choices about each. Unless the consumer is mentally incompetent – which is seldom the case with consumers who are hard of hearing and late deafened – this planning should take place directly with the consumer, not with a parent, family member or advocate. The counselor must make available whatever communication enhancement techniques and devices, e.g., speech reading techniques, oral interpreters, correct lighting, lack of background noise and other distractions, assistive listening devices, computer assisted techniques, etc., that the consumer can successfully use to be an active participant in his or her own planning.

Related Mandates: 

Section 100(a)(C) requires that applicants be active and full partners in the vocational rehabilitation process, making meaningful and informed choices during assessments for determining eligibility and vocational rehabilitation needs, and in the selection of employment outcomes, services needed to achieve the outcomes, entities providing such services, and the methods used to secure such services

Section 102(a)(B)(2)(B) requires that the IPE be developed and implemented in a manner that affords eligible individuals the opportunity to exercise informed choice in selecting an employment outcome, the specific vocational rehabilitation services to be provided under the plan, the entity that will provide the vocational rehabilitation services, and the methods used to procure the services.

Section 102(b)(3)(A) requires that each IPE contain a description of the specific employment outcome that is chosen by the eligible individual consistent with his/her unique strengths, resources, priorities, concerns, abilities, capabilities, interests, and informed choice.

The IPE must, if appropriate, include a statement of the specific rehabilitation technology services to be provided to assist in the implementation of the consumer’s IPE. The counselor therefore must know how to identify technology options and where to get them, to be able to provide the consumer with sufficient information and options on which to make an informed choice.

Related Mandates:

Section 102 (b)(3)(B)((i) requires that each IPE include a description of the specific vocational rehabilitation services that are needed to achieve the employment outcome, including, as appropriate, the provision of assistive technology devices and assistive technology services.

Providing a written copy of the IPE to be read and signed by the consumer is not enough. Discussion and feedback on each point in the IPE should occur to double check consumer understanding and intentions for follow through.

Related Mandate

Section 102(b)(2)(C) requires an individualized plan for employment to be agreed to, and signed by the individual or, as appropriate, the individual’s representative.

Impact on the current job or on the consumer’s ability to get a job must be analyzed functionally and must be clearly understood by the consumer. The consumer must understand his or her specific employment related problems and understand why specific service options are being considered, and what the expected impact on employment (or employability) will be.

Scope of Services

In addition to VR services traditionally considered, many consumers who are hard of hearing and late deafened need a variety of non-traditional services in order to gain or maintain employment. Some of these services might include:

Finding local resources qualified to work with consumers who are hard of hearing and late deafened is not an easy task in most states. The VR counselor and the State Coordinator of Services for Deaf and Hard of Hearing (SCD/HH) will need to devote time to identifying existing resources, and to develop and educate a cadre of professionals to fill the service gaps.

Related Mandates:

Section 103(a) describes vocational rehabilitation services in an individualized plan for employment as those services necessary to assist an individual with a disability in preparing for, securing, retaining, or regaining an employment outcome that is consistent with the strengths, resources, priorities, concerns, abilities, capabilities, interests, and informed choice of the individual.

Section 103(a)(14) includes rehabilitation technology, including telecommunications, sensory, and other technologic aids and devices as potential services.

Services for the benefit of groups of individuals should be considered in the areas of use of telecommunications systems, captioning of films and videos, and technical assistance to businesses.

Section 103(b) – Vocational rehabilitation services, when provided for the benefit of groups of individuals with disabilities, may include (among others): the use of  telecommunications systems (including telephone, television, satellite, radio, and other similar systems) that have the potential for substantially improving service delivery methods of activities and developing appropriate programming to meet the particular needs of individuals with disabilities; captioned television, films, or video cassettes for individuals who are deaf or hard of hearing; and other special services that provide information through tactile, vibratory, auditory, and visual media. Technical assistance and support services may be provided to businesses that are not subject to title I of the Americans with Disabilities Act of 1990 and that are seeking to employ individuals with disabilities.


Significant counselor-consumer contact is recommended after suitable job placement has been made to be certain that the consumer who is hard of hearing or late deafened has made a satisfactory vocational adjustment. Since it is not usually inability to perform work tasks that interferes with continued and successful employment of these consumers, counselors must be certain to attend to the following:

Post-Employment Services

At the time of IPE development, and at the time of 26 closure, the counselor must consider the need for and record plans for the provision of post-employment services, if any. These are services that are projected to be necessary after 26 closure for the consumer to maintain employment or regain other suitable employment. Since eligibility does not have to be reestablished in order to provide post-employment services, the counselor thus has the ability to act quickly in a job-threatening situation.

Some post-employment services to be considered for consumers who are hard of hearing or late deafened are:

Related Mandate:

Section 102(b)(3)(G) requires each IPE to contain, as determined to be necessary, a statement of projected need for post-employment services.

Other Policy Issues 

Audiology- Hearing Aids- Cochlear Implant- CART- C-Print- Cooperative Agreements

Because of constantly changing medical and technology advancements, periodic ongoing review of policy and fees in these areas should be conducted.

State Rehabilitation Council

Each state VR agency is required to have a State Rehabilitation Council (SRC) to provide advice to the agency regarding agency performance. The council is responsible to conduct a periodic consumer satisfaction survey, and partners with the agency in conducting a statewide consumer needs assessment every three years. The law mandates that a majority of council members be persons with disabilities, one of whom is mandated to be a person with a sensory disability. Members are appointed by the governor. It is important to advocate for the appointment of a person with a hearing loss to the council, ideally a current or former consumer, so that the issues of persons with hearing loss can be brought to the attention of the council as policies, practices, and surveys/studies are conducted.

Related Mandates:

Section 105(a)(1) mandates that in order to be eligible to receive financial assistance, a state must establish a state rehabilitation council (in accordance with the mandates of Section 105).

Section 105(b)(A)(vii)(I) lists one of the mandated membership areas as “individuals with physical, cognitive, sensory, and mental disabilities.”

Staff and Consumer Input

Staff Interviews

Obtain rehabilitation counselor for the deaf (RCD), general counselor, first-line supervisor, field office manager, and administrator input to gain their perceptions of what is working and what needs work. Focus groups, by job title, are suggested to include the following areas of discussion: staffing; office accessibility; policy, practice and fees; service provision issues; and staff training needs.

Consumer Input

Consider holding consumer focus groups. Conduct separate groups for hard of hearing and late deafened because of differing needed communication accommodations and differing issues.

Input from consumer organizations is also helpful to gain their knowledge of and perceptions of available VR services. Most states have chapters of Hearing Loss Association of America (HLAA). Many states have chapters of the Association of Late Deafened Adults (ALDA). Many states have an office or commission for “the Deaf and Hard of Hearing.”