Equal Access to CTE for Students with Special Needs



Gavin Newsom.,GovernorState of CaliforniaHealth and Human Services AgencyPradeep Kotamraju, PhDDirector of Career and College Transition DivisionCalifornia Department of Education1430 N StreetSacramento, CA 95814Office of the Director721 Capitol MallSacramento, CA 95814(916) 558-5800 VOICE(916) 558-5806 FAX(916) 558-5807 TTYDecember xx, 2019Re: Comments on Draft California Perkins V State Plan Dear Dr. Kotamraju: The California Department of Rehabilitation (DOR) appreciates the opportunity to provide comments in response to the California State Board of Education and Board of Governors of the California Community Colleges draft California Perkins V State Plan. The DOR agrees that California has a unique opportunity to reshape the role of career technical education (CTE) as a driver for education, workforce development, and economic prosperity for the State. Department of Rehabilitation comments focus on inclusive access to CTE for individuals with disabilities so they can attain employment, achieve independence, and realize equality. Individuals with disabilities are unemployed at a higher rate than individuals without disabilities. For 2017, the American Community Survey (ACS) indicates the employment rate of working-age individuals with disabilities in California was 36%, versus 75% for individuals without disabilities. It is imperative that individuals with disabilities have equal access to education and training opportunities to prepare for and achieve competitive integrated employment. Below, please find DOR comments (note: footnotes reflect sections and page numbers on the Draft California Perkins V State Plan as of November 2019):Equal Access to CTE for Students with Special NeedsThe DOR applauds the early delivery of CTE to K-12 and strongly supports collaboration and coordination to achieve the plan goals and outcomes. Insomuch as the State Plan is intended to guide state policy and practice across partner programs, as well as inform local policy and service delivery, local CTE plans should include a needs assessment related to the inclusion of students and youth with disabilities in collaboration and coordination with the local DOR district and local partners. The plan discusses how CTE begins as early as elementary school and progresses throughout the middle grades, high school, and higher education. For students with disabilities who are integrated in mainstream classrooms, they would likely have the opportunity to participate in the same CTE programs as all students. However, if students with special needs are in segregated classrooms, there is concern that they would not have equal access to CTE programs as students in the mainstream classes. Are there mechanisms in place to ensure students with special needs in segregated classrooms could access CTE, for instance CTE elective classes that are open to all? The plan discusses ensuring and expanding access to CTE for special populations. While DOR appreciates that “K–12, adult schools, and the California Community College system are committed to ensuring equal access to CTE programs and support activities and services for all its students, particularly members of identified special population groups,” the plan would be stronger if it included specific measures to ensure students with special needs in segregated K-12 classrooms have equal access to CTE programs. The DOR appreciates that the plan provided statistics on economic, racial, and English language learner special populations. Providing such statistics demonstrates the scale of impact of CTE can have on the special population. Students with disabilities may also be part of economic, racial, and linguistic special populations. It is also worth noting that in 2018 there are approximately 795,000 students enrolled in special education in California. In addition, the wage gap between working-age people with and without disabilities is significant. In 2017, the full-time/full-year (FTFY) median annual earnings of working-age people with disabilities was $40,353.? Conversely, people without disabilities out-earned people with disabilities by $5,096 ($45,449 median annual earnings). According to the 2018 Annual Report on People with Disabilities in America, the national poverty rate of individuals with disabilities (ages 18-64) was almost 30% in 2017. In contrast, the poverty rate of individuals without disabilities was estimated at 13%. To provide equal access to CTE that helps individuals become socially mobile, DOR echoes the efforts to ensure individuals with disabilities can fully participate in CTE, including counseling and guidance for students with special needs, provision of adaptive equipment, and other accommodations and supports, as appropriate to the individual.Cross-Agency Systems Alignment The DOR appreciates being a partner in supporting special student populations, including students with disabilities. The DOR agrees that partnerships with state agencies are essential to better plan, implement, and evaluate services to increase opportunities for students with disabilities to enter into competitive integrated employment. The DOR advocates for a “One Person - One Plan” approach when developing the Individualized Education Program and the Individualized Plan for Employment (and Individual Program Plan, as appropriate) to ensure that transition services and career assessments support opportunities to explore CTE, work experience, and competitive integrated employment. From start to finish, families must be included in the person-centered planning process, including linkages to family empowerment centers and other family organizations.It is important to identify, leverage, and align existing training programs, ensuring programs have methods of identifying and applying best practices for incorporating youth with disabilities and cross training among agencies and systems. Examples of relevant collaborative training programs include: DOR College 2 Career (C2C), CDE Workability I, DOR Transition Partnership Program (TPP), DOR pre-employment transition services for potentially eligible students who have not yet applied for vocational services, Independent Living Center (ILC) transition services, and America’s Job Center of California (AJCC) training services. With respect to the braiding of funds and improving alignment between DOR and CDE, the DOR has increased its focus on transition services, including pre-employment transition services for students with disabilities, consistent with the Workforce Innovation and Opportunity Act (WIOA). Such services help meet the unmet transition needs for students with disabilities and help meet the need for coordinated career exploration activities that have not been widely available before or during the high school years. LCAP and MTSS AlignmentThe DOR supports the State’s strategy of leveraging funds through the Local Control Funding Formula (LCFF) system. The DOR strongly encourages that the Local Control Accountability Plan (LCAP) establishes equal access goals that allow all students with disabilities to succeed at all levels. The DOR strongly encourages an inclusive “carve-in” approach for CTE rather than a separate treatment for students with disabilities. This approach is more aligned with the Multi-Tier System of Support (MTSS) framework and a culture of inclusiveness. The MTSS is “an integrated, comprehensive framework that focuses on instruction, differentiated learning, student-centered learning, individualized student needs, and the alignment of systems necessary for all student’ academic, behavioral, and social success.” Each individual experiences their disability uniquely. The MTSS framework provides the most inclusive learning environment specific to individual student’s needs regardless of physical challenge, intellectual ability, capacity, or competency. Additionally, the MTSS framework allows students with disabilities to access CTE that is specific to their individual needs and learning style.Preparing Special Education Teachers and School PersonnelThe plan has a section on preparing teachers and faculty, including special education teachers, to provide CTE instruction. It also discusses “CTE Teach” which provides instruction and support for individuals desiring to earn a teaching credential in specific CTE Industry Sectors. To further strengthen teacher preparation in working with and improving instruction for students with disabilities, DOR suggests that teachers receive trauma-informed training to help teachers better support students in building better relationships, preventing conflict, and learning more effectively. This training is appropriate for all personnel, including general education and special education teachers who provide instruction to students with disabilities, including foster youth and juvenile justice-involved youth. Many of these students have been impacted by trauma and/or have hidden disabilities. Trauma-informed training can foster positive learning environments, where students can grow, learn, and succeed in school, including through CTE.Partnering with Business and IndustryThe DOR agrees that local business and industry should have a role in supporting CTE and would also like to see “active industry participation, building relationships for authentic engagement and stronger connections between industry and schools.” Participation on local CTE advisory boards and committees are ways for business and industry to actively participate in CTE programs. The DOR recognizes that the CDE developed a CTE Advisory Committee Manual to provide information on forming an advisory committee and its functions and duties. The DOR encourages individuals with disabilities to fully participate in CTE Advisory Committees to ensure CTE opportunities are fully inclusive. Increasing CTE Opportunities through Dual EnrollmentRecent State initiatives have demonstrated the State’s commitment to improve cross system collaboration and program alignment to ease students to dually enroll in both secondary and postsecondary education. The DOR supports California committing considerable resources, as it continues to endorse and encourage education agencies to develop opportunities for dual or concurrent enrollment programs. Providing students, including individuals with disabilities, the opportunity to take CTE courses at a community college or other postsecondary education institution prior to high school graduation can help facilitate transition from secondary school to postsecondary education and the workforce. The DOR appreciates the opportunity to provide comments on the draft California Perkins V State Plan and looks forward to ongoing collaborative efforts to further the role of CTE in providing equity and access to special populations, including students with disabilities. ................
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