NCIL Presents Concerns and Recommendations on reauthorization of WIA to the Department of Labor

On October 1, 2009 NCIL staff Jason Beloungy presented the following recommendations on reauthorization of the Workforce Investment Act (WIA) at a listening session held by the Department of Labor.

October 1st, 2009

Seth Harris, Deputy Secretary of the U.S. Department of Labor; Jane Oates, Assistant Secretary for the Employment and Training Administration; and Kathy Martinez, Assistant Secretary for the Office of Disability Employment Policy
United State Department of Labor
Frances Perkins Building
200 Constitution Ave., NW
Washington, DC  20210

Dear Seth, Jane and Kathy:

The National Council on Independent Living (NCIL) is the nation’s oldest cross-disability, grassroots, consumer-run organization. NCIL would like to offer the following testimony to the Department of Labor regarding our concerns and suggestions for the reauthorization of the Workforce Investment Act (WIA) of 1998. NCIL is a membership organization that represents Centers for Independent Living (CILs), Statewide Independent Living Councils (SILCs), other disability rights organizations, and people with disabilities throughout the nation. NCIL has been working on reauthorization for over a decade while people with disabilities fall through the cracks and face a level of unemployment unparalleled to any other demographic in the nation. NCIL thanks the Department of Labor for the opportunity to express our concerns and recommendations for the reauthorization of WIA.

What is working well in WIA

NCIL supports the reauthorization of WIA, with strongly recommended improvements. NCIL feels that there are some positive aspects of WIA:

1. The disability navigator program, when properly funded and staffed with qualified and competent people has been an asset to people with disabilities looking for assistance in navigating the complexities of state and federal programs and systems.
   
   
2. The creation of the one-stops, when open and accessible to all job-seekers, has created an avenue for people with disabilities who need assistance with finding competitive employment in their area.

What is NOT working well in WIA

NCIL believes that in order to Reauthorize the Workforce Investment Act, there needs to be changes to improve employment services for underserved populations that further embrace consumer control over one’s life and one’s programs and services.

1. Many one-stops are physically, programmatically and attitudinally inaccessible to people with disabilities. Often people with disabilities cannot physically access a one-stop because the building or location of the office is inaccessible. This is a clear violation of the law, but continues to happen. Additionally, many one-stops are programmatically inaccessible. This means that people who need accommodations for vision, hearing, cognitive or other disabilities – hidden or visible – are not always provided them. Finally, attitudes of staff at some one-stops have created an inaccessible atmosphere. If a staff person believes that a job-seeker with a disability is not qualified or able to work – a determination one should never make in that or any capacity on behalf of another person – they will pass the person on to Vocational Rehabilitation Services unnecessarily or not help them at all.
   
   
2. Access to one-stops is severely limited to people with disabilities who do not have their own means of transportation or do not have access to mass transit opportunities. The best one-stop services in the country are meaningless to someone who has no way to get there. Many one-stops are set up in rural locations, where there is no mass transit system. Job seekers living in outlying areas, where economic hardships may be increased and employment opportunities limited, face increased barriers to employment due to lack of access to viable transit options.
   
   
3. People with disabilities are not adequately represented on statewide or local Workforce Investment Boards. Not having adequate representation of a group of job-seekers who face unique and persistent barriers to employment and access to one-stops is what contributes to the creation and continued existence of these problems.

Opportunities for innovation and change

Many of the problems that NCIL described in the previous sections could be addressed with simple changes – attitudinally, physically and programmatically. NCIL offers the following suggestions:

1. Put greater emphasis on consistency and enforcement of physical, programmatic and attitudinal barriers of one-stops.  NCIL feels that Centers for Independent Living should be a required partner to help one-stops achieve their requirements to ensure that their physical locations are accessible, their programs and services are provided fairly and equally with necessary accommodations to all job-seekers, and their staff treat all job-seekers as capable and talented individuals who have the right to seek meaningful competitive employment opportunities through the services of a one-stop.
   
   
2. Transportation should be addressed in more than one way. In areas where mass transit options are available, NCIL feels that a one-stop job centers should be located within a one-block radius of a mass transit location. Job seekers who have a greater chance of having little or no income should be able to access a federally funded one-stop by using low cost mass transit options. NCIL realizes that there are a number of one-stops in rural areas of the country. Many of these areas have no mass transit system, not even a taxicab option, let alone an accessible taxicab. For such areas, new ideas should be developed to connect job seekers to one-stops. Accessible transportation will need to be included in such ideas.
   
   
3. Workforce Investment Boards need to have adequate representation of job seekers with disabilities. NCIL feels that a simple change could be made by mandating two people with disabilities, who are current or former one-stop clients, to be a part of the Statewide Workforce Investment Board.
   
   
4. Another idea to improve the areas suggested in number one is to create a national Technical Assistance Program to improve services to people with disabilities at one-stops. For example, such a program could improve physical accessibility through assessments of the location. Trainings could also be provided to staff of a one-stop to address accessibility and discrimination. Centers for Independent Living provide such services in their regions, and would be a natural partner.
   
   
5. Provide new funding for Centers for Independent Living (CIL) that provide services such as Assistive Technology, Independent Living Skills Training, Peer Support and Advocacy, which help people with disabilities seek and maintain employment, and tie those services in with the services offered at a one-stop job center.
   
   
6. Include benefit specialists in one-stops to help job seekers on public benefits to understand the impact of benefits and employment. Job seekers on public benefits may be fearful or unsure as to how much they can earn. Other job seekers may not be aware of any detrimental effects of employment that could cost them a cash benefit or health insurance.

Conclusion

NCIL believes that it is the obligation of the federal government to tear down the barriers to job-seekers that exist, which in some cases are exacerbated by WIA in its current form. With an economic crisis and a shrinking workforce already making the task of finding meaningful competitive employment difficult, there is an opportunity to make sure that all of the rungs are in place for people with disabilities to climb the ladder to success, independence and happiness.

NCIL thanks the Department of Labor for taking the time and initiative to seek out input about the Workforce Investment Act, and to address the issues that are specific to job seekers with disabilities. We welcome the opportunity to discuss these and other issues related to the employment of people with disabilities in the future and hope this process leads to real reform. Thank You.

Sincerely,

Kelly Buckland                                 Dan Kessler
Executive Director                           President