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Advancing Competitive Integrated Employment: RespectAbility Advises AbilityOne Commission on Strategic Plan

Washington, D.C., April 13 – One of the nation’s oldest federal disability employment programs is looking ahead and adapting for the future. This week, the U.S. AbilityOne Commission finished collecting public comment and direct feedback on a new 2022-2026 Strategic Plan for the nation’s most important government program to employ people who are blind or have significant disabilities.

Originally founded in 1938 with the passage of the Wagner-O’Day Act, the AbilityOne program directly helps people who are blind or have significant disabilities through employment programs, contracts to satisfy government procurement needs, and a full range of services/supports.

Looking ahead to the future, the AbilityOne Commission, which oversees these programs, is rolling out a new strategic plan to decide on goals, set priorities, and measure success. In response, the national disability inclusion organization RespectAbility developed and submitted a clear set of recommendations and ideas on how to make this strategic plan better.

“This is one of the most interesting and dynamic times ever for the one-in-five Americans living with a disability. After two years of pandemic economic insecurity and social instability, the labor force participation rate for working-aged people with disabilities is now at 37.8 percent,” said Olegario “Ollie” Cantos VII, RespectAbility’s Chairman. “The strategic plan unveiled by the Commission, with its strong focus on aligning systems and improving competitive integrated employment (CIE) outcomes, will take advantage of this trend.”

RespectAbility’s recommendations to the AbilityOne Commission include suggestions to improve the role of assistive technology in employment programs, adopting strength-based definitions, and facilitating cooperation between partner agencies.

To read the AbiltiyOne Strategic plan in full, please visit their website.

At the same time, you can review public comments on the Strategic Plan via the Federal Register.

To learn more about RespectAbility’s advocacy work, please visit our Policy website.

RespectAbility’s full testimony is presented online and below:

To: Members and Staff, U.S. AbilityOne Commission
From: RespectAbility
Re: Public Comments for Draft FY 2022-2026 Strategic Plan

Dear Chairperson Koses and Acting Executive Director & CEO Zeich,

Thank you very much for the opportunity to offer our comments on the U.S. AbilityOne Commission Draft FY 2022-2026 Strategic Plan. RespectAbility is a nonpartisan, nonprofit disability inclusion organization dedicated to fighting stigmas and advancing opportunities for millions of Americans with disabilities.

This is one of the most interesting and dynamic times ever for the one-in-five Americans living with a disability. After two years of pandemic economic insecurity and social instability, the labor force participation rate for working-aged people with disabilities is now at 37.8 percent. This historic percentage marks a major, sustained, and positive trend upwards in economic opportunities for people with disabilities. The strategic plan you are rolling out with its strong focus on aligning systems and improving competitive integrated employment (CIE) outcomes will take advantage of this trend.

In our comments below, our team outlines both the points where we commend your proposed strategic plan and where greater clarity is needed. We look forward to a final plan the even further reflects the insights that people with disabilities have to offer when we have a place at the decision-making table.

Commendation for Clear Timelines, Legislative Priorities and Modernizations Efforts

  • We believe that the Plan is absolutely correct in identifying the need for draft legislation to modernize in Javits-Wagner-O’Day and the timeline is both realistic and achievable. Innovative technologies exist that open workforce opportunities for people with significant disabilities in ways that were unimaginable ten years ago. As such, we hope there is sufficient energy among Congressional leaders to ensure success.
  • If such a meaningful change is indeed a goal, that change needs to reflect the perspectives, input, and collective wisdom of self-advocates, federal agencies, and state partners. We encourage the Commission to develop a clear and public input collection process as modernization efforts move forward. We look forward to collaborating with leaders from the disability community in support of this goal.
  • In the third decade of the twenty-first century, modernization and innovation need to be the watchwords of legacy programs within our nation’s government. Leaders must leave behind regulations, policies, and procedures rooted in economic, legal, or technological realities outmoded by evolving technology, the political climate or cultural change. As such, RespectAbility commends the leadership at the U.S. AbilityOne Commission for setting a clear line of modernization effort in Outcome Goal 2 and aligning “the AbilityOne Program with contemporary disability employment policy.”

Adopting a Strength-Based/Person Centered Planning Approach to Individual Employment Eligibility (IEE) forms

  • With the present state of assistive technology, workforce inclusion practices and community identity, people with disabilities are more engaged than ever before. People with disabilities want to earn an income and achieve independence, just like anyone else. Public programs that directly employ or create systems that benefit people with disabilities need to reflect that perspective. It is thus good and appropriate that the Commission will look at appropriately narrowing the definition of “severe disability” under JWOD to ensure that all of those able to succeed will be served by a revised standard of Individual Employment Eligibility (IEE) and “implement a revised…form based on an updated understanding of the term.”
  • In this process, we encourage the adoption of a strength-based perspective that does not perpetuate stigma through language. In looking at how to change the IEE form itself, greater emphasis should be placed on identifying and advocating for the necessary accommodation, assistive technology, or other actions necessary to achieve inclusion for the individual with disabilities in question. Lastly, there is a place for reflecting lessons from the body of literature that documents the positive impact of person-centered planning models in the disability space.

Stakeholder Engagement Strategies – Methods, Modes, and “Nothing About Us, Without Us”

  • Problems are best solved by working with people who have experienced them firsthand and know solutions that work. Just like issues that impact people of different racial, ethnic or other backgrounds, people with disabilities should be involved in solving issues that impact them. As such, RespectAbility believes that the AbilityOne program should amend that draft strategic plan to delineate its process for working “with broad range of stakeholders to advance CIE.” How will the program solicit input from current or former AbilityOne workers? Administrative or program staff? Self-advocates? Outside disability consultants? Advocacy organizations? Subject matter experts? Family members of current or former AbilityOne workers? Youth with significant disabilities who might consider working at an AbilityOne program?
  • The Department of Labor has had demonstrable success with focused online policy dialogues to generate ideas, solicit external resources, and publicly track input, which could work well here. At the same time, we must recognize that an online dialogue prevents the involvement of people with disabilities from multiply marginalized communities who may face serious gaps in access to technology. It is thus imperative that the plan include a place for in-person listening sessions outside of the halls of power. Regardless of the mechanics used to achieve this goal, the process should be public, clear, and accountable.

Data Collection, Public Transparency, and Accountability

  • RespectAbility is glad to see the serious commitment to addressing “top management and performance challenges, including those identified by the Inspector General” written throughout the Strategic Plan. The strategy and performance measures in the plan seem well calibrated to achieve the specific aims necessary to restore the program’s public reputation, meet the needs of federal agency customers and streamline management. Our only further comment on that subject is to say that good governance is synonymous with making a public commitment to being accountable and transparent. We look forward to seeing the Commission reflect that commitment in the months ahead.

Contracting, Entrepreneurship and Collaboration

  • RespectAbility is glad to see the serious commitment in the plan towards modernizing the Commission’s “data backbone.” The recent challenges witnessed across the nation’s unemployment insurance programs and in various states reflect the toll taken after years of under investment in the data infrastructure of federal, state, and local government agencies. Now is the time for proactive investment in data tracking, database management, and the other digital bones in the skeleton of the AbilityOne program.
  • RespectAbility also commends the Commission for moving forward to implement “the Commission’s Diversity, Equity, Inclusion, and Accessibility Plan.” DEI requires a living commitment from the organizations and agencies responsible and this represents a significant opportunity for the Commission to improve internal practices and hire talented, diverse workers with valuable lived experience and intersectional identities.
  • RepsectAbility is also glad to see that Performance Measure 3 focuses on coordination between the Commission and other federal agencies, particularly around “federal contractors” and “their Section 503 and Section 501 goals.” The past years have seen an explosion of innovative practices and work being done by federal contractors to meet those goals and really turn them into competitive business practices. We believe that the contractors previously recognized by the Office of Federal Contract Compliance Programs (OFCCP) with their Excellence in Disability Inclusion Award offer valuable lessons in this work. At the same time, OFCCP learned much about practical realities around setting and meeting goals through the use of Section 503 Focused Reviews. We look forward to seeing the results of this cooperation.
  • We were pleased to see a brief mention of collaborating with entrepreneurs with disabilities at the end of the Strategic Plan. In fact, given the outcomes of entrepreneurship programs for people with disabilities, we believe that this should be a significant strategy of the AbilityOne commission. We will be developing significant additional data and approaches on this point within the next twelve months, and we would welcome the opportunity to work with the AbilityOne Commission on integrating it into your plan. At the same time, as this is a federal agency, we believe there is a strong role to be play in coordinating with the SBA. We respectfully encourage the Commission to begin or accelerate collaboration in this regard.

These comments were prepared thanks to the hard work and close attention of RespectAbility’s Apprentices, Staff, and Board Members. Special credit is due to current Apprentices Alex Hilke, Elizabeth Pezone, Shereen Ali, and Roy Payan who have been active contributors to our organization’s work on policy, advocacy, civic engagement and advancing disability inclusion. They represent future leaders who will have a substantial impact on the opportunities and aspirations of millions of Americans with disabilities.

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