Background and Purpose

The WIOA amendments to the Rehabilitation Act of 1973 have resulted in changes to case service reporting and documentation requirements for state vocational rehabilitation (VR) programs (U.S. Department of Education Office of Special Education and Rehabilitative Services, 2016). Examples include additional data elements collection on program participant barriers, performance reports to help identify measurable skill gains and credentials, and follow-up on program participant closures to identify wages and sustainability required for quarterly case service reports. The guidelines for maintaining appropriate supporting documentation and requirements have elevated the need for strong internal processes to monitor and manage accountability of reported performance for core programs and services under WIOA. This is particularly true regarding requirements related to serving students and youth, such as the reporting and documentation for educational and/or training programs and employment outcomes (Fabian et al., 2018).

While VR agencies have been responsible for key performance management elements for decades, implementation of WIOA heightened VR agencies’ responsibilities around data collection, staff training, and the supporting documentation for services provided (Cummings et al., 2011; Leahy et al., 2009). These changes have enhanced the need for clear processes and evaluative efforts to identify any business process revisions and training needs, as well as options for identifying resources needed to support improvements. Collaborating with other WIOA partner agencies helps the Indiana Division of Disability and Rehabilitative Services (INDDRS) meet the supporting documentation requirements, as well as identify additional resources and strategies to blend services and improve outcomes. However, to ensure the agency was meeting the federal common performance measures requirements, INDDRS sought to assess the effectiveness of current processes and identify additional strategies to support the agency in meeting its performance expectations.

The purpose of this study was to (a) determine the challenges with implementing WIOA within the INDDRS state VR agency; (b) assess effectiveness and understanding of WIOA collaboration and data requirements by field staff; and (c) determine the effectiveness of current business processes, training, and resources to collect data.


To assess WIOA implementation challenges experienced by VR counselors within INDDRS, a survey was developed using Qualtrics. This survey contained nine questions with multiple choice and true/false options and included a comment field text for ‘other’ responses. This survey was emailed to 171 VR counselors (VRC) working for INDDRS, including itinerant VRC (working lead counselors) and trainee vocational rehabilitation counselors. The email included a hyperlink to the survey along with basic instructions and was available to INDDRS counselors for five days during March 2020. One follow-up reminder was sent to encourage participation, and time was provided for staff to complete the survey during the workday.


One hundred and ten (110) of the 171 surveys were completed, providing a response rate of 64.3%. Approximately one third (35.45%) reported having more than five years of experience as a VRC; 32.73% reporting two to five years of experience, and 31.82% of respondents reporting less than two years of experience as a VRC. The descriptive results reflect the perspectives shared by respondents.

Challenges Implementing WIOA Within the VR Agency

The primary challenges expressed by participants focused on communication, follow-through, and engagement of participants with active cases in the VR system. The additional reporting and documentation requirements for Measurable Skills Gains (MSG), credential attainment, and employment status were specifically identified as areas warranting further study. In terms of MSG, 32.95% of VR counselors had difficulty obtaining responses from participants and 32.39% expressed difficulty obtaining the required follow-up documentation from participants to support the MSG outcomes (see Table 1).

Table 1.WIOA Reporting and Documentation Challenges Reported by VR Counselors
WIOA requirement category Challenges reported Response percentage
Measurable Skills Gains Unable to obtain responses from participants  32.95
Difficulty obtaining documentation for case record 32.39
Credential attainment Unable to obtain responses from participants  35.67
Difficulty obtaining documentation for case record 32.75
Employment records Unable to obtain responses from participants  40.27
Difficulty obtaining documentation for case record 28.19
Follow-up documentation Unable to reach participant despite multiple attempts    33.91
Participant phone/address no long valid  28.70
Participant chose not to participate and provide additional information  28.26

Within WIOA requirement categories, 35.67% of respondents reported difficulty obtaining responses from participants regarding credential attainment and 32.75% had difficulty obtaining the documentation needed for confirmation and reporting purposes. This was more difficult for employment, where 40.27% noted difficulty obtaining responses from participants regarding employment and 28.19% had difficulty obtaining employment documentation.

In terms of the follow-up required on closed cases, roughly 90% of counselors reported difficulty contacting these participants specific to (a) 33.91% being unable to contact or locate the participant despite multiple attempts, (b) 28.70% of the participants phone number or address being invalid, and/or (c) 28.26% of participants opting not to provide the information. Among the minority, 5.2% of the survey respondents noted ‘no issues’ and 3.9% used the text field to note ‘n/a’ or ‘most participants not told at closure about the follow-up, making them not wanting to respond’.

Regarding the overall reporting and documentation requirements of WIOA implementation, counselors reported an impact on job duties, noting these changes (a) took time away from their ability to work with open active cases, (b) were [negatively] affecting their overall joy of the job, and (c) resulted in the number of cases requiring follow-up, which continued to grow (see Table 2).

Table 2.VR Counselor Knowledge and Perceived Impact of WIOA on Job Satisfaction
VR counselor perception Response options Response percentage
Overall impact of WIOA on job satisfaction Neutral-unchanged 39.09
Negative change 28.18
Knowledgeable about referring to partnering agencies Yes 60.00
No 40.00
Knowledgeable about WIOA reporting and documentation requirements Yes, I feel knowledgeable about inputting information and documenting   36.36
No, I have difficulty with education, MSG, credentials, and follow-up data and documentation requirements 26.36

Effectiveness and Understanding of WIOA Collaboration and Data Requirements

Sixty percent (60%) of VR counselors noted they felt knowledgeable on how to refer participants to partnering agencies. However, 53.6% felt they did not feel knowledgeable about where to document this collaboration in the VR program’s case records system. Overall findings suggested that staff have difficulty (a) obtaining the data and documentation, (b) finding time to effectively enter data, (c) with receiving timely responses from participants with closed cases, and (d) acquiring required follow-up documentation from participants after case closures.

Effectiveness of Current Data Collection Business Processes, Training, and Resources

In regard to feeling knowledgeable about what documentation to input in the system for WIOA reporting, the largest percentage of respondents (36.3%) reported they felt knowledgeable; however, on other measures: 26.6% noted difficulty with MSG, credentials, and follow-up; 16.3% had difficulty only with MSG’s and credentials; and 11.8% had difficulty with only follow-up after case closure. A smaller proportion (9%) of respondents offered other perspectives, noting (a) difficulty remembering what documentation is needed and/or feeling comfortable the documentation is correct, (b) the need for more training and/or clarity, (c) needing time to catch up with the additional guidance, and (d) the time-consuming nature of entering all the required information into the case management data system.

In terms of strategies to aid in resolving these challenges, counselors shared the following suggestions: (a) additional training on techniques and documentation needs, (b) re-allocation of responsibilities to staff beyond VR counselors to assist with managing time and caseloads, and (c) future agency collaborations and partnerships to support data exchanges and obtain required information and documentation more efficiently.

Recommendations and Implications for Practice

Based on the findings from this study, the following recommendations are offered to improve VR program processes and performance:

  • Provide additional training to VR staff in the identified WIOA performance areas.

  • Explore options for utilizing Case Coordinator staff roles within VR to assist in supporting counselors with the required reporting and documentation efforts. Consider the time and workload implications for VRCs regarding the WIOA requirements and engage staff in designing the new position. It is important to consider all tasks to be performed, length of time needed, and best options for allocating the responsibilities.

  • Utilize the Department of Education and State Wage Interchange System (SWIS) interfaces to administratively obtain follow-up documentation for Measurable Skills Gains and other WIOA information, to help reduce burden on field staff.

  • Staff training on WIOA requirements should be ongoing and include (a) initial training, (b) intermittent follow-up training, and (c) integrated into the orientation and training materials for newly hired VRCs.

  • Pursue data sharing with partner agencies to promote collaboration and alleviate field staff burden.

Author Note

The contents of this paper were developed under a cooperative agreement with the U.S. Department of Education, Technical Assistance Center for Vocational Rehabilitation Agency Program Evaluation and Quality Assurance (PEQA-TAC) (Grant Award Number: H263B150004). However, the contents and views expressed in this publication do not necessarily represent the positions or policies of the U.S. Department of Education, and you should not assume endorsement by the Federal government.