ࡱ>    s@  jbjb {l   4$ $ $ $ h T $ UipHHW"${'hhhhhhh,k mh(i- ***(i* H****  h*L l l *h* *+GY n^\/;$ $ *.Z[4n^ UiUi[Mo*Mon^* The Utilization of IPE/IWRP Goals other than Competitive Employment for American Indians and Alaska Natives with Disabilities FINAL REPORT 2003 Robert M. Schacht, Ph.D. Principal Investigator Hlne Flamand, M.Ps. Graduate Assistant American Indian Rehabilitation Research and Training Center  Institute for Human Development Arizona University Center on Disabilities PO Box 5630 Flagstaff AZ 86001-5630 The Utilization of IPE/IWRP Goals other than Competitive Employment for American Indians and Alaska Natives with Disabilities FINAL REPORT 2003 Robert M. Schacht, Ph.D. Principal Investigator Hlne Flamand, M.Ps. Graduate Assistant (Project Number R-49) American Indian Rehabilitation Research and Training Center Institute for Human Development Arizona University Center on Disabilities Northern Arizona University PO Box 5630 Flagstaff AZ 86001-5630 (928) 523-4791 Voice  (928) 523-9127 Fax  (928) 523-1695 TDD http://www.nau.edu/ihd/airrtc Funded by the National Institute on Disability and Rehabilitation Research (NIDRR) Office of Special Education and Rehabilitative Services, U.S. Department of Education, Washington, DC Grant No. H133B980049 The contents of this report are the responsibility of the American Indian Rehabilitation Research and Training Center and no official endorsement by the U.S. Department of Education should be inferred. Northern Arizona University is an Equal Opportunity/Affirmative Action Institution This report is available in alternate formats by contacting the Institute for Human Development at (928) 523-4791 Table of Contents List of Tables ii List of Figures ii Acknowledgements iii Summary iv Introduction 1 Legislative Basis 1 Defining Employment Options 3 Summary of Relevant Research 4 Self-employment 5 Homemaker and Unpaid Family Worker 5 The Issue of Gainful Employment 7 Sheltered Workshops vs. Supported Employment 8 Business Enterprise Programs 9 Rethinking Competitive Employment 10 Research Design and Methodology 11 Research Population 11 Procedures 12 Data from State VR Programs 14 Data from Tribal VR Programs 14 Data Analysis 14 Results 15 State VR Programs 15 Tribal VR Programs 17 Discussion 20 Unresolved Questions 23 Recommendations 24 References 25 Appendix A 28 List of Tables Table 1. State Agencies Using Alternatives to Competitive Employment the Most 16 Table 2. Work Status at Closure by Type of Closure (Tribal VR) 18 Table 3. Percentages, VR Work Status at Closure: American Indians and Alaska Natives 21 List of Figures Figure 1. Scatter plat of % Status 26 (rehabilitated) by % Competitive employment (State Agencies, RSA 911) 17 Figure 2. Type of Closure by Work Status (Tribal VR) 19 Acknowledgements We want to thank our two graduate assistants, Flor Lozano and Raeann Valdez, for their assistance with the research phase of this project. We also want to extend our sincere appreciation to the tribal vocational rehabilitation (VR) programs that took the time to respond to our survey. Their participation has been extremely valuable. We also want to thank those tribal VR program directors who expressed continuing interest in our research on alternatives to competitive employment. Summary Conventional competitive employment opportunities for American Indians with disabilities are often not available in places where they want to live, especially in remote rural areas and on or near reservations and other tribal lands. In addition, existing conventional competitive employment opportunities may not be culturally sensitive for members of tribal communities or allow these individuals to use their best skills and abilities. The public vocational rehabilitation (VR) system, funded in part by the federal Rehabilitation Services Administration (RSA), provides for several kinds of goals within the Individualized Plan for Employment (IPE) (formerly Individual Written Rehabilitation Plan [IWRP]) in addition to competitive employment. Such goals include self-employment, homemaker, unpaid family worker, business enterprises managed by state or tribal VR agencies, and sheltered workshops or supported employment. In addition, tribal VR programs have been working creatively to develop culturally appropriate interpretations of and alternatives to competitive employment. Some states, such as Alaska, have also developed innovative approaches that redefine the nature of competitive employment itself (see, for example, Anderson & Corbridge, 1989). The purpose of the research reported here was to improve employment outcomes for American Indians and Alaska Natives by demonstrating the effectiveness of implementing best practice strategies for achieving employment. These best practice strategies include employment goals that are culturally appropriate and that take into consideration a noncompetitive occupational environment, which is often the case in rural and reservation areas. The research hypothesis was that American Indian and Alaska Native clients of VR programs that offer culturally relevant interpretations of and culturally relevant alternatives to competitive employment in rural and reservation areas will have higher rates of successful rehabilitation (i.e, Status 26 closure) and will spend less time in Status 20 (ready for employment). That portion of the research hypothesis that could be tested was somewhat supported by state VR data and not supported by tribal VR data. Specifically, testing the hypothesis was challenged by certain data conditions: Information on time spent in Status 20 was not available, so that part of the hypothesis could not be tested. Work status at closure was not recorded by state VR programs (form RSA-911) and some tribal VR programs except for cases closed rehabilitated. This meant that a straightforward test of the hypothesis using RSA-911 data could not be performed. "Rural and reservation areas" cannot be distinguished from urban areas in RSA-911 data, making that part of the hypothesis untestable. Review of the available data for state VR programs indicated that, as the percentage of cases closed in competitive employment increased, the percentage closed rehabilitated decreased. For state VR, it appears that American Indian-Alaska Native outcomes in alternatives to competitive employment were rarely used, and that this may have negatively impacted the number of successful closures. On the other hand, in tribal VR programs, using survey data collected in 2003, competitive employment placements seemed to correlate positively with successful rehabilitation closures. However, service outcomes reported by the tribal VR programs included a large "Other" category (n = 122), used by 8 of the 25 programs reporting. Time limitations prevented researchers from researching these responses in enough detail to understand adequately what kinds of outcomes they really represented. What seemed clear, however, was that the diversity of approaches made possible by tribal sovereignty also made the task of data analysis more difficult. The competitive employment outcomes used by tribal VR may in fact represent culturally relevant interpretations of and culturally relevant alternatives to what the mainstream culture considers competitive employment. The significance of this finding for future research is that tribal diversity results in an opportunity for creative approaches to VR that require considerable time for analysis and understanding. It is our impression that this diversity deserves more careful study, both to help programs that are struggling to provide effective rehabilitation and to recognize and publicize innovative solutions to the unique challenges of tribal vocational rehabilitation. We found that the percentage of American Indians and Alaska Natives closed in competitive employment increased by substantial amounts (8% or more) in both state and tribal VR programs since 1996. On the other hand, homemaker and unpaid family worker closures dropped significantly in both state and tribal VR programs, even though they remain legal options. Tribally managed Business Enterprise Programs (BEP) were still significant in tribal VR programs even though the percentage dropped by almost half in just two years. Self-employment outcomes decreased in tribal VR programs, although these placements remain at least twice as common as in state VR programs. Finally, the number of American Indians and Alaska Natives receiving VR services increased: the number closed rehabilitated in state VR programs doubled in two years, and the number of tribal VR programs increased to a total of 71, of which 69 receive RSA funding. Based on the results of our research, we make the following recommendations: In regard to state VR documentation, when a case is closed not rehabilitated after IPE is initiated (Status 28), and, for example, the client has begun working but has been unable to maintain employment, the work status at closure should be recorded in RSA-911 case service reports, rather than being left blank. These data are important for analyzing and understanding rehabilitation outcomes that are not considered successful. Results from the tribal VR survey suggest that there is still some unfamiliarity with the alternatives to competitive employment, or at least as defined by RSA. Furthermore, the federal emphasis on competitive employment as the gold standard VR outcome may have the effect of discouraging use of the legal alternatives. In order for the tribal VR programs to learn from each other in a helpful way, Consortia of Administrators for Native American Rehabilitation (CANAR) conferences (annual and/or mid-year) should include workshops on alternatives to competitive employment. One-hour sessions on each alternative could focus on (a) the definition of that employment category, (b) services helpful to VR customers who desire that employment goal, (c) funding sources, (d) typical challenges that must be solved, and (e) factors promoting long-term success. Rather than or in addition to lectures and other didactic presentations, we recommend panel discussions in which tribal and state VR professionals can communicate specific challenges and successful strategies. The Utilization of IPE/IWRP Goals other than Competitive Employment for American Indians and Alaska Natives with Disabilities The emphasis on conventional competitive employment as the gold standard of vocational rehabilitation (VR) outcomes for all consumers with disabilities who want or need to work is based on assumptions about the desirability, suitability, and availability of competitive employment. However, many VR customers live in environments or are members of cultural groups in which these assumptions are not universally valid. Such noncompetitive occupational environments may include, for example, rural and remote areas, communities on or near American Indian reservations, culturally distinct areas, or some inner city communities (see Anderson & Corbridge, 1989). Among the strategies available to individuals and the VR agencies that serve them are relocation to cities, using alternatives to competitive employment, and redefining the nature of competitive employment itself. Legislative Basis Employment outcomes other than competitive employment are recognized in current rehabilitation statutes and policies, and some of these may meet the needs of some American Indians with disabilities better than competitive employment. As defined in the HYPERLINK "http://www.access.gpo.gov/nara/cfr/waisidx_02/34cfr361_02.html"  State Vocational Rehabilitation Services Program regulations (2001), section 5(b), employment outcomes mean, with respect to an individual, entering or retaining full-time or, if appropriate, part-time competitive employment, as defined in 361.5(b)(11), in the integrated labor market, supported employment, or any other type of employment in an integrated setting, including self-employment, telecommuting, or business ownership, that is consistent with an individual's strengths, resources, priorities, concerns, abilities, capabilities, interests, and informed choice. [Authority: Sections 7(11), 12(c), 100(a)(2), and 102(b)(3)(A) of the Act; 29 U.S.C. 705(11), 709(c), 720(a)(2), and 722(b)(3)(A)] This list is not complete, however. In Appendix A of the final regulations for state VR, and in response to the question, Are Homemaker and Unpaid Family Worker Considered Employment Outcomes for Purposes of the VR Program?, it is stated: Yes. The chief purpose of the regulations is to ensure that individuals with disabilities participating in the VR program are able to pursue the same type[s] of employment opportunities that are available to the general public. Extended employment [e.g., sheltered worshops] jobs, unlike homemakers and unpaid family workers, are primarily reserved for those with disabilities HYPERLINK "http://www.access.gpo.gov/nara/cfr/waisidx_02/34cfr361_02.html"  (State Vocational Rehabilitation Services Program, 2001, Appendix A) In other words, homemaker, unpaid family worker, and sheltered workshops remain valid employment outcomes under current law. The regulations for VR explicitly list alternatives for nonintegrated extended employment in settings such as sheltered workshops. Such alternatives include entering or retaining full-time or, if appropriate, part-time competitive employment in the integrated labor market, the practice of a profession, self-employment, homemaking, farm or family work (including work for which payment is in kind rather than cash), extended employment in a community rehabilitation program, supported employment, or other gainful work [Authority: Sec 7(5) of the Act; 29 U.S.C. 706(5);  HYPERLINK "http://www.access.gpo.gov/nara/cfr/waisidx_02/34cfr361_02.html" State Vocational Rehabilitation Services Program, 2001]. These employment options are tracked in Rehabilitation Services Administration (RSA) documents under the headings Work Status at Referral, Individual Plan for Employment (IPE) Goal (formerly Individual Written Rehabilitation Plan [IWRP]), and Work Status at Closure. The Rehabilitation Act of 1973, as amended, requires that the client be informed about and involved in choosing among alternative goals. This policy is supported by the principles of community integration (e.g., Taylor, 1987), person-centered planning (Gahungu, 2002), and the Olmstead decision of the U.S. Supreme Court (Olmstead v. L. C. and E. W, 1999). Defining Employment Options Employment goals utilized by American Indian tribal VR programs are governed by the definitions in Vocational Rehabilitation Service Projects (2002) (see Vocational Rehabilitation Service Projects for American Indians with Disabilities, 1995, section 4[a]). Traditional art, artisan, and craft activities such as weaving, silversmithing, beadwork, pottery making, wood sculpting, and leatherwork have been significant cultural and religious expressions, as well as forms of livelihood, in traditional Native cultures on this continent for many generations. Mainstream VR programs may emphasize training American Indian VR customers to be employees rather than to take advantage of Native traditions as craftsmen, family workers, and homemakers. As a result, American Indians engaged in the VR process may receive counseling in employment opportunities that are difficult to find in their home areas, requiring relocation in order to achieve rehabilitation (Schacht & Minkler, 1991). This practice may contribute to the continuing breakup of American Indian families and tribes and the placement of individuals in socially vulnerable employment patterns that lack the informal support networks available closer to their homes. Greater use of culturally sensitive employment options that recognize Native traditions would make it easier for American Indians with disabilities who reside on or near reservations to find or create work opportunities in their home areas, for example in small-scale home-based industries. While use of these alternatives to competitive employment is tracked annually by state agencies through the use of the RSA-911 Case Service Reports (CSR) (Rehabilitation Services Administration, 1995), the tracking of alternatives to competitive employment by tribal VR programs is less clear because there is no standardized reporting system for tribal VR programs comparable to the state VR RSA-911 CSRs. There is a need to understand more clearly the strategies being used in the tribal VR programs, both in development of Individual Plans for Employment (IPEs) and in finding culturally appropriate employment placements for American Indians that may differ from textbook off-reservation rehabilitation strategies. Finally, the very definition of competitive employment can be reevaluated in the light of culturally appropriate standards of productive work. Summary of Relevant Research In 1987, Martin and Frank wrote that "...the unemployment rates of American Indians, especially those living on or adjacent to reservations, are pervasively higher than unemployment experienced in the total civilian labor force..." (p. 142). Other studies reported that the unemployment rate for American Indians was about 1.5 to two times that of the total population (U.S. Census Bureau, 1991, p. 39; LaPlante, 1988, p. 11). Unemployment among American Indians was estimated at 13% using 1994-1995 National Health Interview Survey data and 11.5% using 2002 Current Population Survey data (Schacht, White, & Daugherty, 2003). Specific to American Indians living on and adjacent to reservations, according to the 1990 U.S. Census, 25.6% of the civilian labor force on American Indian reservation and trust lands was unemployed (U.S. Census Bureau, 1993, Table 9). In 1995, the Bureau of Indian Affairs (BIA) estimated that 49% of the American Indian labor force was not employed (Bureau of Indian Affairs, 1995, Table 3). The reasons for the differences among these estimates are not clear, yet these data point to an adverse employment situation on or near the reservations or tribal lands where many American Indians want to live. A preliminary study of the utilization of IPE goals other than competitive employment for American Indians with disabilities showed that about 20% of American Indian cases were closed in various alternatives to competitive employment, compared with 15% of non-Indian cases (Schacht, Wagner, Clay, Vanderbilt, & White, 2001, p. 21). Even so, certain alternative placements were being discouraged, even though it might serve the best interests of the VR customers to use them more optimally and more widely. Specifically, national Rehabilitation Services Administration (RSA) data from state VR programs for 1996 cited in this study indicated that work status at closure for American Indians closed in Status 26 (rehabilitated) consisted of 80% competitive employment, 7% homemakers, 5.5% unpaid family workers, 4% self-employed, and 3.5% in sheltered workshops. Only one was closed in a Business Enterprise Program (BEP) (.06%). Compared with non-Indians, American Indians in VR were closed rehabilitated three times more often than non-Indians in unpaid family worker status (5.5% vs. 1.7%) (p. 21). However, these data did not include work status at closure for tribal VR programs. Self-employment The 2001 study by Schacht, Wagner, Clay, Vanderbilt, and White suggested that tribal VR programs were using self-employment as a placement goal more often than state VR programs: 4% of American Indian and Alaska Native cases closed rehabilitated in state VR programs in FY 1996 were self-employed [most recent RSA data available at the time of the study], while for 18 tribal VR programs surveyed in 1997-1998 the comparable figure was 13%. A study on the relocation of American Indians with disabilities (Schacht & Minkler, 1991) concluded with a recommendation that "Training programs promoting the goal of self-employmentshould be developed or enhanced, and publicized" (p. 101) in order to avoid over-reliance on relocation. Self-employment placements, if appropriately planned and implemented, may also strengthen and support the family while providing an adequate source of income. This type of placement requires creativity and resourcefulness on the part of both counselor and client, as they consider local business needs and perhaps even subsistence needs when establishing a variety of alternative employment goals and new occupations. Success in self-employment often requires patience and tenacity. Barriers to self-employment through VR can include the need to develop an appropriate business plan, start-up costs, and HUD housing regulations (i.e., people cannot do business at home if they live in HUD-supported housing). Additionally, there has been a general lack of knowledge about self-employment on the part of both counselors and their clients/customers. Not only do customers need to have the knowledge about how self-employment works, but counselors may need training in this area as well. Counselor skills in understanding self-employment will be passed on to customers, resulting in a greater success rate with those individuals for whom more traditional employment venues are not possible or desirable. (Schacht, Wagner, Clay, Vanderbilt, & White, 2001, pp. 67-68) Homemaker and Unpaid Family Worker As mentioned earlier, although current federal regulations in the State Vocational Rehabilitation Services Program (2001) do not explicitly refer to homemaker and unpaid family worker outcomes, these are explicitly included in the definition of VR employment outcomes ( HYPERLINK "http://www.access.gpo.gov/nara/cfr/waisidx_02/34cfr369_02.html" Vocational Rehabilitation Service Projects, 2002). There was an extended discussion of these categories in the rule-making process (State Vocational Rehabilitation Services Program, 2001), the main issue appearing to be the question of whether, given the emphasis on placements in integrated settings, homemakers and unpaid family workers would qualify. Wage issues were another concern. These issues were resolved as follows: The definition of employment outcome, for purposes of the VR program, in these final regulations modifies the prior regulatory definition by requiring that employment outcome under the VR program occur in integrated settings. The final regulations do not address wage issues, meaning that non-wage earning (and other sub-minimum wage) employment outcomes, as long as they occur in integrated settings, satisfy the VR program definition of employment outcome in Sec. 361.5(b)(16). While we strongly believe that individuals with disabilities receiving VR services should pursue employment outcomes with competitive wages, the final regulations do not mandate that result. Schacht, Wagner, Clay, Vanderbilt, and White (2001) found that of American Indian and Alaska Native cases closed rehabilitated in state VR programs in FY 1996, 7.2% were homemakers; in tribal VR programs surveyed in 1997-1998, the comparable figure was 6%. Further, in several states it was observed that, on the one hand, VR counselors find a need to use homemaker status as a rehabilitation goal, and on the other hand, certain rehabilitation service managers have sought to minimize the use of, or even to phase out, this option. The attitude of state service managers can be a very strong barrier, creating confusion about rehabilitation options, and narrowing the potential for successful placements and case closures. An important objective when implementing placements for American Indians may be the cultural need for collaborative rather than individual decision making on behalf of the consumer. In this case, the whole family should become involved when setting goals for placement, particularly when homemaker status is a possible eventuality. For homemaker placements, there seemed to be a number of barriers to utilization: (a) pressure from managers to minimize use of non-competitive placements, (b) the fear by counselors of repetitive requests for on-going services, and (c) lack of funding. Perhaps the solution to some of these matters of closure is for the family to be brought into the picture from the beginning, with clear outcome objectives and closure criteria. Additionally, although homemakers with disabilities like diabetes and blindness may not be able to earn money from the services rendered by VR and other specialists, they will have heightened independent living skills and make their contributions to the well-being of others. These are benefits that can be just as beneficial as the financial rewards of competitive employment. (p. 69) The Issue of Gainful Employment Current federal regulations do not address wage issues, meaning that non-wage earning (and other sub-minimum wage) employment outcomes, as long as they occur in integrated settings, satisfy the VR program definition of employment outcome (State Vocational Rehabilitation Services Program, 2001, Section 5[b][16]). In addition, the current regulations recognize that employment outcomes may include farm or family work (including work for which payment is in kind rather than cash) ( HYPERLINK "http://www.access.gpo.gov/nara/cfr/waisidx_02/34cfr369_02.html" Vocational Rehabilitation Service Projects, 2002, Section 4). Schacht, Wagner, Clay, Vanderbilt, and White (2001) observed that "unpaid family workers who engage in traditional subsistence activities such as hunting or herding, or noncommercial farming and gardening, can be productive while supporting the family and decreasing its need for outside assistance (p. 70). Some American Indian reservations and Alaska Native village areas are large enough to permit traditional subsistence activities, or modern versions of these, to exist. These activities can provide important opportunities for productive work, but payment may not be in the form of conventional wages. In explaining changes made in 1995 to federal regulations relating to gainful employment under the tribal VR programs (Vocational Rehabilitation Service Projects for American Indians with Disabilities, 1995, Section 1), the Department of Education wrote: The Secretary interprets the term gainful employment to be any employment outcome that is consistent with individual strengths, resources, priorities, concerns, abilities, capabilities, and informed choice. Gainful employment is not synonymous with competitive employment; the term includes, but is not limited to, competitive employment. The Secretary believes that the new legislative language, as reflected in the regulations, strengthens consumer choice of a vocational goal under the program rather than diminishing it as some commenters feared. (p. 58136) Thus, gainful employment is not restricted to competitive employment and includes alternatives to competitive employment. The Dictionary of Occupational Titles (U. S. Department of Labor, 1991) recognizes an entire division (codes 400-499) devoted to Agriculture, Fishery, Forestry, and Related Occupations, which includes hunting and trapping. Thus, the employment outcome of unpaid family worker (including farm or family work), for which payment is in kind rather than cash, may be especially relevant to members of Native cultures. While some VR programs explicitly recognize this possibility (e.g., Anderson & Corbridge, 1989, p. 7-8), little research has been done about the use of this employment outcome for American Indians and Alaska Natives, other than the studies by Anderson and Corbridge (1989) and Schacht, Wagner, Clay, Vanderbilt, and White (2001). As reported earlier, Schacht et al. found that, of American Indian and Alaska Native cases closed rehabilitated in state VR programs in FY 1996, 5.5% were unpaid family workers (p. 21); however, the comparable 1997-1998 rate for tribal VR programs was 2.3%, indicating that tribal VR programs were using this placement goal about half as often as state VR programs. Sheltered Workshops vs. Supported Employment In the RSA-911 Case Service Report Manual (Rehabilitation Services Administration, 1995), extended employment (workshops) is defined as "work for wages or salary in a setting conducted by a nonprofit organization for persons with disabilities unable to enter into or not ready for competitive employment. Such settings are variously referred to as rehabilitation, community, curative, sheltered, industrial, or occupational workshops" (p. 38). In conjunction with independent living programs, sheltered workshop settings can provide the kind of working environment that some customers need in order to succeed (see, for example, Streissguth, LaDue, & Randels, 1988, pp. 44-47). Schacht, Wagner, Clay, Vanderbilt, and White (2001) found that, of American Indian and Alaska Native cases closed rehabilitated in state VR programs in FY 1996, 3.5% were in sheltered workshops; in tribal VR programs surveyed in 1997-1998, the comparable figure was 0.7%, perhaps reflecting lack of availability of sheltered placements on reservations. However, the viability and success of sheltered workshops for some American Indian customers has been demonstrated at sites such as Toyei Industries and Coyote Canyon on the Navajo Reservation. Such reservation-based sheltered workshops can be run using American Indian concepts of wellness and wholeness, and can promote transition to supported and other kinds of employment when appropriate (Schacht, Wagner, Clay, Vanderbilt, & White, 2001, p. 66). Extended employment (i.e., sheltered or non-integrated employment) remains both an initial step toward achieving integrated employment under the VR program and a long-term employment option through sources of support other than the VR program (State Vocational Rehabilitation Services Program, 2001, p. 7254). In this explanation, the Department of Education seems to be saying that sheltered employment is a viable VR outcomeas long as another funding source is identified for the long-term sheltered employment support for individuals with the most significant disability. Withdrawing or reducing funding for this option thus becomes a barrier to its use. Historically, changes in policy regarding sheltered employment have affected utilization of options of this kind (e.g., Will, 1987). Federal regulations were changed in 2001 to stipulate that the employment outcome should be in the most integrated setting possible, consistent with the individuals informed choice (State Vocational Rehabilitation Services Program, 2001, section 56). Sheltered employment is considered a segregated setting, while supported employment is considered an integrated setting. Supported employment has been advocated as a progressive alternative" in regard to placement in sheltered workshops (Rosen, Bussone, Dakunchak, & Cramp, 1993). Thus, in some states supported employment, like sheltered employment, is now being used as an alternative to competitive employment. Business Enterprise Programs The Rehabilitation Services Administration (1995) defines business enterprise programs as vending stands and other small businesses operated by persons with severe disabilities under the management and supervision of a State agency. It includes home industry, farming, and other enterprises. Home industry involves work performed under the management and supervision of a State agency in the clients own home or residence for wages or salary on a piece-rate, hourly, weekly, or monthly basis. Such employment may be engaged in by persons capable of activity outside the home, as well as by homebound persons. ( p. 39) In their study of noncompetitive employment outcomes for American Indians with disabilities, Schacht, Wagner, Clay, Vanderbilt, and White (2001) found that, of American Indian and Alaska Native cases closed rehabilitated in state VR programs in FY 1996, .06% were in BEPs; the comparable figure for tribal VR programs using 1997-1998 data was 13%. This large percentage in the tribal VR programs was due primarily to two programs, although 7 of the 18 programs responding to the survey reported at least one BEP placement. For one tribe, the use of BEPs for VR employment placements appeared to be an intentional response to an otherwise bleak employment situation (p. 47). The researchers made the following observations about BEPs: Knowledgeable VR staff people mentioned three barriers to the successful use of BEPs: finances, information, and severe disability. Clients that are successful with BEPs were likely to have more similarities with self-employment placements than with sheltered workshop placements, and the same kind of creativity is needed to generate both kinds of new employment ventures. If the financial issues can be worked out for BEPs, such as who pays how much for what and where taxes go, the other barriers may not seem so insurmountable. The Tuba City Laundromat might serve as a model for such programs because it was established and funded by the Navajo Nation specifically for the employment of people with disabilities. . . . (p. 68) Rethinking Competitive Employment Some states have implemented innovative policies for competitive employment as well as alternatives to competitive employment. In Alaska, a special definition of employment has been used that includes any substantial, meaningful activity to which an individual devotes time and exerts physical or mental effort toward the production or accomplishment of something which significantly contributes to the livelihood of the individual and which benefits society (Anderson & Corbridge, 1989). Successful rehabilitation is then redefined for a person who lives in a noncompetitive employment environment. The special status of American Indians and Alaska Natives was highlighted by Schacht, Wagner, Clay, Vanderbilt, and White (2001) in their recommendation that National and regional RSA offices should be informed about the cultural importance of alternatives to competitive employment, and should be trained by Regional Rehabilitation Continuing Education Programs (RRCEPs) to deal with this issue in a culturally competent way. Insensitive attempts to discourage these alternatives should be countered with appropriate information about their importance to the vitality of Native cultures (p. 71, emphasis in original). They also recommended training for state and tribal VR program staff in the advantages and appropriate use of the legal alternatives to competitive employment, and full disclosure to all American Indian and Alaska Native customers about all legal alternatives to competitive employment so that they can make an informed choice of goals in their plan for employment. None of the legal alternatives should be described negatively (pp. 71-72). Research Design and Methodology The purpose of this research was to improve employment outcomes for American Indians and Alaska Natives by demonstrating the effectiveness of implementing best practice strategies for achieving employment in which the employment goals sought are culturally appropriate when the occupational environment is noncompetitive, as is often the case in rural and reservation areas. The research hypothesis was that American Indian and Alaska Native clients of VR programs that offer culturally relevant interpretations of competitive employment and culturally relevant alternatives to competitive employment in rural and reservation areas will have higher rates of successful rehabilitation (i.e., Status 26 closure), and will spend less time in Status 20 (ready for employment). Research Population Data from RSA-911 Case Service Reports for FY 1998, the most recent data then available, were obtained on compact disk (CD) in order to test the research hypothesis and to identify state VR programs that were placing at least 20% of their customers in alternatives to competitive employment. Data were analyzed from 69 state VR programs (including state programs for the blind) that had American Indians or Alaska Natives who were closed rehabilitated (N = 1,952). Since tribal VR projects are not required to submit annual RSA-911 reports, we designed a special one-page survey form (Appendix A) to gather information from them. A letter of invitation to participate was sent with the survey form to all 71 tribal VR projects (both federally and tribally funded); 30 surveys were returned, a response rate of 42%. Of that number, four agencies were new and did not report any closures. One agency did not use the same closure status categories and did not report numbers, and therefore was not included in the results. The 25 tribal VR programs that did have data to report (35% of existing programs) generated 737 individual cases (N=737). Procedures Time spent in Status 20 could not be tested; we were informed (D. Corbridge, personal communication, October 16, 2002) that You cannot retrieve the time spent in status 20 from the 911 data orany data captured by RSA. State VR data does not distinguish among urban, rural, and reservation contexts. The only geographical identifier in the RSA-911 data is an agency code, so in these data there appears to be no way to differentiate between rural residents and urban residents within each state. Thus, we focused on two kinds of data on employment outcomes: RSA-911 data from state VR programs and data from a survey of tribal VR programs. In the state VR program there are a number of different types of closure, each designated by a closure code: Closed, not accepted for VR services, from applicant status (Status 08 from Status 02); Closed, not accepted for VR services, from extended evaluation (Status 08 from Status 06); Closed rehabilitated (Status 26); Closed, not rehabilitated, after Individualized Written Rehabilitation Program/Individual Plan for Employment (IWRP/IPE) initiated (Status 28); Closed, not rehabilitated, before Individualized Written Rehabilitation Program/Individual Plan for Employment (IWRP/IPE) initiated (Status 30); Closed from the pre-service listing (Status 38 from Status 04). For the purpose of this research, the relevant closure statuses were closure codes 3 5 (Statuses 26, 28, and 30). The test statistic, then, was the number of cases closed rehabilitated (Status 26) divided by the number of cases closed in statuses 26, 28, and 30 (percent rehabilitated). Placement in alternatives to competitive employment was traced by work status at closure, a variable with six values (Rehabilitation Services Administration, 1995, p. 38) that categorizes the legal employment outcomes as: Competitive employment Extended employment (workshops) Self-employment (except BEP) State-agency-managed business enterprises (BEP) Homemaker Unpaid family worker However, we discovered that these categories were reported only if the case closed in status 26 (rehabilitated.) Thus, if a case closed not rehabilitated, we had no way to know what employment goal the IPE [(then termed an Individualized written plan (IWRP)] contained. For simplicity, the test statistic, Percent Competitive Employment, was the number closed in work status code 1, divided by the number closed in work status codes 1 through 6. If the research hypothesis were true, we would expect that, for American Indians and Alaska Natives, the more often the work status at closure was an alternative to competitive employment, the more often cases would close rehabilitated. The units of analysis in this case were VR programs. According to the hypothesis, the programs should report more success (i.e., more cases closed rehabilitated) with American Indians and Alaska Natives when the work status at closure was an alternative to competitive employment. Therefore, to test the hypothesis, work status at closure was dichotomized into competitive employment vs. all other (hence, noncompetitive) categories of employment. Type of closure was dichotomized into cases closed rehabilitated (Status 26) versus those closed not rehabilitated (Statuses 28 and 30). Cases closed in other statuses were not used in the analysis. Only American Indian and Alaska Native cases were used. Data from State VR Programs Since work status at closure is provided only when a case is closed rehabilitated (Status 26), it was not possible to determine from the RSA-911 data what the placement goals were in the cases closed not rehabilitated (Statuses 28 and 30)i.e., whether the goal of rehabilitation had been placement in competitive employment or placement in an alternative to competitive employment. Thus, we could not test the hypothesis by crosstabulating work status at closure and type of closure using the RSA-911 data. Consequently, we could not analyze the failurescases closed not rehabilitatedto see what work status goals were not being achieved. However, we could still calculate percentage of competitive employment (for cases closed rehabilitated) and percentage rehabilitated (for cases closed rehabilitated or not rehabilitated) for each VR program, and this was the procedure we used to test the hypothesis. Data from Tribal VR Programs The tribal VR survey form invited the programs to indicate work status at closure for cases closed not rehabilitated as well as for cases closed rehabilitated. Some tribal VR programs, like the state VR programs, did not provide work status breakdowns for cases closed not rehabilitated, but 13 did; these provided the basis for analysis. Data Analysis Analysis of state VR (RSA-911) data was conducted using the Statistical Package for the Social Sciences (SPSS) (1993) to obtain crosstabulations and, when appropriate, chi-square statistics. Crosstabulation of type of closure (TOC, Statuses 26, 28, and 30) by agency with work status at closure (WSC) by agency generated raw counts and percentages by state for each TOC and WSC category. These results were then combined into a spreadsheet in which the rows were the agencies and the columns were frequencies of closure statuses and work statuses at closure. Columns were then added for percentage of Status 26 (number of cases closed rehabilitated, divided by the total number of cases closed in Statuses 26, 28, or 30) and percentage of competitive employment (number of cases closed in competitive employment, divided by number of cases closed in all employment categories). A total of 69 state agencies (VR and blind services) had at least one American Indian or Alaska Native closed in Status 26 (rehabilitated). In these 69 programs, 1,952 American Indians and Alaska Natives were closed rehabilitated. Aggregate tribal VR survey data from 25 programs were used to reconstruct 737 individual cases. This case-level data consisted of six variables: (a) an arbitrary case number, (b) identification number for tribal VR program, (c) state, (d) work status at closure, and (e) type of closure. Using this data, we were able to conduct some of the same analyses as for the state VR RSA-911 data. Results State VR Programs The agencies using alternatives to competitive employment the most (in percentage terms) were eight agencies for the blind, with up to 50% of their cases in competitive employment. Most of these agencies served small numbers of American Indians and Alaska Natives; the largest had 25 cases closed rehabilitated. The most frequent alternative to competitive employment among these American Indians and Alaska Natives was the work status of homemaker. Table 1 shows statistics from eight of the nine state programs that used alternatives to competitive employment the most. Nine programs placed 15 30% of their customers in noncompetitive placements; these can be considered high use states. Note that the state agencies are listed in ascending order of percentage of cases in competitive employment work status (Status 26) at closure; Pennsylvania, with 13 Status 26 closures and 2 noncompetitive placements, meets the technical definition of "high use" but is not included in Table 1, which lists the state agencies that had more than 15 American Indians and Alaska Natives closed rehabilitated. Table 1 State Agencies Using Alternatives to Competitive Employment the MostType of ClosureWork Status at Closure State Agency TotalStatus 26 (Rehabilitated) nStatus 26 %Compet. Employ. nCompet. Employ. %HMKR( nSE( nExEm( nUFW( nBEP( nNew Mexico19611257.14%7970.54% 2112Wisconsin1263830.16%2873.68%28 Nebraska 611931.15%1473.68%5 Oklahoma24716466.40%12375.00%3029New York 1806837.78%5377.94%438Missouri521630.77%1381.25%111Illinois492346.94%1982.61%1 3Colorado 783747.44%3183.78%5  1All Reporting Agencies 4663 1952 41.86% 1712 87.70% 90 77 65 6 2( UFW = unpaid family worker; BEP = business enterprise program; ExEm = extended employment; SE = self-employment; HMKR = homemaker; Compet. = competitive; employ. = employment A scatter plot (Figure 1) of state VR data gives percentage of American Indian and Alaska Native cases closed rehabilitated (Status 26) by percentage with competitive employment at closure. A trend line was added to the scatter plot using SPSS. The slope of the trend line was negative, indicating that as the percentage of cases closed in competitive employment increased, the percentage closed rehabilitated decreased. The F-test for this regression line was marginally significant at F (1, 67) = 3.967, p = .05, with % Status 26 as the dependent variable. Figure 1. Scatter plot of % Status 26 (rehabilitated) by % Competitive Employment (State Agencies, RSA-911) EMBED Word.Picture.8 Tribal VR Programs We made a working assumption that even though the tribal VR programs are not required to submit annual RSA-911 case summary reports they would be familiar with or actually use the same terminology and definitions in their own record keeping (see Appendix A); 25 programs reported on a total of 737 cases. Some programs were able to report only a few cases (minimum = 2), but three reported on more than 70 cases (maximum = 73). Work status at closure was reported for cases closed not rehabilitated by all but three programs; for these three programs, it was not clear whether the lack of data for cases closed not rehabilitated reflected missing data or whether the three programs were actually 100% successful in rehabilitating their customers. Tribal VR programs varied considerably in their percentage of closures in Status 26. The average across all programs was 54% of the 737 cases being closed rehabilitated (Status 26). One program was closing fewer than one third of its customers as rehabilitated (Status 26), and five more reported under 40% of closures in Status 26. Competitive employment remained both the primary type of successful closure (300 of 400 closures, or 75%, in competitive employment) and by far the most common work goal, at 60% (n = 440), of all closures (including cases closed not rehabilitated, Statuses 28 and 30). Of those with a work goal of competitive employment, 68% were closed rehabilitated (Status 26). With this as the standard, we see from Table 2 that some of the alternatives to competitive employment had even higher success rates: tribal BEPs (100%), unpaid family workers, etc. (100%), self-employment (91.5%), and homemakers (72.7%). The principal exception was supported employment, with only 11.8% closed rehabilitated. However, the data in this case might be skewed by the two tribal VR programs that had the largest number of supported employment placements, both of which reported no cases of supported employment closed rehabilitated, suggesting the possibility of a programmatic explanation for this phenomenon. Table 2 Work Status at Closure by Type of Closure (Tribal VR)Work Status at ClosureType of ClosureTotalStatus 26Status 28Status 30  n%n%n%Competitive Employment30068.2%10323.4%378.4%440 Self-Employment4391.5%48.5%0.0%47 State or Tribal BEP38100.0%0.0%0.0%38 Supported Employment411.8%3088.2%0.0%34 Homemaker872.7%327.3%0.0%11 Unpaid Family Worker, Subsistence Worker, Other (Seasonal Worker) 5100.0%0.0%0.0%5Extended Employment1100.0%0.0%0.0%1 Unemployed0.0%3384.6%615.4%39Other1.8%7158.2%5041.0%122Total40054.3%24433.1%9312.6%737 In the tribal VR data, the relationship between type of closure and work status is direct: the percentage of Status 26 (rehabilitated) closures is proportional to the percentage of closures in competitive employment (Figure 2), and the slope of the trend line was positive and statistically significant [F (1, 23) = 5.298, p = .031]. Similarly, the Pearson Correlation of .433 was significant at the 0.05 level (2-tailed). Figure 2. Type of Closure by Work Status (Tribal VR) EMBED Word.Picture.8 As discussed earlier, there is some indication that the different tribal VR programs are not necessarily using the terms work status at closure and types of closure in the same way. This is understandable given the great diversity of American Indian and Alaska Native tribal entities and the fact that tribal VR programs are not required to and do not necessarily follow the reporting conventions of the state system (RSA-911). We include the following examples to illustrate how some tribal VR programs may define and report rehabilitation progress and outcomes quite differently from national norms. One tribal VR program reported its unsuccessful closures of cases without an IPE initiated as Status 28 and with IPE initiated as Status 30; for purposes of consistency and thus analyzability, we reversed these codes in data entry. Another tribal VR program provided the following explanations for the high ratio of their cases closed in Status 28: A high illiteracy rate. Two of the customers disabilities progressively worsened and they were unable to continue with their IPEs. Several customers moved to locations off-reservation. Entering the VR program was sometimes motivated by customers spouses more than by the customers themselves; therefore customers lost interest and dropped out. Some customers dropped out of VR services when they found out they were eligible for SSI benefits. There was a tribal policy that discouraged hiring persons with felony convictions. The geographic regions unemployment rate hovered at about 65%. There was a high rate of chemical dependency among potential customers. One Alaskan VR program defined subsistence work as hunting, whaling, and Native crafts with marine animals that are accessible only to Native Alaskans. Another noted that tribally-managed businesses were considered competitive employment, and that many of the businesses are tribally owned. One program did not use the standard RSA closure codes but instead defined two closures: Status 10 (successful, competitive employment) and 15 (other). Discussion The current state VR practice of recording work status at closure or work goal only for cases closed rehabilitated may hinder analyses that attempt to discover what went wrong. It is understandable that in many cases closed not rehabilitated before IPE/IWRP is initiated (Status 30), the employment goal may not yet have been determined. However, for cases closed not rehabilitated after IPE is initiated (Status 28), the employment goal should be known and therefore reportable. What would be useful, for post-hoc analysis, would be to use the six categories of work status at closure to record (1) IPE/IWRP goal, (2) provisional work status, and finally, of course, (3) work status at closure. This information, in combination with type of closure and reason for closure, would permit analysis of problems that might be associated with some IPE/IWRP goals. As it is, for state VR, we only have data in the RSA-911 case service reports for successful employment closures. We believe that the overall response rate of 42% from tribal VR programs can be attributed in part to personal contact with the respondents during the National Conference on Native American Rehabilitation convention November 17-20, 2002 in Seattle, Washington. Researchers also employed extensive telephone contact to follow up their request for survey responses. Table 3 summarizes the research results, with data added from Schacht, Wagner, Clay, Vanderbilt, and White (2001, Tables 1 and 2). Table 3 Percentages, VR Work Status at Closure: American Indians and Alaska NativesNCompetitive EmploymentExt.Emp. (workshops) & Sup.Emp.Self-Empl.BEPHome-makerUnpaid Family WorkerState VR FY 199696679.703.504.0000.067.205.50Tribal VR 199830161.790.66 (ExEm) 3.99 (SUPP)12.6212.625.982.33State VR FY 1998195287.703.333.9400.104.610.31Tribal* VR 200357675.990.17 (ExEm) 5.90 (SUPP)8.166.601.910.87*In addition to the data presented, there were 39 unemployed and 122 other cases The summary data from Table 3 provide a basis for the following observations: The number of American Indians and Alaska Natives receiving VR services increased. The number closed rehabilitated in state VR programs doubled in two years. The number of tribal VR programs has increased to a total of 71, of which 69 receive RSA funding (Richard Corbridge, personal communication, August 26, 2003). The percentage of American Indians and Alaska Natives with rehabilitation closures in competitive employment increased by substantial amounts (8% or more) in both state and tribal VR programs. Self-employment outcomes decreased in tribal VR programs, although these placements remain at least twice as common as in state VR programs. State business enterprise programs (BEPs) continue to be negligible in percentages, but BEPs were still significant in tribal programs, even though that percentage dropped by almost half in just two years. Since the RSA-911 manual (Rehabilitation Services Administration, 1995) stated that this category includes home industry, farming, and other enterprises, this category may overlap with others (p. 39). Homemaker and unpaid family worker closures dropped significantly in both state and tribal VR programs in even though they remain legal options. Extended employment (workshops) was at negligible levels on reservations, while supported employment increased and appeared more common on the reservation than elsewhere. However, many of these cases were closed not rehabilitated, which suggests some problems in implementation. The research hypothesis was that American Indian and Alaska Native clients of VR programs that offer culturally relevant interpretations of and culturally relevant alternatives to competitive employment in rural and reservation areas will have higher rates of successful rehabilitation (i.e., Status 26 closure) and will spend less time in Status 20 (ready for employment). That portion of the research hypothesis that could be tested was somewhat supported by state VR data and not supported by tribal VR data. Specifically, testing the hypothesis was challenged by certain data conditions: Information on time spent in Status 20 was not available, so that part of the hypothesis could not be tested. Work status at closure was not recorded by state VR programs (RSA-911) and some tribal VR programs except for cases closed rehabilitated. This meant that a straightforward test of the hypothesis using RSA-911 data could not be done. "Rural and reservation areas" cannot be distinguished from urban areas in RSA-911 data, making that part of the hypothesis untestable. Review of the available data for state VR programs indicated that, as the percentage of cases closed in competitive employment increased, the percentage closed rehabilitated decreased. For state VR, it appears that American Indian-Alaska Native outcomes in alternatives to competitive employment were rarely used, and that this may have negatively impacted successful closures. On the other hand, in tribal VR programs, competitive employment placements seemed to correlate positively with successful rehabilitation closures. However, service outcomes reported by the tribal VR programs included a large "Other" category (n = 122), used by 8 of the 25 programs reporting. Time limitations prevented researchers from researching these responses in enough detail to understand adequately what kinds of outcomes they really represented. What seemed clear was that the diversity of approaches made possible by tribal sovereignty also made the task of data analysis more difficult. The competitive employment outcomes used by tribal VR may in fact represent culturally relevant interpretations of and culturally relevant alternatives to what the mainstream culture considers competitive employment. The significance of this finding for future research is that tribal diversity results in an opportunity for creative approaches to VR that require considerable time for analysis and understanding. It is our impression that this diversity deserves more careful study, both to help programs that are struggling to provide effective rehabilitation and to recognize and publicize innovative solutions to the unique challenges of tribal vocational rehabilitation. Unresolved Questions The tribal VR data raised two questions that should be considered in future research: Several tribal VR programs reported large numbers of supported employment cases closed in Status 28. Do these cases really represent a failure of rehabilitation or was this status assigned, perhaps arbitrarily, for administrative reasons? Several tribal VR programs reported large numbers of other work statuses at closure, all but one closed in Status 28 or Status 30. Do these constitute cases where the employment goal was not yet adequately defined? Recommendations Based on the results of our research, we make the following recommendations: 1. In regard to state VR documentation, when a case is closed not rehabilitated after IPE is initiated (Status 28), and, for example, the client has begun working but has been unable to maintain employment, the work status at closure should be recorded in RSA-911 case service reports, rather than being left blank. These data are important for analyzing and understanding rehabilitation outcomes that are not considered successful. 2. Results from the tribal VR survey suggest that there is still some unfamiliarity with the alternatives to competitive employment, or at least as defined by RSA. Furthermore, the federal emphasis on competitive employment as the gold standard VR outcome may have the effect of discouraging use of the legal alternatives. In order for the tribal VR programs to learn from each other in a helpful way, Consortia of Administrators for Native American Rehabilitation (CANAR) conferences (annual and/or mid-year) should include workshops on alternatives to competitive employment. One-hour sessions on each alternative could focus on (a) the definition of that employment category, (b) services helpful to VR customers who desire that employment goal, (c) funding sources, (d) typical challenges that must be solved, and (e) factors promoting long-term success. Rather than or in addition to lectures and other didactic presentations, we recommend panel discussions in which tribal and state VR professionals can communicate specific challenges and successful strategies. References Anderson, K., & Corbridge, R. (1989). Work, employment and employability in non-competitive occupational environments: A concept paper. Unpublished manuscript. Bureau of Indian Affairs. (1995). Indian service population and labor force estimates, 1995. Washington, DC: U.S. Department of Labor, Bureau of Indian Affairs. Gahungu, A. (2002). Person-centered planning: Can it work in American Indian communities? Journal of Rehabilitation Administration, 26(4), pp. 213-230. LaPlante, M. P. (1988). Data on disability from the National Health Interview Survey, 19831985. Washington, DC: National Institute on Disability and Rehabilitation Research. Martin, W. E., Jr., & Frank, L. (1987). An analysis of the labor market participation of American Indians with implications for rehabilitation. In A study of the special problems and needs of American Indians with handicaps both on and off the reservation, Vol. II, pp. 99145. Flagstaff and Tucson, AZ: Native American Research and Training Center. Olmstead v. L .C. and E. W. (1999). (98-536) 527 U.S. 581. 138 F.3d 893, affirmed in part, vacated in part, and remanded. Retrieved June 24, 2003, from  HYPERLINK "http://supct.law.cornell.edu/supct/html/98-536.ZS.html" http://supct.law.cornell.edu/supct/html/98-536.ZS.html Rehabilitation Services Administration. (1995). Reporting manual for the case service report (RSA-911). State-Federal Program of Vocational Rehabilitation. Washington, DC: Author. Rosen, M., Bussone, A., Dakunchak, P, & Cramp, Jr., J. (1993). Sheltered employment and the second generation workshop. Journal of Rehabilitation, 59(1), 30-34. Schacht, R., & Minkler, S. (1991). The voluntary temporary relocation of rural disabled American Indians: An investigation of factors contributing to vocational outcomes. Flagstaff: Northern Arizona University, Institute for Human Development, American Indian Rehabilitation Research and Training Center. (Available from the American Indian Rehabilitation Research and Training Center, Institute for Human Development, Northern Arizona University, PO Box 5630, Flagstaff, AZ 86011). Schacht, R. M., Wagner, K. D., Clay, J. A., Vanderbilt, R., & White, M. L. (2001). Utilization of IWRP goals other than competitive employment for American Indians with disabilities: A preliminary study. Flagstaff: American Indian Rehabilitation Research and Training Center, Institute for Human Development, Northern Arizona University. (Available from the American Indian Rehabilitation Research and Training Center, Institute for Human Development, Northern Arizona University, PO Box 5630, Flagstaff, AZ 86011. Also, see  HYPERLINK "http://www.nau.edu/ihd/airrtc/catalog" http://www.nau.edu/ihd/airrtc/catalog). Schacht, R. M., White, M. L., & Daugherty, R. (2003). An analysis of disability and employment outcome data for American Indians and Alaska Natives: Final report. Flagstaff: American Indian Rehabilitation Research and Training Center, Institute for Human Development, Northern Arizona University (Available from the American Indian Rehabilitation Research and Training Center, Institute for Human Development, Northern Arizona University, PO Box 5630, Flagstaff, AZ 86011, Also, see  HYPERLINK "http://www.nau.edu/ihd/airrtc/catalog" http://www.nau.edu/ihd/airrtc/catalog). State Vocational Rehabilitation Services Program. (2001). Final Rule, 66 Fed. Reg. 7249-7258 (January 22, 2001) (to be codified at 34 C.F.R. pt. 361). Retrieved June 24, 2003, from  HYPERLINK "http://www.ed.gov/legislation/FedRegister/finrule/2001-1/012201a.html" http://www.ed.gov/legislation/FedRegister/finrule/2001-1/012201a.html Statistical Package for the Social Sciences. (1993). SPSS for Windows [Computer Software and Manuals]. Chicago, IL: SPSS Inc. Streissguth, A. P., LaDue, R. A., & Randels, S. P. (1988). A manual on adolescents and adults with fetal alcohol syndrome with special reference to American Indians. University of Washington, Seattle: Department of Psychiatry and Behavioral Sciences, the Child-Development-Mental Retardation Center, and the Alcoholism and Drug Abuse Institute. Taylor, S. J. (1987). Introduction. In S. J. Taylor, D. Biklen, & J. Knoll (Eds.), Community integration for people with severe disabilities (pp. xv-xx). New York: Teachers College Press. U. S. Census Bureau. (1991). Statistical abstract of the United States: 1991 (111th ed.). Washington, DC: U.S. Government Printing Office. U. S. Census Bureau. (1993). 1990 Census of Population: Social and Economic Characteristics, American Indian and Alaska Native Areas. Washington, DC: U.S. Government Printing Office. U. S. Census Bureau. (2000).  HYPERLINK "javascript:openMetadataBrowser(" Census 2000 Summary File 3 (SF 3) - Sample Data.  HYPERLINK "javascript:openMetadataBrowser(" GCT-P12.Employment Status and Commuting to Work:2000. Retrieved June 24, 2003, from  HYPERLINK "http://factfinder.census.gov/servlet/GCTTable?ds_name=D&geo_id=D&mt_name=DEC_2000_SF3_U_GCTP12_US14&_lang=en" http://factfinder.census.gov/servlet/GCTTable?ds_name=D&geo_id=D&mt_name=DEC_2000_SF3_U_GCTP12_US14&_lang=en U.S. Census Bureau (2002). Current Population Survey - Design and Methodology. Technical Paper 63RV. Washington, D.C.: U.S. Department of Commerce. Retrieved February 19, 2003 from  HYPERLINK "http://www.census.gov/prod/2002pubs/tp63rv.pdf" http://www.census.gov/prod/2002pubs/tp63rv.pdf U. S. Department of Labor. (1991). Dictionary of occupational titles. (4th ed. rev.). Washington, DC: U.S. Employment Service.  HYPERLINK "http://www.access.gpo.gov/nara/cfr/waisidx_02/34cfr369_02.html" Vocational Rehabilitation Service Projects. (2002). 34 C.F.R. 369. Retrieved July 1, 2003, from  HYPERLINK "http://a257.g.akamaitech.net/7/257/2422/14mar20010800/edocket.access.gpo.gov/cfr_2002/julqtr/34cfr369.4.htm" http://a257.g.akamaitech.net/7/257/2422/14mar20010800/edocket.access.gpo.gov/cfr_2002/julqtr/34cfr369.4.htm Vocational Rehabilitation Service Projects for American Indians with Disabilities. (1995). Final Rule, 60 Fed. Reg. 58135-58137. (November 24, 1995) (To be codified at 34 C.F.R. pt. 371.1). Retrieved June 25, 2003 from  HYPERLINK "http://www.ed.gov/legislation/FedRegister/finrule/1995-4/fr24no5b.html" http://www.ed.gov/legislation/FedRegister/finrule/1995-4/fr24no5b.html Will, M. (1987). Supported employment. Rehab Brief, 10(1), p.1. Appendix A Tribal VR Data Collection Instrument Please fill in the following table with the information from your agency for last year: Number of cases closed in StatusWork Status at ClosureStatus 26Status 28Status 30Competitive EmploymentSupported Employment onlyExtended Employment (incl. Sheltered Workshops)Self-employmentState or Tribally managed Business EnterprisesHomemakerUnpaid Family WorkerOther:__________________________ (Please specify) How is last year defined? a. Calendar year 2001 b. Fiscal year (ending _______, 200___) c. Other (Please define:_____________) If the closure categories used by your agency are not the same as the ones listed above, or you have unique interpretations of the categories, please explain:  PAGE 19 :;+8> B yv5F-8+5C%%~))z+//-0.03344444*5+5-:.:z:{:|:󥶠j3Uj2U jUOJQJCJ OJPJQJ6 B*phB*OJQJph5CJOJQJCJKHOJQJ 6@CJ@CJ;@KHOJQJ j@U5@@5CJ ;@OJQJ6$Fd` $d`a$$dha$$da$$F:<\Ŀ~ytoje`]Unz    56Mfghijklqr$:<\*+89>?@AZqrd`dhdh$dha$ $d`a$*+89>?@AZqr < X d } h L " # zupkfa\PQo9uvwx2# < X d } h L " # A B $a$d` $d`a$ A B  1J  .GZhyvw/01234F-.08+5! %~))z+/   e X      )DEFGH\ a b2  1J  .GZhyv8dh^8` 8# $a$ #  # dh # vw/01234F-.08+5dhx1$^`dhx$dha$)dh] $dhxa$ $a$ !8dh^8` 8#  #$a$ #5! %~))z+///////-0.0$dha$ddh1$  & Fdhx1$  & Fdhx hdhx`hdhx1$^` dhx` & Fdhdx[$]///////-0.0/033j578:>}@@FIJNSSXp[[^EaQbhhnpuu|vsnic  +$ =o !$   02 ~  $.0/033j578:>}@@FIJNS$dhx dhx`dhx7$8$H$`dhx dh]^dh]^` $dhxa$dhx1$^` 1$^`|:::::K=L========W@q@s@x@}@@IJNSSSo[p[\\\\\]]EasaQbhhhhjjjjj%k&kuu{n߉=Z OJQJmH  6OJQJ >*OJQJ@j6U>*CJj5OJQJUjOJQJUmH  *OJQJOJQJ0J#j4U6 jUBSSXp[[^EaQbhhnpuu{n $dhxa$dhx dh]^ $dhxa$ dhx`dhx]^$dhxdh]^`dhxu{n܆߉=my%0('ڛ_ax½yvsme]Up            )  K       D*0P s >$܆߉=my%0(' dhx`dhxdhx$dhx1$^`a$dhx1$^`$dh]^a$ ! $dhxa$dhx]^dhx^`Zmy"$%?Cšv&CEFGVWop}~еѵյ׿Ǹ5CJ5PJ5CJ5CJOJPJQJCJ >*OJQJ CJOJQJ6CJOJQJOJQJPJ60J%@ @B*ph5>*B*OJQJphB*OJQJph 5CJPJ5CJ59'ڛ_axšv&Cdhx$dhx1$^`a$dhx1$^` & Fdhx dhx`dhx & Fdhxšv&ChEFGWop~ϵѵ׵ٵݵߵ  #%'(269@CJLNQSUV`cfmpwy{~   6  @  SChE $xx$Ifa$dhxdhx^` $dhxa$dhx EFGWo} $$Ifa$ d$If$Iff$$Ifl4$$  0$4 lalop~ϵѵsjjjjjjjjj $$Ifa$ $$If]a$$Ifx$$IfFi$ ' $    22 4al յֵ׵ٵ۵ܵݵ޵  "$%&'(125689?@BCIKLOPRSTUV_`bceflmopvz{|} *PJCJPJ5PJ 5CJH* j5CJH*CJH* 5CJmH 55CJ jCJH*Pѵ׵ٵݵߵ $Y<<$If]Ya$<<$If w$<<$If]a$$<<$If]a$ <<$IfFf7 $$If]a$ $$If]a$ $$Ifa$ #%'(269@CJLNQ˸$Y<<$If]Ya$<<$If w$<<$If]a$ <<$IfFf@: $<<$Ifa$$<<$If]a$$<<$Ifa$ )QSUV`cfmpwy{~Ffj>$<<$Ifa$ )$Y<<$If]Ya$<<$If w$<<$If]a$$<<$If]a$ <<$IfFfU< $<<$Ifa$¶öɶʶ̶ͶӶԶնֶ׶ضٶ۶ܶݶ޶߶  "#)*+-./023456?@BCE5PJ5CJPJ`öʶͶԶֶضڶܶ޶߶  #*,/1356@CFMPWY\_acd{|6bc!4#TU]  _öʶͶ <<$IfFf@ $<<$Ifa$$<<$Ifa$ )$Y<<$If]Ya$<<$If w$<<$If]a$$<<$If]a$ͶԶֶضڶܶ޶߶ˬ$Y<<$If]Ya$<<$If w$<<$If]a$ <<$IfFfB $<<$Ifa$$<<$If]a$$<<$Ifa$ )  #*,/1356@FfF$<<$Ifa$ )$Y<<$If]Ya$<<$If w$<<$If]a$$<<$If]a$ <<$IfFfD $<<$Ifa$@CFMPWY\_acd{|0 <<$IfFfH $<<$Ifa$$<<$Ifa$ )$Y<<$If]Ya$<<$If w$<<$If]a$$<<$If]a$EFLMOPVWXZ[]^_`bcd{йٹ MN`a  !4U/1AZ\p$;<P CJOJQJ5CJOJQJ 5OJQJ@ >*OJQJ juMUj{"C UV jUCJ @B*ph6 jH*5CJPJH6bc`^FfJ$<<$If]a$ $<<$Ifa$$Y<<$If]Ya$<<$If wc!4#TU]$<<$7$8$H$Ifa$8$$If4""  "a $xx$Ifa$dhxdhxd dhx`#&+/1ADJLQSWZ\psz|$&-/359;<PRY[_aegitvz} csssa$<<$7$8$H$Ifa$$<<$7$8$H$Ifa$<<$7$8$H$Ifj$$If4F` "e  "    ab<SAAAAA$<<$7$8$H$Ifa$<<$7$8$H$If$$If4r` "e <<< 2"a$<<$7$8$H$Ifa$$$If4ִ` :v"e  F"    a#&+/$<<$7$8$H$Ifa$<<$7$8$H$If/1ADC4"$<<$7$8$H$Ifa$<<$7$8$H$If$$Ifִ` :v"e   "    aDJLQSWZ$<<$7$8$H$Ifa$Z\psC4"$<<$7$8$H$Ifa$<<$7$8$H$If$$Ifִ` :v"e   "    asz|$<<$7$8$H$Ifa$C4"$<<$7$8$H$Ifa$<<$7$8$H$If$$Ifִ` :v"e   "    a$<<$7$8$H$Ifa$C4"$<<$7$8$H$Ifa$<<$7$8$H$If$$Ifִ` :v"e   "    a$<<$7$8$H$Ifa$$&Cl4"$<<$7$8$H$Ifa$<<$7$8$H$If$$Ifִ` :v"e   "    a&-/359;$<<$7$8$H$Ifa$;<PRC4"$<<$7$8$H$Ifa$<<$7$8$H$If$$Ifִ` :v"e   "    aRY[_aeg$<<$7$8$H$Ifa$Pgit  -y~89}~ 23Cyz ʾB*OJQJph@mH CJ @B*ph56;@CJOJQJ5;@CJOJQJ;@CJOJQJ j`Uj{"C UV jU5@6@ 0J"<@@5 CJOJQJ;gitvC4"$<<$7$8$H$Ifa$<<$7$8$H$If$$Ifִ` :v"e   "    avz}$<<$7$8$H$Ifa$C4"$<<$7$8$H$Ifa$<<$7$8$H$If$$Ifִ` :v"e   "    a$<<$7$8$H$Ifa$ OR-9.NY]h}~ "(-23CGMejotyz_       VC4"$<<$7$8$H$Ifa$<<$7$8$H$If$$Ifִ` :v"e   "    a$<<$7$8$H$Ifa$CA:5ddhx$$Ifִ` :v"e   "    aOR-9 $xx$Ifa$dh $dh`a$dh dhx` & Fdhx  & Fdhxdhxd`.NY]h}~o$d<<$If`a$Ff_xd<<$If`f$$Ifl4D%%  0%4 la $d<<$If`a$d<<$If`$d<<$If`a$ $$Iflִv\ Bm D%Tuq  0%    4 la$d<<$If`a$$d<<$If`a$d<<$If` $$Iflִv\ Bm D%Tuq  0%    4 la "(-2$d<<$If`a$$d<<$If`a$d<<$If`23$$Iflִv\ Bm D%Tuq  0%    4 la3CGMejoty$d<<$If`a$$d<<$If`a$d<<$If`yz$$Iflִv\ Bm D%Tuq  0%    4 laz_ FA"dhx dhx` & Fdhdx[$]dhdx[$]`  & F dhx  & F dhx & F8dhx1$^8 8dhx`d` FA" 1%k6|4 h(od  - p q r ~      5 ? I S T k l m n o                      $    PgAD1%M&k \^gN4IX346_k?K0J!jb{U0J!>*B*phjzU jU0J#mH  6OJQJ;@CJOJQJ @OJQJ CJOJQJ@OJPJQJ@6 B*phOJQJ@ 1%k6hdhx^h` `0dhx^`0dhxhdhx^h`$d hdhx`hdhx  & F dhxdhx|4 h(od  - p q r $d dhx`0dhx7$8$H$^`00dhx^`0hdhx^h`dhx0dhxx^`0% 01ABCI(Gvo WXyzbcVWX Z[\jU0J!>*j4U0J!>*B*phjUj2Uj~~UmH 0J!>*B*phj~}U0J!jp|U jU65@<=>     * + - W f p r s ~   T Q b f g                 ü0J&mH0J& j0J&U >*OJQJOJQJCJ5CJ CJOJQJ5PJOJQJ6jDB*Uph0J!>*B*phjB*Uph B*phjB*Uph,r ~      5 ? I S F$$Ifl40H(#4 la $$Ifa$$If$a$ S T k l m n lx$Ifm$$Ifl\H(#4 lan o            x||||Po x$If !x$If x$If !m$$Ifl\H(#4 la             |||8o x$If ! x$If !m$$Ifl\H(#4 lax$If         + , - . / P b c d e f g                           )   + , - . / P b c d e f g d~dh$Ifm$$Ifl\H(#4 lax$Ifg                      $h]ha$h]h $dh dh !dh@&$1hP/ =!"#$%*001hP/ =!"#$%'01hP/ =!"#$%2Dd   C A..\..\..\..\..\..\..\Documents and Settings\lar\My Documents\logos\mtnbludk.tif"b1]E 0Mm1Dcn1]E 0MmPNG  IHDR{sRGB pHYs.#.#x?v1#IDATx^ Uŕ1((*P!P h'`0UT >1hD:jn؈ H؉1A(6@+-Zj=:kqw=Uj֬t HHH*IyT6 q) $@$@$Pj"(3  Ov^;gKLHHHଋ~uJҪL   "PAy 5.eHH ǽ5R0  r-=p̨z%}\=d\X|  (w-Ѹ* ̃HHq)$@$@$Pj"(3  ƥ @qDxCVyp&WoRa7B1DHTbMuԇĿ|W=MHF NPAƜym8]n#_1uxI]Z%9Fen|n$EW{vՄD! L͓=CJJSVcUAqEԸ1o,E'f)Oq)@Clu'Q<Q*VeLReJ=U_$Ԍ!rצn76 hlǣʋnWzCHUX0uej慑YxQTL3wGW9`'r Wқb76}FSy$M0*L,7|OF[pDj܂4\J_883B.*!"<EZtOA87[iQ,RY0ʫY&v¶Ը@.o@E,^y+tqC/$㬎m~=@zT[MڷQY ߫ob,>5n?^y  [.K[)p"8߶ѥYG-|yڷ0QJxH{x5r^?'pMMq+tx艼 Jn*R_'Ŏz0+ytv‰_k&Yʾ7ߓk& ۵n\,Xw5o,P qƩ7cU+̜OMC>:2RX0~ӵ0,E]<}ųԨR^Qu]%`/7͞rbOUșپ9Q-Ya)||C K[sVz7T{.l-Vةȍ ^r$'Kks^*ǂI^\3s?KმsV"5TOa|=OxSGM⁁`So-X~-{M3JٝS\lW9 2󂩖pRT K!cU9RBQfe/znS6R\'z73s.##wDP9IsV綇R ,OI5ʋ^mE ϋ7UCV˹)X`93;,gzzsSR8gIU!Q=oH4iDjܤJz㫖M|ojufQ\xK^(j|$ m*w5'JSp[ JykU IM-k*}`x6|gK6Ӌ֪DMWUwEl&||yʋn4EneB9EHx6V65n L(9Ƴrj|' S#U]7Oͪ oZAԾ\M:W0ɩq+twU0Ux QQ.ٟUԸlU\E-×,EB&^һkVQTZZI8wxGt[7O)/Q<,gcWIZQwW|,fuM8Ⴠ C(j&0a&Zpn*WUԸEWDa٧o]cZ$ K vˣ+j~SYxxZUERPX'קkֹHV^I F&B$# j=O֛K35n*8-{mM$ @<$@5y~q[TWDJc Rp>PW.Ը>,|C E$:-!4˦ʌF$P%$ޝ9T.Ը{ųqU2P$@<[ضeGn !j܆Fh`- ^^c<% , @z \Z+ e1F̘HW-͵\+`\nґ @?s{Z&,Ji"w IH`-jwi [wZO>c! N[Eֲ-(`;1 %uzwVm5q+7ec @%8/jת4nRQ5X3C$@$X5Wmq+qEO6V_b$@$H~z5n \( F$@!`[ZԸy]EHOjҸ_7wǢU2^5SSe\  ikl~lP%9ƽ5!&X1f.$@$@`Pˆw" .]6N:@䬋~u ~Mݬصd|#Y @-04jn 5ni# )Ը5՜ @i q*- HHBthwطC&:d Ð @U f}ǣqiUs aIH "@[hfC$@$Pq\X}  Pِ 9V9b|SSUxI`"!1L} C}VkgMe C0 cR$Y Ny|!kf|o[1aWf##Rԏ^`AgVoB@Z7 >nzB]fk|O [jӤ}~[^l_y߯ԾEa?U|}dsW_ݱ B;w_/3u 7o{zrcG,لyiQK^|qv%!U npV&\銸Cg/O` 'm#+*5|NΐHRұ߫E.s.+j+y%ZFy8 JNHb߶ ;>͎RHԃRRSzNuoC,>|BK.M>Fҕlѽ ˂F檫~p׼Wf3c\$̝xd Կ=_r)/٦-#}#0xߤ=6C \C;1vr7bP^ HIB7:^_T]:{C:8 Oe={5H IЩ'Ccm;6Go݆:jeGZXbmh"](d+I' % |"{ڕa>a+WVxj,U~tiS qH + %9Tzx*oOɪPo\R"DP_y7/M#.QҎ\mۻi睻e҃y؊U^Th~is4(̛wg5aY~:LRP[zj*: Q$s*76aCI^\Ӈnոеw\5@ y7Zz?JtR`4GVT;̌*|>xnGGmv_ƟR_,zAo`2*c4Yu9\7v t<_>& yDȢQUBQR0R3=܇׍8bumkզYM'.|kǫz|֒DVA $D#믜tמw8n8f͚Ń"eu$/$ņO׀| ϣ6s#-]vf7tdp #B؆t8n*VT F\Ҹ T JXFv;Xd5KKGt7Fpӥ"Jzp?^Oc7sm f*2?02R~Z y.Wɿ::y8trQF@ s-V`N!%$Qm,GB~9h]HupϓyFE >5HʩMէgY;3wG6fQ ۇ?iaB}7JrՏ9"M:@{#g+nY?BI_F˷FIz-K;/0¤P2 QO{+%n2k|We1~tx`F[\ °Q$]t>|8%G~]Y9'72g0QF% RFMm4.rώŞXiH2UTUcY)=mf{ U0 o8S6` cg *XfWP2uvL #7N nsj1:X P}YŪlU0Ez+qsL 禾@e14^64ޢti쮫O?z0[LslM&k cXr9`k䨯A񕑈?,| ƹJ%gzR?cD1m&)G99ˇM``!_n8w1E˞b}΋[. ԭX/: 4jXGgic;ܔN bT1K+byiuCg be(PN-g<- #LCgMox>s}=YaMבaFD]ؗ,am'~Qel׸2G wUO[ ?AX (oH.gP~lV^d +ݤCE4f/LLY6йqW_J0*B\SQ_ZOȏ%Uee'OudN;OLVϛDk,޲Q:MVCLS#1- @eaggBd"EK¦5 32kXj[Xͱr)g^CC^eY-ƒ!uh5g[wMHkݱE_mDeٽQN' !h m-z87؍-k94vӗ4 QG097b %ŀ8 tqy'ػMer5CiKCR7 Ϟ}ʨV_YHǶBgԲ!P@ ^m%/?{%J7/gTXʷ2kۣzw! .3[[r;׸Uk%Wwۇa=S|X-\(${rJW .^2kIghu u46!J.cЊYB^ 6}K5-rW2@an 4׈3z瀦y'#-Y3Q]{ BmUQ0w_:hC>Tu60N W + \٧Q?]fèvluT}DR 9zEӁk,>;lV9 23しqtbht{v&) P*Oh"1 ('VFtc#8~ۍ QֹX*'AݩS/se5.r]҇O@SZcPcZx韆:ᨙ^9L= &ͽ%AAM%shBT^[7ocZNG{<0qTq+ \{jX\==EPޟ}Sǵk atU NCVE}?tjw2.bJtИhz/V86f3Q҂;R BmZ^FJ̼5+b?l[s׸tJ7::>(8/y?! \'2nĖ;&'BbM_w=Ch,/_ )0I8VUF7 %]S~vind{gr@E_b4dft j(bK,pG_R,/,!?^WZSjD3*q?o{Q!-8-wq&+l`瘏X+[W{vL$hGtgqKl5>=44sOv16zw*`Ldp ]L0+ 9rE5 \ >IsΚVNW[_Tmj!(⡋Gw8`ׯD-=ZJC2*]9aGMo$?ie.Nj W+e/L3f'Řh(!b"ޘcQ!7 c=c?JW@8QQE4h~řD0Ee;A2hGȤoLbXT5y +uVjnx-y0jg;L(4 @x҃܍ ᣔ.LS7LtWgp\^F~콌́ST% 7{#gTXA8e-vLH8Q%r GA'-4Ԩ ?ƙfEI \MtR'^NU @yJ)6OĩtYJ]27 ,:GFÔNh/Օ~:kS4urD FX_  )6%_0}xRᡰD$E !},^QF׃9FcвQ%1PO%0e'Teؾ䃺*栉N[Sza_ 5tSw4#%4"BHV9ITT,c kL3.pta-co P=#/`K5 Wb;UK? H4 '— S? 4}, ^!cIg|hL{;Kg 4eQbH(lT`'!55% \ /O`0aB6I≰Bv\#9)lž_ Xl!^x!'ģʿ=%c39hWǓ1zc"M܅6Duyү $}ܴPJ^?8"$ ]*?v{[y1$)]!( 0ݢɥs#~[I4 Utp"}п$QMc[d_a a$[x8cJ`i)!$P_\wpz>a0LV Ouj6L5'{|!:%ґ<|o%ly¬9"."`m0FyGë3ϗ)h&PxgT aةl[ y*CAl(Rd006mkhd֍ؙ/bķXEaryxA;7d2u.=nߧ\7E)VPNR #=E (` 6J8뜵7<ߓs1^A+ZX&F㨑S牍Brf~^8vc ӗ4.bkEdžҍUNzCns]h` c$҃4P2ؓkCz,tਅ2s]梱YQ}5n>6~hXpTO ?p&R d!s1r@jjACl(}_F:`b9h=#y@BNBPM(mdۏ=F!=T80*h./_keqHr=kF,76\$w-vbh QTuza 0 9do8`@@1S>] ζh`1M\n/]6!L( y7z g v:b~M,#2ORv4 w}@d00$ NwE>CVNb8!A3ێԯUAe'6z1TwD>l޶f! {D%M"0  i>Hդ芏H3Rp֠jD*C+Q<N{(N4:MF^RԅK7[L=1Vpp:8xq15xUC]D 6 Hcogvisby/g ٺ YZuyOPYŒ)ƌY8GE&ƶ=KyB_x$cTn EYGJ7nH=I]/e,m!4~+i?ڡ_㠂\BĦVl~1Q,`TFKZS3KI $81V.)(!!!:UQt'jz-3Q($@ Ao v#/ſ3l@{}/7ԫzݩ!DOwT,CR'[<0$gxIFcjO ++F?E͡cA&Q*@?>:Z KP;