Dear Select County and District Superintendents, Special Education Local Plan Area Directors, Special Education Administrators at County Offices, Special Education Program Directors, Nonpublic School Directors, and Workability Program Coordinators:

Workability I 2021–22 Program Guidance

The purpose of this letter is to provide 2021–22 program guidance to support local educational agencies (LEAs) that continue to be impacted by COVID-19. This is specific to the Workability I (WAI) state funded grant program managed by the California Department of Education (CDE), Special Education Division (SED). The CDE provides secondary transition services through the WAI program and 263 LEAs receive WAI grant funds to participate in the program annually.

In response to the closure of school sites, the CDE will provide WAI grantees the flexibility needed to meet the requirements of the program for students with disabilities placed in work experience programs during these unprecedented times. Three areas of concern are addressed in this letter: Temporary waiver of three grant conditions grantees are placed in if specific program criteria are not met for the fiscal year (FY).

WAI Staffing Shortages and Work Experience Placements Opportunities

Due to the concern that many school sites were not able to consistently place students in remote and on campus work experience placement opportunities by the fall of 2021, due to staffing shortages and varying health and safety measures across the state, the CDE, SED, conducted a brief statewide survey of WAI grantees to collect a list of whether WAI grantees were able to provide students with subsidized or unsubsidized placements through their WAI grant. This survey received 254 responses accounting for 96.6 percent of all WAI grantees.

The survey revealed that almost a quarter of WAI grantees (24.4 percent of respondents) were greatly impacted by staffing shortages effecting their grant’s ability to serve students. The majority of WAI grantees (54.7 percent of respondents) reported being impacted by staffing shortages impacting their grant’s capacity to serve students enrolled in the WAI program.

Regarding WAI work experience placements, a significant portion of WAI grantees (42.9 percent of respondents) were very limited in their ability to provide subsidized placements, with another 9.4 percent of respondents indicating they could not place students in subsidized placement opportunities. The responses for WAI unsubsidized placements indicated that a significant portion of WAI grantees (42.5 percent of respondents) were very limited in their ability to provide subsidized placements, with another 10.6 percent of respondents indicating they could not place students in unsubsidized placement opportunities.

The option of paid community-based work experience is an integral component of the WAI grant, and grantees receive funding to be specifically allocated for student wages per California Education Code (EC) Section 56471(e)(6). The employment portion of transition services under the Individuals with Disabilities Education Act helps facilitate movement towards competitive integrated employment and should be provided in the Least Restrictive Environment. The LEAs placing students in WAI work-based experiences should be mindful of the employer location, and ensure opportunities for interaction with non-disabled peers and customers are provided. This applies to both subsidized and unsubsidized work experience placements.

2021–22 Grant Conditions

To address the concern with WAI grantees being placed on fiscal grant conditions for 2021–22, the CDE will waive three grant conditions so that WAI grantees do not risk being penalized for lack of work experience placement opportunities due to health and safety related concerns. This waiver is offered to provide flexibility to WAI grantees without undermining the basic intent of the law or the California EC sections 56470–56474 which govern the WAI program.

As part of waiving the grant conditions, WAI grantees shall assure that the use of WAI grant funds are expended in accordance with the provisions of all other applicable statutes, regulations, approved program applications, plans, and budgets, and legal assurances which are not subject to this waiver to continue to provide the WAI program.

The following conditions are temporarily waived:

• All approved project funds must be expended within the designated award period.
  • The WAI FY 2021–22 amendment period opens April 1, 2022, and will remain open for 45 days. Grantees who do not anticipate utilizing all of their funds should submit an amendment during this period of time.
• Serving all students for which funding was received.
  • If grantees are unable to serve students for which funding was received, they will submit expenditures for the actual amount of funding used.
• Placement into employment at least 15 percent of the students funded to serve.

The WAI grantees receiving state grant funds are required per EC Section 41010 to follow the definitions, instructions, and procedures in the California School Accounting Manual (CSAM). Operating agencies and districts are mandated to follow CSAM guidelines for conformity with generally accepted accounting principles, which are essential for consistency and comparability in financial reporting. The CSAM is to be used for classifying, developing, and recording all revenues and expenditures for the WAI program.

Please refer to the CSAM website to view the object classification codes. It is the responsibility of WAI grantees to review the complete listing of object classification codes in the CSAM and to check for updates to this document.

If you have additional questions on the above information, please contact Nick Wavrin, Education Programs Consultant by email at NWavrin@cde.ca.gov.

Sincerely,
Heather Calomese, Director
Special Education Division
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