[REVISED: 10/1/15]

1. Definitions.
   
   1. Job placement services include, but are not limited to, direct placement, referral to employers, job development, job search assistance (i.e., interviewing techniques, filling out a job application, resume writing, planning the job search, disclosure of disability to employer, etc.), job retention skills training, consulting and advising on job adjustment and VR client-employer conflicts, employer services (i.e., task analysis and job restructuring, assistance with Affirmative Action programs and projects), employer incentives, and other services needed to place a job-ready individual in employment. Guidance, instruction, and assistance may be provided on a one-to-one or group basis as appropriate. (For definition of employment outcome, see Chapter 11, CLOSURE, Policy 1).
      
      
      Note: This is distinct from counseling and guidance concerning employment options and the employment process that the counselor provides throughout the vocational rehabilitation process.
      
      
   2. Direct placement means the counselor has documentation in the case file that DRS provided placement services and communicated with the employer before the VR client entered employment.
      
      
2. Provided Under Employment Plan.
   All VR clients determined eligible for the Vocational Rehabilitation program (and not in Delayed status if DRS is on Order Of Selection) are eligible for job placement services needed to achieve an employment outcome. Job placement services, if any, should be planned in the Employment Plan based on a needs assessment of the specific needs of the VR client(per 2001 Federal Regulation 34 CFR § 361.46 and 2001 Federal Regulation 34 CFR § 361.53).
   
   
3. Integrated setting.
   The job placement must be in an integrated setting and consistent with the VR client strengths, resources, priorities, concerns, abilities, capabilities, interests, and informed choice (per 2001 Federal Regulation 34 CFR § 361.56).  
   
   
4. Release.
   The counselor must have the VR client informed written consent (i.e., signed RS-3e form in the case file) to share personal information with a potential employer. Consent may be for the category of “potential employers” or for specifically named potential employers.

   
   Guidance: The counselor (and job placement specialist) must be aware of DRS confidentiality policies in discussions with employers and potential employers. As the employer only needs to know whether the individual has any functional limitations that will impact on job tasks, the counselor must limit the discussion to any potential functional limitations that will impact on the individual’s ability to perform the job tasks or functions identified by the employer. This discussion may also include identifying reasonable accommodations that have been provided or could be provided. An employer cannot ask whether the job applicant is a person with a disability nor ask about the nature (i.e., whether the loss of a leg is indicative of an underlying disease or impairment) or severity of the disability. However, the employer may make pre-employment inquiry into a job applicant’s ability to perform job-related tasks or functions or, if there is a known disability, ask the job applicant to demonstrate or explain how, with or without reasonable accommodation, the individual would perform job-related functions (P.L. 101-336 Americans with Disabilities Act of 1990 and P.L. 102-569 Rehabilitation Act of 1973 as amended in 1993 Title V Section 504; federal technical assistance RSA-TAC-FY-93-01 issued October 2, 1992).
   

5. Schedule A.
   For eligibility criteria for Schedule A appointments to federal agencies, see Chapter 9.2, APPOINTMENTS, Policy 2.
   
   
6. Postal appointments. 
   For eligibility criteria for competitive and non-competitive United States Postal placement, see Chapter 9.2, APPOINTMENTS, Policy 1.
   
   
7. Minimum wage.
   The counselor may be responsible for assisting the employer to determine whether an exemption from the Fair Labor Standards Act minimum wage requirement is needed according to the individual’s functional level. Contact the U.S. Department of Labor Richmond Office for criteria and required forms.

   Note: If the service provider is an Employment Services Organization (ESO), this is usually the ESO’s responsibility.
   
   

8. Disallowed services.
   
   1. DRS staff shall request payment only for those services that are part of the individual’s Employment Plan (2001 Federal Regulation 34 CFR § 361.45). DRS staff shall not request payment for service unless the service is authorized in writing by the counselor before the service is provided or before the individual incurs the expense (per 2001 Federal Regulation 34 CFR § 361.50).
      
      
   2. Monetary loans to individuals are strictly prohibited by agency mandate.  
      
      
   3. DRS shall not pay bad debts, liens, or judgments (e.g., outstanding bills); entertainment expenses, including costs of amusements and social activities; fines, court costs, and similar expenses; or the consumer’s interest payments (e.g., interest portion of payment for consumer loan) (per federal OMB Circular A-87 revised May 10, 2004).
      
      
9. Consumer responsibilities.
   The VR client must meet all requirements in Section B of this policy.
   
   
10. Financial participation.
    Job placement services are exempt from consumer financial participation policy (per 2001 Federal Regulation 34 CFR § 361.54).
    
    
11. Comparable benefits. 
    Job placement services are exempt from search for comparable benefits (per 2001 Federal Regulation 34 CFR § 361.53).
    
    
12. Purchasing. 
    Job placement services are subject to DRS established purchasing policies and procedures. See Chapter 14.1, PURCHASING, Policy 1.