New Guidance for State VR Agencies on Using Recovery & Reinvestment Act to Pay for Internships

Can a State VR agency use VR ARRA funds to pay for internships for its consumers as a necessary service to facilitate permanent employment for those individuals?
Under Section 103(a) of the Rehabilitation Act and 34 CFR 361.48, a VR service is any VR service described in an individualized plan for employment (IPE) "necessary" to assist an individual with a disability to achieve an employment outcome. Both the statute & implementing regulations provide a broad, although not exhaustive, list of VR services, including training.

Thus, a State VR agency could determine that a paid internship is "necessary" as a VR service in order for an individual to achieve an employment outcome. For example, a VR agency could determine that the paid internship is necessary to train the individual on how to perform a particular job skill or to learn about the culture of day-to-day employment if that individual has never held long-term employment. The paid internship would be a VR service under the Title I VR program and would be an allowable expenditure with VR ARRA funds. However, the VR agency must make this determination on a case-by-case basis & should document the determination in the individual's IPE and case file. For federal reporting purposes, State VR agencies should report paid internships, when provided as a VR service, as "on-the-job training."
SOURCE: GUIDANCE Funds for Title I, Part B of the Rehabilitation Act of 1973, as amended Made Available Under the American Recovery and Reinvestment Act of 2009. Available online at www.ed.gov/policy/gen/leg/recovery/guidance/vr.doc#_Toc234815041