Roadmap for Change: Roadmap for Change

Roadmap for Change: Maine's Response to the Olmstead Decision
a report prepared by Maine’s Work Group for Community-Based Living

Roadmap for Change

Where We Are: Building on Our Strengths

Like other states, historically, Maine segregated people with disabilities into institutional settings. Services for people with mental illness were offered primarily through two state-operated mental health institutions, the Augusta Mental Health Institute (AMHI) and the Bangor Mental Health Institute (BMHI). Services for persons with mental retardation and developmental disabilities were offered at another state-operated institution, Pineland in Pownal. Many people with physical disabilities had no alternative but to live in nursing facilities because needed services were not available in the community. In addition, many children were denied equal access to an education because schools did not provide the services needed. Children were entering adulthood unprepared to support and take care of themselves, forced to continue a life of dependency.

Over the last several decades, Maine policymakers and public have become more aware of discrimination against people with disabilities. In addition to effective advocacy, public outrage over abuses, class action law suits, sweeping federal legislation, forward looking leadership in Maine government, and budgetary concerns have helped to drive a shift away from institutionalization. Some of the pivotal events influencing Maine’s services include:

The passage of state legislation, in 1973, and subsequent federal legislation, in 1975, and again in 1997, guaranteeing all children a “free appropriate public education” in the “least restrictive environment.”
Consent decrees in 1975 and 1994 that led to the eventual closing of Pineland in 1996.
A class action lawsuit filed in 1988 on behalf of individuals who had been or who would be admitted to AMHI. This lawsuit resulted in a judicially enforceable settlement agreement for developing community services.
A budget crunch in the mid-nineties forcing the state government to strictly limit access to nursing facility services.

As a result of these events, and other pressures, Maine has made significant progress in minimizing segregation and meeting the needs of people with disabilities. For example, Pineland, which at one time could serve 1500 residents, is now closed. Maine is one of only nine states in the country that has closed all state-operated institutions for persons with mental retardation and developmental disability. In 1998, Maine was one of only 19 states providing 70 percent or more of residential services in settings for six or fewer persons. (footnote 6) In 1998, Maine served over 1,300 people under the MaineCare program’s home- and community-based waiver for persons with mental retardation.

AMHI and BMHI in 1958 had an average daily census of 3,400. Consistent with the deinstitutionalization trend in other states, forty years later, the average daily census is 180. (footnote 7) As the inpatient count has decreased, Maine has worked to build the community supports needed.

In 1994, the State tightened the medical eligibility for nursing homes so that only people with the greatest need would be admitted. Over the next several years, Maine reprogrammed state and federal funding to build and support home- and community- services. Between 1995 and 1999, Maine decreased the number of people residing in nursing facilities by 13%, while nearly doubling the number of adults receiving MaineCare and state-funded long-term care services at home. In FY 2001, MaineCare supported 681 adults ages 18 through 64 in nursing facilities. (footnote 8)

In addition, inter-departmental cooperation has made it possible for Maine to significantly reduce the rate of out-of-state placements for children and increase the number of children returning to the state. Between January 1999 and September 2002, the number of children funded by BDS and DHS’ Bureau of Children and Family Services in out-of-state placements decreased by 62%, from 205 to 78. (footnote 9) This progress is expected to continue.

Maine has also increased its vocational rehabilitation services. Over the past ten years, the number of successful case closures has increased, with a shift away from sheltered workshop settings and toward more integrated employment settings. Between 1990 and 1999, the number of successful case closings increased from 350 to over 1,000 per year. In the same period, successful case closings in a sheltered workshop setting dropped from five-percent of all successful closings to less than one percent. The Department of Labor plans to reduce the reliance upon sheltered workshop placements even further.

Thus, as we have noted, Maine has been moving in the direction of community integration for many years. As a result, we are ahead of many states in minimizing reliance on institutions for persons with disabilities. As Maine has transitioned from institutional services, it has built a broad array of community services.

Much of Maine’s progress can be attributed to strong advocates who have been passionate in their commitment to civil rights and access to services for persons with disabilities. Through numerous organizations and initiatives, we continue to build an advocacy community of strong, articulate consumer and family representatives. We have numerous advisory boards, committees, and councils all working toward addressing the needs of persons with disabilities.

We also give credit to our leaders. Many of our leaders have a personal commitment to community integration. Our state government is small, making access to and collaboration among leaders easier. We have a Legislature that listens to the people it represents and responds to their needs. And we are fortunate to live in a state that cares about people, with a supportive press community that highlights disability issues.

The Road Left to Travel

While much progress has been made, when one compares the general well-being of persons with disabilities with the well-being of persons without disabilities, it is easy to see that there is a long way to go before our vision of equality and integration is achieved. Persons with disabilities are more likely to live in poverty, more likely to be unemployed, and more likely to feel excluded from our society than persons without disabilities. Below we review some of the national and state data that document our continued need to address the barriers to community integration and equality.

Income and Employment

Nationally, almost 30% of persons with a severe disability live below poverty, compared to 8% of persons without a disability. (footnote 10)
For working aged adults, persons with disabilities are much less likely to be employed (either full-time or part-time) than people without disabilities (32% versus 81% respectively). (footnote 11)
When people with disabilities are employed, they earn on average only 67% as much as people without disabilities. (footnote 12)
Supplemental Security Income (SSI), an income-support program for persons with disabilities, currently pays $545 ($6540 annually) for an eligible individual and $817 ($9804 annually) for an eligible couple. (footnote 13) The individual SSI benefits (including a state supplement of $10) total 22.5% of the one-person median income in Maine. (footnote 14)
Social Security Disability Insurance (SSDI) is an income-support program available to persons who have worked and paid into Social Security (or their dependents). Benefits vary with contribution. If a 40-year old earning $45,000 annually becomes disabled, annual SSDI benefits would be an estimated $17,300. (footnote 15)
Nationally, 36% of employed people with disabilities say they have encountered some form of discrimination in the workplace due to their disabilities. Of people who have experienced discrimination, 51% say they have been refused a job due to their disabilities. Others say they have been denied a workplace accommodation (40%), given less responsibility than co-workers (32%), paid less than other workers with similar skills in similar jobs (29%), refused a job promotion (28%), and refused a job interview (22%). (footnote 16)

Housing

One study found that over 87 percent of a monthly SSI benefit is required to rent a one-bedroom housing unit in Maine. (footnote 17)
For some communities in Maine, rent for a one-bedroom would consume all or more than all of a person’s SSI benefit. (footnote 18)
Thirty-five percent (35%) of subsidized households headed by a non-elderly adult, include a head of household or spouse with a disability. For the elderly, the rate is 17%. (footnote 19)
Forty-five percent of homeless people in Maine have a mental illness; 60% have an addiction disorder. (footnote 20)
Homelessness for persons with addiction disorders has increased since a change in federal law in 1996, denying SSI and SSDI (and with it health coverage) to people whose addiction is considered to be the cause of their disability status. Two-thirds of those who were paying for their own housing and who lost benefits because of this change went on to lose their housing as well. (footnote 21)
Less than 5% of people with disabilities who receive SSI own their own homes. (footnote 22)

Transportation

Persons with disabilities are three times as likely to have a problem with inadequate transportation, than persons without disabilities (30% versus 10%). (footnote 23)
Twenty-nine percent of non-working adults with disabilities who report difficulty looking for work said that the lack of transportation is a barrier to employment. (footnote 24)

Education

Nationally, 22% of persons with disabilities fail to complete high school, compared to 9% of those without disabilities. (footnote 25) Graduation rates have improved over the last 15 years. In 1986, 39% of people with disabilities failed to complete high school.
The likelihood of graduating depends on the nature of the disability. National data show that students with sensory impairments are most likely to graduate (73 %), while about two-thirds of students with orthopedic impairments, mental retardation, multiple disabilities, and learning disabilities graduate. (footnote 26) Children with serious emotional disabilities are least likely to graduate (35%).
People with disabilities are less likely to graduate from college than people without disabilities (12% versus 23%). (footnote 27) Data also show that persons with disabilities are less likely to enroll in a 4-year college than their counterparts without disabilities (42% versus 62%). (footnote 28)
Students in special education account for 31% of the incidents resulting in removal from school. Of these students, 47% had behavioral impairments and, of those, 51% were referred to alternative placements. (footnote 29)

Isolation and Inclusion

People with a disability are less likely to socialize with friends, relatives or neighbors and are less likely to go out to a restaurant, go shopping, or go to a movie. (footnote 30)
For elders, social isolation and loneliness, often resulting from living alone, are important contributors to the high rate of suicide. (footnote 31)
People with a disability are also less likely to vote, sometimes prevented by inaccessible polling places. (footnote 32)
A person with a disability is twice as likely to live alone as a person without a disability. (footnote 33)
Children and adolescents with disabilities are much more likely to feel sad, unhappy, or depressed. (footnote 34) Adults with disabilities are much more likely to report feelings such as sadness, unhappiness, or depression that prevent them from being active. (footnote 35)
Compared to persons without disabilities, persons with disabilities tend to be less satisfied with their lives and feel excluded. Thirty-three percent are very satisfied with life in general, compared with 61% for persons without disabilities. (footnote 36) Forty-eight percent of people with disabilities say they feel left out of things in their communities, compared to 32% for people without disabilities. (footnote 37)

Families

A needs assessment conducted in Maine suggests that parents caring for a child with a disability experience limited or reduced work because of their caregiving responsibilities. Three-fourths of respondents reported one or more limitations on employment as a result of meeting the needs of a family member, including limited job choice and giving up a paying job. (footnote 38)
A study found that women who provided 100 or more hours of assistance to their elderly parents in the past 12 months cut back on work by about 459 hours per year. (footnote 39) This reduction in work translates into approximately $7,800 in lost wages (using 1994 dollars), which in turn translates into lost retirement savings because fewer credits are earned toward future Social Security and private pension benefits. In addition, some lose health insurance benefits.

Opportunity for Change

Recent events provide hope and an unprecedented opportunity to build upon and improve the services and public awareness we have now.

The Olmstead decision is the primary reason the opportunity for change is so great. The Olmstead decision has triggered “Olmstead planning” in 40 states across the country. In addition, it has triggered a tremendous amount of activity at the federal level. Under the Clinton administration, the federal government spurred states to respond to Olmstead and backed up its commitment with $64 million dollars in grants, including grants under the Real Choices Systems Change grant initiative. (Previously, the federal government had enacted the Ticket-to-Work and Work Incentives Improvement Act (TWWIIA) with its own array of grants.) The Bush administration has also leant its support to “implementing Olmstead” through its New Freedom Initiative. To that end, ten federal agencies evaluated their policies, programs, statutes and regulations to determine whether any should be revised or modified to improve the availability of community-based services. Through these federal initiatives, increased attention has been focused on housing, transportation and employment resources, in addition to improving and expanding access to community health, mental health and supportive services.

The Olmstead decision provides an opportunity for increasing the level of awareness in the community. Nearly 14 years after the enactment of the ADA, public awareness and support for community integration have grown. Progress toward integration in the schools, which began under state law in 1973 and is now also governed by the Individuals with Disabilities Education Act of 1997, has also helped to increase public understanding and awareness of needed supports and services. The Olmstead decision reinforces this trend by providing another vehicle for pressing the “integration imperative” under these civil rights statutes.

Advances in technology also offer new opportunities for change. An expanded array of technologies, including assistive technology and information technology, permits more people to move from restrictive environments into more integrated living arrangements, with more independence. In addition, advances in information systems technology offer the opportunity for data-driven policy development. The potential to integrate information systems offers the opportunity to reduce the cost of collaboration, reducing one of the barriers to integrated information and referral, integrated services, and integrated funding.

As we consider the opportunities before us, we think, too, about what true lasting change would look like. Transforming the lives of persons with disabilities means transforming the political and cultural landscape, which can create or remove barriers to community integration. In our transformed world:

The leadership in our state and federal government will have a shared understanding of the meaning of community integration that will endure and expand over time and with changing administrations.
Our leaders will advocate for and implement creative changes responsive to the needs of people with disabilities.
Our leaders will commit the resources necessary to make community integration a reality.
Our community will value the lives and respond to the needs of persons with disabilities, advocating for inclusion and equality in dignity and rights.
We will understand that “disability” is not about somebody else; it is about all of us.
We will create a single, coherent and accessible approach to serving persons with disabilities, responsive and accountable to the persons served.
We will provide meaningful choice by opening to each person the world of possibilities and providing the supports to make those possibilities attainable.
We will make sure that we have the quality providers we need to make community integration possible.
We will never ask families to give up their children to make sure they have needed services.
We will have the information we need to make reasoned decisions about allocating resources.
We will continually monitor our progress toward community integration with consumers playing a meaningful and active role in that process.
We will protect each individual’s right to privacy, while making sure we open the lines of communication for integrating services.

Recommendations

While it is ambitious to think about transforming our community’s understanding and responsiveness to the needs of persons with disabilities, we can take some positive steps toward change. With enough political will and commitment from our leaders and community (and united support from advocates), we can begin down the path toward our vision of community integration. We can start with the recommendations below.

Consumer Voice

Support the recruitment and training of consumers to participate on state and provider boards, including consumer advisory boards, quality improvement boards for mental health and other provider agencies. Require publicly financed providers to support self-advocacy, and to complete training programs for self-advocacy and peer supports.
Train employers, community leaders, churches and others to be open and receptive to self-advocacy.
Develop more user-friendly advocacy organizations and materials.
Provide supports for protecting individual rights, including user-friendly guides and training programs to educate people about their rights, focusing on different topics (e.g., housing, employers, public accommodations, eligibility for services, filing complaints, successfully negotiating with service providers); and expanding legal resources to advise people on how to protect their rights and to pursue alternative dispute resolution options.
Develop alternative advocacy models to enable participation by people who do not usually have the opportunity, means, or time to do so.
Create advocacy organizations independent of the State with funding that cannot be jeopardized by taking positions adverse to the State or provider agencies. (For example, the Office of Consumer Affairs, within the Department of Behavioral and Developmental Services (BDS), should be independent of BDS.)

Organized Consumer Advocacy

Eliminate barriers to participating in public policymaking, including physical and communication barriers.
Pay for support services necessary for participation, such as readers, notetakers, drivers, and personal care attendants.
Make available funding to support transportation costs, childcare costs, and other out-of-pocket expenses that make participation a burden.
Develop and publicize alternative means for giving input into the political process with use of technology and assistive technology.
Support coalitions of advocacy groups around key issues.
Support clearinghouse and information exchange between advocacy groups.
Support leadership training.

Choice and Control

Expand self-directed services by providing individuals and families with the power to control and direct the services delivered, including the right to recruit and select their own employees and deliver the paycheck.
Offer individual budgets for the entire range of long term care and home and community based services needed, basing the level of support on health, functional status, and living situation (including housing and transportation needs). Permit the individual or family to determine which services to purchase.
Allow and promote the use of independent employment management services (e.g., withholding and filing employment taxes, preparing and disbursing payroll checks) and other types of supports for persons directing their own care. Ensure that the Fiscal/Employer Agent (FEA) has no financial interest in the self-directed services purchased by the individual or family.
Develop intermediate supports so that self-directed care is an option for persons who do not want all the responsibilities of self-direction (e.g., people who do not want to decide who to hire and fire).
Develop standards for offering the self-directed care option to persons not legally competent to direct their own care by allowing surrogate decision makers to direct care (including quality-management standards for ensuring that the surrogate is acting in the interests of the individual).
Define “allowable expenses” while permitting individuals and families to use their budgets to meet individual needs.
Develop strategies for reducing the reliance on forced medication and involuntary hospitalization.

Person-Centered Services

Organize services around the person served, not for provider convenience.
Provide individuals and families with the option of having one comprehensive resource plan incorporating the full range of needs.
Provide individuals and families with the option of having one independent person facilitate service integration and coordination across providers and programs.
Create a “circle of accountability” to ensure that all persons who are part of a comprehensive resource plan are accountable for their roles and that gaps are filled when a promised support fails.
Adopt accountability standards that require individuals and families to actively participate in planning, to register sources of satisfaction and dissatisfaction, to file grievances, to learn and exercise rights, to share relevant information, to make informed choice, to take advantage of opportunities to serve on policy boards, and to complete information on progress toward outcomes and quality of services received.

No Wrong Door

Create a statewide, integrated information and referral system that covers all disability-related services through an interactive, searchable website and a statewide toll-free hotline.
Develop integrated service centers to serve as entry points and information sources about services across programs; including an integrated application process for those who choose it.
Conduct education and outreach to make sure people know where they can obtain services.
Conduct follow-up surveys to identify opportunities for improvement in information and referrals.

Coherent System of Services

Develop common vocabulary across systems.
Develop a common set of measures for assessing the effectiveness of the State’s services, including measures of whether services are provided in the most integrated setting, whether waiting lists are fairly administered, and whether people move off waiting lists at a reasonable pace.
Develop the capacity to integrate data, as well as the capacity to maintain the infrastructure to use and evaluate integrated data. This development process should be sensitive to concerns about the security of integrated data and the protection of confidential information.
Develop standards for measuring and improving community integration.
Integrate information sources across systems, while protecting individual control over privacy.

Responsive Service Coordination (footnote 40)

Identify gaps in eligibility for service coordination services.
Explore new ways of providing service coordination, including strategies for ensuring the independence of support and providing service coordination at neutral sites.
Improve quality through training and quality monitoring.
Explore the appropriateness of combining counseling and care management services.

Funding & Planning

Pursue more accurate measures for how many people have a disability and type of disability, counting both people who receive services and those who do not.
Define “need for services” to include the range of services necessary to support sustained community living and participation.
Collect data on place of residence, across a range of settings (e.g., institutional, boarding facility, home, street, shelter); the barriers to moving to a more integrated setting, if applicable; and the individual’s preference for where to live.
Link data across programs so that the State has the information it needs to effectively manage the allocation of its resources.
Improve measures of the future need for services by enhancing data collection efforts in schools and evaluating trends that influence the need for services.
Develop other measures of unmet need, using claims data and other resources to identify when people are waiting too long for services.
Expand the statutory requirement that state budget requests be based on anticipated need for services, by also requiring budget requests to include the current need for services and unmet need for services. Improve state compliance with this statutory requirement.
Explore other opportunities to leverage federal funding, including possibly using MaineCare to pay for additional services consistent with the home and community-based services model.
Advocate at the federal level to eliminate cost neutrality requirements in Home and Community-Based Services (HCBS) Medicaid waivers thereby increasing access.
Advocate at the federal level for people with mental illness to have reasonable access to Medicaid options that support integrated living.

Waiting Lists

Develop standards for collecting consistent data on waiting lists.
Develop standards for maintenance of provider waiting lists.
Develop standards for the fair administration of waiting lists, including how people get on a waiting list, how persons are prioritized, how persons are notified of their status, etc.

Direct Care Providers

Build respect for direct-care workers by developing a public relations plan for communicating their importance and responsibilities to key constituencies, including potential direct care workers, their employers, consumers, legislators, and the general public; Build respect through exploring models for elevating the status of direct care workers.
Explore increasing the educational and training requirements for certain direct-care services.
Improve recruitment and training by defining the competencies the professional direct-care workers should master; creating effective training; providing direct, hands-on experience during training, providing more supervision, transition, and mentoring support, especially during the first year.
Consider increasing the direct-care educational and training prerequisites for the provision of certain services.
Define and develop professional growth opportunities along a career track of increasing responsibility, reward and compensation and create multiple levels of state certification to support the career track.
Encourage employers of direct-care staff to improve wages and benefits.
Explore whether or not to create a statewide or regional association to support direct-care workers.

Quality Services

Build standards for quality and accountability into the design of services and evaluate quality on an ongoing basis.
Develop a consumer-driven approach to quality management, so that the people receiving the service define what is meant by “quality.”
Develop a comprehensive definition of quality that includes a complete view of a person’s life, including home and family, school, work and daily activities, and social and community living.
Measure the contribution of all supports in a person’s life at home, at work, or in daily living activities, and community.
Measure quality focusing on what the person values as being most important and what enhances the person’s experience.
Require providers to assess and evaluate satisfaction with the services they provide, use findings to improve services, incorporate the consumer and family in quality management and program design and implementation.
With the input of consumers, develop quality indicators related to the expected results of the services for the individual, how the design of the services meets the identified need, how the services will be delivered, the expected duration of specific services, possible alternatives for services, and how results will be evaluated.

Accessible, Available Transportation

Support the recruitment and training of consumers to participate in consumer advisory boards for regional transportation organizations.
Petition for regional transportation boards to develop consumer advisory boards and committees if they do not already exist.
Improve coordination between the Department of Transportation and other state agencies to maximize the effective and efficient use of resources and to make sure there is a link between the location of services and transportation planning.
Experiment with more flexible MaineCare policies which would allow use of Medicaid dollars for transportation services beyond medical appointments (e.g., a Medicaid waiver that allows use of fixed monthly transportation allowances for meeting any transportation need).
Explore the development and operation of rural programs which train, coordinate, and monitor volunteer drivers and ride-share programs that meet transportation needs of rural residents without cars.
Identify departmental representatives to participate in a cross-system transportation funding development and oversight group that works to identify and then take advantage of creative funding opportunities, particularly discretionary federal and foundation grants (e.g., social service funding application that takes advantage of allowable transportation cost option, or transportation asset application that takes advantage of allowable costs to train people with disabilities to use public transit).
Undertake an audit of consumer-led cross-departmental transportation policies and programs to identify opportunities and barriers for better transportation services for individuals with disabilities at the community level.
Hire a director of statewide driver-training to coordinate training programs for all regional providers.

Integrated, Accessible and Affordable Housing

Expand the Bridging Rental Assistance Program (BRAP) to cover all who need it.
Educate bankers, realtors, and other housing professional about home ownership options for people with disabilities, available subsidies and assistance programs, and landlord/tenant issues.
Make sure resources are available to pay for modifying a home or an apartment when necessary; make sure home modification is affordable.
Support the recruitment and training of consumers to participate on public housing boards and in public housing authority annual or 5-year planning processes.
Expand legal resources to advise people on how to protect their housing rights.
Support training programs to educate people about their housing rights and effective ways of educating landlords about rights and accommodations.
Support training programs for landlords to educate them about disabilities and different accommodations.
Advocate to remove the federal barrier to housing assistance for persons in recovery who have a conviction for a drug-related offense.
Identify departmental representatives responsible for ensuring that the relationship between the location of housing, services and access to transportation are taken into account in the planning and development process.
Give people options about where to live and with whom and develop those options
Break the link between housing and services so that individuals do not feel they have to give up their choice of providers in order to keep their residence.
Break the link between a residential setting and the level of services available so that, rather than moving from one setting to another setting a person can stay in one place and receive appropriately adjusted levels of service.
Review and modify regulations, as appropriate, to ensure that basic needs, such as home modifications, communications systems, transportation, and other transitional services are provided to meet the needs of people in institutions who wish to return home.
Make sure that service coordination, including case management services and community support services are available to assist in a transition, for up to 180 days before a transition from an institutional setting.
Define “most integrated setting,” and track whether the people served are receiving services in the most integrated setting appropriate to their needs and preferences.
Make sure that all people not served in the most integrated setting appropriate to their needs and preferences are provided that option within a reasonable period of time.
Increase the affordability of homeownership by supporting homeownership loan programs such as Coastal Enterprise Inc.’s now unfunded Home Assistance Venture II, which assisted people with disabilities in making down payments and meeting closing costs. (footnote 41)
Examine all MaineCare options that impact on housing to ensure that only those that maximize integration (such as HCBS) are used.

Jobs

Expand legal resources to advise people on how to protect their employment rights.
Support training programs to educate people about their employment rights.
Explore current personal-assistance service offerings and additional policy options that Maine might take advantage of under federal law.
Modify personal-assistance services assessment tools to identify what a person specifically needs in the home in order to prepare for work, as well as what personal-assistance services might be needed on the job site to successfully complete job tasks.
Expand supported employment services to all who need them regardless of diagnosis.
Eliminate sheltered workshops and enclaves.
Improve and expand coordination between schools and vocational rehabilitation services.
Increase awareness and understanding of disability to eliminate stigma and fear of litigation and costs of complying with the ADA.
Educate providers on their role in protecting an employee’s rights under the ADA.
Increase support within local secondary schools to provide assistance for students with disabilities in seeking and maintaining after-school and weekend jobs, internships, and cooperative education (work-study) arrangements
Undertake a statewide effort in partnership with the Social Security Administration to make better use of existing Plan for Achieving Self-Support (PASS) and Impairment Related Work Expenses (IWRE) procedures that allow people with disabilities to target earnings to meet specific work support needs in a way that also continues cash support and medical insurance.
Develop and sustain additional means of involving employers, particularly small businesses, in leadership networks which allow them to both define and oversee employment preparation and support services. Current opportunities for this include the national Business-Leadership Network, employer networks which are forming under the federal Workforce Investment Act (WIA), and Project with Industry models as funded in the federal labor and vocational rehabilitation systems.
Promote and support alternative and flexible work options that meet the needs, skills and availability of workers with severe disabilities, including telecommuting, job-sharing arrangements, and use of assistive technology.
Explore and develop strategies to increase employment options for people with disabilities who have criminal records.