11.1 The Rehabilitation Case Management Process: Intake to Closure
Key Takeaways
- State VR eligibility is generally determined within 60 days after application unless an allowed extension or trial work experience process applies.
- When eligibility and priority cannot be resolved from available evidence, obtain additional assessment; trial work experiences are required before a finding that a person cannot benefit due to disability severity.
- The IPE is developed as soon as possible and no later than 90 days after eligibility unless an agreed extension is justified by exceptional and unforeseen circumstances.
- Closure with an employment outcome requires the IPE outcome to be maintained at least 90 days, satisfactory performance, informed agreement, and no further VR services needed at that time.
11.1 The Rehabilitation Case Management Process: Intake to Closure
Current terminology: Older rehabilitation texts teach numeric statuses such as 02, 06, 08, and 26. Current federal regulations and RSA-911 reporting use data elements and exit categories rather than that legacy workflow. Learn the governing decision, deadline, documentation, and appeal right—not an obsolete status number.
Referral, Application, and Accessibility
A referral becomes an application when the person or representative provides information necessary to begin assessment and is available to complete it under agency procedure. At first contact, explain the VR program, confidentiality, eligibility process, Client Assistance Program (CAP), appeal rights, communication access, and any Order of Selection. Provide interpreter, alternate format, assistive technology, or another reasonable modification needed for equal participation.
Use existing information to the maximum extent appropriate. Records, client report, observations, school or work information, and prior assessment may answer the decision. Purchase additional assessment only when necessary. The counselor should not require avoidable testing or delay an application because a medical record is imperfect.
Eligibility and Priority
State VR eligibility generally requires a physical or mental impairment, a substantial impediment to employment, a need for VR services to prepare for, secure, retain, advance in, or regain employment, and a presumption that the person can benefit in terms of an employment outcome. Eligibility must generally be determined within 60 days after application. An extension is permitted when exceptional and unforeseen circumstances beyond agency control prevent completion and the individual agrees to a specific extension, or when trial work experiences are needed.
The benefit presumption is important. An agency may not conclude that disability is “too severe” without clear and convincing evidence after providing trial work experiences of sufficient variety and duration in the most integrated settings possible, with appropriate supports. Experiences are periodically assessed. Current rules do not establish a routine 18-month ceiling that candidates should memorize.
When an agency cannot serve every eligible person, an approved Order of Selection prioritizes categories based on significance of disability. An eligible person placed in a closed category receives required information and referral and remains subject to the agency's waiting-list procedures. Order of Selection is not a finding that the person is ineligible.
An ineligibility decision requires consultation with the individual, a written decision explaining the reasons, information about review and mediation procedures, and CAP information. When ineligibility rests on a finding that the person cannot benefit because of disability severity, the agency must conduct the required periodic review unless the person refuses, cannot be located, has a terminal condition, or another regulatory exception applies.
Individualized Plan for Employment
After eligibility, the counselor supports informed choice about employment outcome, services, providers, and methods. The Individualized Plan for Employment (IPE) is developed as soon as possible and ordinarily within 90 days of eligibility. An extension requires exceptional and unforeseen circumstances beyond agency control and agreement to a specific extension.
The IPE identifies the chosen employment outcome, intermediate objectives when used, specific services, providers, start dates, evaluation criteria, responsibilities, participation in cost when applicable, comparable benefits, and terms for supported employment or post-employment services as relevant. The counselor and individual sign the plan, provide it in an accessible format, review it at least annually, and amend it when the outcome or services materially change.
Comparable benefits are explored according to federal and state rules, but their search must not interrupt or delay specified exempt services or create prohibited delay where an exception applies. Policy cannot override individualized need or informed choice.
Service Coordination and Monitoring
Services may include assessment, counseling and guidance, restoration, training, assistive technology, transportation, benefits counseling, placement, supported employment, and post-employment support. Coordination means assigning responsibility, authorizing service, confirming access, monitoring quality, and solving barriers—not handing the person a provider list.
Case notes should connect each service to the IPE and document client participation, progress, expenditures, informed choice, changes, risk, consultation, and next steps. Review objective and client-reported outcomes. When progress stalls, assess service quality, access, health, transportation, benefit concerns, job-market change, and goal fit before attributing noncompliance.
Employment Outcome and Exit
When employment begins, verify that it matches the IPE and meets the applicable definition, including competitive integrated employment when that is the planned outcome. Monitor accommodation, performance, satisfaction, stability, wages, hours, supports, and emerging needs. Under 34 C.F.R. § 361.56, closure with an employment outcome requires that the outcome be maintained for at least 90 days, that the person and counselor consider it satisfactory and agree the person is performing well, and that the person no longer needs VR services at that time.
Exit for another reason requires the correct current RSA-911 category, timely notice as applicable, appeal and CAP information, referral when useful, and documentation of outreach before lost-contact closure. Post-employment services may address a limited need necessary to maintain, regain, or advance in employment when a full new case is unnecessary.
Current VR Milestones
| Milestone | Current planning anchor |
|---|---|
| Eligibility | Generally within 60 days of application, subject to the regulatory exceptions |
| Trial work | Used before a severity-based inability-to-benefit finding when evidence remains insufficient |
| IPE | As soon as possible and generally within 90 days after eligibility, subject to an agreed qualifying extension |
| Employment exit | Outcome maintained at least 90 days plus the other requirements of 34 C.F.R. § 361.56 |
Agency data systems may display local labels, but the federal decision and documentation control.
What is the general federal timeline for a state VR eligibility determination after application?
An eligible person has maintained the IPE employment outcome for 95 days, both counselor and client consider it satisfactory, the person is performing well, and no further VR service is needed. Which action fits current federal terminology?
Available evidence is insufficient to determine whether an applicant with a significant disability can benefit from VR services. What is required before finding the person unable to benefit because of disability severity?
Which protection belongs in a written VR ineligibility decision?