Regarding a recent question about the 704 report — thank you to Deborah A. Cotter, Independent Living Program Specialist with Independent Living Administration for this clarification:
Since the current 704 report is unchanged and does not address the new service of transition, below, in black are the instructions we provided to CILs last year for the 704 Part II:
The 704 Report instrument and instructions will be revised at a future date to incorporate the new core services and other pertinent WIOA provisions. In the meantime, CILs are expected to use the current 704 Report instrument to report on their IL core service activities during the past year in the three areas specified by WOIA:
a) Nursing home transition – From institution to home and community-based living;
b) Diversion – Preventing at-risk individuals from entering an institution; and
c) Youth transition – From school to postsecondary life.
Each of these areas is to be reported in a different 704 Report section:
a) Nursing home transition:
Subpart III, Section B – Significant Life Areas
Item (J) Relocation from a Nursing Home or Institution to Community-Based Living
b) Diversion:
Subpart III, Section B – Significant Life Areas
Item (D): Community-Based Living
c) Youth transition:
Subpart III, Section A – Individual Services
Item (U) Youth/Transition Services
We are aware that some CILs may have provided services that would fall within the new fifth core service during this reporting period. CILs that choose to do so may provide additional data about the new core service in Subpart VII, Section A – Other Accomplishments, Activities and Challenges. CILs should specify, for example, the number of diversion-related outcomes in Section B, Item (D), separate from the other types of Community-Based Living outcomes. CILs should also distinguish between the number of school transition-related services and other kinds of Youth Service outcomes in Section A, Item (U).
We ask CILs do their best with the current 704 Report format and the data already collected, until the revised 704 Report and corresponding guidance become available. CILs are also encouraged to start adapting their IL data collection and reporting systems to accommodate the new IL core service.
We appreciate your understanding as ACL and RSA partner together on this transition period, while implementing the new provisions of WIOA as expeditiously as possible.
Here is ACL’s clarification re the interpretation of youth transition:
Our regulations define “youth with a significant disability” to include the age range of 14-24.
The regulatory definition of the IL core services says “facilitate the transition of youth who are individuals with significant disabilities who were eligible for IEP…. And who have completed their secondary education or otherwise left school to postsecondary life …”
Apply the definition of youth with a significant disability to the IL core service definition, the IL core service would apply to people who are in the 14-24 year age range. A 25-year old or a 13-year old who is being helped should count towards IL services and not IL core service.
I bookmarked the FedReg so that I’d have the final rule at my fingertips: https://www.federalregister.gov/documents/2016/10/27/2016-25918/independent-living-services-and-centers-for-independent-living
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