IL-NET TA

Advocacy Skill Building Toolkit – Teaching Advocacy to Youth

You may have heard that, when Ed Roberts (the father of Independent Living) was asked to name the core services for Centers, he replied, “Advocacy, Advocacy, Advocacy”. While we know there are other core services, advocacy is the foundation. At both the individual and systems levels, advocacy is essential to our survival. People with disabilities continue to be devalued by our society. The most important skill we can learn is advocacy.

If you want to see a unique approach to teaching advocacy, you have to look at this material. How clever, engaging and effective to use games and improv to advocate. Check out this concept at https://www.youtube.com/watch?v=Gb1mYCCSbzE&feature=youtu.be

The Research and Training Center on Disability in Rural Communities (RTC) at the University of Montana in Missoula is a partner with Independent Living Centers in providing curriculum. Many of you have used their Living Well with a Disability, Working Well with a Disability, and Self-Employment publications and materials. They have released their newest — a toolkit to teach advocacy skills. While it is targeted to emerging leaders and youth, all advocates will benefit from the solid information and the unique approach. As they say on their website, “An important part of advocacy, no matter if the goal is to help one person or many, is establishing a confident voice, developed and supported by a community of peer support. This workshop and accompanying toolkit materials give participants the opportunity to explore their voices, build confidence, and display their skills both verbally as well as in written form. The intent is to provide a safe space among peers and trusted facilitators to introduce the concept of both group and self-advocacy.”

The toolkit is available at http://rtc.ruralinstitute.umt.edu/resources/advocacy-skill-building-toolkit/

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Do your bylaws include these fifteen important elements?

From time to time I get requests for sample bylaws or bylaws content for CILs. I don’t have any samples, mainly because there are no hard and fast national rules and the state requirements vary somewhat state to state. I do have a little advice and if you want more, would be happy to review your current bylaws and make suggestions.

There are organizations that provide sample bylaws. Here is a link you might find useful.

Since bylaws are the foundation for your organization, you may want to open with the mission or purpose of the organization. Typically the name is also included, and if the name you use is different from the one on your articles of incorporation you may want the corporate name, then “doing business as…” for the other name. Both should be in the bylaws in that case.

Look at these items and check them off. We can find some sample language if you aren’t currently addressing that area at all.

Bylaws need to provide your organization with structure. They should indicate how many members are on your board (or a minimum and maximum number like not less than 5 and not more than 15). You probably want to repeat the requirement from the law, that more than 50% of the members of the board must self-identify as individuals with significant disabilities. You can describe how individuals are nominated and elected. Is there an application process? Describe it.
How long is a board term? Can a member serve more than one term? What is the limit? Typically I see members serve 2 three-year terms, or 3 2-year terms, and then must sit out a year before being considered for new terms. Do you have attendance requirements? Donor requirements?
You will want to add language about accommodations, something like “Materials for the board members will be provided in alternate formats if requested. Meetings will be held in accessible locations. If the board member requires other accommodations in order to fully participate, they should request those accommodations from the chair.”
State that all members are volunteers and cannot receive compensation for serving on the board, but may be reimbursed for actual, reasonable expenses incurred on Organizational business. You decide if this includes attending board meetings, in which case you may pay for mileage or an attendant or taxi fare etc.
Identify the officers of the board and their responsibilities, and the members of the Executive Committee. (Some CILs include only officers; others include one or two positions “at large” which are elected and give the executive committee broader perspective.)
State if the executive committee can make decisions for the full board between meetings, or if they must take all decisions back to the full board.
Other standing committees can be listed in your bylaws. I personally prefer to have just the Executive Committee and the Nominating Committee in the bylaws. The organization can have more committees, but wouldn’t be required to. If your board is small, lots of committees are difficult to maintain.
Minimum number of meetings, or a frequency. Don’t put “monthly” in your bylaws if you always take December off, for example. “Meetings will typically be held monthly, and the board will meet a minimum of ten times a year” might be good language. If your board only meets quarterly, you would adjust this language and make a provision for someone to review monthly financial statements with the Executive Director.
Define a quorum, which is typically at least 51%, or more than 50%.
Think about other details related to holding the meetings. Do you allow members to attend by phone or by video chat? Can you take an email vote between meetings? Are your meetings open to the public? Usually they are, except when the board meets in executive session to review personnel or legal matters.
I like to see the requirement that, if a board member wishes to apply for a position at the center, they must first resign their position on the board. A member cannot serve on the board when their employment application is being considered for any position.
Usually you see sections on risk management.
Define the fiscal year (Beginning October 1 and continuing through September 30 is typical, but there are others.)
The process for amending the bylaws is described. Often it requires a higher percentage to be at the meeting than 50%. Also typically the bylaws address what to do if the corporation is to be dissolved.\
Conflict of Interest is usually addressed. Here is a sample:

ARTICLE VIII: CONFLICT OF INTEREST

SECTION 1. DEFINITION: No member of the **** Board of Directors or Staff shall derive any personal profit or gain, directly or indirectly, by reason of his or her participation in ****. Each individual shall disclose to the President or the Executive Director any personal interest which he or she may have in any matter pending before the organization and shall refrain from participation in any decision on such matter. Any member of ****’s Board of Directors or Staff shall refrain from obtaining any list of **** clients for personal or private solicitation purposes at any time during the term of their affiliation.

SECTION 2. DISCLOSURE: Officers, Directors, and employees shall review the conflict of interest policy for applicability and, at least annually or as business is considered, disclose potential conflicts of interest in accordance with procedures established by the Board of Directors.

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When is a Youth receiving Transition Services?

Question: We have a question concerning documentation of youth transition services. When a Center provides services to a youth during the summer, when still enrolled in school but during summer break, how should this be documented? Would this service be documented in our database as a youth transition service? The other choice is to document this service as a different core service such as advocacy or independent living skills depending on the nature of service.

Reply: Services provided over the summer to youth who are still in school is recorded as a service to youth, but the service is the other core services (whictever apply), not transition. Youth transition services are only post secondary. The person has to have finished school, even if they moved to a GED program.

Typically you want to start services earlier than this, so that you are in touch with youth as they leave school and can begin to transition to post-secondary life. Post secondary can be after graduation, when a student drops out, when a they move to a GED program or when a student ages out by finishing their IEP at age 19, 20,21 or 22.

A few basics about planning

There isn’t a single way to write a strategic plan. We suggest that the CIL set goals and objectives that are measurable, and result in measurable outcomes. If you search for “outcomes” on our website at http://www.ilru.org you will find a number of on-demand training sessions addressing outcomes.

Any planning tool or template can be used to record this. Most CILs put it in narrative form in a word document. Some set it up in a chart. Some borrow or buy a template (you can Google “strategic plan template”).

Typically the elements of a plan are the mission and/or vision, long range goals, short range goals and specific measurable objectives with persons responsible and a target date, so everyone can check in from time to time and see how they are progressing on the plan. Typically the board (with the ED and with or without other staff and stakeholders) set the mission, vision and long range goals, then the staff flesh them out and are held accountable for their progress and outcomes.

I suggest that CILs start with the grant goals they have promised to their funders and make sure that any plan encompasses those routine things along side of their dreams.

Business Agility – how to approach your operations in a flexible, responsive manner.

Business agility is closely related to something called “agile project management”, an approach to constantly reassess and adjust priorities and being flexible as the circumstances change, so that you maximize your desired outcomes.Think about it — we live in a world where everything is connected, and connection is instantaneous. Information moves so fast, we must be agile in responding.

If you are working with a strategic plan, you know that your goals, objectives and activities typically change over the course of the multi-year plan. Have you noticed that in recent years they are changing even more quickly? Sometimes there are external factors that force change – funding, geography, economy, technology, regulations, leadership and more. If you want to remain competitive and take advantage of new opportunities, then the ability to anticipate change and adapt quickly is critical. Is your Center or Council ready to shift and change quickly if you need to?

If your leadership tends to get bogged down in long discussions and to deliberate across many meetings before making a decision, then being agile will take some willingness to consider other models of decision making.

Service delivery. Review how you deliver your services. While it is true that all centers are required to offer the same core services, there is a great deal of latitude for the local center to develop its service delivery model to match the needs of its community. Independent Living Skills are taught many different ways across the country — at home, at the center, or in a public place like a home economics classroom in a high school or college. Some are group classes at the center, some are on-line courses and others are one-to-one. Some emphasize skills for mobility, others for financial security, and other for shopping, cooking, cleaning and other skills needed to address those skills the individual finds most pressing at the moment. Almost always, as the consumer accesses the community, advocacy issues emerge related to equal access. The best Centers adjust both the topics and the teaching method to meet the individual needs of the consumer in that moment — which requires some agility.

Consumer Satisfaction. To know whether your services have the agility that your consumers need, you need to find out if they are satisfied. All centers are required to measure satisfaction, but are you asking the right questions? For example, how quickly did the center respond to the consumer’s first inquiry? We live in a 24/7 world. Did your response meet the expectations of the consumer?

Responsiveness. Examine your internal processes for getting a new person started with their own plan for Independent Living. How many steps does it take? How much time? You need to find the right balance between an “intake” process that allows you to understand what the person wants and needs, and a bureaucratic process that has too many steps. Think about how you can meet our funder’s requirements and still keep things moving. (Our regulations require that you determine eligibility – that the person says they have a significant disability, and that you inform them of some specific things like rights, registering to vote, and the Client Assistance Program, for example.) Using a prepared packet and a checklist might assist you with meeting the requirements quickly so you can move on to understanding their Independent Living goals.

Empowering, not controlling. The individual sets their own goals and does most of the work to achieve them. The staff role is to provide peer support, to assist the person in knowing their choices, and to provide them with community resources and connections that might further their Independent Living. If the CIL has a rigid, controlling process for “intake”, you will be less agile in the delivery of needed supports and core services. You want a process that can move with the person through their journey, not attempt to take them where you think they ought to go.

From Service Providers to Community. I have noticed a disturbing trend among some centers, a trend to identify more as service providers rather than as Independent Living. The IL philosophy is a movement by and for people with disabilities. Services are provided from within that framework of consumer control, peer support, equal access, and self-determination. If service models come first, we have lost our way. If we are to be agile in the 21st century we need to reclaim our place as a community of people with disabilities.

Here are some key phrases from the Responsive Organization’s manifesto for you to think about:

… people who want a better world for themselves and their communities are looking to new ambitious organizations to shape our collective future.
Responsive Organizations are built to learn and respond rapidly through the open flow of information; encouraging experimentation and learning on rapid cycles; and organizing as a network of employees, customers, and partners motivated by shared purpose.
A clear and visionary purpose brings together stunning talent, committed shareholders, partners, and communities.
Because we can’t predict the future, time and resources devoted to planning are a less valuable investment than embracing agile methods that encourage experimentation and fuel rapid learning.

Building this new kind of organization should come naturally to Centers and SILCs because of our commitment to consumer control. Take a deep look at your organization — have you drifted from that principle? Evaluate your Center or SILC and the ways in which you can remove bureaucracy and be agile in responding to consumers.

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How to have an effective relationship between the Board Chair and the Executive Director

There are specific dynamics to every relationship. There are people in your life who make you bristle just by coming into the room. Others make you smile when you think of them. Some share your sense of humor and you often laugh together. You connect to others through a shared experience that was meaningful to both of you. Whether at work, at home, or out in the world around you, relationships are both the best and worst part of our lives.

One of the relationships I am often asked about is that between the board chair and the executive director of a Center or Council. Inevitably when that comes up, the issue has something to do with one or the other either overstepping or failing to fulfill their duties. For that reason we often recommend that the two sit down to sort out their respective roles and responsibilities. Clarifying and agreeing on what each will do should provide the framework for the relationship between the two. However, that is not the only dynamic at work in this important relationship, and in fact sometimes being too rigid in emphasizing this can impair the agility of the organization.

Of course, there can be tension in this relationship because each of the parties is holding the other accountable. The Executive Director works with the Board Chair in the development of the agenda, and in arranging the meeting place, assuring reasonable accommodations for board members, and in identifying potential new board members, for example. Seldom does the volunteer chair take the lead on this and frankly, the Executive Director has business items that must be approved by the board, so has a stake in that agenda.

Here are some other dynamics that impact the Board Chair/Executive Director relationship.

Facts-sharing. The study found that keeping each other informed, with or without actually having a conversation, was the most basic of the interpersonal interactions.
Ideas-sharing. brainstorming, problem solving or thinking things through together strengthens the bond. Quick exchange or longer discussion, this two way sharing strengthens the dynamic between the parties.
Knowledge-sharing. When either of the two provides learning or coaching for the other it strengthens this work relationship.
Feelings-sharing. Support, reassurance, caring and appreciation are types of feeling sharing that strengthens this bond.
Give-and-take. When each is willing to adjust to the other person’s style, whether the ED is adjusting to a new Chair or the Chair to a new role, then these accommodations for each other help them to be aligned in their board work.

And the more of these dynamics the better. The study found that pairs with the strongest trust demonstrated all of these interaction types. In those that demonstrated great relationships, they described energy and synergies in the relationship that catalyzed organization productivity and engagement with the community. Often they were able to leverage the relationships between all the board members and work together to make connections with key people in their community to further their mission.

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If “Lean” is your dream – How can you grow your center with minimal staff and funding?

We provide considerable information on how to raise money, develop fee for service projects, and partner with funders for other than Independent Living funds. The struggle is getting it done. Everyone is already busy. Who has time to plan and execute a plan for a new project? Here are some tips for keeping your operations lean and strong and still finding ways to grow.

Keep you mind wide open for ways to grow your center and its services. If you are at a national conference, on one of our webinars or otherwise rubbing elbows with your peers, listen to what they are doing and how they are funding it. Our most successful centers don’t stray too much from the core services but find ways to enrich those services to the benefit of their consumers. They are also willing to share their work, typically, as in policies or other information that will help you duplicate their efforts.
In the Lean Startup world, the only way to find a solution to the problem you want to tackle is customer feedback. This Lean Startup model may serve you well. How does your CIL collect feedback from consumers? How do you gauge how successful your new idea will be? This is more than asking if they like your current services. You need to ask lots of people about their response to your potential idea, too. Then as the new project gets rolling, continue to collect feedback and adjust your program.
Develop questions that are open enough to give you new ideas for growth and improvement. Get them out to as broad a group as you can. Don’t just ask your recent consumers. Are there other lists like past consumers, youth, service partners or more that can inform your new project and its growth.
Turn to your mission for inspiration. If you are focused on your primary purpose, the impact you expect to have on your world, you will not be tempted into unrelated or less effective “side businesses”. You never want to take on a new project that is counter to Independent Living Philosophy. Keep your focus.
Eliminate uncertainty. Take the time to map out your future, to measure your results, and to keep all stakeholders informed about your direction and success. This will help you to adhere tightly to the things that must be done, and to self-direct if a detour isn’t providing results.
Utilize a plan-act-measure-plan cycle, or build/measure/learn. Be willing to continually self-correct based on measurable expectations for the organization.
Think of this as more of an experiment model than a detailed blueprint model. What does an experiment do? It identifies an hypothesis and then measures to see if it is true or not. That way, as you learn what is working and not working, you can adjust your practices and try a new approach.

Thanks to Michelle Martin for her research on the New Century CIL Blog. For more on this topic:

Lean Startup Methodology (LSM). Created by Eric Ries, this process identifies ways for entrepreneurs to start a company quickly and efficiently.

http://www.plusacumen.org/courses/lean-for-social-impact

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Systems change advocacy – six effective strategies

I was readying an article in Non-Profit Quarterly recently, an article about how to change an established system. I was reminded of a few important principles around system change.

We are not the only group in the world working for change. Economists look to change markers related to money — interest rates, wages, taxes — in order to change how the economy works. Other social justice entities look to change society and its perceptions and prejudices for much the same reason we do — in order to remove barriers and change attitudes. We can learn from each other in the IL movement. We can also learn from the world around us if we are paying attention.
There is always a leverage point where you can apply pressure for change. Jay Forrester said of these leverage points, “People know intuitively where leverage points are. Time after time I’ve done an analysis of a company, and I’ve figured out a leverage point. Then I’ve gone to the company and discovered that everyone is pushing it in the wrong direction!” Finding the right leverage points is key. As you approach any system change effort in your community, consider where you can apply pressure to get the change you want. Do you know and have a relationship with someone in power in the situation? Is this a time to enlist public support by getting on the news? Is there a legal aspect that can be explored? Do you have facts, figures, data that will apply the right leverage?
Just because a method of pushing for change worked once, doesn’t mean it will be effective the next time. Continually assess whether your efforts are getting the results you intend. If not, step back and analyze why not. Then adjust your strategies to get a better response. This is something you should measure if you want peak effectiveness in your Systems Change advocacy efforts. Sometimes gathering the troops, circling the target with signs and shouts, is extremely effective. In other situations, the target for change becomes more and more entrenched. When that happens, it is time to see if other leverage points can get a different result.
Measure the things you need to know. Donella Meadows wrote, “In 1986 the U.S. government required that every factory releasing hazardous air pollutants report those emissions publicly. Suddenly everyone could find out precisely what was coming out of the smokestacks in town. There was no law against those emissions, no fines, no determination of “safe” levels, just information. But by 1990 emissions dropped 40 percent. One chemical company that found itself on the Top Ten Polluters list reduced its emissions by 90 percent, just to ‘get off that list.’” Information can power change, if it is the right information and is put in front of those who need to change.” What information loops are in place to measure what concerns you? Use them.
Pay attention to the rules. Rules — laws, policies, or even unwritten social rules — can drive change. Change the rules and the system will be required to follow. Meadows also said, “If you want to understand the deepest malfunctions of systems, pay attention to the rules, and to who has power over them.” A review of the rules in a system fraught with barriers may very well tell you where that system is malfunctioning.
Sometimes you need to break away from the old rules and start over. We have all seen those systems that are inflexible and difficult to change. Sometimes those systems need to go, and something new needs to take its place. “”Any system, biological, economic, or social, that scorns experimentation and wipes out the raw material of innovation is doomed over the long term on this highly variable planet. The intervention point here is obvious but unpopular. Encouraging diversity means losing control. Let a thousand flowers bloom and ANYTHING could happen! Who wants that?” – Donella Meadows

Independent Living Philosophy teaches us that we should have equal access in our communities, and each of us defines where access is compromised and where our systems advocacy efforts will be focused. The point of system change advocacy is equality. It is change we work for every day.

Donella Meadows is an ecologist and founder of the Donella Meadows Institute who died suddenly of meningitis on February 20, 2001. Meadows wrote extensively about economic systems and sustainability, and wrote and worked tirelessly on behalf of the Earth.

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7 Frequently Asked Questions about Youth Transition

Independent Living Services for Children and Youth with Disabilities (continued from May 2)
On April 14, 2017, Bob Williams, Director of Independent Living Administration, provided additional explanation regarding services by Centers to youth, related both to the more traditional IL services and to the new core service of transition, specifically to youth and young adults with disabilities as they transition to postsecondary life once they are no longer receiving a secondary education. The full text of the letter and guidance can be found on our website. Here are seven questions addressed in that information.

What are core transition services for “out-of-school youth”?
Core transition services for out-of-school youth are found in the Rehabilitation Act of 1973, as amended (the Act), Sec. 7 (17)(E)(iii). This
category covers services designed and provided by the CIL specifically to facilitate the successful transition of youth to post-secondary life. A CIL can also provide other core services that meet this aim.
What does the phrase “out-of-school youth” mean?
It refers to youth with significant disabilities ages 14 to 24 who have completed their secondary education or otherwise are no longer in a secondary education or special education program. Such youth include those enrolled in a GED or post-secondary education program (e.g., college, career development or related programs). (Note from Paula – I think this is an important clarification, and it is good to know that enrollment in a GED program is not considered part of secondary school.)
Do students have to have had an individualized education program (IEP) for the CIL to provide core transition services for out-of-school youth?
No, the criteria that must be met is eligibility for an IEP. The eligibility criteria for out-of-school youth to receive these services are set forth in the Act (as amended by WIOA) at Sec. 7(17) (E) (iii). Only youth “Who were eligible for individualized education programs under section 614(d) of the Individuals with Disabilities Education Act (20.S.C. 1414(d)), and who have completed their secondary education or otherwise left school may be eligible to receive these services. (Emphasis added). However, it is permissible, and in many instances appropriate, to provide the same or similar services and assistance to both youth that are eligible for the new core services and those that are not eligible. (See Q4 and Q5.)
Written documentation is not required, but rather, is based on self-report by the consumer and/or his/her guardian that he or she was eligible for an IEP. (Note from Paula – this clarification is extremely helpful. A youth can self-disclose that s/he was eligible for an IEP when they were attending school.)
May CILs provide the same or similar services and assistance to secondary school students as they would to out-of-school youth who are eligible for new core services?
Yes, this is permissible and in many instances appropriate to do. CILs that do this, however, must be sure to distinguish in their reporting between services provided to youth who are eligible to receive the new core service for youth and services provided to other youth who do not meet this definition and report accordingly. While the reporting requirements are different, ILA strongly encourages CILs to design and provide services and assistance that empower and strengthens the independence and self-determination of young people with significant disabilities in a coordinated, sequenced and seamless manner that builds lifelong success.
May CILs provide core transition services for out-of-school youth to students who were not eligible for an IEP, such as those that had a Section 504 plan when they were in school?
It is permissible, and in many instances appropriate, to provide the same or similar services and assistance to both youth that are eligible for the new core services and those that are not eligible. However, these would not be considered “core transition services” as created by WIOA.
When this is done the CIL must be sure to distinguish in its reporting between services provided to youth who are eligible to receive the new core service for youth and services provided to other youth who do not meet this definition and report accordingly. It’s also important to note that students who were eligible for an IEP, but chose to be served under a 504 plan, would be considered eligible for the new core service for youth if the other criteria are met.
What is the age range within which services can be provided for transition of youth core services?
The Centers for Independent Living regulations at 45 CFR 1329.4 define “youth with a significant disability” to include the age range of 14-24. Transition of youth core services may be provided within this age range. General core transition services for out-of-school youth are available to individuals according to the CIL’s eligibility criteria.
What are requirements for transition of youth for students with disabilities who were home-schooled or who attended private school or public charter schools?
The criteria that must be met is eligibility for an IEP. As is the case with public school students, documentation is not required, but rather, is based on self-report by the consumer and/or his/her guardian that he or she was found eligible for an IEP.

Please Note: If you have additional questions, please contact your state project officer or the CIL training and technical assistance center at www.ilru.org. Specific training is also available at http://www.ilru.org/topics/youth-transition.

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Who are the Youth in Youth Transition?

Independent Living Services for Children and Youth with Disabilities
On April 14, 2017, Bob Williams, Director of Independent Living Administration, provided additional explanation regarding services by Centers to youth, related both to the more traditional IL services and to the new core service of transition, specifically to youth and young adults with disabilities as they transition to postsecondary life once they are no longer receiving a secondary education. The full text of the letter and guidance can be found on our website. Here are some key points.

Centers for Independent Living (CILs) must provide independent living (IL) core services to individuals with a significant disability, regardless of age, income or disability type. This includes services to children and youth with disabilities. Recent changes to the law and regulations have not changed this general requirement.
In the Workforce Innovation and Opportunity Act of 2014 (WIOA) Congress added new IL core services that target specific populations. This includes a focus on youth who are out of school. The text of the Rehabilitation Act of 1973, as amended, Sec. 7 (17) (E) says that centers are to:
(iii) Facilitate the transition of youth who are individuals with significant disabilities, who were eligible for individualized education programs under section 614(d) of the Individuals with Disabilities Education Act (20 U.S.C. 1414(d)), and who have completed their secondary education or otherwise left school, to postsecondary life.
WIOA defines youth with a disability to mean “an individual with a disability who is not younger than 14 years of age; and is not older than 24 years of age.” ACL adopted this definition in the final IL regulation. This differs from the definitions that others might choose, including NCIL who defines a youth as someone through age 26.
IL services are available to pre-school children, youth who are in school, and youth who are out of school. To help understand the full spectrum of services available, it is essential to recognize the distinction between the core transition services for out-of-school youth with significant disabilities and other IL services provided to pre-school children and youth who are still in school.
You will need to determine how the service provided to a youth with a disability should be captured and reported on the annual performance report. A service provided to a child or youth with disabilities too young for or enrolled in a secondary education program would NOT be captured and reported as a new youth-in-transition core service. The service would be captured and reported as another IL service. A service provided to a youth with disabilities who is no longer in a secondary school and satisfies other regulatory criteria, may be captured and reported as a new core service. The FAQ sheet includes a chart to better clarify how youth should be counted when reporting their services.
The Act remains unchanged in IL services CILs may offer pre-school and youth in school. Services include: “training to develop skills … (that) promote self-awareness and esteem, develop advocacy and self-empowerment skills, and explore career options” and other “services to children”. (Section 7 (18)(B)(xvi) and (xvii).
WIOA adds new core services to the Act that include: “Facilitate the transition of youth who are individuals with significant disabilities, who were eligible for individualized education programs under section 614(d) of the Individuals with Disabilities Education Act (20 U.S.C. 1414(d)), and who have completed their secondary education or otherwise left school, to postsecondary life.

We will examine this further in the next post to this blog.