Comment on FR Doc # 2026-10134
Griffin-Hammis Associates, in collaboration with Marc-Gold and Associates and UT State IDRPPSupportOther
Summary: The commenter recommends that the RSA clarify that Transition Discovery can be used as a methodology for delivering existing Pre-Employment Transition Services (Pre-ETS). They argue that this framework provides a more coordinated, person-centered approach to help students with disabilities build on vocational experiences over time.
We respectfully recommend that RSA clarify, within the RSA-911 instructions or related technical assistance, that Transition Discovery may be used as a methodology for delivering existing Pre-Employment Transition Services when its activities align with the required Pre-ETS categories.
The required Pre-ETS activities provide important opportunities for students with disabilities to explore careers, participate in work-based learning experiences, develop workplace readiness skills, and strengthen self-advocacy. However, these activities are often delivered as discrete services rather than as part of a coordinated, individualized process that builds on each experience over time. Transition Discovery provides that continuity by helping students identify their strengths, interests, support needs, and emerging vocational themes, using each experience to inform the next and ultimately supporting more informed transition planning.
Unlike Customized Employment Discovery, which is intended to culminate in an individualized employment outcome, Transition Discovery would support a progression of individualized employment experiences throughout the transition years. These experiences may include work-based learning experiences, internships, informational interviews, and other individualized work experiences that help students make increasingly informed employment and postsecondary decisions while remaining engaged in school.
Transition Discovery is not intended to replace or expand the required Pre-ETS activities. Rather, it provides a person-centered framework for delivering existing services in a more individualized and coordinated manner by strengthening job exploration counseling, informing individualized work-based learning experiences, supporting self-advocacy, and guiding postsecondary planning.
Clarifying that Transition Discovery may be used to deliver existing Pre-ETS services would encourage more individualized transition planning while promoting continuity between school and adult vocational rehabilitation. Information developed through this process could inform future employment planning and reduce the need to begin Customized Employment Discovery only after school exit.
Thank you for considering this recommendation.