2. 43410-FAQs-CIE (Attachment I).pdf

ETA Advisory File Text

1 Frequently Asked Q uestions Competitive Integrated Employment and Blending Braiding and Sequencing Resources Services and Funding August 3 2022 Question 1 What is blending resources Bl ending occurs when dollars from multiple funding streams are combined to create a single pot of commingled dollars that is then used to fund an initiative or purchase one or more specific services that support an individual with a disability in pursuing obtaining or maintaining competitive integrated employment CIE . i Typically combining dollars from multiple funding streams requires explicit statutory or regulatory authorization because the funds lose their individual program identity when blended. ii However there are some specific instances when such authorization is not required or where blending is permitted in a limited way. States should check with their program officer on allowable activities. Question 2 What is braiding resources Br aiding occurs when multiple funding streams separately and simultaneously provide specific services that support an individual with a disability in pursuing obtaining or maintaining CIE while retaining the ability to track and account for funds separately. Unlike blending programs retain their identity when resources are braided. Because braiding involves simultaneous service delivery by two or more systems it may require interagency coordination and collaboration with this specific goal in mind. Specific statutory or regulatory authority is not required to braid resources. Question 3 What is sequencing resources Seque ncing occurs when multiple funding streams separately and sequentially provide specific services that support an individual with a disability in pursuing obtaining or maintaining CIE. Question 4 Can State governments receive and simulta neously use resources from more than one Federal program source to support the employment goals of an individual with disabilities Yes State governments can receive and simultaneously use resources including funding from more than one Federal source to support the employment goals of job seekers with disabilities. 2 The most common strategy for leveraging resources from multiple Federal programs to support the employment goals of a single eligible individual with a disability is through braiding. There are a variety of funding sources that can be leveraged through braiding if the following criteria are met Individuals have applied are determined eligible and have completed the appropriate enrollment processes for all systems providing resources toward a mutual employment goal. When braiding funds the funds can be tracked and documented to meet any accounting and auditing requirements of each individual federally funded system involved. The various systems have developed and agreed to a plan in which all resources being leveraged are supplementing and not duplicating efforts. Unless blending is occurring agencies cannot pay for the same service at the same time. In other words with braiding they can pay for services that supplement each other. For example one system can pay for a job coach while another system pays for transportation to and from work. In some circumstances programs can pay for the same services under a braiding strategy. If funding is simultaneous payer of last resort rules require detailed accounting processes documenting that without the investment of resources from two or more programs the individual would not be able to access and benefit from the specific service s . See additional information in Questions 7 and 8. Question 5 What are some examples of programs and funds that may be blended braided and or sequenced to support competitive integrated employment CIE outcomes The following funds can be blended braided and or sequenced as applicable with funds from different funding sources to assist eligible individuals with disabilities to achieve CIE outcomes Individuals with Disabilities Education Act IDEA Part B funds reserved for State-level activities may be used to carry out the development and implementation of transition programs including coordination of services with agencies involved in supporting the transition of students with disabilities to postsecondary activities. 34 CFR 300.704 b 4 vi . IDEA Part B funds are provided to States which subgrant the funds to local educational agencies LEAs to support the provision of a free appropriate public education to eligible students with disabilities in accordance with their individualized education program IEP . The IEP developed under IDEA for each student with a disability must address transition services requirements beginning not later than the first IEP to be in effect when the student turns 16 or younger if determined appropriate by the IEP Team and must be updated annually thereafter. The IEP must include 3 1 Appropriate measurable postsecondary goals based upon age-appropriate transition assessments related to training education employment and when appropriate independent living skills and 2 The transition services including courses of study needed to assist the student with a disability in reaching those goals. 34 CFR 300.320 b . While the IDEA statute and regulations refer to courses of study they are but one example of appropriate transition services. iii Transition services may include job development job analysis job placement and job coaching. The V ocational Rehabilitation VR program title IV of WIOA which provides funding for services designed to meet employment and career goals on an individualized basis could fund on-the-job training assistive technology trial work experiences skills training and supported self and customized employment services. Workforce Innovation and Opportunity Act WIOA Youth Services Title I of WIOA provides funding for leadership development activities summer work experiences skills training financial literacy supportive services and case management. The Centers for Medica re Medicaid Services CMS funds employment and related services through the Medicaid State plan and home and community-based serv ices HCBS waivers. Medicaid State plan s services and HCBS waivers can provide funding for prevocational services supported and customized employment services transportation benefits counseling financial capability development workplace personal assistance peer support and support coordination. Milestone Outcome payments from the Social Security Administration SSA f or Ticket to Work can be made at the same time as CMS provides funding for supported employment services. CMS has clarified that Ticket to Work Outcome and Milestone payments funded through the Social Security Administration may occur simultaneously with payment for Supported Employment services funded through the Medicaid HCBS waiver program to create a more robust support system for individuals seeking sustained CIE. Such combined support increases employment opportunities and meaningful community engagement. States have flexibility to craft their own service definitions even though many States rely on the core service definitions provided by CMS.iv This flexibility helps State agencies come together to support and increase opportunities for C IE f or Medicaid HCBS waiver participants. Additional information can be found at https www.hhs.gov guidance sites default files hhs-guidance-documents CIB-09-16-2011 2.pdf WIOA Adult Services title I of WIOA provides funding for skills training soft skills development financial literacy career counseling and individual training accounts. The Substance Abuse and Mental Health Services Administration s SAMHSA s Mental Health Block Grants provide funds to behavioral mental health agencies for eligible individual person-centered plans that cover the costs of peer support supported employment r ehabilitative ser vices and service coordination. 4 The Consumer and Consumer Supporter National Technical Assistance Centers under the SAMHSA provide training and technical assistance to promote employment for individuals with serious mental illness including peer support financial literacy planning for employment and entrepreneurship. Public housing agencies that receive U.S. Department of Housing and Urban Development HUD funding for family self-sufficiency programs cover the expenses of financial literacy service coordination and career pathways. Centers for Independent Living CILs under the Administration for Community Living ACL Independent Living program provide career exploration job readiness training resume building work-based internships and activities and work incentives benefits counseling. University Centers for Excellence in Developmental Disabilities Education Research and Service UCEDD under the Developmental Disabilities Assistance and Bill of Rights Act DD Act provide job skills training through university resources. Funds available to local educational agencies and other eligible subrecipients under the Carl D. Perkins Career and Technical Education Act of 2006 as amended by the Strengthening Career and Technical Education for the 21st Century Act Perkins V may be used to pay for the costs of career and technical education CTE services required in an IEP developed under IDEA or the costs of CTE services necessary to meet the requirements of Section 504 of the Rehabilitation Act. Funds also may be used to reduce or eliminate out-of-pocket expenses for individuals with disabilities and other special populations participating in CTE including those participating in dual or concurrent enrollment programs or early college high school programs and supporting the costs associated with fees transportation childcare or mobility challenges. With support from their Governors and or legislators a growing number of states have created state-level cross-agency working groups to implement Employment First strategies through cross-system coordination of public resources to advance CIE outcomes. v Under 20 U .S.C. 1413 a 2 D and 34 CFR 300.206 LEAs may use IDEA Part B funds to carry out a schoolwide program under Title I of the Elementary and Secondary Education Act ESEA provided certain requirements are met including that the amount of funds used in any such program is in general proportional to the number of children with disabilities participating in the schoolwide program. vi Schoolwide programs under Title I of the ESEA allow for greater flexibility in the way public schools may use funds provided they are based on a comprehensive schoolwide plan built on the results of a comprehensive needs assessment. Additional information on schoolwide programs under Title I of ESEA is available at https oese.ed.gov offices office-of-formula-grants school-support-and-accountability title-i- part-a-program resources . 5 Additional examples of services and resources that can be blending braided and or sequenced can be found at the end of this document. Question 6 How can interagency agreements be used to design collaborative resource leveraging processes to initiate resource blending braiding and or sequencing between two or more public entities The Workforce Innovation and Opportunity Act WIOA encourages and in some instances mandates interagency agreements between two or more public entities at both the State and local level for youth and working age adults with disabilities. vii Public entities benefit from these interagency agreements at State and local levels because they clarify roles and responsibilities. In addition these interagency agreements offer common definitions for specific supports and services to reduce confusion for provider agencies and individuals with disabilities. They provide guidance on collaboration in the development of individual education employment and support plans specify financial responsibilities and establish the scope and duration of services and supports. These agreements can also describe the approach to data sharing and measuring performance. They can help avoid confusion among personnel from participating agencies and possible delays in the provision of employment-related services through clearly defined roles and responsibilities. Additionally interagency agreements can be used to outline how the collaboration between two or more agencies will result in continued compliance with all relevant Federal and State rules and regulations. As a result of such agreements more support is available to better ensure that individuals with disabilities achieve and retain competitive integrated employment CIE . For more information refer to the Workforce GPS Sample MOU and Infrastructure Costs Toolkit. The f ollowing are examples of interagency agreements between State and local government entities to leverage resources across systems and ensure that services are appropriately provided to individuals with disabilities American Job Centers AJCs and State Local Workforce Development Boards WDBs are State or local government partners that enter into interagency agreements when the other entities are components of the statewide workforce development system of the State. viii Under 34 CFR 361.24 g the vocational rehabilitation VR services portion of the WIOA State Plan must describe how the VR agency will collaborate with the State agency responsible for administering the State Medicaid Program the State agency responsible for providing services for individuals with intellectual and developmental disabilities I DD and the State agency responsible for providing mental health services to develop opportunities for community-based employment in integrated settings to the greatest extent practicable. State workforce entities local Centers for Independent Living CILs and other for-profit or non-profit local entities providing employment support services to Social Security 6 Disability beneficiaries may choose to enter into an agreement Ticket to Work Program Agreement with the Social Security Administration SSA to become a Ticket to Work Employment Network EN . As a Ticket to Work EN the organization is eligible for outcome payments based on beneficiary work and earnings outcomes. These funds may be used at the discretion of the organization. ix In addition to workforce entities Ticket to Work outcome a nd milestone payments can be received and used concurrently with payments for Medicaid services because these payments are made for an outcome rather than for a Medicaid service rendered. x Most State agencies have interagency agreements between the workforce system Medicaid VR I DD Mental Health Substance Use and Education. The U.S. Departments of Labor Education and Health and Human Services have collaborated for more than a decade on career pathway approaches for individuals with and without disabilities which also encourages resource braiding through interagency agreements among multiple pu blic entities as highlighted in the Career Pathways Toolkit A Guide for Systems Development.xi The Maryland Department of Labor MD Labor State Department of Education Division o f Rehabilitation Services DORS Department of Human Services DHS Governor s Workforce Development Board GWDB and Department of Housing and Community Development DHCD createdcomprehensive cross-agency policy guidance on creating and implementing Workforce Innovation and Opportunity Act WIOA Memoranda of Understanding MOUs and Resource Sharing Agreements RSAs to promote interagency collaboration and the leveraging of resources between programs. Through the Disability Innovation Fund program authorized by the Further Consolidated Appropriations Act 2020 Pub. L. 116-94 the Rehabilitation Services Administration encourages the development of interagency agreements to support innovative activities aimed at improving the outcomes of individuals with disabilities and the education and post-school outcomes of children receiving Supplemental Security Income SSI and their families which may result in long-term improvement in the SSI child recipient s economic status and self-sufficiency.xii Under the R ehabilitation Act of 1973 as amended by WIOA and its implementing regulations VR agencies must enter into formal interagency agreements with State educational agencies SEAs to collaboratively plan and coordinate transition services for students with disabilities. The formal interagency agreement which may also include local educational agencies LEAs must describe ho w the parties will conduct joint transition planning and provide pre-employment transition services for in -school youth with d isabilities.xiii 7 Funding for transition services for youth with disabilities served under the Individuals with Disabilities Education Act IDEA may be braided with Medicaid HCBS waiver funds through the development of interagency agreements that specify the responsibility of each partner in accordance with the youth s individualized education program IEP provided the services for those youth are not required under the IDEA. The provider agency must provide documentation showing that the services are required and that they are not already required under the IDEA. xiv The collaboration and braiding of funds allow for additional services to advance employment outcomes and community participation for youth with disabilities who are eligible individuals under both IDEA and State Medicaid HCBS waivers. CMS notes that supported employment cannot be funded through Medicaid if those services include special education and related services as such terms are defined in Section 602 of the IDEA which otherwise are available to the individual through a local education agency. Question 7 What does payer of last resort mean and does this prevent State or local agencies from braiding resources to support the employment goals of individuals with disabilities Payer o f last r esort means the entity that pays after all other programs have been pursued for enrollment and payment. Under the payer of last resort also referred to in Medi caid as third party liability Section 1902 a 25 of the Social Security Act requirement State Medicaid programs must take all reasonable measures to ascertain the legal liability of third parties. xv Even t hough many but not all publicly funded services are defined as the payer of last resort there are options that permit braiding resources with other public funders to meet the needs of individuals with disabilities. Further if the payer of last resort has paid a bill that should have been paid by another entity then the State or local agency that is the payer of last resort may seek reimbursement.xvi The payer of last resort requirement does not prevent State and local agencies from braiding resources. Braiding resources to meet the needs and employment goals of individuals with significant disabilities is a strategy that is supported across the Federal government. In 2011 CMS issued an Informational Bulletin clarifying that Medica id HCBS waiver funds may be used for supported and customized employment peer support services and prevocational services. xvii The Medicaid 1915 c HCBS Waiver program complements as well as supplements services that are already available under the Medicaid State plan and other Federal State and local public programs as well as the supports that families and communities provide.xviii 8 Question 8 How can State and local partners use interagency agreements to promote competitive integrated employment CIE that meet payer of last resort a lso known as third party liability requirements St ate agency funders e.g. vocational rehabilitation behavioral health developmental disabilities education should develop interagency agreements that outline the specific resources i.e. funds staff and services for which each funder is taking responsibility to jointly support job seekers with a disability. Interagency agreements detail how the separate agencies will come together to make decisions and engage common customers in making informed choices about services. By clarifying responsibilities between the agencies upfront the funders will be able to work collaboratively to ensure a smoother payer of last resort process when providing services to a shared job seeker. A procedure for resolving disputes regarding payment or reimbursement for specific services can also be specified in the agreement. To comply with payer of last resort requirements an interagency agreement must include descriptions of the specific services to be provided. Public entities should also specify in the interagency agreement who will provide specific services under what conditions for how long how they are going to help the individual and how they are going to fund the services. If services for an individual are likely to overlap due to the timing and sequencing of the services the interagency agreement should specify which entity funds what services. Question 9 Where can States and local partners find more information to support competitive integrated employment CIE for job seekers with disabilities To le arn more about proven and promising practices that result in CIE outcomes for individuals with disabilities please visit the Knowledge Translation KT Consortium page on the LEAD Center website. The KT Consortium brings together over 25 federally funded training and technical assistance centers each with their own unique mission addressing different aspects of employment career readiness and development transition and accessibility for youth and adults with disabilities. On the LEAD Center website you also can find State Specific Policies and Data resources on Competitive Integrated Employment WIOA data resources employment strategies e.g. inclusive career pathways inclusive apprenticeship programs customized employment and discovery Individual Placement and Support for People with Mental Health Conditions and more. These training and technical assistance centers are funded by the following Federal agencies Administration for Community Living ACL National Institute for Disability Independent Living and Rehabilitation Research NIDILRR Office of Disability Employment Policy ODEP Office of Special Education Programs OSEP Rehabilitation Services Administration RSA Social Security Administration SSA and the Substance Abuse and Mental Health Services Administration SAMHSA . 9 Examples of Programs and Services for Blending Braiding and or Sequencing Resources to Support Competitive Integrated Employment CIE Agency Program Health and Human Services Centers for Medicare Medicaid Services CMS Home and Community-Based Services HCBS Waivers Medicaid State Plan Services Prevocational Services Supported Employment wage or self-employment Customized Employment Personal Assistance Personal Care Assistance Transportation Work Incentives Benefits Counseling Peer Support CMS 1915 c Technical Guide Instructions Technical Guide and Review Criteria . HCBS Authorities Information Medicaid Employment Initiatives ACA Premium Assistance Options Money Follows the Person MFP Community First Choice Option CFC State and local initiatives through HCBS and other waivers Extended supports for people not enrolled in HCBS waiver American Rescue Plan Act of 2021 Section 9817 web page provides information on State s approved plans to spend a total of 25 billion in funding on enhancing expanding and strengthening HCBS. Health and Human Services Administration for Community Living ACL Centers for Independent Living Career Exploration Individual Advocacy Job Readiness Training Resume Building Work-based Internship Activities Work Incentives Benefits Counseling Peer Support Assistive Technology 10 Agency Program Ticket to Work University Centers for Excellence in Developmental Disabilities Education Research and Service UCEDD Education Occupational skills training Supportive services Technical Assistance Assistive Technology Mentoring State Grants for Assistive Technology AT Program Public awareness training and technical assistance Information assistance and referral AT device demonstrations and device loans Reutilization of AT devices and durable medical equipment State financing activities Health and Human Services Substance Abuse and Mental Health Services Administration SAMHSA Individual Placement and Support IPS Evidence -based Supported Employment Grants Community Mental Health and Substance Abuse Treatment and Prevention Block Grants Certified Community Behavioral Health Clinic Grants Healthy Transitions Grants Treatment Recovery and Workforce Support Grants Person-centered recovery plans used for Rehabilitative services Supported employment Service coordination Self-directed care Behavioral health care Social Security Administration SSA Ticket to Work Free employment support services provided by an Employment Network or Vocational Rehabilitation agency to Social Security beneficiaries aged 18 to 64 with disabilities Choose Work - Ticket to Wor k - Social Security ssa.gov 11 Agency Program Plan to Achieve Self -Support PASS Excludes income or resources saved for vocationally related objectives that would otherwise be counted in determining SSI eligibility Social Security Online -Plan to Achieve Self-Support PASS ssa.gov SSA Work Incentives Social Security Online - The Red Book - A Guide to Work Incentives ssa.gov Work Incentives Planning Assistance WIPA Free work incentives and benefits counseling services for beneficiaries with disabilities The Work Si te - Work Incentives Planning and Assistance ssa.gov Protection and Advocacy for Beneficiaries of Social Security PABSS PABSS advocates provide legal support advocacy and information to assist beneficiaries to resolve employment-related concerns Labor Employment and Training Administration ETA Workforce Innovation and Opportunity Act WIOA Adult and Dislocated Worker Programs Career and training services available along with supportive services to allow participation in those services. The Adult program prioritizes adults receiving public assistance adults who are low- income and adults who are basic skills deficient. The Dislocated Worker program serves those impacted by layoffs or economic disruptions. Training is often purchased through an Individual Training Account ITA a voucher-like mechanism. Local boards may also deliver class-size trainings in certain circumstances outside the ITA process. Registered Apprenticeships WIOA Youth Services Tutoring study skills training instruction and dropout prevention services Alternative secondary school services and dropout recovery services Paid and unpaid work experiences Occupational skills training Education offered concurrently with workforce preparation and training Leadership development opportunities Supportive services Adult mentoring Follow up services Comprehensive guidance and counseling 12 Agency Program Financial literacy education xEntrepreneurial skills training Job Corps Services that provide labor market information Post-secondary preparation and transition activities Competitive Grant Programs i.e. Pathway Home Young Adult Reentry Partnerships Growth Opportunities YouthBuild Senior Community Service Employment Program Career services Training services Supportive services Paid and unpaid work experiences Education Office of Elementary and Secondary Education OESE Title I ESEA Improving Basic Programs Operated by Local Educational Agencies Counseling College and career awareness and preparation Mentoring Family Literacy Education Office of Career Technical and Adult Education OCTAE State Leadership Activities under Perkins Title I Basic State Grants Recruitment of special populations to enroll in career technical education programs Career technical education programs for students in State schools for the deaf or blind Local Uses of Funds under Perkins V Title I Basic State Grants Career exploration and career development activities Career and technical education CTE programs CTE services required in an individualized education program developed under the Individuals with Disabilities Education Act and services necessary to meet the requirements of section 504 of the Rehabilitation Act of 1973 with respe ct to ensuring equal access to CTE. Continuum of work-based learning opportunities including simulated work environments Industry- recognized certification examinations or other assessments leading toward a recognized postsecondary credential Support to reduce or eliminate out-of-pocket expenses for individuals with disabilities and other special populations participating in CTE including costs associated with participating 13 Agency Program in dual or concurrent enrollment programs or early college high school programs and costs associated with fees transportation child care or mobility challenges Education Office of Special Education Programs OSEP Special Education and Related Services Individualized Education Program Transition Services in Most Integrated Setting Work Experience On-the-Job Training OJT Assistive Technology Financial Capability Education Rehabilitation Services Administration RSA Title IV of WIOA Vocational Rehabilitation Core Services Purchase of services for employment-related objectives Assistive Technology On-the-Job Training OJT Work Readiness Skills Development Internships Trial Work Experiences Work-Based Learning Education Training Work Incentives Benefits Counseling Supported Self and Customized Employment services Job Loss Prevention services Pre-Employment Transition Services for students Housing and Urban Development HUD Family Self -Sufficiency Programs Homeownership Rental Assistance Jobs Plus Initiative JPI program HUD 14 Agency Program oDepartment of Health and H uman Services Centers for Medicare Medicaid Services CMS Administration for Community Living ACL and Substance Abuse and Mental Health Services Administration SAMHSA oDepartment of Educa tion s Rehabilitation Services Administration RSA and Office of Special Educ ation Programs OSEP oSocial Security Admi nistration SSA . Recent Funding Opportunities to Expand Access to CIE for Individuals with Disabilities dol.gov The Fu rther Consolidated Appropriations Act of 2020 FCAA Coronavirus Aid Relief and Economic Security Act CARES the Coronavirus Response and Relief Supplemental Appropriations Act CRRSA the American Rescue Plan Act of 2021 ARPA . i The Workforce Innovation Opportunity Act WIOA Public Law No. 113-128 defines comp etitiv e integrated employment as work that i Is performed on a full-time or part-time basis including self-employment and for which an individual is compensated at a rate that- A Is not less than the higher of the rate specified in section 6 a 1 of the Fair Labor Standards Act of 1938 29 U.S.C. 206 a 1 or the rate required under the applicable State or local minimum wage law for the place of employment B Is not less than the customary rate paid by the employer for the same or similar work performed by other employees who are not individuals with disabilities and who are similarly situated in similar occupations by the same employer and who have similar training experience and skills and C In the case of an individual who is self-employed yields an income that is comparable to the income received by other individuals who are not individuals with disabilities and who are self-employed in similar occupations or on similar tasks and who have similar training experience and skills and D Is eligible for the level of benefits provided to other employees and ii Is at a location - A Typically found in the community and B Where the employee with a disability interacts for the purpose of performing the duties of the position with other employees within the particular work unit and the entire work site and as appropriate to the work performed other persons e.g. customers and vendors who are not individuals with disabilities not including supervisory personnel or individuals who are providing services to such employee to the same extent that employees who are not individuals with disabilities and who are in comparable positions interact with these persons and iii Presents as appropriate opportunities for advancement that are similar to those for other employees who are not individuals with disabilities and who have similar positions. 29 U.S.C. 705 5 and 709 c 34 CFR 361.5 c 9 . 15 ii Butler S. Higashi T. and Cabello M. 2020 . Budgeting to promote social objectives A primer on braiding and blending. Brookings Institution and LEAD Center 2013 . Building a Progressive Vision for a Policy and Service Delivery Framework that Promotes the Effective Leveraging of Resources to Improve Employment Socioeconomic Advancement of Youth and Adults with Disabilities. Office of Disability Employment Policy U.S. Department of Labor. https leadcenter.org resources 2013-lead-center-policy-roundtable-report-making- collabor ation-real iii A Transition Guide to Postsecondary Education and Employment for Students and Youth with Disabilities. Revised August 2020. iv The CMS 1915 c Technical Guide is available at https wms-mmdl.cms.gov WMS help 35 Instructions TechnicalGuide V3.6.pdf v U.S. Department of Labor Office of Disability Employment Policy Employment First State Leadership Mentoring Program found at http www.dol.gov odep topics EmploymentFirst.htm viSee regulations at 34 CFR 300.206 https www.ecfr.gov current title-34 subtitle-B chapter-III part-300 p- 300.206 a vii WIOA section 121 c and h requires that Local Workforce Development Boards sign an MOU with one-stop partners programs on service delivery and cost-sharing within AJCs as described in the WIOA Joint Rule at 20 CFR 678.500 for the core programs administered by the U.S. Department of Labor and in 34 CFR 361.500 and 463.500 for the Vocational Rehabilitation and Adult Education and Family Literacy Act AEFLA programs. viii 29 U.S.C. 721 a 11 A as amended ix RFA and TPA - yourtickettowork.ssa.govx Centers for Medicare Medicaid Services. September 16 2011 . CMCS Informational Bulletin and Technical Guide. https www.hhs.gov guidance sites default files hhs-guidance-documents CIB-09-16-2011 2.pdf https wms-mmdl.cms.gov WMS help 35 Instructions TechnicalGuide V3.6.pdfxi Workforce GPS 2019 . Career Pathways Toolkit A Guide for Systems Development.xii Federal Register. Notice inviting applications for fiscal year FY 2021 for the Disability Innovation Fund Career Advancement Initiative Model Demonstration Project Assistance Listing Number 84.421C. xiii Federal Register 2016 29 U.S.C. 721 a 11 D and 34 CFR 361.22 xiv 34 CFR 300.154 a and b xv Social Security Act codified at 42 U.S.C. 1396a a 25 xvi See 42 U.S.C. 1396a a 25 xvii Centers for Medicare Medicaid Services. September 16 2011 . CMCS Informational Bulletin and Technical Guide. https www.hhs.gov guidance sites default files hhs-guidance-documents CIB-09-16-2011 2.pdf https wms-mmdl.cms.gov WMS help 35 Instructions TechnicalGuide V3.6.pdf. xviii See Social Security Act 1915 c