410.00 Non-Degree Training at Trade, Business and Other Schools Policy

(Revised December 2019)

Table of Contents

Purpose

ACCES-VR provides services that assist participants to meet their employment outcomes.  Non-Degree Training at a trade, business school or other schools may be provided to a participant when:

  • The participant and the ACCES-VR counselor both agree that Non-Degree Training is needed to achieve the employment outcome; 
  • The Individualized Plan for Employment (IPE) contains an employment goal requiring Non-Degree Training;
  • The training is consistent with the participant’s strengths, capabilities and informed choice; and
  • The training will result in the participant being able to be directly employed upon completion.

Definitions

Available Resources:  This is the amount of money that a participant has available to pay toward ACCES-VR Financial Need-Based Services, such as training at a non-degree trade, business or other school.  This amount is identified by a calculation known as the Participant Contribution in the Cost of Services.  This is also known as a Spend Down or the amount of money that the participant contributes towards ACCES-VR Financial Need-Based Services.

Comparable Benefits and Services: These are services or financial assistance from a source other than ACCES-VR that will meet, in whole or in part, the cost of vocational rehabilitation services provided by ACCES-VR.  (see 208.00 Comparable Benefits and Services Policy).

Eligible Individual:  An eligible individual is a person who has applied to ACCES-VR for services and it has been determined that they have a physical, developmental or behavioral impairment that is a substantial impediment to employment, can benefit in terms of achieving an employment outcome with their strengths, priorities, concerns, abilities, interests, and informed choice and requires vocational rehabilitation services to prepare for, secure, retain, advance in, or regain employment. 

Enrollment Agreement:  This is a contract signed between the student and a non-degree granting proprietary school. The agreement specifies the conditions under which the school will provide instruction to the student. The agreement is signed and dated by the student and the licensed agent of the school. Review a sample enrollment agreement.

Financial Need:  This is a threshold that is established that identifies when ACCES-VR may contribute funding toward some, but not all, vocational rehabilitation services.  This threshold is 300% of the Federal Poverty Level for a household (see 1125.00 Financial Need Review Policy).

Financial Need-Based Services: Some of ACCES-VR’s services, such as training at non-degree trade, business or other schools, require participants to meet ACCES-VR’s financial need.   ACCES-VR uses a calculation of Participant Contribution in the Cost of Services and some participants may be required to contribute to the cost of these services, based upon their available resources (see 1125.00 Financial Need Review Policy).

Individualized Plan for Employment (IPE):  The IPE is ACCES-VR’s written plan, agreed upon by the person and the ACCES-VR counselor, that identifies an employment outcome, the services that will be provided to achieve the employment outcome, the timeframes for the services, and the steps that will be used to measure progress toward the employment outcome. The IPE must be written within 90 days from the date of eligibility determination.

Non-Degree Training:  This is formal instruction (i.e. academic coursework, required internship and/or externship) that provides specific occupational knowledge and skills for a professional, semi-professional, technical, clerical, agricultural occupation, or for a skilled or semi-skilled trade.  The training received must provide the participant with the occupational knowledge and skills necessary for employment directly upon completion of the program. Note:  Non-Degree Training received at trade, business and other schools should also prepare the participant to take appropriate examination/licensure tests, if required, for employment.

Participant: An individual with a disability who has been determined eligible for ACCES-VR vocational rehabilitation services, has an approved and signed Individualized Plan for Employment (IPE), and receives a service from ACCES-VR on or after the date that the IPE is signed.

ACCES-VR Approval of a Non-Degree Training Program

Non-Degree Training may be provided by trade and business schools licensed or registered under Article 101 of the Education Law and Part 126 of the Regulations of the Commissioner of Education or other similar programs that provide vocational training. The New York State Education Department's (SED) Bureau of Proprietary School Supervision (BPSS) oversees and monitors all non-degree granting private proprietary schools in New York.  Colleges and universities providing non-degree programs (e.g. certificate programs) must be accredited by a regional accrediting body recognized by the U.S. Secretary of Education or approved by the New York State Board of Regents and meet Section 50.1(j) of the Regulations of the Commissioner of Education. 

Additional ACCES-VR vendor requirements for Non-Degree Training provided by trade, business and other schools, including colleges and universities, are covered in the Trade, Business, and Other Schools Requirements section of this policy.

ACCES-VR Process for Determining Contribution to Non-Degree Training

ACCES-VR completes a two-step process to determine its contribution, if any, toward Non-Degree Training (see 1125.00 Financial Need Review Policy). 

1. Comparable Benefits

All comparable benefits must be utilized prior to ACCES-VR funding Non-Degree Training services.  The participant must seek out and apply for all available comparable benefits and inform the ACCES-VR counselor about awards and changes to awards. Examples of comparable benefits that may be used for non-degree training include New York State Tuition Assistance Program, or TAP (for participants enrolled in programs with at least 1,440 instructional hours at private business schools or certificate programs at a college or university) and Pell grants (for certificate programs at a college or university or for participants enrolled in programs that are accredited by:  National Association of Trade and Technical Schools, Accrediting Council for Continuing Education and Training and licensed by SED, Accrediting Commission of Career Schools and Colleges of Technology, and Association of Independent Colleges and School).   Note: Comparable benefits must also be secured for all services, regardless of Financial Need (see 208.00 Comparable Benefits and Services Policy).

2. Determination of Financial Need

ACCES-VR funding of the following Non-Degree Training at Trade, Business or Other Schools is contingent upon Financial Need:

  • Tuition
  • Required Fees
  • Required Textbooks and Materials
  • Required Equipment and/or Tools
  • Required Clothing
  • Assistive Technology
  • Transportation

All participants in need of Non-Degree Training must complete a Financial Need Review at least annually or sooner if there is a change in their financial status.  ACCES-VR funding of Non-Degree Training is contingent upon the determination of a participant’s Financial Need and available resources, when applicable.  Based upon the Financial Need Review (see 1125.00 Financial Need Review Policy), it will be determined if the participant:

  • Is exempt from consideration of available resources as someone who receives public assistance.  If the participant meets these criteria, then ACCES-VR may contribute to the cost of the Non-Degree Training up to, but not exceeding, the maximum allowances identified in this policy.
  • Meets Financial Need and has no available resources, based on the calculation of participation in the cost of services.  If the participant meets these criteria, ACCES-VR may contribute to the cost of the Non-Degree Training up to, but not exceeding, the maximum allowances identified in this policy.
  • Does not meet Financial Need because they have available resources.  A participant’s available resources are identified by the calculation of participation in the cost of services.  When the participant has available resources, they are then required to contribute to the cost of the Non-Degree Training.  The participant’s contribution to Non-Degree Training is known as a Spend Down.  Once the participant has agreed to their contribution and the Spend Down is met, the participant will then meet the Financial Need criteria and ACCES-VR may contribute to the cost of the Non-Degree Training up to, but not exceeding, the maximum allowances identified in this policy.   Note: When the participant’s identified Spend Down amount is not met, ACCES-VR will not contribute to the cost of the Non-Degree Training.

The Role of the ACCES-VR Counselor

The ACCES-VR counselor and the participant both have responsibilities in maintaining ongoing communication about expectations, both academic and financial, and ensuring the accurate calculation of ACCES-VR’s contribution, if any, to Non-Degree Training. 

The ACCES-VR Counselor:

  • Discusses with the participant comparable benefits such as grants and the associated eligibility requirements.
  • Reviews information that the participant is meeting academic standards as established by the Non-Degree Training program and retaining financial aid eligibility.
  • Maintains contact with the Non-Degree Training program’s financial aid office or financial aid officer, as needed, to ensure the participant is receiving consideration for financial aid.
  • Ensures that financial aid is applied to all direct costs including textbooks and required materials.

The Role of the ACCES-VR Participant

The participant must seek to secure all available financial aid, in whole or in part, from other sources. ACCES-VR’s contribution is contingent on the participant’s timely application for all available financial aid. The participant must:

  • Possess the minimum skills and abilities to complete the course requirements before beginning training from a non-degree trade, business, or other school.
  • Meet the same enrollment, admission, attendance, academic progress and completion standards as outlined by the school for all students.  Note:  If the entrance requirements include aptitude testing, the participant is required to take and achieve a satisfactory grade for admission.  School-provided reasonable accommodation(s) may be utilized, when appropriate. 
  • Maintain the academic performance standards of the school, remain in good academic standing, and finish incomplete courses.  Note:  ACCES-VR may allow for up to 50% above the expected duration to complete a program, when appropriate. For example, for programs that typically take six months to complete, the participant may be allowed to complete the program in nine months.  Programs that typically take one year to complete, the participant may be allowed to complete the program in one and a half years.
  • Provide the ACCES-VR counselor with written information from the non-degree training program regarding the academic standards that must be met to remain in good standing at the school and to retain eligibility for financial aid, when applicable.
  • Apply for all financial aid and available benefits within required timeframes including, but not limited to completing the Free Application for Federal Student Aid (FAFSA), when applicable. This single application is required to apply for the Pell grant and for other financial aid, including TAP.  Note:  TAP and Pell are grants, not student loans that require repayment.
    • Provide the ACCES-VR counselor with verification of application for financial aid and awarded amounts.
  • Inform the ACCES-VR counselor of changes to awards or changes in financial status and provide documentation that verifies these awards or changes.
  • Register with Selective Service, when applicable.  Federal financial aid requires registration with the Selective Service System. If a participant is not eligible to receive financial aid due to failure to register for Selective Service, he must register with the Selective Service prior to being eligible for ACCES-VR funding for Non-Degree Training. Participants must provide documentation that they have registered and are eligible for financial aid.
  • Provide the ACCES-VR counselor with grades and a copy of documentation of program completion (e.g. certificate, license).

Note:  Default of a Student Loan:  If a participant is in default of a student loan or has not provided a refund for a grant such as TAP or Pell, financial aid (including Pell and TAP) will not be available. ACCES-VR is prohibited from paying for any training or related services for a non-degree trade, business or other school that receives TAP and/or Pell for a participant who owes a refund on a grant or is in default of a student loan unless maximum effort has been made to resolve the default. Maximum effort means that the participant must work out a satisfactory repayment plan with the Higher Education Services Corporation (HESC), lending institution or grantor and re-establish eligibility for financial aid.  The participant must provide documentation from HESC that a repayment plan has been established and eligibility for financial aid is restored.  ACCES-VR may then consider funding Non-Degree Training once eligibility for financial aid has been re-established.

Note:  Controlled Substance Rule:  Participants who have been convicted under Federal or State law of illegal sale or possession of a controlled substance lose eligibility for Pell grants for a period of time depending on the offense. Eligibility for Pell grants may resume upon successful completion of a drug rehabilitation program. ACCES-VR participants affected by this law, who may be seeking to attend Non-Degree Training at a program that receives Pell, must apply for Pell funds to determine eligibility status.  If the participant is temporarily ineligible for Pell grants, ACCES-VR will continue to provide the required services necessary to attain an employment outcome, including training at non-degree trade, business and other schools that receive Pell grants. 

ACCES-VR Contribution and Responsibility

ACCES-VR Maximum Contribution to Non-Degree Training Expenses

As outlined above, for participants who meet Financial Need (except for Cost Effective Skills Training, see below) ACCES-VR may pay for the following expenses after application of all comparable benefits, up to the identified maximum amounts:

  • Tuition:  Maximum Tuition:  ACCES-VR may pay for tuition only at the published rate in the enrollment agreement, catalog, or brochure up to a maximum of $10,000.  Note:  ACCES-VR will support the most cost-effective program including comparable programs at New York State public colleges and universities when the available courses and programs meet the training needs of ACCES-VR participant.
  • Required Fees:  ACCES-VR may pay up to a maximum of $300 for required fees during the training program. Examples of fees include, but are not limited to, registration fees, lab fees, licensing and/or certification fees.
  • Required Books and Materials:  ACCES-VR may pay up to a maximum of $500 for required textbooks and materials and other items needed to participate in a specific course or program. ACCES-VR will not pay for typical expendable supplies (i.e. items that cannot be reused) such as paper, pencils and notebooks, unless documentation is provided demonstrating specific requirements for a course and/or they are necessary to address a disability-related limitation.

Participants are expected to use cost-saving strategies, whenever possible, in the purchase of textbooks and materials such as purchasing used textbooks and selecting bookstores with the most competitive pricing.Note:  When a participant is using ACCES-VR funding to purchase required books and materials from an online source, the most cost-effective shipping method must be used. Purchasing items with ACCES-VR funds that are not required books and materials .Should a participant use funds inappropriately and not follow these requirements, ACCES-VR will seek reimbursement for the costs of non-required books and materials and may re-evaluate future funding for Non-Degree Training.

  • Required Equipment and/or Tools:  ACCES-VR may pay up to a maximum of $1,000 for required equipment and/or tools for the non-degree training program during the training period.  Required equipment and/or tools are not expendable, may be re-used, may be provided at the lowest possible cost, and should not be included in tuition costs.

Note:  Equipment and/or tools purchased by ACCES-VR are the property of ACCES-VR until released to the participant upon successful employment after 90 days. If the participant does not achieve their employment outcome, the ACCES-VR funded equipment and/or tools must be returned to ACCES-VR.

  • Required Clothing:  ACCES-VR may fund up to a maximum of $300 for required articles of clothing that are necessary for the training program.   This includes clothing that may be a required uniform or used for safety or performance that are not expendable.  Note:  ACCES-VR may provide funding toward clothing outside of non-degree training, when appropriate.  However, ACCES-VR may only provide up a $300 maximum for clothing, regardless of reason, for the lifetime of the person’s case. 

Note:  ACCES-VR reserves the right to purchase required books and materials, required clothing, and required equipment and/or tools, when it is cost-effective, from any ACCES-VR approved vendor, not only the vendor providing the training to the participant.

Note: An approved enrollment agreement must include New York State Education Department’s Bureau of Proprietary School Supervision (BPSS) stamp with signature or be accessible on the BPSS public website. ACCES-VR reviews the participant’s enrollment agreement, when applicable, and verifies all costs associated with the Non-Degree Training program prior to authorizing services.

ACCES-VR Contribution Toward Other Non-Degree Training Related Expenses

As outlined above, for participants who meet Financial Need, ACCES-VR may pay for the following expenses after application of all comparable benefits:

Assistive Technology: If the participant requires specific assistive technology devices to make use of purchased books and materials, ACCES-VR may purchase limited to low cost adaptive items such as, but not limited to, electronic text players, spellcheckers and note-taking devices.

Additional materials and equipment required by the participant to address disability-related needs are considered separately under Rehabilitation Technology (See 1370.00 Rehabilitation Technology Policy).

Transportation:  All transportation, including special transportation, will be authorized separately consistent with the ACCES-VR Transportation Policy (see 1355.00 Transportation Services Policy).  Transportation may only be for the dates the participant is in Non-Degree Training and must be the most cost-effective method of transportation.  When the participant will be living away from home, transportation will not be authorized for travel to and from the non-degree training program. Note:  ACCES-VR may fund a maximum of two (2) round trips per academic year to/from the training program for participants who attend trade, business or other schools away from their primary residence.  This transportation can only be used to travel to and from the non-degree training program that the participant is attending.   

Cost-Effective Skills Training and Non-Degree Training at BOCES

Cost-Effective Skills Training

Cost-Effective Skills Training must meet the following criteria and ACCES-VR’s maximum contribution:

  • The participant does not meet financial need; and
  • The training program is a non-degree program and is no more than 12 months in duration.  Note:  ACCES-VR may allow up to two years for programs that operate on half-day sessions for participants whose disabilities require part-time attendance; and
  • The maximum allowable cost to ACCES-VR for the program including, but not limited to, tuition, books and fees, and required tools and/or equipment for non-degree trade, business or other schools and colleges does not exceed $8,000 (or the balance of cost after TAP and/or Pell grants are applied, if applicable, and less than $8,000).

To provide Cost-Effective Skills Training, all program costs must be documented in the Individualized Plan for Employment (IPE).  Any costs in excess of the $8,000 maximum contribution limit will not be paid by ACCES-VR.

Note: If financial need-based services are also planned in addition to Cost-Effective Skills Training, a financial need review and a participant contribution in the cost of services calculation must be completed.

Non-Degree Training at BOCES

Non-Degree Training at BOCES must meet the following criteria and ACCES-VR’s maximum contributions:

  • For participants who meet financial need:  ACCES-VR may pay up to the full tuition charged by BOCES and up to the maximum contributions, identified in this policy, towards required fees, required books and materials, required clothing, and required equipment and/or tools.
  • For participants who do not meet financial need:  ACCES-VR may only pay up to the full tuition charged by BOCES.  Any costs in excess of the full tuition, including but not limited to required fees, required books and materials, required clothing and required equipment and/or tools, will not be paid by ACCES-VR.

Trade, Business and Other Schools’ Requirements

Schools in New York State must comply with the appropriate state laws, regulations and governing bodies to be approved as an ACCES-VR vendor. ACCES-VR requires that business, trade, and other schools, including colleges and universities, meet the standards set forth by New York State’s Education Department (SED), or the appropriate regulatory agency or vocational rehabilitation agency of the state where the program is located.

Programs Accredited by a Regional Accrediting Body

Colleges and/or universities providing non-degree programs must be accredited by a regional accrediting body recognized by the U.S. Secretary of Education or approved by the New York State Board of Regents and, when applicable, any other oversight agencies.  Colleges and universities must also meet Section 50.1(j) of the Regulations of the Commissioner of Education defining certificate programs. 

Programs Overseen by the New York State Education Department

Business Schools, Trade Schools and Computer Training Facilities must be licensed or registered by the New York State Education Department's Bureau of Proprietary School Supervision (BPSS) to ensure that appropriate standards are met. The BPSS is required by the Education Law and the Regulations of the Commissioner of Education to oversee and monitor all non-degree granting proprietary schools in New York State.

Note: Trade, business and other schools not located in New York State must be approved by the vocational rehabilitation agency or appropriate state regulatory agency of the state where the program is located.

BOCES are established under Education Law and approved by SED’s Office of Elementary, Middle, Secondary and Continuing Education.

Schools that provide non-degree programs that lead to a profession requiring licensure must be approved by SED’s Office of the Professions.

Correspondence and online training programs that are physically located in New York State must be approved by BPSS. If they are physically located outside of New York State, the program must be approved by the vocational rehabilitation agency or appropriate state regulatory agency of the state where the program is located.

Programs Overseen by Other State or Federal Agencies

For programs that are monitored by other State or Federal Agencies such as:

  • Flight schools must be approved by the Federal Aviation Administration (FAA).
  • Driver training schools must be approved by the Department of Motor Vehicles.
  • Truck driver training schools must be approved by the Department of Motor Vehicles.
  • Security Guard training schools must be certified by the Division of Criminal Justice Services.
  • Insurance Agent training schools must be licensed by the Department of Insurance.
  • Training programs requiring education and training provider certification by the Office of Addiction Services and Supports (OASAS) per the Credentialing of Addictions Professionals Regulations, Part 853.

Other Training Programs

Schools that do not have a New York State license or certificate must be approved by ACCES-VR’s Central Office prior to authorizing services.

Trade, business and other schools not located in New York State must be approved by the vocational rehabilitation agency or appropriate state regulatory agency of the state where the program is located.

Trade, Business, and Other Schools’ Responsibilities

Schools approved to provide ACCES-VR Non-Degree Training services must have the following information available and provided upon request.  Note:  Schools licensed by the New York State Education Department will have an approved catalog, approved enrollment agreement, and placement statistics that should contain the following information:

  • The name(s) of the trade, business or other school and its governing body, officials and faculty;
  • A calendar showing legal holidays, beginning and ending dates of instruction such as each quarter, term, or semester, and other important dates;
  • The enrollment dates and designation of the program or course as diploma or certificate;
  • An attendance policy covering leaves, absences, skipped class, makeup work, tardiness and interruptions for unsatisfactory attendance;
  • A policy about standard of progress required of the student by the institution defining the grading system of the institution, the minimum grades considered satisfactory, conditions for interruption of training for unsatisfactory grades or progress, a description of the probationary period, if any, allowed by the institution, and conditions for re-entrance for students dismissed for unsatisfactory progress. The institution will make progress records maintained by the institution and furnished to the student available for review;
  • A policy about student conduct and conditions for dismissal for unsatisfactory conduct;
  • The schedule of all fees including:  Tuition rates, required fees, required books and materials, required equipment and/or tools, required clothing, student activities, service charges, rentals, deposits and all other charges;
  • A description of the available space, facilities and equipment;
  • A brief description of each course showing entrance requirements, subjects or units and the approximate time and clock hours to be spent on each subject or unit;
  • A policy about granting credit for previous educational training;
  • Financial assistance information to be disseminated to enrolled and prospective students, if appropriate;
  • Facility and program accessibility information, including accommodations and support services available for students with disabilities; and
  • Instruction methods including the availability of alternative teaching methods such as taking classes online or distance learning.

Upon a participant’s successful completion of a non-degree program that results in a certificate, license, credential or any other documentation of completion, the non-degree trade, business or other school must send a copy of this documentation to the participant’s ACCES-VR counselor.

Refund Policy

For programs regulated by the New York State Education Department (SED), such as those licensed by BPSS, the refund policy will be determined by the methodology established by SED through the enrollment agreements or other similar documents. For programs not licensed by SED, the guidelines for participant withdrawal, dismissal or interruption and refunds should be clearly established prior to enrollment.

Waiver:  Exception to Limits on Cost

Should a participant believe that there is a need to exceed ACCES-VR’s maximum contribution toward Non-Degree Training, the participant may request the ACCES-VR counselor to submit a waiver request.  The waiver request must be submitted by the ACCES-VR District Office to the Central Office Waiver Committee (see 100.00 Participant Involvement Policy).  Submission of a waiver request does not guarantee approval. The Central Office Waiver Committee will review the following: ACCES-VR’s Non-Degree Training at Trade, Business and Other Schools Policy and all related policies, spending limits for Non-Degree Training, justification for the waiver request, and the participant’s finances (including their entire financial aid package (e.g. grants, loans and scholarships) not considered a comparable benefit). 

Financial Commitments

Individuals should not take on any financial commitments with the anticipation of ACCES-VR funding for services.  Individuals are required to wait until the ACCES-VR counselor provides an ACCES-VR finalized IPE for services and ACCES-VR’s financial contribution towards services before they incur any expenses or costs.  The individual will be responsible for all expenses or costs incurred before receipt of ACCES-VR’s finalized IPE and approval for financial contribution towards ACCES-VR services. 

Related Policies:

100.00 Participant Involvement
208.00 Comparable Benefits and Services Policy
405.00 College and University Training Policy
1125.00 Financial Need Review Policy