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Policy Guide for Pre-Employment Transition Services

Revised: September 2022, April 2024


This policy serves as guidance to Division of Vocational Rehabilitation (DVR) staff and describes statewide service provision to students with disabilities, specifically regarding pre-employment transition services (Pre-ETS), and to youth with disabilities, specifically regarding limitations on subminimum wage employment (Section 511). This guide also contains policy on providing Pre-ETS to potentially eligible students as defined by the Workforce Innovation and Opportunity Act, or WIOA.


WIOA was signed into law on July 22, 2014. Title IV of WIOA reauthorizes the Rehabilitation Act of 1973 and its amendments. This legislation created significant changes requiring vocational rehabilitation (VR) programs to spend 15 percent of their annual budgets on the provision of required Pre-ETS to students with disabilities, including potentially eligible students. Students provided Pre-ETS in collaboration with local schools following the Individual with Disabilities Education Act (IDEA) will be better prepared for employment success upon completion of an educational program.

Additionally, VR programs have responsibilities to limit the flow of youth with disabilities into work settings where they are paid less than minimum wage (employer use of a subminimum wage license, a 14c holder) and to provide opportunities for competitive, community-integrated employment.


Wisconsin DVR has a strong history of working with students with disabilities and working collaboratively with schools on students' transition goals. We have many resources for staff working with students and youth with disabilities who want to find competitive and integrated employment. Since WIOA's inception, Wisconsin's VR program has worked to follow the requirements set forth by WIOA.

WIOA Student/Youth Descriptions

Provision of Pre-ETS

Pre-Employment Transition Services (Pre-ETS)

Pre-employment transition services include the following:

Job Exploration Counseling

Work-Based Learning Experiences

Counseling on opportunities for enrollment in comprehensive transition programs or postsecondary education programs, which can include, but are not limited to:

Workplace Readiness Training - Development of social skills and independent living skills necessary for employment. Can be provided generally in a classroom setting or tailored to an individual's needs within a training program provided in an educational or community setting.

  • Can include, but not limited to:
    • Learning communication and interpersonal skills
    • Understanding employer expectations for punctuality and performance, appropriate behaviors and dress as well as other “soft” skills necessary for employment, e.g., Skills to Pay the Bills classes
    • Financial literacy, including benefits planning services
    • Orientation and mobility skills to access workplace readiness training or to learn to travel independently
    • Job-seeking skills
    • Supportive services of transportation and personal assistance services can be provided as Pre-ETS if needed to workplace readiness training
    • Auxiliary aids/services to support Workplace Readiness Training
  • Self-advocacy which may include peer mentoring - Instruction may be conducted in generalized classroom settings or as an arrangement of individual opportunities. Self-advocacy can include, but is not limited to:

    The supportive services of systematic instruction, transportation and personal assistance can be provided in conjunction with and in supportive of the 5 core Pre-ETS categories of services:

    Auxiliary aids/services can be provided to support participation in Pre-ETS for students with sensory and/or communicative disabilities, impairments, or barriers:

    Tracking Pre-ETS Expenditures

    Outreach and Coordination Activities

    Referrals/Applications of Students Applying to DVR (Regular Case Record)

    Potentially Eligible Students and Process (Potentially Eligible Case Record)

    Student and Youth Requirements for Section 511

    Writing the Individualized Plan for Employment (IPE) for High School Students

    Use of Projected Post-School Employment Outcome for IPE goal

    Best Practices for Working with Students

    DVR Resource Documents: Students and Youth with Disabilities