Strong internal policies and procedures support the TVR staff and participants in the day-to-day administration of services.

While Policies and Procedures may be developed by the TVR agency with feedback and assistance from advisory or community groups and agency participants, they must often be approved by the tribal council or other tribal authority. This may take time, and may require a presentation or explanation by the director to set the context and purpose. It is likely that this same approval must be gained again when changes are made to policies or procedures in the future.

Why Policies and Procedures are needed

Policies establish the rules by which the agency operates and provides services.
Policies describe how the law and regulations apply to the program.
Policies clarify any generalities found in the law and regulations.
Policies instruct TVR staff about the rules of the program.
Policies inform others about how the local officials plan to run the TVR program.
Policies help set the course that applies equally to all who will be served.
Policies are required, as detailed in the Rehabilitation Act, Section 102(d).

Why are both policies and procedures needed?

Policies reflect the “rules” governing the implementation of tribal VR programs and services.

Procedures, on the other hand, represent an implementation of policy and should evolve over time as services are provided, new tools emerge, new processes are designed, and forms change.

Suggested topics for policies and procedures

Policies and procedures can cover a wide range of topics, that might include:

Purpose of the agency
Grant overview (goals, objectives, etc.)
Definitions
Forms
Ethics (CRC, Tribal)
Legal citations
Assurances
Confidentiality
Appeals process
Eligibility determination
Considerations for common disabilities (PTSD, Substance Abuse, etc.)
Order of selection
Assessment
Individualized plan for employment (IPE)
Comparable services and benefits
Types of TVR Services
Agency ownership of purchased services, materials and equipment
Economic need considerations
Case Closure
Case record and retention requirements

Sample topics for a policy and procedure or standard operating procedure manual can be found here.

Quality policies…

Are written in clear, concise, simple language
Are used and updated regularly
Include clear references to the laws, regulations and other guiding materials
Create “ownership” among all TVR staff by including them in the development process, along with the advisory committee and the community

Quality procedures…

Are used and updated regularly
Are tied to policies—it is helpful to make the distinction between policy and procedure clear and explain how the procedure helps the achievement of program goals and objectives and helps ensure staff understanding and compliance
Are developed with the participants in mind
Are understandable—procedures should be written so that what needs to be done can be easily followed by all TVR program staff
When feasible, procedures should offer TVR program staff options—those that are unnecessarily restrictive may limit their usefulness

Policy Topics with References

Community involvement in policy development

The regulations at 34 CFR 371.21(f) require that “American Indians with disabilities living on Federal or State reservations where service programs are being carried out under this Part will have an opportunity to participate in matters of general policy development and implementation affecting vocational rehabilitation service delivery by the tribal vocational rehabilitation program.”

It is up to each grantee to determine how to implement this requirement. There should be a policy describing how the program and/or tribe plans to implement the requirement, which applies not only to program participants but to “American Indians with disabilities.”

Advisory Committee: Some programs choose to form an advisory committee/board as a way to include community members, organizational allies and American Indians with disabilities in the development of program policies and in program provision.

Subjects referenced in 34 CFR 371.21, such as the eligibility decisions being made only by a program representative, order of selection, the definition of the program service area, and the consideration of comparable services and benefits.
Subjects referenced in 34 CFR 371.41 related to allowable costs, such as providing cultural and traditional services, program administration and staff development.
TVR services for individuals, as described in [Section 103 of the Rehabilitation Act].
TVR services for groups of individuals, as seen at 34 CFR 361.49.

Considerations for Developing Policies and Procedures

These two manuals, the New Director's Manual for Operations and the New Director's Orientation Manual, developed by CANAR, provide information about the TVR process and considerations when providing TVR services that may be helpful when deciding what types of policies and procedures to create for the agency.

Sample Policies and Procedures

Please find below sample policies and procedures to review when writing new policies and procedures or modifying existing sets.

Developing Program Forms

A new program will require forms that will be used in the TVR process. Forms would include a program application, an intake, referral forms, a release of information (ROI) form, an Individualized Plan for Employment (IPE), a plan amendment, and closure forms, among others. Forms can be kept in paper files or completed, signed and maintained electronically. Some sample program forms and program information can be found below.

Program Information and Outreach

Application and Intake

Assessment and Eligibility

IPE Development

Provision of Services and Case Closure

Other sample forms can be obtained from other TVR programs, from the AIVRTTAC, the TVR Institute, or state agencies. These can be modified to meet specific agency needs and formats.