A tenth grader's IEP has a line that says "Pre-ETS as available." The parents ask the teacher what it means. The teacher says the vocational rehabilitation agency handles it, and that someone will call. Months pass. Nobody calls.
Pre-employment transition services are a part of the VR program designed for students. They are easy to miss because they sit between the school and an outside agency. This guide explains what the federal regulation says, what the five required activities are, and how to ask for them. It is general information, not legal advice, and your state agency decides how services are delivered.
What they are
Section 361.5 defines pre-employment transition services by pointing to the required and authorized activities listed in section 361.48(a). So the definition is the list. Section 361.48(a) says the state must make sure that its VR unit, in collaboration with the local school districts involved, provides or arranges these services for students with disabilities who need them.
The regulation says they must be made available statewide to all students with disabilities who need them, regardless of whether the student has applied for or been determined eligible for VR services. That is an unusual feature, and it is why a student can start before ever filling out a VR application.
The five required activities
| Activity | What it means | An invented example |
|---|---|---|
| Job exploration counseling | Learning about kinds of jobs and what they involve | A counselor helps a student compare three jobs near home and what each requires |
| Work-based learning experiences | Learning through real work, in or after school or outside the school setting, including internships | A student works after school for six weeks at a pet store with a job coach |
| Counseling on postsecondary opportunities | Information about comprehensive transition programs and college programs | A group session on how college disability offices work |
| Workplace readiness training | Social skills and independent living skills for work | A class on being on time, working with a team, and getting to work |
| Instruction in self-advocacy | Learning to speak up for needs and choices, including person-centered planning and, in some cases, peer mentoring | A student practices asking a supervisor for a task to be explained again |
The regulation adds that work-based learning should be provided in an integrated environment in the community to the maximum extent possible. See job shadowing and work experience.
Authorized activities
After the required activities are provided, the regulation lets the agency use remaining funds for other things that improve the move from school to postsecondary education or work. Examples listed include strategies that improve independent living and inclusion, strategies for people with intellectual and significant disabilities, training for VR counselors and school transition staff, and coordination with schools' transition services under IDEA. Those items are mostly about systems, not about an individual student's services, and families do not usually need to track them.
Which students
Section 361.5 defines a student with a disability for these purposes. The person must be in a secondary, postsecondary, or other recognized education program. The person must be within an age range: not younger than the earliest age the state provides transition services under IDEA, and not older than 21, unless the state sets a higher maximum age for IDEA services. And the person must be eligible for and receiving special education or related services under IDEA Part B, or be a student with a disability under Section 504.
Because the age floor depends on the state, ask your VR agency for the youngest age at which a student can receive Pre-ETS in your state.
How Pre-ETS fit with the school
| School transition services | Pre-ETS | |
|---|---|---|
| Legal home | IDEA, in the IEP | The VR regulation, 34 CFR 361.48 |
| Provided by | The school district | The state VR agency or its contractors, working with schools |
| Based on | The student's IEP and postsecondary goals | The five required activities and the student's needs |
| Application | Part of the IEP process | No VR application required |
| Connection | The IEP can list the activities | The regulation says the VR agency coordinates with the school's IDEA transition services |
The regulation says local VR offices attend IEP meetings for students with disabilities when invited, and work with schools to coordinate pre-employment transition services. Section 300.321(b) of the IDEA rule says that, to the extent appropriate and with the consent of the parent or the student who has reached the age of majority, the school must invite a representative of any participating agency likely to be responsible for providing or paying for transition services. See interagency collaboration.
Asking for Pre-ETS
Tracking what happens
Keep a simple log: the activity, the date, who provided it, and what the student did and said afterward. A short entry such as "Job exploration session, Oct 12, with counselor; student interested in animal care and food service" becomes useful evidence for the next assessment and goal. See age-appropriate transition assessments. Ask that the activities be listed among the transition services in the IEP, so that the school and agency can see the same picture.
When services do not start
If months pass and nothing happens, start with a polite email to the school and the VR office asking for a date. Ask who is responsible for the next step. If the agency says it has no capacity, ask what the state policy says about students and whether there is a waiting list. If the school says the agency owns it, ask the transition coordinator to raise it with the agency. The VR agency's own complaint and appeal processes are described in notices the agency gives. Keep a record of requests and replies.
Pre-ETS mix-ups
- Waiting for a VR application. The regulation does not require one for Pre-ETS.
- Assuming the school does it. The state VR agency provides or arranges it, working with schools.
- Counting only the paid-work activity. Job exploration, readiness, self-advocacy, and counseling on postsecondary options are also required activities.
- Not writing it in the IEP. The activities should show up in the transition services.
- Ignoring the age floor. It depends on the state.
For the larger picture of the agency, see vocational rehabilitation basics. Terms are in the glossary.