ARTICLE
25 July 2025

State Strategies To Expand Integrated Employment For Individuals With Intellectual And Developmental Disabilities

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Manatt, Phelps & Phillips LLP

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Employment plays a vital role in enhancing independence, economic self-sufficiency, social inclusion and overall quality of life for people with intellectual and developmental disabilities (I/DD).
United States Oregon Tennessee Employment and HR

Employment plays a vital role in enhancing independence, economic self-sufficiency, social inclusion and overall quality of life for people with intellectual and developmental disabilities (I/DD).1 Beyond providing income, employment offers individuals the chance to build relationships, contribute to their communities, and develop both personally and professionally. The Americans with Disabilities Act (ADA) laid the foundation for promoting access to employment by prohibiting discrimination and requiring reasonable accommodations. Building on this, more recent policies—such as the Workforce Innovation and Opportunity Act (WIOA) and the Home- and CommunityBased Services (HCBS) settings rule—have advanced efforts to expand competitive integrated employment (CIE) for individuals with I/DD, in particular.

CIE stands in contrast to more segregated day programs and sheltered workshops by promoting jobs in which individuals with I/DD work in inclusive settings, are paid at least minimum wage, perform duties and receive the same benefits as peers without disabilities with similar duties and experience, and have equal opportunities for advancement.2 As part of this paradigm shift, many states adopted "Employment First"—a national framework that promotes CIE as the preferred outcome for all individuals, including those with significant disabilities. This approach calls on publicly funded systems to align policies, regulations, and funding to support CIE as the primary goal of day and employment services.3

While there is broad recognition of the importance of promoting CIE, nationally less than a quarter of individuals with I/DD participate in CIE, with considerable variation across states.4 States with high participation rates—such as Washington (83%), Oklahoma (69%) and Oregon (58%)—have made considerable progress in recent years to proactively engage and support individuals with I/DD in accessing CIE opportunities.5 This issue brief highlights key trends and five best practices in promoting access to CIE, drawn from research on leading states' approaches, including Colorado, Oklahoma, Oregon, Tennessee, Washington and Wisconsin. While not all of these states have yet achieved high rates of employment, they have deployed innovative practices that can inform how other states can approach employment supports.

Best Practice #1: Early and Proactive Engagement in Individualized Career Planning and Exploration

A distinguishing characteristic of high-performing employment programs is the emphasis on early and proactive engagement of individuals with I/DD in employment-related goal setting and planning. States that perform well in employment outcomes typically start career conversations in early childhood and continue them more intentionally during the high school years, ensuring that individuals and families are equipped with information, expectations and opportunities before adulthood. This often includes:

  • Broad Access: The Employment First framework was founded on the core belief that all individuals regardless of the type or complexity of their disability are capable of full participation in CIE with the right supports. Accordingly, many states have started to dismantle systemic barriers to employment, such as rigid job readiness criteria that often exclude individuals from employment supports and competitive job opportunities. At the same time, states have increased adoption of individualized approaches that emphasize customized supports and accommodations. This shift has empowered more individuals with disabilities to pursue employment and explore long-term career paths. More than 35 states have taken steps toward implementing the Employment First framework through legislation, executive orders and other state policies. Of those, at least 21 states have enacted formal policies declaring CIE as the preferred outcome for individuals with disabilities.6
  • Robust Job Exploration Supports: Many states require and train case managers to support career exploration and goal setting from an early age, provide needed information for individuals and families to make informed choices, and coordinate across needed programs and services. States generally start these efforts as early as possible to develop goals and expectations around education and career, and to provide support with pre-employment and employment services during transition age years. For example, Tennessee integrates employment discussions into the Individual Support Plan process, ensuring employment considerations are standard across the board.7 Other states, like Oregon, require and train case managers to engage individuals in deeper conversations about employment when the individual decides not to pursue employment, including discussing concerns and barriers to employment. Recognizing that some individuals require more support than what a case manager can provide, some states have created "exploration and discovery" services delivered by qualified providers, which are frequently paired with benefits counseling, to help individuals get on a career path.
  • Individualized Career Plans: States place strong emphasis on developing, implementing and continuously monitoring individualized plans for employment that are tailored to individual needs and goals. In many cases, states incorporate career planning in the federally required person-centered plan template to encourage case managers to have career discussions with individuals, identify barriers and explore solutions. Some states have gone a step further by requiring quality assurance reviews of career plans to ensure that they are complete and meaningful. In Washington, the state requires case managers to reassess employment goals bi-annually. If individuals remain unemployed for over a year, detailed follow-ups and goal reviews are triggered.8

Best Practice #2: Robust Employment Supports Throughout an Individual's Employment Journey

In most cases, leading states have defined and deployed a set of comprehensive employment services; sequencing services as individuals progress through their career journeys, and offering ancillary supports (e.g., transportation, technology) to ensure individuals are supported holistically to work. Additionally, some states have enacted policies to allow individuals to return to needed supports when their circumstances change, such as a change in jobs, career path or career advancement. Common program features include:

  • Clearly Defined Service Package for Each Stage of an Individual's Employment Journey: Many states provide a package of employment services throughout every stage of the employment journey, including career exploration, job development, benefits counseling and long-term supports. Common features include clear service definitions and expectations; well-defined roles for partner agencies; and close coordination across all agencies involved in serving shared clients (such as state and local I/DD programs, education and vocational rehabilitation). For example, Tennessee provides clearly defined services for both traditional employment and self-employment. The state's service package includes both commonly used services such as job development and job coaching, as well as additional supports like early exploration and discovery, individualized planning, business startup assistance, benefits counseling, and co-worker supports and career advancement.9 Similarly, Wisconsin established a comprehensive set of services, coupled with partnerships with employers to incentivize "fading" of state-provided supports over time (i.e., gradual reduction in supports) as individuals settle into their jobs and increasingly rely on employer-provided supports (e.g., mentoring, training).
  • Sequencing Services Across Systems: Many states have established a sequenced set of services at each stage of an individual's employment journey. Sequenced services are coordinated across agencies and funding sources to ensure the right support is delivered at the right time for an individual, with clear ownership for each service and seamless transitions between systems. In Washington, in most cases, individuals follow a sequenced service model in which they begin with pre-employment services through the developmental services agency, transition to the vocational rehabilitation agency for job development and initial job coaching, and then return to the development services agency for ongoing employment supports once stabilized.10
  • Coordinated and Accessible Employment Supports: Several states ensure that services supporting employment are easily available, such as transportation and assistive technology for remote work. By integrating these supports into employment planning, states are addressing barriers and maximizing individuals' ability to pursue and sustain meaningful employment for long-term success. Oregon, Tennessee, Wisconsin and many other states offer transportation services to help individuals access both their workplaces and employment support appointments.11,12,13 Oregon also provides access to personal care services for employed individuals, both with and without job coaching, as well as direct nursing and professional behavior services.14

Best Practice #3: Support for Entrepreneurship and Self-Employment

Recognizing that traditional employment is not suitable or desired by all, several states have embraced entrepreneurship and self-employment as viable alternatives. These models not only respect individual agency, but can also expand economic participation among individuals with I/DD. Common features include:

  • Feasibility and Business Planning Support: Some states require an assessment by a vocational rehabilitation counselor to evaluate whether an individual's skills and experience are appropriate for self-employment. States, such as Colorado and Tennessee, also commonly provide business planning support to test the feasibility of a proposed business and provide support for developing startup plans.15,16
  • Skill Building and Training: Skills development and training programs tailored to self-employment are common in several states, such as Colorado, Tennessee and Washington. Many states also provide ongoing mentorship and counseling to individuals even after launching a business.
  • Startup Funding: Notably, several states offer direct funding to self-employed individuals with I/DD to support startup costs and other business expenses. For example, Colorado provides up to $12,500 in funding for individuals who meet certain financial contribution requirements.17

Best Practice #4: Cross-Agency Coordination and System Integration

Coordination of services across agencies that serve individuals with I/DD including: developmental services; vocational rehabilitation; education; Medicaid; and others is essential to ensure continuity and effective employment services and supports. Common strategies to promote cross-agency collaboration include:

  • Clearly Defined Roles Across Partner Agencies: Some states use memoranda of understanding (MOU) or other cooperative agreements to align multiple state agencies around a shared vision for employment for individuals with I/DD, while delineating clear roles and responsibilities for each agency. For example, Oregon has a statewide MOU centered around its Employment First philosophy, which describes the roles and responsibilities of key agency partners in supporting individuals in accessing employment, including the Department of Human Services, Vocational Rehabilitation, Department of Education, Oregon Commission on the Blind, and the Office of Developmental Disabilities Services.18 Importantly, the MOU defines specific services that each agency will deliver to individuals, as well as processes to facilitate cross-agency collaboration.
  • Structures to Promote Seamless Transitions Across Services: Many states emphasize a strong role for case managers, counselors and other staff to serve as bridges across multiple agencies, helping individuals navigate multiple service delivery systems and foster a more person-centered approach. This can include coordination between I/DD and VR staff to facilitate timely referrals and information sharing, as well as a "warm handoff" to ensure there is no gap in services as one system takes over authorizing and funding services after another. States also align policies, provider enrollment, credentialing and training to ensure coordination across systems. In Washington, the state assigned liaison counselors in each vocational rehabilitation office who specialize in supporting individuals with I/DD and coordinate onboarding and connections to services for clients who are mutually served by vocational rehabilitation and developmental service agencies, including receiving referrals from developmental services.19 Similarly, Tennessee developed guidance and specific protocols for I/DD support coordinators and vocational rehabilitation counselors, and conducts joint training, to ensure seamless supports.20

Best Practice #5: Rate Structures That Promote Strategic Goals and Employment Outcomes

Several states are transitioning rate models from volume-based, fee-for-service structures to rates that better reflect the individual's level of need, as well as structures that tie payment to desired quality objectives and outcomes. This shift reflects an increasing recognition across states that volume-based structures (e.g., hourly rates for job coaching) are not always appropriate for each service and pose barriers to other goals, such as promoting long-term employment. Some payment models deployed across leading states include:

  • Tiered Payment Structures: States like Oregon and Tennessee have adopted tiered rate structures that reflect the varying levels of support individuals with I/DD may require to obtain and maintain employment. These tiers are typically determined through standardized assessments of individual needs, allowing funding to be tailored to the complexity and amount of supports the person requires. For example, providers serving individuals with more significant support needs receive higher reimbursement rates to ensure adequate staffing, while those serving individuals who require less intensive assistance receive correspondingly lower rates. States like Oregon have further refined their approach by linking job coaching payments to the number of hours an individual works, rather than the number of hours the job coach works.21,22 In Tennessee, providers are paid at higher rate tiers as the individual's need for support decreases over time, creating an incentive to support the individual's independence while improving long-term sustainability.23
  • Performance- or Outcome-Based Rates: Some states have introduced outcomes-based rate models that reward providers for achieving defined outcomes. For example, Oregon's job development rate is comprised of two outcomes-based payments: providers receive an initial payment when the individual gets a job, and a second payment after the individual stays on the job for 90 days (a commonly used benchmark indicating job stability).24 States like Tennessee also offer incentives to providers for helping individuals reach higher hourly work thresholds (e.g., 20+ hours per week).25

Looking Ahead

In recent years, many states have placed a strong emphasis on supporting individuals with I/DD in engaging in CIE. Meaningful participation in the workforce—earning wages, contributing to society and pursuing personal and professional growth—not only enhances the quality of life for individuals with I/DD, but also enriches entire communities by fostering greater inclusion and celebrating developmental diversity in the workplace. As states continue working to expand employment opportunities for people with I/DD, they should look to proven strategies from across the country. These successful approaches often include early and proactive engagement, robust supports at every stage of the employment journey, well-coordinated services across agencies and aligned payment models. By leveraging and building on these successful efforts, states have the opportunity to make a significant positive difference in the lives of many people with I/DD while fulfilling the promise of the ADA and related landmark legislation that aim to promote well-being, community inclusion, and independence.

Footnotes

1. Cantrell, C., Frohlich, J., & Lansky, A. (2024, October 23). Medicaid's role in empowering people with intellectual and developmental disabilities. Manatt, Phelps & Phillips, LLP. https://www.manatt.com/insights/newsletters/health-highlights/medicaid-s-role-in-empowering-people-withintellec

2. Competitive Integrated Employment (CIE). U.S. Department of Labor. (n.d.). https://www.dol.gov/agencies/odep/program-areas/cie

3. Employment First. U.S. Department of Labor. (n.d.-b). https://www.dol.gov/agencies/odep/initiatives/employment-first

4. StateData. StateData | Think Work. (n.d.). https://www.thinkwork.org/statedata

5. State Data: The National Report on Employment Services and Outcomes Through 2022. Institute for Community Inclusion. 2022. https://www. thinkwork.org/sites/default/files/files/blue_book_files/BB_2024_web_F.pdf

6. APSE EMPLOYMENT FIRST STATEMENT. APSE. (n.d.). https://apse.org/wp-content/uploads/2018/09/SABE-doc_D4.pdf

7. Employment & Day Services. TN Department of Disability & Aging. (n.d.). https://www.tn.gov/disability-and-aging/disability-aging-programs/employment-first-and-community-inclusion/employment-and-day-services.html

8. Employment & Community Inclusion Services. Skagit County Developmental Disabilities. (2023). https://www.skagitcounty.net/HumanServices/Documents/DD/Implementation%20Guide%202023.pdf

9. Employment and Community First CHOICES Benefit Table. (n.d.). https://www.tn.gov/content/dam/tn/tenncare/documents/MemberBenefitTable.pdf

10. Memorandum of understanding (MOU) between DSHS Division of Vocational Rehabilitation and DSHS Developmental Disabilities Administration. DSHS Contract #2361-52480. (n.d.). https://www.dshs.wa.gov/sites/default/files/DDA/dda/documents/DVR%20Mou%20Contract%202361-52480%20Executed.pdf

11. Developmental Disabilities Worker's Guide. Oregon Department of Human Services: Worker Guides: Developmental Disabilities Providers and Partners : State of Oregon. (2024, March 1). wg-employment-table-contents.pdf

12. Employment and Community First CHOICES Benefit Table. (n.d.). https://www.tn.gov/content/dam/tn/tenncare/documents/MemberBenefitTable.pdf

13. Memorandum of understanding (MOU) between DSHS Division of Vocational Rehabilitation and DSHS Developmental Disabilities Administration. DSHS Contract #2361-52480. (n.d.). https://www.dshs.wa.gov/sites/default/files/DDA/dda/documents/DVR%20Mou%20Contract%202361-52480%20Executed.pdf

14. ODDS Expenditure Guidelines. Oregon Department of Human Services: Funding Authorities: Developmental Disabilities Providers and Partners : State of Oregon. (n.d.). https://www.oregon.gov/odhs/providers-partners/idd/Documents/odds-expenditure-guidelines.pdf

15. Center on Self-Employment (Colorado). State Policies - National Center on Self-Employment, Business Ownership, and Telecommuting. (n.d.). https://centeronselfemployment.org/policy/state.cfm?s=CO#:~:text=Supported%20self,employmentCO

16. Center on Self-Employment (Tennessee). State Policies - National Center on Self-Employment, Business Ownership, and Telecommuting. (n.d.-b). https://centeronselfemployment.org/Policy/state.cfm?s=TN

17. Center on Self-Employment (Colorado). State Policies - National Center on Self-Employment, Business Ownership, and Telecommuting. (n.d.). https://centeronselfemployment.org/policy/state.cfm?s=CO#:~:text=Supported%20self,employmentCO

18. COOPERATIVE AGREEMENT BETWEEN OREGON DEPARTMENT OF HUMAN SERVICES, OREGON COMMISSION FOR THE BLIND, OFFICE OF DEVELOPMENTAL DISABILITIES SERVICES, AND OREGON DEPARTMENT OF EDUCATION. (n.d.-a). https://www.oregon.gov/odhs/employment-first/Documents/mou-odds-vr-edu.pdf

19. Washington State Department of Social & Health Services. (n.d.). COUNTY SERVICES FOR WORKING AGE ADULTS - POLICY 4.11. Developmental Disabilities Administration. https://dch.wwcowa.gov/Document%20Center/policy4.11.pdf

20. TennCare and Vocational Rehabilitation. (2022). https://www.tn.gov/content/dam/tn/tenncare/documents/VRIAATrainingSlides.pdf

21. Developmental Disabilities Worker's Guide- Job Coaching. Oregon Department of Human Services: Worker Guides: Developmental Disabilities Providers and Partners : State of Oregon. (2024, March 1). https://www.oregon.gov/odhs/employment-first/Documents/wg-jobcoaching.pdf

22. Mills, L. (2021, April). Value-Based Payment Methodologies to Advance Competitive Integrated Employment: A Mix of Inspiring Examples from Across the Country. U.S. Department of Labor. https://view.officeapps.live.com/op/view.aspx?src=https%3A%2F%2Fmcusercontent.com%2F29aa515bd6e4d1a3e196930b4%2Ffiles%2Fcd9b51b9-56be-6eeb-1740-02693edec8e0%2FValue_Based_Payment_Methodologies_FINAL_Lisa_Mills_05_04_2021_READ_ONLY_COPY.02.docx&wdOrigin=BROWSELINK

23. TennCare III Waiver. Department of Health & Human Services. (2025, June 30). https://www.tn.gov/content/dam/tn/tenncare/documents/tenncarewaiver.pdf

24. ODDS Expenditure Guidelines. Oregon Department of Human Services: Funding Authorities: Developmental Disabilities Providers and Partners : State of Oregon. (n.d.). https://www.oregon.gov/odhs/providers-partners/idd/Documents/odds-expenditure-guidelines.pdf

25. Killingsworth, P. (2021, November 2). Wage Increases for Frontline HCBS Workers in Employment and Community First (ECF) CHOICES. TN Division of TennCare. https://www.tn.gov/content/dam/tn/tenncare/documents/ECFCHOICESRateIncreaseMemo11022021.pdf

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