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Time Certification Guide for Pre-Employment Transition Services

Categorized In: Pre-Employment Transition Services - Definitions/Agreements/Guides/FAQ's

Approved Date: February 12, 2021

Owner: Lupe Stevens

The federal regulations require all staff time spent in the delivery and coordination of pre-employment transition services for students with disabilities (SWD) as well as time spent on authorized activities to be reported. The following information is provided for the purpose of guiding staff in recording and reporting time spent in relation to pre-employment transition services..

Pre-employment transition services fall into three categories: required, coordinated and authorized, which will be differentiated below. Time spent coordinating and providing required, coordinated services and authorized activities for SWD, aged 14-21, are allowable pre-employment transition services costs, and are charged to the 15% budget reserve for pre-employment transition services.  Time is reported as either 1) required/coordinated; or 2) authorized.

Pre-employment transition services time spent arranging for and providing required and coordinated activities are combined together for the purpose of reporting to RSA

Pre-employment transition services time spent arranging for and providing authorized activities are reported separately from required and coordinated activities.

When a student who is eligible for pre-employment transition services is also engaged in VR Services, staff must track time engaged in the delivery and coordination of pre-employment transition services separately from the delivery of VR Services (e.g. determining eligibility for VR services is not a pre-employment transition service).

Specific activities related to each of the required, coordinated and authorized categories are listed below. Please note the lists included below are not exhaustive and you may come across instances of pre-employment service provision, whether required & coordinated services or authorized activities. Contact a Program Director for Transition if you are having trouble deciding where to fit particular service/activity. 


Direct provision of required services to a student in a group or on an individual basis:

  • Job exploration counseling
  • Instruction in self-advocacy
  • Counseling on post-secondary training options
  • Workplace readiness
  • Work based learning
  • Time spent preparing for required service delivery individually or as part of a team
  • Traveling in relation to the provision of required services
  • Documentation/task notes of service delivery
  • Case consultation to ensure best practices in service delivery to students


  • Attending IEP meetings
  • Working with local workforce development boards, one stop centers and employers to develop work opportunities for SWD
  • Working with schools to coordinate and ensure the provision of pre-employment transition services
  • Attending person centered planning meetings such as meetings hosted by a Developmental Disabilities service coordinator or Aged and Disabled Waiver case manager 
  • Time spent preparing for coordinated service delivery individually or as part of a team
  • Traveling in relation to the provision of coordinated services
  • Documentation/task notes of coordinated service delivery
  • Providing consultation to parents, school staff, businesses and agencies
  • Discussing VR employment services with parent/students
  • Attending parent/teacher conferences to provide consultation to parents/teachers
  • Sharing information with families and partners regarding community resources


The authorized activities are those pre-employment transition services provided​ ​only after a state has determined that funds remain after provision of the required and coordination activities.

Nebraska VR is currently engaged in the following activities that can be classified as authorized activities:

  • Transition Committee Meetings 
  • VR provided training: presentations at conferences/training events to inform and train about the scope of pre-employment transition services 
  • Any training received either in-house or at conferences or provided by a community partner that is directly related to the coordination and provision of  pre-employment transition services
  • Pre-employment  transition services training provided by our technical assistance (TA) partners (e.g.  NTACT-C) either in-person or via webinars, recordings, etc.
  • Nebraska Youth Transition Council (NYLC)
  • Program development, planning for the implementation of summer transition programs, youth transition conferences 
  • Consulting with TA agencies and regional states
  • Developing and supporting in-state partnerships 

VR agencies are not permitted to pay any administrative costs, as defined in section 7(1) of the Rehabilitation Act and §361.5(c)(2)), such as the salaries for associates or supervisors (unless engaged in providing required, coordinated or authorized pre-employment transition services), with the funds reserved for the provision of pre-employment transition services. Staff time for the purposes of this guide pertain to those individuals employed by the VR agency who directly provide pre-employment transition services.

The following are examples of activities staff would not track their time as pre-employment transition services:

  • Attending all-office meetings, DIG and Program Team Meetings, QE2 Committee Meetings, Budget meetings, OOS meetings
  • Attending NDE meetings such as Commissioner meetings 
  • Recruiting and interviewing for new agency staff
  • Associate support for pre-employment transition coordinators
  • Supervision of pre-employment transition service coordinators/completing performance reviews
  • General case management activities for all other VR services 


For reference:

Authorized Activities include:

(1) implementing effective strategies to increase the likelihood of independent living and inclusion in communities and competitive integrated workplaces;

(2) developing and improving strategies for individuals with intellectual disabilities and individuals with significant disabilities to live independently, participate in postsecondary education experiences, and obtain and retain competitive integrated employment;

(3) providing instruction to vocational rehabilitation counselors, school transition personnel, and other persons supporting students with disabilities;

(4) disseminating information about innovative, effective, and efficient approaches to achieve the goals of this section;

(5) coordinating activities with transition services provided by local educational agencies under the Individuals with Disabilities Education Act (20 U.S.C.1400 et seq.);

(6) applying evidence-based findings to improve policy, procedure, practice, and the preparation of personnel, in order to better achieve the goals of this section;

(7) developing model transition demonstration projects;

(8) establishing or supporting multi-state or regional partnerships involving States, local educational agencies, designated State units, developmental disability agencies, private businesses, or other participants to achieve the goals of this section; and

(9) disseminating information and strategies to improve the transition to postsecondary activities of individuals who are members of traditionally unserved populations.


Time spent on pre-employment transition services must be recorded in KRONOS.

For staff who spend more than 50% of their FTE working in pre-employment transition services the business unit in KRONOS will automatically default to  REQ/COORD Unit. Staff will have to select the AUTH Unit when appropriate to record time spent on authorized activities.

Staff who spend less than 50% will have to select the appropriate pre-employment transition services business unit (either REQ/COORD or AUTH) to record their time spent on pre-employment transition services, when they are completing KRONOS.

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