Many VR agency staff have questions about how they are allowed to use Innovation and Expansion (I&E) funds and how other VR agencies use them. The VRTAC examined all 78 State Plans submitted in 2024 related to the use of I&E funds and we have summarized these findings here for informational purposes to help answer the questions that VR staff about I&E funds.
VR Agencies: Use of Innovation and Expansion Funds
The following information will describe how some VR agencies have used innovation and expansion (I&E) funds to support innovative activities and models of service delivery. In addition, this document will summarize the Federal requirements regarding the use of Title I funds to support I&E activities and will provide an explanation of the State Plan descriptions that may need to be modified and resubmitted for RSA approval before agencies can implement their innovative activities.
Description of Requirement:
The requirement for VR agencies to spend a portion of their Title I funds on I&E activities can be found in 34 C.F.R. § 361.35. Specifically, there are three types of activities that can be funded:
- Development and implementation of innovative approaches to expand and improve the provision of VR services to individuals with disabilities, particularly individuals with the most significant disabilities, including transition services for students and youth with disabilities and pre-employment transition services for students with disabilities, consistent with the findings of the comprehensive statewide needs assessment (CSNA) of the rehabilitation needs of individuals with disabilities under 34 C.F.R. § 361.29(a) and the State's goals and priorities under 34 C.F.R. §361.29(c);
- Funding the State Rehabilitation Council, consistent with the resource plan identified in 34 C.F.R. § 361.17(i); and
- Funding the Statewide Independent Living Council (SILC), consistent with the SILC resource plan prepared under title VII, chapter 1 of the Rehabilitation Act. The State and the SILC may determine in the SILC resource plan whether to use funds reserved under this section to fund the Council and, if so, the amount of funds to be used.
Summary of the analysis of all 78 State Plans on the use of I&E funds:
- The most common use is support for State Rehabilitation Council operations and statutory functions (53 agencies).
- Many agencies also use I&E funds for SRC travel, training, accessible meetings, public input, and annual reports (35 agencies).
- Beyond council support, the most frequent programmatic uses are interagency partnerships and braided funding (24), transition and Pre-ETS expansion (22), specialized sensory-disability capacity (20), and customized or supported employment approaches (19).
- Agencies frequently invest in evaluation and performance improvement (16), provider capacity (14), assistive technology (9), transportation or mobility solutions (8), and targeted outreach to underserved communities (7).
- Lower-frequency activities are not necessarily less important; several represent highly specific pilots or locally tailored innovations, such as self-employment development, digital referral systems, and employer-focused demonstrations.
Methodology and Counting Rules
- Each uploaded plan was searched for the standard VR State Plan prompt concerning “the use of funds reserved for innovation and expansion activities.”
- Where a state operates separate general and blind VR programs, each agency narrative was treated as a separate agency. This produced 78 agency narratives across 57 plans.
- Equivalent wording was consolidated into one activity. For example, “Individual Placement and Support,” “Customized Employment,” “Discovery,” and related supported-employment model development appear under one detailed activity category.
- An agency was counted no more than once in a category, even when its narrative described several projects fitting that category.
- The analysis includes activities described as current, recent, continuing, or planned. It does not treat a statement that an agency does not fund an activity as an affirmative use.
- Counts reflect what was explicitly described in the I&E narrative. A state may conduct an activity with other funds without mentioning it in this section.