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Service Record Closure & Exit

Focus areas

Service record closure and exit occur when the VR agency ends an individual’s active case. Closure may occur after application prior to eligibility determination, after eligibility but prior to plan, and after plan with or without an employment outcome.

Closure is a critical quality assurance point because it affects individual rights, federal reporting, performance accountability, fiscal integrity, and the accuracy of program outcomes.

Requirements in Laws and Regulations:

The VR regulations include several provisions related to closure and service record documentation.

34 CFR § 361.44 addresses closure without an eligibility determination. Before closing a case without determining eligibility, the agency must make reasonable efforts to contact the applicant or representative, unless the individual declines to participate, is unavailable, or has died.

34 CFR § 361.47 requires the VR agency to maintain a record of services for each applicant and eligible individual. The record must include documentation supporting eligibility, priority category, IPE development, services, decisions, notices, and closure.

34 CFR § 361.56 establishes requirements for closing the record of services of an individual who has achieved an employment outcome. Generally, the record may be closed as a successful employment outcome only when:

  • The individual has achieved the employment outcome described in the IPE.
  • The employment outcome is consistent with the individual’s strengths, resources, priorities, concerns, abilities, capabilities, interests, and informed choice.
  • The individual has maintained the employment outcome for an appropriate period of time, but not less than 90 days.
  • The individual and the VR counselor consider the employment outcome to be satisfactory.
  • The individual is informed of the availability of post-employment services.

Closure decisions must be documented in the case record, and individuals must receive required information at closure, including appeal rights and CAP information when applicable.

Considerations:

Common concerns related to closing cases include:

  • Closing cases without sufficient contact attempts.
  • Assurance that an individual is stable on the job.
  • Missing employment information that validates the employment.
  • Closing a case successfully when the employment outcome does not match the IPE.
  • Failure to amend the IPE before closure when the employment outcome changed.
  • Failure to document that services contributed to the employment outcome.
  • Inaccurate closure codes.
  • Insufficient documentation of post-employment service discussion.
  • Lack of evidence that the individual and counselor considered the outcome satisfactory.
  • Closing cases due to non-participation without documenting engagement efforts.

Effective Practices:

Effective closure and exit practices include:

  • Using closure checklists tailored to closure type.
  • Requiring supervisory review of successful employment closures.
  • Verifying employment information before closure, including employer, job title, start date, wages, hours, benefits when available, and whether employment is competitive and integrated.
  • Confirming that the employment outcome is consistent with the IPE or amending the IPE before closure when appropriate.
  • Documenting the individual’s satisfaction with the outcome.
  • Documenting that the employment outcome was maintained for at least 90 days and is stable.
  • Documenting how VR services contributed to the employment outcome.
  • Providing information about post-employment services.
  • Reviewing unsuccessful closures for engagement patterns and possible service access barriers.
  • Monitoring closure data for accuracy, equity, and consistency.
  • Using closure reviews to identify training needs and case management system improvements.

Applicable Laws and Regulations:

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