WIOA: Peer Mentoring and Pre-ETS

The advent of the Workforce Innovation Opportunity Act (WIOA) and its Pre-Employment Transition Services (Pre-ETS) required State Vocational Rehabilitation Agencies (SVRAs) to set aside at least 15% of their federal funds to provide ‘pre-employment transition services’ to eligible ‘students’ with disabilities (14-21).

WIOA’s inclusion of ‘instruction in self-advocacy, which may include peer mentoring’ fueled SVRA’s interest in technical assistance to pilot and implement peer mentoring programs as an outreach and support strategy to engage students with disabilities in self-advocacy and to support ANY and ALL of the 5 required Pre-ETS.

“Research has shown that mentors, especially peer mentors, can positively affect the movement of individuals with disabilities towards self-sufficiency through the establishment of high expectations, support and empowerment.”  WINTAC 2020

The RSA’s 5-year Workforce Innovation Technical Assistance Center (WINTAC) through its Peer Mentoring Workforce Innovation Pilot Projects (WIPP) entered into Intensive Technical Assistance (ITAs) agreements with SVRAs to support the development and provision of a new VR peer mentoring service for students with disabilities as defined under WIOA. 

WINTAC technical assistance included support from its Pre-ETS Subject Matter Experts (SME) and was led by PolicyWorks (PW), a national non-profit organization experienced in the provision of peer mentoring programs to transition-aged youth in post-secondary educational settings.

PW and its Peer MentoringWorks (PMW) emerge from the WINTAC with experience providing technical assistance to SVRAs piloting and implementing peer mentoring provision as a new distinct Pre-ETS service. It includes program and service design, peer mentoring training and certification for providers, and onboarding support for program implementation to Local Education Agencies (LEAs), Disability Service Centers (DSCs), and the network of Community Service Providers (CSPs) including Centers for Independent Living (CILs).

Peer MentoringWorks was designed to support vocational rehabilitation for students, youth, and young adults with disabilities in transition to pre-employment and post-secondary education pursuit of career-path employment.  PW brings a decade of peer mentoring service delivery and 5 years of intensive technical assistance provision experience working with SVRAs through the Workforce Innovation and Technical Assistance Center (WINTAC) to design, pilot, and implement peer mentoring programs in the Pre-Employment Transition Services arena.

The provision of “Instruction in Self-Advocacy” to a student with a disability (14-21), may include the support of a peer mentor, as one of five required Pre-Employment Transition Services (Pre-ETS) funded by the 15% required minimal expenditure of the federal $3.6 billion national vocational rehabilitation (VR) annual budget.

  1. Job exploration counseling
  2. Work-based learning experiences, which may include in-school or after school opportunities, experiences outside of the traditional school setting, and/or internships
  3. Counseling on opportunities for enrollment in comprehensive transition or postsecondary educational programs
  4. Workplace readiness training to develop social skills and independent living
  5. Self-advocacy instruction including peer mentoring

If a VR Agency uses peer mentors to provide any of the five required pre-employment transition services, can they charge the cost of the peer mentor delivering the required Pre-ETS service to the minimum reserve requirement for Pre-ETS?

Yes. The peer mentor in this scenario is treated in the same way as any other contracted service provider and the cost incurred providing direct Pre-ETS services that fall under any of the five required Pre-ETS activities, could be charged to the funds reserved for pre-employment transition services. Wintac FAQs

A portion of the cost incurred in the direct provision of peer mentoring includes the Peer Mentoring Coordinator (PMC), who administrates the provision of service as a “co-pilot” offering mentoring guidance employed by the mentor in the provision of service.  This is unique to VR Pre-ETS peer mentoring, as traditional PMCs serve mainly as program administrators and may be less involved in the direct provision of service.

Research and Effective Communities of Practice

In 2017, the National Mentoring Resource Center released a peer mentoring review that identified key findings and resources.

“The most significant impacts on peer mentoring program effectiveness appear to be the mentors’ attitudes and motivations, clarity of programmatic infrastructure, and fidelity of its implementation.”

“The means by which programs have positive effects on mentees appears to be largely through the consistent and affirming presence of mentors, and the clarity and predictability resulting from a clear program structure.” Peer Mentoring, National Resource Center

Recommendations for how practitioners could enhance their programmatic practices suggested that practitioners:

  • Lay a strong foundation for the program by selecting the right coordinators and the right mentors.
  • Select the right match activities to scaffold relationship building.
  • Provide lots of training and supervision to peer mentors.
  • Let the youth lead as much as possible.

How do State Vocational Rehabilitation Agencies (SVRAs) and Community Rehabilitation Providers turn the promise of peer mentoring into an effective practice?

PW developed the PMW Learn CTR to establish a training and certification protocol for Peer Mentoring Coordinators (PMCs) and Peer Mentors (PMs).  PMW also supports the direct provision of peer mentoring as a Pre-ETS and transition support through its PMW FieldGuide, an on-demand mobile APP.  The PMW FieldGuide includes program supports, transition resources and activity guides that may be customized for the community of peer mentoring service providers.  This PMW community of practitioners include post-secondary disability services centers, networks of community service providers including community providers from WIOA core partners such as Workforce, Education, and Administration for Community Living.

PW supports the national community of practitioners piloting and implementing peer mentoring programs.   The opportunity to employ young adults including those with disabilities to serve as trained and certified peer mentors guided by employment services provider peer mentoring coordinators offers a unique opportunity to build a peer mentoring workforce as a strategy to increase employment and post-secondary transition success for students and youth fostering self-advocacy and youth leadership.

Challenges and Opportunities in the VR Pre-ETS Peer Mentoring

Through the 5-years of the WINTAC, PW gained experience providing technical assistance to VR agencies and their networks of service providers developing and onboarding the provision of service as a WINTAC partner.

The WINTAC was a national center funded by a cooperative agreement from the Department of Education’s Rehabilitation Services Administration (RSA) to provide training and technical assistance to State Vocational Rehabilitation Agencies (SVRAs) and related rehabilitation professionals and service providers to help them develop the skills and processes needed to the meet the requirement of the Workforce Innovation and Opportunity Act (WIOA).

Steven Allen, President of PolicyWorks served as a Peer Mentoring Workforce Innovation Pilot Project (PM WIPP) Senior Project Manager during the WINTAC.  He also served as a technical assistance liaison for the WINTAC coordinating technical assistance for all 5 topic areas working directly with SVRA administrations.  Working with other SMEs through the WINTAC, led to a breadth of experience and knowledge during the first five years of WIOA implementation. 

His experience with the project informs the following questions and responses informed from his work with the PM WIPPs.


  1. What is the goal of Peer Mentoring as a distinct transition or pre-employment transition support under WIOA?
  2. What were the program model objectives identified in the Peer Mentoring Pilots?
  3. What are some of the challenges that faced SVRAs in implementing Peer Mentoring Services?
  4. What were the opportunities that arose through the work of the WINTAC?
  5. What are the characteristics of some of the models that were supported during the WINTAC?
  6. What are some of the challenges of implementing a VR peer mentoring program and how can you mitigate them? 
  7. What are the challenges and opportunities for the promise of VR-funded peer mentoring?
  8. Finally, what are the key design elements and program values that mark successful peer mentoring program design for models in the VR field of practice?

Q1.  What is the goal of Peer Mentoring as a distinct transition or pre-employment transition support under WIOA?

Since Peer Mentoring was mentioned in WIOA as a potential Pre-ETS fundable support for instruction in self-advocacy, the primary goal of peer mentoring in VR is to support the development and practice of self-advocacy for students with disabilities (14-21).  RSA further interpreted that the law allowed for the provision of peer mentoring in support of the provision of any and all of the Pre-ETS services and that the cost of the peer mentoring support could also be used by SVRA’s and counted toward the 15% required expenditure. 

Some SVRA’s have recognized the value of peer mentoring and began offering the service as enhanced transition support to youth and young adults in early transition to employment. 

Q2.  What were the program model objectives identified in the Peer Mentoring Pilots?

Although the primary objective of VR peer mentoring was instruction in self-advocacy (WIOA), the PM WIPPs set the objectives of the service to help students (and youth) with disabilities to increase their self-determination and self-advocacy skills and their ability to independently seek out, connect to and participate in 1) community networks, 2) social networks, and 3) professional networks. 

These goals identified the long-range target and allowed the PMC/PM team to meet the student where they were and guide them toward increasing their ability to make connections to support their success and independence.  Isn’t this the core of self-advocacy and self-determination?  Learning to build networks and establish connections to a network of people and resources may be one of the most underdeveloped skills for young adults of all abilities and one of the most valuable skills for career path success.

This is possibly truer for students and youth with disabilities who often face a level of isolation resulting from their experience with a disability. 

Establishing connections requires the development of those elusive soft skills that employers are often looking for when hiring new employees.  Soft skills like self-advocacy are more easily obtained through practice rather than in the classroom.  A definition and understanding of their meanings will not always result in their practice.  Peer mentoring along with the strategy to support students with disabilities in activities seems to offer the mentee an opportunity to effectively practice and gain them.  I think this is the value proposition for peer mentoring.

Q3.  What are some of the challenges that faced SVRAs in implementing Peer Mentoring Services?

Mostly starting from scratch.  Peer mentoring was not a traditional transitional service and was not typically included as part of an IPE (Individual Plan for Employment) SVRA’s had to develop a plan for its provision including determining appropriate fee scheduling, service goals, training requirements, metrics, and provider capacity.

Starting small with a targeted pilot was often seen as a method to build out capacity without diluting the focus on long-term objectives with the challenges of starting a new service and onboarding a new provider network.  In Florida, many of those decisions were made prior to WIOA because Florida started its Youth Peer Mentoring program before WIOA was enacted.   This allowed Florida to pioneer statewide expansion supported through WINTAC. 

Many SVRAs had what I would describe as “bandwidth issues”.  Although they were facing the challenges of meeting Pre-ETS expenditure requirements, they were also facing new performance measure realignment, implementation of 511 requirements, alignment with the workforce development system, the new definition of competitive integrated employment, etc.  Although many progressive VR agencies recognized the great potential for peer mentoring, they found dedicating program development resources scarce during the early years of WIOA implementation.

One of the other unexpected challenges, that in some way remains, is a bias toward the value and impact of a peer mentor.   Helping VR administrators, counselors and providers see that peer mentoring, especially peer mentoring as a Pre-ETS support was not just about identifying a “friend” for the student mentee to hang with for social support.  VR peer mentoring was centered around the engagement of a student/youth in their own self-advocacy with a focus on the transition to employment.  If realized, peer mentoring offers an opportunity to improve systemic performance metrics to meet these objectives. 

SVRAs are more successful at meeting the required expenditures; VR counselors are more successful at achieving the new WIOA performance standards; mentors gain experience in their own self-advocacy as they are employed to model and mirror self-advocacy for their mentee; mentees receive support in helping to navigate the supports and accommodations that support expanding self-expectation, self-advocacy, and self-determination; and, employers have stronger candidates with disabilities prepared to function and perform in the workforce.

This issue was less apparent within the network of service providers.  Service providers such as the disability services centers at colleges and universities and the centers for independent living had previous experience with mentoring programs.  Although these peer mentoring programs have different objectives and programmatic requirements, the impact and experience with both group and individual mentoring make them a natural host for VR peer mentoring service provision. 

Q4.  What were the opportunities that arose through the work of the WINTAC?

Well, First, personally and professionally I benefitted from working with the incredible WINTAC team of subject matter experts employed to support systems change during a major program transition was an incredible opportunity.  Everyone was so amazing!  They had such incredible credentials and experience in vocational rehab administration.   I learned so much about VR, its culture, and the impact of an intensive technical assistance approach system improvement or change.  The WINTAC ITA approach was designed to ensure accountability in reaching short and long-term outcomes and outputs.

I came to that team with an ‘outsider’ perspective as a systems improvement advocate (M. Architecture).  I had some knowledge of vocational rehab, but more knowledge around the workforce system; Medicaid Buy-In; the ADA; the national deinstitutionalization movement (Check out the Deinstitutionalization Toolkit from the National Council on Disability), Social Security Administration’s Ticket Program – specifically VR ‘cost reimbursement’, and the Workforce System’s ‘Partnership-plus’.  

My advocacy effort with PolicyWorks included working with World Institute on Disability (WID) and the National Council of Independent Living (NCIL) on a policy initiative called CareerACCESS.  My annual pilgrimage to DC for the NCIL conference helped me appreciate the importance of advocacy and mentoring as part of a community.    

Finally, I would mention my personal experience as a Veteran with a service-connected disability that offered an opportunity to compare the vastly different Veteran Administration’s disability system.

The greatest opportunity for working under the WINTAC was the development and real-world laboratory for the implementation of peer mentoring programs.   The forecasted return on investment for creating sustainable structural supports for peer mentoring was supported through an understanding that peer mentoring was not merely a ‘passing fancy’ but potentially a replicable and lasting new method for the VR provision of self-advocacy due to the workforce act.

Many states were understandably focused on the provision of the service as a direct service to students with disabilities. This was driven by the need to expend the 15% dedicated funding.   I think that one of the potential outcomes of VR peer mentoring is the impact on the mentors.   If the mentor is a young adult leader who has a disability, this may be the first job on the resume and an opportunity to practice for themselves what they are mentoring.  I think this creates a systemic pipeline around employment for individuals with disabilities.   Youth leadership programs are active nationally and often hosted within the independent living community.  They are an ideal place to recruit peer mentors.

Gaining skills and training through the provision of the service offers great promise to increasing transition to competitive integrated employment and at the same time building community.

Centers for Independent Living have long employed youth leadership and community influence to foster advocacy development.  Although CILs don’t always focus on employment as an outcome, that has evolved as the national movement has increased recognition that employment and independent living are often inextricably connected.  Employing a paid peer mentor model to support VR transition goals in a CIL just seems to be a winning combination supporting youth leadership employment pipelines.

Building a workforce of peer mentors with disabilities who may have career interests in social services should increase awareness of consumer perspectives for service providers, counselors, and program administrators.  Hopefully, the realization of this potential will continue to expand and impact the employment outcomes for individuals with disabilities. 

Q5.  What are the characteristics of some of the models that were supported during the WINTAC?

Florida’s model was the easiest to support because the pilot had established basic program components and the initial onboarding of the provider network, with expansion underway.  Today, the two earliest community employment service providers in the pilot are among the top achieving peer mentoring service providers in the state.  

All models recognized that training and structural supports for the service were an important asset to establishing the value proposition of the services.  Starting small either with an organization, region or location helped to increase potential success and impact. 

The state leadership’s commitment to the service helped the provider community buy-in and fostered a commitment to the buildout of the service provider network.  Pilot programs that are one and done are all too common in the social service community.  Many initiatives come and go with each administration or grant funding opportunity.  Florida’s commitment to a statewide service prior to WIOA and the impact of the dedicated Pre-ETS funding was a perfect scenario for success.

Florida’s leadership and commitment prior to WIOA was a hard sale to the provider community but led to the successful launch of the pilot.  The service was fortified with the passage of WIOA and continues to expand from the groundwork initiated in 2014.  The struggle is still real.  Getting counselors to make a referral continues to be a struggle.  Even though FL YPM referral process is among the simplest processes, getting counselors to make a referral has been a challenge.  Once a counselor makes an initial referral and understands the process and the benefit of the service it becomes much easier.

Mississippi’s peer mentoring focused on successful retention in post-secondary institutions.  It began with a pilot at two state universities.  It has now expanded statewide at universities and also the community college system.  The disability services center network at each location work with VR counselors to identify potentially eligible students and in-plan VR services customers to increase successful transition outcomes.  Like CILs, DSCs are optimal settings to pilot peer mentoring programs.   The central community nature of the setting serves as a home base and host for developing support and resources for the mentors and mentees.

Maine had a similar challenge getting counselors to make a new referral.  Like Florida, Maine has a variety of provider types.  These include disability service centers, CILs, and the broader network of community service providers.  These organizations invest in getting a peer mentoring coordinator and peer mentor trained and in place and then must wait for a referral from a VR counselor.  If the referral doesn’t happen the provider struggles to grow the supply of experienced and trained mentors to meet the demand.  Sometimes it’s just economics. 

The commitment from the VR administration in each of these states has been strong and enduring.  In Maine, the peer mentoring program meeting has worked with counselors in the state by reviewing caseloads to help counselors in the state to identify a candidate and initiate the referral. 

This is easier in Maine because of the population of the state but then the population density becomes a factor in serving students across the state.  Post-covid, the use of virtual platforms offers opportunities to reach these frontiers.

Q6. What are some of the challenges of implementing a VR peer mentoring program and how can you mitigate them? 

I think one of the challenges for getting the program fully operational has been improved due to the impact of Covid-19.  Before the pandemic, peer mentoring was a one-on-one in-person service.  The ability to provide peer mentoring virtually helped improve the rate of engagement for the mentoring pairs.  The level or quality of the engagement also improved. This might seem odd, but when a mentor and a mentee meet online it expands the opportunity for the pair to explore the internet and use some electronic tools as props to increase effectiveness.  Sometimes a mentor must ‘drop the prop’.  Having great tools or activities, or props can also offer a means to make progress toward the objectives. Maintaining quality “personal” engagement in the mentoring relationship in a zoom-like meeting is a challenge, but I believe it is mitigated with well-designed intentional program supports and constructs available accessible through the PMW Fieldguide.  

An in-person meeting is of great value too.  Optimally, a mentoring pair engages both online and in-person, as well as one-on-one and in groups.  Peer mentors can effectively work with their individual mentee in a group setting too. Well-developed group activities that align or are designed to support both individual and group mentoring are important and increase the impact for a mentee when conducted peer-group setting.

Finding mentor talent is a challenge too.  I would say it is easier in universities and CILS.  Post-secondary settings seem to have a good selection of young high achieving candidates who might serve as peer mentors.  DSCs are serving returning students experienced in navigating the university community.  They are familiar with academic supports, accommodations, and resources.  With some training, these candidates are effective mentors to incoming students with disabilities.

The peer mentor students are motivated to earn extra income serving as a mentor with the added benefit of adding work experience to their resumes.  High achieving students who are pursuing degrees in social sciences are especially good candidates.  A student who possesses leadership skills, experience with disability, and who is motivated to serve others is an ideal candidate.  Community-based service providers also recruit from local universities and community colleges as a good source for motivated young potential mentors. 

CILs deserve a mentioned as a very strong location for recruiting mentors.  I mean, where do I start?  First, they are a national network of a community-based organization that serves and is led by individuals with disabilities who are accessing resources to support community-based advocacy and service resourcing.  They are historically established around the concept of mentoring.  Most CILs have existing group mentoring activities and the community is built around a mentoring philosophy.   Even formal mentoring programs are a staple of community engagement and CILs often connected or conduct youth leadership programs.

In most of the programs that PW has worked with so far, connecting youth mentees to community-based resources has been one of the objectives of the VR peer mentoring programs.   In Florida, counselor-to-client mentee referrals require the peer mentoring provider to support the student to connect and engage in community-based advocacy groups.  CILs are specifically cited along with other national community-based organizations.  Every referral must include at least one selection from the list of community-based resources per the referral requirement.

For providers, it is “supply & demand”.  The supply of good peer mentors is critical.  Mentors are trained and certified to provide the formal VR peer mentoring service activities to achieve VR program objectives.  A supply of peer mentors who model and mirror their own self-advocacy while supporting the growth and development of the mentee is the goal. This is counterbalanced by meeting the demand for the service. Simply, are the referrals forthcoming?  Are students with disabilities receiving referrals for peer mentoring? 

I anticipate this will become easier with the growth and expansion of the service.  These VR peer mentoring models are practicing continuous program and service evaluation, resourcing, and improvement.  Documenting impacts during the service provision will make the case for more counselors to consistently evaluate the need for youth and students to receive the new service.

Q7. What are the challenges and opportunities for the promise of VR-funded peer mentoring?

Starting with opportunities, the expanding community of practitioners; the development of more tools and resources to support the provision of VR peer mentoring; and the ever-emerging and expanding peer mentoring models offer a laboratory for the development of tools, resources, best practices, impact data, program pilot site or program development, etc.

PMW and its growing library of resources, training protocols, service support tools, and transition resources are evolving with each program model.  These models offer specific communities of peer mentoring practice that are opportunities to customize resources and refine program models for expansion and sustainability.   

PW continues to seek opportunities to support the development of peer mentoring service models.   Working with nationally distributed community-based programs like independent living centers, disability service centers, and disability-specific community leadership models the hope is to continue to improve the value proposition of the service. 

During WINTAC, PW provided technical assistance and program support to VR general, combined, and blind agencies.  Post-WINTAC, opportunities to pilot and expand new and existing models will continue to develop supported replicable and sustainable models.  

Community-based models are opportunities to customize and expand program supports that enhance sustainability and replication for broader duplication.  Sharing the “success stories” and identifying program improvement through communities of practice activities offer an opportunity for model stabilization. 

The promise of peer mentoring is the opportunity to increase access and capacity of a youth or a student mentee to engage in self-advocacy with the support of a peer mentor.  A peer mentor with access to tools and resources supporting the objectives of the program model and service objectives is key.   

Q8. Finally, what are the key design elements and program values that mark successful peer mentoring program design for models in the VR field of practice?

Follow effective best practices.   Research shows the way to effective practice evidence shows that mentors’ attitudes and motivations, clarity of programmatic infrastructure, and fidelity of its implementation are the keys to building effective sustainable, and replicable program models.

Start small and plan big when initiating a peer mentoring service provision model.  Find the right setting for the pilot and focus on building out fidelity and support while visioning sustainability to meet program goals during expansion.

Be intentional about leaving room for peer mentoring to work its ‘magic’.  Structural supports like training and program content are important but it is important to be intentional in integrating opportunities to utilize the peer mentoring relationship to do the heavy lifting to achieve your goals.

Align the objectives of the peer mentoring service to the funding requirements and service goals.  Pre-ETS funding for self-advocacy instruction including the other four required activities is the best place to start when developing program service goals.  For out-of-school youth who are in-plan, the same advice applies.

Don’t reinvent the wheel.  Take advantage of the vast array of peer mentoring and transition resources that currently exist.  Look to other program models nationally to source content and support for peer mentoring service provision.  Many resources are available through existing community-based service providers.  Examples include post-secondary education DSC centers, Centers for Independent Living (CILS), disability-specific community organizations, the broader network of existing employment specialists, and finally, the networks of existing Pre-ETS service providers are examples of potential providers or resources to support the peer mentoring programs.

Pay attention to the fee schedule.   Tying and accurately forecasting the cost of the provision of the service and its delivery will help sustain the program.  Ensuring that the program is economically viable and feasible for providers will benefit the growth and expansion of the program.  For Pre-ETS peer mentoring, consider the cost and value of training and the role of the PMC in the direct provision of the service.  This ties back to being able to prorate a portion of the PMC’s time to the provision of the service.  Administration costs may not be directly fundable through the Pre-ETS 15% expenditures.

Capture the story and impact.  Gather data.  Design metrics to feed stakeholders’ needs into the model.  How do you show, both quantitatively and qualitatively, that the service provision is having the intended impact?  Pre- and post-survey tools and other data collectors and existing program curricula can help document the impact of the service and help make the case for the continued support of the program.  Integrating virtual peer mentoring strategies offers effective ways to document the service value and activities.

Use the data.  Integrate continuous quality improvement to ensure that the program’s structure is supporting the goals and funding objectives of the program.  Integration is about incorporating the data collection as an integrated part of the service.

Consider career pathways opportunities for the mentor are not merely an afterthought.  What are the next job opportunities for growth of the peer mentor in their own sequential workforce experience?  Implementing asynchronous and on-demand training, career exploration may serve as a method to establish the value proposition for the mentor in committing to successful and effective service provision.   

And finally, always consider the importance and value of the peer relationship and the core value of confidentiality in the peer mentee-peer mentor relationship is sacrosanct.  Consider the fine line between capturing and reporting the impact of the peer mentoring relationship without interrupting its effectiveness.  If successful, you can develop the service provision accountability and reporting requirements in a way that is integrated and supports the service provision.