sequencing, and to focus efforts on the development and scaling of models that involve true braiding. Because braiding involves simultaneous service delivery by two or more systems, it necessitates - by design - greater inter-agency coordination and collaboration. This in turn is likely to result in more effective and coordinated application of each system’s respective resources on behalf of the common customer. To facilitate braiding as a common practice across the country, there is a critical need for three things: Revision of Federal statutes, regulations and guidance that currently include language widely interpreted as prohibiting braiding (or waivers of particular statutory or regulatory language that impedes braiding if proper safeguards against fraud and waste have been put in place); Federal guidance, issued jointly by the relevant federal agencies (e.g. OSERS, RSA, CMS and ETA), articulating strong expectations that braiding can, should and will occur at the individual service delivery level and that each system’s individual service authorization plan will reflect the full scope of services being provided to the individual, by all involved systems, in support of the identified employment goal/needs – if the content of existing Federal statutes, regulations and guidance is not considered a barrier. The guidance should offer practical examples of optimal braiding models that are acceptable given federal law. A state-by-state policy audit carried out to identify and correct existing state or local policies that are based on an overly restrictive interpretation of federal statutes, regulations or guidance. Despite the creation of Innovation Funds across the Federal landscape and repeated discussions about the importance of cross-system collaboration, states and communities are eager for practical guidance and acknowledgment of strategies to effectively braid resources across key systems and programs supporting individuals with disabilities. Joint Federal action
sequencing, and to focus efforts on the development and scaling of models that involve true braiding. Because braiding involves simultaneous service delivery by two or more systems, it necessitates - by design - greater inter-agency coordination and collaboration. This in turn is likely to result in more effective and coordinated application of each system’s respective resources on behalf of the common customer. To facilitate braiding as a common practice across the country, there is a critical need for three things: Revision of Federal statutes, regulations and guidance that currently include language widely interpreted as prohibiting braiding (or waivers of particular statutory or regulatory language that impedes braiding if proper safeguards against fraud and waste have been put in place); Federal guidance, issued jointly by the relevant federal agencies (e.g. OSERS, RSA, CMS and ETA), articulating strong expectations that braiding can, should and will occur at the individual service delivery level and that each system’s individual service authorization plan will reflect the full scope of services being provided to the individual, by all involved systems, in support of the identified employment goal/needs – if the content of existing Federal statutes, regulations and guidance is not considered a barrier. The guidance should offer practical examples of optimal braiding models that are acceptable given federal law. A state-by-state policy audit carried out to identify and correct existing state or local policies that are based on an overly restrictive interpretation of federal statutes, regulations or guidance. Despite the creation of Innovation Funds across the Federal landscape and repeated discussions about the importance of cross-system collaboration, states and communities are eager for practical guidance and acknowledgment of strategies to effectively braid resources across key systems and programs supporting individuals with disabilities. Joint Federal action
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