Public Schools in Puerto Rico with No Resources to Comply with Vocational Evaluations for students with Special Needs

More than 90% of Special Education students are not evaluated on their vocational skills, which affects their possibilities of development and employment, and their mental health as well, although there has been a law in place for 13 years that mandates this.

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Eligio Hernández, Secretary of the Department of Education

Foto tomada de Facebook/LauraCristinaMoscoso

Reinalice Carrero-Guerra, a 23-year-old with Down Syndrome, is one of the thousands of special education students who never received a vocational and career evaluation from the Department of Education, despite there being a law in place for 13 years now that requires conducting such assessment.

She neither received help from the Vocational Rehabilitation Administration (ARV in Spanish), an agency ascribed to the Department of Labor and Human Resources (DTRH in Spanish) that is supposed to guide citizens with functional diversity into the workforce. Her mother Alice Guerra said she unsuccessfully requested services after her daughter graduated from high school at 18.


“They interviewed her many times. The person assigned to the case was never there, and I was redirected to anyone else who was available. They stopped calling me and writing to me. They were to train her to work in a supermarket, but that never happened,” said Guerra.

Juliana Ortiz-Pérez, diagnosed with autism, was not evaluated either by the Department of Education. Her mother, Joana Pérez-Coderi, said it was not until she turned 20 that she began a procedure with the Vocational Rehabilitation program for employment and skills for independent living.

Luis Alonso-Quesada, who is partially deaf and blind, and was born with heart disease and mobility problems, was evaluated by the Department of Education at 16. However, his mother, Mónica Quesada, said the vocational evaluation was pointless, and the agency forced them to go straight to Vocational Rehabilitation’s appointments. On one occasion, they had to wait for hours for the appointment , and the specialist sent them off in five minutes. “They spent hardly any time with us.”

Law 263 of 2006, the Vocational and Career Evaluation Service Act, establishes that students with functional diversity must receive a preliminary vocational evaluation at the age of 12, an evaluation that must be completed before they reach 15.

That evaluation seeks to identify and anticipate the behavior of a person with functional diversity in the areas of vocational orientation and employment. Some students come from the public school system or request Vocational Rehabilitation services to receive evaluations, therapies or additional assistance to help them enter the workforce.

The evaluation, as established by the Law, is “a right of students with disabilities in the process of transition to the working force who receive special education services under the Department of Education Special Education Program , guaranteeing their full development and integration into the workforce in their communities.”

“[The evaluation ] was useless. Not even for the Vocational Rehabilitation program. There [was] no job, eyeglasses, or any assistance. Luilli received nothing. The job he got we got it for him at a pharmacy,” Quesada said.

The Department of Education Associate Secretary of Special Educat

Eliezer Ramos-Parés, the Department of Education Associate Secretary of Special Education

ion, Eliezer Ramos-Parés, alleged that Law 263 — passed 13 years ago — is too recent, and that the agency is looking for resources trained in Vocational and Career Evaluation.

“I admit that the project is in an early stage, in terms of its implementation,” said Ramos-Parés in an interview with the Center for Investigative Journalism (CPI, in Spanish).


Although Law 263 acknowledges that school counselors trained in Vocational Evaluation are the best qualified to do the evaluations , the law also allows external Vocational Evaluation specialists to be hired.

“We’re trying to immediately outsource these services in the private sector to establish work plans and staff retraining. It’s an issue that requires many hours of training, additional hours beyond the training, and a multi-million-dollar investment by the Department,” he said.

“Why weren’t the evaluations budgeted? ” the CPI asked.

“The money comes from two sources : direct or transitional services for students. Once [a] viable proposal for the services was received, the analysis was done and the funds were set aside,” Ramos-Parés answered through written statements two months after the information was requested, without addressing the direct question.

The agency alleged it has tried to recruit specialists and vocational evaluators to administer the assessments . However, the CPI confirmed that no company or individual has submitted a proposal for these purposes.

“The issue with the Department [of Education] is that they have been focusing their efforts on working on the budget and by focusing on that, there are services that are not being provided for or are falling behind ,” said Attorney Adamaris Feliciano, of the Special Education Class Action Lawsuit Steering Committee.

Among the issues that have been neglected is the hiring of specialists and resources. “Since there are no funds to pay those already hired , they’re not hiring anyone else. That’s what [Education] has told us,” she added.

When asked about the performance of the students being evaluated , Ramos-Parés said he didn’t know. He said the Department lacks that data because the program is not monitored. The agency also has no statistics about the results of vocational and career evaluations, or the performance of students that have been evaluated .

“There are a few counselors who have the knowledge to administer the tests. It’s not that they’re not done, but I don’t have them registered in the system because there are many other evaluations related to the students’ transition [to post-secondary activities],” he added .

“I would like to be able to tell you that I have all the resources to assist the entire population, the 59,000 students who are eligible for this evaluation, but the Department doesn’t have the resources for that ,” he acknowledged .

Dr. Rosa Lugo, who worked on the drafting of the Vocational and Career Evaluation Service Act and heads the Vocational Rehabilitation Evaluation and Adjustment Center, said that very few students are evaluated .

“The majority, more than 90% of [Special Education] students have not been evaluated when they arrive at the Vocational Rehabilitation program ,” the specialist said.

Regarding the lack of data on student performance, Ramos-Parés said: “if you ask me how many speech therapies are offered in the schools, I know that, because the system was obviously focused on addressing deficiencies and a need related to these therapies. So, now is the time to address the vocational and career evaluation problem.”

Negligence turns into more therapy and more psychological help

If schools don’t offer an effective transition process, as well as vocational and career evaluations tailored to the needs of special education students with functional diversity, many of these children will require more therapy and long-term psychological help in the long run, clinical psychologists Moraima García-Rohena and Ángeles Acosta warned.

“Certainly, one of the great difficulties that many of the cases [of students with functional diversity] have is that they finish high school or are close to finishing, and they haven’t been evaluated with skills or vocational assessments. And they’re not ready,” Dr. García-Rohena said.

Not being evaluated before graduating and going on to the Vocational Rehabilitation program without prior evaluation, results in students possibly not having an adequate transition process. The psychology professor at the University of Puerto Rico, Río Piedras Campus (UPR), warned that it is possible that when they finish their school years, they stay home due to the lack of pre-employment experiences. Being inactive, they could become depressed or develop mental health problems, depending on their cognitive profile.

“Being cooped up at home for too long, without a routine or a short-term goal, can affect their mental balance, develop bipolarity, depression, anxiety disorders or crises,” Garcia-Rohena explained.

The college professor said that of nearly 1,000 patients she has seen in her office since 2009, close to six cases -of students with functional diversity- previously had Education’s vocational evaluation.

Dr. García-Rohena warned that if this situation is not addressed immediately, Education will continue to create a public health problem. Furthermore, she added, that while tests are offered, the agency must establish an effective transition method for these students.

“We’re going to have a huge population [of special education with functional diversity students] that will eventually be old and who will be struggling, not only with their primary impairment, but also with their mental health impairment, caused by a social problem that wasn’t addressed in time,” the clinical psychologist warned.

Many of these young people will go into the Vocational Rehabilitation program after graduation to join the workforce. In the specialist’s opinion, this evaluation and planning process must take place before reaching Vocational Rehabilitation programs.

“They have skills and vocational interests since childhood that we must reinforce , so that they develop over time, and not wait till high school,” said the specialist with 43 years of experience working with functionally diverse.

Education suggests changes to the law

In addition to failing to comply with the current law, the Department of Education official believes Law 263, the Vocational and Career Evaluation Service Act, must be amended to defer from 12 to 16 years the age in which the tests are offered to special education students with functional diversity.

Both clinical psychologists, meanwhile, warned that vocational evaluations should not be put off until then.

Dr. García-Rohena said there is a population of students with functional diversity that, given their conditions, require preparation well in advance to know what the plan will be.

“Career development theories say it’s appropriate to begin evaluating [special education with functional diversity] students starting at the age of 12. It is assumed that career exploration begins between the ages of 12 and 14, and then more complex assessments are done. Another issue is that [Education] lacks the human and operational resources to administer the tests. Education’s stance is that the evaluations should be done at 16 [to lower costs],” Dr. Lugo said.

Although there is a debate among parents, experts , and the agency about when vocational testing should begin, Ramos-Parés said that, “according to the discussions I’ve had with academia,” special education with functional diversity students “could show some level of immaturity to produce a real result that allows outlining the objectives for that student.”

“[Staff trained to administer vocational evaluations] aren’t as available as the law calls for. Of course, the law needs to be revised,” said Ramos-Parés, who pointed out that it’s impossible to evaluate all of the students required by law due to the particularities of each condition. He alleged having “philosophical differences” with what the law requires, and that it should be changed. He said the agency has tried to administer the evaluations even without adequate funds or resources.

Education looks for ‘Plan C’

“Look, you can put in your story that Education recognizes a need for qualified personnel to administer the vocational and career evaluation,” Ramos-Parés insisted.

To work immediately with the evaluations, the agency said it now plans to train special education counselors and teachers to administer them.

“[We want] to train special education teachers within a much more holistic vision of teamwork, so that teachers can conduct these tests,” the official said.

In written statements, the Secretary of Special Education said the agency “is working on a collaborative agreement” with the University of Puerto Rico’s School of Counseling to develop public policies, manuals and workshops related to vocational evaluation.

“We will start with those interested in getting the certification outside work hours,” he added.

But, according to Elizabeth Avilés, a teacher at Ramón Power and Giralt School in San Juan, the administrative burden is already too much. “Now we have double tasks since the facilitators left [the schools],” said the Spanish teacher.

By law, “trained school counselors should be relieved of duties that limit them from offering Vocational Evaluation services.”

Few counselors trained to evaluate

The director of the Vocational Rehabilitation Evaluation and Adjustment Center explained that 13 years ago her agency — jointly with the Department of Education — trained more than 200 school counselors to become professionally certified in Vocational Evaluation.

The Vocational Rehabilitation program agreed with the Department of Education that they twould train school counselors on vocational evaluation, while Education provided the service.

However, according to the Education Department’s last census, most of the counselors who were trained then have retired, the Secretary of Special Education said.

Ramos-Parés said he is looking for support from the Vocational Rehabilitation program. This would imply delegating its responsibility. The director of Vocational Rehabilitation Counseling Services, María Benítez, said that “although it’s true that the Vocational Rehabilitation program is offering the service, the responsibility has to be on Education. Ideally, this vocational evaluation process should happen before [the students] reach the Vocational Rehabilitation program.”

Students with functional diversity waste time when they arrive at Vocational Rehabilitation in search of services if they don’t show up with a vocational evaluation previously carried out by Education.

“When these young people are in the school system, they must develop pre-employment skills, precisely so that when they are in 12th grade, it’s easier to point them toward a vocational goal and not begin then with the evaluation process. The faster you can prepare the person, the faster they can be integrated into the workforce,” Benítez added.

In addition to the evaluations, by virtue of Law 53 of 2016, to get the Functional and Pre-Employment Academic Skills Certification, students with functional diversity, who don’t receive their regular diploma due to their conditions, must be offered a vocational certification.

However, the director of the Vocational Rehabilitation Evaluation and Adjustment Center said offering the certification must be done after the vocational evaluation, which puts the student in a never-ending cycle.

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