Pre-Employment Transition Services: The Five Work Services That Can Start in High School, Before an ACCES-VR Application

If you have been told that ACCES-VR comes later, you were told something partly true. Its full vocational rehabilitation program begins with an application and an eligibility decision, and our own transition timeline puts the referral window for it two years before a student's expected exit from school.

What that leaves out is a set of services the law places earlier, and they run in the opposite order: the services first, with no application needed to begin them. They are called pre-employment transition services, or Pre-ETS. Here is what the law says about them, what the five are, who delivers them in New York, and two questions that help a family find them.

Services First, Without an Application

Start with the statute, 29 U.S.C. §733. Each state must ensure that its vocational rehabilitation agency, "in collaboration with the local educational agencies involved, shall provide, or arrange for the provision of, pre-employment transition services for all students with disabilities in need of such services who are eligible or potentially eligible for services under this subchapter." In New York, the State Education Department's memo names two such agencies: ACCES-VR and the NYS Commission for the Blind.

Two phrases in that sentence matter most. Potentially eligible is why an application is not the starting line. In need of such services is the condition the law sets, and it is a question about your student, answered with the people who know them, not by a website. The federal regulation, 34 CFR §361.48, settles the order:

"Pre-employment transition services must be made available Statewide to all students with disabilities, regardless of whether the student has applied or been determined eligible for vocational rehabilitation services."

The Education Department's policy brief, attached to its memo of October 1, 2025, adds the sentence a family with a 504 plan rather than an IEP needs: "Students with individualized education programs (IEP) and those with Section 504 Plans may participate in Pre-ETS."

ACCES-VR's own transition page draws the same line: "it is expected that students who are age 14 and/or more than two years prior to anticipated exit from high school will receive Pre-ETS services without formal application to ACCES-VR." That is about when no application is needed, not a promise about any one student, and the same page is plain about the wider program: "Unlike special education, the vocational rehabilitation program is not an entitlement program. You must be determined to be eligible to receive vocational rehabilitation services."

When They Can Start

The brief gives the ages in two sentences worth having exactly:

"Students with disabilities can begin participating in Pre-ETS as early as age 14 while the student is enrolled in an educational program. A student receiving Pre-ETS cannot exceed the age of 22."

For students in secondary school, it adds that Pre-ETS "may be delivered in either the educational setting during the school day, or outside of the educational setting, including after school, school breaks, summer vacation or weekends." The IEP has its own clock for transition planning, which our timeline article walks through date by date. Pre-ETS run alongside that clock, not instead of it.

The Five Services, in the Law's Own Words

The statute lists them under the heading "Required activities." Each is quoted below as written, with examples from the Education Department's brief, which says "All Pre-ETS are based on a student's individualized needs." The examples show what a service can look like, not a menu every student is handed.

1. "job exploration counseling" — for example, "Administering vocational interest inventories to assist with the identification of career pathways of interest."
2. "work-based learning experiences, which may include in-school or after school opportunities, or experience outside the traditional school setting (including internships), that is provided in an integrated environment to the maximum extent possible" — for example, "A job shadowing experience" or "Informational interviews with professionals working in fields of interest to the student."
3. "counseling on opportunities for enrollment in comprehensive transition or postsecondary educational programs at institutions of higher education" — for example, advice on college and training applications and the federal student aid form, or "Connecting the student to the disability support services that would be available through other state agencies."
4. "workplace readiness training to develop social skills and independent living" — for example, "Increasing financial literacy skills," "Improving travel skills," or "A work-readiness skills club that meets during or after school."
5. "instruction in self-advocacy, which may include peer mentoring" — its examples close this article, because they belong to the student.

ACCES-VR's Pre-ETS page says these services "are available free of charge to eligible or potentially eligible students through ACCES-VR."

Who Delivers Them, and What Stays With the School

The brief answers the first half in two sentences:

"For PE students, Pre-ETS are delivered by community-based providers or vendors funded by ACCES-VR. For students who are already receiving services from ACCES-VR, Pre-ETS can be provided by both community-based providers and/or ACCES-VR counselors."

"PE" is the brief's shorthand for potentially eligible: a student who has not yet applied. The providers are contracted by ACCES-VR and work "in partnership with the student, their family, the school, and any other agencies involved with the student." This article names none of them; the two questions below are how a family finds the ones serving its area.

What stays with the school matters just as much:

"The delivery of Pre-ETS is not intended to shift the responsibility of service delivery from LEAs to ACCES-VR. The school district will continue to be responsible for providing transition planning and educational services."

An LEA, a local educational agency, is the law's term for the school district. And for a student who is blind, the brief says provision of Pre-ETS "is coordinated through the New York State Office of Children and Family Services Commission for the Blind (NYSCB)," and it gives NYSCB's statewide contact.

Two Questions That Open the Door

If no one at school has been designated, ACCES-VR's Pre-ETS page gives families the route directly: "To access Pre-ETS, contact the ACCES-VR Senior Vocational Rehabilitation Counselor for Transition and Youth Services (SVRC TAYS) in your area." Contact details are on ACCES-VR's transition page, and in Western New York, ACCES-VR's Buffalo District Office lists Allegany, Cattaraugus, Chautauqua, Erie, Genesee, Niagara, Orleans and Wyoming as the counties it serves. A student already working with ACCES-VR goes through their own counselor, who, the brief says, "makes arrangements for Pre-ETS."

The second question runs through consent, in the brief's words:

"Consent from the student's parent (or from the student who is 18 years of age or older) must be obtained prior to inviting a participating agency to the meeting."

The consent is written, the brief explains, because "personally confidential information about a student will be shared at the CSE meeting." Notice the parenthesis: in the Education Department's own sentence, consent passes to the student at eighteen. The CSE meeting is where the IEP is developed, so this question is for students with one. For a student with a 504 plan, the first question is the one to ask, with the brief's 504 sentence in hand.

Where the Special Wage Comes In

These services also matter past school. Our article on the special wage explains the federal 14(c) certificate that lets some employers pay a worker with a disability less than the minimum wage, and it noted additional conditions for workers aged 24 or younger. Under 29 U.S.C. §794g, a certificate holder may not pay an individual with a disability "who is age 24 or younger" below the federal minimum wage unless conditions are met. For someone starting such a job, the first step that must be completed and documented before the work begins is that the individual "has received pre-employment transition services that are available to the individual under section 733 of this title, or transition services under the Individuals with Disabilities Education Act". Section 733 is where this article began.

The Fifth Service Belongs to the Student

All five are for the student, but the fifth is the one nobody else can do for them. The statute calls it "instruction in self-advocacy, which may include peer mentoring," and the brief's examples read like a list of what a young adult will one day do at work without a parent in the room:

• "Disability understanding and disclosure"
• "Identifying independence and decision making (including supported decision making)"
• "Identifying, selecting, requesting and utilizing accommodations"
• "Knowledge of rights and responsibilities"

Those are your student's skills, not yours: deciding whether and how to tell an employer about a disability, asking for an accommodation, making decisions with support rather than having them made. The brief states the goal of Pre-ETS as "to prepare students to become engaged in their own transition and vocational planning." Our guide to guardianship and supported decision-making covers the supported part from the family's side.

So hand this article to your student. Let them ask the school who connects students to a provider, and let them raise, at the next CSE meeting, whether ACCES-VR should be invited, with your consent while they are under eighteen and their own after that. Practising those questions in high school, with you beside them rather than in front of them, is self-advocacy already.

The Honest Summary

Where to Take It

For the dates on the school's side, the IEP clock and the two-year referral window, the transition timeline is the page. For the bigger picture of leaving school for work, see our guide to moving from school to work, and for what ACCES-VR offers once a student applies, our ACCES-VR guide. And when school is ending and the goal is a job, finding work that fits is what we do.