A Practical Guide to Pre-Employment Transition Services (Pre-ETS) for Schools

By the Ori Learning Curriculum Team · Reviewed by Dr. Miriam Gayle, EdD, VP of Operations · Updated August 27, 2026

Pre-Employment Transition Services (Pre-ETS) are five services that state Vocational Rehabilitation (VR) agencies must make available statewide to students with disabilities who need them and are eligible or potentially eligible for VR services. They are authorized under the Rehabilitation Act §113, as amended by the Workforce Innovation and Opportunity Act (WIOA), and a student does not need an open VR case to receive them. For school teams, Pre-ETS is a chance to give transition instruction a practical structure. The goal the services work toward is competitive integrated employment (CIE): full- or part-time work, including self-employment, in an integrated setting, paid at or above the highest applicable minimum wage and at rates comparable to coworkers without disabilities doing similar work, with comparable benefits and opportunities for advancement (34 CFR §361.5(c)(9)).

For new transition coordinators, the first question is usually some version of “Where do I even start?” This guide is a practical answer: what Pre-ETS involves, who delivers each service, how the funding actually works, what to document, and how a structured curriculum supports the classroom-based services without substituting for VR coordination.

What are the five required Pre-ETS services?

Under the Rehabilitation Act as amended by WIOA (Rehabilitation Act §113), every state VR agency must make five Pre-Employment Transition Services available to eligible and potentially eligible students with disabilities (34 CFR §361.48(a)(2)):

1. Job exploration counseling — helping students learn about careers, their own interests, and the local labor market.
2. Work-based learning experiences — in-school or after-school opportunities, including internships and job shadowing, provided in an integrated community setting to the maximum extent possible.
3. Counseling on postsecondary education and training — guidance on college, trade school, certificate programs, and other paths after high school.
4. Workplace readiness training — training in workplace-readiness skills such as communication, time management, problem-solving, social skills, and independent living.
5. Instruction in self-advocacy — teaching students to understand their strengths and learn if, when, and how to disclose a disability and request accommodations, including through peer mentoring.

One quick clarification, because it trips up a lot of teams: these five are the required services. With funds left after the five are covered, VR agencies may also provide nine authorized activities — and coordination activities, like attending IEP meetings when invited, are something VR is required to carry out, not an optional extra (34 CFR §361.48(a)(3)–(4)). So “the five” are the floor, not the whole of Pre-ETS.

Here is what each service tends to look like once it lands in an actual school, and where a sequenced curriculum can carry the classroom-based pieces.

On paper these read like five neat boxes. In a real classroom they blur together, and that is a good thing. Work-based learning is the clearest example of why. The first time a student clocks in somewhere real — a hospital supply room, a grocery back-of-house, a campus mailroom — the other four services get somewhere to land: job exploration gains a reference point, self-advocacy has a reason, and postsecondary planning stops being abstract. Classroom instruction can prepare students for and reinforce that experience; it cannot substitute for it.

The research points the same way. In the systematic review of secondary-transition predictors synthesized for the National Technical Assistance Center on Transition, paid work experience during high school is identified as a predictor of post-school employment for students with disabilities (Mazzotti et al., 2021). Predictor evidence is correlational — it supports giving work-based learning early attention rather than saving it for last; it does not establish that any single activity causes an employment outcome.

Who is eligible for Pre-ETS?

Pre-ETS are available to students with disabilities who are eligible or “potentially eligible” for VR services and who need the services — a student does not need an approved VR case to receive them (34 CFR §361.48(a)(1)). The terms matter: a student who is eligible has applied and been determined eligible for VR, while a student who is potentially eligible has not applied for VR services or has applied but has not yet been determined eligible. Federally, a “student with a disability” must be enrolled in a secondary, postsecondary, or other recognized education program, fall within the state’s applicable age range, and either receive services under IDEA or qualify as an individual with a disability under Section 504 (34 CFR §361.5(c)(51)). Documentation, consent, and referral steps vary by state, so confirm the specifics locally.

The 504 inclusion is worth pausing on, because plenty of guides miss it: the federal definition is not limited to students with IEPs. Identification and referral procedures should include students who qualify under Section 504, following the state’s age, documentation, and consent rules.

The early timing is deliberate. Pre-ETS is designed to reach students while they still have the structure of school around them, rather than waiting until after graduation when support tends to fall away. The students most likely to miss out are often the ones whose support needs are least visible on paper — the quiet ones drifting toward a gap year that turns into three. Pre-ETS exists to close that gap before it opens.

How are Pre-ETS funded?

Short answer: Pre-ETS are funded through state VR agencies under WIOA, which must reserve at least 15% of the state’s federal VR allotment specifically for Pre-ETS (34 CFR §361.65(a)(3)). VR funds are a supplement to, never a replacement for, the transition services schools are already required to provide under IDEA.

This is where teams need to be precise. The 15% reserve is real, and it is meaningful money — but it is a VR funding requirement, not an automatic reimbursement stream for districts. VR funds do not relieve a district of its obligation to ensure a free appropriate public education (FAPE) under IDEA, and which agency delivers or pays for a particular service is set by applicable law and the state’s formal interagency agreement (34 CFR §361.22; 34 CFR §300.154). Do not assume staff time, transportation, or another cost is reimbursable merely because the activity relates to Pre-ETS.

In practice, that means finding the state cooperative or interagency agreement — and any local implementing agreement — and using it to name school and VR contacts, define referral and consent steps, and state who delivers and pays for each activity. Then aim for a standing relationship rather than a paper one: a named VR counselor who knows the students, sits in on planning, and treats school staff as partners rather than referral sources. If roles are unclear, clarify them before building delivery around assumed reimbursement.

How do schools deliver Pre-ETS?

Delivery arrangements vary by state and may be individual or group-based. When services run as group instruction, a consistent, sequenced curriculum matters even more: the same content has to work for a roomful of students with very different needs. Common arrangements fall into a partnership between the school and VR:

• VR-led — a VR counselor or contracted provider delivers services directly, often in group sessions at the school.
• School-led with VR support — special education or transition staff deliver the classroom-based services using an agreed curriculum, coordinated with VR. Whether and how VR reimburses any of this is state-dependent and set by a formal agreement, so do not assume reimbursement.
• Blended — schools handle workplace readiness and self-advocacy instruction in the classroom, while VR coordinates community-based work experiences.

The hard part in practice is not deciding whether Pre-ETS matters. It is delivering all five services consistently, across multiple staff and a wide range of student needs, in a way the team can document. Unsequenced one-off lessons that live in one staff member’s head create continuity and documentation risk — the program stops the day that person is out. The fix is not working harder. It is a sequence anyone on the team can pick up and teach.

A practical documentation baseline

Documentation is the quiet pain point of Pre-ETS. State VR rules control here: every agency sets its own referral, consent, and reporting paperwork, so get your agency’s current template or written field list before delivery begins. As a planning baseline — not a universal requirement — ask whether records must capture:

• The student’s eligibility or potentially-eligible status, with consent and referral as required by your state.
• The Pre-ETS service category (which of the five).
• The date, duration, and whether the service was delivered individually or in a group.
• The provider and the location.
• A short description of the activity and the student’s participation or outcome.

This is dull work, and it is where a structured program earns its keep: mapping each activity to a service category up front reduces recoding later. Confirm whether your VR agency requires student-level hours or another reporting format.

How to evaluate a transition curriculum

If group delivery and documentation are the real problems, then the question is not “which brand” but “does this curriculum solve those problems?” Before adopting anything, ask four questions:

• Does it map clearly to the classroom-based Pre-ETS services (workplace readiness, self-advocacy, career exploration, postsecondary planning)?
• Is it sequenced, so a substitute or paraprofessional can pick up the next lesson without the lead teacher?
• Does it differentiate, so the same activity works for students with a wide range of support needs in one group?
• Does it make documentation easier, not harder — can you show a VR partner what was taught, when, and to whom?

A curriculum that does those four things is far easier to justify and document than a folder of one-off lessons, which matters when you are accountable to both your business office and a VR partner. A planned curriculum like the Ori Learning Transition Curriculum is one example: its employment-skills lessons walk students through building a resume, completing a job application, and practicing interviews, with differentiation tiers within each lesson and documentation support built in. For ready-to-use interview practice, see our 42 mock interview questions for high school students. Confirm with your VR partner how each lesson should be classified under the five service categories.

If you’re weighing options, our guide on how to choose a transition curriculum walks through the questions worth asking before you commit, and seven mistakes to avoid in special-education transition lesson plans.

Pre-ETS vs. transition services in the IEP

Short answer: Transition services are part of the IEP process under IDEA, and they are the district’s responsibility. Pre-ETS are made available and funded through VR under WIOA. They overlap and should be coordinated, but they come from different laws and different funding streams.

This distinction matters more than it sounds, because Pre-ETS is a VR-side service framework, not the school’s IDEA compliance framework. Pre-ETS activities can be written into an IEP as coordinated transition activities, but participating in Pre-ETS does not, on its own, satisfy IDEA. The IEP must still meet IDEA’s transition requirements: measurable postsecondary goals based on age-appropriate transition assessments and updated annually, transition services including courses of study, annual IEP goals tied to the student’s transition needs, evidence the student was invited to the IEP meeting, and — when appropriate and with the required consent — invitation of a representative of a participating agency (34 CFR §300.320(b); §300.321(b)). Indicator 13 is the compliance indicator states use to measure these requirements — it does not create a separate set of obligations.

Pre-ETS or a life-skills program: which fits your students?

It is easy to confuse Pre-ETS with functional life-skills instruction, but the difference is about the student’s goal, not the student’s disability. Functional life-skills curricula often emphasize daily living, community participation, and independence. Pre-ETS-aligned employment-readiness content focuses more directly on career exploration, workplace readiness, self-advocacy, postsecondary options, and work-based learning.

Here is the part many guides get badly wrong: Pre-ETS must be available to eligible and potentially eligible students who need the services, including students with the most significant disabilities — the regulation says “without regard to the type of disability” (34 CFR §361.48(a)). That is not a footnote; it is central to WIOA’s intent. A student working on functional daily-living skills can receive Pre-ETS to explore supported or customized employment — pathways to competitive integrated employment, not alternatives to it. Functional life-skills instruction and Pre-ETS can run concurrently when both match the student’s needs.

So the useful question is not “mild or significant?” It is: what does this student need to be doing eighteen months from now, and what are their measurable postsecondary goals? The mismatch shows up quickly when the answer and the materials do not line up: a college-bound junior may tune out if the work feels unrelated to employment or postsecondary goals, while a student who needs concrete, repeated practice may struggle with an abstract career-interest inventory. Start from current transition-assessment information and the student’s measurable postsecondary goals, use Pre-ETS to organize the employment and postsecondary instruction, and use the IEP process for the full individualized transition program — including independent living where appropriate.

Getting started: a Pre-ETS checklist for schools

1. Identify your state VR agency’s Pre-ETS contact and find the written policy, eligible age range, consent and referral process, and cooperative-agreement terms.
2. Map your current transition instruction to the five required services, and find the gaps.
3. Decide your delivery model (VR-led, school-led with VR support, or blended) and clarify which costs are IDEA/LEA responsibilities and which VR may support.
4. Adopt or build a sequenced curriculum for the classroom-based services (workplace readiness, self-advocacy, career exploration, postsecondary planning).
5. Set up VR-aligned documentation so services are trackable by category, date, duration, provider, and group-vs-individual delivery.
6. When VR is likely to provide or pay for transition services, get the required consent, then invite the VR representative to the IEP meeting. Review the IDEA transition requirements measured by Indicator 13 separately — Pre-ETS does not satisfy them on its own.

Frequently asked questions

Is Pre-ETS the same as transition services in the IEP?

No. Transition services are part of the IEP process under IDEA; Pre-ETS are made available and funded through Vocational Rehabilitation under WIOA. They overlap and should be coordinated, but they come from different laws and different funding streams, which is exactly why coordinating them well matters.

Do students need an approved VR case to receive Pre-ETS?

No. A student who meets the federal definition of a “student with a disability,” needs Pre-ETS, and has not applied for VR — or has applied but has not yet been determined eligible — can receive the five required services as “potentially eligible.” State consent, documentation, and referral procedures still apply. Individualized VR services under an Individualized Plan for Employment (IPE) require an application, an eligibility determination, and an approved IPE (34 CFR §§361.41–361.45).

What ages does Pre-ETS cover?

The range is set by each state within federal parameters. Under 34 CFR §361.5(c)(51), the minimum is the state’s earliest age for IDEA transition services unless the state elects a lower minimum for Pre-ETS, and the maximum is 21 unless state law sets a higher maximum age for IDEA services. Confirm the operative range with your state VR agency.

Are Pre-ETS only for students with significant disabilities, or only for diploma-track students?

Neither. Pre-ETS are for eligible and potentially eligible students with disabilities who need the services, including students with the most significant disabilities and regardless of diploma track. The goal is competitive integrated employment, and students working on functional skills can receive Pre-ETS to explore supported or customized employment as pathways toward it.

Can a single curriculum cover all five Pre-ETS services?

No. A curriculum can support job exploration counseling, postsecondary counseling, workplace-readiness training, and self-advocacy instruction. It can prepare students for and help document work-based learning, but it cannot replace the actual work-based learning experience, provided in an integrated community setting to the maximum extent possible.