Thank you for the opportunity to comment on this document. Listed below are areas that we believe could benefit from some additional work in order to be as helpful as possible to families and professionals who are working to develop measurable post-secondary goals.

1. The student sample goals do not really meet the definition of SMART goals. There are no time frames in any of the examples and some of the goals seem more like activities.
2. Sample student 5 is noted to have an applied studies diploma. They have the independent living goal as living in a group home or other supported housing (which is fine) and participating in volunteer activities through the Arc/day support/group homes.  While likely unintended and meant to show divergent needs, it appears to have a message that if you get an applied studies diploma you need to live in congregate housing participate in congregate activities. Perhaps changing day support to community engagement or community activities would help.
3. In Sample Student Scenario 1. The employment goal is very vague--work part-time in a retail store.  The education goal is to complete a sign language class with support at the community college.  The independent living goal is to complete an IL class at the local CIL.  A better connection between these would be helpful and again, completion of the IL class seems to be an activity that would support a goal, not a goal itself.
4. In Sample Student Scenario 2, DARS is referred to as DRS; that should be updated. There are no time frames on the proposed goals.
5. Student Scenario #3.  The description notes a transition assessment--singular.  Since multiple assessments are required, it would be helpful to modify this. The employment goal here is also vague:  Work part-time in an employment setting that meets needs and preferences. It is not specific or measurable and there is no timeframe. The student is to complete a training program to improve communication skills in the community and employment site.  To be as helpful as possible to the reader, it should note what skills are to be improved (verbal, written) and in what way.  There is a reference to learning and using a problem-solving model to make food and wardrobe choices. It is unclear what that means.  Parents reading it would likely be unclear.  Finally, the independent living goal is to maintain the communication skills learned in high school  Again, that is vague and does not meet SMARG goal critiera.
6. Student Scenario #4. This is a new addition from the previous version of the guidance and we appreciate that an example of someone with very significant disabilities was included.  As with the other scenarios, some of the goals appear to be activities.  Going back to an earlier point about assumptions. The description states that the student lives in a residential facility due to his complex health needs and his independent living goal is to live in a facility that supports his medical and social needs. While these are examples, this one is less than progressive and presumes that a person with a very complex disability has to live in a facility.  We would ask that rewording be considered as follows:  Edwin has complex health needs and currently lives in a residential facility--and change the goal to something like "live in a community-based setting that supports his medical and social needs. The DD Waivers have demonstrated that people with the most complex needs can live at home or in an apartment if they have the appropriate services and supports. This was evidenced by the closure of 4 of the 5 training centers. We believe that softening the language to show high expectations for all people would be helpful.

Thank you again for the opportunity to make this public comment.  We are happy to respond to any questions you may have.