Fiscal Year 2007 Monitoring Report on the Vocational Rehabilitation and
Independent Living Programs in Washington

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**U.S. Department of Education**

**Office of Special Education and\
Rehabilitative Services**

**Rehabilitation Services Administration**

**September 7, 2007**

> contentS

EXECUTIVE
SUMMARY................................................\.................3\
\
INTRODUCTION...........................................................................5\
\
CHAPTER 1: REVIEW
PROCESS......................................................7

cHAPTER 2: DIVISION OF VOCATIONAL REHABILITATION AND\
SUPPORTED EMPLOYMENT
PROGRAMS...........................\...............9

CHAPTER 3: FISCAL REVIEW OF THE VR PROGRAM\..........................18

CHAPTER 4: BLIND AND VISUALLY IMPAIRED VOCATIONAL REHABILITATION AND
SUPPORTED EMPLOYMENT PROGRAMS....\....24

CHAPTER 5: FISCAL REPORT FOR BLIND AND VISUALLY IMPAIRED
PROGRAMS......................................................\......................\.....33

CHAPTER 6 INDEPENDENT LIVING ROGRAM................................39

CHAPTER 7: INDEPENDENT LIVING FOR OLDER BLIND PROGRAM....42

CHAPTER 8: PROGRESS ON ISSUES RAISED IN PREVIOUS REVIEWS

OF THE DIVISION OF VOCATIONAL REHABILITATION PROGRAM \.....44

CHAPTER 9: STATUS OF ISSUES RAISED IN PREVIOUS REVIEWS OF

THE DIVISION FOR THE BLIND AND VISUALLY IMPAIRED
PROGRAM.............................................................................\...\....46

CHAPTER 10: SUMMARY
CONCLUSION...............................\............47

## Executive Summary

## 

The Rehabilitation Services Administration (RSA) reviewed the
performance of the following programs of the Rehabilitation Act of 1973,
as amended (the Act) in the state of Washington (WA):

-   the Vocational Rehabilitation (VR) program, established under Title
    I;

-   the supported employment (SE) program, established under Title VI,
    Part B;

-   the independent living (IL) programs, authorized under Title VII,
    Part B; and

-   the Independent Living Services Program for Older Individuals Who
    Are Blind (OIB), established under Title VII, Chapter 2.

## 

In WA the Division of Vocational Rehabilitation (DVR) is located within
the Department of Social and Health Services and is responsible for the
general VR program, SE and maintains their own IL program. The
Department of Services for the Blind (DSB) reports directly to
Governor's office and is responsible for VR, SE, OIB and their own
unique IL program for people with visual impairments.

Both DVR and DSB have DSA/DSU responsibilities as it relates to the IL
program. DSB and DVR also maintain their own IL programs.

RSA's review began in the fall of 2006 and ended in the summer of 2007.
During this time, RSA's WA state team:

-   gathered and reviewed information regarding each programs
    performance;

-   identified a wide range of VR and IL stakeholders and invited them
    to provide input into the review process;

-   conducted two on-site visits, and held multiple discussions with
    state agency staff, SRC members, SILC members, and stakeholders to
    share information, identify effective practices and areas for
    improvement;

-   provided technical assistance;

-   worked with DSB, DVR and stakeholders to develop goals, strategies,
    and evaluation methods to address performance and compliance issues;
    and

-   identified the technical assistance that RSA would provide to help
    improve program performance.

As a result of the review, RSA:

-   identified effective practices;

-   identified performance and compliance issues;

-   and DVR and DSB developed performance and compliance goals and
    strategies related to selected issues;

-   identified the technical assistance that it would provide assist the
    agency to achieve the goals identified as a result of the review;

-   made recommendations in those instances when DSB, DVR and RSA did
    not agree on issues; and

-   identified potential issues for further review.

Strengths and Challenges:

DVR is addressing a number of issues, all of which are closely related
to the long-term presence of a particularly large waiting list. These
issues include Community Rehabilitation Program (CRP) utilization,
caseload efficiency, and relationships with community partners, consumer
relations, data/fiscal tracking and forecasting future demands related
to taking people off the waiting list. DVR has recently demonstrated
significant progress in addressing these issues.

The IL community in WA has historically dealt with capacity issues,
particularly as it relates to unserved parts of the state. They have
recently been presented with a number of opportunities to increase
funding, and thus capacity, and are in the early phases of maximizing
those opportunities.

DSB has been coping with increasing demand, declining rehabilitation
rates, and increasing costs to reach an employment outcome. The agency
is working to address this through new initiatives to focus their
multiple programs around a few central themes, enhancing OTC efforts and
expanding CRP system capacity.

The OIB program is working to balance the needs of serving
high-population urban areas with rural, less populated areas. OIB
resources in the lower population areas report being able to meet needs
while being concerned that significant (and likely) increases in need
would be problematic.

## Introduction

Section 107 of the Rehabilitation Act of 1973, as amended, requires the
Commissioner of the Rehabilitation Services Administration (RSA) to
conduct annual reviews and periodic on-site monitoring of programs
authorized under Title I of the Act to determine whether a state
vocational rehabilitation (VR) agency is complying substantially with
the provisions of its State Plan under section 101 of the Act and with
the evaluation standards and performance indicators established under
section 106. In addition, the Commissioner must assess the degree to
which VR agencies are complying with the assurances made in the
Supplement for Supported Employment under Title VI of the Act and
programs offered under Title VII of the Act are substantially complying
with their respective state plan assurances and program requirements.

In order to fulfill its monitoring responsibilities, RSA:

-   reviewed the state agency's performance in assisting eligible
    individuals with disabilities to achieve high-quality employment and
    independent living outcomes;

-   developed, jointly with the state agency, performance and compliance
    goals as well as strategies to achieve those goals; and

-   provided technical assistance (TA) to the state agency in order to
    improve its performance, meet its goals, and fulfill its state plan
    assurances.

## Scope of the Review

RSA reviewed the performance of the following programs of the Act:

-   the VR program, established under Title I;

-   the Supported Employment (SE) program, established under Title VI,
    Part B;

-   the Independent Living (IL) programs, authorized under Title VII,
    Part B; and

-   the Independent Living Services Program for Older Individuals Who
    Are Blind (OIB), established under Title VII, Chapter 2.

In addition, RSA also reviewed DVR and DSB progress on:

-   the agencies' Corrective Action Plan (CAP) that was established as a
    result of findings from RSA's FY 2004 Section 107 monitoring review;

-   the assurances that DVR and DSB made to RSA in conjunction with its
    FY 2007 state plan.

[Washington Administration of the VR, SE, IL, and OIB
Programs]{.underline}

DVR reports directly to the Secretary of the Department of Social and
Health Services and is responsible for the VR, SE and IL programs.

DSB reports directly to the Governor's office and is responsible for the
VR, SE, IL and OIB programs for people with visual impairments

For the four programs listed above, this report describes RSA's review
of DVR and DSB, provides information on the agency's performance,
identifies effective practices, identifies performance and compliance
issues, and identifies the related goals, strategies, and technical
assistance that RSA will provide to DVR and DSB to address each of the
issues identified during the review.

## Appreciation

RSA wishes to express appreciation to the representatives of the
Department of Social and Health Services, DSB, DVR, the State
Rehabilitation Councils, the Statewide Independent Living Council, and
the stakeholders who assisted the RSA monitoring team in the review of
DVR and DSB.

## Chapter I: RSA's Review Process

## Data Used During the Review

RSA's review of DVR and DSB began in the fall of 2006 and ended in the
summer of 2007. RSA's data collections are finalized and available at
different times throughout the year. During this review, RSA and the
state agency used the most recent data that was available from the FY
2005 and FY 2006 collections. As a result, this report cites data from
FY 2005 and FY 2006.

## Review Process Activities

During the review process RSA's WA state team:

-   gathered and reviewed information regarding DVR and DSB's
    performance;

-   identified a wide range of VR and IL stakeholders and invited them
    to provide input into the review process;

-   conducted one on-site visit, and held multiple discussions with
    state agency staff, SRC members, SILC members, and stakeholders to
    share information, identify effective practices and areas for
    improvement;

-   provided technical assistance to DVR and DSB;

-   worked with DVR and DSB to develop goals, strategies, and evaluation
    methods to address performance and compliance issues;

-   made recommendations to DVR and DSB in those instances when DVR and
    DSB and RSA did not agree on issues;

-   identified potential issues for further review; and

-   identified the technical assistance that RSA would provide to help
    DVR and DSB improve its performance.

## RSA WA State Team Review Participants 

Members of RSA's WA state team included representatives from each of
RSA's State Monitoring and Program Improvement's (SMPID's) five
functional units. The RSA WA state team was led by RSA's state liaison
to WA, Sean Barrett (Independent Living Unit) and the following RSA WA
team members: Carol Dobak (Vocational Rehabilitation unit), Fred
Isbister (Technical Assistance unit), Regina Luster (Fiscal Unit) and
Steve Zwillinger (Data Unit).

## Information Gathering 

During FY 2007, RSA began its review of DVR and DSB by analyzing
information including, but not limited to, RSA's various data
collections, DVR and DSB's VR and IL state plans, and DVR and DSB's
State Rehabilitation Council's (SRC's) Annual Report. After completing
its internal review, the RSA team carried out the following information
gathering activities with DVR, DSB and stakeholders in order to gain a
greater understanding of DVR and DSB's strengths and challenges:

-   the RSA WA state liaison conducted a series of individual
    teleconferences with the WA management team as well as stakeholders;

-   the RSA WA state team conducted four teleconferences with the DVR
    and DSB management;

-   the RSA WA state team held two teleconferences with stakeholders;

-   RSA conducted an on-site monitoring visit from May 1 through May
    10, 2007. May 1 through May 4, 2007 was spent reviewing DVR while
    May 7 through the May 10, 2007 was spent reviewing DSB;

-   the RSA WA state team held several teleconferences and on-site
    meetings focused on the SRC and IL services, including the
    development of the Statewide Independent Living Council (SILC); and

-   the RSA WA state team conducted teleconferences and held on-site
    meetings with the SILC chairperson as well as potential members of
    the SILC.

> [Chapter 2: Division of Vocational Rehabilitation and Supported
> Employment Programs]{.underline}

## Program Organization

DVR has 42 offices divided into three geographic areas. Area one covers
south King County, south to the Oregon border including the western
coast. Area two covers Seattle to Canada. Area three covers all
territory east of the Cascade Mountains.

DVR maintains 42 offices with a total of 301.3 FTEs that are comprised
of 245.3 field 46 administration positions. Of the field positions,
130.45 of the FTEs are listed as counselors with 22 being supervisors.
The remaining field positions are comprised of mostly Rehab Technicians
with a variety of other support type staff.

In early FY 2001, DVR implemented an order of selection (OOS) and has
done so continuously since that time. Under the agency's policies
governing its OOS, individuals are determined eligible for services and
then assigned to one of three priority categories: individuals with the
most severe disabilities, individuals with severe disabilities and all
other individuals with disabilities. As reported by the agency in its FY
2008 VR State Plan, DVR maintained a waiting list of 12,250 individuals
from all three priority categories at the beginning of FY 2007. During
the concluding months of FY 2006 and through FY 2007, the agency
undertook steps to reduce the number of individuals waiting to receive
services. As a result, by June of 2007, 7,700 (by August, 2007, 5,196)
individuals were waiting to receive services. The agency's continuing
efforts to serve increasing numbers of individuals on the waiting list
are discussed in greater detail in connection with Performance Issue 1,
pertaining to the agency's ability to manage its resources in an
efficient manner.

As reported to RSA on Form SF 269, "Financial Status Report," DVR spent
a total of \$55,340,524 on the administration and operation of the VR
program in FY 2006. With these funds, the agency provided services to
7,803 individuals with disabilities. Of this total, the agency assisted
1,969 individuals to achieve employment outcomes, 1,715 of whom were
employed in integrated settings without supports. During this period,
individuals achieving gainful employment earned an average hourly wage
of \$10.08 and worked an average of 27.17 hours per week.

**Table 1: Performance Measures by Year\
**

Table 1 provides fiscal and program data for fiscal years 2002 through
2006. These data provide an overview of the VR program's costs,
outcomes, and efficiency. The table identifies the amount of funds used
by the agency, the number of individuals who applied, and the number who
received services. It also provides information about the quality of the
agency's employment outcomes and its transition services.

  ----------------- -------------- -------------- -------------- -------------- --------------
  WASHINGTON        2002           2003           2004           2005           2006

  Total funds used  \$47,634,099   \$63,653,332   \$52,379,836   \$55,932,489   \$55,340,524

  Individuals       9,518          11,959         8,952          9,314          7,803
  served during                                                                 
  year                                                                          

  Applicants        13,510         16,109         11,236         10,492         9,164

  Closed after      2,495          4,949          4,612          3,957          4,303
  receiving                                                                     
  services                                                                      

  Closed with       1,365          2,405          2,107          1,737          1,969
  employment                                                                    
  outcomes                                                                      

  Employment        1,243          2,186          1,832          1,522          1,715
  outcomes without                                                              
  supports in an                                                                
  integrated                                                                    
  setting                                                                       

  Average cost per  \$5,004.63     \$5,322.63     \$5,851.19     \$6,005.21     \$7,092.21
  individual served                                                             

  Average cost per  \$34,896.78    \$26,467.08    \$24,859.91    \$32,200.63    \$28,105.90
  employment                                                                    
  outcome                                                                       

  Employment        28.66          37.78          40.23          31.06          35.58
  outcomes per                                                                  
  \$million spent                                                               

  Competitive       27.73          37.04          39.25          30.47          34.97
  employment                                                                    
  outcomes per                                                                  
  \$million spent                                                               

  Average hourly    \$10.06        \$9.81         \$10.08        \$10.28        \$10.08
  earnings for paid                                                             
  employment                                                                    
  outcomes                                                                      

  Average state     \$18.39        \$18.76        \$18.90        \$19.48        \$20.36
  hourly earnings                                                               

  Average hours     29.84          29.50          28.30          27.87          27.17
  worked per week                                                               
  for paid                                                                      
  employment                                                                    
  outcomes                                                                      

  Percent of        17.68          18.57          19.25          20.55          23.68
  transition age                                                                
  served to total                                                               
  served                                                                        

  Employment rate   63.95          49.40          50.79          49.94          49.46
  for transition                                                                
  age served                                                                    

  Average time      27.50          22.30          27.20          31.40          28.80
  between                                                                       
  application and                                                               
  closure (in                                                                   
  months) for                                                                   
  individuals with                                                              
  successful paid                                                               
  employment                                                                    
  outcomes                                                                      

  Average number of 26.81          32.50          24.59          27.72          24.16
  individuals                                                                   
  served per total                                                              
  staff                                                                         
  ----------------- -------------- -------------- -------------- -------------- --------------

  ------- ---------------------------------------------------------------
          Total Applicants

          2002

          13,510
  ------- ---------------------------------------------------------------

  ------- ---------------------------------------------------------------
          Total Applicants

          2003

          16,109
  ------- ---------------------------------------------------------------

  ------- ---------------------------------------------------------------
          Total Applicants

          2004

          11,236
  ------- ---------------------------------------------------------------

  ------- ---------------------------------------------------------------
          Total Applicants

          2005

          10,492
  ------- ---------------------------------------------------------------

  ------- ---------------------------------------------------------------
          Total Applicants

          2006

          9,164
  ------- ---------------------------------------------------------------

  -------- --------------------------------------------------------------
           Total Served

           2002

           9,518
  -------- --------------------------------------------------------------

  -------- --------------------------------------------------------------
           Total Served

           2003

           11,959
  -------- --------------------------------------------------------------

  -------- --------------------------------------------------------------
           Total Served

           2004

           8,952
  -------- --------------------------------------------------------------

  -------- --------------------------------------------------------------
           Total Served

           2005

           9,314
  -------- --------------------------------------------------------------

  -------- --------------------------------------------------------------
           Total Served

           2006

           7,803
  -------- --------------------------------------------------------------

  -------- --------------------------------------------------------------
           Total Closed

           2002

           2,495
  -------- --------------------------------------------------------------

  -------- --------------------------------------------------------------
           Total Closed

           2003

           4,949
  -------- --------------------------------------------------------------

  -------- --------------------------------------------------------------
           Total Closed

           2004

           4,612
  -------- --------------------------------------------------------------

  -------- --------------------------------------------------------------
           Total Closed

           2005

           3,957
  -------- --------------------------------------------------------------

  -------- --------------------------------------------------------------
           Total Closed

           2006

           4,303
  -------- --------------------------------------------------------------

  ----- -----------------------------------------------------------------
        Employment Outcomes

        2002

        1,365
  ----- -----------------------------------------------------------------

  ----- -----------------------------------------------------------------
        Employment Outcomes

        2003

        2,405
  ----- -----------------------------------------------------------------

  ----- -----------------------------------------------------------------
        Employment Outcomes

        2004

        2,107
  ----- -----------------------------------------------------------------

  ----- -----------------------------------------------------------------
        Employment Outcomes

        2005

        1,737
  ----- -----------------------------------------------------------------

  ----- -----------------------------------------------------------------
        Employment Outcomes

        2006

        1,969
  ----- -----------------------------------------------------------------

[SE Services\
]{.underline}

DVR provides SE services through contracts with community organizations
serving individuals with developmental disabilities and individuals with
mental illness. The agency reports that it does not encounter
significant difficulty in obtaining extended services for individuals
with developmental disabilities once they have transitioned to
competitive employment. However, DVR indicates that there is a lack of
capacity among organizations serving individuals with mental illness to
provide such long-term supports. The lack of capacity has resulted from
significant reductions in the funding that supports the mental health
service delivery system in the state.

To address this lack of capacity, DVR is collaborating with the state's
Mental Health Division to develop a strategic initiative that will
increase the availability of mental health services in the state, as
well as expectations for the employment outcomes achieved by individuals
served by mental health providers. DVR is also engaging in joint
training activities with the Mental Health Division regarding improved
collaboration by DVR staff and mental health providers. Finally, DVR is
seeking other sources of extended services, including peer support
provided through clubhouses and wellness recovery action plans.

DVR provides SE services only through contracts with community
providers. Therefore, improved performance of the SE program can best be
assessed through the same measures used to determine the agency's
progress toward achieving Performance Goal 2, related to the improved
effectiveness of service providers.

## Provision of Technical Assistance

During the review process, RSA provided technical assistance to DVR.
RSA:

-   discussed the agency's case management system; and

-   demonstrated the use of RSA's Management Information System.

RSA also verified DVR RSA-911 data while on site. This verification
process consisted of using a custom computer application to compare the
data reported on the RSA-911 Case Service Report submitted to RSA by DVR
to the actual case files including the original application to the
agency and the Individual Plan for Employment. The verification process
focused on 42 data elements reported on the RSA-911 Case Service Report.
The 42 data elements included the date of application, gender, date of
birth, race, ethnicity, source of referral, impairment code and cause of
impairment for both primary and secondary impairments, weekly earning at
application and closure, hours worked in a week at application and
closure, primary source of support at application and closure, level of
education attained at application and closure, employment status at
application and closure, type of public support at application and
closure, date of eligibility determination, date of individualized plan
for employment, date of closure, and type of closure.

The RSA on site monitoring team reviewed a non-statistical sample of 10
case files. Five of the records were closed in FY 2006; four were closed
in FY 2005; and one of the records were closed in FY 2004. Both
successful and unsuccessful closures were reviewed. No significant
issues were identified. Minor inconsistencies between original case file
data and final reported data were identified and resolved.

####### Effective VR Practices Identified by DVR and Stakeholders During the Review Process

[SRC Implementation\
]{.underline}

####### Following discussions with DVR officials and members of the SRC, RSA has concluded that the SRC carries out its responsibilities under the Act in a very effective and independent manner. While the members of the SRC are highly motivated, several other factors contribute to the success of this organization. First, the daily activities of the SRC are conducted by a full-time executive director, who communicates with the chairperson and other members, as well as DVR officials, on an ongoing basis. Though employed by the agency, the executive director and the chairperson and other members of the SRC assured RSA that this relationship does not hinder her ability to conduct her duties free from interference by DVR. The SRC also shares a support staff with the SILC, freeing up the executive director to focus on policy and leadership issues.

In addition, the members of the Council serve on committees that
function throughout the year. As a result, the SRC is able to respond to
the agency's requests for input and recommendations in a timely fashion,
without the need to limit this activity to the convening of regular or
special meetings of the entire Council.

Finally, and perhaps most significantly, DVR is committed to the active
participation of consumers in the VR program, which it seeks to obtain,
in part, through its relationship with the SRC. This commitment is
evidenced by the fact that DVR leadership invited the SRC executive
director to participate in the on-site entrance and exit meetings, along
with the teleconference following the visit. The SRC Executive Director
was in attendance when RSA and DVR discussed the goals, strategies and
methods of evaluation that were to be developed as a result of the
review.

####### VR and SE Issues Identified by DVR and Stakeholders During the Review Process

During the review process, RSA solicited input from DVR and stakeholders
regarding the issues that would be reviewed. Of concern to the agency
and the stakeholders were:

-   the ability of DVR to manage its resources while engaged in efforts
    to eliminate the waiting list for services;

-   the accountability and performance of the agency's service
    providers;

-   the agency's focus on increasing the quantity of employment
    outcomes, which stakeholders believe is to the detriment of the
    quality of those outcomes;

-   DVR's review of existing cases involving the provision of financial
    assistance for postsecondary education and other high cost services;
    and

-   the failure to appoint a representative of the CAP to the SRC for
    the past two years.

As a result, RSA and DVR agreed to address these issues during the
course of monitoring activities.

## VR and SE Performance Issues, Goals, Strategies, and Technical Assistance 

RSA and DVR agreed on the following performance goals, strategies to
achieve those goals, and the technical assistance that RSA will provide
to assist the agency to achieve each goal. DVR will consider including
these goals and strategies in the agency's FY 2009 State Plan and if
they are included, DVR will report progress toward the achievement of
these goals in its FY 2011 annual State Plan submission.

1.  [Management of Resources]{.underline}

Issue: As shown in Table 1, the performance of DVR has remained largely
unchanged or declined from FY 2002 through FY 2006. For example, the
agency provided services to 11,959 individuals during FY 2003, a number
which declined steadily to 7,803 in FY 2006. In addition, in FY 2002,
DVR assisted 1,365 individuals to achieve employment outcomes. This
figure increased by nearly 1,000 individuals the following year, but
then declined to 1,969 individuals at the close of FY 2006.

The ability of DVR to improve its overall performance with respect to
the number of individuals served and the quality of outcomes they
achieved is dependent in part on the ability of the agency to
effectively manage its OOS. DVR indicates in its FY 2008 State Plan that
it intends to eliminate the waiting list for the OOS by the end of FY
2008. To accomplish this goal, DVR plans to serve all individuals with
the most significant disabilities, without a need to wait for services,
and to remove 1,000 additional individuals from the waiting list each
month. During the course of monitoring, DVR reported that approximately
70 percent of the individuals formerly on the waiting list and who were
contacted for services to date did not receive services. DVR attributes
this result to the lengthy period of time that these individuals had
been waiting for services, causing them to no longer be available or in
need of VR services. However, RSA and DVR anticipate that this situation
will change as length of time between placement on the waiting list and
the offering of services decreases.

In January 2006, DVR conducted a statewide case review using the 107
review instrument. The results raised significant concerns around the
appropriate identification of barriers to employment and spending
practices among current cases. To respond to these concerns, DVR
undertook a review of all existing cases involving the provision of
financial support for postsecondary education and other services costing
\$10,000 or more. During on-site discussions, DVR explained that the
purpose of this review was to determine if all barriers to employment
resulting from an individual's disability were properly addressed
through the original Individualized Plan for Employment (IPE). Based on
case review results, current management believes that counselors did not
always conduct thorough assessments in prior years because of
departmental pressure to increase the number of plans developed.
However, representatives of stakeholders and CAP, contend that DVR
engaged in this review for cost management purposes. It is unclear based
on discussions with agency officials and personnel how many, if any, of
the IPEs were amended to either add services that better address the
individual's barriers to employment or to reduce educational or
high-cost services. Nonetheless, DVR and its stakeholders have opposing
perceptions of the process.

In light of this activity, coupled with the agency's renewed efforts to
serve increasing numbers of individuals through the VR program, RSA
recommended during the on-site discussions that DVR management clearly
explain verbally and in writing the purpose of any such future
activities.

Based on more detailed discussions of the above performance data and
information related to the historical development and current management
of the OOS, RSA and DVR have agreed to the following goal.

Goal: DVR will manage its resources in an effective manner so that it
can improve the quantity and quality of employment outcomes achieved by
individuals with disabilities.

Strategies: To achieve this goal, DVR will:

-   conduct caseload analysis to determine how many new applications
    each office should be targeting to maintain full caseload capacity
    as it eliminates the waiting list for services;

-   establish new area office targets for applications;

-   manage caseload growth and anticipated expenditures through use of
    projection tools and the ongoing monitoring of performance and
    expenditures; and

-   train field staff on how to build and manage full caseloads when the
    agency is no longer implementing the OOS.

Methods of Evaluation: DVR and RSA will use the following measures to
assess the agency's progress toward the goal:

-   new applications to each area office will increase (baseline
    performance level will be determined in FY 2008); and

-   number of new IPE's developed will increase with performance targets
    of 3-4 new IPE's per counselor per month (360-480) and a FY 2008
    agency target of 5,600.

Technical Assistance: To assist DVR to achieve the goal, RSA will inform
DVR of any effective practices used by other agencies with respect to
the management and reduction of large waiting lists under an OOS.

## Accountability and Performance of Service Providers

Issue: During the review, DVR informed RSA that historically the agency
has expended approximately 48 percent of the funds available for the
purchase of services on those services provided by CRPs while the number
of outcomes provided by CRPs had declined. As a result, the cost per
rehabilitation outcome provided by a CRP had increased sharply. In an
effort to contain costs, serve more individuals and increase outcomes,
DVR revised its contract model in FY 2006. This new contract model
includes cost-saving measures, narrows the agency's use of CRPs, and
requires all CRPs to obtain CARF accreditation. At the time of the
review, DVR was considering revising its CRP contract model again to
bring about increased accountability and further cost reductions.

While on-site, RSA met with representatives of CRPs from across the
state. They recommended that DVR counselors collaborate more closely
with CRP staff regarding the services to be provided to agency
consumers, that VR counselors be required to meet with the CRP staff
every two to three months to review the individual's accomplishments and
challenges and that DVR involve families in the VR process because of
the critical role that they can play in the success of the individual.
Additionally, while not satisfied with the current contract, the
representatives believed that the consistently increasing numbers of
individuals coming off the waiting list, and thus into services, could
likely change how the contract functions. They therefore believe that
DVR should not revise the contract process at this time, and should wait
to see how the increased flow of consumers impacts CRPs ability to
provide services under the contract. However, the CRP representatives
were supportive of the development of a "report card" system that DVR
would use as the basis for future contract negotiations.

## 

## To bring about greater accountability and to improve provider performance, DVR and RSA have agreed to the following goal.

##  

## Goal: DVR will develop a CRP business model that meets the needs of the agency and enhances provider effectiveness.

## 

## Strategies: To achieve the goal, DVR will:

-   analyze and evaluate CRP contract results and their relationship to
    rehabilitation outcomes; establish performance targets;

-   publish and disseminate reports that reflect CRP contract results;

-   build capacity of CRPs to offer benefits planning on a fee for
    service basis in high demand areas; and

-   assess CRP capacity issues related to current caseload and referral
    levels.

## Methods of Evaluation: DVR and RSA will use the measures listed below to assess the agency's progress toward the goal.

-   Percent of overall rehabilitation outcomes resulting from CRP
    placement services compared to previous years;

-   Number of CRPs offering benefits planning on a fee for service basis
    with target to be determined based on assessment of need and
    identification of high demand areas; and

-   Length of time it takes for CRP services to commence after a
    referral has been made compared to previous years.

## Technical Assistance: RSA will inform DVR of any effective practices used by other agencies to address this issue, and will identify additional technical assistance resources as requested by the agency.

## VR and SE Compliance Issues, Goals, Strategies, Methods of Evaluation, and Technical Assistance 

Issue: 34 CFR 361.17(b)(1)(iii) requires that the membership of the SRC
be comprised of "At least one representative of the Client Assistance
Program established under 34 CFR part 370, who must be the director of
or other individual recommended by the Client Assistance Program." This
CAP's person on the SRC has not been filled for the past two years.

RSA met with representatives from the governor's office to discuss this
issue. As a result of these discussions, the representatives indicated
that they would complete the appointment of a representative of the CAP
to the SRC by the close of FY 2007.

Goal: The governor will appoint a representative of the CAP to the SRC
for DVR, in accordance with 34 CFR 361.17(b)(1)(iii), by September 30,
2007.

Method of Evaluation: RSA will consider the matter to be resolved upon
receipt of written confirmation from the governor's office that the
appointment has been made in accordance with the requirements of federal
regulations.

Technical Assistance: RSA is available to provide further explanation to
DVR, the SRC and representatives of the governor's office regarding the
regulatory provisions concerning the appointment of a representative
from the CAP to the SRC.

Chapter 3: Fiscal Review of the VR Program

RSA reviewed DVR's fiscal management of the VR program. During the
review process RSA provided technical assistance to the state agency to
improve its fiscal management and identified areas for improvement. RSA
reviewed the general effectiveness of the agency's cost and financial
controls, internal processes for the expenditure of funds, use of
appropriate accounting practices, and financial management systems.

The data in the following table, taken from fiscal reports submitted by
the state agencies, speak to the overall fiscal performance of the
agency. The data related to matching requirements are taken from the
fourth quarter of the respective fiscal year's SF-269 report. The
maintenance of effort (MOE) requirement data are taken from the final
SF-269 report of the fiscal year (two years prior to the fiscal year to
which it is compared). Fiscal data related to administration, total
expenditures, and administrative cost percentage are taken from the
RSA-2.

**Table \# 2:**

**Fiscal Data for DVR for FY 2002 through FY 2006**

  ----------------------------- ------------ ------------ ------------ ------------ ------------
  **Washington (G)**                                                                

  **Fiscal Year**               **2002**     **2003**     **2004**     **2005**     **2006**

  **Grant Amount**              36,598,501   37,220,804   38,890,809   38,642,787   40,155,006

  **Required Match**            9,905,312    10,073,737   10,525,721   10,458,594   10,867,873

  **Federal Expenditures**      23,503,075   37,220,804   36,539,718   35,559,184   35,683,981

  **Actual Match**              10,256,154   10,174,620   10,525,740   9,958,594    11,227,935

  **Over (Under) Match**        350,842      100,883      19           (500,000)    360,062

  **Carryover**                 13,095,426   0            2,351,091    3,083,603    4,471,025

  **Program Income**            1,637,639    670,123      1,444,833    1,324,238    1,519,788

  **Maintenance of Effort       12,339,382   9,856,680    10,256,154   10,174,620   10,525,740
  (MOE)**                                                                           

  ** **                                                                              

  **Administrative Costs**      6,555,445    6,513,032    7,240,106    6,536,917    6,690,255

  **Total Expenditures**        47,634,099   63,653,332   52,379,836   55,932,489   55,340,524

  **Percent Admin Costs to      13.76%       10.23%       13.82%       11.69%       12.09%
  Total Expenditures**                                                              
  ----------------------------- ------------ ------------ ------------ ------------ ------------

[Explanations Applicable to the Fiscal Profile Table]{.underline}

[Grant Amount:]{.underline} The amounts shown represent the final award
for each fiscal year, and reflect any adjustments for MOE penalties,
reductions for grant funds voluntarily relinquished through the
reallotment process, or additional grant funds received through the
reallotment process.

[Match (Non-Federal Expenditures)]{.underline}: The non-Federal share of
expenditures in the Basic Support Program, other than for the
construction of a facility related to a community rehabilitation
program, was established in the 1992 Amendments to the Rehabilitation
Act at 21.3 percent. As such, a minimum of 21.3 percent of the total
allowable program costs charged to each year's grant must come from
non-Federal expenditures from allowable sources as defined in program
and administrative regulations governing the VR Program. (34 CFR
361.60(a) and (b); 34 CFR 80.24)

In reviewing compliance with this requirement, RSA examined the
appropriateness of the sources of funds used as match in the VR Program,
the amount of funds used as match from appropriate sources, and the
projected amount of state appropriated funds available for match in each
federal fiscal year. The accuracy of expenditure information previously
reported in financial and program reports submitted to RSA was also
reviewed.

#### [Carryover]{.underline}: Federal funds appropriated for a fiscal year remain available for obligation in the succeeding fiscal year only to the extent that the VR agency met the matching requirement for those federal funds by September 30 of the year of appropriation. (34 CFR 361.64(b)) Either expending or obligating the non-federal share of program expenditures by this deadline may meet this carryover requirement. 

In reviewing compliance with the carryover requirement, RSA examined
documentation supporting expenditure and unliquidated obligation
information previously reported to RSA to substantiate the extent to
which the state was entitled to use any federal funds remaining at the
end of the fiscal year for which the funds were appropriated.

[Program Income]{.underline}: Program income means gross income received
by the state that is directly generated by an activity supported under a
federal grant program. Sources of state VR program income include, but
are not limited to, payments from the Social Security Administration for
rehabilitating Social Security beneficiaries, payments received from
workers' compensation funds, fees for services to defray part or all of
the costs of services provided to particular individuals, and income
generated by a state-operated community rehabilitation program. Program
income earned (received) in one fiscal year can be carried over and
obligated in the following fiscal year regardless of whether the agency
carries over federal grant funds. Grantees may also transfer program
income received from the Social Security Administration for
rehabilitating Social Security beneficiaries to other formula programs
funded under the Act to expand services under these programs.

In reviewing program income, RSA analyzed the total amount (as compared
to the total percentage of income earned by all VR agencies and
comparable/like VR agencies), sources, and use of generated income.

[Maintenance of Effort (MOE)]{.underline}: The 1992 Amendments revised
the requirements in section 111(a)(2)(B)(ii) of the Act with respect to
maintenance of effort provisions. Effective Federal FY 1993 and each
Federal fiscal year thereafter, the maintenance of effort level is based
on state expenditures under the title I State plan from non-federal
sources for the federal fiscal year two years earlier. States must meet
this prior year expenditure level to avoid monetary sanctions outlined
in 34 CFR 361.62(a)(1). The match and maintenance of effort requirements
are two separate requirements. Each must be met by the state.

In reviewing compliance with this requirement, RSA examined
documentation supporting fiscal year-end and final non-federal
expenditures previously reported for each grant year.

[Administrative Costs]{.underline}: Administrative costs means
expenditures incurred in the performance of administrative functions
including expenses related to program planning, development, monitoring
and evaluation. More detail related to expenditures that should be
classified as administrative costs is found in VR Program regulations at
34 CFR 361.5(b)(2).

####### Provision of Technical Assistance to the VR and SE Programs During the Review Process

####### RSA provided fiscal TA to DVR during the review process. RSA:

-   provided a synopsis of each requirement and reviewed with financial
    staff RSA's assessment of the agency's compliance with specific
    financial requirements -- match, maintenance of effort (MOE),
    carryover, reallotment, program income, liquidation of outstanding
    obligations and grant closeout;

-   conducted one day of intensive financial management training for 10
    financial staff from the Department of Services for the Blind and
    the Division of Vocational Rehabilitation addressing VR Program
    formula, allotment process and program cost of living increases,
    match/overmatch, maintenance of effort, carryover, grant period,
    liquidation of obligations, grant closeout, prior approval
    requirements, program income, allowable costs, guidance and
    reference materials, financial reports, and reallotment;

-   discussed the agency's relationship with CRPs, outcome based
    contracting, issues related to the delivery of services, and the
    availability of online CRP performance reports;

-   discussed the rapidly growing amount (and percentage) of federal
    funds carried over since FY 2003. Although operating on an order of
    selection, carryover funds are expected to reach the \$11,000,000
    level at the end of FY 2007. As DVR continues to build caseloads and
    initiate services for more consumers, this trend is expected to
    reverse;

-   reviewed and assessed data and management reports developed to
    manage being on an order of selection with closed categories; and

-   reviewed reductions in mid-management positions (5 FTE) that
    occurred during the 2-year budget cycle ending June 30, 2007. As a
    result of these reductions, administrative costs charged to the VR
    Program in FY 2008 are expected to be closer to the national
    averages for all VR agencies and General VR agencies.

####### Effective VR and SE Practices Identified by DVR and Stakeholders During the Review Process

# [Financial and Program Data Integration]{.underline}

In part because of going on an order of selection with closed categories
and a waiting list, DVR has integrated extensive financial and program
data that allows the agency to track actual expenditures at the state
and sub-state level, determine actual and projected costs for the
delivery of services, and provides trend data. This extensive data
allows the agency to easily manage being on an order of selection with
closed categories.  Staff can project the long-term and short-term costs
of providing services under the VR Program, the number of consumers that
the agency has the resources to serve, and quickly move consumers off
the waiting list as resources are available. Examples of reports
generated and disseminated to management staff include:

-   area/office allotment Tracking (Includes funds held in reserve --
    prepared monthly);

-   office allotment tracking that tracks allotment by area offices and
    each individual office, current and prior year cancellation rates,
    amount authorized, rate of authorization, expenditures, percent
    expended, percent of allotment paid and outstanding, percent of
    total budget as of the day report is run, and number of days into
    fiscal year.);

-   average spending per plan in each DVR office;

-   spending by service category;

-   funding for case services (by month);

-   expenditure projection by service category including monthly trend
    information to compare to prior fiscal year;

-   expenditure projection by budget line item;

-   expenditures by grant (separate report prepared to show monthly
    totals, separated by federal/state);

-   grant financial status (summary information for all federal grants);

-   indirect cost history (4-year trend information);

-   vocational rehabilitation basic support grant estimates (actual
    match and maintenance of effort trend data for five fiscal years,
    projected for two additional fiscal years);

-   statewide caseload profile (spreadsheet reflecting monthly totals
    for the entire fiscal year - detailed program information tracked
    related to open caseload, applications, eligibility determinations,
    IPE's written, closures, rehabilitation rate and hourly wages after
    rehabilitation);

-   performance status by unit (14 program areas tracked for each unit
    office);

-   monthly authorizations by service category groupings; and

-   division monthly fiscal status report (prepared monthly for
    Department managers and includes notes explaining expenditure
    patterns, issues faced related to compliance with program
    requirements, and out of the ordinary expenditures);

[Social Security Reimbursement Claims Processing]{.underline}

DVR automated its SSA claim process in early 2004.  Two data interfaces
were instrumental in its success. The first was to piggyback on an
existing data share agreement between SSA and DVR's parent agency, the
Washington State Department of Social and Health Services.  This enabled
verification of clients receiving SSI and/or SSDI. The second key piece
was gaining access to earnings data from the state's Employment Security
Department.  This enabled verification of client earnings at or above
SGA levels. The new verification ability results in a higher percentage
of reimbursement claims being approved leading to higher processing
priority with SSA.

Since the entire process is automated, it only takes a couple of hours
each quarter to activate the program and print the claims package that
is submitted to SSA for reimbursement.

## VR and SE Recommendations 

>  

[1. Personnel Compensation\
]{.underline}

RSA discussed with financial staff the current status of repeat audit
findings that appeared in the State of Washington's FYs 2003, 2004 and
2005 Single Audits. The agency had not complied with the OMB Circular
A-87 semi-annual certification requirement applicable to all employees
who spend 100% of their time working on one federal grant program (or
cost objective). In the state's Single Audit for state fiscal year 2006,
part of the salaries of six employees, assigned to other components of
the Department of Social & Health Services, were charged to the VR
Program based upon pre-determined budgeted amounts. The employees in
question do perform work for several components; however, no adjustments
to actual costs were made.

DVR has taken action to ensure completion of the semi-annual
certification and will switch funding for the positions in question to
100% state (non-match). Because the employees in question are not
assigned to DVR, the agency does not have the authority to require them
to keep time distribution records. Upon review, RSA recommends that DVR
enter into a contractual arrangement to reimburse the State for services
performed by these non-VR employees. Appropriate documentation would
have to be maintained, submitted, reviewed and approved before payment
is made.

DVR has stated that the charges for the employees in question will be
switched to 100 percent state funding. Upon receipt of final SF-269s,
RSA will make an official determination related to the repayment of
grant funds if DVR has not removed the salary charges from previously
reported FY 2006 expenditures. In determining the amount of payback, if
any, the harm to the federal interest will be weighed against the
benefit received from the services performed by these six individuals.

[2. Staff Development Activities]{.underline}

To have a better understanding of how their specific work ties to the
overall agency mission, financial staff (at all levels) should be
provided opportunities to be exposed to various areas of the VR programs
that the agency administers. Suggested activities include site visits
with community providers, spending a day shadowing VR Counselors, and
attending all or part of internal training sessions geared toward
program staff.

[Chapter 4: Blind and Visually Impaired Vocational Rehabilitation and
Supported Employment Programs]{.underline}

[Program Organization]{.underline}

DSB has seven statewide offices, six of which are staffed fulltime.
 Statewide, DSB has 75 FTEs. There are currently four VR field services
teams, with immediate plans to create a fifth. Each team covers a
specific geographic area, Northwest, Eastern, Southwest or West Central
(King County). Teams overlap and work collectively to serve all
customers. There is no unit or team within the agency that would be
considered as a stand-alone entity.

The Orientation and Training Center is located in Seattle. IL services
are provided through a combination of a contracted agencies and
itinerant contractors.

As reported to RSA on Form SF 269, "Financial Status Report," DSB
expended a total of \$8,088,353 on the administration and operation of
the VR program in FY 2006. With these funds, the agency provided
services to 824 individuals who are blind or visually impaired. Of this
total, the agency assisted 138 individuals to achieve employment
outcomes, 129 of whom were employed in integrated settings without
supports. During this period, individuals achieving gainful employment
earned an average hourly wage of \$15.30 and worked an average of 31.13
hours per week.

Table 3 provides fiscal and program data for fiscal years 2002 through
2006. These data provide an overview of the VR program's costs,
outcomes, and efficiency. The table identifies the amount of funds used
by the agency, the number of individuals who applied, and the number who
received services. It also provides information about the quality of the
agency's employment outcomes and its transition services.

**\
**

**Table 3: Performance Measures by Year**

  ----------------- ------------- ------------- ------------- ------------- -------------
  WASHINGTON        2002          2003          2004          2005          2006

  Total funds used  \$8,709,999   \$8,765,106   \$8,478,505   \$8,696,329   \$8,088,353

  Individuals       772           845           856           853           824
  served during                                                             
  year                                                                      

  Applicants        418           409           382           365           385

  Closed after      194           218           248           227           261
  receiving                                                                 
  services                                                                  

  Closed with       121           125           130           129           138
  employment                                                                
  outcomes                                                                  
  ----------------- ------------- ------------- ------------- ------------- -------------

  ----------------- ------------- ------------- ------------- ------------- -------------
  WASHINGTON        2002          2003          2004          2005          2006

  Employment        113           112           120           121           129
  outcomes without                                                          
  supports in an                                                            
  integrated                                                                
  setting                                                                   

  Average cost per  \$11,282.38   \$10,372.91   \$9,904.80    \$10,194.99   \$9,815.96
  individual served                                                         

  Average cost per  \$71,983.46   \$70,120.85   \$65,219.27   \$67,413.40   \$58,611.25
  employment                                                                
  outcome                                                                   

  Employment        13.89         14.26         15.33         14.83         17.06
  outcomes per                                                              
  \$million spent                                                           

  Competitive       12.74         13.69         14.27         14.03         16.94
  employment                                                                
  outcomes per                                                              
  \$million spent                                                           

  Average hourly    \$13.15       \$14.16       \$14.50       \$14.34       \$15.30
  earnings for paid                                                         
  employment                                                                
  outcomes                                                                  

  Average state     \$18.39       \$18.76       \$18.90       \$19.48       \$20.36
  hourly earnings                                                           

  Average hours     33.74         31.28         32.56         31.70         31.13
  worked per week                                                           
  for paid                                                                  
  employment                                                                
  outcomes                                                                  

  Percent of        9.79          11.47         9.68          14.98         14.94
  transition age                                                            
  served to total                                                           
  served                                                                    

  Employment rate   36.84         44.00         33.33         35.29         41.03
  for transition                                                            
  age served                                                                

  Average time      26.40         29.10         23.20         31.50         30.30
  between                                                                   
  application and                                                           
  closure (in                                                               
  months) for                                                               
  individuals with                                                          
  successful paid                                                           
  employment                                                                
  outcomes                                                                  

  Average number of 10.58         11.74         12.78         13.76         12.88
  individuals                                                               
  served per total                                                          
  staff                                                                     
  ----------------- ------------- ------------- ------------- ------------- -------------

  ------- ---------------------------------------------------------------
          Total Applicants

          2002

          13,510
  ------- ---------------------------------------------------------------

  ------- ---------------------------------------------------------------
          Total Applicants

          2003

          16,109
  ------- ---------------------------------------------------------------

  ------- ---------------------------------------------------------------
          Total Applicants

          2004

          11,236
  ------- ---------------------------------------------------------------

  ------- ---------------------------------------------------------------
          Total Applicants

          2005

          10,492
  ------- ---------------------------------------------------------------

  ------- ---------------------------------------------------------------
          Total Applicants

          2006

          9,164
  ------- ---------------------------------------------------------------

  -------- --------------------------------------------------------------
           Total Served

           2002

           9,518
  -------- --------------------------------------------------------------

  -------- --------------------------------------------------------------
           Total Served

           2003

           11,959
  -------- --------------------------------------------------------------

  -------- --------------------------------------------------------------
           Total Served

           2004

           8,952
  -------- --------------------------------------------------------------

  -------- --------------------------------------------------------------
           Total Served

           2005

           9,314
  -------- --------------------------------------------------------------

  -------- --------------------------------------------------------------
           Total Served

           2006

           7,803
  -------- --------------------------------------------------------------

  -------- --------------------------------------------------------------
           Total Closed

           2002

           2,495
  -------- --------------------------------------------------------------

  -------- --------------------------------------------------------------
           Total Closed

           2003

           4,949
  -------- --------------------------------------------------------------

  -------- --------------------------------------------------------------
           Total Closed

           2004

           4,612
  -------- --------------------------------------------------------------

  -------- --------------------------------------------------------------
           Total Closed

           2005

           3,957
  -------- --------------------------------------------------------------

  -------- --------------------------------------------------------------
           Total Closed

           2006

           4,303
  -------- --------------------------------------------------------------

  ----- -----------------------------------------------------------------
        Employment Outcomes

        2002

        1,365
  ----- -----------------------------------------------------------------

  ----- -----------------------------------------------------------------
        Employment Outcomes

        2003

        2,405
  ----- -----------------------------------------------------------------

  ----- -----------------------------------------------------------------
        Employment Outcomes

        2004

        2,107
  ----- -----------------------------------------------------------------

  ----- -----------------------------------------------------------------
        Employment Outcomes

        2005

        1,737
  ----- -----------------------------------------------------------------

  ----- -----------------------------------------------------------------
        Employment Outcomes

        2006

        1,969
  ----- -----------------------------------------------------------------

## Supported Employment Program

DSB provides SE services to individuals with the most significant
disabilities through performance-based contracts with the same network
of service providers used by DVR. DSB engages in several activities to
assess the performance of the SE providers, including the review of
individual vendor performance, supervisory reviews designed to ensure
that the outcomes achieved by individuals are competitive and in
integrated settings, and consumer satisfaction surveys of individuals
who achieve SE outcomes. In addition, DSB takes steps to ensure that its
staff and counselors possess current knowledge of the SE services
program. For example, agency staff participates in annual training
conferences sponsored by the Washington Initiative for Supported
Employment, during which they receive training on innovative project
design and financial systems analysis.

## 

## Provision of Technical Assistance

During the review process, RSA provided technical assistance to DSB
regarding verification of the agency's RSA 911 case record data for FY
2004, FY 2005, and FY 2006. While on-site, RSA verified data reported by
DSB on the RSA-911, "Case Service Report." This verification process
consisted of using a custom computer application to compare the data
reported and submitted by DSB on the RSA-911 to the actual case files,
including the original application to the agency and the Individualized
Plan for Employment (IPE). The verification process focused on 42 data
elements reported on the RSA-911 related to an individual's
demographics, type of disability, employment status at application and
closure, type of outcome, earnings and hours worked at closure, and
dates pertinent to the completion of the various stages of the VR
process, among others. Since most of the DSB case management system is
automated, only those data elements that were reported on paper
documents were verified. The RSA state team prepared to review many
files. However, when a non-statistical sample of 5 case files from FY
2006 showed almost no discrepancies (in one record the applicant's
ethnicity was ambiguous), this activity was concluded.

## RSA's Management Information System

RSA demonstrated the RSA Management Information System (MIS) to DSB
staff. The demonstration included how to locate the RSA-113/RSA-2
monitoring tables, RSA-911 monitoring tables, the standard and
indicators, agency report cards and the underlying report card tables.
The RSA team also showed agency staff how to conduct ad hoc queries on
the MIS, to obtain information about the agency, and/or compare and
contrast the agency's performance with that of other similar agencies.

####### 

####### VR and SE Issues Identified by DSB and Stakeholders During the Review Process

During the review process, RSA solicited input from DSB and stakeholders
regarding the issues that would be reviewed. Of concern to the agency
and the stakeholders were:

-   the relatively low number of individuals served by DSB and the
    corresponding high cost per employment outcome;

-   the nature of services provided individuals at the agency's
    Orientation and Training Center, in particular whether these
    services were effectively integrated within DSB and focused on the
    achievement of employment outcomes; and

-   the accountability and performance of the agency's service
    providers.

As a result, RSA and DSB agreed to address these issues during the
course of monitoring activities.

## VR and SE Performance Issues, Goals, Strategies, and Technical Assistance 

RSA and DSB agreed on the following performance goals, which are
consistent with the goals identified by DSB in its strategic performance
plan currently under development. However, the agency has yet to
finalize the strategies that it will implement to achieve the goals and
the methods of evaluation that it will use to assess its progress toward
each goal. Once the agency has determined the strategies and measures
that will be included in its strategic performance plan, it will use
these strategies and measures in connection with the goals identified
below. In addition, DSB will consider including these goals and
strategies in the agency's FY 2009 State Plan and if they are included,
DSB will report progress toward the achievement of these goals in its FY
2010 annual State Plan submission.\

[1.]{.underline} [Enhancing OTC Services as a Method to Improve Quantity
and Quality of Employment Outcomes]{.underline}

Issue: As shown in Table 1, DSB served an increasing number of
individuals from 772 in FY 2002 to 853 in FY 2005. This number decreased
to 824 in FY 2006. Additionally, DSB assisted more individuals to
achieve employment outcomes during this same period. In FY 2002 121
individuals achieved employment outcomes, while in FY 2006, the agency
assisted 138 individuals to obtain employment. However, the data
indicates that despite this improvement in performance, the agency still
assists a low number of individuals to achieve employment in comparison
to the number of individuals served each year. For example, in FY 2006,
DSB assisted 138 of a total of 824, or 16.75 percent, of the individuals
served to achieve employment outcomes. The national average for this
category is 23.5%.

In addition, although the number of individuals served and who achieved
employment outcomes have improved, DSB remains inefficient in its use of
resources. In FY 2006, the agency's cost per individual served was
\$9,815.96, and its cost per employment outcome was \$58,611.25.
Finally, in that year, the agency served only 12.88 individuals per
staff. The 2005 national average for this category was 14.5.\
\
Along with a review of this and other performance data, RSA conducted
monitoring activities related to the agency's operation of the
orientation and training center (OTC). Through the OTC DSB provides
approximately 15 individuals at any point in time training in Braille,
the use of assistive technology, orientation and mobility and other
techniques of daily living. Specifically, in response to concerns
expressed by stakeholders, RSA focused its activities on the connection
between the training provided at the OTC and the agency's ultimate
mission of assisting individuals to achieve employment. In doing so, RSA
reviewed OTC brochures and curriculum descriptions prior to the on-site
visit, met with OTC staff, agency counselors and students at the OTC
regarding the services provided, and conducted a limited service record
review to analyze the experiences of individuals who had participated in
OTC training.

## 

## While on-site, DSB informed RSA that, in FY 2003, it began to take steps to better focus the OTC training on employment in response to its own concerns and those expressed by OTC students and stakeholders. For example, in that year, the OTC introduced a career exploration class in its curriculum. During this course, students identify two careers of their choosing, research the functions of these jobs, the qualifications required to perform the jobs, the demand in the labor market for these jobs and other information pertinent to selecting a career goal, and then report in writing the results of this research. In addition, DSB currently is developing an internship program, through which students will work with employers in the OTC's local area to gain on-the-job experience.

## 

## Because most often students are referred to the OTC prior to selecting an employment outcome and developing an IPE, it is critical that counselors and students maintain contact during the 30 weeks of training so that an individual's progress through the VR program is not delayed once training is completed. Therefore, RSA inquired of both counselors and students the extent to which contact was maintained during training. The counselors described the various points during training at which they have contact with the individuals they are assisting, including the point of referral to the OTC, the completion of each 10 week semester, during the student's participation in the career exploration class and the completion of training. However, they stated that they often maintained contact with staff of the OTC, rather than directly with the students. RSA met with fourteen current OTC students who reported varied levels of satisfaction with the amount of contact they had with their counselors. However, through the review of 11 open and closed service records of individuals who had participated in OTC training, RSA found that in nine of the cases counselor notes indicated that contact with the individual was irregular or infrequent. Again, counselor notes indicated more frequent contact with OTC staff.

## 

## As a result of the performance data and the information obtained during monitoring activities related to training at the OTC, RSA and DSB have agreed to the following goal. 

## 

## Goal: Enhance vocational focus and efficiency of OTC services

Strategies: To achieve this goal, DSB will;

-   enhance employment focus of OTC;

-   increase communication between counselors, OTC staff and consumers;
    and

-   establish processes to assure IPE goals are established as early in
    OTC process as appropriate.

Method of Evaluation:

-   evidence of increased OTC focus on employment. Could include
    materials, curriculum and/or policies.

-   implementation of new policies that create better and more frequent
    communication between counselors, consumers in the OTC and OTC staff

## Technical Assistance: RSA will inform DSB of effective strategies used by other agencies for the blind to focus OTC training on employment.

## Accountability and Performance of Service Providers

## 

Issue: DSB's high costs per individual served and employment outcome
are, in part, the result of the amount of funds expended on contracts
with community rehabilitation programs (CRP). During the review process,
DSB also informed RSA of concerns with respect to the capacity of CRPs
in the state to serve individuals who are blind and visually impaired.
DSB staff find that CRP staff do not always possess the qualifications
to assist individuals who are blind and often are misinformed regarding
the capabilities of blind individuals. In addition, DSB adopted the
payment-for-performance contract model used by DVR and has found that
this model does not sufficiently address the needs of DSB because
individuals who are blind require unique skill sets that current DSB
vendors are often unable to provide.

Goal: Increase productivity of CRPs system.

Strategies: To achieve this goal, DSB will:

-   increase collaboration among DSB and CRP staff regarding the
    services provided to DSB consumers;

-   conduct regular meetings among DSB counselors and CRP staff to
    review individual accomplishments and identify challenges to the
    achievement of the employment outcome;

-   develop training programs to build CRP capacity;

-   develop a "report card" for each CRP to provide evaluation of its
    performance and establishment of clear expectations for performance
    goals for the subsequent fiscal year; ; and

-   enhance quality assurance activities, including the conduct of
    on-site reviews of each CRP throughout the state on a yearly basis
    to verify reported data and the quality of services.

Method of Evaluation: Reporting of increased CRPs production supported
by relevant supporting data.

Technical Assistance: RSA will inform DSB of effective contract models
used by other blind agencies that have lead to improved performance and
greater accountability.

3.  [Strategic Use of Data]{.underline}

DSB will benefit from enhancing their collection, analysis and reporting
of program data. With enhanced data procedures, it will be easier to
compile data, to gain increased understanding from data and to use data
to help effective decision-making.

Currently, each program area collects data for their program and reports
it as the program director considers appropriate. While this contributes
to communicating programmatic successes, it makes it difficult to
compare activities or results across programs and it increases the
difficulty in telling a comprehensive story about agency outcomes and
successes.

The information contained in standardized reports should mirror the
indicators of program success contained in the agency's strategic plan.
The use of a standardized set of report templates may ease staff burden
in creating custom charts and tables for reporting program outcomes.

A standardization of reporting definitions, formats and contents will be
useful for reporting agency measures and strategies as well as for
reporting outcomes. An agency can adopt any approach it prefers, but
consistency in formats and definitions will make it easier for DSB staff
to use data strategically.

Goal:  Increase the strategic use of data.\
**\
**Strategies: To achieve this goal, DSB will;

-   identify key stakeholders and the types of information they need;

-   create standardized data reporting tools across DSB programs
    (including Washington's GMAP for reporting to the Governor's office
    so that:

    -   definitions are consistent across agency programs;

    -   each program area reports similar categories of successes and
        outcomes;

    -   each report serves a specific purpose which can be described in
        a descriptive report title;

-   use standardized agency measures for tracking agency progress and
    program progress;

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-   develop evaluation strategies and models using program outcome data
    to compare programs' results over time and with other programs; and

-   develop a multi-year plan for staff development and providing DSB
    staff with skills and tools for collecting, analyzing, and using
    data as a tool to help make decisions and for guiding program
    improvement decisions. This may also include Excel functions for
    analysis and reporting.

Methods of Evaluation

-   Identification of stakeholders and types of information needed.

-   Development of standardized reporting packages.

-   Development of a plan for staff development.

Technical Assistance: RSA will provide technical assistance in data
quality, reporting of data, and enhancing the use of data.\
\
[4. Effective use of Strategic Planning]{.underline}

Issue: An integrated and aligned strategic planning process between DSB
and its component parts may help DSB achieve its goals. As DSB and its
components share common goals and objectives, and as, in addition, each
has unique goals, it is important to have a common or standardized
approach to planning that balances the need for agency standardization
with the need for program specific objectives and targets. The challenge
that many organizations, including DSB, face is coordinating a multitude
of strategic plans prepared at different levels of the organization.
Each plan is thoughtful and meets the needs of the sponsoring entity.
The desired goal is that all of the plans are aligned so the
relationship between them is clear and the agency goals shape all
subordinate goals and program goals fit within the larger agency goals.

Goal: Develop a common structure for Strategic Planning initiatives and
activities agency wide.

Strategies: To achieve this goal, DSB will:

-   develop strategic planning format and definitions of key terms used
    in planning;

-   align VR state plan with the agency plan;

-   align the agency plan with OTC plan and with all other program
    specific plans that exist within the agency; and

-   use external facilitator to gain familiarity with strategic planning
    processes so they can apply evenly across agency.

##### Technical Assistance

-   RSA can provide guidance and technical assistance in the technical
    aspects of plan development.

-   RSA can provide assistance in developing plans.

-   RSA can provide assistance in reviewing plans for consistency and
    for alignment.

## VR and SE Recommendations 

## Program Integration

The RSA representatives met with a number of individuals within
Washington DSB and were provided the opportunity to receive orientations
to the various programs. DSB has a general VR structure with 4 teams
that cover 39 counties. The VR counselors send selected individuals to
the Orientation and Training Center (OTC) for training. DSB's OTC
provided orientation and other training to program participants. The OTC
has adaptive skills assessment and training components and, similar to
the VR function, assists individuals with career planning and
employment. The Child and Family program covers birth to 21 and
provides, among other services, transition services to individuals
including assistance in the development of IPE's. The AT unit provides
training, evaluation and job site assistance with establishing and
setting up technology. The low-vision clinic assists with evaluation,
training and support for vision and technology issues. DSB also
maintains significant contact with DVR on consumers that have multiple
disabilities.

Overall, RSA noted that in certain components to the DSB program
operations, there was a lack of coordination and integration of services
both internally as well as externally. In terms of external
coordination, the DSB VR counselors advised RSA that confusion exists
between Washington DVR and DSB regarding who serves specific individuals
with visual impairments or to what degree and under what situations this
cooperation should occur. In terms of the internal components to DSB's
programs, RSA observed and was advised:

-   DSB clients reported that they had significant concerns regarding
    the lack of collaboration that exists between VR and the OTC.

-   DSB clients stated that they are not exposed to a full array of IT
    and AT services and that these services are not always provided in a
    timely manner.

-   DSB management reported that 25% of the VR caseloads require job
    development despite the fact that the OTC staff work on employment
    issues.

In light of the above, RSA recommends that DSB:

-   review and possibly enhance the current memorandum of understanding
    and work with Washington DVR to clarify the appropriate agency to
    serve individuals who are blind/visually impaired and develop a
    procedures manual that outlines the process for counselor use;

-   develop a system that provides for more coordination and cross
    communication among its various components and program participants
    so that it has a more integrated and seamless system that provides
    comprehensive services to the blind population.

Chapter 5: Fiscal Report for Blind and Visually Impaired Programs

RSA reviewed DSB's fiscal management of the VR program. During the
review process RSA provided technical assistance to the state agency to
improve its fiscal management and identified areas for improvement. RSA
reviewed the general effectiveness of the agency's cost and financial
controls, internal processes for the expenditure of funds, use of
appropriate accounting practices, and financial management systems.

The data in the following table, taken from fiscal reports submitted by
the state agencies, speak to the overall fiscal performance of the
agency. The data related to matching requirements are taken from the
fourth quarter of the respective fiscal year's SF-269 report. The
maintenance of effort (MOE) requirement data are taken from the final
SF-269 report of the fiscal year (two years prior to the fiscal year to
which it is compared). Fiscal data related to administration, total
expenditures, and administrative cost percentage are taken from the
RSA-2.

**Table \# 3**

**Fiscal Data for DSB for FY 2002 through FY 2006**

  ------------------------------- ----------- ----------- ----------- ----------- -----------
  **Washington (B)**                                                              

  **Fiscal Year**                 **2002**    **2003**    **2004**    **2005**    **2006**

  **Grant Amount**                6,057,895   6,203,152   6,331,062   6,290,686   6,751,827

  **Required Match**              1,639,557   1,678,871   1,713,489   1,702,562   1,827,369

  **Federal Expenditures**        6,057,895   6,203,152   5,934,112   5,998,424   6,227,762

  **Actual Match**                1,875,630   1,795,864   1,858,920   2,203,205   1,467,369

  **Over (Under) Match**          236,073     116,993     145,431     500,643     (360,000)

  **Carryover**                   0           0           396,950     292,262     524,065

  **Program Income**              303,600     14,681      26,993      0           0

  **Maintenance of Effort (MOE)** 1,264,645   1,505,830   1,858,920   1,795,864   1,858,920

  ** **                                                                            

  **Administrative Costs**        1,559,099   1,401,711   1,315,190   1,652,211   1,348,126

  **Total Expenditures**          8,709,999   8,765,106   8,478,505   8,696,329   8,088,354

  **Percent Admin Costs to Total  17.90%      15.99%      15.51%      19.00%      16.67%
  Expenditures**                                                                  
  ------------------------------- ----------- ----------- ----------- ----------- -----------

[Explanations Applicable to the Fiscal Profile Table]{.underline}

[Grant Amount:]{.underline} The amounts shown represent the final award
for each fiscal year, and reflect any adjustments for MOE penalties,
reductions for grant funds voluntarily relinquished through the
reallotment process, or additional grant funds received through the
reallotment process.

[Match (Non-Federal Expenditures)]{.underline}: The non-Federal share of
expenditures in the Basic Support Program, other than for the
construction of a facility related to a community rehabilitation
program, was established in the 1992 Amendments to the Rehabilitation
Act at 21.3 percent. As such, a minimum of 21.3 percent of the total
allowable program costs charged to each year's grant must come from
non-Federal expenditures from allowable sources as defined in program
and administrative regulations governing the VR Program. (34 CFR
361.60(a) and (b); 34 CFR 80.24)

In reviewing compliance with this requirement, RSA examined the
appropriateness of the sources of funds used as match in the VR Program,
the amount of funds used as match from appropriate sources, and the
projected amount of state appropriated funds available for match in each
federal fiscal year. The accuracy of expenditure information previously
reported in financial and program reports submitted to RSA was also
reviewed.

#### [Carryover]{.underline}: Federal funds appropriated for a fiscal year remain available for obligation in the succeeding fiscal year only to the extent that the VR agency met the matching requirement for those federal funds by September 30 of the year of appropriation. (34 CFR 361.64(b)) Either expending or obligating the non-federal share of program expenditures by this deadline may meet this carryover requirement. 

In reviewing compliance with the carryover requirement, RSA examined
documentation supporting expenditure and unliquidated obligation
information previously reported to RSA to substantiate the extent to
which the state was entitled to use any federal funds remaining at the
end of the fiscal year for which the funds were appropriated.

[Program Income]{.underline}: Program income means gross income received
by the state that is directly generated by an activity supported under a
federal grant program. Sources of state VR program income include, but
are not limited to, payments from the Social Security Administration for
rehabilitating Social Security beneficiaries, payments received from
workers' compensation funds, fees for services to defray part or all of
the costs of services provided to particular individuals, and income
generated by a state-operated community rehabilitation program. Program
income earned (received) in one fiscal year can be carried over and
obligated in the following fiscal year regardless of whether the agency
carries over federal grant funds. Grantees may also transfer program
income received from the Social Security Administration for
rehabilitating Social Security beneficiaries to other formula programs
funded under the Act to expand services under these programs.

In reviewing program income, RSA analyzed the total amount (as compared
to the total percentage of income earned by all VR agencies and
comparable/like VR agencies), sources, and use of generated income.

[Maintenance of Effort (MOE)]{.underline}: The 1992 Amendments revised
the requirements in section 111(a)(2)(B)(ii) of the Act with respect to
maintenance of effort provisions. Effective Federal FY 1993 and each
Federal fiscal year thereafter, the maintenance of effort level is based
on state expenditures under the title I State plan from non-federal
sources for the federal fiscal year two years earlier. States must meet
this prior year expenditure level to avoid monetary sanctions outlined
in 34 CFR 361.62(a)(1). The match and maintenance of effort requirements
are two separate requirements. Each must be met by the state.

In reviewing compliance with this requirement, RSA examined
documentation supporting fiscal year-end and final non-federal
expenditures previously reported for each grant year.

[Administrative Costs]{.underline}: Administrative costs means
expenditures incurred in the performance of administrative functions
including expenses related to program planning, development, monitoring
and evaluation. More detail related to expenditures that should be
classified as administrative costs is found in VR Program regulations at
34 CFR 361.5(b)(2).

####### Provision of Technical Assistance to the VR and SE Programs During the Review Process

During the review process, RSA provide fiscal technical assistance to
DSB. RSA:

-   Provided a synopsis of each requirement and reviewed with financial
    staff RSA's assessment of the agency's compliance with specific
    financial requirements -- match, maintenance of effort (MOE),
    carryover, reallotment, program income, liquidation of outstanding
    obligations and grant closeout.

-   Conducted one day of intensive financial management training for 10
    financial staff from the Department of Services for the Blind and
    the Division of Vocational Rehabilitation. Topics covered included:
    VR Program formula, allotment process and program cost of living
    increases, match/overmatch, maintenance of effort, carryover, grant
    period, liquidation of obligations, grant closeout, prior approval
    requirements, program income, allowable costs, guidance and
    reference materials, financial reports, and reallotment.

-   Discussed change in funding split resulting in increased resources.

-   Advised staff of OMB Circular A-87 requirements related to charging
    indirect costs to federal grant programs.

-   Advised staff of OMB Circular A-87 requirements related to charging
    budgeted salary costs to federal grant programs.

-   Discussed expenditures made under the VR Program's innovation and
    expansion (I & E) authority and the allowability of charging
    expenses related to the SILC's resource plan to I & E (Since the
    agency receives less that \$50,000 each year for the IL - Part B
    program, this shift in funding will provide additional resources for
    the provision of services to IL consumers.)

-   Reviewed sources of match for the VR Program and the fact that in FY
    2006 DSB utilized \$352,000 in Business Enterprise Program (BEP)
    expenditures from vending machine income as match for the VR
    Program, with no federal VR Program funds being used to support this
    program (this strategy enabled the agency to drawdown and utilizes
    an additional \$1,300,582, or 19.3 percent of its federal VR Program
    allotment).

-   Reviewed with staff the practice of charging BEP vendor training to
    the VR Program (since this training is included in each consumer's
    Individualized Plan for Employment (IPE) and is required to achieve
    his or her employment objective, this is an allowable and
    appropriate charge to the VR Program).

-   Obtained and input all Financial Status Reports (SF-269s) not
    previously entered into RSA's Management Information System (MIS)
    for all formula grant programs and reviewed reports with agency
    staff, made corrections, and approved all reports for FYs 2002
    -- 2007. DSB was advised that, with the exception of the VR Program
    (Basic Support Program), quarterly reports should not be submitted
    for any other formula grant program.

-   Reviewed DSB's reported administrative costs that are much higher
    than the national averages for all VR agencies and all Blind
    agencies. This review disclosed that, contrary to instructions
    issued by RSA, DSB is allocating the costs of field offices to this
    category. Taking this action will considerably reduce these costs
    and bring DSB's administrative costs more inline with national
    averages.

-   Reviewed DSB\'s reported administrative costs that are much higher
    than the national averages for all VR agencies and all Blind
    agencies.  This review disclosed that, contrary to instructions
    issued by RSA, DSB is allocating the costs of field offices to this
    category.  Appropriately removing these charges from the
    administrative costs line, will considerably reduce the
    administrative cost level and bring DSB's administrative costs more
    inline with national averages.

-   DSB was advised to revise the RSA-2 report submitted for FY 2006 to
    correctly report administrative expenditures, once the agency has
    taken appropriate action to comply with this request.

## VR and SE Performance Issues, Goals, Strategies, and Technical Assistance 

1.  [Cost Allocation]{.underline}

> Issue: Administrative/indirect costs are not properly allocated to
> RSA-funded programs. During the onsite review, DSB provided
> documentation to RSA to support that the Rehabilitation Services
> Administration, Region X Office, reviewed and determined to be
> approvable the use of a cost allocation plan rather than an indirect
> cost rate to allocate indirect costs. This action was taken on April
> 5, 1991. Since that time the approved bases have been changed, with no
> documentation to support when the current allocation methodologies
> were instituted or approved. From RSA's limited onsite review, it was
> determined that the bases currently used are inappropriate for the
> type of expense being charged.

Goal: Ensure that costs are allocated in accordance with the
requirements in OMB Circular A-87, "Cost Principles for State, Local and
Indian Tribal Governments."

Strategy:

-   Develop and submit for RSA's review, a new cost allocation plan with
    appropriate allocation bases. This plan must contain updated
    information on all federal and non-federal programs that DSB is
    responsible for administering and funding information related to
    each program.

-   Since the U.S Department of Education is the cognizant federal
    agency for DSB, the new cost allocation plan must be submitted to
    the U.S. Department of Education, Office of the Chief Financial
    Officer, Indirect Cost Group, for final review and approval.

Technical Assistance: RSA and Department of Education's Indirect Cost
Group staff will provide technical assistance on the development of a
quality cost allocation plan.

1.  [Salary Charges]{.underline}

Issue:  OMB-Circular A-87 requires: (1) semi-annual certifications for
(or from) all staff working full-time on one grant program or cost
objective; (2) maintenance of time distribution records for staff (not
included in an indirect cost pool) that work on more than one grant
program or cost objective, and (3) periodic adjustment of any budgeted
salary charges to actual salary charges.

Goal: DSB will ensure compliance with the compensation for personnel
services requirements in OMB Circular A-87, Attachment B, Paragraph 11,
for salaries charged to the VR Program.

Strategy:

-   Outline procedures and identify responsibilities to ensure that
    semi-annual certifications are completed by, or for, all employees
    who spend 100 percent of their time working on one federal grant
    program each fiscal year, beginning with FY 2007. 

-   Upon completion, submit these procedures and the form(s) used to
    document the results of this process to RSA for review and comment.

-   Develop and institute procedures to identify all staff required to
    maintain time distribution records. 

-   Meet with RSA to discuss the positions identified and the
    methodology that will be used to charge salary costs to federal
    programs for these individuals/positions.  At this meeting, unless
    daily time distribution records will be maintained, the agency
    should have documentation available to support approval of the
    allocation methodology.

-   Develop and institute procedures to ensure that individuals whose
    salaries are initially charged to federal grant programs based upon
    budgeted amounts are appropriately identified, documentation is
    maintained to adjust budgeted costs to actual, and adjustments are
    made within the timeframes prescribed in OMB Circular-87.

Technical Assistance:  RSA will consult with DSB on a quarterly basis
throughout this process to provide technical assistance, review draft
policies and procedures, and ensure that all identified issues have been
appropriately addressed.  

## VR and SE Issues for Further Review 

Throughout FY 2008 RSA will:

-   continue monitoring activities to complete verification of the
    accuracy of the RSA-2 (Annual Vocational Rehabilitation Program/Cost
    Report); and

-   determine the extent to which indirect costs were not properly
    allocated to RSA-funded programs in FYs 2003 -- 2008.

######## Chapter 6: IL Program

[Program Organization]{.underline}

There are currently seven CILs in WA. Five CILs are located in western
Washington with two serving the predominately rural areas of eastern
Washington. Four of the seven CILs reside in the greater Puget Sound
area where Seattle and a majority of the state's population reside.

Each CIL receives Title VII, Part B and Part C funds with each center
receiving an equal amount. DVR has been contracting 100 percent of their
Title VII Part B funds to CILs since July of 2003.

DVR provides the WASILC and WSRC with office space located in the same
building as DVR and DSB state headquarters. The WASILC has a full-time
Executive Director and shares a full time office support staff with the
SRC. The WASILC recruits potential members to the SILC and makes
recommendations for appointments to the Governor's office for final
decisions on appointments. WASILC has eight members, two represent state
government and thus serve in ex-officio status.

 

**Table 4:**

### Sources and Amounts of Funding (FY 2006)

  --------------------------------- --------------------------------------
                                    Amounts of Funding

  Part B Funds                      351,312

  Older Blind                       617,336

  Other Federal Funds               0

  State Funds                       357,949

  Local Government                  0

  Private/Other Funds               170,000

  Total                             1,496,597
  --------------------------------- --------------------------------------

####### Provision of Technical Assistance to the IL Program During the Review Process

RSA provided technical assistance to DSB, DVR and the WASILC in a number
of IL program areas during the review process. RSA:

-   reviewed roles and responsibilities of IL partners;

-   provided guidance on SPIL development; and

-   advised on future opportunities and strategies to maximize outcomes.

####### IL Issues Identified by DSB, DVR and Stakeholders During the Review Process

RSA's review process solicited input from DVR and DSB and stakeholders
about IL performance and compliance issues. The following issues were
identified:

-   insufficient resources available to provide comprehensive IL
    services; and

-   lack of effective collaboration between IL and VR communities.

Following compilation of this list, RSA worked with DSB, DVR and the
WASILC to address as many of these issues as possible either directly or
by consolidating the issue into a broader issue area.

## 

## IL Performance Issues, Goals, Strategies, and Technical Assistance 

As a result of the review, RSA, DVR and DSB agreed on the following IL
performance goals, strategies to achieve those goals, and technical
assistance that RSA would provide to assist DVR and DSB achieve each
goal.

[1. Low IL System Capacity]{.underline}

Issue: The WA IL community has historically operated with low to
moderate funds in the CIL system. One direct cause for this is the lack
of formal cooperation between IL (SILC or CILs) and VR or other agencies
serving people with disabilities. Individual CILs may have relationships
with community partners but this partnership rarely exists in any
structured statewide manner.

In the last three to four years the WA IL community has experienced a
few changes that place it in a unique position to address these
concerns:

-   In July of 2003 DVR began contracting all of the Title VII Part B
    dollars directly to CILs. These funds currently total \$351,312.\
    \
    However, the contracts are written in such a way that they lack
    concrete services that will be provided. DVR has identified this as
    a barrier to effectively providing statutorily required monitoring
    of Title VII dollars.\
    \
    The DVR director has expressed a desire to increase contracting with
    CILs to provide IL services that would enhance VR outcomes (e.g. IL
    evaluations, benefits planning). This could be a tremendous
    enhancement to CILs funding and capacity.

-   Aging and Disability Services Administration (ADSA) in Washington
    was recently awarded a Money Follows the Person demonstration grant.
    On-site meetings with ADSA staff demonstrated a strong interest to
    contract with CILs as a method to meet requirements of this grant.\
    \
    Administration in both ADSA and DVR acknowledge that contracting
    with CILs could be a major benefit to their programs. At the same
    time they acknowledge a need for CILs to gain capacity around
    handling fee-for-service contracts in a volume and type that most
    CILs have not previously dealt with. Both ADSA and DVR are willing
    to provide training in this area.

DSB IL does not have the capacity to cover the same range of issues as a
typical CIL. CILs however are, by definition, cross-disability and
therefore rarely have the internal skill sets necessary to address the
most complicated issues related to vision impairment that DSB IL does
(e.g., mobility training, daily skills training, etc.).

Goal: Increase the Capacity of the Independent Living Community
(including CILs and SILs).

To achieve this goal, the IL community will:

-   rewrite the Part B contract to reflect more measurable goals and
    definable activities. Assure that designated activities are clear
    enough to facilitate a clear understanding of what services are
    covered by the contract and what other services can be provided on a
    fee-for-services basis;

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-   provide training and other education to maximize capacity among IL
    Centers to provide fee-for-service work with VR; and

-   explore opportunities for OIB/IL and CIL staff to cross-train by
    having on-site partnerships between CILs and DSB IL staff or
    contractors.

Technical Assistance:

-   RSA will provide guidance on best practices for effective IL-VR
    partnerships.

-   RSA will be available to review new Title VII Part B contracts and
    provide recommendations when necessary.

> [Chapter 7: OIB Program]{.underline}

[Program Organization]{.underline}

WA receives \$1,106,250 per year to operate OIB services, of which
\$617,336 comes from Title VII, Chapter 2. At the time of the review
these funds covered 24.2 FTEs, of which 3.1 FTEs are stage agency staff,
the balance being contractors.

The 24.2 FTEs served a total of 2031 consumers in FY 2006. Most
consumers fell between the ages of 80 and 89, which is typical for OIB
programs. OIB did however show a higher than typical number of consumers
between the ages of 70 -- 79 and 90+, this last group comprising 36
percent of the consumers served. Over 90 percent of the consumers
reported being legally blind or having a severe visual impairment with
only 2.4 percent reporting being completely blind. Time since onset of
significant vision loss varied widely, with 10 or more years being the
largest single group.

Only three percent of consumers report living with a personal care
assistant who is not a spouse. Eighty-seven percent live either in a
private residence or in a community residential setting. Twelve percent
live in either an assisted living facility or nursing home type
facility. Fifty percent of referrals came from either self-referral or
family/friend.

OIB reported none of three service categories (assistive devices,
training and other) showed a predominate usage over others, although
training showed a slightly higher amount of services provided.

####### Provision of Technical Assistance to the OIB Program During the Review Process

RSA provided technical assistance to DSB in a number of OIB program
areas during the review process. RSA:

-   discussed strategies for community collaboration; and

-   provided information/training on IL regulations.

####### OIB Issues Identified by DSB and Stakeholders During the Review Process

RSA's review process solicited input from DSB and stakeholders about OIB
performance and compliance issues. Identifying the most effective
service provision method was identified as an issue.

## 

## OIB Performance Issues, Goals, Strategies, and Technical Assistance 

As a result of the review, RSA and DSB agreed on the following OIB
performance goals, strategies to achieve those goals, and technical
assistance that RSA would provide to assist DSB achieve each goal.

[1. Identifying Long-Term Vendor Structures That Meets the Unique Needs
of Rural and Urban Locations]{.underline}

Issue: OIB services throughout WA are provided almost exclusively
through vendors. Conversations with rural providers indicates that
current capacity is barely meeting needs and often suffers from spending
long amounts of time travelling for a relatively few number of
consumers. There is significant concern, from vendors and
administration, that the current structure will be severely challenged
if consumer demands increase.

OIB administration is further challenged by the fact that rural areas
often do not possess enough consumers to warrant establishing a vendor
base within immediate geographical proximity.

Goal: To identify vendor structures that meet unique needs of rural and
urban locations

To achieve this goal, OIB will:

-   identify needs of future growth in population; and

-   investigate alternative vendor structures for urban and rural
    settings.

Technical Assistance: RSA will provide guidance on possible vendor
structures, including any applicable best practices

## Chapter 8: Progress On Issues Raised In Previous Reviews Of The Division Of Vocational Rehabilitation Program

As a result of the RSA review conducted with DVR in FY 2003-2004, the
agency developed a Corrective Action Plan (CAP).

###### Corrective Action Plan

Through the implementation of its CAP, DVR has successfully resolved
compliance findings related to the following topics:

-   incorrect eligibility determination;

-   implementation of presumptive eligibility;

-   insufficient information in case records to identify and describe
    all rehabilitation needs;

-   insufficient information developed to select vocational goal;

-   inadequate practice of informing individuals about application
    requirements related to time between referral and application;

-   lack of ensuring eligibility is made in 60 days or documenting
    applicant agreement to an appropriate extension;

-   lack of ensuring all services identified in the IPE are necessary to
    reach the state employment outcome;

-   lack of appropriately amending IPEs to include all relevant services
    when rehabilitation and employment goals change;

-   insufficient identification of necessary services;

-   insufficient and inaccurate documentation of successful outcomes;

-   inappropriate amendments to IPEs, including homemaker as the
    employment goal and services needed to achieve goals;

-   insufficient documentation when changing from competitive goal to
    homemaker; and

-   lack of sufficiently implemented certification process.

DVR implemented significant improvements to training of staff in
documentation requirements, timelines associated with each status,
determining appropriate services and documenting decisions (services
needed, IEP goals and closure status). DVR also instituted significant
increases in quality assurance practices including annual statewide
review of 250 cases and significant changes to their internal data
tracking system (STARS). These activities had lead to successful
resolution of the issues listed above.

DVR has not successfully resolved compliance findings related to the
following topics and continues to work toward their resolution.

[1. Agreement with Public Institution of Higher Education]{.underline}:
DVR and DSB are working in partnership on this issue.

[\
Status:]{.underline} DVR and DSB have been working closely with IHE over
the last year. As of the date of this report both parties have come to
an agreement as to the specific details of a PIHE agreement. Current
work revolves around contract language and format. The agency expects to
meet the September 30, 2007 deadline.

Chapter 9: Status Of Issues Raised In Previous Reviews Of The Division
For The Blind And Visually Impaired Program

As a result of the RSA review conducted with DSB in FY 2003-2004, the
agency developed a CAP.

###### Corrective Action Plan

Through the implementation of its CAP, DSB has successfully resolved
compliance findings related to the following topics:

-   insufficient information to determine the presence of a disability;

-   insufficient compliance with presumptive eligibility for individuals
    receiving SSI or SSDI;

-   insufficient assessment information to identify and describe all VR
    needs;

-   untimely development of IPEs;

-   insufficient assessment information to identify and describe all of
    the eligible individual's VR needs; and

-   insufficient changes to goal status when changes occur

-   insufficient service rate of minorities.

Since the review that generated these findings DSB has developed a new
field services case review guide, significantly increased training of
counselors to educate on case requirements and guidelines, focused on
quality vocational assessments and increased the number and frequency of
case review activities. These actions have led to the completion of the
above listed findings.

DSB has not successfully resolved compliance findings related to the
following topics and continues to work toward their resolution.

[1. Agreement with Public Institution of Higher Education]{.underline}:
DVR and DSB are working in partnership on this issue.

[\
Status:]{.underline} DVR and DSB have been working closely with IHE over
the last year. As of the date of this report both parties have come to
an agreement as to the specific details of a PIHE agreement. Current
work revolves around contract language and format. The agency expects to
meet the September 30, 2007 deadline.

## Chapter 10: Summary Conclusion

Over the last few years DVR has been dealing with large waiting lists,
extremely high costs per employment outcome, low rehab rates and
significant discontent among community partners and consumers. All or
most of these can be directly tied to the presence and duration of such
a large waiting list. DVR has been proactively addressing these issues.
At the time of writing this report the rehabilitation rate since January
1, 2007 is 52.6 percent, higher than it has been for over two years. DVR
has also taken over 6,000 consumers off of the waiting list since
January 1, 2007 and is now serving individuals in the highest priority
category with no waiting.

DVR is making these gains by addressing underlying issues such as CRP
utilization, caseload efficiency, and relationships with community
partners and consumer relations. Working through these issues has also
necessitated new fiscal and programmatic forecasting tools. DVR has done
a highly effective job in developing and using these systems. This
success should serve them well as they continue to make progress on OOS
related issues.

IL in Washington has historically had low capacity levels and as a
result struggles with uncovered portions of the state. The IL community
has however recently experienced a number of new opportunities that
could very well lead to significant increases in dollars and services
available to consumers. These opportunities include new staff, with
extensive IL experience, in key statewide positions. Furthermore,
community partners are extending significant funding relationship
opportunities that fit clearly into the IL mission.

DSB has been dealing with increasing caseloads, a declining rehab rate
and the corollary issue of high costs per employment outcome. DSB has
many internal programs that attempt to work together to maximize
employment outcomes. With these many internal programs DSB has, as can
be expected in this environment, experienced difficulties in focusing
these many programs around a few central themes. This focus, when
implemented, should coalesce their multiple programs around employment
outcomes while retaining each programs unique contribution.

DSB has also struggled with an inadequate CRP base and as a result are
working to enhance the amount and quality of community resources
available to maximize outcomes. These efforts are focused on expanding
the size and proficiency of the CRP network and building cross training
relationships where IL and OIB staff can interact with existing IL
community resources.

Related to these activities is the ability to track, report and utilize
data in a meaningful and productive manner. Once accomplished these new
tools should not only allow DSB to better track and utilize data to
improve agency performance, they will empower DSB to communicate exactly
how it is achieving these employment outcomes and what role each of its
components is playing in these outcomes. This should greatly enhance
DSB's ability to market to and partner with a variety of community
partners.

Table 5 summarizes the results of RSA's review.

+----------------------+----------------------+-----------------------+
| **Agency: DVR**      |                      |                       |
+----------------------+----------------------+-----------------------+
| Program: VR          |                      |                       |
+----------------------+----------------------+-----------------------+
| Goal                 | Strategies           | Technical Assistance  |
+----------------------+----------------------+-----------------------+
| 1\. DVR will manage  | \- DVR will conduct  | To assist DVR to      |
| its resources in an  | caseload analysis to | achieve the goal, RSA |
| effective manner so  | determine how many   | will inform DVR of    |
| that it can improve  | new applications     | any effective         |
| the quantity and     | each office should   | practices used by     |
| quality of           | be targeting to      | other agencies with   |
| employment outcomes  | maintain full        | respect to the        |
| achieved by          | caseload capacity as | management and        |
| individuals with     | it eliminates the    | reduction of large    |
| disabilities.        | waiting list for     | waiting lists under   |
|                      | services;            | an OOS.               |
|                      |                      |                       |
|                      | \- DVR will          |                       |
|                      | establish new area   |                       |
|                      | office targets for   |                       |
|                      | applications;        |                       |
|                      |                      |                       |
|                      | \- DVR will manage   |                       |
|                      | caseload growth and  |                       |
|                      | anticipated          |                       |
|                      | expenditures through |                       |
|                      | use of projection    |                       |
|                      | tools and the        |                       |
|                      | ongoing monitoring   |                       |
|                      | of performance and   |                       |
|                      | expenditures; and    |                       |
|                      |                      |                       |
|                      | \- DVR will train    |                       |
|                      | field staff on how   |                       |
|                      | to build and manage  |                       |
|                      | full caseloads when  |                       |
|                      | the agency is no     |                       |
|                      | longer implementing  |                       |
|                      | the OOS.             |                       |
+----------------------+----------------------+-----------------------+
| ## 2. DVR will       | \- Analyze and       | ## RSA will inf       |
| develop a CRP busine | evaluate CRP         | orm DVR of any effect |
| ss model that meets  | contract results and | ive practices used by |
| the needs of the age | their relationship   |  other agencies to ad |
| ncy and enhances pro | to rehabilitation    | dress this issue, and |
| vider effectiveness. | outcomes; establish  |  will identify additi |
|                      | performance targets; | onal technical assist |
|                      |                      | ance resources as req |
|                      | \- Publish and       | uested by the agency. |
|                      | disseminate reports  |                       |
|                      | that reflect CRP     |                       |
|                      | contract results;    |                       |
|                      |                      |                       |
|                      | \- Build capacity of |                       |
|                      | CRPs to offer        |                       |
|                      | benefits planning on |                       |
|                      | a fee for service    |                       |
|                      | basis in high demand |                       |
|                      | areas; and           |                       |
|                      |                      |                       |
|                      | \- Assess CRP        |                       |
|                      | capacity issues      |                       |
|                      | related to current   |                       |
|                      | caseload and         |                       |
|                      | referral levels.     |                       |
+----------------------+----------------------+-----------------------+
| 3\. The governor     |                      | RSA is available to   |
| will appoint a       |                      | provide further       |
| representative of    |                      | explanation to DVR,   |
| the CAP to the SRC   |                      | the SRC and           |
| for DVR, in          |                      | representatives of    |
| accordance with 34   |                      | the governor's office |
| CFR                  |                      | regarding the         |
| 361.17(b)(1)(iii),   |                      | regulatory provisions |
| by September 30,     |                      | concerning the        |
| 2007.                |                      | appointment of a      |
|                      |                      | representative from   |
|                      |                      | the CAP to the SRC    |
+----------------------+----------------------+-----------------------+
| Recommendations      |                      |                       |
+----------------------+----------------------+-----------------------+
| 1\. RSA discussed    |                      |                       |
| with financial staff |                      |                       |
| the current status   |                      |                       |
| of repeat audit      |                      |                       |
| findings that        |                      |                       |
| appeared in the      |                      |                       |
| State of             |                      |                       |
| Washington's FYs     |                      |                       |
| 2003, 2004 and 2005  |                      |                       |
| Single Audits. The   |                      |                       |
| agency had not       |                      |                       |
| complied with the    |                      |                       |
| OMB Circular A-87    |                      |                       |
| semi-annual          |                      |                       |
| certification        |                      |                       |
| requirement          |                      |                       |
| applicable to all    |                      |                       |
| employees who spend  |                      |                       |
| 100% of their time   |                      |                       |
| working on one       |                      |                       |
| federal grant        |                      |                       |
| program (or cost     |                      |                       |
| objective). In the   |                      |                       |
| state's Single Audit |                      |                       |
| for state fiscal     |                      |                       |
| year 2006, part of   |                      |                       |
| the salaries of six  |                      |                       |
| employees, assigned  |                      |                       |
| to other components  |                      |                       |
| of the Department of |                      |                       |
| Social & Health      |                      |                       |
| Services, were       |                      |                       |
| charged to the VR    |                      |                       |
| Program based upon   |                      |                       |
| pre-determined       |                      |                       |
| budgeted amounts.    |                      |                       |
| The employees in     |                      |                       |
| question do perform  |                      |                       |
| work for several     |                      |                       |
| components; however, |                      |                       |
| no adjustments to    |                      |                       |
| actual costs were    |                      |                       |
| made.                |                      |                       |
|                      |                      |                       |
| DVR has taken action |                      |                       |
| to ensure completion |                      |                       |
| of the semi-annual   |                      |                       |
| certification and    |                      |                       |
| will switch funding  |                      |                       |
| for the positions in |                      |                       |
| question to 100%     |                      |                       |
| state (non-match).   |                      |                       |
| Because the          |                      |                       |
| employees in         |                      |                       |
| question are not     |                      |                       |
| assigned to DVR, the |                      |                       |
| agency does not have |                      |                       |
| the authority to     |                      |                       |
| require them to keep |                      |                       |
| time distribution    |                      |                       |
| records. Upon        |                      |                       |
| review, RSA          |                      |                       |
| recommends that DVR  |                      |                       |
| enter into a         |                      |                       |
| contractual          |                      |                       |
| arrangement to       |                      |                       |
| reimburse the State  |                      |                       |
| for services         |                      |                       |
| performed by these   |                      |                       |
| non-VR employees.    |                      |                       |
| Appropriate          |                      |                       |
| documentation would  |                      |                       |
| have to be           |                      |                       |
| maintained,          |                      |                       |
| submitted, reviewed  |                      |                       |
| and approved before  |                      |                       |
| payment is made.     |                      |                       |
|                      |                      |                       |
| DVR has stated that  |                      |                       |
| the charges for the  |                      |                       |
| employees in         |                      |                       |
| question will be     |                      |                       |
| switched to 100      |                      |                       |
| percent state        |                      |                       |
| funding. Upon        |                      |                       |
| receipt of final     |                      |                       |
| SF-269s, RSA will    |                      |                       |
| make an official     |                      |                       |
| determination        |                      |                       |
| related to the       |                      |                       |
| repayment of grant   |                      |                       |
| funds if DVR has not |                      |                       |
| removed the salary   |                      |                       |
| charges from         |                      |                       |
| previously reported  |                      |                       |
| FY 2006              |                      |                       |
| expenditures. In     |                      |                       |
| determining the      |                      |                       |
| amount of payback,   |                      |                       |
| if any, the harm to  |                      |                       |
| the federal interest |                      |                       |
| will be weighed      |                      |                       |
| against the benefit  |                      |                       |
| received from the    |                      |                       |
| services performed   |                      |                       |
| by these six         |                      |                       |
| individuals.         |                      |                       |
+----------------------+----------------------+-----------------------+
| 2\. To have a better |                      |                       |
| understanding of how |                      |                       |
| their specific work  |                      |                       |
| ties to the overall  |                      |                       |
| agency mission,      |                      |                       |
| financial staff (at  |                      |                       |
| all levels) should   |                      |                       |
| be provided          |                      |                       |
| opportunities to be  |                      |                       |
| exposed to various   |                      |                       |
| areas of the VR      |                      |                       |
| programs that the    |                      |                       |
| agency administers.  |                      |                       |
| Suggested activities |                      |                       |
| include site visits  |                      |                       |
| with community       |                      |                       |
| providers, spending  |                      |                       |
| a day shadowing VR   |                      |                       |
| Counselors, and      |                      |                       |
| attending all or     |                      |                       |
| part of internal     |                      |                       |
| training sessions    |                      |                       |
| geared toward        |                      |                       |
| program staff.       |                      |                       |
+----------------------+----------------------+-----------------------+
| Program: IL          |                      |                       |
+----------------------+----------------------+-----------------------+
| Goal                 |                      |                       |
+----------------------+----------------------+-----------------------+
| 1\. Increase         | When appropriate     | -RSA will provide     |
| Capacity of          | rewrite Part B       | guidance on best      |
| Independent Living   | contract to reflect  | practices for         |
| Community (including | more measurable      | effective IL-VR       |
| CILs and SILSs)      | goals and definable  | partnerships.         |
|                      | activities. Assure   |                       |
|                      | that designated      | \- RSA will be        |
|                      | activities are clear | available to review   |
|                      | enough to facilitate | new Title VII Part B  |
|                      | a clear              | contracts and provide |
|                      | understanding of     | recommendations when  |
|                      | what services are    | necessary.            |
|                      | covered by the       |                       |
|                      | contract and what    |                       |
|                      | other services can   |                       |
|                      | be provided on a     |                       |
|                      | fee-for-services     |                       |
|                      | basis                |                       |
|                      |                      |                       |
|                      | \- Maximize capacity |                       |
|                      | among IL Centers to  |                       |
|                      | provide VR and AASA  |                       |
|                      | services (benefits   |                       |
|                      | planning, IL         |                       |
|                      | evaluations) on a    |                       |
|                      | fee for service      |                       |
|                      | basis. Utilize       |                       |
|                      | training             |                       |
|                      | opportunities to     |                       |
|                      | build necessary      |                       |
|                      | capacity             |                       |
|                      |                      |                       |
|                      | \- Explore           |                       |
|                      | opportunities for    |                       |
|                      | WASDSB IL and CIL    |                       |
|                      | staff by having      |                       |
|                      | on-site partnerships |                       |
|                      | between CILs and DSB |                       |
|                      | IL staff or          |                       |
|                      | contractors. This    |                       |
|                      | would allow for      |                       |
|                      | immediate staff and  |                       |
|                      | interaction, cross   |                       |
|                      | training and         |                       |
|                      | immediate access to  |                       |
|                      | specialized          |                       |
|                      | resources for CIL    |                       |
|                      | consumers. May work  |                       |
|                      | best with a few      |                       |
|                      | demonstration sites  |                       |
+----------------------+----------------------+-----------------------+
| **Agency: DVR**      |                      |                       |
+----------------------+----------------------+-----------------------+
| Program: VR          |                      |                       |
+----------------------+----------------------+-----------------------+

+----------------------+---+---+----------------------+---+-----------------------+
| **Agency: DSB**      |   |   |                      |   |                       |
+----------------------+---+---+----------------------+---+-----------------------+
| Program: VR/SE       |   |   |                      |   |                       |
+----------------------+---+---+----------------------+---+-----------------------+
| Goal                 |   | S |                      | T |                       |
|                      |   | t |                      | e |                       |
|                      |   | r |                      | c |                       |
|                      |   | a |                      | h |                       |
|                      |   | t |                      | n |                       |
|                      |   | e |                      | i |                       |
|                      |   | g |                      | c |                       |
|                      |   | i |                      | a |                       |
|                      |   | e |                      | l |                       |
|                      |   | s |                      | A |                       |
|                      |   |   |                      | s |                       |
|                      |   |   |                      | s |                       |
|                      |   |   |                      | i |                       |
|                      |   |   |                      | s |                       |
|                      |   |   |                      | t |                       |
|                      |   |   |                      | a |                       |
|                      |   |   |                      | n |                       |
|                      |   |   |                      | c |                       |
|                      |   |   |                      | e |                       |
+----------------------+---+---+----------------------+---+-----------------------+
| 1\. Enhance OTC      |   | \ |                      | # |                       |
| services as a method |   | - |                      | # |                       |
| to improve quantity  |   | E |                      |   |                       |
| and quality of       |   | n |                      | R |                       |
| employment outcomes. |   | h |                      | S |                       |
|                      |   | a |                      | A |                       |
|                      |   | n |                      |   |                       |
|                      |   | c |                      | w |                       |
|                      |   | e |                      | i |                       |
|                      |   | e |                      | l |                       |
|                      |   | m |                      | l |                       |
|                      |   | p |                      |   |                       |
|                      |   | l |                      | i |                       |
|                      |   | o |                      | n |                       |
|                      |   | y |                      | f |                       |
|                      |   | m |                      | o |                       |
|                      |   | e |                      | r |                       |
|                      |   | n |                      | m |                       |
|                      |   | t |                      |   |                       |
|                      |   | f |                      | D |                       |
|                      |   | o |                      | S |                       |
|                      |   | c |                      | B |                       |
|                      |   | u |                      |   |                       |
|                      |   | s |                      | o |                       |
|                      |   | o |                      | f |                       |
|                      |   | f |                      |   |                       |
|                      |   | O |                      | e |                       |
|                      |   | T |                      | f |                       |
|                      |   | C |                      | f |                       |
|                      |   | . |                      | e |                       |
|                      |   |   |                      | c |                       |
|                      |   | \ |                      | t |                       |
|                      |   | - |                      | i |                       |
|                      |   | I |                      | v |                       |
|                      |   | n |                      | e |                       |
|                      |   | c |                      |   |                       |
|                      |   | r |                      | s |                       |
|                      |   | e |                      | t |                       |
|                      |   | a |                      | r |                       |
|                      |   | s |                      | a |                       |
|                      |   | e |                      | t |                       |
|                      |   | c |                      | e |                       |
|                      |   | o |                      | g |                       |
|                      |   | m |                      | i |                       |
|                      |   | m |                      | e |                       |
|                      |   | u |                      | s |                       |
|                      |   | n |                      |   |                       |
|                      |   | i |                      | u |                       |
|                      |   | c |                      | s |                       |
|                      |   | a |                      | e |                       |
|                      |   | t |                      | d |                       |
|                      |   | i |                      |   |                       |
|                      |   | o |                      | b |                       |
|                      |   | n |                      | y |                       |
|                      |   | b |                      |   |                       |
|                      |   | e |                      | o |                       |
|                      |   | t |                      | t |                       |
|                      |   | w |                      | h |                       |
|                      |   | e |                      | e |                       |
|                      |   | e |                      | r |                       |
|                      |   | n |                      |   |                       |
|                      |   | c |                      | a |                       |
|                      |   | o |                      | g |                       |
|                      |   | u |                      | e |                       |
|                      |   | n |                      | n |                       |
|                      |   | s |                      | c |                       |
|                      |   | e |                      | i |                       |
|                      |   | l |                      | e |                       |
|                      |   | o |                      | s |                       |
|                      |   | r |                      |   |                       |
|                      |   | s |                      | f |                       |
|                      |   | , |                      | o |                       |
|                      |   | O |                      | r |                       |
|                      |   | T |                      |   |                       |
|                      |   | C |                      | t |                       |
|                      |   | s |                      | h |                       |
|                      |   | t |                      | e |                       |
|                      |   | a |                      |   |                       |
|                      |   | f |                      | b |                       |
|                      |   | f |                      | l |                       |
|                      |   | a |                      | i |                       |
|                      |   | n |                      | n |                       |
|                      |   | d |                      | d |                       |
|                      |   | c |                      |   |                       |
|                      |   | o |                      | t |                       |
|                      |   | n |                      | o |                       |
|                      |   | s |                      |   |                       |
|                      |   | u |                      | f |                       |
|                      |   | m |                      | o |                       |
|                      |   | e |                      | c |                       |
|                      |   | r |                      | u |                       |
|                      |   | s |                      | s |                       |
|                      |   | . |                      |   |                       |
|                      |   |   |                      | O |                       |
|                      |   | \ |                      | T |                       |
|                      |   | - |                      | C |                       |
|                      |   | E |                      |   |                       |
|                      |   | s |                      | t |                       |
|                      |   | t |                      | r |                       |
|                      |   | a |                      | a |                       |
|                      |   | b |                      | i |                       |
|                      |   | l |                      | n |                       |
|                      |   | i |                      | i |                       |
|                      |   | s |                      | n |                       |
|                      |   | h |                      | g |                       |
|                      |   | I |                      |   |                       |
|                      |   | P |                      | o |                       |
|                      |   | E |                      | n |                       |
|                      |   | g |                      |   |                       |
|                      |   | o |                      | e |                       |
|                      |   | a |                      | m |                       |
|                      |   | l |                      | p |                       |
|                      |   | s |                      | l |                       |
|                      |   | a |                      | o |                       |
|                      |   | s |                      | y |                       |
|                      |   | e |                      | m |                       |
|                      |   | a |                      | e |                       |
|                      |   | r |                      | n |                       |
|                      |   | l |                      | t |                       |
|                      |   | y |                      | . |                       |
|                      |   | i |                      |   |                       |
|                      |   | n |                      |   |                       |
|                      |   | O |                      |   |                       |
|                      |   | T |                      |   |                       |
|                      |   | C |                      |   |                       |
|                      |   | p |                      |   |                       |
|                      |   | r |                      |   |                       |
|                      |   | o |                      |   |                       |
|                      |   | c |                      |   |                       |
|                      |   | e |                      |   |                       |
|                      |   | s |                      |   |                       |
|                      |   | s |                      |   |                       |
|                      |   | a |                      |   |                       |
|                      |   | s |                      |   |                       |
|                      |   | p |                      |   |                       |
|                      |   | o |                      |   |                       |
|                      |   | s |                      |   |                       |
|                      |   | s |                      |   |                       |
|                      |   | i |                      |   |                       |
|                      |   | b |                      |   |                       |
|                      |   | l |                      |   |                       |
|                      |   | e |                      |   |                       |
|                      |   | . |                      |   |                       |
+----------------------+---+---+----------------------+---+-----------------------+
| 2\. Increase         |   | \ |                      | R |                       |
| productivity of CRPs |   | - |                      | S |                       |
| system               |   | I |                      | A |                       |
|                      |   | n |                      | w |                       |
|                      |   | c |                      | i |                       |
|                      |   | r |                      | l |                       |
|                      |   | e |                      | l |                       |
|                      |   | a |                      | i |                       |
|                      |   | s |                      | n |                       |
|                      |   | e |                      | f |                       |
|                      |   | c |                      | o |                       |
|                      |   | o |                      | r |                       |
|                      |   | l |                      | m |                       |
|                      |   | l |                      | D |                       |
|                      |   | a |                      | S |                       |
|                      |   | b |                      | B |                       |
|                      |   | o |                      | o |                       |
|                      |   | r |                      | f |                       |
|                      |   | a |                      | e |                       |
|                      |   | t |                      | f |                       |
|                      |   | i |                      | f |                       |
|                      |   | o |                      | e |                       |
|                      |   | n |                      | c |                       |
|                      |   | a |                      | t |                       |
|                      |   | m |                      | i |                       |
|                      |   | o |                      | v |                       |
|                      |   | n |                      | e |                       |
|                      |   | g |                      | c |                       |
|                      |   | D |                      | o |                       |
|                      |   | S |                      | n |                       |
|                      |   | B |                      | t |                       |
|                      |   | a |                      | r |                       |
|                      |   | n |                      | a |                       |
|                      |   | d |                      | c |                       |
|                      |   | C |                      | t |                       |
|                      |   | R |                      | m |                       |
|                      |   | P |                      | o |                       |
|                      |   | s |                      | d |                       |
|                      |   | t |                      | e |                       |
|                      |   | a |                      | l |                       |
|                      |   | f |                      | s |                       |
|                      |   | f |                      | u |                       |
|                      |   | r |                      | s |                       |
|                      |   | e |                      | e |                       |
|                      |   | g |                      | d |                       |
|                      |   | a |                      | b |                       |
|                      |   | r |                      | y |                       |
|                      |   | d |                      | o |                       |
|                      |   | i |                      | t |                       |
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|                      |   | . |                      |   |                       |
+----------------------+---+---+----------------------+---+-----------------------+
| 3\. Increase the     |   | \ |                      |   |                       |
| strategic use of     |   | - |                      |   |                       |
| data                 |   | I |                      |   |                       |
|                      |   | d |                      |   |                       |
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|                      |   | \ |                      |   |                       |
|                      |   | - |                      |   |                       |
|                      |   | D |                      |   |                       |
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|                      |   | n |                      |   |                       |
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|                      |   | n |                      |   |                       |
|                      |   | d |                      |   |                       |
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|                      |   | n |                      |   |                       |
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|                      |   | B |                      |   |                       |
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|                      |   | t |                      |   |                       |
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|                      |   | t |                      |   |                       |
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|                      |   | l |                      |   |                       |
|                      |   | p |                      |   |                       |
|                      |   | m |                      |   |                       |
|                      |   | a |                      |   |                       |
|                      |   | k |                      |   |                       |
|                      |   | e |                      |   |                       |
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|                      |   | c |                      |   |                       |
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|                      |   | s |                      |   |                       |
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|                      |   | n |                      |   |                       |
|                      |   | s |                      |   |                       |
|                      |   | a |                      |   |                       |
|                      |   | n |                      |   |                       |
|                      |   | d |                      |   |                       |
|                      |   | f |                      |   |                       |
|                      |   | o |                      |   |                       |
|                      |   | r |                      |   |                       |
|                      |   | g |                      |   |                       |
|                      |   | u |                      |   |                       |
|                      |   | i |                      |   |                       |
|                      |   | d |                      |   |                       |
|                      |   | i |                      |   |                       |
|                      |   | n |                      |   |                       |
|                      |   | g |                      |   |                       |
|                      |   | p |                      |   |                       |
|                      |   | r |                      |   |                       |
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|                      |   | g |                      |   |                       |
|                      |   | r |                      |   |                       |
|                      |   | a |                      |   |                       |
|                      |   | m |                      |   |                       |
|                      |   | i |                      |   |                       |
|                      |   | m |                      |   |                       |
|                      |   | p |                      |   |                       |
|                      |   | r |                      |   |                       |
|                      |   | o |                      |   |                       |
|                      |   | v |                      |   |                       |
|                      |   | e |                      |   |                       |
|                      |   | m |                      |   |                       |
|                      |   | e |                      |   |                       |
|                      |   | n |                      |   |                       |
|                      |   | t |                      |   |                       |
|                      |   | d |                      |   |                       |
|                      |   | e |                      |   |                       |
|                      |   | c |                      |   |                       |
|                      |   | i |                      |   |                       |
|                      |   | s |                      |   |                       |
|                      |   | i |                      |   |                       |
|                      |   | o |                      |   |                       |
|                      |   | n |                      |   |                       |
|                      |   | s |                      |   |                       |
|                      |   | . |                      |   |                       |
|                      |   | T |                      |   |                       |
|                      |   | h |                      |   |                       |
|                      |   | i |                      |   |                       |
|                      |   | s |                      |   |                       |
|                      |   | m |                      |   |                       |
|                      |   | a |                      |   |                       |
|                      |   | y |                      |   |                       |
|                      |   | a |                      |   |                       |
|                      |   | l |                      |   |                       |
|                      |   | s |                      |   |                       |
|                      |   | o |                      |   |                       |
|                      |   | i |                      |   |                       |
|                      |   | n |                      |   |                       |
|                      |   | c |                      |   |                       |
|                      |   | l |                      |   |                       |
|                      |   | u |                      |   |                       |
|                      |   | d |                      |   |                       |
|                      |   | e |                      |   |                       |
|                      |   | E |                      |   |                       |
|                      |   | x |                      |   |                       |
|                      |   | c |                      |   |                       |
|                      |   | e |                      |   |                       |
|                      |   | l |                      |   |                       |
|                      |   | f |                      |   |                       |
|                      |   | u |                      |   |                       |
|                      |   | n |                      |   |                       |
|                      |   | c |                      |   |                       |
|                      |   | t |                      |   |                       |
|                      |   | i |                      |   |                       |
|                      |   | o |                      |   |                       |
|                      |   | n |                      |   |                       |
|                      |   | s |                      |   |                       |
|                      |   | f |                      |   |                       |
|                      |   | o |                      |   |                       |
|                      |   | r |                      |   |                       |
|                      |   | a |                      |   |                       |
|                      |   | n |                      |   |                       |
|                      |   | a |                      |   |                       |
|                      |   | l |                      |   |                       |
|                      |   | y |                      |   |                       |
|                      |   | s |                      |   |                       |
|                      |   | i |                      |   |                       |
|                      |   | s |                      |   |                       |
|                      |   | a |                      |   |                       |
|                      |   | n |                      |   |                       |
|                      |   | d |                      |   |                       |
|                      |   | r |                      |   |                       |
|                      |   | e |                      |   |                       |
|                      |   | p |                      |   |                       |
|                      |   | o |                      |   |                       |
|                      |   | r |                      |   |                       |
|                      |   | t |                      |   |                       |
|                      |   | i |                      |   |                       |
|                      |   | n |                      |   |                       |
|                      |   | g |                      |   |                       |
|                      |   | . |                      |   |                       |
+----------------------+---+---+----------------------+---+-----------------------+
| 4\. Develop a common | \ |   |                      |   | \- RSA can provide    |
| structure for        | - |   |                      |   | guidance and          |
| Strategic Planning   | D |   |                      |   | technical assistance  |
| initiatives and      | e |   |                      |   | in the technical      |
| activities agency    | v |   |                      |   | aspects of plan       |
| wide.                | e |   |                      |   | development.          |
|                      | l |   |                      |   |                       |
|                      | o |   |                      |   | \- RSA can provide    |
|                      | p |   |                      |   | assistance in         |
|                      | s |   |                      |   | developing plans.     |
|                      | t |   |                      |   |                       |
|                      | r |   |                      |   | \- RSA can provide    |
|                      | a |   |                      |   | assistance in         |
|                      | t |   |                      |   | reviewing plans for   |
|                      | e |   |                      |   | consistency and for   |
|                      | g |   |                      |   | alignment.            |
|                      | i |   |                      |   |                       |
|                      | c |   |                      |   |                       |
|                      | p |   |                      |   |                       |
|                      | l |   |                      |   |                       |
|                      | a |   |                      |   |                       |
|                      | n |   |                      |   |                       |
|                      | n |   |                      |   |                       |
|                      | i |   |                      |   |                       |
|                      | n |   |                      |   |                       |
|                      | g |   |                      |   |                       |
|                      | f |   |                      |   |                       |
|                      | o |   |                      |   |                       |
|                      | r |   |                      |   |                       |
|                      | m |   |                      |   |                       |
|                      | a |   |                      |   |                       |
|                      | t |   |                      |   |                       |
|                      | a |   |                      |   |                       |
|                      | n |   |                      |   |                       |
|                      | d |   |                      |   |                       |
|                      | d |   |                      |   |                       |
|                      | e |   |                      |   |                       |
|                      | f |   |                      |   |                       |
|                      | i |   |                      |   |                       |
|                      | n |   |                      |   |                       |
|                      | i |   |                      |   |                       |
|                      | t |   |                      |   |                       |
|                      | i |   |                      |   |                       |
|                      | o |   |                      |   |                       |
|                      | n |   |                      |   |                       |
|                      | s |   |                      |   |                       |
|                      | o |   |                      |   |                       |
|                      | f |   |                      |   |                       |
|                      | k |   |                      |   |                       |
|                      | e |   |                      |   |                       |
|                      | y |   |                      |   |                       |
|                      | t |   |                      |   |                       |
|                      | e |   |                      |   |                       |
|                      | r |   |                      |   |                       |
|                      | m |   |                      |   |                       |
|                      | s |   |                      |   |                       |
|                      | u |   |                      |   |                       |
|                      | s |   |                      |   |                       |
|                      | e |   |                      |   |                       |
|                      | d |   |                      |   |                       |
|                      | i |   |                      |   |                       |
|                      | n |   |                      |   |                       |
|                      | p |   |                      |   |                       |
|                      | l |   |                      |   |                       |
|                      | a |   |                      |   |                       |
|                      | n |   |                      |   |                       |
|                      | n |   |                      |   |                       |
|                      | i |   |                      |   |                       |
|                      | n |   |                      |   |                       |
|                      | g |   |                      |   |                       |
|                      | . |   |                      |   |                       |
|                      |   |   |                      |   |                       |
|                      | \ |   |                      |   |                       |
|                      | - |   |                      |   |                       |
|                      | A |   |                      |   |                       |
|                      | l |   |                      |   |                       |
|                      | i |   |                      |   |                       |
|                      | g |   |                      |   |                       |
|                      | n |   |                      |   |                       |
|                      | V |   |                      |   |                       |
|                      | R |   |                      |   |                       |
|                      | s |   |                      |   |                       |
|                      | t |   |                      |   |                       |
|                      | a |   |                      |   |                       |
|                      | t |   |                      |   |                       |
|                      | e |   |                      |   |                       |
|                      | p |   |                      |   |                       |
|                      | l |   |                      |   |                       |
|                      | a |   |                      |   |                       |
|                      | n |   |                      |   |                       |
|                      | w |   |                      |   |                       |
|                      | i |   |                      |   |                       |
|                      | t |   |                      |   |                       |
|                      | h |   |                      |   |                       |
|                      | A |   |                      |   |                       |
|                      | g |   |                      |   |                       |
|                      | e |   |                      |   |                       |
|                      | n |   |                      |   |                       |
|                      | c |   |                      |   |                       |
|                      | y |   |                      |   |                       |
|                      | p |   |                      |   |                       |
|                      | l |   |                      |   |                       |
|                      | a |   |                      |   |                       |
|                      | n |   |                      |   |                       |
|                      | . |   |                      |   |                       |
|                      |   |   |                      |   |                       |
|                      | \ |   |                      |   |                       |
|                      | - |   |                      |   |                       |
|                      | A |   |                      |   |                       |
|                      | l |   |                      |   |                       |
|                      | i |   |                      |   |                       |
|                      | g |   |                      |   |                       |
|                      | n |   |                      |   |                       |
|                      | A |   |                      |   |                       |
|                      | g |   |                      |   |                       |
|                      | e |   |                      |   |                       |
|                      | n |   |                      |   |                       |
|                      | c |   |                      |   |                       |
|                      | y |   |                      |   |                       |
|                      | p |   |                      |   |                       |
|                      | l |   |                      |   |                       |
|                      | a |   |                      |   |                       |
|                      | n |   |                      |   |                       |
|                      | w |   |                      |   |                       |
|                      | i |   |                      |   |                       |
|                      | t |   |                      |   |                       |
|                      | h |   |                      |   |                       |
|                      | O |   |                      |   |                       |
|                      | T |   |                      |   |                       |
|                      | C |   |                      |   |                       |
|                      | p |   |                      |   |                       |
|                      | l |   |                      |   |                       |
|                      | a |   |                      |   |                       |
|                      | n |   |                      |   |                       |
|                      | a |   |                      |   |                       |
|                      | n |   |                      |   |                       |
|                      | d |   |                      |   |                       |
|                      | w |   |                      |   |                       |
|                      | i |   |                      |   |                       |
|                      | t |   |                      |   |                       |
|                      | h |   |                      |   |                       |
|                      | a |   |                      |   |                       |
|                      | l |   |                      |   |                       |
|                      | l |   |                      |   |                       |
|                      | o |   |                      |   |                       |
|                      | t |   |                      |   |                       |
|                      | h |   |                      |   |                       |
|                      | e |   |                      |   |                       |
|                      | r |   |                      |   |                       |
|                      | p |   |                      |   |                       |
|                      | r |   |                      |   |                       |
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|                      | g |   |                      |   |                       |
|                      | r |   |                      |   |                       |
|                      | a |   |                      |   |                       |
|                      | m |   |                      |   |                       |
|                      | s |   |                      |   |                       |
|                      | p |   |                      |   |                       |
|                      | e |   |                      |   |                       |
|                      | c |   |                      |   |                       |
|                      | i |   |                      |   |                       |
|                      | f |   |                      |   |                       |
|                      | i |   |                      |   |                       |
|                      | c |   |                      |   |                       |
|                      | p |   |                      |   |                       |
|                      | l |   |                      |   |                       |
|                      | a |   |                      |   |                       |
|                      | n |   |                      |   |                       |
|                      | s |   |                      |   |                       |
|                      | t |   |                      |   |                       |
|                      | h |   |                      |   |                       |
|                      | a |   |                      |   |                       |
|                      | t |   |                      |   |                       |
|                      | e |   |                      |   |                       |
|                      | x |   |                      |   |                       |
|                      | i |   |                      |   |                       |
|                      | s |   |                      |   |                       |
|                      | t |   |                      |   |                       |
|                      | w |   |                      |   |                       |
|                      | i |   |                      |   |                       |
|                      | t |   |                      |   |                       |
|                      | h |   |                      |   |                       |
|                      | i |   |                      |   |                       |
|                      | n |   |                      |   |                       |
|                      | t |   |                      |   |                       |
|                      | h |   |                      |   |                       |
|                      | e |   |                      |   |                       |
|                      | a |   |                      |   |                       |
|                      | g |   |                      |   |                       |
|                      | e |   |                      |   |                       |
|                      | n |   |                      |   |                       |
|                      | c |   |                      |   |                       |
|                      | y |   |                      |   |                       |
|                      | . |   |                      |   |                       |
|                      |   |   |                      |   |                       |
|                      | \ |   |                      |   |                       |
|                      | - |   |                      |   |                       |
|                      | U |   |                      |   |                       |
|                      | s |   |                      |   |                       |
|                      | e |   |                      |   |                       |
|                      | e |   |                      |   |                       |
|                      | x |   |                      |   |                       |
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|                      | l |   |                      |   |                       |
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|                      | n |   |                      |   |                       |
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|                      | i |   |                      |   |                       |
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|                      | h |   |                      |   |                       |
|                      | s |   |                      |   |                       |
|                      | t |   |                      |   |                       |
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|                      | a |   |                      |   |                       |
|                      | t |   |                      |   |                       |
|                      | e |   |                      |   |                       |
|                      | g |   |                      |   |                       |
|                      | i |   |                      |   |                       |
|                      | c |   |                      |   |                       |
|                      | p |   |                      |   |                       |
|                      | l |   |                      |   |                       |
|                      | a |   |                      |   |                       |
|                      | n |   |                      |   |                       |
|                      | n |   |                      |   |                       |
|                      | i |   |                      |   |                       |
|                      | n |   |                      |   |                       |
|                      | g |   |                      |   |                       |
|                      | p |   |                      |   |                       |
|                      | r |   |                      |   |                       |
|                      | o |   |                      |   |                       |
|                      | c |   |                      |   |                       |
|                      | e |   |                      |   |                       |
|                      | s |   |                      |   |                       |
|                      | s |   |                      |   |                       |
|                      | e |   |                      |   |                       |
|                      | s |   |                      |   |                       |
|                      | s |   |                      |   |                       |
|                      | o |   |                      |   |                       |
|                      | t |   |                      |   |                       |
|                      | h |   |                      |   |                       |
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|                      | y |   |                      |   |                       |
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|                      | a |   |                      |   |                       |
|                      | n |   |                      |   |                       |
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|                      | y |   |                      |   |                       |
|                      | e |   |                      |   |                       |
|                      | v |   |                      |   |                       |
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|                      | n |   |                      |   |                       |
|                      | l |   |                      |   |                       |
|                      | y |   |                      |   |                       |
|                      | a |   |                      |   |                       |
|                      | c |   |                      |   |                       |
|                      | r |   |                      |   |                       |
|                      | o |   |                      |   |                       |
|                      | s |   |                      |   |                       |
|                      | s |   |                      |   |                       |
|                      | a |   |                      |   |                       |
|                      | g |   |                      |   |                       |
|                      | e |   |                      |   |                       |
|                      | n |   |                      |   |                       |
|                      | c |   |                      |   |                       |
|                      | y |   |                      |   |                       |
|                      | . |   |                      |   |                       |
+----------------------+---+---+----------------------+---+-----------------------+
| 5\. Ensure that      |   |   | \(1\) Develop and    |   | Technical Assistance: |
| costs are allocated  |   |   | submit for RSA's     |   | RSA and Department of |
| in accordance with   |   |   | review, a new cost   |   | Education's Indirect  |
| the requirements in  |   |   | allocation plan with |   | Cost Group staff will |
| OMB Circular A-87,   |   |   | appropriate          |   | provide technical     |
| "Cost Principles for |   |   | allocation bases.    |   | assistance on the     |
| State, Local and     |   |   | This plan must       |   | development of a      |
| Indian Tribal        |   |   | contain updated      |   | quality cost          |
| Governments."        |   |   | information on all   |   | allocation plan.      |
|                      |   |   | federal and          |   |                       |
|                      |   |   | non-federal programs |   |                       |
|                      |   |   | that DSB is          |   |                       |
|                      |   |   | responsible for      |   |                       |
|                      |   |   | administering and    |   |                       |
|                      |   |   | funding information  |   |                       |
|                      |   |   | related to each      |   |                       |
|                      |   |   | program. (2) Since   |   |                       |
|                      |   |   | the U.S Department   |   |                       |
|                      |   |   | of Education is the  |   |                       |
|                      |   |   | cognizant federal    |   |                       |
|                      |   |   | agency for DSB, the  |   |                       |
|                      |   |   | new cost allocation  |   |                       |
|                      |   |   | plan must be         |   |                       |
|                      |   |   | submitted to the     |   |                       |
|                      |   |   | U.S. Department of   |   |                       |
|                      |   |   | Education, Office of |   |                       |
|                      |   |   | the Chief Financial  |   |                       |
|                      |   |   | Officer, Indirect    |   |                       |
|                      |   |   | Cost Group, for      |   |                       |
|                      |   |   | final review and     |   |                       |
|                      |   |   | approval.            |   |                       |
+----------------------+---+---+----------------------+---+-----------------------+
| 6\. (1) Ensure that  |   |   | Strategy: (1a)       |   | RSA will meet with    |
| semi-annual          |   |   | Outline procedures   |   | DSB on a quarterly    |
| certifications are   |   |   | and identify         |   | basis throughout this |
| competed for all     |   |   | responsibilities to  |   | process to provide    |
| employees who spend  |   |   | ensure that the      |   | technical assistance, |
| 100 percent of their |   |   | certifications are   |   | review draft policies |
| time working on one  |   |   | completed for each   |   | and procedures, and   |
| federal grant        |   |   | fiscal year,         |   | ensure that all       |
| program. (2) Ensure  |   |   | beginning with FY    |   | identified issues     |
| that salaries are    |   |   | 2007. (1b) Submit    |   | have been             |
| only charged to      |   |   | these procedures and |   | appropriately         |
| federal grant        |   |   | the form(s) used to  |   | addressed.            |
| programs in          |   |   | document the results |   |                       |
| accordance with the  |   |   | of this process to   |   |                       |
| approved methodology |   |   | RSA for review and   |   |                       |
| for documenting      |   |   | comment. (2a)        |   |                       |
| salary charges for   |   |   | Develop and          |   |                       |
| those individuals    |   |   | institute procedures |   |                       |
| working on more than |   |   | to identify all      |   |                       |
| one grant program.   |   |   | staff required to    |   |                       |
| (3) Ensure that      |   |   | maintain time        |   |                       |
| salaries initially   |   |   | distribution         |   |                       |
| charged to federal   |   |   | records. (2b) Meet   |   |                       |
| grant program based  |   |   | with RSA to discuss  |   |                       |
| on budgeted amounts  |   |   | the positions        |   |                       |
| are adjusted to      |   |   | identified and the   |   |                       |
| actual costs as      |   |   | methodology that     |   |                       |
| prescribed in OMB    |   |   | will be used to      |   |                       |
| Circular A-87.       |   |   | charge salary costs  |   |                       |
|                      |   |   | to federal programs  |   |                       |
|                      |   |   | for these            |   |                       |
|                      |   |   | in                   |   |                       |
|                      |   |   | dividuals/positions. |   |                       |
|                      |   |   | At this meeting,     |   |                       |
|                      |   |   | unless daily time    |   |                       |
|                      |   |   | distribution records |   |                       |
|                      |   |   | will be maintained,  |   |                       |
|                      |   |   | the agency should    |   |                       |
|                      |   |   | have documentation   |   |                       |
|                      |   |   | available to support |   |                       |
|                      |   |   | approval of the      |   |                       |
|                      |   |   | allocation           |   |                       |
|                      |   |   | methodology. (3)     |   |                       |
|                      |   |   | Develop and          |   |                       |
|                      |   |   | institute procedures |   |                       |
|                      |   |   | to ensure that       |   |                       |
|                      |   |   | individuals whose    |   |                       |
|                      |   |   | salaries are         |   |                       |
|                      |   |   | initially charged to |   |                       |
|                      |   |   | federal grant        |   |                       |
|                      |   |   | programs based upon  |   |                       |
|                      |   |   | budgeted amounts are |   |                       |
|                      |   |   | appropriately        |   |                       |
|                      |   |   | identified,          |   |                       |
|                      |   |   | documentation is     |   |                       |
|                      |   |   | maintained to adjust |   |                       |
|                      |   |   | budgeted costs to    |   |                       |
|                      |   |   | actual, and          |   |                       |
|                      |   |   | adjustments are made |   |                       |
|                      |   |   | within the           |   |                       |
|                      |   |   | timeframes           |   |                       |
|                      |   |   | prescribed in OMB    |   |                       |
|                      |   |   | Circular-87.         |   |                       |
+----------------------+---+---+----------------------+---+-----------------------+
|                      |   |   |                      |   |                       |
+----------------------+---+---+----------------------+---+-----------------------+
| Recommendations      |   |   |                      |   |                       |
+----------------------+---+---+----------------------+---+-----------------------+
| 1\. Review and       |   |   |                      |   |                       |
| possibly enhance the |   |   |                      |   |                       |
| current memorandum   |   |   |                      |   |                       |
| of understanding and |   |   |                      |   |                       |
| work with Washington |   |   |                      |   |                       |
| DVR to clarify the   |   |   |                      |   |                       |
| appropriate agency   |   |   |                      |   |                       |
| to serve individuals |   |   |                      |   |                       |
| who are              |   |   |                      |   |                       |
| blind/visually       |   |   |                      |   |                       |
| impaired and develop |   |   |                      |   |                       |
| a procedures manual  |   |   |                      |   |                       |
| that outlines the    |   |   |                      |   |                       |
| process for          |   |   |                      |   |                       |
| counselor use;       |   |   |                      |   |                       |
+----------------------+---+---+----------------------+---+-----------------------+
| 2\. Develop a system |   |   |                      |   |                       |
| that provides for    |   |   |                      |   |                       |
| more coordination    |   |   |                      |   |                       |
| and cross            |   |   |                      |   |                       |
| communication among  |   |   |                      |   |                       |
| its various          |   |   |                      |   |                       |
| components and       |   |   |                      |   |                       |
| program participants |   |   |                      |   |                       |
| so that it has a     |   |   |                      |   |                       |
| more integrated and  |   |   |                      |   |                       |
| seamless system that |   |   |                      |   |                       |
| provides             |   |   |                      |   |                       |
| comprehensive        |   |   |                      |   |                       |
| services to the      |   |   |                      |   |                       |
| blind population.    |   |   |                      |   |                       |
+----------------------+---+---+----------------------+---+-----------------------+
| 3\. DSB gain a       |   |   |                      |   |                       |
| better understanding |   |   |                      |   |                       |
| of how their         |   |   |                      |   |                       |
| specific work ties   |   |   |                      |   |                       |
| to the overall       |   |   |                      |   |                       |
| agency mission,      |   |   |                      |   |                       |
| financial staff (at  |   |   |                      |   |                       |
| all levels) should   |   |   |                      |   |                       |
| be provided          |   |   |                      |   |                       |
| opportunities to be  |   |   |                      |   |                       |
| exposed to various   |   |   |                      |   |                       |
| areas of the VR      |   |   |                      |   |                       |
| programs that the    |   |   |                      |   |                       |
| agency administers.  |   |   |                      |   |                       |
| Suggested activities |   |   |                      |   |                       |
| include site visits  |   |   |                      |   |                       |
| with community       |   |   |                      |   |                       |
| providers, spending  |   |   |                      |   |                       |
| a day shadowing VR   |   |   |                      |   |                       |
| Counselors, and      |   |   |                      |   |                       |
| attending all or     |   |   |                      |   |                       |
| part of internal     |   |   |                      |   |                       |
| training sessions    |   |   |                      |   |                       |
| geared toward        |   |   |                      |   |                       |
| program staff..      |   |   |                      |   |                       |
+----------------------+---+---+----------------------+---+-----------------------+
| Program: OIB         |   |   |                      |   |                       |
+----------------------+---+---+----------------------+---+-----------------------+
| Goal                 |   | S |                      | T |                       |
|                      |   | t |                      | e |                       |
|                      |   | r |                      | c |                       |
|                      |   | a |                      | h |                       |
|                      |   | t |                      | n |                       |
|                      |   | e |                      | i |                       |
|                      |   | g |                      | c |                       |
|                      |   | i |                      | a |                       |
|                      |   | e |                      | l |                       |
|                      |   | s |                      | A |                       |
|                      |   |   |                      | s |                       |
|                      |   |   |                      | s |                       |
|                      |   |   |                      | i |                       |
|                      |   |   |                      | s |                       |
|                      |   |   |                      | t |                       |
|                      |   |   |                      | a |                       |
|                      |   |   |                      | n |                       |
|                      |   |   |                      | c |                       |
|                      |   |   |                      | e |                       |
+----------------------+---+---+----------------------+---+-----------------------+
| 1\. To identify      |   | \ |                      | R |                       |
| vendor structure(s)  |   | - |                      | S |                       |
| that meet unique     |   | I |                      | A |                       |
| needs of rural and   |   | d |                      | w |                       |
| urban locations      |   | e |                      | i |                       |
|                      |   | n |                      | l |                       |
|                      |   | t |                      | l |                       |
|                      |   | i |                      | p |                       |
|                      |   | f |                      | r |                       |
|                      |   | y |                      | o |                       |
|                      |   | n |                      | v |                       |
|                      |   | e |                      | i |                       |
|                      |   | e |                      | d |                       |
|                      |   | d |                      | e |                       |
|                      |   | s |                      | g |                       |
|                      |   | o |                      | u |                       |
|                      |   | f |                      | i |                       |
|                      |   | f |                      | d |                       |
|                      |   | u |                      | a |                       |
|                      |   | t |                      | n |                       |
|                      |   | u |                      | c |                       |
|                      |   | r |                      | e |                       |
|                      |   | e |                      | o |                       |
|                      |   | g |                      | n |                       |
|                      |   | r |                      | p |                       |
|                      |   | o |                      | o |                       |
|                      |   | w |                      | s |                       |
|                      |   | t |                      | s |                       |
|                      |   | h |                      | i |                       |
|                      |   | i |                      | b |                       |
|                      |   | n |                      | l |                       |
|                      |   | p |                      | e |                       |
|                      |   | o |                      | v |                       |
|                      |   | p |                      | e |                       |
|                      |   | u |                      | n |                       |
|                      |   | l |                      | d |                       |
|                      |   | a |                      | o |                       |
|                      |   | t |                      | r |                       |
|                      |   | i |                      | s |                       |
|                      |   | o |                      | t |                       |
|                      |   | n |                      | r |                       |
|                      |   |   |                      | u |                       |
|                      |   | \ |                      | c |                       |
|                      |   | - |                      | t |                       |
|                      |   | I |                      | u |                       |
|                      |   | n |                      | r |                       |
|                      |   | v |                      | e |                       |
|                      |   | e |                      | s |                       |
|                      |   | s |                      | , |                       |
|                      |   | t |                      | i |                       |
|                      |   | i |                      | n |                       |
|                      |   | g |                      | c |                       |
|                      |   | a |                      | l |                       |
|                      |   | t |                      | u |                       |
|                      |   | e |                      | d |                       |
|                      |   | a |                      | i |                       |
|                      |   | l |                      | n |                       |
|                      |   | t |                      | g |                       |
|                      |   | e |                      | a |                       |
|                      |   | r |                      | n |                       |
|                      |   | n |                      | y |                       |
|                      |   | a |                      | a |                       |
|                      |   | t |                      | p |                       |
|                      |   | i |                      | p |                       |
|                      |   | v |                      | l |                       |
|                      |   | e |                      | i |                       |
|                      |   | v |                      | c |                       |
|                      |   | e |                      | a |                       |
|                      |   | n |                      | b |                       |
|                      |   | d |                      | l |                       |
|                      |   | o |                      | e |                       |
|                      |   | r |                      | b |                       |
|                      |   | s |                      | e |                       |
|                      |   | t |                      | s |                       |
|                      |   | r |                      | t |                       |
|                      |   | u |                      | p |                       |
|                      |   | c |                      | r |                       |
|                      |   | t |                      | a |                       |
|                      |   | u |                      | c |                       |
|                      |   | r |                      | t |                       |
|                      |   | e |                      | i |                       |
|                      |   | s |                      | c |                       |
|                      |   | f |                      | e |                       |
|                      |   | o |                      | s |                       |
|                      |   | r |                      |   |                       |
|                      |   | u |                      |   |                       |
|                      |   | r |                      |   |                       |
|                      |   | b |                      |   |                       |
|                      |   | a |                      |   |                       |
|                      |   | n |                      |   |                       |
|                      |   | a |                      |   |                       |
|                      |   | n |                      |   |                       |
|                      |   | d |                      |   |                       |
|                      |   | r |                      |   |                       |
|                      |   | u |                      |   |                       |
|                      |   | r |                      |   |                       |
|                      |   | a |                      |   |                       |
|                      |   | l |                      |   |                       |
|                      |   | s |                      |   |                       |
|                      |   | e |                      |   |                       |
|                      |   | t |                      |   |                       |
|                      |   | t |                      |   |                       |
|                      |   | i |                      |   |                       |
|                      |   | n |                      |   |                       |
|                      |   | g |                      |   |                       |
|                      |   | s |                      |   |                       |
+----------------------+---+---+----------------------+---+-----------------------+

Please take a moment to participate in a survey about RSA\'s performance
on the FY 2007 monitoring of Vocational Rehabilitation agencies.

Visit
<http://www.ed.gov/rschstat/eval/rehab/107-reports/2007/index.html>