Fiscal Year 2007 Monitoring Report on the Vocational Rehabilitation and
Independent Living Programs in the Commonwealth of Pennsylvania

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height="2.9972222222222222in"}

**U.S. Department of Education**

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

**Rehabilitation Services Administration**

**September 7, 2007**

## Contents

##  

Page

eXECUTIVE SUMMARY 3

introduction 5

cHAPTER 1: rEVIEW pROCESS 7

cHAPTER 2: vOCATIONAL rEHABILITATION AND sUPPORTED

EMPLOYMENT PROGRAMS 9

CHAPTER 3: FISCAL REVIEW OF THE VR PROGRAM 20

cHAPTER 4: iNDEPENDENT lIVING pROGRAM............................. 25

cHAPTER 5: INDEPENDENT LIVING FOR oLDER BLIND PROGRAM 30

cHAPTER 6: STATUS OF ISSUES RAISED IN PREVIOUS REVIEWS 32

cHAPTER 7: SUMMARY CONCLUSION 34

## 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 Commonwealth of Pennsylvania (PA):

-   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 PA, the Office of Vocational Rehabilitation (OVR) together with the
statewide rehabilitation council and the statewide independent living
council are responsible for the four programs.

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

-   gathered and reviewed information regarding each program'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, PA state rehabilitation council (PaRC) members,
    PA Statewide Independent Living Council (PA SILC) members, PA Client
    Assistance Program (PA CAP), and stakeholders to share information,
    identify promising practices and areas for improvement;

-   provided technical assistance;

-   worked with OVR 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 promising practices;

-   identified performance and compliance issues;

-   and OVR 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;
    and

-   identified potential issues for further review.

Strengths and Challenges:

OVR staff are dedicated to providing quality services to individuals in
the Commonwealth of PA. OVR has established effective collaborative
relationships with other PA agencies. There is a consumer and advocacy
community committed to improving the lives of individuals with
disabilities and working with OVR to ensure that quality services are
provided and successful employment outcomes are achieved. OVR has
established collaborative relationships with the PA state education
agency and local school districts to address the successful transition
of youths to post secondary education and training, community
participation, and employment.

OVR faces the challenges of operating a state-funded VR program separate
and distinct from the Title 1 VR program, improving the rehabilitation
rate of transition age youths, and employment outcomes for blind and
visually impaired consumers. OVR must also successfully implement and
complete the remaining corrective actions from RSA's FY 2005 monitoring
of the agency.

OVR, the PA SILC, and IL partners face challenges related to varying
definitions for services used by CILs, access to services, outreach, and
public awareness.

## Introduction

Section 107 of the Rehabilitation Act of 1973, as amended, requires the
Commissioner of 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:

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

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

-   provides technical assistance 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 OVR's progress on:

-   the agency's Corrective Action Plan (CAP) that was established as a
    result of findings from RSA's FY 2005 Section 107 monitoring review;
    and

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

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

In PA, OVR is the designated State unit for the general VR services
program and services for individuals who are blind or visually impaired.
The PA State Board of Vocational Rehabilitation is the designated state
agency. OVR and the PA SILC jointly administer the IL program under
Chapter 1 and the OIB program under Chapter 2.

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

## Appreciation

RSA wishes to express appreciation to the representatives of the
Pennsylvania State Board of Vocational Rehabilitation and OVR, PaRC, PA
SILC, PA CAP, Disability Rights Network of PA, and other stakeholders
who assisted the RSA monitoring team in the review of OVR.

## Chapter I: RSA's Review Process

## Data Used During the Review

RSA's review of OVR 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 PA state team:

-   gathered and reviewed information regarding OVR'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, PaRC members, PA SILC members, and stakeholders
    to share information, identify promising practices and areas for
    improvement;

-   provided technical assistance to OVR;

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

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

## RSA PA State Team Review Participants

Members of RSA's PA state team included representatives from each of
RSA's State Monitoring and Program Improvement's (SMPID's) five
functional units. The RSA PA state team was led by RSA's state liaison
to PA, Terrence Martin (VR Unit) and the following RSA PA team members:
Sue Rankin-White (Technical Assistance Unit); Regina Luster (Fiscal
Unit); Jean Yan (Data Unit); and Elizabeth Akinola (IL Unit).

## Information Gathering

During FY 2007, RSA began its review of OVR by analyzing information
including, but not limited to, RSA's various data collections, OVR's VR
and IL state plans, and OVR'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 OVR and
stakeholders in order to gain a greater understanding of OVR's strengths
and challenges:

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

-   the RSA PA state team conducted three teleconferences and one
    meeting with the OVR management;

-   the RSA PA state team held five teleconferences and one meeting with
    stakeholders;

-   RSA conducted an on-site monitoring visit on April 2 - 6, 2007;

-   the RSA PA state team also held several teleconferences and on-site
    meetings focused on the PaRC and IL services, including the
    development of the SILC;

-   the RSA state team attended public meetings soliciting input on the
    FY 2008 state plan; and

-   the RSA PA state team conducted teleconferences and held on-site
    meetings with the SILC chairperson and representatives from the IL
    community.

## Chapter 2: Vocational Rehabilitation and Supported Employment Programs

[Program Organization]{.underline}

OVR provides VR and SE services through 15 district offices.
Additionally, six district offices provide services to individuals who
are blind or visually impaired. At the time of the review, OVR staffing
included 381 VR counselors in the general VR services program, and 31 VR
counselors serving individuals who are blind or visually impaired. The
average caseload of a VR counselor in the general VR services program
was 118. The average caseload of a VR counselor serving individuals who
are blind or visually impaired was 66. At the time of the review, there
were approximately 40 VR counselor vacancies.

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.

**Table 1**

**PA OVR Trend Data**

  -------------------------------------------------------------------------------------------------
  PENNSYLVANIA      2002            2003            2004            2005            2006
  ----------------- --------------- --------------- --------------- --------------- ---------------
  Total funds used  \$146,257,595   \$151,981,006   \$163,927,060   \$153,386,934   \$160,240,862

  Individuals       57,087          59,512          61,531          60,950          60,213
  served during                                                                     
  year                                                                              

  Applicants        28,999          30,344          31,640          29,770          28,951

  Closed after      16,983          17,705          18,620          18,914          18,960
  receiving                                                                         
  services                                                                          

  Closed with       11,035          11,052          11,067          10,897          10,995
  employment                                                                        
  outcomes                                                                          

  Employment        9,796           9,951           10,092          9,967           10,214
  outcomes without                                                                  
  supports in an                                                                    
  integrated                                                                        
  setting                                                                           

  Average cost per  \$2,562.01      \$2,553.79      \$2,664.14      \$2,516.60      \$2,661.23
  individual served                                                                 

  Average cost per  \$13,253.97     \$13,751.45     \$14,812.24     \$14,076.07     \$14,573.98
  employment                                                                        
  outcome                                                                           

  Employment        75.45           72.72           67.51           71.04           68.62
  outcomes per                                                                      
  \$million spent                                                                   

  Competitive       70.77           68.86           64.19           68.19           66.31
  employment                                                                        
  outcomes per                                                                      
  \$million spent                                                                   

  Average hourly    \$9.34          \$9.60          \$9.80          \$9.98          \$10.25
  earnings for paid                                                                 
  employment                                                                        
  outcomes                                                                          

  Average state     \$17.22         \$17.78         \$18.24         \$19.03         \$19.65
  hourly earnings                                                                   

  Average hours     33.16           33.23           33.20           32.88           33.01
  worked per week                                                                   
  for paid                                                                          
  employment                                                                        
  outcomes                                                                          

  Percent of        25.89           25.01           25.30           26.04           26.55
  transition age                                                                    
  served to total                                                                   
  served                                                                            

  Employment rate   67.86           66.82           62.53           57.23           59.45
  for transition                                                                    
  age served                                                                        

  Average time      28.00           27.20           26.40           27.00           28.20
  between                                                                           
  application and                                                                   
  closure (in                                                                       
  months) for                                                                       
  individuals with                                                                  
  successful paid                                                                   
  employment                                                                        
  outcomes                                                                          

  Average number of 57.03           59.45           62.34           62.45           59.62
  individuals                                                                       
  served per total                                                                  
  staff                                                                             
  -------------------------------------------------------------------------------------------------

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

RSA provided technical assistance to OVR in a number of VR and SE
program areas during the review process. RSA:

-   verified the agency's RSA 911 case record data for FY 2004, FY 2005,
    and FY 2006;

-   provided feedback to the agency on its present case management
    system;

-   provided training on how to use RSA's Management Information System;

-   advised agency on expanding partnerships with other entities such as
    community development department, assistive technology grantee,
    transportation alliance, and volunteers in order to leverage
    resources;

-   provided results of a survey of vehicle purchase policies and
    guidelines;

-   reviewed mechanisms for consumer involvement;

-   reviewed a state statute that facilitates the maintenance of the
    membership of the statewide rehabilitation council, and the
    reimbursement of expenses related to participation;

-   reviewed the status of existing CAP, and provided additional
    guidance;

-   reviewed status of assurances provided for FY 2007 state plan
    approval;

-   assessed data collection methodology related to programs and
    activities conducted with the PA Community on Transition;

-   reviewed the Comprehensive Workforce Development System (CWDS) being
    developed for case management;

-   provided guidance on allowable use of electronic signatures in the
    CWDS; and

-   assessed QA practices and provided information on QA.

####### Promising VR and SE Practices Identified by OVR and Stakeholders During the Review Process

RSA's review process solicited input from OVR and stakeholders about
promising practices. The following promising practice was identified:

1\. Participation in the Pennsylvania Community on Transition.

OVR is an active participant in the PA Community on Transition - State
Leadership Team. The PA Community on Transition initiative is a result
of a Memorandum of Understanding (MOU) established by the 1998
Governor's Executive Order, "Interagency Committee to Coordinate
Services Provided to Individuals with Disabilities." The State
Leadership Team is comprised of representatives from the significant
Commonwealth agencies providing services to individuals with
disabilities and is dedicated to fulfilling the intent of the MOU to
improve coordination of services to children across the Commonwealth. In
2006, a new MOU was signed to advance and reconfirm the original 1998
MOU. Through this MOU, representatives from four PA agencies (Department
of Education; Department of Labor and Industry; Department of Public
Welfare; and the Department of Health) committed to "work together in
supporting youth and young adults with disabilities transitioning into
adult life in the achievement of their desired post-school outcomes,
with a focus on post-secondary education, training and lifelong
learning; community participation; and healthy lifestyles... to work in
equal partnership with youth and young adults with disabilities and
their families and care givers in advancing this shared agenda."

The 2006 MOU strengthened the commitment of the original 1998 MOU that
provided the springboard for the work of the PA Community on Transition.
OVR, as a participant in the 2006 MOU, and member of the State
Leadership Team, committed to the PA Community on Transition vision. In
addition to serving on the State Leadership Team, OVR representatives
have been instrumental in the creation of one of the four Outcome
Practice Groups. The Employment Outcome Practice Group was established
to increase the number of youth in Pennsylvania that obtains competitive
employment, as a result of a systematic approach to career development
activities.

As an active participant in the Pennsylvania Community on Transition,
OVR has been a significant contributor to the development and
implementation of over 40 transition programs in career exploration, job
shadowing, and mentoring, as well as developing and conducting capacity
building training programs such as \"Building Partnerships to Improve
Employment Outcomes of Youth with Disabilities." OVR is an active
participant in the 70 Local Transition Coordinating Councils (LTCCs)
across the state. The LTCCs are comprised of OVR staff, educators,
parents, advocates, and community rehabilitation providers. The LTCCs
provide training on transition services and employment. In addition, OVR
is an active participant in the IDEA partnership, and disseminates
materials, experiences, models, and resources through the Sharedwork.org
web site funded by the U.S. Department of Education's Office of Special
Education Programs.

In FY 2006, 5,033 youths with disabilities were served by OVR, an
increase from 4,926 served in FY 2005. In FY 2006, the cases of 2,992
youths with disabilities were successfully closed, an increase from
2,819 in FY 2005 (RSA).

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

RSA's review process solicited input from OVR and stakeholders about VR
and SE performance and compliance issues. The following issues were
identified:

-   providing vocational rehabilitation services to returning veterans;

-   number of cases PA CAP receives in relation to number of
    applications and people served;

-   order of selection category determination;

-   access to One-stop facilities and programs;

-   counselor vacancies and large caseloads;

-   communication with referral sources;

-   need for training VR program participants in the use of assistive
    technology prior to entering college;

-   information on policy waivers provided to consumers;

-   communication and timely access to materials during policy
    development;

-   fair hearing officer selection and training;

-   fair hearing process satisfaction survey;

-   outreach to individuals who are deaf, hard of hearing, and
    individuals with intellectual disabilities;

-   customer satisfaction survey for all closures;

-   merit scholarship in computing costs for college programs;

-   number of blind or visually impaired individuals in leadership and
    professional positions;

-   counselor contact with consumer while awaiting services; and

-   long term employment support and outcome based contracting.

Following compilation and discussion with OVR about the issues, RSA
worked with OVR to address as many of these issues as possible either
directly or by consolidating the issue into a broader issue area.

## 

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

RSA and OVR agreed on the following performance goals; strategies to
achieve those goals, and technical assistance that RSA would provide to
assist OVR achieve each goal. These goals and strategies will be
considered for inclusion in OVR's FY 2009 state plan and if they are
included, progress on achieving these goals will be reported in OVR's FY
2011 annual state plan submission.

[1. Transition Age Youths]{.underline}

Issue: During FY 2005, OVR served 4,926 transition age youths
representing 26.04 percent of the total of the number of individuals
served by OVR. In FY 2006, PA OVR served 5,033 transition age youths
representing 26.55 percent of the total number of individuals served.
The rehabilitation rate for transition youths also increased from 57.23
percent in FY 2005, to 59.45 percent in FY 2006, as a result of an
increase from 2,819 successful outcomes in FY 2005, to 2,992 successful
outcomes in FY 2006. The national employment rate for 16 to 24 year old
youths reported by the US Department of Labor in the summer of 2006 was
88.8 percent.

Providing services that result in the successful transition of youths to
employment outcomes is a significant issue for OVR. Transition age
youths represent a substantial percentage of the total number of
individuals OVR serves. During the on-site visit, OVR staff expressed
concern about tracking youths who participate in programs conducted
through the PA Community on Transition. In FY 2006, 1,288 youths were
closed after determination of eligibility for services without an
Individualized Plan for Employment (IPE) being developed, or after
development of the IPE without receiving services. Data regarding
participation and outcomes could be used to maximize resources, and
improve programs.

In addition, issues such as those related to the provision of services
and policy development, which were expressed by stakeholders during the
monitoring process, have implications for providing services to
transition age youths that result in quality employment outcomes.

Goal: Close the gap between the rehabilitation rate of transition age
youths with disabilities and the employment rate of all youths.

Strategies:

1\. hire new transition coordinator by October 1, 2007 to continue and
enhance effective collaborative relationships with state and federal
entities serving youths, and family and student organizations;

2\. develop and implement common data elements with collaborating
partners to enhance tracking and reporting capabilities; and

3\. analyze data to assess impact of collaborative activities on
outcomes.

Method of Evaluation: OVR will be successful as the gap between the
rehabilitation rate of transition age youths with disabilities and the
employment rate of all youths is closed.

Technical Assistance: RSA will provide technical assistance on
measurement of progress and outcomes.

[2. Individuals who are Blind or Visually Impaired]{.underline}

Issue: In 1999, OVR was restructured with the establishment of the
Bureau of Blindness and Visual Services within OVR. The bureau mission
is to assist individuals who are blind or visually impaired gain the
skills necessary to live and work independently in their communities.
The bureau provides services with staff located in six district offices.
In FY 2006, OVR served 761 individuals who are blind or visually
impaired, an increase from the 699 individuals served in FY 2005. The
number of individuals who are blind or visually impaired receiving
services represents 4 percent of OVR's total population served in FY
2006. In FY 2006, 527 individuals who are blind or visually impaired
achieved an employment outcome, which is a 69.3 percent rehabilitation
rate.

The BEP is an employment outcome option available to individuals who are
blind or visually impaired. In FY 2006, 11 individuals chose BEP as an
employment outcome, which was an increase from three in FY 2005. During
FY 2006, there were 54 vendors in PA. At the end of FY 2006, there were
57 BEP cafes, snack bars, and vending locations. Two new locations were
opened in FY 2006. OVR also operates a BEP training program as part of
the state operated comprehensive rehabilitation center, the Hiram G.
Andrews Center, in Johnstown, PA. The BEP training program provides
initial, advanced, and upward mobility training for vendors. The three
training programs had nine participants in FY 2006.

Goals:

1\. Close the gap between employment outcomes of individuals who are
blind/visually impaired and the employment rate of the general
population in Pennsylvania.

2\. Increase BEP outcomes for those individuals choosing the BEP as an
outcome.

Strategies:

1\. focus counselors on providing services to achieve employment
outcomes;

2\. establish one new BEP location in FY 2008, and two new BEP locations
in FY 2009;

3\. provide initial, advanced, and upward mobility training to 10 BEP
managers in FY 2008, and 15 BEP managers in FY 2009; and

4\. enhance BEP training at HGAC to develop BEP facility managers for
new locations and upward mobility.

Methods of Evaluation:

1\. OVR will be successful as the gap between employment outcomes of
individuals who are blind/visually impaired and the employment rate of
the general population in Pennsylvania is closed; and

2\. OVR will be successful as the number of BEP outcomes for those
individuals choosing BEP as an outcome increases in FY 2008, and FY
2009.

Technical Assistance: RSA will provide technical assistance by assisting
OVR in learning more about BEP training programs at other state
agencies.

[3. Quality Improvement]{.underline}

Issue: OVR will implement a new case management system beginning in
November of 2007, followed by three more system component releases over
the next four years. The new system, CWDS, has been under development
since 2005. OVR staff have been active participants in the design of the
CWDS, and in end-user testing. System implementation and staff training
during FY 2008 will present demanding challenges for OVR. The CWDS
project is a partnership among the Department of Labor and Industry's
Bureau of Workforce Development Partnership and OVR, and the Department
of Public Welfare's Bureau of Employment and Training Programs. The CWDS
is an extensive systems upgrade that will affect case management
procedures and processes, as well as provide new tools to all staff. A
review of the functionality of the CWDS demonstrated to RSA staff that
the system would provide OVR with a significant tool for enhancing its
existing QA practices, and for developing new process analysis measures
to ensure continuous improvement in the quality of service provision.

During the on-site review, the RSA state team had the opportunity to
review the QA process for case review, and the results of customer
satisfaction surveys. OVR's case review process is based on effective QA
practices and provides significant performance data to counselors and
supervisors, as well as to district office and central office
management. The data are also used to determine training needs.

OVR also uses data derived from customer satisfaction surveys as a
source of information on agency performance. It was noted during
discussions that OVR only surveys those individuals who have been closed
with an employment outcome. PaRC and PA CAP representatives raised
concerns about surveying only individuals with employment outcomes. They
noted that it may be beneficial to solicit input from individuals
exiting without employment outcomes in order to provide a more complete
view of consumer satisfaction, and to enable OVR to make program
improvements to respond to consumer concerns derived from the surveys.

Goal: Increase agency capacity for continuous improvement of service
delivery and achievement of employment outcomes through enhancement of
existing QA processes and procedures, and development of new QA
processes and procedures.

Strategies:

1\. identify data and capacities available within the new CWDS that can
be used to assess agency performance and support continuous improvement
of service delivery;

2\. hire two program analysts in FY 2008;

3\. develop key indicators, performance measures, and reports by
September 30, 2008; and

4\. implement improvement recommendations resulting from analysis of
performance data by September 30, 2008.

Method of Evaluation: OVR will be successful as quality and performance
measures are developed in the CWDS and implemented to support QA and
continuous improvement of services and outcomes.

Technical Assistance: RSA will provide technical assistance on
development of QA and continuous improvement processes and procedures.

[4. Consumer Involvement]{.underline}:

Issue: RSA observed active and dedicated stakeholders in Pennsylvania.
OVR, in collaboration with consumers and stakeholders, has established
Citizen Advisory Councils in each of the 21 OVR district office areas.
The CACs enable consumers and stakeholders at the district level to
provide OVR with input on service delivery and policy development. OVR
management expressed appreciation for the involvement of the PaRC, the
PA CAP, the CACs and other advisory groups and stakeholders in assisting
OVR with its mission "to assist Pennsylvanians with disabilities to
secure and maintain employment and independence."

OVR management expressed their intention to seek input on policy related
matters from consumers early in the process. However, feedback from the
PaRC and the PA CAP indicated their concern that, from their
perspective, they were not involved with OVR in policy development at
the formative stages of development, but only after the fact, and then,
only in a perfunctory manner. OVR has established CACs across the state
for the purpose of securing consumer input into the VR program. However,
based on discussions with stakeholders, the network is currently
underutilized.

RSA staff had an opportunity to attend a session for public comment on
the FY 2008 state plan on April 4, 2007, held at the Harrisburg district
office. At the public comment session, RSA observed that attendance
appeared to be lower than expected with only a few individuals
attending. OVR staff indicated that attendance has been low over the
last few years in spite of extensive efforts to publicize the sessions.
Dialogue ensued with district office staff on strategies to potentially
improve attendance, such as conducting focus group discussions and
conducting meetings in neutral locations. District staff indicated they
have tried many ways to increase participation.

Goal: OVR and its stakeholders will work together to enhance consumer
involvement in VR program activities.

Strategies:

1\. access capacity building training for CACs and/or alternative
community advocates to improve their effectiveness in providing input
into the VR program; and

2\. develop and implement strategies to increase participation on public
meetings.

Method of Evaluation: OVR and its stakeholders will be successful as
consumer involvement in policy development is enhanced.

Technical Assistance: RSA will provide technical assistance to OVR and
stakeholders on approaches used by other agencies and constituent groups
to enhance involvement.

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

The following was identified as a compliance issue during FY 2007
monitoring.

[1. State-Funded VR Program]{.underline}

Issue: OVR's state-funded VR program was established on July 1, 1998,
when funds were made available from the Commonwealth of Pennsylvania to
OVR to serve individuals with disabilities "who are eligible under the
federal Act and meet the definition of Severely Disabled (SD) or
Non-Severely Disabled (NSD)" (Department of Labor and Industry, Office
of Vocational Rehabilitation, Program Policies & Guidelines, 98-300.30,
1998, p.1). Authorization to operate the program was derived from the
State Vocational Rehabilitation Act of 1987 enacted by the General
Assembly (Senate Bill 1190, Session of 1987). The program was to be,
"funded entirely by a State appropriation," and "most of the provisions
of the Federal Rehabilitation Act of 1973 and its amendments are not
applicable" (98-300.30, p.1). The intent of the appropriation was "to
provide only immediate and short-term services to effect an employment
outcome" (p.1). The program was initially established within OVR as a
"demonstration project to allow for a period of review and revision"
(p.1), but was extended by 98-300.30 (Supplement 2) through June 30,
2000. "Although it is anticipated the Program will become permanent, it
will continue as a demonstration project until final policy development"
(98-300.30 (Supplement 2), p.1).

Program Policies & Guidelines 98-300.30, provides operational
instructions for the state-funded VR program to OVR staff on appropriate
customers; allowable services; service providers; plan development;
fiscal procedures; case documentation; case closure; appeals; and
information system code changes. Operational instructions provided to VR
counselors state that **"**in order to receive services, an individual
and their OVR counselor must develop a mutually agreed upon employment
plan...The plan shall include decisions made as to selection of
vocational goal, services to be provided, and parties responsible for
the cost of such services...Decisions will be made after the individual
and counselor discuss appropriate options" (p.3). Furthermore,
"throughout the life of the case it is the counselor's responsibility to
document activities as regards all aspects of the case. Documentation
should include, but is not limited to, progress notes as regards
personal or phone contacts, discussions with the individual or vendors
and employment activities germane to case services" (p.3).

OVR's State VR Program Report, July 1, 2005 - June 30, 2006, provides
statistics for the period July 1, 2005 through June 30, 2006. The report
indicates that, as of June 30, 2006, OVR had 1,550 open cases in the
State-funded VR program; 1,699 receiving services under the state-funded
program; and 1,560 closed State-funded VR program cases, of which 1,284
were closed working.

34 CFR 361.13(b)(iii) states that the designated State unit have a staff
"at least 90 percent of whom are employed full time on the
rehabilitation work of the organizational unit." The state-funded VR
program is administered by OVR through the Commonwealth of Pennsylvania
law that provides the authority of the State Board of Vocational
Rehabilitation. The State Board of Vocational Rehabilitation is the
Designated State Agency. The VR counselor staff of OVR provide the
services of the state-funded VR program to individuals. VR counselors
are paid 100 percent from Basic Support Program funds, and work with
these individuals until they obtain employment and are closed under the
rules of the state-funded VR program. 

On July 10, 2007, RSA advised OVR that in order for a state VR agency to
operate a separate VR program with state funds or other sources, the
program must be totally separate and distinct from the VR program
established under Title I of the Act. In particular, funds allotted
under Title I must be kept completely separate from that other program.
If OVR were to operate this state-funded program such that the funds
were kept completely separate and the counselors\' salaries/benefits and
other administrative costs were allocated properly between the programs,
then it may be possible for OVR to run a separate program. If the
program is completely separate and distinct from the Title I VR program,
then OVR is not obligated to follow federal requirements for the
separate state-funded program.

To resolve this compliance issue, OVR must submit a CAP for RSA approval
within 30 days of receiving this report. The submitted CAP will
describe:

-   the steps OVR will take to ensure that Title I funds are not used in
    the administration of the state-funded VR program; and

-   the timelines for completing the steps necessary to ensure that
    Title I funds are not used in the administration of the state-funded
    VR program.

## VR and SE Recommendations

RSA recommends that OVR establish goals and strategies to address the
following VR and SE issue:

-   As noted earlier in this report, OVR only sends consumer
    satisfaction surveys to individuals who have exited the VR program
    with an employment outcome. The PaRC and PA CAP representatives
    raised concerns about surveying only individuals with employment
    outcomes. The PaRC and PA CAP have recommended that OVR survey
    individuals exiting the VR program without employment outcomes in
    order to provide a more complete view of consumer satisfaction.

## VR and SE Issues for Further Review

RSA plans on conducting further review of the following VR and SE issue.

Issue: Fair hearing process.

During monitoring activities, stakeholders noted issues related to the
fair hearing process. Specifically, stakeholders noted concerns about
fair hearing officer selection, qualifications, and training.
Additionally, stakeholders noted dissatisfaction about the
discontinuance of fair hearing process satisfaction surveys. As a result
of stakeholders' expressing these concerns, RSA will conduct further
review of the fair hearing process during FY 2008.

## Chapter 3: Fiscal Review of the VR Program

RSA reviewed OVR'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 OVR for FY 2002 through FY 2006**

  --------------------------- ------------- ------------- ------------- ------------- -------------
  **Pennsylvania (C)**                                                                

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

  **Grant Amount**            111,070,319   113,062,577   115,424,463   115,157,515   118,963,780

  **Required Match**          30,060,963    30,600,164    31,239,404    31,167,155    32,197,313

  **Federal Expenditures**    101,873,054   96,605,820    110,833,827   112,485,743   108,080,795

  **Actual Match**            30,060,963    30,993,091    31,310,953    31,187,719    32,199,928

  **Over (Under) Match**      0             392,927       71,549        20,564        2,615

  **Carryover**               9,197,265     16,456,757    4,590,636     2,671,772     10,882,985

  **Program Income**          8,329,536     6,124,669     3,948,580     3,475,212     5,533,438

  **Maintenance of Effort     28,310,456    28,834,759    30,060,963    30,600,164    31,239,404
  (MOE)**                                                                             

  ** **                                                                                

  **Administrative Costs**    12,355,774    13,286,023    12,558,640    13,495,609    13,855,384

  **Total Expenditures**      146,257,595   151,981,006   163,927,060   153,386,934   160,240,862

  **Percent Admin Costs to    8.45%         8.74%         7.66%         8.80%         8.65%
  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 technical assistance to OVR in a number of fiscal areas
during the review. RSA:

-   obtained and input all Financial Status Reports (SF-269s) not
    previously entered into RSA's Management Information System (MIS)
    for all formula grant programs;

-   reviewed financial reports with agency staff, made corrections, and
    approved all reports for FYs 2002 -- 2007;

-   clarified issues related to the carryover of federal funds from FYs
    2003, 2004 and 2005;

-   made adjustments to properly report the obligation and expenditure
    of FYs 2003, 2004 and 2005 carryover funds (\$5,754,786);

-   provided extensive technical assistance to ensure future compliance
    with the statutory carryover requirement;

-   identified significant issue with the sufficiency of matching funds;

-   discussed strategies to address the growing shortfall of matching
    funds for the VR Program;

-   discussed RSA's analysis of Pennsylvania's allotment from FYs 2002
    -- 2007, and the agency's entitlement to priority consideration for
    additional federal funds through the reallotment process in each of
    these years;

-   analyzed the impact of requesting and receiving \$5,855,891 through
    the reallotment process during the 4-year period from FYs 2003 --
    2006 (The expenditure of these funds reduced the amount of state
    funds projected as available for match in the subsequent federal FY
    and essentially increased the growing match shortfall by
    \$1,584,885);

-   reviewed variances in program income earned each fiscal year and the
    impact of the shortfall in projected FY 2007 program income;

-   provided comparisons of OVR's program income earned with national
    averages for all VR agencies and combined agencies;

-   discussed strategies for increasing program income, and the agency's
    use of this income to increase counselor case services budgets in
    the districts in which the income was earned;

-   indicated that administrative costs charged to the VR program are
    well-below national averages and, from initial discussions with the
    agency, concluded that these costs may not be accurately reported
    and distributed to all benefiting programs; and

-   reviewed time distribution documentation requirements and the OMB
    Circular A-87 semi-annual certification requirement for all staff
    charged 100 percent to any federal grant program.

[VR and SE Performance Issues, Goals, Strategies, and Technical
Assistance]{.underline}

[1. Match]{.underline}

Issue: There is a significant and increasing shortfall in non-federal
funds available for match in the VR Program. At the time of RSA's onsite
review, an analysis of agency workpapers substantiated a projected match
shortfall of \$14,000,000 for FY 2007. One part of this deficit can be
attributed to the increase in the VR Program allotment each year since
FY 2002, without a corresponding increase in state matching funds (FY
2003 - \$539,201; FY 2004 -- \$639,240; FY 2005 - \$72,249; FY 2006 --
1,030,158; FY 2007 - \$750,134). A second factor to take into
consideration is the additional \$5,855,891 received through the
reallotment process from FYs 2003 -- 2006, which also had to be matched
during this period. With no increase in state funding, OVR began to
borrow more and more of the state funds appropriated for future grant
periods to closeout the current federal FY. Financial staff are aware of
this large deficit and continuously update resource information (federal
and state) to provide management with accurate financial information
related to this growing deficit.

Goal: To obtain full match for each federal fiscal year.

Strategies:

1\. explore options to reduce match shortfall and eliminate reliance on
the use of state funds appropriated for future periods to close out each
federal fiscal year (increase in state appropriations, outside sources
of match); and

2\. if unable to reduce shortfall, develop a strategy for releasing
federal funds through the reallotment process (timing and amount).

Technical Assistance: RSA will provide on-going technical assistance
throughout this exploration process as OVR devises strategies to
increase VR Program matching funds, resolves the issue of a significant
shortfall in current year state appropriations, and, if necessary,
through the development of a strategy to begin the release of federal
funds through the reallotment process.

[VR and SE Issues for Further Review]{.underline}

RSA plans on conducting further review of the following VR and SE issue.

Issue: Continuance of financial monitoring review activities to complete
all planned review activities.

Upon completion of the onsite review activities there were three
financial areas where planned review activities were incomplete.
Throughout FY 2008, RSA will continue monitoring activities as described
below.

-   Complete the review of the classification and reporting of
    administrative costs charged to the VR Program. (RSA-2 Report,
    Schedule I, Line 1). Although reported costs are lower than the
    national averages for all VR agencies and combined agencies,
    concerns surfaced during an initial review of workpapers that some
    administrative costs may not be properly reported and such costs may
    not be allocated to all benefitting programs.

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-   Verify adherence (since documentation was not available during the
    onsite review) to time distribution and A-87 certification
    requirements outlined in OMB Circular A-87, Attachment B, Paragraph
    H -- support for salaries and wages. (These requirements are
    separate from time and attendance requirements for all employees
    charged to federal grant programs.).

-   Conduct a complete review of the procurement process used by OVR to
    purchase goods and services for the VR Program. This review will
    include the sufficiency of staff to carry out this function, the
    agency's use of the innovation and expansion authority to "grant" VR
    Program funds and other procurement arrangements classified by OVR
    as grants, contracts and interagency agreements. Procurement
    impediments, contractor evaluation and contract oversight will also
    be reviewed.

-   Review charges allocated to the VR Program and other RSA-funded
    programs for the Department of Labor & Industry's new CWDS. At the
    time of RSA's onsite review, OVR had been designated as a mandatory
    partner and it was projected that a minimum of \$10.08 million had
    been, or would be, charged to the VR Program for the initial costs
    of this new system.

## Chapter 4: IL Program

[Program Organization]{.underline}

OVR and the PA SILC jointly administer the state's Part B IL program.
The Pennsylvania Council on Independent Living, (PCIL), works closely
with the PA SILC to administer the other IL programs in the state. The
PA SILC and the PCIL are each primarily responsible for fulfilling the
day-to-day administrative responsibilities for their respective
organizations. The state has nine federally funded, and nine
state-funded CILs. Through a contractual agreement, Resources for Human
Development was responsible for providing training to both the PA SILC
and the CILs at the time of RSA's on-site visit.

**Table 3**

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

  ------------------------------------- ---------------------------------
                                        SILC

  Part B Funds                          702,551

  Older Blind                           1,489,998

  Other Federal Funds                   566,640

  State Funds                           231,421

  Local Government                      0

  Private/Other Funds                   0

  Total                                 2,990,610
  ------------------------------------- ---------------------------------

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

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

-   provided technical assistance on ways to develop a statewide uniform
    reporting system for the CILs programs in the state. RSA shared
    information about the I-Online, a statewide reporting system that is
    being used successfully in Virginia. All the IL key players were
    interested in learning more about the I-Online, and suggested that
    RSA facilitate discussions with Access to Independence, the CIL in
    Virginia that provides training on using the I-Online on their
    behalf. RSA has since spoken with Access to Independence, and they
    have agreed to work with the PA SILC. Contact information has been
    shared with representatives of both parties;

-   provided technical assistance on how to improve working
    relationships for better collaboration, coordination, and
    cooperation among the different IL programs in the state, including
    the IL services for older blind individuals; and

-   provided technical assistance on how PA SILC can participate in the
    achievement of State Plan for Independent Living goals without
    engaging in activities beyond those SILC statutory duties that are
    laid out in Section 705(c) of the Act.

####### Promising IL Practices Identified by OVR and Stakeholders During the Review Process

RSA's review process solicited input from OVR and stakeholders about
promising practices. The following promising practices was identified:

1\. Effective Utilization of PA SILC Staff in SPIL Monitoring and
Evaluation.

The PA SILC has adopted a staff model in which employees are trained to
specialize in issue areas based on the goals and objectives identified
in the SPIL. These staff monitor implementation and progress as
activities are conducted to accomplish each SPIL goal or objective. This
approach is effective because the PA SILC staff work as a team,
exchanging ideas and suggestions on SPIL-related projects and activities
based on each person's area of expertise. This staff model allows the PA
SILC to effectively evaluate implementation of SPIL goals and
objectives, and determine whether or not to explore alternative methods
and/or approaches. The use of specialized staff and teamwork gives the
PASILC the appropriate feedback with which the organization provides
direction to the IL community in meeting consumer service needs.

####### IL Issues Identified by OVR and Stakeholders During the Review Process

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

-   lack of a uniform statewide reporting system for CILs;

-   need for a stronger working relationship between the different IL
    programs in the state; and

-   need for increased outreach efforts by the different IL programs in
    the state.

Following compilation of this list, RSA worked with OVR 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 and OVR agreed on the following IL
performance goals, strategies to achieve those goals, and technical
assistance that RSA would provide to assist OVR achieve each goal.

[1. Uniform Statewide Reporting System]{.underline}

Issue: According to information obtained from stakeholders, it has been
difficult to develop a set of uniform definitions for the different IL
services provided by all the CILs, federally funded and state-funded.
This has led to a statewide inconsistency in the types of IL services
provided by the different CILs, and in the method of reporting service
outcomes. Having a uniform statewide accountability system in place will
ensure that there is consistency in the types of services provided, that
consumers are able to receive similar IL services from any CIL, and that
the CILs will be able to report similar outcomes for each type of
service provided regardless of where the CIL is located within the
state.

Goal: Develop a statewide uniform accountability system for improved IL
service provision and reporting.

Strategies:

1\. the PA SILC and the PCIL will continue to work together to come up
with uniform definitions for all the types and categories of IL services
that are provided in the state;

2\. the PA SILC will continue to search for suggestions and ideas from
other states on how to ensure that all IL service types and categories
have the same definition statewide, and that all consumers seeking these
services have equal access to them regardless of where a CIL is located
within the state;

3\. OVR, the PA SILC, and the PCIL will jointly create a statewide
reporting system by developing a database that contains all the
definitions for all IL service types and categories; and

4\. OVR and the PA SILC will organize training and technical assistance
to enable all CIL staff and IL service providers learn how to operate
the database, and thus improve the method of reporting statewide.

Method of Evaluation: OVR and the PA SILC will be successful when a
statewide uniform accountability system is developed.

Technical Assistance: RSA will facilitate the exchange of ideas with
other states where such systems have been developed and utilized
successfully.

[2. Stronger working relationship between the different IL programs in
the state.]{.underline}

Issue: Currently, IL issues affecting the blind have generally been
separated from those affecting other disability groups. The PA SILC, the
OIB program officers, the CILs, individual consumers, and consumer
advocacy groups agree that when it comes to IL services, the disability
category is secondary. All the parties strongly believe that
strengthening the working relationship between the PA SILC and the OIB
program will ensure that issues affecting the older blind are identified
and addressed along with those of other disability groups.

Goal: Improve the collaboration, cooperation, and coordination among the
PA SILC, the CILs, and the OIB program.

Strategies:

1\. the PA SILC and the CILs will continue to strengthen the existing
working relationship with the OIB program;

2\. OVR will work more closely with the PA SILC to ensure that the PA
SILC receives more feedback from older blind consumers on IL service
provision, and service areas needing improvement;

3\. OVR will work more closely with the PA SILC to increase public
awareness about the OIB program, and issues affecting older blind
consumers; and

4\. OVR will work more closely with the CILs to improve access to IL
services for older blind consumers through the CILs in their
communities.

Method of Evaluation: OVR and the PA SILC will be successful when
collaboration, cooperation, and coordination among OVR, PA SILC, the
CILs, and the OIB program have improved.

Technical Assistance: RSA will provide technical assistance when
requested by the PA SILC, the CILs, and OVR regarding ways to improve
collaboration, coordination, and cooperation among all the parties.

[3. Outreach to increase public awareness of IL services in the
state.]{.underline}

Issue: Currently, many of the centers for independent living conduct
outreach activities in their communities. However, the rural nature of
some geographic areas in the state hinders progress on this issue for
some centers. There is a need for increased outreach efforts by the
different IL programs to increase public awareness of IL services
available within PA, especially the awareness of those individuals
residing in rural areas.

Goal: Improve outreach efforts to increase public awareness, especially
among individuals in rural areas, about the availability of IL services.

Strategies:

1\. the PA SILC and PCIL will identify increased outreach efforts,
especially rural outreach, as part of the goals and objectives in the
new SPIL;

2\. all IL service providers and partners in the state will periodically
organize and increasingly participate in rural community events as a way
of reaching out to individuals with disabilities residing in those
communities; and

3\. the PA SILC, all IL service providers, and partners will work
closely with individual IL consumers and consumer advocacy groups to
develop new methods and approaches for increasing public awareness about
disability issues in all geographic areas of the state.

Method of Evaluation: OVR and the PA SILC will be successful when there
is increased public awareness, especially among individuals in rural
areas, of IL services in the state.

Technical Assistance: RSA will share techniques utilized by states with
similar demographics to address issues of IL service provision to rural
populations. RSA will also facilitate training and technical assistance
from the Association of Programs for Rural Independent Living.

## Chapter 5: OIB Program

[Program Organization]{.underline}

The OIB program in Pennsylvania is operated by OVR. The program receives
\$1,489,998 of Title VII, chapter 2 funds; and \$165,555 state funds
(excluding in-kind contributions).

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

RSA provided technical assistance on how to improve the working
relationship between the OIB and other IL programs in the state.

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

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

-   consumers with visual impairments, especially the older blind, have
    very limited access to IL services;

-   consumers are unaware of the vast array of services that CILs
    provide; and

-   general belief in the blindness community that CIL services are only
    available to individuals with physical disabilities.

Following compilation of this list, RSA worked with OVR to address as
many of these issues as possible.

## 

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

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

[1. Access to IL services for older blind consumers.]{.underline}

Issue: Individuals with visual impairments, especially the older blind,
have very limited access to IL services. This is because a high number
of these individuals are unaware of the vast array of services that CILs
provide, or that these services are available to them because of the
general belief in the blindness community that CIL services are only
available to individuals with physical disabilities. There is a need for
increased access to IL services for the blind and visually impaired,
especially the older blind, through the CILs.

Goal: Increase access to IL services for older blind individuals.

Strategies:

1\. the PA SILC and the OIB program director will continue to improve on
their existing working relationship;

2\. OVR will strengthen its working relationship with the CILs as a way
of improving access to IL services for older blind consumers in a timely
manner; and

3\. OVR and OIB program officers will provide some basic blindness and
IL skills training to CIL staff to enable them meet the basic IL service
needs of the older blind and other consumers with vision impairments.

Method of Evaluation: OVR and the OIB program will be successful when
older blind individuals' access of IL services increases.

## Chapter 6: Progress on Issues Raised in Previous Reviews

As a result of the RSA review conducted with OVR in FY 2005, the agency
developed a CAP. A summary of the progress that OVR has made on the CAP
is described below.

###### Corrective Action Plan

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

-   establishing a policy with a time standard for contacting an
    individual referred to the agency for services;

-   establishing a policy with a time standard for development of the
    IPE following a determination of Eligibility;

-   establishing time standards for: contact with Referrals; determining
    Eligibility and priority for services; and development of the
    customer's IPE;

-   taking corrective action to assure all services considered necessary
    for an employment outcome are provided and contribute substantially
    to the employment outcome of the individual;

-   taking action to assure the individual achieves the employment
    outcome described in the IPE;

-   taking corrective action to assure service records include
    verification that the individual's wage and level of benefits are
    not less than that usually paid non-disabled individuals for the
    same or similar work;

-   revising its training policy to state that a customer is not
    required to take out a loan to pay for this service;

-   revising its training policy to assure that the rehabilitation needs
    of each individual's IPE are the basis for determining the cost of
    training;

-   revising its SF-269's for the fourth quarter of FY 2004 and FY 2005
    to properly reflect how it's using program income; and

-   revising its RSA-2 for FY 2004 to reflect BEP expenditures.

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

1\. Developing formal written agreements or other mechanisms with PA
state universities and community colleges, setting forth (1) the
financial responsibility of each party; (2) the conditions, terms and
procedures for reimbursement; (3) procedures for resolving disagreements
between the parties; and (4) procedures for coordinating services among
the parties in accordance with 34 CFR 361.53(d).

[Status]{.underline}: On August 15, 2007, RSA received an update on the
status of this CAP item from OVR stating that the final document has
been sent to the State System of Higher Educations (SSHE) for three
required signatures. Following return from SSHE OVR will secure four
additional required signatures from within the PA Department of Labor
and Industry and the Attorney General's Office. OVR provided RSA an
assurance that the agreements will be signed by September 30, 2007, for
approval of the FY 2007 state plan.

2\. Taking corrective action to ensure counselors appropriately follow
agency policies on determining the significance of disability of a
customer.

Status: Training has been provided to the VR staff in four OVR District
Offices. Also, training was provided to the newly hired VR counselors
from all the 21 field offices. Three levels of QA Reviews are done on an
ongoing basis. This will also be covered in the training component for
implementation of the new computer system, which will occur in October
2007.

3\. Revising its order of selection policy and procedures to be
consistent with 34 CFR 361.36 (d) (1).

4\. Taking corrective action to assure its policies for determining
significance of disability are consistent with the tools used by
counselors to implement the policy. It must also use the appropriate
functional capacities and recommends use of the ones found in Section 7
(21) (A) of the Act.

5\. Take corrective action to assure that the functional capacities used
in its definition of "significant disability" and "most significant
disability" and the related process for determining limitations in these
capacities, be the same as outlined in Section 7 (21) (A) of the Act.

[Status]{.underline}: On August 15, 2007, RSA received an update on the
status of this CAP item from OVR stating that the three items above will
be corrected by revising its order of selection policy and procedures by
adopting guidance related to determining significance of disability
provided in RSA Technical Assistance Circular (TAC) 05-01. RSA will
review the revised policy memo to ensure compliance with 34 CFR
361.36(d)(1). OVR will also provide training to staff to ensure that the
revised policies and procedures for determining significance of
disability are implemented correctly.

## Chapter 7: Summary Conclusion

OVR staff are dedicated to providing quality services to individuals in
the Commonwealth of PA. OVR has established effective collaborative
relationships with other PA agencies. There is a consumer and advocacy
community committed to improving the lives of individuals with
disabilities and working with OVR to ensure that quality services are
provided and successful employment outcomes are achieved. OVR has
established collaborative relationships with the PA state education
agency and local school districts to address the successful transition
of youths to post secondary education and training, community
participation, and employment.

OVR faces the challenges of operating a state-funded VR program separate
and distinct from the Title 1 VR program, improving the rehabilitation
rate of transition age youths, and employment outcomes for blind and
visually impaired consumers. OVR must also successfully implement and
complete the remaining corrective actions from RSA's FY 2005 monitoring
of the agency.

OVR, the PA SILC, and IL partners face challenges related to varying
definitions for services used by CILs, access to services, outreach, and
public awareness.

Table 4 summarizes the results of RSA's review.

**Table 4**

**Summary of the Results of RSA's Review**

+-----------------------+-----------------------+-----------------------+
| **Agency: PA OVR**    |                       |                       |
+-----------------------+-----------------------+-----------------------+
| **Program: VR**       |                       |                       |
+-----------------------+-----------------------+-----------------------+
| **Goal**              | **Strategies**        | **Technical           |
|                       |                       | Assistance**          |
+-----------------------+-----------------------+-----------------------+
| **1.** **Transition   | 1 Hire new transition | RSA will provide      |
| Age Youths**          | coordinator by        | technical assistance  |
|                       | October 1, 2007 to    | on measurement of     |
| Close the gap between | continue and enhance  | progress and          |
| the rehabilitation    | effective             | outcomes.             |
| rate of transition    | collaborative         |                       |
| age youths with       | relationships with    |                       |
| disabilities and the  | state and federal     |                       |
| employment rate of    | entities serving      |                       |
| all youths.           | youths, and family    |                       |
|                       | and student           |                       |
|                       | organizations.        |                       |
|                       |                       |                       |
|                       | 2\. Develop and       |                       |
|                       | implement common data |                       |
|                       | elements with         |                       |
|                       | collaborating         |                       |
|                       | partners to enhance   |                       |
|                       | tracking and          |                       |
|                       | reporting             |                       |
|                       | capabilities.         |                       |
|                       |                       |                       |
|                       | 3\. Analyze data to   |                       |
|                       | assess impact of      |                       |
|                       | collaborative         |                       |
|                       | activities on         |                       |
|                       | outcomes.             |                       |
+-----------------------+-----------------------+-----------------------+
| **2.** **Individuals  | 1\. Focus on          | RSA will provide      |
| who are Blind or      | providing services to | technical assistance  |
| Visually Impaired**   | achieve employment    | by assisting OVR in   |
|                       | outcomes.             | learning more about   |
| 1 Close the gap       |                       | BEP training programs |
| between employment    | 2\. Establish one new | at other state        |
| outcomes of           | BEP location in FY    | agencies.             |
| individuals who are   | 2008, and two new BEP |                       |
| blind/visually        | locations in FY 2009. |                       |
| impaired and the      |                       |                       |
| employment rate of    | 3\. Provide initial,  |                       |
| the general           | advanced, and upward  |                       |
| population in         | mobility training to  |                       |
| Pennsylvania.         | 10 BEP managers in FY |                       |
|                       | 2008, and 15 BEP      |                       |
| 2 Increase BEP        | managers in FY 2009.  |                       |
| outcomes for those    |                       |                       |
| individuals choosing  | 4\. Enhance BEP       |                       |
| the BEP as an         | training at HGAC to   |                       |
| outcome.              | develop BEP facility  |                       |
|                       | managers for new      |                       |
|                       | locations and upward  |                       |
|                       | mobility.             |                       |
+-----------------------+-----------------------+-----------------------+
| **3. Quality          | 1\. Identify data and | RSA will provide      |
| Improvement**         | capacities available  | technical assistance  |
|                       | within the new CWDS   | on development of QA  |
| Increase agency       | that can be used to   | and continuous        |
| capacity for          | assess agency         | improvement processes |
| continuous            | performance and       | and procedures.       |
| improvement of        | support continuous    |                       |
| service delivery and  | improvement of        |                       |
| achievement of        | service delivery.     |                       |
| employment outcomes   |                       |                       |
| through enhancement   | 2\. Hire two program  |                       |
| of existing QA        | analysts in FY 2008.  |                       |
| processes and         |                       |                       |
| procedures, and       | 3\. Develop key       |                       |
| development of new QA | indicators,           |                       |
| processes and         | performance measures, |                       |
| procedures.           | and reports by        |                       |
|                       | September 30, 2008.   |                       |
|                       |                       |                       |
|                       | 4\. Implement         |                       |
|                       | improvement           |                       |
|                       | recommendations       |                       |
|                       | resulting from        |                       |
|                       | analysis of           |                       |
|                       | performance data by   |                       |
|                       | September 30, 2008.   |                       |
+-----------------------+-----------------------+-----------------------+
| **4. Consumer         | 1\. Access capacity   | RSA will provide      |
| Involvement**         | building training for | technical assistance  |
|                       | CACs and/or           | to OVR and            |
| OVR and its           | alternative community | stakeholders on       |
| stakeholders will     | advocates to improve  | approaches used by    |
| work together to      | their effectiveness   | other agencies and    |
| enhance consumer      | in providing input    | constituent groups to |
| involvement in VR     | into the VR program.  | enhance involvement.  |
| program activities.   |                       |                       |
|                       | 2\. Develop and       |                       |
|                       | implement strategies  |                       |
|                       | to increase           |                       |
|                       | participation on      |                       |
|                       | public meetings.      |                       |
+-----------------------+-----------------------+-----------------------+
|                       |                       |                       |
+-----------------------+-----------------------+-----------------------+
| **Program: IL**       |                       |                       |
+-----------------------+-----------------------+-----------------------+
| **Goal**              | **Strategies**        | **Technical           |
|                       |                       | Assistance**          |
+-----------------------+-----------------------+-----------------------+
| **1. Uniform          | 1\. The PA SILC and   | RSA will facilitate   |
| Statewide Reporting   | the PCIL will         | the exchange of ideas |
| System**              | continue to work      | with other states     |
|                       | together to come up   | where such systems    |
| Develop a statewide   | with uniform          | have been developed   |
| uniform               | definitions for all   | and utilized          |
| accountability system | the types and         | successfully.         |
| for improved IL       | categories of IL      |                       |
| service provision and | services that are     |                       |
| reporting.            | provided in the       |                       |
|                       | state.                |                       |
|                       |                       |                       |
|                       | 2\. The PA SILC will  |                       |
|                       | continue to search    |                       |
|                       | for suggestions and   |                       |
|                       | ideas from other      |                       |
|                       | states on how to      |                       |
|                       | ensure that all IL    |                       |
|                       | service types and     |                       |
|                       | categories have the   |                       |
|                       | same definition       |                       |
|                       | statewide, and that   |                       |
|                       | all consumers seeking |                       |
|                       | these services have   |                       |
|                       | equal access to them  |                       |
|                       | regardless of where a |                       |
|                       | CIL is located within |                       |
|                       | the state.            |                       |
|                       |                       |                       |
|                       | 3\. OVR, the PA SILC, |                       |
|                       | and the PCIL will     |                       |
|                       | jointly create a      |                       |
|                       | statewide reporting   |                       |
|                       | system by developing  |                       |
|                       | a database that       |                       |
|                       | contains all the      |                       |
|                       | definitions for all   |                       |
|                       | IL service types and  |                       |
|                       | categories.           |                       |
|                       |                       |                       |
|                       | 4\. OVR and the PA    |                       |
|                       | SILC will organize    |                       |
|                       | training and          |                       |
|                       | technical assistance  |                       |
|                       | to enable all CIL     |                       |
|                       | staff and IL service  |                       |
|                       | providers learn how   |                       |
|                       | to operate the        |                       |
|                       | database, and thus    |                       |
|                       | improve the method of |                       |
|                       | reporting statewide.  |                       |
+-----------------------+-----------------------+-----------------------+
| **2. Stronger working | 1\. The PA SILC and   | RSA will provide      |
| relationship between  | the CILs will         | technical assistance  |
| the different IL      | continue to           | when requested by the |
| programs in the       | strengthen the        | PA SILC, the CILs,    |
| state**               | existing working      | and OVR regarding     |
|                       | relationship with the | ways to improve       |
| Improve the           | OIB program.          | collaboration,        |
| collaboration,        |                       | coordination, and     |
| cooperation, and      | 2\. OVR will work     | cooperation among all |
| coordination among    | more closely with the | the parties.          |
| the PA SILC, the      | PA SILC to ensure     |                       |
| CILs, and the OIB     | that the PA SILC      |                       |
| program.              | receives more         |                       |
|                       | feedback from older   |                       |
|                       | blind consumers on IL |                       |
|                       | service provision,    |                       |
|                       | and service areas     |                       |
|                       | needing improvement.  |                       |
|                       |                       |                       |
|                       | 3\. OVR will work     |                       |
|                       | more closely with the |                       |
|                       | PA SILC to increase   |                       |
|                       | public awareness      |                       |
|                       | about the OIB         |                       |
|                       | program, and issues   |                       |
|                       | affecting older blind |                       |
|                       | consumers.            |                       |
|                       |                       |                       |
|                       | 4\. OVR will work     |                       |
|                       | more closely with the |                       |
|                       | CILs to improve       |                       |
|                       | access to IL services |                       |
|                       | for older blind       |                       |
|                       | consumers through the |                       |
|                       | CILs in their         |                       |
|                       | communities.          |                       |
+-----------------------+-----------------------+-----------------------+
| **3. Outreach to      | 1\. The PA SILC and   | RSA will share        |
| increase public       | PCIL will identify    | techniques utilized   |
| awareness of IL       | increased outreach    | by states with        |
| services in the       | efforts, especially   | similar demographics  |
| state**               | rural outreach, as    | to address issues of  |
|                       | part of the goals and | IL service provision  |
| Improve outreach      | objectives in the new | to rural populations. |
| efforts to increase   | SPIL.                 | RSA will also         |
| public awareness,     |                       | facilitate training   |
| especially among      | 2\. All IL service    | and technical         |
| individuals in rural  | providers and         | assistance from the   |
| areas, about the      | partners in the state | Association of        |
| availability of IL    | will periodically     | Programs for Rural    |
| services.             | organize and          | Independent Living.   |
|                       | increasingly          |                       |
|                       | participate in rural  |                       |
|                       | community events as a |                       |
|                       | way of reaching out   |                       |
|                       | to individuals with   |                       |
|                       | disabilities residing |                       |
|                       | in those communities. |                       |
|                       |                       |                       |
|                       | 3\. The PA SILC, all  |                       |
|                       | IL service providers, |                       |
|                       | and partners will     |                       |
|                       | work closely with     |                       |
|                       | individual IL         |                       |
|                       | consumers and         |                       |
|                       | consumer advocacy     |                       |
|                       | groups to develop new |                       |
|                       | methods and           |                       |
|                       | approaches for        |                       |
|                       | increasing public     |                       |
|                       | awareness about       |                       |
|                       | disability issues in  |                       |
|                       | all geographic areas  |                       |
|                       | of the state.         |                       |
+-----------------------+-----------------------+-----------------------+
|                       |                       |                       |
+-----------------------+-----------------------+-----------------------+
| **Program: OIB**      |                       |                       |
+-----------------------+-----------------------+-----------------------+
| **Goal**              | **Strategies**        | **Technical           |
|                       |                       | Assistance**          |
+-----------------------+-----------------------+-----------------------+
| **1. Access to IL     | > 1\. The PA SILC and | RSA will provide      |
| services for older    | > the OIB program     | technical assistance  |
| blind consumers**     | > director will       | when requested.       |
|                       | > continue to improve |                       |
| Increase access to IL | > on their existing   |                       |
| services for older    | > working             |                       |
| blind individuals.    | > relationship.       |                       |
|                       | >                     |                       |
|                       | > 2\. OVR will        |                       |
|                       | > strengthen its      |                       |
|                       | > working             |                       |
|                       | > relationship with   |                       |
|                       | > the CILs as a way   |                       |
|                       | > of improving access |                       |
|                       | > to IL services for  |                       |
|                       | > older blind         |                       |
|                       | > consumers in a      |                       |
|                       | > timely manner.      |                       |
|                       |                       |                       |
|                       | 3\. OVR and OIB       |                       |
|                       | program officers will |                       |
|                       | provide some basic    |                       |
|                       | blindness and IL      |                       |
|                       | skills training to    |                       |
|                       | CIL staff to enable   |                       |
|                       | them meet the basic   |                       |
|                       | IL service needs of   |                       |
|                       | the older blind and   |                       |
|                       | other consumers with  |                       |
|                       | vision impairments.   |                       |
+-----------------------+-----------------------+-----------------------+

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>