Fiscal Year 2007 Monitoring Report on the Vocational Rehabilitation and
Independent Living Programs in the Territory of the U.S. Virgin Islands

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**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......\... 19

Chapter 4: INDEPENDENT LIVING PROGRAMS............. 27

cHAPTER 5: INDEPENDENT LIVING

FOR oLDER BLIND PROGRAM........................................ 31

cHAPTER 6: STATUS OF ISSUES RAISED

IN PREVIOUS REVIEWS.................................................. 33

cHAPTER 7: SUMMARY CONCLUSION............................ 35

## 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 territory of the U.S. Virgin Islands:

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

-   the State Supported Employment (SE) Services Program, established
    under Title VI, Part B;

-   the Independent Living (IL) program, 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 the U.S. Virgin Islands, the Division of Disabilities and
Rehabilitation Services (VIDDRS) is the agency that is responsible for
the administration of the four programs cited above.

RSA's review began in the fall of 2006 and ended in the summer of 2007.
During this time, RSA's VIDDRS 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 two on-site visits and held multiple discussions with
    state agency staff, SRC members, SILC members, and stakeholders to
    share information, identify promising practices and areas for
    improvement;

-   provided technical assistance;

-   worked with VIDDRS 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 performance and compliance issues;

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

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

-   made recommendations in those instances when VIDDRS and RSA did not
    agree on issues; and

-   identified potential issues for further review.

[VIDDRS' Challenges]{.underline}

The VIDDRS has significant challenges ahead in order to address the
identified developmental issues to increase the quantity and quality of
its employment outcomes; improve data usage and reporting; improve its
fiscal accountability; establish a more focused direction with CRPs to
increase productivity; identify an appropriate quality assurance and
evaluation system to ensure VIDDRS developmental milestones; and
consolidate the management team to unify efforts toward achieving the
goals outlined below.

## Introduction

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

In order to fulfill its monitoring responsibilities, RSA:

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

## 

## Scope of the Review

## 

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

-   the VR program, established under Title I;

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

-   the Independent Living (IL) program, 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 VIDDRS' progress on:]{.underline}

-   the agency's Corrective Action Plan that was established as a result
    of findings from RSA's FY 2003-4 Section 107 monitoring review;

-   the agency's Program Improvement Plan that was established as a
    result of the fact that VIDDRS did not meet performance standards
    for indicators 1.1, 1.4 and 1.5 for FY 2004; and

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

## The Territory of the U.S. Virgin Islands Administration of the VR, SE, IL, and OIB Programs

## 

VIDDRS falls under the umbrella of the Department of Human Services
(DHS) in the U.S. Virgin Islands. VIDDRS administers a combined program
that serves individuals who are blind as well as individuals with other
disabling conditions.

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

## 

## Appreciation

## 

RSA wishes to express appreciation to the representatives of the Virgin
Islands Department of Human Services (DHS), VIDDRS, the State
Rehabilitation Council, the Statewide Independent Living Council, and
the stakeholders who assisted the RSA monitoring team in the review of
VIDDRS.

## 

## Chapter I: RSA's Review Process

## Data Used During the Review

## 

RSA's review of VIDDRS 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 were available from the FY 2005 and FY
2006 data collections. Unlike other reviews that RSA conducted in FY
2007, this report cites more data from FY 2005 and than from FY 2006
because VIDDRS did not submit a significant portion of its FY 2006 data
to RSA in a timely manner.

## Review Process Activities

## 

During the review process, RSA's VIDDRS state team:

-   gathered and reviewed information regarding VIDDRS' performance;

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

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

-   provided technical assistance to VIDDRS;

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

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

-   identified potential issues for further review; and

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

## RSA's VIDDRS State Team Review Participants

## 

Members of RSA's VIDDRS state team included representatives from each of
RSA's State Monitoring and Program Improvement Division's (SMPID's) five
functional units. The RSA VIDDRS state team was led by RSA's state
liaison to VIDDRS, Fred Isbister (technical assistance unit), and the
following RSA VIDDRS team members: Carol Dobak (vocational
rehabilitation unit), Sean Barrett (independent living unit), Regina
Luster (fiscal unit), and Steve Zwillinger (data unit).

## Information Gathering

## 

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

-   conducted a series of individual teleconferences with the VIDDRS
    management team as well as stakeholders;

-   conducted four teleconferences with VIDDRS senior management;

-   held two teleconferences with stakeholders;

-   conducted two on-site monitoring visits: the first monitoring visit
    was conducted from January 12, 2007 through January 19, 2007 and the
    second monitoring visit was conducted from March 19, 2007 through
    March 23, 2007;

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

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

## Chapter 2: Vocational Rehabilitation and Supported Employment Programs

## 

## Program Organization

## 

At the time of the review, VIDDRS employed a total of 15 staff to
administer the VR and SE programs through two area offices, one on St.
Thomas and another on St. Croix. One counselor is assigned to the Island
of St. John. There were three staff vacancies in the St. Croix office.
At the time of this review, VIDDRS was implementing an Order of
Selection with no eligible individuals waiting to receive services.
Finally, the federal government has placed the government of the Virgin
Islands in receivership due to financial mismanagement. A third party
fiduciary must approve the expenditure of all federal funds, including
those made by VIDDRS.

During FY 2005, VIDDRS expended a total of \$2,661,501 under Title I of
the Act on the administration and operation of the VR program. During
this period, VIDDRS provided services to a total of 431 individuals. Of
this total, 49 individuals exited the VR program after receiving
services, and VIDDRS assisted 26 individuals to achieve employment
outcomes. Individuals achieving employment outcomes received an average
hourly wage of \$10.17 and worked an average of 34.9 hours per week.
This and other data are set forth in Table 1 which describes the
agency's performance trends from FY 2001 through FY 2005, the most
recent year for which RSA has complete data from VIDDRS.

**Table 1**

**FY 2001 - FY 2005 VIDDRS VR Program Highlights**

Table 1 - Performance Measures by Year

  ----------------- ------------- ------------- ------------- ------------- -------------
  VIRGIN ISLANDS    2001          2002          2003          2004          2005

  Total funds used  \$2,572,452   \$2,646,208   \$2,359,526   \$2,366,714   \$2,661,501

  Individuals       526           521           455           432           431
  served during                                                             
  year                                                                      

  Applicants        345           263           192           243           239

  Closed after      71            97            67            37            49
  receiving                                                                 
  services                                                                  

  Closed with       53            57            40            25            26
  employment                                                                
  outcomes                                                                  

  Employment        Data not      39            30            24            26
  outcomes without  available                                               
  supports in an                                                            
  integrated                                                                
  setting                                                                   
  ----------------- ------------- ------------- ------------- ------------- -------------

  ----------------- ------------- ------------- ------------- ------------- --------------
  Virgin Islands    2001          2002          2003          2004          2005

  Average cost per  \$4,890.59    \$5,079.09    \$5,185.77    \$5,478.50    \$6,175.18
  individual served                                                         

  Average cost per  \$48,536.83   \$46,424.70   \$58,988.15   \$94,668.56   \$102,365.42
  employment                                                                
  outcome                                                                   

  Employment        20.60         21.54         16.95         10.56         9.77
  outcomes per                                                              
  \$million spent                                                           

  Competitive       Data not      15.87         13.56         10.14         9.77
  employment        available                                               
  outcomes per                                                              
  \$million spent                                                           

  Average hourly                  \$8.73        \$7.30        \$7.42        \$10.17
  earnings for paid                                                         
  employment                                                                
  outcomes                                                                  

  Average state                   \$14.67       \$14.89       \$15.11       \$16.06
  hourly earnings                                                           

  Average hours                   0.00          0.00          0.00          34.92
  worked per week                                                           
  for paid                                                                  
  employment                                                                
  outcomes                                                                  

  Percent of                      9.28          28.36         35.14         38.78
  transition age                                                            
  served to total                                                           
  served                                                                    

  Employment rate                 44.44         52.63         69.23         42.11
  for transition                                                            
  age served                                                                

  Average time                    34.00         24.50         30.00         30.30
  between                                                                   
  application and                                                           
  closure (in                                                               
  months) for                                                               
  individuals with                                                          
  successful paid                                                           
  employment                                                                
  outcomes                                                                  

  Average number of 30.94         40.08         37.92         36.00         39.18
  individuals                                                               
  served per total                                                          
  staff                                                                     
  ----------------- ------------- ------------- ------------- ------------- --------------

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

          2001

          345
  ------- ---------------------------------------------------------------

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

          2002

          263
  ------- ---------------------------------------------------------------

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

          2003

          192
  ------- ---------------------------------------------------------------

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

          2004

          243
  ------- ---------------------------------------------------------------

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

          2005

          239
  ------- ---------------------------------------------------------------

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

           2001

           526
  -------- --------------------------------------------------------------

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

           2002

           521
  -------- --------------------------------------------------------------

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

           2003

           455
  -------- --------------------------------------------------------------

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

           2004

           432
  -------- --------------------------------------------------------------

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

           2005

           431
  -------- --------------------------------------------------------------

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

           2001

           71
  -------- --------------------------------------------------------------

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

           2002

           97
  -------- --------------------------------------------------------------

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

           2003

           67
  -------- --------------------------------------------------------------

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

           2004

           37
  -------- --------------------------------------------------------------

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

           2005

           49
  -------- --------------------------------------------------------------

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

        2001

        53
  ----- -----------------------------------------------------------------

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

        2002

        57
  ----- -----------------------------------------------------------------

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

        2003

        40
  ----- -----------------------------------------------------------------

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

        2004

        25
  ----- -----------------------------------------------------------------

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

        2005

        26
  ----- -----------------------------------------------------------------

####### VIDDRS receives an annual allotment of approximately \$37,125 under Title VI, part B of the Act, which represents 35 percent of the agency's total expenditures for SE services, with the remaining 65 percent provided by VR program funds. VIDDRS enters into contractual arrangements with two community rehabilitation programs in the territory, Work Able, Inc. and the Harvest, to provide a full range of SE services to the agency's consumers. Once individuals have achieved stable employment, extended services are provided by the Harvest or by the employers through "natural supports." 

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

## 

RSA provided technical assistance to VIDDRS in a number of VR program
areas during the review process. RSA provided information on:

-   the agency's case management system;

-   use of RSA's Management Information System;

-   the content of the VR state plan and supplement for SE services, as
    required by Sections 101(a) and 625(a) of the Act;

-   the appointment and composition requirements for the SRC, resulting
    in the governor filling all vacant membership positions prior to the
    issuance of this report; and

-   the provisions of the Act and regulations governing the
    implementation of an order of selection, based on which VIDDRS
    determined to no longer implement an order.

## VR and SE Issues Identified by VIDDRS and Stakeholders during the Review Process

## 

During the review process, RSA solicited input from VIDDRS and
stakeholders about VR and SE performance and compliance issues. The
following issues were identified:

-   VIDDRS did not have a legally constituted SRC that had received
    gubernatorial appointment;

-   the Virgin Islands has a limited number of community rehabilitation
    programs;

-   the Virgin Islands has a general lack of medical, training and
    educational resources;

-   the cost of evaluations and general services are significantly
    higher than mainland programs because participants who require
    services or training not available on the Islands are transported to
    the mainland for services;

-   staff turnover has been ongoing and staff vacancies persist due to
    the Virgin Islands State Personnel Department's delay in filling
    positions;

-   Order of Selection (OOS) had not been implemented consistent with
    federal regulations;

-   VIDDRS has had a significant decrease in the number of individuals
    served by the agency over the past several years;

-   VIDDRS lacked clear performance expectations for Community
    Rehabilitation Programs (CRPs); and

-   VIDDRS' cost per rehabilitation has escalated as the FY 2005 data
    indicated. It cost VIDDRS \$102,000 per individual rehabilitated and
    the current data for FY 2007 indicate the agency's cost per
    rehabilitated individual will greatly increase unless VIDDRS makes
    significant progress in the current fiscal year.

Following compilation and discussion with VIDDRS about the issues, RSA
worked with VIDDRS 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 VIDDRS agreed on the following performance goals and strategies
to achieve those goals, and technical assistance that RSA will provide
to assist VIDDRS to achieve each goal. VIDDRS will consider including
these goals and strategies in its FY 2009 state plan and if they are
included, the agency will report progress on achieving these goals in
its FY 2011 annual state plan submission.

[1. Number and Quality of Successful Outcomes]{.underline}

##  

Issue: As reflected in Table 1 above, VIDDRS experienced a significant
decline in its performance from FY 2001 through FY 2005. For example,
the number of individuals served by the agency decreased from 526 in FY
2001 to 431 in FY 2005. The agency assisted 53 individuals to achieve
employment outcomes in FY 2001, but only 26 individuals achieved
employment outcomes in FY 2005, a decrease of approximately 50 percent.
At the same time, the agency's costs per employment outcome were
increasing, rising to a high in FY 2005 of \$102,365. In addition, the
VIDDRS management team expressed its concern regarding the agency's lack
of higher level employment opportunities for program participants.

Based on a review of this and other performance data, VIDDRS and RSA
agreed to the following goal to address the need for improved
performance on behalf of individuals with disabilities.

Goal: VIDDRS will increase the number and quality of employment outcomes
over the next two years: goal of 39 successful outcomes in FY 2008 and
goal of 52 successful outcomes in FY 2009.

Strategies: To achieve this goal, VIDDRS will implement the strategies
listed below:

-   conduct caseload analyses to determine the number of new
    applications VIDDRS should receive to maintain active, viable case
    movement;

-   conduct outreach efforts to increase client population and establish
    office targets for new applications;

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

-   train field staff on how to build and manage full caseloads;

-   establish appropriate linkages with the employer community, as well
    as placement goals for each counselor;

-   train staff on methods of job placements;

-   implement a quality assurance and evaluation program focused on the
    quantity and quality of outcomes;

-   develop a contract-based CRP system focused on increases in the
    quality and quantity of outcomes; and

-   appoint a project manager to work with RSA on this goal.

Method of Evaluation: Through quarterly teleconferences and written
reports, VIDDRS and RSA will use the following measures to assess the
agency's progress toward achieving the goal: VIDDRS will be successful
if it doubles the number of employment outcomes over the next three
years using the FY 2006 baseline of 26 (targets: FY 2007 - 33; FY 2008 -
39; FY 2009 - 52.)

Technical Assistance: RSA will identify and/or provide the technical
assistance listed below to assist VIDDRS to achieve the goal:

-   provide quarterly TA through teleconferences on issues identified by
    VIDDRS as the strategies are implemented;

-   provide consultation on the development of a quality assurance and
    evaluation system and provide TA from other VR agencies, as
    appropriate;

-   arrange for TA from other VR agencies that have been successful with
    contract-based CRP systems; and

-   work with the RCEP to secure training for counselors on job
    development and placement, including the conduct of outreach with
    employers.

###### 2. Participation of Consumers in the VR Program

###### 

Issue: The SRC was established under Section 105 of the Act to provide a
vehicle through which individuals with disabilities can work in
partnership with the state agencies to improve the VR program. To this
end, the Act specifies a number of functions that SRC members are
required to perform, including jointly developing and agreeing to agency
goals and priorities, providing input on the agency's state plan,
providing recommendations on the development and amendment of agency
policies on the provision of VR services and evaluating the performance
of the program. The VIDDRS management team stated that consumer
involvement was minimal. The agency has had no focus group meetings with
its consumers in the recent past and the SRC essentially was not
meeting.

As stated above, the Governor of the Virgin Islands recently filled
long-standing vacancies on the SRC for the territory. To assist the
newly formed Council to perform its responsibilities in an effective and
independent manner, VIDDRS and RSA have agreed to the following goal.

Goal: To improve the participation of consumers in the VR program,
VIDDRS will support the efforts of SRC members to carry out their
mandated functions in an effective and independent manner.

Strategies: VIDDRS will employ the following strategies to achieve the
goal:

-   assign a staff person to work with the newly-formed SRC;

-   assist the SRC to hold quarterly meetings and ensure that it has
    necessary supports to function; and

-   sponsor annual joint consumer information workshops.

Method of Evaluation: To determine the extent to which the SRC is
functioning in an effective and independent manner, VIDDRS and RSA will
review the SRC's annual report for FY 2008 and for each year thereafter.
The SRC is required to submit this report to RSA within 90 days from the
end of the fiscal year covered by the report.

Technical Assistance: To assist VIDDRS and the SRC to achieve the goal,
RSA will provide the technical assistance described below:

-   train the newly formed SRC in its role and functions;

-   conduct teleconferences with the SRC to address topics of specific
    interest to the members;

-   provide quarterly teleconference hook-ups with the RSA national
    meeting of SRC participants;

-   provide web-based training for SRC members;

-   arrange for TA from the RCEP to train on strategies for the
    development of effective SRCs; and

-   provide TA from other resources as appropriate.

###### 

###### 3. Improve the VIDDRS management practices through improved MIS data usage.

###### 

Issue: RSA observed that the supervisors within VIDDRS seldom meet as a
management team and the director works individually with each
supervisor. Through discussions with the director, RSA advised that
VIDDRS would benefit if she developed a management team approach with
her supervisors and shared the overall responsibility for the
administration of the program with them. Specifically, RSA recommended
that the management team use the MIS systems as a management tool to
strengthen the agency's operation.

Goal: To improve the VIDDRS management team's use of the MIS (collection
and use of data).

Strategies: VIDDRS will employ the following strategies to achieve the
goal:

-   implement a monthly management meeting to review and discuss data
    verification of the agency's RSA 911 case record data for FY 2004,
    FY 2005, and FY 2006;

-   implement a monthly management meeting to review and discuss data
    verification of the agency's RSA 911 case record data for FY 2004,
    FY 2005, and FY 2006;

-   train staff on data analysis;

-   analyze trends in data to establish appropriate targets for program
    improvement;

-   establish appropriate targets for caseloads through data analysis;

-   resubmit the last three years of RSA-113 data for review to RSA as
    this data was misreported; and

-   appoint a project manager to work with RSA on this goal.

Method of Evaluation: RSA will evaluate VIDDRS' submission of reports to
RSA to assess the agency's abilities in the development and use of this
data.

Technical Assistance:

-   RSA will hold quarterly teleconferences with VIDDRS management team
    to review their collection and use of data.

-   RSA will secure TA from high-performing VR agencies or other sources
    to assist VIDDRS in its use of data.

###### 

###### 4. Performance of Service Providers

## 

Issue: The RSA representatives met with a number of individuals within
VIDDRS regarding the identified issue of community rehabilitation
program (CRP) usage in the state. The senior leadership of VIDDRS
advised RSA that VIDDRS primarily works with two community
rehabilitation programs and has minimal involvement with the Projects
with Industry (PWI) program that serves the Islands. The RSA
representatives met with all three CRP program providers to discuss
their programs. The Harvest program serves only the St. Croix office.
The Work Able, Inc. serves both islands, but has had significant losses
in staff and was not fully operational at the time of this review. Work
Able, Inc. and Harvest are provided a fee that totals \$1,384 per month
per client. VIDDRS had not implemented outcome standards with the CRPs
and many individuals spend significant time in the CRPs with no
successful outcomes. RSA asked the CRP directors and the VIDDRS
management team how many VIDDRS clients were enrolled in the CRPs, what
was the average length of stay at each CRP, and how many successful
outcomes had been achieved. VIDDRS and the CRP directors were unable to
provide this information. In reviewing the high CRP costs and low
productivity in terms of successful CRP outcomes, VIDDRS should
establish standards of performance with the currently funded CRPs. The
RSA representatives held focus group meetings with representatives of
the CRPs to discuss a performance-based contract system. The
participants were receptive to this change.

After these CRP meetings, the RSA representatives suggested to the
VIDDRS management team that an investment in establishing a more
accountable, timely and outcome-based CRP contract system would be an
appropriate developmental goal for VIDDRS over the next few years. The
VIDDRS management team supported this goal. RSA suggested that VIDDRS:

-   institute an annual report card to evaluate CRP performances and
    establish future performance goals based on each CRP's performance;

-   consider that financial rewards be more heavily weighted toward
    successful outcomes rather than job preparation and placement
    efforts;

-   consider establishing a performance expectation that VIDDRS
    counselors collaborate more closely with CRP staff regarding ongoing
    client services in order to provide more seamless services to
    individuals and that VIDDRS require VR counselors to meet with CRP
    staff on an established basis in order to process each client's
    progress, problems and future challenges;

-   establish a quality assurance and evaluation system and conduct
    annual site visits to all CRPs throughout the territory to evaluate
    each CRP's reports as well as the quality of services; and

-   establish a working relationship with the PWI program serving the
    islands in order to provide services to less significantly disabled
    individuals.

Goal: VIDDRS will develop a CRP business model that meets the needs of
VIDDRS and enhances CRP effectiveness.

Strategies: VIDDRS will employ the following strategies to achieve the
goal:

-   analyze CRP past performance and identify CRP data needed and make
    available to VIDDRS senior managers and to CRPs;

-   negotiate contract-based services with CRPs and issue yearly "report
    cards" to CRPs to establish appropriate targets for improvements in
    quality and quantity of outcomes;

-   identify content elements to be included in CRP report cards and the
    associated grading system (criteria for excellent A, good B, fair C,
    etc.);

-   conduct analysis regarding the length of time individuals receive
    services from CRPs prior to successful outcome; and

-   appoint a project manager to work with RSA on this goal.

Method of Evaluation: Review data outcomes on a quarterly basis to track
progress toward improved performance by CRPs.

Technical Assistance:

-   RSA will provide quarterly reviews of the agency's progress in this
    area and provide TA to the VIDDRS management team.

-   RSA will provide TA to VIDDRS in the areas of identifying relevant
    CRP data and in defining the components to be included in the CRP
    report cards.

-   RSA will provide TA to CRPs to assist the CRPs to improve the
    quantity and quality of outcomes.

-   as appropriate, RSA will identify VR agencies that use this business
    contract model to assist VIDDRS improve CRP performance.

-   RSA will solicit training from the RCEP on contract-based models if
    appropriate.

-   RSA will arrange for TA from VR agencies and/or other resources as
    appropriate.

[5. Quality Assurance System]{.underline}

Issue: During the extensive work that was conducted by RSA with the
VIDDRS senior managers, it was evident that VIDDRS did not have a viable
quality assurance or evaluation system in place. RSA noted during one of
the on site visits that the VIDDRS management team was unaware of how
many individuals the agency had successfully rehabilitated at that point
in the year and had not established over agency goals for the numbers of
individuals to be served, successfully placed, etc. RSA asked to review
the agency's methods for establishing its goals and evaluating its
accomplishments. However, it was clear that such a system had not been
established. RSA discussed this with the VIDDRS leadership and it was
agreed that this would be a worthwhile goal for the future development
of the VIDDRS management team.

Goal: VIDDRS will develop a quality assurance and evaluation system to
improve the overall operation of VIDDRS.

Strategies: VIDDRS will employ the following strategies to achieve the
goal:

-   develop a quality assurance and evaluation system that is focused on
    the unique needs of VIDDRS;

-   train field staff on the intent of this system;

-   identify appropriate targets for field offices;

-   DHS designate an evaluator to work with VIDDRS regarding the quality
    assurance and evaluation system; and

-   appoint a project manager to work with RSA on this goal.

Method of Evaluation:

-   VIDDRS will work with RSA to evaluate progress on a quarterly basis.

-   VIDDRS will incorporate the use of the RSA case monitoring tool and
    conduct a thorough analysis annually of each counselor's case
    documentation, timeliness of services and appropriateness of
    services.

Technical Assistance:

-   RSA will hold quarterly teleconferences with VIDDRS and DHS to
    provide TA on its implementation of this system.

-   As appropriate, RSA will identify high-performing VR agencies that
    will be enlisted to consult with VIDDRS on the development and
    implementation of the system.

-   If appropriate, RSA will work with the RCEP to assist VIDDRS refine
    and improve its system.

## VR and SE Program Recommendations

## 

RSA recommends that VIDDRS establish goals and strategies to manage the
case flow within the agency and to establish a standard for quality of
outcomes in order to improve these basic components to the basic
operation of the VR program:

-   RSA should arrange for TA from VR agencies and/or other resources as
    appropriate to assist the VIDDRS management team to establish a
    system to track the monthly flow of cases and establish a system to
    monitor progress toward yearly goals.

-   VIDDRS should evaluate the quality of outcomes on a quarterly basis
    to assure the agency is improving its performance in terms of
    increased salaries and benefits.

## Chapter 3: Fiscal Review of the VR Program

RSA reviewed VIDDRS' 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 are taken from the fourth quarter of the respective fiscal
year's SF-269 report. The maintenance of effort (MOE) requirement data
is 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 is taken from the RSA-2.

**Table 2**

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

  ------------------------------- ----------- ----------- ----------- ----------- -----------
  Virgin Islands (C)                                                              

  Fiscal Year                     2002        2003        2004        2005        2006

  Grant Amount                    1,976,916   1,849,919   1,889,392   1,861,075   1,935,920

  Required Match                  535,048     500,677     511,360     503,696     523,953

  Federal Expenditures            1,942,573   1,780,421   1,670,564   1,812,858   1,817,007

  Actual Match                    604,943     530,665     607,690     584,074     650,867

  Over (Under) Match              69,895      29,988      96,330      80,378      126,914

  Carryover                       34,343      69,498      218,828     48,217      118,913

  Program Income                  0           0           0           0           0

  Maintenance of Effort (MOE)     307,553     415,409     604,943     530,665     607,690

                                                                                   

  Administrative Costs            298,515     287,191     286,078     241,018     Not
                                                                                  Available

  Total Expenditures              2,646,208   2,359,526   2,366,714   2,661,501   Not
                                                                                  Available

  Percent Admin Costs to Total    11.28%      12.17%      12.09%      9.06%       Not
  Expenditures                                                                    Available
  ------------------------------- ----------- ----------- ----------- ----------- -----------

## Explanations Applicable to the Fiscal Profile Table

## 

[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
reallottment process, or additional grant funds received through the
reallottment 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 or each grant year. 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:

-   conducted 1½ days of intensive financial management training with
    financial staff (including staff of the 3rd party fiduciary agent).
    Topics covered include: the VR program formula, the allotment
    process and program cost of living increases, match/overmatch,
    maintenance of effort, carryover, grant period, liquidation of
    obligations, grant closeout, prior approval requirements, program
    income, allowable costs, guidance and reference materials, financial
    reports, reallottment and establishment authority;

-   conducted ½ day of financial training for program managers and
    supervisors (including a representative from the Designated State
    Agency). Topics covered included: the VR Program formula and
    allotment trends for each VR and Independent Living program, match,
    maintenance of effort, carryover, reallottment, and financial
    reporting requirements;

-   met with staff of the 3rd party fiduciary agency (Alvarez and
    Marsal) to discuss the implications of the high-risk designation and
    issues related specifically with VIDDRS' financial performance since
    the onset of this arrangement;

-   worked with the 3rd party fiduciary agency to determine the
    allowability of questionable program costs that had not been
    approved by them for payment. (after review, authorized payment of
    these invoices);

-   discussed strategies related to managing the maintenance of effort
    requirement (leveling MOE);

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

-   reviewed administrative costs with national and comparable agency
    data provided to analyze these costs;

-   analyzed the sufficiency of matching resources for FYs 2007 and 2008
    and determined the level of additional funds that can be matched if
    requested and received through the reallottment process;

-   discussed the fact that Financial Status Reports (SF-269s) not
    entered into RSA's Management Information System (MIS) for the VR
    Programs FYs 2002 -- 2007; and

-   discussed with program managers all current and pending contractual
    arrangements.

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

## 

###### VR Program Financial Accountability

###### 

Issue: VIDDRS' Financial Status Reports (SF-269s) and Annual Vocational
Rehabilitation Program/Cost Reports (RSA-2s) have longstanding issues
related to the accuracy and timely submission of both reports. Tables 3
and 4 below provide information on the due dates, submission dates and
missing reports. As a result of VIDDRS' untimely submission of required
reports, the current knowledge level of staff recently assigned the
responsibility for report preparation, and RSA's inability to verify
reported information while onsite, the accuracy of reported information
is also questioned.

**Table 3**

**SF-269 Due Date and Submission Date Information**

+----------+---------------+---------------+---------------+-----------+
| ######   |               |               |               |           |
| ### VIDD |               |               |               |           |
| RS -- Fi |               |               |               |           |
| nancial  |               |               |               |           |
| Status R |               |               |               |           |
| eports ( |               |               |               |           |
| SF-269)  |               |               |               |           |
+----------+---------------+---------------+---------------+-----------+
| #        |               |               |               |           |
| ######## |               |               |               |           |
|  FY 2003 |               |               |               |           |
+----------+---------------+---------------+---------------+-----------+
| Quarter  | Quarter       | Report Due    | Report        | Untimely  |
|          | Ending Date   | Date          | Submission    |           |
|          |               |               | Date          | \(X\)     |
+----------+---------------+---------------+---------------+-----------+
| 1        | 12/31/02      | 01/30/03      | 02/16/03      | X         |
+----------+---------------+---------------+---------------+-----------+
| 2        | 03/31/03      | 04/30/03      | 05/13/03      | X         |
+----------+---------------+---------------+---------------+-----------+
| 3        | 06/30/03      | 07/30/03      | 08/20/03      | X         |
+----------+---------------+---------------+---------------+-----------+
| 4        | 09/30/03      | 12/29/03      | 11/18/03      |           |
+----------+---------------+---------------+---------------+-----------+
| 5        | 12/31/03      | 01/30/04      | 02/24/04      | X         |
+----------+---------------+---------------+---------------+-----------+
| 6        | 03/31/04      | 04/30/04      | 05/17/04      | X         |
+----------+---------------+---------------+---------------+-----------+
| 7        | 06/30/04      | 07/30/04      | 08/11/04      | X         |
+----------+---------------+---------------+---------------+-----------+
| 8        | 09/30/04      | 12/29/04      | 11/07/04      |           |
+----------+---------------+---------------+---------------+-----------+
| C        |               |               |               |           |
| omments: |               |               |               |           |
| Six of   |               |               |               |           |
| eight    |               |               |               |           |
| q        |               |               |               |           |
| uarterly |               |               |               |           |
| reports  |               |               |               |           |
| were not |               |               |               |           |
| timely   |               |               |               |           |
| su       |               |               |               |           |
| bmitted, |               |               |               |           |
| but      |               |               |               |           |
| within   |               |               |               |           |
| an       |               |               |               |           |
| ac       |               |               |               |           |
| ceptable |               |               |               |           |
| t        |               |               |               |           |
| olerance |               |               |               |           |
| level    |               |               |               |           |
| (less    |               |               |               |           |
| than 30  |               |               |               |           |
| days).   |               |               |               |           |
| The      |               |               |               |           |
| final    |               |               |               |           |
| report   |               |               |               |           |
| for FY   |               |               |               |           |
| 2003 was |               |               |               |           |
| timely   |               |               |               |           |
| su       |               |               |               |           |
| bmitted. |               |               |               |           |
+----------+---------------+---------------+---------------+-----------+
| #        |               |               |               |           |
| ######## |               |               |               |           |
|  FY 2004 |               |               |               |           |
+----------+---------------+---------------+---------------+-----------+
| 1        | 12/31/03      | 01/30/04      | 05/17/04      | X         |
+----------+---------------+---------------+---------------+-----------+
| 2        | 03/31/04      | 04/30/04      | 05/17/04      | X         |
+----------+---------------+---------------+---------------+-----------+
| 3        | 06/30/04      | 07/30/04      | 08/11/04      | X         |
+----------+---------------+---------------+---------------+-----------+
| 4        | 09/30/04      | 12/29/04      | 11/30/04      |           |
+----------+---------------+---------------+---------------+-----------+
| 5        | 12/31/04      | 01/30/05      | 02/16/05      | X         |
+----------+---------------+---------------+---------------+-----------+
| 6        | 03/31/05      | 04/30/05      | 06/14/05      | X         |
+----------+---------------+---------------+---------------+-----------+
| 7        | 06/30/05      | 07/30/05      | 08/17/05      | X         |
+----------+---------------+---------------+---------------+-----------+
| 8        | 09/30/05      | 12/29/05      | 11/30/05      |           |
+----------+---------------+---------------+---------------+-----------+
| 9        | 12/31/05      | 01/30/06      | 03/14/06      | X         |
+----------+---------------+---------------+---------------+-----------+
| C        |               |               |               |           |
| omments: |               |               |               |           |
| Seven of |               |               |               |           |
| nine     |               |               |               |           |
| required |               |               |               |           |
| reports  |               |               |               |           |
| were not |               |               |               |           |
| timely   |               |               |               |           |
| su       |               |               |               |           |
| bmitted. |               |               |               |           |
| Of the   |               |               |               |           |
| seven    |               |               |               |           |
| late     |               |               |               |           |
| reports, |               |               |               |           |
| three    |               |               |               |           |
| exceeded |               |               |               |           |
| 30 days. |               |               |               |           |
| The      |               |               |               |           |
| final    |               |               |               |           |
| report   |               |               |               |           |
| was 42   |               |               |               |           |
| days     |               |               |               |           |
| late.    |               |               |               |           |
+----------+---------------+---------------+---------------+-----------+
| #        |               |               |               |           |
| ######## |               |               |               |           |
|  FY 2005 |               |               |               |           |
+----------+---------------+---------------+---------------+-----------+
| 1        | 12/31/04      | 01/30/05      | 02/16/05      | X         |
+----------+---------------+---------------+---------------+-----------+
| 2        | 03/31/05      | 04/30/05      | 06/14/05      | X         |
+----------+---------------+---------------+---------------+-----------+
| 3        | 06/30/05      | 07/30/05      | 08/16/05      | X         |
+----------+---------------+---------------+---------------+-----------+
| 4        | 09/30/05      | 12/29/05      | 11/30/05      |           |
+----------+---------------+---------------+---------------+-----------+
| 5        | 12/31/05      | 01/30/06      | 03/30/06      | X         |
+----------+---------------+---------------+---------------+-----------+
| C        |               |               |               |           |
| omments: |               |               |               |           |
| Four of  |               |               |               |           |
| the five |               |               |               |           |
| required |               |               |               |           |
| reports  |               |               |               |           |
| were not |               |               |               |           |
| timely   |               |               |               |           |
| su       |               |               |               |           |
| bmitted, |               |               |               |           |
| with the |               |               |               |           |
| 5^th^    |               |               |               |           |
| quarter  |               |               |               |           |
| report   |               |               |               |           |
| being 60 |               |               |               |           |
| days     |               |               |               |           |
| late.    |               |               |               |           |
| *None*   |               |               |               |           |
| of the   |               |               |               |           |
| other    |               |               |               |           |
| q        |               |               |               |           |
| uarterly |               |               |               |           |
| reports  |               |               |               |           |
| (6^th^,  |               |               |               |           |
| 7^th^ or |               |               |               |           |
| 8^th^),  |               |               |               |           |
| i        |               |               |               |           |
| ncluding |               |               |               |           |
| the      |               |               |               |           |
| final    |               |               |               |           |
| report   |               |               |               |           |
| required |               |               |               |           |
| to       |               |               |               |           |
| closeout |               |               |               |           |
| this FY, |               |               |               |           |
| have     |               |               |               |           |
| been     |               |               |               |           |
| su       |               |               |               |           |
| bmitted. |               |               |               |           |
+----------+---------------+---------------+---------------+-----------+
| #        |               |               |               |           |
| ######## |               |               |               |           |
|  FY 2006 |               |               |               |           |
+----------+---------------+---------------+---------------+-----------+
| 1        | 12/31/05      | 01/30/06      | 10/06/06      | X         |
+----------+---------------+---------------+---------------+-----------+
| 2        | 03/31/06      | 04/30/06      | 10/06/06      | X         |
+----------+---------------+---------------+---------------+-----------+
| 3        | 06/30/06      | 07/30/06      | 10/06/06      | X         |
+----------+---------------+---------------+---------------+-----------+
| 4        | 09/30/06      | 12/29/06      | 12/11/06      |           |
+----------+---------------+---------------+---------------+-----------+
| C        |               |               |               |           |
| omments: |               |               |               |           |
| Three of |               |               |               |           |
| the four |               |               |               |           |
| q        |               |               |               |           |
| uarterly |               |               |               |           |
| reports  |               |               |               |           |
| s        |               |               |               |           |
| ubmitted |               |               |               |           |
| for FY   |               |               |               |           |
| 2006     |               |               |               |           |
| were not |               |               |               |           |
| timely   |               |               |               |           |
| su       |               |               |               |           |
| bmitted. |               |               |               |           |
| The      |               |               |               |           |
| 1^st^    |               |               |               |           |
| quarter  |               |               |               |           |
| report   |               |               |               |           |
| was over |               |               |               |           |
| eight    |               |               |               |           |
| months   |               |               |               |           |
| late.    |               |               |               |           |
| The      |               |               |               |           |
| 2^nd^    |               |               |               |           |
| quarter  |               |               |               |           |
| report   |               |               |               |           |
| was over |               |               |               |           |
| five     |               |               |               |           |
| months   |               |               |               |           |
| late.    |               |               |               |           |
| The      |               |               |               |           |
| 3^rd^    |               |               |               |           |
| quarter  |               |               |               |           |
| report   |               |               |               |           |
| was over |               |               |               |           |
| two      |               |               |               |           |
| months   |               |               |               |           |
| late. No |               |               |               |           |
| other    |               |               |               |           |
| q        |               |               |               |           |
| uarterly |               |               |               |           |
| reports  |               |               |               |           |
| (5^th^,  |               |               |               |           |
| 6^th^,   |               |               |               |           |
| 7^th^,   |               |               |               |           |
| or       |               |               |               |           |
| 8^th)^   |               |               |               |           |
| have     |               |               |               |           |
| been     |               |               |               |           |
| s        |               |               |               |           |
| ubmitted |               |               |               |           |
| for FY   |               |               |               |           |
| 2006.    |               |               |               |           |
+----------+---------------+---------------+---------------+-----------+
| #        |               |               |               |           |
| ######## |               |               |               |           |
|  FY 2007 |               |               |               |           |
+----------+---------------+---------------+---------------+-----------+
| No       |               |               |               |           |
| q        |               |               |               |           |
| uarterly |               |               |               |           |
| F        |               |               |               |           |
| inancial |               |               |               |           |
| Status   |               |               |               |           |
| Reports  |               |               |               |           |
| have     |               |               |               |           |
| been     |               |               |               |           |
| s        |               |               |               |           |
| ubmitted |               |               |               |           |
| for FY   |               |               |               |           |
| 2007. As |               |               |               |           |
| of       |               |               |               |           |
| August   |               |               |               |           |
| 10,      |               |               |               |           |
| 2007,    |               |               |               |           |
| VIDDRS   |               |               |               |           |
| was      |               |               |               |           |
| required |               |               |               |           |
| to       |               |               |               |           |
| submit   |               |               |               |           |
| reports  |               |               |               |           |
| for the  |               |               |               |           |
| 1^st^,   |               |               |               |           |
| 2^nd^    |               |               |               |           |
| and      |               |               |               |           |
| 3^rd^    |               |               |               |           |
| quarters |               |               |               |           |
| for this |               |               |               |           |
| FY.      |               |               |               |           |
+----------+---------------+---------------+---------------+-----------+

######### Table 4

**RSA-2 Report Due Date and Submission Date Information**

+------------+---------------+-------------------+-------------------+
| **VIDDRS** |               |                   |                   |
|            |               |                   |                   |
| **Annual   |               |                   |                   |
| Vocational |               |                   |                   |
| Reha       |               |                   |                   |
| bilitation |               |                   |                   |
| Pr         |               |                   |                   |
| ogram/Cost |               |                   |                   |
| Report     |               |                   |                   |
| (RSA-2)**  |               |                   |                   |
+------------+---------------+-------------------+-------------------+
| FY         | Due Date      | Date Submitted    | Untimely (X)      |
+------------+---------------+-------------------+-------------------+
| 2002       | 01/31/03      | 01/08/04          | X                 |
+------------+---------------+-------------------+-------------------+
| 2003       | 01/31/04      | 09/01/04          | X                 |
+------------+---------------+-------------------+-------------------+
| 2004       | 01/31/05      | 05/02/05          | X                 |
+------------+---------------+-------------------+-------------------+
| 2005       | 01/31/06      | 04/18/06          | X                 |
+------------+---------------+-------------------+-------------------+
| 2006       | 12/31/06      |                   | X                 |
+------------+---------------+-------------------+-------------------+
| Comments:  |               |                   |                   |
| The RSA-2  |               |                   |                   |
| reports    |               |                   |                   |
| for FYs    |               |                   |                   |
| 2002 --    |               |                   |                   |
| 2005 range |               |                   |                   |
| from over  |               |                   |                   |
| 2 months   |               |                   |                   |
| to one     |               |                   |                   |
| year late. |               |                   |                   |
| At the     |               |                   |                   |
| time of    |               |                   |                   |
| RSA's      |               |                   |                   |
| onsite     |               |                   |                   |
| monitoring |               |                   |                   |
| review in  |               |                   |                   |
| March      |               |                   |                   |
| 2007, a    |               |                   |                   |
| draft      |               |                   |                   |
| report for |               |                   |                   |
| FY 2007    |               |                   |                   |
| had been   |               |                   |                   |
| prepared   |               |                   |                   |
| and was    |               |                   |                   |
| available  |               |                   |                   |
| for review |               |                   |                   |
| (almost    |               |                   |                   |
| three      |               |                   |                   |
| months     |               |                   |                   |
| after the  |               |                   |                   |
| due date). |               |                   |                   |
| VIDDRS     |               |                   |                   |
| staff      |               |                   |                   |
| preparing  |               |                   |                   |
| the report |               |                   |                   |
| had        |               |                   |                   |
| recently   |               |                   |                   |
| been given |               |                   |                   |
| this       |               |                   |                   |
| assignment |               |                   |                   |
| and could  |               |                   |                   |
| not fully  |               |                   |                   |
| explain or |               |                   |                   |
| provide    |               |                   |                   |
| supporting |               |                   |                   |
| doc        |               |                   |                   |
| umentation |               |                   |                   |
| for        |               |                   |                   |
| ex         |               |                   |                   |
| penditures |               |                   |                   |
| on the     |               |                   |                   |
| draft      |               |                   |                   |
| report. As |               |                   |                   |
| a result,  |               |                   |                   |
| RSA        |               |                   |                   |
| instructed |               |                   |                   |
| VIDDRS not |               |                   |                   |
| to submit  |               |                   |                   |
| the RSA-2  |               |                   |                   |
| report for |               |                   |                   |
| FY 2006    |               |                   |                   |
| until      |               |                   |                   |
| training   |               |                   |                   |
| was        |               |                   |                   |
| provided   |               |                   |                   |
| to agency  |               |                   |                   |
| staff      |               |                   |                   |
| related to |               |                   |                   |
| the        |               |                   |                   |
| p          |               |                   |                   |
| reparation |               |                   |                   |
| of this    |               |                   |                   |
| report.    |               |                   |                   |
+------------+---------------+-------------------+-------------------+

Goal: Ensure the accuracy and timely submission of SF-269 and RSA-2
reports.

Strategies: VIDDRS will employ the following strategies to achieve the
goal:

-   assign responsibilities for the preparation, review and approval of
    all required SF-269s and the RSA-2 report;

-   complete a listing of all outstanding reports;

-   identify and remove impediments to the timely and accurate
    submission of required reports;

-   submit missing reports, along with any supporting documentation
    requested by RSA necessary to review the accuracy of reported
    information; and

-   establish internal policies and procedures to ensure the accurate
    and timely submission of required reports.

Technical Assistance: RSA will provide the technical assistance required
throughout this process to ensure that the goal is met.

###### Contractual Arrangements

###### 

Issue: VIDDRS has exhibited limited program and financial accountability
in existing and pending contractual arrangements. RSA determined that
contracts do not have measurable deliverables, and, in one instance, the
contractor was authorized to begin work had almost completed the
project, and still the contractual document had not been signed by the
appropriate VI DHS officials. Loose procurement controls put contractors
at risk of not being paid with federal grant funds. Further, there was
no system in place to monitor and evaluate the work done under
contractual arrangements.

Goal: Strengthen financial and program accountability under contractual
arrangements.

Strategies: VIDDRS will employ the following strategies to achieve the
goal:

-   submit copies of policies and procedures to RSA for review and
    discussion;

-   RSA will review with staff the current policies/procedures
    applicable to entering into contractual arrangements in the Virgin
    Islands;

-   submit a copy of all FYs 2006 and 2007 contractual arrangements to
    RSA for evaluation (upon completion, RSA will discuss with VIDDRS
    the weaknesses of the existing contractual arrangements and any
    immediate steps that need to be taken to strengthen accountability
    under existing contracts);

-   develop policies and procedures to ensure that future contracts have
    measurable deliverables and meet the requirements of OMB Circular
    A-87, "Cost Principles for State, Local and Indian Tribal
    Governments"; and

-   develop policies and procedures (including assigning
    responsibilities) to ensure that contractor performance is monitored
    and evaluated throughout the contractual arrangement.

Technical Assistance: RSA will provide the technical assistance required
throughout this process to ensure that the goal is met.

###### Financial Management

Issue:  Most of the VIDDRS management team is relatively new in their
positions and are unfamiliar with the financial management requirements
of the VR Program.   As part of their responsibilities, VR program
managers must ensure that the financial requirements of this program are
met, specifically as they relate to match, MOE, carryover, cooperative
arrangements, use of the establishment authority, submission of accurate
and timely required federal reports, and administering the program in an
efficient and effective manner.  VIDDRS' limited knowledge of these
requirements and the lack of controls in place to ensure compliance pose
serious financial risks to the agency.

Goal: Improve the overall financial management of the VR program.

Strategies: VIDDRS will employ the following strategies to achieve the
goal:

-   continue training related to specific financial requirements of the
    VR program, i.e., match, maintenance of effort, carryover, and
    recording and liquidation of obligations;

-   discuss strategies for compliance with fiscal requirements;

-   determine additional training required for financial staff and
    appropriate providers;

-   analyze the cost efficiency of program and administrative costs; and

-   determine the type and frequency of financial/program information
    that need to be disseminated to program managers and provide
    training on how this information should be utilized to improve
    overall VR program efficiency and effectiveness.

Technical Assistance: RSA will provide the technical assistance required
throughout this process (including aiding with the identification of
external training resources) to ensure that the goal is met.

########  Chapter 4: IL Program

VIDDRS receives \$27,953 in part B funding that supports SILC
activities, one part-time SILC support staff, and one part-time staff
liaison from VIDDRS.

The table below identifies funding sources and amounts for the VI IL
programs:

> **Table 5**

Sources and Amounts of IL Funding (FY 2006)

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

  Part B Funds                           27,953

  Older Blind                            40,000

  Other Federal Funds                    0

  State Funds                            0

  Local Government                       27,500

  Private/Other Funds                    2,625

  Total                                  98,078
  -------------------------------------- --------------------------------

At the time of the review, the SILC chairperson reported that he was the
only SILC member who had been officially appointed in the last six
years. An on-site meeting with potential SILC members indicated local
interest in increasing the number of SILC members, as well as VIDDRS'
interest in facilitating applications to the Governor's office.\
\
VIDDRS staff reported interest in expanding the means of providing IL
services by purchasing IL services from the local center for independent
living (CIL). Evidence of this contracting or specific future plans to
do so were not apparent. However, during the review VIDDRS had not yet
entered into a contract with the CIL for these services, nor was there a
plan in place to do so.

At the time of on-site visit in March, 2007, the SILC and VIDDRS had not
begun to develop the SPIL. However, subsequent to the on-site visit, the
VIDDRS director indicated that the SILC had joined with the VIDDRS/SRC
to conduct a comprehensive needs assessment in preparation for
developing the SPIL. Activities to complete the new SPIL had not, as of
the on-site visit, begun. Subsequent conversations did, however,
indicate a plan to join efforts with the VIDDRS/SRC to conduct a joint
comprehensive needs assessment.

Results of the IL program review are discussed below.

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

## 

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

-   met with community members interested in SILC participation and
    educated them on the SILC roles and responsibilities; and

-   provided two hour teleconference training on SILC roles and
    responsibilities, SPIL requirements, and roles of different members
    of the IL community.

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

-   an inactive SILC;

-   inconsistent utilization of IL vendors by VR; and

-   late and inaccurate reporting.

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

[1. Lack of consumer involvement in the state IL program]{.underline}

Issue: To retain eligibility to receive funds under Title VII of the
Act, each state or territory must establish and maintain a Statewide
Independent Living Council (SILC) as defined by section 705.

Section 705 (c) (1) requires that the SILC work in partnership with the
DSU (VIDDRS) to jointly develop and sign the state plan.

During the review, RSA became aware that the VI SILC had not been
officially appointed, had not held an official meeting for numerous
years, and had made no progress in developing the SPIL.

As the time of issuance of this report, the VI SILC had been officially
appointed by the Governor and is therefore no longer a compliance issue.
However, issues related to SILC performance are still relevant.

Goal: To develop a fully and appropriately constituted SILC that
effectively implements an approved SPIL.

Strategies: VIDDRS will employ the following strategies to achieve the
goal:

-   assign a staff person to work with the newly-formed SILC;

-   ensure the SILC has appropriate supports to function; and

-   appoint a project manager to work with RSA on this goal.

Method of Evaluation: RSA will determine that the matter has been
successfully resolved upon completion of the following:

-   RSA approval of the VI SPIL; and

-   provide documentation through periodic reports that the SILC is
    carrying out the activities in the approved SPIL (or conducting IL
    activities consistent with its approved SPIL) six months after SPIL
    approval that IL activities mandated in the SPIL are in process.

## Technical Assistance: RSA will provide the following technical assistance: 

assist in training the newly-formed SILC in its role and functions;

hold teleconferences with the SILC, as needed; and

arrange for TA from VR agencies and/or other resources as appropriate.

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

## 

RSA and VIDDRS agreed on the following IL compliance goals, strategies
to achieve those goals, method of evaluation to determine that the
compliance issue has been resolved and technical assistance that RSA
would provide to assist VIDDRS achieve each goal.

[1. Timely and accurate completion of annual report\
]{.underline}

Issue: Section 704(m) of the Act requires state IL programs to submit
annual reports. However the VI reports for FY 2005 and 2006 were late
and contained multiple inaccuracies. The primary deficiency is that a
very high proportion of reported outcomes for the state IL program are
in fact outcomes generated by the VI CIL.

Goal: VIDDRS and SILC will submit accurate and timely Part 1 704
reports.

Strategies: VIDDRS and the SILC will employ the following strategies to
achieve the goal:

-   work with RSA staff to assure full understanding of reporting
    requirements; and

-   VIDDRS and SILC staff will develop and implement steps to assure
    timely and accurate completion of the Part 1, 704.

Method of Evaluation: RSA will determine the matter has been
successfully resolved upon timely receipt of an accurate Part 1 704.

Technical Assistance: RSA will provide education on report requirements
and timelines as well as address any questions that may arise during the
process.

## IL Recommendations

The director of VIDDRS and the director of the VI CIL indicated there
was no plan on how to best address the VR and IL needs of those
individuals served jointly by both agencies. Therefore, RSA recommends
that VIDDRS and the SILC establish goals and strategies to address the
following:

-   develop and implement strategies to strengthen collaboration and
    communication among VIDDRS, state IL, and CIL programs; and

-   develop a plan to address the VR and IL needs of individuals served
    by both VIDDRS and the VI CIL (the plan would address referrals,
    services of each agency, and funding arrangements).

## Chapter 5: OIB Program

## Program Organization

## 

VIDDRS receives \$40,000 in Chapter 2 funding for the OIB program that
supports one staff person. In FY 2007, the program served 117
individuals.

OIB staff identifies consumers through collaboration between VIDDRS,
senior centers and the local Technology Act program. OIB staff then work
with consumers to identify assistive technology (AT) needs. Staff works
with consumers to identify solutions, occasionally collaborating with
the local AT program. Appropriate technology is then purchased through
the OIB program. OIB staff plans to expand these efforts to community
centers and other more residential facilities.

Results of the IL program review are discussed below.

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

RSA provided TA to VIDDRS on 7-OB reporting requirements.

[Promising OIB Practices Identified by VIDDRS and Stakeholders during
the]{.underline}

[Review Process]{.underline}

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

## 1. Community collaboration to expand AT usage

## 

The practice of collaborating with senior centers and the local AT
project is an excellent method of leveraging resources in a low resource
area. The resources of both provide access to consumers and expertise in
specific areas (seniors and assistive technology) that will maximize
positive outcomes. This collaboration expands resources that support
VIDDRS' plan that enable consumers of the OIB program to be more
independent.

[OIB Issues identified by VIDDRS and Stakeholders during the Review
Process]{.underline}

## 

RSA's review process solicited input from VIDDRS and stakeholders about
OIB performance and compliance issues, and an incomplete 7-OB report
issue was identified.

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

## 

RSA and VIDDRS agreed on the following OIB compliance goals, strategies
to achieve those goals, method of evaluation to determine that the
compliance issue has been resolved and technical assistance that RSA
would provide to assist VIDDRS achieve each goal.

[1. Completion of the 7-OB annual report]{.underline}

Issue: Section 752(i) (2) (A) of the Act requires submission of an
annual report. Most sections of the Virgin Islands OIB report submission
are left incomplete or reported under "data not reported." This has been
a consistent issue over multiple years.

Goal: To submit a completed 7-OB annual report.

Strategies: The strategies to accomplish this goal are listed below:

-   OIB staff will review all current data tracking mechanisms and
    institute mechanisms to assure compliance with standards. These new
    mechanisms will be implemented, to the greatest possible degree, for
    submission of the FY 2007 7-OB report.

-   OIB staff will institute new data measures and assure that 7-OB
    reports, beginning FY 2008, are fully compliant with applicable
    standards.

Method of Evaluation: VIDDRS will be successful if it submits a timely
and complete 7-OB report to RSA in FY 2008 and subsequent years.

Technical Assistance: RSA will provide education on report requirements
and timelines as well as address any questions that may arise during the
process.

######## 

########  

## Chapter 6: Status of Issues Raised in Previous Reviews

As a result of the RSA review conducted with VIDDRS in FY 2003-2004, the
agency developed a Corrective Action Plan (CAP). In addition to the
Corrective Action Plan, VIDDRS was subject to a Program Improvement Plan
(PIP) because VIDDRS did not comply with 34 CFR 361.82 (b) by failing to
meet the performance indicators 1.1, 1.4, and 1.5 for FY 2004. A summary
of the progress that VIDDRS made on the CAP and PIP is described below.

## 

## Corrective Action Plan 

## 

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

-   presumption of eligibility;

-   order of selection;

-   eligibility determination;

-   transitioning students - IPEs;

-   interagency agreement governing transition services; and

-   fee schedules.

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

[1. Written policies for the provision of services to individuals with
disabilities]{.underline}: VIDDRS must develop and submit to RSA for
review a service policy manual that complies with the requirements of 34
CFR 361.50, describing the nature and scope of all VR services available
to its eligible program participants.

[Status]{.underline}: VIDDRS entered into a contractual arrangement to
have its policy manual revised and the manual is expected to be
completed by August, 2007.

[2. Exception or Waiver]{.underline}: VIDDRS must ensure that it is in
compliance with the requirements of 34 CFR 361.50 by developing formal
procedures that are available in written form to individuals who wish to
receive VR services that exceed any thresholds or limitations described
in the written VR service policy manual.

[Status]{.underline}: VIDDRS reported that a contractor will complete
its new policy manual by August 2007 and the manual will contain a
universal waiver policy that applies to the provision of services.

[3. IPE Development]{.underline}: VIDDRS should take corrective action
to ensure that VR counselors meet the established 30-day time standard
for IPE development in at least 90 percent of all cases of individuals
determined eligible for VR services.

[Status]{.underline}: As stated above, VIDDRS will have a new policy
manual and revise this time standard to 60 days for IPE development.
This revised policy will be submitted to the SRC for review.

[4. Interagency Agreements with Institutes of Higher
Education]{.underline}.

[Status]{.underline}: VIDDRS made several attempts to develop an
interagency agreement between the University of the Virgin Islands and
VIDDRS. VIDDRS completed a draft of this agreement that has yet to be
signed by the university.

## Program Improvement Plan

Through the implementation of its PIP, VIDDRS successfully met the
performance standards for indicator 1.1-- Change in the Number of
Employment Outcomes; 1.5\--Significant Disability; and 1.5\--Earnings
Ratio.

[VIDDRS met all the performance standards in FY 2006 and the PIP is
resolved.]{.underline}

## Chapter 7: Summary Conclusion

[VIDDRS' Challenges]{.underline}

The VIDDRS has challenges ahead in order to address the identified
developmental issues to increase the quantity and quality of its
employment outcomes; improve data usage and reporting; improve its
fiscal accountability; establish a more focused direction with CRPs to
increase productivity; identify an appropriate quality assurance and
evaluation system to ensure VIDDRS developmental milestones; and
consolidate the management team to unify efforts toward achieving the
goals outlined below.

**Table 6**

summarizes the results of RSA's review

+-----------------------+-----------------------+----------------------+
| ###                   |                       |                      |
| ###### Agency: VIDDRS |                       |                      |
+-----------------------+-----------------------+----------------------+
| Program: VR           |                       |                      |
+-----------------------+-----------------------+----------------------+
| Goal                  | Strategies            | Technical Assistance |
+-----------------------+-----------------------+----------------------+
| > 1\. VIDDRS will     | -   conduct caseload  | -   provide          |
| > increase the number |     analyses to       |     quarterly TA     |
| > and quality of      |     determine the     |     through          |
| > employment outcomes |     number of new     |     teleconferences  |
| > over the next two   |     applications      |     on issues        |
| > years: goal of 39   |     VIDDRS should     |     identified by    |
| > successful outcomes |     receive to        |     VIDDRS as the    |
| > for FY 2008 and     |     maintain active,  |     strategies are   |
| > goal of 52          |     viable case       |     implemented;     |
| > successful outcomes |     movement;         |                      |
| > by FY 2009          |                       | -   provide          |
|                       | -   conduct outreach  |     consultation on  |
|                       |     efforts to        |     the development  |
|                       |     increase client   |     of a quality     |
|                       |     population and    |     assurance and    |
|                       |     establish office  |     evaluation       |
|                       |     targets for new   |     system and       |
|                       |     applications;     |     provide TA from  |
|                       |                       |     other VR         |
|                       | -   manage caseload   |     agencies, as     |
|                       |     growth and        |     appropriate;     |
|                       |     anticipated       |                      |
|                       |     expenditures      | -   arrange for TA   |
|                       |     through use of    |     from other VR    |
|                       |     projection tools  |     agencies that    |
|                       |     and the ongoing   |     have been        |
|                       |     monitoring of     |     successful with  |
|                       |     performance and   |     contract-based   |
|                       |     expenditures;     |     CRP systems; and |
|                       |                       |                      |
|                       | -   train field staff | -   work with the    |
|                       |     on how to build   |     RCEP to secure   |
|                       |     and manage full   |     training for     |
|                       |     caseloads;        |     counselors on    |
|                       |                       |     job development  |
|                       | -   establish         |     and placement,   |
|                       |     appropriate       |     including the    |
|                       |     linkages with the |     conduct of       |
|                       |     employer          |     outreach with    |
|                       |     community, as     |     employers        |
|                       |     well as placement |                      |
|                       |     goals for each    |                      |
|                       |     counselor;        |                      |
|                       |                       |                      |
|                       | -   train staff on    |                      |
|                       |     methods of job    |                      |
|                       |     placements;       |                      |
|                       |                       |                      |
|                       | -   implement a       |                      |
|                       |     quality assurance |                      |
|                       |     and evaluation    |                      |
|                       |     program focused   |                      |
|                       |     on the quantity   |                      |
|                       |     and quality of    |                      |
|                       |     outcomes;         |                      |
|                       |                       |                      |
|                       | -   develop a         |                      |
|                       |     contract-based    |                      |
|                       |     CRP system        |                      |
|                       |     focused on        |                      |
|                       |     increases in the  |                      |
|                       |     quality and       |                      |
|                       |     quantity of       |                      |
|                       |     outcomes; and     |                      |
|                       |                       |                      |
|                       | -   appoint a project |                      |
|                       |     manager to work   |                      |
|                       |     with RSA on this  |                      |
|                       |     goal              |                      |
+-----------------------+-----------------------+----------------------+
| 2\. To improve the    | -   assign a staff    | -   train the newly  |
| participation of      |     person to work    |     formed SRC in    |
| consumers in the VR   |     with the          |     its role and     |
| program, VIDDRS will  |     newly-formed SRC; |     functions;       |
| support the efforts   |                       |                      |
| of SRC members to     | -   assist the SRC to | -   conduct          |
| carry out their       |     hold quarterly    |     teleconferences  |
| mandated functions in |     meetings and      |     with the SRC to  |
| an effective and      |     ensure that it    |     address topics   |
| independent manner    |     has necessary     |     of specific      |
|                       |     supports to       |     interest to the  |
|                       |     function; and     |     members;         |
|                       |                       |                      |
|                       | -   sponsor annual    | -   provide          |
|                       |     joint consumer    |     quarterly        |
|                       |     information       |     teleconference   |
|                       |     workshops         |     hook-ups with    |
|                       |                       |     the RSA national |
|                       |                       |     meeting of SRC   |
|                       |                       |     participants;    |
|                       |                       |                      |
|                       |                       | -   provide          |
|                       |                       |     web-based        |
|                       |                       |     training for SRC |
|                       |                       |     members;         |
|                       |                       |                      |
|                       |                       | -   arrange for TA   |
|                       |                       |     from the RCEP to |
|                       |                       |     train on         |
|                       |                       |     strategies for   |
|                       |                       |     the development  |
|                       |                       |     of effective     |
|                       |                       |     SRCs; and        |
|                       |                       |                      |
|                       |                       | -   provide TA from  |
|                       |                       |     other resources  |
|                       |                       |     as appropriate   |
+-----------------------+-----------------------+----------------------+
| 3\. To improve the    | -   implement a       | -   RSA will hold    |
| VIDDRS Management     |     monthly           |     quarterly        |
| Team's use of the MIS |     management        |     teleconferences  |
| (collection and use   |     meeting to review |     with VIDDRS      |
| of data)              |     and discuss data  |     management team  |
|                       |     verification of   |     to review their  |
|                       |     the agency's RSA  |     collection and   |
|                       |     911 case record   |     use of data; and |
|                       |     data for FY 2004, |                      |
|                       |     FY 2005, and FY   | -   RSA will secure  |
|                       |     2006;             |     TA from          |
|                       |                       |     high-performing  |
|                       | -   implement a       |     VR agencies or   |
|                       |     monthly           |     other sources to |
|                       |     management        |     assist VIDDRS in |
|                       |     meeting to review |     its use of data  |
|                       |     and discuss data  |                      |
|                       |     verification of   |                      |
|                       |     the agency's RSA  |                      |
|                       |     911 case record   |                      |
|                       |     data for FY 2004, |                      |
|                       |     FY 2005, and FY   |                      |
|                       |     2006;             |                      |
|                       |                       |                      |
|                       | -   train staff on    |                      |
|                       |     data analysis;    |                      |
|                       |                       |                      |
|                       | -   analyze trends in |                      |
|                       |     data to establish |                      |
|                       |     appropriate       |                      |
|                       |     targets for       |                      |
|                       |     program           |                      |
|                       |     improvement;      |                      |
|                       |                       |                      |
|                       | -   establish         |                      |
|                       |     appropriate       |                      |
|                       |     targets for       |                      |
|                       |     caseloads through |                      |
|                       |     data analysis;    |                      |
|                       |                       |                      |
|                       | -   resubmit the last |                      |
|                       |     three years of    |                      |
|                       |     RSA-113 data for  |                      |
|                       |     review to RSA as  |                      |
|                       |     this data was     |                      |
|                       |     misreported; and  |                      |
|                       |                       |                      |
|                       | -   appoint a project |                      |
|                       |     manager to work   |                      |
|                       |     with RSA on this  |                      |
|                       |     goal              |                      |
+-----------------------+-----------------------+----------------------+
| 4\. VIDDRS will       | -   analyze CRP past  | -   RSA will provide |
| develop a CRP         |     performance and   |     quarterly        |
| business model that   |     identify CRP data |     reviews of the   |
| meets the needs of    |     needed and make   |     agency's         |
| VIDDRS and enhances   |     available to      |     progress in this |
| CRP effectiveness     |     VIDDRS senior     |     area and provide |
|                       |     managers and to   |     TA to the VIDDRS |
|                       |     CRPs;             |     management team; |
|                       |                       |                      |
|                       | -   negotiate         | -   RSA will provide |
|                       |     contract-based    |     TA to VIDDRS in  |
|                       |     services with     |     the areas of     |
|                       |     CRPs and issue    |     identifying      |
|                       |     yearly "report    |     relevant CRP     |
|                       |     cards" to CRPs to |     data and in      |
|                       |     establish         |     defining the     |
|                       |     appropriate       |     components to be |
|                       |     targets for       |     included in the  |
|                       |     improvements in   |     CRP report       |
|                       |     quality and       |     cards;           |
|                       |     quantity of       |                      |
|                       |     outcomes;         | -   RSA will provide |
|                       |                       |     TA to CRPs to    |
|                       | -   identify content  |     assist the CRPs  |
|                       |     elements to be    |     to improve the   |
|                       |     included in CRP   |     quantity and     |
|                       |     report cards and  |     quality of       |
|                       |     the associated    |     outcomes;        |
|                       |     grading system    |                      |
|                       |     (criteria for     | -   as appropriate,  |
|                       |     excellent A, good |     RSA will         |
|                       |     B, fair C, etc.); |     identify VR      |
|                       |                       |     agencies that    |
|                       | -   conduct analysis  |     use this         |
|                       |     regarding the     |     business         |
|                       |     length of time    |     contract model   |
|                       |     individuals       |     to assist VIDDRS |
|                       |     receive services  |     improve CRP      |
|                       |     from CRPs prior   |     performance;     |
|                       |     to successful     |                      |
|                       |     outcome; and      | -   RSA will solicit |
|                       |                       |     training from    |
|                       | -   appoint a project |     the RCEP on      |
|                       |     manager to work   |     contract-based   |
|                       |     with RSA on this  |     models if        |
|                       |     goal              |     appropriate; and |
|                       |                       |                      |
|                       |                       | -   RSA will arrange |
|                       |                       |     for TA from VR   |
|                       |                       |     agencies and/or  |
|                       |                       |     other resources  |
|                       |                       |     as appropriate   |
+-----------------------+-----------------------+----------------------+
| 5\. VIDDRS will       | -   develop a quality | -   RSA will hold    |
| develop a quality     |     assurance and     |     quarterly        |
| assurance and         |     evaluation system |     teleconferences  |
| evaluation system to  |     that is focused   |     with VIDDRS and  |
| improve the overall   |     on the unique     |     DHS to provide   |
| operation of VIDDRS   |     needs of VIDDRS;  |     TA on its        |
|                       |                       |     implementation   |
|                       | -   train field staff |     of this system;  |
|                       |     on the intent of  |                      |
|                       |     this system;      | -   as appropriate,  |
|                       |                       |     RSA will         |
|                       | -   identify          |     identify         |
|                       |     appropriate       |     high-performing  |
|                       |     targets for field |     VR agencies that |
|                       |     offices;          |     will be enlisted |
|                       |                       |     to consult with  |
|                       | -   DHS designate an  |     VIDDRS on the    |
|                       |     evaluator to work |     development and  |
|                       |     with VIDDRS       |     implementation   |
|                       |     regarding the     |     of the system;   |
|                       |     quality assurance |     and              |
|                       |     and evaluation    |                      |
|                       |     system; and       | -   if appropriate,  |
|                       |                       |     RSA will work    |
|                       | -   appoint a project |     with the RCEP to |
|                       |     manager to work   |     assist VIDDRS    |
|                       |     with RSA on this  |     refine and       |
|                       |     goal              |     improve its      |
|                       |                       |     system           |
+-----------------------+-----------------------+----------------------+
| > Recommendations:    |                       |                      |
|                       |                       |                      |
| 6.  RSA should        |                       |                      |
|     arrange for TA    |                       |                      |
|     from VR agencies  |                       |                      |
|     and/or other      |                       |                      |
|     resources as      |                       |                      |
|     appropriate to    |                       |                      |
|     assist the VIDDRS |                       |                      |
|     management team   |                       |                      |
|     to establish a    |                       |                      |
|     system to track   |                       |                      |
|     the monthly flow  |                       |                      |
|     of cases and      |                       |                      |
|     establish a       |                       |                      |
|     system to monitor |                       |                      |
|     progress toward   |                       |                      |
|     yearly goals.     |                       |                      |
|                       |                       |                      |
| ```{=html}            |                       |                      |
| <!-- -->              |                       |                      |
| ```                   |                       |                      |
| 7.  VIDDRS should     |                       |                      |
|     evaluate the      |                       |                      |
|     quality of        |                       |                      |
|     outcomes on a     |                       |                      |
|     quarterly basis   |                       |                      |
|     to assure the     |                       |                      |
|     agency is         |                       |                      |
|     improving its     |                       |                      |
|     performance in    |                       |                      |
|     terms of          |                       |                      |
|     increased         |                       |                      |
|     salaries and      |                       |                      |
|     benefits.         |                       |                      |
+-----------------------+-----------------------+----------------------+
| 8\. Ensure the        | -   Assign            | -   RSA will provide |
| accuracy and timely   |     responsibilities  |     TA required      |
| submission of SF-269  |     for the           |     throughout this  |
| and RSA-2 reports     |     preparation,      |     process to       |
|                       |     review and        |     ensure the goal  |
|                       |     approval of all   |     is met           |
|                       |     required SF-269's |                      |
|                       |     and the RSA-2     |                      |
|                       |     report;           |                      |
|                       |                       |                      |
|                       | -   complete a        |                      |
|                       |     listing of all    |                      |
|                       |     outstanding       |                      |
|                       |     reports;          |                      |
|                       |                       |                      |
|                       | -   identify and      |                      |
|                       |     remove            |                      |
|                       |     impediments to    |                      |
|                       |     the timely and    |                      |
|                       |     accurate          |                      |
|                       |     submission of     |                      |
|                       |     required reports; |                      |
|                       |                       |                      |
|                       | -   submit missing    |                      |
|                       |     reports, along    |                      |
|                       |     with any          |                      |
|                       |     supporting        |                      |
|                       |     documentation     |                      |
|                       |     requested by RSA  |                      |
|                       |     necessary to      |                      |
|                       |     review the        |                      |
|                       |     accuracy of       |                      |
|                       |     reported          |                      |
|                       |     information; and  |                      |
|                       |                       |                      |
|                       | -   establish         |                      |
|                       |     internal policies |                      |
|                       |     and procedures to |                      |
|                       |     ensure the        |                      |
|                       |     accurate and      |                      |
|                       |     timely submission |                      |
|                       |     of required       |                      |
|                       |     reports           |                      |
+-----------------------+-----------------------+----------------------+
| 9\. Strengthen        | -   submit copies of  | -   RSA will provide |
| financial and program |     policies and      |     TA required      |
| accountability under  |     procedures to RSA |     throughout this  |
| contractual           |     for review and    |     process to       |
| arrangements          |     discussion;       |     ensure the goal  |
|                       |                       |     is met           |
|                       | -   RSA will review   |                      |
|                       |     with staff the    |                      |
|                       |     current           |                      |
|                       |                       |                      |
|                       |   policies/procedures |                      |
|                       |     applicable to     |                      |
|                       |     entering into     |                      |
|                       |     contractual       |                      |
|                       |     arrangements in   |                      |
|                       |     the Virgin        |                      |
|                       |     Islands;          |                      |
|                       |                       |                      |
|                       | -   submit a copy of  |                      |
|                       |     all FYs 2006 and  |                      |
|                       |     2007 contractual  |                      |
|                       |     arrangements to   |                      |
|                       |     RSA for           |                      |
|                       |     evaluation. (Upon |                      |
|                       |     completion, RSA   |                      |
|                       |     will discuss with |                      |
|                       |     VIDDRS the        |                      |
|                       |     weaknesses of the |                      |
|                       |     existing          |                      |
|                       |     contractual       |                      |
|                       |     arrangements and  |                      |
|                       |     any immediate     |                      |
|                       |     steps that need   |                      |
|                       |     to be taken to    |                      |
|                       |     strengthen        |                      |
|                       |     accountability    |                      |
|                       |     under existing    |                      |
|                       |     contracts);       |                      |
|                       |                       |                      |
|                       | -   develop policies  |                      |
|                       |     and procedures to |                      |
|                       |     ensure that       |                      |
|                       |     future contracts  |                      |
|                       |     have measurable   |                      |
|                       |     deliverables and  |                      |
|                       |     meet the          |                      |
|                       |     requirements of   |                      |
|                       |     OMB Circular      |                      |
|                       |     A-87, "Cost       |                      |
|                       |     Principles for    |                      |
|                       |     State, Local and  |                      |
|                       |     Indian Tribal     |                      |
|                       |     Governments"; and |                      |
|                       |                       |                      |
|                       | -   develop policies  |                      |
|                       |     and procedures    |                      |
|                       |     (including        |                      |
|                       |     assigning         |                      |
|                       |     responsibilities) |                      |
|                       |     to ensure that    |                      |
|                       |     contractor        |                      |
|                       |     performance is    |                      |
|                       |     monitored and     |                      |
|                       |     evaluated         |                      |
|                       |     throughout the    |                      |
|                       |     contractual       |                      |
|                       |     arrangement       |                      |
+-----------------------+-----------------------+----------------------+
| 10\. Improve the      | -   continue training | -   RSA will provide |
| overall financial     |     related to        |     the technical    |
| management of the VR  |     specific          |     assistance       |
| program               |     financial         |     required         |
|                       |     requirements of   |     throughout this  |
|                       |     the VR program,   |     process          |
|                       |     i.e., match,      |     (including       |
|                       |     maintenance of    |     aiding with the  |
|                       |     effort,           |     identification   |
|                       |     carryover, and    |     of external      |
|                       |     recording and     |     training         |
|                       |     liquidation of    |     resources) to    |
|                       |     obligations;      |     ensure that the  |
|                       |                       |     goal is met      |
|                       | -   discuss           |                      |
|                       |     strategies for    |                      |
|                       |     compliance with   |                      |
|                       |     fiscal            |                      |
|                       |     requirements;     |                      |
|                       |                       |                      |
|                       | -   determine         |                      |
|                       |     additional        |                      |
|                       |     training required |                      |
|                       |     for financial     |                      |
|                       |     staff and         |                      |
|                       |     appropriate       |                      |
|                       |     providers;        |                      |
|                       |                       |                      |
|                       | -   analyze the cost  |                      |
|                       |     efficiency of     |                      |
|                       |     program and       |                      |
|                       |     administrative    |                      |
|                       |     costs; and        |                      |
|                       |                       |                      |
|                       | -   determine the     |                      |
|                       |     type and          |                      |
|                       |     frequency of      |                      |
|                       |     financial/program |                      |
|                       |     information that  |                      |
|                       |     need to be        |                      |
|                       |     disseminated to   |                      |
|                       |     program managers  |                      |
|                       |     and provide       |                      |
|                       |     training on how   |                      |
|                       |     this information  |                      |
|                       |     should be         |                      |
|                       |     utilized to       |                      |
|                       |     improve overall   |                      |
|                       |     VR program        |                      |
|                       |     efficiency and    |                      |
|                       |     effectiveness     |                      |
+-----------------------+-----------------------+----------------------+
| Program: IL           |                       |                      |
+-----------------------+-----------------------+----------------------+
| Goal                  | > Strategies          | > Technical          |
|                       |                       | > Assistance         |
+-----------------------+-----------------------+----------------------+
| 11\. To develop a     | -   assign a staff    | -   assist in        |
| fully and             |     person to work    |     training the     |
| appropriately         |     with the          |     newly-formed     |
| constituted SILC that |     newly-formed      |     SILC in its role |
| effectively           |     SILC;             |     and functions;   |
| implements an         |                       |                      |
| approved SPIL         | ```{=html}            | -   hold             |
|                       | <!-- -->              |     teleconferences  |
|                       | ```                   |     with the SILC,   |
|                       | -   ensure the SILC   |     as needed; and   |
|                       |     has appropriate   |                      |
|                       |     supports to       | -   arrange for TA   |
|                       |     function; and     |     from VR agencies |
|                       |                       |     and/or other     |
|                       | -   appoint a project |     resources as     |
|                       |     manager to work   |     appropriate      |
|                       |     with RSA on this  |                      |
|                       |     goal              |                      |
+-----------------------+-----------------------+----------------------+
| 12\. VIDDRS and SILC  | -   work with RSA     | -   RSA will provide |
| will submit accurate  |     staff to assure   |     education on     |
| and timely Part 1 704 |     full              |     report           |
| reports               |     understanding of  |     requirements and |
|                       |     reporting         |     timelines as     |
|                       |     requirements; and |     well as address  |
|                       |                       |     any questions    |
|                       | -   VIDDRS and SILC   |     that may arise   |
|                       |     staff will        |     during the       |
|                       |     develop and       |     process          |
|                       |     implement steps   |                      |
|                       |     to assure timely  |                      |
|                       |     and accurate      |                      |
|                       |     completion of the |                      |
|                       |     Part 1, 704       |                      |
+-----------------------+-----------------------+----------------------+
| Recommendations:      |                       |                      |
|                       |                       |                      |
| 13\. Develop and      |                       |                      |
| implement strategies  |                       |                      |
| to strengthen         |                       |                      |
| collaboration and     |                       |                      |
|                       |                       |                      |
| communication among   |                       |                      |
| VIDDRS, state IL and  |                       |                      |
| CIL programs.         |                       |                      |
|                       |                       |                      |
| 14\. Develop a plan   |                       |                      |
| to address the VR and |                       |                      |
| IL needs of           |                       |                      |
| individuals served by |                       |                      |
| both VIDDRS and the   |                       |                      |
| VI CIL (the plan      |                       |                      |
| would address         |                       |                      |
| referrals, services   |                       |                      |
| of each agency, and   |                       |                      |
| funding               |                       |                      |
| arrangements).        |                       |                      |
+-----------------------+-----------------------+----------------------+
| Program: OIB          |                       |                      |
+-----------------------+-----------------------+----------------------+
| Goal                  | Strategies            | Technical Assistance |
+-----------------------+-----------------------+----------------------+
| 15\. To submit a      | -   OIB staff will    | -   RSA will provide |
| completed 7-OB annual |     review all        |     education on     |
| report                |     current data      |     report           |
|                       |     tracking          |     requirements and |
|                       |     mechanisms and    |     timelines as     |
|                       |     institute         |     well as address  |
|                       |     mechanisms to     |     any questions    |
|                       |     assure compliance |     that may arise   |
|                       |     with standards.   |     during the       |
|                       |     These new         |     process          |
|                       |     mechanisms will   |                      |
|                       |     be implemented,   |                      |
|                       |     to the greatest   |                      |
|                       |     possible degree,  |                      |
|                       |     for submission of |                      |
|                       |     the FY 2007 7-OB  |                      |
|                       |     report; and       |                      |
|                       |                       |                      |
|                       | -   OIB staff will    |                      |
|                       |     institute new     |                      |
|                       |     data measures and |                      |
|                       |     assure that 7-OB  |                      |
|                       |     reports,          |                      |
|                       |     beginning FY      |                      |
|                       |     2008, are fully   |                      |
|                       |     compliant with    |                      |
|                       |     applicable        |                      |
|                       |     standards         |                      |
+-----------------------+-----------------------+----------------------+

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>