Fiscal Year 2008\
Monitoring Report on the Vocational Rehabilitation and Independent
Living Programs\
in the State of\
West Virginia

![](media/image1.wmf){width="2.5in" height="2.501388888888889in"}

**[U.S. Department of Education]{.smallcaps}**

**[Office of Special Education and\
Rehabilitative Services]{.smallcaps}**

**[Rehabilitation Services Administration]{.smallcaps}**

**[September 12, 2008]{.smallcaps}**

**Contents**

**Page**

Executive Summary 1

Introduction 3

Chapter 1: RSA's Review Process 5

Chapter 2: West Virginia (WV) Division of Rehabilitation Services
(WVDRS) Vocational Rehabilitation (VR) and Supported Employment (SE)
Programs 7

Chapter 3: Fiscal Review of WVDRS VR and SE Programs 22

Chapter 4: Independent Living (IL) Program 27

Chapter 5: IL Services Program for Older Individuals Who Are Blind (OIB)
32

Chapter 6: Progress on Issues Raised in Previous Reviews of WVDRS 35

Appendix: Sources of Data 36

# Executive Summary

The Rehabilitation Services Administration (RSA) reviewed the
performance of the following programs authorized by the *Rehabilitation
Act of 1973*, as amended (the Act) in the state of WV:

-   the VR program, established under Title I;

-   the SE program, established under Title VI, Part B;

-   the IL program, authorized under Title VII, Part B; and

-   the IL OIB program, established under Title VII, Chapter 2.

The WV Division of Rehabilitation Services (WVDRS) is responsible for
the four programs, working in partnership with the WV State
Rehabilitation Council (SRC) on the VR and SE programs, and with the WV
Statewide IL Council (SILC) on the IL Part B program.

RSA's review began in the fall of 2007 and ended in the summer of 2008.
During this time, RSA's WV 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 an on-site visit, and held multiple discussions with state
    agency staff, SRC members, SILC members, and stakeholders to share
    information, identify promising practices, compliance findings, and
    areas for improvement;

-   provided technical assistance (TA) during the review process;

-   identified promising practices;

-   recommended that WVDRS undertake specific actions to improve its
    performance;

-   required WVDRS to take corrective action in response to compliance
    findings; and

-   in collaboration with WVDRS identified TA that would be helpful to
    improve its performance or correct compliance findings.

RSA identified the following strengths and challenges of the VR, SE, IL,
and OIB programs:

**Strengths:**

-   WVDRS has consistently met and/or exceeded the required performance
    on the VR standards and performance indicators since FY 2004.

-   WVDRS has forged effective partnerships with the SRC, the SILC,
    stakeholders, CILs, state board of education, local school
    districts, and other state agencies.

-   WVDRS has co-located VR transition counselors in schools to assist
    with facilitation of service delivery, job readiness training, and
    the transition to employment.

-   WVDRS has utilized a skilled internal rehabilitation technology (RT)
    unit that provides comprehensive services throughout the state,
    capitalizes on staff expertise, facilitates timely services, and
    improves cost efficiency, especially in the area of architectural
    modifications.

-   WVDRS has received additional state funds that supplement the IL
    Part B funds for the provision of IL services.

### Challenges: 

-   WVDRS' achievement of successful SE outcomes with limited funds
    available for SE extended services from a state appropriation.

-   WVDRS is rebuilding positive relationships with community
    rehabilitation programs (CRPs).

-   WVDRS must optimize its one-time state appropriation of \$450,000 to
    build service capacity.

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-   WVDRS needs to improve its RSA-2 reporting procedures to ensure that
    the agency properly classifies expenditures, indirect costs,
    (including application of the indirect cost rate), and purchased
    services on the RSA-2.

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-   WVDRS is restructuring the administration of the IL Part B program,
    and realigning respective duties of the designated state unit (DSU)
    and the SILC.

-   WVDRS must secure appointments for all members of the SILC,
    including ex-officio nonvoting members, and ensuring adherence to
    term limits for all members.

-   WVDRS needs to conduct outreach to the OIB population in rural areas
    of the state.

# Introduction

Section 107 of the Act requires the commissioner of the RSA to conduct
annual reviews and periodic on-site monitoring of programs authorized
under Title I of the Act to determine whether a state 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 State Plan Supplement for SE under Title VI part
B 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
    IL outcomes;

-   recommends that the state agency undertake specific actions to
    improve its performance; and

-   provides 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 SE program, established under Title VI, Part B;

-   the IL programs authorized under Title VII, Part B; and

-   the OIB program, established under Title VII, Chapter 2.

In addition, RSA also reviewed WVDRS' progress on:

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

## WV Administration of the VR, SE, IL, and OIB Programs

In WV there is one VR agency for all eligible individuals with
disabilities. The WV Department of Education and the Arts (WVDEA) is the
designated state agency, and WVDRS is the DSU. There are 29 VR branch
offices including seven housed in comprehensive one-stop career centers,
three located in high schools, and one located at Marshall University.
WVDRS works in conjunction with the SILC regarding the administrative
responsibility for the IL program.

## Appreciation

RSA wishes to express appreciation to the representatives of WVDEA and
WVDRS, the SRC, the SILC, the CRPs, and the various stakeholders who
assisted the RSA monitoring team in the review of WVDRS.

# Chapter 1: RSA's Review Process

## Data Used During the Review

RSA's review of WVDRS began in the fall of 2007 and ended in the summer
of 2008. RSA's data collections are finalized and available at different
times throughout the year. During this review, RSA and the state agency
used the most recent data that was available from the FY 2006 and FY
2007 collections. As a result, this report cites data from FY 2006 and
FY 2007 in addition to the trend data since FY 2002.

## Review Process Activities

During the review process, the RSA WV 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 an on-site visit, and held multiple discussions with state
    agency staff, SRC members, SILC members, and stakeholders to share
    information, and identify promising practices and areas for
    improvement;

-   provided TA during the review process;

-   recommended that WVDRS undertake specific actions to improve its
    performance;

-   required WVDRS to take corrective action in response to compliance
    findings; and

-   in collaboration with WVDRS, identified TA that would be helpful to
    improve its performance or correct compliance findings.

## RSA WV State Team Review Participants

Members of RSA's WV state team included representatives from each of
RSA's State Monitoring and Program Improvement's five functional units.
The RSA WV state team was led by RSA's state liaison to WV, Craig
McManus (VR Unit), together with the following RSA WV team members:
Elizabeth Akinola (IL Unit), Christyne Cavataio (VR Unit), Regina Luster
(Fiscal Unit), Sue Rankin-White (TA Unit), and Jean Yan (Data Collection
and Analysis Unit).

## Information Gathering

During FY 2008, RSA began its review of WVDRS by analyzing information
including, but not limited to, RSA's various data collections, WVDRS' VR
and IL State Plans, WVDRS' Client Services Manual (CSM), and the SRC's
annual report. After completing its internal review, the RSA team
carried out the following information gathering activities with WVDRS
and stakeholders in order to gain a greater understanding of WVDRS'
strengths and challenges:

-   conducted multiple teleconferences with VR and IL stakeholders,
    WVDRS management, WVDRS IL program staff, SILC members and
    administrative staff, OIB staff, and the SRC; and

-   conducted an on-site monitoring visit from April 28, 2008, through
    May 2, 2008, and met with staff of WVDEA, WVDRS, Cabell-Midland High
    School, two CRPs, the state advisory committee on CRPs, OIB
    consumers, and members of the SILC and the SRC.

# Chapter 2: WVDRS VR and SE Programs

## Agency Information and Performance 

In FY 2007, WVDRS served 7,402 individuals, of which 1,587 were closed
with an employment outcome, including 67 individuals who achieved a SE
outcome, and 934 closed without an employment outcome. Over the past
five years, the number of individuals achieving employment outcomes
steadily increased from 2,037 in FY 2003, to 2,351 in FY 2006,
representing a 15.4 percent gain. In FY 2007, WVDRS experienced a sharp
decline of individuals achieving employment outcomes, reporting a
decrease of 764, or 32.5 percent. This decrease reflects the closing of
all priority categories in the order of selection from June 2006 to
April 2007, and the institution of a waiting list for new applicants.

The number of applicants and number of individuals served fluctuated
from FY 2003 to

FY 2005, followed by a decrease in applicants of 18.1 percent from FY
2005 (6,444 applicants), to FY 2006 (5,275 applicants), and 29.2 percent
from FY 2006 to FY 2007 (3,735 applicants). Concurrently, the number of
individuals served decreased by 12.3 percent from FY 2005 (10,885
individuals) to FY 2006 (9,550 individuals), and 22.5 percent from FY
2006 to FY 2007 (7,402 individuals).

Table 2.1 provides fiscal and program data for FY 2003 through FY 2007.
The data provide an overview of the VR program's costs, outcomes and
efficiency. The table identifies the amount of funds used by the agency,
the number of individuals who applied, and the number who received
services. It also provides information about the quality of the agency's
employment outcomes, including outcomes for transition-age youths.

**Table 2.1**

**Program Highlights for WVDRS for FY 2003 through FY 2007**

  ------------------------- -------------- -------------- -------------- -------------- --------------
  Data Elements             2003           2004           2005           2006           2007

  Total funds expended on   \$34,770,921   \$36,875,511   \$36,266,724   \$36,403,629   \$35,861,286
  VR and SE                                                                             

  Individuals whose cases   2,037          2,106          2,218          2,351          1,587
  were closed with                                                                      
  employment outcomes                                                                   

  Individuals whose cases   850            1,268          1,390          1,325          934
  were closed without                                                                   
  employment outcomes                                                                   

  Total number of           2,887          3,374          3,608          3,676          2,521
  individuals whose cases                                                               
  were closed after                                                                     
  receiving services                                                                    

  Employment rate           70.56%         62.42%         61.47%         63.96%         62.95%

  Individuals whose cases   116            140            140            154            67
  were closed with SE                                                                   
  outcomes                                                                              

  New applicants per        3,036.46       3,103.30       3,011.54       2,318.13       1,818.23
  million state population                                                              

  Average cost per          \$2,966.08     \$3,323.92     \$3,273.64     \$3,576.44     \$4,047.28
  employment outcome                                                                    

  Average cost per          \$1,591.81     \$1,835.83     \$1,567.93     \$1,709.90     \$1,718.26
  unsuccessful employment                                                               
  outcome                                                                               

  Average hourly earnings   \$8.78         \$8.86         \$9.38         \$9.77         \$11.04
  for competitive                                                                       
  employment outcomes                                                                   

  Average state hourly      \$14.08        \$14.40        \$15.03        \$15.54        \$16.18
  earnings                                                                              

  Percent average hourly    62.36%         61.53%         62.41%         62.87%         68.23%
  earnings for competitive                                                              
  employment outcomes to                                                                
  state average hourly                                                                  
  earnings                                                                              

  Average hours worked per  34.26          34.61          34.76          35.32          37.01
  week for competitive                                                                  
  employment outcomes                                                                   

  Percent of transition-age 38.10%         36.28%         38.58%         39.55%         49.11%
  youths served to total                                                                
  served                                                                                

  Employment rate for       70.36%         62.91%         58.48%         64.65%         63.73%
  transition-age youths                                                                 
  served                                                                                

  Average months between    27.2           27.0           26.8           28.8           37.3
  application and closure                                                               
  for individuals with                                                                  
  competitive employment                                                                
  outcomes                                                                              
  ------------------------- -------------- -------------- -------------- -------------- --------------

## VR and SE Service Delivery 

WVDRS hires and trains employees them to provide direct services. This
includes vocational evaluators to assist with career assessment and
exploration and employment specialists that aid in job placement
services, both of which are represented in each of WVDRS' six districts.
WVDRS employs staff that provide intensive RT services in all areas of
the state.

Following fiscal constraints leading up to the closing of the WV
Rehabilitation Center, WVDRS steadily increased its expenditures on
purchased services from FY 2006 to the present. Consequently, WVDRS
redirected \$6,000,000 to the client services budget. However, WVDRS is
currently rebuilding relationships with CRPs and developing service
capacity, especially in the rural areas, to purchase and deliver
necessary VR services to individuals with disabilities statewide.

Transition-age youths comprise about 40 percent of WVDRS' total
population served, the highest in comparison to its peer agencies[^1]
(see Table 2.2). Transition-age youths also accounted for 40 percent of
individuals achieving successful employment outcomes in FY 2006 (940 out
of 2,351 individuals). Approximately 60 VR transition counselors serve
this population, and three are co-located in high schools. Staff
employed by the state education agency consider co-location to be
successful in promoting effective interactions with students that lead
to successful employment outcomes.

**Table 2.2**

Peer Comparison in Transition-Age Youths Served for FY 2006

  ------------------------ ---------- ---------- ---------- --------- ---------- ----------
  Individuals whose cases  WV -       CO -       KS -       ME -      MT -       Peer
  were closed after        Combined   Combined   Combined   General   Combined   Averages
  receiving services . . . 2006       2006       2006       2006      2006       2006

  Total employment         940        760        423        213       137        494.6
  outcomes                                                                       

  Employment rate          64.65%     71.97%     51.09%     44.84%    53.52%     57.2%

  Percent Employed in      99.57%     98.37%     98.81%     100.00%   81.62%     95.7%
  integrated setting                                                             

  Percent Transition       39.55%     31.15%     26.24%     37.08%    16.18%     30.0%
  served to total served                                                         
  ------------------------ ---------- ---------- ---------- --------- ---------- ----------

The SE program relies on limited extended service funds, provided in an
annual state appropriation, for individuals moving from WVDRS to
long-term job supports. Eligible individuals typically receive two job
coaching hours per month, with additional hours approved under
exceptional circumstances requiring further support.

### Personnel

According to the FY 2006 data, WVDRS employed 572 total staff, including
administrators, VR counselors, rehabilitation services associates,
vocational evaluators, employment specialists, quality assurance (QA)
specialists, and administrative support staff. One hundred and three of
the 572 employees were VR counselors.

WVDRS expressed concern regarding succession planning, as it anticipates
an increase of retirements, especially in management positions. In
response to this future challenge, WVDRS modified its Leadership
Development Academy to address its succession planning needs with a
focused track on management development.

To ensure a high standard of credentials for its qualified
rehabilitation professionals, WVDRS has adopted the national standard in
the absence of a state established standard. WVDRS hires VR counselors
with a master's degree in rehabilitation counseling, counseling, or a
counseling-related field. Those who do not meet the standard enter into
a training plan. In FY 2008, there were four VR counselors that did not
meet the standard. WVDRS experiences difficulty recruiting qualified VR
counselors that meet the standard, especially in the eastern panhandle.
Employee retention issues surface once counselors are fully trained and
have acquired sufficient work experience to secure employment with
better compensation. WV's neighboring states offer higher salaries and
increased opportunities for promotion.

### Data Management 

WVDRS utilizes an electronic case management system most recently
updated on July 1, 2007. The system has the capacity to provide all the
elements for the RSA reports, links costs of services for each
individual, provides case statuses to counselors and managers, and has a
backup system to ensure the integrity of the information in the event of
power failures or other disasters. Though the WVDRS office program
manager assesses data accuracy on a regular basis, a separate program to
verify the accuracy of the data is used. In addition, the system lacks
data verification and data integrity for SE services.

### Quality Assurance 

In FY 2007, WVDRS implemented a QA unit with the intent to achieve
statewide consistency of interpretation and application of policy,
provide quality TA and training, develop and implement policy, and
develop a statistical tracking system to evaluate progress. A QA manager
in the state office oversees seven QA specialists representing all six
districts, a rehabilitation services associate, and a secretary. The QA
unit promotes frequent internal communication through weekly
teleconferences, e-mails, and bimonthly planning meetings. The
activities conducted by the QA unit include:

-   providing comprehensive training to new hires, agency-wide training
    on new policies and procedures, and district-wide training to
    correct casework inconsistencies;

-   providing TA to district staff regarding case management concerns;

-   updating the CSM to tie the policy sections to the federal
    regulations;

-   conducting a review of individuals in eligibility status (also known
    as status 10 reviews) to assess the effectiveness of assessments in
    vocational goal planning, vocational guidance and counseling,
    timeliness of case progression, and case management practices;

-   providing written reports to the QA manager based upon case reviews,
    including recommendations to improve quality, policy, or casework
    practices; and

-   collecting data, both before and after case reviews, to evaluate the
    impact of their review efforts with the VR counselors.

### Planning

The WVDRS executive management team meets every Tuesday as part of a
general planning process to discuss current and emerging issues. Once
monthly, the WVDRS executive management team involves the executive
directors of the SRC and the SILC.

A strategic planning committee, comprised of WVDRS executive managers,
the executive directors of the SRC and the SILC, and other essential
personnel, convenes in the fall to develop and establish agency goals,
objectives and priorities for the ensuing fiscal year's State Plan. To
inform its strategic planning process, WVDRS derives information from
the comprehensive statewide needs assessment (CSNA), consumer
satisfaction surveys, and surveys with WVDRS staff and CRPs.

The strategic plan itself is not a formal document. However, the goals,
objectives and priorities established from committee meetings are
incorporated into the State Plan in the appropriate attachments.

## Promising VR and SE Practice Identified by WVDRS and Stakeholders During the Review Process

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

1.  **RT -- Provision of Architectural Modifications**

WVDRS has developed an internal service delivery model for the provision
of architectural modifications to individuals with disabilities in WV.
Three rehabilitation technicians travel the state in response to
referrals for services including wheelchair ramps, vertical platform
lifts, bathroom modifications (accessible sink, commode, and
shower/bath), stair glides, widening doors, and installing grab bars.
The technicians develop the recommendations and specifications
(including a materials list), and then await counselor review and
approval. If approved, materials are ordered and the technicians travel
back to the site and perform the construction work themselves.

This model of direct service from WVDRS results in multiple benefits for
both WVDRS and individuals with disabilities including significant cost
savings, timely service delivery, ability to accommodate adjustments
during construction, skilled technicians to conduct final inspections,
and increased expertise and accountability for individuals with
disabilities.

## VR and SE Programs TA Provided to WVDRS During the Review Process

RSA provided the following VR and SE program TA to WVDRS during the
review process:

-   informed WVDRS of the current RSA QA pilots and the national
    teleconference that was conducted on July 24 to inform state VR
    agencies about the pilots;

-   clarified that WVDRS cannot apply a financial needs test to job
    related services, including purchased job development and placement;

-   provided information regarding the creation of an on-line resource
    library, and will also follow up with additional information on how
    to organize it;

-   recommended that WVDRS nominate and assign a school representative
    to the state advisory committee on CRPs;

-   trained WVDRS staff on the RSA management information system; and

-   recommended data input accuracy for SE services and closures.

## Observations of WVDRS and Its Stakeholders about the Performance of the VR and SE Programs 

RSA solicited input from WVDRS and a wide range of its stakeholders
about the performance of the VR and SE programs. WVDRS and its
stakeholders shared the following observations:

-   the need for increased funding on purchased services after the
    closing of the rehabilitation center;

-   WVDRS implemented an order of selection in June 2006 with all
    categories closed, and re-opened categories twice through August
    2007 utilizing funds redirected from the closing of the
    rehabilitation center;

-   the need to renew efforts to rebuild working relationships with CRPs
    following a period of financial hardship during which WVDRS was
    unable to provide timely reimbursement;

-   WVDRS has utilized strategies to increase service capacity with
    external CRPs;

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-   WVDRS has focused significant resources and efforts on
    transition-age youths;

-   WVDRS has established effective partnerships with the WV Department
    of Education and schools;

-   WVDRS has provided significant RT services to promote successful
    employment outcomes with the transition-age youths;

-   WVDRS hired an Executive Director to promote the autonomy of the
    council and to assist the council in conducting activities, serving
    as a liaison between the SRC and WVDRS management, and representing
    the council in relevant meetings; and

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-   the insufficiency of funds for extended SE services provided through
    the state earmarked appropriation.

RSA discussed the observations of its stakeholders with WVDRS and
addressed as many of them as possible either directly or by
consolidating them into a broader issue area.

## VR and SE Performance Observations and RSA Recommendations 

RSA identified the following performance observations and made
recommendations to WVDRS about those observations. WVDRS responded to
each of the recommendations and in those instances when RSA and WVDRS
agreed upon a recommendation, RSA and WVDRS identified the TA, when
requested, that RSA would provide to WVDRS to successfully implement the
recommendation.

**1. Enhancing Community-Based Services**

**Observations:** Due to the closing of the rehabilitation center, WVDRS
has experienced significant fluctuation in its ability to purchase VR
services for individuals with disabilities. The change has required
WVDRS to develop and rebuild CRP and vendor relationships.

-   Since the closing of the comprehensive rehabilitation center in
    2007, and the reallocation of approximately \$6,000,000 into the
    consumer services budget, WVDRS has focused upon capacity building
    with CRPs that may include establishing new services, adding staff,
    providing training for new and existing staff, expanding space,
    developing materials, and purchasing equipment.

-   WVDRS received a \$450,000 state appropriation in July 2008 to
    assist in addressing its service delivery needs. WVDRS' most recent
    CSNA focused on the need to establish CRPs within the state. It
    appears that the state appropriation will not be sufficient to build
    CRP capacity to respond to the statewide service needs of
    individuals with disabilities in WV.

-   There are approximately 55 parent CRPs and 71 total CRPs including
    the satellite locations throughout the state, 28 of which provide
    sheltered employment. During the period that WVDRS operated its
    rehabilitation center and provided VR services through the center,
    it did not utilize CRPs to provide a significant percentage of the
    services provided by WVDRS. Discussions with CRP staff indicated
    that during this period, they sought contract work that fostered
    sheltered employment in order to sustain their existence.

-   WVDRS has a longstanding state advisory committee on CRPs that
    provides advice and guidance to the division in relation to planning
    and promoting CRPs. The committee has not been active in recent
    times until the closing of the rehabilitation center, and the
    members are attempting to revitalize it. WVDRS is now actively
    seeking input from the committee regarding its efforts to
    reestablish community-based services. The committee is composed of
    agency staff and CRP staff, and by statute intends to include
    private citizens involved and interested in CRPs and related state
    agencies. However, there is no school representative on the
    committee.

-   WVDRS has implemented strategies to re-establish its relationships
    with CRPs throughout the state, including soliciting input from the
    state advisory committee on CRPs, implementing a communication plan,
    and formulating a plan to expand the service capacity of CRPs to
    serve individuals with disabilities.

-   WVDRS is revising its CRP and vendor fee schedule to more
    competitive rates in an attempt to adapt to WVDRS' new business
    approach regarding purchased services. In addition, WVDRS intends to
    implement new standards for CRPs. However, at the time of the
    on-site visit, the standards had not been implemented.

-   Transition-age youths comprise 40 percent of the individuals at
    WVDRS. Discussions with special education staff indicated that CRPs
    are not adequately prepared to address the VR needs of this
    population. They related that transition students often feel
    stigmatized in the CRP environment and that services are not
    designed to respond to their needs.

**Recommendations:**

1.1 Examine the extent to which the state appropriation to build service
capacity with CRPs is sufficient, and consider the use of Title I funds
under the establishment provisions of the Rehabilitation Act to meet the
service delivery needs of individuals with disabilities at WVDRS.

1.2 Establish standards for CRPs and develop goals regarding performance
standards of the CRPs to improve accountability and increase the quality
of employment outcomes produced by CRPs.

1.3 Designate a school representative to the state advisory committee on
CRPs to provide input on the VR service needs of the transition youth
population.

1.4 Utilize the CSNA results for CRP needs to assess their capacity
building activities on a regular basis, involving the SRC and CRP
representatives.

**Agency Response:** WVDRS agreed with the recommendations and provided
the responses below.

1.  WVDRS is in the process of examining ways in which the state
    appropriation of \$450,000 and any additional Title I funds will
    satisfy individuals' needs for CRP services statewide.

2.  WVDRS is in the process of developing goals regarding performance
    standards of the CRPs that provide services to individuals with
    disabilities at WVDRS.

3.  WVDRS has already received a commitment from a representative from
    the WV Department of Education to attend the state advisory
    committee on CRPs meetings to broaden the discussion on the service
    needs of students with disabilities who are exiting from the WV
    school system.

4.  WVDRS continues to examine the current and potential capacity of
    CRPs to provide additional services to individuals with disabilities
    at WVDRS. At present, the agency is requiring WVDRS districts to
    conduct regular meetings between local CRP and WVDRS personnel to
    share information on the current service needs of individuals with
    disabilities and to identify/discuss critical issues/barriers for
    effective and efficient CRP services within their local communities.
    An invitation will be sent to the SRC requesting a representative
    attend the state advisory committee on CRPs meetings to further
    discuss identified service needs and capacities.

**TA:**

1.  To fully address the service delivery needs of the VR agency, the
    state appropriation may not be sufficient, therefore, the agency may
    have to consider Title I funds under the establishment provisions of
    the Act. RSA will provide TA on the use of those provisions.

2.  WVDRS requests that RSA provide examples of program standards for
    CRPs including information on performance standards for CRPs that
    are currently used by other federal/state VR agencies.

3.  And 1.4 WVDRS does not request TA.

**2. Quality Assurance**

**Observations**: In May 2007, WVDRS fully staffed a QA unit with the
goals of achieving statewide consistency of interpretation and
application of policy, providing quality TA and training, developing and
implementing policy, and developing a statistical tracking system to
evaluate their progress. The QA unit is in the process of evaluating its
performance to improve the efficiencies and impact upon the VR program.

-   The QA unit consists of one QA specialist in each district reporting
    to a QA manager in the state office. This represents an
    organizational change from previous QA initiatives when QA
    specialists reported to the district manager. This is viewed as a
    positive change in that it establishes a more direct connection
    between the state office and the districts.

-   The QA specialists are responsible for reviewing service records of
    VR counselors in their respective district offices, providing
    training to district staff, reviewing and revising VR policies, and
    serving as a resource to district staff on policy interpretations.

-   The QA system was established to respond to an SRC goal to improve
    consistency in VR policy interpretation and service implementation
    throughout the state.

-   The QA specialists do not currently employ standardized tools for
    service record reviews or to determine the impact of assessments on
    improving and increasing employment outcomes, nor do they utilize a
    standardized reporting format for providing information to the QA
    manager for purposes of compiling statewide reports.

**Recommendations:**

2.1 Enhance WVDRS' QA infrastructure by developing more consistent
methods of assessment and service record review in each district.

2.2 Plan the next phase of the development process in the QA unit,
including the development of necessary tools and measures to evaluate
the impact of the assessments on improving and increasing employment
outcomes and evaluating the performance of CRPs (see Recommendation
1.2).

2.3 Standardize reporting procedures from the QA specialists in each
district by developing a uniform instrument for all the QA specialists
to report results to the state office staff QA manager.

**Agency Response:** WVDRS agreed with the recommendations and provided
the responses below.

1.  WVDRS is in the process of developing standardized service record
    evaluation methods to be used by QA specialists in various
    districts.

2.  The QA unit will initiate the planning phase in the near future and
    is looking forward to receiving TA from RSA in developing the
    necessary tools and measures. WVDRS agrees with the recommendation
    to closely examine CRPs that are providing services to individuals
    with disabilities. WVDRS is committed to meeting the need for CRP
    services that will ultimately lead to the fulfillment of
    vocational/employment objectives. At present, the agency is in the
    planning phase of developing additional tools and measures to assess
    the performance of CRPs.

3.  WVDRS is in the process of developing standardized reporting
    procedures to be used by QA specialists when submitting the district
    reports to the QA manager.

**TA:** 2.2 WVDRS participated on the July 24^th^ RSA teleconference to
learn about QA pilots and gain TA from the pilots on how to improve its
QA process.

2.1 and 2.3 WVDRS does not request TA.

**3. Supported Employment -- Extended Services**

**Observations:** WVDRS utilizes 43 providers of extended SE services
for individuals with disabilities requiring long-term supports to
maintain employment. WVDRS' tracking of SE services in the case
management system is inaccurate and reduces the validity of SE data,
including the ability to evaluate SE services.

-   There are limited extended services resources for individuals in SE
    at WVDRS from the Developmental Disabilities Council and the Title
    XIX Medicaid waiver. The state, by statute, provides \$119,034
    annually for extended services funds, with WVDRS serving as the
    fiscal agent to disburse the funds to eligible CRPs. Currently,
    individuals with disabilities are typically eligible for two job
    coaching hours per month from these funds, with special requests
    made in circumstances requiring more than two hours.

-   WVDRS staff indicated that the number of hours is sufficient to meet
    the needs of those in extended services since there is an exception
    to provide additional hours if necessary.

-   Discussions with special education staff and CRP staff indicated
    that the limited number of job coaching hours is not sufficient to
    meet the needs of the general population or the transition
    population.

**Recommendation:** Assess the actual needs of individuals with
disabilities regarding extended SE services job coaching hours and
develop resources as needed to meet the demand.

**Agency Response:** The agency agrees with the observation and
recommendation regarding the extended services of the SE program. The
agency will be reviewing the needs of individuals with disabilities, the
utilization of extended services for job coaching, and the availability
of resources to meet the needs of individuals with disabilities.

**TA:** WVDRS requests that RSA provide information on how other states
administer extended services.

**4. Case Management System**

**Observations:** The case management system contains all of the VR
records at WVDRS. Though the system is stand-alone, it shares
information with other state agencies associate with WVDRS, including
responsibilities regarding agreements. The individual's initial
information is the only part of this Internet-based electronic case
management system that requires manual data input. New counselors and
supervisors receive end-user training and one year of monitoring in the
use of the system.

-   The case management system at the WVDRS includes all the data
    elements for the RSA-2, RSA-113 and RSA-911 reports. Counselors and
    managers indicate it is user friendly and the training they received
    allows them to query information without on-site information
    technology support.

-   The system does not provide a tickler function to incorporate key
    procedural steps (e.g., 60-day from application to eligibility or
    90-day closure after employment) to assist counselors in managing
    the case flow.

-   Fiscal information for individuals receiving IL and OIB services is
    maintained in a separate accounting system and does not connect with
    the case management system.

**Recommendations:**

4.1 Build an internal data check component within the case management
system to (a) reduce the dependence of external human verification of
data accuracy and data quality and (b) incorporate policy procedures for
an individual's case flow. The tickler function would alert field staff
to key timelines, including 60-day eligibility and 90-day closure, to
ensure timely progress through the VR process.

4.2 Establish the connection between the expenditures and services for
an individual in the case management system that calculates the
expenditures by counselor and by service.

4.3 Install a check-up button for the IL Part B program.

4.4 Ensure SE status of an individual at closure is congruent with the
SE status on the individualized plan for employment (IPE).

**Agency Response:** WVDRS agreed with the recommendations and provided
the responses below.

4.1 At present, the case management system has a built-in warning flag
when cases have been sitting in the application status (Status 02) for
more than 60 days without a signed waiver. When a counselor, supervisor,
manager, or state office personnel look up the report on cases for
selected territories, the report will highlight in red the cases that
have been sitting in Status 02 for more than 60 days along with the
actual number of days in that status. All field counselors, case service
personnel, and administrators, including the field supervisors and
district managers have been trained and instructed to monitor this
report. In addition to the "red flag" on the report, the state office
personnel still want to monitor the compliance to ensure that all field
counselors are following the 60-day requirement for Status 02 cases.
Based on the agency's experience, reviewing cases in the case management
system and reporting back to the field personnel any Status 02 cases
that are not meeting the 60-day requirement will reinforce the agency's
commitment to the 60-day policy. At present, the case report in the case
management system does not have a similar red flag that provides
warnings regarding the 90-day closure rule. The agency will be adding to
the case management system a similar warning system that currently
exists for the 60-day eligibility determination rule in the future.

> Additionally, the agency will review the case management system to
> identify specific places where the system can better incorporate or
> locate policy procedures that will result in a better case flow.

4.2 WVDRS is in the process of working toward connecting the
expenditures and services for individuals in the system. The agency
would like to see the system generate expenditure reports by counselor
and by service in the future.

4.3 WVDRS does not directly serve IL clients and uses three CILs to
provide IL services to the IL population across the state. The CILs
maintain their databases that collect necessary information for program
administration/maintenance and state/federal/other reporting. Given the
current method of service provision with respect to IL services, WVDRS
will not need a check-up button for IL Part B population in the agency's
case management system.

The case management system was originally constructed when WVDRS was
providing direct services to IL consumers in addition to VR consumers
and already has built-in tags for specific data for IL consumers served
by WVDRS. The agency can retrieve specific data from former IL cases
that are still in the case management system.

> Additionally, WVDRS retains designated IL territories in case
> management system for possible future usage. The case management
> system can collect data and generate caseload reports relating to IL
> consumers directly served by WVDRS, should we need it in the future.

4.4 WVDRS will adapt the case management system to link the SE status
with employment status at closure for SE cases. Once completed, the case
management system requires/ensures proper employment status for
rehabilitants in the SE program.

**TA:** WVDRS does not request TA.

**5. IPE Timeline**

**Observations:** There is a discrepancy between the timeline written in
the CSM policy and the timeline VR counselors stated they use on a daily
basis. Data analysis provided evidence that, in practice, agency staff
implement the IPE in a shorter time than stated anecdotally, with longer
periods for special populations such as transition-age youths.

-   WVDRS' current timeline for IPE development specified in policy is
    six months (CSM 2701.3). However, management staff indicated that in
    practice the timeline is nine months to take into account the longer
    time that may be necessary to conduct career exploration with
    transition-age youths. The current policy does not include an
    exception to the timeline for extenuating circumstances such as the
    career exploration for transition-age youths.

-   Based on an analysis of three-year trend data, the median time for
    IPE development was 62 days for FY 2007, 49 days for FY 2006, and 44
    days for FY 2005.

-   The median time for transition-age youths was 81 days for FY 2007,
    87 days for FY 2006, and 84 days for FY 2005.

-   Twenty five (25) percent of transition-age youths' eligibility to
    IPE implementation time exceeded 177 days for FY 2007, exceeded 202
    days for FY 2006, and exceeded 216 days for FY 2005.

-   In summary, while IPE development for the total population usually
    takes less than six months, there are a significant number of
    transition-age youths with IPEs that take more than six months to
    develop (see Table 2.3 below).

**Table 2.3**

**Days Taken From Eligibility to IPE for VR Participants by Age Group
for FY 2005 - FY 2007**

<table style="width:100%;">
<colgroup>
<col style="width: 27%" />
<col style="width: 6%" />
<col style="width: 8%" />
<col style="width: 8%" />
<col style="width: 6%" />
<col style="width: 8%" />
<col style="width: 8%" />
<col style="width: 6%" />
<col style="width: 8%" />
<col style="width: 8%" />
</colgroup>
<tbody>
<tr class="odd">
<td> </td>
<td colspan="3"><strong>2007</strong></td>
<td colspan="3"><strong>2006</strong></td>
<td colspan="3"><strong>2005</strong></td>
</tr>
<tr class="even">
<td>Days Taken From Eligibility to IPE</td>
<td>Total</td>
<td>Non-Transition</td>
<td>Transition</td>
<td>Total</td>
<td>Non-Transition</td>
<td>Transition</td>
<td>Total</td>
<td>Non-Transition</td>
<td>Transition</td>
</tr>
<tr class="odd">
<td># of cases having IPE dates</td>
<td>2590</td>
<td>1299</td>
<td>1291</td>
<td>3742</td>
<td>2257</td>
<td>1485</td>
<td>3692</td>
<td>2255</td>
<td>1437</td>
</tr>
<tr class="even">
<td>Average # of days</td>
<td>134.4</td>
<td>118.9</td>
<td>149.9</td>
<td>125.1</td>
<td>91.9</td>
<td>175.4</td>
<td>129.4</td>
<td>99.8</td>
<td>175.9</td>
</tr>
<tr class="odd">
<td>Median # of days</td>
<td>62.3</td>
<td>44.4</td>
<td>80.8</td>
<td>49.4</td>
<td>31.4</td>
<td>86.8</td>
<td>44.4</td>
<td>29.0</td>
<td>83.8</td>
</tr>
<tr class="even">
<td>Mode # of days</td>
<td>0</td>
<td>0</td>
<td>0</td>
<td>0</td>
<td>0</td>
<td>0</td>
<td>0</td>
<td>0</td>
<td>0</td>
</tr>
<tr class="odd">
<td>Standard Deviation in # of days</td>
<td>222.6</td>
<td>227.3</td>
<td>216.7</td>
<td>216.1</td>
<td>180.1</td>
<td>253.4</td>
<td>223.6</td>
<td>196.9</td>
<td>253.2</td>
</tr>
<tr class="even">
<td>Range from min. to max. days</td>
<td>3737.8</td>
<td>3737.8</td>
<td>1733.8</td>
<td>2674.3</td>
<td>2674.3</td>
<td>2356.1</td>
<td>2573.0</td>
<td>2155.2</td>
<td>2573.0</td>
</tr>
<tr class="odd">
<td>Minimum days</td>
<td>0</td>
<td>0</td>
<td>0</td>
<td>0</td>
<td>0</td>
<td>0</td>
<td>0</td>
<td>0</td>
<td>0</td>
</tr>
<tr class="even">
<td>Maximum days</td>
<td>3737.8</td>
<td>3737.8</td>
<td>1733.8</td>
<td>2674.3</td>
<td>2674.3</td>
<td>2356.1</td>
<td>2573.0</td>
<td>2155.2</td>
<td>2573.0</td>
</tr>
<tr class="odd">
<td><p># and % of cases with</p>
<p>Eligibility &amp; IPE in the same day</p></td>
<td>257<br />
(9.9%)</td>
<td>167<br />
(12.9)</td>
<td>90<br />
(7.0%)</td>
<td>423<br />
(11.3%)</td>
<td>313<br />
(13.9)</td>
<td>110<br />
(7.4%)</td>
<td>521<br />
(14.1%)</td>
<td>377<br />
(16.7%)</td>
<td>144<br />
(10.0%)</td>
</tr>
<tr class="even">
<td><p># of days for 25% of</p>
<p>individuals from eligibility to IPE</p></td>
<td>13.0</td>
<td>8.0</td>
<td>21.0</td>
<td>10.0</td>
<td>6.0</td>
<td>25.0</td>
<td>7.0</td>
<td>4.0</td>
<td>21.0</td>
</tr>
<tr class="odd">
<td><p># of days for 50% of</p>
<p>individuals from eligibility to IPE</p></td>
<td>62.3</td>
<td>44.4</td>
<td>80.8</td>
<td>49.4</td>
<td>31.4</td>
<td>86.8</td>
<td>44.4</td>
<td>29.0</td>
<td>83.8</td>
</tr>
<tr class="even">
<td><p># of days for 75% of</p>
<p>individuals from eligibility to IPE</p></td>
<td>157.4</td>
<td>136.7</td>
<td>177.1</td>
<td>141.9</td>
<td>100.3</td>
<td>202.5</td>
<td>150.7</td>
<td>112.3</td>
<td>215.9</td>
</tr>
</tbody>
</table>

**Recommendation:** Review the current timeline for IPE development and
clarify with VR counselors whether it is six or nine months; determine
whether to revise the timeline or not, and inform/train VR counselors
accordingly; and consider including an exception to the timeline based
on extenuating circumstances, such as career exploration for
transition-age youths.

**Agency Response:** The agency agrees with the recommendation regarding
the IPE timeline. The agency reviewed the current IPE timeline and
decided to implement a six-month IPE development timeline with an
exception on cases with extenuating circumstances such as transition-age
youths' cases.

**TA:** WVDRS does not request TA.

**6. Staff Development/Continuing Education**

**Observations:** WVDRS provides opportunities to address the in-service
training needs of staff to enhance the knowledge, skills, and abilities
needed to deliver services proficiently to individuals with
disabilities. The counselor perspective differed from the management
perspective on the agency's support of continuing education requests.

-   Discussions with VR counselors revealed a desire for additional
    opportunities for continuing education credits to aid the counselors
    in retaining credentials.

-   Agency management indicated that WVDRS provides ample opportunity
    for counselors to earn continuing education credits.

**Recommendation:** Conduct dialogue between WVDRS management and agency
staff, including VR counselors, to examine whether staff needs for
continuing education are congruent with opportunities provided by WVDRS.

**Agency Response:** The agency agrees with the observation and the
recommendation regarding staff development and continuing education. The
agency plans to conduct a survey of all VR counselors on their
continuing education needs at the agency-sponsored state conference in
September 2008.

**TA:** RSA provided on-site TA regarding the creation of an on-line
resource library and will also follow up with additional information on
how to organize it.

# Chapter 3: Fiscal Management of WVDRS' VR and SE Programs 

RSA reviewed WVDRS' fiscal management of the VR program. During the
review process RSA provided TA 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.

**Fiscal Management**

The data in the following table, based on data reported on the fiscal
reports submitted by the state agency, address the overall fiscal
performance of the agency. The carryover data are taken from the
unobligated balance of federal funds portion of the fourth quarter
Financial Status Report (SF-269). The data related to matching
requirements are taken from the respective fiscal year's final, or
latest, SF-269 report. The maintenance of effort (MOE) requirement data
are taken from the final, or latest, SF-269 report of the fiscal year
that is two years prior to the fiscal year to which it is compared.
Fiscal data related to administration, total expenditures, and
administrative cost percentage are taken from the RSA-2.

Table 3.1

Fiscal Data for WVDRS for FY 2003 through FY 2007

+---------------------------+-------+--------+-------+-------+--------+
| > Fiscal Year             | >     | > 2004 | >     | >     | > 2007 |
|                           |  2003 |        |  2005 |  2006 |        |
+---------------------------+-------+--------+-------+-------+--------+
| > Grant Amount            | >     | > 24,3 | >     | >     | > 25,5 |
|                           | 23,87 | 81,098 | 24,17 | 25,01 | 39,997 |
|                           | 9,486 |        | 1,790 | 0,537 |        |
+---------------------------+-------+--------+-------+-------+--------+
| > Required Match          | >     | > 6,5  | >     | >     | > 6,9  |
|                           |  6,46 | 98,696 |  6,54 |  6,76 | 12,350 |
|                           | 2,936 |        | 2,047 | 9,053 |        |
+---------------------------+-------+--------+-------+-------+--------+
| > Federal Expenditures    | >     | > 24,3 | >     | >     | > \*   |
|                           | 23,87 | 81,098 | 24,17 | 25,01 | \*24,9 |
|                           | 9,486 |        | 1,790 | 0,537 | 49,764 |
+---------------------------+-------+--------+-------+-------+--------+
| > Actual Match            | >     | > 9,5  | >     | >     | > 10,3 |
|                           |  9,38 | 41,032 |  9,39 |  9,65 | 10,317 |
|                           | 3,620 |        | 4,687 | 5,676 |        |
+---------------------------+-------+--------+-------+-------+--------+
| > Over (Under) Match      | > 2,9 | > 2,9  | >     | >     | > 3,3  |
|                           | 20684 | 42,336 |  2,85 |  2,88 | 97,967 |
|                           |       |        | 2,640 | 6,623 |        |
+---------------------------+-------+--------+-------+-------+--------+
| > Carryover at 9/30 (year | > 14  | > 1,2  | > 59  | > 0   | > 4    |
| > one)                    | 1,196 | 71,608 | 2,549 |       | 51,466 |
+---------------------------+-------+--------+-------+-------+--------+
| > Program Income          | >     | > 3,3  | >     | >     | > 2,0  |
|                           |  5,35 | 25,030 |  4,89 |  1,39 | 72,396 |
|                           | 5,794 |        | 4,237 | 7,159 |        |
+---------------------------+-------+--------+-------+-------+--------+
| > MOE                     | >     | > 8,8  | >     | >     | > 9,3  |
|                           |  8,83 | 15,399 |  9,38 |  9,54 | 94,687 |
|                           | 6,285 |        | 3,620 | 1,032 |        |
+---------------------------+-------+--------+-------+-------+--------+
| >                         |       |        |       |       |        |
+---------------------------+-------+--------+-------+-------+--------+
| > Administrative Costs    | >     | > 6,5  | >     | >     | > 9,8  |
|                           |  5,91 | 35,837 |  5,74 |  8,44 | 37,816 |
|                           | 4,174 |        | 3,045 | 0,406 |        |
+---------------------------+-------+--------+-------+-------+--------+
| > \*Total Expenditures    | >     | > 36,8 | >     | >     | > 35,8 |
|                           | 34,77 | 75,511 | 36,26 | 36,40 | 61,286 |
|                           | 0,921 |        | 6,724 | 3,629 |        |
+---------------------------+-------+--------+-------+-------+--------+
| > Percent Admin Costs to  | > 1   | >      | > 1   | > 2   | >      |
| > Total Expenditures      | 7.01% | 17.72% | 5.84% | 3.19% | 27.43% |
+---------------------------+-------+--------+-------+-------+--------+

\*Includes SE Program Expenditures.

\*\*Deadline for obligating FY 2007 federal grant funds -- September 30,
2008.

##  

##  

## Explanations Applicable to the Fiscal Profile Table

### Grant Amount: 

The amounts shown represent the final award for each fiscal year, and
reflect any adjustments for MOE penalties, reductions for grant funds
voluntarily relinquished through the reallotment process, or additional
grant funds received through the reallotment process.

### Match (Non-Federal Expenditures): 

The non-federal share of expenditures in the state VR program, other
than for the construction of a facility related to a CRP, was
established in the 1992 amendments to the 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 fund sources 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: 

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: 

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 CRP. 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.

### MOE: 

The 1992 amendments revised the requirements in section 111(a)(2)(B)(ii)
of the Act with respect to MOE provisions. Effective federal FY 1993 and
each federal fiscal year thereafter, the MOE 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 MOE requirements are two separate
requirements. Each must be met by the state.

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

### Administrative Costs:

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).

## Fiscal TA Provided to WVDRS During the Review Process

RSA provided the following VR and SE program TA to WVDRS during the
review regarding:

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

-   OMB Circular A-87 time distribution documentation requirements with
    staff working on more than one program (federal and/or state), the
    feasibility of transferring program income (Social Security
    reimbursements) to the IL OIB Program, and the reporting
    requirements for transferring and documenting program income used in
    other RSA-funded formula grant programs;

-   the sufficiency of steps that WVDRS has taken over the past two
    years to strengthen internal controls over consumer procurements and
    vendor payments and current issues related to setting/adopting
    standards for small service providers and the feasibility of
    conducting yearly training sessions for these providers to enhance
    the quality of purchased services;

-   the increase in non-federal expenditures in FY 2005 and FY 2007, the
    future impact on the state's MOE requirement, and strategies for the
    future management of this requirement;

-   WVDRS' plans for the bulk purchase of laptops for staff and WV's
    policies related to ensuring property upon receipt from the vendor,
    since OMB Circular A-87 prohibits the use of federal funds to
    replace stolen laptops that could, or should have been insured;

-   the federal requirements for carrying over federal grant funds and
    strategies, obligation and liquidation deadlines for using these
    funds;

-   the acceptable methodologies for charging indirect costs to federal
    programs as outlined in OMB Circular A-87 and the need for WVDRS to
    develop an indirect cost rate to charge these costs;

-   the increase in costs reported on the RSA-2 for the administration
    of the State VR and SE programs and advised staff that reported
    costs are increasing as a result of improperly classifying some
    program costs as administrative costs, and program staff as
    administrative staff;

-   the actions to be taken to properly report the cost of purchased
    services on the RSA-2 report;

-   the state VR program innovation and expansion (I & E) authority's
    tie-in to WVDRS' State Plan and the requirement to segregate and
    report all expenditures for

> I & E activities in the Block 12 (remarks) of SF-269s; and

-   reviewed, corrected and approved SF-269s for formula grant programs
    for FY 2005 through FY 2008.

## VR and SE Programs' Fiscal Management Performance Observations and RSA Recommendations 

RSA identified the following fiscal performance observations and made
recommendations to WVDRS about those observations. WVDRS responded to
each of the recommendations and in those instances when RSA and WVDRS
agreed upon a recommendation, RSA and WVDRS identified the TA that RSA
would provide to WVDRS to successfully implement the recommendation.

**1. RSA-2 Reporting**

**Observation:** Inaccuracies were noted in the reporting/classifying of
expenditures (resulting in artificially inflated administrative costs),
indirect costs (including application of the indirect cost rate), and
purchased services on the RSA-2.

**Recommendation:** Improve the accuracy of RSA-2 reporting through
assignment of expenditures to the appropriate classification category on
each schedule, and through the correct utilization of the indirect cost
rate to report administrative expenses on Schedule I.

**Agency Response:** The agency agrees with the recommendation to
improve the RSA-2 report. The agency will be working on the assignment
of expenditures to the appropriate classification category and also on
the correct utilization of the indirect cost rate for reporting expenses
on Schedule I of the RSA-2. The agency is looking forward to receiving
additional TA from RSA to successfully accomplish these activities in
the coming months.

**TA:** TA was provided at the National Fiscal/Data Conference to
address these issues. Following the conference, RSA will request that
additional guidance be provided by the U.S. Department of Education's
Indirect Cost Group to clarify the development and utilization of an
indirect cost rate to charge indirect costs to federal programs.

# Chapter 4: IL Program

## Agency Information and Performance 

Based on data in the 704 Part II annual performance reports of the CILs,
WV served 1,001 individuals in FY 2007 through contracts with the
Appalachian CIL, Mountain State CIL, and the Northern WV CIL. WV applied
\$301,477 in Part B funds to supplement the Part C funds of the CILs.
Table 4.1 below displays the funding for the WV IL program during FY
2006 and FY 2007.

Table 4.1

## Funding for WV IL Program for FY 2006 and FY 2007

  ---------------------------------------------- ----------- -------------
  Data Elements                                  2006        2007

  Funding: Title VII, Chapter 1, Part B          301,477     301,477

  Funding: Total Resources (including Part B     1,109,981   1,071,629
  funds)                                                     
  ---------------------------------------------- ----------- -------------

### IL Program Administration and Service Delivery 

WVDRS is the DSU for the IL Part B program in WV. At the time of RSA's
on-site visit, the SILC was responsible for the disbursement of Part B
funds. The SILC issued requests for proposals (RFPs) and participated in
the monitoring, oversight and evaluation of contracts entered into with
the CILs to provide IL services to individuals with significant
disabilities in the state. In addition, the SILC receives direct state
funds of approximately \$350,000 to provide personal attendant services.

### Personnel

At the DSU level, WVDRS assigns one liaison to the SILC. The SILC
performs responsibilities for the Part B program, including overseeing
the annual audit of the CILs, disbursing federal funds, and preparing
reports. To carry out these responsibilities the SILC receives \$16,749,
or five percent of Part B funds, from the DSU as administrative fees.
The SILC is incorporated as a 501(c)(3) nonprofit and employs an
executive director, an administrative assistant, and a program
assistant.

### Data Management 

Each of the three CILs in WV collects data through its own data system.
These data are made available to RSA through each CIL's 704 Part II
annual performance report. The data are also shared at SILC meetings.

### Fiscal Management 

At the time of RSA's on-site visit, WVDRS delegated all program and
fiscal management activities for Part B grantees/contractors to the
SILC. The SILC was responsible for establishing and maintaining
procedures and internal financial controls governing the management and
utilization of Part B funds provided to the CILs through grants and
contracts.

### Quality Assurance

The QA process for the IL program is conducted through consumer
satisfaction surveys jointly developed by the SILC, DSU and the CILs.
The SILC issues the surveys to all IL consumers.

### Planning

The SILC and WVDRS engage in strategic planning and goal development,
including joint development of the SPIL. They conducted public meetings
and incorporated input into the SPIL goals. The SILC executive director
also participates in monthly planning meetings with the WVDRS executive
management team.

### IL Program TA Provided to WVDRS During the Review Process

RSA provided the following IL program TA to WVDRS during the review
process regarding:

-   clarification of the nondelegable duties of the DSU to receive,
    account for, and disburse Part B funds;

-   clarification of the requirements related to the use of Part B funds
    by the SILC in fund raising/resource development;

-   information clarifying the SILC's mandated roles and
    responsibilities;

-   requirements related to SILC appointments and term limits; and

-   clarification regarding the respective roles of the DSU, the SILC
    and the CILs in the administration of the Part B program.

## Observations of WVDRS and Its Stakeholders about the Performance of the IL Program 

RSA solicited input from WVDRS, the SILC and a wide range of its
stakeholders about the performance of the IL program. The WVDRS, SILC
and its stakeholders shared the observations below.

-   The SILC administers the Part B program in the state, including
    disbursing federal funds, overseeing the use of Part B funds, and
    conducting the annual audit of the CIL contractors under the Part B
    program.

-   WV receives additional state funds that supplement the IL Part B
    funds for the provision of IL services.

-   WV has a waiting list for Part B IL services.

-   Ex-officio nonvoting members of the SILC are not appointed by the
    Governor and are not subject to the same term limits as other SILC
    members.

-   The SILC conducts an annual youth leadership caucus and a disability
    caucus.

RSA discussed the observations of its stakeholders with WVDRS and
addressed as many of them as possible either directly or by
consolidating them into a broader issue area.

## IL Program Compliance Findings and Corrective Actions 

RSA identified the following compliance findings and corrective actions
that WVDRS and the SILC are required to undertake. WVDRS and the SILC
must develop a corrective action plan for RSA's review and approval that
includes specific steps the agency will take to complete the corrective
action, the timetable for completing those steps, and the methods the
agency will use to evaluate whether the compliance finding has been
resolved. RSA anticipates that the corrective action plan can be
developed within 45 days and is available to provide TA to assist WVDRS
and the SILC.

**1: SILC Responsibilities**

**Legal Requirements:**

Section 704(c)(1): The plan shall designate the designated State unit of
such State as the agency that, on behalf of the State, shall‑‑

\(1\) receive, account for, and disburse funds received by the State
under this chapter.

Section 705(c) of the Act provides:

The Council shall:

> \(1\) jointly develop and sign (in conjunction with the designated
> State unit) the State plan required in section 704;
>
> \(2\) monitor, review, and evaluate the implementation of the State
> plan;
>
> \(3\) coordinate activities with the SRC established under section
> 105, if the State has such a Council, or the commission described in
> section 101 (a)(21)(A), if the State has such a commission, and
> councils that address the needs of specific disability populations and
> issues under other Federal law;
>
> \(4\) ensure that all regularly scheduled meetings of the SILC are
> open to the public and sufficient advance notice is provided; and
>
> \(5\) submit to the Commissioner such periodic reports as the
> Commissioner may reasonably request, and keep such records, and afford
> such access to such records, as the Commissioner finds necessary to
> verify such reports.

**Findings:**

-   The SILC is performing responsibilities outside its mandated
    functions, including disbursing funds, conducting resource
    development, and monitoring evaluation of the plan.

-   The SILC issues RFPs and participate in the monitoring, oversight,
    and evaluation of contracts with CILs to provide IL services.

-   The SILC conducts a Disability Caucus under the authority of Section
    705(d) function to hold such hearings and forums as the Council may
    determine to be necessary to carry out the duties of the Council.

-   The SILC's fundraising activities using federal funds to organize
    and participate in the Disability Caucus are not authorized
    activities under the Act.

-   The SILC organizes an annual youth leadership caucus and conducts
    fundraising activities using federal funds, activities not
    authorized under the Act.

**Corrective Actions:**

1.1 Take corrective action to restructure responsibilities to comply
with requirements regarding the nondelegable duties of the DSU.

2.  Revise the SPIL to align the duties of the SILC and the DSU with
    federal requirements.

3.  Take corrective action to restructure responsibilities to comply
    with 705(c) requirements regarding the statutory duties of the SILC,
    including activities related to fundraising for the Disability
    Caucus, and responsibilities regarding the participation with the
    organization of events such as the annual youth leadership caucus.

**Agency Response:** With respect to the compliance finding (in
connection to the SILC responsibilities), the agency agrees with the
corrective action and is in the process of working with relevant
stakeholders to develop a corrective action plan. This plan will specify
steps that the SILC will take to restructure responsibilities to comply
with federal requirements, including activities related to fundraising
for the Disability Caucus, and responsibilities regarding the
participation with the organization of events such as the annual youth
leadership caucus.

### 2: SILC Appointments and Term Limits

### Legal Requirement:

34 CFR 364.21(b)(1), and (b)(2)(i)(b).

\(b\) Appointment and composition-(1) Appointment. Members of the SILC
must be appointed by the Governor or the appropriate entity within the
State responsible, in accordance with State law, for making
appointments.

\(2\) Composition. (i) The SILC must include- (B) As ex-officio,
nonvoting members, a representative from the DSU and representatives
from other State agencies that provide services to individuals with
disabilities (34 CFR 364.21(f), and (f)(3)).

\(f\) Terms of appointment. Each member of the SILC shall serve for term
of three years, except that-

\(3\) No member of the SILC may serve for more than two consecutive full
terms.

**Finding:** Ex-officio members of the SILC are not appointed by the
Governor and are not subject to the same term limits as other SILC
members. DSU staff reported that the WV Governor does not appoint
ex-officio non-voting council members to state councils.

**Corrective Action 2:** Take corrective action to ensure that all SILC
members are appointed by the Governor, including ex-officio, nonvoting
members, and are subject to uniformly implemented term limits.

**Agency Response:** With respect to the compliance finding (in
connection to SILC appointment), the agency agrees with the correction
action and will develop and implement a CAP. This plan will have the
steps to ensure to the best of the agency's ability that all SILC
members are appointed by the Governor, including ex-officio, nonvoting
members.

# Chapter 5: IL OIB Program

## Agency Information and Performance 

Based on data in the FY 2007 7-OB annual performance report, WVDRS
served 271 individuals directly and expended \$227,290 in Title VII,
Chapter 2 funds, \$2,334 in third-party contributions (including local
and community funding), and \$37,371 of in-kind contributions. Table 5.1
below displays expenditures and performance data for WV in FY 2006 and
FY 2007.

## Table 5.1

## Expenditures and Performance for WV for FY 2006 and FY 2007

  ----------------------------------------------- ----------- -----------
  Data Elements                                   2006        2007

  Expenditures: Title VII, Chapter 2              228,991     227,290

  Expenditures: Total (including Chapter 2)       268,202     266,995

  Performance: Total Older Individuals who are    321         271
  Blind Served                                                
  ----------------------------------------------- ----------- -----------

### OIB Program Administration and Service Delivery 

Prior to FY 2007, WVDRS administered the OIB program under a contract
with WV University Center of Excellence for Disabilities. Based on
unsatisfactory performance under the contract, WVDRS currently
administers the program directly through its VR counselors.

### Personnel

WVDRS devotes .24 full time equivalent (FTE) administrative staff, .31
FTE support staff, and 2 FTE direct service staff to the program. WVDRS
currently has four vacancies in the direct service staff.

### 

### Data Management 

WVDRS utilizes a web-based data collection/case management system to
collect and compile data for purposes of developing the RSA 7-OB annual
performance report. This is a separate database from the case management
system utilized for the VR and SE programs. The database provides case
monitoring and management capacity and includes security features
designed to comply with program confidentiality requirements.

### Fiscal Management 

WVDRS provides fiscal management for WV's OIB program.

### Quality Assurance

WVDRS conducts annual consumer satisfaction surveys. The results are
used for program monitoring and improvement. WVDRS also conducts annual
service record reviews of OIB consumers. The program manager reviews
between 20 and 25 percent of active and completed consumer service
records.

### Planning

WVDRS OIB staff coordinate planning activities in the state with the VR
blind services program.

### OIB Program TA Provided to WVDRS During the Review Process

RSA provided the TA to WVDRS during the review process regarding
strategies to improve outreach efforts to serve the OIB population
located in the rural areas of WV.

## 

## Observations of WVDRS and Its Stakeholders about the Performance of the OIB Program 

RSA solicited input from WVDRS and a wide range of its stakeholders
about the performance of the OIB program. WVDRS and its stakeholders
shared the observations below.

-   OIB stakeholders indicated the need for increased outreach and
    community awareness to serve additional older blind individuals in
    rural WV.

-   WV is increasing collaborative activities with the CILs to leverage
    resources.

-   WV plans to purchase and locate closed circuit televisions in public
    places for use by older blind individuals.

RSA discussed the observations of its stakeholders with WVDRS and
addressed as many of them as possible either directly or by
consolidating them into a broader issue area.

## OIB Program Performance Observations and RSA Recommendations 

RSA identified the following performance observations and made
recommendations to WVDRS about those observations. WVDRS responded to
each of the recommendations and in those instances when RSA and WVDRS
agreed upon a recommendation, RSA and WVDRS identified the TA that RSA
would provide to WVDRS to successfully implement the recommendation.

**1. Outreach**

**Observation:** OIB staff and stakeholders agree that the OIB program
needs to serve more rural consumers across the state, especially in the
northern part of the state, including Morgantown, Wheeling and Weirton.

**Recommendation:** Increase outreach efforts, especially in the rural
parts of the state, including Morgantown, Wheeling and Weirton.

**Agency Response:** The agency agrees with the need to increase the
rural outreach. The agency is in the process of realigning the areas
covered by the OIB service providers to meet the needs of OIB consumers.
By realigning the coverage areas of the OIB service providers, the
agency will focus more attention on the underserved OIB population,
especially in the northern part of the state, including Morgantown,
Wheeling and Weirton.

**TA:** WVDRS does not request TA.

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

As a result of the RSA review conducted with WVDRS in FY 2004, WVDRS
developed a CAP. A summary of the progress that WVDRS has made on the
CAP is described below.

## CAP

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

-   developing a cooperative agreement with the WV Public Institutions
    of Higher Education;

-   updating and providing policy exceptions to medical services in the
    fee schedule; and

-   establishing a written policy describing the nature and scope of
    rehabilitation teaching services.

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

**1. Motor Vehicle Purchase:** The 2004 monitoring report identified
four compliance findings and WVDRS, through implementation of its CAP,
successfully resolved three of the four findings.

The remaining finding relates to a policy that prohibits the purchase of
vehicles for individuals receiving VR services, and does not include
exception language for extenuating circumstances.

WVDRS was instructed to wait for additional guidance from RSA to assist
with the resolution of this finding.

At this time, the finding has not yet been resolved. However, WVDRS
indicated it intends to delete the current policy as a result of the
implementation of a new initiative, the Good News Mountaineer Garage
(GNMG) that will allow for the provision of vehicles.

**Status:** WVDRS has a draft policy for the GNMG, and the agency is
currently following procedures necessary to implement new policies.

**Agency Response:** With respect to compliance issues from previous
reviews (regarding vehicle purchase), the agency agrees with RSA and
took the corrective action by removing the policy that prohibits vehicle
purchase from the current WVDRS CSM. The agency is in the process of
implementing a new I & E project that will allow for the provision of
vehicles for qualified individuals with disabilities at WVDRS.

# Appendix: Sources of Data

## VR and SE Program Highlights 

-   Total funds expended on VR and SE - RSA-2 line 1.4

-   Individuals whose cases were closed with employment outcomes -
    RSA-113 line D1

-   Individuals whose cases were closed without employment outcomes -
    RSA-113 line D2

-   Total number of individuals whose cases were closed after receiving
    services - RSA-113 line D1+D2

-   Employment rate - RSA-113 line D1 divided by sum of RSA-113 line
    D1+D2, multiplied by 100

-   Individuals whose cases were closed with SE outcomes - Total number
    of individuals whose employment status at closure (record
    position 161) = 7 in the RSA-911 report

-   New applicants per million state population - RSA-113 line A2
    divided by the result of the estimated state population divided by 1
    million. The estimated state population is found on the following
    website:<http://www.census.gov/popest/states/NST-ann-est.html>

-   Average cost per employment outcome - Sum of individuals' cost of
    purchased services from the RSA-911 (record position 104-109) for
    individuals who achieved an employment outcome (record position 198
    =3) divided by the total number of these individuals

-   Average cost per unsuccessful employment outcome - Sum of
    individuals' cost of purchased services from the RSA-911 (record
    position 104-109) for individuals who did not achieve an employment
    outcome (record position 198 = 4) divided by the total number of
    these individuals

-   Average hourly earnings for competitive employment outcomes - Sum of
    individuals' weekly earnings at closure (record position 163-166)
    divided by the total hours worked in a week at closure (record
    position 167-168) for individuals where weekly earnings at closure
    \> 0, where the type of closure (record position 198) = 3, and where
    competitive employment (record position 162) = 1

-   Average state hourly earnings - Using the most relevant available
    data from the Bureau of Labor Statistics Report
    (http://www.bls.gov), state average annual earnings divided by 2,080
    hours

-   Percent average hourly earnings for competitive employment outcomes
    to state average hourly earnings - Average hourly earnings for
    competitive employment outcomes (above) divided by the Average state
    hourly earnings (above) multiplied by 100

-   Average hours worked per week for competitive employment outcomes -
    Average hours worked in a week at closure (record position 167-168)
    for individuals where weekly earnings at closure (record position
    163-166) \> 0 and where the type of closure (record position 198) =
    3 and competitive employment (record position 162) = 1

-   Percent of transition age served to total served - Total number of
    individuals whose age at closure is 14-24 and whose type of closure
    (record position 198) is 3 or 4 divided by all individuals of any
    age whose type of closure (record position 198) is 3 or 4

-   Employment rate for transition population served - Total number of
    individuals whose age at closure is 14-24 and whose type of closure
    (record position 198) = 3 divided by the number of individuals whose
    age at closure is 14-24 and whose type of closure (record
    position 198) is 3 or 4 multiplied, the result of which is
    multiplied by 100

-   Average time between application and closure (in months) for
    individuals with competitive employment outcomes - Average of
    individuals date of closure (record position 201-208) minus date of
    application (record position 15-22) in months where type of closure
    (record position 198) = 3 and competitive employment (record
    position 162) =1

IL Program Highlights (From RSA 704 report)

-   Funding: Title VII, Chapter 1, Part B - Subpart I, Administrative
    Data, Section A, Item 1(A)Funding: Total Resources (including Part B
    funds) - Subpart I, Administrative Data, Section A, Item 4

-   Performance: Total Served - Subpart II, Number and Types of
    Individuals with Significant Disabilities Receiving Services,
    Section A(3)

-   Performance: Total Consumer Service Records Closed - Subpart II,
    Number and Types of Individuals with Significant Disabilities
    Receiving Services, Section B(6)

-   Performance: Cases Closed - Completed All Goals - Subpart II, Number
    and Types of Individuals with Significant Disabilities Receiving
    Services, Section B(4)

-   Performance: Total Goals Set - Subpart III, Section B, Item 1, sum
    of (A) + (B) + (C) + (D) + (E) + (F) + (G) + (H) + (I) + (J) + (K) + (L)
    for the column "Goals Set"

-   Performance: Total Goals Met - Subpart III, Section B, Item 1, sum
    of (A) + (B) + (C) + (D) + (E) + (F) + (G) + (H) + (I) + (J) + (K) + (L)
    for the column "Goals Achieved"

-   Performance: Total Accesses Achieved - Subpart III, Section B, Item
    2, sum of (A) + (B) + (C) for the column "# of Consumers Achieving
    Access"

-   Staffing: Total FTEs - Subpart I, Section F, sum of Item 2 for the
    column "Total Number of FTEs"

-   Staffing: Total FTEs with Disabilities - Subpart I, Section F, sum
    of Item 2 for the column "Total Number of FTEs with Disabilities"

## ILOB Program Highlights (From RSA 7-OB Form)

-   Expenditures: Title VII, Chapter 2 - Part I-Sources and Amounts of
    Funding, (A)(1)

-   Expenditures: Total (including Chapter 2) - Part I-Sources and
    Amounts of Funding, (A)(6)

-   Performance: Total Older Individuals who are Blind Served - Part
    III-Data on Individuals Served During This Fiscal Year, (B)-Gender,
    sum of (1) + (2)

-   Staffing: Total FTEs - Part II-Staffing, sum
    of (1) + (2) + (3) + (4) for the column "Total FTEs: State Agency +
    Contactors"

-   Staffing: Total FTEs with Disabilities - Part II-Staffing, sum
    of (1) + (2) + (3) + (4) for the column "FTEs with Disability"

[^1]: Peer agencies are those that are similar to WVDRS in grant size.
    For WVDRS, peer agencies are: Colorado-Combined, Kansas-Combined,
    Maine-General, and Montana-Combined.