United States Government Accountability Office

GAO Report to Congressional Requesters

FEDERAL 

DISABILITY 

ASSISTANCE 

Stronger Federal 

Oversight Could Help 

Assure Multiple 

Programs’ 

Accountability 

January 2007 

 

GAO-07-236 
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

January 2007

FEDERAL DISABILITY ASSISTANCE

Stronger Federal Oversight Could Help 

Highlights of GAO-07-236, a report to Assure Multiple Programs’ Accountability 

congressional requesters 

Congress has created 20 federal 

employment-related programs that 

are aimed at helping people with 

disabilities obtain jobs. Little is 

known about the effectiveness and

the management of some of these

programs. GAO was asked to

review four of these programs; the

Department of Education

(Education) oversees three—

Projects with Industry (PWI), 

Supported Employment State 

Grants, and Randolph-Sheppard. 

An independent federal agency, the

Committee for Purchase, oversees 

the fourth, Javits-Wagner-O’Day

(JWOD). Specifically, GAO 

assessed the extent to which 

(1) performance goals and 

measures have been established for 

these programs and (2) the

agencies responsible have

established adequate oversight

procedures. We reviewed program 

planning and performance 

information, interviewed agency 

officials, and visited each of the

four programs in four states. 

What GAO Recommends

GAO recommends that Education 

establish goals for the RandolphSheppard program and strengthen 

program monitoring and guidance. 

GAO also recommends that the 

Committee for Purchase ensure 

JWOD goals and measures are 

clear and measurable and 

strengthen its procedures for 

overseeing the JWOD nonprofit

agencies. In their comments, 

Education and the Committee for

Purchase generally agreed with 

GAO’s recommendations. 

Three of the four programs have federal performance goals. No federal 

performance goals or measures currently exist for the Randolph-Sheppard 

program, which provides opportunities for individuals who are blind to 

operate vending facilities on federal properties. Without goals, it is difficult 

to assess the program’s performance, but Education officials told GAO they 

are developing them. Education has a goal and a measure for the Supported 

Employment State Grants program—a federal grant program that provides 

job coaching and other support to help individuals with severe disabilities 

secure jobs. The goal indirectly measures the program’s performance 

because grant funds are mixed with other funding sources to provide 

supported employment services. Education has also developed one goal for 

the PWI program--a federal grant program that helps individuals with 

disabilities obtain competitive employment--that is consistent with the 

mission of the program. The goal is to create and expand job opportunities 

for individuals with disabilities in the competitive labor market by engaging

business and industry, and one of the measures tracks the percentage of 

individuals placed in employment in work settings making at least minimum 

wage. The Committee for Purchase, which oversees the JWOD program—a 

program that helps to create jobs through the federal property management 

and procurement systems—first developed federal goals and measures for 

its fiscal year 2005-2007 strategic plan and has since revised them. The 

revised measures still have limitations, such as not being clearly defined or 

being difficult to measure. 

Education’s and the Committee for Purchase’s oversight of the four 

programs has been uneven. Education has established procedures, such as 

on-site reviews, for the PWI and Supported Employment State Grants 

programs that, if consistently followed, would provide reasonable assurance 

that the programs are in compliance with applicable laws and regulations. 

However, Education conducts limited oversight of the Randolph-Sheppard 

program. For example, Education does not routinely analyze or report the 

data it collects from states and has provided little guidance to ensure states

comply with laws or consistently interpret program requirements. One area

in which Education has not provided sufficient guidance is the 

circumstances under which federal agencies may charge fees to licensed 

vendors operating vending facilities on their properties. As a result, vendors 

in some locations were paying commissions or fees but those in other 

locations were not. Finally, the Committee for Purchase delegates most of its 

oversight responsibilities to two central nonprofit agencies that also 

represent the interests of the JWOD nonprofit agencies they oversee. This 

arrangement, as well as the fact that they receive a percentage of the total 

value of the contracts from the JWOD nonprofit agencies, raises questions 

about their independence and gives them little incentive to identify instances 

of noncompliance that could result in the JWOD nonprofit agency losing its 

federal contract. 

www.gao.gov/cgi-bin/getrpt?GAO-07-236.

To view the full product, including the scope 

and methodology, click on the link above. 

For more information, contact Robert E. 

Robertson at (202) 512-7215 or 

robertsonr@gao.gov. 
Contents 

Letter 1

Results in Brief 3 

Background 5

Three of the Four Programs Have Established Goals and Measures 12 

Uneven Federal Oversight Provides Little Assurance of 

Accountability for Two Programs 18 

Conclusions 27

Recommendations 28

Agency Comments and Our Evaluation 29 

Appendix I Objectives, Scope, and Methodology 32 

Appendix II Performance Goals and Measures for the 

Javits-Wagner-O’Day (JWOD) Program 35 

Appendix III Comments from the Department of Education 37 

Appendix IV Comments from the Committee for Purchase from 

People Who Are Blind or Severely Disabled 39 

Appendix V GAO Contact and Staff Acknowledgments 43 

Page i GAO-07-236 Federal Disability Assistance
Tables 

Table 1: Federal and State Funds, Other Funding Sources, Total 

Funds, and Funds per Vendor for Four State RandolphSheppard Programs in Fiscal Year 2005 13 

Table 2: Supported Employment State Grants Program Goal and 

Actual Performance, Fiscal Years 2003 through 2005 14 

Table 3: PWI Performance Goal and Actual Performance, Fiscal 

Years 2003 through 2005 15 

Table 4: JWOD Performance Goals and Examples of Performance 

Measures, Fiscal Years 2007-2009 18 

Table 5: JWOD Performance Goals and Measures 35 

Figure 

Figure 1: Number of Vendors in Program, Fiscal Years 2001-2005 9 

Abbreviations 

BAC Business Advisory Councils 

ETS Committee for Purchase’s Essentially The Same 

GPRA Government Performance and Results Act of 1993

JWOD Javits-Wagner-O’Day 

NCED National Center for the Employment of the Disabled 

NIB National Industries for the Blind 

NISH National Industries for the Severely Handicapped 

PWI Projects with Industry 

RSA Rehabilitation Services Administration 

SLA State Licensing Agency 

VR Vocational Rehabilitation 

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Page ii GAO-07-236 Federal Disability Assistance
United States Government Accountability Office

Washington, DC 20548 

January 26, 2007 

The Honorable Edward M. Kennedy 

Chairman 

Committee on Health, Education, Labor, and Pensions 

United States Senate 

The Honorable Henry A. Waxman 

Chairman 

Committee on Oversight and Government Reform 

House of Representatives 

The employment rate for working-age people with disabilities is about half

of the employment rate for working-age people without disabilities.1

 In 

fiscal year 2003, at least $2.4 billion was spent on 20 federal programs that 

are aimed to improve employment opportunities for people who have 

disabilities, but little is known about how effectively some of these 

programs are achieving their intended outcomes. You asked us to review 

four of these programs: Projects with Industry (PWI), Supported 

Employment State Grants, Randolph-Sheppard Vending Facility Program 

(hereafter known as Randolph-Sheppard), and Javits-Wagner-O’Day 

(JWOD). PWI and Supported Employment State Grants are federal grant

programs that fund services that help individuals with disabilities to obtain 

competitive employment. The other two programs, Randolph-Sheppard 

and JWOD, help create jobs for individuals with disabilities through the 

federal property management and procurement systems. RandolphSheppard licenses people who are blind to operate vending facilities on 

federal or other properties, and JWOD gives preference to nonprofit 

agencies who employ people with disabilities to produce goods and 

services for the federal government. 

The Department of Education (Education) is responsible for administering 

the Projects with Industry, Supported Employment State Grants, and 

Randolph-Sheppard programs. By law, Randolph-Sheppard is a stateoperated program with limited federal responsibilities. The Committee for 

Purchase from People Who Are Blind or Severely Disabled (Committee for 

 1

Cornell University Institute for Policy Research, Policy Brief, Dismantling the Poverty 

Trap: Disability Policy for the 21st Century (Washington, D.C.: July 2005). 

Page 1 GAO-07-236 Federal Disability Assistance
Purchase), a small independent federal agency, is responsible for 

administering the JWOD program. The Committee for Purchase utilizes 

two central nonprofit agencies—National Industries for the Blind (NIB) 

and NISH2

—to help carry out its responsibilities. 

You asked us to determine to what extent (1) performance goals and 

measures have been established for these programs and (2) the agencies 

responsible for these programs have established adequate procedures for 

overseeing program implementation and assuring laws and regulations are 

followed. 

To determine the extent to which performance goals have been

established for these programs, we conducted a review of program laws, 

guidance, and performance documents.3

 To obtain additional information 

about the performance goals and measures and determine the extent that

the agencies responsible for these programs have established adequate 

procedures for overseeing program implementation and assuring that laws 

and regulations are followed, we reviewed agency policies and guidance, 

and interviewed agency officials at Education and the Committee for 

Purchase. We also met with officials of the two central nonprofit agencies

(NIB and NISH) that assist the Committee for Purchase in performing its 

oversight responsibilities for JWOD. To supplement the overall program 

information, we reviewed each of these programs at the local level in four 

states—Arizona, Kansas, New York, and North Carolina—and analyzed

documentation (e.g., program guidance, monitoring protocols, etc.) to 

ascertain how these programs were administered and monitored. We 

selected these four states based on factors such as whether they had all 

four programs operating in the state, geographic diversity, and whether 

the states’ Vocational Rehabilitation (VR) programs had a separate blind 

program (about half of all states have two agencies; one for the general VR

program and one for the blind program).4

 We visited a total of 4 PWI 

projects, 4 Supported Employment State Grants recipients, 7 Randolph-

 2

NISH was formerly known as the National Industries for the Severely Handicapped.

3

The Government Performance and Results Act of 1993 (GPRA) requires federal executive 

branch agencies such as the Department of Education to set goals, measure their 

performance, and report on their accomplishments. Agencies are required to develop

annual performance plans that use performance measurement to reinforce the connection

between the long-term strategic goals outlined in their strategic plans and the day-to-day

activities of their managers and staff. 

4

State VR programs provide assistance to individuals with disabilities and are overseen by

the Department of Education.

Page 2 GAO-07-236 Federal Disability Assistance
Sheppard vendors, and 13 JWOD nonprofit agencies. We reviewed 

available audit reports on the state-operated Randolph-Sheppard program 

for the states we visited and for other states. We also reviewed other 

available audit reports for JWOD nonprofit agencies and PWI grantees. 

Finally, we interviewed officials of agencies engaged in disability research 

and advocacy at the national level including the Council of State 

Administrators of Vocational Rehabilitation, National Council on 

Disability, and the National Council of State Agencies for the Blind. 

(App. I contains a more detailed discussion of our scope and 

methodology.) We conducted our work between March 2006 and 

December 2006 in accordance with generally accepted government 

auditing standards. 

Three of the four programs we reviewed had federal goals. Currently, no 

formal federal performance goals exist for the Randolph-Sheppard 

program, but two of the four states we visited had established their own 

performance goals, such as increasing the number of participating 

licensed vendors and vending facilities. Education officials told us they are 

developing federal goals and should complete them by April 2007. 

Education has a goal for the Supported Employment State Grants 

program, which is for individuals who have significant disabilities to 

achieve high quality employment, but it cannot fully assess this program’s 

performance because these grant funds are mixed with other funding 

sources to provide supported employment services; which is common in 

such situations. The Projects with Industry program has a performance 

goal that is consistent with the mission of the program. The program’s goal 

is to create and expand job opportunities for individuals with disabilities 

in the competitive labor market by engaging business and industry. The 

program has had mixed success in meeting its targets for this goal. For 

example, the program did not meet one target with regard to the 

percentage of individuals served who were placed into competitive 

employment between fiscal years 2003 and 2005. However, it consistently 

exceeded its target for the average increase in weekly earnings during the 

same period. For the JWOD program, the Committee for Purchase first 

developed performance goals and measures as part of its fiscal year 2005-

2007 strategic plan, but did not include a key component—performance 

targets—necessary for assessing performance. The Committee for 

Purchase has since revised its performance management system and 

established some performance targets, but cannot yet report progress 

toward its goals. Measures under the revised system have some 

limitations, such as not being clearly defined or being difficult to measure. 

Results in Brief 

Page 3 GAO-07-236 Federal Disability Assistance
Education and the Committee for Purchase’s oversight for the programs 

they are responsible for has been uneven. Education has established 

procedures for the PWI and the Supported Employment State Grants 

programs that, if consistently followed, should provide reasonable 

assurance that the programs are in compliance with applicable laws and

regulations. For example, Education told us they conduct quarterly 

monitoring calls with all PWI grantees, require grantees to submit annual 

reports on project activities and performance, and conduct some on-site 

reviews. Oversight of the Supported Employment State Grants program is 

accomplished as part of the ongoing monitoring of state Vocational 

Rehabilitation programs and includes examining state VR program plans 

and required data reports. In the four states visited, we found that each of 

these states had its own accountability procedures for ensuring that VR 

grant funds, including Supported Employment State Grants funds, were 

being used in accordance with federal laws and regulations. Concerning 

the Randolph-Sheppard program, however, Education relies heavily on 

self-reported data for its monitoring and does not routinely analyze or 

report the data it collects. The agency has also provided little guidance to 

states to ensure compliance with laws or consistent interpretation of 

program requirements. For example, Education has not provided clear 

guidance or policies regarding when federal agencies may charge 

commissions or fees to licensed vendors as a condition of operating a

vending machine on federal property. We found that licensed vendors are 

paying commissions or fees in some locations but not in others and the 

federal agency had not obtained approval from Education. With regard to 

JWOD, the Committee for Purchase does perform some compliance 

monitoring for its participating nonprofit agencies. However, the majority 

of the compliance visits are performed by the two central nonprofit 

agencies that must also represent the interests of the JWOD nonprofit 

agencies they oversee. This arrangement, as well as the fact that they 

receive a percentage of the total value of contracts from the JWOD 

nonprofit agencies, raises questions about their independence and gives 

them little incentive to identify instances of noncompliance that could 

result in the member JWOD nonprofit losing its contract. 

We are making recommendations to the Secretary of Education and to the

Chairperson of the Committee for Purchase aimed at improving 

performance management and oversight of the Randolph-Sheppard and 

JWOD programs, respectively. In its comments on a draft of this report, 

both Education and the Committee for Purchase generally agreed with our 

recommendations and provided information on actions they were taking 

or planning to take to enhance performance management and oversight of 

their respective programs. 

Page 4 GAO-07-236 Federal Disability Assistance
Over the years, Congress has established many employment-related 

programs to help people with disabilities obtain jobs. Four of these 

programs, PWI, Supported Employment State Grants, Randolph-Sheppard, 

and JWOD, illustrate several different approaches taken by Congress to 

create more employment opportunities for people with severe 

disabilities—from providing job training and support to enabling 

individuals to run businesses. Congress created two of the four programs 

(PWI and Supported Employment State Grants) in the 1970s and the other 

two (Randolph-Sheppard and JWOD) in the 1930s.

PWI was established in 1978,5

 and is a discretionary grant program that 

provides financial assistance for up to 5 years to organizations to assist 

individuals with disabilities in obtaining competitive employment.6

 

However, according to Education officials, recent grants have been 

awarded for 3-year periods. Grantees of the PWI program include 

community rehabilitation program providers, employers, labor unions, 

nonprofit agencies or organizations, trade associations, and others. The 

purposes of the PWI program are to (1) create and expand job and career

opportunities for individuals with disabilities in the competitive labor 

market by engaging private industry as partners in the rehabilitation 

process, (2) identify competitive job and career opportunities and the 

skills needed to perform these jobs, (3) create practical settings for job 

readiness and job training programs, and (4) provide job placements and 

career advancements. PWI grantees must establish business advisory 

councils (BAC) comprised of representatives of private industry, 

organized labor, and individuals with disabilities and their representatives, 

and others. BACs are required, among other things, to identify jobs and 

careers available in the community, the skills necessary to perform them, 

and prescribe appropriate training and job placement programs. Seventynine grantees received about $22 million in fiscal year 2005 and served 

more than 10,000 individuals with significant disabilities. 

Background 

Projects with Industry 

 5

Pub. L. No. 95-602 (1978); 29 U.S.C. § 795. 

6

Competitive employment is any full- or part-time job that pays at least the federal 

minimum hourly wage and provides a work setting typically found in the community in 

which individuals with disabilities interact with non-disabled individuals, other than nondisabled individuals who are providing services to them, to the same extent that nondisabled individuals in comparable positions interact with other persons. 

Page 5 GAO-07-236 Federal Disability Assistance
The Department of Education is responsible for administering and 

overseeing PWI and is required to: 

• Conduct annual on-site compliance reviews—Education’s primary 

means of verifying the accuracy of the information grantees 

submit—of at least 15 percent of grant recipients, chosen at 

random. 

• Submit an annual report to Congress that analyzes the extent to 

which the individual grant recipients have complied with the 

evaluation standards. For example, the project must serve 

individuals with disabilities that impair their capacity to obtain 

competitive employment. In selecting persons to receive services, 

priority must be given to individuals with significant disabilities. 

• Have a performance reporting system that grantees can use to 

routinely submit program data that evaluates the grantees’ progress 

in achieving the stated objectives, the effectiveness of the project in 

meeting the purposes of the program, and the effect of the project 

on its participants. 

Supported Employment 

State Grants 

Established in 1978,7

 the Supported Employment State Grants program 

provides funds to states and is designed to assist states in developing 

collaborative programs with appropriate organizations to provide 

supported employment services to individuals with the most severe 

disabilities who require these services to enter or retain competitive 

employment. Supported Employment State Grants funded services include 

a wide array of employment-related activities ranging from intensive onthe-job skills training to discrete post-employment services such as job 

station redesign or repair and maintenance of technology to help them 

perform job functions, generally for up to 18 months after job placement.

In fiscal year 2005, the grant program was funded at approximately 

$37 million.8

 7

Pub. L. No. 95-602 (1978); 29 U.S.C. §§ 795g-795n. 

8

States do not have a matching requirement for federal funds to receive this grant. 

Page 6 GAO-07-236 Federal Disability Assistance
The Supported Employment State Grants program is an integrated 

component of state VR programs, which are also overseen by Education.9

Title I of the Rehabilitation Act of 1973 authorizes a federal-state VR 

program to provide services to persons with disabilities so that they may 

prepare and engage in meaningful employment.10 Education provided 

$2.6 billion in fiscal year 2005 in VR grants to the states and territories 

based on a formula that considers the state’s population and per capita 

income.11 Each state and territory designates a single VR agency to 

administer the VR program, except where state law authorizes a separate

agency to administer VR services for individuals who are blind. State VR 

agencies provide services to individuals in 22 service categories, such as 

vocational counseling and guidance, job placement assistance, on-the-job

supports, college or university training, rehabilitation technology, and 

interpreter services. State VR agencies that determine they will not be able

to serve all eligible individuals who apply for services must develop 

criteria for prioritizing services to individuals with the most significant 

disabilities. Education reported that, as of fiscal year 2006, 40 of the 80 

state VR agencies had such an order of selection.

Oversight for Supported Employment State Grants is conducted as part of

oversight of state VR programs, and Education is required to:

• conduct annual reviews of state VR programs that include collecting 

and reporting information on budget and financial management 

data, and an analysis of program performance, including relative 

state performance, based on the standards and indicators; and 

• conduct periodic on-site monitoring of state VR programs. 

 9

In this report, the term state VR programs refers to programs or agencies in the 50 states, 

the District of Columbia, and the territories of American Samoa, Guam, Northern Marianas

Islands, Puerto Rico, and the Virgin Islands. 

10This program was most recently reauthorized as part of the Workforce Investment Act of

1998. 

11The act generally requires states to match federal funds at a ratio of 78.7 percent federal 

to 21.3 percent state dollars. 

Page 7 GAO-07-236 Federal Disability Assistance
The Randolph-Sheppard program12 was created in 1936 to provide blind 

persons with gainful employment, enlarge their economic opportunities, 

and encourage their self-support.13 While Randolph-Sheppard is under the 

authority of Education, the states are primarily responsible for operating 

their programs, and every state except Wyoming has established a vendor 

program. Each state that has a Randolph-Sheppard program is required to

have a state licensing agency (SLA), under the auspices of the state VR 

program and approved by Education, to operate the program, including 

the authority to promulgate rules and regulations that govern the program. 

The SLAs are responsible for training, licensing, and placing people who 

are blind as operators of vending facilities (machines, snack bars, and 

cafeterias) located on federal and other properties. In addition, SLAs must 

annually submit information about their Randolph-Sheppard programs to 

Education, including information on the number of applicants and the 

number accepted, the number of vending facilities and vendors, and the 

total amount of vendor earnings. 

Randolph-Sheppard 

In fiscal year 2005, SLAs spent about $37 million in federal and state VR 

grant funds to help operate and support the program. In addition to VR 

funds, some states fund the program through optional set-asides from 

licensed vendors, which are a percentage of their revenues, and through 

the profits from vending machines located on federal properties that are 

not operated by licensed vendors. State funds are also used to operate the 

program. In total, more than $76 million were used to operate and support 

the Randolph-Sheppard program nationwide in fiscal year 2005. 

In fiscal year 2005, the Randolph-Sheppard program generated 

$661.3 million in total gross income and the average annual earnings of 

vendors was $43,584. Over a 5-year period (fiscal year 2001 through fiscal 

year 2005), the number of vending facilities have been in decline 

nationwide, decreasing from 3,193 to 3,080. Over the same period, the 

number of vendors decreased annually except in fiscal year 2005, as 

shown in figure 1. 

 12In the four states we visited, Randolph-Sheppard is called the Business Enterprise

Program. 

13Randolph-Sheppard Act, ch. 638, 49 Stat. 1559 (1936) (codified at 20 U.S.C. §§ 107, 107a107f). 

Page 8 GAO-07-236 Federal Disability Assistance
Figure 1: Number of Vendors in Program, Fiscal Years 2001-2005 

2200

2300

2,400

2,500

2,600

2,700

2,800

Number of vendors

Source: Department of Education.

2001 2002 2003 2004 2005

2,712

2,564

2,529

2,631

2,681

While states are responsible for operating their programs, among other 

things, Education is required to: 

• approve applications from a state’s VR agency to serve as the SLA, 

and approve the rules and regulations the SLA promulgates to 

implement the Randolph-Sheppard Act; 

• conduct periodic evaluations of the program to determine whether 

the program is being used to its maximum potential; and 

• convene arbitration panels and pay for arbitration to resolve vendor 

and SLA disputes. 

Javits-Wagner-O’Day Established in 1938,14 JWOD is a federal procurement set-aside program 

designed to increase employment and training opportunities for persons 

 14Wagner-O’Day Act, ch. 697, 52 Stat. 1196 (1938) (codified at 41 U.S.C. §§ 46-48). 

Page 9 GAO-07-236 Federal Disability Assistance
who are blind or have other severe disabilities.15 Through this program, the 

government purchases commodities and services from nonprofit agencies

employing workers who are blind or have severe disabilities. According to 

Committee for Purchase officials, in fiscal year 2006, federal procurement 

expenditures for goods and services provided by JWOD program suppliers 

totaled about $2.3 billion, and provided employment for about 

48,000 people who are blind or have severe disabilities at more than 

600 participating JWOD nonprofit agencies. The types of employment 

opportunities range from working in food service or providing janitorial 

services in federal office buildings to producing and/or assembling boxes 

and office supplies such as pens, notepads, file folders, and other goods.

For fiscal year 2005, Committee for Purchase officials reported that JWOD 

workers earned an average of $9.49 per hour. 

The Committee for Purchase, which administers the program, received 

about $5 million in federal funds in fiscal year 2005 to support the 

activities of a 15-member, presidentially appointed board and 29 full-time 

program staff, including managing the JWOD procurement list.16 The 

Committee for Purchase is required by law to designate one or more 

central nonprofit agencies to facilitate the distribution of federal 

procurement contracts among qualified nonprofit agencies, and has 

designated two agencies for this purpose: NIB, which represents member 

nonprofit agencies employing individuals who are blind, and NISH, which 

represents its member nonprofit agencies that employ individuals with 

other severe disabilities.

 15A blind person is defined as a person who has been determined to have (1) not more than

20/200 central visual acuity in the better eye with correcting lenses or (2) an equally 

disabling loss of the visual field as evidenced by a limitation to the field vision in the better 

eye to such a degree that its widest diameter subtends an angle of no greater than 

20 degrees. A person with a severe disability, other than a blind person, is any person who 

has a severe physical or mental impairment (a residual, limiting condition resulting from an

injury, disease, or congenital defect) that so limits the person’s functional capabilities 

(mobility, communication, self-care, self-direction, work tolerance or work skills) that the

individual is currently unable to engage in normal competitive employment. 41 C.F.R. 

§ 51-1.3. 

16The Committee for Purchase is responsible for publishing a procurement list of the 

commodities produced by any qualified nonprofit agency for the blind or by any qualified 

nonprofit agency for the severely disabled and the services provided by any such agency,

which the Committee for Purchase determines are suitable for procurement by the 

government under JWOD. The Committee for Purchase determines the fair market price of

commodities and services that are contained on the procurement list and offered for sale to

the government by any qualified JWOD agency. 

Page 10 GAO-07-236 Federal Disability Assistance
In addition to its duties related to establishing and maintaining a 

procurement list of goods and services that must be purchased through 

qualified JWOD suppliers, the Committee for Purchase is required to: 

• establish rules, regulations, and policies to carry out the purposes of 

the JWOD program, and to provide that nonprofit agencies 

employing individuals who are blind have priority in obtaining

JWOD contracts; 

• monitor nonprofit agency compliance with Committee for Purchase 

regulations and procedures; 

• inform federal agencies about the JWOD program and encourage 

their participation, and, to the extent possible, monitor federal 

agencies’ compliance with JWOD requirements; and 

• study and evaluate its activities on a continual basis to ensure the 

effective and efficient administration of the JWOD Act. 

The Committee for Purchase has also established regulations that require 

the two central nonprofit agencies (NIB and NISH) to evaluate the 

qualifications and capabilities of nonprofit agencies that apply for 

contracts and provide pertinent data concerning the JWOD nonprofit 

agencies, such as their status as qualified nonprofit agencies, and their 

manufacturing or service capabilities. Additionally, NIB and NISH are to 

monitor and inspect the activities of participating nonprofit agencies to 

ensure compliance with the JWOD Act and appropriate regulations. For 

example, to maintain its status as a qualified nonprofit agency organized 

for the purposes of the JWOD program, an agency must employ persons 

who are blind or have severe disabilities to perform at least 75 percent of 

the work-hours of direct labor during the fiscal year to furnish such 

commodities or services (whether or not the commodities or services are 

procured under the JWOD Act). 

The Committee for Purchase’s regulations require that each nonprofit 

agency maintain employment files for persons with severe disabilities 

participating in the JWOD Program. Each file must contain either a 

certification by a state or local government entity or a written report 

signed by a licensed physician, psychiatrist, or qualified psychologist, 

reflecting the nature and extent of a participant’s disability or disabilities 

that qualify as severe. These reports must also state whether an individual

with severe disabilities is capable of engaging in normal competitive 

Page 11 GAO-07-236 Federal Disability Assistance
employment and be signed by persons qualified to evaluate their work 

potential, interests, aptitudes, and abilities.17 

Federal performance goals and measures have been established for three 

of the four programs we reviewed. Education has not established 

performance goals and measures for the Randolph-Sheppard program, 

although two of the four states that we visited had their own goals and 

measures. Education has one goal for the Supported Employment State 

Grants program, but the goal only provides an indirect measure of the 

program’s performance because the data also include individuals with 

significant disabilities who receive supported employment services funded 

under state VR programs. Education has established a performance goal 

for PWI, which is consistent with the purpose of the program. Finally, for 

the JWOD program, the Committee for Purchase recently revised its 

performance goals and established some targets. 

Education does not have GPRA performance goals for the RandolphSheppard program, and neither the Randolph-Sheppard Act nor its 

implementing regulations require them. According to Education officials, 

no formal federal performance goals or measures currently exist for the 

Randolph-Sheppard program, but they are under development and 

expected to be completed by April 2007. Although not specifically required

by law, Education does collect some information related to program 

performance from the states. For example, Education collects information 

on total vendor income, number of facilities, and vendors. Education also 

collects information on the numbers of individuals who are blind or have 

disabilities who are employed by vendors, although there is no 

requirement for vendors to employ workers who have disabilities. 

Three of the Four 

Programs Have 

Established Goals and 

Measures 

Education Has Not 

Established Federal Goals 

for Randolph-Sheppard 

States may develop performance goals for their Randolph-Sheppard 

programs, and two (Arizona and Kansas) of the four states we visited had

established performance goals. Arizona’s goals were to increase the 

number of licensed vendors and vending facilities. In fiscal year 2005, the 

state set a target of 32 vendors and five new facilities. However, Arizona 

did not meet these targets and had 30 licensed vendors and added one new 

facility. Kansas’ fiscal year 2005 goal was that at least 90 percent of the 

licensed vendors maintain or increase their level of income from the prior 

 1741 C.F.R. § 51-4.3. 

Page 12 GAO-07-236 Federal Disability Assistance
year, and the state reported that this goal had been exceeded in each of 

the past 3 fiscal years. According to program officials in New York and 

North Carolina, no state goals were established for their RandolphSheppard programs. In the four states we visited, nearly $10 million, 

including more than $7 million in federal and state funds, were used to 

support operations for about 215 licensed vendors, as shown in table 1. 

Table 1: Federal and State Funds, Other Funding Sources, Total Funds, and Funds per Vendor for Four State RandolphSheppard Programs in Fiscal Year 2005 

State 

Federal and 

state funds

Other

funding sourcesa

Total

funds

Vendors

 (staff years) 

Funds

per vendor

Arizona $1,681,418 $ 790,531 $2,471,949 29.7 $83,231

Kansas 517,202 165,732 682,934 15 45,529

New York 2,705,026 848,736 3,553,762 86.5 41,084

North Carolina 2,478,909 711,558 3,190,467 82.3 38,766

Total $7,382,555 $ 2,516,557 $9,899,112 213.5 $46,366

Sources: RSA-15 reports submitted by officials of the Arizona, Kansas, New York, and North Carolina Business Enterprise Programs. 

a

Other funding sources are vending machine income (federal and non-federal), and a percentage of 

net proceeds from licensed vendors. 

In these four states, we also interviewed seven licensed vendors who 

operated businesses that ranged from full-service cafeterias to small 

convenience stores or canteens. We found that all of the licensed vendors 

we met with worked full-time and most earned incomes that provided an 

income that made them relatively self-sufficient. However, not all licensed

vendors nationwide receive incomes that allow them to support 

themselves and their incomes may be subsidized through program 

revenues generated by other vendors. Two states we visited were taking 

steps to increase vendors’ income by consolidating facilities. Regardless of 

their financial status, three of the seven licensed vendors we interviewed 

continued to receive financial benefits from other federal disability 

assistance programs, such as Social Security Disability Insurance. In 

addition, at least 6 of the 7 vendors employed fewer than 10 workers, most 

of whom were not blind or did not have severe disabilities. However, some 

of the vendors we interviewed told us that they are interested in ways to 

reach out to and employ more workers who are blind or have severe 

disabilities. Further, states we visited told us about other program 

challenges, such as a decline in customers as a result of increased security

in federal buildings and consolidation of unprofitable facilities that 

reduced the number of opportunities available to vendors. 

Page 13 GAO-07-236 Federal Disability Assistance
Education has a GPRA goal for the Supported Employment State Grants 

program that the department uses to indirectly measure the program’s 

performance. According to program officials, Education has not sought 

information that isolates the performance of federally-funded Supported 

Employment State Grants because they are used together with state and 

other federal funds to provide supported employment services, as is often 

the case when funds from different sources are used to achieve an 

outcome. Officials told us a separate measure for the Supported 

Employment State Grants program would be an artificial distinction. The 

performance goal is for individuals who have significant disabilities to 

achieve high quality employment. For this goal, Education only includes 

individuals with significant disabilities who have a goal of supported 

employment, that is, achieving competitive employment with support 

services such as rehabilitation technology or on-the-job supports. The 

measure is the percentage of individuals who achieve competitive 

employment, which they define as making minimum wage or higher, but 

not less than the wages paid to workers without disabilities performing 

similar work, and working alongside workers without disabilities in an 

integrated setting. 

During fiscal years 2003 and 2004, Education exceeded its performance 

target for placing Supported Employment State Grants program 

participants in competitive employment. For fiscal year 2005, Education 

increased the performance target to 93 percent and achieved 92.6 percent,

as shown in table 2. 

Table 2: Supported Employment State Grants Program Goal and Actual Performance, Fiscal Years 2003 through 2005 

Performance 

Goal: Individuals with significant disabilities with 

a supported employment goal will achieve highquality employment. 2003 2004 2005

Performance measure Target Actual Target Actual Target Actual

Percentage of individuals with a supported 

employment goal who achieve a competitive

employment outcome. 

77.8% 92.7% 78% 92.8% 93% 92.6%

Source: Department of Education. 

Education has established a GPRA performance goal that includes four 

measures for the PWI program. The goal of the PWI program is to create 

and expand job opportunities for people with disabilities in the 

competitive labor market by engaging business and industry in the 

Education Has a 

Supported Employment 

State Grants Program Goal 

That Indirectly Measures 

Performance 

Education Has Established 

One Federal Performance 

Goal for the PWI Program 

Page 14 GAO-07-236 Federal Disability Assistance
rehabilitation process. The four performance measures are consistent with 

the program’s goal. For example, one measure is the percentage of 

individuals served by the program who were placed into competitive 

employment. Another measure, cost per placement, was only recently 

established for fiscal year 2006 and performance data are not yet available.

In recent years, Education has had mixed success in meeting the GPRA 

targets. For example, in fiscal years 2003 to 2005, the PWI program did not 

meet its target of increasing the percentage of individuals who were 

placed into competitive employment. However, it consistently exceeded 

its target for increased earnings over the same period, as shown in table 3. 

Table 3: PWI Performance Goal and Actual Performance, Fiscal Years 2003 through 2005 

Performance 

Goal: Create and expand job opportunities in the 

competitive labor market by engaging the 

participation of business and industry in the 

rehabilitation process. 2003 2004 2005

Performance measures Target Actual Target Actual Target Actual

Percentage of individuals served by the program who 

were placed into competitive employmenta

62.4% 54.2% 62.7% 61.5% 63% 51.9%

Percentage of previously unemployed individuals 

served who were placed into competitive employmenta

63% 54% 64% 65.5% 65% 62.4%

Average increase in weekly earnings $231 $242 $233 $247 $238 $253

Cost per placement (federal grant funds only)

b

NAcNAcNAc$3,139dNAc$3,014d

Source: Department of Education. 

a

An evaluation of the PWI program, published in 2003, raised some doubts about the reporting on the 

percentage of individuals placed in competitive employment. 

b

Cost per placement will become a GPRA indicator in fiscal year 2006. 

c

Not available. 

d

Data are being used to develop a baseline for fiscal year 2006 performance. 

Education has revised its GPRA performance measures for the PWI 

program for fiscal year 2006. Specifically, Education will begin to measure 

the percentage of PWI projects whose cost per placement is within a 

specified range, which has yet to be determined. The agency will also 

measure the percentage of all individuals who exit the program and are 

placed in competitive employment. According to Education officials, this

measure was added in response to recommendations by the Office of 

Management and Budget and will allow more accurate comparisons with

other job training programs throughout the government. 

Page 15 GAO-07-236 Federal Disability Assistance
We visited four PWI grantees in the four states and found that these 

projects set goals that are consistent with the goals of the PWI program, 

such as placing people in competitive employment. For example, one PWI 

grantee in Kansas is serving individuals with all types of disabilities ages 

16 and older. One goal of the project is to place 75 percent of the people 

they serve each year in competitive employment, which is higher than the 

GPRA target set by Education. According to agency officials, clients are 

being placed in jobs such as call centers and other customer service 

positions, earning average salaries of $9.25 to $10.00 per hour. In another 

example, one PWI grantee in New York has a goal to transition youth from

school to work and targets its services to individuals ages 16 to 25 with a 

mental, physical, or emotional disability. One of the goals of the project is

to place about 67 percent of the people served in jobs over 3 years. 

According to the grantee, a successful outcome in the program is 

competitive employment in at least a part-time position paying at least the 

federal minimum wage, and continued employment for at least 6 months. 

The PWI projects in Kansas and New York just completed the first year of 

operations. 

The Committee for

Purchase Recently 

Updated Its Strategic Plan 

for the JWOD Program; 

Progress toward Goals Is 

Not Yet Known 

For the first time, the Committee for Purchase developed performance 

goals and measures for the JWOD program in its fiscal year 2005-2007

strategic plan and updated this plan in October 2006, but it has not yet 

reported progress toward meeting these goals. While JWOD’s enabling 

legislation and regulations do not require goals, the strategic plan includes 

five performance goals and a number of measures for each of these goals.18

The current strategic plan includes some performance measures and 

targets, but some of the measures that are more qualitative in nature do 

not include targets, and it is unclear how JWOD will measure progress in 

these areas. In keeping with the overall mission of the JWOD program, the 

goals are aimed at increasing the number of job opportunities for people 

who are blind or have severe disabilities. One of the plan’s five goals is to 

expand employment opportunities. The other four goals include increasing 

customer satisfaction (JWOD customers are federal agencies), improving 

efficiency of operations, expanding program support and developing new 

markets for its products and services. However, these goals do not 

 18Although the JWOD Act does not require GPRA performance goals and measures, the

Committee for Purchase has determined that the JWOD program is covered by federal 

strategic planning requirements. 

Page 16 GAO-07-236 Federal Disability Assistance
specifically address one part of the program’s mission, which is to increase 

training opportunities.19 

Furthermore, some of the performance measures are not clearly defined

or may be difficult to measure, thus making it difficult to assess 

performance. For example, there are several measures that involve using

“milestone tracking” although the milestones are not provided. One of 

these measures will track progress toward annually updating and 

implementing a plan to address communication and information sharing 

with and among stakeholders. Further, JWOD has over 30 performance 

measures, which may make it difficult to identify performance problems. 

As we discussed in our June 1996 guide on implementing GPRA,20

performance measures should be limited to the vital few. Limiting 

measures to core program activities enables managers and other 

stakeholders to assess accomplishments and make decisions without 

having an excess of data that could obscure rather than clarify 

performance issues.21 The JWOD performance goals and examples of 

measures are shown in table 4. All of the JWOD performance measures are 

listed in appendix II. 

 1941 C.F.R. § 51-1.1(a). 

20GAO, Executive Guide: Effectively Implementing the Government Performance and

Results Act, GAO/GGD-96-118 (Washington, D.C.: June 1996). 

21GAO, Tax Administration: IRS Needs to Further Refine Its Tax Filing Season 

Performance Measures, GAO-03-143 (Washington, D.C.: Nov. 22, 2002). 

Page 17 GAO-07-236 Federal Disability Assistance
Table 4: JWOD Performance Goals and Examples of Performance Measures, Fiscal Years 2007-2009 

Performance goals Examples of performance measures 

Continue to expand employment opportunities for people 

who are blind or have other severe disabilities under the 

JWOD program, including wage progression, benefits, 

upward mobility, and personal job satisfaction. 

• Percentage increase in direct labor hours performed by people who are 

blind or have other severe disabilities on JWOD products and services. 

• Percentage increase in the number of people who are blind or have 

other severe disabilities employed in direct labor positions on JWOD

products/services. 

Partner with federal customers to increase customer 

satisfaction and loyalty, so that the JWOD program 

becomes their preferred source for products and 

services. 

• Federal agency scorecard that evaluates the level of satisfaction with

JWOD products, services, and/or customer experience among key 

federal agencies, using a stoplight or similar summary format. 

• Increased customer satisfaction with quality, timeliness, and price, based 

on customer surveys and/or alternative qualitative research (e.g., focus 

groups). 

Improve efficiency and effectiveness of the JWOD

program by streamlining and automating processes and 

procedures, and improving communication, while 

continuing to ensure program integrity. 

• Reduction in the cycle time for the addition of a new JWOD product or 

service to the procurement list. 

• Milestone tracking of evaluation of commercial distribution processes, 

including staff resources and financial resources. 

Expand awareness, understanding, and preference for 

the JWOD program within the public, Congress, federal 

agencies, the disability community, and other JWOD

stakeholders through effective communication and 

information sharing. 

• Milestone tracking of annual update and implementation of a plan that 

addresses communication and information sharing with and among both 

internal and external stakeholders. 

• Among members of congressional committees or subcommittees with 

oversight or other significance for the JWOD program, number who have 

been educated about the JWOD program and/or are actively engaged 

with their local JWOD-participating nonprofit agency(ies). 

Strategically develop new markets and expand existing 

markets in which the JWOD program can provide best 

value products and services to federal customers in 

order to expand employment opportunities that meet the 

needs of people who are blind or have other severe 

disabilities. 

• Milestone tracking of establishment and implementation of a program 

market development plan that addresses existing customers, existing 

products/services, new customers, and new products/services. 

• Percent increase in the employment of people who are blind or have 

other severe disabilities under the JWOD program, measured in (1) 

actual direct labor hours, (2) actual jobs, (3) projected direct labor hours 

on procurement list additions, and (4) projected jobs on procurement list 

additions by key market segment. 

Source: Final FY 2007-2009 Strategic Plan for the Javits-Wagner-O’Day (JWOD) Program, Committee for Purchase from People Who 

Are Blind or Severely Disabled, October 16, 2006. 

Education and the Committee for Purchase engage in a number of 

oversight activities for the programs they are responsible for, but their 

efforts to ensure compliance with applicable laws and regulations have 

been uneven, and overall have provided little assurance of program 

accountability for two of the four programs reviewed. Specifically, 

Education has established oversight procedures for the PWI and the 

Supported Employment State Grants programs that, if consistently 

followed, should provide reasonable assurance of compliance with 

relevant laws and regulations. The agency is just beginning to conduct onsite monitoring of PWI grantees that may be sufficient for testing the 

Uneven Federal 

Oversight Provides 

Little Assurance of 

Accountability for 

Two Programs

Page 18 GAO-07-236 Federal Disability Assistance
accuracy of the information used to monitor compliance. Education’s 

oversight of these two programs has generally been more active than its 

oversight of the Randolph-Sheppard program. Education relies primarily 

on self-reported data for its monitoring of the Randolph-Sheppard program 

and does not routinely analyze or report the data it collects. Finally, the 

Committee for Purchase has established procedures for monitoring and 

overseeing the JWOD program, but has prescribed regulations that 

delegate most of the responsibility for carrying out these procedures to 

two central nonprofit agencies that are also responsible for representing 

the interests of the JWOD nonprofit agencies they monitor, raising 

questions about independence. Furthermore, there are no procedures in 

place for the Committee for Purchase to address instances where the 

central nonprofit agencies fail to carry out their oversight responsibilities. 

Education Performs 

Various PWI Oversight 

Activities, and On-site 

Monitoring Is Improving 

Education regularly performs a number of oversight activities to ensure 

that PWI grantees are making progress toward project goals and 

complying with applicable laws and regulations. Specifically, program 

specialists told us they conduct quarterly monitoring calls with all PWI 

grantees in which they ask a series of 30 questions that help them to 

identify and proactively resolve problems with individual projects. The 

questions address several areas, including progress toward meeting goals, 

activities of the BACs, interaction with the state VR agency, and fiscal 

management. Further, Education requires that PWI grantees submit annual

reports that include detailed information about project activities and 

performance, and informs grantees of this requirement as part of the 

application process. Education uses the project information it receives 

from grantees to identify those grantees that may be at risk of being out of 

compliance with program requirements and to target these grantees for 

additional assistance or for on-site reviews. Education also relies on the 

data it receives from grantees to provide information about grantees’ 

performance in its annual reports to Congress.22

Although grantees are responsible for monitoring their own projects, 

Education is required to conduct random on-site reviews of 15 percent of 

 22By law, Education is required to develop standards for the annual review and evaluation

of a grant recipient’s project, which include a number of compliance indicators. These 

include, for example, the number of applicants and individuals eligible for a program, and

the number of significantly disabled people who ended their participation in the program,

became employed, and were still employed after 6 and 12 months. 

Page 19 GAO-07-236 Federal Disability Assistance
PWI grantees annually.23 On-site reviews are the primary means by which 

Education can assess the accuracy of the performance data submitted by 

grantees. Education conducted 11 of the 12 required on-site reviews in 

fiscal year 2006 and had scheduled the remaining review for November 

2006. However, it conducted only 3 of the 12 required for 2005, and 0 in

2004, and therefore did not have enough information to provide reasonable 

assurance of the accuracy of the data submitted by grantees in those 

years. Although each of the PWI grantees that we visited had procedures 

in place to review the data they submitted to Education, a research 

organization conducted an evaluation of the program that raised doubts 

about the accuracy of PWI data submitted by grantees in general.24

Specifically, reviewers found that about one-fifth of PWI grantees surveyed 

(19 out of 92) provided information on the number of persons placed in 

fiscal year 2001 that was inconsistent with the information they had 

submitted to Education.

Education is also required to submit an annual report to Congress 

analyzing the extent to which the individual grant recipients have 

complied with program evaluation standards.25 In fiscal years 2003, 2004, 

and 2005, Education has met this requirement by providing summaries of 

the extent to which grantees have met program performance targets in its 

Performance and Accountability Report to Congress. 

Education’s Oversight of 

Supported Employment Is 

Part of Overall VR 

Program Monitoring 

Efforts 

Education’s oversight of the Supported Employment State Grants program 

is integrated into its ongoing efforts to review and monitor state VR 

programs.26 During fiscal year 2006, Education revised its annual state plan

review protocols and prepared a draft on-site monitoring plan for the VR 

program.27 Annual reviews include examining each state’s VR program 

plans and other documentation, such as required annual data reports on 

 2329 U.S.C. § 795(f)(3)(A). 

24RTI International, Evaluation of the Projects with Industry Program, Final Report 

(Research Triangle Park, N.C.: 2003). 

2529 U.S.C. § 795(f)(5).

26For more information on Education’s oversight of state VR programs, see GAO, 

Vocational Rehabilitation: Better Measures and Monitoring Could Improve the

Performance of the VR Program, GAO-05-865 (Washington, D.C.: September 2005).

27The procedures were developed with input from national experts, state VR agency 

officials, State Rehabilitation Council members, VR consumer and advocacy groups, 

community partners and provider organizations and other key stakeholders.

Page 20 GAO-07-236 Federal Disability Assistance
VR customers, services, and outcomes; caseloads; and financial 

accountability and data reporting procedures. Education’s October 2006 

draft on-site monitoring protocols call for on-site reviews once every 

3 years and are designed to verify and supplement the information it 

receives from the states regarding program performance and compliance, 

and include reviewing case files and holding public hearings or other 

discussions with VR program consumers and advocates, as needed. 

Education has not yet conducted any on-site reviews using the revised 

protocols, but plans to conduct its first reviews beginning in fiscal year 

2007. Once fully implemented, the annual reviews and on-site monitoring, 

along with state-level activities, should offer reasonable assurance that the 

Supported Employment State Grants program is in compliance with 

applicable laws and regulations and the data that states submit to 

Education annually are accurate. 

In addition, we found that all four states we visited had their own 

accountability procedures for ensuring that VR grant funds, including 

Supported Employment State Grants funds, were being used in

accordance with federal laws and regulations. For example, the New York 

state VR agency has configured its automated information management 

system in a way that only authorizes payment for supported employment 

services to providers that have a contract to provide these services, at the 

contracted rates. In addition, three of the four states had adopted 

performance-based contracting systems, whereby vendors providing 

supported employment services, such as job coaching or training, are 

required to demonstrate progress toward required milestones in order to 

receive payment from the state agencies, and VR counselors monitor their 

progress on a weekly, biweekly, or monthly basis. 

Education Provides Little 

Oversight of the RandolphSheppard Program 

Education provides little oversight of the Randolph-Sheppard program. 

Despite being required to conduct periodic evaluations of the program and 

being responsible for approving states’ rules and regulations for 

implementing the Randolph-Sheppard Act,28 Education has no formal 

procedures for evaluating state programs. In addition to lacking 

procedures, Education has performed few on-site monitoring reviews of 

SLAs in recent years. According to agency officials, Education has 

performed five on-site monitoring reviews since the beginning of fiscal 

year 2005 and had performed no recent site visits in the four states that we 

 2820 U.S.C. § 107a and 34 C.F.R. §§ 395.4 - .5. 

Page 21 GAO-07-236 Federal Disability Assistance
visited. Education’s oversight activities primarily consist of collecting data

from states through annual reports from the SLAs that administer the 

program and providing requested technical assistance. Although the states 

report considerable information including earnings data; the number of 

vendors, facilities, individuals employed by vendors; types of facilities; 

costs; and sources of funding, Education does not test the accuracy of data 

that it requires states to report, nor does the agency routinely analyze the 

data to assess program performance and management. As a result, 

Education cannot assess trends in performance, identify possible best 

practices, or help states that may need assistance. Upon request, 

Education also provides technical assistance to SLAs. According to 

Education officials, technical assistance and guidance is regularly 

provided to SLAs through telephone calls and written correspondence,

including e-mails, with staff on specific questions. 

In its oversight role, Education has not provided clear guidance to states

on emerging issues that could have nationwide implications. Instead, 

Education responds to individual state concerns and convenes panels to

arbitrate disputes that SLAs are unable to resolve. As a result, states have

different policies regarding the permissibility of teaming agreements, 

which partner licensed vendors with commercial food operators in order 

to help manage larger food service operations at dining facilities at 

military bases. SLAs may have such agreements for various reasons, such 

as state program officials’ lack of expertise or licensed vendors’ 

inexperience running such facilities. In these cases, the licensed vendor 

generally does not operate the food service facilities, but rather manages 

some aspects of food service operations. For example, one of the states 

we visited (Kansas) had a teaming agreement. One of the states we visited 

(New York) does not currently allow teaming agreements, while another 

(Arizona) has no policy regarding teaming agreements. The fourth state, 

North Carolina, permits teaming agreements but does not currently have 

any as of June 2006. 

Although Education has noted the increasing use of teaming agreements, it 

has not issued guidance to the SLAs directly addressing whether these are 

in keeping with the spirit of the Randolph-Sheppard Act, or whether they 

should be subject to limitations, despite concerns expressed by states and 

others. For example, the California State Auditor found that by allowing 

teaming agreements, the SLA had inadequately protected the interests of 

the state and licensed vendors. The SLA had not (1) ensured that written 

contracts existed before beginning operations, (2) analyzed the investment 

and return on investment of the teaming agreement to the program and 

licensed vendors, (3) adequately reviewed the teaming agreements, or 

Page 22 GAO-07-236 Federal Disability Assistance
(4) ensured that the commercial food service operators were paying their 

fair share of program costs. In addition, the Georgia State Auditor 

identified some concerns about teaming agreements, including the failure 

to define the duties for participating licensed vendors, resulting in these 

vendors having little, if any, responsibility for the overall operation and 

success of subcontracted food services. Further, the auditor noted that the 

program is not ensuring that the commercial food service operators are 

making progress toward the program’s goal that licensed vendors 

eventually assume responsibility for operating the facility. 

Additionally, Education has not provided clear guidance or policies 

regarding when federal agencies may charge fees or commissions to 

licensed vendors as a condition of operating a vending facility on federal

property. The Randolph-Sheppard Act has been interpreted to prohibit 

commissions unless federal agencies obtain written approval from the 

Secretary of Education.29 We found that licensed vendors have paid 

commissions or fees in some locations but not in others and the federal

agencies had not obtained approval from Education. For example, in one

state we visited (Kansas), at least one licensed vendor was required to pay 

1.5 percent of total revenues to the U.S. Postal Service in exchange for 

permission to operate vending facilities on the agency’s properties. 

However, Education has not prohibited such practices or required the 

Postal Service or other federal agencies charging commissions to obtain 

written approval. Furthermore, officials in Kansas have chosen not to 

dispute it. According to agency officials, Education has never approved 

such a limitation and cannot routinely monitor state-level or vendorspecific business negotiations, but would intervene to bring the parties 

together in an attempt to resolve disputes or make clear the requirements 

of the Randolph-Sheppard Act. 

Although Education has exercised little oversight for this program, the 

four SLAs that we visited had certain procedures in place that should, if 

consistently operated along with other certain complementary processes 

and procedures such as management’s monitoring of performance over 

 29Under 20 U.S.C. § 107(b), any limitation on the placement or operation of a vending 

facility shall be fully justified in writing to the Secretary, who shall determine whether such 

limitation is justified. In 2005, an arbitration panel ruled that a 10-percent commission 

charged by the U.S. Postal Service to licensed vendors without authorization of the

Secretary of Education was a limitation not allowed under the law. The panel was 

convened by Education after it received a complaint and, as required by law, Education 

published a synopsis of the decision in the Federal Register. 70 Fed. Reg. 60803-04. 

Page 23 GAO-07-236 Federal Disability Assistance
time, help safeguard program assets. SLA officials obtained cash register 

receipts, daily reports on business activities, or monthly reports submitted 

by the vendors to review the financial operations for these programs. 

However, audits of programs in other states have reported certain issues 

relating to the accountability of state-operated programs under the 

Randolph-Sheppard Act. For example, the Michigan Auditor General 

reported that SLA staff did not comply with established equipment 

inventory control procedures for program equipment and could not 

account for equipment inventory, placing inventory at risk of 

misappropriation.30 Further, the California State Auditor reported that, 

among other things, the SLA has not followed up on missing financial 

reports from licensed vendors and has not been able to monitor licensed 

vendors’ financial problems properly. In addition, the auditor found that 

the SLA was not adequately pursuing past-due commissions owed to the 

program by private businesses operating vending machines on federal 

properties.31

Committee for Purchase 

Delegates Most Oversight 

Responsibilities for JWOD 

to Two Organizations That 

Represent the Interests of 

the Agencies They Oversee 

The Committee for Purchase has established procedures for monitoring 

and overseeing the JWOD program, but has delegated most of the 

responsibility for monitoring participating JWOD nonprofit agencies to 

two central nonprofit agencies. As of April 2006, NIB officials reported 

that they worked with 81 participating JWOD nonprofit agencies that 

employed individuals who are blind, and NISH officials reported that they 

worked with 552 JWOD nonprofit agencies that employed individuals with 

other severe disabilities.32 In particular, although the Committee for 

Purchase must approve the nonprofit agencies’ participation in the 

program, it relies on the central nonprofit agencies to certify that: 

• 75 percent or more of the direct labor hours under JWOD contracts 

are performed by individuals who are blind or have severe 

disabilities, and if not, that there is a suitable plan in place to bring 

this percentage up to the required level; 

 30Michigan Office of the Auditor General, Performance Audit, Michigan Commission for 

the Blind, Department of Labor and Economic Growth and Family Independence 

Agency, Report Number: 43-231-03 (October 2004). 

31California State Auditor, Department of Rehabilitation: Its Delay in Correcting Known

Weaknesses Has Limited the Success of the Business Enterprise Program for the Blind,

Report No. 2002-031 (September 2002).

32NISH was formerly called National Industries for the Severely Handicapped.

Page 24 GAO-07-236 Federal Disability Assistance
• agencies maintain required documentation for each of these 

individuals;

• agencies function as nonprofit entities serving individuals who are 

blind or have severe disabilities; 

• agencies have a required job placement program; and 

• agencies comply with applicable occupational safety and health 

standards. 

The Committee for Purchase requires that the JWOD nonprofit agencies

certify annually that they are in compliance with program requirements 

but does not routinely verify this information, relying instead on the 

central nonprofit agencies to do so. According to agency officials, the 

Committee for Purchase performs about 20 field visits annually, visiting up

to 3 agencies per visit, or about 60 of the more than 600 participating 

nonprofit agencies. At this rate, the Committee for Purchase is unable to 

satisfy its own requirements to perform on-site compliance reviews at 

each fully compliant participating nonprofit agency every 5 years. 

The Committee for Purchase’s regulations create at least two problems for 

NIB and NISH: the potential for a conflict of interest resulting from a lack 

of organizational independence as well as disincentives to perform their 

monitoring duties effectively. Specifically, these regulations require that 

NIB and NISH, on behalf of the Committee for Purchase, monitor the 

compliance of JWOD nonprofit agencies, but, at the same time, represent 

them in their dealings with the Committee for Purchase. Moreover, the 

regulations also permit NIB and NISH to charge a fee based on JWOD 

nonprofit agencies’ sales to the government that does not exceed the limit 

set by the Committee for Purchase, and require the nonprofit agencies to 

pay that fee in order to remain in good standing in the program. This 

system of compensation may create a disincentive for NIB and NISH to 

identify instances of noncompliance that could result in the JWOD 

nonprofit agency losing its contract, especially for those JWOD nonprofit 

agencies that are generating large volumes of JWOD sales. Finally, 

although the regulations and procedures provide for a number of duties 

that the central nonprofit agencies must perform, they do not specify 

actions the Committee for Purchase can take if the central nonprofit 

agencies fail to execute these duties.

NIB and NISH officials reported that they monitor JWOD nonprofit 

agencies’ compliance with relevant laws and regulations by conducting onPage 25 GAO-07-236 Federal Disability Assistance
site reviews of nonprofit agencies every 3 years,33 and require quarterly 

statistical reports from the agencies they oversee. The Committee for 

Purchase has established procedures for these reviews that require each

central nonprofit agency to use a standardized review sheet to assess 

whether the JWOD nonprofit agency is compliant in 11 different program 

areas, including the percentage of direct labor hours performed by 

individuals who are blind or have severe disabilities, documentation of an

employee’s disability, and an evaluation of whether or not the individual is

capable of competitive employment.34 The on-site reviews are the primary 

means for NIB and NISH to test the accuracy of the data that the JWOD 

nonprofit agencies submit, but the scope of the reviews may not be 

sufficient to provide reasonable assurance of the accuracy of all of the 

data. For example, NIB and NISH officials reported that they test the 

accuracy of the data for percentage of direct labor hours by reviewing a 

sample of case files, but they do not verify other data, such as job 

placement and upward mobility statistics. Further, they do not always 

report instances of noncompliance they find to the Committee for 

Purchase. 

In the states we visited, reports from NIB’s and NISH’s on-site reviews 

generally showed that the JWOD nonprofit agencies were in compliance 

with program requirements, and most files contained the required 

documentation. Eleven of 13 agencies that we visited provided

documentation of the results of their most recent on-site reviews showing 

they were in compliance. However, in our limited reviews of 137 case files 

at these 13 agencies, we found that 5 of 8 NISH agencies had at least 1 file 

that lacked the required medical documentation of a worker’s disability, 

and that 3 of these 8 NISH agencies had at least 1 file that lacked the 

required documentation on competitive employment. We also found that 

one of the five NIB agencies we visited had one case file that lacked the 

required medical documentation. In sum, 11 percent of the files we 

reviewed at the NIB and NISH agencies we visited lacked the required 

medical or competitive employment documentation. 

 33In 2005, NIB performed about 27 on-site reviews in 2005 and NISH performed about 180, 

according to agency officials.

34For individuals employed at NISH associated agencies, any individual who is capable of

competitive employment is not considered severely disabled, according to program 

regulations. See the Committee for Purchase’s Compliance Memorandum No. 7, “On-Site 

Compliance Reviews,” dated May 6, 1998.

Page 26 GAO-07-236 Federal Disability Assistance
A serious instance of noncompliance escaped detection by the responsible 

central nonprofit agency (NISH) and the Committee for Purchase. In this 

case, the National Center for the Employment of the Disabled (NCED) in 

El Paso, Texas, failed to use workers with severe disabilities to perform 

the required percentage of direct labor hours on its JWOD contracts, 

which were valued at over $200 million. Instead, NCED inflated its 

reported percentage by improperly including economically disadvantaged 

workers. The problems at NCED were detected not through routine 

monitoring, but rather through an anonymous tip to the Committee for 

Purchase, and resulted in as many as 1,144 JWOD jobs being lost to 

individuals who did not have severe disabilities during fiscal years 2004 

and 2005. The JWOD nonprofit agency took actions prescribed by the 

Committee for Purchase to come into compliance, including dividing the

agency’s operations into two different units—one for JWOD work and one 

for commercial activities—and the Committee for Purchase is satisfied 

with the actions taken. 

The definition of a severe disability in the law allows for differing 

interpretations, which may complicate efforts to ensure compliance for 

agencies that serve individuals who have severe disabilities. The statutory 

definition of blindness is fairly straightforward: a lack of visual acuity of 

not more than 20/200 in the better eye with correcting lenses or a limited 

field of vision of not more than 20 degrees. In contrast, the definition of a 

severe disability requires a diagnosis of a residual, physical or mental 

impairment that limits functioning in one of five areas (mobility, 

communication, self-care, self-direction, and work tolerance or work 

skills), and a determination that the impairment has rendered the 

individual unable to engage in normal competitive employment over an

extended period of time. Despite the fact that the definition is subject to 

interpretation, the Committee for Purchase has offered little additional 

guidance that would clarify when disabilities that may not normally be 

considered severe could be, such as the conditions under which a 

recovering alcoholic or a person with diabetes could be considered to 

have a severe disability. During our review of case files at 13 JWOD 

nonprofit agencies, we noted instances where it was unclear in the 

medical documentation that the disability was severe, such as a case in 

which the individual was diabetic, with no indicated symptoms, and 

another in which the individual was diagnosed as having an aggressive 

personality.

All four of these programs generally provide training and employment 

opportunities that might not otherwise be available for individuals who are Conclusions 

Page 27 GAO-07-236 Federal Disability Assistance
blind or have severe disabilities. However, two are hampered by 

weaknesses in performance management and program oversight that 

signal a need for stronger federal leadership. Absent federal goals for the

Randolph-Sheppard program and routine analyses and reports from 

Education on states’ program operations and performance, little is known 

about how this program is improving the lives of participants. Having such 

information about outcomes is an important component of any program, 

and essential during times of fiscal austerity. Further, by not exercising 

more oversight and issuing clear guidance to all states on emerging issues

that could affect program participants, Education may be missing an 

important opportunity to help states improve program operations or 

proactively respond to these issues. While recognizing that there may be 

increased costs for improved oversight, these costs could be minimized by,

for example, monitoring Randolph-Sheppard activities as part of 

Education’s oversight for the VR program. Although the Committee for 

Purchase has made significant progress in developing goals for the JWOD 

program, some of the goals lack key elements—clear measures and 

performance targets. Also, the current approach for overseeing nonprofit

agencies operating under the JWOD program poses difficult challenges for 

the two central nonprofit agencies in managing the conflicts of interest 

that may exist because of their lack of organizational independence, and 

therefore demands strong and effective oversight from the Committee for 

Purchase. Ensuring program integrity is particularly important for JWOD 

since nonprofit agencies are given a competitive advantage over private 

business and industry in the federal procurement system to ensure that 

opportunities are provided to individuals with severe disabilities. 

1. To improve program performance management and oversight, we 

recommend that the Secretary of Education provide more effective 

leadership of the Randolph-Sheppard program by: 

Recommendations 

• establishing performance goals to identify desired programwide 

outcomes that assess states’ licensed vendor programs’ 

performance as a whole in achieving established goals; 

• being more proactive in disseminating clear, consistent and routine 

guidance about program requirements and prohibited practices to 

federal agencies and states; and 

• strengthening their monitoring of SLA and Randolph-Sheppard 

program performance in a cost-effective manner.

Page 28 GAO-07-236 Federal Disability Assistance
2. To improve program performance management, we recommend that 

the Chairperson for the Committee for Purchase assess goals and 

measures for JWOD to ensure that they are clear, measurable and 

continue to capture key aspects of program performance as the 

Committee for Purchase continues to develop its performance 

management system. 

3. To help ensure that JWOD nonprofit agencies comply with program 

laws and regulations, we recommend that the Chairperson of the 

Committee for Purchase improve procedures for overseeing these 

agencies. This could include requiring the central nonprofit agencies to 

enter into written contracts with the Committee for Purchase that 

clearly lay out their oversight responsibilities and the consequences for 

failing to fulfill them, providing a means of compensating the central 

nonprofit agencies for their services that provides an incentive for 

effective enforcement, or having the Committee for Purchase assume 

greater responsibility for oversight of JWOD nonprofit agencies, by 

performing more on-site compliance reviews. 

We received written comments on a draft of this report from the 

Department of Education and the Committee for Purchase. Education and 

the Committee for Purchase generally agreed with our recommendations 

and provided information on activities they had underway or planned. 

Agency Comments 

and Our Evaluation 

Education agreed that it should provide more effective leadership of the 

Randolph Sheppard program and commented that the actions we 

recommended were consistent with the steps the program is taking to 

improve program administration. Some of the steps Education cited 

included developing appropriate performance goals, enhancing its efforts 

to provide clear and consistent guidance, and improving program 

monitoring. We believe these efforts will help to improve program 

performance management and oversight. 

The Committee for Purchase agreed that its performance goals and 

measures for the JWOD program should be assessed to ensure that they 

are clear and quantifiable. However, the Committee for Purchase 

commented that its regulations did not intend for “training” to be taken 

literally as a mission output and, therefore, the agency did not establish a 

separate goal for training activities. Rather, the Committee for Purchase 

stated that it viewed training as an important, but incremental activity that 

equips persons who are blind or have severe disabilities with the 

knowledge and skills necessary for employment, which it considers the 

Page 29 GAO-07-236 Federal Disability Assistance
paramount goal of the program. Also, the Committee for Purchase believes 

the reporting requirements for establishing a separate goal for training 

would burden the nonprofit agencies. To avoid confusion over the 

Committee for Purchase’s goals in the future, the agency plans to clarify 

its regulations. While we believe that training is key to preparing persons 

who are blind or have severe disabilities for employment, we can 

understand the Committee for Purchase’s view that the paramount 

program goal is employment. Clarifying the regulations regarding the 

Committee for Purchase’s intent with respect to the role of training may 

make it clear that a separate goal for training is not essential.

With respect to ensuring effective monitoring and oversight, the 

Committee for Purchase agreed that more guidance was needed to help 

ensure that JWOD nonprofit agencies comply with program laws and 

regulations. Additionally, the Committee for Purchase commented that it 

has recently begun taking steps to address possible conflicts of interest 

between the two roles played by the central nonprofit agencies. The 

Committee for Purchase also commented that it is considering 

establishing other oversight and compliance mechanisms and in its 

proposed fiscal year 2007 budget included three new positions and 

additional funding for oversight, compliance monitoring, and program 

review. We believe the Committee for Purchase’s proposed actions are 

positive steps toward helping to ensure that JWOD nonprofit agencies 

comply with program laws and regulations. 

Education and The Committee’s comments appear in appendixes III and 

IV, respectively. Both agencies also provided technical comments, which 

we have incorporated into the report as appropriate. 

We are sending copies of this report to the Secretary of Education, 

Chairperson of the Committee for Purchase, relevant congressional 

committees, and others who are interested. Copies will also be made 

available at no charge on GAO’s Web site at http://www.gao.gov. 

Page 30 GAO-07-236 Federal Disability Assistance
Please contact me on (202) 512-7215 if you or your staff have any 

questions about this report. Contact points for our Offices of 

Congressional Relations and Public Affairs can be found on the last page 

of this report. Other major contributors to this report are listed in 

appendix V.

Robert E. Robertson 

Director 

Education, Workforce, and Income Security 

Page 31 GAO-07-236 Federal Disability Assistance
Appendix I: Objectives, Scope, and Appendix I: Objectives, Scope, and Methodology 

Methodology 

The objectives of our study were to assess to what extent (1) performance 

goals and measures have been established for these programs and (2) the 

agencies responsible for these programs have established adequate 

procedures for overseeing program implementation and assuring laws and

regulations are followed. 

To determine what performance goals and measures have been

established for these programs, we reviewed program laws, guidance, and 

performance-related documents. To obtain additional information about 

the performance goals and measures, and determine the extent that the 

agencies responsible for these programs have established adequate 

procedures for overseeing program implementation and assuring that laws 

and regulations are followed, we (1) reviewed federal laws, regulations, 

and guidance to determine the programs’ requirements; and 

(2) interviewed agency officials at the Rehabilitation Services 

Administration (RSA) within the Department of Education, and the 

Committee for Purchase from People Who Are Blind or Severely Disabled 

(Committee for Purchase). In addition, we interviewed officials of the two 

central nonprofit agencies—the National Industries for the Blind (NIB) 

and NISH—that have been delegated certain oversight responsibilities for 

Javits-Wagner-O’Day (JWOD) member nonprofit agencies by the 

Committee for Purchase. 

To obtain additional information about program goals and measures and 

oversight for the four programs, we conducted site visits to four states 

(Arizona, Kansas, New York, and North Carolina). During these visits, we 

met with state VR agency officials to discuss the Supported Employment, 

Projects with Industry (PWI), JWOD, and Randolph-Sheppard programs. In 

addition, we visited 4 PWI grantees, 13 JWOD nonprofit agencies, and 

7 Randolph-Sheppard vendors. Several criteria were used in selecting the 

states to visit. States that were considered had all four of the employmentrelated disability programs currently present and operating in them. States 

varied in the administration of their VR programs with about half of all 

states having two separate programs—one for the general VR and a 

separate one for the blind—and the remaining states having only one VR 

program. We selected two states (New York and North Carolina) that had

both general and blind VR programs, and two states (Arizona and Kansas) 

that had one VR program that served all people with disabilities seeking 

employment-related assistance. In addition, we selected states based on a

review of information about the characteristics of NIB and NISH member 

nonprofit agencies to include both large and small, urban and rural, and 

different kinds of work performed (products and services). States were 

also selected to include geographic diversity. 

Page 32 GAO-07-236 Federal Disability Assistance
Appendix I: Objectives, Scope, and 

Methodology 

During the state visits, we met with officials representing each of the four 

programs. For Education’s programs, we interviewed local officials of 

nonprofit agencies with PWI grants, state program administrators for the 

state-operated Randolph-Sheppard programs as well as licensed vendors,

and state VR officials responsible for administering the Supported 

Employment State Grants program. For JWOD, we interviewed chief 

executive officers or their representatives of the JWOD nonprofit agencies

with current federal contracts to provide goods and/or services. In 

addition, during these meetings, we collected documentation to ascertain

how the federal and two central nonprofit agencies were monitoring their 

respective programs. We also reviewed the records of 137 workers who 

were blind or had severe disabilities, selecting some records at each of the 

13 JWOD nonprofit agencies we visited. The records were randomly 

selected from lists of current JWOD workers. A random number generator

was used to assign a number to each name on the active roster and 

records were selected on the basis of the number—starting with the 

lowest number. During the record review, we assessed whether the 

agencies’ files of workers who were blind or had severe disabilities 

contained required medical documentation and assessment of ability to 

work in competitive employment. 

We determined that the fiscal and program data we used in this report was 

reliable for our purposes. To make this determination, we assessed the 

reliability of fiscal and programmatic data by interviewing officials 

knowledgeable about the data and the steps they take to ensure accuracy. 

For Supported Employment, prior GAO work had systematically tested 

relevant variables, including all 22 variables of the services provided. In 

addition, for this engagement we obtained documentation from two states 

(Kansas and New York) that described the states’ procedures for checking 

the reliability of their data. Programmatic data collected by the Committee 

for Purchase for the JWOD program, and Education for the PWI and 

Randolph-Sheppard programs were self-reported by local program 

officials. For example, reviews of the information reported by officials for 

the PWI program were generally performed by project managers. For 

fiscal reporting, however, we found that JWOD nonprofit agencies, PWI 

grantees, and licensed vendors generally had systems and procedures for 

stronger accounting of financial data. For example, state licensing agency 

(SLA) officials used cash register receipts and routine reports on business 

activities submitted by the licensed vendors to the SLAs to review the 

financial information for these programs. In addition, licensed vendors 

were also required to complete merchandise inventories at least once each

year. 

Page 33 GAO-07-236 Federal Disability Assistance
Appendix I: Objectives, Scope, and 

Methodology 

We also reviewed other available reports on the Randolph-Sheppard 

program of the states visited, and reviewed the findings and 

recommendations of state audit reports from four other states—California, 

Georgia, Michigan, and South Carolina—that had evaluated all or certain 

aspects of their state-operated Randolph-Sheppard programs in recent 

years. In addition, we interviewed officials of agencies engaged in 

disability research and advocacy at the national level to learn more about 

each of the objectives. These organizations were the Council of State 

Administrators of Vocational Rehabilitation, Disability Policy 

Collaboration, Easter Seals, Goodwill Industries International, National 

Council on Disability, and the National Council of State Agencies for the 

Blind. We also met with officials of the General Services Administration, a 

federal procurement agency and partner of the JWOD program. 

We conducted our work between March 2006 and December 2006 in 

accordance with generally accepted government auditing standards. 

Page 34 GAO-07-236 Federal Disability Assistance
Appendix II: Performance Goals and 

Measures for the Javits-Wagner-O’Day 

(JWOD) Program 

Table 5: JWOD Performance Goals and Measures 

Performance goals Performance measures 

Continue to expand employment opportunities 

for people who are blind or have other severe

disabilities under the JWOD program, including 

wage progression, benefits, upward mobility, 

and personal job satisfaction. 

• Percentage increase in direct labor hours performed by people who are blind or 

have other severe disabilities on JWOD products and services. 

• Percentage increase in the number of people who are blind or have other severe 

disabilities employed in direct labor positions on JWOD products/services.

• Percentage increase in the number of people receiving benefits versus not 

receiving benefits. 

• Percentage decrease in the number of people receiving less than the federallymandated minimum wage or Service Contract Act wage rate, segmented by 

disability. 

• The number of employees who are blind or have other severe disabilities who are 

promoted into a direct labor job, other than supervisory or management positions, 

which includes increased wages and/or fringe benefits, not attributed to cost of 

living or productivity increases of less than 20 percent. Promotions can be 

movement between JWOD and non-JWOD jobs. 

• The number of employees who are blind or have other severe disabilities who are 

promoted into an indirect labor job requiring supervisory, management, or 

technical skills, that included increased wages and/or fringe benefits, not attributed 

to cost of living raises. 

• The number of employees who are blind or have other severe disabilities who 

leave the nonprofit agency through competitive or supported employment 

placements. 

Partner with federal customers to increase 

customer satisfaction and loyalty, so that the 

JWOD program becomes their preferred 

source for products and services. 

• Federal agency scorecard that evaluates the level of satisfaction with JWOD

products, services and/or customer experience among key federal agencies, using 

a stoplight or similar summary format. 

• Time to resolve customer questions or complaints received via the central 

customer feedback mechanism(s) or other means of communication. 

• Increased customer satisfaction with quality, timeliness, and price, based on 

customer surveys and/or alternative qualitative research (e.g., focus groups). 

Improve efficiency and effectiveness of the 

JWOD program by streamlining and 

automating processes and procedures, and 

improving communication, while continuing to

ensure program integrity. 

• Overhead cost as a percentage of JWOD program direct labor hours, calculated 

as total Committee for Purchase budget plus central nonprofit agencies’ operating

and supporting costs (excluding capital expenditures), divided by total number of 

direct labor hours, segmented by overall program (Committee for Purchase plus 

central nonprofit agencies’ overhead), National Industries for the Blind (NIB) and 

NISH. 

• Reduction in the cycle time for the addition of a new JWOD product or service to 

the procurement list. 

• Percentage increase in sales of products through commercial distribution 

channels, segmented by product category. 

• Ranking of commercial distributors, evaluated against consistent program

performance expectations, including compliance with the Committee for 

Purchase’s Essentially The Same (ETS) requirements, segmented by product 

category. 

• Milestone tracking of evaluation of commercial distribution processes, including 

staff resources and financial resources. 

Appendix II: Performance Goals and 

Measures for the Javits-Wagner-O’Day 

(JWOD) Program 

Page 35 GAO-07-236 Federal Disability Assistance
Appendix II: Performance Goals and 

Measures for the Javits-Wagner-O’Day 

(JWOD) Program 

Performance goals Performance measures 

• Percent of information technology projects on which the Committee for Purchase, 

central nonprofit agencies, and nonprofit agencies collaborated to increase

efficiency and exchange of information. 

• Decrease in the percentage of JWOD nonprofit agencies found out of 

compliance, segmented by reason. 

• Consider a future measure linked to the results of governance and executive 

compensation actions. 

Expand awareness, understanding, and 

preference for the JWOD program within the 

public, Congress, federal agencies, the 

disability community, and other JWOD

stakeholders through effective

communication and information sharing. 

• Effectiveness of communication and information sharing measured by increased

percentages in awareness, familiarity (understanding) and preference, 

segmented by key stakeholders. 

• Milestone tracking of annual update and implementation of a plan that addresses 

communication and information sharing with and among both internal and 

external stakeholders. 

• Analysis of program-level communications execution to ensure that program 

resources are used in support of the strategic communications plan. 

• Analysis of program-level publications, events, and other communications tools to 

evaluate message alignment.

• Facilitate nonprofit agency adoption of program messaging and branding. 

• Awareness, understanding, preference among federal customers, segmented by 

Department of Defense and civilian agencies.

• Awareness, understanding, preference for “the disability community,” comprised 

of government policy makers, academia, and private membership or advocacy 

organizations for people who are blind or have other severe disabilities. 

• Among members of congressional committees or subcommittees with oversight 

or other significance for the JWOD program, number who have been educated 

about the JWOD program and/or actively engaged with their local JWODparticipating nonprofit agency(ies). 

Strategically develop new markets and 

expand existing markets in which the JWOD

program can provide best value products and

services to federal customers in order to 

expand employment opportunities that meet 

the needs of people who are blind or have 

other severe disabilities. 

• Milestone tracking of establishment and implementation of a program market 

development plan that addresses existing customers, existing products/services, 

new customers, and new products/services. 

• Percent increase in the employment of people who are blind or have other severe 

disabilities under the JWOD program, measured in (1) actual direct labor hours, 

(2) actual jobs, (3) projected direct labor hours on procurement list additions, and 

(4) projected jobs on procurement list additions by key market segment. 

• JWOD goal achievement, by agency and overall federal government. 

• Milestone tracking of establishment and implementation of a strategy for greater 

cooperation between JWOD and the small business community, which may 

explore counting appropriate JWOD awards toward the annual Small Business 

procurement goals and/or the federal government’s inclusion of disability-owned 

businesses within the small business measure categories (relates to leveraging 

the JWOD program to create additional jobs in the commercial sector). 

• Milestone tracking of implementation of a strategy for greater cooperation 

between JWOD and Randolph-Sheppard programs. 

• Milestone tracking of establishment and implementation of a strategy for greater 

cooperation with service-disabled veterans’ businesses. 

Source: Final FY 2007-2009 Strategic Plan for the Javits-Wagner-O’Day (JWOD) Program, Committee for Purchase From People Who 

Are Blind or Severely Disabled, October 16, 2006. 

Page 36 GAO-07-236 Federal Disability Assistance
Appendix III: Comments from the Department Appendix III: Comments from the of Education 

Department of Education 

Page 37 GAO-07-236 Federal Disability Assistance
Appendix III: Comments from the Department 

of Education 

Page 38 GAO-07-236 Federal Disability Assistance
Appendix IV: Comments from the Committee 

for Purchase from People Who Are Blind or Appendix IV Severely Disabled : Comments from the Committee 

for Purchase from People Who Are Blind or 

Severely Disabled 

Page 39 GAO-07-236 Federal Disability Assistance
Appendix IV: Comments from the Committee 

for Purchase from People Who Are Blind or 

Severely Disabled 

Page 40 GAO-07-236 Federal Disability Assistance
Appendix IV: Comments from the Committee 

for Purchase from People Who Are Blind or 

Severely Disabled 

Page 41 GAO-07-236 Federal Disability Assistance
Appendix IV: Comments from the Committee 

for Purchase from People Who Are Blind or 

Severely Disabled 

Page 42 GAO-07-236 Federal Disability Assistance
Appendix V: 

A

GAO Contact and Staff 

cknowledgments 

Page 43 GAO-07-236

Appendix V: GAO Contact and Staff 

Acknowledgments 

Robert E. Robertson (202) 512-7215 

The following individuals made important contributions to this report: 

Shelia D. Drake, Timothy Hall, Regina Santucci, Don Allison, 

Rachael Valliere, Daniel Schwimer, Walter Vance, and Robert Owens. 

Federal Disability Assistance

GAO Contact 

Acknowledgments 

(130560) 
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