National Council on Disability

Performance and Accountability Report

Fiscal Year 2014
Table of Contents

Introduction

Report Purpose .............................................................................................................1

Report Organization ......................................................................................................1

Message from the Chair................................................................................................2

Management’s Discussion and Analysis

History ...........................................................................................................................5

Organization..................................................................................................................5

Mission, Vision, Goals and Objectives ..........................................................................7

Agency Mission Challenges ..........................................................................................7

Performance Measurement Methodology .....................................................................8

Performance Highlights .................................................................................................9

Financial Highlights .......................................................................................................17

Management Assurances and Analysis of Controls, Systems and Legal 

Compliance

Implementation of Federal Manager’s Financial Integrity Act (FMFIA) at NCD.............21

Legal Compliance .........................................................................................................23

Chair’s FMFIA Statement of Assurance ........................................................................25

Performance Section

Performance Framework...............................................................................................26

Performance Measurement Challenge..........................................................................30

Program Activities & Performance Results by Strategic Objectives ..............................31

Financial Section

Message from the Executive Director............................................................................51

Independent Auditor’s Report

Principal Financial Statements

Notes to the Financial Statements

Appendix A – Listing of Abbreviations and Acronyms
Introduction

1

Report Purpose

The National Council on Disability’s (NCD) Fiscal Year (FY) 2014 Performance and 

Accountability Report (PAR) provides the results of the agency’s program and financial 

performance and demonstrates to the Congress, the President, and the public NCD’s 

commitment to its mission and accountability over the resources entrusted to it.

This report includes information that satisfies the reporting requirements contained in 

the following legislation:

• Federal Managers’ Financial Integrity Act of 1982

• Government Performance and Results Act of 1993

• Government Management Reform Act of 1994

• Reports Consolidation Act of 2000

• Accountability of Tax Dollars Act of 2002

• Improper Payments Information Act of 2002

• GPRA Modernization Act of 2010

Report Organization

1. Management’s Discussion and Analysis - Provides an overview of 

NCD’s mission and organization, mission challenges, performance measurement 

methodology, key performance measures and efficiency measures, performance 

highlights, alignment of NCD costs and goals, financial highlights, and 

management assurances on internal control and financial systems.

2. Performance Section – Explains NCD’s performance relative to its strategic 

goals and objectives, and includes an overview on how performance data are 

verified and validated.

3. Financial Section – Provides financial details, including the independent 

auditors report and audited financial statements with accompanying notes.
 National Council on Disability

An independent federal agency making recommendations to the President and Congress 

to enhance the quality of life for all Americans with disabilities and their families.

Message from the Chairperson

On behalf of the members of the National Council on Disability (NCD or the Council), I 

am pleased to submit the Fiscal Year (FY) 2014 Performance and Accountability Report 

(PAR). The Council received an unqualified opinion from its independent auditors on its 

FY 2014 annual financial statements. 

The Council is working intensely with technical and contractual support from the 

General Services Administration to improve and further strengthen our internal agency 

operations and fiscal management. Additionally, NCD is also implementing best 

practice procedures in accordance with guidance from the Government Accountability 

Office (GAO) and the AICPA Audit Committee Effectiveness Center. 

During the course of FY2014, the Council began implementing the policies and 

procedures listed in the financial procedural manual facilitated under the leadership of 

the Audit and Finance Committee and reviewed by external government partners for 

additional input. In FY2015, the same quality work will be conducted on the Council’s 

Administrative Policy manual to bring this document up to the standards required by the 

federal government. 

The Audit & Finance Committee and the Executive Committee have reviewed and 

approved the Council’s Corrective Action Plan (incorporated in this document) to make 

decisive action to improve internal controls, IT security, and overall oversight as we 

move into FY2015. We have also worked with GSA to refine the requirements and 

duties of a financial analyst to further strengthen our internal operations. 

As the Council moved to fill our vacant positions in FY2014, we partnered with GSA in 

obtaining recommended contractual support to carry out these functions in the interim to 

ensure continuity of operations and improve the segregation of duties.

The Council’s role as an independent advisor on disability matters to the President and 

Congress is essential to assuring the Federal government is well informed and qualified 

to perform their duties and effectively serve the public, including individuals with 

disabilities. NCD carries out its mission to promote equality of opportunity, full 

participation, independent living and economic self-sufficiency for people with 

disabilities of all ages and backgrounds by: (1) continually reviewing disability programs 

and policies, (2) meeting with people with disabilities and other stakeholders around the 

country to learn about on-the-ground realities, and (3) providing advice, analysis and 

recommendations on disability policy to the President, Congress, and other federal 

agencies. NCD’s analysis and recommendations have led to enactment of important 

laws and other improvements to the programs and services provided by the many 

federal agencies that serve the disability community. NCD’s most notable achievement 

is drafting and recommending the Americans with Disabilities Act.

During FY 2014, the Council extended its engagement in several substantive areas that 

contributed to the nation’s progress toward achieving the goals of equality of 

opportunity, independent living, full participation, and economic self-sufficiency for all 

people with disabilities. 
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These efforts have been undertaken as effective stewards of limited fiscal resources 

and included addressing the needs of people who have acquired disabilities, measuring 

the accessibility of polling places, promoting innovation in health care and fairness in 

the implementation of managed care. Additionally we are proud to continue our efforts 

in promoting effective communication fully accessible to all people with disabilities 

throughout all phases of emergency management.

The Council hosted several policy forums on Medicaid managed care implementation 

across the country and partnered with the White House on several initiatives promoting 

new leaders in the disability community and addressing issues of mental health reform. 

In addition, during the course of the fiscal year NCD released a series of reports, 

papers, and letters including:

Reports: 

• Effective Communications for People with Disabilities: Before, During, and After 

Emergencies

• Experience of Voters with Disabilities in the 2012 Election Cycle

• Clearing the Backlog and Facilitating Benefits for Veterans with Disabilities

• NCD Education Forum Report: U.N. Convention on the Rights of Persons with 

Disabilities (CRPD)

• Progress Report on Tribal Consultation Coordination

• Language Access Plan Implementation Annual Report

Statements:

• Statement on the CRPD

• Statement on the “Prevalence of Autism Spectrum Disorder among Children Aged 8 

Years” report by the Center for Disease Control

• Statement on the Lyndon B. Johnson Library Civil Rights Act 50th Anniversary Event

• Statement in recognition of National Foster Care Month

• Statement on the 15th anniversary of the Olmstead decision

• Statement on the passing of Senator Jim Jeffords

• Statement of solidarity with the victims of police violence in Ferguson, MO

• Statement on the passing of Mary Ann Mobley Collins

• Statement on “Stand Your Ground” laws

Letters:

• Letter to Senate Finance Committee in support of amendment language regarding 

supported employment

• Letter to House Homeland Security Subcommittee on Emergency Preparedness 

regarding Integrated Public Alert and Warning System (IPAWS) bill

• Letter to President Obama regarding mental health funding

• Letter to Senate Foreign Relations Committee reaffirming its strong support of ratification 

of the U.N. Convention on the Rights of Persons with Disabilities (CRPD)

• Letter to Vice President Biden regarding the CRPD

• Letter to the Centers for Medicare and Medicaid Services (CMS) about an amendment 

to Kancare Medicaid, Section 1115
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• Letter to the Department of Justice on an investigation of Title II Americans with 

Disabilities Act (ADA) violations in Rhode Island

• Letter to the President and Labor Secretary Tom Perez on the minimum wage Executive 

Order

• Letter to the President and Education Secretary Arne Duncan on including the 

Individuals with Disabilities Education Act (IDEA) in the FY2015 Budget

• Letter to Veterans Affairs Under Secretary for Benefits Allison Hickey about the claims 

backlog

• Letter to Washington state Representative Roger Freeman in support of state parenting 

rights bill

• Letter to Education Secretary Duncan about students with 504 plans, and the school-toprison pipeline

• Letter to the Food and Drug Administration on taking action against Judge Rotenberg 

Center

• Letter to the House/ Senate conference on the Workforce Investment Act

• Letter to House Speaker Boehner encouraging a House vote on the ABLE Act

• Letter to National Children’s Study about the design of the National Children’s Study and 

implications for the generalizability of results

• Letter to U.S. Agency for International Development Administrator Shah regarding 

humanitarian and economic assistance to Ukraine

• Letter to Defense Secretary Hagel regarding humanitarian and economic assistance to 

Ukraine

• Letter to Department of Labor regarding the implementation of the “Application of the 

Fair Labor Standards Act to Domestic Service” final rule

• Letter to the House Energy and Commerce Committee with recommendations for the 

Helping Families in Mental Health Crisis Act of 2013

The Council released its Annual Progress Report in the fall of 2013, in accordance with 

NCD’s authorizing statute: National Disability Policy: A Progress Report.

NCD is proud of its successful efforts in promoting equality of opportunity, full participation, 

independent living, and economic sufficiency for all individuals with disabilities, of all ages, 

throughout the country. I want to express my profound appreciation for the hard work and 

dedication of NCD’s Members and staff, who continued to make important policy contributions 

while simultaneously addressing concerns raised in last year’s audit. We remain steadfast in 

our commitment to carrying out our responsibilities in working with the President, the 

Congress and each level of local, state and federal agencies to accomplish our nation’s vision 

of valuing and respecting each member of our society. 

Sincerely,

Jeff Rosen, Chairperson
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History

National Council on Disability (NCD) (www.ncd.gov) is an independent federal agency 

that advances full inclusion, independence, and equal opportunity for people with 

disabilities. NCD was initially established in 1978 as an advisory board within the U.S. 

Department of Education (Public Law 95-602). The Rehabilitation Act Amendments of 

1984 (Public Law 98-221) transformed NCD into an independent agency and required 

NCD to provide expert advice to Congress and the Administration. Changes were also 

made to NCD’s statutory mandate by the Rehabilitation Act Amendments of 1992 and 

1998 and the Education of the Deaf Act Technical Amendments of 1993. 

NCD’s governing body is the Council, which is currently comprised of 15 Presidential 

appointees, including a Chair, whom the President appoints, and a Vice Chair, 

determined by the Chair. With the recent passage of the Workforce Innovation and 

Opportunity Act (Public Law 113-128), Council Membership will be composed of nine 

members, including five members appointed by the President of the United States and 

four members appointed by the leadership of Congress, including one member 

appointed by each of the following: the Speaker of the House, the House Minority 

Leader, the Senate Majority Leader and the Senate Minority Leader. 

Council Members live across the country and each brings a unique perspective 

informed by varied personal and professional experiences. Council Members are people 

with disabilities, disability service providers, parents or family members of people with 

disabilities, or other people who have substantial knowledge of or experience with 

disability policies and programs. Council Members are appointed to represent people 

with disabilities, national organizations concerned with disabilities, providers and 

administrators of services to people with disabilities, people engaged in conducting 

medical or scientific research related to disabilities, business concerns and labor 

organizations. The majority of the current Council Members are people with disabilities.

As the governing body, Council Members establish NCD’s priorities and budget, and 

monitor and provide oversight of NCD’s programs, operations and finances. The 

Council’s oversight responsibilities are organized and led by a six-member Executive 

and Finance Committee, consisting of the Chairperson of the Council; the two Co-Vice 

Chairs of the Council; and three Council Member principals for finance, governance and 

policy. The Chairperson of the Council also serves as the Chairperson of the Executive 

and Finance Committee. NCD also has a Policy Committee that proposes NCD policy 

priorities for discussion.

The Chairperson appoints an Executive Director and evaluates the Executive Director’s 

performance.

Organization
6

NCD’s Executive Director serves as the chief executive of the agency and has full 

responsibility for managing the agency to accomplish the mission, and the goals and 

objectives established by legislation or Council members. When fully staffed, NCD has 

13 full-time employees, organized into three teams:

• Policy & Legal Team - The Policy & Legal Team analyzes federal laws, 

regulations, programs, policies and case law precedent; and proposes and 

develops NCD policy positions that have a national, state and international 

impact on the lives of people with disabilities.

• Legislative Affairs & Outreach Team - The Legislative Affairs & Outreach 

Team analyzes proposed legislation and monitors congressional activity on 

issues critical to the disability community; cultivates and maintains relationships 

with NCD’s diverse stakeholders at the federal, state and local levels; and 

promotes NCD’s policy positions through a variety of mediums.

• Administrative Operations Team - The Administrative Operations Team provides 

staff support and monitors the agency's finance and accounting, information 

technology, and human resources management.
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Mission, Vision, Goals & Objectives

NCD has a unique mission among federal agencies because it is charged with 

reviewing all programs and policies across the Federal Government, not merely one 

aspect of policy affecting people with disabilities. 

Mission

Promote equality of opportunity, full participation, independent living 

and economic self-sufficiency of people with disabilities of all ages 

and backgrounds by providing advice, analysis and 

recommendations on disability policy to the President, Congress 

and other federal agencies.

Vision

NCD leads by facilitating, articulating and promoting inclusion and 

empowerment of individuals with disabilities to live, learn and earn 

based on informed choices.

Strategic 

Goal

Advance the goals of the Americans with Disabilities Act by 

promoting policies, programs, practices, and procedures that 

guarantee equal opportunity and provide for economic selfsufficiency, independent living, and inclusion and integration

into all aspects of society for individuals with disabilities.

Strategic 

Objectives

1. Engagement - Engage stakeholders in order to assess 

concerns and priorities and build a network of NCD partners.

2. Policy Development & Collaboration – Address 

stakeholder concerns and priorities by advancing specific, 

practical, policy solutions and encouraging collaboration.

Agency Mission Challenges

NCD is a micro-agency, and with a current budget of $3.2 million, 15 part-time Council 

Members (reducing to nine after the effective date of the WIOA), and 13 full-time staff 

when fully staffed, NCD has adopted a strategy of working in conjunction with a wide 

range of stakeholders – including people with disabilities, federal, state and local 

agencies, elected officials and their staff, universities, and a diverse group of non-profit 

organizations and individual disability policy experts and advocates – to leverage and 

steward resources while advancing our mission, goals and objectives. 

NCD’s strategic objectives of engagement and policy development can be quantifiably 

measured by the number of people that attend our forums, regularly engage with us via 

social media, download and read our policy reports, and adopt or promote our 

recommendations. However, measuring NCD’s impact on its strategic goal of 

guaranteeing equal opportunity and providing for economic self-sufficiency, independent 

living, and inclusion and integration into all aspects of society for individuals with 

disabilities is far more subjective since these are systemic endeavors in which NCD is 
8

part of a community of agencies, advocates and others seeking to secure such 

outcomes. Accordingly, NCD’s analysis of the relationships of program outputs (such as 

forums and reports) to tangible outcomes impacting our stakeholders requires a multiyear horizon. 

NCD is continually working to identify better mechanisms for measuring outcomes and 

reporting achievements. This includes increased efforts to gather and report personal 

stories of where our engagement or policy initiatives provided a tipping point toward 

improving the lives of people with disabilities. The Performance Highlights portion of the 

Management’s Discussion and Analysis section presents specific stories and comments 

from impacted stakeholders and a case study of how engagement and policy converged 

into positive outcomes.

Performance Management Methodology

NCD utilizes the following performance management methodology to set priorities, 

allocate resources, and evaluate results.

Strategic Goal Statements of long-term aims outlined in Strategic Plan, 

which define how NCD carries out its mission.

Objectives Statements of how NCD plans to achieve its strategic goals.

Performance 

Measures

Indicators used to gauge success in reaching strategic 

objectives.

Key Measures

Measures that best indicate whether NCD’s activities are 

achieving the desired outcome associated with the related 

objective.

Targets

Expressions of desired performance levels or specific 

desired results targeted for a given fiscal year. Targets are 

expressed in quantifiable terms.

Outcomes Meaningful measures to show effectiveness, efficiency and 

results in mission achievement.

As previously mentioned, measuring NCD’s impact on its strategic goal of guaranteeing 

equal opportunity and providing for economic self-sufficiency, independent living, and 

inclusion and integration into all aspects of society for individuals with disabilities is 

challenging since these are large-scale, long-term endeavors. 

Accordingly, as we evaluate performance measurements, key measures, targets and 

outcomes, we ask:

• Has NCD identified critical needs where our engagement with stakeholders and 

policy development and collaboration can advance existing initiatives?
9

• Can NCD be a thought leader, performing important research and analysis on 

critical topics?

• Can NCD provide practical, timely policy recommendations and consultations to 

Members of Congress and the Executive Branch? 

Performance Highlights

NCD’s meaningful accomplishments in the last fiscal year that advanced its mission, 

vision, strategic goals, and strategic objectives included engaging stakeholders to learn 

about critical issues; conducting independent, objective, fact-based research and 

analyses of issues; publishing reports with policy recommendations and questions for 

consideration by policymakers; and finally reengaging stakeholders on the issues to 

monitor progress. A recent proud example of this integrated engagement and policydevelopment process at work is NCD’s sustained efforts to ensure the rights of parents 

with disabilities.

Parents with Disabilities and Their Families 

On July 25, 2014, NCD, utilizing its statutory authority to receive testimony, convened a 

congressional forum on the status of parents with disabilities and their families. 

Through the invited testimony of several panels, comprised of policy and practice 

experts; parents and their children; and state legislators; as well as the questions asked 

of the panels by the NCD Council Members, the forum highlighted the barriers people 

with disabilities face in creating and maintaining strong families and examined what 

policy measures are either underway or are needed to address the persistent barriers 

experienced by people with disabilities when attempting to exercise their fundamental 

and cherished right to parent. In response to NCD’s regular outreach to federal partners 

since the issuance of NCD’s 2012 Rocking the Cradle report on the topic, the 

Department of Justice Civil Rights Division informed NCD just before its forum that over 

the next year, DOJ will be developing technical assistance guidance to educate state 

dependency courts and child welfare agencies about their obligations under the ADA 

related to parents with disabilities and their families. They will also be looking into 

possible enforcement actions to protect and vindicate parents’ rights.

Other examples of NCD’s FY2014 integrated policy development and engagement: 

Emergency Communications

In May 2014, NCD released a report examining the accessibility of communication 

before, during and after emergencies for people with sensory disabilities (deaf, hard of 

hearing, blind, low-vision, deaf-blind and speech disabilities) as well as people with 

intellectual, developmental and/or psychiatric disabilities. In the report, NCD 

documented successful practices and barriers to effective emergency communications. 

This study, released during National Hurricane Preparedness Week, was conducted to 

help emergency planners and state and local officials provide effective communication 

to people with disabilities before, during, and after emergencies and was 
10

enthusiastically received by regional and state emergency managers. NCD held a policy 

briefing on the findings of the report on Capitol Hill, which was well-attended by 

congressional staff of committees of jurisdiction over the topics discussed in the report. 

The report continues the strong history of timely policy work the Council has done in the 

area of emergency management since 2003. In 2007, NCD was provided additional 

Congressional appropriations to continue investing in this area of work as a part of the 

Post-Katrina Emergency Reform Act (PKEMRA).

Minimum Wage

In January, at word of an impending Executive Order extending a $10.10 minimum 

wage per hour to workers under service or concessions contracts with the Federal 

Government, NCD called on the Administration to specifically include individuals with 

disabilities who are currently paid less than minimum wage under Section 14(c) of the 

Fair Labor Standards Act, in the Executive Order. Soon after, the Administration issued 

the Executive Order, which specifically included these individuals. The Executive Order 

(E.O. 13658) states: 

“Under current law, workers whose productivity is affected because of their 

disabilities may be paid less than the wage paid to others doing the same job 

under certain specialized certificate programs. Under this Executive Order, all 

individuals working under service or concessions contracts with the federal 

government will be covered by the same $10.10 per hour minimum wage 

protections.”

NCD hopes this marks a step toward the eventual legislative elimination of the Section 

14(c) provision, which the agency views, as “a relic” of the 1930’s when it was assumed 

that people with disabilities could not work. (In 2012, NCD released a report on 

subminimum wage and supported employment, which contains more detail on NCD’s 

recommendations in this area). 

Medicaid Managed Care

Beginning in December 2013 and continuing through the duration of FY 2014, NCD 

collaborated with federal agency representatives and disability leadership stakeholders 

to obtain input in the planning and implementation of Medicaid managed care through a 

series of five community forums in federal fiscal year 2013-2014 which were held in 

Topeka, KS; Tallahassee, FL; Chicago, IL; Sacramento, CA; and New York, NY, 

promoting stakeholder engagement with federal and state officials. The forums featured 

facilitated discussion of experiences, preferences and desired outcomes for Medicaid 

managed care as described by disability leadership; federal and state agency 

representatives, health plans, and providers. At the forums, NCD was able promote the 

Medicaid managed care principles outlined in the NCD report, “Medicaid Managed Care 

for People with Disabilities.”i

In August, NCD’s issue session proposal on Medicaid managed care and people with 

disabilities was accepted for presentation at the National Conference of State 

Legislatures, and approximately 150 state legislators attended the session to learn from 
11

the panel about how to roll out managed care in their home states so as to best deliver 

services in a manner consistent with Olmstead v. L.C. and the goals of the ADA. 

Outreach Metrics

Throughout FY 2014, NCD has improved measurement of outputs and outcomes. This 

includes more formal tracking of engagement activities at forums, website usage, social 

media, and collecting personal stories of how NCD’s work has benefited people with 

disabilities. NCD reached hundreds of thousands of people in FY 2014 through Council 

meetings, speaking engagements, panel discussions, roundtables, listening sessions 

and media coverage of NCD’s policy work. NCD’s website received approximately 

404,000 unique visitors in the last fiscal year – over 1,100 a day and an increase of 40% 

over the previous fiscal year. NCD offers its research publications in multiple formats 

online and continued observing a pattern of tens of thousands of downloads of its policy 

reports from domestic and international sources. NCD’s most popular three policy 

publications, according to the number of report views, were The Current State of Health 

Care for People with Disabilities (FY08); the Rocking the Cradle report (FY13) on the 

rights of parents with disabilities; and Effective Emergency Management (FY10). In 

addition, NCD reaches several thousand people through its official agency list serve, its 

Facebook page, and Twitter accounts. NCD’s Facebook account is “liked” by over 

15,000 (60% increase over FY13) individuals, and NCD’s Twitter account, from which 

NCD live-tweets disability-focused legislative hearings and briefings, has 5,489 

followers. In addition, national media has continued to include statements of NCD staff 

and Council Members in reports on a variety of disability-related news, often yielding 

repeated requests of NCD for specific topics, including parenting rights, the abuse of 

people with disabilities, and subminimum wage. 
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Performance Highlights: Goals, Measures & Activities

Goals, Measures, and Program Highlights 

Strategic Goal 

Components

Key Measures Program Activity 

Highlights for FY 2014

Potential and Planned 

Activities for FY 2015 and 

2016

Integrated Approach

Economic Self 

Sufficiency

Enhance 

participation in and 

knowledge of 

programs available 

to assist people 

with disabilities in 

enhancing their 

self-sufficiency 

through 

employment, 

education and job 

training. 

Advised the President and 

the Secretary of Labor to 

include individuals with 

disabilities employed under 

14C of the Fair Labor 

Standards to be included in 

the Minimum Wage 

Increase Executive Order 

raising the wage to $10.10 

for federal contractors. 

Once issued, policy 

reflected their inclusion as 

advised. 

Conference on the rights of 

parents with disabilities 

Plan a disability policy track 

at annual legislative summit 

of state legislator association 

to enhance state/federal 

policy coordination 

Continue regular speaking 

engagements, congressional 

briefings and hearings; 

agency website 

enhancements, pursue use of 

captioned video and podcasts 

to convey key points of long 

reports; pursue development 

of infographics to accompany 

agency reports to convey key 

and complex data in a more 

user-friendly format 

Continue engagement with 

stakeholders from all levels of 

government, including state 

legislators, governors and 

CMS to promote the 

understanding of the needs of 

people with disabilities in a 

managed care system.

Focus effort on examining the 

school to prison pipeline and 

the propensity of individuals 

with disabilities to fall into this 

category.

Host congressional briefings 

on the impact of the 

Affordable Care Act on 

individuals with disabilities.

Reports/Papers

NCD’s Annual Progress 

Report: ADA@ 25 

SCORECARD

ACA Impact Analysis

People with Disabilities and 

Independent 

Living

Improving access 

to long term 

services and 

support, health 

care, housing and 

transportation

Convened five regional 

forums with key 

stakeholders and 

representatives of CMS and 

other federal and state 

agencies to address states’

adoption of Medicaid 

managed care models. The 

forums provided critical 

feedback for CMS and key 

state agencies regarding the 

efficacy of and potential 

pitfalls of managed care for 

individuals with disabilities 

with long term support 

needs Integration and 

Inclusion

Improving policies 

and practices to 

ensure that all 

children, youth, and 

adults with 

disabilities are 

valued by, and 

contribute to, their 

communities of 

choice and civil 

rights are protected

Issued reports and 

recommendations regarding 

the rights of individuals with 

disabilities to be free from 

the use of aversive 

therapies consistent with the 

aims of the Food and Drug 

Administration.

Assisted three state 

legislators in drafting and 

working on legislation on the 

rights of parents with 

disabilities and their 

families. One bill passed 

into law. 

Currently working with the 

Disability Education Rights 

Defense Fund in support of 
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Goals, Measures, and Program Highlights 

Strategic Goal 

Components

Key Measures Program Activity 

Highlights for FY 2014

Potential and Planned 

Activities for FY 2015 and 

2016

the development of 

recommendations tied to the 

development and use of 

autonomous vehicles to 

promote inclusion and 

access.

NCD provided input into the 

development of H.R. 3283, 

the “Integrated Public Alert 

and Warning System 

(IPAWS) Modernization Act 

of 2013.” The bill 

represents an encouraging 

and positive step forward in 

considering and integrating 

the needs of people with 

disabilities into emergency 

communications proactively, 

rather than approaching 

disability access as a 

freestanding framework 

outside of the general 

population’s needs and will 

continue to work closely with 

the committee staff as this 

bill and related bills are 

debated. 

In partnership with current 

and former service 

members and Paralyzed 

Veterans of America, NCD 

released Clearing the 

Backlog and Facilitating 

Benefits for Veterans with 

Disabilities. The report 

includes opinions and 

evaluations by key 

stakeholders, buoyed by the 

insights of experts, in 

addressing the current state 

of the Department of 

Veterans Affairs (VA) 

disability claims backlog.

NCD convened a roundtable 

of individuals from major 

disability organizations and 

the civil rights community to 

Medicaid Managed Care -- 

recommendations from 

listening to stakeholders 

around the country as states 

roll out these models

Education issue briefs in light 

of reauthorization efforts in 

FY15 (ESEA, HEA)

Cross-Agency Collaboration

Partnering with NCIL, WID 

and SSA to convene a 

hearing tied to young people 

with disabilities and SSI/SSDI 

reform.

Monthly participation in White 

House Initiative on 

Educational Excellence and 

African-Americans twitter 

roundtables to discuss the 

issues facing AfricanAmericans with disabilities, 

their families and educators. 

Working with other federal 

agencies and stakeholders in 

2015 to utilize the occasion of 

the 25th Anniversary of the 

ADA to analyze how states 

are faring in meeting the 

goals of the ADA based the 

four key principles to 

determine key goals for 

ADA30.

White House Forum on 

Parenting with a Disability 

 
14

Goals, Measures, and Program Highlights 

Strategic Goal 

Components

Key Measures Program Activity 

Highlights for FY 2014

Potential and Planned 

Activities for FY 2015 and 

2016

provide information to an 

audience of two 

commissioners of the 

Presidential Commission on 

Election Administration 

(PCEA) and provided written 

recommendations, as well, 

based largely on NCD’s Fall 

2013 released report titled, 

The Experience of Voters 

with Disabilities in the 2012 

Election Cycle, a report that 

examines the impact of the 

Help America Vote Act 

(HAVA) of 2002 by 

documenting the 

experiences of voters with 

disabilities during the 2012 

general election cycle. NCD 

documented these accounts 

using an open-ended 

questionnaire, through 

which NCD gathered the 

experiences of nearly 900 

voters with disabilities 

across the nation during the 

2012 election.

As NCD continues to urge 

ratification of the United 

Nations Convention on the 

Rights of Persons with 

Disabilities (UNCRPD), 

NCD provided, in 

conjunction with the United 

States International Council 

on Disabilities (USICD), an 

education forum in 

Washington, DC, with nearly 

100 representatives of the 

disability and veteran 

communities from across 

the country. NCD

developed and provided key 

resource materials for 

participants to increase their 

awareness and 

understanding of the 

provisions in the CRPD and 

to be able to address and 
15

Goals, Measures, and Program Highlights 

Strategic Goal 

Components

Key Measures Program Activity 

Highlights for FY 2014

Potential and Planned 

Activities for FY 2015 and 

2016

respond to misinformation.

Performance Highlights: Real Life Stories

Below are some testimonials from individuals who engaged with NCD in FY 2014 at an 

event or responded to one of the agency’s policy reports:

Performance Highlights-Real Life Stories

Program/Product Program Outcomes and Accomplishments 

Medicaid Managed 

Care Regional Forums

A Kansas citizen with significant and challenging health needs was 

informed by his Managed Care provider that under managed care his 

care plan would be subjected to a 76% reduction in service. 

Following the NCD Topeka, KS Medicaid Managed Care Forum, 

which included key decision makers from the state and CMS, the 

state and MCO provider reconsidered and restored the citizen’s care 

plan consistent with the principles articulated in the NCD Managed 

Care Statement of Principles.

Rocking the Cradle: 

Ensuring the Rights of 

People with Disabilities.

Since releasing Rocking the Cradle, NCD regularly hears from 

parents and advocates encountering discrimination within the child 

welfare and family law systems. In FY14, NCD increased its 

collaboration with DOJ and HHS on this issue. One such example 

involves a young mother with an intellectual disability whose daughter 

was taken by the state and put into foster care directly from the 

hospital at 2 days old. The child has lived in foster care for nearly two 

years, and the state has not provided appropriate supports or 

accessible parenting assessments for the family. Upon learning of 

this, NCD referred the matter to DOJ and both DOJ and HHS are 

presently involved.

NCD connected with a state legislator from Washington and provided 

assistance on a bill seeking to protect the rights of parents with 
16

intellectual and developmental disabilities in dependency proceedings 

and helped to see the bill to final passage into law.

Adoptive parents with disabilities who are familiar with NCD’s work on 

the topic of ensuring the rights of parents with disabilities sought 

assistance when encountering difficulties adopting a child with a 

disability from the People’s Republic of China. NCD’s Executive 

Director worked closely with the U.S. State Department’s Office of 

Special Advisor for International Disability Rights to facilitate the 

successful adoption of an infant with dwarfism whose exit from China 

was encumbered, and not likely to occur without direct intervention.

NCD report on 

Subminimum Wage 

and Supported 

Employment for 

Workers with 

Disabilities

The Council worked effectively with the Administration and the 

Secretary of Labor to ensure that people with disabilities paid under 

14C of the Fair Labor Standards Act would be included in the 

Executive Order increasing the minimum wage for federal contracts to 

$10.10.

NCD disability voting 

roundtable, hosted for 

the Presidential 

Commission on 

Election Administration

The Presidential Commission on Election Administration provided 

feedback to NCD that they were extremely grateful for the assistance 

in convening a cross-disability discussion about voting access 

concerns and found the content incredibly informative and helpful. 

Prior to NCD’s offer to convene the roundtable, the Presidential 

Commission had not heard from any groups from within the disability 

community. The Presidential Commission’s final report reflected a 

great deal of information NCD helped to provide to the Commission 

regarding disability access concerns.

The Performance Section presents the agency’s performance in Fiscal Year 2014, the 

third year of its five-year Strategic Plan, which can be read in its entirety at: 

http://www.ncd.gov/Accountability/strategicplan/. This section also includes a discussion 

of strategies and factors affecting performance, the relationship of outputs to outcomes, 

a summary of methods used to verify and validate performance data, and performance 

results by strategic goal and strategic objectives.
17

Financial Highlights

NCD received an increase in funding in FY 2014 due to Government-wide 

sequestration. Year over year changes in financial position, results of operations and 

key budgetary accounts are summarized below. NCD continues to implement cost 

cutting measures while increasing performance and productivity. 

Financial 

Line Item

FY 2014 FY 2013 Dollar 

Change % Chg Explanation of Change

Total Assets

$1,424,548 $1,003,562 420,986 41.9%

Increase in Fund 

Balance with 

Treasury and 

Advances & 

Prepayments to 

other Federal 

entities.

Total 

Liabilities

$317,791 $476,536 (158,745) -33.3%

Decrease in 

accounts payable

Net Position

$1,106,757 $527,026 579,731 110.0%

Increase in Fund 

Balance with 

Treasury and 

increase in 

accounts payable.

Net Cost of 

Operations $2,650,259 $2,864,127 (213,868) -7.5%

Decrease in 

expenditures

Outlays, net

$2,845,022 $3,023,188 (412,809) -13.7%

Timing of 

payments.

Appropriations

$3,186,000 $3,257,831 (71,831) 2.2%

Sequestration from 

prior years

Obligations 

Incurred

$3,474,233 $2,831,229 643,004 22.7%

Improved 

productivity and 

production due to 

increased 

appropriations.

Undelivered Inadequate staffing 
18

Financial 

Line Item

FY 2014 FY 2013 Dollar 

Change % Chg Explanation of Change

Orders $705,153 $80,945 624,208 771.2% impeded 

contractual activity

Management is working to improve and refine NCD’s fiscal management in concert with 

GSA technical assistance and support services. Major efforts have been initiated in FY 

2014 to better define strategy in a strategic plan, streamline to strategic goals, develop 

more effective measures for strategic objectives, and commence the process for better 

allocation of costs to program activities to better illustrate alignment of costs and goals. 

Combined with initial efforts to improve internal controls over contract monitoring and 

financial reporting, management believes NCD has improved economy and efficiency as 

well as reliability and usefulness of financial reporting.

Discussion and Analysis of Financial Statements

NCD prepares financial statements in conformity with accounting principles generally 

accepted in the United States for Federal Government entities. The Federal Accounting 

Standards Advisory Board has established a framework of integrated budgetary and 

proprietary reporting. Budgetary reporting addresses appropriations, budget authority, 

budgetary resources, obligations, undelivered orders and delivered orders. Proprietary 

reporting is traditional financial reporting of assets, liabilities, net position, and net cost. 

OMB Circular A-136, Financial Reporting Requirements, defines the form and content of 

financial statements, accompanying notes and supplemental information.

NCD’s financial statements are subject to independent audit to ensure they are free from 

material misstatement. No material weaknesses were identified in internal control over 

financial reporting for FY 2014. The financial statements of the National Council on 

Disability were audited and NCD received an unqualified opion for FY2014.Furthermore, 

the audit did not identify any deficiencies in internal control. 

Balance Sheet

The Balance Sheet presents the total amounts available for use by the Council (assets) 

against the amounts owed (liabilities) and amounts that comprise the difference (net 

position). Balance sheets are a snapshot in time (fiscal year end) to an entity’s present 

financial position.

NCD’s assets (items with future value) are virtually all Fund Balance with Treasury 

(FBWT), which represents NCD’s cash balances with the U.S. Treasury from which the 

Council is authorized to make expenditures and pay liabilities from operational activities. 

FBWT is primarily increased by receiving appropriations and primarily decreased by 

making expenditures or cancellations of expired appropriations. NCD’s remaining asset 
19

amounts consist of trivial accounts receivable and a loan receivable from a retired 

employee. While NCD owns computer equipment, furniture and leasehold 

improvements, these items have been fully depreciated or amortized, thus do not 

appear on the balance sheet as property, plant and equipment.

NCD’s liabilities (what entity owes) are entirely current liabilities (due within one year) and 

primarily with the public ($317,791) as opposed to intragovernmental ($16,706). At fiscal 

year ended September 30, 2014, accounts payable with the public were $177,544, as 

opposed to $340,454. This is primarily a result of improved contract management and 

accrual process, as well as the recognition of costs in the current year of multiyear 

contract costs obligated in prior years.

NCD’s net position is a combination of unexpended appropriation and cumulative 

results of operations. Net position decreased significantly due to the decrease in Fund 

Balance with Treasury and increase in accounts payable. Management does not believe 

this change is a meaningful financial measure, and is more reflective of timing 

differences between years, as unused prior year appropriations expire, and contracting 

cycles shorten.

Statement of Net Cost

The Statement of Net Cost presents the annual cost of operating the Council’s

programs on an accrual basis, which means costs are recognized when incurred, not 

when paid. In contrast, outlays are cash basis costs recognized when paid. The major 

difference between accrual and cash on NCD’s books are year-end accounts payable 

accruals and imputed financing costs for employee benefits. Gross costs less any 

earned revenue is used to arrive at the total net cost of operations. NCD has no earned 

revenue. NCD’s net costs were $2,650,259 for FY 2014, down 7.5% from FY 2013’s 

$2,864,127.

Net Cost of 

Operations $2,650,259 $2,864,127 (213,868) -7.5%

Decrease in 

expenditures
20

Major Costs in FY 2014 vs. FY 2013

Cost 

Category FY 2014 FY 2013 Dollar Change % Chg Explanation of Change

Personnel 

Costs

$1,542,491 $1,835,545

(293,054) -16.1%

Vacant Positions

Contractual 

Services

$

744,797

$699,918

44,879 6.4%

Increase in 

contractual services 

due to lack of staff 

resources

Travel $

128,138

$197,586 (44,899)

(69,448) -35.1%

Decrease in 

engagement 

activities

Rent $

255,250

$252,132 3,118 0.1% N/A

Personnel costs consistently account for over 50% of NCD’s net costs of operations 

year over year since the agency is primarily delivering engagement and policy 

development services, which involve Council members and staff with specialized skills 

in disability policy. Contractual services consist primarily of private sector research 

contracts and intergovernmental costs. Rent is for the agency’s headquarters in 

Washington, DC, which houses 9 full time equivalent employees. Travel is related to 

Council meetings and engagement forums. NCD has budgeted for increases in travel 

and contractual services in FY 2015.

NCD’s administrative overhead costs consist primarily of intergovernmental costs with 

federal agency service providers that support independent agencies, leading to cost 

savings for the agency and the federal government overall. The Council uses the 

General Services Administration (GSA) to provide accounting, payroll, human 

resources, facilities management, and legal assistance. Finally, the Government 

Printing Office provides printing services to NCD. The services provided by these 

agencies consume about 10 percent of NCD’s total budget. 

Statement of Changes in Net Position

This statement presents in greater detail the net position section of the Balance Sheet, 

which includes Cumulative Results of Operations and Unexpended Appropriations. The 

statement identifies the activity that caused the net position to change during the 
21

reporting period. The total net position increased by approximately $579,731 for 

reasons explained above.

Statement of Budgetary Resources

The Statement of Budgetary Resources provides information on the source and status of 

budgetary resources made available to the NCD during the reporting period. It presents 

the relationship between budget authority and budget outlays, as well as the reconciliation 

of obligations to total outlays. Total Budgetary Resources and Status of Budgetary 

Resources for FY 2014 was $2,845,022, a decrease of $412,809 or 13.7%. The decrease 

results from timing of payments and the expiration of prior year unused appropriations.

Limitations of the Financial Statements

The principal financial statements have been prepared to report the financial position 

and results of operations of the Council, pursuant to the requirements of 31 U.S.C. 3515 

(b). While the statements have been prepared from the books and records of the 

Council in accordance with U.S. generally accepted accounting principles (GAAP) for 

federal entities and the formats prescribed by OMB, the statements are in addition to 

the financial reports used to monitor and control budgetary resources, which are 

prepared from the same books and records. The statements should be read with the 

realization that they are for a component of the U.S. Government, a sovereign entity.

NCD has a unique mission among federal agencies because it is charged with reviewing 

all programs and policies across the federal government, not merely one aspect of policy 

affecting people with disabilities. While the Council’s independent status allows NCD to 

provide an unbiased overview of many of those agency services and programs, it is the 

nature of NCD’s overview and recommendations that make NCD’s work so important in 

the eyes of those who eventually benefit when those recommendations are acted upon by 

those who have the power to do so. 

The Council produces information critical to improving the delivery of programs to 

individuals with disabilities. The Council’s series of reports and papers study a broad 

array of disability-related laws and programs and has resulted in or documented the 

need for ongoing changes to many of the services needed to sustain the health and 

independence of many of our citizens with disabilities. These reports can be found at 

http://www.ncd.gov/publications. In addition, as related below, NCD has been given 

substantial responsibilities for disability-related issues in the nationwide effort to improve 

emergency preparedness and enhance homeland security.

Management Assurances and Analysis of Controls, Systems and 

Legal Compliance

Implementation of the Federal Managers’ Financial Integrity Act (FMFIA) at NCD
22

Federal agency managers have a fundamental responsibility to develop and maintain 

effective internal controls. Effective internal controls help to ensure that programs are 

managed with integrity and resources are used efficiently and effectively through three 

objectives: effective and efficient operations, reliable financial reporting, and compliance 

with laws and regulations. The safeguarding of assets is a subcomponent of each 

objective.

NCD management is responsible for establishing and maintaining effective internal 

control and financial management systems that meet the objectives of the Federal 

Managers’ Financial Integrity Act (FMFIA) of 1982 as implemented by OMB Circular A123, revised, Management’s Responsibility for Internal Control. Circular A-12 focuses 

on providing agencies with a framework for assessing and managing risks more 

strategically and effectively. The Circular contains multiple appendices that address, at 

a more detailed level, one or more of the objectives of effective internal control. 

Appendix A provides a methodology for agency management to assess, document, test 

and report on internal controls over financial reporting. 

Appendix B requires agencies to maintain internal controls that reduce the risk of fraud, 

waste, and error in Government charge card programs. Appendix C implements the 

requirements of the Improper Payments Information Act, as amended by the Improper 

Payments Elimination and Recovery Act, which includes measurement, reporting, 

recovery and remediation. As a small, independent agency covered by the 

Accountability of Tax Dollars Act of 2002 as opposed to the CFO Act, NCD is exempt 

from many formal reporting requirements in Circular A-123.

The FMFIA requires federal agencies to provide an annual statement of assurance 

regarding management controls and financial systems. The objectives of NCD’s internal 

controls are to provide reasonable assurance that:

• Obligations and costs are in compliance with applicable laws and budget 

restrictions;

• Assets are safeguarded against waste, loss, unauthorized use, or 

misappropriation;

• Revenues and expenditures applicable to NCD operations are properly recorded 

and accounted for to permit the preparation of accounts and reliable to financial 

and statistical reports, and to maintain accountability over assets; and

• All programs are efficiently and effectively carried out in accordance with 

applicable laws and management policy.

Section 2 of the FMFIA requires federal agencies to report, on the basis of annual 

assessments, any material weaknesses that have been identified in connection with 

their internal and administrative controls. 

NCD’s completed an independent audit of financial statements for FY 2014 to ensure 

the agency is free from material misstatement. No material weaknesses were identified 

in internal control over financial reporting for FY 2014. The financial statements of the 
23

National Council on Disability were audited and NCD received an unqualified opion for 

FY2014.Furthermore, the audit did not identify any deficiencies in internal control. 

This resulted in an unqualified assurance that NCD’s systems and management 

controls comply with the requirements of the FMFIA. During FY 2014, the Council’s 

Audit and Finance Committee and NCD management focused efforts on streamlining 

financial processes and monitoring the operating effectiveness of key controls, such as 

monthly reconciliations of agency data to service provider data, quarterly analysis of 

financial statements, monitoring contracts and undelivered order status of open 

obligations, and year-end search for unrecorded liabilities and preparing year-end 

accruals. Accordingly, NCD’s assurance on its internal controls was unqualified based 

on the reviews and consideration of internal analyses, reconciliations and the findings 

identified in the Independent Auditor’s Report on Internal Control Over Financial 

Reporting, 

Section 4 of the FMFIA requires that agencies' financial management systems controls 

be evaluated annually. NCD relies upon GSA for the evaluation of its financial 

management systems for the fiscal year ending September 30, 2014 in accordance with 

the FMFIA and OMB Circular No. A-127, Financial Management Systems, as 

applicable. NCD uses GSA as its accounting service provider. GSA’s financial 

management systems conform to the principles and standards required under Section 4 

of the FMFIA. Accordingly, NCD is able to provide reasonable assurance under Section 

4 of the FMFIA. 

Legal Compliance

Federal agencies are required to comply with a wide range of laws and regulations, 

including appropriations, employment, ethics, health and safety, and others. 

Responsibility for compliance primarily results with agency management. Compliance is 

addressed as part of agency financial statement audits. Agency auditors test for 

compliance with selected laws and regulations related to financial reporting. The FY 

2014 audit did not report any instances of non-compliance. Management comments on 

compliance efforts with specific laws and regulations are below.

Federal Financial Management Improvement Act (FFMIA)

Agencies subject to the Accountability of Tax Dollars Act (ATDA) of 2002 are not 

subject to the requirements of FFMIA. Accordingly, NCD is not subject to the 

requirements of FFMIA. However, OMB A-136, revised, requires NCD to be in 

compliance with FFMIA. NCD uses GSA as its accounting service provider. GSA’s 

financial management systems conform with the principles and standards required 

under OMB A-136 and FFMIA.

Improper Payments Elimination and Recovery Act 
24

The Improper Payments Information Act (IPIA—P.L. 107-300) requires federal agencies 

to identify and report on significant payment programs that are susceptible to improper 

payments. The Act defines significant improper payments as those within a single 

payment program that exceed both 2.5 percent of that program’s annual amounts paid 

and $10 million annually. 

The Improper Payments Elimination and Recovery Act of 2010 (IPERA), enacted on 

July 22, 2010, requires the development of policies and procedures for the prevention 

and detection of improper payments in the federal government. The Act expands on the 

Improper Payments Information Act of 2002 (IPIA), which requires an initial assessment 

to identify those programs that are susceptible to significant risk of improper payments. 

“Significant,” as defined in the Act, means that in the preceding fiscal year, improper 

payments in the program or activity may have exceeded $10,000,000 of all program or 

activity payments made during that fiscal year reported and 2.5 percent of program 

outlays; or $100,000,000.

NCD does not have any programs where significant erroneous payments have occurred 

within the agency. The Council will continue to review its financial operations on an 

annual basis to determine if any significant erroneous payments exist.

Prompt Payment Act

The Prompt Payment Act requires federal agencies to make timely payments to 

vendors, including any interest penalties for late invoice payments. In FY 2014, the NCD 

paid an immaterial amount in interest penalties on invoices processed. However, in the 

Rocha and Company, PC final report, NCD’s auditors found that:

“The Council does not appear to comply with the Prompt Payment Act. During our 

audit, we noted instances where payments to contractors and vendors were not made 

within the required 30-day stipulation.” 

NCD implemented procedures that will ensure that all payments are made within the 

timeframe prescribed by the Prompt Payment Act.

Chairman’s Assurance on Internal Control-The following pages contain NCD 

Chairman’s Statement of Assurance on Internal Control.
25

Chairman’s Statement of Assurance 

The Council's management is responsible for establishing and maintaining effective internal 

control and financial management systems that meet the objectives of the Federal 

Managers' Financial Integrity Act (FMFIA). Based on the findings of the FY2013 Audit, the 

Council took aggressive steps in ensuring that its internal control over the effectiveness and 

efficiency of operations and compliance with applicable laws and regulations were in place 

and working effectively moving forward. As a result no material weaknesses were 

identified in internal control over financial reporting for FY 2014. The NCD received an 

unqualified opinion for FY2014. Furthermore, the audit did not identify any deficiencies 

in internal control. 

NCD is continually in monitoring internal control effectiveness. Operating with a small staff 

and under limited resources, the Council relies highly on the effectiveness and good-faith 

efforts of a staff. The Council has hired permanent full-time staff with the skills to implement 

and maintain the key function of agency operations and to ensure continuity in operation. 

As the Council closes its FY2014 books, we have developed controls to identify failures or 

deficiencies in real-time to ensure that corrective measures will be taken while they still can 

still be remedied. The Council's goal is to become a model small independent agency with 

regard to financial procedures and controls. ln FY2015, the Council intends to strengthen its 

financial oversight by cross training key personnel to ensure ongoing compliance and 

continuity of NCD’s financial operations. Additionally, the Audit and Finance Committee is 

tasked with the oversight of increased transparency and accountability of the financial 

management of the agency. 

Based on our assessment, we have determined that the Council's financial systems 

conform to applicable financial systems requirements.

Jeff Rosen

Chairperson

February 6, 2015
Performance Section

26

The Performance Section presents the agency’s performance in Fiscal Year 2013, the 

first year of its five-year Strategic Plan, which can be read in its entirety at: 

http://www.ncd.gov/Accountability/strategicplan/

This section also includes a discussion of strategies and factors affecting performance, 

the relationship of outputs to outcomes, a summary of methods used to verify and 

validate performance data, and performance results by strategic goal and strategic 

objectives.

Performance Framework

NCD’s performance framework consists of a mission statement supported by a single, 

overarching strategic goal supported by two strategic objectives that advances NCD’s 

statutory mandate. The two supporting objectives and their corresponding strategies 

indicate how NCD will achieve its goal and provide an approach for measuring NCD’s 

progress and success. The strategic framework in the table below is followed by a 

detailed view of each objective and its corresponding strategies, key outcomes, means 

and key activities, and performance measures follows the overview.

Mission

Promote equality of opportunity, full participation, independent living 

and economic self-sufficiency of people with disabilities of all ages 

and backgrounds by providing advice, analysis and 

recommendations on disability policy to the President, congress 

and other federal agencies.

Vision

NCD leads by facilitating, articulating and promoting inclusion and 

empowerment of individuals with disabilities to live, learn and earn 

based on informed choices.

Strategic 

Goal

Advance the goals of the Americans with Disabilities Act by 

promoting policies, programs, practices, and procedures that 

guarantee equal opportunity and provide for economic selfsufficiency, independent living, and inclusion and integration

into all aspects of society for individuals with disabilities.

Strategic 

Objectives

Engagement - Engage stakeholders in order to assess concerns 

and priorities and build a network of NCD partners.

Policy Development & Collaboration – Address stakeholder 

concerns and priorities by advancing specific, practical, policy 

solutions and encouraging collaboration.
Performance Section

27

Stakeholders

All Americans with disabilities – a population diversified by 

geography, age, race, gender, ethnicity, sexual orientation, 

income, education, political party, type of disability, and other 

affiliations and identities.

Policymakers and decision makers – including the President 

and all federal agencies, Congress, state, tribal, and local 

governments and communities – who create and implement 

federal policies and programs that affect people with disabilities.

Groups and organizations concerned with people with 

disabilities.

Families and support systems of people with disabilities, 

including parents and guardians. 

Society at large – employers, educators, manufacturers, 

service providers, engineers, designers, entertainers, and other 

individuals and organizations who influence inclusion and 

participation of Americans with disabilities.

NCD has developed specific strategies and measurements of outcomes, means and 

key activities for its two strategic objectives.

Strategic 

Objective #1

Engagement – Engage stakeholders in order to assess concerns and 

priorities and build a network of NCD partners.

Overview: NCD cannot fulfill its mission without regular, meaningful engagement with its 

stakeholders. NCD’s authorizing statute mandates this valued interaction. More importantly, 

the value of policy evaluation and recommendations should be measured by whether they 

are consistent with the needs, challenges, and aspirations of NCD’s stakeholders. By 

facilitating meaningful communication with stakeholders, Objective 1 (Engagement) 

supports the agency’s strategic goal through identification of systems of success as well as 

shortfalls, toward which NCD can direct its attention in the formulation of policy solutions. 

Over the last several years, NCD has closely consulted stakeholders as key advisors in 

shaping NCD’s policy endeavors. NCD gathers information through a variety of means: 

public testimony, national and regional forums, electronic mail or letters from the public, 

public consultations via the Internet, research reports, conferences and meetings of 

stakeholder groups, federal workgroups, and meetings with members of Congress or their 

staff. In addition, NCD has also pursued creation of public-private working groups and/or 
Performance Section

28

federal advisory committees on priority issues to ensure NCD is both in continual contact with 

stakeholders and to act nimbly and efficiently when responding to identified need for action.

Strategy 1A – Create and maintain regular opportunities to receive direct input from 

community stakeholders: Coordinated collaboratively by the General Counsel and Policy 

Directorate and Legislative Affairs and Outreach Directorate, NCD will develop and 

implement an annual outreach plan to provide meaningful venues for direct contact with 

disability community stakeholders on a regular basis.

Strategy 1B – Cultivate trusted relationships with Congress: Coordinated 

collaboratively by the General Counsel and Policy Directorate and Legislative Affairs 

and Outreach Directorate, NCD will develop and implement a program for meaningful 

NCD engagement with Congressional Members and their staff and Committee 

leadership and their staff.

Strategy 1C – Establish and cultivate trusted relationships with state, local, and 

tribal governments and other entities: Coordinated collaboratively by the Legislative 

Affairs and Outreach Directorate and the General Counsel and Policy Directorate, NCD 

will develop and implement a program for meaningful NCD engagement with leaders of 

state, local, and tribal governments and other entities. 

Strategy 1D – Brand NCD as a principal national voice of the disability 

community: Coordinated by the Legislative Affairs and Outreach Directorate, NCD will 

develop and implement a communications plan to develop messages and modes of 

delivery designed to enhance the understanding of NCD’s mission, activities, and 

accomplishments with its stakeholders.

Strategic 

Objective #2

Policy Development & Collaboration – Address stakeholder 

concerns and priorities by advancing specific, practice policy solutions 

and encouraging collaboration.

Overview: Using the information NCD has gained from its engagement activities with its 

stakeholders, as outlined in Objective 1 (Engagement) above, NCD must identify and 

prioritize opportunities to add value and make a difference in peoples’ lives. NCD does 

not have rulemaking or enforcement authority. Rather, NCD serves as an independent 

advisor on disability matters to the President and Congress. This role is essential to 

assure the Federal Government is well-informed and qualified to perform its duties and 

effectively serve the public, including individuals with disabilities. In addition to meeting 

with stakeholders, NCD advocates for equality of opportunity, full participation, 

independent living, and economic self-sufficiency for people with disabilities of all ages 

and backgrounds by continually reviewing disability programs and policies and providing 

analysis and recommendations on disability policy to the President, Congress, and 

other federal agencies. 
Performance Section

29

NCD’s analysis and recommendations have led to enactment of important laws and 

other improvements to the programs and services provided by the many federal 

agencies that serve the disability community. Yet people with disabilities continue to 

face personal, social, and economic disadvantages and barriers that prevent access to 

the same opportunities as Americans without disabilities. Therefore, NCD will increase 

emphasis on providing recommendations and looking for opportunities for their 

implementation. 

NCD optimizes opportunities to put to practical use its vast amount of acquired 

knowledge through years of intensive research activities. This research is reflected in 

NCD’s reports, papers, and briefs which each contain analysis and recommendations 

for actions at all levels of government. These reports and papers are available on 

NCD’s agency website at www.ncd.gov. 

Objective 2 (Policy Development & Collaboration) supports the activities of identifying and 

formulating solutions to emerging and existing challenges; providing tools to facilitate effective 

implementation of policy solutions; and engaging and influencing current debates, all of which 

directly support the strategic goal. Further, Objective 2 supports the strategic goal by 

leveraging NCD’s resources through coordination and collaboration to amplify its impact 

relative to the agency’s size.

Strategy 2A – Cultivate trusted relationships with other federal agencies and look 

for opportunities to coordinate and work collaboratively: Coordinated collaboratively 

by the General Counsel and Policy Directorate and Legislative Affairs and Outreach 

Directorate, NCD will develop and implement a program for meaningful NCD engagement 

with other federal agencies. 

Strategy 2B – Work closely with and enlist the support of stakeholders to develop 

and advance policy responses to priority issues: Coordinated collaboratively by the 

General Counsel and Policy Directorate and Legislative Affairs and Outreach 

Directorate, NCD will develop and implement a program to partner with a cross-section 

of stakeholders to consider priority policy issues and strategic activities to address 

them, and to support successful implementation of federal legislation that benefits 

people with disabilities. 

Strategy 2C – Produce materials that have practical utility for federal, state, tribal 

and local stakeholders regarding successful implementation of federal policies: 

Coordinated collaboratively by the General Counsel and Policy Directorate and 

Legislative Affairs and Outreach Directorate, NCD will produce and disseminate shorter, 

timely policy briefs, white papers, “policy toolkits,” and other materials. 

Strategy 2D - Update NCD’s annual progress report to be more responsive to 

Congress and the Administration: Coordinated collaboratively by the General 
Performance Section

30

Counsel and Policy Directorate and Legislative Affairs and Outreach Directorate, NCD 

will develop a new model for its statutorily mandated annual progress report that will 

contain a significant discussion of the overall state of the disability community and the 

policies affecting it based upon information NCD acquires through use of strategies 

envisioned throughout this plan.

Performance Measurement Challenges

NCD is a micro-agency that advises the President and Congress on disability policy by 

engaging with the community, setting policy priorities and working in such areas, 

developing policy recommendations and promoting progress and systems change on 

issues that affect the disability community. With a budget of only $3.2 million, 15 parttime Council Members, and 13 full-time staff (when fully staffed), NCD has adopted a 

strategy of working in conjunction with a wide range of stakeholders – including people 

with disabilities, federal, state and local agencies, elected officials and their staff, 

universities, and a diverse group of non-profit organizations and individual disability 

policy experts and advocates – to advance our mission, goals and objectives. 

NCD’s strategic objectives of engagement and policy development can be quantifiably 

measured by our raw data and enumerating the number of people that attend our 

forums, regularly engage with us via social media, download and read our policy 

reports, and adopt or promote our recommendations. However, measuring NCD’s 

impact on its strategic goal of guaranteeing equal opportunity and providing for 

economic self-sufficiency, independent living, and inclusion and integration into all 

aspects of society for individuals with disabilities is far more subjective since these are 

systemic endeavors in which NCD is part of a community of agencies, advocates, and 

others seeking to secure such outcomes. 

Accordingly, NCD’s analysis of the relationships of program outputs (such as forums and 

reports) to tangible outcomes impacting our stakeholders requires a multi-year time 

horizon. Measuring NCD’s impact on its strategic goal of guaranteeing equal opportunity 

and providing for economic self-sufficiency, independent living, and inclusion and 

integration into all aspects of society for individuals with disabilities is challenging since 

these are large-scale, long-term endeavors. 

Accordingly and as previously mentioned, as we evaluate performance measurements, 

key measures, targets and outcomes, we ask:

• Has NCD identified critical needs where our engagement with stakeholders and 

policy development and collaboration can advance existing initiatives?

• Can NCD be a thought leader, performing important research and analysis on 

critical topics?
Performance Section

31

• Can NCD provide practical, timely policy recommendations and consultations to 

Members of Congress and the Executive Branch? 

NCD is continually working to identify better mechanisms for measuring outcomes and 

reporting achievements. This includes increased efforts to gather and report personal 

stories of where our engagement or policy initiatives provided a spark or tipping point 

toward improving the lives of people with disabilities. The Performance Highlights 

section of the Management’s Discussion and Analysis presents specific comments from 

impacted stakeholders and a case study of how engagement and policy converged into 

positive outcomes on the issue of parenting rights of people with disabilities.

Program Activities and Performance Results by Strategic Objectives

As indicated above, NCD has one overarching strategic goal and two strategic 

objectives to advance the agencies mission, strategic goal and statutory responsibilities. 

Below is a description of key policy and program accomplishments in FY 2012 and 

planned future activities.

Objective 1: Engagement

NCD is an advisory agency that seeks to provide timely, valuable counsel to the 

President, Congress and other federal agencies regarding policies, programs, practices, 

and procedures that affect people with disabilities. NCD views its diverse stakeholders –

people with disabilities of all ages and types of disability; groups and organizations 

concerned with people with disabilities; policymakers; and families and support system 

of people with disabilities – as key informants to the development of NCD’s policy 

recommendations. Accordingly, NCD prioritizes creating opportunities to hear from its 

stakeholders through a variety of means: regional policy forums; public testimony 

received at meetings in person or by telephone; letters of concern from the public; 

participation at conferences and meetings of stakeholder groups; congressional policy 

briefings; and listening sessions and town halls the agency hosts throughout the year.

In addition to these opportunities, NCD’s legislation mandates a minimum of four public 

meetings annually. Some of NCD’s most important activities occur during the quarterly 

meetings. Public comments, full-length presentations by stakeholders, and opportunities 

to meet with additional stakeholders in the disability community who attend the meetings 

afford NCD the opportunity to identify needs as well as promising practices in 

communities and regions across the country. NCD also has a history of playing a 

convening role, advancing policy discussions in the process, by bringing diverse 

stakeholders together that may not otherwise have policy discussions with one another. 

Fiscal Year 2014

In FY2014, NCD hosted several such gatherings on the topics stakeholders have 

indicated they want to hear the most about and that build on our previous work: 
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• NCD, in conjunction with the United States International Council on Disabilities 

(USICD), held an education forum in Washington, DC, with nearly 100 

representatives of the disability and veteran communities from across the 

country. The educational forum was an opportunity to hear from leaders and 

experts from various disability, veteran, faith and business organizations involved 

in promoting greater understanding of the importance of the treaty and the 

process for ratification. The UNCRPD offers a vital framework for creating 

legislation and policies around the world that embraces the human rights and 

dignity of all people with disabilities. 

• From December 2013 to June 2014, NCD collaborated with federal agency 

representatives, including the Center for Medicare and Medicaid Services (CMS) 

and disability leadership stakeholders to obtain input in the planning and 

implementation of Medicaid managed care through a series of five community 

forums in federal fiscal year 2013-2014 which have been so far held in Topeka, 

KS; Tallahassee, FL; Chicago, IL; Sacramento, CA; and New York, NY 

Upcoming forums will be held in Atlanta, GA; Philadelphia, PA; Baton Rouge, LA; 

and Seattle, WA. The forums promote consumer and stakeholder engagement 

with federal and state officials and feature facilitated discussion of experiences, 

preferences and desired outcomes for Medicaid managed care as described by 

disability leadership; federal and state agency representatives, health plans, and 

providers. At the forums, NCD uses the Medicaid managed care principles 

outlined in the NCD report, “Medicaid Managed Care for People with Disabilities”ii

to help frame discussions and the values guiding policy transitions in the states. 

• In May 2014, NCD held a congressional briefing on Capitol Hill in conjunction 

with the release of a report examining the accessibility of communication before, 

during and after emergencies for people with sensory disabilities (deaf, hard of 

hearing, blind, low-vision, deaf-blind and speech disabilities) as well as people 

with intellectual, developmental and/or psychiatric disabilities. In the report, NCD 

documented successful practices and barriers to effective emergency 

communications. This study, released during National Hurricane Preparedness 

Week, was conducted to help emergency planners and state and local officials 

provide effective communication to people with disabilities before, during and 

after emergencies. The briefing was well-attended by congressional staff and 

state and local emergency managers. 

• In June 2014, NCD co-hosted a forum on issues related to adoption and foster 

care and people with disabilities. The Bipartisan Disabilities Caucus, 

Congressional Coalition on Adoption Institute, National Council on Disability, 

Child Welfare League of America, National Association of Social Workers and 

the American Psychological Association joined with NCD to host this event. The 

forum was well attended by congressional staff and representatives of applicable 
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federal agencies with regulatory and enforcement responsibilities in these topics. 

The forum explored the disproportionate number of parents with disabilities who 

have had to fight within the child welfare system to retain or sometimes gain 

custody of their own children as well as the issues faced by people with 

disabilities who would like to become parents either through domestic or foreign 

adoption or through assistive reproductive technologies.

• In July 2014, NCD convened a congressional forum on the status of parents with 

disabilities and their families. Through the invited testimony several panels of 

witnesses as well as the questions asked of the witnesses by the NCD Council 

Members, the forum highlighted the barriers people with disabilities are facing in 

creating and maintaining strong families and examined what policy measures are 

either underway or are needed to address the persistent barriers experienced by 

people with disabilities when attempting to exercise their fundamental and 

cherished right to parent. Testimony was presented from both individuals with 

disabilities and Republican and Democratic state lawmakers, as well as child 

welfare experts on the frequent incidence of parents with disabilities to be 

challenged in guardianship proceedings or challenged for their abilities to perform 

as parents. Child welfare experts and others provided expert testimony 

disapproving such beliefs.

In addition to congressional and intergovernmental engagement, NCD also continued to 

actively solicit and collect public comments as a regular part of its quarterly meetings. 

In addition to oral remarks made, with every meeting, NCD also receives numerous 

written comments in advance. Comments received before and during NCD’s four 

quarterly meetings in FY 2014 were wide-ranging but included those about the U.N 

Convention on the Rights of Persons with Disabilities, the futility care policies of states 

and hospitals, deinstitutionalization policies, chemical and electrical sensitivities, and 

voting poll access.

In addition to congressional and intergovernmental engagement, NCD also continued to 

actively solicits and collects public comments as a regular part of its quarterly meetings. 

In addition, with every meeting, NCD also receives numerous written comments in 

advance, in addition to the oral remarks made. Comments during NCD’s four quarterly 

meeting in FY 2013 were focused on workplace accommodations, the U.N Convention 

on the Rights of Persons with Disabilities, futility care policies of states and hospitals, 

deinstitutionalization, access to service for children with complex medical needs, and 

special education policy.

Conferences and Other Speaking Engagements – NCD receives numerous 

invitations each year to speak at state, national, and international conferences and other 

events and makes good use of the opportunities it accepts by sharing its latest policy 

findings and recommendations with hundreds of attendees at each event. In FY 2013, 

NCD participated in over 50 outreach events increasing last year’s total by 1/3rd with our 
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media exposure more than doubling last year’s totals. Events included interviews, opeds, presentations at national and state level conferences/meetings, webinars and 

testimony. These extend beyond our report releases and hearings and often lead us to 

new work and exciting new working relationships. Highlights included: 

• NCD submitted a policy session proposal regarding Medicaid managed care and 

people with disabilities to the National Conference of State Legislators (NCSL) 

for their annual legislative summit, which hosts thousands of state legislators 

and international policymakers each year. After NCSL accepted the proposal, 

NCD assisted in identifying appropriate speakers and producing policy materials 

for the session, which was attended by approximately 150 state legislators. 

• NCD staff co-authored an op-ed on law enforcement’s response to people with 

disabilities featured in The Atlantic . 

• NCD Council members and staff were quoted and its work highlighted numerous 

times throughout the year in a variety of state, local, and national news 

broadcasts, newspapers, magazines, and blogs, including the Associated Press, 

Fox News, Washington Post, and many, many others. 

• In ongoing cross-agency collaboration, NCD has maintained a regular presence 

in posts to Disability.gov’s blog and participation in the White House Initiative on 

Educational Excellence and African-Americans weekly Twitter Roundtables. 

• NCD Council Members continue their engagement with the tech industry through 

meetings with representatives of Facebook, Twitter, Google and Apple to 

discuss accessibility. A Council Member provided the keynote presentation at 

the M-Enabling conference on the topic of social media accessibility, and at a 

Linux Conference in Chicago.

• As an outcome of the engagement in the social media accessibility meeting 

noted above, the Federal Emergency Management Agency (FEMA) organized 

and ran a social media access 'hackathon', which NCD helped to promote, and 

NCD collaborated with ODEP again to run three on-line dialogues on social 

media access, technology and employment opportunities.

• NCD utilized a different format to host a stakeholder forum in Berkeley, California 

in which participants determined the content and presentations of the event. 

More than 270 people attended over two days of policy discussions that 

addressed everything from the school-to-prison pipeline for students with 

disabilities to accessible transportation, housing futures for the thousands of 

autistic adults flooding current services, and encouragement of new technology, 

including transportation network companies, to be fully inclusive. The major 
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areas of focus that came out of this meeting ensured that the Council continues 

engaging on the issues that matter to Americans with Disabilities from outside 

the beltway.

• An NCD staff member and author of the Rocking the Cradle report presented at 

numerous academic, legal, and policy events on the topic of ensuring the rights 

of parents with disabilities and their children.

• NCD took a leadership role in two major White House firsts. The first ever Black 

History Month event discussing the contributions of African-Americans with 

Disabilities, and the first ever LGBT/ADA Pride event, discussing the issues 

facing LGBT Americans with Disabilities.

• NCD members met with the Department of Justice, the National Economic 

Council and representatives of the Domestic Policy Council discuss NCD’s work 

on subminimum wage.

• NCD Council Members maintained ongoing collaboration with the Vice 

President’s Office in response to the Newtown school shooting about youth with 

mental health disabilities. 

• NCD presented to the Kansas legislature about managed care.

Through these engagements activities NCD reached over 10,000 people.

Congressional and Federal Agency Engagement – Throughout FY 2014 NCD 

continued to cultivate and deepen relationships with staff of congressional offices as a 

trusted advisor in both Member and committee offices and federal agencies. NCD 

responds to calls and letters from individual congressional offices throughout each year 

that request disability-related information regarding constituents’ needs. In addition to 

being a resource for Members’ district offices, NCD strives to provide timely policy 

information and recommendations to legislative offices and federal agencies. NCD staff 

provided electronic copies of its policy reports and papers to legislative directors in the 

House and Senate and appropriate federal agencies throughout the past fiscal year. In 

addition, NCD staff has offered policy briefings on its reports’ major findings and 

recommendations, as well, utilizing teleconferences and in-person Hill and agency 

briefing formats. Some highlights of NCD’s FY14 congressional activity include the 

following:

• Over several months and iterations, NCD provided suggested language changes 

to the Integrated Public Alert Warning System (IPAWS) legislation considered in 

the House regarding increasing requirements regarding its accessibility. Those 

changes were incorporated into the legislative language in the version that was 
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passed by the House Homeland Security Committee. 

• NCD provided briefings of its Clearing the Backlog and Facilitating Benefits for 

Veterans with Disabilities report to the House Veteran Affairs Committee and the 

Senate Veteran Affairs Committee.

• In May 2014, NCD held a congressional briefing on Capitol Hill in conjunction 

with the release of a report examining the accessibility of communication before, 

during and after emergencies for people with sensory disabilities (deaf, hard of 

hearing, blind, low-vision, deaf-blind and speech disabilities) as well as people 

with intellectual, developmental and/or psychiatric disabilities. In the report, NCD 

documented successful practices and barriers to effective emergency 

communications. This study, released during National Hurricane Preparedness 

Week, was conducted to help emergency planners and state and local officials 

provide effective communication to people with disabilities before, during and 

after emergencies. The briefing was well-attended by congressional staff and 

state and local emergency managers.

• In June 2014, NCD co-hosted a forum on issues related to adoption and foster 

care and people with disabilities. The Bipartisan Disabilities Caucus, 

Congressional Coalition on Adoption Institute, National Council on Disability, 

Child Welfare League of America, National Association of Social Workers and 

the American Psychological Association joined with NCD to host this event. The 

forum was well attended by congressional staff and representatives of applicable 

federal agencies with regulatory and enforcement responsibilities in these topics. 

The forum explored the disproportionate number of parents with disabilities who 

have had to fight within the child welfare system to retain or sometimes gain 

custody of their own children as well as the issues faced by people with 

disabilities who would like to become parents either through domestic or foreign 

adoption or through assistive reproductive technologies.

• In July 2014, NCD hosted a congressional forum on the challenges facing parents 

with disabilities. Active participants and supporters of this hearing included state 

legislators who have passed or proposed state legislation to protect the rights of 

parents with disabilities in their states; the American Psychological Association; 

the National Association of Social Workers; the National Center on Parents with 

Disabilities and their Families; and the National Council on Independent Living.

In FY 2014, the Chairperson and Executive Director continued to engage in extensive 

outreach to NCD’s federal agency partners. NCD met with colleagues at over 50 

agencies, sub-agencies, and Hill offices to continue partnership conversations and zero 

in on key policy foci of NCD, including the Office of Federal Contracts and Compliance 

Programs (Section 503 regulations), the Pentagon (ADA compliance and international 
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installations), U.S. Department of Agriculture (farm bill & rural housing issues), the 

Office of Veterans Affairs and the Veterans Benefits Administration (disability claims 

backlog), the Department of Defense (disability claims backlog), Joining Forces of the 

Office of the First Lady at the White House (disability claims backlog), the Office of the 

Vice President (mental health & gun control) as well as our traditional partners of the 

Departments of Education, Health and Human Services, and the Social Security 

Administration. 

Understanding the critical role NCD plays in bringing a diversity of voices representing 

Americans with disabilities to the White House and the Congress, NCD has worked to 

maintain relationships with non-disability diversity organizations including but not limited 

to the Leadership Conference for Civil and Human Rights, the Human Rights 

Campaign, the Asian American Justice Coalition, the American Civil Liberties Union, the 

National Council of La Raza, and the National Black Justice Coalition. This has resulted 

in the Council ensuring that communities of color are at the table as we discuss critical 

issues but also that feedback from these communities is integrated as NCD determines 

its policy priorities. 

As referenced later in this narrative, NCD continued its dedicated focus on emergency 

management, closely collaborating with the Federal Emergency Management Agency 

(FEMA) within the U.S. Department of Homeland Security through weekly calls with the 

Director of the Office of Disability Integration and Coordination. NCD has also provided 

updates to the House Homeland Security Committee’s Subcommittee on Emergency 

Preparedness, Response and Communications on this collaboration, as well as other 

critical areas of emergency management, to help inform the oversight role of the 

Committee. 

Finally, in keeping with NCD’s strategic plan goal to leverage media more aggressively 

to help brand NCD and help frame national conversations on disability, NCD Members 

and staff were highlighted in numerous state, local, national and international media 

pieces on a broad range of topics.

Highlights of NCD’s media placement in FY14 include:

• NCD’s Executive Director received a long quote by the Washington Post 

following NCD’s support of the historic White House event on the intersection of 

the LGBT and disability communities in FY14. 

• NCD’s Public Affairs Specialist co-authored an opinions article in The Atlantic 

titled “How Misunderstanding Disability Leads to Police Violence.” This piece has 

led to subsequent pieces in The Daily Beast, and the Huffington Post.

• NCD’s Attorney Advisor wrote an article in GPSolo: A Publication of the 

American Bar Association, titled “Can Parents Lose Custody Simply Because 
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They Are Disabled?” regarding key findings and recommendation in NCD’s 

Rocking the Cradle report. 

• Kansas newspapers, television newscasts and online blogs were abuzz for most 

of December 2013 following NCD’s Medicaid managed care forum following 

NCD’s suggestion that there should be a one year delay of KanCare’s 

developmental disabilities carve-in given the degree of problems identified in the 

roll-out of Medicaid managed care in the state thus far. 

These activities, in combination with regular and numerous in-office meetings, including 

with international delegations, demonstrate that NCD has maintained a large impact, 

relative to its size. NCD continues to make strides in being a national voice of the 

disability community, reflective of the community’s wide range of disability types, 

geography, age, and cultural diversity.

Fiscal Year 2015

In Fiscal Year 2015, the National Council on Disability (NCD) will work with our federal 

partners and stakeholders to advance the goals of the Americans with Disabilities Act 

(ADA) by promoting policies, programs, practices, and procedures that guarantee equal 

opportunity and provide for economic self-sufficiency, independent living, and inclusion 

and integration into all aspects of society for individuals with disabilities. NCD is 

committed to approaching its work with an inclusive lens that learns about, includes, 

and respects various perspectives and backgrounds, including multi-generational 

perspectives, reflected in the disability community. Impact the development and 

implementation of Medicaid managed care systems across the country to ensure they 

are successful for beneficiaries with disabilities;

• Work with congressional staffers toward introduction of federal legislation that 

emphasizes and invests in integrated, individualized supported employment and 

deemphasizes and shifts resources away from segregated, subminimum wage

employment;

• Work with congressional staffers toward introduction of federal legislation that 

clarifies and safeguards the rights of parents with disabilities; 

• Work with federal agencies toward development of guidance that clarifies rights 

and protections of parents with disabilities within a variety of circumstances;

• Develop definitions of and offer mechanisms to measure the quality of home- and 

community-based services;

• Offer policymakers a viable policy roadmap to reform Social Security’s disability 

program;
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• Assist federal partners, congressional staff, and Administration officials in seeing 

an elimination of the veterans disabilities claim backlog;

• In concert with industry partners, develop and facilitate solutions to accessibility 

issues using social media; and

• Work with state and federal partners to sharpen the focus outcomes based 

compliance and monitoring for students with disabilities in kindergarten through 

twelfth grade with particular emphasis on literacy, high school graduation, and 

post-secondary enrollment.

Objective 2: Policy Development & Collaboration

NCD contributes to the promotion of successful disability policies in education, 

transportation, emergency preparedness, international disability rights, employment, 

foster youth with disabilities, vocational rehabilitation, livable communities, and crime 

victims with disabilities - to name a few. This section outlines NCD’s activities in this 

area for FY 2014 and what the agency has planned for 2015 and 2016.

Fiscal Year 2014

In FY 2014, NCD held multiple forums and completed several reports, including:

• Clearing the Backlog and Facilitating Benefits for Veterans with Disabilities:

http://www.ncd.gov/publications/2013/11122013/

• Experiences of Voters with Disabilities in the 2012 Election Cycle: 

http://www.ncd.gov/publications/2013/10242013/

• NCD Educational Forum Report: United Nations CRPD: 

http://www.ncd.gov/publications/2013/12122013/

• A Promising Start: A Preliminary Analysis of Court Decisions of the ADA 

Amendments Act: http://www.ncd.gov/publications/2013/07232013/

• A Medicaid Block Grant Program: Implications for People with Disabilities: 

http://www.ncd.gov/publications/2013/05222013/

• The Case for Medicaid Self-Direction: A White Paper on Research, Practice and 

Policy Opportunities: http://www.ncd.gov/publications/2013/05222013A/

• Medicaid Managed Care for People with Disabilities: 

http://www.ncd.gov/publications/2013/20130315/
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• Toward the Full Inclusion of People with Disabilities: Examining the Accessibility 

of Overseas Facilities and Programs: 

http://www.ncd.gov/publications/2013/032013/

• National Disability Policy: A Progress Report: 

http://www.ncd.gov/progress_reports/10312013

In FY 2014 NCD’s Annual Progress Report, we mark 30 years of progress on disability 

rights, while also highlighting outstanding barriers. We have updated a series of data 

tables that look at trends in disability policy including voting, housing rights, IDEA 

enforcement, transportation and other markers of independence. 

In October 2013, NCD released, “Experience of Voters with Disabilities in the 2012 Election 

Cycle,” to gauge the effectiveness of the Help America Vote Act (HAVA). The report 

was prepared in partnership with the National Disability Rights Network and EIN SOF 

Communications. Enacted by Congress in 2002, HAVA seeks to ensure that Americans 

with disabilities could vote independently and privately alongside their non-disabled 

peers. NCD gathered the experiences of nearly 900 voters with disabilities across the 

nation during the 2012 election cycle using an open-ended questionnaire, which 

became the blueprint for the report. Experience of Voters with Disabilities also provides a 

comprehensive overview of how federal funds were used in an attempt to increase and 

insure voting access in the United States. The report explored the physical barriers, 

attitudes, technological gaps, legislative hurdles and polling place practices 

encountered by voters with disabilities in 2012, by detailing how HAVA has improved 

voting access for Americans with disabilities in the past decade. This report continued 

to be central to the work of the Council throughout 2014. 

Beginning in December 2013 and continuing through the duration of FY 14 and 15, 

NCD collaborated with federal agency representatives and disability leadership 

stakeholders to obtain input in the planning and implementation of Medicaid Managed 

Care through a series of five community forums in federal fiscal year 2013-2014 which 

were held in Topeka, KS; Tallahassee, FL; Chicago, IL; Sacramento, CA; and New 

York, NY, promoting stakeholder engagement with federal and state officials. Upcoming 

forums will take place in Atlanta, GA; Philadelphia, PA; Baton Rouge, LA; and Seattle, 

WA. The forums featured facilitated discussion of experiences, preferences and desired 

outcomes for Medicaid managed care as described by disability leadership; federal and 

state agency representatives, health plans, and providers. At the forums, NCD was 

able to promote the Medicaid managed care principles outlined in the NCD report, 

Medicaid Managed Care for People with Disabilities.

iii 

On May 27, 2014, NCD issued a report examining the accessibility of communication 

before, during and after emergencies for people with sensory disabilities (deaf, hard of 

hearing, blind, low-vision, deaf-blind and speech disabilities) as well as people with 
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41

intellectual, developmental and/or psychiatric disabilities. In the report, NCD 

documented successful practices and barriers to effective emergency communications. 

This study, released during National Hurricane Preparedness Week, was conducted to 

help emergency planners and state and local officials provide effective communication 

to people with disabilities before, during and after emergencies.

A Promising Start: Preliminary Analysis of Court Decisions under the ADA Amendments 

Act, which reviewed the court decisions that have been rendered to date applying the 

Americans with Disabilities Act Amendments Act of 2008 (ADAAA) and reveals 

significant improvements in how courts are interpreting protections intended for 

coverage under the ADA. NCD’s report provided 23 findings and three 

recommendations based on an analysis of court decisions made under the ADAAA by 

examining decisions rendered under ADA amendments that were agreed on across 

both sides of the aisle in Congress. Using this measure, it is clear that the ADAAA has 

made a significant positive difference for plaintiffs in ADA lawsuits thus far. 

NCD’s efforts continue to explore the current issues in effective communications before, 

during and after an emergency situation; seek to identify potential solutions; develop 

proposals intended to have a positive impact on the policy environment; and develop 

guidance summarizing promising practices intended to educate emergency planners, as 

well as state and local officials, about how to provide effective communication to all people 

with disabilities.

NCD also weighed in on a variety of subjects via letters and meetings including, but not 

limited to, the U.S. Department of Labor companionship exemption, the Judge 

Rotenberg Center’s use of electroshock therapy; the U.S. Department of Housing and 

Urban Development’s Olmstead guidance; the President’s Budget; Executive Order, 

sheltered workshops, Building bridges with LBGTQ, the U.N. Convention on the Rights 

of Persons with Disabilities; NCD will follow-up on the recommendations contained in 

each of those reports, provide direct and timely assistance to the Administration and 

Congress, and will continue to work with our stakeholders to identify new policy areas to 

study. 

NCD’s report highlights the place of disability in our national fiscal policy and analyzes 

options for SSI and SSDI reform, including what measures could increase work effort for 

people currently utilizing SSI/DI, what measures could decrease the likelihood of using 

such benefits, and what financing options exist for both programs.

Fiscal Year 2015

NCD will shortly release Reforming Social Security’s Disability Benefits System, a report 

examining complex policy in two benefit programs linked to key aspects of the ADA—

Social Security Disability Insurance (SSDI) and Supplemental Security Income (SSI). 
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Recommendations focus primarily on decoupling health care benefits and cash benefits 

eligibility, providing wrap-around health benefits, further examination, planning, and 

gradual phase-in of a revised disability definition for benefits eligibility, management 

proficiency, early intervention, improved federal collaboration efforts, ways to boost 

work incentives, evidence-based practices addressing youth and people with mental 

health needs among vulnerable groups, and state supplemental systems. Current 

budget debates in Congress and with the President have highlighted that our nation 

faces fiscal challenges. According to the 2011 Social Security Trustees’ Report, the 

Social Security Disability Insurance Trust Fund is scheduled to become exhausted in 

2016. Because of increasing numbers of claims due to the economic situation and 

concerns with potential work disincentives facing both Social Security Disability 

Insurance (SSDI) and Supplemental Security Income (SSI) recipients, these programs 

have been highlighted as in need of reform by policymakers. 

As we approach the 25th Anniversary of the Americans with Disabilities Act, the National 

Council on Disability has heard feedback from our colleagues at the White House, from 

Congress, and from the general public, and have decided to tailor our youth-focused 

projects on three issues that are often obstacles for youth to achieve the goals of the 

ADA, full participation, economic self-sufficiency, independent living, and equality of 

opportunity

School to Prison Pipeline

In 2003, NCD has decided to take a look back its 2003 report Addressing the Needs of 

Youth with Disabilities in the Juvenile Justice System: The Current Status of EvidenceBased Research. In the last year, a number of different efforts have been going on 

around the country looking at best practices in reforming the juvenile justice system to 

improve outcomes for all young people.

With the tremendous body of work tied to this subject area already, the Council does not 

intend to reinvent the wheel and engage in a deep dive about the state of the state. 

Rather, NCD is looking to work with key partners including the Disability Rights and 

Education Defense Fund, the HSC Foundation, the Civil Rights Project at UCLA, and 

others to look at the work that contributed to the Council of State Governments 

report Core Principles for Reducing Recidivism and Improving Other Outcomes for 

Youth in the Juvenile Justice System. While this report represents a wide array of 

perspectives and far reaching recommendations, it is NCD’s hope to use it as a tool to 

establish a foundation for more focused discussion, tied specifically to potential 

upcoming reauthorizations of IDEA and ESEA.

Social Security 

In 2015, the National Council on Disability will be engaging with the National Council on 

Independent Living, the World Institute on Disability, and utilizing its hearing authority to 

convene a hearing on Capitol Hill tied to Social Security reform and youth with 
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disabilities. Following the publication of NCD’s upcoming report on SSI/SSDI, the goal 

of this hearing is to allow members of Congress and their staff to hear directly from 

young people utilizing the program (or having transitioned off) as to what changes need 

to be made to assist youth with disabilities to transition off of benefits, and additionally to 

deter young people from entering the system at all.

Education Issue Briefs In Light of Reauthorizations of ESEA and HEA

Given the priorities in Congress of completing the reauthorizations of both the 

Elementary and Secondary Education Act (ESEA) and the Higher Education Act (HEA) 

in the coming session, NCD intends to provide policy principles and recommendations 

to both House and Senate committees working on reauthorization, to promote education 

equality and high expectations for students with disabilities as well as consider 

professional development programs and strategies to support teachers to meet the 

needs of students with disabilities. 

CMS Regional Office Stakeholder Meetings – This project is follow-up to our 

Medicaid Managed Care report and would facilitate NCD, local stakeholder and CMS 

Regional Office staff conversations to promote greater dialogue and contact between 

key decision-makers in CMS' Regional Office system and the disability community 

regarding Managed Care waiver applications and dual eligible demonstration 

proposals. In FY 15, NCD will hold four additional regional forums with HHS regional 

offices regarding Medicaid managed care and the review of state 1115 and 1915(b)(c) 

waiver applications, dual eligible demonstration proposals and relevant Medicaid waiver 

or state plan amendments.

Transportation – Investing in independence necessarily involves investing in 

transportation. People with disabilities cannot work if they cannot get to the workplace.

In 2005, NCD released a comprehensive transportation report addressing access to 

ground transportation for people with disabilities: The Current State of Transportation for 

People with Disabilities in the United States, (2005), 

www.ncd.gov/publications/2005/06132005. In FY 2014, NCD has looked at progress 

made since 2005 and examining the recommendations made by NCD in the 2005 report 

to identify which recommendations have and have not been addressed successfully, and 

identify what barriers remain for people with disabilities in accessing transportation, 

including rural transportation. Particular emphasis is being placed on transportation 

issues for people with disabilities in rural and outlying urban areas; and inner city transit 

issues – subways, buses, taxis and issues regarding “silo” transit systems such as paratransit. 

Emerging Technology in Transportation - In 2004 NCD issued a report, Design for 

Inclusion, aimed at educating designers and manufacturers about the way electronic 

and information technology (E&IT) intersects with the needs of individuals with 

disabilities, and how designing with access in mind can significantly increase the size of 
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targeted markets for E&IT. In 2011, NCD took the next step in recognizing the 

transformative power of technology and innovation, and examined the importance of 

social media and other information technologies in connecting people to job 

opportunities in report The Power of Digital Inclusion. 

The latest innovations in technology are now upon us through the use of autonomous 

vehicles. Autonomous vehicles are vehicles capable of operating with minimal or no 

input from a human driver beyond entering an intended destination or a planned travel 

route. While this technology is still in its infancy, it is emerging. The expanded use of 

these vehicles could begin to address the dramatic increase in social isolation, chronic 

unemployment, and an overall poorer quality of life stemming in no small part from a 

lack of transportation. For people who are blind, experience seizures, or have physical, 

developmental or intellectual disabilities whose effects prevent them from driving, 

autonomous vehicles could provide a new and vital transportation option. Many senior 

citizens would also benefit from this technology as they experience isolation - often from 

a lack of transportation. In addition, in most rural areas of the country there simply is 

not adequate public transportation to meet the needs of persons with disabilities. 

Advancing this technology may ease the demand on government dollars to support 

such transit systems. Hence the potential opportunities this advance could bring to 

people with disabilities is significant and requires an examination of the public policy

barriers that need to be eliminated to further the development of this technology, and 

improve the quality of lives for persons with disabilities. 

Several states across the country have already passed legislation relative to the 

operation of autonomous vehicles. NCD would like to ensure, as more states begin to 

experiment with allowing this technology that no federal barriers exist that would prevent 

its wider use. In 2014, NCD will engage with industry experts to identify the policy 

barriers of this technology and recommend federal legislation to further advance the 

testing and trial operation of autonomous vehicles. In addition, the project will include 

drafting model legislation, which states may use to create a consistent approach across 

the country. 

Activities such as these assist with NCD meeting performance measures highlighted in 

its strategic plan resulting in an immediate impact. For instance, because of our work 

NCD has been asked to participate on a number federal commissions and councils

including the Transportation Security Administration’s (TSA) Disability Working Group, 

Federal Emergency Management Agency’s (FEMA) Long Term Disaster Recovery 

Initiative and National Response Framework as well as at the state level with our 

involvement in the Council of State Governments (CSG) Deeper Learning Focus Group 

(related to education reform). 

Indeed, the Centers for Medicare and Medicaid Services (CMS) linked to NCD’s FY 12

Analysis and Recommendations for the Implementation of Managed Care in Medicaid 

Programs for People with Disabilities document http://www.medicaid.gov/Medicaid-CHIP-
Performance Section

45

Program-Information/By-Topics/Delivery-Systems/Medicaid-Managed-Long-TermServices-and-Supports-MLTSS.html on the same website where CMS is highlighting their 

own initiatives. 

Defining and Measuring Home and Community Based Services Quality - Over the 

course of the last several years, considerable energy and effort has been focused on 

the topic of expanding Home and Community Based Services (HCBS) for people with 

disabilities and older adults. Through programs like Money Follows the Person, the 

State Balancing Incentive Program and the Community First Choice State Option, 

states have been offered financial incentives to shift away from institutional services and 

towards HCBS. Studies have shown that community services are less expensive than 

institutional care and making such a shift could potentially save Medicaid millions of 

dollars annually. Additionally, efforts by the Department of Justice’s Civil Rights Division 

to enforce the Supreme Court’s 1999 Olmstead v. L.C. decision have also helped to 

further the shift towards community services. Despite this significant progress in terms 

of state willingness to invest in community support infrastructure, considerable tensions 

remain as to how to define and assess the quality of HCBS. 

Additionally, as the Olmstead decision is applied in new contexts, definitions of 

integrated day and employment activities acquire particular relevance.

CMS has recently issued numerous public comment opportunities focusing on this 

particular question, and ongoing deliberations within numerous federal agencies, 

including DOJ, HUD, CMS and the new Administration on Community Living continue to 

work to identify the best ways at ensuring quality measurement infrastructures that are 

truly reflective of community life. This project will provide a meaningful and practical 

summary of the relevant issues and options available to state and federal policymakers 

with regards to defining and assessing HCBS systems for consistency with the goals 

and intent of the Medicaid HCBS program, compliance with the Americans with 

Disabilities Act, and the ability to meaningfully enhance the quality of life of individuals 

with disabilities and older adults. Further aspects of this project that could be explored 

include examining: how HCBS should be defined and what should and should not be 

funded utilizing HCBS dollars; what constitutes meaningful compliance with the federal 

Olmstead decision and what implications have yet to be fully explored by policymakers 

and advocates; and how policymaking and quality assessment activities of both 

Medicaid and non-Medicaid programs can be improved with regards to HCBS. 

Affordable Care Act--NCD expects to release a report on the Affordable Care Act in 

FY15. The purpose of the research will be to analyze the impact of the Affordable Care 

Act (ACA) on people with disabilities . ACA is one of the most significant pieces of 

domestic legislation enacted since the 1960s. ACA’s changes to the country’s health care 

system will affect millions of Americans, with a disproportionate impact on people with 

disabilities. Without question, many provisions of ACA will result in significant 

improvements in health care access for people with disabilities. On the other hand, as 
Performance Section

46

they implement ACA’s favorable provisions, federal and state policymakers may not use 

approaches calculated to achieve the maximum possible gains for people with disabilities. 

Moreover, ACA’s new initiatives create new dangers. 

The decisions of federal and state policymakers as well as private sector entities (such 

as insurers and providers) will greatly shape the fate of people with disabilities under 

ACA. ACA implementation is at a critical point, a time to take stock of what has already 

happened and to identify the future choices that will most significantly affect people with 

disabilities. The first open enrollment period has ended and the second took place 

during work on this project. Also, most (but not all) of ACA’s key federal regulations 

have been finalized. Critically important decisions loom ahead, some at the federal 

level, but many more for states and private entities, including health plans and 

employers. This project will assess what has taken place thus far while providing a 

comprehensive guide to future decisions impacting people with disabilities. 

ADA@25 Scorecard -- In our work to revise the format of the Annual Progress report to 

make it more user-friendly for our varied stakeholders, including Members of Congress 

and their staff, in 2015, NCD plans to produce, with the assistance of a contractor and 

local stakeholders, a five state examination of progress made in implementing the goals 

of the ADA in the past 25 years. The Council will convene a stakeholder group of 

national disability stakeholders to determine objective metrics to measure 

implementation and compliance with the ADA. Additionally state stakeholders will be 

asked to identify targets and goals to be achieved by the 30th ADA Anniversary to 

measure continuing and future implementation efforts. These metrics will be utilized by 

the Council in meeting our statutory obligation to inform the President and Congress 

about annual progress. We also envision this as a way to make the Progress Report 

more valuable to our stakeholders and an actual tool that they can use in their work at 

all levels of government. 

White House Forum on Parenting with a Disability – As mentioned earlier, the 

Council continues to receive significant interest from Federal and State legislators, 

community based organization (disability and non-disability), and the general public 

about its work on the Civil Rights of Parents with Disabilities. NCD is looking to 

convene a forum on this topic-- to provide a venue for the necessary key stakeholders 

(parents with disabilities, federal agencies, advocates, members of Congress and their 

staff, service providers, and researchers) to convene and begin focusing the necessary 

attention this issue so rightly deserves. The conference would attempt to answer 

several questions of prominent concern such as: what actions have been taken on the 

state and federal level to address discrimination against parents with disabilities and 

their children – what are the barriers and facilitators; what promising practices and/or 

state initiatives have been implemented to support parents with disabilities and their 

children since the release of NCD’s report; and what progress has been made on 

NCD’s report recommendations and what more needs to be done to advance and 

promote the rights of parents with disabilities and their children. In addition, the 
Performance Section

47

conference will break the report out into key topics including, but not limited to child 

custody, foster care and adoption.

Fiscal Year 2016 

For FY 2016, NCD plans on building on past success such as our revamped annual 

progress report and completing several significant policy reports in areas of priority to 

the community and Congress. We also intend to begin several new policy projects of 

national concern for people with disabilities identified through our outreach and 

engagement efforts. Though these topics are weighty, the goal is not to issue a series of 

multi-hundred page reports, but rather keep the length to something useful and include 

concise summaries, accessible data tables and infographics, and specific policy 

recommendations tied to upcoming reauthorizations. NCD has identified several 

possible new projects and areas to address systemic issues affecting people with 

disabilities. These potential policy areas include: 

Reforming Private Health Insurance to be Consistent with the Goals of the ADA --

The current focus on health reform, community living, and enforcement of the Supreme 

Court decision in Olmstead v. L.C.iv primarily focuses on public health benefits, 

Medicaid, in particular. However, little attention is being paid to the extent to which 

private health insurers structure health benefits in ways that interfere with an individual’s 

right to live in the community. Private health policies often contain exclusions or 

restrictions on the types of services most needed by people with disabilities, and have 

an institutional bias – covering services if an individual lives in a nursing home or 

rehabilitation facility, but not covering the services in the individual’s home. Many private 

insurance plans fail to adequately cover rehabilitation and habilitation services and 

devices; and mental health and substance use disorders, including behavioral health 

treatment. 

According to the Institute of Medicine,v habilitation, mental health, substance abuse and 

behavioral services have largely been left to the public sector to provide and fund at 

taxpayers’ expense. For example, many private plans fail to cover, or place unrealistic 

restrictions on, durable medical equipment and limit prosthetic limbs to one per lifetime. 

In addition, many private plans only cover therapies to the extent that they result in 

progress toward recovery – thereby discriminating against people with permanent 

disabilities who need therapies to maintain functioning or prevent deterioration of 

functioning, such as people with cerebral palsy, multiple sclerosis, or people who need 

psychiatric rehabilitation. Most private plans do not cover hearing aids or low vision 

aids and avoids covering services for children with autism or intellectual disabilities 

through use of a definition of “medical necessity” that applies only to restoration of 

function. 

Such benefit limitations have a disproportionate detrimental effect on people with 

disabilities that go far beyond a negative impact on health. The impact is so extreme 
Performance Section

48

that many people with disabilities cannot work because employer-sponsored health 

insurance is inadequate compared with the benefits they can receive from Medicaid. 

Private insurance limitations and exclusions force some people who would rather be at 

home into more costly institutions; placing further strain on cash strapped public 

programs. This is in direct contravention to the Americans with Disabilities Act, the 

Olmstead decision and generally-accepted principles of community living and inclusion. 

The private insurance market is in need of significant reforms if people with disabilities 

are to participate equally in private health insurance. The purpose of this potential 

project is to analyze the policies of the 20 largest private health insurers and document 

the contract provisions that are inconsistent with the goals of the ADA, the Olmstead 

decision and the Administration on Community Living (ACL) initiatives. Furthermore, 

the analysis could include specifics such as spotlighting the practices of the private 

insurance market that have the intent or effect of discriminating against individuals with 

disabilities. The Council will dedicate $50,000 to this project.

ELL & IDEA

Research indicates that students of color with limited use of English sometimes get 

mislabeled as disabled rather than receive appropriate services as English Language 

Learners. However, there are students who are both students with disabilities and 

English Language Learners. The purpose of this project would be to look into what are 

the challenges facing this population and what are the barriers in accessing programs 

and services that could meet their needs, and what (if any) best practices exist in 

ensuring their academic, social, and occupational success. This would also look at how 

Centers for Independent Living, Protection and Advocacy Organizations, Parent 

Training and Information Centers, engage with families of children with disabilities who 

also have limited English proficiency. This project would include formal 

recommendations for inclusion in upcoming reauthorizations of IDEA and ESEA. 

ADA Scorecard

As a follow up to the 2015 Annual Report to Congress, NCD will roll out a series of 

state-focused fact sheets that individuals with disabilities, state and local organizations 

and members of Congress can utilize when looking at ways to improve access to 

programs and services for individuals with disabilities. This fulfills NCD’s goal of 

reimaging its Progress Report to increase its value to the general public while at the 

same time highlighting groundbreaking work the Council is engaging in to improve the 

lives of people with disabilities. 

Social Media Dialogue on Voting

With 2016 being an election year, and building off of NCD’s existing body of work tied to 

the voting rights of people with disabilities, the Council will utilize its social media 

capacity and host 3 dialogues tied to ongoing physical barriers, attitudes, technological 

gaps, legislative hurdles, and polling place practices encountered by voters with 

disabilities. 
Performance Section

49

Congressional Forums

NCD has made use of its statutory authority to receive testimony by hosting 

congressional forums on the topics of the federal budget, voting, and parenting rights. In 

FY16, the Council intends to continue utilizing this authority to host at least one 

congressional forum, likely tied to the topic of one of its recent reports, taking into 

consideration the interests of NCD’s stakeholders and the focus of Congress at the 

time. 
Appendix A

50

The financial section presents the message from the Executive Director, followed by the 

independent auditor’s report and the financial statements with accompanying notes.

Discussion of the financial statements, financial position and results of operations can 

be found in Management Discussion and Analysis Section.
Appendix A

51

Message from the Executive Director

I am pleased to report that the National Council on Disability earned an unqualified audit 

opinion on its consolidated financial statements. We have spent much of FY2014 

working to remedy the issues noted in our FY2013 audit and to enact appropriate 

general and entity level controls over our integrity and security of our financial and 

administrative operations. 

Following the close of FY2014 the Council started taking progressive action to address 

the findings of the FY2013 audit. We viewed our response to the findings as an 

opportunity to fundamentally correct deficiencies common to small, independent federal 

entities. Our goal continues to be to ensure formal checkpoints and controls to identify 

failures and deficiencies in advance of adverse outcomes. We have developed a 

streamlined system to ensure efficient and documented processing of invoices and 

vouchers among our Administration and Finance team members. The goal of this is 

twofold: to create transparency and to ensure every team members is aware of their 

and others responsibilities and who the necessary back-ups are. Regular 

communications between financial staff, the Chairperson, Executive Director, and 

Finance Committee chair are essential to providing the level of transparency that 

ensures continuity of operations. We continue to work to ensure NCD’s Information 

Technology systems and equipment include the formulation of appropriate procedures 

and controls throughout. In sum, our goal, as detailed in our Management Letter 

Comments, is to increase the transparency, accountability, and reliability of our financial 

and operations systems as we move through FY2015. 

Finally, I want to take this opportunity to acknowledge the efforts of the Council and the 

entire staff that made our financial management a priority during FY 2014. We are all a 

dedicated to ensuring the development of stronger controls in the future to maintain our 

commitment to quality financial management.

Rebecca Cokley

Executive Director
Appendix A

52

Appendix A – Listing of Abbreviations and Acronyms

ADA Americans with Disabilities Act of 1990, as amended

AICPA American Institute of Certified Public Accountants

ATDA Accountability of Tax Dollars Act of 2002

CFO Chief Financial Officer

CFR Code of Federal Regulations

CSRS Civil Service Retirement System

DOL Department of Labor

ED Executive Director

ESEA Elementary and Secondary Education Act

FASAB Federal Accounting Standards Advisory Board

FBWT Fund Balance with Treasury

FECA Federal Employees Compensation Act

FERS Federal Employees’ Retirement System

FFMIA Federal Financial Management Improvement Act

FICA Federal Insurance Contribution Act

FISMA Federal Information Security Management Act

FMFIA Federal Managers’ Financial Integrity Act

FOIA Freedom of Information Act

FTE Full-time Equivalent

FY Fiscal Year

GAAP Generally Accepted Accounting Principles

GAO Government Accountability Office

GPRA Government Performance and Results Act

GSA General Services Administration

IPIA Improper Payments Information Act

IT Information Technology

MD&A Management’s Discussion and Analysis

NCD National Council on Disability

NCLBA No Child Left Behind Act reauthorization

OMB Office of Management and Budget

OPM Office of Personnel Management

PP&E Property, Plant and Equipment

PAR Performance and Accountability Report

SAS Statement on Auditing Standards

SBR Statement of Budgetary Resources

SFFAS Statement of Federal Financial Accounting Standards

SNC Statement of Net Cost

TSP Thrift Savings Plan

UDO Undelivered Orders

USC United States Code
Appendix A

53

 i The publication can be found on the National Council website at the following link: 

http://www.ncd.gov/publications/2013/20130315/

ii The publication can be found on the National Council website at the following link: 

http://www.ncd.gov/publications/2013/20130315/

iii The publication can be found on the National Council website at the following link: 

http://www.ncd.gov/publications/2013/20130315/

iv Olmstead v. L.C., 527 U.S. 581 (1999). vv Institute of Medicine, “Essential Health Benefits: Balancing Coverage and Cost” p. 108, (Oct. 2011). v Institute of Medicine, “Essential Health Benefits: Balancing Coverage and Cost,” p. 131. v