NATIONAL COUNCIL ON DISABILITY

National Council on Disability (202) 272-2004 Voice

1331 F Street, NW, Suite 850 (202) 272-2022 Fax

Washington, DC 20004

www.ncd.gov

Fiscal Year 2020

CONGRESSIONAL BUDGET JUSTIFICATION
1 of 47

CONTENTS

 Table of Contents............................................................................1

 

 Note from the Chairman....................................................................2

 

 INTRODUCTION

 Agency & Mission Overview ..............................................................4

 PERFORMANCE

 Strategic Framework ........................................................................9

 Strategic Goal ...............................................................................10

 Strategic Objectives ........................................................................10

 Summary of Results and Plans .........................................................11

 Cross-Agency Collaborations ............................................................31

 Major Management Priorities & Challenges ..........................................34

 

 BUDGET JUSTIFICATION 

 Cost Discussion ..............................................................................40

 Analysis of Resources ......................................................................41

 
2 of 47

A Note from the Chairman

This document presents both the National Council on Disability (NCD)’s performance 

plan and budget justification for fiscal year 2020. These resources will be applied to the 

furtherance of NCD’s mission to advise the President, Congress, and other federal 

agencies regarding federal policies’ impact on people with disabilities. We advise by 

conducting rigorous research, engaging NCD’s stakeholders to inform our work, and by 

developing policy recommendations based on the findings from our research and 

engagement. 

Our appropriated funding also supports requirements to implement improvements to the 

efficiency and effectiveness of our operations. Unfortunately, due to the requirement to 

comply with cybersecurity protocols mandated for all federal agencies NCD must 

reallocate resources from policy priorities to activities that are not mission critical. 

NCD is positioned to do the full scope of work in FY 2020 with thirteen full-time career 

staff and nine part-time, congressionally and presidentially appointed Council Members. 

More detailed explanations follow in the budget justification.

Respectfully,

Neil Romano

Chairman
3 of 47

Agency & Mission Overview

Agency Mission

Agency Mission

The mission of NCD is to be a trusted advisor regarding the impact of federal policies 

on the lives of people with disabilities to the President, Congress, and other federal 

agencies by developing policy recommendations; reviewing existing policies’ effects 

on the quality of life of people with disabilities; and by engaging policymakers and 

responding to their requests for assistance accurately, efficiently and without bias.

Agency Information

The National Council on Disability (NCD) is an independent, nonpartisan federal agency 

that provides the Administration and the U.S. Congress with timely analysis and 

recommendations to advise policy development, revision, implementation, and 

enforcement efforts as they have impact on the lives of people with disabilities across 

America. NCD’s purview is not limited to a set policy area or subgroup of disabled 

Americans, so its advice is not siloed at the exclusion of others’ interests. On the 

contrary, NCD’s strives to provide advice that thoughtfully considers the diverse needs 

of its core constituency, which varies greatly by type and severity of disability. 

NCD has a critical role to play in preserving and strengthening the impact of the 

Americans with Disabilities Act (ADA) in our nation’s policies and programs. Indeed, 

NCD’s very identity is inextricably intertwined with the ADA and its history. 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 advice to Congress and the Administration. Changes were also made to NCD’s 

statutory mandate by the Rehabilitation Act Amendments of 1992 and 1998, the 

Education of the Deaf Act Technical Amendments of 1993, and most recently, by the

Workforce Innovation Opportunity Act (WIOA) of 2014 (Public Law 113-128).

Upon its establishment as an independent agency, Congress charged NCD with a new 

mandate to review all existing federal policies and programs. Two years later, NCD 

delivered on that charge with its path breaking report, Toward Independence, which 

called for enactment of a federal disability civil rights law. NCD later offered the first 

draft of that recommended civil rights law in 1988. After President George H.W. Bush 

signed the ADA into law, NCD’s mission was again amended to reflect the national 

disability policy goals now enshrined in the ADA. 
4 of 47

NCD serves a unique role among federal agencies because its mission reflects the 

breadth and diversity of the disability community itself. In its authorizing statute, the 

agency’s duties are extensive and belie the agency’s limited financial and human 

resources. In FY18, NCD had a $3.25 million annual appropriation to support its mission 

of gathering information and reviewing and evaluating on a continuing basis all “policies, 

programs, practices, and procedures concerning individuals with disabilities conducted 

or assisted by federal departments and agencies...,” and “all statutes and regulations 

pertaining to federal programs which assist such individuals with disabilities...” 

NCD’s governing body is the Council, comprised of nine members (five presidential and 

four congressional appointees), including a Chair, whom the President appoints; and a 

Vice Chair, determined by the Chair. Congressional appointees are appointed by each 

of the following: the Speaker of the House, the House Minority Leader, the Senate 

Majority Leader, and the Senate Minority Leader. Each Council Member serves a threeyear term, with the possibility of a second term.

Council Members are special government employees (SGE) that live across the country 

and are restricted to serve a maximum of 120 days per year in a part-time capacity. 

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. Eighty-nine percent of the 

current Council Members are people with disabilities and parents of children with 

disabilities.

A small, dedicated full-time staff located in Washington, D.C. support the work of the 

Council Members. Eighty-two percent of full-time staff are people with disabilities and 

parents of children with disabilities.

Organizational Structure

To accomplish its policy research work in fulfillment of its mission, NCD’s Council is 

organized into committees for each policy project. These committees are comprised of 

three or four Council Members each plus a full-time NCD staff member who manages 

the Council’s work on a project, drafts portions of policy advice based upon Council 

discussions and research, and who acts as a Contract Officer Representative (COR), or 

Agreements Coordinator, for any supplemental data provided to a project from a
5 of 47

contracted researcher. Once each policy project yields a final draft product, it is shared 

with the entire Council for review, discussion, refinement, and ultimately, a vote of 

approval, which often takes place at in-person quarterly meetings. Once approved, NCD 

staff provide final edits and dissemination of the policy advice to applicable parties. In 

the instances of need for brief, nimble responses to proposed legislation or regulations, 

NCD staff will often draft work products directly, drawing upon the Council’s existing 

body of work in so doing. 
6 of 47

National Council on Disability Organizational Chart

Council Chair

& Members

Executive Director

Director of Legislative 

Affairs & Outreach

Director of Operations 

& Administration General Counsel

& Director of Policy

Attorney-Advisor Staff Assistant

Financial 

Management 

Analyst

Legislative Affairs 

Specialist 

Public Affairs 

Specialist

Attorney-Advisor

Attorney-Advisor

Special Assistant

(Contractor)

IT/Cybersecurity 

Specialist

(Contractor)
7 of 47

National Council on Disability Organizational Structure

NCD’s staff is organized into three teams, led by team directors, all of whom report to 

the Executive Director. The Executive Director serves at the pleasure of the Chair and 

reports to the members of the Council. 

NCD’s Policy / Legal (Policy) 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.

NCD’s Administration / Finance / Operations (AFO) team provides critical staff 

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

human resources management, as well as partners with the policy and outreach teams 

to build strategic relationships that are critical to the agency's work.

NCD’s Legislative / Outreach (LAO) team closely monitors Congressional activity on 

issues critical to the disability community and cultivates and maintains effective working 

relationships with NCD stakeholders at the federal, state, and local levels.
8 of 47

Performance Section

Strategic Framework, FY 2018 – FY 2022

Agency Mission

The mission of the National Council on Disability (NCD) is to be a trusted advisor 

regarding the impact of federal policies on the lives of people with disabilities to the 

President, Congress, and other federal agencies by developing policy 

recommendations; reviewing existing policies’ effects on the quality of life of people 

with disabilities; and by engaging policymakers and responding to their requests for 

assistance accurately, efficiently and without bias.

Agency Vision

The vision of the National Council on Disability (NCD) is to advance the goals of the

Americans with Disabilities Act (ADA) through recommendations regarding federal 

policy.

GOALS

1. Develop new disability policy recommendations, such as for entitlement reform 

discussions.

2. Review and analyze proposed and existing federal policies’ impact on people with 

disabilities. 

3. Engage policymakers and respond to their requests for assistance accurately, 

efficiently and impartially.

4. Gather information from subject matter experts and members of the disability 

community to help inform policymakers’ work. 

5. Enhance agency operational and programmatic internal controls in order to 

effectively service execution of statutory duties.

6. Recruit, retain, and develop a highly qualified professional staff in order to 

effectively service execution of statutory duties.

OBJECTIVES

GOAL 1 -- New Disability Policy Recommendations –

1. Develop materials regarding findings on the impact of charter schools and school 

vouchers on students with disabilities and offer recommendations to 

policymakers. 

2. Develop materials regarding the use and impact of guardianship on national 

disability policy goals; federal court jurisdiction regarding guardianship cases; and 

the ways guardianship uniquely affects the lives of people with intellectual and 

developmental disabilities and offer recommendations to policymakers. 

3. Provide policymakers NCD’s Medicaid policy findings and recommendations 

during healthcare reform discussions.
9 of 47

4. Provide policymakers NCD’s Social Security policy findings and 

recommendations during Social Security reform discussions.

5. Develop materials and recommendations regarding findings of research on the 

involuntary institutionalization of people with disabilities as a result of disasters.

6. Develop materials and recommendations regarding findings of research on 

bioethical issues affecting people with disabilities.

7. Develop materials and recommendations regarding the creation of a centralized 

accommodations fund for the Federal Government.

OBJECTIVES

GOAL 2 -- Proposed and Existing Federal Policies –

1. Provide findings and recommendations regarding the implementation of the 

Workforce Innovation and Opportunity Act’s requirement to provide preemployment transition services to transition-age students with disabilities.

2. Provide recommendations regarding the implementation of the Individuals with 

Disabilities Education Act and the Higher Education Act if Congress pursues 

reauthorization efforts.

3. Recommend improvements to the efficiency, effectiveness, and coordination of 

existing federal disability programs and offices.

4. Develop materials and recommendations regarding findings of research on the 

use of subminimum wages in for-profit supply chains and highlight best practices 

used by providers that transitioned away from the use of subminimum wages. 

GOAL 3 – Engage Policymakers and Respond to Their Requests for Assistance

1. Provide regular disability policy briefings for members of the Administration and 

Hill staff. 

2. Regularly provide congressional leadership and members of the Administration 

written briefing materials on policy priorities of the disability community. 

3. Increase time of NCD staff and appointed Council members spent in direct 

engagement of congressional and Administration policymakers with NCD’s policy 

advice; and/or of radio, television, print, and online media regarding topics NCD 

has engaged.

GOAL 4 – Gather Information from Subject Matter Experts 

1. Engage the disability community beyond Washington, DC, soliciting their views 

regarding timely policy matters and providing the input of the disability community 

for policymakers to weigh in their decision making.

2. Develop information partnerships with subject matter experts inside and outside 

the disability community to generate effective intelligence for policymakers to use 

in weighing issues. 
10 of 47

GOAL 5 – Enhance Agency Operational and Programmatic Internal Controls

1. Evaluate and update agency IT infrastructure.

2. Enhance planning and evaluation of all agency projects to ensure continual 

improvements.

3. Ensure compliance with financial regulatory and reporting requirements.

4. Update all agency internal policies and procedures.

5. Evaluate and implement mandated cyber security requirements. 

GOAL 6 – Recruit, Retain, and Develop a Highly Qualified Professional Staff 

1. Enhance new staff orientation materials and process.

2. Perform a SWOT analysis and identify best practices from select agency projects 

from the prior fiscal year. 

3. Identify training to support improvement in areas identified as weaknesses or 

signifying skills gaps by project analysis. 

4. Continue to be a model agency by employing and retaining employees with 

disabilities.

Strategic Goals

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 all people with disabilities or all policy areas affecting only one 

subpopulation of people with disabilities. For that reason, NCD’s six strategic goals

reflect the agency’s areas of core focus in implementing its mission – develop and offer 

solutions for current policy debates affecting people with disabilities; continually review 

the experience of existing policies on people with disabilities; be in tune with the needs 

of the policymakers who are considering these policies; ensure our information is 

sourced in quality expertise and reflects our core constituency accurately; and steward 

the agency’s financial and human capital resources to ensure excellence in delivery of 

our work. 

Strategic Objectives

NCD has several strategic objectives for each of its six strategic goals for 23 strategic 

objectives in total. Each of these objectives is reviewed and updated annually to reflect 

Council-set policy project work for the upcoming fiscal year, as well as management-set 

operational, reporting, and compliance priorities based upon OMB-driven guidance, new 

executive orders, and any new legislative responsibilities.
11 of 47

Tracking Progress on NCD’s Strategic Objectives

NCD accomplishes its mission by assessing concerns and priorities of its stakeholders 

and then providing independent and reliable information, analysis, and 

recommendations to Congress, the President, and other federal agencies, in 

furtherance of the goals of the ADA. NCD defines its programs for purposes of 

evaluation as its policy development activities, its research initiatives, its communication 

efforts, and its administrative systems and policies. We conduct program evaluations

before implementation (formative needs evaluations), periodically and ad hoc (formative 

process evaluation), and at the end of each (summative outcome and impact 

evaluations). Historically, NCD has reported on these evaluations in its annual 

Performance and Accountability Report (PAR).

Next Steps for Strategic Objectives

Last year, NCD undertook a review and rewrite of its strategic framework when updating 

its five-year strategic plan (for FY 2019 – FY 2022). The changes made were 

substantial, and each level of the plan implemented strategies approved by OMB to 

streamline operations and maximize outcomes. NCD’s strategic plan provides greater 

specificity intended to reflect the outcomes the agency is trying to achieve as well as 

more clearly articulating our plan of action in pursuing those ends. In mid-FY18, 

following the issuance of the President’s Management Agenda and a Council vote on a 

new set of policy projects for FY19, NCD management updated its strategic objectives 

to reflect these priorities.

Summary of Results and Plans

RESULTS OF OBJECTIVES FOR GOAL 1

GOAL 1 OBJECTIVES

New Disability Policy Recommendations –

1. Develop materials regarding findings on the impact of charter schools and school 

vouchers on students with disabilities and offer recommendations to 

policymakers. 

2. Develop materials regarding the use and impact of guardianship on national 

disability policy goals; federal court jurisdiction regarding guardianship cases; and 

the ways guardianship uniquely affects the lives of people with intellectual and 

developmental disabilities and offer recommendations to policymakers. 

3. Provide policymakers NCD’s Medicaid policy findings and recommendations 

during healthcare reform discussions.

4. Provide policymakers NCD’s Social Security policy findings and 

recommendations during Social Security reform discussions.
12 of 47

5. Develop materials and recommendations regarding findings of research on the 

involuntary institutionalization of people with disabilities as a result of disasters.

6. Develop materials and recommendations regarding findings of research on 

bioethical issues affecting people with disabilities.

7. Develop materials and recommendations regarding the creation of a centralized 

accommodations fund for the Federal Government.

In FY18, NCD continued to honor its policy development cycle of engaging NCD’s 

stakeholders, which includes: pursuing policy research in line with stakeholder-identified 

concerns and priorities; developing policy recommendations to address those concerns;

returning to NCD’s stakeholders with the final product; working with policymakers 

regarding its recommendations; and ultimately receiving another round of iterative 

feedback, concerns and priorities to begin the cycle anew. While the objectives of Goal 

1 are primarily executed by the Policy / Legal team, NCD’s policy development cycle 

that produces NCD’s new policy products requires blending the work of the Legislative 

Affairs / Outreach team’s core functions as well. 

Highlights of NCD’s results in Goal 1 objectives for FY18 included:

• NCD Conducted Timely School Choice Research – NCD conducted 

qualitative and quantitative research regarding the impact of charter schools and 

school choice vouchers on students with disabilities during the entirety of FY18, 

culminating in two reports with key research findings and recommendations for 

policymakers. Those two reports were discussed and approved by the Council in 

August 2018 and will comprise a single report series release in early FY19 during 

a congressional briefing. 

• Professional Association Takes Action In Response to NCD 

Recommendations Regarding Dental Care of People with Intellectual and 

Developmental Disabilities (ID/DD) – Individuals with ID/DD and their loved 

ones often struggle to locate dentists who are trained and are willing to provide 

dental care to individuals with ID/DD. In FY 2018, NCD completed a short policy 

brief that highlights these challenges and offers policy recommendations for this 

largely overlooked issue. The brief recommended that 1) the American Dental 

Association revise its Code of Professional Conduct (traditionally adopted by 

respective states as state professional liability law) to reflect that, as a matter of 

civil rights, Dentists may not discriminate in their patient selection based on a 

person’s disability (as is already the case based on a patient’s race, creed, color, 

sex, or national origin); 2) the Commission on Dental Accreditation (CODA) 

should, as a matter of equal treatment, revise its national standards to require 
13 of 47

that dental students be trained in the treatment management of patients with 

ID/DD; and 3) that Congress should revise the Public Health Service Act to 

designate people with ID/DD as a “medically underserved population” as a 

means of improving the evident lacking healthcare for that population. 

Subsequent to NCD’s efforts in making these recommendations, the American 

Dental Association (ADA) informed NCD that its relevant review committee 

recommended that the ADA adopt NCD’s recommendation to revise its 

professional code by a vote of the ADA’s House of Delegates in October 2018, in 

accordance with NCD’s recommendation; CODA informed NCD that it has begun 

a public comment period of one year as part of an administrative process 

concerning the revision of CODA’s standards per NCD’s recommendation; and a 

bipartisan bill has been introduced in Congress that designates the ID/DD 

population as a medically underserved population as per NCD’s recommendation 

(more on this legislation in the next bullet point).

• Legislation Introduced Designating the ID/DD Population as Medically 

Underserved – Consistent with NCD’s recommendation, and with the assistance 

of NCD in drafting the legislative language, bipartisan legislation was introduced 

in Congress that would improve the delivery of medical and dental care to people 

with ID/DD. Under the Healthcare Expansion and Accessibility for 

Developmentally Disabled and Underserved Population (HEADs UP) Act, the 

Public Health Service Act would be revised to designate people with ID/DD as a 

medically underserved population, thereby granting people with ID/DD access to 

the programs and resources of the National Health Service Corps (as is the case 

for the homeless, residents of public housing, and migrant workers). NCD 

continues to field related questions by lawmakers concerning the lack of proper 

healthcare that people with ID/DD continue to suffer in relation to other 

population groups.

• Legislation Introduced to Address the Sexual Assault of Students with 

Disabilities on College Campuses – In view of recent national attention on 

sexual assault at college campus’ as well as the announcement of a bipartisan 

congressional taskforce to address the issue, NCD published a report in FY18 

that included an examination of sexual assault statistics, college policies 

regarding response to sexual assault and how those policies impact and largely 

ignore the needs of students with disabilities in particular, as is also the case with 

post-assault services provided to survivors with disabilities. Following the 

recommendations made in that report, legislation was introduced in Congress as 

a means of addressing these concerns. The Safe Equitable Campus Resources 
14 of 47

and Education (SECuRE) Act, introduced in March 2018 is bicameral legislation 

intended to address many of the systemic failures brought to light in NCD’s 

recent report, Not on the Radar: Sexual Assault of College Students with 

Disabilities. 

• NCD Conducting Seminal Guardianship Research – Guardianship is an 

ongoing interest of the Senate’s Special Committee on Aging, within the context 

of elder abuse and the burgeoning aging population. However, guardianship 

concerns also greatly impact people with disabilities, which NCD seeks to 

incorporate into ongoing policy discussions through its research findings and 

recommendations:

o Beginning FY17 and concluding in FY18, NCD conducted a 

comprehensive review of guardianship law and policy using a disability 

civil rights framework for the analysis. The review included dozens of 

interviews, ongoing consultation with an advisory panel, and an extensive 

literature review of existing research. The report focused on how 

guardianship impacts people with disabilities and their families; how 

guardianship furthers or impedes national disability policy goals; and how 

alternatives to guardianship such as supported decision-making may 

improve outcomes and further the goals of the ADA. The final report, 

Beyond Guardianship: Toward Alternatives That Promote Greater SelfDetermination for People with Disabilities, was released March 2018 at the 

Jacobus tenBroek Disability Law Symposium. 

o Toward the end of FY18, NCD launched two additional guardianship 

research projects regarding federal court jurisdiction of guardianship 

cases as well as the ways in which guardianship uniquely affects the lives 

of people with intellectual and developmental disabilities. The research will 

conclude in mid-FY19, and the final findings and recommendations will be 

offered to policymakers in the spring of 2019.

• NCD Conducting Critical Research on the Involuntary Institutionalization of 

People with Disabilities as a Result of Disasters – NCD began research in 

FY18 on the involuntary institutionalization of people with disabilities as a result 

of disaster, coordinating the research effort with the Government Accountability 

Office, who in response to a Congressional request, is researching several 

related topics as well. The NCD research will conclude in FY19 and the final 

findings and recommendations will be offered to policymakers in the spring of 

2019.
15 of 47

• NCD Conducting Research on the Intersection of Bioethics and Disability –

NCD also began research in FY18 on what will be released as a report series on 

bioethics and disability policy. The report series will examine policies and 

practices related to the availability of medical interventions and life-saving 

medical care for people with disabilities. It will examine five intersections of 

disability and bioethics – organ transplants; medical futility; genetic testing for 

fetal disability; Quality Adjusted Life Years Analysis (QALYS); and physicianassisted suicide. The report series will conclude in FY19 and the series will be 

offered to policymakers in the spring of 2019.

• NCD Conducting Research on the Need for a Centralized Accommodations 

Fund – NCD began research in FY18 regarding the creation of a centralized 

accommodations fund for the Federal Government by conducting outreach to 

agencies Government-wide regarding their current practices. Research will 

continue into and conclude in FY19, with NCD’s findings and recommendations 

for policymakers offered at that time. 

• Other Policy Recommendations – In addition to the research projects NCD 

undertook in FY18 in order that it might advance policy recommendations for 

legislators and agency leadership, NCD also advised in short form through letters

on the following critical issues:

o Accessible Medical Equipment – NCD drafted a letter to U.S. Attorney 

General Sessions concerning the necessity & appropriateness of 

accessible medical equipment regulations. NCD advised that as a means 

of ensuring compliance with the Americans with Disabilities Act, and also 

as a means of saving additional healthcare costs, a clear and unequivocal 

directive to healthcare providers must be established on the need to 

provide accessible medical diagnostic equipment. NCD’s Chair has met 

with the White House Domestic Disability Policy Council to discuss this 

important issue. 

o Disaster Management – NCD wrote a letter to FEMA Administrator Long 

concerning disaster management to offer specific recommendations to 

improve the outcomes of people with disabilities before, during, and after a 

major disaster. Specifically, NCD recommended restructuring the Regional 

Disability Integration Specialist roles and responsibilities; supporting 

Congress in efforts to modify the Stafford Act to eliminate the inclusion of 

medical expenses for grant max totals and implementing policies to 
16 of 47

improve data collection on the outcomes of people with disabilities in the 

aftermath of a major disaster.

PLANNED ACTIVITIES FOR GOAL 1 OBJECTIVES FOR FY 2020

Every year, NCD’s Council and staff propose and advance new policy projects for the 

coming fiscal year based upon current events and national trends, respective areas of 

expertise, suggestions from policymakers, and anticipated legislative reauthorizations or 

regulatory activities. Typically, all of these proposals will be presented to the full 

Council, one by one, and a priority vote will occur after the presentations. On the basis 

of the outcome of the prioritization, staff will then draft statements of work for each 

approved priority project and begin the process to undertake the research. At its 

January 2019 council meeting, the National Council on Disability voted to approve the 

following slate of policy projects for the FY19 and FY20 years:

Follow up to NCD’s letter (https://ncd.gov/publications/2018/letter-us-attorneygeneral-sessions-accessible-medical) to the Department of Justice (DOJ) 

regarding accessible medical equipment regulations. In a conference call with 

Department of Justice officials, DOJ stressed the need for hard data supporting the 

cost-effectiveness of accessible medical diagnostic equipment. All new regulations must 

be off-set and come in at a $0.00 cost cap according to Executive Order number 13771. 

In order to demonstrate that, DOJ needs research that supports that if all clinics and 

hospitals have accessible diagnostic equipment, patients with disabilities would not be 

forced to use emergency rooms, would utilize the health system for preventive care, 

would reduce injuries to the workforce, and thereby achieve cost-savings that would 

allow the rule to be promulgated via the rule-making process. NCD would like to 

complete a research study on the economic cost-savings of accessible medical 

equipment. The research study could also encompass the savings that have been 

achieved by the states that have enacted safe patient handling rules. 

ABLE Convenings - The House Appropriations Committee’s Labor, Health and Human 

Services, Education, and Related Agencies Appropriations Committee Report included 

language requesting NCD, when convening stakeholders, to conduct information 

sessions on ABLE accounts as well as to serve as an interagency coordinator to ensure 

consistency across Federal agencies and programs re: ABLE implementation. We will 

begin ABLE information sessions at the February Council meeting and will continue to 

do so at other Council meetings. NCD did not receive any funding to conduct this task, 

thus we are adding it to this list for consideration as a funding priority.
17 of 47

Foreign Policy follow-up – NCD has published a number of reports containing 

recommendations regarding how US money is spent overseas. In our reports, we have 

mainly focused on the State Department and USAID. However, in recent years, the 

Department of Defense (DOD) has played a more significant role in capacity and 

infrastructure building in developing countries. NCD should conduct a follow-up study 

looking in depth at the rebuilding conducted by the Department of Defense. As part of 

this work, NCD could conduct a site visit to a post-conflict country to look at how US 

funds are being used in rebuilding efforts and accessibility of new infrastructure. 

Airline Travel for People with Disabilities - NCD released a position paper in 2004 

recommending the Air Carrier Access Act (ACAA) be amended to allow for a private 

right of action. Our work in this area goes as far back as 1999 report, where NCD 

specifically addressed wheelchairs being mishandled and refusal to stow adaptive 

equipment such as walkers and folding wheelchairs in the aircraft cabin. Many problems 

stem from the unwillingness of some airline staff to recognize that a request for an 

accommodation in air travel invokes civil rights protections. The newly enacted FAA 

Reauthorization Act of 2018 includes amendments in the form of directives for the 

Department of Transportation and DHS that impact the ACAA. NCD could update our 

1999 report and our position paper by evaluating how the directives in the FAA 

Reauthorization Act of 2018 can be utilized to address and improve the outcome of 

airline travelers with disabilities.

AbilityOne - This paper would be the 2nd in a series on AbilityOne. The 1st paper is the 

currently underway white paper that will take a cursory 1st look at the Commission’s 

governance and responsibilities. This report will drill down and ultimately discuss 

whether the AbilityOne Commission is fulfilling its mission and if it has been an effective 

tool in employing people with disabilities. This report would look at issues discussed in 

the 1st series in more depth and detail. Such as the 898 Commission; the payment of 

fees from nonprofit agencies to the CNA’s; and in turn the CNA’s using those fees to 

lobby. 

Subminimum Wage 14 (c) – A follow-up report to NCD’s fall 2018 release From the 

Real Deal to the New Deal: Joining Industries of the Future. Recommended areas of 

focus would be to expand data collection beyond the top 50 facilities, which were looked 

at in the original report, so as to assess representative data as to the overall wage 

disparity. Elaborate on the relationship between the EEOC and the DOL pertaining to 

reasonable accommodations for persons with disabilities employed at sheltered 

workshops. Additionally, discuss in more detail the relationship of for-profit agencies 

and its use of subminimum wage employees.
18 of 47

Subminimum Wage/AbilityOne - This report would serve as a follow-up to the 

subminimum wage report and the AbilityOne white paper. This report will be used as a 

guide to modernize AbilityOne. If the 14 C program is being modernized, then 

AbilityOne must follow suit. Issues to be addressed is governance, oversight and 

transparency. How are these 3 factors being addressed by the Commission? What is 

the mission of AbilityOne? Is that mission being served? Take a deep dive into the data 

as well as proffering site visits to speak to people around the nation. Getting specific 

data pertaining to AbilityOne which does not exist at this time. The last report pertaining 

to AbilityOne was a GAO report released in 2001. This report would offer solid 

recommendations to go hand-in-hand with the subminimum wage report 

recommendations to improve the employment outcomes of people with disabilities.

Bioethics – We will have first drafts of NCD’s bioethics report series in February. Based 

on what research turns up, NCD could follow up on any potential recommendations for 

further research or study or need for further data.

NCD will also continue to disseminate its work and meet with policymakers regarding its 

FY18 and FY19 reports (mentioned in the highlights section above), to ensure that its 

new policy advice is known and understood. Additionally, even though NCD gives 

priority to its latest releases, NCD’s LAO team will continue to inform policy discussions 

and media coverage of topics about which NCD has offered a body of research and 

advice in recent years throughout FY20. 

RESULTS OF OBJECTIVES FOR GOAL 2 

GOAL 2 OBJECTIVES

Proposed and Existing Federal Policies –

1. Provide findings and recommendations regarding the implementation of the Workforce 

Innovation and Opportunity Act’s requirement to provide pre-employment transition 

services to transition-age students with disabilities.

2. Provide recommendations regarding the implementation of the Individuals with 

Disabilities Education Act and the Higher Education Act if Congress pursues 

reauthorization efforts.

3. Recommend improvements to the efficiency, effectiveness, and coordination of existing 

federal disability programs and offices.

4. Develop materials and recommendations regarding findings of research on the use of 

subminimum wages in for-profit supply chains and highlight best practices used by 

providers that transitioned away from the use of subminimum wages. 
19 of 47

In FY18, NCD continued to regularly examine existing federal policies’ effect on the 

lives of people with disabilities, as well as review and provide insights on proposed 

legislative and regulatory initiatives and their potential impact on people with disabilities. 

Highlights of NCD’s results in Goal 2 objectives for FY18: 

• Workforce Investment Opportunity Act (WIOA) report – In line with the goals 

of the Administration and Congress to place an emphasis on increasing 

employment, NCD released findings and recommendations regarding Vocational 

Rehabilitation’s progress in implementing WIOA’s requirement to provide preemployment transition services (PETS) to transition-age students with 

disabilities.

• Individuals with Disabilities in Education Act (IDEA) policy brief series –To 

support improved outcomes of students with disabilities and in anticipation of an 

eventual reauthorization of IDEA, NCD issued a series of policy briefs that 

examine the following topics under IDEA -- segregation, funding, monitoring, 

English Language Learners, and the interplay between IDEA and Every Student 

Succeeds Act (ESSA).

• Foreign Policy – NCD has issued a series of reports in the past regarding the 

inclusion of people with disabilities in U.S. foreign policy. In our FY 2018 report, 

we marked the progress made on our past recommendations as well as identified 

the areas that still require follow up at the State Department, USAID, and the 

Peace Corps. The report also examined the policies and practices of the 

Millennium Challenge Corporation to determine whether it applies U.S. disability 

laws and policies to its programs overseas. In view of the President’s budgetary 

proposal to significantly alter the U.S. approach to foreign aid, NCD released this 

report in a timely manner to inform planned changes in a way that will not impede 

progress toward greater inclusion of people with disabilities in U.S. foreign policy.

• National Disability Policy: A Progress Report – In early FY18, NCD released 

its statutorily required annual report reporting on the state of disability policy in 

key areas. In its FY18 edition, NCD used the intersection of disability and poverty 

as its organizing theme, as poverty is a common thread that continues to 

compound many of the core concerns for people with disabilities in America. The 

report addressed why people with disabilities are often destined to live in poverty 

and experience high unemployment despite existing federal regulations and 

public policies geared toward improving the lives of people with disabilities. The 
20 of 47

report concluded with an overview of several emerging and promising practices 

for achieving economic self-sufficiency for consideration by policymakers to bring 

to scale.

• Subminimum Wage Reform / Competitive Integrated Employment – During 

late FY18, NCD conducted qualitative research and examined the most current 

quantitative data regarding the use of Section 14c of the Fair Labor Standards 

Act that allows payment of subminimum wages to people with disabilities; and 

examined the best practices of providers that have voluntarily transitioned away 

from its use. NCD will finalize the research’s findings and recommendations in 

early FY19, followed by the report’s release and dissemination. Additionally, NCD 

is creating an infographic that will visually present the outcomes of a person with 

a disability absent sub-minimum wage and a person with a disability paid subminimum wages. The outcome is a testament of the negative impact of 14c.

• ADA Notification Proposed Legislation – NCD sent a letter to the leadership of 

the U.S. House of Representatives advising against H.R. 620, a bill that would 

limit the recourse of a person with a disability in the face of an inaccessible 

establishment. Proponents of H.R 620 argue(d) that the Americans with 

Disabilities Act (ADA) has become a tool of vexatious litigants who use it to extort 

money from well-meaning business owners who have made every attempt to 

comply with the law. However, as NCD had argued previously, this is a false 

narrative. NCD noted that the ADA expressly provides that business owners only 

have to make their facilities accessible to the extent that is “readily achievable” 

and does not constitute “undue burden.”

• Congressional Immigration Reform Discussions – NCD drafted a letter to 

Congressional leadership and the President regarding Immigration policy 

discussions and the impact of U.S. immigration policy on the disability 

community. Given the well-documented growth in demand for direct care workers 

for the elderly and people with disabilities that far surpasses current supply, as 

well as the documentation of the challenges this profession experiences with 

high turnover, NCD advised Congress and the White House to consider policies 

that would provide employment-based legal pathways for both currently 

undocumented immigrants who serve in these roles now, as well as for new 

immigrants to the U.S. who would commit to working in this highly in-demand 

service profession.
21 of 47

• Marrakesh Treaty – NCD was instrumental in encouraging the U.S. Senate 

Foreign Relations Committee to ratify of the Marrakesh Treaty. The Marrakesh 

Treaty allows “authorized entities” to create accessible versions of published 

materials and share them with individuals who need them to access the material 

at no cost. Additionally, the treaty allows authorized entities to exchange 

accessible works across international borders with each other, thereby reducing 

duplication and cost. NCD advised that the treaty enhances the lives of people all 

over the world who are blind, visually impaired or print disabled by providing 

them access to books and other material in accessible formats, including braille, 

audio, digital, large print and other formats that emerge as technology advances.

• CMS Notice of Proposed Rulemaking Regarding Medicaid Reimbursement 

Rates – NCD drafted a letter to the Center for Medicaid and Medicare Services 

in response to the Notice of Proposed Rulemaking that sought to give states 

greater flexibility to lower reimbursement rates to Medicaid providers. NCD 

proved that lower reimbursement rates can negatively impact the quality of the 

services provided, which can lead to unintended consequences, particularly for 

individuals who rely on Medicaid for the services they need to remain in their 

homes and communities. 

• Department of Transportation Corporate Average Fuel Economy (CAFÉ) 

Standards – NCD sent a letter to U.S. Department of Transportation Secretary 

Chao and Environmental Protection Agency Administrator Pruitt on the CAFE

standards' impact on people with disabilities. NCD noted that two significant 

concerns stood out, including the standards’ possible effects on vehicle 

affordability and the ability and willingness of vehicle manufacturers to continue 

to produce vehicles that can be specially equipped for people with disabilities 

who use heavy wheelchairs.

• Department of Education’s Proposed Postponement of Equity in IDEA 

Regulations – NCD sent a letter to U.S. Department of Education Asst. Sec. 

Collett regarding a proposed postponement of the Equity in IDEA (Individuals 

with Disabilities Education Act) regulations. In a Notice of Proposed Rulemaking 

the Department proposed to postpone compliance of the Equity in IDEA 

regulations for two years so that it could review the regulations to ensure they 

effectively addressed significant disproportionality. The Department also 

proposed postponing the date for including children ages three through five in the 

analysis of significant disproportionality with respect to the identification of 
22 of 47

children as children with disabilities and as children with a particular impairment. 

NCD advised that a postponement would prolong the long-recognized 

disproportionality in our nation’s special education system and the resulting 

negative impacts on students with disabilities of color and their families.

• Department of Housing and Urban Development (HUD) Proposed Revisions 

on Service Animals – NCD wrote a letter to HUD Assistant Secretary Farias 

urging a meeting on proposed revisions to guidance on service animals and 

assistance animals for people with disabilities in housing and HUD-funded 

programs. As part of its statutorily mandated role, NCD was offering to serve as a 

conduit to disability policy stakeholders so that revisions would properly be 

informed by the community most effected by the revisions.

• Department of Transportation’s Plans to Suspend Enforcement of Claims 

Regarding Psychiatric Service Animals – NCD sent a letter to U.S. 

Department of Transportation (DOT) General Counsel Workie concerning service 

animal discrimination claims, to convey NCD’s concerns regarding DOT’s plan to 

indefinitely suspend enforcement of certain disability discrimination claims 

regarding psychiatric service animals (PSAs) and emotional support animals 

(ESAs). NCD advised that DOT’s proposal to allow airlines to require 

documentation that is unallowable under the existing regulation, and to deny 

complainants with psychiatric disabilities the right to DOT enforcement of 

legitimate claims, gives airlines permissions to violate the law with impunity, and 

to impose significant burdens on persons with psychiatric disabilities.

PLANNED ACTIVITIES FOR GOAL 2 OBJECTIVES FOR FY 2020

NCD will vote on a new slate of policy priorities (as noted herein), including research 

projects that may examine existing federal laws, at its winter FY19 Council meeting. 

In addition to the projects that the Council will vote to commence for work and 

dissemination in FY20, NCD will also continue to disseminate its work and meet with 

policymakers regarding its reports and position letters that addressed proposed and 

existing legislation, the most recent of which is mentioned in the FY18 highlights 

section. If IDEA reauthorization is pursued, as an example, NCD’s FY18 IDEA report 

series will be front and center in its LAO team’s outreach work. Older reports will also be 

used for informing policy discussions as appropriate. If Social Security reform is 

pursued, for example, NCD’s FY15 Securing the Social Contract: Reforming Social 

Security Disability report will again be brought to policymakers’ attention.
23 of 47

Additionally, NCD will weigh in disability-related regulatory proposals that impact people 

with disabilities that may arise; general legislative proposals that impact people with 

disabilities; as well as disability-specific legislation that is introduced.

In FY20, NCD’s 2019 annual Progress Report will focus on the monitoring and 

enforcement activities of the U.S. Department of Justice, the U.S. Department of 

Housing and Urban Development, Ability One and the Federal Communications 

Commission. 

Topics that have been the focus of recent proposals and/or policy discussions on which 

NCD has weighed in and will continue to weigh in throughout FY19 and FY20 include:

• Direct care workforce

• Subminimum wage and competitive integrated employment

• Health care reform

• Javits-Wagner O’Day modernization

RESULTS OF OBJECTIVES FOR GOAL 3

GOAL 3 OBJECTIVES

Engage Policymakers and Respond to Their Requests for Assistance

1. Provide regular disability policy briefings for members of the Administration and 

Hill staff. 

2. Regularly provide congressional leadership and members of the Administration 

written briefing materials on policy priorities of the disability community. 

3. NCD staff and appointed Council members increase time spent in direct 

engagement of congressional and Administration policymakers with NCD’s policy 

advice; and/or of radio, television, print, and online media regarding topics NCD 

has engaged.

In FY18, NCD continued its efforts to respond to congressional requests for policy 

assistance; to meet with and offer briefings to congressional and committee offices 

regarding newly released NCD policy research; to engage with congressional and 

agency offices regarding their own priority areas that have implications for Americans 

with disabilities; and to engage media on topics on which NCD has done its research 

and made its advice to policymakers. Highlights of NCD’s results in Goal 3 objectives 

for FY18 include:
24 of 47

• Legislation Designating the ID/DD Population as Medically Underserved –

In line with NCD’s policy advisement in its December 2017 policy brief on the 

dental care of people with intellectual and developmental disabilities, NCD 

assisted a requesting congressional office with drafting and introducing bipartisan 

legislation that seeks to improve the delivery of medical and dental care to 

people with ID/DD. Under the Healthcare Expansion and Accessibility for 

Developmentally Disabled and Underserved Population (HEADs UP) Act, the 

Public Health Service Act would be revised to designate people with ID/DD as a 

medically underserved population, thereby granting people with ID/DD access to 

the programs and resources of the National Health Service Corps (as is the case 

for the homeless, residents of public housing, and migrant workers). Since the 

brief’s release and the bill’s introduction, NCD continues to field related questions 

by lawmakers and will participate in a congressional briefing with the sponsoring 

offices in early FY19. Numerous disability groups have made the NCD-inspired 

legislation a key legislative priority for their respective advocacy groups, 

indicating the legislation’s resonance.

• Sexual Assault of Students with Disabilities on College Campuses –

Following the release of NCD’s research and policy recommendations on the 

sexual assault of college students with disabilities, offices in the House and 

Senate contacted NCD about introducing legislation based on the report’s 

recommendations. Less than two months after the report’s release, the Safe 

Equitable Campus Resources and Education (SECuRE) Act was introduced, 

which intends to address many of the systemic failures brought to light in NCD’s 

Not on the Radar: Sexual Assault of College Students with Disabilities. In 

conjunction with sponsoring offices, NCD also held a congressional briefing on its 

report and the legislation introduced based on its recommendations. 

• The Disability Community’s Interactions with Law Enforcement – As a 

follow-up activity to our December 2016 policy roundtable on the same topic, 

NCD drafted a letter to U.S. Department of Justice (DOJ) Attorney General 

Sessions that provided insight and recommendations concerning the interaction 

between law enforcement and members of the disability community, including the 

broader cross-disability population, during “first response” scenarios. Subsequent

to that correspondence, NCD met with representatives of DOJ, including 

representatives of DOJ’s Disability Rights section, Special Litigation section, and 

the Community Oriented Policing Services (COPS) office, to discuss NCD’s

recommendations. As a result of this meeting, NCD drafted recommended 

questionnaire language that DOJ’s National Data Collection Program office is 
25 of 47

considering for inclusion in its questionnaire that will be dispersed to local law 

enforcement agencies across the U.S. as a means of addressing potential first 

response concerns between law enforcement and people with disabilities.

• Media Engagement and Interest in NCD’s Work – NCD’s work is routinely 

highlighted in national media and industry publications, and NCD regularly 

receives media inquiries for comment on current events related to people with 

disabilities and to its most recent report releases. A small sampling of NCD’s 

media mentions in FY18 follow below:

o NCD’s long record of engagement of policy discussions regarding disaster 

management was noted by National Public Radio in a piece done in early 

FY18 that included an interview with NCD about its work in the area of 

disaster management.

o In addition to introduced legislation following its Not on the Radar report 

regarding sexual assault on college campuses, national media noted 

NCD’s research findings and recommendations to policymakers, including 

Politico, the Chronicle of Higher Education, Rewire, and several college 

radio stations.

o Teen Vogue prominently featured NCD’s Breaking the School to Prison 

Pipeline for Students with Disabilities report in a feature piece it ran in its 

magazine in early FY18.

o The National Conference of State Legislatures’ membership magazine 

featured NCD’s work on 14c / subminimum wages in a feature it ran on 

nationwide trends away from subminimum wage’s use. 

• Other Engagement and Assistance – In addition to its traditional and primary 

advisees, throughout each year, NCD also commonly engages or responds to 

requests for assistance from other groups and interested parties as well. A small 

sampling of these interactions for FY18 follows:

o Showcasing U.S. federal disability rights leadership for international 

delegations – NCD staff and Council Members met with representatives 

from many countries to discuss U.S. federal disability civil rights laws 

(which many nations desire to study and replicate) and the structure and 

role of NCD as an independent federal advisory body regarding disability 

policy. Many countries have signed and ratified the Convention on the 

Rights of Persons with Disabilities and thus are seeking information from 

the United States on how best to implement, given our long history with 

the Americans with Disabilities Act and other disability laws. While it is 
26 of 47

difficult to gauge specific outcomes from these meetings, the most 

frequent subject of discussion is how to create their own “National Council 

on Disability,” what structure of government is required; how to achieve 

the right make-up; and how to ensure it can be effective in its role as a 

government advisor. 

o National Governors Association – NCD reached out to the Director of 

the National Governors Association "NGA Future" Initiative, as a means of 

expanding dialogue concerning the importance of accessibility of 

emerging technologies for people with disabilities, which was wellreceived.

o American Dental Association – NCD engaged the leadership of the 

American Dental Association, recommending that it revise its Code of 

Professional Conduct to better reflect the rights of people with disabilities 

in compliance with the Americans with Disabilities Act and as a matter of 

equal treatment. After several exchanges, the ADA House of Delegates 

voted in favor of implementing NCD’s recommendation and have indeed 

revised its Code accordingly.

o Commission on Dental Accreditation (CODA) – NCD contacted the 

Commission on Dental Accreditation (CODA) requesting and advising that 

its accreditation standard be revised in compliance with the Americans 

with Disabilities Act and also as a matter of equal treatment. At present, 

CODA does not require that dental students be instructed in providing 

treatment to patients with I/DD (intellectual and developmental disabilities-

-representing millions of Americans), thus a treatment gap exists that often 

leads to great health risks and costs. CODA responded by acknowledging 

that the standard could be changed and submitted the revision for a public 

comment period to close in the summer of 2019.

PLANNED ACTIVITIES FOR GOAL 3 OBJECTIVES FOR FY 2020

NCD’s update of its five-year strategic plan for FY 2018 – FY 2022 includes enhanced 

engagement activities that will continue to prominently shape the work of the agency. 

In FY19 and FY20, NCD will continue to work with sponsoring offices of legislation 

based on NCD’s report recommendations, presently including the SECURE Act (sexual 

assault on college campus legislation), the HEADS Up Act (dental care of people with 

I/DD), and autonomous vehicle legislation. NCD was also tasked in FY18 by language 

in the House Appropriations Committee Report with new responsibilities to conduct 

information sessions across the country regarding the Achieving a Better Life 

Experience (ABLE) Act and for interagency coordination so that federal agencies are 
27 of 47

providing information and guidance consistent with the legislation. Accordingly, NCD will 

work in FY19 and beyond on these new responsibilities. 

In FY 2020, NCD will provide regular disability policy briefings for members of the 

Administration and Hill staff. In line with specific requests of committee and Member 

offices regarding content, NCD plans to provide at least two congressional briefings a 

year utilizing NCD research. Additionally, by the end of March 2020 and again by the 

end of March 2021, NCD plans to provide a high-level primer in the form of a Hill 

briefing on the policy areas of greatest priority for the disability community, targeting 

staff of new members’ offices. 

In FY 2020, NCD will provide congressional leadership and members of the 

Administration written briefing materials on policy priorities of the disability community. 

In advance of any congressional hearing regarding a topic of priority concern for the 

disability community, NCD will provide written briefing materials to committee members, 

including key findings and recommendations from NCD’s body of research, as well as 

suggested questions for witnesses. Additionally, by the end of March 2020 and again by 

the end of March 2021, NCD plans to provide a high-level written primer to offer at a Hill 

briefing on the policy areas of greatest priority for the disability community, targeting 

staff of new members’ offices. 

In FY 2020, NCD also plans to increase the time of NCD staff and Council members 

spent in direct engagement of congressional and Administration policymakers with 

NCD’s policy advice. For its 2019 Washington, DC-located board meeting and every 

DC-based meeting thereafter, NCD staff plans to arrange agency and congressional 

meetings to discuss NCD policy advice and solicit advisee feedback to coincide with the 

time during which the NCD Council Members will be in town. By 1st quarter FY19, NCD 

management will incorporate federal agency advisee outreach following report release 

into performance plans of employees tasked with shepherding NCD policy reports to 

completion. 

In FY 2020, NCD will continue to offer “town hall” public comment opportunities at each 

of our NCD quarterly meetings around the country to create opportunities for the 

Council to hear directly from members of the public; meet regularly with international 

delegations; and provide regular disability policy briefings for members of the 

Administration and congressional staff. NCD continually receives public comment 

outside of quarterly meetings via all social media platforms and NCD’s website. NCD 

also plans to examine and revise the format of its publications, briefing materials, and 

briefing methods in FY 2020, with a mind toward increasing their responsiveness to the 

specific needs of NCD advisees.
28 of 47

RESULTS OF OBJECTIVES FOR GOAL 4

GOAL 4 OBJECTIVES

Gather Information from Subject Matter Experts 

1. Engage the disability community beyond Washington, DC, soliciting their views 

regarding timely policy matters and providing the input of the disability community 

for policymakers to weigh in their decision making.

2. Develop information partnerships with subject matter experts inside and outside 

the disability community to generate effective intelligence for policymakers to use 

in weighing issues.

In FY18, in service of its policy development cycle, NCD staff and Council members 

continued outreach efforts to national organizations, individual constituents, academics, 

disability coalitions; and disability conferences, all of which informed the research 

projects as well as helped steer the direction of policy priorities the agency set for the 

next fiscal year. For every one of NCD’s FY18 released reports, NCD’s research 

involved engagement of people with disabilities from across the country in the form of 

focus groups, interviews, and advisory councils. In each report, NCD highlighted and 

summarized those interactions so as to elevate first-hand experiences of people with 

disabilities to the attention of policymakers. 

In FY18, NCD entered into cooperative agreements with subject matter experts to assist 

with nearly all of NCD’s research endeavors to ensure that the information provided to 

policymakers was current, relevant, and accurate. These agreements are at times with 

organizations that have specialized expertise in certain policy areas, and at other times 

with academic institutions or research groups.

PLANNED ACTIVITIES FOR GOAL 4 OBJECTIVES FOR FY 2020

In FY19 and FY20, NCD will continue its process of purposed engagements of 

individuals from the disability community from across the country to inform its research 

reports; and its usage of cooperative agreements to obtain data and elicit expert input 

into all of its research. It will also hold informational sessions on the ABLE Act, inviting 

members of the disability community, at each of its quarterly Council meetings to satisfy 

one of its new duties under House Appropriations Committee Report language.
29 of 47

RESULTS OF OBJECTIVES FOR GOAL 5

GOAL 5 OBJECTIVES

Enhance Agency Operational and Programmatic Internal Controls

1. Evaluate and update agency IT infrastructure.

2. Enhance planning and evaluation of all agency projects to ensure continual 

improvements.

3. Ensure compliance with financial regulatory and reporting requirements.

4. Update all agency internal policies and procedures.

In FY18, Highlights of NCD’s results in Goal 5 objectives for FY18 include:

• In FY17 and throughout FY18, NCD has worked collaboratively with the 

Department of Homeland Security to implement EINSTEIN requirements. NCD 

has complied with all mandated requirements to the maximum extent that the 

budget allowed. 

• In FY18, NCD entered into an agreement with the Department of Interior to 

complete a security assessment and authorization (SA&A), required by the 

Federal Information Security Management Act (FISMA). All systems and 

applications that reside on U.S. government networks must go through a formal 

SA&A before being put into production. This process has evaluated 514 controls 

on NCD’s network. 

• In FY18, NCD entered into an agreement to do the framing work so that personal 

identity verification (PIV) cards are activated for individuals who require access to 

NCD’s network. The PIV card will contain the necessary data for the cardholder 

to be granted to Federal facilities and information systems and assure 

appropriate levels of security for all applicable Federal applications.

• In FY18, NCD entered into an agreement to create a SharePoint platform to 

increase transparency, communication and implement additional cybersecurity 

mandates. The platform will continue development in FY19 and FY20.

• The Accountability for Tax Dollars Act requirement for an annual preparation and 

audit of financial statements of smaller agencies was exempted by OMB as a 

cost savings for NCD and in recognition of the stewardship NCD had presented 

through ongoing unqualified audits. 

• In FY19, NCD will implement Managed Trusted Internet Protocol Service 

(MTIPS) which allows U.S. Federal agencies to physically and logically connect 

to the public Internet and other external connections in compliance with the 
30 of 47

Office of Management and Budget's (OMB) Trusted Internet Connection (TIC) 

Initiative. 

• In FY19, NCD will implement OpenFISMA which will provide a Web-based 

centralized repository to manage and track vulnerability reporting and 

remediation activities. Users will log in to their role-based accounts to work 

through or oversee the compliance processes. 

• In FY19, NCD will implement Voice Over IP (VoIP) for internet and phone 

service.

• In FY19, NCD will adopt an Authorization to Operate (ATO) which explicitly 

accepts the risk to agency operations.

PLANNED ACTIVITIES FOR GOAL 5 OBJECTIVES FOR FY 2020

• In FY20, NCD will continue to plan actions and milestones (POA&M) to track and 

fix security vulnerabilities. complete the Plan of Action (POAM) to ensure that all 

cybersecurity mandates are completed. 

• In FY20, NCD will complete a bi-annual audit to ensure all fiduciary duties were 

adhered during FY18 and FY19. 

• In FY20, NCD will focus on the agency’s Continuity of Operations (COOP) to 

protect and secure the integrity of the agency and to preserve the work that is 

critical to the mission of the agency. 

• In FY20, NCD computer equipment is scheduled to refresh. Based upon 

availability of funding the agency will move forward with refreshing the equipment 

needs for the agency.

RESULTS OF OBJECTIVES FOR GOAL 6

GOAL 6 OBJECTIVES

Recruit, Retain, and Develop a Highly Qualified Professional Staff 

1. Enhance new staff orientation materials and process.

2. Perform a SWOT analysis and identify best practices from select agency projects 

from the prior fiscal year. 

3. Identify training to support improvement in areas identified as weaknesses or 

signifying skills gaps by project analysis.

In FY18, NCD experienced several significant leadership and staffing changes, 

including a new incoming Chairman, designated by President Trump, a new Executive 

Director designated by the Chairman, a new congressionally appointed Council 

Member, and the hiring of two, new full-time staff to fill vacancies. 
31 of 47

Highlights of NCD’s results in Goal 6 objectives for FY18 include:

• NCD enhanced procedures to onboard new staff and member by providing an 

agency-wide orientation within one week of hire or appointment. In FY18, four

orientations occurred. In FY17, four orientations occurred. The orientation 

process includes all staff and is continually reviewed for accuracy and updates. 

• Operational training has been incorporated into council meetings to ensure 

members and staff receive ongoing training on personnel and financial 

requirements. 

• To ensure ethical conduct of all staff and members, NCD partners with the U.S. 

Department of Education, Office of the General Counsel, Ethics Division to 

provide members and staff annual ethics training. 

• In FY19, NCD will partner with GAO to evaluate hiring and retaining people with 

disabilities in the federal government. As a follow-up report to the GAO report in 

2012, GAO is evaluating ten agencies and has NCD as a model agency to assist 

in the process. 

PLANNED ACTIVITIES FOR GOAL 6 OBJECTIVES FOR FY 2020

In FY20, with adequate funding NCD will employ additional full-time staff to assist with 

meeting the critical mission of the agency. 

In FY20, NCD will continue to provide ethics training annually. 

NCD will continue review and revision of all administrative policies and procedures to 

ensure risk is mitigated

The directors of NCD will continue to complete SWOT analyses to identify best 

practices from select agency projects from the prior fiscal year and identify training to 

support improvement in areas identified as weaknesses or signifying skills gaps by 

project analysis.

Cross-Agency Collaborations

NCD’s policy advisement is often directed at other federal agencies, and it is vital that 

we maintain open communication and relationships with agencies across the 

government in furtherance of our research to policymakers and to also help close key 

feedback loops for agencies, by assisting them in hearing from people with disabilities 

across the country. Fostering such cross-agency relationships supports our strategic 

objective to develop policy recommendations and encourage collaboration. With each 

policy project, NCD shares our recommendations in advance with the agencies we are 

examining to ensure technical accuracy and strives to follow up with the same agencies 
32 of 47

in assessing their implementation of our recommendations. In addition to these piecemeal federal agency collaborations, specific instances of ongoing cross-agency 

collaborations include the following:

GOVERNMENT ACCOUNTABILITY OFFICE (GAO)

In FY18, NCD coordinated with GAO regarding NCD’s research project on the 

involuntary institutionalization of people with disabilities as a result of natural disasters

given GAO’s work in the same area, to ensure duplication of effort was avoided. NCD 

also continued to correspond regularly with GAO on report GAO-17-115 “Prescription 

Drug Labels” regarding NCD’s work related to an awareness campaign regarding 

accessible drug labels. 

SMALL BUSINESS ADMINISTRATION

In FY 2018, NCD met with the Small Business Administration (SBA) several times to 

discuss SBA’s 8(a) Business Development Program in the context of the disabilityowned small businesses and the well-documented employment disadvantages of 

people with disabilities. Because of the productive discussions, SBA requested NCD to 

serve in an ex-officio role on its Council on Underserved Communities. 

CENTERS FOR MEDICARE AND MEDICAID SERVICES (CMS)

In FY 2018, NCD met twice with new leadership of CMS to discuss their intentions 

regarding potential changes to recent CMS regulations in light of NCD’s five-year

engagement of Medicaid stakeholders across the country (Medicaid beneficiaries, 

service providers, managed care organizations, state Medicaid departments) to assess 

the effectiveness of federal Medicaid policy at the state level.

FEDERAL EMERGENCY MANAGEMENT AGENCY

Prior to the catastrophic hurricanes of 2005 (Katrina and Rita) NCD led a project related 

to emergency preparedness for people with disabilities - Saving Lives: Including People 

with Disabilities in Emergency Planning. Based on that work, NCD received additional 

appropriations through the Post-Katrina Emergency Management Reform Act of 2006 

(PKEMRA) to continue working on emergency preparedness efforts for people with 

disabilities and we worked collaboratively with FEMA to co-host conferences and issue 

follow up recommendations on post-disaster planning including a research study 

regarding effective communications for people with disabilities before, during, and after 

emergencies. NCD continues to collaborate with FEMA, most recently co-hosting a 

Twitter chat on FEMA’s effectiveness in fulfilling Section 504 requirements in public-
33 of 47

facing programs during emergencies. NCD also now serves on the Integrated Public 

Alert and Warning System (IPAWS) Subcommittee to the Federal Emergency 

Management Agency (FEMA) National Advisory Council (NAC). The subcommittee’s 

creation is pursuant to the IPAWS Modernization Act of 2015 (Public Law 114-143). The 

IPAWS Subcommittee is tasked with making recommendations through the NAC to 

ensure that FEMA can provide timely and effective warnings regarding natural 

disasters, acts of terrorism, and other man-made disasters or threats to public safety. 

The IPAWS Subcommittee convenes every other month to consult with and consider 

changes to improve IPAWS and new and developing technologies that may be 

beneficial to the public alert and warning system. NCD assisted GAO in their 

assessment of FEMA’s response to people with disasters for people with disabilities. 

DEPARTMENT OF JUSTICE

NCD met with representatives of the DOJ, including representatives of DOJ’s Disability 

Rights section, Special Litigation section, and the Community Oriented Policing 

Services office, to discuss NCD’s recommendations regarding potentially harmful 

interactions between law enforcement and members of the disability community. As a 

result, NCD drafted recommended questionnaire language that the DOJ’s National Data 

Collection Program office is considering for inclusion in its questionnaire that will be 

dispersed to local law enforcement agencies across the U.S. as a means of addressing 

potential first response danger concerns between law enforcement and people with 

disabilities.

DEPARTMENT OF STATE

In FY 2018, NCD meet regularly with international delegations, at the request of the 

U.S. Department of State, to discuss federal disability civil rights laws, such as the 

Americans with Disabilities Act (ADA), as well as the history and structure of NCD as a 

disability advisory body within the Federal Government. This year, NCD met with 

representatives from Bulgaria; Bahrain; Israel; Argentina; Philippines; Rwanda; Nigeria; 

Brazil; Ghana; India; Sri Lanka and Sierra Leone; and Vietnam. 

DEPARTMENT OF LABOR

NCD continues to serve on the interagency Partners in Transition workgroup regarding 

increasing systems coordination to improve employment outcomes for young people 

with disabilities. The workgroup meets monthly, and this past year, NCD leveraged this 

group and their grantee networks to line up subject matter experts as panelists at its 

quarterly meetings. 
34 of 47

ADMINISTRATION ON COMMUNITY LIVING

Throughout FY18, NCD participated in the ACL Multi-Agency Task Force on Increasing 

Employment Opportunities for People with Disabilities, which is a group of agency 

representatives working on a National Action Plan to improve employment outcomes. 

NCD brings NCD’s report findings and recommendations regarding employment and 

poverty to bear in those task force meetings. 

U.S. DEPARTMENT OF HEALTH AND HUMAN SERVICES

In FY18, NCD participated in a Federal Partners Meeting on Increasing Accessibility of 

Health Care Facilities, hosted by HHS, Office of Minority Health. NCD presented on its 

dental brief and discussed progress made towards equal opportunity to dental care for 

people with DD/ID, as well as on information regarding on the recently developed Core 

Competencies on Disability for Health Care Education and The Need for Disability 

Standards in Healthcare Education (Ohio State University & Alliance for Disability in 

Healthcare Education) as a way to connect the researchers with federal partners for 

collaborative efforts to get medical education providers to adopt the standards as part of 

medical curricula.

DISABILITY POLICY INTERAGENCY WORKING GROUP (DPG)

NCD leadership meets monthly with the DPG to ensure cross collaboration with other 

disability agencies focused on information sharing, best practices, and collaborative 

partnerships designed to make the Federal Government a model employer of people 

with disabilities.

In FY18, a sub-group was created to look at the Opioid Crisis. NCD management and 

council membership is a member of the sub-group

SMALL AGENCY COUNCIL EXECUTIVE COMMITTEE AND GSA PARTNERSHIP

In FY18, the small agency council created a committee to assess federal partnerships 

with GSA. NCD leadership is a member of the evaluation committee working 

relationship with GSA to improve their services to the federal government. 

Major Management Priorities & Challenges

Given NCD’s limited budget, we must be diligent in the planning and evaluation of all 

agency projects and work to ensure continual improvements.

NCD has enhanced Operational and Programmatic Internal Controls and ensured 

compliance with financial regulatory and reporting requirements by entering into a 
35 of 47

Memorandum of Agreement (MOA) with the Department of Homeland Security (DHS)

and the Department of Defense (DOD) to secure America’s cyber networks. NCD 

entered into a MOA with the DHS, Office of Cybersecurity and Communications to 

ensure the deployment of EINSTEIN Cybersecurity capabilities. NCD is participating in 

the deployment of EINSTEIN Intrusion Prevention Security Services (IPSS) on its 

networks for network security purposes, to look for network traffic indicating known or 

suspected malicious cyber activity. 

NCD is committed to transparency, participation and collaboration. NCD encourages

participation from the public in determining policy priorities. Our past and current 

practice is to receive public comment at our quarterly council meeting in addition to 

public hearings and information sessions. 

NCD establishes and maintains effective internal control and financial management 

systems that meet the objective of the Federal Manager's Financial Integrity Act. We 

conduct our assessment of the effectiveness and efficiency of internal control and 

ensure compliance with applicable laws and regulations in accordance with OMB 

Circular A-123, Management's Responsibility for Internal Control. Based on the results 

of this evaluation, we can provide reasonable assurance that our internal control over 

the effectiveness and efficiency of operations and compliance with applicable laws and 

regulations is operating effectively and no material weaknesses were found in the 

design or operation of the internal controls.

Currently, NCD publishes 3-5 full-length reports a year. Each of these research 

publications often involves outside contractual assistance. These full-length reports are 

fulsome research endeavors that entail a broad scope of policy consideration, and/or 

address an emerging topic or technology that NCD urges policymakers to consider. 

While NCD will continue to service the needs of policymakers and the disability 

community’s interests and publish research/policy reports each year, we are forced to 

reallocate money from this mission critical task to ensure we are in compliance with 

cybersecurity mandates. As a result, NCD is transforming the majority of its policy 

recommendations and research to shorter brief formats. This approach will attempt to 

be more responsive and timelier to a Congressional and Administration audience as 

well as save the agency contractual dollars. Our performance indicators will include the 

feedback we receive to the new format and approach by NCD’s core audience –

congressional and Administration policymakers and staff.

NCD’s management’s major priorities in FY 2019 and FY 2020 are to:
36 of 47

1. Thoughtfully assess agency workforce, workload, and workflow against the 

backdrop of the March 13, 2018 Reorganization Executive Order and 

accompanying guidance (M-17-22);

2. Ongoing review and updates to NCD’s internal control policies and procedures; 

3. Complete compliance with mandated cybersecurity protocols; and

4. Train, develop, and retain NCD’s existing exceptional workforce and do the same 

when filling existing vacancies.

5. Continue to practice and promote hiring of people with disabilities. 

An enduring management challenge is how best to approach the allocation of the 

agency’s limited financial and human resources. With a full-time career staff of eleven 

and nine Council members balancing their service on NCD with their own full-time 

careers, and given the breadth of its mission, the scope of NCD’s engagement, policy 

development, and collaborative activities is necessarily limited. NCD’s modest budget 

figure and small workforce necessitates balancing and prioritizing stakeholder needs 

with available resources. 

Related to the allocation of resources, maintaining a continuity of workforce is both a 

management priority and challenge. Unlike the experience of a larger agency that can 

withstand numerous vacancies without immediate implication to mission 

accomplishment or the operational integrity of the agency, in an agency the size of 

NCD, even a single vacancy can create a palpable operational effect on the agency.

Additionally, with the extent of discrete responsibilities every federal agency faces, 

regardless of size, some individual NCD employees may be the sole individual 

responsible for and knowledgeable of how to complete particular tasks. This necessarily 

creates risk for which the agency must account and control. Therefore, employee 

retention, professional development, cross-training among employees, and thoughtful 

hires in the case of vacancies are clear management priorities at all times as are 

persisting in efforts to seek opportunities to strengthen and add to the number of staff if 

possible. 

PLANNED ACTIONS TO ADDRESS PRIORITIES & CHALLENGES

In FY 2018, NCD reviewed the profile and continued to closely monitor areas that could 

present potential risk for the agency. In FY18, NCD management continued to pursue

training on program evaluation and outcome measurement. In FY19 and FY20, NCD 

management will complete an update of the agency’s internal control policies and 

procedures and will continue to pursue opportunities to enhance its program evaluation 

methods.
37 of 47

Throughout FY18, NCD’s management team has spent considerable time 

understanding and pursuing compliance with all cybersecurity protocols. Given the 

absence of in-house expertise related to the requirements of the protocol and the lack of 

resources, NCD has had to shift resources from mission critical work to contract for 

assistance to ensure our compliance with the new requirements. The expense 

associated with this compliance is further discussed in the budget justification section.

Continuing in FY18, NCD management designated a specific line item per team (based 

upon the number of employees in each team) for workforce training and development 

and encouraged employees to pursue such opportunities. NCD management continued 

to emphasize cross-training among members of each team and required employees as 

a part of their annual performance plans to incrementally add and ultimately complete 

“desk manuals” to ensure an additional layer of risk mitigation with respect to task 

completion. NCD’s AFO team also began work in FY18 on a SharePoint intranet that 

will enhance agency coordination across teams and among the staff and Council. This 

project will continue and be rolled out into operation in early FY19.
OBJECTIVES BY TEAM

As outlined in the Performance Section, NCD’s staff is organized into three teams, each 

with its own director. NCD’s Policy / Legal (Policy) is the primary team responsible for 

the agency’s policy development activities. Policy provides legal analysis and advice to 

the Council; regularly interacts with federal agencies; staffs the Council’s policy project 

committees; and researches and drafts many of its publications. 

NCD’s Legislative Affairs / Outreach (LAO) is the primary team of responsible for the 

agency’s engagement activities. LAO regularly interacts with congressional member 

and committee offices and briefs them on NCD’s work; edits and publishes NCD’s 

publications; creates and manages content for the agency’s website; regularly interacts 

with NCD’s core constituency of Americans with disabilities; and organizes briefings and 

engagement opportunities. 

NCD’s Administration / Finance / Operations (AFO) team provides critical Council and 

staff support in furtherance of both strategic objectives. AFO monitors the agency’s 

finances, information technology, human resources management and facility operations. 

The Executive Director provides critical oversight of all teams and monitors progress 

and performance in furtherance of both objectives and the agency’s mission 

accomplishment. These team / strategic objective relationships are noted in the table 

below.

Strategic 

Objective

Goal 1 

Objective

New 

Disability 

Policy 

Advice 

Goal 2 

Objective

Proposed 

and 

Existing 

Federal 

Policies

Goal 3 

Objective

Engage 

Policymakers

Goal 4 

Objective

Subject 

Matter 

Expert 

Information

Support of 

All

Objectives

Goal 5 

Objective

Internal 

Controls of 

Operations 

and 

Programs

Goal 6 

Objective

Highly 

Qualified 

Career Staff

Oversight 

of All 

Objectives

Responsibility

by Team

Policy 

Team LAO Team AFO Team

Each Team 

Director Executive
39 of 47

NATIONAL COUNCIL ON DISABILITY BUDGET JUSTIFICATION

DESCRIPTION

FY 2018 

Appropriation

FY 2019 

Appropriation

FY 2020 

Request

BUDGET TOTAL 3,250,000 3,250,000 3,450,000

PERSONNEL 1,726,898 1,924,693 2,020,878 

TRAVEL 166,528 138,100 148,500

RENT, UTILITIES AND 

COMMUNICATIONS

327,215 315,590 319,672

PROGRAM, RESEARCH AND 

PRINTING

225,050 233,695 201,500

TRAINING AND 

PROFESSIONAL 

ASSOCIATIONS

32,746 31,610 35,000

AUDIT 30,000 35,000 0

PAYROLL, ACCOUNTING AND 

HR SERVICES

122,500 122,500 122,500

SUPPORT CONTRACT 

SERVICES

163,634 130,820 180,500

INFORMATION TECHNOLOGY 235,223 207,736 300,000

PAYMENTS TO FEDERAL 

AGENCIES

22,306 9,000 20,950

SUPPLIES, SUBSCRIPTIONS 

AND MATERIALS

50,400 68,756 66,000

LEGAL / OTHER FEES 115,000 0 0

ANTIDEFICIENCY * 32,500 32,500 34,500
Cost Discussion

The Council is requesting a total budget authority in FY 2020 of $3,450,000. 

The Council requested a total budget authority in FY 2019 of $3,250,000. 

In FY 2019, the Council was provided $3,250.000.

In FY 2018, the Council was provided with $3,250,000.

* NCD reserves a percentage of our annual appropriated budget for unanticipated 

expenses and to ensure the agency does not exceed available funds. 

Analysis of resources follows.
41 of 47

Analysis of Resources

PERSONNEL

FY 2018 $1,726,898

FY 2019 $1,924,693

FY 2020 $2,020,878

For FY 2018, NCD’s budget supported 9 Council 

members and 11 staff (FTEs). The 11 FTEs consist of 

an Executive Director and 10 permanent staff. NCD 

was not fully staffed throughout FY2018 however two 

vacant positions were filled toward the end of the fiscal 

year (Public Affairs Specialist and Administrative 

Support Specialist. Obtaining and maintaining full time 

federal staff is critical to fulfillment of the agency’s

mission, as noted in the Major Management Priorities 

and Challenges narrative. NCD continues to need 

several additional positions. 

Due to lack of funding, our FY2019 budget request 

supports maintaining the current slate of employees 

and filling one vacancy, regularly scheduled 

performance increases per OPM policy. Benefits have 

been calculated based on our experience with the 

benefit packages employees have chosen in the past. 

Our FY2020 budget request supports 9 Council 

members and 13 staff (FTEs). The personnel total 

includes regularly scheduled performance increases 

per OPM policy and associated benefits. Benefits have 

been calculated based on our experience with the 

benefit packages employees have chosen in the past.
42 of 47

TRAVEL

FY 2018 $ 166,528

FY 2019 $ 138,100

FY 2020 $ 148,500

The largest portion of our travel budget is devoted to 

the cost of fulfilling NCD’s statutory requirement to 

conduct public meetings no less than four times each 

year. All Council members and staff are reimbursed in 

accordance with federal per diem regulations. 

In conjunction with policy development or engagement 

activities, at times, NCD convenes policy forums to 

gather or provide expert information. On these 

occasions, NCD may extend invitations to subject 

matter experts whose travel-related expenses NCD 

covers (airfare or train, lodging, per diem, and disability 

accommodations if applicable). 

NCD has conducted quarterly meetings by telephone in 

the past however due to the variety of disability 

accommodations necessary for our Council Members 

and staff to participate fully, telephone conferences are 

not an ideal medium for meeting as they have a 

practical impact on the ability of the Council Members 

to conduct its usual agenda of business, thus we limit 

the agenda for that meeting. Additionally, telephone 

conferences prohibit our ability to encourage public 

input and participation.

For FY 2018 and FY2019, NCD’s budget supported 

travel related to the cost of fulfilling NCD’s statutory 

requirement to conduct public meetings no less than 

four times each year. 

For FY 2020, NCD’s budget request supports travel 

related to the cost of fulfilling NCD’s statutory

requirement to conduct public meetings no less than 

four times each year in addition to ABLE information 

sessions, policy briefs and to continue the goal of 

increasing community input and participation, 

recognizing the need for outreach to the disability 

community to maximize the impact on the ability of the 

Council to fulfill the agency’s mission.
43 of 47

RENT, UTILITIES AND 

COMMUNICATIONS

FY 2018 $ 327,215

FY 2019 $ 315,590

FY 2020 $ 319,672

NCD currently leases office space from the General 

Services Administration. Our lease expires August 21, 

2021. Costs are attributable to the operational costs 

and real estate taxes per the occupancy agreement. 

With the majority of staff being people with disabilities,

and as the federal voice of the over 56 million 

Americans with a wide variety of disabilities, NCD 

utilizes several communication methods to facilitate the 

work of and between NCD members and staff, as well 

as to engage with stakeholders. 

For FY 2018, NCD’s budget supported office space 

and communication methods related to the cost of 

fulfilling NCD’s mission and statutory requirement to 

conduct public meetings no less than four times each 

year. 

For FY 2019, NCD’s budget request supports office 

space and communication methods related to the cost 

of fulfilling NCD’s mission and statutory requirement to 

conduct public meetings no less than four times each 

year. 

For FY 2020, NCD’s budget supports office space and 

communication methods related to the cost of fulfilling 

NCD’s mission and statutory requirement to conduct 

public meetings no less than four times each year. 

NCD has anticipated increased cost due to the need to 

update our current telephone system and the 

escalation of costs for rental space. The ability to 

remain at the current location, which is accessible for 

people with disabilities will be reviewed in 

contemplation of renewing the lease. 
44 of 47

PROGRAM, RESEARCH AND 

PRINTING

FY 2018 $ 225,050

FY 2019 $ 233,695

FY 2020 $ 201,500

To reduce costs, NCD has streamlined our report 

editing and printing processes using several 

Government Publishing Office (GPO) federal programs 

that negotiate the best prices for government 

customers. 

In recent time, NCD has begun to rely more heavily on 

the in-house expertise of its staff to produce its policy 

projects. However, this is becoming a challenge due to 

unmet staffing needs. NCD’s policy priorities are 

established by appointed Council members who 

represent the disability community. The Council 

members receive public comments and engage the 

agency’s stakeholders throughout the year and 

propose and determine projects based upon the goals 

and objectives outlined in NCD’s strategic plan. Policy 

reports, working groups, white papers and projects 

may at times enlist the support of outside individuals 

and groups who possess subject matter expertise not 

available on NCD’s staff or Council or who possess 

data sets NCD needs to produce its reports. 

For FY 2018, NCD’s budget supported policy projects 

relative to fulfilling the mission of the agency. 

For FY 2019, NCD’s budget supported policy projects 

relative to fulfilling the mission of the agency. 

For FY 2020, NCD’s budget supported policy projects 

relative to fulfilling the mission of the agency. 
45 of 47

AUDIT

FY 2018 $ 30,000

FY 2019 $ 35,000

FY 2020 $ 0

NCD solicits an outside vendor to conduct a financial 

audit of our internal operations. 

The audit reviews the Council's internal control over 

financial reporting in compliance with OMB audit 

guidance for expressing an opinion on financial 

statements in line with the agency’s annual 

Performance and Accountability Report.

For FY2020, as part of NCD’s reform plan and allowed 

per the Accountability for Tax Dollars Act requirement 

for an annual preparation and audit of financial 

statements of smaller agencies was exempted by 

OMB. NCD was granted this exemption in recognition 

of the stewardship NCD had presented through 

ongoing unqualified audits. 

PAYROLL, ACCOUNTING AND 

HR SERVICES

FY 2018 $ 122,500

FY 2019 $ 122,500

FY 2020 $ 122,500

NCD contracts with the General Services 

Administration (GSA) Commissions and Boards 

(CABS) and Office of the Chief Financial Officer 

(OCFO) for accounting, payroll and financial service

provision. Through these interagency agreements, 

NCD receives support to complete payroll, accounting, 

human resource services and legal consultation. These 

contracts facilitate smooth operations at NCD and 

assists in fulfilling federal requirements. 

For FY2019, NCD will invest in training staff and rely 

more heavily on the in-house expertise of its staff to 

fulfill these duties, which will allow the agency to avoid 

an increase in fees. 

For FY2020, NCD will continue to rely more heavily on 

the in-house expertise of its staff to fulfill these duties

to avoid an increase in fees. 
46 of 47

SUPPORT CONTRACT 

SERVICES

FY 2018 $ 166,634

FY 2019 $ 130,820

FY 2020 $ 180,500

Many of the staff and Council members are people with 

a variety of disabilities. NCD provides accommodations 

for employees with disabilities during work hours and at 

NCD meetings and events as requested. 

For FY 2018, NCD’s budget supports contractual 

services based upon the needs of the agency, staff and 

members. 

For FY 2019, NCD’s budget supports contractual 

services based upon the needs of the agency, staff and 

members.

For FY 2020, NCD’s budget supports contractual 

services based upon the needs of the agency, staff and 

members.

INFORMATION TECHNOLOGY

(IT)

FY 2018 $ 235,223

FY 2019 $ 207,736

FY 2020 $ 300,000

As a small agency, NCD secures outside support to 

assist in meeting the agency’s IT and cybersecurity 

requirements. Expenses peaked in FY2018 because of 

new federal requirements such as the EINSTEIN 

cybersecurity initiative. NCD has a part-time contractor 

assisting with these mandates. 

For FY2019, the funds reflected here are to cover 

contractor and / or staffing costs to meet the day-to-day 

IT and cybersecurity mandates. 

For FY2020, funds reflect expenses associated with 

day-to-day IT and cybersecurity requirements. This 

amount has increased due to federal requirements

requiring compliance with VOIP, MTIPS, & PIV Card 

implementation to be in compliance with IT and 

cybersecurity mandates. 
47 of 47

PAYMENTS TO FEDERAL 

AGENCIES

FY 2018 $ 22,306

FY 2019 $ 9,000

FY 2020 $ 20,950

As a micro agency, NCD secures interagency 

agreements with other federal agencies for technical 

functions such as job postings, procurements, and 

security services. Utilizing interagency agreements in 

this way assists NCD in fulfilling federal requirements 

by providing NCD with subject matter expertise not 

required on staff for agency mission fulfilment.

Costs are relative to the anticipated needs of the 

agency during each fiscal year in addition to the 

agency’s decision to utilize fee-for-service expertise. 

SUPPLIES, SUBSCRIPTIONS 

AND MATERIALS

FY 2018 $ 50,400

FY 2019 $ 68,756

FY 2020 $ 66,000

NCD utilizes professional periodicals, subscriptions, 

technical publications and services to stay informed of 

policy developments, conduct legal and other research, 

and access federal directories in furtherance of its 

mission. These resources are essential to meet the 

critical mission for NCD operations. 

As a micro agency, NCD is a good steward of federal 

funds and utilizes a very small budget for office 

supplies, furniture and general supplies each year.

Costs are relative to the anticipated needs of the 

agency during each fiscal year. 

LEGAL, OTHER FEES

FY 2018 $ 115,000

FY 2019 $ 0

FY 2020 $ 0

NCD closed a legal liability in FY2018. NCD responded 

to this challenge by developing more projects in-house.

For FY19 and FY20, NCD does not anticipate any legal 

fees. 

ANTI-DEFICIENY 

FY 2018 $ 32,500

FY 2019 $ 32,250

FY 2020 $ 34,500

NCD reserves a percentage of our annual appropriated 

budget for unanticipated expenses and to ensure the 

agency does not exceed available funds.