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Rehabilitation Services Administration

Rehabilitation Services Administration. New FY 2015 Grant Award Notification Attachments Pre-Employment Transition Services, Supported Employment, & Maintenance of Effort. FY 2015 GAN Attachments. Presenters Janet LaBreck, RSA Commissioner David Steele, Fiscal Unit Chief

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Rehabilitation Services Administration

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  1. Rehabilitation Services Administration New FY 2015 Grant Award Notification Attachments Pre-Employment Transition Services, Supported Employment, & Maintenance of Effort

  2. FY 2015 GAN Attachments Presenters • Janet LaBreck, RSA Commissioner • David Steele, Fiscal Unit Chief • Julya Doyle, Financial Management Specialist 2

  3. Webinar Core Topics VR Pre-Employment Transition Services • Reserve Requirement • Administrative Costs • Reporting Requirements Supported Employment • Reserve Requirement • Matching Requirement • Administrative Costs • Reporting Requirements VR Maintenance of Effort • Assessment of Penalties Additional Updates 3

  4. GAN Attachments • GAN Attachments and Enclosures are documents used by the Department to convey legally binding grant terms and conditions associated with a grant award. 4

  5. VR Pre-employment Transition Services Background • Section 110 of the Rehabilitation Act of 1973 (Rehabilitation Act) was amended by the Workforce Innovation and Opportunity Act (WIOA) and took effect on July 22, 2014. • Section 113, pre-employment transition services (PETS), was added. 5

  6. VR Pre-employment Transition Services Reserve Requirement • Section 110(d) states, “from any State allotment under subsection (a) for a fiscal year, the State shall reserve not less than 15 percent of the allotted funds for the provision of pre-employment transition services.” • The mandate to reserve VR funds for the sole purpose of providing pre-employment transition services is also included at section 113(a). 6

  7. VR Pre-employment Transition Services Reserve Requirement (continued) Each agency must reserve at least 15 percent of its Federal VR allotment for the provision of pre-employment transition services under section 113. • The State is required to reserve the funds from its total 110 VR grant award amount. • Agencies will not receive a separate grant award for the 15 percent. 7

  8. VR Pre-employment Transition Services Reserve Requirement (continued) Agencies must base the percentage on the total amount in each GAN it receives during the period of the award. This includes: • Continuing resolutions, reallotment, relinquishment, Maintenance of Effort penalties and any other adjustments to the grant award amount that result in a revised GAN. 8

  9. VR Pre-employment Transition Services Implementation Considerations • RSA has no authority to exempt VR agencies from meeting the PETS reserve requirement. • The funds reserved in accordance with section 110(d) may NOT be used to pay for administrative costs or other VR services. • For States with Blind and General VR agencies, satisfying the PETS reserve requirement is based on the sum of each agency’s VR award amount. This is similar to the current match and maintenance of effort requirements. 9

  10. VR Pre-employment Transition Services Implementation Considerations (continued) • The 15 percent reserve requirement does not apply to the non-Federal share. • The non-Federal share used to match the 15 percent reserve for PETS is not restricted to non-Federal expenditures for the provision of PETS. • Each VR agency is responsible for accurately tracking and reporting the amount of Federal funds expended for the provision of PETS. 10

  11. VR Pre-employment Transition Services Reserve Requirement (continued) Example 1: • A VR agency receives a VR GAN for $100,000 in October. The agency must reserve $15,000 of that amount to be expended ONLY for the provision of PETS. • The VR agency receives a supplement of $1,000,000 in December. An additional 15 percent of the supplement amount ($150,000) must also be reserved. • The VR agency MAY NOT use the reserved PETS funds from the initial award ($15,ooo) for non-PETS expenditures and then reserve a higher percentage from the supplement to offset the initial reserved funds not used for PETS. 11

  12. VR Pre-employment Transition Services Reserve Requirement (continued) Example 2: • A VR agency receives a VR GAN for $1,000,000 in October. The agency must reserve $150,000 to be spent for the provision of PETS. The VR agency later relinquishes $500,000 through the reallotment process and receives a revised GAN showing an adjusted award amount of $500,000. • The VR agency’s new base for the 15 percent is $500,000. • The VR agency must reserve $75,000 for PETS, not the full $150,000 per the initial grant award amount. 12

  13. VR Pre-employment Transition Services Reserve Requirement (continued) Example 3: • A VR agency receives a VR GAN for $1,000,000 in October. The VR agency reserves $150,000 for the provision of PETS. • At the end of the award period, the VR agency was only able to match and expend $900,000 in Federal funds. • Of the $900,000 in Federal funds expended, $150,000 must have been reserved and expended for PETS. 13

  14. VR Pre-employment Transition Services Administrative Costs • Administrative costs are expenditures incurred in the performance of administrative functions under the VR program. • Administrative costs include expenses related to program planning, development, monitoring and evaluation. Including (but not limited to) quality assurance, budgeting, accounting and financial management, technical assistance and support to other State agencies or CRPs, operating and maintaining State facilities and equipment, supplies, administration of the CSPD, administrative salaries, travel costs related to carrying out the program, etc. (§361.5(b)(2)) 14

  15. VR Pre-employment Transition Services Administrative Costs (continued) The funds reserved for the provision of PETS may not include -- • administrative costs that are not otherwise allowable under Section 113(c); • administrative costs associated with a CRP if the contract includes itemized budgets; • administrative costs associated with a VR agency counselor/employee; and • any other costs not directly associated with the provision of PETS. 15

  16. VR Pre-employment Transition Services Administrative Costs (continued) • For VR counselors providing PETS, the actual time spent directly providing services to individuals served by PETS would be an allowable cost. This includes the VR counselor’s salary and fringe costs allocated in proportion to the time worked on PETS. However, associated costs such as supervision, space, utilities, training, etc., are administrative costs and may not be counted toward the 15 percent reserve requirement. 16

  17. VR Pre-employment Transition Services Administrative Costs (continued) CRP Contracts with Itemized Budgets • In determining the amount of Federal funds contributing to PETS, administrative costs in contracts with line item budgets must be excluded. For example, costs associated with telephones, utilities, space, indirect costs, etc., do not count toward the PETS reserve requirement. 17

  18. VR Pre-employment Transition Services Administrative Costs (continued) Fee-for-Service CRP Contracts • Contracts with CRPs that utilize a fee-for-service rate for the provision of PETS do not need to be disaggregated to determine the amount of administrative costs included in the fee. 18

  19. VR Pre-employment Transition Services Administrative Costs (continued) • Section 113(c) describes other authorized activities that the State may provide after the provision of the activities required under Section 113(b) and if funds are still available. • Some of the services under 113(c) would generally be considered administrative costs (e.g., providing instruction to counselors, disseminating information about innovative practices for PETS, etc.). The direct costs associated with these activities are allowable PETS. However, the administrative costs (e.g., indirect costs, e.g.) are not. 19

  20. VR Pre-employment Transition Services SF-425 Reporting Requirements • Line 10e – Report all Federal VR expenditures, including Federal expenditures for the provision of PETS. • An additional reporting item will be added to Line 12 to capture the amount of Federal VR expenditures reported on line 10e that were for the provision of PETS. This is how RSA will ensure the agency meets the reserve requirement. 20

  21. VR Pre-employment Transition Services SF-425 Reporting Requirements (continued) • The PETS amount reported on Line 12 will not include unliquidated obligations. • Since the PETS requirement is a State requirement, VR agencies will report the total PETS Federal expenditures and not just the minimum amount (15 percent). 21

  22. Supported Employment Background • WIOA also made changes to the Supported Employment program(Title VI of the Rehabilitation Act of 1973 as amended by WIOA). 22

  23. Supported Employment Section 603 - Reserve Requirement • VR agencies must reserve and expend 50 percent of their SE award to provide SE services to eligible youth with the most significant disabilities in order to assist them in achieving an employment outcome of supported employment. • VR agencies must reserve and expend 50 percent of each GAN for this purpose. • States will not receive a separate grant award for this 50 percent reserve. 23

  24. Supported Employment Section 604 – Reserve Requirement (continued) • In addition to SE services, VR agencies may use the funds reserved for youth with the most significant disabilities to provide extended services for up to 4 years. VR funds may also be used to provide extended services to youth with the most significant disabilities for up to 4 years. • VR agencies are still prohibited from using SE funds to provide extended services to adults with the most significant disabilities. 24

  25. Supported Employment Section 606 - Matching Requirement • The VR agency must provide non-Federal contributions in an amount that is not less than 10 percent of the costs of carrying out supported employment services to youth with the most significant disabilities. • The matching requirement applies only to the 50 percent reserved for services to youth with the most significant disabilities. 25

  26. Supported Employment Matching Requirement (continued) • The VR agency may use non-Federal expenditures for allowable SE purposes paid directly by the designated State agency. • Third-party in-kind contributions are NOT an allowable source of match under the SE program. • The agency must be able to match any Federal funds expended. (§80.24) 26

  27. Supported Employment Matching Requirement – Example • A VR agency receives $2,000,000 for its SE award. $1,000,000 must be reserved for the provision of SE services to youth with the most significant disabilities. • For every $90 of SE Federal funds drawn down to pay for SE expenditures incurred by serving youth with the most significant disabilities, the VR agency would provide a match of $10 in non-Federal funds. • Assuming the VR agency draws down the entire $1 million reserved for this purpose, the agency would have to provide a match of $111,111 in non-Federal expenditures. 27

  28. Supported Employment Section 603(c) – Administrative Costs • Administrative costs are expenditures incurred in the performance of administrative functions under the SE program. • VR agencies may not use more than 2.5 percent of their SE award to pay for administrative costs. (This amount was reduced from 5 percent.) 28

  29. Supported Employment Administrative Costs (continued) CRP Contracts with Itemized Budgets • In determining the amount of Federal funds contributed to meeting the SE reserve requirement, administrative costs over 2.5 percent in contracts with line item budgets must be excluded. For example, costs associated with telephones, utilities, space, indirect costs, etc., do not count toward the SE services to youth with most significant disabilities reserve requirement. 29

  30. Supported Employment Administrative Costs (continued) Fee-for-Service CRP Contracts • Contracts with CRPs that utilize a fee-for-service rate for the provision of SE services to youth with the most significant disabilities do not need to be disaggregated to determine the amount of administrative costs included in the fee. 30

  31. Supported Employment Implementation Considerations • RSA has no authority to exempt VR agencies from meeting the SE reserve requirement. • The funds reserved may NOT be used to pay for administrative costs above 2.5 percent or SE services to adults. • For States with Blind and General VR agencies, satisfying the SE reserve requirement is based on the sum of each agency’s SE award amount. This is similar to the current match and maintenance of effort requirements. 31

  32. Supported Employment Implementation Considerations (continued) • Each VR agency is responsible for accurately tracking and reporting on the provision of supported employment to youth with the most significant disabilities and accounting for the expenditure of funds. 32

  33. Supported Employment SF-425 Reporting Requirements • Line 10e – Report all Federal SE expenditures including Federal expenditures for the provision of SE to youth with the most significant disabilities. • An additional reporting item will be added to Line 12 to capture the amount of Federal SE expenditures reported on line 10e that were for the provision of services to youth with the most significant disabilities. 33

  34. Supported Employment SF-425 Reporting Requirements (continued) • The VR agency will report on line 10j the non-Federal share of expenditures for youth with the most significant disabilities. (This is the SE match requirement.) • As the matching requirement is a State requirement, VR agencies should report the total amount of non-Federal SE expenditures for youth with the most significant disabilities. 34

  35. VR Maintenance of Effort Maintenance of Effort (MOE) • WIOA made changes to the MOE requirement in section 111(a)(2)(B) of the Rehabilitation Act of 1973. 35

  36. VR Maintenance of Effort Section 111 - Payments to States • The revised section 111 (a)(2)(B) states -- The amount otherwise payable to a State for a fiscal year under this section shall be reduced by the amount by which expenditures from non-Federal sources under the State plan under this title for any previous fiscal year are less than the total of such expenditures for the second fiscal year preceding that previous fiscal year. 36

  37. VR Maintenance of Effort Section 111 – Payments to States (continued) • The Secretary is now permitted to reduce a grant in a fiscal year for any prior fiscal year’s MOE shortfall. • Previous statute required the Secretary to reduce the grant in the fiscal year immediately following the fiscal year with the MOE deficit. 37

  38. VR Maintenance of Effort Section 111 – Payment to States (continued) • Under the new requirements, if a MOE shortfall is revealed after the next fiscal year’s grant is awarded, the Secretary will reduce the grant in another subsequent fiscal year. • Under previous statute, if the MOE deficit was discovered after the next fiscal year’s grant was awarded, the Secretary was required to seek a remedy via a disallowance. In such instances, the State would have been required to make payment for that recovery with non-Federal funds that were not allowable as match for the VR program. 38

  39. Additional Updates Additional Updates • To prevent a disruption in the operation of the transfer of the Independent Living Services, Centers for Independent Living, and Protection and Advocacy for Assistive Technology programs, the Department of Education will continue to administer the funds for these programs for such period of time as may reasonably be needed to facilitate the orderly implementation of the transfer of these programs. 39

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