Transcript TARGET Discovery Series: Discover How the Department of

State Plan for FY 20092011 and
Program Review of
Statewide AT Programs
Jeremy Buzzell
and
Robert Groenendaal
PART 2
Overview of State Plan for AT
A.
B.
C.
D.
E.
F.
G.
H.
Identification and Description of Lead Agency and
Implementing Entity; Change in Lead Agency or
Implementing Entity
Advisory Council, Budget Allocations, and Identification
of Activities Conducted
State Financing Activities
Device Reutilization Activities
Device Loan Activity
Device Demonstration Activity
State Leadership Activities
Assurances, Performance Measures, Signatures
3
Overview of Program Review
A review assesses two “Core
Components” of how the state plan is
implemented:
Core Component 1 – Program
Management
• Core Component 2 – Program
Performance
4
Core Components of Program
Review
Elements of Program
Management
• Fiscal Management
• Personnel Management
• Contract Oversight
• Consumerresponsiveness
Elements of Program
Performance
• Increasing access to,
acquisition of, and
knowledge about AT
• Statewideness and
comprehensiveness
• Measurable goals
5
Lead Agency and Implementing
Entity
Information Required in State Plan
Selection and Participation in
Program Review
State Plan: Identification and
Description of Lead Agency
1.
2.
3.
4.
5.
6.
7.
8.
Name Given to Statewide AT Program. [Text box]
Website dedicated to Statewide AT Program. [Text box]
Name and Address of Lead Agency. [Text box]
Name, Title, and Contact Information for Lead Agency
Certifying Representative. [Text box]
Information about Program Director at Lead Agency.
[Text box]
Information about Program Contact(s) at Lead Agency.
[Text box]
Telephone at Lead Agency for Public. [Text box]
E-mail at Lead Agency for Public. [Text box]
7
State Plan: Identification and
Description of Lead Agency
9. Select the most appropriate descriptor of the
agency/division/bureau directly responsible for the
Statewide AT Program within the Lead Agency.
[Drop-down menu]
 General Vocational Rehabilitation Agency
 Vocational Rehabilitation for the Blind Agency
 State Education Agency
 University
 Health and Human Services Agency
 Aging and Disability (or similar) Agency
 Other
8
State Plan: Identification and
Description of Lead Agency
10. If “Other” was selected for question 9, identify
and describe the agency. [Text box]
11. Does your Lead Agency contract with an
Implementing Entity to carry out the Statewide AT
Program on it’s behalf? [yes/no drop-down menu]
If you answered “no” to question 11, you may skip
ahead to the items on change in Lead Agency or
Implementing Entity. Otherwise, you must answer
the following questions.
9
State Plan: Identification and
Description of Implementing Entity
12. Name and Address of Implementing Entity. [Text
box]
13. Information about Program Director at the
Implementing Entity. [Text box]
14. Information about Program Contact(s) at
Implementing Entity. [Text box]
15. Telephone at Implementing Entity for Public.
[Text box]
16. E-mail at Implementing Entity for Public. [Text
box]
10
State Plan: Identification and
Description of Implementing Entity
17. Select the most appropriate descriptor of the type of organization that is the Implementing Entity.
[Drop-down menu]
 AgrAbility Program
 Alliance for Technology Access Center
 Bank or other financial institution
 Easter Seals
 Independent Living Center
 Institution of Higher Education
 Non-categorical disability organization
 Organization that primarily serves individuals who are blind or visually impaired
 Organization that primarily serves individuals who are deaf or hard of hearing
 Organization that primarily serves individuals with developmental disabilities
 Organization that primarily serves individuals with physical disabilities
 Organization focused specifically on providing AT
 Protection and Advocacy organization
 UCP
 Other
11
State Plan: Identification and
Description of Implementing Entity
If applicable, the national affiliation of an entity
should be selected before other descriptors. These
include:
 AgrAbility Program
 Alliance for Technology Access Center

Easter Seals

Independent Living Center

Protection and Advocacy organization

UCP
12
State Plan: Identification and
Description of Implementing Entity
If a private entity has no national affiliation, use the following
more general descriptors.
 Bank or other financial institution

Non-categorical disability organization

Organization that primarily serves individuals…

Organization focused specifically on providing AT
 Other
18. If “Other” was selected, identify and describe the entity.
[Text box]
13
State Plan: Implementing Entity and
Lead Agency
19. Describe the mechanisms established to ensure
coordination of activities and collaboration between the
Implementing Entity and the state. [Text box]
Identify the mechanism used and how the Lead Agency
provides oversight and holds the Implementing Entity
accountable.
14
State Plan: Change in Lead Agency or
Implementing Entity
Is the Lead Agency [Implementing Entity] named in this State
Plan a new or different Lead Agency from the one designated
by the Governor in your previous State Plan? [yes/no dropdown menu]
The “previous State Plan” was from October 1, 2005 until the
submission of this State Plan.
If a change in Lead Agency [Implementing Entity] already
has been approved by RSA the state can select “no.”
If you select “yes,” the information provided throughout this
State Plan should pertain to the new Lead Agency
[Implementing Entity].
15
State Plan: Change in Lead Agency or
Implementing Entity
Explain why the Lead Agency [Implementing Entity]
previously designated by your state should not serve
as the Lead Agency. [Text box]
Explain why the Lead Agency [Implementing Entity]
newly designated by your state should serve as the
Lead Agency. [Text box]
16
Role of Lead Agencies and
Implementing Entities in Program
Reviews
•
•
The LEAD AGENCY is being
reviewed.
Participation from BOTH the Lead
Agency and Implementing Entity is
expected.
17
How are Lead Agencies selected for
review?
Random selection of an equal number of
grantees in two categories:
(1) Grantees that have a title III AFP, serve as
the Lead Agency for the AFP, and claim the
AFP in State Plan; or
(2) Grantees that don’t meet the criteria in (1).
18
How are Lead Agencies selected for
review?
Exceptions to random selection:
• Recent (major) change in State Plan
(ex: Change in Lead Agency or
Implementing Entity).
• Recent major disaster.
• RSA is concerned.
19
How many Lead Agencies are
selected for review?
6 grantees per cycle (3 x 3)
• A “cycle” is a fiscal year (Oct. 1 to Sept. 30)
• 9 weeks per grantee (some reviews may
overlap)
• First year of reviews:
• Jan. 1 to Sept. 30
• Only 3 reviews
•
20
What happens when a Lead Agency is
selected?
RSA notifies grantee in spring prior to
next cycle.
• RSA and grantee negotiate 9-week
window within next cycle.
• RSA recruits third-party (peer)
reviewers.
• Grantee begins preparing for review.
•
21
Core Components of Program
Review
Elements of Program
Management
• Fiscal Management
• Personnel Management
• Contract Oversight
• Consumerresponsiveness
Elements of Program
Performance
• Increasing access to,
acquisition of, and
knowledge about AT
• Statewideness and
comprehensiveness
• Measurable goals
22
Personnel
Identification in State Plan
Participation in Program Review
Review of Personnel Management
State Plan: Identification and Description of Lead
Agency and Implementing Entity Personnel
Name, Title, and Contact Information for Lead
Agency Certifying Representative. [Text box]
Information about Program Director at Lead Agency
[Implementing Entity]. [Text box]
Information about Program Contact(s) at Lead
Agency [Implementing Entity]. [Text box]
24
Program Review: Personnel
Participation
•
•
Participation of all personnel listed in the
State Plan is required to some degree (see
exception in next bullet).
Participation of the Certifying
Representative is encouraged but not
required.
25
Program Review: Personnel
Management
OMB Circulars:
•
•
•
•
compensation to personnel must be reasonable
charges to Federal awards for salaries and wages are based
on documented payrolls
charges for salaries and wages of employees who work
solely on a single Federal award are supported by periodic
certifications
charges for salaries and wages of employees who work on
multiple activities are supported by personnel activity
reports
26
Program Review: Personnel
Management
Submit either:
(A) Position descriptions of record for those
being paid with grant funds and personnel
activity reports for them; OR
(B) Synopsis for key personnel describing his
or her role and responsibilities associated
with the grant.
27
Program Review: Personnel
Management
What RSA is looking for:
• Appropriate number of personnel
• Appropriate time commitments of
personnel
• Appropriate duties for personnel
28
Role of Consumers in Statewide
AT Program
State Plan Requirements related to
Advisory Council
Review of Consumer-responsiveness
AT Act: Consumer-responsiveness
Comprehensive statewide program means: a
consumer responsive program of technologyrelated assistance for individuals with disabilities,
implemented by a State, and equally available to
all individuals with disabilities residing in the
State, regardless of their type of disability, age,
income level, or location of residence in the State,
or the type of assistive technology device or
assistive technology service required. Sec. 3
30
AT Act: Consumer-responsiveness
AT Act definition:
• easily accessible to, and usable by
consumers
• involves consumers in decisions related to
the maintenance, improvement, and
evaluation of the program
• responds to the needs of consumers in an
appropriate manner
31
AT Act: Consumer-responsiveness
State plan requirements:
• Advisory council
• Assurance of ADA compliance
• Assurance of 508 compliance
32
AT Act: Advisory Council
Requirements related to composition
• Agency representatives
• Consumer representatives (diversity and majority)
Requirements related to role
“advice to the State for, planning of, implementation
of, and evaluation of the activities carried out through
the grant, including setting the measurable goals”
33
State Plan: Advisory Council
1. In accordance with section 4(c)(2) of the AT Act of 1998,
as amended our state has a consumer-majority advisory
council that provides consumer-responsive, consumerdriven advice to the state for planning of, implementation
of, and evaluation of the activities carried out through the
grant, including setting measurable goals. This advisory
council is geographically representative of the State and
reflects the diversity of the State with respect to race,
ethnicity, types of disabilities across the age span, and
users of types of services that an individual with a
disability may receive. [yes/no drop-down menu]
34
State Plan: Advisory Council
2. The advisory council includes a representative of the designated State agency,
as defined in section 7 of the Rehabilitation Act of 1973 (29 U.S.C. 705);
[Drop-down menu]
3. The advisory council includes a representative of the State agency for
individuals who are blind (within the meaning of section 101 of that Act (29
U.S.C. 721)); [Drop-down menu]
4. The advisory council includes a representative of a State center for independent
living described in part C of title VII of the Rehabilitation Act of 1973 (29
U.S.C. 796f et seq.); [Drop-down menu]
5. The advisory council includes a representative of the State workforce
investment board established under section 111 of the Workforce
Investment Act of 1998 (29 U.S.C. 2821); [Drop-down menu]
6. The advisory council includes a representative of the State educational agency,
as defined in section 9101 of the Elementary and Secondary Education Act
of 1965; [Drop-down menu]
35
State Plan: Advisory Council
7. The advisory council includes other
representatives (list below). [Text box]
8. The advisory council includes the following
number of individuals with disabilities that use
assistive technology or their family members or
guardians: [Number field]
9. If the Statewide AT Program does not have the
composition and representation required under
section 4(c)(2)(B), explain here. [Text box]
36
Program Review: Role of Advisory
Council/Consumers
•
•
•
No role for consumers not affiliated
with the advisory council.
Participation by the advisory council is
encouraged but not required.
Dissemination of final results to
advisory council is expected.
37
Program Review: Consumerresponsiveness
Submit to RSA:
• A description of advisory council:
• List all members
• Describe members (not personally
identifiable)
• Describe council operations
• Description of any other consumer feedback
mechanisms
38
Program Review: Consumerresponsiveness
Submit to RSA:
• A description of how the grantee
ensures compliance with ADA
(including subcontracts, if applicable)
• A description of how the grantee
ensures compliance with 508
(including subcontracts)
39
Program Review: Consumerresponsiveness
What RSA is looking for:
• Completeness of council
• Role of council
• How grantee ensures ongoing 508 and
ADA compliance
40
Use of Funds
Funding Information in State Plan
Review of Fiscal Management
Use of Funds
Requirements in AT Act:
• 60/40%, 70/30%, 5%
• 10% indirect limitation
• Can’t use to purchase AT for individuals
• State plan assurance that the funds are expended in accordance
with AT Act
• State plan description of planned tracking procedures for
expenditures
• State Plan assurance you have fiscal control and accounting
procedures necessary to ensure proper accounting of funds
• Proposed budget allocations in State Plan
42
State Plan: Proposed Budget Allocations
State Financing Activities [Drop-down menu]
Device Reutilization Activities [Drop-down menu]
Device Loan Activity [Drop-down menu]
Device Demonstration Activity [Drop-down menu]
State Leadership Activities [Drop-down menu]







Claiming Comparability
Claiming Flexibility
$1 to $10,000
$10,001 to $20,000
$20,001 to $30,000 …
$90,001 to $100,000
More than $100,000
43
State Plan: Proposed Budget Allocations
For every activity for which you selected
“claiming comparability,” describe the
comparable activity: [text box]
44
State Plan: Tracking Use of Funds
Describe your planned procedures for tracking
expenditures for State-level and State
Leadership Activities: [Text box]
45
Program Review: Fiscal
Management
In addition to State Plan requirements . . .
EDGAR requirements:
• Fiscal control and accounting procedures to insure proper
disbursement of and accounting for Federal funds and adequate
to establish that such funds have not been used in violation of
applicable statutes
• Records that fully show the amount of funds under the grant,
how the grantee uses the funds, the total cost of the project, the
share of the cost provided by other sources, and other records to
facilitate an effective audit
• Audits in accordance with OMB A-133.
46
Program Review: Fiscal
Management
Submit to RSA:
• Expenditure report
• Approved indirect cost rate agreement/cost allocation plan
OR questionnaire provided by RSA (applies to both Lead
Agencies and Implementing Entities)
• Copies of most recent audit reports OR questionnaire
provided by RSA (applies to both Lead Agencies and
Implementing Entities)
In addition, RSA will look at SF-269s and GAPS records.
47
Program Review: Expenditure Report
1 for Lead Agency, 1 for Implementing Entity
• Most recent annual award for which obligation and
liquidation is complete.
• Annual award = may have been spent over 2 years.
• There is no “format,” but RSA must be able to
understand it.
• It must account for all funds – including those
brought into the program from other sources.
•
48
Expenditure Report
What RSA is looking for:
• Existence, quality, legitimacy of
report
• Tracking of 60/40 or 70/30 and 5%
• Compliance with indirect cost
limits
49
Program Review: Indirect Cost
Rates
What RSA is looking for:
• Existence of agreement
• Appropriate kind of agreement
• Handling of indirect if Implementing Entity
is involved
• Amount of indirect will be seen in
expenditure report
50
Program Review: Audits
What RSA is looking for:
• An audit was done (if required)
• Findings of the audit
• Resolution of findings
51
SF-269s and GAPS Records
What RSA is looking for:
• Full use of funds
• Timely use of funds
• Completeness and accuracy of
financial reports
52
Involvement of Other Entities
State Plan requirements related to
involvement of other entities
Program Review of Contract
Oversight
AT Act Requirements Related to
Other Entities
State plan must describe how public and
private entities were involved in developing
the State Plan and will be involved in
implementation (including resources)
• State plan must describe state support
• State leadership activities include
coordination and collaboration
• Data collection related to leveraged funds
•
54
State Plan: Identifying Involvement of
Other Entities
For each activity:
Who conducts this activity? (Check all that apply)
 The Statewide AT Program [check-box to indicate
“yes”]
 Other entities (e.g., contractors) [check-box to
indicate “yes”]
55
State Plan: Identifying Involvement of
Other Entities
•
•
•
•
•
•
•
The Statewide AT Program provides and/or receives the following
support (choose all that apply):
Provides financial support to other entities via an agreement with the
Statewide AT Program. [check-box to indicate “yes”]
Provides in-kind support to other entities via an agreement with the
Statewide AT Program. [check-box to indicate “yes”]
Receives financial support from the state. [check-box to indicate
“yes”]
Receives in-kind support from the state. [check-box to indicate “yes”]
Receives financial support from private entities. [check-box to indicate
“yes”]
Receives in-kind support from private entities. [check-box to indicate
“yes”]
56
State Plan: Identifying Involvement of
Other Entities
•
The Statewide AT Program provides and/or receives the following
support (choose all that apply): CONT’D
•
Coordinates and collaborates with other entities for the purpose of
establishing a new program or service. [check-box to indicate “yes”]
Coordinates and collaborates with other entities for the purpose of
expanding an existing program or service. [check-box to indicate
“yes”]
Coordinates and collaborates with other entities for the purpose of
reducing duplication of programs or services. [check-box to indicate
“yes”]
•
•
57
State Plan: Identifying Involvement of
Other Entities
If you conduct this activity by providing financial or in-kind
support to other entities, identify the kinds of entities you
support in column (a) of the following table.
If you receive financial or in-kind support from the state to
conduct this activity, identify the state entities that provide
this support in column (b) of the following table.
If you receive financial or in-kind support from private
entities, identify the private entities that provide this support
in column (c) of the following table.
If you coordinate and collaborate with other entities in
conducting this activity, identify those entities in column (d)
of the following table.
58
59
State Plan: Identifying Involvement of
Other Entities
Other information related to
coordination and collaboration and
leveraging of funds is captured under
data collection.
60
Program Review: Contract Oversight
EDGAR requires grantees to:
• directly administer or supervise the administration
of each project
• have procedures for providing TA, evaluation and
for performing other administrative
responsibilities necessary to ensure compliance
• monitor activities to assure compliance with
applicable Federal requirements and that
performance goals are being achieved
61
Program Review: Contract Oversight
Submit either:
(A) The state’s contract selection policies and a
sample of contracts (selected by RSA after reviewing
State Plan – Implementing Entity always is in
sample); OR
(B) A synopsis of major contracts.
This is contracts FROM and contracts TO the
grantee – but only those claimed in State Plan and
used for reporting data
62
Program Review: Contract Oversight
Synopsis of major subcontracts (to and from)
includes:
• Amount of funds
• Kind of entity and qualifications
• Method for choosing entity
• Duties carried out by entity
• Any limitations
• Methods of oversight
• Methods for collecting and reporting data
63
Program Review: Contract Oversight
What RSA is looking for:
• Appropriate process for awarding
• Appropriate entities receiving awards
• Appropriate oversight to protect Federal
interests and ensure implementation
• Relevant to the AT Act
64
Process for Reviewing Program
Management
•
•
•
•
Submit all the previously described documents.
RSA reviews the documents.
RSA discusses the documents via conference call
(the grantee is responsible for bringing together
the appropriate parties)
RSA uses this information to answer questions
about program management.
• Yes/no with explanation.
65
Questions about Program Management
1. Does the grantee account for its funds accurately and completely in
accordance with EDGAR and the AT Act?
2. Does the grantee use its funds within the limitations of the AT Act?
3. Does the grantee obligate and liquidate its funds in a timely manner? If
not, does the grantee have a plan for improving the timeliness of
obligations and liquidations?
4. Does the grantee maximize the use of its funds (i.e., does not return
funds to the Department)? If not, does the grantee have a plan for
increasing the amount of funds it uses?
5. Does the grantee comply with indirect cost requirements?
6. Does the grantee comply with audit requirements?
66
Questions about Program Management
7. Does the grantee select subcontractors in accordance with
generally accepted practice? If not, does the grantee have a
plan for improving its selection process?
8. Does the grantee exercise appropriate fiscal and
performance oversight of its subcontracts? If not, does the
grantee have a plan for improving its oversight?
9. Is the inclusion of subcontracts received by the grantee in
the grantee’s State Plan and annual data justified?
67
Questions about Program Management
10. Does the grantee distribute the time of its
personnel appropriately based on their
responsibilities? If not, does the grantee have a
plan to distribute time more appropriately?
11. Does the grantee support with grant funds only
personnel with responsibilities germane to the
grant?
68
Questions about Program Management
12. Does the grantee have processes and procedures to ensure
ongoing physical and programmatic accessibility? If not, does
the grantee have a plan for improving its physical and
programmatic accessibility?
13. Does the grantee have and use an advisory council that meets
the requirements of the AT Act and is involved in the Statewide
AT Program as the AT Act intends? If not, does the grantee have
a plan for improving its advisory council?
14. Is there evidence of other efforts at making the program more
consumer-responsive?
69
Assessing Compliance of Program
Management
There is no overall rating of compliance.
For each element of Program Management, a
grantee will receive 1 of 3 ratings:
Compliant
• In Need of Improvement
• Fails to substantially comply
•
70
Assessing Compliance of Program
Management
The rating is based on how RSA answers the
questions:
Initial question: Does the grantee maximize
the use of its funds?
• Subquestion: If not, does the grantee have a
plan for increasing the amount of funds it
uses?
•
71
Assessing Compliance of Program
Management
•
•
•
•
If the answer to the initial question is “Yes” – the
grantee is rated as compliant.
If the answer to the initial question is “No” – the
rating depends on the answer to the subquestion.
If the answer to the subquestion is “Yes” – the
grantee is rated as in need of improvement.
If the answer to the subquestion is “No” – the
grantee is rated as failing to substantially comply.
72
Assessing Compliance of Program
Management
Questions for which “needs improvement” doesn’t apply:
Does the grantee account for its funds accurately and completely?
Does the grantee use its funds within the limitations of the AT Act?
Does the grantee comply with indirect cost requirements?
Does the grantee comply with audit requirements?
Does the grantee support with grant funds only personnel with responsibilities
germane to the grant?
Is the inclusion of subcontracts received by the grantee in the grantee’s State
Plan and NISAT data justified?
Is there evidence of other efforts at making the program more consumerresponsive? . . . is not rated at all
73
Assessing Compliance of Program
Management
The onus is on the grantee to present
evidence/plan sufficient to get to a “yes”
answer.
RSA will ask questions or provide examples of
sufficient evidence if needed.
• Grantee likely will know their status before the
conversation is over.
•
74