Fiscal Year 2012 Monitoring Report on the Wyoming Division of ...

Fiscal Year 2012
Monitoring Report

on the

Wyoming Division of
Vocational Rehabilitation

Vocational Rehabilitation Program


U.S. Department of Education

Office of Special Education and
Rehabilitative Services

Rehabilitation Services Administration

April 10, 2012
Table of Contents

Page

Section 1: Executive Summary 1

Section 2: Performance Analysis 4

Section 3: Emerging Practices 10

Section 4: Results of Prior Monitoring Activities 12

Section 5: Focus Areas 16

A. Organizational Structure Requirements of the Designated
State Agency and Designated State Unit 16

B. Transition Services and Employment Outcomes for
Youth with Disabilities 19

C. Fiscal Integrity of the Vocational Rehabilitation Program
23

Section 6: Compliance Findings and Corrective Actions 25

Appendix A: Agency Response 37

Appendix B: Legal Requirements 41


Section 1: Executive Summary


Background


Section 107 of the Rehabilitation Act of 1973, as amended (Rehabilitation
Act), requires the Commissioner of the Rehabilitation Services
Administration (RSA) to conduct annual reviews and periodic on-site
monitoring of programs authorized under Title I of the Rehabilitation Act
to determine whether a state vocational rehabilitation (VR) agency is
complying substantially with the provisions of its State Plan under section
101 of the Rehabilitation Act and with the evaluation standards and
performance indicators established under Section 106. In addition, the
commissioner must assess the degree to which VR agencies are complying with
the assurances made in the State Plan Supplement for Supported Employment
(SE) Services under Title VI, part B, of the Rehabilitation Act.

Through its monitoring of the VR and SE programs administered by the
Wyoming Division of Vocational Rehabilitation (DVR) in federal fiscal year
(FY) 2012, RSA:

. reviewed the VR agency's progress toward implementing recommendations
and resolving findings identified during the prior monitoring cycle
(FY 2007 through FY 2010);
. reviewed the VR agency's performance in assisting eligible individuals
with disabilities to achieve high-quality employment outcomes;
. recommended strategies to improve performance and required corrective
actions in response to compliance findings related to three focus
areas, including:
o organizational structure requirements of the designated state
agency (DSA) and the designated state unit (DSU);
o transition services and employment outcomes for youth with
disabilities; and
o the fiscal integrity of the VR program;
. identified emerging practices related to the three focus areas and
other aspects of the VR agency's operations; and
. provided technical assistance to the VR agency to enable it to enhance
its performance and to resolve findings of noncompliance.

The nature and scope of this review and the process by which RSA carried
out its monitoring activities, including the conduct of an on-site visit
from December 5 through 9, 2011, is described in detail in the FY 2012
Monitoring and Technical Assistance Guide for the Vocational Rehabilitation
Program located at: http://www.ed.gov/rschstat/eval/rehab/107-
reports/2011/monitoring-and-technical-assistance-guide.doc or,
www.ed.gov/rschstat/eval/rehab/107-reports/2011/monitoring-and-technical-
assistance-guide.pdf


Emerging Practices


Through the course of its review, RSA collaborated with DVR, the State
Rehabilitation Council (SRC), the Technical Assistance and Continuing
Education (TACE) center and other stakeholders to identify the emerging
practice below implemented by the agency to improve the performance and
administration of the VR program.


Transition


. Transition counselors in DVR utilize Google Groups to provide the
opportunity to come together online, in one place to communicate,
brainstorm ideas, collaborate and post information that will be useful
to all transition counselors.

A more complete description of this practice can be found in Section 3 of
this report.


Summary of Observations


RSA's review of DVR resulted in the observation related to the focus area
identified below. The entire observation and the recommendations made by
RSA that the agency can undertake to improve its performance are contained
in Section 5 of this report.


Transition Services and Employment Outcomes for Youth with Disabilities


. While the number of DVR transition-age youth achieving employment
outcomes remained relatively stable for the period beginning in FY
2006 and ending in FY 2010, the attrition of these individuals during
various stages of the VR process increased and resulted in a decreased
employment rate over the same period.


Summary of Compliance Findings


RSA's review resulted in the identification of the compliance findings
specified below. The complete findings and the corrective actions that DVR
must undertake to bring itself into compliance with pertinent legal
requirements are contained in Section 6 of this report.

. DVR does not meet its established time standard pertaining to the
development of the individualized plan for employment (IPE) for
transition-age youth determined eligible for VR services.
. DVR's interagency agreement with the Wyoming Department of Education
does not include all required elements.
. DVR did not disburse all program income prior to requesting the
drawdown of additional federal funds.
. DVR does not conduct periodic certifications for employees working
solely on the VR program.
. The expenditure of VR program funds on costs incurred under contracts
with the non-profit operator of the Wyoming business leadership
network are not allowable and/or allocable to the VR program to the
degree that such funds were not used to provide VR services to program
applicants and eligible individuals, or to benefit groups of
individuals with disabilities. In addition, the non-federal
expenditures incurred in connection with such expenditures are not a
permissible source of match for the VR program to the extent that the
expenditures are not either allowable under, and/or allocable to, the
program.
. DVR does not monitor its contracts to ensure that grant-supported
activities performed by the contractors comply with applicable federal
requirements and that performance goals are achieved.


Development of the Technical Assistance Plan


RSA will collaborate closely with DVR and the Region 8 TACE to develop a
plan to address the technical assistance needs identified by DVR in
Appendix A of this report. RSA, DVR and the TACE will conduct a
teleconference within 60 calendar days following the publication of this
report to discuss the details of the technical assistance needs, identify
and assign specific responsibilities for implementing technical assistance
and establish initial timeframes for the provision of the assistance. RSA,
DVR and TACE will participate in teleconferences at least semi-annually to
gauge progress and revise the plan as necessary.


Review Team Participants


Members of the RSA review team included Larry Vrooman, David Wachter, and
Melissa Diehl (Vocational Rehabilitation Program Unit); James Billy,
Suzanne Mitchell, and Janette Shell (Technical Assistance Unit); Yann-Yann
Shieh (Data Collection and Analysis Unit); and Tanielle Chandler (Fiscal
Unit). Although not all team members participated in the on-site visit,
each contributed to the gathering and analysis of information, along with
the development of this report.


Acknowledgements


RSA wishes to express appreciation to the representatives of DVR for the
cooperation and assistance extended throughout the monitoring process. RSA
also appreciates the participation of the SRC, the Client Assistance
Program and advocates, and other stakeholders in the monitoring process.

Section 2: Performance Analysis

This analysis is based on a review of the VR programmatic and fiscal data
contained in Tables 2.1 and 2.2 below and is intended to serve as a broad
overview of the VR program administered by DVR. It should not be construed
as a definitive or exhaustive review of all available agency VR program
data. As such, the analysis does not necessarily capture all possible
programmatic trends. In addition, the data in Table 2.1 measure
performance based on individuals who exited the VR program during federal
fiscal year 2006 through 2010. Consequently, the table and accompanying
analysis do not provide information derived from DVR open service records
including that related to current applicants, individuals who have been
determined eligible and those who are receiving services. DVR may wish to
conduct its own analysis, incorporating internal open caseload data, to
substantiate or confirm any trends identified in the analysis.


Performance Analysis



VR Program Analysis


Table 2.1
DVR Program Performance Data for FY 2006 through FY 2010
All Individual Cases Closed |Number, Percent, or Average |2006 |2007 |2008
|2009 |2010 |Change from 2006 to 2010 |Agency Type 2010 | |TOTAL CASES
CLOSED |Number |1,640 |1,828 |1,824 |2,007 |2,262 |622 |281,286 | |
|Percent |100.0% |100.0% |100.0% |100.0%