Fiscal Year 2012 Monitoring Report on the Alabama Department of ...

Fiscal Year 2012
Monitoring Report
on the
Alabama Department of Rehabilitation Services
Vocational Rehabilitation Program

U.S. Department of Education
Office of Special Education and
Rehabilitative Services
Rehabilitation Services Administration

May 24, 2012
Table of Contents

Page

Section 1: Executive Summary 2

Section 2: Performance Analysis 5

Section 3: Emerging Practices 11

Section 4: Results of Prior Monitoring Activities 13

Section 5: Focus Areas 17

A. Organizational Structure Requirements of the Designated State
Agency and Designated State Unit 17

B. Transition Services and Employment Outcomes for Youth with
Disabilities 18

C. Fiscal Integrity of the Vocational Rehabilitation Program 25

Section 6: Compliance Findings and Corrective Actions 26

Appendix A: Alabama Department of Rehabilitation Services Response 38

Appendix B: Legal Requirements 43



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
Alabama Department of Rehabilitation Services (ADRS) 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 January 23-27, 2012, is described in detail in the FY 2012 Monitoring
and Technical Assistance Guide for the Vocational Rehabilitation Program.


Emerging Practices


Through the course of its review, RSA collaborated with ADRS, the State
Rehabilitation Council (SRC), the Southeast Region 4 Technical Assistance
and Continuing Education Center (Southeast TACE), and other stakeholders to
identify the emerging practices below implemented by the agency to improve
the performance and administration of the VR program.

. Program Evaluation and Quality Assurance Practices: In 2010, ADRS
implemented a vision to place greater emphasis upon the measurement of
quality and the lasting impact of VR services. Utilizing the
foundation of data recorded by counselors within the ADRS case
management system, and building upon investments in a business
intelligence (BI) model, an entirely new set of resources was
introduced to support the achievement of agency goals.

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


Summary of Observations


RSA's review of ADRS resulted in the observations related to the focus
areas identified below. The entire observations 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


. Approximately 30 percent fewer ADRS transition-age youth achieved SE
outcomes in FY 2010 than in FY 2006, and the SE outcome rate for
transition-age youth was less than half of the combined agency average
throughout the period under review.
. ADRS experienced a downward trend in the array of services provided to
transition-age youth and in the number of individuals who received
those services.In addition, ADRS served significantly fewer transition-
age youth with the most significant disabilities than the average for
all combined agencies during the performance period.


Summary of Compliance Findings


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

. ADRS is not in compliance with the requirements for third-party
cooperative arrangements (TPCA) with respect to its 67 agreements to
provide services to transition-age youth and thus, the expenditure of
VR funds associated with these arrangements as well as the non-federal
expenditures used as match are unallowable.
. ADRS is not in compliance with the requirements for the use of set-
aside funds under the Randolph-Sheppard Vending Facility program as
match for the VR program because it used expenditures as match that
were allowable under the Randolph-Sheppard program but not allowable
for purposes of match under the VR program.
. ADRS expended VR funds for the provision of services through a
contract with the Alabama Institute for Deaf and Blind, E.H. Gentry
Technical Facility (AIDB), that are either not allowable and/or
allocable to the VR program to the degree that such expenditures are
not sufficiently traceable through appropriate supporting
documentation to the provision of VR services to applicants,
individuals determined eligible for VR services, or an authorized
group; and the non-federal share provided by AIDB to ADRS associated
with these non-allowable and/or allocable expenditures is not a
permissible source of match.
. ADRS lacks sufficient fiscal and internal controls with respect the
use of its "revolving fund" and contract arrangements to ensure that
VR funds are used properly and efficiently and expended only for
allowable VR expenditures in accordance with federal regulations.


Development of the Technical Assistance Plan


RSA will collaborate closely with ADRS and the Southeast TACE to develop a
plan to address the technical assistance needs identified by ADRS in
Appendix A of this report. RSA, ADRS and Southeast 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,
ADRS and the Southeast 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 David Steele and Tarsha Johnson
(Fiscal Unit); Ed West, Zera Hoosier and Sandy DeRobertis (Vocational
Rehabilitation Unit); Joe Doney (Technical Assistance Unit); Joan Ward
(Data Collection and Analysis Unit); and Pamela Hodge (Independent Living
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 ADRS 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 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 ADRS. 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 or fiscal trends. In addition, the data in Table 2.1
measures performance based on individuals who exited the VR program during
federal fiscal years 2006 through 2010. Consequently, the table and
accompanying analysis do not provide information derived from ADRS open
service records including that related to current applicants, individuals
who have been determined eligible and those who are receiving services.
Preliminary FY 2011 RSA-911 data for Alabama was available at the time of
this rev