The United States Department of Education, Office of Special Education and Rehabilitative Services (OSERS), Rehabilitation Services Administration (RSA) is the federal agency that provides grant funding for all American Indian Vocational Rehabilitation Services (AIVRS) programs, as authorized by Section 121 of the Rehabilitation Act, as amended (the Act), and implemented by the subsequent program regulation at 34 CFR §371. There are currently 88 AIVRS Grant Projects across the United States.
RSA and AIVRS
The mission statement for the RSA declares:
Our mission — to provide leadership and resources to assist state and other agencies in providing vocational rehabilitation (VR) and other services to individuals with disabilities to maximize their employment, independence and integration into the community and the competitive labor market.
The RSA further elaborates on the AIVRS grants with the following purpose statement:
The purpose of this program is to provide vocational rehabilitation (VR) services, including culturally appropriate services, to American Indians who are individuals with disabilities residing on or near federal or state reservations, consistent with such eligible individuals’ strengths, resources, priorities, concerns, abilities, capabilities, interests, and informed choice, so that such individuals may prepare for, and engage in, high quality employment that will increase opportunities for economic self-sufficiency.
Communication between the RSA Project Officer and a New AIVRS Project Director
RSA promotes open communication between their staff and AIVRS Project Directors. Project Directors are encouraged to contact their assigned RSA Project Officer whenever there are questions or concerns. Due to the number of AIVRS Projects and only two RSA Project Officers at the present time, email is the preferred method of communication.
The name of each grantee’s assigned RSA Project Officer is listed on the AIVRS Grant Award Notification (GAN) document. It is expected that a new AIVRS Project Director would contact their Project Officer and introduce themselves. RSA Project Officers are not always aware when there is a Project Director change or a Project Director hired for a newly funded grant.
Although there are open communication opportunities between an AIVRS Project Director and their assigned RSA Project Officer, there are certain situations when a Project Director is required to contact their Project Officer other than the introduction contact. For example, contact the Project Officer regarding the approval of Key Personnel, change in position descriptions from those in the approved grant application, excessive unspent grant balances, and questions about the vocational rehabilitation process, consumer services, or financial or regulatory issues.
As of December 2017, the RSA staff who communicate directly with AIVRS Project personnel include Dr. Thomas Finch, Director of the Training and Service Programs Division for U.S. DOE/OSERS/RSA, and the two RSA Project Officers, Sonja Turner and August Martin.
- Director, Training and Service Programs Division
- RSA Project Officers
Thomas Finch, Ph.D.
U.S. Department of Education
400 Maryland Avenue SW.
Potomac Center Plaza (PCP), Room 5147
Washington, DC 20202-2800
400 Maryland Avenue, SW
PCP, Room 5049
Washington, DC 20202
400 Maryland Avenue, SW
PCP, Room 5049
Washington, DC 20202
RSA Conference Calls
- Monthly RSA Conference Calls with AIVRS Project Directors
For over 20 years, there was a Monthly RSA Conference Call with all AIVRS Project Directors across the United States. The call recently changed to a Quarterly Call. As of December 2017 the quarterly RSA conference call is held the third Thursday of every third month from 2:00 pm to 3:30 pm EST.
AIVRS Project Directors look forward to these calls as they provide the opportunity to interact with other AIVRS Project Directors about topics of importance to the AIVRS projects and the VR profession as a whole. The process is similar for each quarterly conference call. RSA emails an announcement about the call, with time, date and call in numbers. The announcement also contains RSA agenda and invites AIVRS Project Directors to submit additional agenda items. The day before the call, RSA emails a reminder with a full agenda.
The calls are friendly and interactive, even with many people participating. Once the agenda has been covered, there is time allotted to talk about upcoming conferences and professional learning events. Near the end of the call, AIVRS Project Directors have time for information sharing about unsolved problems, new staff or situations, or a new VR service or activity that worked well.
- RSA Grant Administration Conference Calls with AIVRS Project Directors
As needs are identified, RSA staff conduct professional training and technical assistance about critical areas related to grant administration with all AIVRS Project Directors. RSA staff arranges these calls and information about the call is emailed to all AIVRS Directors. Past topics include financial information; budget management; new legislation or regulations; and redesigning the AIVRS Annual Performance Reports.
Amendments to the AIVRS Approved Grant Proposal
As an AIVRS Project Director, there may be situations that arise requiring a change in a component of the five-year funded grant proposal. Some examples of required changes include: a new position description; upgrading an objective to a goal; revising the number of consumers to be served or consumer employment outcomes; or adjusting a budget line item. The AIVRS funded grant is an agreement between the Tribe or organization and RSA that needs to be implemented as approved. Therefore, if there are changes to be made, the amendment process documents these changes to the original agreement through a formal approval process.
If there is a need to formally request a change, the AIVRS Project Director works with their assigned RSA Project Officer to utilize the amendment process. The amendment process requires the AIVRS Project Director to prepare an amendment letter explaining the reason and justification for request. The next step is to work with the tribe’s Authorized Representative, which is usually the Tribal Chairperson, to make the official request with a signed letter that is emailed to the RSA Project Officer.
An Assurance Statement may also be required depending upon the amendment content; consequently, additional documentation may be necessary, such as a position description or a budget modification.
Rehabilitation Services Administration (RSA) Approval for AIVRS Key Personnel
Key Personnel are defined as individuals who contribute to the development and execution of an AIVRS project in a substantial and measurable way. For AIVRS Projects, Key Personnel refers to the Project Director (required), Project Manager/Coordinator (if applicable), and the Vocational Rehabilitation Counselor. Certify with your RSA project officer if you are not clear about Key Personnel designations.
Due to the critical role of Key Personnel in implementing an AIVRS grant, prior RSA approval of the program staff selected by the Tribe for the positions is required before they are hired. To seek approval for Key Personnel their position description, resume, and other documentation of their qualifications for the position need to be emailed to your assigned RSA Project Officer. When emailing this information enter, “Request for RSA Prior Approval of Key Personnel” in the subject line. The RSA Project Officer will then know this is an urgent request.
Although prior approval for Key Personnel by RSA is required, the tribe may not have been aware of this requirement, due to the complexities of the grant submission and funding process. If current Key Personnel have not received RSA approval, it is critical to email the AIVRS RSA Project Officer immediately to explain the situation, and then email the required approval documents.
Required Reporting to Rehabilitation Services Administration (RSA)
Tribal Nations and qualifying tribal organizations throughout the United States are eligible to apply for a 5-year discretionary grant entitled the American Indian Vocational Rehabilitation Services (AIVRS) funded by the United States Department of Education (USDOE) – Rehabilitation Services Administration (RSA). AIVRS grants are awarded to qualifying organization to provide vocational rehabilitation services to eligible Tribal Members with disabilities. One crucial obligation of receiving an AIVRS grant is regular mandatory reporting to RSA on grant fund expenditures, the types of services provided to consumers/clients and the resulting outcomes. The three required types of reports are: 1) A six-month report required only during Year 1 of the grant; 2) annual performance reports required Years 1-5 of the grant; and 3) a 5-year summary report describing expenditures, vocational rehabilitation services provided, successful and unsuccessful participant outcomes, and cost of successful employment outcomes over the entire five-year grant period.
The key to successful and consistent reporting to RSA involves having data-gathering techniques and strategies in place to track consumer/client-related information prior to project initiation. Information to be collected includes client progress toward goals, vocational rehabilitation services received, project related expenditures, outcomes and overall case management activities. Many AIVRS Directors utilize one of two commercially available software programs developed specifically for AIVRS monitoring and reporting, DataOps and AWARE. Other Directors have developed their own internal competencies and databases to manage, track, and report data. Timely and accurate reporting to RSA is critical to on-going grant funding. Therefore, submitting the AIVRS required reports to RSA on or before the due date is imperative. For questions about the reports or problems accessing reports in the electronic reporting system, contact the assigned RSA Project Officer by email early in the reporting process.ED-524B-Report-Package.pdf (70 downloads)
All three types of RSA reports require completion of the ED 524B forms and a detailed narrative. The ED 524B forms and instructions for completion are emailed from RSA Project Officers to the AIVRS Project Directors approximately 90-days before the report is due. If an AIVRS Project Director does not receive the ED 524B, an email should be sent to the RSA Project Officer immediately so documents will be sent. The ED 524B forms are completed in two parts: 1) Forms completed by the tribal accounting office containing required financial information and the tribe’s current Indirect Cost Rate Agreement; and 2) a descriptive “Executive Summary” narrative prepared by the AIVRS Project Director. The ED 524B forms are the same for each submission, so you can always use copies of blank forms from a previous report, unless this is your first year of operation.
- Suggested AIVRS information to include in the ED 524B “Executive Summary” narrative include:
- Project progress towards achieving the grant goals and objectives
- Amendment(s) to grant
- Personnel updates such as hiring of staff or change in personnel including employment gaps
- Fiscal information on expenditures and brief justification
- Tribal financial freeze that impacts AIVRS spending
- Outreach activities conducted
- Consumer related activities such as collaboration and use of comparable service providers
- Information related to Advisory Committee activities
- Consumer Satisfaction Survey data analysis
- State VR interaction
- Culturally appropriate activities
- Challenges and barriers encountered by the AIVRS project staff or consumers
- Highlight a confidential consumer success story (do not include identifying consumer information)
- Share an AIVRS programmatic success
The AIVRS 6-Month Performance Report is directly entered into RSA’s Management Information System (MIS) and is due after March 31st of the first-year of a newly awarded 5-year grant. Information about accessing the MIS database, and preparing and submitting the 6-month report is emailed by the RSA to each AIVRS Project Director for newly funded AIVRS grants prior to the grant’s 6-month midpoint, March 31st. The 6 Month Report uses the same format as the Annual Performance Report. This report covers the 6-Month date range from the beginning of the Fiscal Year (October 1st) through the 6-month grant midpoint (March 31st) of the following calendar year, and provides the opportunity for the AIVRS project to provide, and RSA to review, the activities, expenditures and outcomes associated with the initial implementation of new AIVRS project. The 6-month report provides the vehicle for both the Tribe and RSA to monitor the progress of the AIVRS Project against the plan described in the grant proposal.
The AIVRS Annual Performance Report encompasses a 12-month fiscal year period from October 1 of one year through September 30 of the next year (e.g. 10/1/2016 to 9/30/2017). Information about accessing the MIS database, and preparing and submitting each Annual Performance Report is emailed directly to each Project Director by RSA, after the close of every grant year. The AIVRS Annual Performance Report contains information about fiscal and budget expenses, the Grant Award Notification (GAN), and data describing consumer/client vocational rehabilitation services and educational and employment outcomes. The annual performance report is due 90-days after the end of each of the five fiscal years, however, RSA frequently extends the due date to January 15.
The comprehensive 5-Year Performance Report is due 90-days after the close of Year 5 of the AIVRS Grant. Information about accessing the G-5 database, and preparing and submitting the 5-Year Performance Report is emailed directly to each Project Director by RSA, after the close of the fifth grant year. This comprehensive report summarizes the entire 5-years of the grant and is required in addition to the Year-5 Annual Performance Report. The 5-Year Performance Report uses a different format and is entered in RSA’s G-5 system. Year 5 ends on September 30 and the 5-Year Performance Report is due December 30 unless the due date is extended by RSA. The 5-Year closure report requires information that the Project Director can glean from the accumulated Annual Performance Reports from Years 1-5. However, new information is also requested such as “Cost Each Year for Clients Served and for Each Successful Employment Outcomes”.
Resources and Link