The Rehabilitation Services Administration (RSA) is the federal agency that provides grant funding for all American Indian Vocational Rehabilitation Services (AIVRS) programs (MAP of 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. RSA is housed in the Department of Education (ED) , Office of Special Education and Rehabilitative Services (OSERS). There are currently 88 AIVRS Programs with federal grant funding 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 Program Director
RSA promotes open communication between their staff and AIVRS Program Directors. AIVRS Program Directors are encouraged to contact their assigned RSA Project Officer with questions and concerns in the implementation of the AIVRS grant and the assigned Project Officer will provide answers and technical assistance according to regulations. Examples of reasons for contacting a Project Officer may include: a) approval of key personnel; b) a change in position descriptions from those in the approved grant application; or c) excessive unspent grant balances. In addition, questions about the VR process, consumer services, or financial or regulatory issues would also be appropriate. Your assigned RSA Project Officer is listed in the AIVRS Grant Award Notification (GAN) document. It is recommended that a new AIVRS program director contact their RSA Project Officer and provide an introduction because often a project officer may not be aware when there is a change in a program director or when a program director is hired for a newly funded grant.
As of December 2017, the RSA staff who communicate directly with AIVRS program personnel include Dr. Thomas Finch, Director of the Training and Service Programs Division for ED/OSERS/RSA, and the two RSA Project Officers, Sonja Turner and August Martin.
- Director, Training and Service Programs Division
Thomas Finch, Ph.D.
U.S. Education Department
400 Maryland Avenue SW.
Potomac Center Plaza (PCP), Room 5147
Washington, DC 20202-2800
RSA Conference Calls
For over twenty years RSA conference calls with AIVRS Program Directors occurred monthly. These calls were recently changed to occur quarterly. As of December 2017 the quarterly RSA conference call is held the fourth Thursday of every third month from 2:00 pm to 3:30 pm EST.
AIVRS Program Directors look forward to these calls as they provide the opportunity to interact with other AIVRS Program Directors about topics of importance to the AIVRS programs 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 the RSA agenda and invites AIVRS Program 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 Program Directors have time for information sharing about unsolved problems, new staff or situations, or a new VR service or activity that worked well.
As needs are identified, RSA staff conduct professional training and technical assistance on critical areas related to grant administration with all AIVRS Program Directors. RSA staff arranges these calls and information about the call is emailed to all AIVRS Directors. Past topics have included 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 Program Director, there may be situations that arise requiring a change in a component of the five-year funded grant proposal. Some examples of possible changes include: a new position description, upgrading an objective to a goal, adding an outreach activity not included in the grant proposal, 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 originally 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 Program Director works with their assigned RSA Project Officer to utilize the amendment process. The amendment process requires the AIVRS Program Director to prepare an amendment letter explaining the reason and justification for the 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 Letter-of-assurance.pdf (43 downloads) may also be required depending upon the amendment content; consequently, additional documentation may be necessary, such as a position description or a budget modification. When making an amendment request, it is important to discern whether any modifications or amendments to the approved grant proposal or grant application will have an adverse effect on the provision of VR services to all eligible tribal members with a disability.
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 program in a substantial and measurable way. For AIVRS programs, key personnel refers to the Program Director (required), Program Manager/Coordinator (if applicable), and the Vocational Rehabilitation Counselor. Confirm 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 position is required before key personnel is hired. To seek approval for key personnel, the position description, resume, an official letter of appointment from the Tribe, and other documentation of qualifications for the position should 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)
The key to successful and consistent reporting to RSA involves having data-gathering techniques and strategies in place to track consumer related information prior to program initiation. Information to be collected includes consumer progress toward goals, VR services received, program related expenditures, outcomes, and overall case management activities. The three necessary performance reports are: 1) a six-month report required only during Year 1 of the grant; 2) annual reports required in Years 1-5 of the grant; and 3) a five-year final summary report describing expenditures, VR services provided, successful and unsuccessful participant outcomes, and cost of successful employment outcomes over the entire five-year grant period. Timely and accurate reporting to RSA is critical to on-going grant funding. RSA is obligated to put a temporary hold on a tribe’s finances if a report is delayed and the hold will stay in effect until the performance report is submitted. Therefore, submitting the performance reports to RSA on or before the due date is imperative. For questions about the mandatory reports, contact the assigned RSA Project Officer by email early in the reporting process.
All three RSA reports require the completion of the ED 524B 2-part form, which includes: 1) a Project Status Report, completed by the tribe’s financial department containing required financial information and the tribe’s current Indirect Cost Rate Agreement; and 2) an Executive Summary, completed by the AIVRS Program Director or Manager. 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. The ED 524B forms and instructions for completion are emailed from RSA Project Officers to the AIVRS Program Directors approximately 90 days before the report is due ED-524B-Report-Package.pdf (135 downloads) . If an AIVRS Program Director does not receive the ED 524B, an email should be sent to the RSA Project Officer reporting the mistake so it can be rectified.
- Example of ED 524B executive summary
When writing a narrative for the ED 524B Executive Summary, consider this process as an opportunity to highlight your AIVRS Program. For example:
- Describe how the goals and objectives were accomplished earlier than proposed;
- Discuss the need for an amendment to the original grant;
- Describe the barriers preventing you from achieving the grant goals and objectives;
- Note a new successful outreach activity implemented; and
- Most importantly, highlight a consumer success story (be sure not include recognizable information that could identify the consumer in the community)
The AIVRS Six-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 five-year grant. Information about accessing the MIS database and preparing and submitting the six-month report is emailed by RSA to each AIVRS Program Director for newly funded AIVRS grants prior to the grant’s six-month midpoint, March 31st. The Six-Month Report uses the same format as the Annual Performance Report (APR). The report covers the six-month date range from the beginning of the fiscal year (October 1st) through the six-month grant midpoint (March 31st) of the following calendar year. The report provides RSA an opportunity to review activities, expenditures, and outcomes associated with the initial implementation of new AIVRS program. The six-month report allows for both the tribe and RSA to monitor the progress of the AIVRS Program against the plan described in the grant proposal. RSA is obligated to put a temporary hold on a tribe’s finances if a six-month report is delayed and the hold will stay in effect until the six-month report is submitted.
The AIVRS Annual Performance Report (APR) 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). The annual performance report is due 90-days after the end of each of the five fiscal years. Information about accessing the Management Information System (MIS) database and preparing and submitting each Annual Performance Report is emailed directly to each Program 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 vocational rehabilitation services and educational and employment outcomes. RSA is obligated to put a temporary hold on a tribe’s finances if an annual performance report is delayed and the hold will stay in effect until the annual performance report is submitted.
The comprehensive Five-Year Final Performance Report (FYFPR) is due 90 days after the close of Year 5 of the AIVRS Grant and the report provides a summary of the entire five years of the grant with accumulated data related to the goals and objectives of the approved grant application. The FYFPR is submitted in the G5 system and information about accessing the G5 database and preparing and submitting the Five-Year Final Performance Report is emailed directly to each Program Director by RSA after the close of the fifth grant year. Directors can expect a pre-expiration letter or check list from their assigned Project Officer 60 days prior to the FYFPR or at the conclusion of the grant. Independently of the FYFPR, two other reports are due at the end of the grant, an Annual Performance Report that is submitted through the RSA Management Information System (MIS) and the Department of Education (ED) Grant Performance Report, the ED 524B, submitted through G5. The Five-Year Final Performance Report format is different from the Annual Performance Report and each report is submitted through different reporting systems. The grant ends on September 30 and the Five-Year Final Annual Performance Report is due December 30, 90 days after the close of the grant year. The report requires information that a Program 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 Consumer Served and for Each Successful Employment Outcomes.”