The American Indian Vocational Rehabilitation Services (AIVRS) program section of the toolkit provides information that is relevant to new AIVRS Program Directors. The purpose and design of AIVRS programs is to provide culturally appropriate vocational rehabilitation (VR) services, to American Indian with disabilities who reside on or near federal or state reservations, consistent with such eligible individual’s strengths, resources, priorities, concerns, abilities, capabilities, interests, and informed choice, so that such individuals may prepare for, and engage in, competitive integrated employment that will increase opportunities for economic self-sufficiency. AIVRS programs are funded by the Department of Education (ED), Office of Special Education and Rehabilitative Services (OSERS), Rehabilitation Services Administration (RSA) to improve and sustain employment outcomes for American Indians with disabilities. Toolkit -Federal .
- AIVRS = American Indian Vocational Rehabilitation Services
- AIVRTTAC = American Indian Vocational Rehabilitation Training and Technical Assistance Center
- BH = Behavioral Health
- BIA = Bureau of Indian Affairs
- CANAR = Consortia of Administrators for Native American Rehabilitation, Inc.
- CRC = Certified Rehabilitation Counselor
- CSAVR = Council of State Administrators of Vocational Rehabilitation
- ED = Department of Education
- EDGAR = Education Department General Administrative Regulations
- GAN = Grant Award Notice/Notification
- GPRA = Government Performance and Results Act of 1993
- HR = Human Resources
- IHS = Indian Health Services
- IPE = Individualized Plan for Employment
- MIS = Management Information System
- NIA = Notice Inviting Application
- OSERS = Office of Special Education and Rehabilitative Services
- PES = Post-Employment Services
- RSA = Rehabilitation Services Administration
- TANF = Temporary Assistance for Needy Families
- TERO = Tribal Employment Rights Ordinance/Office
- VR = Vocational Rehabilitation
- WIOA = Workforce Innovation and Opportunity Act
- 2 CFR 200 = Uniform Administrative Requirements, Costs Principles, and Audit Requirements for Federal Awards
The Grant Award Notification (GAN) is the official document that serves to inform the grantee that their application has been selected for funding and it is very important for the AIVRS Program Director to become familiar with the contents of the GAN. The GAN provides detailed information about the grant award that include the amount of the award, specific terms and conditions of the award, and AIVRS contact information, including the AIVRS authorized representative, usually the Chairperson of the tribe. The GAN also include standard information about the payment procedures, performance and financial reporting requirements, audit requirements, and other required information the grantee must know.
In the Review Your AIVRS Program Grant Award section, dropdown tabs, using the headings of the grant proposal, provide guidelines to implement an AIVRS program with the purpose of assisting a new Program Director in achieving the goals and objectives of the five-year grant.
Review Your AIVRS Program Grant Award
It is important that the AIVRS Program Director and staff understand all aspects of the approved grant proposal as it informs and guides all program activities. As a new AIVRS Program Director, review and familiarize yourself with the entire grant proposal, including the annual federal and non-federal budgets and the budget justifications.
- First, Services Delivery and the Goals and Objectives of Grant Award
The goals and objectives of the AIVRS grant are interconnected to the delivery of consumer service. The questions that a Program Director must answer in the annual report are about consumer service delivery. The primary reason for an AIVRS is the provision of consumer services.
Service delivery is designed around the principals, values, and policies that guide the appropriate service provision to the AIVRS program consumers. Service delivery is embedded in the VR process where each process is related to the other and the process can be considered a revolving, progressive system towards the ultimate goal of employment and self-sufficiency. The process is as follows: a) intake to application, b) application to eligibility, c) eligibility to case open, d) case open to the development of the individualized plan for employment (IPE), e) IPE to employment, f) employment to successful case close, and g) successful closure to tracking and post-employment services. Throughout the life of the VR process, each consumer’s case is continually evaluated for the consumer’s proper placement in the process.
Understand that as a new AIVRS Program Director you may not be able to grasp the magnitude of the questions now or have the answers to the questions posed; however, the questions can be your to-do list for learning.
Link the goals and objectives of the grant to consumer service delivery:
- Do you understand the goals and objectives outlined in the grant? Consider reviewing the goals and objectives with staff during an annual retreat and developing a strategic plan for the new grant year.
- Does your AIVRS program have a method to measure the goals of the grant? Why or why not?
- Is your AIVRS program achieving the grant goals? Why or why not? Analyze your program methods of outreach and the provision of services. Do you need to make changes to reach your goals effectively
- How are the program goals relevant to the consumer and the provision of services? Be able to explain and justify your answer.
- How is the program honoring the timeline of the grant? Be able to explain and justify you answer?
If you cannot answer the above questions now, you have a number of resources available to you:
- Reach out to other AIVRS Directors through the list serve or a one-on-one consultation,;
- Contact your project officer;
- Reach out to an AIVRTTAC specialist;
- If you are taking classes with Northwest Indian College, ask questions; and
- Request that CANAR (Consortia of Administrators for Native American Rehabilitation, Inc.) provide specific training around your need.
- Second, Management Plan
The management plan should incorporate the program goals, timeline to implement the goals, and staff task assignments with deadline dates. Consider a one- to two-day AIVRS staff retreat to review the annual goals and objectives and develop strategies to achieve the goals and objectives on time and within budget.
The AIVRS Program Director and staff are encouraged to establish a vision and mission together, to ensure the development of a team culture where each staff member’s voice is acknowledged in both statements. The greater the staff buy-in to the vision and mission of the program the less likely staff will create their own modifications to the AIVRS philosophy and activities. If the AIVRS program already has a vision and mission statement, create a value word exercise and create a brief statement using the values words from the exercise that honors the tribal culture, the program culture, and the consumers of the program.
Managing your AIVRS program more effectively:
- Is the management plan realistic in achieving the program goals and objectives on time and within budget? If not, as the Program Director with the assistance of your staff, how will you correct the plan?
- Are the time commitments of key personnel appropriate and adequate to meet the program goals and objectives? If not, as the Program Director, what is the procedure for changing time commitments of key personnel?
- Does the management plan clearly define the responsibilities of key personnel so that all the program goals and objectives will be achieved? In not, is there a method to amend the management plan?
- Are the timelines reasonable to achieve the proposed milestones for accomplishing program tasks? How will you, as the Program Director, amend the timelines to ensure the tasks are realistic to achieve
- Does the management plan clearly describe the order in which proposed goals and objectives will be completed? As the Program Director, what are the steps to be taken to rectify problems?
- Is the management plan rationally designed to serve all eligible consumers under an Individualized Plan for Employment (IPE) and assist them in achieving gainful employment in a timely manner? What steps will you, as the Program Director, take to ensure the management plan is feasible and that consumers will receive the services required to help them become gainfully employed?
If you answered “no” or “I do not know” to any of the above questions, contact your project officer a) for a precise answer and b) to discuss the possibility of a grant revision through the amendment process, if necessary. Toolkit-Federal
Monitor the management plan: revisit it every three months with staff and consider the following questions:
- Are the proposed program accomplishments aligned with the timelines?
- Have any unanticipated challenges occurred that require adjustment of the timelines?
- Are any changes required to the plan of operation?
- Are you documenting consumer outcomes in the Annual Performance Report? Toolkit-Federal
- Is the AIVRS facility fully accessible to individuals with disabilities? If not, what are the options for change?
- Why outreach?
- Is the AIVRS disseminating program material efficiently?
- Does the marketing strategy promote the AIVRS program effectively?
- Through best practices, how are you expanding the AIVRS program?
- Is the AIVRS program reaching out to all potential consumers? How?
- How is your AIVRS program building local capacity to increase awareness and understanding about tribal members with disabilities? What is local capacity?
Reflect on the need for outreach: AIVRS programs provide VR services to American Indians with disabilities living on or near the tribe’s geographic service area that is generally located in remote and/or rural areas. Most state VR agencies do not provide VR services in a consistent manner to American Indians with disabilities; consequently, the need for the AIVRS programs. With the inception of the AIVRS programs, there have been some improvements in the coordination of VR services with the state VR agencies, however there are still gaps in serving tribal consumers; therefore, a need for program outreach. Outreach is an important AIVRS program activity because the activity informs tribal members, family members, and the community about VR services that prepare eligible individuals for gainful employment.
If you answered “no” or “I do not know” to any of the above questions, a) learn where to seek answers to puzzling questions, b) meet with the assigned RSA project officer if an amendment to your five-year management plan is required, and c) meet with the AIVRS program staff to develop an annual strategic plan. The rational of an annual strategic plan is to determine the need for amendments to the grant proposed goals and objectives and to determine if adequate resources are available in serving all eligible consumers. Toolkit-Federal
- Third, Evaluation Plan
The evaluation of the AIVRS program is conducted in two formats, formative and summative. Formative is an on-going process and is a management tool for program improvement. A consumer satisfaction survey, upon the closing of their case is an example of formative evaluation ( Consumer-Satisfaction-Survey-Example.pdf (163 downloads) ). Summative is the overall appraisal of the program activities and outcomes that are reflected in the annual performance report ( APR-Example-2019.pdf (34 downloads) ). Each process, formative and summative, is essential to the transparency of information that defines the overall effectiveness of an AIVRS program in meeting the goals and objectives outline in the grant award. The AIVRS program collects quantitative and qualitative data. Quantitative data consists of numbers or quantities gathered with closed-ended questions and limited-choice answers, such as “what is the number of consumers served and employed?” Qualitative data exams the quality of services, which is implemented in open-ended questions with an unlimited choice in answers. Qualitative data is gathered through one-on-one interviews or focus groups, and includes questions like “What is the one AVIRS service that was provided in your IPE that helped you the most?”
Questions to provoke learning and change:
- Who is responsible for evaluating your program? Check to see if you have an assigned evaluator. If not, you need to determine who will lead the evaluation activities.
- Is the grant evaluation plan design in alignment with the proposed goals and objectives? If not, how would the Program Director align the evaluation plan to the goals and objectives?
- What qualitative and quantitative data will be collected? How will the data be collected?
- Who will be responsible for data collection, management, and the analysis of the program data?
- Are the evaluation tools valid, reliable, and appropriate for the AIVRS program?
- Will the AIVRS program use electronic software for case management?
- Does the evaluation plan include a consumer satisfaction closure survey to evaluate program services?
- Does the evaluation plan include the use of an external evaluator?
- Does the evaluation plan include the use of the funding agency requirements or standards?
- Does the evaluation plan include provisions for program performance feedback to develop corrective action plans?
Utilize the review process to develop your annual work plan and determine your priorities. If you make any changes to your approved grant award, for example changing the title and function of a staff position from an Employment Specialist to a VR Counselor, you need to get approval from your RSA project officer. Toolkit – Federal
- Fourth, Fiscal Management
To ensure proper fiscal management of the AIVRS program, the Program Director must understand the detailed information of each annual federal and non-federal budget and budget justification. It is also recommended that the AIVRS Program Director review and understand the resource section of the grant proposal that describes the adequacy of the tribal support including facilities, equipment, supplies, and other resources. As needed, request guidance from your assigned RSA project officer and assigned tribal finance personnel to assure standard accounting principles are used and in compliance with the 2 CFR 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal awards occurs.
AIVRS Program Funds
The AIVRS funds are provided through a federal portion that is ninety percent of the total cost of the AIVRS program and the mandatory non-federal portion (the tribal match) is ten percent of the total cost of the AIVRS program. The ten percent mandatory tribal match can be: a) capital only, and is delineated and monitored in the Non-Federal B Budget, b) an in-kind contribution only, for example, the tribe provides the AIVRS program an office at no cost to the program; or c) a combination of dollars and an in-kind contribution. To calculate the ten percent total cost of the AIVRS program, divide the Federal portion by the number nine and the result is the matching requirement.
To financially operate an AIVRS program, it is important to understand the Federal A Budget, the Non-Federal B Budget, and the accompanying narrative budget justification. The A and B budget will have an indirect cost rate that must be established through the tribe’s cognizant agency; often the Bureau of Indian Affairs (BIA) is the cognizant agency. The approved tribal indirect cost rate agreement is used to calculate the funds that will be used by the tribe for the administration of the AIVRS program.
A tribe may require an AIVRS program to create an internal single-entry system, a CUFF account to document and monitor all program expenditures; thereby, the Program Director can compare the program CUFF account expenses with the tribal accounting department expenses.
Other important elements of AIVRS program fiscal management include:
RSA approval for tribal and/or AIVRS Program Director’s access to the G5 and Management Information System (MIS) for reporting purposes.
Tribal designation of authorized personnel responsible for AIVRS program drawdown of funds and documentation of the tribal ten percent cash match for reporting purposes. The Program Director is advised to contact the tribal grants and contracts department for all related grant spending and drawdown questions.
RSA approval process to amend the AIVRS program federal budgets.
- Fifth, Design Section / Collaboration
The design section of the AIVRS grant is dedicated to the collaboration between existing service providers, such as the state VR agency, tribal programs, and local providers with the primary goal to better serve eligible tribal consumers who are striving to obtain competitive integrated employment. In the AIVRS grant proposal, review the appendices for the commitment letters from the AIVRS stakeholders.
If an AIVRS program is designed as a “consortia” that will serve more than one tribe, letters from individual participating tribes will designate one tribal governing body to apply for the grant and serve as the central administrative office. The written plan that is agreed upon by the consortia will support the AIVRS program with available resources to serve and prepare all eligible consumers for suitable employment.
Building effective collaboration between agencies and programs requires time, trust building, respect, commitment, communication, and flexibility. Identification of appropriate partnerships/stakeholders is important to the program’s resources, reputation, and willingness to coordinate services and to avoid the duplication of services in the provision of exemplary services to AIVRS program consumers.
If the AIVRS grant proposal outlines the establishment of a volunteer advisory committee, identify individuals who possess the commitment, time, and expertise to serve in an advising capacity. The objective of an advisory committee is to develop plans for the continual growth of the AIVRS program, as well as providing feedback for the improvement and expansion of VR services. Toolkit – Federal
The following is a list of potential volunteer advisory committee members and stakeholders:
- Consumers of the AIVRS program
- Family member of an AIVRS consumer
- State VR Counselor
- Local primary employers: Indian Health Services (IHS), Schools, Bureau of Indian Affairs (BIA), and Tribal Government
- Tribal/Federal programs: Grants and Scholarships, Head Start, Workforce Innovation and Opportunity Act (WIOA), Temporary Assistance for Needy Families (TANF), Community Health Representatives, Behavioral Health (BH), Social Services, Tribal Employment Rights Ordinance/Office (TERO)
- Non-profit organizations
The following is a list of agencies to consider for AIVRS program partnerships/stakeholders:
- State VR Agency
- State Rehabilitation Council (SRC)
- Consortia of Administrators for Native American Rehabilitation (CANAR), Inc.
- American Indian Vocational Rehabilitation Training and Technical Assistance Center (AIVRTTAC)
- Northwest Indian College Tribal Vocational Rehabilitation Institute
- Council of State Administrators of Vocational Rehabilitation (CSAVR)
- Sixth, Personnel
Review the personnel section of the AIVRS grant proposal for information on staff training and professional development activities. Evaluate your program management plan to ensure that professional development activities do not cause any unnecessary interruptions in consumer services.
Program regulation 34 CFR §371.41(a)(1) allow for expenditures for staff development. The professional development goals must support and align with the program’s mission, needs, goals, and the provision of quality and culturally appropriate services for tribal members with disabilities.
The AIVRS staff is required to have a detailed job description that clearly identifies the duties and obligations of a staff position; thereby, providing the benchmarks of the personnel development plan. The professional development of the AIVRS staff individualizes the employee plan that includes education, training, staff evaluations, and timelines for completion.
The completion of formal coursework that leads to academic degrees or continuing education units and credits may be used to document staff development in their individual employee personnel records. Training and personnel development may be obtained through conference participation, informal learning opportunities, formal coursework, webinars, and online training. In addition, program staff can earn or maintain professional credentials in VR (i.e. Certified Rehabilitation Counselor (CRC)).
Your AIVRS personnel development plans may include identification and collaboration with appropriate resources to assist with professional staff development. For example, AIVRTTAC, Northwest Indian College Tribal Vocational Rehabilitation Institute, CANAR, and the state VR agency.
AIVRS program investment in each staff member through the use of a written development plan will enhance skills and inspire staff through: increasing job retention and decreasing employment gaps; promoting confidence in the performance of work duties; improving the delivery of quality VR consumer services; increasing consumer employment outcomes; and enriching AIVRS program performance.
Some tribes use staff professional development plans and forms created by the tribal Human Resource (HR) department and will vary in format design. The professional development plans are typically established as part of the annual employee performance appraisal and implemented as part of the next annual employee appraisal.
The following are recommended steps to encourage each AIVRS program employee’s professional and personal growth:
- Conduct staff self-assessment of their skills, interests, capabilities, strengths, behaviors, and personality characteristics.
- Assess interpersonal skills, natural abilities, cultural awareness, academic achievement, disability awareness, motivation level, and attitude.
- Identify areas for improvement to enhance employee knowledge and skills:
- VR processes (e.g., intake, determination of applicant eligibility, development of consumer IPE, case closure, post-employment services);
- Knowledge to determine how an individual’s disability is an impediment to employment;
- Case management skills;
- VR rules and regulations; and
- Interviewing and counseling skills.
- Discuss professional development goals of the employee and jointly develop a professional development plan, including outcomes and benefits.
- Implement and monitor the employee professional development plan.