The American Indian Vocational Rehabilitation Services Project (AIVRS) section of the toolkit provides information that is relevant to new AIVRS directors. The purpose and design of AIVRS projects is to provide vocational rehabilitation, including culturally appropriate services, to American Indians 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, high-quality employment that will increase opportunities for economic self-sufficiency. The AIVRS project is authorized by Section 121 of the Rehabilitation Act of 1973, as amended (the Act), and implemented by the subsequent program regulation at 34 CFR § 371.
Important definitions and acronyms:
- OSERS = Office of Special Education and Rehabilitative Services
- RSA = Rehabilitation Services Administration
- AIVRS = American Indian Vocational Rehabilitation Services
- GAN = Grant Award Notification
- GPRA = Government Performance and Results Act of 1993
- EDGAR = Education Department General Administrative Regulations
- 2 CFR 200 = Uniform Administrative Requirements, Costs Principles, and Audit Requirements for Federal Awards
- IPE = Individualized Plan for Employment
- MIS = Management Information System
- RFP = Request for Proposal
Following is a list of project specific activities recommended for new AIVRS directors to complete, to aide in their understanding of their AIVRS project, and move forward in achieving its goals and objectives.
Review Your AIVRS Program Grant Award
It is important that the AIVRS Project Director and staff understand all aspects of the approved grant proposal as it informs and guides all project activities. It is recommended that one of the first things you do as a new AIVRS Director is review and familiarize yourself with the entire grant proposal, including the annual federal and non-federal budgets and budget justifications.
- First, Goals and Objectives
- Are the project goals specific?
- Are the project goals measurable?
- Are the project goals achievable?
- Are the project goals relevant?
- Are the project goals time bound?
If you answer no to any of the above questions or determine a need to amend a project goal, see the Federal section of the toolkit to learn the process. You will need to work with your assigned RSA Project Officer to approve any amendments to a project goal. Toolkit-Federal
- Second, Management Plan
- Is the management plan realistic to achieve the project goals and objectives on time and within budget?
- Are the time commitments of the key personnel appropriate and adequate to meet the project goals and objectives?
- Does the management plan clearly define the responsibilities of key personnel to achieve the project goals and objectives? Toolkit-Federal
- Are the timelines reasonable to achieve proposed milestones for accomplishing project tasks?
- Does the management plan clearly describe the order in which proposed goals and objectives will be completed?
- Is the management plan realistically designed to serve all eligible consumers, under an Individualized Plan for Employment (IPE), and assist them in achieving gainful employment in a timely manner?
If you answer no, to any of the above questions, you should work with your project officer to make revisions.
Keep your eyes on the management plan: revisit it every three months and consider the following questions:
- Are the proposed project accomplishments aligned with the timelines?
- Have any unanticipated challenges occurred that require adjustment of the timelines?
- Are any changes required to the overall plan of operation?
- Do you need to contact your RSA Project Officer? Toolkit-Federal
- Are you sharing project and consumer successes in the mandatory RSA reports to the federal government? Toolkit-Federal
- How are you expanding the AIVRS project based on successes and best practices?
- Is the AIVRS outreach coupled with dissemination of material, and does the marketing strategy promote the AIVRS project effectively?
- Is the AIVRS project reaching out to all potential consumers?
- How is your AIVRS project building local capacity to increase awareness and understanding about tribal members with disabilities?
- Is the AIVRS facility fully accessible to individuals with disabilities?
If you answer no to any of the above questions you should meet with the project staff and if needed, work with your assigned RSA Project Officer to amend your five-year management plan. It is recommended that the AIVRS project staff utilize the existing management plan, in the development of an annual strategic plan. The rational of an annual strategic plan is to determine the need for amendments to grant proposed goals and objectives, and to determine if adequate resources are available to serve all eligible consumers. Toolkit-Federal
- Third, Evaluation Plan
- 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 evaluation plan designed in alignment with the proposed goals and objectives?
- What qualitative and quantitative data will be collected?
- Who will be responsible for the collection, management, and analysis of the project data?
- Are the evaluation tools valid, reliable, and appropriate for the AIVRS project?
- Will the AIVRS project use an electronic software for case management?
- Does the evaluation plan include a consumer satisfaction survey to evaluate project 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 project 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 number of consumers served annual from 50 to 20, you need to get approval from your RSA project officer.
- Fourth, Fiscal Management
To ensure proper Fiscal Management the AIVRS project director must understand the detailed information of each annual federal and non-federal budget and budget justification. It is also recommended that the AIVRS project 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 compliance with the 2 CFR 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal awards occurs.
The Federal share is ninety percent of the total cost of the AIVRS project and the mandatory non-Federal share (Match) is ten percent of the total cost of the AIVRS project. Other important elements of correct AIVRS fiscal management include:
- Tribal Indirect Cost Rate Agreement approved by the Federal Government: The approved Indirect Cost Rate is used to calculate the funds that will be used by the tribe for administrative oversight of the AIVRS project
- RSA approval for tribal and/or AIVRS project director’s access to the G-5 and Management Information System (MIS)
- Tribal designation of authorized personnel responsible for AIVRS project drawdown of funds and documenting tribal ten percent match for reporting purposes
- Use of internal AIVRS project cuff accounting to monitor all expenditures
- A “cuff” account is a single entry accounting method to track expenses so an AIVRS director can compare project expenses with the tribal accounting department expenses
- RSA approval process to amend the AIVRS project federal budgets. Toolkit-Federal
- Fifth, Design Section
When reviewing the Design Section of the grant proposal the goal is to become familiar with AIVRS project plans to collaborate with appropriate existing service providers or agencies to better serve all eligible consumers as they strive to become gainfully employed. To learn more about who the project partners and stakeholders are, review the support/commitment letters in the appendices of the grant. If the AIVRS project is designed as a “consortia” to 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, including plans to support the AIVRS project with available resources for greater impact on tribal members with disabilities to prepare for and achieve suitable employment.
Building effective collaboration requires time, trust building, respect, commitment, communication, and flexibility. Identification of appropriate partnerships/stakeholders is important in reference to resources, abilities, reputation, and willingness to coordinate services in order to provide exemplary services to applicants and consumers of the AIVRS project, and avoid the duplication of services.
If you plan to establish and use an 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 project, as well as providing feedback for the improvement and expansion of VR services. The following is a list of projects and agencies to consider for AIVRS project partnerships/stakeholders. Toolkit-Federal
- State VR Agency
- State Rehabilitation Council
- 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)
- Local primary employers (Indian Health Services, Schools, Bureau of Indian Affairs, Tribal Governments)
- Tribal/Federal programs (Grants and Scholarships, Headstart, WIOA, TANF, Community Health Representatives, Behavioral Health, Social Services, TERO)
- Non-profit organizations
- Sixth, Personnel
Review the Personnel section of the AIVRS grant proposal for information on staff training and professional development activities. Project regulations at 34 CFR §371.41(a)(1) allow for expenditures for staff development. Your AIVRS personnel development plans may include identification and collaboration with appropriate resources to assist with professional staff development; for example, Northwest Indian College Tribal Vocational Rehabilitation Institute, Consortia of Administrators for Native American Rehabilitation (CANAR), and provisions detailed in the cooperative agreement between the AIVRS project and the state VR agency.
Professional Development (PD) is an ongoing learning process that helps keep project staff abreast of new concepts and ideas in their respective professions and helps individuals earn or maintain professional credentials (i.e. Certified Rehabilitation Counselor (CRC)). The completion of formal coursework, that leads to academic degrees or continuing education units and credits, may be used to document staff development in individual employee personnel records. Training and PD may be obtained through conference participation, informal learning opportunities, formal coursework, webinars, and online training.
The AIVRS project investment in staff professional development will enhance skills and expand professional attributes of the AIVRS staff; increase job retention and decrease employment gaps; promote confidence in the performance of work duties; enhance the delivery of quality VR consumer services; assist in improving consumer employment outcomes; and improve AIVRS project performance. Keep in mind that professional development goals need to support and align with the project’s mission, needs, goals, and provision of quality and culturally appropriate services for tribal members with disabilities. In addition, review your project management plan to ensure that professional development activities do not cause any unnecessary interruptions in consumer services.
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 developed 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 project employee’s professional and personal growth:
- Conduct self-assessment of staff 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)
- Determine how an individual’s disability is an impediment to employment
- Case management
- VR rules and regulations
- Interviewing and counseling skills
- Joint development of the professional development goals by the supervisor and employee
- Execute and monitor the employee professional development plan
- Supervisor and employee meet upon completion of the professional development plan to determine outcomes and benefits