State Plan for FY 2009-2011 and Program Review of Statewide AT Programs

State Plan for FY 2009-State Plan for FY 2009-2011 and2011 and

Program Review of Program Review of Statewide AT ProgramsStatewide AT Programs

Jeremy BuzzellJeremy Buzzell

andand

Robert GroenendaalRobert Groenendaal

PART 2

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Overview of State Plan for AT

A.A. Identification and Description of Lead Agency and Identification and Description of Lead Agency and Implementing Entity; Change in Lead Agency or Implementing Entity; Change in Lead Agency or Implementing EntityImplementing Entity

B.B. Advisory Council, Budget Allocations, and Advisory Council, Budget Allocations, and Identification of Activities ConductedIdentification of Activities Conducted

C.C. State Financing ActivitiesState Financing ActivitiesD.D. Device Reutilization ActivitiesDevice Reutilization ActivitiesE.E. Device Loan ActivityDevice Loan ActivityF.F. Device Demonstration ActivityDevice Demonstration ActivityG.G. State Leadership ActivitiesState Leadership ActivitiesH.H. Assurances, Performance Measures, SignaturesAssurances, Performance Measures, Signatures

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Overview of Program Review

A review assesses two “Core A review assesses two “Core Components” of how the state plan is Components” of how the state plan is implemented: implemented: Core Component 1 – Program Core Component 1 – Program ManagementManagement• Core Component 2 – Program Core Component 2 – Program PerformancePerformance

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Core Components of Program Review

Elements of Program Elements of Program ManagementManagement• Fiscal ManagementFiscal Management• Personnel ManagementPersonnel Management• Contract OversightContract Oversight• Consumer-Consumer-responsivenessresponsiveness

Elements of Program Elements of Program PerformancePerformance• Increasing access to, Increasing access to, acquisition of, and acquisition of, and knowledge about ATknowledge about AT• Statewideness and Statewideness and comprehensivenesscomprehensiveness• Measurable goalsMeasurable goals

Lead Agency and Implementing Entity

Information Required in State PlanInformation Required in State Plan

Selection and Participation in Selection and Participation in Program ReviewProgram Review

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State Plan: Identification and Description of Lead Agency

1.1. Name Given to Statewide AT Program. [Text box]Name Given to Statewide AT Program. [Text box]2.2. Website dedicated to Statewide AT Program. [Text box]Website dedicated to Statewide AT Program. [Text box]3.3. Name and Address of Lead Agency. [Text box]Name and Address of Lead Agency. [Text box]4.4. Name, Title, and Contact Information for Lead Agency Name, Title, and Contact Information for Lead Agency

Certifying Representative. [Text box]Certifying Representative. [Text box]5.5. Information about Program Director at Lead Agency. Information about Program Director at Lead Agency.

[Text box][Text box]6.6. Information about Program Contact(s) at Lead Agency. Information about Program Contact(s) at Lead Agency.

[Text box][Text box]7.7. Telephone at Lead Agency for Public. [Text box]Telephone at Lead Agency for Public. [Text box]8.8. E-mail at Lead Agency for Public. [Text box]E-mail at Lead Agency for Public. [Text box]

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9. Select the most appropriate descriptor of the 9. Select the most appropriate descriptor of the agency/division/bureau directly responsible for the agency/division/bureau directly responsible for the Statewide AT Program within the Lead Agency. Statewide AT Program within the Lead Agency.

[Drop-down menu][Drop-down menu] General Vocational Rehabilitation AgencyGeneral Vocational Rehabilitation Agency Vocational Rehabilitation for the Blind AgencyVocational Rehabilitation for the Blind Agency State Education AgencyState Education Agency UniversityUniversity Health and Human Services AgencyHealth and Human Services Agency Aging and Disability (or similar) AgencyAging and Disability (or similar) Agency OtherOther

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10. If “Other” was selected for question 9, identify and 10. If “Other” was selected for question 9, identify and describe the agency. [Text box]describe the agency. [Text box]11. Does your Lead Agency contract with an 11. Does your Lead Agency contract with an Implementing Entity to carry out the Statewide AT Implementing Entity to carry out the Statewide AT Program on it’s behalf? [yes/no drop-down menu] Program on it’s behalf? [yes/no drop-down menu]

If you answered “no” to question 11, you may skip ahead If you answered “no” to question 11, you may skip ahead to the items on change in Lead Agency or Implementing to the items on change in Lead Agency or Implementing Entity. Otherwise, you must answer the following Entity. Otherwise, you must answer the following questions. questions.

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State Plan: Identification and Description of Implementing Entity

12. Name and Address of Implementing Entity. 12. Name and Address of Implementing Entity. [Text box][Text box]13. Information about Program Director at the 13. Information about Program Director at the Implementing Entity. [Text box]Implementing Entity. [Text box]14. Information about Program Contact(s) at 14. Information about Program Contact(s) at Implementing Entity. [Text box]Implementing Entity. [Text box]15. Telephone at Implementing Entity for Public. 15. Telephone at Implementing Entity for Public. [Text box][Text box]16. E-mail at Implementing Entity for Public. [Text 16. E-mail at Implementing Entity for Public. [Text box]box]

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17. Select the most appropriate descriptor of the type of organization that is the Implementing Entity. 17. Select the most appropriate descriptor of the type of organization that is the Implementing Entity. [Drop-down menu][Drop-down menu]

AgrAbility ProgramAgrAbility Program Alliance for Technology Access CenterAlliance for Technology Access Center Bank or other financial institutionBank or other financial institution Easter SealsEaster Seals Independent Living CenterIndependent Living Center Institution of Higher EducationInstitution of Higher Education Non-categorical disability organizationNon-categorical disability organization Organization that primarily serves individuals who are blind or visually impairedOrganization that primarily serves individuals who are blind or visually impaired Organization that primarily serves individuals who are deaf or hard of hearingOrganization that primarily serves individuals who are deaf or hard of hearing Organization that primarily serves individuals with developmental disabilitiesOrganization that primarily serves individuals with developmental disabilities Organization that primarily serves individuals with physical disabilitiesOrganization that primarily serves individuals with physical disabilities Organization focused specifically on providing ATOrganization focused specifically on providing AT Protection and Advocacy organizationProtection and Advocacy organization UCPUCP OtherOther

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If applicable, the national affiliation of an entity If applicable, the national affiliation of an entity should be selected before other descriptors. These should be selected before other descriptors. These include:include: AgrAbility ProgramAgrAbility Program Alliance for Technology Access CenterAlliance for Technology Access Center Easter SealsEaster Seals Independent Living CenterIndependent Living Center Protection and Advocacy organizationProtection and Advocacy organization UCPUCP

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If a private entity has no national affiliation, use the If a private entity has no national affiliation, use the following more general descriptors.following more general descriptors. Bank or other financial institutionBank or other financial institution Non-categorical disability organizationNon-categorical disability organization Organization that primarily serves individuals…Organization that primarily serves individuals… Organization focused specifically on providing ATOrganization focused specifically on providing AT OtherOther 18. If “Other” was selected, identify and describe the entity. 18. If “Other” was selected, identify and describe the entity. [Text box][Text box]

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State Plan: Implementing Entity and Lead Agency

19. Describe the mechanisms established to ensure 19. Describe the mechanisms established to ensure coordination of activities and collaboration between the coordination of activities and collaboration between the Implementing Entity and the state. [Text box]Implementing Entity and the state. [Text box]

Identify the mechanism used and how the Lead Agency Identify the mechanism used and how the Lead Agency provides oversight and holds the Implementing Entity provides oversight and holds the Implementing Entity accountable.accountable.

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State Plan: Change in Lead Agency or Implementing Entity

Is the Lead Agency [Implementing Entity] named in this State Is the Lead Agency [Implementing Entity] named in this State Plan a new or different Lead Agency from the one designated Plan a new or different Lead Agency from the one designated by the Governor in your previous State Plan? [yes/no drop-by the Governor in your previous State Plan? [yes/no drop-down menu]down menu]

The “previous State Plan” was from October 1, 2005 until the The “previous State Plan” was from October 1, 2005 until the submission of this State Plan. submission of this State Plan. If a change in Lead Agency [Implementing Entity] already has If a change in Lead Agency [Implementing Entity] already has been approved by RSA the state can select “no.” been approved by RSA the state can select “no.” If you select “yes,” the information provided throughout this If you select “yes,” the information provided throughout this State Plan should pertain to the new Lead Agency State Plan should pertain to the new Lead Agency [Implementing Entity]. [Implementing Entity].

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State Plan: Change in Lead Agency or Implementing Entity

Explain why the Lead Agency [Implementing Explain why the Lead Agency [Implementing Entity] previously designated by your state should Entity] previously designated by your state should not serve as the Lead Agency. [Text box]not serve as the Lead Agency. [Text box]

Explain why the Lead Agency [Implementing Explain why the Lead Agency [Implementing Entity] newly designated by your state should serve Entity] newly designated by your state should serve as the Lead Agency. [Text box]as the Lead Agency. [Text box]

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Role of Lead Agencies and Role of Lead Agencies and Implementing Entities in Program Implementing Entities in Program

ReviewsReviews

• The LEAD AGENCY is being The LEAD AGENCY is being reviewed.reviewed.

• Participation from BOTH the Lead Participation from BOTH the Lead Agency and Implementing Entity is Agency and Implementing Entity is expected.expected.

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How are Lead Agencies selected for review?

Random selection of an equal number of Random selection of an equal number of grantees in two categories:grantees in two categories:

(1) Grantees that have a title III AFP, serve (1) Grantees that have a title III AFP, serve as the Lead Agency for the AFP, and claim as the Lead Agency for the AFP, and claim the AFP in State Plan; orthe AFP in State Plan; or

(2) Grantees that don’t meet the criteria in (1).(2) Grantees that don’t meet the criteria in (1).

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How are Lead Agencies selected for review?

Exceptions to random selection:Exceptions to random selection:• Recent (major) change in State Plan Recent (major) change in State Plan (ex: Change in Lead Agency or (ex: Change in Lead Agency or Implementing Entity).Implementing Entity).• Recent major disaster.Recent major disaster.• RSA is concerned.RSA is concerned.

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How many Lead Agencies are selected for review?

• 6 grantees per cycle (3 x 3)6 grantees per cycle (3 x 3)• A “cycle” is a fiscal year (Oct. 1 to Sept. 30)A “cycle” is a fiscal year (Oct. 1 to Sept. 30)• 9 weeks per grantee (some reviews may 9 weeks per grantee (some reviews may overlap)overlap)• First year of reviews: First year of reviews:

• Jan. 1 to Sept. 30Jan. 1 to Sept. 30• Only 3 reviewsOnly 3 reviews

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What happens when a Lead Agency is selected?

• RSA notifies grantee in spring prior to RSA notifies grantee in spring prior to next cycle.next cycle.• RSA and grantee negotiate 9-week RSA and grantee negotiate 9-week window within next cycle.window within next cycle.• RSA recruits third-party (peer) RSA recruits third-party (peer) reviewers.reviewers.• Grantee begins preparing for review.Grantee begins preparing for review.

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Core Components of Program Review

Elements of Program Elements of Program ManagementManagement• Fiscal ManagementFiscal Management• Personnel ManagementPersonnel Management• Contract OversightContract Oversight• Consumer-Consumer-responsivenessresponsiveness

Elements of Program Elements of Program PerformancePerformance• Increasing access to, Increasing access to, acquisition of, and acquisition of, and knowledge about ATknowledge about AT• Statewideness and Statewideness and comprehensivenesscomprehensiveness• Measurable goalsMeasurable goals

Personnel

Identification in State PlanIdentification in State Plan

Participation in Program ReviewParticipation in Program Review

Review of Personnel ManagementReview of Personnel Management

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State Plan: Identification and Description of Lead Agency and Implementing Entity Personnel

Name, Title, and Contact Information for Lead Agency Name, Title, and Contact Information for Lead Agency Certifying Representative. [Text box]Certifying Representative. [Text box]

Information about Program Director at Lead Agency Information about Program Director at Lead Agency [Implementing Entity]. [Text box][Implementing Entity]. [Text box]

Information about Program Contact(s) at Lead Agency Information about Program Contact(s) at Lead Agency [Implementing Entity]. [Text box][Implementing Entity]. [Text box]

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Program Review: Personnel Participation

• Participation of all personnel listed in the Participation of all personnel listed in the State Plan is required to some degree (see State Plan is required to some degree (see exception in next bullet). exception in next bullet).

• Participation of the Certifying Participation of the Certifying Representative is encouraged but not Representative is encouraged but not required.required.

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Program Review: Personnel Management

OMB Circulars:OMB Circulars:• compensation to personnel must be reasonablecompensation to personnel must be reasonable• charges to Federal awards for salaries and wages are based charges to Federal awards for salaries and wages are based

on documented payrolls on documented payrolls • charges for salaries and wages of employees who work charges for salaries and wages of employees who work

solely on a single Federal award are supported by periodic solely on a single Federal award are supported by periodic certificationscertifications

• charges for salaries and wages of employees who work on charges for salaries and wages of employees who work on multiple activities are supported by personnel activity multiple activities are supported by personnel activity reportsreports

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Submit either:Submit either:

(A)(A) Position descriptions of record for those Position descriptions of record for those being paid with grant funds and personnel being paid with grant funds and personnel activity reports for them; ORactivity reports for them; OR

(B)(B) Synopsis for key personnel Synopsis for key personnel describing his describing his or her role and responsibilities or her role and responsibilities associated associated with the grantwith the grant..

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What RSA is looking for:What RSA is looking for:• Appropriate number of personnelAppropriate number of personnel• Appropriate time commitments of Appropriate time commitments of

personnelpersonnel• Appropriate duties for personnelAppropriate duties for personnel

Role of Consumers in Statewide AT Program

State Plan Requirements related to State Plan Requirements related to Advisory CouncilAdvisory Council

Review of Consumer-responsivenessReview of Consumer-responsiveness

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AT Act: Consumer-responsivenessAT Act: Consumer-responsiveness

Comprehensive statewide program means: Comprehensive statewide program means: a a consumer responsiveconsumer responsive program of technology- program of technology-related assistance for individuals with disabilities, related assistance for individuals with disabilities, implemented by a State, and equally available to implemented by a State, and equally available to all individuals with disabilities residing in the all individuals with disabilities residing in the State, regardless of their type of disability, age, State, regardless of their type of disability, age, income level, or location of residence in the State, income level, or location of residence in the State, or the type of assistive technology device or or the type of assistive technology device or assistive technology service required. assistive technology service required. Sec. 3Sec. 3

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AT Act: Consumer-responsiveness

AT Act definition:AT Act definition:• easily accessible to, and usable by easily accessible to, and usable by

consumersconsumers• involves consumers in decisions related to involves consumers in decisions related to

the maintenance, improvement, and the maintenance, improvement, and evaluation of the programevaluation of the program

• responds to the needs of consumers in an responds to the needs of consumers in an appropriate mannerappropriate manner

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AT Act: Consumer-responsiveness

State plan requirements:State plan requirements:• Advisory councilAdvisory council• Assurance of ADA complianceAssurance of ADA compliance• Assurance of 508 complianceAssurance of 508 compliance

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AT Act: Advisory Council

Requirements related to compositionRequirements related to composition• Agency representativesAgency representatives• Consumer representatives (diversity and majority)Consumer representatives (diversity and majority)

Requirements related to roleRequirements related to role

““advice to the State for, planning of, advice to the State for, planning of, implementationimplementation

of, and evaluation of the activities carried out of, and evaluation of the activities carried out throughthrough

the grant, including setting the measurable goals”the grant, including setting the measurable goals”

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State Plan: Advisory Council

1. In accordance with section 4(c)(2) of the AT Act of 1998, 1. In accordance with section 4(c)(2) of the AT Act of 1998, as amended our state has a consumer-majority advisory as amended our state has a consumer-majority advisory council that provides consumer-responsive, consumer-council that provides consumer-responsive, consumer-driven advice to the state for planning of, implementation driven advice to the state for planning of, implementation of, and evaluation of the activities carried out through the of, and evaluation of the activities carried out through the grant, including setting measurable goals. This advisory grant, including setting measurable goals. This advisory council is geographically representative of the State and council is geographically representative of the State and reflects the diversity of the State with respect to race, reflects the diversity of the State with respect to race, ethnicity, types of disabilities across the age span, and ethnicity, types of disabilities across the age span, and users of types of services that an individual with a users of types of services that an individual with a disability may receive. [yes/no drop-down menu]disability may receive. [yes/no drop-down menu]

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2. The advisory council includes a representative of the designated State agency, 2. The advisory council includes a representative of the designated State agency, as defined in section 7 of the Rehabilitation Act of 1973 (29 U.S.C. 705); as defined in section 7 of the Rehabilitation Act of 1973 (29 U.S.C. 705); [Drop-down menu][Drop-down menu]

3. The advisory council includes a representative of the State agency for 3. The advisory council includes a representative of the State agency for individuals who are blind (within the meaning of section 101 of that Act individuals who are blind (within the meaning of section 101 of that Act (29 U.S.C. 721)); [Drop-down menu] (29 U.S.C. 721)); [Drop-down menu]

4. The advisory council includes a representative of a State center for independent 4. The advisory council includes a representative of a State center for independent living described in part C of title VII of the Rehabilitation Act of 1973 (29 living described in part C of title VII of the Rehabilitation Act of 1973 (29 U.S.C. 796f et seq.); [Drop-down menu] U.S.C. 796f et seq.); [Drop-down menu]

5. The advisory council includes a representative of the State workforce 5. The advisory council includes a representative of the State workforce investment board established under section 111 of the Workforce investment board established under section 111 of the Workforce Investment Act of 1998 (29 U.S.C. 2821); [Drop-down menu] Investment Act of 1998 (29 U.S.C. 2821); [Drop-down menu]

6. The advisory council includes a representative of the State educational agency, 6. The advisory council includes a representative of the State educational agency, as defined in section 9101 of the Elementary and Secondary Education Act as defined in section 9101 of the Elementary and Secondary Education Act of 1965; [Drop-down menu]of 1965; [Drop-down menu]

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7. The advisory council includes other 7. The advisory council includes other representatives (list below). [Text box]representatives (list below). [Text box]

8. The advisory council includes the following 8. The advisory council includes the following number of individuals with disabilities that use number of individuals with disabilities that use assistive technology or their family members or assistive technology or their family members or guardians: [Number field]guardians: [Number field]

9. If the Statewide AT Program does not have the 9. If the Statewide AT Program does not have the composition and representation required under composition and representation required under section 4(c)(2)(B), explain here. [Text box]section 4(c)(2)(B), explain here. [Text box]

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Program Review: Role of Advisory Council/Consumers

• No role for consumers not affiliated No role for consumers not affiliated with the advisory council.with the advisory council.

• Participation by the advisory council is Participation by the advisory council is encouraged but not required.encouraged but not required.

• Dissemination of final results to Dissemination of final results to advisory council is expected.advisory council is expected.

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Program Review: Consumer-responsiveness

Submit to RSA:Submit to RSA:• A description of advisory council:A description of advisory council:

• List all membersList all members• Describe members (not personally Describe members (not personally

identifiable)identifiable)• Describe council operationsDescribe council operations

• Description of any other consumer feedback Description of any other consumer feedback mechanismsmechanisms

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Submit to RSA:Submit to RSA:• A description of how the grantee A description of how the grantee

ensures compliance with ADA ensures compliance with ADA (including subcontracts, if applicable)(including subcontracts, if applicable)

• A description of how the grantee A description of how the grantee ensures compliance with 508 ensures compliance with 508 (including subcontracts)(including subcontracts)

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What RSA is looking for:What RSA is looking for:• Completeness of councilCompleteness of council• Role of councilRole of council• How grantee ensures ongoing 508 and How grantee ensures ongoing 508 and

ADA complianceADA compliance

Use of Funds

Funding Information in State PlanFunding Information in State Plan

Review of Fiscal ManagementReview of Fiscal Management

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Use of FundsRequirements in AT ActRequirements in AT Act::• 60/40%, 70/30%, 5%60/40%, 70/30%, 5%• 10% indirect limitation10% indirect limitation• Can’t use to purchase AT for individuals Can’t use to purchase AT for individuals • State plan assurance that the funds are expended in accordance State plan assurance that the funds are expended in accordance with AT Actwith AT Act• State plan description of planned tracking procedures for State plan description of planned tracking procedures for expendituresexpenditures• State Plan assurance you have fiscal control and accounting State Plan assurance you have fiscal control and accounting procedures necessary to ensure proper accounting of fundsprocedures necessary to ensure proper accounting of funds• Proposed budget allocations in State PlanProposed budget allocations in State Plan

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State Plan: Proposed Budget Allocations

State Financing Activities [Drop-down menu]State Financing Activities [Drop-down menu]Device Reutilization Activities [Drop-down menu]Device Reutilization Activities [Drop-down menu]Device Loan Activity [Drop-down menu]Device Loan Activity [Drop-down menu]Device Demonstration Activity [Drop-down menu]Device Demonstration Activity [Drop-down menu]State Leadership Activities [Drop-down menu] State Leadership Activities [Drop-down menu] Claiming ComparabilityClaiming Comparability Claiming FlexibilityClaiming Flexibility $1 to $10,000$1 to $10,000 $10,001 to $20,000$10,001 to $20,000 $20,001 to $30,000 …$20,001 to $30,000 … $90,001 to $100,000$90,001 to $100,000 More than $100,000 More than $100,000

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State Plan: Proposed Budget Allocations

For every activity for which you selected For every activity for which you selected “claiming comparability,” describe the “claiming comparability,” describe the comparable activity: [text box]comparable activity: [text box]

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State Plan: Tracking Use of Funds

Describe your planned procedures for Describe your planned procedures for trackingtracking

expenditures for State-level and expenditures for State-level and State Leadership Activities: [Text State Leadership Activities: [Text box]box]

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Program Review: Fiscal Management

In addition to State Plan requirements . . .In addition to State Plan requirements . . .

EDGAR requirementsEDGAR requirements::• Fiscal control and accounting procedures to insure proper Fiscal control and accounting procedures to insure proper disbursement of and accounting for Federal funds and adequate disbursement of and accounting for Federal funds and adequate to establish that such funds have not been used in violation of to establish that such funds have not been used in violation of applicable statutes applicable statutes • Records that fully show the amount of funds under the grant, Records that fully show the amount of funds under the grant, how the grantee uses the funds, the total cost of the project, the how the grantee uses the funds, the total cost of the project, the share of the cost provided by other sources, and other records to share of the cost provided by other sources, and other records to facilitate an effective auditfacilitate an effective audit• Audits in accordance with OMB A-133.Audits in accordance with OMB A-133.

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Program Review: Fiscal Management

Submit to RSA:Submit to RSA:• Expenditure reportExpenditure report• Approved indirect cost rate agreement/cost allocation plan OR Approved indirect cost rate agreement/cost allocation plan OR questionnaire provided by RSA (applies to both Lead Agencies and questionnaire provided by RSA (applies to both Lead Agencies and Implementing Entities)Implementing Entities)• Copies of most recent audit reports OR questionnaire provided by Copies of most recent audit reports OR questionnaire provided by RSA (applies to both Lead Agencies and Implementing Entities)RSA (applies to both Lead Agencies and Implementing Entities)

In addition, RSA will look at SF-269s and GAPS records.In addition, RSA will look at SF-269s and GAPS records.

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Program Review: Expenditure ReportProgram Review: Expenditure Report

• 1 for Lead Agency, 1 for Implementing Entity1 for Lead Agency, 1 for Implementing Entity• Most recent annual award for which obligation and Most recent annual award for which obligation and liquidation is complete.liquidation is complete.• Annual award = may have been spent over 2 years.Annual award = may have been spent over 2 years.• There is no “format,” but RSA must be able to There is no “format,” but RSA must be able to understand it.understand it.• It must account for all funds – including those It must account for all funds – including those brought into the program from other sources.brought into the program from other sources.

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Expenditure ReportExpenditure Report

What RSA is looking for:What RSA is looking for:• Existence, quality, legitimacy of reportExistence, quality, legitimacy of report• Tracking of 60/40 or 70/30 and 5%Tracking of 60/40 or 70/30 and 5%• Compliance with indirect cost limitsCompliance with indirect cost limits

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Program Review: Indirect Cost Rates

What RSA is looking for:What RSA is looking for:• Existence of agreementExistence of agreement• Appropriate kind of agreementAppropriate kind of agreement• Handling of indirect if Implementing Entity Handling of indirect if Implementing Entity is involvedis involved• Amount of indirect will be seen in Amount of indirect will be seen in expenditure reportexpenditure report

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Program Review: Audits

What RSA is looking for:What RSA is looking for:• An audit was done (if required)An audit was done (if required)• Findings of the auditFindings of the audit• Resolution of findingsResolution of findings

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SF-269s and GAPS Records

What RSA is looking for:What RSA is looking for:• Full use of fundsFull use of funds• Timely use of fundsTimely use of funds• Completeness and accuracy of Completeness and accuracy of

financial reportsfinancial reports

Involvement of Other Entities

State Plan requirements related to State Plan requirements related to involvement of other entitiesinvolvement of other entities

Program Review of Contract Program Review of Contract OversightOversight

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AT Act Requirements Related to Other Entities

• State plan must describe how public and State plan must describe how public and private entities were involved in developing private entities were involved in developing the State Plan and will be involved in the State Plan and will be involved in implementation (including resources)implementation (including resources)• State plan must describe state supportState plan must describe state support• State leadership activities include State leadership activities include coordination and collaborationcoordination and collaboration• Data collection related to leveraged fundsData collection related to leveraged funds

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State Plan: Identifying Involvement of Other Entities

For each activity:For each activity:

Who conducts this activity? (Check all that apply)Who conducts this activity? (Check all that apply) The Statewide AT Program [check-box to indicate The Statewide AT Program [check-box to indicate “yes”]“yes”] Other entities (e.g., contractors) [check-box to Other entities (e.g., contractors) [check-box to indicate “yes”]indicate “yes”]

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• The Statewide AT Program provides and/or receives the following The Statewide AT Program provides and/or receives the following support (choose all that apply):support (choose all that apply):

• Provides financial support to other entities via an agreement with the Provides financial support to other entities via an agreement with the Statewide AT Program. [check-box to indicate “yes”]Statewide AT Program. [check-box to indicate “yes”]

• Provides in-kind support to other entities via an agreement with the Provides in-kind support to other entities via an agreement with the Statewide AT Program. [check-box to indicate “yes”]Statewide AT Program. [check-box to indicate “yes”]

• Receives financial support from the state. [check-box to indicate Receives financial support from the state. [check-box to indicate “yes”]“yes”]

• Receives in-kind support from the state. [check-box to indicate “yes”] Receives in-kind support from the state. [check-box to indicate “yes”] • Receives financial support from private entities. [check-box to indicate Receives financial support from private entities. [check-box to indicate

“yes”]“yes”]• Receives in-kind support from private entities. [check-box to indicate Receives in-kind support from private entities. [check-box to indicate

“yes”]“yes”]

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• The Statewide AT Program provides and/or receives the following The Statewide AT Program provides and/or receives the following support (choose all that apply): CONT’Dsupport (choose all that apply): CONT’D

• Coordinates and collaborates with other entities for the purpose of Coordinates and collaborates with other entities for the purpose of establishing a new program or service. [check-box to indicate “yes”]establishing a new program or service. [check-box to indicate “yes”]

• Coordinates and collaborates with other entities for the purpose of Coordinates and collaborates with other entities for the purpose of expanding an existing program or service. [check-box to indicate expanding an existing program or service. [check-box to indicate “yes”]“yes”]

• Coordinates and collaborates with other entities for the purpose of Coordinates and collaborates with other entities for the purpose of reducing duplication of programs or services. [check-box to indicate reducing duplication of programs or services. [check-box to indicate “yes”] “yes”]

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If you conduct this activity by providing financial or in-kind If you conduct this activity by providing financial or in-kind support to other entities, identify the kinds of entities you support to other entities, identify the kinds of entities you support in column (a) of the following table.support in column (a) of the following table.If you receive financial or in-kind support from the state to If you receive financial or in-kind support from the state to conduct this activity, identify the state entities that provide conduct this activity, identify the state entities that provide this support in column (b) of the following table.this support in column (b) of the following table.If you receive financial or in-kind support from private If you receive financial or in-kind support from private entities, identify the private entities that provide this support entities, identify the private entities that provide this support in column (c) of the following table.in column (c) of the following table.If you coordinate and collaborate with other entities in If you coordinate and collaborate with other entities in conducting this activity, identify those entities in column (d) conducting this activity, identify those entities in column (d) of the following table.of the following table.

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Other information related to Other information related to coordination and collaboration and coordination and collaboration and leveraging of funds is captured under leveraging of funds is captured under data collection.data collection.

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Program Review: Contract Oversight

EDGAR requires grantees to:EDGAR requires grantees to:• directly administer or supervise the administration directly administer or supervise the administration

of each projectof each project• have procedures for providing TA, evaluation and have procedures for providing TA, evaluation and

for performing other administrative for performing other administrative responsibilities necessary to ensure complianceresponsibilities necessary to ensure compliance

• monitor activities to assure compliance with monitor activities to assure compliance with applicable Federal requirements and that applicable Federal requirements and that performance goals are being achievedperformance goals are being achieved

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Submit either:Submit either:(A)(A) The state’s contract selection policies and a The state’s contract selection policies and a sample of contracts (selected by RSA after reviewing sample of contracts (selected by RSA after reviewing State Plan – Implementing Entity always is in State Plan – Implementing Entity always is in sample); ORsample); OR(B)(B) A synopsis of major contracts.A synopsis of major contracts.

This is contracts FROM and contracts TO the This is contracts FROM and contracts TO the grantee – but only those claimed in State Plan and grantee – but only those claimed in State Plan and

used for reporting dataused for reporting data

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Synopsis of major subcontracts (to and from) Synopsis of major subcontracts (to and from) includes:includes:• Amount of fundsAmount of funds• Kind of entity and qualificationsKind of entity and qualifications• Method for choosing entityMethod for choosing entity• Duties carried out by entityDuties carried out by entity• Any limitationsAny limitations• Methods of oversightMethods of oversight• Methods for collecting and reporting dataMethods for collecting and reporting data

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What RSA is looking for:What RSA is looking for:• Appropriate process for awardingAppropriate process for awarding• Appropriate entities receiving awardsAppropriate entities receiving awards• Appropriate oversight to protect Federal Appropriate oversight to protect Federal interests and ensure implementationinterests and ensure implementation• Relevant to the AT ActRelevant to the AT Act

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Process for Reviewing Program Management

• Submit all the previously described documents.Submit all the previously described documents.• RSA reviews the documents.RSA reviews the documents.• RSA discusses the documents via conference call RSA discusses the documents via conference call

(the grantee is responsible for bringing together (the grantee is responsible for bringing together the appropriate parties)the appropriate parties)

• RSA uses this information to answer questions RSA uses this information to answer questions about program management.about program management.

• Yes/no with explanation.Yes/no with explanation.

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Questions about Program Management

1. Does the grantee account for its funds accurately and completely in 1. Does the grantee account for its funds accurately and completely in accordance with EDGAR and the AT Act? accordance with EDGAR and the AT Act?

2. Does the grantee use its funds within the limitations of the AT Act?2. Does the grantee use its funds within the limitations of the AT Act?

3. Does the grantee obligate and liquidate its funds in a timely manner? If 3. Does the grantee obligate and liquidate its funds in a timely manner? If not, does the grantee have a plan for improving the timeliness of not, does the grantee have a plan for improving the timeliness of obligations and liquidations?obligations and liquidations?

4. Does the grantee maximize the use of its funds (i.e., does not return 4. Does the grantee maximize the use of its funds (i.e., does not return funds to the Department)? If not, does the grantee have a plan for funds to the Department)? If not, does the grantee have a plan for increasing the amount of funds it uses?increasing the amount of funds it uses?

5. Does the grantee comply with indirect cost requirements?5. Does the grantee comply with indirect cost requirements?

6. Does the grantee comply with audit requirements?6. Does the grantee comply with audit requirements?

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7. Does the grantee select subcontractors in accordance with 7. Does the grantee select subcontractors in accordance with generally accepted practice? If not, does the grantee have a plan generally accepted practice? If not, does the grantee have a plan for improving its selection process?for improving its selection process? 8. Does the grantee exercise appropriate fiscal and performance 8. Does the grantee exercise appropriate fiscal and performance oversight of its subcontracts? If not, does the grantee have a oversight of its subcontracts? If not, does the grantee have a plan for improving its oversight?plan for improving its oversight?

9. Is the inclusion of subcontracts received by the grantee in the 9. Is the inclusion of subcontracts received by the grantee in the grantee’s State Plan and annual data justified? grantee’s State Plan and annual data justified?

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10. Does the grantee distribute the time of its 10. Does the grantee distribute the time of its personnel appropriately based on their personnel appropriately based on their responsibilities? If not, does the grantee have a responsibilities? If not, does the grantee have a plan to distribute time more appropriately? plan to distribute time more appropriately?

11. Does the grantee support with grant funds only 11. Does the grantee support with grant funds only personnel with responsibilities germane to the personnel with responsibilities germane to the grant? grant?

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12. Does the grantee have processes and procedures to ensure 12. Does the grantee have processes and procedures to ensure ongoing physical and programmatic accessibility? If not, does ongoing physical and programmatic accessibility? If not, does the grantee have a plan for improving its physical and the grantee have a plan for improving its physical and programmatic accessibility?programmatic accessibility?

13. Does the grantee have and use an advisory council that meets 13. Does the grantee have and use an advisory council that meets

the requirements of the AT Act and is involved in the Statewide the requirements of the AT Act and is involved in the Statewide AT Program as the AT Act intends? If not, does the grantee AT Program as the AT Act intends? If not, does the grantee have a plan for improving its advisory council?have a plan for improving its advisory council?

14. Is there evidence of other efforts at making the program more 14. Is there evidence of other efforts at making the program more

consumer-responsive?consumer-responsive?

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Assessing Compliance of Program Management

There is no overall rating of compliance.There is no overall rating of compliance.

For each element of Program Management, a For each element of Program Management, a grantee will receive 1 of 3 ratings:grantee will receive 1 of 3 ratings:

• CompliantCompliant• In Need of ImprovementIn Need of Improvement• Fails to substantially complyFails to substantially comply

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The rating is based on how RSA answers the The rating is based on how RSA answers the questions:questions:

• Initial question: Does the grantee maximize Initial question: Does the grantee maximize the use of its funds? the use of its funds? • Subquestion: If not, does the grantee have a Subquestion: If not, does the grantee have a plan for increasing the amount of funds it plan for increasing the amount of funds it uses?uses?

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• If the answer to the initial question is “Yes” – the If the answer to the initial question is “Yes” – the grantee is rated as compliant.grantee is rated as compliant.

• If the answer to the initial question is “No” – the If the answer to the initial question is “No” – the rating depends on the answer to the subquestion.rating depends on the answer to the subquestion.

• If the answer to the subquestion is “Yes” – the If the answer to the subquestion is “Yes” – the grantee is rated as in need of improvement.grantee is rated as in need of improvement.

• If the answer to the subquestion is “No” – the If the answer to the subquestion is “No” – the grantee is rated as failing to substantially comply.grantee is rated as failing to substantially comply.

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Questions for which “needs improvement” doesn’t apply:Questions for which “needs improvement” doesn’t apply: Does the grantee account for its funds accurately and completely?Does the grantee account for its funds accurately and completely? Does the grantee use its funds within the limitations of the AT Act?Does the grantee use its funds within the limitations of the AT Act? Does the grantee comply with indirect cost requirements?Does the grantee comply with indirect cost requirements? Does the grantee comply with audit requirements?Does the grantee comply with audit requirements? Does the grantee support with grant funds only personnel with responsibilities Does the grantee support with grant funds only personnel with responsibilities

germane to the grant? germane to the grant? Is the inclusion of subcontracts received by the grantee in the grantee’s State Is the inclusion of subcontracts received by the grantee in the grantee’s State

Plan and NISAT data justified?Plan and NISAT data justified? Is there evidence of other efforts at making the program more consumer-Is there evidence of other efforts at making the program more consumer-

responsive? . . . is not rated at all responsive? . . . is not rated at all

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The onus is on the grantee to present The onus is on the grantee to present evidence/plan sufficient to get to a “yes” evidence/plan sufficient to get to a “yes”

answer.answer.

• RSA will ask questions or provide examples of RSA will ask questions or provide examples of sufficient evidence if needed.sufficient evidence if needed.• Grantee likely will know their status before the Grantee likely will know their status before the conversation is over.conversation is over.

Documents

State Plan for FY 2009-2011 and Program Review of Statewide AT Programs