Implementing RSA-911 Reporting: Training Series Objectives and Paperwork Reduction Act Overview

Case Service Report (RSA-911) RSA-PD-19-03 Program Year 2020 Implementation WINTAC/RSA Training Series (1/8)

Training Series Objectives 1. Explain the intent of PD-19-03 reporting requirements. 2. Assist State Vocational Rehabilitation (VR) agencies in the implementation of the Case Service Report (RSA-911). 3. When possible, share examples of what needs to live outside of RSA-911 reporting, in addition to the discussed data elements (e.g., source documentation). 4. Provide considerations and expectations during each training (e.g., policies State VR agencies need to establish and implement, tools and resources that are available, and internal controls). 2

Presenters Christopher Pope, RSA Rachel Anderson, WINTAC 3

Background and Implementation (1/8 Training Series) October 2019

Todays Training 1. Summary of Paperwork Reduction Act (PRA) process, comments, approvals, timeline, implementation, etc. 2. New RSA-911 layout and appendices 3. Deleted Data Elements and New Data Elements 4. RSA-911 Correction Procedures 5. RSA-911 PD 16-04 to PD 19-03 Crosswalk 6. RSA-911 Internal Controls 7. What is RSA doing to prepare for implementation? 8. Outline for upcoming RSA-911 training topics 9. Tools/resources 5

Paperwork Reduction Act (PRA) On October 1, 2018, RSA proposed changes to the RSA-911 through a Federal Register Notice, beginning 60 days of public comment. When the comment period closed on November 30, 2018, RSA had received comments from 26 entities (e.g., State VR agencies, CSAVR). Through a Federal Register Notice on February 15, 2019, RSA submitted the RSA-911 to the Office of Management and Budget (OMB) for approval, beginning 30 days of public comment. When the comment period closed on March 18, 2019, RSA received comments from seven entities. RSA issued the final version of the RSA-911 through PD 19-03 on May 6, 2019, signaling that implementation will begin in Program Year 2020. 6

Requesting RSA-911 Data Files State VR agencies and researchers may request the complete RSA-911 data file for the national VR program (based on respective PD and year). Requestors should email RSAData@ed.gov to request the data file and complete the Case Service Report (RSA-911) Data File Request form. RSA will review each request on a case-by-case basis. Prior to releasing RSA-911 Data Files, RSA takes every precaution to de- identify individuals with disabilities reported to ensure their identities are not disclosed. RSA will omit from all Data Files all direct identifiers (e.g., Social Security Numbers and Dates of Birth) as well as any characteristics that might lead to identification to protect the confidentiality of the individuals served by the VR program. 7

Case Service Report (RSA-911) RSA-PD-16-04 vs. RSA-PD-19-03

RSA-911 Overview Number of Data Elements o RSA deleted 94 Data Elements from PD 16-04 o RSA added 14 new Data Elements to PD 19-03 o Net gain of 80 fewer Data Elements that require reporting on PD 19-03 New Layout o Data Elements on PD 19-03 are numbered 1 through 407 (the 14 new Data Elements are numbered 394 through 407) o Deleted Data Elements from PD 16-04 will be left blank o RSA-911 in PD 19-03 has six Appendices o RSA-911 in PD 19-03 is Excel-based RSA will implement PD 19-03 for PY 2020 effective July 1, 2020. Expiration of OMB Approval (1820-0508): April 30, 2022 o RSA-911 will expire during PY 2021. 9

Deleted Data Elements PD 16-04 (1 of 3) At Application DE 3: Date Report Submitted DE 17: Living Arrangement DE 23-37, 393: Benefits at Application At Exit DE 348-349, 351-352, 358: Employment Outcome Results at Exit DE 361-375: Benefits at Exit Post Exit DE 380-382, 384, 387-388, 390-391: Employment Quarters After Exit o Example DE 381: Type of Employment Match - 1st Quarter After Exit o Example DE 390: Wages 4th Quarter After Exit 10

Deleted Data Elements PD 16-04 (2 of 3) At Individualized Plan for Employment (IPE) DE 48: Date of Most Recent or Amended IPE DE 75-76: School Status and Highest Education Level DE 80: Enrolled in State Adult Secondary School at the High ASE Level DE 83: Enrolled in Postsecondary or Graduate Education DE 91: Enrolled in a Career or Technical Training Program, Not Leading to a Recognized Credential DE 92: Enrolled in a Career or Technical Training Program, Leading to a Recognized Credential DE 101-102, 107-108, 113-114, 119-120, 125-126: Comparable Benefits Providers for Pre-Employment Transition Services o At IPE AND Potentially Eligible Students with Disabilities 11

Deleted Data Elements PD 16-04 (3 of 3) At Time of Training or Career Service DE for Training Provided by VR Agency Staff DE 129: Graduate College or University Training o DE 136: Four-Year College or University Training o DE 143: Junior or Community College Training DE 133,140, 147, 154, 161, 167, 174, 181, 188, 195, 202, 209: Training Services SE Title VI Funds o Example DE 147: Four-Year College or University Training o Example DE 181: Job Readiness Training DE 216, 223, 230, 237, 244, 251, 265, 272, 291, 298, 305, 312, 319, 326, 333, 340: Career Services SE Title VI Funds o Example DE 223: Diagnosis and Treatment of Impairments o Example DE 272: Benefits Counseling o 12

New Data Elements PD 19-03 (1 of 2) At Application DE 394: Monthly Public Support at Application DE 395: Medical Insurance Coverage at Application At Exit DE 396: Monthly Public Support at Exit DE 397: Medical Insurance Coverage at Exit At Individualized Plan for Employment (IPE) DE 398: Date of Initial IPE DE 399: IPE Development Extension DE 400: Enrolled in a Recognized Secondary School Equivalency Program DE 401: Date Completed During Program Participation in an Education or Training Program Leading to a Recognized Postsecondary Credential or Employment 13

New Data Elements PD 19-03 (2 of 2) At Time of Training Service DE 402: Work-Based Learning Experience, Service Provided by VR Agency Staff (in-house) DE 403: Work-Based Learning Experience, Service Provided through VR Agency Purchase DE 404: Work-Based Learning Experience, Purchased Service Provider Type DE 405: Work-Based Learning Experience, Amount of VR Funds Expended for Service (Title I) DE 406: Work-Based Learning Experience, Service Provided by Comparable Services and Benefits Providers DE 407: Work-Based Learning Experience, Comparable Services and Benefits Provider Type 14

RSA-911 Correction Procedures May 13, 2019 https://www2.ed.gov/rschstat/eval/rehab/rsa-911-correction- procedures.pdf?utm_content=&utm_medium=email&utm_na me=&utm_source=govdelivery&utm_term=

RSA-911 Correction Procedures Within the Program Year s reporting period, agencies may internally correct any Data Element except the following three: o Data Element 5: Unique Identifier; o Data Element 6: Social Security Number; and o Data Element 7: Date of Application RSA will consider the most recently reported value as the correct value for any Data Element that does not allow multiple values. Agencies must request all corrections to Data Elements 5, 6, and 7 by sending an encrypted file by email to RSAData@ed.gov. o For more information, review procedures. 16

Correction Procedures (continued) Agencies may request that RSA disapprove a previous RSA-911 report so the agency may submit the report again with the corrected information within that Program Year s reporting period. RSA will only consider requests to disapprove quarterly reports and allow agencies to resubmit if agencies make the request within the Program Year s reporting period. If an agency requests to resubmit a prior Program Year s quarterly report and the reporting period for that Program Year has concluded, RSA will not consider the request. RSA will review each request on a case-by-case basis and may follow up with the agency if more information is needed. 17

RSA-911 Crosswalk August 14, 2019 https://www2.ed.gov/rschstat/eval/rehab/case-service-report- rsa-911-crosswalk-of-changes.xlsx

RSA-911 Crosswalk To assist State VR agencies with collecting and reporting VR program data, RSA developed a crosswalk of changes made to RSA-911 from PD-16-04 to PD-19-03. These changes pertain to some RSA-911 Data Elements and various code values specified in the appendices. 19

RSA-911 Crosswalk: Example RSA-911 PD 16-04 RSA-911 PD19-03 Code 1 Source of Referral at Application 14(c) Certificate Holders Code 1 Source of Referral 14(c) Certificate Holders 2 Adult Education and Literacy Programs 2 Adult Education and Family Literacy Act Program (Title II of WIOA) 3 4 5 6 7 American Indian VR Services Program Centers for Independent Living Child Protective Services Community Rehabilitation Programs Consumer Organizations or Advocacy Groups Department of Labor Employment and Training Service Programs for Adults, Dislocated Workers, and Youth Educational Institutions (Elementary/Secondary) Educational Institutions (Postsecondary) Employers Extended Employment Providers Faith Based Organizations Family/Friends Intellectual and Developmental Disabilities Providers Medical Health Provider (Public or Private) Mental Health Provider (Public or Private) Public Housing Authority Self-referral Social Security Administration (Disability Determination Service or District office) State Department of Correction/Juvenile Justice Temporary Assistance for Needy Families (TANF) Veteran's Benefits Administration (which includes VA Vocational Rehabilitation) Veteran's Health Administration (the VA hospital system, as well as the VA transitional living, transitional employment, and compensated work therapy programs) 3 4 American Indian VR Services Program (AIVRS) Centers for Independent Living Other Sources Service Providers Other Sources 29 6 29 8 8 Adult, Dislocated Worker, and Youth Programs (Title I of WIOA) 9 9 Elementary and Secondary Schools Post-secondary Education Institutions Employers Extended Employment Providers Other Sources Self-referral, friends, family Intellectual and Developmental Disability Agencies Medical Health Providers Mental Health Providers Other Sources Self-referral, friends, family Social Security Administration Other Sources Temporary Assistance for Needy Families (TANF) Veteran s Benefits or Health Administration 10 11 12 13 14 15 16 17 18 19 20 21 22 23 10 11 12 29 19 15 16 17 29 19 20 29 22 23 24 23 Veteran s Benefits or Health Administration 25 Wagner-Peyser Employment Service Program 25 Wagner-Peyser Act Employment Service Program (Title III of WIOA) 26 27 28 29 30 31 Welfare Agency (State or local government) Worker's Compensation Other One-stop Partner Other Sources Other State Agencies Other VR State Agencies Other WIOA-funded Programs including Job Corps, YouthBuild, Indian and Native Americans, and Migrant and Seasonal Farmworker Programs 29 27 29 29 29 29 Other Sources Worker s Compensation Other Sources Other Sources Other Sources Other Sources 20 32 32 Other American Job Center or Workforce Development Programs

RSA-911 Internal Controls Requirements 2 C.F.R. 200.61 & 2 C.F.R. 200.303 - Internal controls means a process, implemented by a non-Federal entity, designed to provide reasonable assurance regarding the achievement of objectives in the following categories: a. Effectiveness and efficiency of operations; b. Reliability of reporting for internal and external use; and c. Compliance with applicable laws and regulations. 21

RSA-911 Internal Controls Requirements (continued) In accordance with 34 C.F.R. 361.12, State VR agencies must implement policies and procedures that ensure the proper and efficient administration of the VR program, including those necessary to carry out all functions for which the State is responsible under this program. So that each State VR agency is able to collect and report on the revised RSA-911 by July 1, 2020, each State VR agency s internal controls should ensure that its 1. Data collection system is capable of capturing and reporting all the required Data Elements contained in RSA-PD-19-03; 2. Staff have completed training necessary to ensure the collection and reporting of the required Data Elements; and 3. Internal controls processes to ensure the accuracy and validity of the data have been implemented. 22

RSA Preparation for PD-19-03 Implementation Collaboration with Federal Partners RSA-911 Edit Checks Quarterly Data Dashboards Analyzing VR Program Data and WIOA Performance Measures and Sharing Results with All State VR Agencies Data-Informed Decision-Making Website News o RSA.ED.gov; and o WIOA State Plan Portal RSA-911 Training Series o In partnership with WINTAC 23

WINTAC Preparation for PD-19-03 Implementation RSA-911 Training Series o In partnership with RSA Collaboration with RSA and other Key Partners o Making key information available to all State VR Agencies Providing Technical Assistance and Training (e.g., policy and procedures, staff training, internal controls) Tool and Resource Development (e.g., MSG and Credential Attainment Guides, ESE Crosswalk, FAQs) Assisting states in using RSA-911 data for program improvement, identifying areas of need and progress, case management system development, etc. 24

RSA-911 Training Series 1. Background and Implementation 2. Reporting Expenditures for VR Services 3. Pre-Employment Transition Services (Pre-ETS) 4. Supported Employment (SE) Services 5. Measurable Skill Gains (MSG) and Credential Attainment 6. Exit and Post-Exit Data Elements 7. New Data Elements Additional Need to Know Information 8. RSA-911 Information Used in the WIOA Annual Report 25

Resources: General Performance and Reporting RSA-911 Webpage https://rsa.ed.gov/display.cfm?pageid=75&utm_content=&utm_medium=email&utm_name=& utm_source=govdelivery&utm_term= U.S. DOL ETA Performance and Results Page https://www.doleta.gov/performance/ WINTAC http://www.wintac.org/ WINTAC - CPM & 911 Reporting Resources http://www.wintac.org/topic-areas/transition-to-the-common-performance-accountability- system RSA-PD-16-04 Case Service Report (RSA-911) https://www2.ed.gov/policy/speced/guid/rsa/subregulatory/pd-16-04.pdf RSA-PD-19-03 Case Service Report (RSA-911) https://www2.ed.gov/policy/speced/guid/rsa/subregulatory/pd-19-03.pdf 26

Contact Christopher Pope Chief, Data Collection & Analysis Unit (202) 245-7375 RSAData@ed.gov rsa.ed.gov Rachel Anderson (435) 764-8487 randerson@ndi-inc.org www.WINTAC.org 27