PKG00262840-instructions.pdf

U.S. DEPARTMENT OF EDUCATION

OFFICE OF SPECIAL EDUCATION AND REHABILITATIVE SERVICES

WASHINGTON, D.C. 20202-2800

FY 2020 APPLICATION KIT FOR NEW GRANTS

UNDER

THE REHABILITATION SERVICES ADMINISTRATION

VOCATIONAL REHABILITATION TECHNICAL ASSISTANCE

CENTER – QUALITY EMPLOYMENT

CFDA 84.264K

FORM APPROVED

OMB NO. 1820-0018, EXP. DATE: 06/30/2022

ED FORM 424, OMB APPROVED

DATED MATERIAL—OPEN IMMEDIATELY

CLOSING DATE: SEPTEMBER 2, 2020

CONTENTS

SUBJECT SECTION

Dear Applicant Letter .................................................................................................................. A

Notice of Final Priorities.............................................................................................................. B

Notice Inviting Applications for New Awards ............................................................................... C

Selection Criteria for Applications ............................................................................................... D

Application Transmittal Instructions ............................................................................................ E

Application Abstract Instructions ................................................................................................. F

Application Forms....................................................................................................................... G

Part I: Federal Assistance Face Page (SF-424) Part II: Budget Information (ED 524) Part III: Application Narrative Part IV: Grant Application Form for Project Objectives and Performance Measures Information Part V: Evidence Form (optional) Part VI: Certifications and Disclosures:

• Certification Regarding Lobbying: Certification for Contracts, Grants, Loans and Cooperative Agreements;

• Disclosure of Lobbying Activities (SF-LLL)

Important Notices/Information .................................................................................................... H

• Notice to All Applicants, Section 427 of the General Education Provisions Act (GEPA)

• The Government Performance and Results Act (GPRA)

• Executive Order 12372 (Intergovernmental Review of Federal Programs)

• Electronic Notification Option for Grant Awards

Additional Information .................................................................................................................. I

• Applicant Checklist

• Common Questions and Answers

• Program Application Indirect Cost Instructions

• D-U-N-S Number Instructions

Section A

Dear Applicant Letter

UNITED STATES DEPARTMENT OF EDUCATION

OFFICE OF SPECIAL EDUCATION AND REHABILITATIVE SERVICES

REHABILITATION SERVICES ADMINISTRATION

August 3, 2020

Dear Applicant:

This application package contains information and the required forms for you to use in submitting a new application for funding under Rehabilitation Training Program.

The Department of Education (Department) is issuing a notice inviting applications (NIA) for fiscal year (FY) 2020 to fund a cooperative agreement to establish the Vocational Rehabilitation

Technical Assistance Center-Quality Employment (VRTAC-QE), Catalog of Federal Domestic

Assistance (CFDA) number 84.264K.

The purpose of the VRTAC-QE is to increase the number and quality of employment outcomes for individuals with disabilities through training and technical assistance to State vocational rehabilitation (VR) agency personnel on innovative and effective employment strategies and supporting practices.

Please read this letter carefully as it includes important information related to the grant competition. Take the time to review all applicable requirements, definitions, selection criteria, and application instructions thoroughly. An application will not be evaluated for funding if the applicant does not comply with all procedural rules that govern the submission of the application or if the application does not contain the information required. (EDGAR §75.216 (b) and (c)).

Please note the following:

NOTICE OF FINAL PRIORITIES

The notice of Final Priorities (NFP) is published in the Federal Register, contained in Section B of this application package, and is available to download and review.

NOTICE INVITING APPLICATIONS

The notice inviting applications (NIA) is published in the Federal Register, contained in Section C of this application package, and is available to download and review.

PRE-APPLICATION MEETING AND POWERPOINT PRESENTATION

The Office of Special Education and Rehabilitative Services (OSERS) will post a PowerPoint presentation that provides general information related to the Rehabilitation Services

Administration’s (RSA’s) discretionary grant competitions and PowerPoint presentations specifically related to the VRTAC-QM and VRTAC-QE competitions at https://ncrtm.ed.gov/RSAGrantInfo.aspx. OSERS will conduct a pre application meeting via conference call to respond to questions specific to the VRTAC-QM and the VRTAC-QE.

Information about the pre-application meeting will be available at https://ncrtm.ed.gov/RSAGrantInfo.aspx prior to the date of the call. OSERS invites you to send questions to 84.264K@ed.gov in advance of the pre-application meeting. The teleconference information, including a summary of pre-application questions and answers, will be available at https://ncrtm.ed.gov/RSAGrantInfo.aspx within 6 days after the pre-application meeting.

COMMON INSTRUCTIONS FOR APPLICANTS TO DEPARTMENT OF EDUCATION

DISCRETIONARY GRANT PROGRAMS

Applicants are required to follow the Common Instructions for Applicants to Department of

Education Discretionary Grant Programs, published in the Federal Register on February 13, 2019

(84 FR 3768), and available at www.govinfo.gov/content/pkg/FR-2019-0213/pdf/2019-02206.pdf, which contain requirements and information on how to submit an application.

GRANTS.GOV APPLICATION SUBMISSION AND SAM REGISTRATION

Applications for grants under this competition must be submitted electronically using the

Grants.gov Apply site (www.Grants.gov). Please read carefully the Grants.gov Submission

Procedures and Tips for Applicants document included in Section D of this application package, which includes helpful tips about submitting electronically using the Grants.gov Apply site. Grants.gov registration involves many steps including registration on SAM (www.sam.gov) which may take approximately one week to complete, but could take as many as several weeks to complete. You may begin working on your application while completing the registration process, but you cannot submit an application until all of the registration steps are complete. Please note that once your SAM registration is active, it will take 24-48 hours for the information to be available in Grants.gov. You cannot submit an application through Grants.gov until

Grants.gov has received your SAM registration information. We strongly encourage you to familiarize yourself with SAM and Grants.gov and strongly recommend that you register and submit early.

Applicants are required to upload any narrative sections and all other attachments to your application as files in either Portable Document Format (PDF) or Microsoft Word. However, it is recommended that applicants upload files as read-only flattened PDFs. Please be aware that applications submitted to Grants.gov for the Department of Education will now be posted using

Adobe forms. Information on computer and operating system compatibility with Adobe and links to download the latest version of Adobe are available on Grants.gov. Please note that you must follow the application procedures as described in the Federal Register notice announcing this grant competition. Information (including dates and times) about how to submit your application electronically can also be found in Section D of this application package.

https://ncrtm.ed.gov/RSAGrantInfo.aspx https://ncrtm.ed.gov/RSAGrantInfo.aspx https://ncrtm.ed.gov/RSAGrantInfo.aspx https://ncrtm.ed.gov/RSAGrantInfo.aspx http://www.govinfo.gov/content/pkg/FR-2019-02-13/pdf/2019-02206.pdf http://www.govinfo.gov/content/pkg/FR-2019-02-13/pdf/2019-02206.pdf http://www.govinfo.gov/content/pkg/FR-2019-02-13/pdf/2019-02206.pdf http://www.sam.gov/ http://www.sam.gov/ http://www.sam.gov/

EDUCATION DEPARTMENT GENERAL ADMINISTRATIVE REGULATIONS (EDGAR)

The Rehabilitation Training program is subject to the requirements of the Education Department

General Administrative Regulations at 34 CFR Parts 75, 77, 79, 81, 82, 84, 86, 97, 98, and 99.

These regulations set forth all general rules affecting application submittal, review, grant awarding, and post-award administration of Department of Education grant programs.

INTERGOVERNMENTAL REVIEW

This competition is subject to Executive Order 12372 and the regulations in 34 CFR part 79.

However, under 34 CFR 79.8(a), we waive intergovernmental review in order to make an award by the end of FY 2020.

BUDGET INFORMATION

Applicants for multi-year projects are required to provide detailed budget information for each of the five project years. Funds under the Rehabilitation Training program and the

Demonstration and Training program must be budgeted and tracked separately.

Maximum Award Amount

The competition included in this package has a maximum award amount. Please refer to the specific information for the priority/competition to which you are submitting an application (i.e., Section B of this package) for detailed budget information for the total grant period requested.

Please be advised that for the priority in this package, the maximum award amount covers all project costs including indirect costs.

The Department will determine at the time of the initial award, the funding levels for each year of the grant award. However, we will not make an award exceeding $3,344,560 for a single budget period of 12 months. Of this amount, $3,000,000 is from the Rehabilitation Training program and will be used for the provision of training and technical assistance, and $344,560 is from the

Demonstration and Training program and will be used for evaluation activities.

Required Cost Share

The Department determined that cost sharing of 10 percent of the total cost of the project is required of grantees under both the Rehabilitation Training program and the Demonstration and Training program. Therefore, cost sharing of 10 percent of the total cost of the project (i.e., based on the sum of Federal and non-Federal project costs) is required of the grantee under this competition. Given the importance of the cost share funds to the long-term success of the project, eligible entities must identify appropriate cost share funds in the proposed budget. Finally, the selection criteria include factors such as “the adequacy of support, including facilities, equipment, supplies, and other resources, from the applicant organization or the lead applicant organization” and “the relevance and demonstrated commitment of each partner in the proposed project to the implementation and success of the project,” which may include a consideration of demonstrated cost sharing support.

Cost-Share Calculation Example:

The applicant’s cost-share requirement is 10 percent of the total cost of the project (Federal and non-Federal).

Federal share divided by 9 = Applicant Cost Share Amount

Example of Cost Share Calculation: The Federal funding amount is $1,000,000.00. The non- Federal cost share is $111,111.11 (i.e., $1,000,000 divided by 9).

$1,000,000.00 divided by 9 = $111,111.11

The total coast of the project is $1,111,111.11 (Federal Share of $1,000,000 plus cost share of $111,111.11), of which the applicant must contribute $111,111.11.

Indirect Costs

The awards will be jointly funded by the Rehabilitation Training program and the Demonstration and Training program, which have different indirect cost rate requirements. These funds must be budgeted and tracked separately, with the correct indirect cost rate applied to each set of funds.

Under 34 CFR 75.562(c), an indirect cost reimbursement on a training grant is limited to the recipient’s actual indirect costs, as determined by its negotiated indirect cost rate agreement, or eight percent of a modified total direct cost base, whichever amount is less. Indirect costs in excess of the limit may not be charged directly, used to satisfy matching or cost-sharing requirements, or charged to another Federal award. This requirement applies only to the Rehabilitation Training program funds, which amount to up to $3,000,000 of the $3,344,560 available for each award.

Under 34 CFR 373.22, indirect cost reimbursement for grants under the Demonstration and Training program is limited to the recipient’s actual indirect costs, as determined by its negotiated indirect cost rate agreement, or 10 percent of the total direct cost base, whichever amount is less. This requirement applies only to the Demonstration and Training program funds, which amount to up to $344,560 of the $3,344,560 available for each award.

Program Income

Any program income that may be incurred during the period of performance may only be directed towards advancing activities in the approved grant application and may not be used towards the 10 percent cost share requirement.

Tracking Budgets for the Rehabilitation Training Program and the Demonstration and Training Program

Applications must include separate ED-524 budget forms and budget narratives for funds requested under the Rehabilitation Training and Demonstration and Training programs, respectively.

Please note that Grants.gov allows applicants to select each of the forms, including the ED524 budget form, only once. Therefore, please submit one combined ED524 budget form as the budget form. The individual ED524 budget forms (one for Rehabilitation Training funds and one for Demonstration and Training funds) may be uploaded in the Budget Justification Narrative form section as multiple files may be uploaded in this section. The Other Attachments form also allows up to 10 files to be uploaded, if you need the extra space. Further, in the budget narrative you must provide and describe how the funding from each source (the Rehabilitation Training program and the Demonstration and Training program), including the amounts (e.g., cost share, indirect costs, etc.) for each. Also, keep in mind that you must be able to track the funds by program separately through the life of the grant, should you receive funding.

Subgrantees (Subawards)

Under 34 CFR 373.23(b), a grantee under this competition may not award subgrants using Demonstration and Training program funds to entities to directly carry out project activities described in its application. Under 34 CFR 75.708(b) and (c), a grantee under this competition may award subgrants using Rehabilitation Training program funds--to directly carry out project activities described in its application--to the following types of entities: States and public or private nonprofit agencies and organizations, including Indian Tribes and institutions of higher education.

The grantee may award subgrants to entities it has identified in an approved application or that it selects through a competition under procedures established by the grantee. Under 34 CFR 75.708(e) and 373.23(b), a grantee may use either Demonstration and Training program or Rehabilitation Training program funds to contract for supplies, equipment, and other services in accordance with 2 CFR part 200.

ABSOLUTE PRIORITIES

The NIA contains two absolute priorities:

• Absolute Priority 1: Vocational Rehabilitation Technical Assistance Center for Quality

Management (VRTAC-QM)

• Absolute Priority 2: Vocational Rehabilitation Technical Assistance Center for Quality

Employment (VRTAC-QE)

An applicant may apply for both priorities if it submits separate applications and demonstrate in each application that it has sufficient institutional capacity to fully implement multiple awards, including the required cost share. This application package is specific to VRTAC-QE (Absolute

Priority 2), described as follows in the NIA:

The purpose of the VRTAC-QE is to upgrade and increase the competencies, skills, and knowledge of VR personnel to implement and sustain employment strategies and supporting practices that enable individuals with disabilities to achieve quality employment and career advancement, particularly competitive integrated employment as defined in the Rehabilitation Act.

The center will include strategies and practices that meet the needs and promote the quality employment of individuals with significant and the most significant disabilities, students and youth with disabilities, and traditionally underserved populations. The VRTAC-QE will implement a coordinated plan to provide intensive training and technical assistance, targeted training and technical assistance, and universal training and technical assistance to State VR agencies on a broad range of employment strategies and supporting practices.

Please refer to the NFP and NIA for more details about this absolute priority.

Applicants must address the absolute priority in the budget information (ED Form 524, Section B) and budget narrative. The applicant must propose the amount of cash or in-kind resources to be contributed for each year of the grant.

Prior to the peer review, Department staff will determine if an application has met the appropriate absolute priority and is eligible for peer review. An application that has not met the absolute priorities will not be considered for funding and may not be reviewed.

APPLICATION NARRATIVE AND SELECTION CRITERIA

Part III of the application narrative is where you, the applicant, address the absolute priority, particularly the Application Requirements and the Project Requirements in the NFP and the NIA.

The application narrative must also address the Selection Criteria, which the competition peer reviewers use to evaluate and score each application. These may be found in Section D of this application kit or Section V.1. of the NIA. Please note that peer reviewers are instructed that appendix material is considered supplemental material to support or show evidence supporting statements made in the narrative, and that they are not required to review such material. (They are neither asked nor expected to consider appendix material in rating applications.)

EVIDENCE OF EFFECTIVENESS FORM (OPTIONAL)

Applicants are not required to complete the Evidence of Effectiveness Form for the 84.264K competition in this application package.

PROTECTION OF HUMAN SUBJECTS IN RESEARCH

The discretionary grant Application Form SF-424 requires applicants to indicate whether they plan to conduct research involving human subjects at any time during the proposed project period. The

Protection of Human Subjects in Research Attachment is an integral part of the SF-424 form. It includes information that applicants need to complete the protection of human subjects item and, as appropriate, to provide additional information to the Department regarding human subjects research projects. Additional information on completing the protection of human subjects item is also available and can be accessed on the internet at:

www.ed.gov/about/offices/list/ocfo/gcsindex.html www.ed.gov/about/offices/list/ocfo/humansub.html

RESPONSE TO PERFORMANCE MEASURES

This program contains two types of performance measures: 1) those related to Government

Performance and Results Modernization Act (GPRA) of 2010, known as GPRA measures and 2) program measures.

As required by the GPRA, the Rehabilitation Services Administration (RSA) has developed four

GPRA measures for this program. In addition, RSA has developed one program measure that applies to the Rehabilitation Training Program. Approved applications for this program should have project outcomes and measures consistent with the performance measures established in the NIA. Projects funded under this competition are required to submit data on the program measure as directed by RSA. Applicants can design their projects to meet the established performance measures and develop evaluation techniques that provide valid and reliable data on the established performance measures. See the Performance Measures section of the NIA.

Applicants are encouraged to review this information carefully when preparing their applications.

COPIES OF THE APPLICATION

Unless you qualify for an exception in accordance with the instructions in the NIA, you must submit your application electronically. Therefore, you do not need to submit paper copies of the application. If you are granted an exception, current Government-wide policy requires that an original and two paper copies need to be submitted. Please note: If an application is http://www.ed.gov/about/offices/list/ocfo/gcsindex.html http://www.ed.gov/about/offices/list/ocfo/gcsindex.html http://www.ed.gov/about/offices/list/ocfo/gcsindex.html http://www.ed.gov/about/offices/list/ocfo/humansub.html recommended for funding and a grant award is issued, we will contact the applicant to request an electronic copy of the application in MS Word or a PDF file. The Department is moving toward an electronic grant filing system and an electronic copy of all applications that are being funded will facilitate this effort.

REVIEW AND SELECTION PROCESS

We remind potential applicants that in reviewing applications in any discretionary grant competition, the Secretary may consider, under 34 CFR 75.217(d)(3), the past performance of the applicant in carrying out a previous award, such as the applicant’s use of funds, achievement of project objectives, and compliance with grant terms and conditions. The Secretary may also consider whether the applicant failed to submit a timely performance report or submitted a report of unacceptable quality.

In addition, in making a competitive grant award, the Secretary requires various assurances, including those applicable to Federal civil rights laws that prohibit discrimination in programs or activities receiving Federal financial assistance from the Department (34 CFR 100.4, 104.5, 106.4, 108.8, and 110.23).

ADDITIONAL INFORMATION

For information about other U.S. Department of Education grant and contract opportunities, we encourage you to use the Department's grant information web page which can be accessed on the internet at: http://www.ed.gov/about/offices/list/ocfo/grants/grants.html.

Applicants may contact Felipe Lulli, competition manager, who may be reached at (202) 245-7425 or 84.264K@ed.gov, to discuss any matters relating to this competition.

Sincerely, Mary F. Lovley, Director, Training and Service Programs Division

400 MARYLAND AVE. S.W., WASHINGTON, DC 20202-2800 www.ed.gov

The Department of Education’s mission is to promote student achievement and preparation for global competitiveness by fostering educational excellence and ensuring equal access http://www.ed.gov/about/offices/list/ocfo/grants/grants.html http://www.ed.gov/about/offices/list/ocfo/grants/grants.html

Section B

Notice of Final Priorities

4000-01-U

DEPARTMENT OF EDUCATION

34 CFR Chapter III

[ED-2020-OSERS-0104]

Final priorities, requirements and definitions—-

Rehabilitation Training: Vocational Rehabilitation

Technical Assistance Center—Quality Management; and Vocational

Rehabilitation Technical Assistance Center—Quality Employment

AGENCY: Office of Special Education and Rehabilitative Services

(OSERS), Department of Education.

ACTION: Final priorities, requirements, and definitions.

SUMMARY: The Department of Education (Department) announces priorities, requirements, and definitions under the Rehabilitation

Training program, Catalog of Federal Domestic Assistance (CFDA) numbers 84.264J and 84.264K. The Department may use one or more of these priorities, requirements, and definitions for competitions in fiscal year (FY) 2020 and later years. We take this action to focus attention on an identified national need to fund a Vocational Rehabilitation Technical Assistance Center for

Quality Management (VRTAC-QM) and a Vocational Rehabilitation

Technical Assistance Center for Quality Employment (VRTAC-QE). We intend for the VRTAC-QM and VRTAC-QE to increase the number and quality of employment outcomes for individuals with disabilities through training and technical assistance to State vocational rehabilitation (VR) agency personnel. We expect the VRTAC-QM to enable State VR agency personnel to manage available resources better and improve service delivery, and the VRTAC-QE to support

State VR agency personnel to implement innovative and effective employment strategies and supporting practices.

EFFECTIVE DATE: These priorities, requirements, and definitions are effective September 2, 2020.

FOR FURTHER INFORMATION CONTACT: For 84.264J: Douglas Zhu, U.S.

Department of Education, 400 Maryland Avenue, SW, room

5095, Potomac Center Plaza, Washington, DC 20202-2800. Telephone:

(202) 245-6037. Email: 84.264J@ed.gov. For 84.264K: Felipe

Lulli, U.S. Department of Education, 400 Maryland Avenue, SW, room

5101, Potomac Center Plaza, Washington, DC 20202-2800. Telephone:

(202) 245-7425. Email: 84.264K@ed.gov.

If you use a telecommunications device for the deaf (TDD) or a text telephone (TTY), call the Federal Relay Service (FRS), toll free, at 1-800-877-8339.

SUPPLEMENTARY INFORMATION:

Purpose of Program: Under the Rehabilitation Act of 1973

(Rehabilitation Act), as amended by the Workforce Innovation and

Opportunity Act (WIOA), the Rehabilitation Services Administration

(RSA) makes grants to States and public or nonprofit agencies and organizations (including institutions of higher education) to pay part of the cost of projects to provide State VR agency personnel with training and technical assistance designed to assist in increasing the numbers of, and upgrading the skills of, qualified personnel (especially rehabilitation counselors), who are trained in providing vocational, medical, social, and psychological rehabilitation services to individuals with disabilities. They are also trained to assist individuals with communication and related disorders and to provide other services authorized under the Rehabilitation Act.

Program Authority: 29 U.S.C. 772(a)(1).

Applicable Program Regulations: 34 CFR part 385.

We published a notice of proposed priorities, requirements, and definitions (NPP) for this program in the Federal Register on

April 9, 2020 (85 FR 19908). That notice contained background information and our reasons for proposing the particular priorities, requirements, and definitions.

Except for minor editorial and technical revisions for grammar and clarity and three minor substantive changes explained in the discussion of comments that follow, there are no differences between the proposed priorities, requirements, and definitions and these final priorities, requirements, and definitions.

Public Comment: In response to our invitation in the NPP, 12 parties submitted comments on the proposed priorities, requirements, and definitions.

We group major issues according to subject and discuss substantive issues under each of the titles—priorities, requirements, and definitions—to which they pertain. Generally, we do not address technical and other minor changes, or suggested changes the law does not authorize us to make. In addition, we do not address general comments that raise concerns not directly related to the proposed priorities, requirements, or definitions.

Analysis of Comments and Changes: An analysis of the comments and of any changes in the priorities, requirements, and definitions since publication of the NPP follows.

Priorities

Comment: Some commenters expressed concern that the proposed priorities contained what appeared to be some conceptual overlapping of lead responsibilities between the VRTAC-QM and the

VRTAC-QE, for example, between improving VR service delivery and implementing employment strategies. One of the commenters referenced the centers’ shared focus on pre-employment transition services. Another commenter pointed out that both centers are required to engage with the training and technical assistance resources funded by the U.S. Departments of Education, Labor, and

Health and Human Services. The commenters recommended that the final priorities provide specifics about the nature and extent of required coordination between the two VRTACs to ensure that each center’s resources are used most effectively, clearly differentiate the lead responsibilities among the centers, and require the centers to coordinate their work on the State, regional, and national levels.

Discussion: The Department appreciates the commenters’ suggestions and recommendations. The Department agrees that clarity of roles and coordination of activities between the centers are necessary for the efficient and cost-effective delivery of intensive training and technical assistance to State

VR agency personnel. This is why we require the VRTAC-QM and

VRTAC-QE to coordinate training and technical assistance with other technical assistance centers. Such clarity and coordination are especially critical because both centers will assist VR agencies to improve the provision of VR services, including pre-employment transition services and the achievement of quality employment outcomes. The VRTAC-QM pursues these goals through improved program management and resource utilization, whereas the

VRTAC-QE focuses on the implementation of promising employment strategies and practices. Coordination and clarity of roles between the VRTAC-QM and VRTAC-QE will be pursued through RSA’s cooperative agreement with each center, training and technical assistance agreements with each State VR agency, RSA leadership and direction at the national level, and ongoing communication between the respective project officers. As such, further clarification and differentiation are not necessary.

Changes: None.

Comment: One commenter noted that although the WIOA Joint Rule for Unified and Combined State Plans, Performance Accountability, and One-Stop System Joint Provisions became effective on October

18, 2016, several key RSA policy directives and technical assistance circulars that have provided guidance in implementing those regulations were released a year or more later. As a result, State VR agencies still need technical assistance to ensure effective implementation of the requirements of the newer rules. The commenter suggested that Priority 1, VRTAC-QM, include a more general focus on continued training and technical assistance to assist State VR agencies in implementing the requirements of WIOA.

Discussion: The Department appreciates the commenter’s suggestion. As stated in the purpose of the program in the VRTAC–

QM and the VRTAC–QE priorities, each project will provide training and technical assistance to State VR agency personnel to equip and increase the number of personnel with the necessary skills to implement the provisions in the Rehabilitation Act as amended by

WIOA. The VRTAC-QM and VRTAC-QE will provide training and technical assistance to address the need of State VR agencies to ensure effective implementation of the requirements of WIOA, including those raised by the commenter.

Changes: None.

Comment: One commenter noted that resource limitations related to

States’ challenges in meeting VR program match requirements, as well as the requirement to reserve at least 15 percent of Federal

VR program funds for pre-employment transition services to eligible and potentially eligible students with disabilities, have reduced State VR agencies’ ability to serve all eligible individuals with disabilities. The commenter stated that, in the absence of significant additional resources devoted to serving individuals with disabilities, the coronavirus pandemic’s current and future impact on State budgets and labor markets will almost certainly lead to even fewer eligible individuals being served and smaller numbers of employment outcomes among VR participants in program year 2020 and beyond. This commenter suggested that targeted and intensive technical assistance can help VR agencies identify ways to use available resources more effectively.

Discussion: The Department appreciates the commenter’s support for the priorities. Under the priority for quality management, the VRTAC-QM will be able, through targeted and intensive technical assistance, to help State VR agencies to identify ways to use available resources more effectively and to implement program and resource management strategies and practices that lead to effective and efficient service delivery and quality employment outcomes.

Changes: None.

Comment: Several commenters addressed the COVID-19 pandemic’s potential impact on VRTAC-QM and VRTAC-QE’s intensive training and technical assistance delivery methods, topic areas, and performance assessments. A few of the commenters inquired whether

RSA would allow the centers’ intensive training and technical assistance to be delivered virtually rather than in-person, if necessary or advisable due to continued travel restrictions and social distancing requirements. One commenter recommended that the intensive training and technical assistance include a focus on promoting effective distance service delivery and community engagement approaches, especially in the provision of pre-employment transition services. Another commenter inquired whether RSA would consider the pandemic’s impact on State budgets, local economies, employers, and, ultimately, VR participants in its evaluation of the centers’ performance.

Discussion: The VRTAC-QM and the VRTAC-QE will provide training and technical assistance to State VR agency personnel to achieve the State VR agency’s program management, service delivery, and quality employment goals in a manner consistent with the priority and with each State’s particular circumstances, including those related to COVID-19. The centers’ training and technical assistance will help VR personnel to assess and improve the VR agency’s management and service delivery systems, which may include remote delivery of services, including how to provide pre-employment transition services remotely. Further, while intensive training and technical assistance are typically provided on-site, nothing in the priorities precludes the VRTAC-QM and VRTAC-QE from providing the training and technical assistance remotely if on-site delivery is not possible or advisable. The service delivery and performance evaluation considerations related to COVID-19 can be addressed in the cooperative agreement between RSA and the respective technical assistance center. To reflect that the priorities are broad enough to encompass these activities, RSA has revised the priorities to address remote delivery of training and technical assistance and to provide technical assistance on remote delivery of services.

Changes: We have revised the definition of “intensive training and technical assistance” under the Final Definitions section by adding remote delivery as needed and appropriate.

Comment: One commenter asserted that the VRTAC-QE should not be responsible for directly implementing employment strategies and supporting practices in the participating State VR agencies.

Discussion: We agree with the commenter that the VR agencies are responsible for implementing specific strategies or practices in their States. The VRTAC-QE and VRTAC-QM are responsible for conducting comprehensive reviews of current and promising strategies and practices, presenting them as options to participating State VR agency personnel, and providing high-quality and relevant intensive training and technical assistance to State VR agency personnel if they choose to implement selected strategies or practices.

Changes: None.

Comment: Several commenters expressed concern that the proposed priorities did not sufficiently emphasize training and technical assistance to Community Rehabilitation Programs (CRPs), given the importance of CRPs’ role in promoting quality employment outcomes for individuals with disabilities. One of the commenters noted that the proposed priorities focus exclusively on improving the knowledge, skills, and capabilities of VR personnel but devote little or no attention to the knowledge, skills, and capabilities of CRP personnel. One commenter pointed out that only one of the six listed supporting practices explicitly references CRPs.

Another commenter stressed the need for flexible and innovative approaches for CRPs in Supported Employment, in particular. The commenters recommended that the proposed priorities elevate the role of CRPs and prioritize training and technical assistance to

CRP personnel.

Discussion: We agree that CRPs play a very important role in promoting quality employment outcomes for individuals with disabilities. Consistent with section 302 of the Rehabilitation

Act, as amended by WIOA, the purpose of these priorities is to support projects that provide training and technical assistance designed to assist in increasing the numbers of, and upgrading the skills of, qualified personnel (especially rehabilitation counselors). The VRTAC-QM and VRTAC-QE will provide intensive training and technical assistance to VR personnel according to a signed agreement between RSA and each participating State VR agency. The intensive training and technical assistance agreement includes the specific State agency’s goals and objectives, selected strategies and practices, individuals or groups of individuals to receive the training and technical assistance, and designated partner organizations. The intensive training and technical assistance provided under an agreement may involve CRPs as partner organizations because of their expertise in and potential contributions to the implementation of VRTAC-QM or

VRTAC-QE strategies and practices and may include topics and approaches such as those recommended by the commenter.

Changes: We added a reference to CRPs and other partners in both priorities.

Comment: One commenter noted that the employment rate of people with intellectual and developmental disabilities has been nationally around 20 percent for the last 10 years, and a reasonable person would have a hard time believing that the low rate is because of what VR counselors are doing or not doing, or that technical assistance can make a positive impact. This commenter suggested that when starting the technical assistance centers, it would be prudent for the centers to include people who can analyze such data.

Discussion: The Department agrees that it is necessary for the technical assistance centers to include personnel who can analyze data. Data collection, data analysis, and evaluation are addressed in the proposed priorities and project requirements and include activities such as analyzing case service data, including the VR Program Case Service Report (RSA-911) data and other agency performance data, to identify trends and inconsistencies in program performance and developing strategies to improve the quantity and quality of employment outcomes achieved by various groups of individuals with disabilities served by the VR program.

Changes: None.

Comment: A few commenters noted that many nonprofit organizations employ people with disabilities and have the capacity to hire and train more people with disabilities than they currently hire and train. These commenters suggested that the VRTAC-QE assist VR agencies’ personnel to expedite and streamline the referral of persons with disabilities to nonprofit organizations.

Discussion: The Department appreciates the commenters’ suggestions. Nothing in the priorities precludes the technical assistance centers from providing training and technical assistance to VR agency personnel on topics related to improving referrals for the purpose of assisting individuals with disabilities to achieve competitive integrated employment, if it is identified as a need by a VR agency.

Changes: None.

Comment: One commenter noted that the way in which current program performance measures are calculated is important, but that it is even more important both to understand the limitations on the reliability and validity of the data used to calculate the measures and to ensure that program performance data are used appropriately to inform program and policy decisions. The work of the Technical Assistance Center for Program Evaluation and Quality

Assurance (PEQA-TAC), including the collaborative Summit

Conference in which the PEQA-TAC has played a major role in recent years, has been of tremendous value in enhancing VR agencies’ use of effective program evaluation strategies, according to the commenter. The commenter suggested that the VRTAC-QM focus on enhancing VR agencies’ ability to effectively use both performance measurement strategies and in-depth program evaluation processes as recommended by the Government Accountability Office in publications such as GAO-05-739SP and GAO-11-646SP.

Discussion: The Department agrees with the commenter that the ability of VR personnel to effectively use both performance measurement strategies and in-depth program evaluation processes is important for VR program management. Since conducting quality assurance and performance improvement, including the use of data for performance management systems and the implementation of the common performance measures required by WIOA, are already included in the priority for VRTAC-QM, there is no need to make changes to the priority to address this focus area.

Changes: None.

Comment: One commenter suggested that RSA continue funding for the existing technical assistance centers that have effectively served VR agencies over the past several years. The commenter also stated that the challenges inherent in establishing new national technical assistance centers will inevitably result in delays in the centers’ collective ability to respond to the needs of State VR agencies, as well as gaps in the technical assistance available to VR agencies that they can ill afford to experience during a time of ongoing change in State VR programs, particularly in light of the current and ongoing challenges that all VR agencies face in addressing the COVID-19 pandemic. The commenter suggested that RSA consider continuing funding the current technical assistance centers for at least the next two years.

Discussion: The Department agrees with the commenter that the current centers have performed well and continued technical assistance is needed. The current centers were put in place to respond to very specific changes WIOA made to the Rehabilitation

Act, and State VR agencies are in a different place now than they were five years ago with respect to implementing the changes. The current set of RSA-funded VR technical assistance centers will be reaching the end of their five-year performance period, and the

Department believes the new priority areas will provide the training and technical assistance that State VR agencies need.

Given the status of the State VR agencies in implementing the specific changes based on WIOA, RSA believes that State VR agency personnel will benefit from technical assistance to achieve the

State VR agency’s program management, service delivery, and quality employment goals, in a manner consistent with the priority and with each State’s particular circumstances, including those related to COVID-19. RSA expects that the new technical assistance centers will be able to respond to the technical assistance needs of the State VR agencies.

Comment: One commenter noted that quality management is a pressing topic for individuals with disabilities accessing the

State VR program for the purpose of achieving competitive integrated employment. This commenter also noted that the amendments to the Rehabilitation Act emphasized expanding quality employment outcomes and career advancement for individuals with disabilities. The commenter suggested that the VRTAC-QM focus on fiscal and programmatic changes to VR agency operations that are philosophically consistent with the emphasis on expanding quality employment outcomes and career advancement for as many eligible individuals with disabilities as possible. The commenter also suggested that increasing the capacity of agencies in these areas should result in qualifying individuals for services in a manner that does not lead to the disqualification of other individuals.

Discussion: The Department appreciates the commenter’s suggestions. The priority for the VRTAC-QM stresses maximizing available resources to support consumer services and includes the types of services and outcomes suggested by the commenter.

Changes: None.

Project Requirements

Comment: One commenter suggested making it mandatory to include a representative from a CRP or a provider association on the advisory committee for the VRTAC-QM.

Discussion: The Department acknowledges the important role of

CRPs in assisting individuals with disabilities to achieve their employment outcomes. The proposed priority for the VRTAC-QM requires a representative of stakeholders, which would include

CRPs, to serve on the committee. However, given the important role of CRPs in providing rehabilitation services, RSA agrees with the commenter that the committee must include a CRP representative.

Changes: We added CRP representatives to the list of required members of the VRTAC-QM advisory committee in the Project

Requirements section of Priority 1.

Comment: One commenter asked for clarification regarding whether the VRTAC-QM has discretion to provide distinct intensive training and technical assistance to State VR agencies on resource management or programmatic management.

Discussion: The Department believes that the VRTAC-QM should have the capacity to provide intensive training and technical assistance to VR agencies on both program management and resource management. The VRTAC-QM may provide training and technical assistance to State VR agency personnel on topics related to program management, resource management, or both, based on the participating State VR agency’s identified needs.

Changes: None.

Comment: One commenter asked whether the state-of-the-art website and information technology (IT) platform to be established by the technical assistance centers for communicating with State VR agencies can be an existing website specifically designed to house and provide VR-specific information and resources, or whether a new site must be constructed.

Discussion: If the grantee has a website that can be modified for the purpose of the specific technical assistance center and it meets all of the final requirements, RSA may approve that website.

Otherwise, a new website must be constructed for the purpose of the VRTAC-QM or VRTAC-QE exclusively.

Changes: None.

Comment: One commenter suggested that the VRTAC-QM have three critical management objectives: (1) explore strategies to respond to increased demands for services that build capacity through the redesign of service delivery, including, but not limited to, virtual counseling, outcome-based payments to incentivize success with job placement and worker retention, and increased emphasis on poverty reduction that recognizes the impact of financial stress on physical and mental health; (2) develop new options for collaboration that draw additional financial and human resources in coordination with VR to meet expanded client demand; and (3) expand coordination with the employer community to build new on-ramps and pathways into employment for individuals with disabilities through inclusive apprenticeships and entrepreneurial opportunities.

Discussion: The Department agrees that these three objectives are reasonable options under the priorities, if they are among the needs identified by the participating VR agency; supported by the agency’s strengths, weaknesses, opportunities for improvement, and threats (SWOT) quality management assessment; and included in the corresponding training and technical assistance agreement. Please note that building new on-ramps and pathways into employment for individuals with disabilities is addressed through the priority for the VRTAC-QE.

Changes: None.

Comment: One commenter suggested that RSA establish criteria to prioritize the State VR agencies to receive intensive technical assistance from the technical assistance centers. The commenter noted that the criteria would be based on the degree to which

State VR agencies exhibit (1) ownership of their conditions, (2) engagement willingness, (3) clear understanding of technical assistance to meet needs, and (4) partnership and communication capacities.

Discussion: The Department agrees that, given the limited resources of the technical assistance centers, it is possible that there will be multiple VR agencies requiring training and technical assistance from the centers. The technical assistance centers need to have a system in place to address this scenario so that they can prioritize the training and technical assistance to the State VR agencies most in need. RSA will work with the technical assistance centers to prioritize which VR agencies get technical assistance through the cooperative agreement between RSA and the technical assistance centers.

Comment: One commenter suggested that the Department be cautious reaching any conclusions regarding VR agencies’ performance that are based primarily on data from Program Year (PY) 2017 and PY

2018 because the reliability, validity, and completeness of the new performance indicator data first reported in 2017 are limited.

The commenter noted that the current RSA-911 reporting requirements that went into effect on July 1, 2017, compelled

State VR agencies to make substantial, complex, and challenging revisions to the information collected and reported on the individuals they serve, and to provide significant training and support to VR counselors who are responsible for much of the new data collection. The commenter stated that, in particular, the PY

2017 and PY 2018 data on measurable skill gains (MSG) among VR participants enrolled in education or training were suppressed by limitations on the timeframe for reporting those gains, combined with the requirement for VR staff to verify the gains with supporting…