BE A FI$CAL $.T.A.R. VR PRACTICES

RSA-2 and SF 425 REPORTING Presenters: Julya Doyle, Management and Program Analyst, SMPID Fiscal Unit Craig McManus, Financial Management Analyst, SMPID Fiscal Unit Scott Dennis, Director, Business Support Services, Maryland Division of Rehabilitation Services

OVERVIEW RSA-2: Changes to the New Form Maryland Practice for Data Reporting Questions SF-425: Recent Changes and Common Reporting Errors Grant Closeout Procedures Questions

RSA–2 Form RSA–2 Form The Annual Vocational Rehabilitation Program/Cost Report (RSA-2) for the Vocational Rehabilitation (VR) and Supported Employment (SE) programs captures: Administrative expenditures for the VR and SE programs; VR program service expenditures by category; SE program service expenditures; Expenditures for the VR program by number of individuals receiving purchased services; The costs by type of services provided; and A breakdown of staff employed by the VR agencies.

RSA-2 Form: General Revisions General revisions to the RSA-2 form (RSA-PD-13-04) include: Removing Schedule IV, Expenditures from Title VI-B Funds and Other Rehabilitation Funds, and Schedule V, Carryover Funds, from the RSA-2 form because these sections were found to be redundant with other fiscal data collection forms; Removing the requirement to include unliquidated obligations when calculating expenses; Removing data elements that RSA could calculate based upon other information provided by the agency (e.g., subtotals and totals); and Aligning the service categories with those contained in the VR program Case Service Report (RSA-911) data collection instrument.

RSA-2 Form: Schedule Revisions The RSA-2 form has been reduced from 5 schedules to 3 schedules: Prior Schedule I renamed from Total Expenditures to Agency Expenditures; Prior Schedule II (Individuals Served and Expenditures) moved to Schedule III; Prior Schedule III (Person Years) moved to Schedule II and revised (Labor Hours); Prior Schedule IV (Title VI-B and other Rehabilitation Funds) eliminated and Supported Employment pulled into Schedule I and III; and Prior Schedule V (Carryover Funds) eliminated as this data is collected in the SF-425 report.

Schedule I  The administrative costs in Line 1 have been expanded to include expenditures related to: Personnel costs; Direct costs; Indirect costs; and SE program costs.  Transition Consultation and Technical Assistance (3.D) has been added under Services to Groups Expenditures.

Schedule II  The basis for calculation of personnel effort has been changed from person-years to labor hours. Examples for calculating full-time and part-time employees are provided.  A separate data field is provided (line 5) to denote the number of hours considered full time in the state, due to state variation in the weekly threshold.

Schedule III  The new RSA-2 form has expanded to 28 discrete service categories that align with the RSA-911 form, combining both VR and SE program funds.  Schedule III will only include the number of individuals and expenditures for purchased services.

Schedule III (cont.)  The instructions for “Information and Referral” were clarified by including an “e.g.” before cooperative agreements to indicate that this is an example, and not the only source through which information and referral services may be provided.

Schedule III (cont.)  The Post-Employment Services category was eliminated as a service category in the new form.  Services provided under Post-Employment should now be recorded in the appropriate service category.

Schedule III (cont.)  The description of Vocational Rehabilitation Counseling and Guidance was clarified to ensure consistency with the VR regulations.  For purposes of Schedule III – purchased VR Counseling and Guidance is distinct from the case management relationship between counselor and individual during the VR process.

Schedule III (cont.)  The former Training service sub-categories were expanded into discrete categories, including: Graduate College or University Training; Four-Year College or University Training; Junior or Community College Training; Occupational or Vocational Training; On-the-job Training; Apprenticeship Training; Basic Academic Remedial or Literacy Training; Job Readiness Training; Disability Related Skills Training; and Miscellaneous Training.

Schedule III (cont.)  Some new additional service categories to note include: Job Search Assistance; On-the-job Supports – Time limited; On-the-job Supports – Supported Employment; Reader; Interpreter; Technical Assistance; Benefits Counseling; and Customized Employment.

Schedule III (cont.)  Cross-checking data: The dollar amounts on Schedule III, should reflect the total of the amounts included in Schedule I, Agency Expenditures, Section 2.B., lines 1 through 4.

Form Access The RSA-2 and SF-425 forms are available on the RSA website ( Agencies must ensure the appropriate personnel maintain, obtain, or perhaps terminate their access to the program and fiscal reports To obtain access from the website, select “Info for new users” on the right side of the home page and follow the instructions under “OBTAINING MIS ACCESS.”

G5 Access The SF-425 instructions require grantees to verify drawdowns from G5. Therefore, staff responsible for reporting will be required to register in the G5 system to access grant funds: ( Follow the instructions after selecting the “Non ED employee Sign Up” link.

RSA-2 Impact – State Partner RSA-2 Impact – State Partner Schedules I and II do not impact the agency’s data collection or reporting.

Schedule III Impact – State Partner  DORS Case Management System Revision of the existing Category System Realigning and creating new sub-categories to match new reporting requirements System testing

Schedule III Impact – State Partner  Staff Staff adjustment to the new coding categories Training of staff on new service categories Quality assurance testing to assess effectiveness of staff training Staff time providing Counseling and Guidance (case management) on Schedule I vs. purchased Counseling and Guidance on Schedule III

Schedule III Impact – State Partner  Community Rehabilitation Programs (CRPs) Training on potential impact for CRP service reporting Training CRP staff on new RSA coding requirements CRP billing concerns – specificity of services on invoices Example: Prior RSA-2 includes job related services, which are not split into several discrete service categories in the revised RSA-2 (e.g., Job Search Assistance, Job Placement Assistance, and On-the-Job-Supports – Time Limited)

Schedule III Impact – State Partner Reporting – State Partner  Tying Schedule 1, Section 2 to Schedule III  Agencies may not report activity for some service categories (e.g., Customized Employment)

QUESTIONS – RSA-2

Recent SF-425 Changes and Clarifications Recent SF-425 Changes and Clarifications RSA-PD Cash Receipts and Disbursements – Lines 10a and 10b Federal Share of Expenditures – Line 10e Program Income – Lines 10l through 10o Indirect Expenses – Lines 11a through 11f Remarks – Lines 12a through 12h

Cash Receipts and Disbursements Cash Receipts should be reported as the net amount that the grantee has drawn down from G5. Cash Disbursements are the sum of the actual cash expenditures made for direct charges for goods and services, the amount of indirect expenses charged to the award, and the amount of cash advances and payments made to contractors/vendors. For each reporting period these two lines are an accumulative amount. They should include the amount drawn down and the amount disbursed from the start of the award through that report period end date.

Federal Share of Expenditures For Annual Reports prepared on a cash basis, the agency should report federal fund expenditures as the sum of cash disbursements for direct charges for goods and services, the amount of indirect expenses charged, and the amount of payments made to contractors/ vendors. For reports prepared on an accrual basis, grantees should report federal fund expenditures listed above as well as and the increase or decrease in the amounts owed by the recipients for goods received and services performed by employees, contractors/vendors, and other payees. The final report should include the total sum of expenditures. Line 10e should equal Cash Receipts and Disbursements.

Program Income Program Income is considered earned in the fiscal year in which the funds were actually received by the grantee. VR Program Income is the gross income received by the grantee that is directly generated by an activity supported under the VR program.

Deduction and Addition Alternative, What’s the Difference? The Addition Alternative (line 10n) is used when the agency supplemented the federal share of the total program costs, representing actual disbursements of program income by the grantee. The Deduction Alternative (line 10m) should be used when program income was used to reduce the federal share of the total VR program costs. The amount of funds entered in line 10m will reduce the federal share, resulting in the return of these funds to RSA.

Transferring Program Income When Social Security Reimbursement program income is transferred to another eligible program, the program income is reported on Line 10l (Total Federal Program Income Earned) of both the transferring (VR) and receiving programs’ SF-425 reports. Additionally, both the transferring and receiving programs report program income expended on line 10n (Program Income Expended in Accordance with the Addition Alternative). The transferring program will report the amount transferred to the receiving program in the appropriate line in section 12. The receiving program will identify that the program income was not earned, but received through transfer, in section 12 remarks.

Section 11: Indirect Expenses Whether an agency has an Approved Indirect Cost Rate or a Cost Allocation Plan, the agency must fill out section a – Type of Rate 11b – Rate 11c – Period from; Period to 11d – Base 11e – Amount Charged 11f – Federal Share

Section 12: Remarks Section 12 – The Remarks section was revised and lists eight data elements, six allow for data to be entered. These items include: 12a – reporting on the non-federal share of expenditures for the construction and establishment of facilities for community rehabilitation program purposes; 12d – recipient share of unliquidated obligations – the portion of unpaid obligations to be paid with non-federal funds meeting program requirements; 12e, f and g – the transfer of federal VR Social Security reimbursement program income to other eligible programs (SILS, OIB, CAP); 2h – the total federal VR Social Security reimbursement program income transferred to all eligible programs; and 12b and c – not applicable.

Grant Closeout Grant Closeout All final reports are due 90 days after the end of grant support, at which time RSA will begin the closeout process. The grant may be closed out if the following criteria are met: Grant funds are no longer available for liquidation after the performance period ends; All funds remaining in G5 were either deobligated or liquidated; All required performance and financial reports have been received; All single audits for the grant period have been resolved; and There are no outstanding issues that were identified in the monitoring reports.

Grant Closeout Checklist. There are no validation errors on the form and each line required was filled out. Final Performance and Financial Reports have been submitted. There is no Cash on Hand. Cash Receipts equal Net Draws from G5. Federal Expenditures equal Net Draws from G5. Recipient Share of Expenditures is greater than or equal to Total Recipient Share Required. There are no unliquidated obligations. There is no unexpended Program Income. Let’s look at the line items in more detail…

Grant Closeout – Final Reports. All final performance and financial reports associated with the award must be completed and submitted. If the grantee liquidates obligated funds within the 90-day liquidation period, the grantee does not need to submit an SF-425 report on 9/30 and then another SF-425 after the funds are liquidated. If a grantee has Late Liquidation approved, the grantee submits the Final (9/30) SF-425 report at the end of the extended liquidation period.

Grant Closeout – Cash Receipts and Disbursements. Cash Receipts (line 10a) must equal Cash Disbursements (line 10b), indicating that there is no cash that was drawn down, but not spent for the grant period. Cash Receipts (line 10a) must equal the amount of award drawdowns from the G5 system (Net Draws).

Grant Closeout – Expenditures.Federal Share of Expenditures (line 10e) equals net drawdowns from G5. Do not include federal program income received by the grantee on line 10e. Recipient Share of Expenditures (line 10j) is greater than or equal to Total Recipient Share Required (line 10i), indicating that the grantee has met the match requirement.

Grant Closeout – Unliquidated Obligations and Program Income. Federal Share of Unliquidated Obligations (line 10f) and Recipient Share of Unliquidated Obligations (line 12d) must be zero, indicating there are no remaining obligations under this grant award which have not been paid. Unexpended Program Income (line 10o) must be zero, indicating that all program income was expended. Program Income cannot be transferred from one grant award year to another grant award year.

Noncompliant Grant Closeouts. If all of the steps outlined earlier are met, the grant award will be closed in compliance, but if any of the above are not corrected the grant award may be closed in noncompliance. The Department is adhering to stricter accountability related to noncompliance.

References.  Grant Closeout – 34 CFR and CFR  Financial Reporting Requirements – 34 CFR  Program Income – 34 CFR and 34 CFR 80.21(f)(2)  Non Compliance Actions – 34 CFR  VR Counseling and Guidance – 34 CFR (c)  Services to Groups – 34 CFR  Revision of Annual Vocational Rehabilitation Program/Cost Report (RSA-2) for the State Vocational Rehabilitation Services Program and the State Supported Employment Services Program – RSA-PD  Revision of PD-11-02, instructions for completing the Federal Financial Report (SF-425) for the Vocational Rehabilitation State Grants Program. – RSA-PD-12-06

QUESTIONS – SF-425