1. State Plan for FY 2009- 2011 and Program Review of Statewide AT Programs Jeremy Buzzell and Robert Groenendaal

2. PART 2

3. 3 Overview of State Plan for AT A. Identification and Description of Lead Agency and Implementing Entity; Change in Lead Agency or Implementing Entity B. Advisory Council, Budget Allocations, and Identification of Activities Conducted C. State Financing Activities D. Device Reutilization Activities E. Device Loan Activity F. Device Demonstration Activity G. State Leadership Activities H. Assurances, Performance Measures, Signatures

4. 4 Overview of Program Review A review assesses two “Core Components” of how the state plan is implemented: Core Component 1 – Program Management Core Component 2 – Program Performance Core Component 2 – Program Performance

5. 5 Core Components of Program Review Elements of Program Management Fiscal Management Fiscal Management Personnel Management Personnel Management Contract Oversight Contract Oversight Consumer- responsiveness Consumer- responsiveness Elements of Program Performance Increasing access to, acquisition of, and knowledge about AT Statewideness and comprehensiveness Measurable goals

6. Lead Agency and Implementing Entity Information Required in State Plan Selection and Participation in Program Review

7. 7 State Plan: Identification and Description of Lead Agency 1. Name Given to Statewide AT Program. [Text box] 2. Website dedicated to Statewide AT Program. [Text box] 3. Name and Address of Lead Agency. [Text box] 4. Name, Title, and Contact Information for Lead Agency Certifying Representative. [Text box] 5. Information about Program Director at Lead Agency. [Text box] 6. Information about Program Contact(s) at Lead Agency. [Text box] 7. Telephone at Lead Agency for Public. [Text box] 8. E-mail at Lead Agency for Public. [Text box]

8. 8 State Plan: Identification and Description of Lead Agency 9. Select the most appropriate descriptor of the agency/division/bureau directly responsible for the Statewide AT Program within the Lead Agency. [Drop-down menu]  General Vocational Rehabilitation Agency  Vocational Rehabilitation for the Blind Agency  State Education Agency  University  Health and Human Services Agency  Aging and Disability (or similar) Agency  Other

9. 9 State Plan: Identification and Description of Lead Agency 10. If “Other” was selected for question 9, identify and describe the agency. [Text box] 11. Does your Lead Agency contract with an Implementing Entity to carry out the Statewide AT Program on it’s behalf? [yes/no drop-down menu] If you answered “no” to question 11, you may skip ahead to the items on change in Lead Agency or Implementing Entity. Otherwise, you must answer the following questions.

10. 10 State Plan: Identification and Description of Implementing Entity 12. Name and Address of Implementing Entity. [Text box] 13. Information about Program Director at the Implementing Entity. [Text box] 14. Information about Program Contact(s) at Implementing Entity. [Text box] 15. Telephone at Implementing Entity for Public. [Text box] 16. E-mail at Implementing Entity for Public. [Text box]

11. 11 State Plan: Identification and Description of Implementing Entity 17. Select the most appropriate descriptor of the type of organization that is the Implementing Entity. [Drop-down menu]  AgrAbility Program  Alliance for Technology Access Center  Bank or other financial institution  Easter Seals  Independent Living Center  Institution of Higher Education  Non-categorical disability organization  Organization that primarily serves individuals who are blind or visually impaired  Organization that primarily serves individuals who are deaf or hard of hearing  Organization that primarily serves individuals with developmental disabilities  Organization that primarily serves individuals with physical disabilities  Organization focused specifically on providing AT  Protection and Advocacy organization  UCP  Other

12. 12 State Plan: Identification and Description of Implementing Entity If applicable, the national affiliation of an entity should be selected before other descriptors. These include:  AgrAbility Program  Alliance for Technology Access Center  Easter Seals  Independent Living Center  Protection and Advocacy organization  UCP

13. 13 State Plan: Identification and Description of Implementing Entity If a private entity has no national affiliation, use the following more general descriptors.  Bank or other financial institution  Non-categorical disability organization  Organization that primarily serves individuals…  Organization focused specifically on providing AT  Other 18. If “Other” was selected, identify and describe the entity. [Text box]

14. 14 State Plan: Implementing Entity and Lead Agency 19. Describe the mechanisms established to ensure coordination of activities and collaboration between the Implementing Entity and the state. [Text box] Identify the mechanism used and how the Lead Agency provides oversight and holds the Implementing Entity accountable.

15. 15 State Plan: Change in Lead Agency or Implementing Entity Is the Lead Agency [Implementing Entity] named in this State Plan a new or different Lead Agency from the one designated by the Governor in your previous State Plan? [yes/no drop- down menu] The “previous State Plan” was from October 1, 2005 until the submission of this State Plan. If a change in Lead Agency [Implementing Entity] already has been approved by RSA the state can select “no.” If you select “yes,” the information provided throughout this State Plan should pertain to the new Lead Agency [Implementing Entity].

16. 16 State Plan: Change in Lead Agency or Implementing Entity Explain why the Lead Agency [Implementing Entity] previously designated by your state should not serve as the Lead Agency. [Text box] Explain why the Lead Agency [Implementing Entity] newly designated by your state should serve as the Lead Agency. [Text box]

17. 17 Role of Lead Agencies and Implementing Entities in Program Reviews The LEAD AGENCY is being reviewed. The LEAD AGENCY is being reviewed. Participation from BOTH the Lead Agency and Implementing Entity is expected. Participation from BOTH the Lead Agency and Implementing Entity is expected.

18. 18 How are Lead Agencies selected for review? Random selection of an equal number of grantees in two categories: (1) Grantees that have a title III AFP, serve as the Lead Agency for the AFP, and claim the AFP in State Plan; or (2) Grantees that don’t meet the criteria in (1).

19. 19 How are Lead Agencies selected for review? Exceptions to random selection: Recent (major) change in State Plan (ex: Change in Lead Agency or Implementing Entity). Recent (major) change in State Plan (ex: Change in Lead Agency or Implementing Entity). Recent major disaster. Recent major disaster. RSA is concerned. RSA is concerned.

20. 20 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 overlap) 9 weeks per grantee (some reviews may overlap) First year of reviews: First year of reviews: Jan. 1 to Sept. 30 Jan. 1 to Sept. 30 Only 3 reviews Only 3 reviews

21. 21 What happens when a Lead Agency is selected? RSA notifies grantee in spring prior to next cycle. RSA notifies grantee in spring prior to next cycle. RSA and grantee negotiate 9-week window within next cycle. RSA and grantee negotiate 9-week window within next cycle. RSA recruits third-party (peer) reviewers. RSA recruits third-party (peer) reviewers. Grantee begins preparing for review. Grantee begins preparing for review.

22. 22 Core Components of Program Review Elements of Program Management Fiscal Management Fiscal Management Personnel Management Personnel Management Contract Oversight Contract Oversight Consumer- responsiveness Consumer- responsiveness Elements of Program Performance Increasing access to, acquisition of, and knowledge about AT Statewideness and comprehensiveness Measurable goals

23. Personnel Identification in State Plan Participation in Program Review Review of Personnel Management

24. 24 State Plan: Identification and Description of Lead Agency and Implementing Entity Personnel Name, Title, and Contact Information for Lead Agency Certifying Representative. [Text box] Information about Program Director at Lead Agency [Implementing Entity]. [Text box] Information about Program Contact(s) at Lead Agency [Implementing Entity]. [Text box]

25. 25 Program Review: Personnel Participation Participation of all personnel listed in the State Plan is required to some degree (see exception in next bullet). Participation of all personnel listed in the State Plan is required to some degree (see exception in next bullet). Participation of the Certifying Representative is encouraged but not required. Participation of the Certifying Representative is encouraged but not required.

26. 26 Program Review: Personnel Management OMB Circulars: compensation to personnel must be reasonable compensation to personnel must be reasonable charges to Federal awards for salaries and wages are based on documented payrolls charges to Federal awards for salaries and wages are based on documented payrolls charges for salaries and wages of employees who work solely on a single Federal award are supported by periodic certifications charges for salaries and wages of employees who work solely on a single Federal award are supported by periodic certifications charges for salaries and wages of employees who work on multiple activities are supported by personnel activity reports charges for salaries and wages of employees who work on multiple activities are supported by personnel activity reports

27. 27 Program Review: Personnel Management Submit either: (A) Position descriptions of record for those being paid with grant funds and personnel activity reports for them; OR (B) Synopsis for key personnel describing his or her role and responsibilities associated with the grant.

28. 28 Program Review: Personnel Management What RSA is looking for: Appropriate number of personnel Appropriate number of personnel Appropriate time commitments of personnel Appropriate time commitments of personnel Appropriate duties for personnel Appropriate duties for personnel

29. Role of Consumers in Statewide AT Program State Plan Requirements related to Advisory Council Review of Consumer-responsiveness

30. 30 AT Act: Consumer-responsiveness Comprehensive statewide program means: a consumer responsive program of technology- related assistance for individuals with disabilities, implemented by a State, and equally available to all individuals with disabilities residing in the State, regardless of their type of disability, age, income level, or location of residence in the State, or the type of assistive technology device or assistive technology service required. Sec. 3

31. 31 AT Act: Consumer-responsiveness AT Act definition: easily accessible to, and usable by consumers easily accessible to, and usable by consumers involves consumers in decisions related to the maintenance, improvement, and evaluation of the program involves consumers in decisions related to the maintenance, improvement, and evaluation of the program responds to the needs of consumers in an appropriate manner responds to the needs of consumers in an appropriate manner

32. 32 AT Act: Consumer-responsiveness State plan requirements: Advisory council Advisory council Assurance of ADA compliance Assurance of ADA compliance Assurance of 508 compliance Assurance of 508 compliance

33. 33 AT Act: Advisory Council Requirements related to composition Agency representatives Agency representatives Consumer representatives (diversity and majority) Consumer representatives (diversity and majority) Requirements related to role “advice to the State for, planning of, implementation of, and evaluation of the activities carried out through the grant, including setting the measurable goals”

34. 34 State Plan: Advisory Council 1. In accordance with section 4(c)(2) of the AT Act of 1998, as amended our state has a consumer-majority advisory council that provides consumer-responsive, consumer- driven advice to the state for planning of, implementation of, and evaluation of the activities carried out through the grant, including setting measurable goals. This advisory council is geographically representative of the State and reflects the diversity of the State with respect to race, ethnicity, types of disabilities across the age span, and users of types of services that an individual with a disability may receive. [yes/no drop-down menu]

35. 35 State Plan: Advisory Council 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); [Drop-down menu] 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 (29 U.S.C. 721)); [Drop-down menu] 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 (29 U.S.C. 721)); [Drop-down menu] 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 U.S.C. 796f et seq.); [Drop-down menu] 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 U.S.C. 796f et seq.); [Drop-down menu] 5. The advisory council includes a representative of the State workforce investment board established under section 111 of the Workforce Investment Act of 1998 (29 U.S.C. 2821); [Drop-down menu] 5. The advisory council includes a representative of the State workforce investment board established under section 111 of the Workforce Investment Act of 1998 (29 U.S.C. 2821); [Drop-down menu] 6. The advisory council includes a representative of the State educational agency, as defined in section 9101 of the Elementary and Secondary Education Act of 1965; [Drop-down menu]

36. 36 State Plan: Advisory Council 7. The advisory council includes other representatives (list below). [Text box] 8. The advisory council includes the following number of individuals with disabilities that use assistive technology or their family members or guardians: [Number field] 9. If the Statewide AT Program does not have the composition and representation required under section 4(c)(2)(B), explain here. [Text box]

37. 37 Program Review: Role of Advisory Council/Consumers No role for consumers not affiliated with the advisory council. No role for consumers not affiliated with the advisory council. Participation by the advisory council is encouraged but not required. Participation by the advisory council is encouraged but not required. Dissemination of final results to advisory council is expected. Dissemination of final results to advisory council is expected.

38. 38 Program Review: Consumer- responsiveness Submit to RSA: A description of advisory council: A description of advisory council: List all members List all members Describe members (not personally identifiable) Describe members (not personally identifiable) Describe council operations Describe council operations Description of any other consumer feedback mechanisms Description of any other consumer feedback mechanisms

39. 39 Program Review: Consumer- responsiveness Submit to RSA: A description of how the grantee ensures compliance with ADA (including subcontracts, if applicable) A description of how the grantee ensures compliance with ADA (including subcontracts, if applicable) A description of how the grantee ensures compliance with 508 (including subcontracts) A description of how the grantee ensures compliance with 508 (including subcontracts)

40. 40 Program Review: Consumer- responsiveness What RSA is looking for: Completeness of council Completeness of council Role of council Role of council How grantee ensures ongoing 508 and ADA compliance How grantee ensures ongoing 508 and ADA compliance

41. Use of Funds Funding Information in State Plan Review of Fiscal Management

42. 42 Use of Funds Requirements in AT Act: 60/40%, 70/30%, 5% 60/40%, 70/30%, 5% 10% indirect limitation 10% 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 with AT Act State plan assurance that the funds are expended in accordance with AT Act State plan description of planned tracking procedures for expenditures State plan description of planned tracking procedures for expenditures State Plan assurance you have fiscal control and accounting procedures necessary to ensure proper accounting of funds State Plan assurance you have fiscal control and accounting procedures necessary to ensure proper accounting of funds Proposed budget allocations in State Plan Proposed budget allocations in State Plan

43. 43 State Plan: Proposed Budget Allocations State Financing Activities [Drop-down menu] Device Reutilization Activities [Drop-down menu] Device Loan Activity [Drop-down menu] Device Demonstration Activity [Drop-down menu] State Leadership Activities [Drop-down menu]  Claiming Comparability  Claiming Flexibility  $1 to $10,000  $10,001 to $20,000  $20,001 to $30,000 …  $90,001 to $100,000  More than $100,000

44. 44 State Plan: Proposed Budget Allocations For every activity for which you selected “claiming comparability,” describe the comparable activity: [text box]

45. 45 State Plan: Tracking Use of Funds Describe your planned procedures for tracking expenditures for State-level and State Leadership Activities: [Text box]

46. 46 Program Review: Fiscal Management In addition to State Plan requirements... EDGAR requirements: Fiscal control and accounting procedures to insure proper disbursement of and accounting for Federal funds and adequate to establish that such funds have not been used in violation of applicable statutes Fiscal control and accounting procedures to insure proper disbursement of and accounting for Federal funds and adequate to establish that such funds have not been used in violation of applicable statutes Records that fully show the amount of funds under the grant, 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 facilitate an effective audit Records that fully show the amount of funds under the grant, 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 facilitate an effective audit Audits in accordance with OMB A-133. Audits in accordance with OMB A-133.

47. 47 Program Review: Fiscal Management Submit to RSA: Expenditure report Expenditure report Approved indirect cost rate agreement/cost allocation plan OR questionnaire provided by RSA (applies to both Lead Agencies and Implementing Entities) Approved indirect cost rate agreement/cost allocation plan OR questionnaire provided by RSA (applies to both Lead Agencies and Implementing Entities) Copies of most recent audit reports OR questionnaire provided by RSA (applies to both Lead Agencies and Implementing Entities) Copies of most recent audit reports OR questionnaire provided by RSA (applies to both Lead Agencies and Implementing Entities) In addition, RSA will look at SF-269s and GAPS records.

48. 48 Program Review: Expenditure Report 1 for Lead Agency, 1 for Implementing Entity 1 for Lead Agency, 1 for Implementing Entity Most recent annual award for which obligation and liquidation is complete. Most recent annual award for which obligation and 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 understand it. There is no “format,” but RSA must be able to understand it. It must account for all funds – including those brought into the program from other sources. It must account for all funds – including those brought into the program from other sources.

49. 49 Expenditure Report What RSA is looking for: Existence, quality, legitimacy of report Existence, 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 limits Compliance with indirect cost limits

50. 50 Program Review: Indirect Cost Rates What RSA is looking for: Existence of agreement Existence of agreement Appropriate kind of agreement Appropriate kind of agreement Handling of indirect if Implementing Entity is involved Handling of indirect if Implementing Entity is involved Amount of indirect will be seen in expenditure report Amount of indirect will be seen in expenditure report

51. 51 Program Review: Audits What RSA is looking for: An audit was done (if required) An audit was done (if required) Findings of the audit Findings of the audit Resolution of findings Resolution of findings

52. 52 SF-269s and GAPS Records What RSA is looking for: Full use of funds Full use of funds Timely use of funds Timely use of funds Completeness and accuracy of financial reports Completeness and accuracy of financial reports

53. Involvement of Other Entities State Plan requirements related to involvement of other entities Program Review of Contract Oversight

54. 54 AT Act Requirements Related to Other Entities State plan must describe how public and private entities were involved in developing the State Plan and will be involved in implementation (including resources) State plan must describe how public and private entities were involved in developing the State Plan and will be involved in implementation (including resources) State plan must describe state support State plan must describe state support State leadership activities include coordination and collaboration State leadership activities include coordination and collaboration Data collection related to leveraged funds Data collection related to leveraged funds

55. 55 State Plan: Identifying Involvement of Other Entities For each activity: Who conducts this activity? (Check all that apply)  The Statewide AT Program [check-box to indicate “yes”]  Other entities (e.g., contractors) [check-box to indicate “yes”]

56. 56 State Plan: Identifying Involvement of Other Entities The Statewide AT Program provides and/or receives the following support (choose all that apply): The Statewide AT Program provides and/or receives the following support (choose all that apply): Provides financial support to other entities via an agreement with the Statewide AT Program. [check-box to indicate “yes”] Provides financial support to other entities via an agreement with the Statewide AT Program. [check-box to indicate “yes”] Provides in-kind support to other entities via an agreement with the Statewide AT Program. [check-box to indicate “yes”] Provides in-kind support to other entities via an agreement with the Statewide AT Program. [check-box to indicate “yes”] Receives financial support from the state. [check-box to indicate “yes”] Receives financial support from the state. [check-box to indicate “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 “yes”] Receives financial support from private entities. [check-box to indicate “yes”] Receives in-kind support from private entities. [check-box to indicate “yes”] Receives in-kind support from private entities. [check-box to indicate “yes”]

57. 57 State Plan: Identifying Involvement of Other Entities The Statewide AT Program provides and/or receives the following support (choose all that apply): CONT’D The Statewide AT Program provides and/or receives the following support (choose all that apply): CONT’D Coordinates and collaborates with other entities for the purpose of establishing a new program or service. [check-box to indicate “yes”] Coordinates and collaborates with other entities for the purpose of establishing a new program or service. [check-box to indicate “yes”] Coordinates and collaborates with other entities for the purpose of expanding an existing program or service. [check-box to indicate “yes”] Coordinates and collaborates with other entities for the purpose of expanding an existing program or service. [check-box to indicate “yes”] Coordinates and collaborates with other entities for the purpose of reducing duplication of programs or services. [check-box to indicate “yes”] Coordinates and collaborates with other entities for the purpose of reducing duplication of programs or services. [check-box to indicate “yes”]

58. 58 State Plan: Identifying Involvement of Other Entities If you conduct this activity by providing financial or in-kind support to other entities, identify the kinds of entities you support in column (a) of the following table. If you receive financial or in-kind support from the state to conduct this activity, identify the state entities that provide this support in column (b) of the following table. If you receive financial or in-kind support from private entities, identify the private entities that provide this support in column (c) of the following table. If you coordinate and collaborate with other entities in conducting this activity, identify those entities in column (d) of the following table.

59. 59

60. 60 State Plan: Identifying Involvement of Other Entities Other information related to coordination and collaboration and leveraging of funds is captured under data collection.

61. 61 Program Review: Contract Oversight EDGAR requires grantees to: directly administer or supervise the administration of each project directly administer or supervise the administration of each project have procedures for providing TA, evaluation and for performing other administrative responsibilities necessary to ensure compliance have procedures for providing TA, evaluation and for performing other administrative responsibilities necessary to ensure compliance monitor activities to assure compliance with applicable Federal requirements and that performance goals are being achieved monitor activities to assure compliance with applicable Federal requirements and that performance goals are being achieved

62. 62 Program Review: Contract Oversight Submit either: (A) The state’s contract selection policies and a sample of contracts (selected by RSA after reviewing State Plan – Implementing Entity always is in sample); OR (B) A synopsis of major contracts. This is contracts FROM and contracts TO the grantee – but only those claimed in State Plan and used for reporting data

63. 63 Program Review: Contract Oversight Synopsis of major subcontracts (to and from) includes: Amount of funds Amount of funds Kind of entity and qualifications Kind of entity and qualifications Method for choosing entity Method for choosing entity Duties carried out by entity Duties carried out by entity Any limitations Any limitations Methods of oversight Methods of oversight Methods for collecting and reporting data Methods for collecting and reporting data

64. 64 Program Review: Contract Oversight What RSA is looking for: Appropriate process for awarding Appropriate process for awarding Appropriate entities receiving awards Appropriate entities receiving awards Appropriate oversight to protect Federal interests and ensure implementation Appropriate oversight to protect Federal interests and ensure implementation Relevant to the AT Act Relevant to the AT Act

65. 65 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 (the grantee is responsible for bringing together the appropriate parties) RSA discusses the documents via conference call (the grantee is responsible for bringing together the appropriate parties) RSA uses this information to answer questions about program management. RSA uses this information to answer questions about program management. Yes/no with explanation. Yes/no with explanation.

66. 66 Questions about Program Management 1. Does the grantee account for its funds accurately and completely in accordance with EDGAR and 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 not, does the grantee have a plan for improving the timeliness of obligations and liquidations? 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 increasing the amount of funds it uses? 5. Does the grantee comply with indirect cost requirements? 6. Does the grantee comply with audit requirements?

67. 67 Questions about Program Management 7. Does the grantee select subcontractors in accordance with generally accepted practice? If not, does the grantee have a plan for improving its selection process? 8. Does the grantee exercise appropriate fiscal and performance oversight of its subcontracts? If not, does the grantee have a plan for improving its oversight? 9. Is the inclusion of subcontracts received by the grantee in the grantee’s State Plan and annual data justified?

68. 68 Questions about Program Management 10. Does the grantee distribute the time of its personnel appropriately based on their responsibilities? If not, does the grantee have a plan to distribute time more appropriately? 11. Does the grantee support with grant funds only personnel with responsibilities germane to the grant?

69. 69 Questions about Program Management 12. Does the grantee have processes and procedures to ensure ongoing physical and programmatic accessibility? If not, does the grantee have a plan for improving its physical and programmatic accessibility? 13. Does the grantee have and use an advisory council that meets the requirements of the AT Act and is involved in the Statewide AT Program as the AT Act intends? If not, does the grantee have a plan for improving its advisory council? 14. Is there evidence of other efforts at making the program more consumer-responsive?

70. 70 Assessing Compliance of Program Management There is no overall rating of compliance. For each element of Program Management, a grantee will receive 1 of 3 ratings: Compliant Compliant In Need of Improvement In Need of Improvement Fails to substantially comply Fails to substantially comply

71. 71 Assessing Compliance of Program Management The rating is based on how RSA answers the questions: Initial question: Does the grantee maximize the use of its funds? Initial question: Does the grantee maximize the use of its funds? Subquestion: If not, does the grantee have a plan for increasing the amount of funds it uses? Subquestion: If not, does the grantee have a plan for increasing the amount of funds it uses?

72. 72 Assessing Compliance of Program Management If the answer to the initial question is “Yes” – the grantee is rated as compliant. If the answer to the initial question is “Yes” – the grantee is rated as compliant. If the answer to the initial question is “No” – the rating depends on the answer to the subquestion. If the answer to the initial question is “No” – the rating depends on the answer to the subquestion. If the answer to the subquestion is “Yes” – the grantee is rated as in need of improvement. If the answer to the subquestion is “Yes” – the grantee is rated as in need of improvement. If the answer to the subquestion is “No” – the grantee is rated as failing to substantially comply. If the answer to the subquestion is “No” – the grantee is rated as failing to substantially comply.

73. 73 Assessing Compliance of Program Management 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 germane to the grant? Does the grantee support with grant funds only personnel with responsibilities germane to the grant? Is the inclusion of subcontracts received by the grantee in the grantee’s State Plan and NISAT data justified? Is the inclusion of subcontracts received by the grantee in the grantee’s State Plan and NISAT data justified? Is there evidence of other efforts at making the program more consumer- responsive?... is not rated at all Is there evidence of other efforts at making the program more consumer- responsive?... is not rated at all

74. 74 Assessing Compliance of Program Management The onus is on the grantee to present evidence/plan sufficient to get to a “yes” answer. RSA will ask questions or provide examples of sufficient evidence if needed. RSA will ask questions or provide examples of sufficient evidence if needed. Grantee likely will know their status before the conversation is over. Grantee likely will know their status before the conversation is over.