RSA offers this guide to support State Vocational Rehabilitation (VR) agency directors in the important work of administering Federally funded programs under the Rehabilitation Act of 1973 (Rehabilitation Act), as amended by Title IV of the Workforce Innovation and Opportunity Act (WIOA), including the State VR Services program (Title I); State Supported Employment Services program (Title VI); and Independent Living Services for Older Individuals who are Blind program (Title VII, Chapter 2)
RSA developed this orientation to assist State VR agency leadership in the effective administration and management of their programs. Please contact your RSA State Liaison with questions or for assistance in locating other resources.
RSA provides leadership and resources to assist States and other agencies in providing VR and other services to individuals with disabilities, including students and youth with disabilities, to maximize their employment, independence, and integration into the community and the competitive labor market.
RSA is a component of the Office of Special Education and Rehabilitative Services (OSERS) within the U.S. Department of Education. The mission of OSERS is to improve early childhood, educational, and employment outcomes and raise expectations for all people with disabilities, their families, their communities, and the nation. OSERS’ vision is that all Americans with disabilities will live and thrive in their own communities.
RSA is established by Congress as the principal Federal agency authorized to carry out Titles I, III, V (Sections 509 and 511), VI, and VII (Chapter 2) of the Rehabilitation Act. Additionally, RSA administers programs and activities under the Randolph-Sheppard Act, as amended.
The programs administered by RSA develop and implement comprehensive systems of vocational rehabilitation, supported employment, and independent living services for older individuals who are blind through the provision of services, training, and advocacy to maximize the employment, independence, and integration of individuals with disabilities in their communities.
RSA accomplishes its mission by:
Administering formula and discretionary grant programs authorized by Congress;
Evaluating, monitoring, and reporting on the implementation of Federal policy and programs and the effectiveness of vocational rehabilitation, supported employment, independent living services for older individuals who are blind, and other related programs for individuals with disabilities; and
Coordinating with other Federal agencies, State agencies, and the private sector including professional organizations, service providers, and organizations of persons with disabilities for the review of program planning, implementation, and monitoring.
RSA Divisions and Staff
RSA is led by a Commissioner who advises the Secretary and the Assistant Secretary for OSERS on programs and issues affecting individuals with disabilities. The Commissioner and Deputy Commissioner provide overall direction, coordination, and leadership to RSA's two Divisions: State Monitoring and Program Improvement Division (SMPID) and Training and Service Programs Division (TSPD).
SMPID is responsible for reviewing and approving WIOA Unified and Combined State Plans, administering and monitoring formula grant programs, and providing technical assistance to ensure consistency with Federal requirements and to ensure that States continue to implement programs designed to improve and maximize employment outcomes and self-sufficiency for individuals with disabilities. SMPID consists of four functional Units and four State Teams.
RSA State Liaisons and Project Officers
Each State VR agency is assigned an RSA State Liaison who can assist you with questions or concerns you may have about the Federal formula grants. See links below for project officers and descriptions for the following programs:
RSA State Liaisons, Project Officers, and State Teams also may respond to inquiries or provide assistance to the public, individuals with disabilities, and other stakeholders.
TSPD administers several programs under the Rehabilitation Act, as amended by Title IV of WIOA, and the Randolph-Sheppard Act. The programs include competitive and discretionary grants. TSPD consists of two units: the Training Programs Unit administers the rehabilitation training and special demonstration programs while the Service Programs Unit administers direct service-related programs and projects.
TSPD staff carry out the following activities in administering these programs:
Monitor grants and provide technical assistance;
Conduct discretionary grant competitions and process grant awards;
Coordinate arbitrations for the Randolph-Sheppard program;
Review and analyze data, prepare reports including the annual summary of the vendors and vending facilities; and
Work with grantees to develop program performance measures, which are used to evaluate and monitor grantees.
Legislation, Regulations and Sub-Regulatory Guidance
In order to effectively administer Federal awards and manage programs, State VR agencies must be knowledgeable and familiar with applicable statutory and regulatory requirements. It is also important to understand sub-regulatory guidance. RSA recommends routinely sharing such information with State VR agency staff to assist them in understanding the basis for leadership decisions and policy development. Below you will find listed legislation, regulations, and guidance that are fundamental to the administration and management of RSA grants.
WIOA and its implementing Federal regulations are designed to strengthen and improve our nation's public workforce system and help Americans with significant barriers to employment, including individuals with disabilities, achieve high quality jobs and careers and help employers hire and retain skilled workers.
The U.S. Department of Education issues regulations to clarify and implement statutory requirements applicable to programs administered under the Rehabilitation Act of 1973, as amended by Title IV of WIOA and the Randolph-Sheppard Act. These "program regulations" establish requirements that grantees must follow, in addition to applicable requirements in legislation.
RSA establishes policy and prescribes the methods found necessary for the proper and efficient administration of the programs for which RSA is responsible. Joint guidance issued by the U.S. Department of Education with other Federal agencies, such as the U.S. Department of Labor, may also be found under Sub-Regulatory Guidance.
Policy Directives (PD) are formal statements of required action(s) or condition(s) that must be carried out or met by State VR agencies or other RSA grantees in order to be in compliance with the Acts. A PD is legally enforceable because it is based on a statutory or regulatory provision.
Technical Assistance Circulars (TAC) are formal statements of guidelines and/or suggested methods to satisfy statutory, regulatory or policy requirements. A TAC addresses those areas of program requirements for which State VR agencies or other RSA grantees have flexibility in determining precisely how such requirements are to be met.
Information Memoranda transmit information to grantees who operate formula or discretionary grant programs authorized by the Acts, and to individuals who are responsible for monitoring these programs.
Grant Award Notifications are official documents signed by an obligator stating the amount and conditions of a Federal award for a formula grant.
Dear Director Letters provide broad written guidance and clarification regarding implementation of the Rehabilitation Act. RSA typically issues these letters in response to specific questions raised by grantees, representatives of advocacy organizations, stakeholders, community rehabilitation providers, and other interested parties.
Frequently Asked Questions provide information, guidance and clarification regarding implementation of the Rehabilitation Act through the presentation of important questions complete with responses to these questions.
Other Guidance include guides, explanatory letters, and procedure documents based on support identified by grantees, stakeholders, Federal partners, and other interested parties.
Order of Selection (OOS)
Section 101(a)(5) of the Rehabilitation Act of 1973, as amended by title IV of WIOA, establishes provisions related to OOS for VR services. The U.S. Department of Education implements these provisions in VR program regulations at 34 CFR § 361.36. VR agencies outline their ability to serve all eligible individuals with disabilities in the VR Services Portion (part "m") of the WIOA Unified and Combined State Plans. Priority must be given to serving individuals with the most significant disabilities if a VR agency is unable to serve all eligible individuals with disabilities.
State Rehabilitation Councils (SRC)
The SRC is a key partner with the State VR agency in the administration of the VR program. Among its many responsibilities, the SRC reviews, evaluates, and advises the agency regarding its performance and effectiveness in the delivery of services and the effect of service provision on the achievement of employment outcomes by individuals with disabilities. Additionally, the SRC ensures that the community of stakeholders’ voice is heard as agencies develop and implement policies and procedures that directly affect the individuals served by the VR agency.
The SRC brings together a variety of individuals with disabilities, disability groups, VR professionals, service providers, and leaders in the community, including those representing business, industry, and labor. The requirements for the SRC composition and responsibilities are specified in Section 105 of the Rehabilitation Act and 34 C.F.R. §§ 361.16 and 361.17.
The Rehabilitation Act requires the State Plan to specify that the designated State agency (DSA) either is an independent commission or has established an SRC. Most states have established an SRC to work in partnership with the DSA and the designated State unit. There are, however, a few State VR agencies that are organized as "independent commissions." Section 101(a)(21)(A)(i) of the Rehabilitation Act sets forth State Plan requirements for independent consumer-controlled commissions.
WIOA Unified and Combined State Plans
WIOA Unified and Combined State Plans outline the strategies and operational planning elements State and Territories are implementing to assist employers and job-seekers, including those with barriers to employment, such as individuals with disabilities, into high-quality careers while providing businesses with skilled workers. Unified and Combined State Plans also enhance the coordination and partnerships across core programs and other educational and service entities to improve efficiency in service delivery across the State and local areas. The VR agency administers a core program and should be integrally involved in the development of the Unified or Combined State Plan with other partner programs.
As a part of the Unified or Combined State Plan, the VR agency must submit the VR services portion of the State Plan to meet the requirements in Section 101 of the Rehabilitation Act. The VR services portion of the State Plan includes multiple descriptions and assurances related to the effective administration of the VR and Supported Employment programs. RSA reviews each VR services portion of the Unified or Combined State Plan prior to approval by the RSA Commissioner and works closely with VR agencies to provide feedback, as necessary, to ensure all descriptions and assurances are accurate. RSA also reviews to the State Plan during State VR agency monitoring and review activities.
Under WIOA, States and Territories developed the first Unified and Combined State Plans for the four-year period covering Program Years 2016 through 2019 (July 1, 2016 - June 30, 2020) in the Spring of 2016. WIOA requires States and Territories to modify their State Plans at least every two years, or before the start of the third program year. In the Spring of 2018, States and Territories developed and submitted its two-year modifications covering Program Years 2019 and 2020 (July 1, 2019 - June 30, 2020). The approved Unified and Combined State Plans and two-year modifications are available on the WIOA State Plan Portal.
In the Spring of 2020, States and Territories submitted their second four-year Unified and Combined State Plans covering Program Years 2020 through 2023 (July 1, 2020 - June 30, 2024). Two-year modifications will be due in the Spring of 2022 for implementation beginning on July 1, 2022. States are required to submit a Unified or Combined State plan every four years and a two-year modification will be due in the Spring of the second year of the four year State plan cycle for implementation at the start of the third program year (July 1).
The U.S. Departments of Education and Labor publish approved State Plans on the WIOA State Plan Portal. States and Territories have the option to submit modifications to its Unified or Combined State plan for review and approval by the Departments of Education and Labor.
Additional technical assistance resources related to Unified and Combined State Plans developed by the U.S. Departments of Education and Labor are available using these links:
Monitoring of the Vocational Rehabilitation and Supported Employment Programs
Section 107 of the Rehabilitation Act requires RSA to conduct annual reviews and periodic on-site monitoring of programs authorized under Title I of the Rehabilitation Act to determine whether a State VR agency is complying substantially with the provisions of its State Plan under Section 101 and with the Evaluation Standards and Performance Indicators established under Section 106, as well as the performance accountability measures and requirements under Section 116 of WIOA.
Monitoring is conducted by State Teams on-site; however, under certain circumstances off-site reviews are conducted. RSA reviews and analyzes the programmatic and financial performance of the State VR agency and provides technical assistance as needed to assist the State VR agency with continuous improvement. RSA selects State VR agencies to monitor using an accountability model, taking into account the specific needs identified by either RSA or the State VR agency. Beginning with Federal Fiscal year 2007, Monitoring and Technical Assistance Guides (MTAGs) and monitoring reports are available here.
Fiscal Management and Resources
To assist States with the fiscal administration of the VR and other formula grant programs authorized under the Rehabilitation Act, RSA developed several fiscal resources including policy directives and training materials on specific areas of fiscal policy and program administration. Financial management of RSA formula awards is governed by two general types of Federal laws and regulations: those that are applicable governmentwide and those that are program specific.
The Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards: 2 C.F.R. Part 200, also known as the Uniform Guidance, is a key regulation applicable to all Federal awards.
The Uniform Guidance includes requirements pertaining to allowable and allocable costs, financial management, internal controls, prior (written) approval, property standards, financial monitoring and reporting, remedies for non-compliance, procurement, audit, indirect costs/cost allocation plans, among many other topics.
Grant Award Notifications
In addition to the program-specific laws and regulations noted at the beginning of this document, grantees are responsible for carrying out grant terms and conditions noted in each award’s Grant Award Notification (GAN). GAN terms and conditions are available to directors after the start of the Federal fiscal year when awards are made in G5, the U.S. Department of Education’s Financial Management System. GANs include attachments from RSA that note key requirements applicable to the specific award. Grantees should refer to GANs for current awards, available in G5, as the terms and conditions are subject to change year to year.
Fiscal Technical Assistance
While the Fiscal Technical Assistance page of the website will eventually provide a more thorough overview of financial management topics, several key RSA formula award financial management topics and associated resources are included below.
When Obligations are Made: 34 C.F.R. Section 76.707
Non-Federal Share (Match) and Carryover Requirements: see current GAN in G5; see also 2 C.F.R. Section 200.306
Note: non-Federal share must be obligated during the year of appropriation and liquidated either in the year of appropriation or in the subsequent carryover year including the liquidation period following the period of performance end date.
Maintenance of Effort (MOE): Applicable to the VR program, MOE requires States to maintain a level of non-Federal share it provided in the previous FFY, that is at least equal to the total non-Federal share provided by the State two years prior.
Reallotment: Each formula grant recipient is required to submit a Grant Reallotment Form (RSA-692) to RSA during July of the FFY of appropriation to determine whether the grantee is relinquishing grant funds, requesting additional grant funds, or seeking no change in the current award amount.
Prior Approval: See 2 C.F.R. Section 200.407 for an index of cost categories requiring prior approval. See FAQs about Prior Approval for a description of specific flexibilities for RSA formula awards.
Cost Allocation: Items of costs that benefit multiple cost objectives must be allocated based on relative benefit and proportionate use. See pages 10-14 of RSA-TAC-17-03 for an overview of cost allocation methodology.
State-Administered Programs (EDGAR): 34 C.F.R. Part 76
Subgranting: The IL-OIB authorizing statute is the only authorizing stature of any RSA formula grant program to permit subgranting.
WIOA One-Stop Service Delivery System: Infrastructure Funding of the One-Stop Delivery System (RSA-TAC-17-03) and One-Stop Operations Guidance (RSA-TAC-17-02)
Federal Financial Report submission instructions are below.
Vocational Rehabilitation (FFY 2021 and later awards): Instructions for Vocational Rehabilitation Financial Report (RSA-17)
Vocational Rehabilitation (FFY 2020 and earlier awards): PD-15-05
Note: Lines 10i and 10k do not always display the actual amount of recipient share required and to be provided. Data on these lines are based on total cash receipts (Line 10a), however the required Federal share, per statute, is based on total Federal share (Line 10g), the calculation of which is not identified on the SF-425.
Supported Employment – A: PD-18-01
Supported Employment – B: PD-18-02
CAP, PAIR, and IL-OIB: Revised Instructions for Completing SF-425 for CAP, OIB, and PAIR
WIOA Performance Accountability
Section 116 of WIOA establishes performance accountability indicators that apply across the core programs to assess the effectiveness of States and local areas in achieving positive outcomes for individuals served by these programs. Under section 116(b)(2)(A) of WIOA, there are six primary indicators of performance. More information on the common performance indicators can be found in RSA-TAC-17-01. Please visit the below pages for more information related to:
RSA Technical Assistance Centers
Aligning with RSA’s mission to provide leadership and resources to grantees and stakeholders, RSA funds training and technical assistance centers and demonstration projects to assist State VR agencies and their partners in providing VR and other services to individuals with disabilities. Each technical assistance center focuses its efforts on a specific set of topics or areas designed to provide universal, targeted, and intensive training and technical assistance for the purpose of improving services to individuals with disabilities to maximize their employment, independence and integration into the community and the competitive labor market. State VR agencies are encouraged to reach out to technical assistance centers to assist them in the management and operation of their programs.
Vocational Rehabilitation Technical Assistance Center for Quality Management (VRTAC-QM)
The VRTAC-QM provides intensive training and technical assistance, targeted training and technical assistance, and universal training and technical assistance to State VR agencies on quality management strategies that will enable VR agencies to improve service delivery to, and employment outcomes achieved by, individuals with disabilities. The training and technical assistance will upgrade and increase the competencies, skills, and knowledge of VR personnel, enabling them to assess current VR program performance and to identify the strengths, weaknesses, opportunities for improvement, and threats (SWOT) that impact the effectiveness of VR agency service delivery and the quality of employment outcomes. The VRTAC-QM coordinates the provision of training and technical assistance with the Vocational Rehabilitation Technical Assistance Center for Quality Employment and other RSA-funded technical assistance and training centers. The VRTAC-QM is housed at San Diego State University Research Foundation.
VRTAC-QM Website: https://www.vrtac-qm.org/
Project Director: Chaz Compton
RSA Project Officer: Karin Grandon
Vocational Rehabilitation Technical Assistance Center for Quality Employment (VRTAC-QE)
The VRTAC-QE provides 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. The training and technical assistance will 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 VRTAC-QE includes 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 center is housed within the Board of Regents University of Wisconsin System.
VRTAC-QE Website: https://tacqe.com/
Project Director: Timothy Tansey
RSA Project Officer: Karin Grandon
National Technical Assistance Center on Transition: The Collaborative (NTACT: C)
The NTACT: C assists State and local education agencies, state VR agencies and VR service providers in implementing evidence-based and promising practices to help ensure students with disabilities, including those with significant disabilities, graduate prepared for success in postsecondary education and employment. The NTACT-C engages in partnerships with parents, families, and diverse stakeholders and empowers States to pursue innovation. Further, the Center customizes its intensive, targeted and universal technical assistance to meet each State's specific, identified needs. The NTACT-C is housed at the University of North Carolina at Charlotte.
NTACT:C Website: https://transitionta.org/
Project Director: Catherine Fowler
OSEP Project Officer: Selete Avoke
American Indian Vocational Rehabilitation Training and Technical Assistance Center (AIVRTTAC)
The AIVRTTAC provides intensive, targeted, and universal training and technical assistance to governing bodies of Indian Tribes, or consortia of those governing bodies that have received an American Indian Vocational Rehabilitation Services (AIVRS) grant. The AIVRTTAC also prepares AIVRS project personnel in VR, specifically the development of a structured program of training for AIVRS personnel with limited knowledge or experience in the VR field to improve the delivery of VR services to American Indians with disabilities. The AIVRTTAC is housed at the Northern Arizona University, Institute for Human Development.
AIVRTTAC Website: http://aivrttac.org/
RSA Project Officer: August Martin
Independent Living Services for Older Individuals Who Are Blind Training and Technical Assistance Center (OIB-TAC)
The OIB-TAC provides training and technical assistance to designated State agencies (DSAs) that receive grant funding under the OIB program and to other service providers that receive OIB program funding from DSAs to provide services to consumers. The training and technical assistance will improve the operation and performance of programs and services for older individuals who are blind resulting in their enhanced independence and self-sufficiency. The OIB-TAC is housed at the Mississippi State University.
OIB-TAC Website: http://www.oib-tac.org/
Project Director: Kendra Farrow
RSA Project Officer: Mary Williams
RSA Demonstration Projects
To learn more about Demonstration Projects, please visit RSA Programs.
ED and OSERS Social Media
ED Twitter: https://twitter.com/usedgov
ED Facebook: https://www.facebook.com/ED.gov/
ED YouTube: https://www.youtube.com/user/usedgov
OSERS Twitter: https://twitter.com/ED_Sped_Rehab
OSERS Blog: https://sites.ed.gov/osers/