RSA-227 - Annual Client Assistance Program (CAP) Report

Idaho (DisAbility Rights Idaho, Inc.) - H161A160059 - FY2016

General Information

Designated Agency Identification

NameDisability Rights Idaho, Inc.
Address4477 Emerald Street
Address Line 2Suite B-100
Zip Code83706
Website Address
Toll-free Phone866-262-3462
Toll-free TTY

Operating Agency (if different from Designated Agency)

NameDisability Rights Idaho, Inc.
Address4477 Emerald Street
Address Line 2Suite B-100
Zip Code83706
Website Address
Toll-free Phone866-262-3462
Toll-free TTY

Additional Information

Name of CAP Director/CoordinatorDina Flores-Brewer
Person to contact regarding reportDina Flores-Brewer
Contact Person Phone208-336-5353

Part I. Non-case Services

A. Information and Referral Services (I&R)

Multiple responses are not permitted.

1. Information regarding the vocational rehabilitation (VR) program6
2. Information regarding independent living programs0
3. Information regarding American Indian VR Service projects0
4. Information regarding Title I of the ADA0
5. Other information provided0
6. Information regarding CAP1
7. Total I&R services provided (Lines A1 through A6)7

B. Training Activities

Training Activities: 1. Northern Rockies AER Annual Conference - Transition Workshop, October 16, 2015. CAP Director provided training for approximately 35 parents, teachers, and individuals who are blind at the Regional Northern Rockies AER Annual Conference (Association for Education and Rehabilitation of Blind and Visually Impaired Individuals). “Transition: It’s a Team Sport”, a 2-hour workshop, focused on steps for transition planning, including student input; former Community Work Incentives Coordinator also provided information on basic work incentives and benefits planning resources. Attendees were from Idaho, Wyoming, Colorado, & Utah. 2. Partners in Policy Making — Transition Planning Workshop, November 13, 2015. CAP Director provided a 60-minute overview training of transition planning to approximately 15 members of the Partners in Policymaking group, sponsored by the Idaho Council on Developmental Disabilities. The Partners group consists of parents of children with developmental disabilities, and 4-5 young adults with developmental disabilities learning about the different services and agencies that serve people with developmental disabilities, with the goal of being trained to provide input and guidance to public policymakers. Workshop provided information on transition services, different service providers, and services available by the Client Assistance Program. Translation in Spanish was provided to non-English speakers. 3. East Junior High School — Presentation on services available from DisAbility Rights Idaho, January 12, 2016. Senior advocate gave a one-hour presentation to approximately 26 students, parents, and educators on DRI services available to transition age youth, including through the PABSS program and the CAP, as part of the high school’s disability awareness week. Additional information was provided on employment services and benefits, including work incentives and accommodations. 4. CAP Presentation to LINC Staff, January 14, 2016. CAP Director provided a 60-minute presentation to approximately 15 independent living center staff from Boise, Caldwell and Twin Falls (via teleconference) on the Client Assistance Program, what we do, service limitations, regulations, and what we look for, as well as what types of remedies we seek. Additional information was provided on what changes were coming through WIOA, and how the general P&A system worked. LINC staff then provided a 60-minute overview of the independent living center, its program and client services. 5. Transition Fair Rocky Mountain High School in Meridian, Idaho, February 18, 2016. Senior Advocate gave a 30-minute brief overview/presentation to approximately 16 students, parents and educators as part of a day-long seminar on preparing for transition from high school. Information on the assistance available from the P&A, CAP and PABSS programs was also provided. 6. Tools for Life Annual Transition Conference, March 2, 2016. P&A/CAP staff conducted 4 presentations at the Tools for Life Transition conference held each year throughout Idaho. Approximately 240 transition age students, parents, service providers, and educators. The different presentations were “Transition Planning: It’s a Team Sport!” about the IDEA requirements of transition planning; “Self-Advocacy” which provided tools and strategies for effective self-advocacy by transition age youth; “Go Vote”, presentation about the registration requirements and voting rights of students who are turning 18, or who have turned 18; and, “Alternatives to Guardianship,” a presentation about the alternatives to full guardianship, including limited guardianships, powers of attorney, and the Supported Decision Making model. 7. Autism Society — Employment Services Presentation, March 14, 2016. Senior Advocate gave a two-hour presentation on the employment services available from the P&A, including the CAP and PABSS programs, as well as an overview of employment rights and work incentives to approximately 16 individuals on the autism spectrum and their parents at an evening meeting for the Boise Autism Society at St. Luke’s Hospital in Meridian. Written information was also presented in Spanish to one parent of a child with autism. 8. Goodwill Working Solutions — Employment Services presentation, March 18, 2016. Senior Advocate gave a 45-minute presentation to approximately 15 service providers, on the employment services available to people with developmental disabilities through the P&A, including through the CAP and PABSS programs. 9. Idaho Department of Labor Career Exploration Fair, April 21, 2016. Senior Advocate gave a one-hour overview of P&A, CAP, PABSS and voting information to approximately 16 transition age youth at the IDOL office in Twin Falls as part of their career exploration program for disadvantaged youth.

1. Number of training sessions presented to community groups and public agencies.12
2. Number of individuals who attended these training sessions.394
3. Describe training presented by the staff. Include the following information:
  1. topics covered
  2. purpose of the training
  3. description of the attendees

C. Agency Outreach

Describe the agency's outreach efforts to previously un-served or underserved individuals including minority communities.

1. Outreach to people with DD in general and people with DD receiving services in sheltered workshops: Outreach to individuals with developmental disabilities in 4 sheltered workshops. Included tours of the facilities, work areas, break areas, and general grounds. Advocates were able to speak with employees about P&A and CAP services. Additionally, voter training was provided to the participants. Outreach to 88 individuals in four different facilities. a. TESH, Inc., August 17, 2016 b. 7 Oaks Community Homes, August 18, 2016 c. Opportunities Unlimited, Inc., August 18, 2016 d. Tri-Co., August 19, 2016

Additional outreach was conducted at Disability Action Day at the Capitol, in Boise on February 23, 2016. Approximately 150 people with disabilities (mostly with developmental disabilities), families, and service providers were in attendance. CAP staff talked to approximately 75 people including PWDs, providers, agency personnel, and legislators. Disseminated blog on DRI position on the Optum Idaho/Medicaid evaluation from the Office of Performance Evaluations, as well as the Executive Director’s testimony regarding Idaho Health Plans HB1204 & HB1205. Also provided training on BMD-Automark. Local media (KTVB-Channel 7) filmed a blind individual practicing his vote, and interviewed the Executive Director. Outreach to approximately 150 children with developmental disabilities and their families was provided at the Annual Run for Autism in Veteran’s Memorial Park in Boise on May 23, 2016. Information regarding the P&A, CAP and other programs were provided, including information about transition services and the new focus at Idaho Division of Vocational Rehabilitation on providing transition services to youth.

2. Outreach to Hispanic/Latino Community: CAP Director met with about 12 people at the Amigas! Canyon County monthly meeting. It is a group of individuals who share information and resources to help Spanish speaking families in the Treasure Valley. The topic in September was disability services. Invited speakers were from Idaho Department of Health and Welfare; former P&A Board Member and consultant with the Idaho Council on Developmental Disabilities, Griselda Comacho; DD Council staff Toni Brineger; DisAbility Rights Idaho; and Manuel Guerra, Vocational Rehabilitation Counselor from Idaho Division of Vocational Rehabilitation. Information on CAP and P&A services, information on voting rights and the voter’s hotline were provided, along with about 30 registration forms.

3. Outreach to Transition Age Youth: CAP provided outreach at the annual Tools for Life Transition Conference on March 2, 2016 in Boise to approximately 350 transition age youth, parents, care providers and school staff. Information on CAP and P&A services was provided in conjunction with a “scavenger hunt” where attendees had to visit each booth to earn a prize. Advocates also conducted trainings.

4. Outreach to Native American/Shoshone-Bannock Tribe members:

a. CAP provided outreach to the Fort Hall Indian Reservation on April 29, 2016. Advocate met with the Tribal Adult Protection Services Advocate. Advocate provided P&A and CAP brochures and explained what the P&A/CAP was, and what services we could provide for tribal members who are utilizing the services for people with disabilities both in and outside of the reservations. Advocate explained how P&A can help if IEP issues arise with people whose family goes to school in the school districts outside of the Tribal School System, and how CAP can assist members of the tribe access tribal and/or state vocational rehabilitation services. b. CAP was also invited to have an outreach booth at Shoshone Bannock Elderly Abuse Conference at Fort Hall on May 20, 2016. Approximately 100-150 people attended the conference. Advocate answered questions from people stopping by the booth regarding CAP and the P&A.

5. Outreach to Independent Living Centers in rural Idaho: CAP provided outreach to the independent living center in north Idaho, Disability Action Center-Northwest, at the main office in Moscow, and two satellite offices in Lewiston and Post Falls on August 15-18, 2016. Information about CAP was provided to 6 staff members, as well as information regarding sheltered workshops, and the Idaho Division of Vocational Rehabilitation. CAP staff provided 25-50 copies of the new ILC CAP brochures to each office for consumers.

D. Information Disseminated To The Public By Your Agency

For each method of dissemination, enter the total number of each method used by your agency during the reporting period to distribute information to the public. For publications/booklets/brochures (item 4), enter the total number of documents produced. Agencies should not include website hits. See instructions for details.

Workgroup/Task Forces 1. CAP Director is a member of the Idaho State Rehabilitation Council. The SRC meets quarterly to provide input on the Idaho Division of Vocational Rehabilitation’s state plan, and services. The focus this year was providing input to ensure the agency’s compliance with the new WIOA (Workforce Innovation and Opportunity Act) regulations, especially with regard to transition programs, summer work experiences, and proposed rule changes regarding financial participation and order of selection. 2. CAP is a member of the Idaho Employment First Consortium, sponsored by the Idaho Council on Developmental Disabilities, which meet monthly to collaborate with staff from the Division of Vocational Rehabilitation, the Idaho Department of Labor, DD Council, State Independent Living Council, DisAbility Rights Idaho, and the Idaho Department of Health and Welfare to develop a strategic plan to make the recommendation that funds be allotted in the annual budget for development of an employment plan for individuals with disabilities who access state Medicaid funds for other services. Plan was developed and presented to IDHW in 2016 and then will be introduced as potential legislation for changes to the Idaho Medicaid rules to support funding employment education and access in FY2017. 3. CAP Director participated on the Idaho Interagency Council on Secondary Transition. The IICST meets quarterly in Boise. The Council is made up of agencies with an interest in transition age students-the Department of Education, Idaho Assistive Technology Project, Idaho Division of Vocational Rehabilitation, Idaho Commission for the Blind and Visually Impaired, Department of Labor, Juvenile Corrections, Idaho Council on Developmental Disabilities, schools/districts, Idaho Parents Unlimited, DisAbility Rights Idaho, and others. Discussions involved pre-employment transition services for transition age youth, changes required by the Workforce Innovation and Opportunity Act (WIOA), transition technical assistance reports, legislative updates, and planning for the Tools for Life transition conference sponsored by the Idaho AT Project. Additional topics during the year included providing input for the IDOL’s Disability Employment Initiative grant/application, improving transition outcomes for youth, and different programs offered by Idaho colleges and universities to prepare students with disabilities for life after high school. 4. Medicaid for Workers with Disabilities. CAP Director participated on an informal workgroup started by Boise Representatives Melissa Wintrow and Matt Erpelding, to address systemic problems with the Idaho Medicaid for Workers with Disabilities Program, Idaho’s Medicaid Buy-In program, and a source for comparable benefits for IDVR clients. The workgroup met with Medicaid staff to identify and address participant barriers to MWD. Issues identified include difficulty navigating the website, the application, self-reliance workers’ unfamiliarity with the program, denial of an appeals process, improper notices (contain generic reasons for denials and do not cite to rules), and ensuring people who approach the program through the Developmental Disabilities Services unit are redirected back to H&W. The workgroup met 3 times this past year, and Medicaid staff addressed the website and application issues, are working with the IDOL to address the links between the two websites, have acknowledged the required appeals process, and are working on how to ensure proper notice is given. The workgroup was provided with detailed information on how MWD applications are processed, and anecdotal information seems to indicate that problems with the program are now individual in nature, not system wide. H&W now has a new dedicated website to facilitate access.

1. Agency Staff Interviewed or Featured on Radio and TV1
2. Articles about CAP Featured in Newspaper/Magazine/Journals0
3. PSAs/Videos Aired about the CAP Agency0
4. Publications/Booklets/Brochures Disseminated by the Agency7200
5. Number of Times CAP Exhibited at Conferences, Community Fairs, etc.9
6. Other (specify below)

E. Information Disseminated About Your Agency By External Media Coverage

Describe the various sources and information disseminated about your agency by an external source.

Information about the CAP program has been disseminated by the Idaho Division of Vocational Rehabilitation, the Tribal Vocational Rehabilitation Programs and Independent Living Centers. Additionally, a webpage about the CAP program is in development for inclusion on the website for the Idaho State Independent Living Council.

Part II. Individual Case Services

A. Individuals served

An individual is counted only once during a fiscal year. Multiple counts are not permitted for Lines A1-A3.

1. Individuals who are still being served as of October 1 (carryover from prior year)4
2. Additional individuals who were served during the year29
3. Total individuals served (Lines A1+A2)33
4. Individuals (from Line A3) who had multiple case files opened/closed this year (In unusual situations, an individual may have more than one case file opened/closed during a fiscal year. This number is not added to the total in Line A3 above.)4
5. Individual still being served as of September 30 (Carryover to next year. This total may not exceed Line A3.)4

B. Problem areas

Multiple responses permitted.

1. Individual requests information2
2. Communication problems between individual and VR counselor9
3. Conflict about VR services to be provided13
4. Related to VR application/eligibility process5
5. Related to assignment to order of selection priority category0
6. Related to IPE development/implementation
  1. Selection of vendors for provision of VR services
  2. Selection of training, post-secondary education
  3. Selection of employment outcome
  4. Transition services
7. Related to independent living services0
8. Other Rehabilitation Act-related problems1
9. Non-Rehabilitation Act related
  1. TANF
  3. Housing
  4. Other:
10. Related to Title I of the ADA1

C. Intervention Strategies for closed cases

(Choose one primary service the CAP provided for each closed case file. There may be more case files than actual individuals served.)

1. Short Term Technical Assistance26
2. Investigation/Monitoring0
3. Negotiation1
4. Mediation and other methods of Alternative Dispute Resolution4
5. Administrative / Informal Review1
6. Formal appeal / Fair Hearing0
7. Legal remedy / Litigation0
8. Total32

D. Reasons for closing individuals' case files

(Choose one primary reason for closing each case file. There may be more case files than the total number of individuals served.)

1. All issues resolved in individual's favor23
2. Some issues resolved in individual's favor (when there are multiple issues)3
3. CAP determines VR agency position/decision was appropriate for the individual1
4. Individual's case lacks legal merit; (inappropriate for CAP intervention)1
5. Individual chose alternative representation0
6. Individual withdrew complaint2
7. Issue not resolved in clients favor2
8. CAP services not needed due to individual's death, relocation, etc.0
9. Individual not responsive/cooperative with CAP0
10. CAP unable to take case due to lack of resources0
11. Conflict of interest0
12. Other (Please explain below)

E. Results achieved for individuals

(Choose one primary outcome for each closed case file. There may be more case files than the total number of individuals served.)

3 - individuals withdrew complaint.

1. Controlling law/policy explained to individual5
2. Application for services completed0
3. Eligibility determination expedited2
4. Individual participated in evaluation0
5. IPE developed/implemented/Services Provided0
6. Communication re-established between individual and other party6
7. Individual assigned to new counselor/office5
8. Alternative resources identified for individual7
9. ADA/504/EEO/OCR complaint made4
10. Other (Please explain below)

Part III. Program Data

A. Age

Multiple responses not permitted.

1. Up to 181
2. 19 - 242
3. 25 - 403
4. 41 - 6426
5. 65 and over1
6. Total (Sum of Lines A1 through A5. Total must equal Part II, Line A3.)33

B. Gender

Multiple responses not permitted.

1. Females12
2. Males21
3. Total (Lines B1+B2. Total must equal Part II, Line A3.)33

C. Race/ethnicity of Individuals Served

1. Hispanic/Latino of any race (for individuals who are non-Hispanic/Latino only)3
2. American Indian or Alaskan Native2
3. Asian0
4. Black or African American3
5. Native Hawaiian or Other Pacific Islander0
6. White23
7. Two or more races2
8. Race/ethnicity unknown0

D. Primary disabling condition of individuals served

Multiple responses not permitted.

1. Acquired Brain Injury2
4. Amputations or Absence of Extremities0
5. Arthritis or Rheumatism0
6. Anxiety Disorder0
7. Autism Spectrum Disorder0
8. Autoimmune or Immune Deficiencies (excluding AIDS/HIV)0
9. Blindness (Both Eyes)2
10. Other Visual Impairments (Not Blind)2
11. Cancer0
12. Cerebral Palsy0
13. Deafness0
14. Hard of Hearing/Hearing Impaired (Not Deaf)2
15. Deaf-Blind0
16. Diabetes0
17. Digestive Disorders0
18. Epilepsy0
19. Heart & Other Circulatory Conditions0
20. Intellectual Disability2
21. Mental Illness9
22. Multiple Sclerosis0
23. Muscular Dystrophy0
24. Muscular/Skeletal Impairment0
25. Neurological Disorders/Impairment3
26. Orthopedic Impairments7
27. Personality Disorders0
28. Respiratory Disorders/Impairment0
29. Skin Conditions0
30. Specific Learning Disabilities (SLD)1
31. Speech Impairments0
32. Spina Bifida0
33. Substance Abuse (Alcohol or Drugs)0
34. Other Disability3
35. Total (Sum of Lines D1through D34. Total must equal Part II, Line A3.)33

E. Types of Individual Served

Multiple responses permitted.

1. Applicant of VR18
2. Individual eligible for VR services currently on a wait list0
3. Individual eligible for VR services not currently on a wait list5
4. Applicant or individual eligible for Independent Living9
5. Transition student/High school student1
6. All other applicants or individuals eligible for other programs or projects funded unther Rehabilitation Act2

Part IV. Systemic Activities and Litigation

A. Non-Litigation Systemic Activities

1. CAP Director became aware of a systemic issue following an individual case regarding the new summer work experience program offered by Idaho Division of Vocational Rehabilitation as part of its WIOA required focus on providing services to transition age youth. After the individual case was resolved (see case summary for more detail), the CAP Director met with VR administration to discuss the issue that students with severe disabilities were being excluded from participating in the summer work program. Included in the eligibility criteria for the program, as stated in its brochure, was that eligible students had to meet behavioral criteria, and had to independently take care of their own hygiene needs, i.e. independently go to the bathroom. This categorically excluded students with severe cognitive and/or severe physical disabilities from participating in the program on the basis of their disability. Following the meeting, IDVR agreed to immediately withdraw the brochure statewide, eliminate the exclusionary criteria in all regions, and provide individual summer work experiences for any youth who wanted to participate in the program, but were excluded by the previous criteria. Furthermore, IDVR agreed to make available future brochures on the program to CAP for review prior to dissemination, and made assurances that students with significant disabilities would not be excluded from any current/future transition programs based on impermissible criteria. CAP and IDVR will meet on a quarterly basis to discuss systemic issues, and keep communication open.

2. CAP Senior Advocate is a member of the Brain Injury Alliance of Idaho Board of Directors. The Board meets quarterly to address issues regarding people with traumatic brain injuries. One of the issues addressed this year was the difficulty people with TBI have accessing post-secondary education and training with regard to accommodations and accessibility, creating a barrier to employment. CAP took on the task of developing a brochure providing information on how to request information and accommodations, and other rights information for people with TBI, for review and adoption by the Board. Following negotiations and conversations between CAP and Vocational Rehabilitation, a final draft was presented and adopted by the BIA-ID, to be provided to students with disabilities at Idaho colleges and universities.

3. CAP met with IDVR and other stakeholders in June to discuss IDVR’s obligations under Section 511 (regarding outreach to sheltered workshops) in the newly reauthorized Workforce Innovation and Opportunity Act (WIOA). In attendance was a representative from the former TACE to provide technical assistance on IDVR’s obligations. The group began drafting a plan on how to address all of the new requirements, including how to ensure outreach is done, who employment networks should contact to ensure appropriate training is provided, etc. Work will continue as more clarification is received from RSA regarding implementation of Section 511.

1. Number of non-litigation systemic activities not involving individual representation that resulted in the change of one or more policy or practice of an agency.3
2. Describe the systemic activities conducted by CAP during the fiscal year and its impact on other agency's policies or practices.

B. Litigation

Cases were resolved without litigation.

1. Total number of CAP cases requiring litigation involving individual representation resulting in, or with the potential for, systemic change.
a. Number of cases requiring litigation involving individual representation filed during fiscal year.0
b. Number of on-going cases pending at start of fiscal year (carryover from prior fiscal year).0
c. Number of cases resolved through litigation during fiscal year.0
2. Describe the agency's on-going and completed systemic litigation activities involving individual representation.

Part V. Agency Information

A. Designated Agency

1. Agency Type (select only one option) External-Protection and Advocacy agency
2. Name of designate agencyDisability Rights Idaho, Inc.
3. Is the designated agency contracting CAP services?No
4. If yes, name of contracting agency:N/A

B. Staff Employed

Provide a description of all CAP positions (see instructions)

CAP Director/Attorney, Legal Director, Advocacy Supervisor, Senior Advocates (2), Staff Attorney (2) Advocate (3)

Type of Position FTE % Year Filled Person Years Professional 1.20 79.49% 1.17 Full-Time NA NA NA Part-Time 1.20 79.49% 1.17 Vacant 1.25 10.42% 0.13

Clerical 0.46 80.00% 1.86 Full-Time NA NA NA Part-Time 0.46 80.00% 1.86 Vacant 1.00 8.33% 0.08

Part VI. Case Examples

Provide some examples of some interesting cases during the past fiscal year.

1. CAP was contacted by the mother of a 16-year-old African-American male diagnosed with cerebral palsy, neurological disorders, pervasive developmental disorder, physical impairments, speech impairments and TBI. She was appealing Idaho Division of Vocational Rehabilitation’s denial of eligibility for the summer work experience program. The client was denied eligibility because he was unable to independently take care of his own hygiene, a requirement for the summer work program. Parent had spoken with VR counselor, who told her they (VR) did not want to overwhelm employers with extra staff to take care of participants’ toileting needs, even though mother informed VR that participant’s personal care staff would be on call to provide personal care, so job coach would not be required to do so. CAP requested informal review with Regional Manager and mother. Following discussion about how this exclusion based on disability violated participant’s rights, and violated Title II of the ADA as well as Section 504 of the Rehabilitation Act, RM agreed to develop summer work experience for participant. Systemic issue of categorical denial of eligibility for this and other programs was addressed by the CAP Director with IDVR administration (more in systemic section off this report). The participant was able to work during the summer, and the impermissible eligibility criteria was rescinded for all current and future transition programs.

2. CAP was contacted by a 60-year-old Caucasian male diagnosed with diabetes and mental illness requesting assistance with appeal a Notice of Denial of Services and Case Closure by IDVR. Services denied included eyeglass, bus passes, and reimbursement for work related items purchased by the client. Basis for denial was that the client was not seeking full time work, but rather was employed as a part time bell ringer for the Salvation Army, and seasonally worked during the spring and summer for a lawn maintenance company. CAP appealed the denial and represented the client in a meeting, informing the Regional Manager that the client was working, and would be returning to his lawn care job in the spring. The VR case was reopened, however, the client did not have completed plan with IDVR yet, so CAP assisted with plan development, with the goal of increasing hours of employment and receiving new glasses and a bus pass. CAP was unable to secure reimbursement from IDVR for the items purchased by the client, as they were not part of an individual plan for employment; however, the client was able to get reimbursement from his employer with CAP’s assistance. Client was able to get the necessary services from IDVR to work more hours.

3. CAP was contacted by a 42-year-old white male with physical and orthopedic limitations to appeal IDVR’s denial of an electric wheelchair so he could complete his program at a local university, and go to work. IDVR was requiring client to exhaust his comparable benefits, however, he had already received a denial from Medicare because the electric chair was not necessary in the home, and Medicare does not consider community access medically necessary. Medicare will pay for power wheelchairs only if needed in the home — the client had a manual chair sufficient for mobility in his small home; however, the manual wheelchair was not sufficient/safe to get across campus, or to travel to/from the bus stop. IDVR was insisting the client appeal the Medicare denial before they would consider providing funding. CAP appealed to the Regional Manager, providing documentation of the Medicare rule, and explaining the futility of appealing the Medicare denial. In addition, CAP pointed out that IDVR policy did not require a participant to appeal another agency’s service denial prior to IDVR payment for that service, as appeals are voluntary. The Regional Manager reversed the denial, and the client was able to purchase an electric wheelchair for use at school and work.


Reports are to be submitted to RSA within 90 days after the end of the fiscal year covered by this report. Please be reminded that you can enter data directly into RSA's website via the internet. Information on transmittal of the form is found on pages 19 and 20 of the reporting instructions.

Name of Designated Agency OfficialJames R. Baugh
Title of Designated Agency OfficialExecutive Director
Date Signed12/20/2016