Meeting of the Board of Regents | May 2008
TO: VESID Committee
FROM: Rebecca H. Cort
SUBJECT: The Vocational Rehabilitation Program’s Quality Assurance and Monitoring Unit
DATE: April 30, 2008
STRATEGIC GOAL: Goal 1
Issue for Discussion
The implementation and current status of VESID’s Vocational Rehabilitation program’s Quality Assurance and Monitoring Unit.
Reason for Consideration
To inform the Regents and obtain their support for the actions being taken by the new Quality Assurance and Monitoring Unit that will significantly improve the delivery of vocational rehabilitation services and improve the Vocational Rehabilitation program’s internal controls.
The attached report will update the Regents on the numerous accomplishments made by the Quality Assurance and Monitoring Unit over the past year and seek support from the Regents on the Quality Assurance and Monitoring Unit’s proposed future endeavors. This item was scheduled for discussion in March but due to time constraints it was deferred to the May meeting.
The Vocational Rehabilitation program’s Quality Assurance and Monitoring Unit was established as a result of the 2004 Office of Audit Services’ Internal Audit Report. Since the report was issued, a March 2005 Vocational Rehabilitation Cabinet Monitoring Subgroup report was issued outlining objectives envisioned for the Unit. The vision of the Quality Assurance and Monitoring Unit began to be realized through its first staffing assignments which were made in January 2006 and the hiring of a manager, effective May 2007. The Unit’s goals are to ensure efficient Vocational Rehabilitation program operations and delivery of quality services; ensure that assets are protected and public funds are expended appropriately; and ensure that applicable Federal and State laws, as well as agency regulations, policies, procedures and guidelines are met.
The Board of Regents will continue to support VESID’s Quality Assurance and Monitoring Unit and its initiatives.
Timetable for Implementation
With Regents support, the described activities will continue to move forward.
VESID’S QUALITY ASSURANCE AND MONITORING UNIT
I. Introduction and History
On September 3, 2004 the Internal Audit Report titled, VESID - Internal Controls over the Procurement and Payment of Goods and Services for the period January 1, 2000 through June 30, 2004 prepared by the Education Department’s Office of Audit Services found that VESID had not established and maintained an effective internal control system. The report made 30 recommendations that VESID accepted and immediately began to implement.
As a result of the audit report the Vocational Rehabilitation Cabinet was established. Additionally, a subgroup of the Cabinet was formed to propose a conceptual design for a comprehensive monitoring system for the Vocational Rehabilitation program. The Monitoring Subgroup Report was issued in March 2005. According to the Monitoring Subgroup, "the monitoring system for VESID-Vocational Rehabilitation should be designed to accomplish the following objectives:
- Protect the assets under its control;
- Promote quality assurance by ensuring that eligible consumers get the services they require to reach an appropriate employment outcome and by managing consumer progress through the system;
- Identify areas of risk and detect incidents of noncompliance; and
- Ensure compliance with State and Federal Laws and regulations.”
In response, a new unit was created integrating the Quality Assurance Unit with Program Monitoring. The Quality Assurance and Monitoring Unit (the Unit) began to be staffed as of January 2006 and a manager was hired effective May 10, 2007.
This report describes the actions and key initiatives that the Unit has undertaken over the past 26 months to affect its goals.
II. Key Initiatives
A. Supported Employment Review Protocols
Supported Employment is paid competitive work that offers ongoing support services in integrated settings for individuals with the most significant disabilities. The Unit undertakes regular provider reviews of approximately two hundred Supported Employment programs. To do this, six monitors are assigned primary responsibility for thirty to thirty five Supported Employment provider agencies. As the Unit was first being formed it became apparent that there was a lack of structure regarding Supported Employment reviews. This has been addressed by putting a Supported Employment workgroup together comprised of monitoring staff, district office staff and provider agencies. A draft comprehensive protocol package that includes formatted letters, review forms, review summary charts and finding reports has been developed. Also, the Unit will commence a major change in its previous review process by adding a review of the corresponding district office file for files reviewed at the provider agency. The new comprehensive protocol and the addition of reviewing district office files will ensure that all monitors are conducting their reviews in a uniform manner throughout the state.
Additionally, a schedule has been put in place to standardize visits by the monitors, monitor how often a facility is being visited and that a timely review report is being submitted by the monitor. All pertinent information will be placed into a computer program and information regarding the monitoring of a particular Supported Employment provider will be readily available.
B. Case Review Protocols
In order to ensure that the Vocational Rehabilitation (VR) program is compliant with State and Federal laws and regulations, as well as its own policies and procedures, individual consumer case reviews need to be undertaken regularly. The results of a well conducted case review can give VESID critical insight into what legal, regulatory or policy issues the field offices are encountering and if the program is effective for VESID consumers.
Because a 2006 case review documented a failure to reach the Rehabilitation Service Administration’s (RSA) 90% compliance level on certain topics, the Unit and VESID’s Management agreed that a top priority was to review and revise the case review protocols. This was accomplished by putting a workgroup together of several Unit staff as well as field counselors. A draft protocol, field guide and formatted finding report has been developed.
The protocols seek information on numerous topics that have been addressed in recent monitoring and audit reports so that VESID can obtain more detailed information as to whether problems exist and then prepare corrective action, if needed. For example, single audit reports for the last two years have found that consumers are not always being made eligible for services in a timely manner. The protocols have refined the questions regarding the time frame of consumer application to consumer eligibility so that findings can be compared to those of the auditors and the need for further action, such as training, can be determined.
The first case review with the revised protocols is scheduled for July 2008. This case review will be on the same topic as was conducted in the 2006 case review “Eligibility and Significance of Disability.” The Unit is working diligently to ensure that the RSA 90% compliance level on the topic of Eligibility and Significance of Disability is met in this next case review. This will allow VESID to meet the compliance criteria that RSA established as part of our Corrective Action Plan.
C. On-Line Assessment for Counselors
To help meet the RSA imposed 90% compliance level, the Unit has developed an on-line assessment tool for all counseling staff on the topic of Eligibility and Significance of Disability. This unique tool helps VESID assess staff knowledge and understanding of the Eligibility and Significance of Disability policies, determine the need for training, if any, and prepare for VESID’s July 2008 case review on the topic. Essentially counselors have been asked, via e-mail, to answer a set of 30 questions on the topic of Eligibility and Significance of Disability. If questions are answered incorrectly a counselor is referred back to the policy and procedure. The test is not considered completed by the counselor until he or she earns a score of at least 80%.
Although VESID’s Central Office will not receive the results of any individual counselor, results will be tabulated by District Office so that further outreach and training can be done if necessary.
D. Unified Contract Services
The VR program is in the process of redesigning its Unified Contract System (UCS). The new system will clearly define services for VR consumers; provide methods for evaluating the services; allow for continuous recruitment of new providers through a provider performance assessment and establish equitable rates for services provided. The Unit has been continuously involved in the UCS redesign process.
The Unit’s first assignment was to review records at provider agencies and district offices to ascertain issues with the current unified contract service system. Twenty four agencies, providing four types of services, were reviewed, as well as their corresponding district office records. A report was issued in November 2007 documenting the general findings of the reviews and proposing recommendations for the UCS Workgroup. These recommendations included the need for clear service definitions, and the establishment of performance measures and monitoring processes.
The Unit’s next assignment was to assist with the UCS subgroup charged with developing the definitions of the services to be covered in the new UCS contract. A draft definitions report was issued by this subgroup on January 16, 2008. The UCS services of Entry Services, Assessment Services, Work Readiness Services, Job Placement and Adjunct Services were categorized and defined by this subgroup.
The Unit’s current UCS assignment involves its participation in the contract performance and assessment subgroup. This subgroup has been charged with the task of providing performance indicators for the definitions discussed above.
The Unit’s work in performance and assessment will continue even after performance indicators are established for the UCS definitions. In September 2007 the Unit applied for, and was awarded, a quality assurance technical assistance grant from RSA. Under this grant, the VR program, with the Unit’s oversight, is receiving free technical assistance to expand upon the initial UCS assignment and develop a provider performance and assessment report on all UCS providers. New York State is one of only three states that have begun the process of implementing a provider assessment tool.
This provider assessment tool will assist the VR program to analyze the need for additional providers, assist providers who are not meeting standards, and make available valuable information on providers to VR counselors and their consumers. Finally, it is expected that, after a provider assessment tool is in place, the Unit’s monitors will expand their current Supported Employment agency visits to include UCS providers.
E. Vocational Rehabilitation Impartial Hearing Officer Recruitment and Training
In late 2006 the Unit, which oversees the scheduling of consumers’ due process hearing requests, realized that the VR Program was facing a serious shortage of trained VR Impartial Hearing Officers who oversee due process hearings. Therefore, beginning in early 2007, the Unit undertook the task of recruiting, interviewing and hiring additional VR Impartial Hearing Officers. This process included submitting a justification to the Office of Fiscal Management to increase the VR Impartial Hearing Officer fee from $600 (instituted in 1998) to $1,100. The justification was approved and the new fee has been effective since November, 2007. With this increase in payment, the interest in the VR Impartial Hearing Officer positions was substantially improved over previous years’ recruitment efforts. After conducting interviews in four district offices located throughout the state, the Quality Assurance section added an additional twenty-five VR Impartial Hearing Officers to its roster.
Additionally, the Unit entered into a Memorandum of Understanding with the University at Buffalo Law School to provide training to the VR Impartial Hearing Officers. This training will ensure that the new VR Impartial Hearing Officers have a comprehensive understanding of the Federal Rehabilitation Act, the Vocational Rehabilitation program in New York as well as all applicable laws, rules, regulations, policies and procedures. All VR Impartial Hearing Officers are expected to participate in training which will be held in April, 2008.
Finally, at the request of the district offices, the Unit has prepared a report for the 2006-2007 federal fiscal year entitled “Summary of Hearing Decisions.” This report summarizes the hearings held in each district office, the issues that were involved in the hearing and what decision was reached. The district offices have responded positively to this report and it is expected that the Unit will prepare it at the end of each federal fiscal year.
F. Consumer Satisfaction Survey Response
VESID undertook a Consumer Satisfaction Survey in 2006 and used the Center for Essential Management Services to receive and compile the results. While the results, as a whole, were very favorable, the Unit felt a need to respond to two of the findings in particular. First, the survey found that approximately 27% of former VESID consumers who were unemployed at the time of their case closure had become employed when surveyed and second, conversely, the survey found that approximately 30% of former VESID consumers who were employed at the time of their case closure had become unemployed.
These findings led the Unit to create a follow-up project it called the “Alumni Outreach Project.” This project consisted of a letter and a regional resource information sheet, created by the Quality Assurance section of the Unit, being sent to more than four thousand previous VESID consumers or “alumni.” The Unit received 438 responses, an approximate 10% response rate. Of those responses, 70 alumni reported that they had become competitively employed since leaving VESID. This information was then provided to the appropriate district office, which in numerous instances, was able to convert the case into a successful closure.
Additionally, other questions asked in the survey provided valuable insight into the issue of availability of health insurance to our consumers, once they become employed. Further, many of the findings in the original Consumer Satisfaction Survey were validated by the answers received in the Alumni Outreach Project. The Unit is currently working with VESID’s Projects Planning Team (PPT) to devise a way to continue this Alumni Outreach Project on an annual basis. Also, the unit is considering undertaking another Consumer Satisfaction Survey in 2009.
1. Consumer Satisfaction
The Quality Assurance and Monitoring Unit also responds to consumer inquiries and complaints on a daily basis. This includes responding to E-mails that are sent from consumers, providers and potential employers. The E-mail address is on VESID’s web-site and people are encouraged to use it. Additionally, the Unit responds to a 1-800 phone number by answering questions about VESID, forwarding misplaced calls and responding to complaints. Finally, the Unit is charged with responding to correspondence regarding the vocational rehabilitation program. These E-mails, phone calls and correspondence often require discussion with supervisors at a district office to better understand the consumer’s concerns and potentially intervene on their behalf. All inquiries and complaints are carefully documented in a quality assurance database.
III. Future Endeavors
Over the next several months, the Unit expects to be primarily focused on the implementation of its new protocols for Supported Employment reviews and case reviews. As discussed above, a state-wide case review is planned for July 2008 on the topic of Eligibility and Significance of Disability. Additionally, the implementation of a provider performance assessment tool for use in the new UCS is a long-term project that will incorporate numerous different data gathering activities, such as consumer, counselor and provider satisfaction surveys. With support from the Regents, the Unit will continue to implement the activities and initiatives described above and will begin work on new projects that further correspond with the objectives of the Unit’s goals.