CPM Frequently Asked Questions
The WINTAC wants to ensure that State VR Agencies (SVRAs) have the most up-to-date answers to questions regarding the Common Performance Accountability System, RSA-911 Reporting and any other data-related questions that surface. We will update this FAQ section as pertinent information becomes available and RSA provides clarification to common questions to assist SVRAs in the implementation and evolution of WIOA performance measures within their systems.
For more information and to stay connected to WINTAC regarding Common Performance Measures and RSA-911 Reporting, please join our email distribution list. For technical assistance or to speak with one of our Subject-Matter Experts, please contact Rachel Anderson at firstname.lastname@example.org (please note updated email address for Rachel Anderson).
Click each topic for more information:
- General Reporting FAQ
- Credential Attainment & Measurable Skill Gains FAQ
- Pre-Employment Transition Services Reporting FAQ
- Blind VR Agency/Services Specific FAQ
- Federal Partner (RSA, DOL, etc.) FAQ’s
1. What are the required reports for State Vocational Rehabiliation Agencies (SVRAs)?
The WINTAC has developed a resource table, SVRA Reporting Deadlines, listing the required reports for SVRAs. This table includes the report name, reporting frequency, and detailed description of the report. This document can also be found on our resources page.
2. What are the reporting time frames applicable to SVRAs?
Federal Program Year
The Program Year (PY) is the period of time in which WIOA performance is collected and reported on the Case Service Report (RSA-911). Beginning July 1, 2017, SVRAs began collecting and reporting RSA-911 information based on the PY. Prior to July 1, 2017, VR agencies collected and reported data on the RSA-911 on a Federal Fiscal Year (FFY). This change is to establish a reporting period that is common for all six Core Programs under WIOA.
The PY begins on July 1 and ends on June 30 of the following year. The year designation for a PY will be consistent with the calendar year in which the first six months exist. For example, the PY that began July 1, 2017, and ended June 30, 2018, is referred to as PY 2017.
Federal Fiscal Year
The FFY is the period of time in which each VR agency is funded. The FFY begins on October 1 and ends on September 30 of the following year. The year designation for a FFY corresponds with the calendar year within which the last nine months (January through September) exist. For example, the FFY that began on October 1, 2016, and ended September 30, 2017, is referred to as FFY 2017.
3. When will SVRAs and the Rehabilitation Services Administration (RSA) negotiate expected levels of performance)?
The U.S. Departments of Education and Labor plan to issue joint guidance on negotiations and sanctions related to WIOA performance accountability. SVRAs) will negotiate expected levels of performance with RSA directly. These targets will likely be set for a two-year period. For example, targets set for PY 2020 (July 1, 2020 through June 30, 2021) will also be used for PY 2021 (July 1, 2021 through June 30, 2022). New targets would be set for PY 2022 and PY 2023.
4. Who are Reportable Individuals?
A reportable individual is an individual who has taken action that demonstrates intent to use program services and who meets specific reporting criteria of the program. Reportable individuals must be reported in the RSA-911. For the purposes of VR program, a reportable individual includes students with disabilities who solely receive pre-employment transition services, and individuals who have not applied or been determined eligible for VR services. Reportable Individuals are not included in calculations of performance because they do not meet the definition of a participant.
In the RSA-911, Reportable Individuals are those whose service records meet the following conditions:
- Data Element 7: Date of Application is not blank; or
- Data Element 96: Start Date of Pre-Employment Transition Services is not blank.
Reportable individuals must be reported until the quarter after they exit the VR program (Data Element 353: Date of Exit).
5. Who are Participants?
For purposes of the VR program, a participant is a reportable individual who has applied and been determined eligible for VR services, has an approved and signed IPE, and has begun to receive services under the IPE. Participants are included in the calculations of performance.
In the RSA-911, Participants are individuals whose service records meet the following conditions:
- Data Element 7: Date of Application is not blank;
- Data Element 38: Date of Eligibility Determination is not blank;
- Data Element 48: Date of Most Recent IPE or Amendment is not blank;
- Data Element 127: Start Date of Initial VR Service on or after IPE is not blank; and
- Data Element 353: Date of Exit is blank.
All participants MUST be reported on each quarterly RSA-911 submission, regardless of whether or not any information in their service record has changed.
6. When does a participant exit the program?
A participant exits the VR program when his or her service record is closed in accordance with VR program requirements. Exit status is a “trigger” for including a participant in the performance calculations.
A participant’s record of service may be closed in accordance with 34 CFR § 361.56 because the participant achieved an employment outcome; or
A participant’s service record may be closed because the individual did not achieve an employment outcome or the individual has been determined ineligible after receiving services in accordance with 34 CFR § 361.43.
7. Which elements in the RSA-911 are updateable by way of making corrections in subsequent quarterly reports and which need to go through RSA?
RSA published the Case Service Report (RSA-911) Correction Procedures. This technical assistance resource outlines the options available to State Vocational Rehabilitation agencies to correct information reported on the RSA-911 when errors in data collection or reporting are identified. Please email RSAData@ed.gov or contact your RSA State Liaison with any questions.
8. Do SVRAs need to use the same Unique Identifier with other WIOA core programs, or may each of the core programs have a separate Unique Identifier?
There is no requirement that core programs use the same Unique Identifier for reportable individuals and participants. However, it may benefit the SVRA to work with the other core programs to develop a system for assigning Unique Identifiers, but there is no requirement at this time.
As outlined in PD 16-04, when a Blind or General SVRA in the same state identifies that an individual has been or is being served by the other agency, every effort should be made to ensure the same Unique Identifier is used for both agencies.
9. When will SVRAs have the ability to report all of the information for each of the WIOA performance measures?
Because SVRAs began collecting and reporting WIOA information on the RSA-911 beginning with PY 2017, it will require eight quarters of reporting, or two full PYs, before SVRAs have all of the information to completely report on the performance measures in PY 2019. Please refer to the following example:
|Measurable Skills Gains||100%||100%||100%||100%|
|Employment Rate 2nd Quarter after Exit||0%||75%||100%||100%|
|Median Earnings 2nd Quarter after Exit||0%||75%||100%||100%|
|Credential Attainment Rate||0%||50%||100%||100%|
|Employment Rate 4th Quarter after Exit||0%||25%||100%||100%|
10. Due to the lag in receiving Unemployment Insurance (UI) wage data, SVRAs will be two quarters behind reporting this data for Employment Rate 2nd Quarter after Exit, Median Earnings 2nd Quarter after Exit, and Employment Rate 4th Quarter after Exit. How long do SVRAs have to report after a participant exits the VR Program?
|PY||Quarter||Exit Quarter||Quarter End Date||Quarterly Report Due to RSA||Data|
|2018||Q1||0||September 30, 2018||November 15, 2018||Participants exits during PY 2018 Q1|
|2018||Q2||1||December 31, 2018||February 15, 2019||-|
|2018||Q3||2||March 31, 2019||May 15, 2019||
Employment 2nd Quarter after Exit;
|2018||Q4||3||June 30, 2019||August 15, 2019||Employers report wage data from PY 2018 Q3 to State UI|
|2019||Q1||4||September 30, 2019||November 15, 2019||
Employment 4th Quarter after Exit
|2019||Q2||5||December 31, 2019||February 15, 2020||Employers report wage data from PY 2019 Q1 to State UI|
|2019||Q3||6||March 31, 2020||May 15, 2020||
State UI provides SVRA with the PY 2019 Q1 data
If a participant exits the VR program on September 15, 2018, the participant exited during PY 2018 Q1, which ends on September 30, 2018. The SVRA must collect and report information on this participant for six full quarters, through the end of PY 2019 Q3.
Due to the two quarter lag, the SVRA receives the PY 2018 Q3 data, which reflects the participant’s employment in the 2nd Quarter after Exit and Median Earnings in the 2nd Quarter after Exit, in PY 2019 Q1; the SVRA then reports this data in the quarterly report due to RSA by November 15, 2019.
Similarly, the SVRA receives the PY 2019 Q1 data, which reflects the participant’s employment in the 4th Quarter after Exit, in PY 2019 Q3; the SVRA then reports this data in the quarterly report due to RSA by May 15, 2020.
1. What resources are available to help guide states through the process of developing data sharing agreements and understanding agency-specific requirements for partners entering into these agreements?
The U.S. Departments of Labor and Education issued Joint Guidance on Data Matching to Facilitate WIOA Performance Reporting and Evaluation to assist State workforce development agencies (including SVRAs) and educational agencies with performance reporting and evaluation requirements under the Workforce Innovation and Opportunity Act (WIOA).
The WINTAC created a Data Sharing Agreement Toolkit to help SVRAs develop data sharing agreements, particularly for use in the Common Performance Measures.
The WINTAC is also gathering examples of data sharing agreements (for UI and Credential data) from partners in a variety of states that may be shared with SVRAs who need assistance.
2. If SVRAs enter into data sharing agreements with higher education, secondary education or other training entities (e.g., National Public Clearing House) to obtain data related to credential attainment and/or measurable skill gains, does the data match count as “documentation,” or do SVRAs also need to gather actual diplomas, certificates and other documentation for individual case files?
The joint Data Validation guidance (RSA TAC-19-01) includes “data match” as allowable source documentation for the Data Attained Recognized Credential (Data Elements 87, 88, 89, 90, 93, 94, 95). Though SVRAs do not have to also acquire diplomas, certifications, and other documentation for service records, the SVRA must maintain the data match for audits, monitoring reviews, or verification of the credential attained.
3. Are SVRAs allowed to backdate the date a participant earned a Credential or achieved a Measurable Skill Gains, if verification is received after the close of the quarter in which it was achieved?
Measurable Skill Gains (MSG)
SVRAs have some flexibility reporting MSGs earned if the SVRA receives verification in a subsequent reporting quarter within the same PY. MSGs are reported on open cases; therefore, as long as the SVRA receives verification prior to the submission of the 4th quarter report (due by August 15 each year), the SVRA may report the date a participant achieved a MSG in the quarter it was earned. This would still be included as a positive outcome. However, if verification that a participant achieved a MSG is received after the close of the PY, it will not be included in the MSG indicator for that PY because reporting ended after submission of the 4th quarter report. The MSG cannot be carried over into the next PY either.
Though agencies should have policies and procedures to report credentials as participants earn them, there is also some flexibility with when these are reported to RSA. The Credential Attainment Indicator is calculated AFTER a participant exits the VR program. The SVRA can earn a positive outcome for a credential earned during the life of the case or up to one year after exit. Therefore, if the SVRA obtains verification of the credential across quarters or program years, the SVRA may report this on the RSA-911, as long as the participant earned the credential before his or her service record was closed or within one year of exiting the VR program.
4. Can a Work-Based Learning Experience (WBLE) through Project Search count as a Measurable Skill Gain?
WBLE through Project Search may count toward a Measurable Skill Gain. The WINTAC, in partnership with RSA, developed this FAQ which addresses topics State VR agencies should consider as they determine whether or not activities through Project Search can be reported as various types of MSGs.
5. What is the Eligible Training Provider list? Can VR agencies use the list to identify training programs that qualify as leading towards a credential under WIOA?
WIOA requires title I programs in each State to have a list of eligible training providers (ETP). Only training providers who are determined eligible may receive funds from an Individual Training Account (ITA), which is the primary funding mechanism for participant training under WIOA title I. The ETP list is also important to WIOA title I program participants to aid them as they research training options suitable to their interests and make informed consumer choices. The State ETP list includes providers who offer postsecondary training programs reviewed and approved by the designated State entity (in coordination with local areas) in each State as meeting WIOA and State standards. WIOA requires that in order to be on the ETP list, the provider must offer a training program that leads to:
- a credential;
- employment; or
- a measurable skill gain leading to a credential or employment.
Therefore, it is possible that there are ETPs on the list whose programs do not lead to a credential. However, some States have additional requirements that place greater emphasis on credentials in the eligibility process and therefore result in high percentages of programs on the list that lead to credentials. Title I programs (with limited exceptions) may fund postsecondary training for participants using training programs on the ETP list. VR agencies, on the other hand, are not limited to using only those programs on the list. In some States, there may be programs that qualify, but do not appear on the ETP list.
We recommend that VR agencies consult with their colleagues who administer the title I programs to ensure those programs listed in the ETP list meet standards for recognized postsecondary credentials under WIOA and discuss whether these training programs have been effective in meeting participants’ training needs. For more information on ETP requirements for the WIOA title I programs, see Training and Employment Guidance Letter (TEGL) 08-19 and related resources on WorkforceGPS.
6. What is On-the-Job Training (OJT) and does completing an OJT count as a Measurable Skill Gains (MSG)?
OJT is an allowable VR service under 34 CFR 361.48(b)(6) and must be provided to a VR program participant under an Individualized Plan for Employment (IPE). Generally, OJT means occupational training provided directly by an employer. Sometimes the participant is compensated for the work he or she performs for the employer. In some instances, VR agencies enter into an agreement with the employer to fund the training and/or the participant’s wages with the expectation that the employer will hire the participant upon completion of the OJT. OJT provides the participant the opportunity to acquire the knowledge and skills required to perform the job in competitive integrated employment. OJT is time-limited and the duration is based on the unique circumstances of the participant and the content and scope of the training needed. Like all VR services, OJT should assist the participant with meeting his or her employment goal on the IPE.
Under WIOA, there are five types of MSG. If a participant completes an OJT, this can count as a MSG: Training Milestone. RSA-TAC-17-01 states that, “The measurable skill gains indicator is used to measure interim progress of participants who are enrolled in education or training services for a specified reporting period.” The guidance outlines what documented progress means; this includes, “Satisfactory or better progress report, towards established milestones, such as completion of OJT or completion of one year of an apprenticeship program or similar milestones, from an employer or training provider who is providing training.” Unlike other types of MSG (e.g., postsecondary transcript), completing an OJT may count as a MSG even though the participant is not pursuing a recognized postsecondary credential. While the expectation should remain that the employer hire the participant upon completion of the OJT, employment with this specific employer is not required for the OJT completion to count as a MSG: Training Milestone. The employer must provide documentation of OJT completion to the participant or the VR agency; this documentation should be detailed enough to clearly explain the knowledge and skills the participant acquired as a result of the OJT.
VR agencies must establish policies and procedures related not only to the provision of the OJT itself, but also for the employer’s documentation substantiating that the participant completed the OJT and made measurable progress.
7. What is Customized Training and does completing Customized Training count as a Measurable Skill Gains (MSG)?
The joint performance accountability guidance (RSA-TAC-17-01) includes a definition of Customized Training in Attachment 1. In general, Customized Training:
a) is designed to meet the specific requirements of an employer (including a group of employers);
b) is conducted with a commitment by the employer to employ a VR program participant upon successful completion of the training; and
c) for which the employer pays---
(i) a significant portion of the cost of training, as determined by the VR agency or other program, taking into account the size of the employer and such other factors as the program determines to be appropriate, which may include the number of employees participating in training, wage and benefit levels of those employees (at present and anticipated upon completion of the training), relation of the training to the competitiveness of a participant, and other employer-provided training and advancement opportunities; and
(ii) in the case of customized training involving an employer located in multiple local areas in the State, a significant portion of the cost of the training, as determined by the Governor of the State, taking into account the size of the employer and such other factors as the Governor determines to be appropriate.
Similar to an OJT, if a participant completes a Customized Training program, this can count as a MSG: Training Milestone. Like all VR services, VR agencies must establish policies and procedures related to the provision of Customized Training. These policies should address the documentation that is required from the employer to substantiate that the participant completed the Customized Training and made measurable progress. Policies should also detail the manner in which the VR agency enters into agreements with employers to fund Customized Training programs.
1. How are Pre-Employment Transition Services documented in the RSA-911? What do states need to know?
For more information related to reporting Pre-Employment Transition Services in the RSA-911 report, please review this FAQ. We also encourage you to watch the full RSA-911 Training Series which provides detailed information on reporting all aspects of individuals receiving services from the VR program, including Pre-Employment Transition Services.
1. Do Randolph Sheppard Business Enterprise Program (BEP) outcomes count toward credential attainment?
As outlined in Attachment 10 of the joint performance accountability guidance (Technical Assistance Circular 17-01), Randolph Sheppard Entrepreneurial Training (RSA-911 Data Elements 198, 199 and 203) are included in the denominator of the Credential Attainment calculation. Once the participant completes the Randolph Sheppard Entrepreneurial Training and receives his or her license, the SVRA should record the date in Date Element 93: Date Attained Vocational/Technical License.
Similar to all services reported in the RSA-911, a recognized education or training program (including BEP) needs to be included on the IPE in order to document the credential earned.
2. Do milestones achieved throughout the duration of Randolph Sheppard Entrepreneurial Training meet the definition of Measurable Skill Gains (MSG)?
Yes, milestones achieved and documented in Entrepreneurial Training may count towards the MSG indicator under Type 4: Satisfactory or better progress report towards established milestones.
SVRAs need to ensure policies and procedures outline which milestones (e.g. completion of Hadley training) count as an MSG during an Entrepreneurial Training program, including when and how to document them in the SVRA’s case management system.
3. Do Randolph Sheppard BEP outcomes meet the definition of “unsubsidized employment” as it relates to WIOA performance indicators?
BEPs are considered to be Competitive Integrated Employment and are generally regarded as self-employment. These outcomes are not subsidized employment, so they are included in the WIOA Performance Indicators and would be positive outcomes if the participants are employed in during 2nd and 4th quarter after they exit the VR program.
RSA-911 Reporting FAQ
The Rehabilitation Services Administration (RSA) has developed Frequently Asked Questions (FAQ) about the RSA-911 Case Service Report Manual.
As states discover additional questions or areas needing clarification, questions regarding the RSA-911 reporting should be sent to RSAData@ed.gov.
RSA: Period of Performance for Formula Grant Awards FAQ
The Rehabilitation Services Administration (RSA) has issued a Frequently Asked Questions (FAQ) document related to the period of performance for formula grant awards. The Uniform Guidance in 2 CFR 200.77 defines “period of performance” as the time during which the non-Federal entity (grantee) may incur new obligations to carry out the work authorized under the Federal award. The FAQ document provides details regarding the process for updating Grant Award Notifications to include a carryover period and explains the relationship between requirements for the period of performance and formula awards.
COVID-19 FAQ - WIOA Performance Accountability Provisions
The Office of Special Education and Rehabilitative Services’ Rehabilitation Services Administration (RSA) announced the U.S. Department of Education has released an initial frequently-asked questions document related to implementing performance accountability provisions under title I of the Workforce Innovation and Opportunity Act (WIOA) as State Vocational Rehabilitation (VR) agencies seek to provide continuity of operations for individuals with disabilities in the COVID-19 environment.
COVID-19 FAQ - VR Administrative and Program Requirements
The Rehabilitation Services Administration (RSA), within the U.S. Department of Education’s (Department) Office of Special Education and Rehabilitative Services, issues this Questions and Answers document in response to inquiries concerning the administration of the State Vocational Rehabilitation (VR) Services, American Indian Vocational Rehabilitation Services (AIVRS), and Randolph-Sheppard programs as grantees seek to provide continuity of operations for individuals with disabilities in the current COVID-19 environment. Regarding data collection and reporting, this FAQ includes responses to questions on the implementation of PD 19-03 (RSA-911) and the effects of COVID-19 on the Statistical Adjustment Model.