Use of DVR Funds for OIB Services

From: Akinola, Elizabeth [mailto:Elizabeth.Akinola@ED.GOV]
Sent: Thursday, September 15, 2011 8:04 AM
To: RSA_OLDER_BLIND_PROJECT_DIRECTOR@LISTSERV.ED.GOV
Subject: [RSA_OLDER_BLIND_PROJECT_DIRECTOR] Guidance regarding use of VR funds to pay OIB staff for providing OIB services

Good morning. We provide the following guidance in response to questions from some agencies regarding the unallowability of using funds from the VR program to pay staff of the chapter 2 Older Individuals who are Blind (OIB) program who provide non VR related IL services to OIB consumers.

If you recall, we discussed the possibility—and encouraged The practice of referring OIB consumers who are interested in going back to work for VR services at the annual conference for OIB program managers in 2008. We did say that OIB consumers may also be VR consumers concurrently. However, we explained that if an OIB consumer has both an OIB case and a VR case open at the same time, the non VR related IL services that the consumer receives are to be paid for with chapter 2 funds, and the staff working with that consumer should also be paid with chapter 2 funds. If, however, that same consumer is also receiving VR services—and/or IL services that are related to achieving their employment goal, those services should be paid for with VR funds, and the staff working with the consumer to achieve the VR goal—and/or IL services related to achieving that VR goal should be paid with VR funds. Hence the importance of correctly allocating and accurately reporting the amount of time each staff works on these programs.

We refer to the foregoing to aid understanding of our answer to the question of whether chapter 2 funds may be solely used to provide OIB services while a state agency pays the staff working on that program to provide those services with funds from other sources. The answer depends upon the sources of the other funds being used. If the agency is using VR funds to pay the personnel costs for the non VR related IL and IL-OIB programs, the agency may be required to repay the VR funds. This is because non VR related IL and IL-OIB costs are not allowable charges to the VR award.

If, however, the agency is using state funds (not being used to match the VR program) or is transferring program income from the VR program to the IL and/or IL-OIB program to pay program costs like salaries, that would be allowable.

The important point is that agencies may not use VR funds to pay for non VR related IL or IL-OIB services. This includes indirect costs, the costs of processing non VR related IL or IL-OIB authorizations, management of the programs, etc.

We hope you find this guidance helpful.

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