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California State Auditor Logo COMMITMENT • INTEGRITY • LEADERSHIP

Department of Rehabilitation
Its Inadequate Guidance and Oversight of the Grant Process Led to Inconsistencies and Perceived Bias in Its Evaluations and Awards of Some Grants

Report Number: 2017-129

Introduction

Background

The Department of Rehabilitation (Rehabilitation) works in partnership with the disability community, including disabled persons, caretakers, and other stakeholders, to provide services and advocacy that result in employment, independent living, and equality for individuals with disabilities, including those living with traumatic brain injuries. To carry out its mission, Rehabilitation employs more than 1,800 people. Although Rehabilitation offers the majority of its services directly to individuals with disabilities through the vocational rehabilitation program, such as career assessments and counseling, career education and training, access to assistive technology, and independent living skills training, it also works in cooperation with other agencies to provide these services to individuals with disabilities. Specifically, Rehabilitation works with 28 nonresidential, nonprofit, community‑based agencies—known as independent living centers—which are operated by individuals with disabilities and located throughout California. In addition to independent living centers, Rehabilitation also works with other specialized community‑based nonprofit agencies that provide services to people with blindness, survivors of traumatic brain injuries, and other disabled individuals who need assistive technology. Each independent living center provides services to people with a variety of disabilities.

Funding for Independent Living Centers

Rehabilitation provides financial support to independent living centers through a combination of federal and state funding. For a state to be eligible to receive federal assistance for its independent living programs, federal law requires it to establish and maintain a Statewide Independent Living Council (State Council) appointed by the governor. The majority of a State Council’s members must be made up of individuals with disabilities who are not employed by any state agency or independent living center. Federal law also permits parents or guardians of individuals with disabilities, advocates, and private business representatives to serve on the State Council. California’s State Council consists of 18 members, including disabled persons who are consumers of independent living services, advocates for people with disabilities, representatives of the business community, and the director of Rehabilitation as an ex officio, nonvoting member. The State Council’s duties include developing the State Plan for Independent Living (State Plan) and submitting it to the federal government for approval at least once every three years. The State Council develops the State Plan in conjunction with Rehabilitation, which is California’s designated state entity responsible for carrying out the State Plan. Consistent with the State Plan, Rehabilitation used a competitive process to award all of the grants it administered during our audit period. Table 1 shows the eight grants Rehabilitation awarded during our audit period of fiscal years 2014–15 through 2017–18, and highlights the four grants that we selected for our review.

Table 1
Grants Rehabilitation Awarded
Fiscal Years 2014–15 Through 2017–18
NAME OF GRANT AND REQUEST FOR APPLICATIONS (RFA) NUMBER PURPOSE OF GRANT YEAR AWARDED (MOST RECENT TO OLDEST) FUNDING AVAILABLE PER GRANT PERIOD DURATION OF GRANT PERIOD NUMBER OF APPLICANTS NUMBER OF AWARDEES
California Assistive Technology Program

   AT-18-01
To establish an effective and efficient program for coordination and delivery of statewide assistive technology services. 2018 $3.4 million total 3.25 years 2 1
Systems Change Network Hub (Systems Change)

   IL-17-01
To maintain, coordinate, and continue development of an existing Systems Change network focused on independent living issues affecting persons with disabilities. 2018 Up to $937,500 total 2.5 years 2 1
Youth Transition

   IL-17-02
To design and implement a Youth Transition Program within California’s independent living network for youth with disabilities, which can serve as a model for service delivery. 2017 $200,000 per awardee 2 years 12 6
Independent Living Services for Older Individuals Who Are Blind (OIB)

   OIB-17-01
To intensify efforts to identify and reach underserved ethnically diverse populations of older persons with visual impairments in California. 2017 $9.5 million total

Awards vary based on county square miles and population
1 year 11 7
Technical Assistance, Leadership Development, and Capacity Building

   IL-16-01
  • To achieve greater long-term stability for independent living networks.
  • To establish a project-demonstrated leadership development model that is based on peer review and peer mentoring and is designed by and for the independent living community.
  • To build capacity by undertaking or developing revenue‑generating ventures.
2015 $132,600 total

Awards vary based on service that the awardee will provide
1 year 11 7
Traumatic Brain Injury (TBI)

   02-24-2015
To provide five core services, as identified in Welfare and Institutions Code Section 4357, for individuals with traumatic brain injury and their families. 2015 $420,000 per awardee 3 years 13 7
Technical Assistance, Leadership Development, and Capacity Building

   IL-15-01
  • To achieve greater long-term stability for independent living networks
  • To establish a project-demonstrated leadership development model that is based on peer review and peer mentoring and is designed by and for the independent living community.
  • To build capacity by undertaking or developing revenue‑generating ventures.
2014 $209,900 total

Awards vary based on service that the awardee will provide
1 year 20 10
OIB

  OIB-14-01
To intensify efforts to identify and reach underserved ethnically diverse populations of older person with visual impairments in California. 2014 $9.3 million total

Awards vary based on county population
3 years 23 22

Source: Analysis of RFAs and supporting documentation for grants Rehabilitation awarded in fiscal years 2014–15 through 2017–18.
 = We selected these grants in our review to determine whether Rehabilitation followed its grant review process as required by law or in accordance with its grant manual. We selected two Independent Living Services for Older Individuals Who Are Blind grants because, in part, these grants are greater in award value than others.

Rehabilitation’s Organizational Approach to the Grant Process

For the purposes of this report, the process for soliciting and evaluating grant applications from the independent living centers and awarding grant funds to them (grant process) comprises three general phases: the solicitation of grant applications, the evaluation of applications and the awarding of grants, and the appeals process. Figure 1 summarizes these phases. Rehabilitation has two primary divisions that oversee the grant process, and additional executive management and review teams are responsible for certain procedural controls. The Specialized Services, Blind and Visually Impaired and Deaf and Hard of Hearing Division administers the grant process for the OIB grant, and the Independent Living and Community Access Division administers the Systems Change grant, TBI grant, Youth Transition grant, and Technical Assistance, Leadership Development, and Capacity Building grant.

Figure 1
Summary of Rehabilitation’s Intended Grant Process and Responsible Parties

A flowchart describing Rehabilitation’s intended grant process and the responsible parties.

Source: Analysis of the California Code of Regulations, Title 9, Section 7334, and Rehabilitation’s grant manual.

* Required by state regulations.

In summary, according to Rehabilitation’s grant manual, each grant begins with the solicitation phase, during which program staff plan the grant process, assign employees’ roles and responsibilities, obtain feedback from stakeholders to inform the development of the RFAs, and draft the RFAs. The RFAs should explain what information and documentation applicants should include in their application to demonstrate that they meet the requirements to apply for the grant. It should also include a detailed description of the criteria evaluators will use to score applications, such as the applicant’s experience and effectiveness in providing certain services. For the four grants we reviewed, Rehabilitation posted the final RFAs to its website.

The grant manual also indicates, in the evaluation and award phase, that program staff are responsible for identifying essential and desired qualifications for those who will evaluate the applications (evaluators), and program management is responsible for selecting evaluators with those qualifications. Evaluators may be state employees, including Rehabilitation employees, or outside subject‑matter experts. Program staff also coordinate the logistics of evaluations and appoint a technical review team. This team consists of subject‑matter experts in program policy and the grant process, and its purpose is to train evaluators on the evaluation process and program requirements before the evaluation, answer evaluators’ questions during the evaluation, and follow up after the evaluation process is complete to ensure that evaluators followed the intended steps. This team then summarizes the evaluation process and recommends grant awards in a memorandum to the director and chief deputy for approval. Once the director and chief deputy approve the grant awards, Rehabilitation posts notice of the awards on its website. If the director and chief deputy do not approve the award, the grant manual specifies that the grant process should start over.

The appeals phase ensues in cases where an applicant appeals an award decision. Upon receipt of an appeal, a review committee appointed by the chief deputy evaluates the appeal’s merit, and the grant manual suggests that the review committee should determine whether there were any procedural errors or omissions, whether there was evidence that evaluator prejudice affected the scoring process, and whether evaluators’ scores are supported by evidence in the relevant applications. After completing its review, the review committee notifies the appellant of its decision, and the grant manual suggests that the chief deputy should notify other affected parties of the appeal decision.



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