May 3, 2005
The Honorable Margaret
Spellings
US Secretary of Education
400 Maryland Avenue
S.W.
Bldg. FOB-6
Washington, D.C. 20202
Dear
Secretary Spellings:
I am writing on behalf of the
Council of State Administrators of Vocational Rehabilitation
(CSAVR) to share our concerns regarding the proposed monitoring
system the Rehabilitation Services Administration (RSA) is in
the process of establishing.
The CSAVR is composed of the
chief administrators of the Public Vocational Rehabilitation (VR)
Agencies serving individuals with physical and mental
disabilities in the states, District of Columbia, and the
territories. These agencies constitute the state partners in the
State-Federal, public-private partnership referred to as the
public VR program.
CSAVR wishes to acknowledge that the
State VR Agencies support accountability, and to that end,
believe in and support a highly specialized monitoring system.
Agency Directors are concerned, however, that the direction the
proposed monitoring system is currently taking, may not be
appropriate, or in the best interest of all of vocational
rehabilitation’s customers and stakeholders.
The new
monitoring system proposes to have vendors, consumers, and state
agencies, participate in the monitoring review process. Based on
this proposal, we respectfully request answers to the following
questions.
1. Why is it not a conflict of interest for
vendors who receive funding from VR to be involved in a state
agency’s performance review?
2. What assurances do state
agencies have that the individuals who will be conducting their
performance reviews are knowledgeable of the Rehabilitation Act,
the implementing regulations, state procurement rules, EDGAR,
and other information, as appropriate to make informed and
accurate decisions?
3. What safeguards will be in place
to protect the confidentiality of VR consumers, whose case
records should not be available to outside entities, simply
because they are part of a monitoring team?
4. What
assurances can you give a state agency that any information
gathered to determine targeted areas for monitoring, is
accurate, appropriate, and based on the Rehabilitation Act and
the implementing regulations?
5. What assurances can you
give a state agency that technical assistance will be available
for the provision of any corrective action necessary, based on
pertinent findings?
CSAVR has several representatives on
the Steering Committee, developed by RSA, to oversee the
implementation of the new monitoring system. They have asked
these same questions on every conference call convened. To date,
however, these questions have not been answered.
CSAVR
would greatly appreciate a response from you or the Inspector
General’s Office regarding our concerns.
If you have any
questions or need additional information, you can reach me by
phone at 301-654-8414 or email
carlsuter@rehabnetwork.org. I shall look forward to hearing
from you at your earliest convenience.
Sincerely,
Carl
Suter, Executive Director
CSAVR
