BE A FI$CAL
$.T.A.R.
VR PRACTICES
RSA-2 and SF 425
REPORTING
Presenters:
Julya Doyle, Management and Program Analyst,
SMPID Fiscal Unit
Craig McManus, Financial Management Analyst,
SMPID Fiscal Unit
Scott Dennis, Director, Business Support Services,
Maryland Division of Rehabilitation Services
OVERVIEW
RSA-2: Changes to the New Form
 Maryland Practice for Data Reporting
 Questions
 SF-425: Recent Changes and Common
Reporting Errors
 Grant Closeout Procedures
 Questions

RSA–2 Form
The Annual Vocational Rehabilitation Program/Cost
Report (RSA-2) for the Vocational Rehabilitation (VR)
and Supported Employment (SE) programs captures:
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Administrative expenditures for the VR and SE
programs;
VR program service expenditures by category;
SE program service expenditures;
Expenditures for the VR program by number of
individuals receiving purchased services;
The costs by type of services provided; and
A breakdown of staff employed by the VR agencies.
RSA-2 Form: General Revisions
General revisions to the RSA-2 form (RSA-PD-13-04)
include:
• Removing Schedule IV, Expenditures from Title VI-B
Funds and Other Rehabilitation Funds, and Schedule V,
Carryover Funds, from the RSA-2 form because these
sections were found to be redundant with other fiscal data
collection forms;
• Removing the requirement to include unliquidated
obligations when calculating expenses;
• Removing data elements that RSA could calculate based
upon other information provided by the agency (e.g.,
subtotals and totals); and
• Aligning the service categories with those contained in the
VR program Case Service Report (RSA-911) data
collection instrument.
RSA-2 Form: Schedule Revisions
The RSA-2 form has been reduced from 5 schedules to 3
schedules:
• Prior Schedule I renamed from Total Expenditures to
Agency Expenditures;
• Prior Schedule II (Individuals Served and
Expenditures) moved to Schedule III;
• Prior Schedule III (Person Years) moved to Schedule II
and revised (Labor Hours);
• Prior Schedule IV (Title VI-B and other Rehabilitation
Funds) eliminated and Supported Employment pulled
into Schedule I and III; and
• Prior Schedule V (Carryover Funds) eliminated as this
data is collected in the SF-425 report.
Schedule I
 The administrative costs in Line 1 have been
expanded to include expenditures related to:
• Personnel costs;
• Direct costs;
• Indirect costs; and
• SE program costs.
 Transition Consultation and Technical Assistance
(3.D) has been added under Services to Groups
Expenditures.
Schedule II
 The basis for calculation of personnel effort has
been changed from person-years to labor hours.
Examples for calculating full-time and part-time
employees are provided.
 A separate data field is provided (line 5) to denote
the number of hours considered full time in the
state, due to state variation in the weekly
threshold.
Schedule III
 The new RSA-2 form has expanded to 28 discrete
service categories that align with the RSA-911
form, combining both VR and SE program funds.
 Schedule III will only include the number of
individuals and expenditures for purchased
services.
Schedule III (cont.)
 The instructions for “Information and Referral”
were clarified by including an “e.g.” before
cooperative agreements to indicate that this is an
example, and not the only source through which
information and referral services may be
provided.
Schedule III (cont.)
 The Post-Employment Services category was
eliminated as a service category in the new form.
 Services provided under Post-Employment
should now be recorded in the appropriate
service category.
Schedule III (cont.)
 The description of Vocational Rehabilitation
Counseling and Guidance was clarified to ensure
consistency with the VR regulations.
 For purposes of Schedule III – purchased VR
Counseling and Guidance is distinct from the
case management relationship between
counselor and individual during the VR process.
Schedule III (cont.)
 The former Training service sub-categories were
expanded into discrete categories, including:
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Graduate College or University Training;
Four-Year College or University Training;
Junior or Community College Training;
Occupational or Vocational Training;
On-the-job Training;
Apprenticeship Training;
Basic Academic Remedial or Literacy Training;
Job Readiness Training;
Disability Related Skills Training; and
Miscellaneous Training.
Schedule III (cont.)
 Some new additional service categories to note
include:
• Job Search Assistance;
• On-the-job Supports – Time limited;
• On-the-job Supports – Supported
Employment;
• Reader;
• Interpreter;
• Technical Assistance;
• Benefits Counseling; and
• Customized Employment.
Schedule III (cont.)
 Cross-checking data:
• The dollar amounts on Schedule III, should reflect
the total of the amounts included in Schedule I,
Agency Expenditures, Section 2.B., lines 1
through 4.
Form Access
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The RSA-2 and SF-425 forms are available on the
RSA website (http://rsa.ed.gov/).
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Agencies must ensure the appropriate personnel
maintain, obtain, or perhaps terminate their
access to the program and fiscal reports
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To obtain access from the website, select “Info
for new users” on the right side of the home
page and follow the instructions under
“OBTAINING MIS ACCESS.”
G5 Access
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The SF-425 instructions require grantees to
verify drawdowns from G5. Therefore, staff
responsible for reporting will be required to
register in the G5 system to access grant
funds: (https://www.g5.gov)
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Follow the instructions after selecting the “Non
ED employee Sign Up” link.
RSA-2 Impact –
State Partner
Schedules I and II do not impact the agency’s
data collection or reporting.
Schedule III Impact – State Partner
 DORS Case Management System
Revision of the existing Category System
 Realigning and creating new sub-categories to
match new
reporting
requirements
Schedule
III Impact
–
State
Partner
 System testing
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Schedule III Impact – State Partner
 Staff
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Staff adjustment to the new coding categories
Training of staff on new service categories
Schedule III testing
Impact – to assess
Stateeffectiveness
Quality assurance
Partner
of staff training
Staff time providing Counseling and Guidance
(case management) on Schedule I vs. purchased
Counseling and Guidance on Schedule III
Schedule III Impact – State Partner
 Community Rehabilitation Programs (CRPs)
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Training on potential impact for CRP service
reporting
Training CRP
staff
on new
Schedule
III Impact
– RSA coding
State
Partner
requirements
CRP billing concerns – specificity of services on
invoices
Example: Prior RSA-2 includes job related services, which are
not split into several discrete service categories in the revised
RSA-2 (e.g., Job Search Assistance, Job Placement Assistance,
and On-the-Job-Supports – Time Limited)
Reporting – State Partner
 Tying Schedule 1, Section 2 to Schedule III
 Agencies may not report activity for some service
categories (e.g., Customized Employment)
Schedule III Impact –
Partner
State
QUESTIONS – RSA-2
Recent SF-425 Changes
and Clarifications
RSA-PD-12-06
•
Cash Receipts and Disbursements – Lines 10a
and 10b
•
Federal Share of Expenditures – Line 10e
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Program Income – Lines 10l through 10o
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Indirect Expenses – Lines 11a through 11f
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Remarks – Lines 12a through 12h
Cash Receipts and Disbursements
• Cash Receipts should be reported as the net amount
that the grantee has drawn down from G5.
• Cash Disbursements are the sum of the actual cash
expenditures made for direct charges for goods and
services, the amount of indirect expenses charged to
the award, and the amount of cash advances and
payments made to contractors/vendors.
• For each reporting period these two lines are an
accumulative amount. They should include the
amount drawn down and the amount disbursed from
the start of the award through that report period end
date.
Federal Share of Expenditures
• For Annual Reports prepared on a cash basis, the agency
should report federal fund expenditures as the sum of cash
disbursements for direct charges for goods and services, the
amount of indirect expenses charged, and the amount of
payments made to contractors/ vendors.
• For reports prepared on an accrual basis, grantees should
report federal fund expenditures listed above as well as and the
increase or decrease in the amounts owed by the recipients for
goods received and services performed by employees,
contractors/vendors, and other payees.
• The final report should include the total sum of expenditures.
Line 10e should equal Cash Receipts and Disbursements.
Program Income
Program Income is considered earned in the
fiscal year in which the funds were actually
received by the grantee. VR Program Income is
the gross income received by the grantee that is
directly generated by an activity supported under
the VR program.
Deduction and Addition Alternative,
What’s the Difference?
• The Addition Alternative (line
10n) is used when the
agency supplemented the
federal share of the total
program costs, representing
actual disbursements of
program income by the
grantee.
• The Deduction Alternative
(line 10m) should be used
when program income was
used to reduce the federal
share of the total VR
program costs. The amount
of funds entered in line 10m
will reduce the federal
share, resulting in the return
of these funds to RSA.
Transferring Program Income
• When Social Security Reimbursement program income is
transferred to another eligible program, the program income is
reported on Line 10l (Total Federal Program Income Earned)
of both the transferring (VR) and receiving programs’ SF-425
reports.
• Additionally, both the transferring and receiving programs
report program income expended on line 10n (Program
Income Expended in Accordance with the Addition
Alternative).
• The transferring program will report the amount transferred to
the receiving program in the appropriate line in section 12.
• The receiving program will identify that the program income
was not earned, but received through transfer, in section 12
remarks.
Section 11: Indirect Expenses
Whether an agency has an Approved Indirect Cost
Rate or a Cost Allocation Plan, the agency must fill
out section 11.
• 11a – Type of Rate
• 11b – Rate
• 11c – Period from; Period to
• 11d – Base
• 11e – Amount Charged
• 11f – Federal Share
Section 12: Remarks
Section 12 – The Remarks section was revised and lists eight
data elements, six allow for data to be entered. These items
include:
• 12a – reporting on the non-federal share of expenditures for
the construction and establishment of facilities for community
rehabilitation program purposes;
• 12d – recipient share of unliquidated obligations – the
portion of unpaid obligations to be paid with non-federal
funds meeting program requirements;
• 12e, f and g – the transfer of federal VR Social Security
reimbursement program income to other eligible programs
(SILS, OIB, CAP);
• 2h – the total federal VR Social Security reimbursement
program income transferred to all eligible programs; and
• 12b and c – not applicable.
Grant Closeout
All final reports are due 90 days after the end of grant
support, at which time RSA will begin the closeout
process. The grant may be closed out if the following
criteria are met:
 Grant funds are no longer available for liquidation
after the performance period ends;
 All funds remaining in G5 were either deobligated or
liquidated;
 All required performance and financial reports have
been received;
 All single audits for the grant period have been
resolved; and
 There are no outstanding issues that were identified
in the monitoring reports.
Grant Closeout Checklist
 There are no validation errors on the form and each
• line
. required was filled out.
 Final Performance and Financial Reports have been
submitted.
 There is no Cash on Hand.
 Cash Receipts equal Net Draws from G5.
 Federal Expenditures equal Net Draws from G5.
 Recipient Share of Expenditures is greater than or
equal to Total Recipient Share Required.
 There are no unliquidated obligations.
 There is no unexpended Program Income.
Let’s look at the line items in more detail…
Grant Closeout – Final Reports
• .All final performance and financial reports associated
with the award must be completed and submitted.
• If the grantee liquidates obligated funds within the
90-day liquidation period, the grantee does not need
to submit an SF-425 report on 9/30 and then another
SF-425 after the funds are liquidated.
• If a grantee has Late Liquidation approved, the
grantee submits the Final (9/30) SF-425 report at the
end of the extended liquidation period.
Grant Closeout – Cash Receipts
and Disbursements
• .
• Cash Receipts (line 10a) must equal Cash
Disbursements (line 10b), indicating that there is no
cash that was drawn down, but not spent for the
grant period.
• Cash Receipts (line 10a) must equal the amount of
award drawdowns from the G5 system (Net Draws).
Grant Closeout – Expenditures
• .Federal Share of Expenditures (line 10e) equals net
drawdowns from G5. Do not include federal
program income received by the grantee on line
10e.
• Recipient Share of Expenditures (line 10j) is greater
than or equal to Total Recipient Share Required
(line 10i), indicating that the grantee has met the
match requirement.
Grant Closeout – Unliquidated
Obligations and Program Income
• .
• Federal Share of Unliquidated Obligations (line 10f)
and Recipient Share of Unliquidated Obligations
(line 12d) must be zero, indicating there are no
remaining obligations under this grant award which
have not been paid.
• Unexpended Program Income (line 10o) must be
zero, indicating that all program income was
expended. Program Income cannot be transferred
from one grant award year to another grant award
year.
Noncompliant Grant Closeouts
• all
. of the steps outlined earlier are met, the grant
If
award will be closed in compliance, but if any of the
above are not corrected the grant award may be
closed in noncompliance.
The Department is adhering to stricter accountability
related to noncompliance.
References
Grant
• . Closeout – 34 CFR 80.50 and CFR 80.51
Financial Reporting Requirements – 34 CFR 80.41
Program Income – 34 CFR 361.63 and 34 CFR 80.21(f)(2)
Non Compliance Actions – 34 CFR 80.43
VR Counseling and Guidance – 34 CFR 361.48(c)
Services to Groups – 34 CFR 361.49
Revision of Annual Vocational Rehabilitation Program/Cost Report
(RSA-2) for the State Vocational Rehabilitation Services Program
and the State Supported Employment Services Program – RSA-PD13-04
 Revision of PD-11-02, instructions for completing the Federal
Financial Report (SF-425) for the Vocational Rehabilitation State
Grants Program. – RSA-PD-12-06
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QUESTIONS – SF-425