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Located in:

d. 2. M. i. II. The Justification for the Order.

Current Narrative:

VR’s available and projected resources is not adequate to ensure the provision of the full range of vocational rehabilitation services, as appropriate, to all eligible individuals in federal fiscal years 2017, 2018, and 2019. VR experienced a deficit of staffing resources in FFY17, and a deficit of both staffing and fiscal resources is projected for FFY18. Insufficient resources are also anticipated for FFY19, however this will be re-evaluated prior to the end of FFY18. Challenges in regards to insufficient staffing resources include high VR Counselor caseloads, a poor VR Counselor retention rate, and other factors further detailed below. Furthermore, VR anticipates a projected annual fiscal deficit of approximately $5 million for both FFY18 and FFY19. The fiscal deficit results from the need to shift resources to meet WIOA requirements, including earmarking 15% of federal funds for pre-employment transition services, and the need to modernize information systems to ensure proper collection of new federal data requirements.

Total annual funding available in FFY18 and FFY19 for serving individuals in Title I ($38.5 million) and VI-B ($500,000), program income ($1 million), administrative costs including personnel ($32 million), and the required pre-employment transition services set aside ($9.5 million) is $81.5 million. Additional staffing would be necessary to provide the full range of services to all eligible individuals in an equitable and expeditious manner. A fiscal deficit is projected due to a need to shift funding to meet federal requirements under WIOA, including earmarking 15% of Title I federal funds on pre-employment transition services and contributing to the operation costs of the Department of Workforce Development (DWD) Work One centers through infrastructure funding agreements, as well as the need to modify data collection systems to meet enhanced federal reporting requirements. The anticipated projected annual deficit for FFY18 and FFY19 is $5 million. Therefore, an annual budget of approximately $86.5 million would be needed in FFY18 and FFY19 to serve all eligible individuals, which is at minimum 15,000. The current ratio of VR Counselors to eligible consumers receiving services under an Individualized Plan for Employment (IPE) is 1:126. BRS believes that a counselor-consumer ratio of no more than 1:100 is optimal to maintain efficient caseload management and high quality services. At this time, additional VR Counselors are needed to work toward this optimal ratio, however there are challenges with expanding the number of VR Counselor positions, including lack of availability of qualified candidates, and challenges with fiscal resources. This is further discussed below. Staff retention of VR Counselors has been a major concern for VR over the past few years. In recent years, the turnover rate for all VR field positions has been 41%, with turnover of 56% for VR Counselor positions. This turnover has been a major contributing factor to BRS’ diminished capacity to serve all individuals seeking VR services, and the inability to serve consumers already in the system in a timely manner. BRS has experienced improvements in the retention rate over the past 9 months, and as of March, 2018 the turnover rate of VR Counselors has decreased to 31%.

Additional data outlining retention challenges is as follows: o Out of 175 current VR Counselors positions: o 56 are filled with staff who have been employed with BRS more than 5 years, representing only 32% of staff. o 57 are filled with staff have been employed with VR more than 2 years, but less than 5 years, which is 33% of staff. o 62 are either vacant or are filled with staff who have less than two years on the job, many of whom are still in the learning curve and in probationary status. This represents 35% of staff.

VR has investigated likely causes of the increased turnover. The two most common reasons reported when a staff member resigns are the overwhelming work load, and the salary for the type of work VR Counselors perform and required qualifications. There are several factors that likely contribute to the overwhelming and dissatisfied experiences that VR Counselors report, including high caseload sizes and the breadth and depth of the case work. Additionally, during periods of time where vacant clerical and support staff positions go unfilled, VR Counselors must absorb those additional tasks, further reducing their ability to provide high quality counseling and guidance to consumers.

Recruitment of qualified individuals to be a VR Counselor is also a significant challenge. Indiana continues to have only one university offering a graduate program in Rehabilitation Counseling, which graduates 5-10 students annually. Several VR field offices are currently experiencing a low response rate to posted vacancies, and are having to repost positions multiple times in order to attract qualified candidates. Additionally, the unemployment rate in Indiana is extremely low at 3.6% as of January, 2018, and it has become more challenging for BRS, like many employers, to attract qualified candidates. If resources became available to increase the number of staff, the availability of qualified candidates for those positions, and ability to attract those candidates to state government, is a significant concern. Contracted staff have been used to provide support in offices, however there are limitations on the tasks that contracted staff can perform to adhere to non-delegable functions outlined in the federal regulations. Several other strategies have been implemented to address staffing capacity challenges, which will be further discussed below.

Obtaining additional VR Counselor and other field staff positions is needed to help address this challenge; however, it is important to understand that this provides only a partial solution. BRS must also address issues related to low retention rates of VR Counselors and significant recruitment challenges. Furthermore, BRS must take into account the lengthy learning curve for new hires. Due to the broad scope of knowledge and skills required for the VR Counselor role, and dependent on the specific background and experience of the staff member, it takes newly hired VR Counselors anywhere from 6-18 months to learn all aspects of the job. New VR Counselor training in a mobile environment adds further challenge as staff are expected to work very independently and have reduced access to co-workers, compared to the office-based approach that existed prior to 2009. Newly hired staff typically work under very close supervision and do not independently manage their caseloads or take a full schedule of new applications for 6-12 months after their hire date.

Challenges with staffing capacity in BRS have increased over the past two to three years. During this time, BRS has been diligent in implementing numerous strategies to work toward increasing capacity and improving service provision. Several of those strategies are outlined below:

o BRS hired additional support staff to assist with billing, follow up on medical records, data entry into the VR Case Management system, and other administrative and case management related tasks that were often falling on the VR Counselors in prior years. o Modifying VR Counselor qualifications in light of the modified CSPD criteria under WIOA. BRS has historically struggled with obtaining and retaining staff with a Master’s degree in Rehabilitation or related area. By expanding VR Counselor qualifications to include individuals with a Bachelor’s degree in Rehabilitation or a related area, plus one year of relevant experience, BRS was able to reach an increased talent pool in 2017, and hired several qualified candidates. Unfortunately, candidates have decreased again over the past few months. BRS has also evaluated whether this modification in hiring criteria has any impact on staff retention, and has seen an improvement in retention over the past year. o VR shifted 7 VR Counselor staff to a ‘Working Lead’ role to help mentor newly hired VR Counselors in field offices that experience a high percent of new staff. These Working Leads have been very effective; however BRS has recognized that several additional Working Lead positions are necessary to truly meet the needs. o After piloting a strategy that shifted VR Counselor roles into designated intake specialists and general counselors, BRS rolled this strategy out in all VR offices in July, 2017. Intake counselors are responsible for all new consumer applications and eligibility and severity determinations. This strategy has assisted with consistency in severity determinations and has also enhanced skills for these designated staff. BRS will continue to evaluate this approach to determine the effectiveness of having designated intake counselors. o BRS created a Program Initiatives Director who consults with staff regarding Small Business Enterprise, Home Modifications, Farm Modifications, and Vehicle Modifications. This individual serves as a subject matter expert for the VR Counselors when they have cases that involve these very difficult specialty services. These cases are often very time consuming for VR Counselors, and BRS has been able to offset some of that time with the addition of this new staff position. o BRS continuously reviews field office coverage areas on an ongoing basis, and shifts counties and staff as appropriate to level caseload sizes across offices to the extent possible. o BRS has continued to implement several, small improvements to the VR Case Management system to gain efficiencies where possible, and is working toward implementation of the AWARE system in early 2019. o BRS is working to implement an electronic claims payment system to streamline billing processes and anticipates this system to ‘go-live’ in 2018. While much improvement has been realized through efforts to improve staff capacity, including decreased retention and improved retention seen over the past several months, overall challenges with staff capacity remain. With the addition of new federal requirements under WIOA, BRS is forecasting an annual budget deficit starting with federal fiscal year 2018. While the VR Federal grant provides sufficient resources to Indiana, BRS is unable to draw all federal funds due to insufficient non-federal match dollars. BRS does not have sufficient funds to serve all eligible individuals, increase staffing and comply with all requirements under WIOA, including earmarking 15% of federal funds for pre-employment transition services, provision of career counseling and information and referral services to over 4,000 individuals employed at sub-minimum wage, and participating in infrastructure funding agreements to support the operation of One Stop locations throughout the state. BRS has identified and implemented several cost savings initiatives over the past few years, however even with the initiatives outlined below, a budget gap of approximately $5 million is anticipated, starting in FFY18. Examples of cost savings efforts include the following: • BRS has been supporting an antiquated case management system that has been in need of replacement for the past several years. Though there is an initial added cost to implement a new system, there is a significant cost savings of at least $500,000 per year that VR will begin to recognize in 2019, as the long term support of the new system is significantly less costly than the current system. BRS also expects to gain efficiency with staff time which will allow VR Counselors to better serve consumers, and allow BRS to recognize additional cost savings. Furthermore, more of the required federal reporting will be automated in the new system, freeing up additional resources. • Although training is incredibly important, BRS has prioritized trainings and reduced training costs beginning in FFY17. The majority of training is conducted internally and focuses on services to individuals with the most significant disabilities, which is the primary population that will be served under the Order of Selection. Over the past several years, BRS has increased use of webinars and ‘train-the-trainer’ style events to reduce costs of training. • BRS has reduced or eliminated several contractual agreements, resulting in anticipated savings of approximately $500,000 annually beginning in FFY18. • BRS continues to review service rates to determine if there are additional savings to realize, however BRS has re-negotiated service rates for many different types of services over the past several years, and therefore further opportunities for savings are likely minimal. As a result of cost containment efforts, BRS continues to recognize a reduced spend on client services. These previous efforts included the purchase of hearing aids and devices at manufacturer rates, paying for medical services and devices at Indiana Medicaid rates, purchasing interpreter services through a single coordinating unit to reduce spend on travel, and implementation of a calculator to ensure consistency in maximizing other resources for post-secondary costs prior to utilizing VR dollars. • BRS is investigating the potential impact of implementing financial participation policies for consumers, in line with federal requirements. • BRS is exploring the use of Third Party Cooperative Arrangements with state and local public agencies and Inter-agency cash transfer agreements with other state agencies, for the provision of pre-employment transition services. BRS did not project any reduction in client services spend as a result of implementing the order of selection during, at minimum, one full year into the order of selection process. BRS has reviewed client services expenditures each month to identify any modifications in spend pattern. As of February, 2018, seven months after implementation of order of selection, BRS has not realized any reduction in client services spending. In fact, spend on some service categories has increased, including a 7% increase in spend on employment services compared to expenditures during the same timeframe in the prior year. With the ongoing staffing capacity challenges, as well as projected budget shortfall beginning in FFY18, BRS must continue to operate under an order of selection.