Management of the Pre-Employment Transition Services Reservation of Funds
In accordance with Section 110(d)(1) of the Rehabilitation Act, “the State shall reserve not less than 15 percent of the allotted funds for the provision of pre-employment transition services.” These reserved funds, as outlined in 34 CFR § 361.48(a), can only be used for the “required, authorized, and pre-employment transition coordination activities” “for all students with disabilities, as defined in § 361.5(c)(51), in need of such services, without regard to the type of disability, from Federal funds reserved in accordance with § 361.65, and any funds made available from State, local, or private funding sources.”
Understanding and properly managing the pre-employment transition services (Pre-ETS) reservation of funds is essential because States must determine whether the funds reserved for the provision of pre-employment transition services are sufficient to meet the needs of all students with disabilities needing the “required” activities listed in section 113(b) of the Rehabilitation Act and 34 C.F.R. § 361.48(a)(2), as well as the coordination activities listed in section 113(d) of the Act and 34 C.F.R. § 361.48(a)(4), prior to using reserved funds for “authorized” activities listed in section 113(c) of the Act and 34 C.F.R. § 361.48(a)(3).
The following are some resources to help you plan for and manage the reservation of funds for Pre-ETS.
Resources
- Pre-ETS Calculator
- Pre-employment transition services set-aside determination guide
- Pre-Employment Transition Services GAN Attachment
- RSA FAQs Pre-ETS
- Strategies for Managing the Pre-Employment Transition Services 15 Percent Minimum Reserve Requirement
- Notice of Interpretation
Staff Time and Effort Reporting
For staff who work on multiple cost objectives, personnel costs must be allocated proportionally between all the different programs administered by the VR agency, and other programs within the designated State agency (DSA) even if outside the designated Staff unit (DSU) or included in the indirect cost rate or cost plan.
In the past, guidance referenced that personnel cost activities required certified personnel reports for individuals working 100 percent on one activity. Sometimes, agencies referred to these as PARS (personal activity reports). PARS are not specifically required, but time and effort record-keeping must meet the standards cited in regulation. However, 2 CFR 200.430 (i)(8) states that the Federal Government may require PARS if the standards described in this section are not met. This citation is referenced below.
It is important to have a policy/procedure that outlines the agency’s practices for reporting time and effort. This policy/procedure should include internal controls to ensure the process is evaluated, and it should outline how and when training will be conducted with all employees to ensure the proper allocation of staff time.
