Independent Living Services

for Older Individuals Who are Blind Grant

Discussion Paper

Background

On November 16, 2015, the Texas Workforce Commission’s (TWC) three-member Commission approved the contracting of the Independent Living Services for Older Individuals Who Are Blind (IL-OIB) grant to the Texas Health and Human Services Commission (HHSC). This would allow HHSC to operate IL-OIB-funded services in conjunction with the other independent living services. This interagency contract would have allowed IL-OIB funds to be pooled with other independent living funds at HHSC to have a greater impact for consumers needing services.

Issue

In December 2015and January 2016, staff from TWC and the Texas Department of Assistive and Rehabilitative Services (DARS) provided the Rehabilitation Services Administration (RSA) with an overview of this IL-OIB model. RSA posed several questions to TWC and DARS, which were addressed on a conference call and through an e-mail. Subsequent to those conversations, RSA had no further communications with TWC or DARS about theIL-OIB service-delivery modeluntil July 25, 2016. On July 25, DARS received an e-mail from RSA noting that TWC was not authorized to contract funds to HHSC, which would in turn subcontract with the Centers for Independent Living (CILs).

TWC and DARS implored RSA to reconsider this ruling. However, on August 2, 2016, DARS received an e-mail noting that RSA Commissioner Janet LeBreck had reviewed therequest, but determined that RSA’s position had not changed. Based on this RSA determination, TWC must now develop an alternate service-delivery strategy for the delivery of IL-OIB-funded services.

Recommendation

The federal IL-OIB grant totals approximately $2.1 million annually. While TWC is authorized to subcontract directly with entities, such as CILs, to administer IL-OIB, the administrative costs associated with subcontracting relatively small amounts of funds is not feasible. HHSC has subcontracted with 16 CILs. Based on the $2.1million grant, if evenly divided and if TWC retained no funds for administration and oversight, each CIL would receive approximately $131,000. In practice, however, TWC would be required to retain a portion of the funds at the state level for administration and oversight, andwould need to ensure that TWChad sufficient staff within subrecipient monitoring to oversee the contracts.

Based on these factors, staff recommends that TWC directly operate IL-OIB-funded services. TWC will work with CILs to coordinate the delivery of independent living services.

TWC plans to hire dedicated IL coordinators to provide services. As we move toward this model, we must ensure that we have IL-OIB-funded services available; therefore, in the shortterm, TWC will work with the 12 Divisionfor Blind Services (DBS) regional offices to identify existing vocational rehabilitationcounselors (VRCs) who can assume an IL-OIB caseload. The VRCs will use the DBS vocational rehabilitation teachers to provide direct consumer services to the older blind population in need of independent living services.

Staff will work on the development of a state budget to support the maximum number of IL coordinators, and will examine how to best deploy these staff members across the state.

DP-IL Older Blind (8 17 16)

August 23, 2016 Commission Meeting Page1