The Massachusetts Commission for the Blind Did Not Ensure That the Information in Its Accessible Web-Based Activity and Reporting Environment Database Was Complete.

MCB’s electronic case-management system did not have information about the race in nearly 10 percent of open participant records.

Overview

For 103 of 1,048 open case-service records in the Massachusetts Commission for the Blind’s (MCB’s) Accessible Web-Based Activity and Reporting Environment (AWARE) database as of the end of our audit period, the client’s race was not indicated. The information in this database, including each person’s race, is used by MCB to produce its Case Service Report. The Case Service Report is used by the Rehabilitation Services Administration (RSA), an agency within the US Department of Education’s Office of Special Education and Rehabilitative Services, to describe vocational rehabilitation (VR) program performance in the Report on Federal Activities under the Rehabilitation Act of 1973, as Amended that it provides to Congress and the President. According to RSA, states that do not meet a minimum minority service ratio of 0.80,⁵ or that provide VR services to fewer than 100 consumers from minority backgrounds with disabilities, are required to develop procedures to improve equal access. Inaccurate race information can affect the accuracy of MCB’s calculated minority service rate ratio and affect its ability to administer this program properly.

Authoritative Guidance

According to Section 1 of the Reporting Manual for the Case Service Report (RSA-911) issued by RSA,

It is incumbent on VR agencies to establish policies and procedures that ensure the accurate collection, retention, and timely reporting of all data.

Section IV of the Reporting Manual for the Case Service Report states,

The data elements contained in this section are to be reported for each individual who has submitted an application to receive services under the VR program during the quarter. . . . Race information should be recorded for all individuals whose service records were opened in the quarter being reported.

Reasons for Noncompliance

The RSA system edit checks used by MCB are not designed to report an error when a person’s race is not indicated; therefore, these errors went undetected. Further, MCB does not have any policies and procedures that require its staff members to monitor and periodically assess the accuracy of the information in AWARE and to take measures to correct inaccurate or incomplete information.

Recommendations

1. MCB should enhance its case-management system to identify VR client case-service records that do not include race.
2. MCB should identify and correct all instances where race is not indicated on VR application records.

Auditee’s Response

The migration to the new Case Management System AWARE from the old legacy database caused discrepancies in data fields. Because of this finding, MCB’s internal data team has made a fix to ensure that blank race fields are not an option going forward and is correcting all instances where race is not indicated on VR application records.

Auditor’s Reply

Based on its response, MCB is taking measures to address our concerns in this area.

5.    According to the Rehabilitation Services Administration Report for Fiscal Years 2014–15, Report on Federal Activities under the Rehabilitation Act of 1973, as Amended, dated April 2018, the “minority service rate ratio is the ratio of the percentage of individuals from minority backgrounds exiting the [VR] program who received services to the percentage of nonminorities exiting the program who received services.”

Date published:	March 28, 2019