In principle, VOR agrees that each State Protection and Advocacy System (P&A) should be subject to accountability, including but not limited to annual performance reports if independently audited. We remain very concerned that nearly all measures of accountability for P&As are self-reported, including annual program performance reports. Although subject to reauthorization, Congress has not reviewed DD Act program outcomes and considered reauthorization since 2000.
It is alarming that these self-developed annual program performance reports will be used by ADD to “respond to administration and congressional requests for specific information about program activities” and “to submit a Centennial Report to Congress.” These are self-reporting activities that are of little objective value in measuring “Performance and Results.”
At minimum, VOR suggests that P&A program performance reports be subject to an independent audit to ensure accuracy. Additionally, organizations representing residents of licensed intermediate care facilities for persons with mental retardation (ICFs/MR) and their families, and others, should be allowed to review these reports prior to publication and be provided an opportunity to respond, with dissenting perspectives included in the reports submitted to the Administration and Congress.
As we have commented in past submissions, performance reports prepared by the very staff who are directly accountable for grant outcomes have no practical utility. Such reports will provide little insight into the actual effectiveness of these programs for their intended beneficiaries.
VOR Submits Federal Comment Urging Independent Oversight of P&As
June 28, 2012
Summary of Comment
In principle, VOR agrees that each State Protection and Advocacy System (P&A) should be subject to accountability, including but not limited to annual performance reports if independently audited. We remain very concerned that nearly all measures of accountability for P&As are self-reported, including annual program performance reports. Although subject to reauthorization, Congress has not reviewed DD Act program outcomes and considered reauthorization since 2000.
It is alarming that these self-developed annual program performance reports will be used by ADD to “respond to administration and congressional requests for specific information about program activities” and “to submit a Centennial Report to Congress.” These are self-reporting activities that are of little objective value in measuring “Performance and Results.”
At minimum, VOR suggests that P&A program performance reports be subject to an independent audit to ensure accuracy. Additionally, organizations representing residents of licensed intermediate care facilities for persons with mental retardation (ICFs/MR) and their families, and others, should be allowed to review these reports prior to publication and be provided an opportunity to respond, with dissenting perspectives included in the reports submitted to the Administration and Congress.
As we have commented in past submissions, performance reports prepared by the very staff who are directly accountable for grant outcomes have no practical utility. Such reports will provide little insight into the actual effectiveness of these programs for their intended beneficiaries.
Read More.
Read related comment regarding state developmental disabilities council performance evaluations.
Read VOR's Urgent Call for Reform and Reauthorization of the Developmental Disabilities Assistance and Bill of Rights Act.