Appendix I

Comments From the Department of
Education and GAO's Response

Officials of the Rehabilitation Services Administration (RSA) provided oral comments on our findings, conclusions, and recommendations. Beyond the points noted, they generally found no errors of fact or analysis and did not take issue with the recommendations.

Concerning chapter 2, RSA officials noted that other data sources, such as the Current Population Survey (CPS), suggest that prevalence of disability is much lower, perhaps 10 to 11 million, in contrast to the 14 to 18 million figure from the surveys we cite in chapter 2. We pointed out the warnings issued by the Bureau of the Census against using CPS to estimate prevalence, and we have added a note in the text explaining why we did not use CPS figures. In any case, whatever the population estimate turns out to be, it is clear that only a small fraction is now served and that an increased proportion of persons with disabilities will be eligible under the new law.

With regard to chapter 4, RSA officials said they were aware of the racial and ethnic group disparities in the amounts of purchased services that we found and were already conducting analyses to understand these disparities better.

Concerning chapter 5, RSA officials stated that some improvement in RSA's outcome measures may be expected in the next several years. They noted that section 127 of the Rehabilitation Act Amendments of 1992 requires the commissioner to establish and publish, by September 30, 1994, evaluation standards and performance indicators (including outcomes) for the program. They believed that such improvements as following clients for a longer period after closure and learning more about their post-program jobs, will be considered in developing these standards.

In addition, RSA officials stated that a comparison in our draft report
between wages of VR clients and wages in the general population was
inappropriate. In order to avoid misunderstanding, we removed that
specific analysis from the final text; however, the issue of
benchmarks—that is, what are reasonable expectations, in economic
terms, for rehabilitants-will persist. RSA officials also said they do not
routinely contrast dropouts and non-rehabilitants, as we do in this report.
They believe dropouts get substantial non-purchased services (in
diagnosis, and evaluation and counseling). The non-rehabilitated are,
however, a large group of clients who spent considerable amounts of time
in VR and were accorded considerable amounts of purchased services. We
therefore continue to believe this group should be a focus of study and

Comments From the Department of
Education and GAO's Response

evaluation so that more may be learned about how resources could be used more effectively.

Concerning the possibilities of additional linkages of RSA and SSA data, the RSA officials said there had been progress made. As of June 1993, a memorandum of understanding between the Departments of Education and Health and Human Services existed in draft form.

Concerning our several recommendations for analyses to be conducted by the yet-to-be-established National Commission on Rehabilitation Services, the officials pointed out that it would be hard for RSA to provide much support for the commission given the limited resources of the agency. We, however, made no change in our recommendation since we believe the opportunity the commission provides for sustained review of the VR program's services and results is important in light of changing eligibility criteria and the implementation of the Americans With Disabilities Act.

Appendix III

Racial Differences on Variables in 1988 Case

Service Reports

As discussed in chapter 4, we found differences in the amount spent for services for people in different racial groups; however, we could not explain these differences. One possible explanation is discrimination in decisions, but data were not available either to support or rebut such a conclusion. A number of other explanations are possible, and this appendix shows data pertinent to two, drawn from the RSA 1988 Case Service Reports.

First, we considered that the different racial groups of VR clients may enter
the VR system with different disabilities or with other background
differences. Spending differences thus could reflect different needs
associated with the preexisting differences. Table III.1 shows whether
1988 clients of different races differ on a number of individual
characteristics, such as disability type and severity, age, and education.1
There are some differences, but they are not large.

'RSA coded the race of the client as (1) white, (2) black, (3) American Indian or Alaskan native, or
(4) Asian American or Pacific islander. RSA also recorded whether the client was of Hispanic origin.
We combined these variables to create a new race/ethnicity variable, with the following categories: (1)
white, not of Hispanic origin; (2) white, of Hispanic origin; (3) black, not of Hispanic origin;
(4) American Indian or Alaskan Native, not of Hispanic origin; and (5) Asian American or Pacific
Islander, not of Hispanic origin.