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Beyond the Signature

NCSAB CONFERENCE WORKSHOP

Understanding the RSA-17 Story and Turning It into Action

Carol Pankow

Cynthia Speight

Casey Stone-Romero

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Disclaimer

The contents of this presentation were developed under grant H264L250001 from the U.S. Department of Education (Department). The Department does not mandate or prescribe practices, models, or other activities described or discussed in this document. The contents of this presentation may contain examples of, adaptations of, and links to resources created and maintained by another public or private organization. The Department does not control or guarantee the accuracy, relevance, timeliness, or completeness of this outside information. The content of this presentation does not necessarily represent the policy of the Department. This publication is not intended to represent the views or policy of or be an endorsement of any views expressed, or materials provided by any Federal agency (EDGAR 75.620).

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Opening Mystery

What do these everyday actions have in common?

COUNSELOR

A service ends, but the authorization stays open.

PROVIDER

A completed service is invoiced three months late.

PRE-ETS STAFF

Staff time is charged to the wrong activity code.

CONTRACT TEAM

The unspent contract ceiling remains on the books.

FISCAL

A correction moves costs to a different award.

Turn to one person: What could these actions change on the RSA-17?

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What the RSA-17 is and Why It Matters

What It Is

A cumulative financial report for each VR award. It reports Federal and non-Federal expenditures, cash, obligations, program income, and selected program costs.
Filed at Q2 and Q4, with Q6 and Q8 when the award remains open during carryover.
Regular reports are due 30 days after the reporting period ends. The final report is due 120 days after the period of performance ends.

What It Can Affect

Pre-ETS reservation
Match and carryover
Maintenance of effort
Cash and program income
Funds remaining or lapsing
Administrative and Services to Groups reporting

The certifier attests that the report is true, complete, and accurate.

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This is Not a Paper Exercise

Real Consequences

RSA uses it for ongoing monitoring—not just filing.
Agency data inform questions RSA must answer, including information reported to Congress.
The report supports decisions involving Pre-ETS, match, MOE, carryover, and funds at risk.

Plan for Turnover

Preparers, fiscal staff, and directors change roles or leave.
With six months between reports, cross-train a backup and maintain a written, usable procedure.
Securely share prior reports, workpapers, reconciliations, remarks, deadlines, and access instructions.

The RSA-17 is the agency’s official financial story, and the agency must be ready to produce it.

TIME 0:10–0:14 | LEAD: Carol

Set the stage: “The RSA-17 is not a paper exercise. It is one of the ways RSA monitors the award between formal reviews. RSA uses the information agencies submit when responding to questions, describing national activity, and reporting information to Congress.”

Connect the report to real consequences. The numbers support oversight and decisions involving the Pre-ETS reserve, match, maintenance of effort, carryover, cash, funds at risk of lapsing, and how administrative and Services to Groups costs are reported. Small errors and unexplained changes weaken confidence in the agency’s whole financial story.

Then name the continuity risk. Preparers, fiscal staff, and directors change roles or leave. With six months between reporting cycles, knowledge can disappear before the next report is due. The agency needs a trained backup, a written procedure another person can actually follow, shared supporting records, a deadline calendar, and clearly assigned review and certification responsibilities.

Practical leadership test: if the primary preparer were unavailable tomorrow, could the backup locate the prior report and workpapers, obtain the right system access, reproduce the reconciliations, explain unusual entries, and meet the deadline?

Accessibility: Read both headings and each paragraph aloud.

[Sources]

RSA, Instructions for the Vocational Rehabilitation Financial Report (RSA-17), DCL-26-03.

VRTAC-QM Director Checklist for Reviewing the RSA-17 Report.

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Why Everyone Should Care

Staff actions create the numbers. The RSA-17 shows how the agency manages its grant.

PRE-ETS TIME AND EXPENSE CODING

LINE 15

Helps show whether the agency met the 15% reserve.

AUTHORIZATIONS AND INVOICES

LINES 14, 18, 20, 29

Shows spending, valid obligations, and carryover.

MATCH AND ADMINISTRATIVE CODING

LINES 28 AND 37

Supports match, MOE, and administrative reporting.

SERVICES TO GROUPS

LINE 39

Shows whether blind-agency group services are in the correct category.

CASH AND PROGRAM INCOME

LINES 13, 21-27

Shows cash management and the use of program income.

You may never complete the form, but your work creates the numbers.

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What Can Your Agency Learn From It?

SERVICE PACE

Are services and expenditures moving at the pace the agency expected?

OPEN WORK

Do Unliquidated Obligations (ULOs) point to active services, late invoices, stale authorizations, or unsupported commitments?

PROGRAM DELIVERY

Do Pre-ETS, contracts, staffing, and provider activity match the operating plan?

AVAILABLE RESOURCES

What remains available, and what could be lost, returned, or carried over?

DATA QUALITY

Do fiscal and program systems describe the same activity and timing?

NEXT ACTION

Who needs to confirm, correct follow up, or change course?

The number is a signal. Operational evidence explains it.

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Two Rules Prevent Many Reporting Mistake

CUMULATIVE

Each report tells the story from the beginning of that award through the reporting-period end date. Amounts generally rise or remain the same; decreases require an explanation.

AWARD-SPECIFIC

Each report belongs to one Federal award and its period of performance. Obligations, liquidations, expenditures, match, and adjustments must be assigned to the correct award within the appropriate timeframe.

Before discussing any number: Which award? Which reporting period? Final or not final?

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How the RSA-17 Numbers Relate

MUST RECONCILE

Federal Expenditures

Valid Federal ULOs

Unobligated Balance

CASH

Receipts minus disbursements equals cash on hand.

CUMULATIVE

Compare with the prior report. Explain unexpected decreases.

SUBSETS

Line 15 is included in Line 14. Lines 39a-39i make up Line 39.

PULL-OUTS

Lines 37 and 39 may combine multiple funding sources.

Before comparing lines, ask: total, subset, or selected pull-out?

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Five Questions Organize the Entire Review

1. Is there enough time?

Use the Federal due date to set earlier internal deadlines for preparation, review, corrections, and certification.

2. Does it reconcile?

Does the RSA-17 agree with the GAN, prior report, drawdown data, accounting records, case system, contracts, and supporting workbook?

3. Does it make sense?

Do the amounts and changes fit what leadership knows about services, staffing, contracts, and operations?

4. What is at risk?

What could be affected if the reported position is wrong? Consider cash, match, carryover, Pre-ETS, program income, and the period of performance.

5. What happens next?

Correct material issues before certifications and assign the follow-up action.

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Shared Ownership

Who creates the numbers-and who can explain them?

PROVIDERS

Service dates • Invoices • Documentation

COUNSELORS

IPE Services • Authorizations • Closures

PROGRAM STAFF

Pre-ETS • Group Services • Staffing

FISCAL / CONTRACTS

Coding • Match • ULOs • Adjustments

LEADERS / DIRECTORS

Questions • Corrections • Certification

People change jobs and get promoted. Understanding the chain makes the next role safer and the current report better.

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If the Report Never Comes to You (1)

1

2

3

4

5

You can review it even after RSA posts it.

OPEN

Find the correct VR award and reporting period on RSA’s public award page.

COMPARE

Place the current report beside the prior cumulative report for the same award

SCAN

Look for missing activity, unexplained decreases, odd zeroes, misplaced amounts, and remarks.

CONNECT

Compare the report with what you know about services, staffing, contracts, Pre-ETS, and invoices.

ASK

Bring specific questions and request the supporting detail. A signal is not proof of the cause.

People change jobs and get promoted. Understanding the chain makes the next role safer and the current report better.

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A seven-minute scan of a posted RSA-17

When You Were Not Part of Preparation

7

5

3

1

6

4

2

Identity

Correct award, quarter, reporting end date, and final status?

Prior Report

Do cumulative amounts rise as expected?

Are decreases explained?

Known Activity

Do Pre-ETS, match, program income, and service activity appear plausible?

Line 20

Blank? Or $0 while the agency says Federal funds carried over?

Relationships

Do award, expenditures, valid ULOs, and unobligated balance make sense together?

Placement

Could an amount be on the wrong line, award, or reporting period?

Remarks

Do the remarks explain material changes and unusual conditions?

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Director Review

What to Have in Front of You

REPORT MATERIALS

Current RSA-17 draft with supporting workbook
Previous cumulative RSA-17 and agency tracker
Most recent GAN
Current RSA-17 instructions

VERIFICATION

Calculator
G5 cash and drawdown report
Source reconciliations for reported amounts
Report preparer available for questions

The RSA-17 should arrive with the support behind every line.

TIME 0:34–0:37 | LEAD: Carol

Use the checklist as a practical setup, not as another compliance form. Before the review, assemble the current RSA-17 draft with the supporting workbook or line-level source detail, the previous cumulative report, the agency's RSA-17 tracker, the most recent GAN, the current RSA-17 instructions, a calculator, the G5 cash and drawdown report, and the reconciliations supporting the reported amounts.

Review the report with the person responsible for overall preparation so questions can be answered line by line. The report should not arrive as a stand-alone form for signature.

At the beginning of each year, the reporting team should also calendar due dates, confirm roles, verify that everyone has the current instructions, and maintain written preparation procedures. Retain the signed and submitted report for monitoring, audit, and oversight.

Accessibility: Read each item aloud.

[Sources]

VRTAC-QM, Director Checklist for Reviewing the RSA-17 Report.

RSA, Instructions for VR Financial Report, DCL-26-03.

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Posted Report Review

A quick scan can catch four kinds of concern

OMISSION

Activity you know occurred missing. Example: no Pre-ETS or non-Federal share appears during an active period.

TRANSCRIPTION

The amount maybe real but appears on the wrong line, report, award, or reporting period.

MATHEMATICAL

Totals, cumulative changes, or related lines do not reconcile or produce an unexplained result.

STRUCTURAL

The data conflict with reporting instructions, timing rules, valid obligations, match, or reservation requirements.

State what you observed. Ask for the explanation and support.

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If the Report Never Comes to You (2)

You can review it even after RSA posts it.

Program Income

Disburse available program income before requesting federal cash.

Worksheet Math

Check formulas, ranges, and totals, even when MIS fields calculate automatically.

Award Limit

Federal expenditures plus unliquidated obligations cannot exceed the adjusted award.

RSA Instructions

Use the applicable DCL and line instructions. Some amounts are subsets of totals.

Zeroes Worth Checking

SRC 41a, IL 41b, infrastructure 40: were reportable expenditures really zero?

Remarks

Explain unusual amounts, adjustments, or unexpected changes.

Due Date

Confirm actual submissions by the deadline. Saving a draft does not submit it.

Presenter guidance: Ask why a number looks unusual or an expected cost is zero. A zero may be correct, but confirm it against accounting records and applicable agreements. Verify worksheet formulas and the submitted report. Federal award limits refer to grant funds, with program income reported separately. Confirm current award adjustments, including reallotment or reductions.

Source for program income: 34 CFR 361.63(c), https://www.ecfr.gov/current/title-34/part-361/section-361.63

Source for infrastructure zero review: RSA FFY 2022 Oregon General monitoring report, https://rsa.ed.gov/sites/default/files/publications/fy2022-or-g.pdf

Reporting tips and line references supplied by Carol Pankow for the RSA-17 session. Confirm the 41b label against the current applicable DCL/form before presenting.

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Director’s Final Quality Check

Confirm the easy facts: award, period, accounting basis, final status, cognizant agency, and signer
Compare with the prior cumulative report. Decreases need support
Check blanks, zeros, transcription, math, and coding. Line 20 cannot be zero in Q4 if you are expecting to carryover funds
Recalculate key relationships. Subset lines cannot exceed totals
Reconcile ULOs, match/MOE, Pre-ETS, program income, cash, Lines 37 and 39
Use remarks to explain adjustments, reclassifications, decreases, and unusual balances

When the easy facts are wrong, confidence in the harder numbers drops.

plan for break right here

TIME 0:35–0:38 | LEAD: Carol

Frame this as the director’s last quality-control pass before certification. Small errors matter. If the report gets an easy fact wrong, reviewers may reasonably question whether the harder figures received a careful review.

Start with the basic fields: award number, reporting period, accounting basis, final-report status, Federal cognizant agency, certifying official, and contact information. The Federal cognizant agency is the agency that approves the indirect cost rate or cost allocation plan. A zero or placeholder is not the agency name.

Check blanks and zeros deliberately. They are not interchangeable. Look for transcription errors, omitted fields, coding errors, unsupported cumulative decreases, and formulas that do not reconcile. Line 20 cannot be blank. Recalculate key relationships and confirm that a subset line does not exceed its related total.

Review the report against the prior cumulative report, supporting workbook, grant award notice, and current instructions. Reconcile ULOs, match and MOE, Pre-ETS, program income, cash, administrative costs on Line 37, and Services to Groups on Line 39.

Use the remarks field to explain anything unusual that the numbers cannot explain by themselves. For a correction, adjustment, reclassification, cumulative decrease, cash anomaly, unusual balance, or movement between categories, state what changed, why it changed, the amount or period affected, and whether it is a correction or reclassification. Avoid vague language such as “adjustment made.” Remarks should clarify an accurate report, not paper over an incorrect number. Correct the number first.

Accessibility: Read each check aloud and identify fields by their full names and line numbers.

[Sources]

VRTAC-QM, Director Checklist for Reviewing the RSA-17 Report.

RSA, Instructions for VR Financial Report, DCL-26-03.

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Greatest Blind Agency of Nirvana

Workshop Case

Put the complete Q2 report beside the complete Q4 draft.

For both rounds:

1. ALIGN

Place Q2 on the left and Q4 on the right. Find the same line on both reports.

2. COMPARE

Mark amounts that decreased, appeared, disappeared, moved categories, or stay unexpectedly unchanged.

3. QUESTION

For each change, decide whether it needs a correction, explanation, or supporting detail.

Round 1 compares the front page.
Round 2 compares the back pages.
Read each cumulative line from Q2 to Q4.

TIME 0:38–0:41 | LEAD: Carol + Casey We need to decide if we are going to certify

Every table is the review team for the Greatest Blind Agency of Nirvana. Give participants both complete reports and explain that both reports are cumulative. Round 1 covers the front page. Round 2 covers the back page.

Facilitator accessibility guidance: Provide the Q2 and Q4 case in an accessible digital format before the session, with large print or braille upon request. Identify each comparison by line number and full label. Read the Q2 value, Q4 value, and discussion question aloud. Do not rely on color, pointing, highlighting, or page position.

Use mixed tables and let participants choose how they contribute. Use microphones for audience comments, ask speakers to identify themselves, repeat comments when necessary, announce time remaining verbally, and allow time for screen-reader navigation. Avoid sticky notes, moving around the room, or visual-only voting.

[Sources]

Fictitious Q2 and Q4 RSA-17 examples supplied for this session.

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Round 1: Q2 Compared with Q4 Fields 1-9

Field	RSA-17 item	Q2 Report	Q4 Draft
1	Federal grant award number	H126A260001	H126A260001
2	Federal fiscal year	2026	2026
3	Grant period	10/1/25–9/30/26	10/1/25–9/30/26
4	Recipient organization	Nirvana State Agency	Nirvana State Agency
5	Basis of accounting	Accrual	Cash
6	Reporting period end date	03/31/26	09/30/26
7	Final report	No	No
8	UEI number	Blank	Blank
9	Recipient account or identifying number	Blank	Blank

Compare every field, including items that stayed blank or changed for an expected reason.

TIME 0:41–0:45 | LEAD: Carol and Casey

Participants compare Fields 1 through 9 without receiving the answer key. Ask them to identify expected changes, inconsistent entries, and information that remains blank.

Facilitator answer: Fields 1 through 4 remain consistent. Field 5 changes from Accrual to Cash and is the planted inaccuracy. Field 6 changes as expected from the Q2 reporting end date to the Q4 reporting end date. Field 7 remains No and may be appropriate if the award remains open during carryover. Fields 8 and 9 remain blank and should be checked against the grant record and agency procedures.

Accessibility: Identify every field by number and full label. Read the Q2 value and Q4 value in that order. Allow time for screen-reader navigation.

[Sources]

Fictitious Q2 and Q4 RSA-17 examples supplied for this session.

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Round 1: Q2 Compared with Q4 Front-page Federal Funds

Compare every field, including items that stayed blank or changed for an expected reason.

Line	Selected RSA-17 item	Q2 Report	Q4 Draft
10	Total Federal funds awarded	$6,000,000	$6,000,000
11	Federal cash receipts	$2,250,000	$3,500,000
12	Federal cash disbursements	$2,230,000	$3,460,000
13	Federal cash on hand	$20,000	$40,000
14	Federal share of expenditures	$2,300,000	$3,650,000
15	Federal funds expended for Pre-ETS	$310,000	$540,000
18	Federal share of unliquidated obligations	1,100,000	$1,750,000
19	Total Federal share	$3,400,000	$5,400,000
20	Unobligated balance of Federal funds	$2,600,000	$600,000

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Round 1: Program Income and Non-Federal Share

Line	Selected RSA-17 item	Q2 Report	Q4 Draft
21	Total Federal program income received	$180,000	$300,000
22	Program income expended under VR	$60,000	$80,000
27	Unexpended program income	$120,000	$220,000
28	Total non-Federal share of expenditures	$1,150,000	$1,100,000
29	Non-Federal share of unliquidated obligations	$160,000	$300,000

Read across each line from Q2 to Q4. A cumulative decrease requires an explanation and support.

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What changed from Q2 to Q4?

Q2 to Q4: Front-page Debrief

What grew?

Which balances increased enough to require an explanation?

What remained available?

What cash or program income question would you ask?

What decreased?

Which cumulative amount declined, and what support would you request?

Pre-ETS

What evidence shows the agency will meet the reserve by the end of the period of performance?

Match and Carryover

What must reconcile before the agency relies on carryover?

Your first question

What neutral, evidence-based question would you ask first?

TIME 0:53–0:58 | LEAD: Carol

Debrief the changes, not isolated Q4 amounts. Ask tables to state each finding as: “Q2 showed ___; Q4 shows ___; therefore I would ask ___.”

Complete front-page comparison: Field 5 changes from Accrual to Cash and is the planted inaccuracy. Field 6 changes from March 31 to September 30 as expected. Fields 8 and 9 remain blank. Cash receipts rise from $2,250,000 to $3,500,000; cash disbursements rise from $2,230,000 to $3,460,000; and cash on hand rises from $20,000 to $40,000. Federal expenditures rise from $2,300,000 to $3,650,000. Line 15 rises from $310,000 to $540,000, and Line 15a changes from blank to $540,000. Federal ULOs rise from $1,100,000 to $1,750,000. Total Federal share rises from $3,400,000 to $5,400,000. Line 20 falls from $2,600,000 to $600,000. Program income received rises from $180,000 to $300,000; program income expended rises from $60,000 to $80,000; and unexpended program income rises from $120,000 to $220,000. Line 28 decreases from $1,150,000 to $1,100,000. Non-Federal ULOs rise from $160,000 to $300,000.

For Pre-ETS, do not describe $540,000 as a shortfall merely because it does not equal 15 percent of the award at Q4. The agency must meet the reserve by the end of the period of performance. Pre-ETS expenditures do not have to track overall Federal expenditures at the same pace.

Accessibility: Read each Q2 value, Q4 value, and review question aloud.

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Line 39 Categories and Examples

Services to Groups

39a

CRP Establishment or Improvement

Public or non-profit CRPs, facilities, or construction

Telecommunications Systems

Telephone, video description, satellite, tactile-vibratory, and similar systems.

Non-visual Access to Information

Braille, audio, tactile and other media, including NFB-NEWSLINE and library services.

Technical Assistance to Businesses

Training or consultation for businesses seeking to employ people with disabilities.

39b

39c

39d

39e

39f

39g

39h

39i

Business Enterprise Program

Management, supervision, equipment, repairs, and allowable initial stock or operating costs.

Transition Consultation and Technical Assistance

Assistance to SEAs and LEAs planning transition to postsecondary life and employment.

Transition Services for Groups

No Pre-ETS expenditures are reported here. Line 39g costs cannot be charged to the Pre-ETS reserve.

Assistive Technology Programs

Demonstration, loan, reuse, or financing programs. Individual IPE devices are reported elsewhere.

Advanced Training for Groups

Cohorts, college partnerships, or scholarships. Individual IPE training is reported elsewhere.

Review:

34 C.F.R. § 361.49 and agency policy before coding Line 39.

TIME 0:57–1:02 | LEAD: Carol

Use this slide before participants review the back page. Read all nine categories and the examples aloud. The short descriptions orient the activity; participants should use 34 C.F.R. § 361.49 and agency policy when deciding where an expenditure belongs.

Call out examples that matter to blind agencies. Line 39c can include NFB-NEWSLINE and library services that provide nonvisual access to information. Line 39e can include allowable BEP management and supervision, equipment purchases and repairs, and initial stocks or operating costs within the applicable limits.

Emphasize Line 39g. It covers general transition services that benefit groups, such as campus tours, employer visits, career fairs, mock interviews, and résumé activities. Pre-employment transition services are never reported on Line 39g, and Line 39g expenditures cannot be charged to the Pre-ETS reserve.

For Lines 39h and 39i, reinforce the difference between a program or activity that benefits a group and an individualized service tied to an IPE. Individual assistive technology devices and individualized training required for an employment goal are reported as individual VR services, not Services to Groups.

Accessibility: Read each line number, category, and example aloud.

[Sources]

34 C.F.R. § 361.49.

Services to Groups explanations supplied for this session.

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How does your agency use the nine categories?

39a

Blind-Agency Practice

39b

39c

39d

39e

39f

39g

39h

39i

CRP Establishment, Development, or Improvement

Telecommunications Systems

Non-Visual Access to Information

Technical Assistance to Business

BEP, including Randolph-Sheppard

Transition Consultation and Technical Assistance

Transition Services to Youth and Students

Assistive Technology Programs

Support for Advanced Training

Table Conversation

What group services do you fund now?
Which Line 39 category should capture each one?
Who knows it happened- and who codes it?
What support would prove the amount?
What may be missing, miscoded, or reported as an individual service?

Important: transition services to groups under §361.49(a)(7) are not Pre-ETS and cannot be charged to the Pre-ETS reserve.

Use the regulation and agency policy to connect the activity, documentation, coding, and Line 39 category.

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Round 2: Back Page - Carryover, Indirect and Administration

Review unchanged fields as carefully as changed fields. Ask what should have moved during the period.

Line	RSA-17 item	Q2 Report	Q4 Draft
32	Non-Federal ULOs liquidated in carryover	Blank	Blank
33	New non-Federal carryover-year expenditures	Blank	Blank
36	Federal cognizant agency	0	0
36a–b	Indirect type and rate	Fixed; 14.99%	Fixed; 14.99%
36c–d	Indirect period	10/1/25–9/30/26	10/1/25–9/30/26
36e	Indirect base	$2,383,095.00	$2,383,095.00
36f	Indirect amount charged	$357,225.94	$357,225.94
36g	Federal share of indirect costs	Blank	$357,225.94
37	Administrative expenditures	$1,811,652	$2,002,453

TIME 1:07–1:10 | LEAD: Carol and Casey

Participants compare the carryover, indirect-cost, and administrative fields. Do not reveal the answers until the debrief.

Facilitator answer: Lines 32 and 33, including their establishment and construction sublines, remain blank in both reports; confirm that no carryover-year activity applies. The Federal cognizant agency remains 0 and should be corrected. The type, rate, period, base, and amount charged remain unchanged. That may be accurate only if supported; the unchanged cumulative base and amount deserve a question. The Federal share of indirect costs changes from blank to $357,225.94. Administrative expenditures increase from $1,811,652 to $2,002,453.

If the agency uses a cost allocation plan rather than an indirect cost rate, follow the RSA-17 instructions for Line 36 rather than entering an indirect-rate amount.

Accessibility: Read each line and full label, followed by the Q2 and Q4 values.

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Round 2: Back Page – Every Services to Groups Category

Use 34 C.F.R. § 361.49 and agency policy to evaluate each category.

Line	Services to Groups Category	Q2 Report	Q4 Draft
39	Services to Groups total	$272,921	$517,184
39a	CRP establishment, development, or improvement	Blank	Blank
39b	Telecommunications systems	Blank	Blank
39c	Nonvisual access to information	Blank	$165,087
39d	Technical assistance to businesses	Blank	Blank
39e	Business Enterprise Program	$272,921	Blank
39f	Transition consultation and technical assistance	Blank	$352,097
39g	Transition services to youth and students	Blank	Blank
39h	Assistive technology programs	Blank	Blank
39i	Support for advanced training	Blank	Blank

TIME 1:10–1:14 | LEAD: Carol and Casey

Participants compare the Line 39 total and all nine categories. Ask them to identify activity that appeared, disappeared, stayed blank, or may have moved categories.

Facilitator answer: Line 39 increases from $272,921 to $517,184. Lines 39a, 39b, 39d, 39g, 39h, and 39i remain blank. Line 39c appears at $165,087; ask whether this represents NFB-NEWSLINE, library services, or another allowable nonvisual-access activity. Line 39e decreases from $272,921 to blank. Because the report is cumulative, request the correction or reclassification support. Line 39f appears at $352,097; confirm that the activity fits transition consultation and technical assistance and is not Pre-ETS or Line 39g. The Q4 category amounts total $517,184.

Accessibility: Read all nine category names and the Q2 and Q4 values. Do not rely on highlighting.

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Round 2: Back Page – Lines 40 – 41, Remarks and Submission

Remarks should explain material changes and unusual balances, not only one isolated item.

Line	RSA-17 item	Q2 Report	Q4 Draft
40	American Job Center infrastructure expenditures	Blank	Blank
41	Total Innovation and Expansion expenditures	Blank	Blank
41a	I&E supporting the SRC resource plan	Blank	Blank
41b	I&E supporting the SILC resource plan	Blank	Blank
Remarks	Explanation entered in the remarks section	0	$40,000 cash balance explained
47	Date report submitted	4/28/2026	10/29/2026

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What questions did Q2 to Q4 raise?

Q2 to Q4: Back-Page Debrief

Completeness

Cumulative

Reconciliation

Services to Groups

Administration

Remarks

Which fields are blank, zero, or incomplete?

Did any category decrease, disappear, or move?

What stayed unchanged when you expected movement?

What activity and documentation belong behind each Line 39 category?

What supporting detail would you request for Line 37?

Which Q2-to-Q4 changes require an explanation in the remarks?

Each table shares one back-page finding and the evidence it would request.

TIME 1:17–1:21 | LEAD: Carol

Collect one finding and one evidence request from selected tables. Separate a confirmed completion error from a change that may be legitimate but needs support.

Complete back-page comparison: Lines 32 and 33 and their sublines remain blank. The Federal cognizant agency remains 0. The indirect type, rate, period, base, and amount charged remain unchanged; the Federal share changes from blank to $357,225.94. Administrative expenditures rise from $1,811,652 to $2,002,453. Services to Groups rises from $272,921 to $517,184. Lines 39a, 39b, 39d, 39g, 39h, and 39i remain blank. Line 39c appears at $165,087. Line 39e decreases from $272,921 to blank. Line 39f appears at $352,097. Lines 40, 41, 41a, and 41b remain blank. Q4 remarks explain the cash balance but not the other material changes. The submission date changes from April 28 to October 29.

Accessibility: Repeat audience responses into the microphone and identify the relevant field by full name and line number.

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Round 3: Ask for the Missing Story

Choose the three pieces of information you want next.

Authorization aging and activity detail
Contract deliverables and invoice status
Staffing vacancies and service trends
Program income cash-management history
Match support and statewide coordination
Explanation and support for the cumulative adjustment

Be specific: What report, list, reconciliation, or person, do you need?

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Round 3: What Evidence is Needed?

What would you request before making decision?

AUTHORIZATIONS

Authorization aging and activity detail

INVOICES

Invoices aging and completed services not yet billed

PROGRAM INCOME

Program income ledger, receipts, expenditures, and cash history

ADJUSTMENT

Adjustment log, allocation support, and draft remarks

CONTRACTS

Contract balances, deliverables, and invoice status. Service and admin contracts- do you have a way to know what is obligated?

PRE-ETS

Reserve calculation, Line 15 detail, staff time and coding support

MATCH AND MOE

Non-Federal expenditure and ULO support by source

LINES 37 and 39

Administrative and Services to Groups detail and reconciliation

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From Report to Action: Translate the Number into an Operational Request

Signal	Leadership Question	Owner	Action
Aging ULOs	Which obligations are still valid?	Supervisors + fiscal	Review open items; confirm, correct, or cancel.
Slow Pre-ETS pace	What activity has occurred or is delayed?	Program + contracts	Reconcile services, invoices, forecast, and plan.
Unspent program income	Were drawdowns sequenced correctly?	Fiscal	Reconcile cash; stop and correct as needed.
Cumulative decrease	What changed, and is it supported?	Fiscal + cost allocation	Validate adjustment; explain in remarks.
Match uncertainty	What Federal position is supported?	Fiscal + leadership	Verify sources, amounts, timing, and carryover effect.

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From a Public Signal to a Better Process

Bring a question that is specific, neutral, and answerable.

“I noticed Line 28 decreased by $50,000 from the prior cumulative report. What correction explains the change, what support was used, and should the remarks describe it?”

NOW

Resolve any accuracy or certification concern that remains open.

NEXT CYCLE

Request the report, prior report, and support before submission.

ONGOING

Create a quarterly program-fiscal review rhythm instead of waiting for Q4.

For separate general and blind agencies: identify statewide items and exchange information early.

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Round 4: Make the Certification Decision

A quick scan can catch four kinds of concern

A

CERITFY

The math works; address operations later.

B

CERTIFY + NOTE

Submit now with a follow-up list.

C

PAUSE

Resolve material items before certification.

D

RETURN

Send it back without a review discussion.

Choose one. Be ready to name the evidence that supports your decision.

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Case Debrief

Recommended Decision: Pause Before Certification

Reconcile program income and Federal cash activity
Validate the amount and aging of Federal and non-Federal ULOs
Confirm the non-Federal share supports the Federal position and carryover plan
Document the reason for the cumulative decrease and use the remarks section
Coordinate with the general agency on statewide information needed for Pre-ETS and fiscal decisions

Then certify a report leadership understands- and launch the operational follow-up plan.

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Five Questions to Ask Every Time

Before You Certify

1

Is there enough time for a real internal review?

2

3

4

5

Is this the correct award, period, and report type?

Does it reconcile to the records and prior report?

What changed, and what is at risk?

What must happen before and after certification?

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One Commitment

Before your next RSA-17 is certified:

What one change will you make to the review conversation?

Write it on your checklist. Share it with one person at your table.

Read the signals. Ask the questions. Choose the action.

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Thank You!

NCSAB CONFERENCE WORKSHOP

Speakers:

Carol Pankow

Cynthia Speight

Casey Stone-Romero