On the Right Track Tracking and Reporting Pre- Employment Transition Services CSAVR Fall Conference 2017
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On the Right TrackTracking and Reporting Pre-Employment Transition Services
CSAVR Fall Conference 2017
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Presenters
Workforce Innovation Technical Assistance Center (WINTAC)• Brenda Simmons, George Washington University (GWU)• Christine Johnson, George Washington University (GWU)• Rachel Anderson, National Disability Institute (NDI)
State of Maryland Division of Rehabilitation Services• John Stem, Program Manager, Rehabilitation Services Quality Assurance
State of Alaska Division of Vocational Rehabilitation• Jim Kreatschman, Youth Transition Coordinator
Side A – Pre-Employment Transition Services
Side B – Additional considerations for
students with disabilities, FAQs, etc.
Presentation Focus and Objectives
• Understand the requirements for ensuring accurate reporting in the 911 case service report and case management systems for students with disabilities
• Discuss the data reporting requirements for Pre-Employment Transition Services (Pre-ETS)
• Policy and procedures
• Internal controls
• Supporting documentation
• Discuss the requirements and recommendations for tracking outcomes of potentially eligible students receiving Pre-Employment Transition Services
• Review State examples and strategies for tracking and reportingPre-Employment Transition Services for both potentially eligible and eligible students with disabilities. 4
Terms Applicable to Pre-ETS and 911 Reporting
• Reportable Individual
• Participant
• Exit
• Pre-Employment Transition Services
• Education Setting
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Reportable Individual
A Reportable Individual is someone who:• Demonstrates intent to use program service;• Provides identifying information;• Is a student with a disability receiving only Pre-Employment
Transition Services (VR-only).
Reportable Individuals are reported, but do not count toward the performance measures
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Participant
For purposes of the VR program, a Participant is someone who:
• Meets the definition of a reportable individual;• Has applied and has been determined eligible for VR services;• Has an approved and signed IPE; and • Has begun to receive services under the IPE
Participants are counted in performance.
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Participants vs. Reportable Individuals Receiving Pre-Employment Transition Services
Students with disabilities receiving Pre-Employment Transition Services who also meet the definition of a Participant are subject to all of the 911 reporting requirements and may be included in the Common Performance Measures.
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Exit – VR Program Specific
Title IV VR has the only program-specific definition of Exit.A participant exits the program when the individual:
• Has achieved an employment outcome and the service record is closed;
• Has not achieved an employment outcome; or• Has been determined ineligible after receiving services (34
CFR 361.43).
Exit date is based on the date the service record is closed.
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Exit – Potentially Eligible Student
• When is the service record of a student with a disability who receives Pre-Employment Transition Services considered “closed”?• The service record is closed when the student is no longer receiving
such services as indicated in the Pre-Employment Transition Services data elements included in the RSA-911-16 Manual.
• Exit Data Elements (XVII)• Element #353: Date of Exit• Element #354: Type of Exit
• Code 8: Potentially eligible individual exited after receiving Pre-Employment Transition Services and has not applied for VR services.
Required 911 Data Elements for Pre-Employment Transition Services
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Student Status –Potentially Eligible and Eligible Clients
VR agencies need to collect the following information for reporting requirements associated with the 911 on Student Status.
Element #22: Student with a Disability (either at application or start of Pre-ETS)
• Code 1 – Individual is a student with a disability and has a section 504 accommodation.
• Code 2 – Individual is a student with a disability and is receiving transition services under an Individualized Education Program (IEP).
• Code 3 – Individual is a student with a disability who does not have a section 504 accommodation and is not receiving services under an IEP.
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Potentially Eligible 911 Required Data Elements
The data elements in the table below are the only ones required if an individual is receiving Pre-Employment Transition Services and has not applied for or has been determined eligible for VR services.
Data Element Name
III.A Unique Identifier
III.B Social Security Number (if available)
IV.B Date of Birth
IV.C.2 – IV.C.6 Race – Required if student is in elementary or secondary education
IV.C.7 Ethnicity – Required if student is in elementary or secondary education
IV.F Student with a Disability
X.A Start Date of Pre-Employment Transition Services
X.B – X.F Pre-Employment Transition Services
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Student with a Disability
A student with a disability is an individual who is in a secondary, post-secondary or other recognized education program; and
• Is not younger than the earliest age for the provision of transition services under section 614(d)(1)(A)(i)(VIII) of the Individuals with Disabilities Education Act (20 U.S.C. 1414(d)(1)(A)(i)(VIII)); or
• If the State involved elects to use a lower minimum age for receipt of Pre-Employment Transition Services under this Act, is not younger than that minimum age; and
• Is not older than 21 years of age; or
• If the State law for the State provides for a higher maximum age for receipt of services under the Individuals with Disabilities Education Act (20 U.S.C. 1400 et seq.), is not older than that maximum age; and
• Is eligible for, and receiving, special education or related services under Part B of the Individuals with Disabilities Education Act (20 U.S.C. 1411 et seq.); or
• Is a student who is an individual with a disability, for purposes of section 504.
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Enrolled in a Recognized Education Program
Educational programs include: • Secondary education programs;• Non-traditional or alternative secondary education programs,
including home schooling;• Postsecondary education programs; and• Other recognized educational programs, such as those offered
through the juvenile justice system.
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IPE Education Requirements911 Reporting (IX.F)
Element #74: State Definition for Age of Students with Disabilities
• Record two-digit lower limit age; two-digit upper limit age
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IPE Education Requirements911 Reporting (continued)
Element #75: School Status• Code 1 – Individual has not received a secondary school diploma
or its recognized equivalent and is attending any elementary or secondary school (including elementary, intermediate, junior high school, whether full- or part-time), or is between school terms and intends to return to school.
• Code 2 – Individual has not received a secondary school diploma or its recognized equivalent and is attending an alternative secondary school or an alternative course of study approved by the local educational agency, whether full- or part-time.
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IPE Education Requirements911 Reporting (cont.)
Element #75, continued• Code 3 – Individual has received a secondary school diploma or its recognized
equivalent and is attending a postsecondary school or program (whether full or part-time), or is between school terms and is enrolled to return to school.
• Code 4 – Individual is not within the age of compulsory school attendance; and is no longer attending any school and has not received a secondary school diploma or its recognized equivalent.
• Code 5 – Individual is not attending any school and has either a secondary school diploma or has attained a secondary school equivalency.
• Code 6 – Individual is within the age of compulsory school attendance, but has not attended school for at least the most recent complete school year calendar quarter and has not received a secondary school diploma or its recognized equivalent.
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Pre-Employment Transition Services
As described in 34 CFR 361.48, the following exclusive list ofPre-Employment Transition Services may be provided:
• Job exploration counseling; • Work-based learning experiences, which may include in-school or after school
opportunities, or experience outside the traditional school setting (including internships);
• Counseling on opportunities for enrollment in comprehensive transition or postsecondary educational;
• Workplace readiness training to develop social skills and independent living; and
• Instruction in self-advocacy
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Start Date of Pre-Employment Transition Service
Element #96: Start Date of Pre-Employment Transition Service• Data entry is required if individual is receiving Pre-Employment Transition
Services, regardless of whether the individual has applied or been determined eligible for VR services.
• Once this data element has been reported, the data element may ONLY be changed by contacting RSA Data Unit staff to initiate a modification.
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911 Reporting Requirements for Pre-ETS
For each Pre-Employment Transition Services category, there are six potential data elements to report(911 Section X, page 51):
• How the service was provided:o By VR Agency Staff (in-house) or o Through VR Agency Purchase
Purchased Service Provider Type
o VR Program Expenditure for Purchased Serviceo By Comparable Services and Benefits Providers
Comparable Services and Benefits Provider Type
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911 Reporting Requirements for Pre-ETS (cont.)
• These six potential data elements must be reported for all individuals receiving the service.• Code 1 – If service was provided in whole or part by …
• Code 2 – If services was provided … and is no longer being provided
• Codes must be entered in the quarter in which the service happens or discontinues, regardless of when payment is made.
• Report each quarter (even without changes).
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Reporting Agency Totals – Outside of the 911
SF425 – Financial Reporting• Line 12.b – Federal Expenditures, not unliquidated Federal obligations
RSA-2 – VR Program Cost Report• Current version does not account for Pre-ETS
• Revised RSA-2 form will include aggregate required activity expenditures, authorized expenditures and coordination expenditures
How are state agencies implementing these data elements and reporting requirements into their case management systems?
Order of Selection --Students with Disabilities ReceivingPre-Employment Transition Services
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Receipt of Pre-ETS while on OOS
Can students with disabilities receive Pre-Employment Transition Services while on the order of selection waiting list?
• If a student with a disability begins one or more of the required activities prior to being determined eligible for VR services, he or she may continue to receive any and all Pre-Employment Transition Services even if the student is assigned to a closed OOS category.
• In addition to the Pre-Employment Transition Services, the student may participate in group transition services while in a closed OOS category; however, the student may not receive any individualized VR services, including individualized transition services, until his or her turn for receipt of VR services comes up under the State's order.
Common Performance Measuresand Students
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CPM as it Relates to Students
• The Common Performance Measures (CPM) require special rules for students.
• CPM and Pre-Employment Transition Services do NOT generally overlap.
• Potentially eligible students receiving Pre-ETS are excluded from the CPM
• The provision of Pre-ETS could greatly influence the long-term employment indicators.
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Employment Indicators
How does the provision of Pre-Employment Transition Services influence the employment indicators for the VR program?
• Employment Rate – 2nd Quarter After Exit
• Employment Rate – 4th Quarter After Exit
• Median Earnings – 2nd Quarter After Exit
Potentially eligible vs. eligible VR clients receiving Pre-ETS
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Credential Attainment/Measurable Skill Gains
• How does the provision of Pre-Employment Transition Services influence the credential attainment and measurable skill gains indicators for the VR program?• Special Rules for Students
• 911 Specific Tracking Requirements
• Do Pre-Employment Transition Services and CPM’s overlap(e.g., Do work experiences count as skill gains, etc.)?
How are State agencies tracking and reporting CPM, as it relates to students with disabilities and differentiating from Pre-ETS?
Policies and Procedures,Internal Controls,and Supporting Documentation
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What do they all mean?
Supporting Documentation
Internal Controls
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Policies and Procedures for Pre-ETS
The VR agency’s policies and procedures include:• Guidance regarding documentation and reporting requirements
for non-applicants, applicants and eligible individuals who are students with disabilities receiving Pre-Employment Transition Services .
• The monitoring and tracking of funds spent on Pre-Employment Transition Services provided through purchased services and/or directly by VR agency personnel (staff time).
• When a student ceases to become a student and Pre-Employment Transition Services must stop.
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Policies and Procedures for Pre-ETS (cont.)
Planning for the provision of Pre-Employment Transition Services, including:
• Quality assurance and performance measures • Strategies for effective engagement of students and youth with
disabilities and measuring effectiveness of services
Ability to answer questions because of policy and procedures
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Policy and Procedure – Written Processes
Guiding questions for accuracy and validity of the data: • What is your methodology?• What are your processes?• Where does the information live?• What is your process to ensure verification of information?o When and how often will you verify data?o Who is responsible for the information? o What does the process look like?
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Policy and Procedure – Additional Needs• Students receiving Pre-Employment Transition Services may also receive VR services.
Describe any additional VR services received by students with disabilities in receipt of Pre-Employment Transition Services. What additional services are most frequently provided?
• Describe the policies and procedures that the VR agency has developed, revised or implemented to address changes related to Pre-Employment Transition Services requirements, including the provision of services to students with disabilities who are potentially eligible for VR services.
• Does the VR agency have a policy that directs counselors to ensure that students with disabilities determined eligible for the VR program have an IPE in place prior to exiting the school setting?
• Describe how the grantee tracks administrative cost expenditures to ensure that any administrative expenditures charged to the VR award are not reported as expenditures meeting the reservation requirement for Pre-Employment Transition Services.
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Internal Controls - Purpose
2 CFR 200.61 defines internal controls as a process, implemented by a non-Federal entity, designed to provide reasonable assurance regarding the achievement of objectives in the following categories:
• Effectiveness and efficiency of operations
• Reliability of reporting for internal and external use
• Compliance with applicable laws and regulations
CFR 200.303 requires the VR agency, as a non-Federal entity, to establish and maintain effective internal control over the Federal award that provides reasonable assurance that it is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
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Internal Controls – Data Accuracy
34 CFR 361.12 requires the VR agency to employ method of administration found necessary by the Secretary of Education for the proper and efficient administration of the VR program and for carrying out all functions for which the State is responsible under the State plan and Federal regulations. These methods must include procedures to ensure accurate data collection and financial accountability.
• Internal control processes must include monitoring of Federal requirements, which would include ensuring data accuracy (2 CFR 200.303(c)).
• RSA will review these internal control procedures and monitor the RSA-911 to ensure the data submitted are accurate.
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Internal Controls – Continuous Improvement
• If executives think of the internal control system as only a means of preventing fraud and complying with laws and regulations, an important opportunity may be missed.
• Internal controls can also be used to systematically improve businesses, particularly concerning effectiveness and efficiency.
• Achieving quality data raises other questions: • How can we automate processes to limit the possibilities for human error?
• Which parts of the process can be changed to keep focus on quality data?
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Example Process for Good Internal Controls
Identify Problem
How Will You Approach Revisions
Write Draft Procedures
Test Draft Procedures and
Revise
Write Implementation
Plan
Implement and Evaluate
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Example of Internal Control Procedures
• An independent staff committee that routinely reviews cases and revises policies and procedures to maintain data quality and integrity.
• Internal controls and the importance of data quality and integrity are a key component of new employee orientation and vendor orientation.
• Supervisors have a regular schedule (e.g., quarterly) to review sample files of counselors to check for data quality and integrity.
• Review of sample files is rotated among a group of trained staff so fresh eyes ensure that procedures are followed and the data and documentation are correctly entered in case files.
• A “common sense” review of internal control reports to see if the results check against expectations, historical trends, “gut feelings.”
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Supporting Documentation
34 CFR 361.47 and 34 CFR 361.56 together, require VR agencies to:• Maintain verifying documentation in an individual’s case file, particularly
regarding eligibility determinations, development of the individualized plan for employment, services provided, and case closure.
It is important to note that the use of an electronic case management system does not remove the requirement for the agency to maintain either hard copies or scanned copies of required supporting documentation in the individual’s service record.
• An electronic case management system is merely a data entry process that is susceptible to data entry errors.
• Requiring staff to note the source of the employment data also does not provide the documentation necessary to ensure data validity and reliability.
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Student with a Disability – Documentation
Required documentation for potentially eligible students receiving Pre-Employment Transition Services may include:
• Case note documenting counselor observation, review of school records, statements of education staff; or
• Referral form for Pre-Employment Transition Services with the identification of a student’s disability, signed by school staff and parent/guardian if the student is under the age of majority in a State (parental consent to participate in Pre-Employment Transition Services is governed by State law, as well as policies of the educational programs and the designated State units (DSU)); or
• Copy of an individualized education program (IEP) document, SSA beneficiary award letter, school psychological assessment, documentation of a diagnosis or disability determination or documentation relating to 504 accommodation(s).
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Post-Secondary Education Setting Documentation
There are four pieces of documentation needed: • Documentation that the individual with a disability graduated from
secondary ed.• Documentation that the individual with a disability has been
accepted into a post-secondary ed. institution/program.• Documentation of the individual with a disability’s intention or
confirmation that they had accepted the invitation to enter the post-secondary program.
• Documentation that the institution has informed the individual with a disability that their “spot” is being held for them.
Documentation for VR Services (in-house)What steps are agencies taking to document in-house services provided directly by VR Counselors?
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How are state agencies implementing policies and procedures, internal controls, andsupporting documentation requirements to ensure the accuracy and validity of data required in the 911 report, SF-425 Fiscal report, and meeting the 15% reserve requirement?
Outcome Tracking forPotentially Eligible Students
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Potentially Eligible Student Outcomes
• WIOA and VR regulations do not require the tracking and reporting of outcomes for students with disabilities who are receivingPre-Employment Transition Services, who have not yet applied and become eligible for the VR program.
• Should states implement tracking strategies for the potentially eligible, even though it is not required at this time?
• What guidance has RSA issued regarding the tracking of outcomes for the potentially eligible?
• Of the students with disabilities who have receivedPre-Employment Transition Services since FY 2014, how many have applied for VR services? (MTAG)
How are states implementing tracking strategies, as it relates to potentiallyeligible students with disabilities receivingPre-Employment Transition Services?
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Recommendations and Lessons Learned
State of Maryland
Division of Rehabilitation services
State of Alaska
Division of Vocational Rehabilitation
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Reporting Resources
• PD-16-04 Case Service Report Manual (RSA-911)
• TAC-17-01 Joint Guidance on Performance Accountability
• TAC-17-04 Joint Guidance on Supplemental Wage Information
• TAC-17-05 WIOA Annual Performance Report Submission
• Federal FY 2017 Monitoring and TA Guide – VR & SE Programs
• WINTAC Pre-Employment Transition Services Implementation Checklist
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Additional Resources of Interest
• Archived Webinars/Live Webinars
• Topic Area resources and best practices
• Email distribution list
www.WINTAC.org
End of Side A Thank you for attending!
WINTAC Contact Information
Brenda Simmons, GWU(816) 739-7648, [email protected]
Christine Johnson, GWU(513) 882-3927, [email protected]
Rachel Anderson, NDI(435) 764-8487, [email protected]
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State VR Agency Contact Information
John Stem, Maryland Quality Assurance(410) 554-9536, [email protected]
Scott Dennis, Maryland Fiscal(410) 554-9414, [email protected]
Mariah Krueger, Alaska VR Chief (907) 269-3559, [email protected]
Jim Kreatschman, Alaska Transition (907) 465-6931, [email protected]
Side B – Additional Considerations for Students with Disabilities, FAQs,
etc.
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RSA Training – CPM
• RSA developed a self-paced training curriculum that provides an overview of the joint guidance issued in Technical Assistance Circulars (TAC) 17-01 and 17-04.
• This presentation will cover some of the special rules related to students; however, it is highly recommended to participate in this seven-module training to learn more about the Common Performance Measures.
• WIOA Performance Accountability for Vocational Rehabilitation Programs
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Credential Attainment for Students
Are students included in the credential attainment measure?• Participants in a postsecondary education or training program, or who are in a
secondary education program (at or above the 9th grade level) without a secondary school diploma or equivalent
• Participants enrolled in secondary education and who have attainment of a secondary school diploma or equivalent identified on their Individualized Plan for Employment (IPE)
• Certificate of Completion – Does not meet the definition of Credential
Special rule:• If participant obtains a secondary school diploma or equivalent, in order to
count in the numerator, they must also be employed or in an education/training program leading to a postsecondary credential within one year after exit.
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Credential Reporting for Students in 911
Element #78: Enrolled in Secondary Education• Code 1 – Individual is enrolled in a secondary education program at or above
the 9th grade level and achieving a high school diploma is a goal on their IPE
• Code 2 – Individual is enrolled in a secondary education program at or above the 9th grade level and achieving a high school diploma is NOT a goal on their IPE
• Code 0 – Individual is not enrolled in a secondary education program at or above the 9th grade level (for whom this does not apply)
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Measurable Skill Gains for Students
Are students included in the Measurable Skill Gains Indicator?• Percentage of program participants who, during a program year, are in an
education or training program that leads to a recognized postsecondary credential or employment and who are achieving measurable skills gains, defined as documented academic, technical, occupational, or other forms of progress, towards such a credential or employment.
• All participants enrolled and participating in a recognized education or training program identified on their IPE are included
• VR measures all five measurable skill gains which include students in secondary education or recognized equivalent programs.
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Frequently Asked Question 1
Question: Can RSA clarify their interpretation of "in an educational setting" and whether the inclusion of trade schools and training programs, such as those at a CRP where a student may earn a certificate, are allowable?
Answer: RSA clarified that educational programming under the definition of a "student with a disability" would include programs that provide a recognized credential of education, such as a certified nursing assistant (CNA) program. However, programs provided by a CRP or Project Search, would not be considered an educational program for the purposes of satisfying "educational programming" within the definition of a student with a disability.
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Frequently Asked Question 2
Question: Is it necessary for the VR program to obtain documentation of a disability at the individual level for a potentially eligible student?
Answer: Yes.
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Frequently Asked Question 3
Question: If SVRAs are able to pay ADA related services such as interpreter, reader, etc., for Pre-ETS clients, do we need to report these service payments under one of the specific five required categories for Pre-ETS? As we don’t report any of the VR Services on Pre-Employment clients, there isn’t an available place to report the payment under the interpreter, reader, etc., categories.
Answer: VR agencies may pay for auxiliary aids and services with funds reserved for the provision of Pre-Employment Transition Services if the auxiliary aids and services are directly related to one of the five required activities outlined in §361.48(a)(2). Examples of auxiliary aids and services include interpreters and video-based telecommunication devices for the deaf and hard of hearing, and readers and voice synthesis software for the blind and visually impaired. These expenses must be incurred as a result of the provision of one of the five required activities outlined in §361.48(a)(2), to be charged to the reserve.
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Frequently Asked Question 3 (continued)
Answer continued: Allowable costs incurred from the provision of the five required activities outlined in §361.48(a)(2), must be recorded in the RSA-911. These costs would be recorded in the appropriate service element in section X of the RSA-911. For example, if the VR agency provided a staff member to serve as an interpreter for a student to participate in a work based learning experience, the cost of the interpreter would be recorded under RSA-911 data element 103, Work Based Learning Experience, Service Provided by VR Agency Staff. If the VR agency contracted with a third party to provide an interpreter for a student to participate in a self-advocacy workshop, the cost of the interpreter would be recorded under RSA-911 data element 122, Instruction in Self Advocacy, Service Provided by VR Agency Purchase.
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Frequently Asked Question 3 (cont.)
Answer continued: Allowable costs incurred from the provision of the five required activities outlined in §361.48(a)(2), for students who have been determined eligible and placed on an IPE must be recorded in the RSA-911. These costs would be recorded in the appropriate service element in section X of the RSA-911. If the VR agency used the same contracted interpreter for the student to participate in a VR activity other than one of the five required activities outlined in §361.48(a)(2), the cost of the interpreter may not be charged to the funds reserved for the provision of Pre-Employment Transition Services. The costs would be recorded in RSA-911 data element 330, Interpreter Services, Services Provided Through VR Agency Purchase.
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Frequently Asked Question 4
Question: States can earn a credential or measurable skill gain for secondary school diploma or recognized equivalent. In special education, students can earn a certificate of completion/attendance/achievement if credits are not earned toward a standard high school diploma. For purposes of the Common Performance Measures, will these special education certificates count as a “recognized equivalent”?
Answer: No. Certificates of completion/attendance/achievement are not recognized by states as attaining passing scores on equivalency tests, nor credit bearing, which would not count as a recognized equivalent.
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Frequently Asked Question 5
Question: If a student completes a year of high school in June, the state may not have the ability to follow-up and obtain appropriate documentation to report the Measurable Skill Gains (MSG) before the Program Year ends on June 30. Can the MSG be reported in the following PY?
Answer: In order for the state to report the MSG, they have to get the documentation before 8/15, when the file is due for the annual report.
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Frequently Asked Question 6
Question: State VR agencies are required to separately track the time VR staff spends carrying out the four coordination activities outlined in 361.48(a)(4), or if the time spent carrying out these activities can be included with the time the agency tracks providing or arranging for the required Pre-Employment Transition Services under 361.48(a)(2)?
Answer: The 911 is specifically capturing the costs per student for purchased services but does not require tracking the direct time spent providing pre-ets services. But for the SF 425, when states report their expenditures, the time tracking and internal controls mechanisms are allowable and will need to include the required and coordination activities. Because they need to make sure they have funds to spend on the authorized activities, it is important the agency staff track their time for all the required activities and also have a way to denote how they are tracking it separately from the authorized activities and also the coordination activities. They don’t need to assign an expenditure value for each right now, but down the road for future reporting purposes, states will need to be able to separate out the staff time spent on each of those three separate categories 361.48(a)(2) and (3), and (4).
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Frequently Asked Question 7
Question: When SVRA’s are determining the allowable costs that can be allocated to the funds reserved for Pre-Employment Transition Services under the nine authorized activities described in 361.48(a)(3), are the travel costs associated with VR staff to carry out, conduct, or attend a training as described under 361.48(a)(3) considered an administrative cost that must be disaggregated from the cost to be charged to funds reserved for Pre-Employment Transition Services, or is it an allowable cost to be charged to the funds reserved as a result of providing that authorized activity?
Answer: RSA stated that the travel costs associated with VR staff to carry out, conduct, or attend a training as described under 361.48(a)(3) are not considered an administrative cost, and VR agency can count them as an allowable cost to be charged to the funds reserved as a result of providing that authorized activity. This can be counted as long as the training is for Pre-ETS purposes, and as long as costs are being allocated appropriately to Pre-ETS. If you have staff attend that training, those authorized activities are not administrative activities (361.48.(c).212?), so yes, those travel costs associated with carrying out or conducting that training can be allocated to Pre-ETS expenditures.
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End of presentation
End of Side B
For additional FAQs and updated information,clarification and resources, please visit www.WINTAC.org.
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