>>Slide 1 Advancing Independent Living as a Network: Clarifying the Roles of CILs, SILCs, and DSEs Office of Independent Living Programs Administration on Disabilities Logo: Administration on Disabilities, a Division of the Administration for Community Living >>Slide 2 Erica McFadden Ed Ahern Office of Independent Living Programs (OILP) >>Slide 3 Outcomes for this session - Clarify specific roles and responsibilities among DSEs, CILs and SILCs. - Understand the requirements for CILs, DSEs and SILCs related to the SPIL and coordinating as a network. - Know what to do if concerns are identified. - Learn how OILP monitors the process. >> Slide 4 Development of a resource plan for the SILC The SILC State Plan resource plan is developed by the SILC and includes: Sufficient funds received from: - Title VII, Subchapter B funds; - Funds for innovation and expansion activities - Other public and private sources >>Slide 5 Content of the SILC Resource Plan, cont’d. The funds needed to support: - Staff/personnel; - Operating expenses; - Council compensation and expenses; - Meeting expenses; - Resources to attend and/or secure training and conferences for staff and council members; and - Other costs as appropriate. The DSE does not oversee the budget of the SILC >>Slide 6 Administrative responsibilities of SILC - Develop, approve and implement written policies and procedures to assure sound organizational and financial practices. - Regularly review and approve financial statements of the SILC. - Plan for cash flow through the payment plan with the DSE, including an advance first of each year. >>Slide 7 Additional SILC administrative responsibilities - Establish a peer or partnership relationship with the director/commissioner of the DSE, which allows for direct communication between the SILC Chair or director and the DSE director - Read and understand Title VII of the Rehab Act and 45 CFR 1329 of the regulations. >>Slide 8 - Responsibility of DSE related to the SILC - Acknowledge its role as the fiscal intermediary to receive, account for and disburse - Value the role of the SILC and assure that the SILC is healthy and functioning. - DSE must ensure SILC resource plan/funding is “necessary & sufficient” for the SILC to operate - DSE has an appointed that may have limited input if the SILC policies allows the ex officio members to have input. >>Slide 9 Designated State Entity Assurances The DSE must make timely and prompt payments to SILCs and Part B funded CILs (cont.): - The payment plan should include advance payments to maintain cash flow. - The DSE will accept requests for advance payments and reimbursements at least monthly; >> Slide 10 More from DSE Assurances The DSE will not interfere with SILC business or operations including: - Expenditure of federal funds - Meeting schedules and agendas - SILC board business - Voting actions of the SILC Board - Personnel actions - Allowable travel - Trainings >>Slide 14 When the SILC utilizes DSE staff - DSE/SILC need to agree on how the person is paid/how their time is tracked and the SILC billed for their time. - The SILC selects and supervises the staff person’s work for the SILC and evaluates their performance. - The SILC cannot be established as an entity within a state agency - If the SILC staff is employed by the DSE, there must be a separation of duties related to the SILC itself, and full autonomy on the part of the SILC to select and supervise those duties. >> Slide 12 SILC Autonomy What are some of the ways that the SILC assures the its autonomy? - Selects and supervises own staff (even if assigned/paid by DSE) - Develops and manages own budget and expenses - SILC submits recommendations for appointment to Governor or appointing authority - Fulfills responsibilities in the Rehab Act - Complies with laws and regulations >>Slide 13 DSE responsibility for SILC Compliance DSE is responsible for: - assuring that resources are available for the SILC to operate. - assuring it meets requirements of law and regulation. - proper disbursement of federal funds, according to the SPIL. The DSE may follow up to ensure funding went to activities per the SPIL, or 725 Assurance for Part B funded Centers >> Slide 14 Appointments to SILC SILC Indicators of minimum compliance require SILC policies and procedures to include method for recruiting, reviewing applications - What is your SILC’s relationship with the appointing authority? - The DSE can assist the SILC in connecting with the governor’s office and support the SILC recommendations. - CIL Executive Directors select one of the EDs for appointment. - CILs may suggest consumers or board members who do not work for the state or a CIL. >>Slide 15 Collaboration on SPIL Planning and Approval? - SILC is responsible to assure SPIL development - SPIL must be developed jointly by SILC and all the CIL directors (that meet 725 assurances) in the state - SPIL must be approved by SILC and CILs and signed by SILC Chairperson and majority of CIL directors - The DSE can submit public comment into the process - DSE signs the SPIL agreeing to serve as DSE – NOT to approve the content >>Slide 16 - What if the SILC doesn’t seem capable of developing and monitoring the SPIL? - Understand why: do they not have sufficient resources? - Most SILCs are non-profits with staff who can support the SPIL. - CILs need to step forward to assure the SPIL is developed. - The type of goal and the measurement of its completion is the responsibility of the SILC. - If more than half the CILs choose not to sign the SPIL, the SPIL cannot be approved. This can cause all IL funding to cease until there is an approved SPIL. >>Slide 17 Gathering Public Input for the SPIL The SILC receives public SPIL input (including to draft) ensuring: - Adequate documentation of the State Plan development process, including but not limited to: - a process for gathering input from CILs and individuals with disabilities throughout the state, - a process for how the information collected is considered. - All meetings regarding State Plan development and review are open to the public and SILCs must provide advance notice >>Slide 18 Section 3.2 - CILs receiving Part C funds will continue to receive those funds: funds cannot be redistributed through the SPIL. - Service areas may be adjusted through the SPIL, with the agreement of at least half the CILs. - Part C funds can be reallotted only if a CIL opts to relinquish some of their Part C award to their state network. The reallotment of those funds need to be detailed in the SPIL. >>Slide 19 How much can the DSE impose in Section 4 of the SPIL? - This section should reflect current practice so that everyone has clear expectations of the process the DSE is expected to follow. - This is what the state and federal requirements are for the DSE as the grant recipient, including the grant process for the use of Part B and other pass-through resources in the plan. *This is a good example of the importance of reading the instructions for the SPIL. >>Slide 20 Compliance review by the DSE - The SPIL should indicate the compliance processes for the DSE to follow. - The DSE may review the allowability, allocability and reasonableness of federal expenditures by Part B subgrantees. >>Slide 21 The SILC monitors, reviews and evaluates the State Plan - This does not mean that the SILC monitors the operations of the CILs. - Note, however, that the CILs have given their word, in their signatures, to accept responsibility for specific areas of the SPIL. - The CILs should report to the SILC on their progress on these items. >>Slide 22 CIL Role in the SILC: support vs interference - There is always a full, voting member on the SILC that is a CIL Executive Director chosen by all the EDs in the state. - The law clearly prioritizes people with disabilities that represent the community, not those who work for a center or the state. - Fifty-one percent of the members of the SILC must be people with disabilities who do not work for either a center or the state. - A CIL may urge consumers or board members with disabilities to apply to be on the SILC. - During a meeting, only the council should discuss items and vote. >>Slide 23 Development of PPR - CILs receiving Part C funds complete a PPR that includes ALL the services provided regardless of funding sources. - ILS PPR does not include services already reported on by Part C CIL PPR. - DSE and SILC are responsible for separate sections of the ILS PPR. This includes centers that are ILS/Part B and don’t receive any Part C funds. >>Slide 24 Sharing Information Regarding the SPIL - The SILC should provide this public document to anyone upon request. - Your Program Officer at ACL can provide a copy of the approved SPIL upon request. - CILs are required to share their approved PPRs with the SILC, so the SILC can evaluate implementation of the Plan. >>Slide 25 How does OILP Monitor SPIL Requirements? About Monitoring - Statutorily required: to assess compliance and assurances - Improves program performance; network strength; and increases availability of IL services in communities - SILC, SPIL, DSE and CIL: 722 states/723 states - Key in monitoring is ensuring training and technical assistance (T/TA) is available - Identifies promising practices; successful programs >>Slide 26 About OILP Program Officers - A full team! -- Peter Nye; Jennifer Martin; Hindley Williams; Ayisha Mamudu; Heyab Berhan; Ed Ahern - Diversity of disability, experience and 100% commitment to supporting the IL Network Questions, ideas, problems, successes – contact your PO! - We want you to know we’re here for you. We are YOUR resource >>Slide 27 Baseline Monitoring Baseline Monitoring - Everyday Interaction - Regular check-in emails; phone/Teams/Zoom calls; questions; general clarifications; change in leadership - Review of annual performance reports (PPR) -- This will likely include a back and forth between the grantee and PO to get clarification or additional information - Review of fiscal documents and drawdowns -- ACL/OFO - Communicating with tools such as our web site, OILP Newsletter, Quarterly Connect and Stakeholder calls, annual IL conferences Monitoring: Targeted Review >>Slide 28 Targeted Review - Generally focused on one issue -- No transition services x 3 PPR years -- Less than 50% people with disabilities on staff, board, SILC -- Complaint from consumer, stakeholder -- Consistently late report submission - Starts with communication – and remains two-way throughout the process - May require review of policies, document or processes directly related to the target issue - Non-Federal Reviewer (NFR) with CIL operational experience participates as third party support; T/TA also a critical part - Review may be as short as a few days; may last weeks - Corrective Action Plan (CAP) may be developed >>Slide 29 Monitoring: Comprehensive Review Comprehensive Review - May be virtual, on site, or hybrid -- 15% of grantees -- May be random or requested -- Combination of issues – fiscal, programmatic, complaint - Starts with two-way communication – which continues throughout the process - Uses the CIL Evaluation Tool following the process in the COMP Guide - Non-Federal Reviewer (NFR) included - Corrective Action Plan (CAP) developed; supported by T/TA and PO - Final report posted on ACL website >>Slide 30 Questions and Answers For Technical Assistance: Paula McElwee - paulamcelwee.ilru@gmail.com; 559-250-3082