1 Training on the revised State Plan for Independent Living (SPIL). Presented by the Rehabilitation Services Administration (RSA). Presenters: Thomas Kelley and Felipe Lulli, RSA. >>>SHARON: Good afternoon, everybody. Welcome to today's webcast and teleconference, presented by the Rehabilitation Services Administration and hosted by IL NET and ILRU. My name is Sharon Finney. I'm with ILRU. I will moderate the webcast and voice any questions submitted via e-mail today. Before we get started I want to remind you about a few things in asking questions. In order to submit a question during today's webcast you can click the submit question at the bottom of the Real One Player screen or simply address an e-mail to webcast@ILRU.org. 2 Webcast -- one word -- at ILRU.org. Please send your questions now or at any point during today's presentation. I will pose your questions to the presenters at that time. I'd like to introduce our operator today, Crystal. Good afternoon Crystal. >>>OPERATOR: Yes. If you would like to ask a question during the teleconference, press star one on your telephone key pad. If you'd like to with draw your question press the pound key. Thank you, Ms. Finney. >>>SHARON: All right. Additionally, if anyone has technical problems today, feel free to give us a call at 713-520-0232 and press 0. This number is both voice and TTY. As I said before, today's presentation is training on the revised state plan for independent living or SPIL, SPIL. It is being presented by Thomas Kelley and Felipe Lulli of Rehabilitation Services Administration. I'm happy to turn the presentation over to Thomas Kelley. 3 >>>THOMAS: Good afternoon. I am Thomas Kelley, chief of the independent living unit at Rehabilitation Services Administration. I have the pleasure of presenting to you the national state plan for independent living, training for designated state units and statewide independent living council units. I understand we have other guests at this training, including center for independent living director and staff, RSA in state monitoring (indiscernible) division. Let me take this opportunity to thank you for participating in this teleconference today and to think IL NET and the independent living research utilization program for providing a webcast of this training. As you know, for states to receive funding under parts B and C RSA must approve a three year state plan for independent living or SPIL. The next SPIL is due to RSA on July 1st of this year. The SPIL instrument and instructions have been revised for this 4 year. The purpose of the revised SPIL is, one, to reduce the data collection and reporting burdens for the state and, two, to make the SPIL information more useful for the states as well as for RSA. The third point is that it now more precisely reflects the requirements of chapter 1, title 7 of the act and the corresponding provision of the Code of Federal Regulation. Here are a couple of highlights. The revised reprint requests only the SPIL information required by federal law and regulation. It is more brief, more clear, more concise and we believe more easy to complete. Combined the revised SPIL instrument instructions have been reduced to 35 pages from the previous documents' 47 pages. The revisions do not change the kinds of goal, activities or services to be reported by the states and should not affect the SPIL development already under way in your city. RSA expects SPIL development in your state will be a joint process 5 involving DSU and SILC as partners. For the SPIL to be developed and implemented successfully, it is critical that DSU SILC and SILS understand their roles and responsibilities. This national training is designed to help you develop an approvable SPIL. We'll highlight important points to consider, provide guidance about what information should be included or not included and provide the middle instructions at the end. Felipe Lulli will be the primary presenter of this information. First, he will give you an overview of the revised SPIL. Then he will go over part one, the assurances, and part two, the narrative sections of the SPIL in some detail. After each part, we will pause for your questions. After parts one and two of the SPIL, we will provide detailed submittal instructions as I mentioned before, and I will provide closing remarks. And now here is Felipe Lulli. >>>FELIPE: Good day, everyone. 6 Good afternoon. My pleasure to walk through the SPIL with the you. Brief overview. The SPIL is the basic blueprint or strategic plan for all IL services and activities in your state. It outlines where you want the program to go -- let's say from point A, 2007, to point B, 2010. Together the SPIL describes how individuals with disabilities, signature disabilities in your state will be better off because of the IL program in your state. Part one of the SPIL is a series of assurances or statements of compliance based on legal and regulatory provisions governing the SILS and CIL program. It's basically the same as the previous SPIL except for a few items I will describe soon. Part two of the SPIL consists of narrative sections in which the state describe its independent living objectives, services, activities, and operational details. The multiple attachments of the old SPIL, including 7 the mandatory area have been replaced by a single document in which a logical sequence of narrative responses provides a clear, readable description of the State's independent living program. So the SPIL looks very different. It reads different but the content is essentially the same as in the past. A brief note about the older blind program, the independent living services for older individuals who are blind. The SPIL relates only to -- specifically to chapter 1, title 7. The older blind program, which is chapter 2, is not subject to the SPIL. However, the law and regulations require certain references to the older blind program in the SPIL. I will point out these references as I go along in the training. Let's start with part one, assurances. This should be brief because everything is self-explanatory. On the upper right-hand corner of part one we have where you indicate what state the SPIL is for. Section 1.1, you insert the name 8 of the DSU, the full name of the DSU. 1.2, you insert the name of the separate state agency authorized under state law to provide VR services to individuals who are blind. This would apply only to states in which there is a blind agency and a separate general agency. This does not refer to the older blind program. Not all states will have information for 1.2. In those cases please indicate "not available." 1.3, you insert the official name of the SILC in your state. A very important note, please make sure that your SILC's membership is up to date. That is, that the members have current appointment and that more than half of its members and voting members are individuals with disabilities. This is important because RSA cannot accept the SPIL if the SILC is not legally constituted because it would not have the authority to sign the SPIL. One thing to keep in mind is that members cannot serve more than two, three consecutive full terms. 9 I'm going to skip over some of the other points which are self-explanatory and which are identical to previous SPIL. In section 1.7 you indicate the name of the DSU director and the name of the director of the separate state agency serving people who are blind. You don't need to insert here the name of the SILC chairperson. That would be included in section 9 of part 1, which is the signature page. I'd like to go on to section 2, SPIL development. 2.1 -- I would like to highlight one phrase in 2.1, and that is "to appropriately address on a statewide and comprehensive basis the needs in the states for" -- and then it has a list of three things -- provision of state services, development of statewide network of centers, and working relationship. The important thing I want to highlight is that unlike the VR state plan the SPIL does not officially require what's called a comprehensive statewide needs assessment. However, 2 .1 10 makes clear that the SPIL must be based on an understanding of what the statewide and comprehensive needs for IL are. This understanding should be reflected in the SPIL, for example in the objectives, in the priority service and populations and many the plans for the network of center, collaboration with other programs, outreach, et cetera. The needs -- the comprehensive need for IL in the state can be identified through a variety of sources. For example, public hearings, the CIL work plans, available data or information from other statewide council, committees or organizations, including the governor's office on disabilities as well as the VR state plan comprehensive needs assessment. We recommend that states if possible have a collaboration between IL and vocational rehabilitation in assessing comprehensive needs in the state. 2.2 deals with the requirement to conduct public hearing regarding this 11 SPIL. Want to point out that we don't require a summary of the public comments. You may want to reference some of the findings from these public hearings, but we do not require an actual summary of the public comments. 2.3. This goes into a little more description about what the requirements are for the public hearings, including providing materials in alternate format. We are not requiring a copy of the written procedures for public hearing. Here all you're doing is assuring us that you have them. Later on in part two you will be describing a little bit more about your written procedures governing a public hearing. 2.5. 2.5 refers to "new methods or approaches developed under the older blind program." In 2.5 I'd like to highlight the phrase "seek to incorporate." Here, the assurance is only that the DSU will seek to incorporate and describe in the state plan any new methods or approaches from the older blind 12 program. Not necessarily to include them but seek to incorporate or seek to learn about innovative approaches in the older blind program. Item 2.6 refers to the consultation with the client assistance program in the development of the SPIL. This was not included in the previous SPIL, but it is not a new policy or legal requirement. This requirement always existed in the regulations. We just basically picked up on it and included it in the revised SPIL. The rest of the assurances, sections 3 through 8, apply to all service providers funded under chapter 1. This includes even those SILS that receive part C funds. We have received several questions about this. For example, how can the SPIL -- DSU and the SILC -- assure that part C only SILS meet these requirements since it is RSA and not the DSU or the SILC's role to monitor those SILS that receive only part C funds? SILS are not supposed to monitor -- SPILs are not to monitor SILS . That 13 question is a good one and we will discuss in greater detail when we get to the narrative section in part 2. Sections 3 through 8, I won't go into great detail because they're self-explanatory and existed in the previous SPIL as well. Section 3 is requirements dealing with independent living services. Section 4 deals with requirement of dealing with eligibility. Now, in 4.2 I want to highlight a phrase, "type of significant disability." So eligibility requirements without regard to age, color, creed, national origin, race religion -- this an important phrase that reflects the cross disability nature of the IL program. Again, also in 4.3 there's one key phrase I'd like to highlight and that is "present in the state." That means that eligibility cannot be limited based on any residency requirement other than the fact that the individual is simply present in the state. Section 5. That is dealing with staff requirements of all source providers. 14 There are two distinct aspects in this requirement in 5.2 dealing with alternate means of communication. The first aspect is alternate modes of communication based on particular disability. The second aspect is separate, and that is dealing with materials or being able to communicate in the native language of people with disabilities whose English proficiency is limited. Section 6 is physical control and fund accounting. Self-explanatory, as is record keeping access and reporting. We do not include all the details, but we do include the citation in the regulation so we encourage you to go to the regulations and look at what the regulations require concerning section 7 and also regarding section 8 that follow. Section 9 is the signature page. Please be sure to fill in all the blanks including the name of the state and the period of the assurances which are 2008 through 2010. And again, for those 15 states that have separate blind and general agencies there would be three signators, not two. This concludes my overview of the part one, assurances, and now we will pause for questions. Crystal, would you open the lines, please. >>>OPERATOR: Yes. Press star one on your telephone key pad. It will be just a moment while we compile the roster, sir. >>>FELIPE: Okay. Thank you. >>>OPERATOR: Currently there are no questions. >>>FELIPE: I don't know if that's good or bad, but we'll carry on. If anyone thinks of any other questions concerning assurances part one, we'll be happy to entertain those questions at any point. We'll have several opportunities for questions. I'd like to move on to section -- part two, the narrative. This is really where the nitty-gritty is -- where all the essential information about your plans 16 are. First I want to point out the upper right-hand corner where you indicate the name of the state. Sometimes the most obvious things are the first things we omit. That's the only reason I'm bringing that up. Section 1 of the narrative are the goals, objectives, and activities. As I mentioned earlier, the SPIL is the blueprint or strategic plan for all IL services and activities in your state for the next three years. 2008 to 2010. It outlines where you want the IL program to go. From point A to point B. How individuals with disabilities will be better off three years from now. The goals and mission section, which is 1.1 below, describes what you want point B to look like for individuals with disabilities. The objectives, which is 1.2, describes how your state will get to point B. The objectives are basically the road map and milestones that lead your state from point A to point B. So the goal is an a statement -- you might want to say to 17 improve the lives of individuals with disabilities by improving transportation, technology -- that would be a broad statement. The objectives would provide more detail -- if the goal talks about transportation, talks about technology and appropriate health care, then the objectives will have specific interim goals or activities leading towards those overall goals. Now I'd like to get into more detail about goals and objectives. Regarding goals. 1.1. States have lots of flexibility with regard to the goals. We do not provide any specific guidance as to what the goals should be. However, the law and the regulations require a couple of things regarding your statement of goals. First that it has to -- the goals have to address both the SILS and the CIL programs. When I say SILS I mean the state independent living services program, and that SILS program is mostly part B funds. And then the CIL program, Centers for Independent Living 18 program, includes mostly the part C. So it should encompass part B and part C aspects of your IL programs. With regard to the SILS, the SILS portion of the plan, it should also include -- or should address the goals or objectives of the state agency for individuals who are blind as they relate to the part of the SPIL administered by that agency. This does not refer to the older blind program itself. This refers to cases where, again -- where a state might have a separate blind agency for VR and another separate general agency for VR. The blind and general agency are partners in developing the SPIL so it should reflect both agencies. It's not related to the older blind program in this part here because the SPIL relates to the goals under chapter 1, not chapter 2 which is the older blind program. Okay. 1.2, objectives. Again, we give the states tremendous flexibility regarding SPIL objectives, but the law does require that your description of the 19 objectives include the following elements: First, a time frame for completing each objective. And two, a financial plan for achieving the objective. That is that you are ensuring there will be funding for the achievement of these objectives. We'll describe more about this when we discuss section 1.3, which is the financial plan for the SPIL. The other thing that the law requires that the objectives address is that it include a plan for outreach to underserve or unserved population. This would -- could include minority groups and urban and rural population. Although not required by law, RSA does expect that the objectives be measurable to the extent possible with outcomes-based indicators. This is as opposed to process or output-based objectives. By outcome-based objectives, we mean objectives that describe the end result for consumers. Output objectives relate more to the means or to the end -- the process that 20 would lead to the overall objective for the consumer. I'll be happy to describe this in more detail if you'd like me to during the question and answer session. Also, we recommend as appropriate that the objectives include the major supporting activities leading to the objectives achievement as well as the assignments or the lead roles for each objective or even activities so that everyone knows clearly -- when I say everyone I mean the major entities, major players -- the DSU, SILC and SILS. So that they know what goals or activities or objectives they're most responsible for and so that they know and they're held accountable but also that the others may collaborate with the lead entity. Section 1.2 A talks about the outreach plan, which is required to also -- the outreach plan must address three elements: One, the populations to be targeted for outreach, the geographic areas -- that is, the communities in 21 which the targeted populations reside -- and three, a plan to address the needs of individuals with significant disabilities from minority group background. Please note the distinction between populations and geographic areas. Both need to be addressed. Okay. 1.3, financial plan. The financial plan is the summary of the anticipated -- I want to focus on the word "anticipated" sources, amount, and uses of all funds available in the state to support the SPIL. Anticipated funding means expected or secured funding. It does not include funding that you hope to achieve. That is, that you will strive to secure during the next three years. If more -- we're talking about more -- closer to what one might describe as money in the bank. There are some -- if there are some other funding sources you're going to strive to secure, you wouldn't put it in the SPIL at this point. But if some of these additional fundings do become available or materialize, you 22 may submit a SPIL amendment. The next point I'd like to discuss regarding the financial plan is that we are providing for the first time a financial table. Maybe you can take a quick glance at the financial table, which is part of the next page. The purpose of the financial table is to provide guidance to all the states as to what is the information that we're looking for. In the past it was very hard for the states to know what we were looking for without precise guidance. The table includes actual grant funds, includes program income as well as pass through funds. But it does not include in-kind resources. The in-kind resources will be described in the financial plan narrative in section 1.3 B. Now, I want to pause for a second and speak to our operator because I'm hearing some static here and I'm wondering if that's affecting our participants. >>>OPERATOR: I was hearing it too, sir. Give me one moment and I'll 23 pull you out of the conference. >>>FELIPE: Should I pause? >>>OPERATOR: You're in the main conference again, sir. >>>FELIPE: Excuse the interruption. I guess it was my cell phone. I will continue. I hope you are looking at the financial table as I speak. If you notice, there are three tables -- one covering each years one, two, and three of the SPIL. For each funding source please provide -- the rows are the funding sources. Please provide the estimated dollar amounts anticipated for each of the applicable uses. The uses would be the four columns -- SILC resource plan, IL services, general CIL operation, and other CIL activities. To the extent possible, include applicable information from the Centers for Independent Living. Feel free to insert extra rows if you have additional sources to describe. Under nonfederal funds you see we have state funds as a row. For example you might want to include 24 what your state matching funds would be versus state funds coming from other sources like legislation, et cetera. More about this later. Okay. I want to continue down here regarding the financial resource plan. The SPIL instructions provide more examples about the different funding sources, but I would like to highlight a few things. First, regarding chapter 2 older blind funds, such funds, older blind funds, are to be included in the financial plan table only if the older blind grantee or agency authorizes the use of any portion of the older blind funding specifically for the achievement of a SPIL objective described in section 1.2. If not, we do not need you to include anything under -- for chapter 2 older blind. We're not looking for the total amount that RSA is providing for the older blind program, only that amount that may or may not be contributed towards the achievement of a SPIL objective. And I'll give you an example 25 of how older blind program dollars could be used to further a SPIL objective. For example, if an objective -- I'll read an objective that would apply to chapter 2. Chapter -- this is an objective that I just made up, that we made up here. Chapter 2 funds will support SPIL objective number 2, increased outreach to older individuals who are blind. And that could be -- for example, if the SPIL identifies an underserved population to be individuals who are 55 and older and maybe the older blind program dollars might want to give money to Centers for Independent Living so that they can increase their outreach effort to that population. That would be a SPIL objective that would have a direct impact on older blind program and the older blind program may wish to contribute to that goal or objective. That's one example. Another point I'd like to bring up regarding funding sources is, as I mentioned earlier, state government 26 funds could include, may include the state IL matching funds, could include general revenue funds, or funds made available through other state programs such as medicaid reimbursement, aging and developmental disabilities council. Whatever sources the state might provide. These would be funding sources -- again, not in-kind sources, in-kind resources will be described later. Okay. Now I would like to highlight a few items regarding possible uses of funds as they appear in the financial plan table. Regarding the first column, the SILC resource plan. The SILC resource plan reflects funding made available to the SILC for carrying out the functions of the SILC outlined in section 705 C of the act. SILC resource -- the SILC resource plan will be addressed in greater detail when we get to section 5. The other column in the financial plan table that I would like to discuss briefly is the column entitled "other SPIL activities." This column includes those 27 activities that support the SPIL objectives that are not part of the SILC resource plan, IL services, or general CIL operations. This anything in addition to or aside from the (indiscernible) IL services and general CIL operations. This column of CIL activities can include any of the activities or a lot of activities in section 13 of the law entitled authorized uses funds. This section includes studies or analysis, developing model policies and procedures, developing procedures to policy makers, includes training to individuals with disabilities, outreach to populations underserved. I suggest you look at this in greater detail with regard to that column, other SPIL activities. I'm moving over now to 1.3 B. This is the financial plan narrative. Let's see. 1.3 B. It says specify how part B, part C, and chapter 2 older blind funds, if applicable, will further the SPIL objectives. A few minutes ago I provided one example of how chapter 2 28 funds could be used to support the achievement of a SPIL objective. Well, the financial table would only include the dollar amount. Here in 1.3 B 1 you would describe what that objective is and how part B dollars -- or chapter 2 dollars would be used for that objective. Same thing with part C, describe how part C dollars, if any, will be used to further a specific SPIL objective. Here you would describe any part C funds that would be used by the centers in a way that is different from what centers do anyways. So for example, one example of how part C funds could be used to support a CIL objective would be if the objective were to increase outreach and use transition and increase resource activities to obtain nontitle 7 sources of funding. If the goal were to find new sources of money in support of the SPIL -- part C dollars could perhaps be pooled to hire a resource developer to find new sources of funds for centers. That's one 29 example. There may be many more that you may have already thought of. Item 1.3 B (2) refers to the coordination of federal and state funding for centers and IL services. This could include for example -- it could include pooling resources or funds for the expansion of network of centers or for conducting outreach centers so federal and state dollars are pooled together. So here you would describe such ideas. In any event if you have anything under 1.3 B please specify the amounts, sources, and purposes of the funding to be coordinated. Okay. 1.3 B (3) refer to the in-kind resources that I mentioned multiple times. 1.3 B (4) would be any other information that would be useful. For example, you may include more details about the funding sources and uses identified in the table. So if you say state funds you might describe what kind of state funds or other federal funds -- describe specifically what other 30 federal sources. You might also describe any cooperative agreements you might have between, say, the state IL program and the council on development of disabilities. Or if you are anticipating the possibility of new circumstances in the future that might affect your financial plan sometime during the next three years you could describe that here. I think this is afterall -- all this talk about money and stuff like that, I think this might be a good point to pause for questions. I'm ready to entertain any of your questions. Crystal? >>>OPERATOR: Simply press star one on your telephone key pad. It will be a moment while I compile the roster. >>>SHARON: I have several e-mail questions. >>>FELIPE: . Okay. Let's hear them. >>>SHARON: This is from south earn CIL. The question is do residency 31 requirements permit services to aliens, legal or otherwise? >>>FELIPE: Well, that question came up in the first -- May the 10th. What I said then and will repeat now is that we will look at that question carefully from a legal point of view and provide a response soon. And we will also -- we also plan to send an e-mail -- kind of a follow-up e-mail to everyone listing some of the highlights of this training and some of the points that came up, and we might include a response to that question in that e-mail. So I ask the person who asked the question to give us time to provide a comprehensive and absolutely correct and uniform response for that question. >>>SHARON: Thank you. This is regarding section 1.3 A. >>>FELIPE: Okay. Let me turn to that. You can continue with the question. >>>SHARON: There should be two DSU columns if two DSUs are 32 involved to separate out what each gets in IL funding. Can we amend the table for this? This is from Iowa. >>>FELIPE: That's a good question. The question is, if a state has two agencies, the blind and the general agency, where this could be broken out so that you can describe what each individual agency is providing and for what purposes, I say you can. You can add a row. You can add a row -- there are two things you could do. You can add a row and put part B and specify the two agencies. Or you could also -- this might be a better way -- to include in the narrative, you know, the details about what each of the agencies is providing and for what purposes. The reason I recommend that option is in order to keep the tables as uniform as possible. But if you have any -- if you want to discuss it further, feel free to send me an e-mail. I guess this is a good opportunity for me to provide any e-mail to all of you. 33 That is as follows: FELIPE.LULLI@ed.gov. Just bare with us. We're doing a lot of reviews of centers of independent living and state programs. We're doing a lot of travel but will endeavor to answer your questions as soon as possible. >>>SHARON: I have a couple more. This is from someone in the Midwest. Would you please again cover the purposes of SILCs. In our state the SILC wants to take on a role of monitoring centers. This seems to be outside the scope of the responsibility of the SILC. >>>FELIPE: Okay. That's an excellent question and actually the participant in anticipating my spiel here. I was going to get to that part later. But I think it's not unreasonable to answer the question now. I'm going to find the exact reference -- I'm going to read what the regulation says -- say. It won't take me long at all. 21 C, I believe -- no. It's -- for those who want to look it up -- 34 we encourage you to look it up. It's a very important part of the SPIL. 364.21 g. This lists five duties -- one to jointly develop and sign in conjunction with the DSUs the state plan required by section 704 of the act. Two, monitor, review, and evaluate the implementation of the state plan. Three, coordinate activities with the state rehabilitation council and other councils that address the needs of specific disability populations and issues. Four, to ensure that all regularly scheduled meetings are open to the public and advanced notice is provided. Five, submit to the secretary all periodic -- let me try that again. Submit to the secretary all periodic reports as the secretary may request and afford access to all records as the secretary finds necessary. Periodic reports refers to the 704 (a) report. These are the only duties currently authorized with federal funds. There is -- there has been some discussion about the possibility of expanding these duties when the Rehab 35 Act is authorized or reauthorized. But as of now these are the duties. As Mr. Kelley mentioned earlier in the overview, the success of the SPIL will depend on each of the major entities -- DSU, SILC, and SILS, understanding what their roles and responsibilities are and are not so they can work together towards common goals and objectives. As the person asking the question suggests, monitoring SILS is not one of the SILC's responsibilities. However, as we'll discuss later, the SILC and the DSU have a role in assuring that the service providers are meeting the requirements, and that's something I want to discuss separately. But let's hold that thought, and I want to thank the person who e-mailed the question for that question. >>>SHARON: Crystal, is there anyone on the teleconference. >>>OPERATOR: Yes. This comes from Robert. >>>CALLER: My question is 36 actually -- I would like you to talk more about the measurability of objectives and describe how you see that working with the SPIL. >>>FELIPE: Do you want to give me an example? >>>CALLER: You mentioned that you were looking for -- I'm looking at my notes. End results for the consumer. If you could describe perhaps in greater detail what you mean by that. >>>FELIPE: Okay. Now, first thing I want to say is that in many cases you won't be able to come up with a measurable objective because of the nature of the objective. So we understand that, but it might be possible in some cases. Let me see if I can think of an objective. Well, let's say if transportation is an issue in many places, many states, many communities. Let's say the state decides to make access to transportation one of the objectives. And let's say you have 20 major 37 communities served by the independent living programs. You might say to achieve -- no. To achieve or to work -- okay. Let's say the objective would be to obtain transit services for individuals with significant disabilities in two of the 20 communities in the state. That's just one example. Did I help you with that question? Are you still on the line? >>>CALLER: Yes. That gives me what I needed. Thank you. >>>FELIPE: You have perfect freedom to come up with the objectives and decide what is and is not realistic. The important thing is that both the state -- well, the state, especially the SILC. That's the main role of the SILC to evaluate the implementation of the SPIL and to the extent you don't have measurable objectives, then it's hard to determine whether -- how the SPIL is going, how well the SPIL is being implemented. So it's kind of a practical issue. Any other questions? 38 >>>OPERATOR: Yes. The next question comes from amy. >>>CALLER: I was going to ask almost the same question that was just asked. So thank you for answering that question about the measurable objectives. >>>FELIPE: Okay. Great. >>>OPERATOR: The next question comes from Maurice. >>>CALLER: Hi. I can't remember which section it was in. If it was the assurances or the narrative. When you talked about eligibility requirements as it pertains to Centers for Independent Living and the person has to be present in the state our CIL network and planning committee discussed what happens when people are not eligible for services because they live outside the service area. They're eligible because they're in the state but they're not eligible because they don't live in that county. >>>FELIPE: Okay. That's a good 39 question. The basic idea is that -- we don't want to turn anybody away. Okay. So let's say somebody calls your center, he or she calls from outside your service area. If that person is seeking information for referral services you would provide that service. If they're asking something that requires a consumer service record, more of a relationship, then it would make sense for you to refer that person to a center that is in that area. >>>CALLER: We have 13 unserved counties in your state. >>>FELIPE: Now, the question then becomes -- some states use part B dollars or state dollars to administer their own program. So in those cases you might want to refer the individual to the State agency, but where that's not possible, it's really up to the centers, what it can or can't do. We can't require you to serve the individual, but we encourage you to do whatever you can to serve the individual, and what that 40 might be varies from state to state. >>>CALLER: What the centers were concerned about was that are you looking in the SPIL to see a policy or procedure when the federal funds state they can only be used to serve the people in the county that you're receiving funding to serve but someone is requesting services or direct advocacy skills training which you can't provide because they're outside of your service area. >>>FELIPE: The service grant agreement with us is specific to the service area. So we would hold the center accountable for individuals who are in that service area. So I don't know if I'm answering your question. >>>CALLER: I'm having a hard time making it clear because it's one of the assurances in the SPIL that says you'll provide IL services to people, you know, as long as they meet eligibility requirements but part of the eligibility requirement is a geographic location. 41 We want to look for the phrasing that says, yes, the centers provide services where required in keeping with the rules and regulations. >>>FELIPE: Okay. What I would do to that -- what I would do -- that's a very important point. And what I would recommend is that when you get to that point -- because that issue comes up in the assurances part one, but it also comes up in the narrative where you actually describe how you will assure. What I would suggest is that you describe what the State intends to do, what the policy -- what you want the SILS and the SILC on the issue decide will be the policy and the limitations of that. And we, RSA, will look at all the SPILs and provide feedback back to you so if the description you make doesn't quite meet the requirement, we'll point it out to you. At the same time, provide further clarification in your particular case. Or whatever you say might be approvable as-is. 42 >>>CALLER: Okay. Great. >>>FELIPE: That's what I recommend. Because once we receive the SPIL, it's not the end of the story because we'll look at each SPIL and in many cases we'll get back to the DSU and SILC of that state and maybe recommend things or we might have questions or things of that nature. We will work closely with the state to make sure that the SPIL is approvable and that we can continue on with the grants for the future. >>>CALLER: Sounds good. >>>FELIPE: Thank you. >>>OPERATOR: There are currently no more questions on the phone line, sir. >>>FELIPE: Okay. Should we all take a big deep breath and continue on. Nobody said no, so I'm going to continue. You're a captive audience. I can't hear what you're saying now, so I'm going to continue. Okay. So let's pick up on 1.4. 1.4 is 43 compatibility of the SPIL with chapter 1 of title 7 and compatibility with the SILC resource plan. Okay? 1.4 A relates to compatibility with chapter 1 of title 7. The purpose of title -- of chapter 1 title 7 appears in section 701 of the act. So we recommend that when you answer this question you answer with 701 -- purpose 701 clearly in mind. So respond to 701 basically. Show how your SPIL relates to 701 or is compatible with 701. But it's a long section. I want to highlight a few key words and phrases. Talking about the purpose is to promote a philosophy of independent living. One thing. And it defines what the philosophy is. Then it goes on to say "in order to maximize the leadership, empowerment, independence, and productivity, and integration and full inclusion of people with disabilities into the main stream of American society." That's the core purpose, and this purpose is accomplished by providing financial assistance to states, providing, 44 expanding, and improving independent living services, providing financial services to support and develop a statewide network of centers and three providing financial assistance for improving working relationships between state independent living program, Centers for Independent Living, SILCs, state VR program, state supported employment program, client assistance programs, and other programs under this -- you know, the Rehab Act and other programs funded by other federal laws or even nonfederal sources. So this is a great statement and to the extent possible the SPIL should reflect this section 701 from the act. With regard to the SILS, the work plan, I want to highlight the following. This is 1.4 B. The plan must describe how the DSU and the SILC considered and incorporated where appropriate the priorities and objectives established by the centers. This is not a new requirement of federal law or 45 regulations. I don't think it was in the previous SPIL, but it does not mean we're changing our policy. It's an existing policy. The most logical place in which the SILC work plans would be incorporated in the SPIL is in the objectives and supporting activities. For example, transportation, housing, nursing home transition, underserved areas. These are examples of activities where SILS would be very much involved. Another way in which SILC work plans would be incorporated in this SPIL would be in identifying the comprehensive needs for IL in the state community by community. So -- but the key thing is you need to describe how the DSU -- kind of the process that the DSU and the SILC followed to understand the SILC work plans, to consider the SILC work plans, and where appropriate to incorporate the SILC work plans into the SPIL. So we're requiring no mandate as to things you have to include. We want to ensure 46 there's a process for incorporating the work plans. 1.5. It asks you in 1.5, please be sure to identify the entities with which you'll work in the context of the SPIL, including the SILC, the center, DSU, other state agencies, other councils, public and private entities. Try to be as specific as you can and describe the entities but also describe how you plan to work together. 1.6 is coordination of services. You know, as first blush -- let me continue with coordination of services, 1.6. You notice in 1.6 how they're very specific descriptions of who the services have to be coordinated with. It talks about the older blind program in the first chapter. It talks about other entities that provide IL or VR related services, and then it includes for example state and local agencies administering special education, vocational education, development disabilities, public health, mental health, housing , transportation, 47 veterans programs, social security. So coordination of services could be very broad, very broad depending on what your plan is. I want to point out that at first blush it may appear that 1.5 and 1.6 is asking for the same thing, but if -- they're not. The big difference is that 1.5 deals mostly with the big picture, kind of policy-level working relationship with these entities. 1.5 is closely related to the SILC's duty, number 3, coordination with SRC and other councils. Big picture policy level. 1.6 is more at the level of services so there might be -- that's where you describe cooperative agreements for providing services -- IL/DD services -- you know, jointly. So I hope this distinction is clear. Let me move on to 1.7. 1.7, again, all you want to know is that there was a process for learning about and considering and possibly incorporating into the SPIL any new methods or approaches derived from the older blind 48 program. The key phrase here is that the DSU determines to be effective. So this section doesn't have to list any innovative approaches from the older blind program. All we need to know is a description of what the process was to learn and possibly incorporate those methods and approaches. Section 2, scope, extent, and arrangement of services. First I want to note that the State is required to provide service -- IL services in the state either directly and/or through contracts and grants. So that is a state responsibility. We're providing a table for this question about scope and extent of services. It's similar to what was there before in the previous SPIL. We don't want any numbers, any dollar figures here. All we want are check marks. Basically a check for the services that are provided. The other different between this table and the one in the old SPIL is that we broke out the DSU section into two. One would be service provided by the 49 DSU directly, and services provided by the DSU services and/or contracts or grants. That could involve centers. The third column would be services provided by the centers except those covered under the second column. So we don't want duplication here. We want to be clear about each of these three categories. All we want is a check mark, and these definitions -- you know, these services, we pull directly from the regulations as they exist now. You could argue that these are not the best definitions for IL services, but this is what we've got, so this is what we're going with. If you're not sure about what some of these categories mean, don't worry about it. Just do the best you can and if you don't know what it is, I wouldn't check it off, to be honest with you. Because what happens is this is a public document, and whatever you check off, you're accountable for providing those services. Okay. Let's move on to 2.1 B. It says 50 "describe any service provision priorities." These are the priorities. So you might list 20 -- let's say 10 services in the table but among these services, if there are any priorities, that's where you talk about which of the services are priorities. And also, priority population for these services. This is something required by law and the regulations, so please answer 2.1 B also. Okay. 2.1 C -- this may or may not apply. This applies only to those states where services are provided based on the ability of consumers to pay for the cost of services. So if the state has a financial needs test. If the state does not have a financial needs test, this should be not applicable. But if the State has a financial needs test, the SPIL needs to describe the written policies to ensure that the financial needs requirement is applied uniformly so that individuals are treated equally. And the documentation that is required by the State to -- well, to document the 51 financial needs of the individual consumers, we don't want the actual policies and procedures to be attached to the SPIL. All we need is a brief description. Whenever I say "brief description," it means you can cite the policy or procedure or the law or maybe what section the law or procedure covers this area. Maybe summarize in the sentence what it says so that we don't want maybe a paragraph -- not much more than a paragraph. Only enough for us to know that you have this requirement covered. And then when we do monitoring reviews, then we'll -- at that point we're on site, we might ask for a copy of policies, but we don't want them with the SPIL. 2.2, arrangement for State provided services. Okay. This question applies directly -- as I mentioned before, the State can provide service directly or through contracts and grants or both. To the extent the State provides services through contracts or grants, 52 those arrangements must be described here under 2.2 A. The description -- here are examples of what the description might include. You might want to include what kind of arrangement -- contract or grant? What the funding sources are for the contract or grant -- federal dollars, part B dollars, state dollars, or other services. Who do you contract with? The centers or with noncenter providers? What types of services do you contract for? Or perhaps you provide grants or contracts for the general operation of centers as opposed to general operation or you might contract with a center for the center to provide a specific service. So all these examples are things that could be included in your description. Now, again, I mentioned that the State can provide services directly or through grants/contracts. And 2.1 A specifically refers to grants or contracts. But we like for those states where this applies -- we would also like the State plan to include 53 a description of the State's IL -- the State administered IL program. So if the State does provide direct services with its own staff, State agency staff, please describe briefly that program in this section, even though it doesn't apply directly to contracts or grants, this is where you want to describe a state program. 2.2 B. This deals with -- this is basically -- needs to describe how the State ensures the definition of a person's eligibility is delegated to the centers for indent living. Describe the policy procedure, don't include a copy of it with the SPIL. Section 3, design for the statewide network of centers. 3.1 and 3.2 should be complementary of each other so that in 3.1 you describe the existing network, so you list -- for example, you list the centers, and you list what populations or geographic areas they serve. Some SPILs -- this is very helpful. It provides the counties served by each center but 54 also the population. How big is the population of individuals with disabilities in those counties? And then the flip side of that is something similar for 3.2 where you describe the areas that are not currently covered by centers for independent living or areas that are underserved. You could also describe population. You might have numbers of people who live in those counties that don't have a center. So 3.1 and 3.2 are almost like mirror imagines. One note about 3.1. The network of centers means those centers that comply with standards and assurances in 725 B and 725 C of the act. We encourage you to take a look at those. The network includes part C centers but also can include nonpart C centers. It can include for example centers that include only state funding or part B funding. As long as they come ply with section 725 B and C. One note about 3.2 is that you describe the areas not served but also the order of priority for serving these 55 areas if additional funding became available. If the state provided for funding for a new center or RSA made available more part C funds for a new center, then of all those underserved areas that you listed before, give us a priority list of where the next center would go, and then the next center after that, and so on. And it could be that you decide, well, for this underserved area we won't wait until we have enough money for a new center. If we had enough money to establish an office of an existing center, that's what we'll do. We'll work on getting an office here first, or we'll work on one person doing itinerate work in this area. These are very important sections of the SPIL because it relates to the purpose of the chapter 1 title 7 as outlined in section 701 of the act. Okay. Let me continue. All right. Section 3.3 refers to 733 states only. These are the only questions that relate -- all the other questions in 56 different ways applies to every state including 723 states. I think this is explanatory, so I'll skip over to section 4, designated state unit. Earlier I recited from the law what the responsibility of the SILC is, what the duties are. These -- I want to just quickly tell you what the DSU's required duties are. First, to receive, account for, and disburse funds received by the State under this chapter. That includes part B and well as state-matched dollars. Two, provide administrative support services for a program under part B. For 723 states that means also provide administrative support services for the part C program. Three, keep such records and afford such access to records as the commissioner finds it to be necessary with respect to the programs. And four, submit such additional information or provide such assurances as the commissioner may require with respect to the programs. So those are the duties of the DSU. 57 In 4.1, the State describes how it fulfills one of the duties. Number two, being administrative support services. So again, it is a required duty. State must provide administrative support services to the part B program. In many cases, that means supporting the SILC, but it's not necessarily supporting the SILC. It could also mean providing State staff -- State agency staff to provide IL services directly. In any event administrative support services could include providing a DSU staff person to perform administrative duties, could include office space, could include equipment or supplies. The regs also include other things such as financial and technical assistance, planning, budget development. Could include financial support including audit, personnel development and record keeping activities. Sections 5, statewide independent living council, SILC. There's a lot here. We haven't added or invented anything regarding the SILC. 58 5.1 is the resource plan. To start the discussion about the SILC resource plan, please turn to the financial plan table on page 9. Go back to that table. >>>SHARON: Excuse me. This is Sharon. There seems to be a bit of confusion for our captioner today when you're speaking. If you could enunciate the difference between a CIL, CIA and a SILC. There was some confusion in your discussion on section 1.4. >>>FELIPE: When I refer to centers of independent living -- I'll say center. Center, SILC, and DSU. >>>SHARON: Okay. >>>FELIPE: Thanks for pointing that out. If you're at the table, financial table, the first column of information is called SILC resource plan. Basic that is the SILC resource plan. The first column is the SILC resource plan. It talks about all the funding sources available to the SILC for the SILC to perform its duties. So the numbers -- 59 the dollar amounts for the SILC resource plan are already in -- on that table, so you don't have to redo that. That's taken care of. Now, when we say SILC resource plan, we do not mean SILC budget. We don't -- we're not requiring a copy of the SILC budget or even a description of the SILC budget. SILCs are expected to have budget but they're not submitted in the SPIL. RSA has an interest in the SILC budget whenever an issue comes up involving the budget and RSA is asking for technical assistance or legal opinions and so forth or when we go to a state on site to do a review, then we'll ask for the SILC budget. Okay. Okay. I'm going to continue. 5.1 A. This is a narrative, so here's where you describe any additional details about the SILC resource plan. That could include, for example, any in-kind resources, such as plant equipment or services provided to the SILC. 5.1 B describes a series of 60 resource plan requirements. These requirements are all aimed at protecting, preserving the independence of the SILC. Again, the description should be very brief. The first one is the SILC's responsibility for the proper expansion of funds and use of resources. The SILC is responsible for expanding funds properly. This is still compatible with the DSU's responsibility to account for or monitor any part B or state funds provided by the DSU to SILC. Assurance or description of how you make sure that no conditions or requirement are added to the resource plan that might compromise the independence of the SILC with regard to the DSU. Okay? 5.2 talks about the establishment and placement of the SILC. I want to describe what establishment and want placement includes. Establishment means two things. It includes how the SILC was established -- that is, by legislation or executive order. The 61 second aspect of establishment is what is the SILC's legal status? Is it a nonprofit? Is it part of the state government structure such as an independent commission. That's establishment. Placement is where the SILC has been placed, either within the state's organizational structure or outside of it as a nonprofit. Important note -- the SILC may not be established as an entity within a state agency. So if it's part of the state's structure, it has to be stand-alone. It can be a part of the VR agency or another state agency. 5.3 is the composition. Here you indicate how individuals are nominated for the SILC. How is the SILC -- how do you track the number of SILC members or people with disabilities -- how do you fill vacancies? 5.4 -- we want to make sure there's no conflict of interest. If the DSU provides a state employee to provide administrative support services, how do 62 you make sure that that individual does not have a conflict of interest -- for example if that person has a policy role with the DSU regarding IL, that would be a conflict of interest. Okay. Section 6.1 through 6.7 -- there's a whole bunch of requirements. I'm not going over all of them. What I do want to say is that these requirements, as I said earlier, apply to all recipients of funds under chapter 1, including SILS that receive part B funds -- centers that receive part C funds. Even in the case of part C centers that do not receive part C or state funds. In these sections, the state plan needs to describe what steps the DSU and the SILC have taken for them to be able to assure RSA that the requirements will be met. These steps the DSU and SILC take must conform to federal law and regulation, especially those that relate to DSU and SILC, duties under the law. For example a SILC does not have the authority to monitor SILS. The -- this 63 might include on the part of the state monitoring centers that receive part B or state funds. RSA is responsible for monitoring part C centers, though. The DSU is not responsible for monitoring centers that receive only part C funds unless centers also receive part C or state funds. So the state is responsible for accounting for and monitoring part B and state funds. Some of those centers -- they also receive part C funds. The state is responsible for monitoring those centers, but centers that receive only part C funds, it's RSA's responsibility to monitor. The question arises, how can a DSU or the SILC assure that a part C only center is meeting the requirements if the DSU is not responsible for monitoring the center? Again, great question. I want to point out that the word "assure" is very different from ensure. Assure versus ensure. Ensure with a E involves monitoring. Assure involves taking the steps necessary to have a reasonable 64 expectation that the service providers will meet the requirement. For example a state can assure that all centers are meeting the requirements by, for example, issuing standards for service providers. It could include providing technical assistance or training to all service providers on those standards. Could involve asking service providers to provide assurances to the DSU similar to what RSA requires the state to provide, just have simple assurances. Or it could include collaborating with RSA on site compliance and reviewing RSA's reports or could include all of the above or any other steps that are taken to -- for the state to feel comfortable in assuring RSA. Whatever the State does, it has to be consistent with the law -- the roles and responsibilities of the SILC and the DSU and cannot go beyond that. If a part C only center -- if RSA finds a center that receives only part C funds is not compliant with a requirement, that 65 center, not the State, is held accountable by RSA. I'm going to skip over those -- if any of you have any questions about any of those requirements in section 6, feel free to ask me after this call -- I mean, in the question/answer period or after this training. Now we're nearing the end of this discussion, and good thing because I'm beginning to run out of voice. I'm going to pause and take some water. Evaluation, section 7. Section 7 is -- has two required elements about evaluating the effectiveness of the plan. One, you know, provide -- explain what steps the SILC and DSU will take to monitor and evaluate the SPIL on the regular basis. This description must include the State's evaluation of satisfaction by individuals with the program. So it needs to have a consumer satisfaction component. The consumer satisfaction component would apply to state provided services as well 66 as CIL provided services. I want to point out that evaluation is perhaps the most important of the SILC's statutory responsibility. Section 8, state imposed condition. If the State has other requirements or conditions not required by federal law regarding -- effecting the IL program either state administered or center administered IL services, the State plan must list and describe those conditions and requirements. Examples include any state law, regulation, rule, or policy related to the administration of IL services, including -- yeah. That can include for example the financial needs test requirement that we included earlier. Okay? So I have covered most of the major points in the SPIL. I am open to questions, and ask Crystal to open up the flood gate. >>>OPERATOR: If you wish to ask a question press star one on our telephone key pad. The first question comes -- 67 >>>CALLER: Hi. I can't remember what it was I was going to ask you about. Skip me and I'll come back. >>>FELIPE: Yeah, please do. >>>CALLER: Okay. >>>OPERATOR: The next question comes from Corey. >>>CALLER: Hi. How are you? >>>FELIPE: Good. >>>CALLER: I have a question about the independent living services side when the state runs the IL program. As the whole program of SILCs has been looking at how SILCs are run -- states that run the IL services program, do you know are most of them doing it with part B money, state money -- does RSA ever give C money to a state or only to centers, thinking in terms of reporting and how that works. I'll ask the rest of my question and listen to your answer. >>>FELIPE: You said seed money? 68 >>>CALLER: C money, part C. >>>FELIPE: The answer to that is no. >>>CALLER: Most likely they're taking their chunk of B and using -- and/or state and using DSU employees to run a IL program. >>>FELIPE: Right. >>>CALLER: In order for them to use the B money their SILC has to be voting on that and putting it in their SPIL or else they have to be jointly doing that with their SILC or they wouldn't have the authority to do it. I'm asking that and I'm done now. Thanks. >>>FELIPE: Thank you. Okay. Well, you pointed out -- I think two important issues. One is that the SPIL is the result of a partnership between a DSU and the SILC. In developing the SPIL the SILC and DSU are equal partners in developing the SPIL. And the second thing is that one of the most important elements of the SPIL is how IL resources will be used to support the 69 SPIL. That would include a decision about how part B dollars will be spent. And so the allocation of how much money, you know, is going to be given -- part B or part C will be given to the SILC or the center or to administer the state program, does there need to be a process in the SPIL development process to make those decisions -- there needs to be buy in by the DSU and SILC and in deciding these important matters you need to have as much input from stake holders including centers. That's why needs assessment is so important. For example one decision you have to make is for unserved areas, what is the best way to reach unserved areas? Establish a new center with part B dollars, or is it better to have VR counselors or State agency employee counselors at every region? Most states have counselors or field officers that cover all regions of the state. It might make sense to use part B dollars to allow field officers of the states to 70 provide services in areas not covered by centers, so these are all decisions that have to be made and discussed during the development of a SPIL. And we don't give any particular guidance on this unless a legal issue comes up where we have authority to make a determination. But we like to leave it to the states. >>>CALLER: Last follow-up and I'll say good-bye. Do you think there's will within RSA -- I know we'd have to be crafty in how we do the language but do you think there's the will to give the designated -- >>>FELIPE: Could you repeat that question again. >>>CALLER: Do you think there's a will within RSA to give CILs sign off by having their representative -- have sign off, that way truly having all three partners -- >>>FELIPE: That's not something we can decide on. >>>CALLER: I know you can't, but 71 I'm saying something to kick around and have, you know, the legislators always want to know -- it's something to talk about and if you guys have any internal -- >>>FELIPE: That's beyond what we've been discussing or considering. The SILC makes a unified decision, however the SILC by-laws determine that the decisions are made. Once the SILC makes the decision all members pretty much are in agreement even if it's not a -- if the SILC signs something that it has won approval of the SILC as a unit and the unit would include the SILC representative. We can't go beyond that. That could be a reasonable policy decision that the State makes. That's something beyond our control. >>>OPERATOR: Next question comes from Mr. Coal. >>>CALLER: Hello. Can the State make a change -- can we provide a grant to the SILC and let the SILC provide grants to other entities, part B 72 grant, and the SILC provide grants to other entities like CILs and other entities that provide IL components. >>>FELIPE: That's a very good question. The answer to your question is that the SILC is not authorized to make grants. Only the DSU has the legal authority to receive, disburse, and account for part B or state matching funds. So in terms of title 7, the State disburses funds. Now, the SILC can -- has a voice -- you know, in recommending how funds the disbursed, but it's ultimately the State's responsibility to disburse those funds. Did that answer your question? >>>CALLER: Yes. I think it did. We're just trying to give autonomy to our SILC and if we're in violation, that's one thing, but I think it's important for SILCs to have more autonomy and Tennessee is pursuing that, so I think that's one of the things that maybe RSA may take a look at. >>>FELIPE: We definitely want to 73 preserve the autonomy of the SILC but within the context of the statutory roles and responsibilities. >>>CALLER: I understand. >>>FELIPE: If any particular issues or questions come up, we'd be happy to address those questions. If a question comes up that involves the DSU and the SILC what we recommend is that any inquiries you send to us, which would be by e-mail, be sent by both the DSU and the SILC just so that if the question is what both want to find out and so that there's no misunderstanding and so when the answer comes to both there's no misunderstanding. >>>CALLER: I have one additional question and it was concerning the conflict of interest. >>>FELIPE: Okay. >>>CALLER: You mentioned if a DSU member was in a IL policy role and say that member was also the liaison of the SILC, that may be a conflict of 74 interest. >>>FELIPE: That wouldn't be a conflict of interest. The conflict of interest refer to administrative support services so that if the State provides a State staff person to provide administrative duties in support of the SILC, that's different from being a liaison to the SILC. Somebody providing -- writing minutes or sending out announcements of meetings. If that person is helping in that capacity and is also a decision making or close to the decision making, that's where the conflict of interest could appear. The DSU official member on the SILC may have a policy making role and that's perfectly appropriate because that person would represent the interest of the DSU. So the distinction is between a member and someone providing administrative support services. >>>CALLER: Okay. That's all I had. >>>FELIPE: Great. Good 75 questions. >>>CALLER: Thank you. >>>OPERATOR: Next question. You have the floor, ma'am. >>>CALLER: Hi. I remembered my question. You were talking about the resource plans for the SILC and kind of piggy-backing on Sam's question there. If the DSU had a contract -- South Carolina independent living is a 501 entity and we have a contract with our DSU, so when it says does the DSU provide the IL services through a contract and then we used part B funds to create new centers and those part B centers that use the part B money to provide the core services are providing IL services -- do we do it as the DSU or as part B services which is the SILCs. I understand our money flows through the DSU and they're accountable for the disbursement of fund but our council has the authority to say this is what we want to do with our part B funding. I want to make sure I fill out the chart 76 properly. >>>FELIPE: Do you run a center? >>>CALLER: I'm a SILC, independent living council. >>>FELIPE: Okay. So let's see, a center receives a contract -- >>>CALLER: Well, our council is a contract with a DSU so we can receive our funding through the DSU. >>>FELIPE: Where do the centers come into play. >>>CALLER: Our council funds part B center. >>>FELIPE: An earlier question -- the council does not disburse the funds. So the council and the DSU together decide how part B funds are going to be used over the next three years. >>>CALLER: Right. >>>FELIPE: Part of that decision making, the decision is made that a certain portion of the funds will be to establish a new center -- it goes to the center not the SILC. Do you see what I'm saying? If the State provides a 77 contract with the center, then that amount -- that fact is reflected -- which table are you talking about? Financial or services? >>>CALLER: Which services are provided -- >>>FELIPE: Okay. There -- see, in that case it would be either -- >>>CALLER: The center one, provided by -- >>>FELIPE: , yes, that one. You put it there. That's money disbursed by the state. >>>CALLER: Okay. >>>FELIPE: Okay? >>>CALLER: Thank you. >>>FELIPE: All right. Anymore questions? >>>OPERATOR: Next question comes from brad. You have the floor, sir. >>>CALLER: Hi. I have a quick question regarding -- if you could explain a little more the difference between 5.1 the resource plan and then I believe it's 78 the financial plan that's referred to earlier in the preprint. A little more about what you're looking for and how that differs from the financial plan. >>>FELIPE: Okay. 5.1 you mean? 5.1 is the SILC resource plan, as you pointed out. Under 5.1 we don't want -- we don't need anymore tables or anymore dollar figures, really. >>>CALLER: Okay. >>>FELIPE: Because that's already laid out on the second column of the financial plan table. >>>CALLER: Okay. >>>FELIPE: So the section in 5.1 dealing with the resource plan are mostly narrative responses. Is that clear? >>>CALLER: Yes, that is very clear. Thank you. >>>FELIPE: Great. Any other questions by phone or e-mail? >>>SHARON: We have a few e-mail questions. 79 >>>FELIPE: We have about five minutes more to answer questions. >>>SHARON: I have about ten minutes left. >>>FELIPE: Right. We're going to cover closing thoughts and operator instruction. I want to make sure we cover those. Now, the SPIL submittal instructions -- I'm going to -- we already had all the details about the submittal instructions. I don't think -- I think in the interest of time we won't have a discussion about that. However, if anyone has questions about submittal, you know, feel free to share them with us now or after the call is over by e-mail. I hope that's okay with everybody. It's due July 1st and can be submitted by e-mail as well as hard copy and also the option to submit on line. I'll be happy to answer anymore questions about that. Let's go on to the questions. >>>SHARON: This comes from the Midwest. In some cases the SILC and individual 80 center may not be in alignment about overall goals. An individual center may believe its objectives are pertinent. If agreement is not achieved, how does this affect plans of the individual center? >>>FELIPE: Well, the center has autonomy in its work plan. The center responds to community priorities. The State cannot dictate to the centers what it has to do to serve its serve area. That decision is made by the centers board of directors. In terms of consistency with the SPIL, the SILC work plans need to be compatible with the purpose of title 7. You know, in particular, section 701. As long as a SILC work plan is con sis at the present time with that, the CIL is okay. Can't be forced to do anything different. But needs to be con sis sent with 701. Some may involve CIL input and CIL activities but the SILC needs to be willing to be committed to those objectives and activities. Doesn't have to. The requirement is that the SILC work plans are incorporated or at least 81 considered but there's no requirement as to how those CIL work plans are incorporated or considered. Again, going back to the earlier point, which is the most important point I can share with you all, is that the DSU, the SILC, and the centers need to be clear as to what their roles and responsibilities are and are not. That's why I read the portions of the law that refer to the SILC roles and duties and the DSU's roles and duties. Whatever is in the SPIL must be able to be related to those specific duties in some way or fashion. We're getting into some questions that might be -- you know, these are fine. I'll give general responses, but if the issues still continue, that's when we need to receive queries in writing by e-mail so we can answer them on a case-by-case basis. I'm trying to give you my best uniform applicable answer. >>>SHARON: Would we list part B dollars for general operation under the other SPIL activities? 82 >>>FELIPE: Okay. Part B dollars for general operation? I would not put it under that -- under other SPIL activities. That would go under the second to last column, general CIL operation. I hope I'm answering the right question. >>>SHARON: I think that's right. >>>FELIPE: I think we have to move on just because we're nearing the end of our call. I love these questions. If there are many questions, feel free to e-mail me. >>>SHARON: Can you repeat the e-mail? >>>FELIPE: . It's felipe.lulli@ed.gov. >>>SHARON: Thanks. >>>FELIPE: All right. Okay. So we'll go on. Mr. Kelley is going to give us closing thoughts, and then I believe Sharon will have the last word. Here we go. >>>THOMAS: Thank you. Just a few comments to keep in mind, and that is it should, in the event or should the 83 Rehab Act be reauthorized and should it substantially affect the SPIL, the states certainly may submit amendments to comply with anything that is required in the new bill. For instance, if the law were to expand the number of core services or anything like that. Amendments are required in the case of any significant and relative change in the operations or the information or the assurances of the plan. In the administration or operation of the plan or in the organization policies or operation of the state agency that receive the grant if the change materially affects the information or assurance ins the SPIL. Also, the SPIL is subject to amendment if the commissioner determines an amendment is essential during the three year effective plan period. If the State amends the SPIL it will use the same procedures it is required to develop the original SPIL, including the requirements for public hearing. In relation to our continuous State 84 monitoring and program improvement process here in RSA, the revised SPIL is designed to support RSA's increased monitoring program improvement and technical assistance activities involving the DSU, SILC and CIL. RSA will used the improved SPIL as a starting point for dialogue as part of the on going monitoring and program improving measures including on site review. RSA may request additional information as necessary to provide appropriate responses to specific monitoring and technical assistance issues that arise in the period by the approved SPIL. I just want to take a moment to thank Felipe for his work and to compliment him on the presentation. Thanks so much. >>>SHARON: Thank you both. The presentation today was excellent. We will archive this on ILRU website at www.ILRU.org. The IL NET and ILRU have been pleased to host this presentation. This training was sponsored and presented by the 85 Rehabilitation Services Administration, your sponsor host for today. Also we'd like to thank the technical support team that put this together -- Marj Gordon, Dawn Heinsohn, Maria Del Bosque, Rob Dickehuth and our captioner, Jennifer Myers. Thank you for joining us and have a great day.