KATHIE KNOBLE-IVERSON: We're going to try to get started. We have a lot of sticky notes last night to take a look at and we have some questions we want to respond to right off the bat. Richard, do you want to do yours first or do you want me to go ahead? Richard's going to start with his question. DENNIS FITZGIBBONS: Den in this case. KATHIE KNOBLE-IVERSON: Dennis. Excuse me. I'm looking right at you, calling you Richard. DENNIS FITZGIBBONS: How we doing? Good morning, everybody. Hope everyone slept well and had a good evening. One of the sticky notes I have here was a question, what are best practices for a CIL to get multiple satellite offices engaged in planning groups, such as committees and trainings, specifically to address mission drift and global-disability related issues. That's a great question. And I wish I had an answer. Just kidding. I have our answer from Alpha One. We have had to address this because our two furthest offices are five hours away from each other. So that's a significant distance to have staff be able to see each other on a regular basis. The way we addressed that is multiple in nature. Every Monday morning, all of our independent living specialists throughout the state are on the telephone, at nine in the morning to get the week started by addressing the issues of the previous week and what's going on in the coming week, it's used for training purposes at times, informational purposes, gets people up to date. It's a teleconference setting, but we also have the Skype capacity between offices through our network and it's a good way of bridging that gap of distance. We also will do in-person training of all the independent living specialists in a central location from time to time so that everybody can see each other in person and have that up close and personal type of approach to things. Another thing we do to address that distance that really does create some issues in communication sometimes is that we share responsibilities across the company. So what we do is we appoint people as point persons for a particular program or service they then become the sort of intake person, no matter where they are in the state for a particular program and they're responsible for the intake and then assigning new consumers to a person in whatever region they need to be assigned to a particular person there. They become the point of contact with the contracting organization or entity and they start to learn some managerial skills by doing that type of thing, helps them lift up some of their own skills, if they're interested in doing this. So they gain some experience, they gain some knowledge and they become the real expert on that particular program or service. And we have, every year, an annual two-day, all staff meeting, where we bring everybody together, no matter what they do for the organization and we develop a pretty tight two-day agenda of things that we're going to address, so lots of ways to get people informed and keep them informed. We're members of NCIL, we get the e-mail occasionally from NCIL about news at the national level that is shared company wide. I'll occasionally send internal messages by e-mail about what's going on at state capitol, with legislation, things like that. So we do our best to try to keep people informed and we also put the expectation on our branch offices that they are the ones who have to have their ear to the ground where they work and live so that they keep us informed on the issues on a state-wide basis. So it's sort of sharing responsibility for making sure we know what's going on. And we will bring training to different parts of the state instead of expecting them to come to us at times and lastly, we look at the independent living specialist as a business unit within the organization. We appoint people to be business unit leaders. They rotate from year to year. They schedule unit goals and objectives, regular meetings and identify training needs that are then addressed by the business unit. So there's lots of ways of doing those kind of things to keep people informed but it is always a challenge and requires great communication. KATHIE KNOBLE-IVERSON: One other thing we do is if a satellite office calls, that call gets dealt with. I don't care what the issue, if it's a simple answer or if it's a crisis they're going on. We have an agency commitment to answer that call. Because they're not like the rest. They can't walk down the hall and get the support they need. I think that's really helpful. Richard, did you want to go next or can I answer my Okay. We had a group of questions around contracts and fee-for-service. One of the questions was particular sources of income. And I think you all got that handout at the end of the day. If that wasn't helpful, we're going to talk more about resources today. So I'm hoping that we can answer those in our presentation. But the other was about contracts. And we, again, are going to deal with contracts today, but there was a really good question about the difference between a contract for a service and a contract for a fee-for-service. And I want to try to distinguish that quickly. And I'm going to use an example. You might get a contract for a service, which is $50,000 to put towards the budget of your mental health drop-in center. That is going to get given to you, either you might get the whole check, probably not. You might get it reimbursed 1/12th or you might get it based on the actual expenses that you incur during the month. And that contract should have some language in there about their expectations, what they expect for that $50,000. You can also have a contract, I will use an example with DVR, division of voc rehab for assistive technology assessments. And that's referral-based. You have no control over how many referrals you get and you sit and wait, pretty much. You can do some outreach, but it's more likely that it's totally referral-based, you've established a rate of reimbursement and the contract should tell you, it should have an attachment, because in our state, all the DVR contracts are the same and then there's an attachment that's very specific to the service they're going to purchase from you. Expectations should be there, what kind of documentation, how much time there should happen between your first contact and the end result, whatever that report, those sorts of things should all be in there, when you can get paid, whether you have to meet with someone prior to getting paid. All of that. So that's the difference. And there's lots of different kinds of contracts and we're going to talk about some of those today. Then one other question was about capacity. When is it, there was two questions. When would you know when to add staff and when was it okay to not take referrals? And this is going to be so individualized. If you're talking about fee-for-service, and that's what I'm going to talk about. I'm not going to talk about IL funds. You have to figure out how much it costs to add a staff person and you have to figure out when is it going to be too much? And I'm going to use assistive technology assessments again. If you're averaging six referrals a month and that's going to take, I figured out, ten and a half hours of referrals. It's 63 hours. It's about 36 percent of a full-time staff person. That's getting tied up. Initially, that person could be funded by your state IL money, agency money, however you decide to fund them. You could have startup money, whatever that is. You have to figure out whether you can work without that 36 percent of that staff in IL or if the money that you're going to generate, you're going to generate close to $4,000 that month. But you're not going to get paid for it for probably 90 to 120 days. So you have to figure out when is it too much for us to have that person working 63 hours a month on assistive technology assessments. And you have to figure out how much, how you're going to pay for that person. You may be generating that money and say, okay. 36 percent of that staff's wages are going to come out of that $4,000. Then what do we have left. And that's what you would use to start to figure out, okay, I can bring a half-time person on with the money we have left. It's very individualized. Because it depends on what you pay people, what you generate, what kind of rates you're going to get from people. But you have to figure out, we're going to talk about how to figure out a rate today and you have to generate enough income so that it, you have sufficient funds. And then the, when is it okay to not take referrals? At our agency, we have a mantra. Unless it's an inappropriate referral, we do not turn down referrals. Because we don't want to set a tone that we can't. But you also don't want to do a poor job. If you don't have the capacity and you know you don't have the capacity, you have to make a decision that works for your organization. You just don't want to send out a really bad assistive technology assessment or do a really poor job with a service that you're going to provide. So you have to sort of make those decisions that work for yourself. If you truly don't have the capacity, talk to the referral source. We have said, okay, we are full. Someone's going to have to wait maybe three weeks before we can get to them. Is that okay? And it's been fine. It's just going to take longer for us to get to what, because you also, when you start doing fee-for-service, the whole IL system does not stop working. You don't stop getting I&Rs and you don't stop getting referrals for folks walking in the door who need your IL services. So you have to figure out what's going to work in your organization. And I did some examples, but if anybody still wants any clarification over break, I can help them figure some of that out. Richard? RICHARD PETTY: Okay. Let's see. I'm going to ask Tim to read the, here, just a moment I'm going to ask Tim to read the note that, where this question came from because I want to get the context exactly right. But before I do that, I also want to come back to something that Kathy said yesterday. Several of you have asked to see copies of contracts, and we can do that. It's not going to be very meaningful. Because the people, most of the time, almost always, the people who do contracts with you are like most of us. They're better at process. They're better at crossing Ts and dotting Is so they're going to make sure that you guys aren't illegal aliens, that you haven't been convicted of Medicaid fraud. They'll go down a boilerplate list of things that you have do. And Kathy said this yesterday. And when it comes to what they're actually asking you to do, she talked about how they'll tell you almost nothing. It will fall to you to make that as specific as you can because you will indeed need to know and they will need to know whether you have performed that contract according to what they really wanted. And you don't want to be in the position of guessing about what's acceptable and what's not acceptable, what's good, what's not good. So, yeah, we can provide copies, but when it's all said and done, unless you're in a very unusual circumstance, you're going to be providing the meat of that contract. And I'm sure that you could reach out to other centers, you could reach out to us and we could try to help you with some of the language if you get to that point. So that's that. Let's go ahead, and Tim, if you could read the question that we're going to try to answer here. TIM FUCHS: Sure. So it's a simple question about a complex issue. Can you use federal funds to pay staff who provide fee-for-service and generate income. RICHARD PETTY: Okay. This is, I'm going to try to do this as quickly as we can to stay within our time frame. But it is like an onion. There are several layers. And let's peel them as quickly as we can. First, you can use federal funds to generate program income. You, as a center for independent living are unique within federally funded programs in that you can do resource development and you're required to do resource development. Now, you're also required to comply with time and effort reporting requirements that are set forth in OMB circular A-122. You do that as a non-profit organization receiving federal funds. And that's something that is beyond RSA. So I believe that will preclude you from double-billing the time of an individual worker. You have to report the time of a worker that's performing work and specify the funding source that's used to support that particular part of the work. Now, it may be that through careful means, you can determine that Title VII funding can support X number of hours, X number of units of service, however you are aligning that within your organization. And so it is possible that someone might spend 40 percent of their time doing work that's funded through Title VII. And they might spend 60 percent of their time performing work that's supported from a private grant or contract, the service could be identical. And yes, you probably did use that, the time and the experience that you have as an organization to create the service that you then sell to other entities. That's part of how you developed it, because you developed it through Title VII. So you can't, again, you can't double-bill, but you can leverage Title VII dollars to do other things. Often, when something's too good to be true, it's too good to be true. And this is no exception. If you use Title VII dollars to generate any additional income that income becomes program income and you must follow the same requirements of the funding source that generated those funds. So that means you have to spend them only for the costs that are allowable under Title VII. You have to spend them within a specified time period. Usually that's within a year of the close of the program year in which the funds were generated. And that requirement continues to the conclusion of the grant which funded those services. So for example, if you received ARRA money, stimulus funds, your grants ended a certain period of time and after the close of those grants, then you don't have to, we have been told, that with, after doing some research and consulting with some non-profit experts, that after that point, you don't have to follow the program income requirements, the things that I've just described. Finally, a practice that you really will want to do and it's really important, if you have not already implemented a cost allocation plan or an indirect cost rate, we urge you to do so. Because it may well be that you will decide that you will do other activities that are not generated through Title VII but funded through separate streams and there are ways in which you can simply allocate the time and activities and if you can demonstrate that those weren't generated through Title VII, then that's an appropriate way that you're not restricted in how you use those additional funds. Long answer. I hope that helps. If we need to go further with that, we certainly can. KATHIE KNOBLE-IVERSON: And I would suggest that you talk to, all of you get audits every year? Talk to your auditors. They helped us develop our allocation plan, they monitor our allocation plan every year. They make any changes that we need. And they help us figure out some of this sort of squishy stuff around federal and state dollars. So we always pulled out all our fee-for-service and treat that as a very separate source of income and we put all the expenses that it takes to generate that money back into that cost station. That's really clean. RICHARD PETTY: Yeah. A very good practice. You may, in this day and age, you may not be able to use your auditor, A-133, that's another federal circular, requires some segregation of duties and responsibilities of the accountants who advise you from the accountants who audit you. That's a requirement for them to follow. They'll know, we hope they know, but you need to monitor it too, what's in and out of their scope of responsibility now. So proceed a little bit cautiously. KATHIE KNOBLE-IVERSON: Our auditors have two divisions. One doesn't do auditing and that's the division we deal with. RICHARD PETTY: Yeah. KATHIE KNOBLE-IVERSON: We get advice from our auditors all the time based on our previous audit. RICHARD PETTY: Right. Okay. Hope that helps. DENNIS FITZGIBBONS: We do the same as well.