PAULA MCELWEE: As I said before the break, we're going to spend a little time in the RSA compliance tool, checklist tool. Actually, we're going to do three different segments of this throughout the next couple of days, but this is the first one. We've talked about what compliance is earlier in the day, a state of being in accordance with established guidelines, specifications, or legislation, or the process of becoming in compliance. So that's the compliance side of things. And in order to be in compliance, every center has to meet a certain set of standards. Now, some of these standards are moving targets. They're changing a little as we go along. There's a couple of good examples here, as a matter of fact. But the regulations that we're bound by right now include these OMB circulars. There are three of them that apply to centers. They include a lot of the guidance around, around cost principles for any non-profit that receives federal money, as interpreted by the Department of Education, which is where we're housed. The OMB circulars apply in a broader scope, but ours are interpreted by EDGAR. Now, that's all changing. These circulars are being rolled into for a while we were calling it a super circular. Now we're calling it guidance again, is the term we're using, but there is going to be some new stuff rolling out. We can't really deal with the new stuff yet because it still hasn't been interpreted by the Department of Education, so even though we've got the crosswalk, we kind of know what areas are going to be affected, we're going to go ahead and go through this checklist from the standpoint of what's there now. We may kind of mention to you that this is an area that may or may not change. Until that is final, there doesn't seem to be a lot of percentage in dealing with it. Yeah. Maureen? AUDIENCE MEMBER: So just to clarify, Paula, are you saying -- when you're referring to compliance for this purpose, you're talking about any center that receives any federal money. If you're a center and you don't receive any money, this doesn't PAULA MCELWEE: If you're a non-profit -- some of these elements will not apply if you're a non-profit that doesn't receive any federal or state money that was passed -- federal money passed through your state, so your Part B money is still federal money, if you hear that term, Part B. If you have state money that comes from another source, that's going to be state money. Often these things also apply there, but that would be different from state to state. What we are going to do is look at the federally funded pieces so we can make sure we got that. AUDIENCE MEMBER: This is Jack again. Isn't that that they're supposed to meet certain criteria, regardless, according to the law, regardless where the money comes from? To call themselves a center for independent living? PAULA MCELWEE: We have both of them in here. We have standards and indicators that define what a center is, but they do come because of the money, so they come through the Rehab Act and the money that comes through the Rehab Act. There are other elements, though, that come because you have any federal money, not just Rehab Act money. That's true with these OMB circulars. The OMB circulars, 112, 122, 133, those are pretty easy numbers to remember; right? Those three circulars right now are what apply to anybody who gets federal money. I'm not going to go into a lot of detail on some of these financial things, but we're just going to talk about what the regs are. Now, EDGAR expands on them a little bit. That's part of the Code of Federal Regulations. Soon it's going to be updated to change. Whatever that is, though, you have to conform with your contracts. And so there are items that may show up in a federal contract that are specific or different. There may be an item that will show up in your grant award from your state that might not be federal at all, it has specific things from your state that you must adhere to. The point here is that you need to know what your regulations are and you need to know how you are meeting them as part of your foundation for quality. Most of those regulations are there for a reason, and we can't just ignore them. We have to at some point acknowledge that they're there and we're required to meet those regulations and not give up our principles in the process. Does that make sense? So these are the -- this is -- there's a graphic on the screen right now that has a pyramid structure, and the Rehabilitation Act is at the top of that pyramid. The Rehabilitation Act has a number of things in it that's mostly what the checklist is about that we're going to review. It's mostly about the content of the Rehab Act, and what is a center and what's required. There are also, the next level down tells you the reference numbers on the Code of Federal Regulations that apply to centers for independent living at this moment. Like I said, some of this is all going to change with this new guidance that's going to be coming out. And then that is interpreted by EDGAR, the Education Department's regulations, and then specific numbers are listed in the graphic. So the 34 CFR numbers 364 through 366, and a lot of times if you see a reference in a report that you get or a training like this or something else, you'll have an actual reference that will have that number, and you'll see that 34 dot 364 dot 2, or whatever, and then that will tell you that that's coming from that document. This is actually one -- one document. The OMB circulars are folded into the part of EDGAR that applies to us. You can get it in one book. It's all together. These aren't separate pieces of information that you have to pick up. It's been all folded together so that we can follow it. But these are the things that we're bound by, as well as the generally accepted accounting practices, that if you're big enough to have an audit, they're going to be checking your conformance also against auditing practices. Think in terms of grants and contracts requirements, whatever you've agreed to as part of that grant or contract, which in the case of your Rehabilitation Act funds, includes all these elements, are part of the foundation of what we must do in order to meet the bare minimum of requirements. And these are necessary in order to keep the money flowing so that you can make sure that it happens. Now, we're not going to go into detail about financial conformance today at all. The Wiki page on financial management, if you go to that Wiki page, you know what else you get there? All the videos. So we have somebody in the back of the room somebody who's doing audio, we have somebody doing video, we have C.A.R.T. folks up here doing the transcription, and when we're done, it gets put together in a package very similar to the one we showed of Bob Michaels. So you've got a caption, you've got a PowerPoint slide, and you've got a video. And the videos from that financial management training that happened in Pennsylvania last May are up on the website, and you can go and see them. And you can actually watch those videos as if you were attending the training. And they're broken up into manageable sizes. Some of them will go 45 minutes, an hour, maybe an hour and a half per topic, depending on the topic, but you can actually go and watch those videos anytime you want to. So we're not going to get into that content. We've got that content other places. And we've also got all of our resources related to this content as Tim showed you on the Wiki page. And, you know, I used to always go to the ILRU.org page, then go over, and I realized I could go to Wiki.ILRU.net and go straight to the WIKI page, save a step. If you want to bookmark both of them, you might find interesting information on both those pages, but it will take you there a little quicker. Anyway, we're not going into that content, that detail, but it's out there for you. If that's content or detail that you need where you're coming from with either your personal experience with independent living or your centers, you know, level of maturity as far as how new you are and how well you've been able to handle all this, all that content is there for you. What we are going to cover today is a little bit of how RSA looks at the issue of independent living philosophy because I think this is where the rubber meets the road for a lot of us related to how we think of quality. So we think of quality, much of it, coming out of our own history of disability rights and consumer control and some of those other principles. So we're going to look at that related to that, specifically. And as we look at the checklist that RSA has created, it's just a jumping off point of structure for the conversation. So it's not the beginning and end of the conversation, it is just a framework to give us a structure. And our purpose is not to just comply, but to exceed the requirements in those standards. So when RSA comes to your center, as they certainly will in the next five years, probably, when RSA comes to your center and takes a look at what you're doing, part of what you want to make sure you're aware of is what they're expecting, and then you are going to exceed their expectations, right, because they're also one of your customers, and you're going to do it from the basis of a sound philosophy about independent living and not from a regulatory standpoint. Two different approaches. Do you see what we mean? So let's take a look at this. Now, the RSA tool lays out those compliance expectations in a checklist form. And that's one of the reasons I like to suggest that people use it, frankly, is that it doesn't take a million pages, and you might make notes in the margins and actually check things off on the checklist, an actual checklist. That's the same checklist that they're going to use. Now, it's not a perfect instrument. I'll give you a couple examples as we go through. It's interesting that I see -- sometimes I see the recommendations coming out of a question that ended up on the checklist that was not the original – it was an example. It was not the only thing that might happen. So, for example, the fragrance-free environment; right? So in equal access in that section on the checklist, one of the things on the checklist is, is the policy related to fragrances posted? Now, that's not an actual requirement. The requirement is that you have a practice and a policy, and that you implement it. But the checklist says, is it posted? So guess what the report says? If it isn't posted, you're going to have a long conversation about your conformance because posted is what they're looking for because it's easy on the checklist, right. We're all like that, when we look at a checklist, sometimes the checklist guides our conversation a little more specifically than we want, so we're going to try to break those open and have a bigger conversation around them as we go through and try to identify as we go through kind of the things that aren't -- they're more specific than helpful sometimes. That self-review, though, will help you make sure you're meeting those federal requirements. It does include regulations that apply to all federal dollars, not just the Department of Education, so as we were saying a minute ago, those OMB circulars apply. You know, there's a conversation, I'm sure most of you know this, there's a conversation going on now about whether independent living will remain in the Department of Education at all. And even if independent living doesn't remain in the Department of Education, content similar to these circulars will still be applied; it'll just be applied from a different department's perspective. But these come out of the White House and they apply across all the departments. So those pieces that come out of the OMB circulars apply, anyway. They may be slightly different, but that's -- that still applies to all federal dollars. We want to know and meet our legal and contractual requirements. Using the checklist helps you to do that. And compliance is that foundation for building and measuring quality. Here's the link, it is a live link in some of our stuff online, the link to the actual checklist when you're ready to go through that, is in your handouts. And the electronic version of this PowerPoint is on that Wiki page, so you can click directly if you don't want to type all those letters, because they -- you know. All right. When you review an instrument like this, it's a tool for checking your own compliance, whether you use this one or the QUILS system or some of the others that we're going to mention before we're done, if you use any instrument to look at how you're doing, always take the time to actually look at how you're doing. Don't just check stuff off when you're talking about it. I've been in situations where sitting around the table, we all believe something is really happening, but if we go out and look, we find that sometimes there's been something that dropped out of the actual functioning of the organization. Does that make sense? So when you look at any instrument to check your quality, you need to actually go look at what it is the quality -- the measurement is measuring. So if you're looking at consumer service records, for example, which we'll get to a little later, if you're looking at consumer service records or CSRs as they're abbreviated for us, if we're looking at those records and we have a requirement that those records include a waiver or a plan, that's one of the things we usually have to see in every record, unless it's only information & referral, in which case you may not have a record, okay, we see it's supposed to have a waiver and plan, and we're sitting around a table and we say, that's our policy, that's what we do, but that doesn't mean that anybody knows that there actually exists either a waiver or plan for all of those services. So when you go back and actually look at it, you might find that there's somebody who isn't implementing that policy. And until you look at your actual quality, how do you know that? You know they should be. That's what you know. You know it's your written policy, but you don't know your day-to-day, individual practices. So when we look at any quality instrument, you can't just talk about it, you have to actually verify it in some way. So my suggestion is that you write all over that checklist. You don't want to forget your thoughts. So you want to write down, yes, we have the policy, I looked it up, it's this policy number, and we made sure that we had this training for our staff, you can find that in the staff training records. Whatever you did in relationship to that item. And then if you are preparing for an actual survey in the near future, my suggestion is that you also organize copies of the documents that show that conformance or put them right together in a banker's box or whatever, but collect them at the time you are going through this, so if you have an upcoming actual review, don't just go through the checklist but actually say, okay, for this checklist item, here is my backup stuff. This is how I prove it. Our experience is that if you don't have the stuff on the spot, that sometimes they are moving on to the next piece of the review. You didn't get it to them so they are moving on and you missed your chance to show them you did that one thing. It's not that you missed all chances forever but it works much more smoothly if you are very prepared, but always ask yourself as you look at any compliance instrument, not only do you meet it but do you exceed it, so exceeding those basic requirements is a big part for what we want to accomplish. So we will think consciously how we build on compliance. First go through the checklist and confirm it and then ask what outcomes or activities can take you to the next level. We will do this with actual items from the checklist in a second. And then identify specific goals that should go into your work plan. All right. If that's -- if this is a new activity, in order to take my center to the next level in this area of compliance, what is my goal? And then what are the outcomes that I am going to report on? I mentioned the board of directors here. It may not be the only place you might make a report. You might make a report back to a consumer summit. You might make a report back on the webpage or FaceBook page or whatever it is, however you communicate to your stakeholders, but how do you identify the outcomes that you will communicate back to any stakeholders. So that's just kind of foundational about why we are looking at compliance at all. I don't think you can look at quality until you have looked at compliance frankly. Because if you don't have a baseline or foundation of these items, it is hard to figure out how to go to the next place and we can get ourselves kind of all tied up in knots over the basic compliance. Here's the first standard on the checklist, they talk about philosophy and this is also found in what we call our standards and indicators. These are standards and indicators that identify what is a center for independent living, what do the centers for independent living believe and how do they behave? There are a number of items here that are part of that philosophy. Each one of them has a little more detail. But as you know consumer control, right, not just in management but also the policy and direction of a center and among other staff. So we are going to look at how we can make consumer control even more effective. Self-help and self-advocacy. Development of peer relationships and peer role models. Equal access to all services, programs, activities, resources and facilities. And the promotion of equal access in society, whether it's public or private, in your community at large, how do we promote access. So those are items that are in that first evaluation standard that you will find on that checklist. Now, under consumer control, the first thing they ask is what percentage of your governing board members have significant disabilities and that's the actual language in the regulations in the Rehab Act and also in the checklist and some centers are still missing this significant disability thing, so there are two places where the disability must be identified as significant, one in the people that you serve, determining if they are eligible, they must have a significant disability. And the other in the representation on your board of directors, the disability - 51% or more than 50% must be persons with a significant disability, and that is true of your board. so whether you are aware of that or not, you need to tuck that one away. So when you look at that, one of the questions that you have to ask is, how do we know about it. An interesting thing you see when people begin to develop the how do you know if people have a significant disability, is that if the history has been with vocational rehabilitation or that kind of determining of eligibility, they want to go right back to, well, do I have to get a medical diagnosis or do I have to do any of that. So if any of you think that's true, the answer is no. It's self-disclosed, always. But you might ask yourself, what is my best practice to get the right answer from the people who are interviewing to be on the board. So help me with this a little bit. I want you to think with me. Consumer control is the out – one of the outcomes I want to have. I want to have consumer control, over 51% consistent with disability. What is the best practice? And I will give you an example. One best practice might be to have a board application process. Because you give people an opportunity to self-disclose disability at the time that they say I would like to be on your board, yes, I am interested on being on your board. It makes recruitment easier. It provides a place where right there you can explain the philosophy a little bit if you'd like to, because sometimes you are working with people who may not be familiar with your center, but that you think are important parts of your community. So you can take a look at how you would do that. So one best practice is a written application. What are some other best practices around board recruitment to get you to that more than 50% which is actually what the Rehab Act says. We just say 51% because it's the same thing. Anybody got an idea? What are some best practices around it? Let's hand you a microphone and tell us what you mean by that. AUDIENCE MEMBER: Advocate to have consumers on the board. PAULA MCELWEE: So meaning actual consumers who have received services at your center. Bob Michaels in the Independent Living Ideal blog that he does had a really interesting article about how perceiving this as actual consumer representation rather than representation by people with disabilities who've never received services can completely change the way a center thinks. So that is interesting. Other ideas, what are some best practices? This is a fun one. Maureen. AUDIENCE MEMBER: Targeted outreach? PAULA MCELWEE: Targeted outreach meaning. AUDIENCE MEMBER: It is helpful to have a wide variety of differing disabilities and sometimes your board can meet the criteria by loading all up with a specific type of disability that is not necessarily in the best interest so reach out to disability populations in all kinds of fashions, for some of those you are currently short on in a board. AUDIENCE MEMBER: We have a spirit of ADA award every year and it goes to the person with a disability and almost every single one of them is a member of our board so it is awesome and keeps repleting itself. PAULA MCELWEE: So you find those new board members because of the spirit of independence and spirit of ADA. Good. Other questions or comments? So you can think about what are some best practices that would help you to recruit board members. Does anybody here struggle with board recruitment? So this is a pretty important one to stop a minute and talk a little more, I think, because I hear that all the time from centers. They are always saying to me, how do you recruit great board members. Actually it is not just centers, you might not be surprised to hear that most nonprofits struggle a little bit with how to recruit great board members because you want that perfect mix of people who are involved and yet not too involved. [LAUGHTER]. So how do you find those perfect people out there that are going to be the board members you are looking for? AUDIENCE MEMBER: Well, I don't know if you said it or not but to have board members recommend people to the board. PAULA MCELWEE: Yes, have board members recommend people to the board. One of the things I have seen with the application process is that the – thank you, I am getting – the application process gives you a chance to not promise people a seat on the board while you are considering them. And I bet every one of us has had an experience where at some point a board member said to their friend, we need board members. Come on, I will put you on the board, which of course is not their choice to do but then it is suddenly a very messy re-teaching and struggling a little bit with how to undo this potential risk that this board member has brought to your table. Where if you have an application process, they can give them an application to be on the board and then there is a process for reviewing those applications and finishing out that process. Yes. AUDIENCE MEMBER: Yes, that's understood, we have an application process and we also interview each board member with a chair of the board and the executive director to see what the person's motive is. After that, we will get back to them and if not, we will tell them why. It's not a problem. PAULA MCELWEE: Yeah. Yeah. It is a real important option to be able to have because otherwise you end up with untangling a delicate situation. Back there at the back. AUDIENCE MEMBER: You don't throw them away. You bless and release them. [LAUGHTER]. PAULA MCELWEE: Oh, I like it. I like it. Never throw them away. Always bless them and send them on their way. You know, when you look at those potential board members, too, we usually try to have a somewhat representative board. We are a cross disability organization. Hopefully we have people from different disabilities represented on our board of directors. Now I will ask -- I will get to you in a second. I will ask you a touchy question, how many people use ASL on your board of directors? We are not doing good there nationally. Nationally we're not doing good. There's lots of reasons, but we really do need to look at that cross disability approach, right, across all disabilities. So tuck that one away. A question or comment back here? AUDIENCE MEMBER: I am interested, do you have a physical application or do you have a virtual application? I know a lot of board members, they have, I call them virtual applications because I never saw it black and white. They come in and apply. We talk to them and then that's the application motto but you are saying to have a real black and white application? PAULA MCELWEE: I am talking about a form. You want to have it simple so it is not a barrier to involvement, but a one-page form. Here is part of the reason for it. You will have to document that they self-disclose a disability. So if they check that box and sign the form, you have the documentation so it kind of gives you a simple way to document that on the other end. The other thing that an application process, a real paper application does, is that you can ask them about their areas of expertise and you are looking for across the board expertise, not just in areas of disability but also in areas of expertise, right, so you want somebody who knows finance. You want somebody who knows personnel law. You want somebody who knows disability rights. You want somebody who knows a number of different things. And sometimes you can identify those and that may also be a part of your application. I have seen some applications that include those kinds of areas of expertise right on the checklist and so they check those boxes, too, which ever ones they feel apply so you can get a sense of who they are. And sometimes when you are keeping those applications and blessing and releasing those candidates, sometimes you may say to yourself, you know, this would be a good candidate to consider when. You know, at a later point. So you don't want to necessarily cut them off. Sometimes they may be candidates that could be useful to you to explore a little bit about how they work in a group by seeing if they would serve on a task force to explore some specific area. So those are some other best practices that we see out there, is how are you cultivating board members. Right? So if they're not ready to be on your board of directors right now, they still may have a leadership role or have the potential to learn and grow into that board role if you give them an opportunity to do that. So that's one of the other ones. The board being a principal decision-making body is another item under this in the checklist, and they ask you that question, then, is the board the principal decision-making body, and there has to be good record-keeping to know the answer to this question. So if you've got great board meetings but lousy minutes, well, then there's no way to tell that the board actually was making the decisions. Interesting, huh? One of the things that I've seen in a good practice around this is -- policies and procedures, yes. Great minutes, yes. But another piece of that is an analysis of the decision that's going to be made. It can be a one-page brief, and you would say on that piece of paper, whoever is presenting it, might be a staff person, might be the executive director, might be a board committee, but whatever decision they're presenting to the board, there's a summary of the issue, any background that you think is necessary, and then a list of potential decisions, you know? Decision one, we could do A, B, and C. Decision two, we could do just A and C. Decision three, we could do nothing, but here's the response -- here's what will happen. And then a recommendation if the committee has made a recommendation on which decision, and then you vote. Now, suddenly, the board has information at hand around the entire conversation that took place before that board meeting around that object. You see what I'm saying? So you have that brief that gives you the information. Hopefully, it can keep it to one page, but that's something they can read in advance, if it doesn't make sense to them, they can come prepared with questions. If they think of an option that the committee didn't think of or that they think is better, now you've got a framework for that conversation to happen efficiently rather than just highjacking the meeting off into a side conversation, which is what sometimes happens if they see another option but can't see the structure. So that's another practice that I see. What are some other practices that are important for boards making decisions? How about this table right back here? AUDIENCE MEMBER: I just want to comment related to your last comment. I had an individual, an attorney talk to me and said that the minutes were too broad, too inclusive, and that the potential for being used in court if a board -- if the board had – were making a decision, they made the wrong decision, if they went back and looked at data showing that someone had presented that, that it could come back and haunt you. And so that person recommended only document your motions and whether they're being passed. PAULA MCELWEE: Well, you know, that's an option. You can certainly take that approach. Most of us spend too much time being worried about what we can get sued for, maybe some, not enough. I did do an interim where I walked in the door and they had four pending lawsuits, and it was pretty ugly. But hopefully, you're not in that kind of situation. And if you're not in that kind of situation, the question you ask is, what helps the board to make a good decision? Now, if you don't want to make that part of the minutes, keep it in the board packet and not part of the minutes, I guess you could handle the information in different ways, but how do you get the board the information to analyze and decide on something? And they're not actually the decision- making body if they're just saying yes to whatever you ask. So there's the distinguishing piece. Right? So the distinguishing piece that people externally are going to look at from us is, how do we give them the tools to make the decision, because they're not part of the day-to-day, so I don't know. Anybody else might have some feedback on that. AUDIENCE MEMBER: Larry Grabel with the Service Center for Independent Life in Clairemont, California. What I do is, two weeks prior to the board meeting, if I have any new policies and procedures or bylaws, I send them out to them. I give them two weeks to give me feedback. Two weeks later we vote on it. Then, if it is approved, I sign it and the board's secretary signs the original copy, and it goes on file. PAULA MCELWEE: Okay. So you've actually told them in advance, and then they sign the actual decision. Okay. Did you have a comment here? AUDIENCE MEMBER: Yeah. I found that in working with boards, is, when you're taking the minutes, record – record the board meeting so that when you do go back to transcribe the minutes, you've got the conversation around the decision that was made, and just put a general description in the minutes so that if there's a question about it, you've got it documented. PAULA MCELWEE: If you do that, a legal advice that I got one time was, don't keep those tapes. You use them for the purpose of creating the minutes. As soon as the minutes are approved at the next meeting, you can tape back over them because then they can become a document that has legal bearing if there's a case like that. We haven't talked about situations where the board might meet without there being minutes kept, but usually we're familiar with executive sessions. Right? So there may be potential that all that would happen is that you would tell the decision of the board, but none of the discussion would be recorded in any way, either on paper or on a voice recorder. The advantage being that especially in personnel matters that are very sensitive are handled in that private meeting. Now, every state is different regarding how they look at open meetings and who is required to be in an open meeting. Centers typically, as non-profits, don't fall there, but in some states they do because of the way the state interprets the money you receive. So you need to know your own laws about what meetings have to be open and closed and when you can do -- when you have to announce your meeting in advance and don't, because that's an important thing for you to know for your own compliance. Kind of a side note there. Yes, back here. AUDIENCE MEMBER: I have a question. This is Mary Lou from the Michigan area. When it comes to the board being the principal decision-making body, how do you balance their getting down into the weeds of the day-to-day business and being able to provide them with just enough so that they can make a good decision? PAULA MCELWEE: Isn't that where the rubber meets the road for all of us? AUDIENCE MEMBER: Yes, it is. PAULA MCELWEE: It really is, because the board has to make the broader policy decisions, has to be aware of the decisions that you're making as an executive director, if you're the executive director, and yet not get involved with your decisions. My suggestion is, and maybe there will be some other comments about that, but my suggestion is, these outcomes that we're coming up with before we're through with this week will be a big part of the solution. Because if you work with a board on what outcomes they expect to see, and then you report to them on those outcomes, they shouldn't have to see the day-to-day business. They should see that you are carrying forth their mission, and here's -- and here's the measurement of that. Does that make sense? So this can be a partial solution to the tendency of some board members to get involved in the day-to-day stuff. I'll tell you, some board members have gotten burnt, and they trusted and thought everything was fine, then somebody came in and showed them everything wasn't fine, and they realized they were not doing their fiduciary duty, and suddenly they are hurting and the center is crumbling around them, and they come back in with all guns blazing saying, I'm not ever going to let that happen again. And it is more difficult, probably, for the director -- the boards of directors of centers that have been through a crisis to let go than you can imagine. I mean, it really is difficult to bring them back to that point. And the only way that you can is that you have some really solid, dependable measures that help them see that you are doing what they ask you to do. And if you've got good, solid outcomes along that line, they will begin to trust again. But especially the ones that have been burned in some kind of a situation where they weren't paying attention and something went south very quickly, and they ended up in some tough situations, it is hard to get them to let go. I don't know if anybody has some principal decision-making without being a day-to-day detail person. Does anybody have other advice on best practices for that? Yeah. AUDIENCE MEMBER: This is Audrey from Three Rivers in Kansas. I think something you mentioned earlier in the day that was really helpful, I stepped into a situation where the director had been absent due to illness for a long time, and the board president was pretty much running the center. And so we got from -- borrowed from another CIL the decision making chart. It really was very specific, here are things the board does, here's what the director does, here's what the management team does, and that helped all of us get through on that. PAULA MCELWEE: And clarifying and agreeing on whose roles it is to do what is an essential part of that for sure. Back here. RICHARD PETTY: It means an ongoing relationship with your board chair, it means an ongoing relationship with your board committees, and it means continually making sure that -- that you're reinforcing the ongoing relationship and the ongoing roles of what's a board role, what's a director role, what's a staff role. And when you neglect that, that's when things begin to fall apart for many center directors. PAULA MCELWEE: That's well said. Well said. Another comment or -- I thought I saw a hand. Could have been my imagination. Maureen. AUDIENCE MEMBER: I don't recall how long ago it was, I know there's been some great trainings through ILRU and IL-NET on board management, board development, and there's been some really good tools that have come out of those trainings. I think lots of times, board members, they are volunteers and their hearts in a good place, but they really need training and this discussion and this work that Richard was talking about, but also some tools, you know, checklists and how to understand financials, and some of those great guidances that are out there. So I'm not sure how far we went back to archive those for Wiki, or if there are some still available, but there's been some great things come out. PAULA MCELWEE: There's been a lot of good board resources. I've sent people to those on a regular basis because usually I'm working with centers where the boards are waking up, maybe is the word. They've had a review and suddenly they're asked to do things they weren't asked to do before, and so they're trying to come through that with a reasonable approach and a balanced approach between who does what and how that's going to work. And I've had board members who have asked that very question, of how do I show that I'm responsible as a board in the decision-making process, without being involved in the day-to-day. And they really cannot see that, that path, unless you assist them. One of the key things, though, is, you hold an executive director accountable for what happens day to day through these measures. And there are other ways to do it, but a lot of the other ways are pretty faulty. If you've got good data and you have good, consistent attention to the goals that you've set, the outcomes that you've identified, then you have good, consistent information given to the board that tells them what they want to know as they continue with their oversight of your organization. Does that make sense? Other comments or questions on that one? Do you see how each item on the checklist, though, needs to be sorted out for your organization? Can you already see that from just this one item? So just this one item has sorted out a number of pieces around the board. Which one of those -- where are you? You know? Which one of those has to be sorted out for you with your board? And what is that going to look like? So that's an important thing for us to look at. The second part on that checklist item is the 50% -- over 50% of the employees in decision-making positions are individuals with disabilities, and over 50% of staff positions are filled with individuals with disabilities. And if you have any lack of clarity on this, each of those -- each of these must be true. So all staff must be made up of more than 50% persons with disabilities, and the decision-making positions must be made up more than 50% of persons with disabilities. Neither of these require a significant disability; both of them must be true. Sometimes an organization will ask, well, what do you mean, decision-making positions? Because this is the language. You get to define that. So you look at your organizational chart, and who's over what, and how you do management team if you do and all that kind of stuff, and you can define that these three people are in decision-making positions. They are a management team. Here's what they do. And of those three then, two must be persons with disabilities. Right? Because more than 50% of three is two. Now, if you have a very small organization and you have one executive director and no other people in decision-making positions, more than 50% of one is one. If you have a small organization, but you have a program director and an executive director and, you know, they both work for this very small center, but they both are in decision- making positions, more than 50% of two is two. More than 50% of two is two. So those are things that are good to kind of know what the requirements are. Those are the requirements. So the best practices that you're also looking at the makeup of your community with your staff and board makeup. So you will also sometimes see goals set around reaching out to certain community in your city, so maybe you are going to reach out to the Latino community in your city so you are going to ask yourself, well, do we have any Latino members on our board of directors and then you going to ask yourself do we have any staff that are Latino and then you are going to ask yourself, does anybody speak Spanish. So you will ask yourself a series of questions based on the thing you want to change about your center. It feeds all the way back to the makeup then of your board and staff so the outcome may be that you want to increase the number of people that you are able to reach who live in a certain demographic, but the how to do that is going to blend through all of the other aspects of what you do, including these areas, right. So that's one best practice I see, is that you have identified your community, your unserved and underserved community has to be identified. It's another one of those things on your 704 report, right, how are you doing that, how are you reaching out to I don't understand why they can't just be underserved because anybody who is unserved is also underserved, because -- unserved and underserved communities. I am sure there is a reason I just don't know it. So anyway how you are doing that and how you are reaching the groups that are traditionally under represented. A best practice is looking at your board and staff makeup related to that. What are some of the best practices around consumer control and staff and board and how you approach that? Any other ideas that have come from you guys. AUDIENCE MEMBER: It's not so much a best practice as a question, is how is RSA now counting employees as -- for the 50% before it used to be you would have to add everybody if somebody moved, left the organization and you had to add that time and then the new person that came on, is that still the process? PAULA MCELWEE: Well one of the things that they've specified is that if you have any kind of involvement with hiring of attendants that those don't count in the count so that group is set aside and then the rest of it is just based on FTEs, is my understanding, so that's what I am seeing in the reports. No? Maureen is frowning at me. What do you see? AUDIENCE MEMBER: I don't know that I am seeing anything. I just don't know if I agree with that. PAULA MCELWEE: Well, yeah. AUDIENCE MEMBER: The other thing we struggle with a lot and I certainly don't have any answer for -- is people who fill out, particularly staff, who fill out – disclose secretly, privately, confidentially that they have a disability, it is kind of like being in a closet and working in a gay organization, do you count those if they are not out? Because part of this whole business is to be a peer and to be able to be able to talk about your experiences. So it is great if you haven't and we hope you come out but maybe they should not be counted until they are outed at a party. PAULA MCELWEE: I think that is a really good question because EEO regulations would require that you cannot disclose their disability unless they choose to do that so I know it's backwards for us, but in order to make that make sense, you are not able to, then, disclose it if they don't disclose it. So like you do in your interview process, when you say to the person who is interviewing, you tell them everything you can tell them about how we are a disability run organization and we have a majority of persons with disabilities and then you ask and what is your experience with disability, and they disclose or they don't, but you hope if they have a disability, that they will disclose at that point. Disclosure is a very personal thing. You really can't cross the line on that disclosure issue, I don't think, but I think FTEs is the answer to your question. So they are looking at that. Yes. Do you have a microphone AUDIENCE MEMBER: This is Lisa. I must tell y'all, I am from Ohio. What do you do with a staff member who doesn't disclose, or maybe even they don't know they have a disability but it is maybe clear they have one? PAULA MCELWEE: There isn't anything you can do. I can tell you the conversation that Gina McDonald had with me but she was not my employer and I was not hers and some of you know Gina from your past years in independent living. She is also from Kansas and she was a past NCIL president, NCIL board member and so forth, but she came to me one day and she said, I don't understand why you don't disclose a disability. Now, she is my friend. She can say that. And I can say to her, because she is my friend, well, I just feel like I would be trying to pass and I don't think I should do that and she can say to me because she's my friend and say, you know, I used to feel that same way about that and Justin Dart took me aside and said Gina, you have a hearing loss and I know you do and yet you still aren't disclosing a disability, why is that? And do you know what if Justin can ask Gina and Gina can ask me and I can ask you but it is all from a friendship basis, what you cannot do in the center is get involved in the employment piece. So as the employer you can't require them to disclose. You can talk about it at a staff meeting. You can train. You can provide lots of information about it but you cannot -- you can neither say to someone I believe you have a disability, nor can you say to them, why don't you disclose your disability if they are your employee. AUDIENCE MEMBER: So you cannot count them without a formal disclosure. PAULA MCELWEE: You can only count the people who disclose to you they have a disability, so even if you think they probably do, we can all make those judgments on the side, right. So I have heard somebody say, well does the board president have a disability because I am sure not seeing it. Well, do you know what? If he discloses it he has a disability. If he doesn't disclose it, he doesn't have a disability. And that's where we have to draw the line, right, but it's a very odd place for us to be sometimes. AUDIENCE MEMBER: So if you have a lot of part-time employees, how do you look at that? Do you count two part-time as one full-time? One as one -- how does that -- PAULA MCELWEE: You count up the number of FTEs to see how many people would have to have a disability in total. I don't know. That's the most recent time I saw it done. That's how I saw it done, so I am really kind of scrambling on that one. I don't know if anybody has more recent. Richard has some disclosure for us on that. [LAUGHTER]. RICHARD PETTY: I am sure everyone understands FTE, full time equivalent but we will -- maybe if you can just walk through that for a minute. PAULA MCELWEE: Sure. If you have a full-time equivalent it is forty hours at your organization and you have four people that work ten hours and of the four that work ten hours only one has a disability and you only count that as .25. But eventually it will all add up to a number that is more than, you know, may or may not be a full person but, you know -- so you are going to end up doing it on a percentage basis putting it all in there and then adding it up and saying is it more than 50%. And that's -- that's the way I have the formula done, so if you have another formula I am not sure it is cut in stone. If you have another way you want to do it and you want to look at the numbers of people, as long as you have more than 50% of the numbers of people, I think that is actually more inclusive of disability right, than the FTE option. I think the FTE option is just an option. But I think you can do either one. Does that make sense? All right. So you can see how as you think about the best practice in any one area, it causes you to ask all kinds of questions about what you are doing right now, doesn't it? Isn't that interesting? So as you look at compliance and you sort out compliance, you begin to think about how can I show that, how can I be that? How can I do that? What can I show for my outcomes, and it leads us through these conversations around each of these items. Here is the next one. Let's see if we can do this as a group. Let's come up with best practice ideas. The next one is self-help and self-advocacy. Promote self-help and self-advocacy among individuals with disabilities. So what are some best practices? Now, I cheated. I gave you a few to start with on this one. So consumer service records clearly reflect self-advocacy on both goals and notes. Consumers interviewed are able to indicate ways that they are learning to advocate for themselves. Maybe your calendar shows self-advocacy events. Those might be ways you could count it or look at it and measure it. What are some other things you can do around self-advocacy and self-help? AUDIENCE MEMBER: You can provide instruction on it, have -- like we have workshops on self-help and advocacy and how to advocate and then have people come and join-- PAULA MCELWEE: So it could be a class or group that is meeting around that, you can show that group. A lot of times this overlaps with your peer support, right, so a lot of times you will see this overlap with peer support because it's a good fit to think in terms of self-advocacy with a group of peers. You will see that sometimes. What else do we see? What are you guys doing that is like really super in this area? Anybody have a good practice you want to share? AUDIENCE MEMBER: Our transition training, we always include advocacy throughout that for the youth? PAULA MCELWEE: From school to the rest of life? Yes. PAULA MCELWEE: So youth transition. Yes. AUDIENCE MEMBER: We have -- we support several different community advocacy groups so we do provide training but then they actually go out and do advocacy work in the community and we provide platforms for them to meet with legislators and have conversations. AUDIENCE MEMBER: We're starting to build community self-advocacy groups that— our systems change person is going in and starting to form those groups. PAULA MCELWEE: What does that mean, community self-advocacy groups? AUDIENCE MEMBER: In cities, we are going in and finding people that have an issue. We are teaching them how to deal with the issue. PAULA MCELWEE: So city wide looking at it? AUDIENCE MEMBER: Yeah. PAULA MCELWEE: Community, community. Okay. AUDIENCE MEMBER: We represent 22 cities. PAULA MCELWEE: Yes, a lot of cities involved. Right here. AUDIENCE MEMBER: It is consumer to consumer. We help consumers share with other consumers, the steps they took to self-advocate for themselves and their experience so they can -- so others can learn? PAULA MCELWEE: That's another overlap with peer support, isn't it? How do you record that? How do you measure that? How do you know that self-advocacy has happened consumer to consumer? AUDIENCE MEMBER: Well, it's documented as a result of that consumer following through with that individual steps and whether they were successful or not. PAULA MCELWEE: Okay, so as you are looking at the individual outcomes you will see the evidence of some of these things we are talk talking about. AUDIENCE MEMBER: I am Cathy Fuller from Services for Independent Living along with Lisa in the Cleveland, Ohio area and we are in the process of developing a systems change coalition and we are bringing in providers, family members, you name it, but we have a significant number of consumers that are on that so to me it does two things. It helps to build advocacy skills but it also teaches the professionals and the other folks about self-advocacy and the independent living philosophy and that kind of stuff so. PAULA MCELWEE: Excellent. Comments or questions? Richard back in the back. RICHARD PETTY: I was just going to ask how many centers have a really solid relationship with an ADAPT chapter. PAULA MCELWEE: Raise your hands if you have a solid ADAPT relationship with a chapter on ADAPT? Only about two and they may be from the same center, they are sitting at the same table. Yes. One center here is admitting to it. Hmmm. RICHARD PETTY: Let me just do a plug, guys. That's going to be self-advocacy at a level that's absolutely tremendous. And when -- when ADAPT comes to your town and does a self-advocacy training, it gets real experiential real quick, and that is -- it's -- can help your center become even more vibrant, and connected to the community and it is a good support for the ADAPT chapter, too, things happen. PAULA MCELWEE: Okay. There's your plug from ADAPT. It's true that there are things that we cannot say. We get into this -- the lobbying question, which we can do another time, too, but sometimes the civil disobedience piece, sometimes your board is not comfortable with that on the part of the executive director. Some of them are. Some of them are, but some of them aren't. So ADAPT can help take over some of that. Yeah. AUDIENCE MEMBER: One thing -- can you hear me? One of the things that we do is when there's an area of concern within our community, that we have one of our consumers be part of that problem-solving within that area of concern so we're within that system, and we find a lot of successful system changes because we have various consumers within that developmental process and solving the problems which -- PAULA MCELWEE: So what drives that development of solving the problems then? How do you involve the consumer, at what point? AUDIENCE MEMBER: Well, first I bribe them. When an individual comes, for example, and they're concerned about transportation, and they're wanting us to go and advocate, what we do is, there's a -- there are times when we meet and can be part of working with that transportation in resolving, and then actually having that person right there, smack dab in the middle to hearing the concerns on both sides and advocating for the accessibility of that transportation. They become processing, learning about transportation as a problem-solver, and also as a rider, and they become empowered. PAULA MCELWEE: And how do we capture that when we're telling people about our outcomes? AUDIENCE MEMBER: That's a really good question, because we oftentimes, we don't do a good job on capturing all of the things that would count, and those are – because sometimes what we have is we have support groups, and from that they hear that Nancy did this, then we have other individuals by that peer, and they also get involved in the other types of coalitions and community meetings, and because of that one incident, we have a trickling effect. And that is a big area of problem. We really don't capture that well. PAULA MCELWEE: Although I want to say one thing, and that is, that it's happening is fabulous. All right? And we don't ever want to lose that kind of person-to-person excitement, and the effectiveness, when somebody is effective in advocacy, how that effectiveness kind of generates energy out to all the other things that we might be thinking about or doing. Never underplay that. That is so important. It's foundational to who we are as centers; right? It's so essential to what we do. But we also want to find ways to make sure that we're capturing it so that we're helping ourselves to do it more. AUDIENCE MEMBER: And that is -- I mean, we're doing it, we capture a little, but I really – but we are not capturing it as much as we probably could, and that's why I'm here. PAULA MCELWEE: Yeah. Okay. Well, good. We'll have to come up with some more ideas on that one. Anything else around the issue of self-help and self-advocacy? Other ideas for how you might capture or measure self-help and self-advocacy? Okay. Let's take a look at peer roles and peer relationships. Now, again, there's a connection between the two. Really strong connection between how self-advocacy happens and how that's shared. Often we learn it through peer relationships. Right? Often we do. And the CIL promotes development of peer relationships and peer role models among individuals with significant disabilities because remember, everyone you serve outside of I&R has a significant disability based on eligibility criteria. So common practices, we see peer groups. We see peer-to-peer relationships developed. Sometimes those relationships are volunteer, sometimes they're formal, sometimes they're informal, so you sometimes see almost a matching process for peer-to-peer relationships. And then regularly convened groups count, but so do any other peer relationships. Certainly the hiring of staff who have disabilities as a part of promoting this philosophy within our center. What are some practices that you've seen or observed or heard about that you think are important and how would we measure those? Okay. Over here. I don't know, is that Lisa? Yes. PAULA MCELWEE: Okay. AUDIENCE MEMBER: This is Lisa again. I am in the process of developing a big peer/little peer program. It's going to be a teenager with disabilities matched with adults with disabilities. She's very excited about this project. PAULA MCELWEE: There are a lot of youth things that are happening that I think are so exciting to see, coming out of this, both youth peers to youth peers, as well as other center peers, so that's exciting. That's good. What other things are happening out there that are exciting and best practices around peer-to-peer relationships? Now, I heard a conversation out of your definition for quality over at this table, around being a more inviting setting. I want to talk about that for just a minute. You know, I'm old. See the gray hair. I was first involved with centers in 1979. Some of you predate that, but not very many of you. That's -- you know, half of you weren't even born yet. But anyway . No, it's not quite that bad. In the beginning, we were a really vital community. I don't know how else to say this. We got together, all the time, about everything, because there was so much that needed done. Right? So we got together and we talked about transportation and we met with these people and we brought those people in to talk about, you know, what we could do with improving the housing situation, and we talked to, you know, everything, everything that came up was a group activity. We had a very vital, active disability community. Some of the centers that I've had a chance to visit with recently have still kept a very vital, active environment at the center, but some of them, when I walk in the door, I'm thinking, it just looks like an office. I can't tell it's a center at all. There's nothing happening here that brings people in the door, except one at a time, maybe, to meet with somebody, but maybe they're doing that on the phone or, you know, e-mail or all this other -- the vital community piece isn't always there. Is it essential to have that if you're at a center? And if it is essential, how do you make it happen? Is it essential, or not? What does everybody think? Think so. Yeah. PAULA MCELWEE: All right. How do we make it happen? Soup. Soup and coffee; right? As a start. Okay. AUDIENCE MEMBER: I'm Tim from Poughkeepsie, New York. I'm program director. I established [indiscernible] and between two of my folks, we're 32 different locations [indiscernible] because most of us consumers do not have transportation, and we meet them in the community, we meet at the library, et cetera, et cetera, et cetera. PAULA MCELWEE: You know, one of the things, when you mentioned the community -- you know, that transportation is not accessible, does that blow anybody else's mind that transportation is still not accessible? I mean, if you stop to think about it, can you believe that transportation is still not accessible? It was on the very first list of things that we had to change in our community before anything else could change. We had to make sure that we had accessible transportation, and yet it is still a huge barrier in many communities. AUDIENCE MEMBER: Let me make it clear. Our transportation system is accessible physically, but I'm telling you it's not because they are looking from a financial point of view because now we have transportation go all over with the county, now it’s got two routes because of the volume. And we're cutting back. PAULA MCELWEE: Yeah. But there's still not enough transportation. Now, I don't know if the baby boomers will help bring this back up as an issue. You know, the graying of America and all – AUDIENCE MEMBER: We need more [indiscernible] parties. PAULA MCELWEE: We'll see. We'll see. But it does blow my mind when I stop and think about it. Wait a minute, how many years has it been now? And it's still on the top of the list. Transportation. Housing in California, anyway, I don't know how it is everywhere else, but it's so expensive and it's so hard to get into anything that isn't expensive, and to find that it's also accessible, it's still on the list. It was on the list then, it's on the list now. Employment, still the largest group of unemployed people in the country are the folks with disabilities, and the figures have just not gone up nearly like we dreamed they would. Okay. Where do I see a hand? Here we go. AUDIENCE MEMBER: I have a question on peer. When we had our site visit from RSA, we were seriously confused because we were told that two people working in the office that could be peers, because they both have disabilities, regardless of the disability, have a conversation, that could be logged in our database as a peer conversation. And we just can not reconcile that. Our site visitor said, oh, yes, that's peer. Would you please just clarify that for once and for all? PAULA MCELWEE: For once and for all, huh? You're not asking much. It is absolutely true that a staff person can provide peer support, and it is absolutely true that any two people with disabilities who are sharing information about which they can share, even if their disabilities are not the same, you know, could certainly be peer support. Two staff people talking to each other, I guess -- my understanding was that peer support was provided as part of your consumer service record, as part of the core services provided; therefore, if one or both of them were consumers, yes. If neither of them are, I don't get it. Is that a good answer?(Laughing). AUDIENCE MEMBER: Neither did we, because we do track our peer and we've got good peer numbers, but we were flabbergasted. So we thought, well, we're just not going to listen to them. PAULA MCELWEE: Yeah. I think I'd let that one go. AUDIENCE MEMBER: Some things we do, we do quarterly holiday events, getting people in. We do chatty cafe, which is a weekly event of peer support, having, you know, snacks and coffee, all out of resource funds. PAULA MCELWEE: Of course. Resource development funds. AUDIENCE MEMBER: And another thing we do is, we have a really thriving employment program, so we get volunteers in to see how they do in an employment setting. They can put that on their resume, and we get a better idea of how they would do an employment setting. And we also have peer bus trainers to do bus trainings. They're very involved. PAULA MCELWEE: And that helps the transportation issue of people coming to the center. How many of you feel like your center is a viable or vital place where people choose to gather? I think maybe about half. Maybe about half. Maybe not quite half. I think that that's an interesting thing that we're seeing come back around right now, and I think that that's going to be an interesting one to watch. But as you determine your quality measures, you may want to ask yourself, is that essential to fulfilling our mission? Yeah. AUDIENCE MEMBER: This is Audrey from Three Rivers in Kansas. We cover a very broad rural area, so all of these wonderful suggestions are things that we can't make happen in our rural areas. So those are the CILs and that population that we've really got to start getting creative. It's very, very difficult. I mean, I have one staff person to cover three counties. We don't have satellite offices because there's no money. On our reservation, the independent living program there was the only place where we've got the community going in a drop-in center. Everywhere else, it's individual. And even if we try to host something, there's no rural transportation to bring them to an event. PAULA MCELWEE: Okay. Yes. Right back here. Yeah. AUDIENCE MEMBER: Bob Maffit from Montana Independent Living Project in Helena. Just as an observation, I hear the comment a lot throughout today, ranging anywhere from when you look at a measure like the peer advocacy, you know, needs to be tethered to a consumer service record, apparently, one of the value – values that RSA has in terms of site review has, is that whatever done is tethered to eligibility. I hear conversation about the old coffee and soup, as to how legitimate it is in terms of -- well, it isn't tied to eligibility, but my point being, I think as a quality measure, would you comment on how, or maybe others in the room, might have best practices, that we start -- obviously, there's no question about consumer service records eligibility, but as you see, there's a lot that we're doing in terms of advocacy, self-advocacy ranging from organizing community groups, being members on public groups such as transportation advisory councils, going to city commissions or being a resource at an ADA committee for a topic or bringing that to an agenda. I guess best practices, it might pop itself into issues or eyebrows being raised under a compliance piece which, through advocacy, we can certainly deal with. But the other thing is, the question is, I think we need to -- or maybe it's an observation -- I think we need to be pretty adamant about the systems change piece in all these issues that are on this checklist, as to how we're engaging that, and that might be an equal or greater measure of increased quality. Could you comment on that? PAULA MCELWEE: Yeah. I will just briefly, and then hit it a little more as we go through the rest of the sections. We need to measure on an individual basis and we usually have a data tool to do that because there is a consumer service record and usually there is an electronic record that is through one – there are a number of them, through one of the database companies that we have. There is a representative here today that maybe will talk to you a little bit more about that later, but -- so we think about individual but we certainly have that systems advocacy as well as that individual advocacy responsibility, right, as centers so we need to figure out how do we measure that and it may or may not be in that database of information. You may have to create your own way of recording that information, setting your goal, measuring how you meet that goal, reporting on it. It may not be something that someone else created for you. It may be that some of the most important things you do, you will have to create your own measures for -- a comment here? AUDIENCE MEMBER: One of the things the coalition we are setting up -- we have only had two meetings but we had 29 community partners, over half a dozen really strong consumers. It has been a fun group and we are in the process right now of identifying what are the major issues and then we will break up into subcommittees. Each subcommittee is going to develop a work plan and in that work plan, one of the things will be: what does success look like and that way we can measure -- PAULA MCELWEE: We are all required to have a work plan. That's part of our funding if you get either Part B or Part C funds, you have to have a 3 year work plan and is part of your 704 report and tell them what you did on the work plan and what you will do on the next work plan and we often don't treat that as part of our whole process but it can be. It can be a very lively, exciting tool for how we proceed and we need to think about, do we want to use it that way. We can drive that content to be interesting, and you mentioned that your group was fun, and I want to ask this question, when is the last time that anybody really had fun at your office? And the answer is we do it all the time, I like that answer and I think that's exciting. If your answer is, what do you mean have fun at our office then we may need to talk. Do you have a comment? That's what it's about. AUDIENCE MEMBER: One of the other things we are doing is taking chatty cafe which is fun and it is coffee and building relationships out to the HUD housing. We are going out there and meeting at their facility to attract more people who are unserved? PAULA MCELWEE: See who wants to come and talk with you guys. AUDIENCE MEMBER: No, we are going to them and working with them on their site. We can build advocacy and build peer relationships. It can help in rural areas? PAULA MCELWEE: In rural areas – in most communities, there is a gathering spot. You have to figure out where it is and you may have to be there at 6:00 in the morning. AUDIENCE MEMBER: This is Peggy from HEART of Central Texas. I would like to follow up with a comment that this gentleman made. We are starting -- we have a parent support group and they are not CSRs but we also have while we meet and we have day-care for the children and these are little ones, and the children all are individuals with disabilities. They are not our consumers but it is a service that is well received and these parents are so hungry for hearing about what is happening and how they can assist to empower their children. To us, this is our future. And when we are counting -- well, it's hard because we aren't -- they are support groups, we feel that this is part of what we do. This is value within our community, and when you count, it doesn't show up in the CSRs, it will show up in our classes and our support but it will not -- PAULA MCELWEE: Probably show up as peer support groups. AUDIENCE MEMBER: But it is an interesting dynamic when -- I am not sure if this is a positive of -- to us, it is awesome, we like this and we support our families but I don't know how that would transfer when somebody is coming in and looking for numbers. PAULA MCELWEE: We will talk about that a little more in a bit. I have two more comments here in the back of the room. Go ahead young lady. AUDIENCE MEMBER: Yes, one thing that comes up in terms of struggles that we have been doing in terms of groups and classes for the peer support model and finding a balance because we are serving people with disabilities but we also want to be inclusive and not segregate people with disabilities to come to programs so finding that balance when developing programs with groups of social opportunities, just because a disability, doesn't mean I am looking to only interact and be in a separate group of people with disabilities, that we want -- we find people we have things in common with and they may or may not have disabilities so that is hard when you look at the peer relationships that this is your peer because you both have a disability and this is how we will support you but, then again, if we are having people come into our facilities who don't have disabilities and aren't consumers we may have people who may be trying to take advantage of another person and who is going to come into these groups and the confidentiality and so many barriers -- but it is more of a question - not – just a barrier that we face as we look at developing those peer relationships? PAULA MCELWEE: It might be something worth considering and looking to, huh. AUDIENCE MEMBER: Yeah, I know there are some centers that are trying to do some different social and more community things. PAULA MCELWEE: We are seeing a lot of community things and youth both. Richard, you had a comment. RICHARD PETTY: A question, for those -- for those peer support groups, why are there not CSRs? Why are you not doing that? PAULA MCELWEE: Let's come back to that, the four core services, the requirement is you don't have to do a CSR for I&R and the other three core services, the expectation is the CSR with them either waiving or creating a plan and with a goal is still in place so the groups that you have that meet that don't have CSRs, we ought to talk about whether they are really falling under this or not.