ROUGH EDITED COPY

NCIL
IL-NET READ FOR REVIEW - USING ACL'S COMPLIANCE & MONITORING PROTOCOL (COMP) TOOL TO ACHIEVE EXCELLENCE
MARCH 31, 2020
3:00 P.M. ET

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This is being provided in a rough-draft format.  Communication Access Realtime Translation (CART) is provided in order to facilitate communication accessibility and may not be a totally verbatim record of the proceedings.  
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	>> TIM FUCHS:  All right, welcome, everyone.  I'm Tim Fuchs with the National Council on Independent Living and I want to welcome you all to our latest IL-NET webinar, "Ready for Review Using ACL's Compliance & Outcome Monitoring Protocol Tool to Achieve Excellence."   So we are recording today's webinar as always and we're currently in presentation mode so we're going to archive this presentation on ILRU's Website so you and your colleagues can access it after the fact that will be up within 48 hours it usually goes up sooner than that and there's a few ways you can ask questions today we are going to wait until our Q&A break we have a big audience which is fantastic thanks for being here thanks for your interest so you can type your questions any time during today's presentation but we'll wait for those Q&A breaks to respond.  So you can see in your Zoom menu bar there's a Q&A tab and you can type your question out there.  Although we won't be able to respond until the breaks, if you've typed it and entered it we're seeing it so just trust that you don't have to enter it twice or wait for you to hear us say anything.  Just know that we got it.  You're welcome to use the chat today to talk to each other to submit a note maybe you want to tell us that you're having an audio problem or say hi to another participant you haven't seen in a long time but try to keep your questions on the Q&A tab.  Because it helps us to go through them especially with such a big audience and prioritize the questions.  I want to mention both the captioning and alternate ways to submit questions.  So the captioning will display in Zoom.  So if you haven't already, you can select the closed captioning or it might be called show subtitle on your screen. 

	And that should bring up the captioning.  
	If you need a full screen CART captioning, or you want to adjust the font size, color or contrast of the captioning, you may want to use the full screen CART at StreamText.net.  That was the link that was sent to you in your confirmation email and we'll put that in the chat in just a moment.  
	You can also submit your questions there.  
	So if you're focused on the full screen CART/captioning if you're not using Zoom, you can submit your question in the chat at StreamText.  I'm logged in there as Tim Fuchs I'll be happy to voice your question during the Q&A break.  
	Finally, if none of those options are accessible to you email me Tim@NCIL.org and if you're only on the phone today and can't access Zoom for accessibility reasons you're welcome to hit star pound on your -- excuse me; star 9 on your telephone to raise your hand.  
	There are a lot of you on the phone and that can be overwhelming for me to manage so I really do ask you all use that as an accommodation so again if you cannot access Zoom and you need to ask a question, you can press star 9.  But I ask you to keep that for those that need it as an accommodation because we are -- I know we're going to have a busy Q&A break -- busy Q&A breaks plural on today's call so thanks for your cooperation there.  The last thing I want to mention in our opening is just the evaluation.  
	So there is a brief evaluation that we would like to ask you to complete after today's call.  When you close the webinar today, that evaluation should actually appear on your screen.  The link to that evaluation was also sent in the confirmation -- that same confirmation email with the connection instructions.  
	So it only takes a few minutes to fill out.  We really would appreciate your input.  And advice on what you thought and what we might be able to do better.  So I'll go ahead here to the next slide.  
	I mentioned the evaluation survey that I just mentioned and also includes Paula's email.  So I want to thank Paula for agreeing to do this two-part webinar with us.  I think you all know Paula, she needs no introduction any longer in IL but Paula of course is the IL-NET technical assistance coordinator at ILRU.  And I can't thank you enough, Paula, for being willing to lead us through the new COMP tool and let us know what we need to do and need to know about both ACL surveys and also assessing our own organizations.  
	I wanted to quickly go through here on Slide 4 these learning objectives.  
	So these are the things that we'll discuss today and remember this is a two-parter.  So there's a lot of content here.  And some of the things that you don't see we'll be reviewing tomorrow on the Part 2 call.  
	Hey, let me mention this, too.  While we're talking about that.  I know there's a number of you especially as things have changed with COVID-19 that may have found that you're not available for one or the other series.  Just please remember that recorded version.  So if you are not available for tomorrow's live webinar, it doesn't mean you need to miss that content.  So just give us a day or two to get the recording up at ILRU.org and you'll be able to access that information.  And you know Paula and I are both staff for the IL-NET project to we're not going anywhere.  If you come up with questions after you watch the recorded version you can submit them to us and we'll make sure you get an answer.  All right.  Back to Slide 4.  
	What we're going to learn today, regulatory requirements to perform annual CIL reviews and how to adequately communicate adherence to compliance during a review.  
	Second, aspects of CIL operations that must meet Federal requirements, including standards, assurances, program operation, organizational structure and administration of the CIL.  
	And finally, the CIL's level of regulatory compliance and readiness for a review by conducting an organizational self-assessment using ACL's Compliance & Outcome Monitoring Protocol, AKA, the COMP tool.  
	So with that, I'm going to turn it over to Paula and click to Slide 5.  And we'll go from there.  
	>> PAULA McELWEE:  Thank you, Tim.  Well, here we are.  We have a tool in our hands.  So earlier this year or late last year I should have looked before I started that line of thought, ACL sent out this information.  It's called the compliance and outcome monitoring protocol or COMP so it's abbreviated as COMP and they developed this as a guide to their surveyors, as their program officers come out on site or other staff or other reviewers come out on site to look at the centers but not just onsite but we'll cover that a little bit and look at how it's laid out because it's more than that and some of you are already seeing that it's more than that.  I'll show you that page later.  It is available for you to download.  There are checklists and forms and things that might be really useful in your own self-evaluation.  So we provided that link for you here.  It has already started.  It was late last year now that I'm -- started there's been full reviews as well as the other sites reviews so next slide, Tim.  
	So the purpose of this is to help us all be better at what we're doing when it comes to following the law and the regulations.  So there are compliance issues built right into the Rehabilitation Act so you'll see some of those sections referenced in the first bullet point the assurance are there the evaluation standards are there we used to call them standards and assurances and we still probably will use that term and there's specific places within the Rehab Act that it describes what a center must do, what a center must be.  So that's the basis for this document or this process.  One of the things that also happens as part of this oversight is the review of documents.  And probably most of you, maybe half of you, have received some kind of communication from your Project Officer about your Program Performance Report.  So that PPR we call it now it used to be the 704 report I used to sometimes get questions about whether it was being read or not this predates ACL but I remember those conversations.  No question about it this year.  
	That's were read.  Lots of people were asked to clarify things or add information or to verify that something that was stated made sense.  Sometimes to change actually, change their process.  
	So you'll see some centers with corrective action plans right now from that PPR.  
	That's one of the steps in the review.  It's not just the new tool I'm going to show you but also the old things that we had in place that are now getting some review so I find that really interesting.  But as they look at the oversight and the monitoring, they want to verify that your center is managed according to these requirements and the requirements are in the Federal regulation, they are in the law, the Rehab Act and also in the fiscal requirements that you'll find in the regulations.  Slide 7, please.  
	So they are going to look at your work plan in your PPR.  So that Program Performance Report includes a work plan there.  
	And one of the things they are looking for is whether that work plan is consistent with the State Plan for Independent Living.  
	And you'll see some other connections with that review where connections between Part B centers and the DSC and connections between the center's and the SILC and how it is being implemented are all part of this review process and they identify areas for improvement in your operations through this onsite thing.  
	They will provide you with technical assistance.  I'm available -- so far I've been available during any reviews so that even during the review if they wanted to, they could connect with me so I could provide you with some support.  
	So they want to make sure that you're following what you need to follow.  But they also want to identify areas of exemplary practice.  And make that available to the larger community.  Because sometimes we want to see that focus, right?  You would like to know that if they come to see you, they are also going to look at what do you do especially well and how can we share that with the field.  
	Slide 8.  
	So the purpose is to improve program performance.  The purpose isn't a got ya.  The purpose is we're getting money that has strings attached and we need to make sure that we are following the requirements for that money.  
	The Office of Independent Living Programs relies on that COMP to provide consistent Federal oversight of grantees.  And because they are doing that PPR review, they are reviewing at some level every single center.  Which is a huge difference from the past.  They are also as part of this doing some onsite reviews.  But they are -- every center is getting some form of review this year.  Think about that.  Isn't that amazing?  
	So you can use this COMP to understand what's required of you and conduct your own evaluations or if you get the call that your center is one of them that's got to be reviewed, you can think about how you're going to prepare for that.  And this tool is going to help you to identify those methods.  
	Slide 9, please.  
	So there's the Federal review of program compliance.  They look at those issues.  Federal review of outcomes.  Federal -- that's your plan.  Your work plan and other outcomes that you might have identified with other -- your Strategic Plan or other planning documents and then the Federal review of your fiscal operations and then the provision of technical assistance.  And all of these are components of the overall review.  
	Next slide.  
	So there are three tiers.  The first one is standard monitoring and it's a desktop review and as we just described the PPR is part of that one of the other things they are looking at is Standard Form 425 reports and sometimes that report is done by somebody else.  So we would just want you to know that your accountant person might be doing that report.  It's a very simple report on what you have drawn down and what you have spent but somebody in your office is doing that report and they are checking that report.  One of the things they are looking at is do your drawdowns make sense.  So if you're drawing down -- well, we'll come to that in a minute.  
	Focused review is the next part.  It's led by a Program Officer.  Your program officers are the ones that are assigned regionally.  There's another person for each of those regions.  And you have somebody assigned to your region.  And they look at the information we talked about.  But they also look at any red flags there.  And they ask you for follow-up.  So still desktop level.  But it's more focused on whatever things that they have seen that are problematic to them.  
	And then Tier 3 is the comprehensive review.  Now, the comprehensive review is led by a Program Officer.  It does bring a team of people to the review process to verify compliance with any of the areas that you have been identified as having a high risk.  But also just the overall review.  So they will conduct interviews.  They will require that you can show them paper that proves things that you're doing.  So those -- all three steps are part of that process.  
	Now, this webinar is looking at that process.  But we mostly are going to talk about that comprehensive review tool.  Because that's the piece that's new that we really all need to kind of know what's expected of us there.  
	Next slide, Tim.  Thanks.  
	So you will be notified if you're going to be reviewed.  The Program Officer will notify the center usually in writing, usually in email, to make sure that your center is contacted -- so make sure that your center's contact information is current by making sure your Program Officer knows if there are any changes, updating your listing which we preserve on ILRU's listing updating your listing in Sam.gov if none of this is familiar to you and you don't know what I'm talking about, drop me an email later but all of those have to be up to date so if you're a new director that hasn't updated those things or if you've had a change of address or any other contact information, you want to make sure that all of your access information is correct.  
	They will tell you what kind of a review you're going to get.  
	So they don't tell you that they are reviewing your PPR because that's routine.  But they will tell you if you're going to undergo a Tier 2 or a Tier 3 review.  And the notification usually looks at some kind of timeline and may even include information about the concerns that they are going to look at.  And that included information will be, you know, good for you to know about.  Probably you've had some correspondence with them about some of these areas already.  And then they are saying, okay, we're coming into review because at least in some of the cases that I've seen there's a lot more activity going on with the program officers letting you know what's expected and asking you to show how you're going to correct it so that's really a Tier 2 level when you get those kind of responses back.  
	If your review places you at high risk, you're required to develop that Corrective Action Plan.  And they have to approve what you said you were going to do as solving whatever the concerns were.  
	And typically that's where I come in.  Typically you would work with our intensive support program.  
	And I would help you or somebody else who consults with us would help you to develop and implement your Corrective Action Plan.  So you're going to see that activity happen if you are at any point in this process and needing to make corrections.  
	Next slide, please.  
	Now, if you don't answer the email questions, you will be placed in the high risk category.  You need to respond.  Usually they are giving you a deadline within the text.  You can ask for a reasonable reason to extend that deadline a little bit.  Not a lot.  But a little bit.  But you have to respond.  
	So when they are asking you questions about compliance, you need to be able to say what you did and why.  And if you have proof that you did comply or you just misstated something or data entry into your database was not correct and so your numbers were off, whatever it is, you need to take that corrective action to take care of it.  
	Now, during this process of moving you to a high risk category, if they found that you are not responsive to what you're required to do, that they have identified in that review, they can restrict your funds.  Then you're on a timeline that cannot exceed 12 months.  In the past under RSA, there were a few corrective action plans that I saw when I first came to work, seven, eight years ago, whenever that was.  
	That had been in place for a while.  Like two years or three years they had still been going back and forth with RSA on their compliance.  The understanding here is the timeline cannot exceed 12 months.  So you have to demonstrate that you're making progress on whatever area they are concerned about.  And you have to show that progress in no less than 12 months.  Now, they can take additional action.  We're not going to go into the details of the action they can take but they can actually move to terminate a Federal award if you are not cooperative and you have not showing progress, that's an application that ACL has within their process.  And there are a number of monitoring actions that could be implemented throughout that period.  So they might decide, for example, that you have to report on when something happens or that you have to provide them backup proof of something.  So you may be given other things -- other requirements that will help them to monitor your situation, whatever the concern is.  
	Let's look at that next slide.  
	Now, there's a lot more -- yeah, after this training, as Tim said, all of this is going to be posted of you.  If you're notified of a pending review, you want to come back and look at this information again.  Because this is going to be very helpful to you to actually present your case.  Your center's situation.  To your reviewers.  
	So keep that in mind.  If you're notified of that pending review, dig back into this material.  Don't hesitate to ask questions.  Because we want you as prepared as possible.  
	We want you prepared day by day.  Because our goal is if all of us are providing quality services and keeping with what's required, we're going to be better as a field so we want to talk about how you use this to improve your program performance, not just if they come to review you.  But the reality is some of you will be reviewed each year.  
	And so if you're notified of that, you do want to dig in here and get ahold of us.  
	Next slide, Tim, thanks.  
	Okay.
	>> Okay.
	>> Questions and answers.  I see Thomas has asked a couple of questions, I'm just going to dive into that one.  There is an intent to use non-Federal reviewers.  There is nothing in the -- there was not at least when we talked at the SILC Congress with the staff from ACL at that point they did not have the funds in the budget to be able to pay the expenses of the non-Federal reviewers.  So they were trying to find some other ways to approach that.  At this point last I knew, that had not been resolved.  So the whole question of non-Federal reviewers is an unanswered question at this point in time and we may get some clarification on that before the next reviews start.  But at this point in time we don't actually have the -- that information.  More questions?  I'm sorry; I jumped on that.
	>> TIM FUCHS:  No that's great just to remind you the Q&A tab is there to ask questions we would encourage you to use that instead of writing in the chat if you can't get the Q&A one you can email me at Tim@NCIL.org if you're using StreamText you can submit your questions there I'll be happy to voice them for you again I'll ask because we have a large audience that you only use this as an accommodation if you can't access those other options but if you're on a phone and can't access the webinar you can press star 9 to raise your hand.  
	Okay.  Dora has the next question follow-up.  Dora is wondering, will there be a SILC  COMP tool.
	>> Good question.  No.  There will not because SILC is subgrantee of the DSE if a review happens it will be of the DSE.  The DSE is already required to review you.  So the DSE is supposed to review whoever they pass money onto and that includes the SILC so there should already be in place a SILC process in your state between you and the DSE.  
	But that's not a process that ACL will apply against the SILC if they come in to look at the Part B money in the future they will look at the DSE.
	>> TIM FUCHS:  Thanks Dave from ACL shared in the chat in regard to Thomas' question they do have funds for non-Federal reviewers at the moment.
	>> I know the funding situation has just shifted and changed, right?  So I was pretty sure they would be rolling that out soon but they had not yet at the time that we talked last.  
	>> TIM FUCHS:  Charlotte is wondering if there will be new compliance indicators.
	>> No.  So as far as we know anyway.  At some point if ACL rolls back those indicators we'll see that but at this point we're not anticipating seeing those.
	>> TIM FUCHS:  Okay.  Great.  I believe we had somebody with their hand raised I'll go to their line now.  User 21 I'll open up your line and if you have a question, you're welcome to go ahead.  
	>> Is your microphone on or are you muted?  You could be muted on your line, too.
	>> TIM FUCHS:  Yeah, go ahead.  Caller, go ahead.  Did you have a question?  
	I'll go ahead -- if you do have a question you're welcome to raise your hand again later in the call.  All right it looks like we have one more typed question.  Paula, Michelle is wondering you mentioned they will have -- that they will have you submit a corrective action if you were put on high risk.  Do you have to submit corrective action on any findings, as well?  It sounds like it's an all or nothing kind of thing.
	>> PAULA McELWEE:  No it often is happening on findings right now related to the PPR.  So some of the folks who were cited related to things on their PPR that appeared that they were not meeting a requirement so if their PPR said that they did not have 51% or more Board Members with disabilities, for example, with significant disabilities, they would reply back to the center and say, show us your plan to come into compliance with this.  So that kind of response is happening routinely with the other kinds of reviews that the Project Officers have or Program Officers have.  
	>> TIM FUCHS:  Okay great.
	>> PAULA McELWEE:  Could I real quickly, Tim, share the page.
	>> TIM FUCHS:  Yeah; yeah, let me stop my share.
	>> PAULA McELWEE:  We're going to shift around here and I just want to show you this page real quickly.  It keeps telling me I can't.  There we go.  
	It's this one.  
	So what you have here is the document -- I just knocked my tea over.  
	>> TIM FUCHS:  Oh, no.  
	>> PAULA McELWEE:  I know.  This is the link for that COMP process and I want you to just notice what you've got here.  So you've got the protocol, which we'll be covering, the purpose of it.  And there's more information there than what we already gave you on the purpose.  Some of the components of the review.  So you'll find that.  But the part that I think you'll find the most interesting is the documents.  So you're going to find the guide for what to do.  It also includes acronyms and a glossary and some of the definitions there are definitions you want to look at that are, you know, associated with this.  And they will actually have the evaluation tool.  I'll suggest in a minute that you print that out and use it to mark all over it and do things so that you can keep notes on where you are with compliance.  It also has appendices for other tools so the financial tools in that appendices, there are some tips on notetaking that are also included so you can find a number of different documents.  I'll switch back now, Tim.  A number of different documents on that that will help you to actually conduct your own review of your center so you know where you stand because we feel strongly that everybody needs to do this review at some point so they really have focused on all of the different compliance areas.  Which sometimes in the day-to-day, we don't get that done.  But we need to.  
	So yeah, just keep that.  I see two questions and I'm going to answer them before we go to the next one just because we can, Tim, if that's okay.
	>> TIM FUCHS:  Please, yeah.
	>> PAULA McELWEE:  How do you prove a 50% disability?  You have to ask the person on the Board if they have a disability a significant disability that's how it's written in the regs if they say yes it's proven for you you don't have to have to have a doctor's excuse or any other proof of a disability the person just says yes, I have a disability.  It counts.  Same with staff.  Same with managers.  Same -- although you have some other caveats with the SILC Council but the SILC Council also has to be 51% so the consumer control goes across all of the aspects of independent living.  
	And then Brian asked if these are picked randomly or chosen based on previous issues.  And prior to WIOA, prior to 2014, they were required to be random.  With that change, the -- the result is that they can now choose to review for cause.  
	So you will see both of them out there.  So that's interesting.  
	We're not going to go real deep into this consumer control.  Get with me if you have an issue.  
	But you cannot require staff to tell you if they have a disability.  But you can ask them to volunteer.  Because it's helpful to your organization.  
	You have to avoid any appearance that you're discriminating against people with disabilities.  And that regulation kind of clashes with this disclosure from your staff.  
	So you do have to have some kind of a state but it doesn't have to be in the personnel file.  It can be a survey of some sort.  But again, the person themselves determines that.  All right.  Let's go on.
	>> TIM FUCHS:  Okay.  All right.  Here we are on Slide 15.
	>> PAULA McELWEE:  All right when you look at that evaluation tool, which you're going to print out, one of the ways you can print that out is if you print it on landscape, it's laid out on -- up and down.  My brain.  Up and down.  So you can leave yourself more notetaking space.  
	So you might think about different ways that you can do that.  Because you're going to want to make a lot of notes in some of these.  You're going to run across one where you really need to do several steps.  So you want to have room to do that.  
	Do not go through and say, yes, yes, yes, yes, yes.  
	Because if you don't stop and prove it, that is worthless to you.  
	You need to actually look at the question and make notes on how can you show that it's true?  
	Is there somebody you could suggest be interviewed to validate whatever it was that you said about compliance?  Is there a policy that applies?  Then put that policy number in there and go look at the policy and make sure that it meets the requirements.  
	Because as you go through these things, it's easy to say, I've seen people do this.  It's easy to say, oh, we're fine there.  Oh, we're fine there, and if they don't actually go back and look, then when they go back and look they say, oh, I didn't realize that we didn't say this.  We need to say this in our Board minutes or in our policy or whatever you're using for documentation.  So keep in mind that as you look at this tool, you're going to ask yourself all of the same questions that a reviewer might ask.  
	Your working draft should be messy.  It should not be a neat little type written tool that you hand to the reviewers and say, see, we're fine.  That does you no good.  Because the reviewers still have to verify it.  All this does good for you is gives you a place to write down what you do and verify it and it gives them a place to write down what they see when they come onsite.  And it should have proof that you can demonstrate whatever the requirements are.  And we'll give you some examples as we go through the requirements.  
	You're going to do a to-do list, as well.  So when you're going through this and you have all of those notes you'll run across things that aren't up-to-date so you'll have a to-do list that says update bylaws to -- bylaws to include and you'll make a list of what you want to correct in your bylaws you'll make a list of policies that need to be updated so your to-do list will be side by side with this evaluation tool.  
	All right, Slide 16, Tim.  
	Thank you.  
	What we're going to look at that's a primary part of this is right out of the Rehabilitation Act and it is those standards and assurances.  So you'll see standards and assurances in the Rehab Act.  And we want to take a look at that.  One of them is reporting whether the number of governing Boards with significant disabilities is and the language in the Rehab Act is actually over 50%.  So over 50% is 51% or more.  They mean the same thing.  And you'll see a lot of times the language that we use.  You know, it's more than 51% but either one is the same mathematically.  
	Now to do this, to report whether or not your governing Board Members have significant disabilities you have to ask.  There's a definition for significant disability that's in the Rehab Act.  And you can look at that and you can give that to them if they are not sure whether their disability is significant or not.  
	But one of the things that I say to people when they are trying to sort this out is, well, does it affect your life?  I mean is this a diagnosis that's completely not an issue in your life?  Well, then it's probably not a significant disability.  But if it affects your life whether or not you can do certain things that you would consider to be important to you, whether or not you really need adaptive equipment or medication or other things to help you function, then you probably need to look at that.  You probably do have a significant disability.  Significance doesn't have to do with what you look like.  A significant disability can be invisible.  
	And, vice versa, a person with a visible disability might feel like their disability is not significant.  They have the right to determine that for themselves.  
	But do give them the right tools to give them that definition so they can take a look at that.  
	The other thing you have to do here is prove that -- demonstrate that your Board is the principle decision-making body.  That means that if you have a Board of Directors who just says yes to everything and never discusses anything and votes however you tell them to, then you probably are the decision making person and not your Board.  And that's not okay.  Your Board of Directors -- centers were set up to all be nonprofits.  And your nonprofit Board of Directors needs to be showing their due diligence in helping you with planning, helping you with risk management.  Helping you with -- you know, with fundraising or things -- resource development, things that have to do with the fiscal responsibility.  And other things that nonprofit Boards do.  So you need to be able to demonstrate that.  Show that the Board is the principle decision making body.  Now, you might do that in minutes.  Probably that's one of the places you'll do it is show them minutes where they make decisions like they picked the auditor and they got the report from the audit and decided what the corrective action would be related to your financial statement audit.  
	You know, look at that and see, what are the decisions that your Board is making.  You probably have an Executive Director who makes the day-to-day decisions.  But the decisions that are important to the structure of your Board are the ones we're talking about here now the reviewers will be looking at all of the Board Members in the past 12 months.  They want to see them they want to know you kept a good record of what, if anything, going on.  You can show where the decision making happened.  They will also ask to see written policies and procedures so they are going to look for anything that you have in writing that tells what the Board does.  Some of you have something what you call a Board job description which description of duties or something is a little better because it's not really a paid job.  But if you have Board Members' duties and responsibilities or something like that, if you have a written document that you provide to the Board, especially during their orientation, their onboarding, hopefully that shows that they are the primary decision-making body.  But they will want to see that.  They will want to see policies, procedures, those descriptions.  And you'll need to have similar information related to employees and it's in two parts.  So the consumer control of staff, the first one is that people in decision-making positions, and you determine who that is.  Some centers it's just the Executive Director.  In some centers it's large enough that there's an executive and associate and fiscal person, you know, whoever you have in those decision-making roles.  51% or more than 50% of them must be individuals with disabilities.  Now the significant label doesn't apply here. 

	But they have to be people with disabilities who say, I have a disability.  
	And those who are the rest of the employees, also have to be 51% or more people with disabilities.  And the only way you know this is to ask them.  You can't require them to disclose this.  But you can ask them to tell you whether or not they have a disability.  Now, as you might imagine, as centers we expect that most people with disabilities would be glad to tell us what that is.  But sometimes there are situations where that's a difficulty.  They don't have to be printed on a list that says this, this, this, disabled but they have to be on a record somewhere that says they have a disability.  Usually that's some kind of a disclosure document that they volunteer to disclose.  
	Okay.  Let's look at the next slide.  
	So the next assurance -- the first assurance was consumer control.  That's what we just talked about.  The next assurance -- standard in the Rehab Act the reference is there is about self-help and self-advocacy so that's a requirement for all centers that you can show a record of self-help and self-advocacy among the individuals that you provide services to.  
	So take a look at, what are you doing?  And how could you show that you are assisting people to be more independent in their self-help and self-advocacy.  So do you participate in both individual and group activities?  Do you conduct those activities that show that there's self-help and self-advocacy going on?  Some people do this in their peer groups.  They identify, you know, system advocacy goal and the group works together on that goal and as they are doing that, they are helping to form what they would do as a self-advocate.  Sometimes that group, people come forward and say, I've got this issue.  Help me to figure out my plan of action.  
	You know, related to this.  
	So look at whether or not their goals and their activities show that you're working on self-help and self-advocacy.  
	And do you have some stuff first you look at the consumer service record but you might also look at the staff that could be interviewed.  You have consumers that could be interviewed.  Who could give you some examples of the activities that they did related to self-help or self-advocacy.  And then of course your consumer information file.  Now we're used to calling it a consumer service record.  That's not anywhere in the requirements.  So consumer information file is the term that's being used in the comp system.  Your consumer information files clearly include information about how you demonstrate that commitment to self-help and self-advocacy.  From your Mission Statement to your policies and procedures to the records of people who are served, it should be obvious that we're not here to do everything for people.  But we're here to grow up the next generation of advocates and people who are willing and able to do -- to reach out and do what they need to do in their own lives because that will also help us advocate with everything else we need.  
	18, Slide 18.  Thank you.  
	All right.  Peer relationships and peer role models is the next one.  And I want to spend a little bit of time on this one.  Because peer role models are not defined.  Advocacy is not defined in the law itself.  When you get over to peer role models and peer relationships or peer counseling, which is what the -- the term that the law uses, well, most of us don't use that peer counseling term because there are licensed counselors and the state has some restrictions on who can say that they are a counselor.  So most of us use peer relationships or peer role models.  Because it's not defined, this happens very differently from one center to the next.  So you need to know how do you define this service.  
	What counts?  What's a part of what you do?  Now, some people are doing groups.  So they say all of our peer relationships are in peer groups that meet.  You can have them meet for a specific purpose.  So it can be Veterans or it can be people with a certain disability or people who want to work on a certain objective together especially systems advocacy you'll see that a lot with these groups but how do you promote the development of peer relationships and peer role models within the community of people with disabilities that -- within the community of people with disabilities that connect with you?  So you need to know.  What is your model?  Because you see everything from a one-to-one model.  We have quite a bit of information about that particular model on our Website.  But you also see people who do only groups.  And you see a mixture.  You see some peer support folks who put together their peer program as a staff to consumer relationship so you hire people with disabilities as staff and they may be providing some of that peer support or peer role models.  Staff can provide that.  
	So figure that out for yourselves, what is it that you do at your center, what do you call peer relationships and peer role models?  And we've been operating under the expectation that you can only call it peer role models.  If they have a goal related to it.  Now we continue that discussion of what counts and doesn't count on the PPR.  And we will probably continue to sort that out a little bit.  But when you think about this process, that's how we have treated it before, if they have a goal, if they have a goal in their planner, if they have waived the plan, you have written down a goal, then you can count it as peer relationships or peer role models.  Otherwise it's something else.  Outreach or system advocacy or some other I&R, information and referral is one of those.  So as you look at that process, that's a real important one to take care of.  
	So what does your file say?  What's the information?  How do you demonstrate your commitment to peer relationships?  Because it's a key concept.  One of those standards that we all adhere to.  So how are we doing it?  And are there peer role models that are a part of it that aren't just staff?  Or aren't just other people -- and then your policies also need to go with that.  
	How about Slide 19?  
	All right.  This is equal access.  Now, that's another one of the standards.  And this is how do you promote equal access for individuals within the community?  
	Now, they do define this.  Equal access for the purposes of this question means that the same access is provided to individuals without disabilities is provided to the -- in the center's service area to individuals with significant disabilities.  
	Often we actually play this out through some kind of an advocacy role.  But equal access is a standard of itself.  We need to make sure that people have equal access.  So as you look at your community and you look at the things that people are telling you they can or can't do, there should be really and solidly clear evidence that you're active in the community to promote equal access.  And you need, again, to demonstrate how you do that.  
	That would be true with anything that you do in the community.  As well as anything you do internal, you are also supposed to promote equal access internally.  Internally and externally.  Within the community.  How do you identify where there isn't access and what you're going to do about it.  And then as the reviewers come in, how do you staff or consumers or both who could be interviewed and show how you achieved equal access in some specific situation?  And then your policies and procedures should also look at that equal access piece.  
	All right.  Slide 20.  
	Language access is part of equal access.  So you're going to see this pop up.  And you're going to ask yourself the question, okay, what languages other than English, are used in the service area in a predominant way?  
	How do you make that information available to people whose English proficiency might be limited?  They may speak English but they are wanting to understand at a deeper level and you don't have English access as a thing that works for them.  How do you deal with that?  So what is the material that you translated would be one question?  Are all of your written policies and procedures and materials and other things available if people ask for it in alternate formats?  So in Braille, in large print, in audio tape, electronically?  You know, what are your -- what are you doing?  Are you willing to say, any document we put out we're happy to put it in large print or we have a Braille printer or we have access to -- and we can do all of this.  
	Audio tape is actually what it says in this stuff.  I know nobody uses audio tape anymore.  Audio is part of that.  
	And then of course, some of this is access to individuals with intellectual disabilities who don't read well because we're talking about some of this is written material.  And also people who are deaf.  Because their language, vocabulary and approach to things is not going to be quite the same.  
	So how do you address that?  And in your written policies and procedures and in your actual operations, how long did it take you to get an interpreter if someone who is deaf comes in for services?  And how and when do you align that?  You need to know.  You need to have a policy and procedure and you need to be able to demonstrate that.  So language access is one of those.  
	One more.  21.  
	So what about the physical accessibility of your space?  And I hate to tell you this.  But there are a lot of centers out there who have not achieved this kind of accessibility.  And it makes me uncomfortable when I visit.  And I think, whoa, what are we going to do here, you know?  
	How do people with mobility disabilities access doors, bathrooms, parking lots, et cetera?  
	So I visited a center that has since moved elsewhere.  Will remain nameless.  But one of the things they did was they had a bus stop right at the -- by the building.  But the only entrance into the center part of the building was down a steep driveway into the parking lot.  Too -- far, far too steep to meet ADA for sure but far too steep any practically speaking.  Like I would not have wanted to take anybody down that path.  I wouldn't have been able to assist them with control, even if they had my help.  So it was definitely not accessible.  And yet, the center had not addressed that earlier.  And so you sit there and you look at the situation.  And you think, what's happening here that no one here processed the fact that they are not practically speaking accessible?  And if you really do an honest to goodness review, a full-fledged ADA review of your space, I think you will probably find some things that you could improve.  Parking lots is one of those things.  Doors that open or close with too much pressure.  Signage.  Where it is, how high it is.  Is it in a format that other people can use like a tactile or large print or both?  
	And then policies and procedures around environmental access.  Do you have a no fragrance policy?  Do you use -- what's your cleaning process?  Do your cleaners use something that's going to be not too pronounced?  Is it going to happen probably Friday night so that it has the weekend to dissipate before Monday morning?  Do you request that visitors not use fragrances?  These are all real life issues that I see centers not always applying.  So you might keep that in mind, too.  
	22.  
	There is an accessibility check here.  Now, you may have a formal ADA review.  I recommend it that.  You really take the time to do that.  You should know the ADA.  Maybe you can do that with your internal staff.  But at the very least, use this CIL Accessibility Checklist.  It's in the materials.  On the Website.  
	And you will -- you will be expected to complete it -- to note what improvements are needed and what policies and procedures apply.  And you're going to present that when they come onsite, if they do.  So start now.  
	Do that review.  Correct the accessibility issues that you identify.  And then you can demonstrate what action you took.  Even if you missed something in your process, you can demonstrate what action you took for that accessibility to be improved at your site.  
	Next slide.  
	Now, we're still going through those assurances, standards and assurances.  
	One of the things every center must do is provide services on a cross-disability basis.  We can't serve only one disability.  And we need to make sure that we're looking at that.  
	So if you look at your last PPR, and the people who come and go in real-time, you should be able to know are you serving people with a range of disabilities, you should be able to show that in your numbers.  You are required to do disability determination.  So what is your process?  Can you show that people who you serve, verify that they have -- there's that word again, significant disabilities.  So a setter -- a center is supposed to serve people with significant disabilities.  And that's a requirement.  And you are required to do determination of that.  
	So what is that process?  Of course, like I said, you are not required to do medical review or anything like that to accomplish this.  But you do need to ask the consumer, do they have a significant disability.  You need to give them the definition if they need that.  
	You also have some processes whereby you are already determining who is underserved or unserved in your state.  That's part of your state planning process.  That's part of your individual center planning process.  So what have you identified?  And what are you doing to improve the access that those folks have to services.  
	So take a look at that.  
	And do you have additional unserved or underserved people that are specific just to your center?  The rest of the state isn't working on it.  But you know you have this huge population of, you know, whatever group it is.  
	So how do you serve them?  What are you doing to make sure that you're reaching out to the Deaf Community, for example, is often one where if centers don't have an interpreter readily available, it's very difficult for you to provide reliable services for that community.  And so sometimes you'll find that that's a gap.  And you want to say, okay, well, what are we doing to change that, to improve that?  So cross disability think about all of your disability groups of course you may also be thinking about other underserved groups but across all disabilities.  
	And 23.  
	>> TIM FUCHS:  Got a little wild with the cursor.  
(Chuckles).
	>> PAULA McELWEE:  I think I wanted to 24.  I think I was wrong about the number.
	>> TIM FUCHS:  There we go.
	>> PAULA McELWEE:  There we go.  And we're going to get to those questions after just a little more here.  So give this -- be patient.  
	Do you have that consumer information file?  This is the next thing.  You have to have independent living goals according to this standard.  It is not required that you have this formal plan.  They can waive that.  But your documentation of the eligibility for services should be one of the things that's contained in this file.  
	It can be electronic.  It does not have to be paper.  It can be paper.  
	But probably a consumer is going to sign a statement that you provide them with that says, yes, they have a significant disability.  Because that determines their eligibility.  And you need to record that.  Put it in the file.  So that it can be reviewed by the -- you know, by the reviewers when they come onsite.  Now, I had an interesting question last week, somebody just looked absolutely stunned when I said, everybody has a goal.  And they said, well, but they can waive their plan.  
	Yes, they can waive their plan.  But we are required to look at whether or not they set goals and whether or not they met goals and the only way you can do that is to write them down when somebody tells you what their goals are, whether or not they agree to a plan.  
	So just kind of keep that in mind that you are expected to still do goals, written goals, whether or not a formal plan is in place.  So keep that in mind.  
	And then of course that's the other documentation that probably will be on the same document.  And that is to notify them of their right to develop or waive the development of an Independent Living Plan.  
	Yes/no statement usually.  Can you show the numbers of how many waived it and how many accepted a plan?  Often that's on an entry level form where they apply for services and that's one of the questions as they apply for services.  So you want to take a look at that.  
	25.  
	All right.  What we are understanding is that you still have to have written goals, even if you don't have a plan.  
	So does the file include notes that indicate what services were requested?  And what services were provided or arranged or assisted with for the consumer?  
	Have they noted what their goal is so that you can write down whether they achieved it or not?  
	Do your notes document completion of those goals?  And if the consumer believes they have achieved those goals and objectives, sometimes your opinion and mine about whether or not the person has achieved a goal may be different.  And it's their goal.  
	So we need to know whether they feel they did.  
	Did the ILPs indicate the goals and objectives established?  The services to be provided?  And the anticipated duration of services?  Those are things that need to be a part of that Independent Living Plan probably using going to want to write those in the notes, whether or not there is a formal plan and does the plan indicate that it was jointly developed?  Does staff sign it as well as the person who is legally responsible for the person with the disability and as I said earlier, electronic or scanned signatures are acceptable for that but you need to show documentation that that's the case.  
	And you need to be able to identify how many waivers you have.  
	It's a really interesting thing to look at that.  Because some centers have almost no waivers.  Because they say to the person, well, we're going to write down some goals, however you want to approach it.  You could have it in a formal plan or not.  But we're going to write them down.  Well, then it's just like, oh, okay, let's put it in the plan then, it doesn't matter.  
	And other centers have almost no plans.  Almost everybody waives the plan.  And when it falls too much in one or the other, I always kind of wonder what the staff's philosophy about that is.  And so you are going to need to identify it.  And maybe identify what it is you say to the consumer to help them make that waiver or plan decision.  
	And then 26.  
	Satisfaction and complaints.  This is, again, something you would probably do at intake.  Did you provide consumers' information on the process to express satisfaction or dissatisfaction with the CIL services?  Did you let them know that they can appeal?  And when we switched over from RSA to ACL, one of the things that I heard some folks say is, well, we can't still go to the protection and advocacy folks, right, because we're not with RSA anymore.  No, you can still go to them and in fact that is part of the expectation.  They are there to give support to people on complaints.  So that the person can complain through those people who are listed in system advocacy with the center so it's still appropriate and that's still what you should be telling them.  You should be providing them with that information so they know what they can do.  You may have other steps, as well.  You may have other ways that they can fill out a complaint form if they want to or do phone complaints through a hotline or whatever you want to work up.  
	But that is also -- needs to include the P&A as part of that.  
	And did you document a notification to the consumer on the existence of or client -- I shouldn't have said the client -- Client Assistance Program.  Some states it's the same.  Some states it's not.  
	And do they get that in an accessible format if they want it?  So if they are using accessible formats for anything, this is a document you don't want to miss.  They need to be told, yes, you can complain.  And here is who you contact.  And give them that information.  
	And also, did you notify the consumer that they can request an accessible format?  And again, if you have a checklist at intake, you can cover a lot of these in an overall checklist format at the time that people start services.  
	All right.  How about 27.  
	I'll come back to this.  Let's do some Q&A right here.  Because I see them adding up over there.
	>> TIM FUCHS:  Okay.  Let's start at the top of the list.  
	So Maria asked, if we're providing resources to individuals during an I&R call could that be an example of self-help or self-advocacy?  
	>> PAULA McELWEE:  My favorite answer is it depends.  It may be if that's the topic.  So if what you're doing at the time that they are asking for some kind of information, if it's related to that, of course.  So if you're assisting them with an I&R related to self-help or self-advocacy then it absolutely would.  But if you're not, you know, it goes either way.  So other questions?  
	>> TIM FUCHS:  Okay.  Thanks.  
	So Maria says, can we use participation on statewide community-based services committees for equal access?  So if we're advocating for community-based services is that considered equal access?  
	>> PAULA McELWEE:  Well it certainly can be, again.  You define a lot of this yourself.  But if you ask yourself the question, is the result of my action that more people can access this, then you have done work on equal access.  
	So if you're assisting whoever it is out there to be more accessible, you're helping them understand what alternate formats would be or whatever piece that they are missing that you're assisting with, then that would be -- would work certainly on equal access.  
	>> TIM FUCHS:  Bill has got a question related to the pandemic and the fact that the recommended cleaners have a lingering odor, how do you handle that with your staff and offices?  
	>> PAULA McELWEE:  What most of you are doing is that you're not meeting in your offices.  And that sounds harsh right now.  But the reality is if you have people coming and going from your office during this pandemic because you feel like what you're doing is essential, which, I agree, it is, but if they are working in your offices, you are responsible for the cleaning.  And you've got to make sure that you have completely sanitized anything that anybody could have touched.  Restrooms, the front corner, you know, the area of the break room.  You know, all of it.  You have to make sure that it's done.  And it is harsh.  Or the individuals themselves, if you want to have one individual come in and only clean up, you know, scrub up after themselves, that's also an option.  But what most people are doing to resolve that is they are not requiring the staff come in during this time and letting them stay at home and clean the way they want to clean at home.  And they are not seeing people face-to-face.  Because they are doing the social distancing.  And they are not going into the office because it's so complicated as soon as you start having people in the office where you would be also expected to disinfect.  
	And it is very harsh.  
	>> TIM FUCHS:  Right.  To the similar question from Marie about shared spaces, you know, regardless of COVID-19, that's an opportunity for advocacy with your landlord or your building manager or your -- the other organizations or companies you share office space with.  I know in our office, we do share a space.  NCIL does it's an uncomfortable conversation sometimes and people don't understand but you have to make them understand it.  And make that work.  So all right.  
	Let me look.  
	Holly says -- oh, there was another one from Marie about requirements for all gender restrooms.  I wasn't sure if she meant why it was or was not included.
	>> PAULA McELWEE:  Yeah, you need to make sure that you are meeting whatever your state requires.  But I do think that having single restrooms is a good solution to many different kinds of issues.  So you know it can be a family accessible restroom, too.  But that allows you to have lots of freedom to make sure everybody has access.  So I suggest it.  That you have one or more single person restrooms that can bridge any of those divides.
	>> TIM FUCHS:  Next question comes from Holly it's always been my understanding that people with disabilities receiving services are self-reported.  Are we now being required to verify.
	>> PAULA McELWEE:  The self-report is the verification that's kind of tricky so you've always been required to say that you are serving people with a significant disability and the only way to know that is to ask them.  You don't have any other reason that you would ask.  They don't have to prove it to you, you just have to ask them.  But that's always been the case.  
	>> TIM FUCHS:  Great.  
	Okay.  Someone reliable NCIL question mark I like that hey we think we're reliable said that the Trump Administration is proposing to have ACL conduct site reviews remotely.  Not actually onsite.  Maybe to save money.  Should we like this idea or not?  
(Chuckles).
	>> TIM FUCHS:  It's a little further down that road than that, Paula do you want to address that question?  
	>> PAULA McELWEE:  Yeah what you just saw in the very beginning of it has both an onsite and a remote component.  And so the remote ones are going to happen no matter what.  The onsites are going to happen based on budget and there is money available that wasn't available that we'll see how it's all going to be spent.  But I think they may now have the funds to do it -- to do more.  This Fiscal Year they have done some onsite.  And I think they will do as many as they can free up staff and travel budgets to do.  
	But they are doing both now.  They have been doing both.  Did you have another observation on that, Tim?  
	>> TIM FUCHS:  No; no.  I think that covers it.  
	So I got -- we got, what, four minutes to get through four questions, that sounds doable.  Nicole has the next question, so if we have electronic files, can we get rid of our paper files?  If we have everything stored properly online?  
	>> PAULA McELWEE:  Yes.  
(Chuckles).
	>> PAULA McELWEE:  I always say that and then I want to hyperventilate because I'm afraid somebody will decide that's no longer the case and if they are gone, they are gone.  We do suggest that you keep all of your records at least five years.  Although there are some requirements that are less than that.  
	Always keep them if you have anything that you need to keep for legal reasons.  Like you're in the middle of something that is legal in nature and you don't want to mess with purging those files.  But you are also allowed to purge files of unimportant old information.  
	So in addition to having electronic files, that's an option for you, too.  Just be very cautious that you're not getting rid of anything that would be later considered an issue.  
	>> TIM FUCHS:  And I'm sure you all know this.  But also with ample consideration of confidentiality, security, and backups.  So it takes some of the nail biting out of online documents if you know that your backup process is sure to keep things from truly being lost.
	>> PAULA McELWEE:  Yeah but the cloud is really -- has really changed things, hasn't it.  The ability for you to have completely offsite resolves issues like the terrible fires we had in California last year where people had to get up and move and take everything.  Well, what are you going to do in that situation if you lose those files?  Well, guess what, if my computer is gone, I still have access to those files.  So making sure that you have that access is a key part of that.
	>> TIM FUCHS:  Yeah, thanks.  All right, Freid asks we document disability the consumer via a conversation.  Though it -- that might be written on an intake form or documented on a consumer data space, is that adequate.
	>> PAULA McELWEE:  Yeah.
	>> TIM FUCHS:  Great.  
	>> PAULA McELWEE:  They do want to see a signature usually, though.  Let me back up.  On an intake form that has the yes/no.  But you always want to know what things are impacting their life.  That's the only way you can assist them with what's going to come next.
	>> TIM FUCHS:  Yeah.  Emeril has a question about writing goals.  So what about consumers that are on a four-year waiting list for things like bathroom mods.  Ongoing goals or quarterly reviews for a lot of the consumers.  Do we need to get even more detail to break things down?  
	>> PAULA McELWEE:  You know, the issue of how detailed your plans are, you do see a lot of variation out there.  But I would say what does it take for you to be effective.  And if that's what you're looking at, what does the consumer need to share with you so that you know how to support them in their own self-advocacy, in their own efforts to change their life and their situation.  
	A four-year waiting list for a bathroom, you better have found another situation for that person.  I mean, you better really be looking.  And I'm not trying to pick on you.  
	But the reality is, sometimes we just think, oh, yeah, somebody else in the community has that job.  It's their job to do that.  So I got them on the waiting list so we're good.  No, you're not.  He still can't use the bathroom.  So how does that affect his life?  What else can you look at that is an option?  You know from taking the door off the hinges and putting a curtain up to whatever else the heck you need to do, what can you do that's concrete that helps that person have access in their life?  Equal access to things like bathrooms.  So I guess I would say -- I would challenge you that you really do need to look at how you can assist the person with their goal, which is to be more independent in their place of living, then maybe they need to live some place else maybe.  But don't stop looking just because they are on a waiting list.  You may not find an easy answer but don't stop looking.
	>> TIM FUCHS:  So Paula, this one is partially for us but really for ACL, Peter is wondering, he says our state does not allow electronic signatures because we don't have documentation that ACL will accept them.  So could we have it in writing that you all will.
	>> PAULA McELWEE:  Good question for ACL.  Yeah, actually there's actually regulation found in the uniform guidance on finances that is a part of the electronic records you know saving the world from extra paper stuff that does allow that and Peter, remind me and I'll send you that reference.
	>> TIM FUCHS:  Along the same lines, Danny says, can we be provided with some best practices for going electronic?  So that's a great idea for future training so we'll bring that up with our training team.
	>> PAULA McELWEE:  Dave wants us to know that it's paper reduction act.  Thank you, Dave my mind sometimes will not think of the words that are on the screen in front of me.
	>> TIM FUCHS:  Yeah.  And let me get to -- this one is easy Hilda is wondering is maintaining a cloud service an allowable expense so can people use their grant funds for these types of things.
	>> PAULA McELWEE:  Absolutely, yeah it's that or a storage shed, right.
(Chuckles).
	>> TIM FUCHS:  Hey, we've got two questions but I want to get back to the presentation.  Make sure we can finish.  Paul has got -- Paula has a few more slides and we'll do another Q&A break before we end.
	>> PAULA McELWEE:  The one that's been up on your screen that you're looking at there has to do with the written plan and file.  I'm not going to go into any detail there but you just need to ask yourself some questions about other things you need like when do you need to get a release of information?  Well you can have that form in your packet.  But if you're not sharing information, you don't need that form.  There are lots of things like that, that just look at whether or not it makes sense for that person.  What are you doing and who is involved and sometimes the whole issue of is the person their own guardian, yes, but Mom wants to be involved.  Uh-oh, you know, you've got some of that going on, especially with youth as they transition.  So you need to figure out all of those ins and outs and you need to have policies and procedures about them.  28.  
	Thanks, Tim.  
	There is actually a checklist.  So in the documents that we mentioned that are in the appendices of the COMP system, there's a checklist for the Consumer Information File.  And so you can actually look at that checklist and you can do the same thing.  Don't just mark yes, yes, yes.  But take the time to say, where is our policy.  Let's look at a file and make sure it's there.  Let's figure out if we need a new form here.  So you actually use it to  conduct an internal file review.  
	Now, that's a great thing to do right now when you have no people there.  Take the time, right, to say, okay, we're going to do a review of the files.  
	Now, you can do that practicing social distancing onsite if you want to.  And a lot of us it would be too hard to get those files some place else but if you have everything electronic, you can find ways with your database provider and they will help you understand how to make it work on a remotely situation and still keep it confidential so it's possible.  And hey, what a great idea.  So let's look at the next one.  All right.  That was it.  I couldn't remember.  
	All right.  So the last one on community options and community capacity that you want to look at is aggressive outreach.  So you'll see that in one of these questions on this slide.  
	What is your aggressive outreach to individuals who are unserved or underserved so what are you doing to make sure that you're finding them, that they know about you?  That they have an opportunity to connect with peers related to you?  So that that's all part of what you want to make sure you have in place.  
	So what is your aggressive outreach?  
	And have you performed outreach with minority groups or have you realized that a lot of your service areas are away from the city and you're serving the city okay but the people out in the country don't have any access to your services?  Those are other issues that you might want to take a look at.  And make sure you've got that.  
	And have you collaborated with those other service providers to make sure that those organizations that benefit the people that you serve are also engaged in some way in your planning or in your network or in your I&R service provision and so forth.  
	Okay.  More questions, Tim, let's finish them up.  
	>> TIM FUCHS:  All right.  Great.  So Michelle says, I keep -- I keep saying that I'm going to go to look up the replacement for the Section 34 CFR 364.40 which pertain to eligibility would you know offhand what the new CFR is or has it been changed the reason I ask is because I still have that old CFR on my forms.
	>> PAULA McELWEE:  Yeah so what you need is 45.  So if you have a 34 in front of anything, that's all RSA.  If you have a 45 in front of it, it's something within HHS.  
	And so we're -- our new regulations have a 45.  And the one that you want for the financial things is 45 CFR 75.  So there you go.  
	And then the regulations related to the services you'll find it 45 CFR 1329.  So you've got -- you know, that's also a good place to look.  
	And then in our case, the law itself has a lot of this stuff we really need to know and adhere to and when it's written in the law itself we still need to do it so you might not find all of that in the regulations.  The detail might be in the Rehab Act itself.
	>> TIM FUCHS:  Okay.  Thanks.  This last question comes from Alexa so the waiver of an Independent Living Plan is something we deal with and usually people are concerned that they may -- it might not be flexible enough to change later even if I tell them that they can do that.  So what might you recommend for explaining the difference there?  
	>> PAULA McELWEE:  Yeah, you know, when I explain it to staff, I get more blunt than I would probably with a consumer.  But the way I understand that it unfolded this way, with the waiver, is that RSA had determined that they wanted us to write down goals, we negotiated as best we could to say now wait a minute.  We don't want to do an Independent Living Plan in the same way that an IEP is done or the same way an IWRP is done or any of those other plan documents out there because they have certain structure and you have to involve the people that the organization wants, who the consumer wants.  So we had this philosophical conversation around what is a plan and what does it look like.  So finally, they said, okay, we get it, you can waive the plan.  But you still have to write down the goals.  
	So what I do when I explain -- when I explain it to stay, I say, so where are you writing down the goals, the goals of that consumer.  Because if you need to capture it, how else are you going to know where you're going, how else are you going to know what they want you need to write it down even if you don't do it in a plan process the thing about a plan, a plan is often done by a group in other kinds of services.  So we want to make sure that we do it with the individual as the primary person and we want to make sure that we capture their goals so we can see whether or not we're doing our goal to help them get to those goals.  So I don't know if that helps, if that's a way to explain it.  But tell them that that's part of holding you accountable.  Yeah you may hold them accountable, too, but they need the right to hold you accountable to whatever you say is going to happen with your role in that plan.  
	>> PAULA McELWEE:  And Alexa clarifies she says I'm asking --
	>> TIM FUCHS:  She says I'm asking how to explain it to consumer because if we say we want to work on their goals they want less paper and et cetera.
	>> PAULA McELWEE:  It helps when you get to where you do it all electronically it doesn't seem like quite a stack of paper.  You pull a file out, you're looking at it differently than when you're looking at it on a screen but you're right and they have probably a lot of paper in their lifetime most folks have whether it's medical reports or Social Security related stuff.  Just think about all of the paper that goes across their life for each of those consumers and it is often a lot.  
	But you know write it down to keep us all on track.  And check now and then to see whether we have done it.  You know, make sure that we're doing what we said we would do.  And then at the end of the period of time, you need to check back and say, okay, this is your PPR report opportunity.  Can we get it done?  Have we assisted that person?  
	>> TIM FUCHS:  Yeah, Carrie was wondering if there was a recommended or required structure or content for an ILP, an Independent Living Plan?  
	>> PAULA McELWEE:  You know we have on our Website and I don't know if Sharon is still around and could post it on the chat real quick.  But we have -- we did a two and a half day onsite training on service coordination and kind of all of the different pieces to how to provide all of the services.  It was a really great set of presenters.  It's all on video.  It's on our Website.  
	Along with the forms.  Along with sample forms that they had and policies and procedures.  From this group of -- I don't know -- Tim do you remember how many Executive Directors?  I can come up with five or six.
	>> TIM FUCHS:  Yeah five or six.
	>> PAULA McELWEE:  Off the top of my head that may not be them all and several of them are on this call.  So I remember that.  Because they were also on that body.  
	But anyway, that link to that training is really excellent for that purpose.  
	It has, like I said, samples and you can also watch the video where people explain what they did.  And then they have the sample forms and policies and procedures.  So yeah, you can find that.  
	We also have a service coordination manual that we have done that has some of that information in it.  So I don't know if -- if she can't get to it, I'll make sure it's posted on the page with this transcript and slides.  
	>> TIM FUCHS:  I just put it into the chat.  
	>> PAULA McELWEE:  You're so good.  
	>> TIM FUCHS:  And then if you all have any questions, just let us know.  You know.  
	And that's one of the things, too, especially with so many people on the phone today I just want to mention, that we really do, we have so many of these ondemand trainings and this is something I feel like we talk about a lot at our own location trainings and maybe not enough on these webinars but there are hundreds of trainings they have all been recorded and along with that are all of the PowerPoints and presentations and handouts arched forms that people have done so if you ever feel like you need a hand like it's too much, you know, you need a little orientation, there's two things.  First of all, you can reach out and we'll walk you through it.  And second of all, we do an orientation each year some of you may have attended the orientation we did in December but even those are recorded.  
	>> PAULA McELWEE:  That's recorded too.
	>> TIM FUCHS:  Get a walk-through of the resources that we have and a walk-through of the Website so if you're new to your center or if your role has changed, it really can be helpful to get a refresher on that.  I thought I would mention that.
	>> PAULA McELWEE:  Yeah, we do have a good search engine that's on that page that helps you to find things but sometimes especially if you're new you don't even know what to put in the search you know kind of vaguely what you want it's okay to reach out to either Tim or I with a quick email and just say, I'm looking for X.  And then we can send back where you find that.  We can give you the same kind of thing he just gave you in the chat a more complete link so you can find it easily.
	>> TIM FUCHS:  Well those are the questions that we have Paula anything from these next couple of slides that you want to go through since we have an extra couple of minutes.
	>> PAULA McELWEE:  Sure, let's go take a look.
	>> TIM FUCHS:  I'm on 31.
	>> PAULA McELWEE:  31 can you document provision of all of the core services.  So one of the things that we want to look for is every one of the core services is represented somewhere.  This is one of them that quite a few were cited on in your PPR if we didn't see or if the Program Officers didn't see that you were providing every one of these core services, then you were cited for that.  And asked to show how you were going to deal with it in the future.  
	Now, documentation of all of these doesn't have to be services if you're doing something big like with transition of nursing homes, sometimes you do a lot of groundwork.  And that groundwork also counts.  You know, meeting with the discharge person at the nursing home.  You know, meeting with the person who makes those decisions.  
	Helping them to understand what we can do and why and maybe helping them understand that maybe the people that they are finding too independent to be well served in a nursing home setting, we may have an alternative there.  
	So do take a look at all of the core services.  
	One clarification on youth, it's a little unclear in the PPR maybe.  Because we've -- we list youth as being from 14 to 24.  
	Or through 24.  But what happens with that youth is that you can serve young people.  But the specific service of youth transition is postsecondary.  They have to be out of school.  So it's not real easy to see where you plug that in in the PPR but you need to make sure that you've looked at postsecondary so the transition of individuals with significant disabilities who were eligible for IEPs and who have completed secondary education or left school.  
	And we're still seeing some confusion out there related to that one, especially.  
	So make sure that you do take a look at that.  
	And I think we have one or two more?  
	Oh, besides that -- yeah, I need to remind you about this.  So besides the core services, you are required in the Rehab Act to provide two other services.  
	And here is a list of what those other services are.  But one of them is other.  So you know, it's a lot of them.  
	But there's quite a few of these that we have outgrown.  I don't think you'll ever see it at a center.  
	So you very seldom would see for example psychological or psychotherapy particular counseling services.  
	I have only seen one in the time that I've been doing this.  It's an option, though, that's allowed.  So you can do it or not do it.  
	But transportation I see a lot.  Right?  
	So taking a look at all of these services.  Do you do at least two of these?  Housing of course we see a lot.  But housing is not a core service.  It's in the other category.  
	And some of the stuff on your PPR falls from this list, as well.  
	>> TIM FUCHS:  Right.
	>> PAULA McELWEE:  Okay.
	>> TIM FUCHS:  Well, we actually already did our final Q&A so I'll click ahead to Slide 34 here and there's a couple of things I want to mention as we close.  
	First of all, you'll see here that the evaluation link is included.  This isn't a live link so unfortunately Zoom doesn't allow you to click on this.  But again, if you close the webinar today you should see that this evaluation will actually open in your browser.  And if that doesn't work or if you don't see it, that same link was included in the confirmation email.  So please do take a minute to share what you thought.  We take those really seriously and we're always looking for your suggestions.  
	And then lastly, I saw a couple of notes in the chat from colleagues.  Just a reminder that for your staff, whether you have new staff or whether you have staff who are looking for support during this change to remote work, that those ondemand trainings are a great place to start.  There's a ton of content there.  And aimed at every staff position you can imagine within CILs and SILCs, Board, as well, so please do take advantage of those.  
	And I wanted to mention, as well, we're getting ready to announce -- you'll see very soon we're going to announce a webinar coming up next week on the 7th on Tuesday afternoon, about telework.  And connecting with consumers during the COVID-19 pandemic.  
	So I know a lot of people are looking for support and answers there.  We had that big webinar on the 20th that was kind of an overview of all things CIL and SILC during the pandemic but we want to drill down into telework and maintaining connections with consumers.  So be on the lookout for that announcement.  
	And I see some items in the chat.  But it's 2 minutes after 4:30 here on the East Coast so we'll have to move to close.  If you have any questions that you didn't get to ask live on the call please don't hesitate to reach out to us.  I hope you all have a great afternoon.  We'll talk to you soon.  Bye bye.
	>> PAULA McELWEE:  Thanks, Tim.
	>> TIM FUCHS:  Thanks, Paula.  

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This is being provided in a rough-draft format.  Communication Access Realtime Translation (CART) is provided in order to facilitate communication accessibility and may not be a totally verbatim record of the proceedings.  
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