ROUGH EDITED COPY 
IL-NET National Training and Technical Assistance Center for Independent Living presents…
What You Need to Know About the New State Plan for Independent Living (SPIL)‑(Dual: Zoom/ST)
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>>  MODERATOR: Hi, everyone, I'm Tim Fuchs with the independent council on independent living.  L What You Need to Know About the New State Plan for Independent Living (SPIL): A Comprehensive Overview of the SPIL Instrument and Instructions.
With us today we have Regina Blye and Paula McElwee who I'll introduce in a moment.  Before I kick the call over to them, I just wanted to go through some housekeeping and accessibility stuff first.  First and foremost, captions are available in Zoom.  I think you all know that.  You can, if you don't see them running, you can open them up by selecting show subtitle in your Zoom options.
And newly available, you can now manipulate font size of captions in Zoom which is pretty cool.  If those captions aren't big enough or say you're only on the telephone today and not using the web version of Zoom, you can always access those captions at StreamText.  That URL is a little too long to read out but it was sent to you in the confirmation email.  It's the same link that we often use if you join IL‑NET calls regularly.
We'll post that link in the chat in Zoom in just a second.  We are recording the call today as we always do so we can archive it on the website.  We are in presentation mode.  All of our participants are muted.  But we will have plenty of time for questions today.  I wanted to talk a bit about the way that you can submit questions.
If you're on the web version of Zoom and you can access the Q&A tab in your Zoom menu bar, that's the way we prefer for it to come in.  It keeps all the questions in one place in chronological order.  It allows us to answer them live or write back to you, so it's pretty convenient.
However, there are some other options in case you're not on the web version of Zoom or Q&A tab is not accessible or convenient for you.  So I mentioned that the captions at StreamText.net, there's a chat feature there that you're probably familiar with.  I'm logged in there as Tim Fuchs.  You can type your questions at any time in the chat box and I'll voice them during the Q&A break.
You're also welcome to email me.  We have got a big audience today.  If you can use some of the other features, I would appreciate if you take advantage of those today.
And then finally, you can raise your hand.  If you're only on the phone today, you can press *9 to raise your hand and I can mute and unmute your line to allow to you ask a question.  Again, I would ask that we save that for an accommodation who need it, especially since we have a couple hundred people on the line.  I have to go through and literally scroll down and see whose hand is raised and unmute you.
I don't mind doing that at all if you need the accommodation.  If you can use the Q&A tab, I appreciate that.
I think the last thing I wanted to mention was just the evaluation form.  So we do have an evaluation form for today's call.  It's pre‑loaded in Zoom.  When you close the webinar today, it will open up on your screen or when I end the webinar at 4:00 eastern.  Please save a couple extra minutes to fill it out.  We're interested in hearing your thoughts.
If you're not on the phone today or you have somewhere to be at 4:00, that eval link was sent to you in the confirmation email.  We would appreciate you going back and fill it out.  We do read them.  We take them seriously.  We use that information all the time.  Please let us know what we might be able to do better.
With us, of course they need no introduction in this community.  Regina Blye is the program officer ‑‑ Administration for Community Living at HHS.  Paula McElwee is the technical assistance coordinator for the IL‑NET at ILRU.  And before I turn the call over, I wanted to go to slide four and quickly run through these learning objectives, an overview of what we are going to cover today.
On today's call you will learn the changes to the SPIL instrument and instructions, the required data needed for each section and the submission deadline details, submission process and the review and approval process.  That's what we are going to cover.  We have got a lot of content to get through.  This is two hours, so those of you who do these calls know they're normally 90 minutes.  We added the 30 minutes to get through it.
We have got Q&A breaks coming up on slide 13, slide 27 and at the very end on slide 52.  We are going to do about 10 minutes for each of those.  If we can shake loose some extra time for the final one, we will.  You're welcome to submit your questions anytime during the call.  But we are going to wait for the Q&A break to address them.
All right.  With that, I'm going to go ahead to slide five and turn it over to Paula.
>> Thanks, Tim!  We're all excited to see we have a new SPIL template.  This will be the first year that we're using this for the preparation of your state plan for independent living.  Here's the information that is found in the template document.  So if you think about what your SPIL contains, it would include some background, it would include there are definitions for your use in the template document, and then of course developing your SPIL,.
How you did it, your submission of that SPIL.  Then there's going to be a review and approval process.  There are specific ways that you make amendments.  We are not going to spend a lot of time on that but just touch on that a little bit today.  Instructions by sections, so we are going to go through that as well.
There are appendices that we'll touch on on how to develop your SPIL.  Some tools for planning.  A full planning table for you to look at.  A concept chain for you to look at.  And then the instrument itself.  So the template document, if you look at this content, you can kind of tell, is instructions and definitions and tools.  It's not just a fill‑in the blank template, but it also gives you a lot of other information to help you with the development and entering of your SPIL.
Regina, would you like to take on the next one as Tim changes the slide?
>> Sure.  And real quickly, I would like to say hello to Nevada, North Carolina, Alaska, and also West Virginia.  Those are the first states that said hello in chat so we're paying attention to the chat, as Tim said.  We're really excited about this training and hope that you find value.
So we are going to go over the 9 sections that are included in the SPIL.  Yes, 9 sections.  And we are going to do our best to get through all of them.  There are Section 1 is goals, objectives and activities.  Section two is scope, extent, and arrangement of services.  Section 3 is network of centers.
Section 4, DSE responsibilities.  Section 5, statewide independent living council SILC.  Section 6, legal basis and certifications, Section 7, DSCA assurances, section 8, statewide independent living council assurances and indicators of minimum compliance.  And section 9.
So as Paula mentioned, we have a lot to cover in a short two‑hour period so we'll dive deep into these sections, but we also want to present a few options for you to consider when you are developing your SPIL.  Next slide.
So I want to take the time, if you haven't done so, that you know that you should pull out your existing SPIL that you're working on or also include the blank template so you can follow along.  So before we focus on the instrument instructions, we want to focus on these resources here that will help you with the submission process and also with developing the SPIL.
So first we want to focus on the SPIL submittal process.  The SILC must submitted the SPIL to ACL/OILP no later on 90 days before completion date of the previous plan.  The SPIL must be submitted in the manner directed by ACL/OILP.  The submission date is 1:59:00 p.m. Eastern on Tuesday, June 30, 2020.  The SILC is required to submit the SPIL to me at Regina.blye@ACL.HHS.gov.
You need to use the completed SPIL instrument, not the previous one, and it must be submitted as a Word document.  You also need to include the signature pages as a PDF document.  These two attachments must be submitted at a 508 compliant document.  Note, you also must make sure that all the signatures are clear and very visible for the reader to be able to understand.
Next slide.  So next we are going to talk about the review process.  So ACL is responsible for reviewing and approving the SPIL.  When the SPIL is approved, the SILC chair will receive an approval letter from ACL.  ACL has the ‑‑ when the SPIL is disapproved, ACL will indicate to the state that it did not meet the requirements of section 704 of the Act and the SILC chair will receive a notice from ACL requesting changes to unapprovable sections of the SPIL.
If for some reason no resolution has been reached after reasonable efforts have been made, ACL may withhold financial know assistance until states submit an approvable plan.  Please note that we are not out to get you.  So we will work with you if you have issues with your plan.  The key thing is that we want you to submit something to us that you think that you've done your best by the required deadline.  And then we'll work with you before the next fiscal year period.
So please make sure you adhere to the June 30 deadline and we'll work with you between that period to make sure that have you something submitted, whether through ACL or ILRU.  We want to make sure that you have an approvable plan through the next three‑year cycle.  Next slide.
>> One of the things to remember is that instructions are in there and you need to follow the instructions.  I know that sounds simplistic, but it really isn't.  If you are reading the instructions carefully, it will tell you what you need to do, what needs to be included, how to describe something or whatever.  And we really do want to stick to those instructions as you go through the process.
It will really help to simplify and it will help to make sure that your SPIL is approvable, which is the goal that all of us have, right?  Next slide, Tim.
Now, there's a checklist and Appendix A that we want to point out to you.  It's optional.  We think it would be useful for you to uses it.  That checklist is used to determine whether or not you meet the minimum requirements.  Those requirements are all listed on the checklist.  If you can check them off and how you would verify them to make sure that you have all the pieces, it really will be helpful to us to have that done so that we can make sure that you've checked all the boxes.
And done all the work.  Next slide.  So there's also, in appendix B, there's another tool that you might find useful.  That is a sample logic model.  Logic model is a term we use for describing how you set goals and measurable goals and activities, also your mission that leads to those goals.  We also have some training available for you on that topic.
We will talk about it a little bit today as we go through, but make sure that you are making goals that are measurable or activities that are measurable so you can measure your progress on the SPIL, which is part of what you're going to have to do throughout the next three years after you have one approved.
Next slide.  There's also a planning table that we find useful.  It helps you to lay out your specific objectives and how you're going to measure it, the indicators that you have to measure those.  It also helps you to identify a scope of that particular goal geographically.  Is it statewide?  Is it only in unserved or underserved areas?  You can identify the lead organization.  And the SILC may be the lead organization for some of your goals, but there are some goals that are related to direct consumers.
To consumers to of course the center or all the centers would be the lead organization in that particular goal.  So make sure that you've set that up and how it's going to be funded.  And there are some other things there that help you to set up a plan in a table format that's going to be useful to you as that planning piece for your SPIL.
I know, that was really fast, huh?  We knew this would be the first quick session, but we would like to kind of do the questions now that have to do with the submittal process.  So if you have those kinds of questions, it's a good time for us to address those.  And then we'll look at the other pieces as we get to those topics. 
>>  MODERATOR: So Paula, just working through the questions that have come in already, Kathy is wondering if the checklist needs to be submitted.
>> Paula:  I don't think so, right, Regina?
>> Regina:  No, the checklist doesn't need to be submitted but we highly recommend that you use it to make sure that you're meeting all the sections that's required.
>> Tim:  Dare ya is wondering in section two they ask for information on CILs.  Do you want funding sources and amount or just the funding sources?
>> We'll get to that.
>> Section two reminds me of the services and I think that's section 2.1 and it has check boxes where you indicate the types of services, but we will get to that so we will go over what is required.  It's coming up!  It's coming up.
>> Tim:  All right, thanks.  Daniel is asking, this seems like a submission question to me.  In terms of of signatures, if I'm a blind person, a signature is not entirely clear.  Would this be a problem?
>> You'll just need to indicate that you need assistance in that area and we'll work on that.  The key thing is that you're submitting to something that's going to go on record and be published to the publishing.  So you want to make sure that you're representing your state in the best light.  So you want to try as best as possible to ensure that the documents you are submitting to us are clearly communicated as best as possible.
>> Okay.  Great.  We have some other questions.  I wanted to get to the questions that related to submission first.
>> I think I started this whole train about everybody saying hey, we're online, hi!
>> Yeah, we have got a lot of these.
>> We have got a lot of those.  It's really cool to see how many.
>> Shout out to everybody all over the country.
>> I don't know if you all see the numbers, but there are over 270 people on the call.  Wow!
>> Tim:  All right.  Let me see if you think you can answer this now.  Anonymous asked if there are questions about content being approvable, how do we formally request guidance and clarification?
>> Regina:  That can be done either way.  You can submit a request to me to review certain sections that you think need to be reviewed.  Or you can also reach out to ILRU and Paula can also provide assistance.  But I just want to make it clear.  It can't be a blanket check, will you look at this and tell me are we okay.  You need to have certain sections that you think might be problematic and you want to have someone work through whatever it is a potential issue.
But it's not our responsibility or role to try to help you figure out what needs to be done, that that's the part that you need to figure out.  But if you need assistance in areas that you know require additional guidance, that's where we can help you out.
>> Paula:  We do find some of that centers on what we are going to talk about today on the goals and objectives and making them measurable.  That's a question that I get a lot and I'm sure you do too, Regina.
>> Regina:  Exactly.  An example would be if you're just asking hey, can you tell me if section two looks good to you, that's not appropriate.  You need to work that out.  If you have a specific question that you need answered, that's exactly what we're here for.
>> Tim:  Okay.  Great.  We have got a cascade of questions about the signatures.  So Daniel asked about accessible signatures but we have got a lot of people wondering about electronic signatures, whether or not all directors need to sign original documents or if they can be scanned.  So how can folks handle that, especially right now with remote work?  How can folks handle E signatures and scans and electronic signatures?
>> Regina:  That's an excellent question.  On Friday ACL released an updated version of FAQ that was sent to the centers about COVID‑19 activities and I believe question 13 pertained to electronic signatures.  And that question also can pertain to the standard of Independent Living Council where it indicates that electronic signatures are allowed and you need to develop some kind of process and have it documented how you are capturing the electronic signatures.
You know that HHS has a requirement for retention process so you need to adhere to those things and make sure that your policies reflect all of those.  If you want to have electronic signatures, that's up to your network.  Just make sure that you have agreement amongst the network and you follow through on it.
>> Tim:  Okay, great.  Dan's wondering if centers that don't receive part C funds sign off on the SPIL.
>> Regina:  That's entirely up to the network.  That's in section 3.1 where you indicate the centers for independent living in your state, whether you believe that's part B, part C, state funded or whatever.  And then you're also supposed to indicate the SPIL signers.  If you do not receive part C funds but your network believes that you're supposed to be a signer, you articulate that in section 3.1.
>> Tim:  Great.
>> I would like to mention that this came up recently, that a center that received two Title VII grants believed they were supposed to sign for each of those two and that's not the case.
>> Just one time.  Just one time.
>> So you don't get to count twice in the majority.  You only get to count once.
>> Exactly.  One time.
>> Tim:  In any direction, whether or not the signatures need to be on a single sheet, if folks need to send multiple PDFs or their own signature on separate PDFs.
>> That's up to the network.  If you have 40 CILs, that's difficult to get on one page.  What I suggest is you merge all those pages into one document.  I don't have a preference on that as long as you use the merge feature on the PDF document.
>> Tim:  Okay.  Great.  And I do see the questions from others about COVID‑19 and some other questions that are going to come up in other sections.  We are going to wait to address those in the next Q&A break.  Thanks for your patience there.  Here's one from Arkansas before I move on.  If part of the funding through the SILC is for [Away from mic] blind services, are they required to sign?
>> No.
>> Unless they're your DSE.
>> Better go back to ‑‑ that would be covered in the DSE section and I think that's around section 4.1 or so when we are talking about DSE responsibilities and that you only have one DSE.  So I think that we could cover that at that point.  But at this point the answer is no.
>> You don't get signatures from every funding source.  Only from the DSE.
>> Correct.
>> Tim:  Beth is wondering what to do in the situation if you're still waiting on appointments.
>> That's very tricky, because you should have a fully constituted board whenever you're making decisions about what funding is going to be issued in the state, what services are going to be provided, and when you are approving the state plan.
So I think at this point, I probably had conversations to you about your appointment status and what needs to happen.  I think that an offline conversation is going to be needed about what you need to do to be compliant and what happens if you're not.  So I won't give all the details about not being in compliance about a bore, but it is an issue if you do not have a compliance for it.
>> That's our 10 minutes for that Q&A break.  I wanted to make sure we have time for the other sections.  Again, some of the questions that came in about COVID‑19 and the CARES Act, we will address in our later Q&A breaks.  With that, I'm going to click ahead to slide 14 and turn it back to Regina.
>> Regina:  In the SPIL we have an executive summary.  I believe this is new for this SPIL and it's basically what we're looking for you to provide a concise summary of the SPIL.  We're looking for no more than two pages.  You're not supposed to duplicate any other portion of the SPIL so we're looking for new content.  So if you're looking to cut and paste and add information in this section, then you're already missing the point.
You want to make sure that you're adding new information.  So this section is usually written last because you want to make sure that, again, you're capturing new information.  And you want to make sure that you figure out all your sections before you're figuring out the executive summary.  But you want to make sure that, when you are writing this executive summary, make sure you're including new information and you're not going beyond two pages.
Next slide.
>> Paula:  Am I the only one that has a big black thing on my ‑‑ I can't look at the slide.
>> Tim:  I was reading questions that came in a Word document.  I didn't know it was blocking the PowerPoint.
>> Oops.
>> We are going to talk a little about the goals and objectives and activities.  As most of you know, it's been an ongoing discussion how to make these meaningful and yet measurable, how to get to something that you can say yes or no to did we accomplish this goal.
So this is an important part of your SPIL.  The first piece of that is a mission.  We are not going to spend a lot of time on mission statements and how you do them, but as you know, your mission statement is bigger in scope.  Often it's what you believe should be the state of the world which may or may not be the case.
So this is a somewhat visionary statement, not to be confused with a vision statement.  But as you look at a mission statement, it's where you expect to be at some future point in time.  Make it as concise as you can.  It certainly can be very futuristic in its look though, so keep that in mind.
Next slide.  I want to spend a little bit more time on the goals and objectives and activities because this is really where you're starting to look at outcomes rather than looking at just global statements.  So your mission is that global statement.  You're going to build toward achieving that mission.  And you're going to do that through goals first.  And those are what you want to achieve.
What are the outcomes that you feel like you can accomplish in your SPIL?  Let's look at the next slide.  So as a statewide network, you're going to set these goals which are more long‑term, but still you want them to be measurable.  You have got to be able to determine, yes, we met the goal.  So your state plan for independent living contains these goal statements and then objectives which are steps of progress towards meeting that goal.
And even when your goal is very broad, difficult to break down and measure, you have got to be able to show that you're making progress towards accomplishing it.  So the objectives are those steps of progress.  So you can go through them and say, okay, first we defined it, then we did this, then we did this, so you can see steps of progress towards it.
Now, you can also use indicators that show your success.  So you may identify a specific indicator.  We have got some samples in just a second.  You do need to know who's responsible.  I mentioned that earlier.  Who is going to report on this progress that you've identified through those objectives?  And then you have to have a method for the SILC to review and evaluate the progress on the SPIL and you may set that up with how you do your goal reviews, how you operate with your committees.
There are lots of different ways to do it, but what is your process for reviewing and evaluating the progress on the SPIL?  If those goals relate to core services or direct services, the CIL will need to provide the information on how to review and evaluate that item, because the SILC doesn't do direct services so the SPIL is going to reflect that the centers will report on whatever the item is if it's something related to direct services or core services.
Let's look at that next slide.  Make sure you include all the requirements in this section.  And there's a chart that we'll look at in a minute that will tie back to this.  You need to look at your geographic scope.  You need to look at where are these services going to occur.  You need to look at what outcomes you want to achieve.  You want to have a target date so you can tell whether or not you're on target with getting this accomplished.
And those target dates probably will unfold throughout the three‑year period of your SPIL.  They shouldn't all be at the end, but you should be able to see steps that you're taking as part of your objectives.  And you know that you want to have this step done in the first quarter of the second year or whatever it is that you think makes sense with your overall plan.  So target dates are a piece.
Measurable indicators, as we said.  That includes compatibility with the IL philosophy.  So you may actually want to look back at the rehab act and that philosophy statement at the very beginning of Title VII.  So chapter 1 of Title VII of the rehab act is very specific about the philosophy and that's useful for you to take a look at because everything we do should fit within that philosophy.
And then the services in 2.1 will tie back to your objectives so we'll want to look at how they flow from your mission to your goals to your objectives to your indicators, you know, and how all that all flows.  Next slide.
Measurable objectives include how do you know if you met the goal.  So it tells you how to be successful in achieving the objective and how you will know, yes, we have got it done.  I always think in terms of if I have a list of things and I want to mark whether or not we did it, I have to know when it's done.
And if we have a general goal that just says we are going to improve transportation but it doesn't have any actual steps that are going to take place, how do I know if we improved it or not?  You can see those general things, really you have to break them down to be more measurable.  We say they should be SMART.
That means they're specific enough to know what you said you're going to get done.  You can measure whether or not you got it done.  It's possible to do.  It's relevant.  And it's timely.  So kind of think of those things that will show a dynamic SPIL as opposed to a static one.  If you have that kind of information in each of your objectives, it should give you some things that you are going to accomplish. it should be exciting to think, okay, now we are going to get these things done.
So specific, it's clear exactly what you're measuring.  Measurable, it's necessary information that you can get.  You can gather that information with a reasonable amount of effort and cost to know how to measure the progress.  It's achievable.  Achievable is somewhere between too easy and hopelessly out of reach.  I that that was pretty good.  It's relevant, captures the core essence of whatever the outcome is that you want to do.
And that relevance often comes from the things that you've learned about the state and the network as you've done your listening sessions and different ways.  And that it's timely, it's a good time to move us through this particular goal in our state.  It's meaningful right now.
And we've all of a sudden got a whole bunch of new things that are meaningful right now, huh?  Slide 20.
So here's an example that's actually in the instructions itself.  I'm not going to go into the mission because I think a lot of you have pulled that mission from chapter 1 of the Title VII of the rehab act or in some other way have connected it back to our philosophy.  But here's two goals.  Individuals with disabilities live independently in the community.  And Formerly underserved populations are served by the CILs.  As you look at this, you don't know yet how to measure it.
It's pretty broad.  They live independently in the community.  How are we going to measured that?  Formerly underserved populations are now served, that tells you right off two things that you are going to have to clarify.  Who are the Formerly unserved populations and how do we know they're now served?  You can begin to see it right there in the goal.
Let's look at 21.
So your objectives might be related to the different things that are needed in order for that goal to be accomplished.  So individuals with disabilities have access to transportation is an objective.  Individuals with disabilities have access to the community‑based resources that they need.  That's an objective.  And then again we are going to have to measure, aren't we?  What are the things that we are going to measure to know whether or not we're doing these things?
The second example is that CIL services are now available in, and you can list the counties that you identified were unserved or underserved.  And now services are available in those counties.  That would be something that you might look toward.  Hispanic individuals with disabilities have access to CIL services.  So if you have identified Spanish speaking individuals as an underserved population, then you might very well have a goal to improve the access that they have to CIL services.
Which may be language related.  22.
So indicators might be what percentage has accessible transportation increased by.  Makes it measurable.  Community‑based resources available increased by what amount?  Or waiting list for the whatever it is, personal services waiver or whatever you have got, waiting list was reduced or eliminated by how many?  So you're going to look at access to services, access to the community and think about some things that you might want to work on.
The same thing with that second goal, services are now provided in whatever counties you identify that didn't have them before.  And materials are available in Spanish and Spanish speaking staff are available during business hours.  So those are the indicators now that you can look at.  You are required to have indicators.
And if you submit your SPIL without indicators, it's going to be returned.  So you need to make sure, as you look at these, that you figure out how you're going to do goals, objectives, and indicators as well.
Let's look at 23.  There's also a new section on evaluation.  And it's required.  And evaluation can only happen when you achieve something measurable as part of what you are doing.  So methods and processes that you used to measure that effectiveness, you're going to need to identify those and you're going to have to say how frequently you've checked those things and you're going to have to evaluate somehow the satisfaction of individuals with disabilities as part of how you evaluate overall.
And we are going to look at some other things, but if you look at the template on page 11, you're going to see most of what you need to cover in an evaluation plan, but you do want to make sure that you are evaluating.  Now, satisfaction of individuals with disabilities, the centers also measure the satisfaction of individuals with disabilities.  And in some states the SILC and the centers work together on a single satisfaction evaluation that covers the things that you need to know in the SPIL.
So you get hopefully statewide coverage with that information.  How you do your satisfaction and whether you do it all together and how frequently the SILC does that and whether or not you work with the CILs could all be part of that conversation around evaluation.
24.
So make sure your evaluation plan measures consumer satisfaction somehow.  And as I said, that's separate from the CIL's responsibility to measure satisfaction but you can do it with them because that will help you to get it out to the people that are receiving services.
You need to incorporate the information from the CILs' most recently available PPR ‑‑ those program performance reports are going to be available.  I don't know, I haven't looked at them lately.  Are available, Regina?  I don't know.  They should provide them to you.  They should be available to you soon on the website if they aren't already and you can look at that.
And part of what you're going to evaluate, some of those numbers would come into play as you evaluate your plan.  So you'll want to see that.  Because if you're talking about an increase or improvement in services, then some of those numbers may be meaningful to you as to measuring that.
You're also going to include a method to gather input from stakeholders who might be a group of targeted population for expansion of services or outreach and from the public.  And that's going to be part of your input then.  You see the cycle forming?  Part of your input then is going to also inform future SPILs or amendments to the SPIL if you need to do that.
Identify the means by which the progress will be measured.  That's the biggest one when it comes to this whole section.  What tools are you going to use, because some are more effective than others?  Some of you may have already noticed this year that you haven't gotten a lot of feedback from people that you wanted to see.  And if your return wasn't very good, then look at other methods.  And don't be afraid to be creative about what methods you use to garner input.
The people in the public, how are you going to gather that information?  Your evaluation plan is going to have you put details there.  You have already had a lot of recent practice so hopefully you can practice it here.  Regina, did you start to say something?
>> No, I'm good.
>> I heard something.  I don't know what it was.  Then time lines, of course, how often are you going to measure this and what's that going to look like?  Your plan, because you're evaluating the progress on the SPIL, that's one of the main things the SILC does, your evaluation plan tells how you're going to do that.
So all these methods need to be rolled into that part of the plan.  25.
I feel like I'm going too fast but it's one of these things like we have to decide and we decided we couldn't do a full‑blown training on this part, but we could hit the high points and then support you as you have questions as you develop it further.
Specifically, you have to identify in your plan what's your time line.  What are your goals, we talked about that.  What are your objectives?  What data is going to be collected and by whom?  And how is a big part of that.  And some of that may be PPR information because we know that's being collected and we know how to access that.  So it may be that that's important, but there may be other methods as well.
And then write down the specifics as much as you need to so everybody knows what they're supposed to do and agrees to that.  Did you want to say something?  Look at 26.
This is your last note about evaluation before we talk about the section and answer some questions about it.  The SPIL evaluation plan is not an evaluation of the quality or the effectiveness of the centers.  It is not looking to see whether or not the centers are complying with the standards and assurances, which is in 725 of the Act.  Compliance by the centers who receive part C money is not the responsibility of the SILC.
That compliance is the responsibility of the Funder.  And so compliance of those centers that receive part B money is the responsibility of the DSE related to that part B money.  That's who oversees it.  They're the recipient of the grant and they have a responsibility to see that the funds are spent correctly.  Neither one of those are what this evaluation plan is about.
This evaluation plan is to measure how well the state network is making progress on the goals and objectives that were identified in the SPIL.  So just be very aware that it's not for the purpose of the SILC evaluating the CILs.  It's for the purpose of the SILC evaluating the progress on the plan.  Okay.
Tim?
>> Tim, before we get to Q&A, while you're looking, I just want to provide some comments about the goals and objectives section because it's really important and I want people to think globally about the information that they're including in the SPIL and realize that it's an opportunity when you're thinking about emergency management activities, it's a great opportunity to include those activities or maybe have a goals and objectives in that section.
Even when you're talking about SILC authorities, perfect place to include that information, because then you can talk about the funding and all your other activities throughout the rest of the sections of the SPIL.  So you want to really think about all the things that you're doing when it comes to the SILC and the CILs and all your other supporting organizations and make sure that everything ties back to your goals and objectives.
And make sure they're measurable so you can evaluate them.
>> You know, I had a note about that, but I didn't see it.
>> I'm right there for you, Paula.
>> All right.  Sounds good.  And I know a lot of the questions here have to do with the CARES Act funding and the fact that the FAQs said however they spend it, it's got to be in keeping with the SPIL.  So I bet some of you are on this call to figure that piece out.  What exactly does that mean?  What it means right now is if anything that you're doing that's counter to the SPIL that you want to do, you can't do it until you amend the current SPIL we're in.
Or you can't start it until September 30 when you begin the next SPIL cycle if you put it in the one you're working on now.  If that makes sense, if there's something that you want to do that especially and specifically was mentioned in keeping with centers serving an unserved County maybe or a part C center assisting a part B center because they didn't get any money.
But if you're going to do anything with the disaster preparedness or disaster relief, you really ought to have a goal about that and how the state works together and what processes are in place to make sure that emergency response is timely and also that the network does a good job of providing that across the state and not just in pocket areas.  Is that close, Regina?
>> Yes.
>> Tim:  We have got a ton of questions.  I'm going to do my best to work through these quickly.  A number of questions came in, Regina, I wanted to ask you to clarify.  You had mentioned at the beginning of the section about making sure that you included new information in the executive summary, but the instructions say that it's supposed to be basically only items that are elsewhere in the SPIL.  Could you clarify that about the executive summary?
>> Say that again and let me go back to the section 2 while you are.
>> Sure.  So you had mentioned the executive summary should include new information, but in the instructions for that section it says to include information that's included elsewhere in the plan.  So did that mean just not to copy and paste or is there another ‑‑ how should folks approach that, given the instructions?
>> So I'm just following what's in the instructions of the SPIL.  It says in the executive summary section, concisely summarize the SPIL.  Do not include anything that the SPIL's other sections do not include.  Any appropriate length for the executive summary is one to two pages.  So you're correct.  What I mean by new information, I mean that when you summarize, it's not a cut and paste.
So you go in and you need to provide something where it's ‑‑ I'm struggling on trying to explain that.  But if you're just going in and cutting and pasting and something so I'm reading the same thing again, that's not what I'm looking for.  I need for you to go in and give me some new information that provides a summary of what you've already provided throughout the document.  I just don't need a cut and paste situation.
>> Tim:  Got it.  Thank you.  That's very helpful.
>> Paula:  Shelly mentioned in the chat and I like this comparison.  It's like an abstract written for a paper.  A summary.  It's not a rehash of the whole paragraphs in the paper.
>> Yeah, because no one has time for that.  Let's just be honest.
>> Cary's wondering if target dates need to be specific to the day or can they be generalized to a year especially further out in the plan?
>> Regina:  That's a good question.  Tim, why don't you circle back on that for me and let me look at that.
>> All right.  Similar question from Kathy wondering if a time line for certain tasks can be the entire life of the SPIL?  Can it be ongoing for the entire three years?
>> Something about ongoing, that, to me, how do you measure progress when it's ongoing?  You need to at least provide some sort of date so you can determine whether or not you're progressing accordingly.  So I wouldn't just necessarily say that ongoing would be appropriate.  You should try to have some sort of estimated date so you can find out whether or not adjustments are needed.
>> Reggie's wondering if the goals, objectives, indicators, evaluations, et cetera in Section 1 can all be presented in a table so that all the components stay together from the beginning to the end?
>> Oh, it is preferred that you include all that information in the table because also, in section 1.4, when you're evaluating those goals and objectives, it's going to make it easy for you to walk through that entire process.  I think if you put that information as a narrative, it's going to make it very hard for you to follow as well as somebody else who has absolutely no idea what's going on in your state.
I think that a table is imperative for your to use.
>> Great.  We are going to get into some other questions here.  If we need to address them later, let me know.  Mary's wondering if there's a best section to add the CIL amendments on COVID‑19, to add that information?
>> Is there a section for what now?
>> Is there a best section to add the COVID‑19 CIL amendment information?  Where would you like to see that in the SPIL?
>> So you're talking about the current SPIL or you're talking about the one that you're drafting now?  Let me just go ahead and take it from the top.  With the COVID‑19, we'll cover that.  So amendments are not needed for the current SPIL.  There's not enough time for you to go and make amendments for you to be able to recognize the COVID‑19 funding that you received.
So you're just going to proceed forward and try to make adjustments as best as possible.  What you are required to do is include the COVID‑19 funding in the SPIL that you are currently working on now.  So you're going to include the COVID‑19 funding in section 1.5, which is the financial table, which we're getting ready to talk about.
You're also going to include COVID‑19 funding activities in section 3.1.  There's other opportunities for you to include COVID‑19 activities.  And that's just going to be a conversation that you'll need to have with your state about what's appropriate for you, but definitely you're going to need to include that information in section 1.5 and section 3.1.  But again, please do not send amendments because of COVID‑19 to the current FY20 SPIL.
>> Great.  Thank you.  All right.  Kathy's wondering, does our SPIL have to actually call it an indicator or can it be an indicator that's called an action step that functions as an indicator.
>> Let me answer this one, Regina.
>> Kathy, remember, it's like taking a test.  Read the instructions, use the same terminology, you won't have problems.  Change the terminology and somebody might ask a question that makes it more complicated.  Why would you change it?
>> Sounds like Kathy is going to be doing some find/replace in the SPIL.  This is similar, but are indicators and evaluation measures functionally the same?
>> Paula:  I think what your evaluation plan includes is the indicators to measure it, yes.  But I'm looking to Regina in case I have that wrong.
>> Regina:  I think you're correct.  Can we put a pin in that one?  That might have to be something that we address offline.  I don't want to tell you anything that's incorrect.
>> Okay.  I have got a couple of people wondering about baselines to measure performance.  Do you need to include baselines in the SPIL?  And what do you do if you don't have that data yet?
>> If you don't have the data yet, you don't have the data and you have to measure it now and going forward.  But a baseline is always really good practice for measuring progress.  If you know your current status, that's the only way you can know how that status changes as a result of the actions you take, right?  So if you don't have a baseline, that needs to be your first step on that goal is figure out what's happening now.
Because if you don't know what's happening now, you can't measure progress.
>> Okay.  Good.  So Cary and some others are wondering, we already put out our drafts bill for public comment, but now we need to make some changes and we planned our hearings for mid‑May.  If we make changes to the draft based on this webinar and the public comment we get, do we need to put it out for an additional 30 day public comment period and have additional hearings before gathering our signatures on the final version?
>> Well, that would depend.  It would depend on what changes are needed.  I think if you have followed the instructions accordingly, then you should be fine and there should be some fine tuning moments as well as COVID‑19, that's new for everybody.  So all 56 entities, all 56 states and territories are going to have to make adjustments to the SPIL because of COVID‑19.
But if it's minor things about changes in your goals and objectives because you might not have included the right time line dates, those things, I wouldn't say, would require another public hearing.  I think most importantly what you would have to do is follow‑up and see if a public hearing is needed.  The key thing is we don't want to prevent you from submitting this bill so more than likely you're probably fine because you had the public hearing.
You're receiving public input so your changes should also be based on what information you received from the public.  If you're making sure that you're doing that, then you should be okay.
>> Great.  Thanks.  Just sorting through some of these.  Do we have to actually put the CIL satisfaction rate in the SPIL?  Or just how we planned on measuring the satisfaction through the program performance reports?
>> So that one, I think it's just what you plan to do and not the actual, but that should be another one that we'll put a pin to because we are not there and once we get to that section, we'll see what the final answer is.
>> Okay.  Paula, I think you said this, but maybe you can help expand on this.  Can you give an example of something that the CIL might want to do that doesn't lineup with the current SPIL.
>> Let me think a second.  Let me give you a couple of examples of things that might lineup with the current SPIL.  I guess one of them would be collaboration during an emergency event.  So a couple of years ago there was a letter that told us that we could collaborate with one another and the FAQ for the CARES Act money emphasizes that again and says we can't do it counter to the plan.
Well, if the SPIL designates service areas and does not allow any exceptions to how a center might cross a service area line, you may need to look at that, because I'm suspecting, I don't know yet if anybody's going to do it, but I'm suspecting that the areas served by part B only centers which have no CARES Act funding, I'm sure that the part B centers would love to have a memorandum of agreement with another center that does have the CARES Act money.
In order to help with the more statewide effort for the services for people who are in desperate need and there are people who have disabilities.  If your section on dividing up the land is real stern and says there will be no crossing of these lines, that might be a barrier that you need to at least mention.  I think you would want to fix it for this one that you are working on now and say how could we collaborate, what might be some methods of collaboration.
I don't know if that's a good example but that's one I could think of.
>> Okay.  Thanks for that.  And again, I'm sorting through these questions that are all about the CARES Act because we are going to get to some of the CARES Act and COVID‑19 answers in the next section.
>> I also might mention, Tim, that that's also the topic of the SILC speaks call on Thursday next week.
>> Good tip.  Thank you, Paula, I had forgotten that.  Marie is wondering is, like they've done in the past, should CILs be creating three‑year plans based on the SPIL?
>> CILs should be creating plans anyway.  They're required to do that.  That's part of what you report on in your PPR.  I'm hoping that you are doing at least a three‑year plan.  If you're not doing that right now, you really do need to rethink that.  Visit with me offline and I'll give you some tools or tips on how to do that if you haven't done it before.
The centers should be constantly planning.  There should be some kind of planning cycle.  Otherwise, what is it that you're reporting in your PPR when you say what goals you met?  They came from, hopefully, a plan.
>> And I think this is the last one that isn't related to the CARES Act.  Someone is wondering, wouldn't adjustments needed to an ongoing goal be addressed in the evaluation plan?  Is that true?  Adjustments to an ongoing goal would be addressed in the evaluation plan.
>> I'm not sure what the participant means exactly, but if what you mean is we are going to identify in the evaluation plan the points at which we evaluate, and then is there a response to that evaluation, yeah, that might be.  And the response might be we forgot to measure this and we really need to step back a step and learn this information before we go forward.  If that's what you mean that you're adjusting your plan as you evaluate, to some extent that's right.
You might have to stay within the goals and adjust some of your activities.
>> Great.  Well, that's our time for this Q&A break.  We took a couple minutes to clear some of those out.  And again, I know some of you have questions pending on the CARES Act.  We'll be talking about that.  I'm going to go ahead to slide 28 and turn it over to Regina.
>> All right.  We need to take a deep breath because it's going to be an exciting ride.  Now we are going to section 1.5, it's the financial plan.  It's time for us to talk about the money.  It's an essential part of the process.  So we are going to cover some of these sections or this section multiple times because it's very important for you to understand how you're utilizing your funds within your state.
States are to report the sources, uses of and efforts to coordinate funding to be used to accomplish the SPIL goals and objectives.  So what's important, we want you to remember that you need to tie everything back to the goals and objectives, including the funding.
So there's a new requirement that states now have to report on the process for grants or contracts, the selection of grantees, distribution of funds to facilitate effective operations and provision of services.  So let's rest on that concept of effective operations.  What does that mean?  Well, I absolutely don't know.  That's for you to tell me what that means in the most descriptive and succinct way possible what that means for your state.
And I think that is what has had states get caught up on the most is about their process when it comes to granting and distributing funds.  So you need to really articulate what you want to have happen in this space so it can be as effective as possible.
In this section, I want to make sure that you all are kind of clear of what I'm looking for.  So I will be checking for part B funding amounts for the SILC resource plan.  And I want to make sure that no SILC is receiving more than 30% of part B funds unless a justification is included in section 5.2.  I will also check to see if the DSE is included, their administrative amount of no more than 5%.
And then lastly, I will also check to see if a non‑federal 10% match is included.  Now, some of you might have used or downloaded an early version of the SPIL.  If so, you have a version that has a max requirement under the part B section.  If so, then you need to remove that from your version because that's not correct.  Next slide.
So now we're wanting to talk about the financial plan table.  So this is the visual piece.  So what you are looking at now is not what's actually in your SPIL.  We've modified it so we can get the table all on one page.  But what I'm looking for on this page is whether or not part B funds were included in the SILC resource plan.  And again, there should be no more than 30% unless there is a justification in 5.2.
Then what I'm looking for is to make sure that part C funds are included for the general CILs operations.  And then again I'm going to look for the 5% administration amount for the DSE.  And then some SILCs do not receive part B funds, so if I don't see a funding amount there, then I'm going to look at other federal funds, which would mean that more than likely the SILC is receiving innovation and expansion funds, which is I and E.
I will look for the amount to be included there.
What makes this section extra special is because of the CARES Act funding.  This is where you're going to include the funding amount that the state received for the part C CILs.  So you'll note that the new SPIL instrument does not include CARES Act funding.  So what you are going to do is go to the column and actually include the words CARES Act funding, and then include the amount that your state received for part C CILs.
So I will be looking for that amount.  And then another key funding amount that I'm going to look for is under the non‑federal funds column.  I'm going to look to see whether or not the tenth% match is included for the DSE.  Now, if all of that is there, then this section will be approved for the funding table.
Of course, there's going to be other funding.  You're going to have possibly state funds, social security and reimbursement funds and other funds.  And that's great if you have those funds, but that doesn't mean that if you have it there, it's a problem, or if it's not there, it's a problem.  I'm just looking for the key things related to part B, part C, I and E or 10% match.  Next slide.
So next we are going to cover the format that the state should use in section 1.5.  The financial plan has two required parts.  It has the table that we just talked about in the narrative section.  So the narrative must include the sources of funding, process for grants or contracts, selection of grantees, and distribution of funds.
States should include a description of the financial plan for the use of federal and non‑federal funds to meet the objectives identified in the SPIL.  Again, we're going back to the whole thing where everything is tied back to your goals and objectives.
We're also asking for the amounts of the distribution of funds to be included in the narrative section.  If you don't specify who receives what funds, it is difficult for us to assure funds are spent according to the SPIL.  I recommend adding a chart in the narrative section and a breakdown according to the funding that the CILs or entities are receiving in the state.
So here's the reason for that, because I received emails or calls from states from either the SILC or CILs or DSEs talking about they're having problems about the distribution of part B funds.  So one way to kind of alleviate that issue is to indicate the actual funding that the entities are supposed to receive.  And this is a perfect section for you to do so in section 1.5.
So if you included a chart, you should be able to include the funding sources for how much each part C funding CIL is receiving in CARES Act funding.  And this is a requirement, so in this section, in some sort of way, a chart would be more organized and easy for us to identify which part C funded CIL is receiving CARES Act funding.
Then you also can include how much each entity, whether it's a CIL, SILC, or another organization, is receiving in part C funds.  You're also welcome to add a breakdown for any other funding source if needed, but it's not required.  But again, as much information that you can provide will help with transparency and it will prevent any kind of potential funding dispute that might happen during the reporting period.
Next slide.  So next we are going to go to section 2, which is scope, extent and arrangement of services.  So this one is pretty straightforward.  What you will do is you're going to check the appropriate boxes in the SPIL instrument table indicating the types of independent living services.
So services to be provided to persons with significant disabilities that promote full access to community life including geographic scope, determination of eligibility, and statewideness.  So you all are supposed to complete this table.  Make sure that you click on the check boxes that make sense for your state, and then you can move to the next section.
What you want to do is make sure that you're indicating the types of IL services to be provided to meet the objectives identified in section 1.3 of this bill.  Again, we're circling back to objectives so make sure they tie back to section 1.3.  You also want to indicate whether the services will be provided by CILs or the DSE.  That's going to be directly and/or through contract or grant, or another entity.
You also are going to include the funding for each service.  Now, in this section you may also include a map.  If you do so, make sure that you include it in such a way that it makes it easy for you to be able to email the completed SPIL to me whenever it's due.
Next section.  So now we're in section 2.2, which is outreach.  There are five key areas that should be included in this section.  When you're writing your narrative, you want to make sure that you're including definitions of unserved and underserved for outreach.  You also want to explain how unserved and underserved are determined.
How services will be provided, including the minority groups in urban and rural populations.  Now, this is important.  You want to make sure that you're including minority groups in urban and rural populations when you are talking about how you're going to provide these services.
You also want to include targeted populations and/or geographic areas.  And lastly, outreach activities and methods to be conducted and who will conduct each.  Now, we want to make it clear that the CILs have their own outreach plans.  This section is to address statewide outreach efforts and is to be separate from and coordinated with but not replacing CIL outreach plans.
Now, I know that this section could get really lengthy, but we want this to be limited to no more than two pages.  All right.  Next slide.
So now we're moving to coordination of services and cooperation among programs.  So this is another narrative section where you're going to describe the plans for coordination and cooperation between the SILC, CILs, and the DSE and with other entities, programs and organizations.  So this section also must stay within two pages.  Next slide.
So now we move to section 3.1.  Section 2.3 was pretty straightforward and to the point.  So now we are going to get to some complex sections where you have quite a few requirements that you have to adhere to.  So with 3.1, you're focusing on your existing centers.  So you want to develop a chart that includes all elements to be approved.
In this chart you want to make sure that you're including the legal name of the CIL, the geographic area, County served by the CIL.  You want to include current sources of funding, not including amount.  So if you remember, I said in section 1.5, that is where you can include the actual amount that each CIL is receiving.  In this section, you just want to focus on the types.  So that would be part B, part C, state general revenue, other federal funds or other.
And other could be donations, for fee services, whatever the CIL feels is necessary for them to provide independent living services to CILs.  Now, in this section, because of CARES Act funding, you're also going to include which CIL is receiving CARES Act funding.  So whatever part C CIL is in your state, you want to indicate that that CIL also received CARES Act funding.
A new requirement in this section is that there is an oversight process that should be included.  You also need to include an over side entity as well as the SPIL signatory.  So this goes back to the person who had the question earlier about who's eligible to sign.  This is the section where you all are telling us or ACL who's eligible to sign.
So it could be a part C funded CIL, of course, maybe.  Or they elected not to sign.  Or it could be a part B funded CIL or state funded CIL.  Whatever the case, you want to make sure that you articulate that in section 3.1.
Next.  So section 3.1 has two required parts.  We have the chart that we just talked about on slide 34 and now it's the narrative section.  The narrative section you need to explain what the CIL is.  Just to make sure that everyone understands that, if you have someone listed in the chart, then in your narrative section you also have to have an explanation of why this CIL is required to sign this SPIL.
You also need to accurately describe how services are to be configured in the SPIL.  Next.
So we move to section 3.2.  This one is a really lofty section and there are a lot of requirements that must be included in the narrative format.  So we are going to spend a few minutes on this section just to make sure that everyone is including all the requirements in this section.
So this slide here is kind of an overview of what's supposed to be included in this section.  So what you're going to be doing is you're going to plan and have priorities for use of funds.  You're going to list the funding sources, whether current, increase, or one time, including part B funds, part C, state and other funds.  What's clear here is what you're going to have to do is include a methodology for distribution of funds.
And you're also going to have to make sure that you include use of funds to build capacity for existing centers, establish new centers, and/or increase statewideness of the network.  Next.
So let's get a little further into what that last slide meant.  So what I just indicated is that you're going to provide a detailed description of the plans for expanding, building and/or adjusting the statewide network of CILs by including a definition of served, unserved, and underserved, which agrees with section 2.2.  So you want to make sure that you review that section to make sure that 3.2 coordinates with whatever is in that section.
So in this section, you're going to include minimum funding levels for a center and a formula or plan for distribution of funds to ensure that each center received at least the minimum amount.  You're also going to include priorities for the establishment of a new CIL.  Now, in the past, people have indicated that they were going to establish a new CIL, but they did not include a priority.  So it is important that you also include a priority.
If you do not, it will be returned so that you will have to include that information.  So next you need an action or process for distribution of funds for relinquished or removed from a center for independent living, and/or if a CIL closes.  This one is important because it used to be an administrative requirement but now it is in this new SPIL.  So you want to make sure that if a CIL closes its doors, whether because they decided that they just didn't want to do it anymore or because of some sort of.
Some sort of fraudulent activity, whatever the case, you need to have something in the SPIL that states what you want to happen with the part C funds.  Now, you need to take into account that things happen and they are not going to happen at the beginning of the fiscal year.  So if the CIL is no longer operational, you want to make sure that there's a potential back up plan that, if the CIL is no longer operational, those funds are available, you want to make sure that ACL.
Has enough time to recompete those funds before the next fiscal year.  Otherwise, we are going to have a pot of money that we are not going to know what to do with.  You want to have a back up in your plan that states if we can't recompete those funds for some reason, what do you want us to do with those funds.
So next you want to have a plan to build capacity of existing CILs or expand statewideness by establishing branch offices and/or satellites of existing CILs.  Then you want to have a plan or formula for distribution of new funds.  That's part B, part C, or one time funds.  With CARES Act funding, you do not need to put that in section 3.2.
If you include that information in section 3.1 and section 1.5, that's enough for the CARES Act funding.  You do not need to include that in section 3.2.  This section is talking globally about new funding but not about a specific type of funding so do not put anything about CARES Act funding in section 3.2.
Next slide.  So we're continuing on about the expansion and adjustment of the network.  You want to have a plan or formula for adjusting distribution of funds when cut or reduced.  A plan for changes to center service areas and/or funding levels to accommodate expansion or adjustment of the network.
And then states need to change or concretely succinctly as possible.  What you want to make sure is that in this section, because there's so much going on there and things change rapidly throughout the year, that there's opportunities for you to have a SPIL amendment.  So you just have to make sure that the SILC and the majority of the CILs agree to the SPIL amendment and you can submit that to me if you feel that you need to have a change in your plan because of any kind of changes that happen in.
Changes that happen in section 3.2.  Next slide.  So next we move to section 4, which is the designated state entity.  This is an affirmation page.  So basically what you are going to do is you're going to include the name of the state agency that is going to serve as the designated state entity.  So you're also going to include the name of the state so that it is clear that the DSE is going to receive, administer and account for the funds made available to the state under Title VII,.
Chapter 1, part B of the Act.  So the DSE is responsible for these acts only.  This page is specifically relevant to the DSE and no one else because this is their key role that they're supposed to administer whenever they agree to sign this bill.  Now, what's key here is that there's only one DSE.
So when they're administering the funds, they have to make sure that they are accounting for all of the funds that are being administered throughout the state.  That's not anyone else's responsibility but the DSE.  So you want to make sure that you have a DSE that is going to account for all the funds and make sure that they distribute the funds according to the SPIL.
If you have a disagreement with that, then you'll need to have a conversation with them to see if there's a way that you could work through those issues or start looking at ways to maybe locate another state agency that would adhere to these requirements.
Next section.  Section 4.2, the grant process and distribution of funds.  This is a narrative section.  It must include the processes, policies, and procedures to be followed by the DSE in the awarding of grants of part B funds.  In this section, you want to make sure that you include a process for soliciting proposals, development of format for proposals, process for reviewing proposals, who reviewers will be, and the process for evaluating performance and compliance of grantees.
The above must also specify any differences from continuation funding versus new awards.  The SILC and the CILs is to complete this section with input regarding state processes.  Next section.  Section 4.3 is oversight process for part B funds.  Here is where you're supposed to describe the oversight process for part C alone or in combination with part B and other funds, oversight by ACL/OILP, part B when no part C is received oversight by DSE, other funds include in 1.5 of the.
1.5 of the financial plan, and 723 states both part C and part B by the DSE.  This is important so you know who is supposed to be responsible for the oversight process.  This is where you have the opportunity to describe what that looks like.  States haven't had that opportunity to articulate that as clearly as you can in this new SPIL version.
So this one is very important that you want to make sure that you're following the 45CSR where it says the DSE may not include any conditions or requirements in the SILC's resource plan that may compromise the independence of the SILC.
Next.  So now we're moving to section 4.4.  This is the administration and staffing provided by the DSE.  So this narrative section should include how the DSE will demonstrate that no more than 5% of the part B appropriation including state match will be used on administrative costs.  When the DSE employees serve as staff to the SILC, a description of how the SILC will hire, fire, and supervise the staff.
When DSE employees serve as staff to the SILC, a description of how the DSE will assure that such staff will not be assigned to other projects and activities that would create a conflict of interest with their SILC responsibilities.
This is an important section for the autonomy of the SILC.  The SILC has the opportunity to ‑‑ the DSE should not initiate that process.  That should be done by the SILC and the SILC is supposed to be responsible for determining what those lines and roles are to ensure autonomy.
Next section.  Section 4.5 is state imposed requirements.  State imposed requirements contained in the provisions of the SPIL including, state law, regulation, Rug or policy relating to the DSE's administration or operation of IL programs.  Rule or policy implementing any federal law, regulation or guideline that is beyond what would be required to comply with 45 CFR 1329.
So this is where it says that limits, expands or alters requirements of the SPIL, and that is 45 CFR 1329.17G.  Next one.
So we're continuing with the state imposed requirements where the narrative should include any requirements imposed by the state that are in addition to the Rehabilitation Act and the IL regulations.  The narrative should describe how the DSE will ensure compliance with state imposed regulations without restricting the autonomy of the SILC in fulfilling its duties, authorities and responsibilities.
And again, this one is important because the SILC is supposed to be an autonomous entity in the state so you want to make sure that you have clear defined lines that makes it clear that the SILC is autonomous that the DSE or any state entity is not running the SILC.  That has been a problem for some states.  So we want to make sure that you have clear information in your SPIL about that process.
>> Paula:  Regina, I would like to second that.  Some of you have asked what do we do if the DSE tries to take over control in different ways and you list the ways.  This is a place where you can say what they actually are going to do.  And if it's not in here, they don't get to do it, if I understand it right.  Is that saying too much, Regina?
>> No, that is correct.  That is absolutely correct.  So I think that at this point those states who feel that is a problem, they should be reaching out to ACL and then also at some point receive technical assistance from ILRU as to how they are going to disentangle that type of relationship.
Next slide, Tim.  So if your state falls under 723, which we have two now, there are a list of requirements that you have to follow.  I'm not going to go through all of those because of time, but if you are a 723 state, you want to make sure that you adhere to what's supposed to be included in the narratives that are on this page.  Next slide.
So section 5, this is where we start focusing solely on the state independent living council.  In this section, you want to talk about how the SILC is established and how the SILC autonomy is assured.  In this section, you're going to describe the establishment of the SILC, the legal mechanism by which the SILC was established.  This is where you want to include the Executive Order or legislation that talks about how the SILC first started.
So you don't want to just include whether or not you're a nonprofit organization because down later you'll see that it talks about the organizational status, which are two separate things.
You also want to talk about placement of the SILC, where it's located organizationally, and fiscally.  And then how autonomy and independence from the DSE and all other state agencies is assured.  This is the page that is all about the SILC and how you're autonomous.  If you're having issues in this section, reach out to ACL immediately as well as follow‑up with ILRU to try to resolve that issue.  Next slide.
So section 5.2 is the resource plan.  I mentioned in section 1.5 that if the SILC received more than 30% of funding, then a justification is needed in this section.  So what you are wanting to make sure that what you do is you provide a detailed description of all types of resources to be included in the SILC resource plan.
And that includes sources and amounts of funding, staff/administrative support, in kind, and then you also want to describe how the resources are necessary and sufficient to ensure the capacity of the SILC to fulfill all duties and selected authorities according to section 705C of the Act.
Now, you're not required to present a detailed SILC budget here.  But again, you always want to try to include as much information as possible to make sure that you are accounting for whatever it is that you want to do during the reporting period.
Next section.  So we are going to continue with the SILC resource plan.  So you want to include how did the SILC, CILs, and DSE determine the amounts and sources of resources to be included in the plan.  You want to also talk about what is the process used for disbursement of funds to facilitate effective operations of the SILC.
And again, what does effective operations mean?  That's for you to tell us what that looks like for your SILC.  And you want to include processes to ensure time lines and efficacy to prevent undue hardship on the SILC and ensure continual uninterrupted operations and effectiveness of the SILC.
Again, this is where I mentioned if your SILC retains more than 30% of funds, you must justify that expenditure in this section.  And then again we have listed that the DSE must not include any conditions or requirements in the SILC resource plan that may compromise the independence of the SILC.
And you should be able to start noticing a pattern about not compromising the autonomy of the SILC or compromising the independence of the SILC.  So you want to make sure that you're including that in the SPIL so it gives direction to the DSE or other state agencies that might unknowingly start imposing things that will be in conflict with federal law.  Next slide.
So section 5.3 is the maintenance of the SILC.  This is another narrative section where you're going to include the process used by the state to appoint members to the SILC who meet the compensation requirements in section 705B.  The appointment process and how the state ensures the SILC compensation and qualification requirements are met.
How the chair is selected.  How term limits are maintained.  How vacancies are filled.  How SILC staffing requirements are addressed.  And you should concisively describe or cite relevant written policies, procedures, bylaws, technical assistance and monitoring activities or other practices in this section to support the maintenance of the SILC.
And this section is extremely important because several states are having problems with maintaining a compliant board.  So you want to talk through this process to make sure that you have a plan so that your board can be compliant.  This section is an excellent piece that you could use when you're talking to the Governor's office about what's required for you to have a fully constituted board.
So you want to make sure you articulate what the board looks like so that everyone in your state understands what is supposed to happen when you're trying to have the appropriate appointments.  Next slide.
So next you also want to describe how the state will assure that the SILC is established and operating, the appointments are made in a timely manner to keep the SILC in compliance with the Act.  You also want to describe that the SILC is organized in a way to ensure it's not part of any state agency.
The SILC has the autonomy necessary to fulfill the duties and authorities.  The resources provided are necessary and sufficient to ensure that the SILC has the capacity to fulfill its statutory duties and authorities.  So, again, this is just another slide here just to make sure that the SILC is operating according to federal law.  So you want to make sure that they are operating in an independent and autonomous way.
Next slide.  So next we're getting to the end of the presentation, and so we're at the signatures section.  So section 6 very first that all entities with authorities and responsibilities for the SPIL.  Section 7 contains the DSE assurances which detail the roles and responsibilities of the DSE.  These assurances are also found on the DSE notice of award.
Section 8 includes the assurances, which detail the functions, authorities, and requirements for operating a SILC and the indicators and minimum compliance, which are reviewed and signed.  And section 9 needs to contain a place for the chair and all the signatories listed in section 3, and at least 51% of the directors of the identified CILs in the network should sign.
Even if a CIL has more than one grant, they only get one signature.  That was something that Paula mentioned earlier, that regardless if you have 30 CILs, you only sign one time.
Next slide.  So now we are at the end of the presentation and we're at the Q&A section.  And I'm pretty sure after we've covered as quickly as possible but hopefully not too fast about 30 slides that I'm sure there are probably a host of questions that a lot of people have, so this is an opportunity for us to have some Q&A.
>> Thank you so much, Regina.  We are going to dive into the Q&A.  I don't think you all need any help with this, but I do like to remind you of the instructions to ask questions.  Looks like you've all found it.  Please use the Q&A tab in Zoom if it's accessible to you.  If that Q&A tab in Zoom is not accessible to you for any reason, you're welcome to email your questions to me at ‑‑ you can press *9 to raise your hand on the phone.
I ask that you save that tool for folks that need it as an accommodation because with all the questions coming in, it can be difficult to manage and find your hand raised in the list of 260 some participants.  Thanks for your cooperation there.  I'm going to work through these mostly chronologically, but I'm going to pull out some from folks who have been waiting a while.
And things that multiple people have asked.  Regina, I wanted to come to you first.  We've gotten a number of questions about listing especially CARES funding in section 3.1.  Brook is wondering, because the SPIL instructions state not to include funding amounts, only sources, would listing CARES Act funding as a funding source be sufficient or do we need to list the actual amounts received?
>> Correct, as I indicated earlier, you're only supposed to include the source.  So in a column you're going to have funding sources and then you're going to include by that CIL name whether they received CARES Act, part B, part C, state funds, or whatever other funds they received but you do not include the actual amounts in section 3.1.
>> Great.  We got some questions about the format of that chart.  Is that something you all would be able to provide an example of where exactly you want the CARES Act funding to be listed within that chart?
>> Are you on section 3.1?
>> Yes.
>> In the SPIL instrument, there is an example.  And again, depending on which version you have, it does not include the column.  So what you are going to do is just use the current example that is in the instrument and you're just going to add another column, and then you're going to include funding sources.  And then you'll just add in the types by each center for independent living in that section.
The chart is there.  You just have to include the funding source column.
>> Okay.  So here on slide 29, this is the example you're referring to?
>> No.  Actually you'll have to ‑‑ it's not in this presentation.
>> Okay.  All right.  So a number of people also have asked about ‑‑ I want to get back to the Q&A ‑‑ have asked about the transition not only in the federal fiscal year but moving to the new SPIL.  Folks are saying how are we accounting for funds appropriated in April 2020 and maybe received in April 2020 for a plan that begins in October 2020 for the 2021 fiscal year?  Is that only going to be money carried over to the new year?
How do folks account for the CARES Act funding in that regard?
>> So that is a good question and I don't have a complete answer for that.  But I will have to say that part of that is going to have to be coordination with the centers for independent living that receive the funding.  If you go to our website and you should have the link for the new ILS program page and you'll be able to see the amount that the CILs received, you'll have to have a conversation about how much money is going to be available when you start FY2020.
And it's all going to kind of be an estimation and it won't be exact, but you're just going to have to have the conversation to kind of figure out what's going to carryover to FY20.  And if there is a potential for that funding to go over to FY21.
>> So an example from Brooke to clarify, for CILs that receive a very small amount under the CARES Act and they anticipate they will probably fully spend that money before the end of this fiscal year, they probably don't need to show any money for 2021, whereas a center that received a larger amount would need to estimate what would be carried over because they know they won't spend it by September 21?
>> Yes.
>> We did get a lot of questions.  Ann is asking when we show CARES Act part C money, let me be clear, you want us to show that in the chart in 3.1, we just discussed, and not in the financial plan table in section 1.5, is that right?
>> No, that's incorrect.  You're going to include the CARES Act funding in section 1.5 under "other federal funds".  And then you're going to include ‑‑ so in 1.5, you actually include the amount that the CIL received.  So you're going to include the dollar amount.  In section 3.1, you're just going to include the funding source CARES Act in that section.
Where I indicated in section 3.2, you do not need to include CARES Act because there's a section that says one time funding.  And one would assume, because CARES Act follows under that one time funding, that you would include it there, but you do not.  So section 1.5, 3.1, but not 3.2.
>> Okay.  Michael is wondering, we've already seen major cuts to social programs from our city.  We expect the same to be done at the state level.  Is ACL prepared to see measurements in the SPIL that actually show decreases in performance?
>> So if there is a decrease, that would fall under, at least in section 3.2.  There's a section where I think there's bullets where you're supposed to indicate what happens if there's an increase or a decrease of funding in your state.  And that would be with part B, part C, or any other funds that you included in the SPIL that are supposed to be for independent living.
So you want to articulate what adjustments you would make if you receive cuts in funding or even if you received an increase.  So that way it will prevent you from having to potentially having an amendment down the road.
>> Thanks.  I think we touched on this with the CARES Act.  It's probably a similar answer.  Someone was wondering, how do we show the exact part B match when it depends on the final award amount annually?  Are we giving an estimate there?
>> Are you asking about part B match for CARES Act funding?  There is not a match.
>> I don't believe it's CARES Act funding.  Don't let me confuse you.  I was just saying we provided an estimate when money carried over from the previous year.  This is part B match, nothing to do with CARES Act.
>> Okay.  That's going to be part of the processes that you define in section 1.5 and I think section 3.1, when you talk about the distribution of funds.  So you want to talk about what that match is and then what happens if there's a need for carryover funding.
So if you carryover, what is that match going to do look like?  That's not something that ACL would be able to tell you.  That's something that you all would have to talk to and figure out what that amount would be.
>> Okay.  Thanks.
>> And I would stress again, because I have not said this at all during this training, but you also want to talk about when you are defining that distribution process, what happens when there is a carryover funding occurrence with part B funds.  You want to articulate whether or not the entity that originally had the funding will have that remaining dollars in the next fiscal year or is it going to go to another entity?
You want to include all of that information in the SPIL so when I get phone calls and people ask me what to do with the funds, the first thing I'm going to say is what does your SPIL say.  That's what we are going to refer to.  So you want to make sure you include that process as well.
>> Okay.
>> Can I add something there if I could?
>> Please.
>> I answered some of the questions while Regina was talking and several had the same theme.  That was how is something decided.  And most of the time the things they are talking about are decided by the SPIL.  So what is the network?  What are the centers, what happens to the money if a center closes, what happens if there's new money.  All of these are things that you determine.  Your SPIL has to say right in there what it is you do, but you get to decide who signs it, what the network looks like.
So there are lots of elements in the SPIL that really are a local decision, and then you're held accountable to what you said in your SPIL.
>> Let's just take the opportunity to thank ILRU.  Let's thank the SPIL drafting committee who gave you all this latitude to be able to make these decisions.  It is clearly a state‑based decision about what you want to do with the part B funds.
So you have this wonderful opportunity to say:  You get X amount of dollars.  And I can tell you after reading I don't know how many PPRs over and over, a lot of states receive $338,717.  You have a lot of play to be able to determine what you want to do with those funds.  And now that you know that there are several CILs in your state that's receiving CARES Act funding, what differently do you want to do with those funds?  Or do you want to do the same thing over?
You really have an opportunity to sit at the table and say here's a blank slate, let's talk about whether or not what we have been doing with the part B funds makes sense.  Or do we want to do something different?  Do we want to have exploratory projects to be able to provide services to consumers?  Or do we want to provide extra funding to the SILC?  Or do we want to do a host of other things.
You actually have that opportunity to have those discussions and if you come to an agreement, you put it in the SPIL and you submit to ACL to review.  And I think that's the beauty of this document is that you have that opportunity to be able to play with this money in such a way that will benefit people with disabilities in your state.
So really take advantage of this opportunity to see how to best use those part B funds.  And I really thank the ILRU and the SPIL drafting committee for being able to put that in there so that you have that flexibility.
>> So getting back to the questions then, for the CIL service area, Brooke is wondering, the CIL service area is included in the existing network section 3.1.  Would it need to be included again or somewhere else under ACL's guidance on disasters, it's assumed that CILs can use CARES Act funding outside their service area, and that does not need to be approved by ACL.  Since that would not be a permanent service area change, it seems like section 3.1 wouldn't be the best place to use that.
>> So it could potentially go in section 3.1 in the narrative.  It also could be an explanation in section 3.2 if you're looking at going outside of your already approved service areas.  I think what you would have to look at is what you are trying to do in your overall goal and see which one would fit best.  So I couldn't necessarily say based off that question whether or not one is better than the other.
But I would say you definitely could look between 3.1 and 3.2 and kind of decide where you think it should land.
>> Someone is asking, is there an easy way to determine how much each CIL has received to the CARES Act or do we need to reach out to them individually and ask?
>> The best way to do that is to go to the ACL website and go to the link that was provided whenever you registered.  It's the ACL.gov/ILS‑programs.  And there's a funding table tab for you to click.  You'll see that there's CARES Act funding.  I think you have to scroll down two pages and it will list out all the CILs that received funding.  And it also includes the funding amount of what they received.  So you could use that to put the amounts in your SPIL.
The information is already there for you.
>> Okay.  Great.  Thank you.  So if our DSE has not, to date, withheld the 5%, should we include the 5% as direction to them that they should, in case they withhold it in the future?
>> I wouldn't necessarily say that it is a mandatory requirement.  If they are not going to use it, then I guess it's okay for them not to.  But I would say that later, down the road, you don't want them to actually be withholding the funds saying they have the right to do so.  It needs to be included in this SPIL that they are using the 5%.  If they are not, they have decided ‑‑
>> Okay.  Great.  We have got just a couple minutes left.  We are not likely to make it through all these questions live, but we'll respond to those we can't finish today by email.  I want you all to know that's our plan going forward as we work through these last couple questions.
So Regina, the table in 2.1 changed in the new instrument.  It used to say provided by the CIL, check.  Provided by the DSE, check.  It now asks based on the funding sources, unless it's changed again.  Can you clarify that in the table in section 2.1?
>> Tim, why don't you go to another one so I can actually get to 2.1.
>> Yeah.  So if the ‑‑ the last two questions are about 2.1 also.  Stephanie is wondering if the DSE is granting part B money to the CILs also, do we also mark DSE in addition to CILs in section 2.1A?
>> Let's see.  So that one might have to be offline, because I was still trying to focus on the first question so I actually wasn't paying attention to that one.  I apologize.  Sorry.  May we say them again but I'm at section 2.1 now.
>> Let's have you address those by email because we're at time.  So those of you that submitted questions in the Q&A that we haven't gotten to yet, we'll respond by email.  Also, another popular question has been about the materials and recording.  All of you should have these training materials already.  In the confirmation email that you received when you registered that included the connection instructions for today, the Zoom link and phone numbers.
That included some attachments that you may not have noticed.  That's the PowerPoint we have been working through today.  Additionally, these trainings, of course, are always archived on the ILRU's website.  That will be up within 48 hours.  That link on ILRU's website under trainings, and then on demand trainings will include the video of this training, the PowerPoint, and a full transcript.
So please know that that will be up within 48 hours, usually much sooner.  We're at time so we have to go ahead and conclude, but again, we will address those questions that we didn't get to by email.  I want to thank you for joining us today.  We had a great big call and I want to thank you for taking the time to be with us.  Regina and Paula, thank you so much for putting together this content.  It's a tremendous amount of content.
If you have other questions, please don't hesitate to reach out.  Paula and Regina were kind enough to include their emails in the PowerPoint.  You can send questions to me.  I hope you have a wonderful afternoon and we'll talk to you soon.  Thanks.  Bye‑bye