IL-NET National Training and Technical Assistance Center presents
Administrative Requirements and Cost Principles for SILCs as Sub‑Grantees
Presented by John Heveron and Paula McElwee
August 13, 2020

TIM:  Welcome everyone.  We're going give just one second to make sure everyone is connected before we start.  If you're just joining, thanks for bearing with us.  We're going give just one second before we get started here to make sure everyone is connected before we go through any content.  
    Let's go ahead and start.  Welcome everyone.  I want to thank you for joining us today.  I'm Tim Fuchs with the National Council on Independent Living to host Administrative and Cost Principles for SILCs.  We do have captions available.  You can turn them on in Zoom by clicking "show subtitle" under your closed caption options.  
    And we are simulcasting these in Streamtext so you know.  If you want to manipulate the font size or change the font or color.  You may want to check out Streamtext.  That URL is a little too long to read but Sharon just posted that in the chat.  
    And it was also included in the confirmation email that you received.  So everybody should have that.  And if you don't see that, just let us know and we'll get it over to you.  
    We are recording today's call.  So that we can archive it on ILRU's website.  Give us 48 hours for that.  That would be the maximum that it would take and you and your colleagues can review the content from there.  We are in presentation mode right now so our audience is muted.  We are going to have a number of Q&A breaks today.  Three in fact so we've got plenty of time for questions.  
    And we encourage you all to take advantage of that.  There's a couple of ways to ask questions.  If you're connected through Zoom today, that Q&A feature is really simple to use.  So it will say Q&A at the bottom of your screen.  Just type your question there, hit enter and it comes right to us.  You can enter your questions at any time during the presentation.  But we are going to wait 
until the Q&A breaks to address them.  I mentioned the Streamtext link.  There's a chat box there.  I'm logged in.  If you're watching the full screen CART captioning and you don't want to go back and forth, you can type your question in that chat box and I'll be happy to voice it for you.  You can email me.  I've got my inbox open my email is Tim@NCIL.org.  I'll be on the lookout for any questions.  Or tech questions.  
    If you need tech help.  If you're only on the phone today you can press star 9 and it will rise your hand.  We've got a big audience.  We've already got 103 people connected and we're expecting many more as the next few minutes pass.  I want to save that star 9 for folks that can't ask questions through the other methods.  We have to go through, find your line and unmute you and you'll ask your question live.  
    We're more than happy to do that, but we don't have time to do that with the entire audience though.  And finally, just a request.  If you could please use one of the options I just described and not use the chat box for content questions.  The chat has a tendency to roll frequently and it's a great place to let us know, to let Sharon and I know if you need help with Zoom on the technical end.  
    But it's not a good place to post content questions.  So if you could submit your content questions the other methods I described, that would be great.  
    The last thing I want to mention is the evaluation form.  We do want your feedback on today's presentation and I hope you'll take time to fill it out.  If you're on Zoom, when I close the webinar today, it will actually open the evaluation form right on your screen.  It only takes a minute to fill out, and if you just save ‑‑ give us a minute of your time after the presentation ends, it easy to submit.  
    If you're not on Zoom, or you really do need to go, the evaluation link was included in that confirmation email too.  But please do fill it out.  
    I'm going to go ahead to slide 3 here.  This just mentions.  Eval.  John and Paula have been generous enough to share their contact information, which is very nice of them.  And I'm so happy to have John and Paula with us for today's presentation.  I think a lot of you have worked with them before.  Certainly many of you know Paula, and have worked closely with her.  
    If you have not worked with John, John is a CPA out of New York that we've worked with for years and have loved working with.  And John has a lot of experience working with CILs specifically doing the large CIL financial management training that we've done, I imagine some of you are signed up for that.  If you hadn't seen that announcement, find that or go to NCIL or ILRU's websites 
and look for the announcement.  We would love to have you join us next month.  They make a fantastic team and between the two of them, I haven't seen many financial issues for CILs and SILCs that they have not dealt with.  Thanks to you for putting together this presentation and making yourselves available.  
    And here on slide 4, just quickly I'm going to go through the learning objectives.  What we're going to learn today.  How to have good internal controls that will protect your assets and your reputation; how you can monitor to be sure that your controls are appropriate and working.  How the DSE may audit the finances of the SILC as a subrecipient and how to be prepared for those audits.  
    That's the end of my intro and I'm going to go to slide 5 and turn it over to John to dive in a little deeper on the content.  John?  
JOHN:  Thanks, Tim.  In the definitions, the first definition is of a nonfederal entity.  That's all of you who are participating in this program.  Basically organizations that receive federal funding but aren't part of the federal government.  And then sub‑grantee funds or subgrantee, if you receive part‑B funds, you're a subgrantee of the designated state entity, which applies to a lot of you on the line right now as well.  
    The modified total direct costs, this may be a bigger deal for the CILs than for you.  It really impacts any organization that is being reimbursed for expenditures they incur because it addresses how certain organizations calculate their indirect costs.  Or how they spread their indirect costs.  
    Modified total direct cost is some but not all direct costs that indirect can be applied to.  Usually a de minimus 10% rate.  
    Usually our costs or costs to benefit all of your programs similarly.  Smaller categories where it is just expedient to combine them.  So, for example, in the old days we used to track calls, long‑distance calls and copies.  And some organizations still do.  And there's nothing wrong with that.  But it can be much more efficient to include those with indirect.  Even though they could be directly assigned 
to each program, sometimes it is easier to combine those with true, legitimate indirect costs that do benefit everything.  Next slide, Tim?  
    So some of the environmental risks that are fairly current come from our American institute of CPAs.  They publish guidance for us every year about different instruments including the non‑profit industry.  And they address what has happened in our environment that will have an impact.  Not all things are bad.  We group them as risks.  But some things are actually more positive for nonprofits.  
    These days I don't know how much positive there is, because we've really had some challenges this year.  But there are changes in software.  Software manufacturers are really pushing their cloud‑based programs.  They like the subscription products.  They're investing much more heavily in that.  And that changes ‑‑ that takes things out of our control a little bit.  
    Their security may be better than ours, but there is a sense of loss and control, and certainly a sense of change this.  I don't know how many of you use cloud‑based programs, but just as one example, QuickBooks has about 100 times as much development effort going with their cloud‑based programs as they do their regular product updates.  So just as an example.  That's where the software manufacturers are going.  
PAULA:  That's also true of some of the database programs that the centers use to keep track of who they're serving.  And I know we're talking to the SILCs mostly but that would be another example of specifically IL‑related software that's also cloud‑based now.  
JOHN:  Not surprising.  Thanks Paula.  Personal identifiable information.  That's things like social security numbers.  That needs to be protected and there is also outsourcing that is happening now.  More and more outsourcing.  Actually, I've seen an unprecedented number of nonprofit organizations outsource their entire bookkeeping functions.  
    We don't do this, but I know a lot of the CPA firms that we network with have gone more to a model of being a controlling account and a bookkeeper than being an auditor and let another firm do the auditing.  So that's good.  You certainly outsource your payroll in many cases.  If you have retirement plans, you probably outsource the administration of your retirement plans.  
    We've seen some problems with some of these outsource services.  And at large the larger organizations get a report.  They have a controls audit over their procedures called a SOC 1.  Service organization provider report.  Basically it's a report on the internal controls for example that you're a payroll processor.  
    That's not going to happen at an accounting firm level.  But it should for payroll and it probably will for things like retirement plans.  Tim?  
    I guess we've all heard enough COVID‑19 but this has changed significantly for us.  We're working remotely, or are unable to work.  And that adds new strategies for internal control.  We may have spent years refining internal controls in our offices.  We've got antivirus and we've got ad blockers and a variety of security methods.  And now we've gone home where we may be sharing 
a computer with the kids, or at least an Internet connection with the kids who are gaming or doing whatever else they're doing.  And so that's a big deal in terms of the security of our information.  We still have those responsibilities.  
    So we need ‑‑ we as leaders of our organizations, need to provide guidance about having a good work space, having a good routine, having good security at home.  Make sure that key software is available to your work‑at‑home staff.  Consider collaboration tools like Microsoft Teams.  I wish we could raise hands here.  I don't know how many are using Microsoft Teams.  It's really quite a good collaboration technology.  
    And be sure that the software is accessible.  And what that means is there may be more of a migration to cloud‑based software.  As people start coming back to work, there are procedures that you should communicate, and there are some very good resources online.  Paula, I don't think we cited any to recommend, but I know the nonprofit leadership organizations are very good 
in terms of providing sample return‑to‑work policies.  
PAULA:  Text you mention specifically they're nice because some of this stuff is free.  That always is nice when you can find software options that are without cost.  
JOHN:  Techsoup.org, thanks for mentioning that.  They are a terrific resource for nonprofits.  They are a nonprofit.  They do provide a variety of software.  They do provide some things.  Registered organizations can get QuickBooks for free through techsoup.org.  You can get discounted Microsoft 365, which is the old Office 365.  But now they've enhanced it by offering training.  
    This is sort of heavyweight stuff.  It's not easy to pick up.  It's not intuitive to know what order things should be done in.  And they have some very affordable training that's available.  So I recommend that.  
PAULA:  Slide 8, Tim.  So I want to mention a couple of things about what we have available and how it relates to SILCs.  Because the manual that we produced, the sample policy and procedure manual is really geared mostly for centers who are mostly set up in the same way across the country.  They are required to be community‑based nonprofits among other things.  And so those policies 
are easy to put together for the centers.  It is a little more challenging to have this kind of a presentation for SILCs.  For one thing, not all of you are organized the same way at all.  Some of your SILCs receive the money from your state.  And you write all your own checks.  Some of you send the bills to the DSE and the DSE writes your checks.  
    So you have very different set‑ups.  That's why it's really important for you to look at your policies and procedures and look at these samples and make sure they're a good fit for you.  Because the reality for you is that we couldn't write a policy that would apply to every SILC.  So you are going to need to look at it and say I can't do it that way.  What would I do.  
    We'll give you some examples as we go through some of the internal controls that should be written into your policies, but remember this is just a starting point.  So you're going to evaluate your current policies and procedures, and you're going to look at developing new ones or adapting things.  And we believe that these ideas apply well.  It's just that there's not a one‑size‑fits‑all 
when it comes to financial policies and procedures, especially with the SILCs because you're all differently organized.  So keep that in mind.  Virtually, all of the policies and procedures area that ACL or other federal entities are requiring related to money, are in this manual.  So we've really taken a hard look and tried to provide you with some really good samples.  But you have to follow your own policies and procedures.  
    So in order to adopt these, you've got to do them.  You're going to be held accountable to them by your DSE.  If they come in and review, one of the things they'll review is what did you say you were going to do.  When they review what you said you were going to do, they'll see if you're compliant with your own policies and procedures.  And if you're not, you can be cited for that.  
    So it's important to keep in mind that you must make them your own.  You are required to meet regulations and have internal controls and your policies and procedures tell how you're going to do that and they give anyone who's reviewing these some good compliance information about how you can comply on the fiscal side.  So that's really important.  
JOHN:  I wanted to say that is a good point.  If you set yourself up for a higher standard, then what is required, while that seems terrific, keep in mind you're going to be held to that higher standard.  So challenge yourself on those things.  You can always practice to a higher standard.  When you set ‑‑ when you have a required higher standard in your own policies and procedures, you do create some risk of noncompliance.  
PAULA:  The expectation for compliance is absolute and any review is going to look at whether or not you're complying with your own policies.  Including an audit is going to look at that.  Including anything that the DSE comes.  
    One of the key things that we talk about in the financial procedures manual is internal controls and we're going to speak about that a little bit more.  But there are some very specific procedures for access to records.  Who can see them, who does what with the bills that come in and the checks that go out.  And your payroll and anything else that's related to money.  
    You've got to have policies that also make sure that you have segregation of responsibilities and specific methods for handling all these procedures.  Those are some things that the manual will suggest policies for.  SILCs are a little more challenged when it comes to internal controls and segregation of responsibilities, because some of you are operating in a one‑person office, or a two‑person office.  
    And there are not a lot of people to share the work.  We will give you some ideas about how you might adopt your own version of these in some of the ways you might be able to impose some internal controls, even in very small offices.  So we will talk to you about that.  And you know, we have some ideas for that that you'll also maybe want to look at that later and talk to us more about.  We're both available.  And if you are struggling 
through the application of these financial procedures to your policies and procedures, we can give you some specific guidance on that.  
    Also, as I mentioned, how much of the financial management is done by the DSE is going to change your policies and procedures.  How much the SILC implements these actions directly and how much is already done by the DSE as the grantee will be sorted out.  So we said this at the top as a definition but I want to repeat it a couple more times here because I think it's an important piece.  
    The designated state entity that receives the Part B funds is the grantee, not you.  So even though the money is controlled by your state plan, the grantee is the DSE.  So they are responsible first.  But they are also responsible for holding you accountable as a subgrantee or a subrecipient.  So we'll talk about the things that they are required to make sure you do, because that's an important thing to understand too.  
    Their role as the grantee and your role as the subrecipient or subgrantee.  So that sets up a situation where the DSE does some of the financial management, and you do some of it, and how you sort out those two roles is an important part of your policies and procedures.  How do you know what the DSE is going to do and what you're going to do and let's make sure that that's clear in what you have written for yourself.  
    Slide 10.  So this is a fun one.  What can go wrong in nonprofits?  John and I have a little bit ‑‑ John much more than I do because he sees more people's books ‑‑ have a little experience with some of these things and we want to mention them to you because it helps you to understand why the internal controls are important.  Here's one.  Refunds.  You can buy something at Amazon and you can send it back and get your money, right?  
    And it is possible for someone is do doing that with the money for the SILC then refund the money then divert it.  Pay the bill twice, overpay the bill, maybe have it shifted to a different account and the Amazon account setting up a way to refund the money or the credit.  So that's an important thing for you to realize.  That refunds are problematic and you need to look at those refunds transactions from time to time.  
    Kickbacks.  Kickbacks aren't as common as they use to be but if you have a specific vendor who wants to give you something so you'll buy from them, that's the kind of kickback we're talking about.  I don't know if you see very many of those or not.  
JOHN:  Not in the nonprofit world.  But actually it is one of the most common forms of fraud.  I think simply because it happens a lot in the construction industry.  And certain types of nonprofits that do affordable housing might be more susceptible to that but not the organizations we're serving and talking about here.  
PAULA:  Yeah.  But it's still possible.  I have seen it with the purchase of things like big fancy copiers and those kind of larger equipment purchases that you might find. 
    Check signatures.  The bank isn't very good at looking at signatures and verifying them.  So people can forge a signature and then make a payment on their own behalf or to themselves.  We had a situation that I know about where this particular center had the Section 8 existing contract for HUD for affordable housing.  
    Two people in the office always did the checks and balances and then one of them ended up out sick for a very long period of time.  8 months, not quite a year.  And the organization failed to put new controls in place.  So the person who was issuing the rent checks started making up addresses of a new landlord that was created and new consumers were created and the landlord's name was on an account that she owned.  
    And she diverted quite a few rent payments off to this $3,000 or $4,000 a month.  And she was prosecuted and she did jail time and a huge fine.  It was a terrible thing, but it was happening partly because approvals and signatures on leases and everything else was also forged.  Set up all the paperwork in order to make these purchases by setting up forged signatures and created people.  11, Tim.  
    That's a better description what I just said.  Credit cards you can use the company cards to charge personal things.  Sometimes that will happen.  You can make returns again and credits that are issued and they might be issued differently than what would preserve it for that company.  
JOHN:  On that one, Paula.  We did have a situation who had been a client of ours.  And not on our watch, but at any rate, their CFO was putting credits to his credit card.  They were quite substantial, I guess one month that it all washed out.  The credit succeeded the charges.  This was an organization that had quite a bit in sales.  It is something that you don't think about that much, but it can be pretty significant.  
PAULA:  The thing that I'm kind of concerned about right, buying a lot of supplies that you've never bought before.  The SILCs less so I guess, because you don't get that money.  But it's happening in centers right now and I know it can happen for anybody.  If you have an event that you purchased supplies for.  The person who runs and gets the supplies includes some personal items leaves them in the trunk.  
    Everybody assumes it was for this event and nobody did an inventory.  If you've got anything of substantial use, you want to make sure that somebody inventories the order as it comes in.  It's true if something is ordered online or if somebody purchases it downtown.  Either way, you'll set your own limits but it's a purchase of a certain amount, it's worth it to have two people unpack and check off on that receipt 
and make sure that everything there was for the organization and is a legitimate cost.  
    And slide 12.  
    A few more examples for you.  Either the payee or the amount is altered after the check was already signed.  So if it's a check made out to that individual, they may be adding a zero or did something other things to erase and change the amount on the check.  There's some things that you can do to reduce that risk.  And we'll talk about those as we talk about some of the internal controls.  
    But it does happen that either the payee or the amount is altered.  And if you don't reconcile your checking account on a regular basis so that you know if improper checks are going through that account, the bank's liability diminishes the longer it takes for you to do your reconciliation.  So we suggest that you have that check register that was printed out 
that's supposed to be the official record and check it against those checks.  Actually look at the images online to make sure that the payees are right and make sure the amounts are right as you reconcile your checking account.  And it's often a good idea for someone other than the person who handles the money to do that check.  We'll talk more about internal controls of that sort in just a minute.  
    But if you don't report the check forgery, the bank won't pay for the ones that are after that.  So if you don't catch on and get it stopped and the person does it on an ongoing basis, it becomes even more difficult.  
    And mobile bank fraud is becoming more common.  John I'm not sure exactly how that happens in a work setting, but I know in my own situation, I have to lock my account on my phone because I have people in my family who play with my phone.  Little people.  
JOHN:  I mean it would just be gaining access to a business account through a cell phone.  That can be done.  That's one of the forms of mobile banking fraud.  The other is just a debit ‑‑ debit cards are used as an example.  People are able to capture that information in different ways.  The information from the debit card and to replicate that.  So it is a concern.  
PAULA:  Tell us more about internal controls.  Slide 13, John.  
JOHN:  Let's move on to the next slide, Tim.  So given all of these things that can go wrong, and by the way it's a good list, but it's never complete.  There are always new things coming up and particularly with the work from home here, there are additional risks.  Keep in mind in your organization, if you've got certain people who are writing checks, they probably should be the only people with access to those checks.  
    Or at least limit the access to the blank checks.  Otherwise somebody might be able to grab one from the pile of checks and process it through.  So you want to be careful with that.  
    There are people in your organization who should be reviewing financial reports.  But not necessarily entering information into the general ledger.  So you want to think about access rights.  And this is something that has become more powerful with most accounting systems.  You have quite a bit of flexibility about the areas that you allow people to review or to post transactions in.  
    Even with simple inexpensive software like QuickBooks.  I know we refer to that a lot but a lot of nonprofits use that.  This software can be set up to limit rights in each area, receivables, payables, check writing.  And it will also limit it by whether you can view reports or whether you can change things.  For example, changing a vendor or entering a vendor.  
    The person who prepares checks should not also mail them.  Paula mentioned a situation of somebody changing the payee.  So the check preparer, once they hand the check to someone for review and signature, they shouldn't get it back.  Again, assuming you've got enough people to do that.  That's not always a possibility.  When you don't, you have to think about other controls, which would include a careful review 
of the bank statement when it's returned.  Paula, you were going to comment on DSE.  
PAULA:  Right.  So when the DSE is involved in your financial procedures, either you're making a check request of them or you're making a request for reimbursement or whatever the interaction is between you and the DSE that helps to pass the money over for you to operate, when the DSE conducts some of these functions, they already have internal controls in place at the state level.  
    And their policies are what will apply.  So there's some situations where you don't have control over the policy or procedure, but the DSE is conducting that part of the function and therefore their policies are the ones that would be followed.  
JOHN:  Thank you.  14, Tim?  
    Some examples here with the general rule of thumb that two people should be involved in most every transaction.  And again, that may not always be possible.  But some examples.  The person who approves the expense and signs checks isn't the same person who's writing the check.  So you want a separation of responsibilities there.  
    No one should sign a check to themselves.  You may have a small staff, maybe a very senior person who's presumably a very reliable person.  Still, they should not sign their own check.  A board member, a council member should sign checks to the executive director 
PAULA:  John I don't remember if we mentioned this elsewhere, but there is software out there, cloud‑based software out there, where people can, who are authorized on the account, can approve a bill remotely using things like bill.com is the one that they use at the center here I know.  But using things like that, a service that you are a part of that will issue a confidential and very secure request for approval 
to whoever that is and that would give your council members or your chair into the approval process in these situations.  So you're not in a situation where the executive director is the only person who can approve even their own reimbursement checks.  
JOHN:  That's a great idea.  And it also documents the approval process.  So it really does help with the record‑keeping system.  Particularly when we can't be together.  Even in a normal situation sometimes it might be difficult to get a board member in the office to look at things.  That's a great solution.  
    We talked about entering new vendors or entering new employees into your system.  Someone should review those records and you want to limit the number of people who can add employees or vendors.  
    The person who reviews the checks and reconciles the accounts should be different from the person who's writing those checks or has access to that information.  That's a very important review that needs to happen on a timely basis.  Certainly within 30 days.  Hopefully quicker than that.  We can move on.  
    So you may have invoices for most things.  There may be situations where there aren't invoices.  So you can use a requisition, a check request.  They still should be approved by an independent person just like an invoice.  
    If you feel that an expense might be questioned, it's worthwhile to explain why this should be allowable and why it should be charged the way it should so you can document that right on the invoice.  Again, we can't get answers to questions here, but think about how expenses are compared to your budget.  Your financial plan.  And probably that's going to happen with a budget to actual report monthly or quarterly, however often 
you do financial statements.  And it usually should be a current period, like a current month comparison, and then a year‑to‑date comparison.  That's the most effective.  And we're not going to talk too much about it here.  But that's another reason to have a simple accounting system.  If the accounting system is simple, these comparisons can be done without having an enormous amount of data.  
    But the data is more meaningful when it can be analyzed.  How do you report to your council as they oversee your organization.  Paula did you want to comment on that at all?  
PAULA:  A little bit.  You know, the council is in charge.  For more than half of you, the council is your private nonprofit board, in addition to being a governor‑appointed council under the Rehab Act.  So often you have kind of both of those situations going on.  But however you review it, the council is autonomous and the council is in charge.  
    So what are the reports they need to accurately oversee what you're doing as a SILC.  And you need to think that through so that as you look at your recordkeeping and as you look at your reporting on that, that you make sure that you have adequate information for them to fulfill that role.  
    Also if you have more than one funding source, we're not going to spend a lot of time today talk about time and effort reporting.  But if you have more than one funding source, you have to spread your costs, including payroll, across those funding sources in a fair and planned way.  And that includes payroll.  
    So if you have a situation where, for example, as a SILC person you're doing some lobbying, and lobbying is not an allowable expense under federal funds, then you would have to keep track of your lobbying time separate from the rest of your time.  So you would have two different places that your time could be shared.  Paid for and shared.  And you can't use the federal dollars for the lobbying piece.  So you need to 
keep track of your time in a way that will help you make sure you can allocate your expenses properly across whatever funding sources and whatever nonallowable activities that you have, if that makes sense.  
JOHN:  We were very deliberate about saying after the fact.  There's more flexibility now in methods for documenting payroll.  But there's no flexibility in the fact this should be done after the fact.  You can use a budget initially with your recordkeeping.  But when you're allocating payroll particularly, they want you to look at what was actually done.  
    Not what you planned to do, not what you intended to do, but what actually happened.  So there should always be a review.  Very least on a quarterly basis of whether payroll is being allocated based on what's actually occurring.  
PAULA:  Slide 16?  S. 
JOHN:  Is it back to me, Paula?  
    So the same thing for other types of costs.  If you have multiple funding sources, you're going to have to allocate responses to the proper source or cost objective.  Sometimes if you have multiple funding sources, sometimes it's easiest to treat this as a simple cost objective and split out the cost using something like an Excel spreadsheet to split them out between the two funding sources 
PAULA:  We will go into this in more detail.  A lot of you don't have more than one funding source, so this may not apply.  But we will go into more detail in the training we're doing next month and we also have some written information online to help you with some of this.  But if the DSE is issuing the checks to reimburse you. 
    They still need to see allocation if they're reimbursing you for more than one funding source or if you have more than one funding source and they're only reimbursing for the portion that comes from them.  So you do need to look at this closely.  And it is a method of making sure that you're controlling expenses because you're making sure that expenses only allocated if it was a proper expense to that funding source.  If that makes sense.  How about 17?  
JOHN:  I'll say it, but I heard you say it Paula.  If you didn't do it, you didn't document it.  When it comes to internal controls, that's really ‑‑ that's really the mantra we should follow.  You've got to get it down on paper.  Not just do it, not just have a policy to do it.  But document that this was done.  This is true for establishing the control environment, which really means the policy you adopt.  Your risk assessment about what could go wrong, control activities, 
communicating procedures to your staff.  The policies and the monitoring that you do.  So all of these should be documented.  And as auditors, when we do compliance audits, we're required to look at your controls over compliance.  And it's going to be the same with DSE and other funder auditors as well.  So we're not only going to look at whether you complied, but whether you had written controls over compliance that you communicated to your staff.  
PAULA:  And one of the things that I always say to people is related to documentation, you don't know that you'll remember it if you don't write it down.  Maybe you're all young enough that you never forget anything.  But what I find is the more I've got going, the more I'm likely to not remember.  And if you can't remember your rationale, you need to write those down as well.  If you feel something is allowable, 
and you think someone else might question it, explain why you think it's an allowable expense.  Put it right there in your record for paying that bill, because you're not going to remember in three years if it was something ‑‑ and that's when anyone federal would take a look at it.  How about slide 18?  
JOHN:  Slide 18 talks about some strategies to improve your banking security.  These come from your bank.  Your bank is really your important when it comes to security over your bank accounts.  And they really work hard at it.  The relationship with your bank is usually pretty successful.  Bank accounts don't get hacked that much.  They've got good internal security.  They've got security people on board.  
    And they've been adding ways for you to secure your bank account.  Things as simple as secure checks that are really easy to falsify.  We talked about altering checks.  Some you can do that more easily.  Some you really can't.  Your banker will tell you about that.  
    Positive pay, and it may be labeled differently with different banks.  It means you provide the information about the checks that you're going to be issuing.  And if they have a check come through that wasn't on your list, they won't pay it without confirmation from you.  And there's a reverse version of that, where the bank simply sends through the list of checks that are going to post to your account.  
    And you have a very limited amount of time, about the at least some time to say wait, that's wrong.  A secure font is good.  Putting asterisks at the end of a payee name to prohibit adding another name can all improve security.  
    We've reached out to our bank and they come right into our office and they will do a seminar for us, not these days I guess they do it virtually, but they're very happy to talk about these things and I know they would be happy to talk with you about it.  So take advantage of that.  
PAULA:  Slide 19 we have some cybersecurity challenges.  
JOHN:  I was watching a program on cybersecurity recently.  We saw a sample ad for basically a thief, not in this country.  In a country where money goes a lot farther but they were offering a salary I think it was $241,000 U.S. for people to just hack accounts.  It's a good‑paying, full‑time job.  And what they want more than anything is money.  In fact that's all they want.  
    They'll steal a number of things or do a number of things to get money.  One of course if they can get access to your accounts to steal money from accounts.  But they'll also lock your data so that you don't have access to it to get ransom.  They will steal credit card numbers or social security numbers that they can sell.  And I guess they go for about $5 apiece.  Pretty scary.  
    They get paid well to do these things.  They work at it all day long.  They continue learning as additional security is put in.  They try to find ways around it.  We're not going to go to these sites, but there are a couple of things that may help you with your staff.  
    Most of the hacking is what's called social engineering.  That's people reaching out to you and your employees with a pretty good appeal and trying to get you to click on a link.  That will allow them to download ransomware or gain access to your confirmation information.  ‑‑ confidential information.  You need to make sure everybody is reminded of this continuously and these couple of links are just for that 
PAULA:  I don't know if it's just anecdotal but one of the things going around with the COVID‑19 crisis is that there's an increase in cyber attacks.  Maybe people have more time on their hands or more people are working from home and they spend some of their work time doing something else.  But I have at least heard there's an increase right now.  
JOHN:  There is.  There is a documented increase and it's one of the few growth industries these days.  And it is for the reasons you say.  First of all, COVID‑19 sort of opens a door because a lot of these people will come in with something very compelling.  You have been in contact with a person who has COVID‑19.  Here's a link to the information about that.  Well, it's not a link to be trusted.  So we do have to be 
diligent all of the time.  It's too bad we have to be so cynical these days, but we have to challenge all of these things.  
PAULA:  Tim, questions for us?  
TIM:  Here we go.  We're at our first Q&A break.  Let me quickly review how you can ask a question.  Some of you have already found the Q&A feature in Zoom.  That's great.  We'll start there.  If that doesn't work for you, you can email your questions for me at Tim@NCIL.org.  If you're only on the phone you can press star 9 to raise your hand.  Or if you're on the full‑screen CART captioning at streamtext.net 
you can submit your questions there.  Early on anonymous ask does the PPP mean we cannot request reimbursement for salaries that were in the PPP period.  I believe that's correct, right?  Otherwise they would be double‑dipping essentially.  Is that right?  
PAULA:  They're using the funds ‑‑ John, if I don't ‑‑ because I don't work with this every day.  If they're using the funds from the PPP to pay the salaries, then those funds are forgiven.  That you couldn't pay for it twice. 
JOHN:  Right.  That's essentially federal funding for those salaries.  So you could not use those same salary expenses against another regular federal funding.  
TIM:  Okay.  Anna is wondering is it okay for an executive director to sign her own check as long as a second signatory signs too.  In this case the second signatory would be a SILC member.  Is that all right?  
PAULA:  I prefer not to.  I don't know about you, John.  
JOHN:  I prefer not to, just because it's sort of the general rule.  But really what we want is an independent signature.  So I wouldn't really have a problem with it.  It's not what I would recommend but I guess I would be okay.  As long as there's an independent review and signature of that check.  As long as that person isn't signing their own check exclusively. 
PAULA:  And sometimes it's not actually a check.  We use that lack wage, but sometimes it's actually a bill that's paid through an electronic service.  We mention bill.com as one of the sources.  I happen to be on a board for a center and I'm one of the signatories.  
    If bill.com comes through and asks me to secure it, it's secure and protected I only give that approval.  Sometimes it's an approval given by a service like that but the check can be signed as long as you've got the approval from the other party.  
TIM:  Is cybersecurity insurance recommended?  
JOHN:  I will tell you that we decided that it was a good idea for our firm.  It's not terribly expensive considering the risks.  The other benefit that you do get out of having this type of coverage is that you do get some guidance from them.  They want you to follow certain standards so they're going to keep you informed.  
    Especially right up front when you're first getting the policy.  So it's not a bad idea, but you always have to weigh the cost and the risks here too.  
TIM:  We ended up getting NCIL because the funder ‑‑ the world changes fast it's something we probably wouldn't have purchased five years ago we wouldn't have because of that requirement.  We've decided it was a good purchase for us.  You've got to be aware of those expectations out in the world too.  
    Dawn is wondering most of our SILC bills are paid directly to companies either through a bank card or a checking account.  That's set up directly with a company you receive services from like the phone company and our copy machine lease, our Zoom payments.  Is this a good way to do business?  We hardly write checks anymore.  What do you think about that, John?  
JOHN:  So I would like to be clear on whether each of these vendors is actually set up to take their own payment, or whether you have them set up as payees in your own bank account and you're paying them electronically.  I would be much more in favor of that second method.  I know how easy it is to have things set up for auto pay with the vendor, but that just gives them quite a degree of control over things.  
    I wouldn't be as much a fan of that.  Paula, I don't know what your experience is with that.  
PAULA:  Yeah.  When you're in control of it, you set it up in your own banking account and you identify the vendor and you have a way within QuickBooks often that's linked that allows you to do the allocation if that's happening, it's going to make sure that you have better control over it than any other way.  And automatic payment, I get caught now and then, I sign up for something and I think three months later did I even use that.  
    You want to have ways that you're looking at all of those bills and make sure they're still things you want to pay for.  
TIM:  And final question for this break comes in from Dora.  Is there an issue with sending invoices by email for approval?  
JOHN:  As Paula said earlier, there are technologies now for electronic approval.  I think that's just the way of the world now.  So I'm fine with that.  Again, you need to document it.  So you need to permanently retain or retain according to your records retention schedule that approval.  But that should be fine.  
TIM:  Great.  All right.  We've got about 31 minutes left.  I'm going to go ahead to slide 21 and we'll keep rolling with the content.  
PAULA:  All right.  We want to talk a little about some specific controls over cash management.  And one of the things you want to do is look at your contract and look at your policy and make sure that they're a good match.  So if your contract has specific requirements on how you do your drawdown for example if you're in a situation where you draw your funds in some process, make sure you've looked at that process and that your policy is approved and that it matches what your contract said you were going to do related to that draw or whatever it is.  Whatever way that you request money to come into your organization based on those relationships.  
    And taking a look at that on a periodic basis is important.  Most of your contracts probably are year to year, so you probably have an automatic period of performance controls where you stop time and you look at the contract and what it requires and you look at your policy and procedure and what it requires and you verify that your process is actually doing what you said you would do in these situations.  
    And I don't know, John, if you had anything to add to that or not.  
JOHN:  I'm good, Paula.  
PAULA:  Okay.  We'll talk just a second about unallowable costs starting on slide 22.  Federal dollars can't pay for everything.  And I think we all know that.  So it's on the next slide, Tim.  So we know what some of these are, but you'll find them in the regulations.  The regulations that HHS, health and human services and ACL use for our grants are found in this reference here, 45CFR75.  
    And the unallowable costs start at 420.  There's actually 421, 422, that's where it starts to list them as items that you cannot pay for with federal funds.  Probably the one we know first and foremost is alcoholic beverages.  We know we're not allowed to do that at all.  There are other kinds of entertainment things and a lot of times the prohibitions on food are kind of related to that entertainment expense.  
    So we'll see a lot of limitations on when you can buy food.  And typically it is not allowable to buy food for your council meetings, for example.  Although I think I would continue to have the argument that it is more efficient with your time for your volunteer council members and it's sometimes not a simple thing to break for lunch and everybody buy their own and reimbursing them anyway.  
    But there have been pretty firm judgments saying meals for SILC council members are not typically allowable.  Interest if you have loans or lines of credit and you're paying interest, that interest is not allowable.  If you're fined, have late fees or penalties of any sort, those fines and penalties are not allowable expenses.  
    And probably the one that hits the or has the potential to be looked at the most is lobbying.  Your council is allowed to do advocacy, including that in your state plan.  But you need to make a distinction between other advocacy efforts and the kind of lobbying that's not allowed.  ACL has a new ‑‑ fairly new, came out last summer ‑‑ guidance or an FAQ around advocacy specifically what's allowable around advocacy.  
    Those are typically not allowable and can't be charged to federal grants.  Dawn asked about, and I'm going to answer this here, asked about the issue of working lunch.  And I would, you know, I would say make that case.  Especially if you have people coming from a statewide basis and you have good statewide representation.  But I think you need to kind of know that it's also still been questioned sometimes.  
    So your DSE could come in and look at that and say no.  They're the ones who are overseeing the use of those funds.  So really that's ‑‑ and they're usually at the table.  So hopefully they're allowing that.  
JOHN:  Before we get off that one, I just want to make a couple of comments.  First of all when it comes to lobbying, lobbying costs is only not allowable, but it is an activity.  So it needs to drag along indirect cost with it.  Not only must lobbying be disallowed, but if you allocate your indirect based on direct labor, for example, then you would have to allocate some indirect to that as well.  
    Also, just wanted to comment that you're right with the interest being disallowed.  There are certain circumstances where interest is allowed.  If it was, for example, mortgage interest, something of that nature.  Just a clarification.  
PAULA:  Not very many SILCs have their own building.  
JOHN:  Right.  
PAULA:  Legal defense and other legal costs are generally allowable.  They are allowable if the litigation is initiated by any government entity around the False Claims Act.  So if a nongovernmental entity, or nonfederal entity is accused of having drawing down money or made requests for funds that were improper, then those costs are not allowable.  
    Typically the costs are not allowable if they're based on or surrounding a whistleblower complaint.  If a current or former employee or someone else who has to do with the SILC's operation makes a whistleblower complaint, the representation that you have to defend you against that accusation would typically not be allowed.  
    And I don't know, John.  It would typically be allowed if you're planning, correct, or if you have legal counsel who's helping you develop policies and procedures or make plans for ways to not be in a legal situation, typically those costs allowed.  
JOHN:  Yes, absolutely.  And. 
PAULA:  And if the claim relates to violation or failure to comply with anything you're required to do, then of course the process of defending yourself against that could not be an allowable cost.  Let's look at slide 24.  
    Membership subscriptions and professional activity costs.  Although the costs of membership in and subscriptions to professional and technical organizations are generally allowable, that doesn't apply to the local country club or organizations where you might want to, I don't know take people out to eat to impress them or whatever.  Those kind of clubs.  Typically those memberships are not allowable.  
    Typically costs for memberships in organizations that are lobbying organizations, is their primary purpose would also not be allowable.  
    For membership in IL organizations that also do lobbying, it is not the organization's responsibility to ensure that their funds ‑‑ it is the organization's responsibility to ensure their funds do not support lobbying.  For example, if your SILC is a member of a membership organization, an IL, and you know that that organization is also lobbying, it would be your responsibility to determine that your membership fees are not paid to support lobbying.  Now, 
this was a language change made by ACL when we submitted these slides for their approval.  So that's their language.  Memberships in IL organizations that also lobbying, it is the organization's responsibility, meaning the SILC or the CIL, to ensure their funds do not support lobbying.  It is the DSE or indirectly the SILC or part B CILs to be responsible that funds are not being used for lobbying.  The DSE will oversee this items.  
    They would look at the SILC's books or part B CIL's books as part of their review and they would look at that issue as part of that review.  Do we have any questions right now or do we want to move on?  
TIM:  We don't.  This is Tim, and in the interest of time I'm going to suggest that we skip this one and we'll have a final Q&A break at the end.  
PAULA:  Perfect.  John you want to take that next section?  
JOHN:  Sure.  So again, this isn't as much of an issue for those organizations, because most of you don't have an indirect cost rate.  But just wanted to make sure that everybody knows that there are a few different approaches.  One can be an approved federal and direct cost rate which was issued after an indirect cost rate proposal is submitted and approved.  
    Some organizations rather than do that will elect to have a 10% de minimus indirect cost rate.  But as we said earlier, it's only 10%.  It's not a very big indirect number and it doesn't apply to all direct costs.  Only some direct costs.  
    Directly, direct allocation, that means you would directly allocate everything to each program.  That's really tough.  At best it's tedious.  And time consuming and probably not worth the benefit is probably not worth the cost.  
PAULA:  I just want to mention the cost allocation plan that we list there.  That is what RSA and the department of rehabilitation had everybody doing back before WIOA.  And as a result of that, a lot of the DSEs are still utilizing that.  And you may or may not as the SILC also be utilizing a cost allocation plan if you have more than one funding source.  
    So if you are using a cost allocation plan, it's allowed by the DSE.  It's not allowed typically for the centers who are part C centers, but it is not being questioned when it's the SILC in relationship to the DSE.  If that makes sense.  
JOHN:  27.  So we've got some sample policies in that financial manual that we referred to.  You need to make these your own, but you do need to have a policy that covers the different types of travel, what the preapproval process is, how they're reimbursed, whether per diems are allowable or only actual expenses.  
    This is an area that is subject to abuse at times.  It's an area that ACL/OILP will most likely look at during their audits.  And it's not just your organizations.  This is fairly universal.  I know in New York State throughout the state, school districts were found to have a big problem in that area.  So it was a focus for the state auditors that were looking at different school districts.  Senior staff needs to be subject to the same documentation 
as other staff.  The director doesn't get a bye in this area.  Often this got identified as an area of abuse.  It might not have been abuse but it might have been a situation where the documentation wasn't as good because there wasn't the same level of oversight.  But it gets written up as being abuse.  And so you just need to hold everybody to the same standard.  
    And use an executive member.  
    When credit cards are used original receipts should be maintained for documentation.  The bill itself doesn't contain enough information because it doesn't document allocation and sometimes it doesn't even document what was purchased.    
    Again in the fiscal procedures manual we've got a sample purchasing policy.  Your organization may not be required to have a procurement policy, but if you do, we've spent a lot of time in that area.  We've got a really good start.  Again you would want to adopt this and make it your own and not commit to things that you're not able to do.  But I think we've been pretty clear to identify what does have to be done.  
    But what the requirements are.  It lists objectives limiting purchases to necessary items, minimizing the possibility of theft and abuse, and that area we talk about conflicts of interest.  Controlling costs while ensuring quality, complying with regulations.  Improperly allocating these things.  
    And let's go on to the next slide.  We talked about procurement thresholds and we've sort of gone back and forth with the dollar amounts.  When uniform guidance first came out, the micro purchase level was what, $35,000 or $3,500?  
PAULA:  $3,500.  
JOHN:  And then small purchases were up to $100,000.  Some of the first the department of defense got increased limits, and then there was a memo that seemed to indicate that every organization got this.  ACL has indicated that they are using these higher limits.  And today, today, August 13th, in the federal register, there were updates to uniform guidance that were issued that confirmed these higher limits.  
    The micro purchases are just under $10,000 they're saying.  Just try to use different vendors for these.  But you don't need to go through a formal process.  As you can see with small purchases now, up to $250,000, you need to get some different quotes from an adequate number of qualified sources.  And by the way, these don't have to be written quotes.  You can go on online and get pricing from different websites 
to document why you selected who you did as a vendor.  And as you get into larger purchases, as you get into constriction, which won't apply to most of you, then you have even greater ‑‑ 
PAULA:  In fact, it was interesting when we were working with ACL about these specific slides, one of the things they said is how often will a center even use that $250,000 level.  Probably not.  I may have something that exceeds $10,000 from time to time but it's not going to be frequent.  It can be multiple purchases but it's still that $10,000 limit.  
    And they said the thing they're most interested in this next one if you're purchasing any equipment or building improvements, in excess of $5,000, it does require prior approval from your funder.  So that's where their focus was the most.  And that's probably true.  We don't use those other limits very often.  
JOHN:  Just to clarify on that $5,000 equipment purchase limit.  That's the federal limit.  If your limit is lower, you're held to your limit.  If you say in your policy that you distinguish between supply items and equipment items based on let's say having a useful life of more than two years and a cost of more than $2,500, then you're held to $2,500.  
    So $5,000 is a limit, but only if it's the limit you adopt in your capitalization policy.  
PAULA:  Of course at the state level, because you're working with the DSE, they may also have a lower threshold that they require you to get approval for.  So keep that in mind too.  
JOHN:  For annual filings, the SILCs generally are 501(c)(3) organizations.  So in most cases, this year being an exception, you have to have your 990 in within four and a half months after the year end.  As I'm sure you know for anybody with a calendar year end, that they've got automatically extended to July 15th, and you can request an extension until November 15th.  
    Most of these organizations, September 30th, Paula?  
PAULA:  Yeah, most of them.  Although some have kept July 30th or the calendar year.  We still see both of those as well.  
JOHN:  So not all of these are going to receive a similar extension.  Generally it's four and a half months after the end of your fiscal year.  Extensions aren't difficult to obtain, but you do want to do that.  And then you may also have a filing with your charities bureau.  I know here in New York there was a submission and of course a requirement for reviewed financial states at a certain level and audits at another level.  
    So make sure you're familiar with the requirements of your charities bureau.  
PAULA:  Slide 31 please.  We're going to talk with this last couple of minutes that we have about that relationship you have as a subrecipient of the DSE.  And for some of you, this is important because how you are treated or categorized by the DSE really is determined and already set up in the federal regulations.  And so you are identified as a subrecipient, not as a contractor.  
    Now, most of the time this is just semantics.  But once in a while we see a situation where, for example, a subrecipient should be able to get an advance, but a contractor can't in that state.  Well, then it would be a good thing for you to clarify this relationship with your DSE that you are a subrecipient or a subgrantee, not a contractor specifically under their definition of it.  
    It's going to vary from state to state, but we want to point out to you that if you're a subrecipient, you're responsible for programmatic decision‑making, for example.  You're responsible for meeting objectives in your SPIL under federal program objectives, you have to be responsible for your own compliance, but you're not competitive like the contractor is.  The SILC is the entity that the DSE will be working with.  
    And the SPIL, the state plan that you wrote, is the document that will oversee how the money is used.  So it's a very different relationship and it's good to know that that language might help you get some clarity sometimes with the DSE.  Let's look at slide 32.  
    So there's actually a section in the federal regulations around how a DSE would monitor a SILC.  And sometimes I'm not sure that that's known by the DSE or known by the SILC.  So you want to make sure we put some of this into place.  
    They are the pass‑through agency.  They don't get to keep the money.  They pass it through to you and they spend it based on the SPIL, whoever writes the checks based on the SPIL.  And as such, they're making sure that they're providing you with the federal name and award and number, and what the award amount is.  
    Now we had some really interesting things happen with the last couple of SPILs where the ‑‑ especially last year because we haven't seen this year's come back yet.  Where the situation was that the DSE did not give the complete amount to the SILC for review, and the SILC is really who gets to decide where that money comes.  But the DSE had already received this pocket of money.  So they just left that out of the communication.  
    They can't do that.  They have to let you know the entire amount.  And there are some other requirements that you might find interesting there.  On slide 33.  
    The DSE can withhold your funds if there are issues.  Until you have shown that your performance is appropriate.  So they can determine how much monitoring to do.  They can decide that you are at risk as a recipient, and they are the grantee.  So they can hold you to some additional monitoring or more detailed reporting until whatever the perceived risk is, has been resolved.  
    Typically this is going to happen at DSE without interference of ACL or the office of independent living programs.  So typically they are not involved in this conversation.  And if there's a review of money in a state, that review is actually of the grantee.  Of the DSE.  So keep that in mind when lieu at the review process.  
    So if you receive part B or I & E funds either one, either way you are a subrecipient of the designated state entity.  So they can do site reviews or our audits as a result of it.  Slide 34?  
    So they can assess that risk by doing a review or by asking for information or doing it on site, either one of the they monitor you for performance and compliance.  And monitoring can include things like examining how you're doing and spending your money and meeting your goals and if there are delays they can judge the risk related to those delays.  So they have a lot of responsibility, as you can see from this content.  
    A lot of responsibility for oversight.  Now when WIOA was first passed in 2014 and we talked about the autonomy of the SILC, this wasn't on our radar this.  Is coming from a different place in the regulations.  This is coming out of the financial regulations in 45CFR75 in what's called uniform guidance that's found in another place.  And this also applies.  
    Which took us a little by surprise when it came to this relationship.  But this is our reality.  35.  
    So you must provide them with information as well, and if you have an indirect cost rate that's part of it.  Just one more word about indirect cost rates.  Again, only necessary if you have more than one funding source or you separate your lobbying costs as a separate cost objective otherwise you only have one funding.  
    But they have the right to look at how you're doing that indirect cost rate.  You still can elect to go the federal route and get approval for that.  If you decide to do the 10% de minimus rate as part of that, we want to have a conversation about that and I also have a blog post about that.  This isn't part of your indirect costs.  It is applied against modified costs.  If you're doing a 10% de minimus.  
    And you're not familiar with what we're describing there, you need to get in touch with us separately so you can take a look at that.  
    The good news is that most of what you do isn't as complex as the requirements.  So the financial operations are fairly straightforward.  Complicated often you only have one source of funding so you don't have to do an indirect cost rate.  And actually you don't have to do a federal indirect cost rate unless the DSE requires you to do that.  You have to work out with them what your indirect costs are and how to do that.  
    Because the SILC is fairly simply put together an you are able to have straightforward and fairly uncomplicated processes and good for you because that's not always the case when it comes to federal dollars.  So it's nice that you can do that.  It can be complicated by your DSE, unfortunately.  
JOHN:  Just to add to that, Paula.  As a very practical matter, a good way of monitoring here is just to look at whether reports have historically been timely and completely submitted.  And if so, that's a big deal right there.  That's a really good indicator about the responsibility of the subrecipient.  
PAULA:  Good point.  And Tim, I think that's our content.  
TIM:  That's right.  Okay.  Well, we did some questions that came in during the last brick.  Paula you just answered one outright the fact you don't need an indirect cost rate if the DSE doesn't require it for SILCs.  And some folks are asking about lobbying as well.  I answered those in the written questions.  You can see those within Zoom.  Basically you do need to ensure that according to ACL's guidance that membership organizations aren't spending their money.  
    NCIL did release a statement last year, we don't use ‑‑ certainly we don't use federal funds for lobbying.  We also don't use membership dues for lobbying for that reason.  
    Got a couple of other questions rolling in.  Realizing this is presented for SILCs but some states do directly fund Part B centers and as such we would be considered separate subrecipient not contractors, right?  Our state tends to treatise like we're getting 110 funds and like a contractor 
PAULA:  And that's part of why we put that information in there about how a subrecipient works.  But yes the Part B centers are also subrecipient.  
TIM:  To the anonymous that asked what the DSE is I'm sorry I missed that one.  Designated state entity.  
PAULA:  That's who actually receives the part B money from the Feds and distributes it based on the SPIL.  Based on the state plan.  
TIM:  Dora asked if that statement is available to print.  Yes it is.  We sent that to all members last year if you don't have that let me know.  Tim@NCIL.org. 
PAULA:  I was a little surprised that that statement that it's up to the person paying the dues to determine whether any portion of that money is spent for lobbying.  So if you're a member of strong lobbying organization that that's mostly what they do, they will give you that breakout too. .  NCIL does many, many other things.  So that breakout was pretty clear that membership dues weren't used for that purpose.  
TIM:  Okay.  We've got just one minute left so if you've got any other questions you might be able to sneak one in.  Dora says thanks.  
    Let me use this time just to plug our evaluation form.  This link right here on slide 37, if you're looking on Zoom anyway that's not a clickable link.  But when I close this webinar, the evaluation will actually open up on your screen if you're connected through Zoom today so please do take a minute to fill that out.  If you're on the phone or if you need to run to another meeting, this link is here on the PowerPoint, but it was also included in the confirmation email.  
    And the link on the confirmation you can just click on to open that.  We would love to have your thoughts.  We really do take your evaluation feedback seriously, so please take a minute to share that with us.  I just clicked over to 4:30 and I don't see any other questions so great job.  This timed out really well.  John and Paula thank you so much for going through this with us.  This is always great clarification.  
    And it's nice to do it with the SILCs.  We've done a number of these with the CILs and it's been good to look at the unique issues for SILC financial management.  With that everybody, we're going to close.  Don't forget this session will be uploaded to ILRU's website under the on‑demand section for trainings within 48 hours, so check that out.  You're welcome to share that link with colleagues or review it yourself.  
    And thanks to all of you for spending your afternoon with us.  If you have any other questions that come up in the future just let us know.  And you can send them to Paula, you can send them to me at Tim@NCIL.org and we'll make sure you get an answer. Bye.