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OK, so hello everyone. My name is Jenny Sichel with the national Council on independent living and I helped coordinate logistics for these events. I am also the operations record NCIL, I want to welcome all to our webinar 'CIL's Use of Self and Peer Mentoring as a Management Tool'.

My pronouns are she, her. To give you a visual discretion I'm a white female with brown hair pulled back, I have on a navy blue shirt. Yes, that is my awesome description (Laughs).

Today's presentation is brought to you by the IL-NET Training and Technical Assistance Center for CILs and CILs. (indiscernible) operated by ILRU and collaborations with the (indiscernible) University of Montana with support provided by the ministries for community living at the US Department of health and human services.

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So it is about that time to begin today's presentations. I first off want to introduce our presenters, we have Annetta Johnson, who is the executive director of North West Virginia Center for Indepedent Living.

We have Kyle Kleist was the executive director at the Center for Independent living for Western Wisconsin and we have Paula Michael Wade who is the director of technical assistance at the IL-NET Training and Technical Assistance Center for independent living at ILRU.

I want to thank you and everybody on this call for taking time for today's event. Make sure you follow the evaluation at the end. So with that, we are going to get started.

Just kidding, apology want to go over this a little bit?

Sure, I can do that. Hi everybody, I am Paula. I am a silver haired, ruddy complected, Scottish heritage and other British Isles, person. And I am wearing a striped shirt but I guess you cannot see that very well.

What we are going to talk about today, I think is really important and it is about how you assess your own program performance because you know that other people are going to assess it in different ways and we will talk a little about that as we weave through this topic but he will probably have a state review if you receive part B money or state funds for your Independent Living program.

You will also, that sometimes has a separate review for the financial piece. You have your own internal audit, that you hire independent auditors to do, probably. You are not always for Carl -- word two, depending on your size but probably you do that.

And the question is are you looking for yourself at the regulations, what they require and what you do to meet them?

We believe that the importance of assessing your own performance is directly connected to the Independent Living philosophy and we want to emphasize that with you.

How you assess your level of regulatory compliance and quality performance yourselves using some kind of organizational self-assessment tool. We are going to talk about a couple of them. That is going to be one of the things you will learn.

And also how to utilize those tools now before you have a review, or the next review (Laughs) In order for you to have the information you need about what you need to do to improve your performance.

So all of those are going to be things that we will discuss as we go along.

Next slide please, Jenny.

We are going to talk about self-monitoring and we have just a few thoughts about the.

As I said, most of you have external monitoring, monitoring is not that new.

Federal monitoring has been less frequent but part C centers know they may get a federal review at any time so the folks at ACL probably are or almost always are inking about where they go for the next federal monitoring.

So it could be anyone. So you might ask the question "then why should we adware workload by monitoring ourselves?".

While our question is "is it really added work or doesn't focus the work you do so that you are always prepared for someone to come along and take a look at your services?".

Next slide, please, Jenny, thank you.

So because we are consumer controlled, we need to remember that the best way to apply regulations and policies for our community is for our community to do it itself.

But we have to understand them. We have to know what to the regulation say, what are the policies around what we are required to do? And then be proactive in understanding those regs. so we do not just look at a piece of paper that says these are the regulations you have to follow, or just look at a sample review instrument and say "oh, yes, I think we need all those".

But to actually drilling a little bit, understand what the requirements are, make sure that we are applying those regulations to allow us to present our consumer perspective about them, to anybody who reviews us.

So that we can say to them "this is how we do this and this is why".

One of the things that is unequally understood across the country is that there is a lot of autonomy for the centers on how they apply regulations. There is not just one way to do things.

And so when you look at a monitoring instrument, it is not as rigid as you might think. There are lots of ways for many of those regulations to be applied.

For example, how you all do peer support.

How do you provide peer services, how do you monitor them? Are your staff considered peers, is the work they do then considered peer support? Do you only do it in group settings? Do you do it one-on-one? Do you use volunteers?

All of these are real options for meeting that one core service but that one core service is not defined. So you get to pick how you apply the regulations to provide that one core service. What do you do? And it may be very different from your neighbor down the street or in the next state.

And that is true of a number of things within the regulations. There is flexibility. We are consumer controlled and our centers should be choosing to do the thing that you feel is most important for you to do for your center.

I hope that made sense. So what you are looking at is a way to be proactive, understand the regs but then also decide what we want to do to perform well in that specific area.

Next slide please.

So when we look at this whole issue of monitoring, we want to talk a couple of centers that are doing it.

So I am going to ask Annetta first and then Kyle second to tell us how your center conducts reviews to assess your compliance to regulations?

So Annetta, tell us how you do that.

(audio issues) management team will look at everything that we have available with policies and procedures and use the COMP Tool to guide us into what we need to be looking for then take it step-by-step so that we can go through.

We include the Board of Directors in doing the research and making sure that we are meeting everything that we need to have.

We have found some things that we need to continue to work on and bring up to be in total compliance. We are but there were always little things that you can change.

It provided a lot of structure in the orca Xi -- organizational framework that a lot of our individuals, the information they were not aware of before so we have used it to definitely help us get on the right track.

Let's talk more about what the COMP tool is. I will put a link to that. Tell us more net on where you found this and what it is.

My program director found it online and had been using it to review things for a few years before I came along. It is put out by -- federal regulations. To help you make sure you have all of the requirements- it points out you have to have your 501(c) certificate, your bylaws, your IRS form 990. And then organizational documents, fiscal documents you need to have and program documents. So that you have this list of items, if you are reviewed, that can help you – if you have the stuff available and you know exactly where it is. Then you are able to provide it a lot easier to the reviewers.

And make the whole process simpler.

The COMP process stands for Compliance and Outcome Monitoring Protocol. That's what COMP stands for. It was a process put together by ACL. Will they ever change their process? I don't know if you are ever planning to but if they do, our suggestion is you go with that flow.

As Annette's organization has been doing, we suggest that it might be useful for you to use this tool. It has the actual checklist that the people monitoring use. It has documents that it lists for you as Annetta was saying so that you know some of the documents you need for review. And it puts it together in a format that the reviewers should be looking at when they come to see you in person.

If your federal -- reviewers come out, this is their document. Your state reviewers may not have this document. We suggest they use it, several states asked me specifically, if we have to do monitoring. (indiscernible) or using the RSA document which is pre-2014. (Audio breaking up) very useful and I think it's more effective to be looking at this document because this is current. Are some of the questions the same? Sure because some of the regulations are the same for topic covers the regulations, goes through the process, and make sure that you take a look at that.

So you are looking at the same things that the reviewer will look at. My suggestion is when you look at the checklist, that you do not just check yes or no. But that you write, how you do it or what it is you do. Or the policy number that applies. Make that checklist a place where you keep notes about your own performance.

I think that is very useful. Carol, you ask about the controlled self assessment and off the top of my head, I don't know what that is. If you would write another note and tell me more, that would be useful.

I did just put the link to this assessment in the chat. It dot comp. So you will find it there. It's the last comment in the chat. That is one of the ways you can certainly look at your own self-assessment because we find it might be useful to use the same tool that the reviewer's useful stop like I said, not all your states use it.

Some of the centers are getting together, and taking a look at the whole state and asking the question, should we/could we do all of this at the state level?

And make sure that we are all doing it and ask our state, our DSC, to use the same instrument so we are on the same page. A couple questions showing up in the chat to the panelists, not to the whole group but let me throw them out. Really quickly. (Reads chat) the O in COMP stands for Compliance and Outcome Monitoring Protocol. The instrument Carol was referencing as an instrument her state is using for not one I am familiar with unless someone else's. So if it is the instrument the DRS uses, your department, of rehabilitation services is using, it's up to you whether you want to advocate for a switch to this instrument. I think it is useful.

I think it is really helpful for you to take a look at that. There are some thoughts on that. Kyle, we want to know about how you do compliance in Wisconsin because it's a very different model. So let us talk a little about what you do there.

Thank you Paula. Kyle Kleist, pronouns are (he/him). White male with glasses, graying hair and goatee. Paula, you brought up some really great points about using the compliance tool. I like to think prior, to assessment. Here in Wisconsin, we have what is called the quality indicators and independent living services as a review tool developed by the centers. As a way of making sure that all centers are not only complying but shall we say, having breast practice -- best practice when it comes to services across the spectrum. COILS tool -- quills tool provides great format for the documents you will need and go through. As part of the review.

I found it helpful as a process, as I am collecting the documents and going through everything and even the checklist, it makes me dig deeper into seeing how I'm actually doing. When it comes to those services. But it really provides a great format to get everything together as far as all the documents.

You brought up a great point about digging deeper as well because one of the things about the Quills review, it not only looks at the checklist but digs deeper into how are you providing the services, making sure they really meet the IL philosophy. Consumer controlled and things like that.

Also I found, it will make you aware of any shortcomings you might have prior to having the review. You will probably be aware as Executive Director, even going into the review, some things you may not be doing so well.

But really getting prepared for it is a way to discover, these are some of the things that you may find out as a process of the review. I will stop there for now.

Don't stop quite yet. (Laughs) You know, this was a very different process. What you just heard about was that the state centers had come up with their own process. It doesn't match everything else that is being done but they do something really interesting. That is, it is a peer review process not a self review process.

You may use the instrument for yourself review first but it is a peer-reviewed process. What is it like Kyle to submit yourself to your peers for that kind of a review?

Paula, one of the things I find really to be one of the best things about the quiz review is that it is done by your peers. So it is not, you are not looking at it this is your compliance officers coming in but these are your peers and people you work with, network with on a regular basis that are coming in.

I have been part of a review on several ends. I have been part of a review when I was on the board, I've been part of federal RSA review toward the end. When I first was assistant director. I have been a facilitator of doing a review for another center. And also, then recently having reviewed on – personally from the process, knowing it was my peers that were coming in, that were doing it, I felt it was almost a safer environment for me.

And the feedback I would receive. And it would be, from a compliance officer so to speak.

I like to hear that because it seems to me, that has multiple advantages. Within a state, if you're willing to work together to do your internal self-review process, and use peers to help with that monitoring process, I think you will become a state that is more open with one another. About what are the areas of weakness where some areas that you can work together to build out your program and make it more effective and interesting. I think it just has a lot of advantages to have a peer process of that sort.

I like – I like the idea of having your peers be side-by-side with you post not everyone is comfortable with that. There are all kinds of reasons why, you learned how competitive your state is, how much trust there is between centers, but I think, a goal for doing this kind of thing, has advantages to building those relationships between one another for Annetta, if I can ask you, how is this review different from your audit, independent audit?

The only independent audit we get is with our financial auditors. That come in once a year. They make sure that we are in compliance with financial type stuff. But, as far as whether we have this other stuff, there is no one monitoring that at this point.

We don't get a state audit per se. That looks at this type of stuff on a regular basis.

But that is kind of what I mean. Your financial audit is a group of auditors who ask you for a bunch of papers, right? (Laughs) Whether they do that in your office or in their office and how much of that is electronic. All that continues to shift to more and more of an electronic process I think COVID drove it faster maybe.


But that is kind of a very narrow look isn't it? Or what you do? Where your COMP system hits almost every area. It hits management, it is finance, personnel...

It's a lot more detailed to me. Prior to this I have always been on the financial side of it. I worked with the auditors on the financial part every year. That was my main job, was the financial cycle stops so this is a lot more – I'm learning a lot, this is, as you know, shorter-term for me so far. All of the things I'm seeing, we are required to have whether we have them or not, it's a lot of information. And it is very much more far-reaching than just the financial audit.

It really is helping you do a deeper dive as we mentioned coming in. A deeper dive than you usually get to see of your own program.


Who has time to go around and double check some of the stuff we ought to double check unless we make time for Ben this is the process that helps us make time for

Yes, it definitely does help. I'm learning a lot from it. Like I said, there's a lot more information involved than I would've ever dreamed. But it gives a lot of guidelines, and different suggestions, and are just very helpful.

Yes. Kyle, if you wouldn't mind it would be great if you answer the question, you are answering in the chat. From Darrell Christiansen. If you would answer that here.

Sure, he was asking about the quails review, does go into making sure that you are providing the core services I'd required (indiscernible) goes over – it covers what your federal requirements are. It's best practices and independent labeling. One of the great things in Wisconsin is a lot of that, not just I/O services -- IL services, that we offer, making sure we do some of the best practice way, but the fee-for-service work we do as well. Kind of as a network of centers.

That is also another thing that really is an advantage of having a peer review as part of your internal review, or your review process to is to share best practices because sometimes somebody else has got that best practice nailed and really share that well, which is advantageous.

If and when you all look at the COMP system, go ahead Kyle-

Paula, I was just going to add to the other part that I added to, is other services that you offer, making sure that they stay within that IL philosophy of consumer control. We operate a couple other programs that we want to make sure that those programs really stay within the IL philosophy to.

I think that is important. In the review looks at those as well.

Yes it doesn't really look set does the philosophy present, is the IL philosophy present throughout your program?

If you look at the form, you will find their instructions and then you will find there is a checklist. And I mentioned before, do not just check off yes or no on the checklist but make comments.

There is a comment section on that form and so what that comment section does is give you an opportunity to actually say how you do it.

So it asks "did you provide independent skill training during the last year?", The period of time that they are reviewing. And you can just say "yes" or you could think to yourself "what is the best way I have to show them how great our independent living skills training is?". Best practices, right?

So you've got that concept and you want to make sure that whatever you do, you are doing the best within the philosophy. And so the questions themselves, and Darrell, this caused your question on how do you measure the IL philosophy for review, you have to continually, I mean they have measurements in here about consumer control, but you have to continually think "let me think about it how do I do this and do it well?".

In the questions and answers throughout the checklist, if you actually take the time to answer them thoroughly, will lead you in the right direction.

I want to mention something that can happen during such a review.

It is never good news exactly but it is preferable to the alternative.

As one of the things that can happen during either a review on your part, is that you may find that there is something going on that should not be.

How serious that is can vary a lot from one place to the next. So when one case it might be a serious embezzlement. In the next case it might just be that someone does not understand your record-keeping system and is not keeping good records of services. And everything in between.

But when you do your own thorough review, you will find things that need to be improved and you want to do them now regardless of whether you are going to have a federal review in the next few years are not. Because you want to do the best services you can do, right?

So as you do a review you may yourselves find something that needs correction. And do not be afraid of that. And in fact embrace it because isn't it better that you find it than if it is the state, you know, the state DR or the DSC or federal reviewers?

You need to know yourselves whether things are being handled according to your policies and procedures. And one of the things they will do is say "do you have a policy?", And then they will ask you if you follow it.

You cannot just check the yes box and say you have a policy, you have to also think in terms of how -- are you following all of the elements of the policy.

Sometimes you may be wondering if the policy is thorough or not?

So I was talking to somebody earlier about conflict of interest and we were discussing the conflict of interest policy and we were thinking out loud about a situation, personal situation where there was a conflict. And whether or not the policy adequately covered that situation.

You should be doing that kind of review every time you use a policy.

Is this policy the very best it can be to address the situation? Whatever the situation is.

And that is what you are seeking as you go through this checklist. That is what you are really wanting to look for as you go through.

There are lots of sections in the checklist. I do not know how many pages it is total but only eight pages total, but if you write your notes in the comments and then turn over the paper and write them on the back, (Laughs), Or use an electronic version and keep letting the comments expand, I think you may find that you really will know more about your organization than you did before you started.

Because they may be asking questions you just have not thought of before.

The questions are all directly related to compliance so they are important but they are also useful. They help you with your organizational structure.

Let us look at that next slide, Jenny.

So, here is the question that I have kind of been circling around. "How does this process help your center to perform better?". Annetta, would you like to lead off on that?

Um, the process is helping us get a better understanding of what we need to be doing, where we need to be at and doing research for how others are doing the processes is also helping us to modify hours to where we need to be.

We have had to show a little progressiveness (Laughs) As far as coming up to the current time for the things that we do at the center.

I hate to interrupt you but your sound is not very good. Could you come closer to the microphone, we are having trouble hearing you.

OK, I think in the process that we are coming up a little better with the times. But going into the details of the things we are supposed to have, how we do them, and then additionally how other people are doing them, are helping us to improve the process of how we are dealing with our consumers.

And I do not know if either of you have done this but one of the things that I have seen that I really like is after you have finished your review, whether you do an annual review or every two or three years, that you feed the review information back individually to some of the staff that it impacts, both complements and things that need corrected so that you can continue that process.

Kyle, how does the process help your center perform better?

Paula, same thing as what Annetta was getting at. One, like she was saying, modified or making sure we are creating processes, making sure you have those in place. Really finding out what you can be doing better. Where are your shortcomings?

So I mean one of the things that came out of our review was we need to be doing a better job when it came to peer support. I mean, I knew we were not doing a very good job but the review process really kind of made that stand out.

In one of the things, I know you and I were talking about prior to this, was, use it for strategic planning. So we had done the review prior to our three-year strategic plan.

So what came out of the review was so helpful, so we could include those things in our three-year strategic plan to make sure that as a center we were going to address them.

I mean really developing goals and strategies around them.

So things like peer support. Things that came out like outreach to underserved populations. So that went into our strategic plan.

Training, more additional training for staff around like diversity, equity, inclusion. That wound up in our strategic plan.

So that was one of the things I really found most helpful, was coming out of the review and going into our strategic planning, it really helped to guide us as a center and as her board found it very helpful as well.

So, whether you're going to be going through any kind of compliance review or not, if you're coming up in years three year strategic plan, you know just going over the COMP Tool is a way to look at whether there are things you need to be addressing over the next three years.

I really like the idea of the COMP Tool leading directly into planning. I think that anytime you assess yourself, you should find ways individually or as an organization as a whole, that you can continue to progress to meet the needs that you have uncovered through your review process.

An attack, there is a question for you in the chat. I think you must've use the word progressiveness and said you have fed -- have had very little progressiveness and they are wondering what you meant by that?

Well in West Virginia, until the last year or two, there has been executive directors that were the same executive directors since the 90s or 80s, whenever the individual center started, that continued to do this -- things the same way as they did and they started.

Times are a little different now (Laughs), The availability of different types of communication and electronics that are out there, it is definitely changing the way that we can do things and so in the time, the six or seven months since I have been the ED, we have been able to bring us a little more up-to-date, and progress in ways that we can perform our services with our consumers and get our messages out there.

Does that answer the question?

I think it does, thank you very much.

You know as we look at this whole big picture of what centers, what the landscape looks like for centers, I do not know if we should call it post COVID, I have not decided but post most of the COVID response, we did learn some things through that process.

And I think one of the things that we learned is both the strengths and weaknesses of electronic information. And I just want to suggest that as you look at a performance review process that you do two things.

That you look first at the policy or the written documentation, and then you say to your staff "OK, now show me how you do this". Because you are never going to really have a complete picture, right? Of the things that are or are not happening if you do not have that direct response from your staff.

Let us look at that next slide, Jenny.

Here is a fun one. So you're going to have a review process. So you are asking questions and looking around and maybe you have some peer-reviewed was as a part of your process. OK, do you find that that review process then becomes a place for your staff to vet personal gripes and how do you handle that? I'm going to direct this one to Kyle first.

Ah! Thank you Paula, yes. So, as I previously said, I have been part of a review team, so cofacilitator. And then as recently -- and that has recently gone through a review.

So let me just say, not going into any details or anything but this you might see as an opportunity that staff may have grievances or issues that have nothing to do with how you are performing as a center. But they may use this as a venue to air some of those grievances.

How I handle that, I just look at it as what it is. I will deal with that after the review process or have this -- their supervisor deal with it, whatever the case may be but just getting back and refined -- reminding the reviewers as well that this is all about, we are operating as a center and you know, but you know on the same note the reviewers may come across a serious issue that you might not be aware of so if something like that came out, I mean, one of the great things is you know, that with the QUILS review that your peers, that you are working with in dealing with, so if a serious issue did come out, rather than anybody on your compliance officers shall we say.

But I have seen from both sides both opportunities that your staff might use this just as a way of airing some of their grievances.

Sometimes they feel... Have a person here who has to listen to me because they are in the process of doing this review. Annetta have you had an experience of that sort it all?

(Audio breaking up) no matter what you're doing they want to get their personal gripes in there. I usually try to divert the conversation by, this isn't the time and place, so we should set up a time to talk.

But, as far as the review, I have not had that come up yet.

One of the things I suggest when it's in the middle of a review, is to look at the policy on what you are supposed to do about this. So we look at the policy and procedure, and it says, whatever it says. That it must be in writing to the supervisor or goes rectally to the executive director there's a grievance committee or board. There are a lot of different setups within your centers so you want to follow your own policy. Looking to see what that policy says first. So that you know exactly what is going on.

Following that policy, help -- helping the staff to follow that policy is important. In this process, sometimes you realize a staff person doesn't know where to find the policies. They were not told, they did not get a copy of the personnel handbook, they came on board during a transition and did not get the update. Whatever the weird situation is, sometimes a person does not know.

Or says they do not know, in which case you still want to go back to the policies and say, "here's the policy, let us follow the policy to resolve this gripe. Let's follow it through."

So you can see how that process works at the same time. Maybe not completely, because the policy sometimes gives you 30 to 60 days or whatever, to resolve it. And of course your COMP reviews will be 2 to 3 days, so maybe not entirely.

Next slide.

I think we may have covered this Kyle, because I jump ahead sometimes. Anything else to say on your peer review process and how you accept peers feedback?

You know Paula, goes to one of the great things about the peer review is, it is confidential. So when you get that file report back, from the review team, which member, those are your peers, it generally consists of three people that would be within administration.

Within an IL center, but also includes experienced IL staff as well. That is yours to do with as you will. Since the review was paid for, through the State Independent living Council, one of the requirements is that you just highlight a couple of the areas that you plan to work on, but generally the tools – what came out of it, is yours to do with.

You could say that you don't agree with any of it and throat away, or you can take it to heart and say that you really need to look at some of the stuff and dig into it. And find out, how you could do better.

But like I said, one of the things I found is that when I know it is coming from my peers, I find it easier to accept. Because these are people I know, for the most part, have been at IL and are providing direct services as well.

I tend to take the more optimistic side. When it comes to accepting the review and the feedback from it.

I like that! Honestly, I think it is so healthy when a state can do that. When they can do a peer review because they have a good enough relationship between the network members in that state. That they can actually review and follow-up and follow-through and support each other. In improving services statewide. Let us look at the next slide.

Whoops! (Laughs) This slide is to remind you about that evaluation but we will go to questions and answers now. In a slide or two. So the COMP review developed by the feds addresses the core services. And there are more than just core services available. It does address some of those programs as far as the philosophies that are captured in the questions.

Let us talk more about exactly how it boils down and helps you with those services that were not poor. Kyle let's start with you because you mention this earlier.

Thank you Paula. One thing that I point to is, we have a personal assistant services or a PAS program. I know a number of independent women's centers across the country are getting into the personal-care business because we are wanting to be there to provide those home and community-based services. So give people a lot of institutions. But as those programs go larger are they staying with the IL philosophy yet are they consumer directed or are they becoming more of a service provision than part of your IL center. Is your agency and IL center at the heart? Regardless of whatever programs you operate. We operate a volunteer driver program that covers half the state of Wisconsin.

When we do that, are we staying true to independent living when it comes to the services we are providing? When it comes to the riders? And what their goals, their wishes are?

Even with the drivers, when we do our training, for our drivers, is it talking about independent living? So, really, that's what we want to stay true to. As other programs grow, other IL centers get into that fee-for-service game, we want to make sure it is driven by that IL philosophy of consumer control.

That is my personal belief as well. But I believe it should speak true for all of the other programs that we operate, from IL centers outside of those five core services.

Annetta, did you have anything to add to that?

(Audio breaking up) I know that we are starting a veterans program. Mainly, because it was brought to us by ACL. But it does definitely fill the IL philosophy. How the COMP tool is going to help or hurt with that I'm not sure yet because we haven't gotten into it that far. I know because of the COMP review, I am looking at things a little closely with this new program.

To make sure it keeps in line with where it needs to be.

That's a really good point, as you look at any new programs that you are putting into place, they are -- there gonna be things about goalsetting and record-keeping and other things that apply to whatever services you provide. In fact, did you all know that centers are required to prevent the core services +2? Have you ever heard of that? Core services +2? I had almost forgotten about it because it's been so long since I've heard about it and then I read through the COMP tool and in section 9, in case you want to check me out and see if I know what I'm talking about, in section 9 it says during the reporting year, did the CIL provide accommodation of any two or more of the other IL services defined in section 718 B? And there's a list of other services that can be Independent Living at one time it was clear to us that we must provide two more besides the core services.

While that has not been talked about a lot lately, that is still in the COMP tool. So it is evidently that ACL will be looking for. It was worth it to come, just to hear that, right? (Laughs) Let us go ahead and look at the next slide.

Questions! I hope that you do have some questions about how to do this, anything that we have not made clear as we have gone along here.

Here's one from Tiffany (Reads chat) don't feel like some of the funds coming through to centers via ACL and federal entities are not challenging us? On the philosophy?

Kyle, Annetta, why don't you answer these questions as they come up? Alright, do you feel that the funds are not – or the funders are not challenging us on the philosophy?

I think I would agree with that Paula. There may be times that the funders are not challenging us. That is where we have to challenge ourselves. Or, even make sure that our board is challenging us.

You know? Or your staff could for that matter. Staff that are involved, make sure that it is being driven by the independent living philosophy because there is so much that goes on that somebody – so many centers are involved in providing those home and community-based services. We want to make sure they are really driven by that philosophy.

This compliance tool has some philosophy elements that I'm not sure centers think about very much. So if you look at section 5, of the COMP tool, it is talking about, from the purposes of the rehab act, it's talking about the equal access section. From the purposes.

It's a specifically active the (indiscernible) access for individuals with significant disabilities within their communities and to all service programs and so forth ... and there is, three or four questions with equal access specifically. It asks about, are you reaching out to our range of significant disabilities? It's asking that cross disability question.

Philosophy has to do with a lot more sometimes than just consumer control. Which is essential. Absolutely. They are not saying it isn't. But wow! What a big deal it is to think about equal access. Where on earth do we have equal access really? Right? And to ask what are we doing to address equal access and to take four questions, ask for questions, and this compliance tool of only eight pages is a pretty big challenge to our philosophy.

Tiffany, I think you are right, sometimes it doesn't come through. Sometimes the focus seems to be just on the consumer information file. Or the core services and not really on the philosophy pieces. As centers, we need to make sure we focus on those philosophy pieces. They are important things we must also do.

I know there are some centers out there that are getting paid based on time, provided for each core service. In one of the challenges that I gave back, although you know, this particular state said that they give lots of money so they don't need to worry about it. But my challenge back is, as soon as you try to pay for so many hours of core services, you are missing this whole point.

It's a very important thing to look at equal access. And we can't miss that. So, we need to keep a look at that.

Paula, I want to say that one of the great things about the QUILS review, that I found helpful, they interviewed both my transportation director, my finance director, my PAS program director and those staff as well. It was the entire agency at all of the staff and all of the programs that we operate that were part of that whole review process.

Yes, so Angela is asking about financial policies, they are extensive, helpful in making it through but how do we get the board to review them? I think the responses you interview the board about them. And that is part of this COMP process.

As you can ask the board what do they know but the financial policies and procedures? They are in charge of that. They have the responsibility at the end of the day for the finances of the organization so I think taking the bylaws back to them and asking them questions as part of the interview process, doing the same with both the financial policies and their policies and procedures, sometimes they have policies and procedures, and then the bylaws themselves, I think would be a really effective way to do that.

What you guys think?

I agree 100%.

OK. Other questions y'all? You have lots of time.

Paula, you know one last thought that came up that you and I had discussed that nobody I am surprised is brought up today is virtual versus in person. We are still in the time of COVID and conducting a review.

Being there in person you have so much access to staff, if you needed to follow up on policies and getting questions answered, it was really easy to do.

When it was consent -- conducted at my center the year before, during COVID, it was done virtually and even those people that conducted the review pointed that there were a number of shortcomings, since it was conducted virtually.

And I will agree with that hands down. We were not able to really get the full feel of the center, so to speak, really talk with the staff, be there in person, get real good and quick follow-up if you had questions and things like that.

So, I would highly encourage people, if you can avoid doing it virtually, do so. In person is so much better and you will really get much better information doing things that way.

And when you're doing a self-review, when you're doing each of these questions the most effective way to do it is to go to the person responsible and to say to them "show me how you do this". And they can show you where they take notes or show you, their phone log or whatever it is that demonstrates what it is they do.

And you cannot really do that effectively, you can say "tell me about" but it is not the same as seeing or hearing directly from them as they are actually showing you a process. Any other questions or comments?

Darrell asks "to this point: what are ACLs plans moving forward in conducting reviews? Have they said how many? Virtual or in-person? What do you know?"

What they have said is the PPR process, the program performance report that you submit in December each year, that that process itself is part one of the review and that they will look at that and they will give you feedback, and they will ask questions and they will make sure that you have, you know, met the compliance required for your center based on your PPR. So that is part one.

And they intend to do that for all centers and they only have, I think they said they only have one center that did not provide the PPR. So that is an interesting one to look at.

As you consider that, as the first process, then the question is "what would other processes be?" And they do do some phone follow-up. If they get a complaint, I understand that they do sometimes follow up with that center.

I do understand that they are also preparing to do their first in person views sometime in the coming, the rest of this calendar year or next year. I do not know exactly when. They were contacting us about a piece of the process but they did not tell us how many are aware or anything like that but I can tell that there was activity around it.

So I think they are moving towards doing those in person reviews at some point in the future and I think we will look forward to seeing that.

Good question though and we would all love to know when and where and how many reviews.

Paula, I think so but he had their hand up.

I saw that and I do not know what to do with that but Jenny is working on it. Because I hand up does not show in this format of webinar so-

I can just chime in, if you have your hand raised, for accessibility, that is great. If you are able to type your answer to -- into the Q&A section, that would be better so we can reserve hand raising for individuals who are phoning in. So if you can just let us know either way in the Q&A section, I can either unmute you or we can answer your question after you type it in.

And do you know (indiscernible) question?

I do not known (Unknown Name)'s question.

(Unknown Name), we do not have any way to my mic you.

Go ahead, Kobe. You just have to take your cell phone off of mute.

Thank you, great. This is Kobe Livinstone and I am they Vice Chair in Albuquerque for the state was Independent living Council. I am legally blind and I cannot type and listen, I really wanted to just talk and I could not do that in the webinar thing so this is great.

So when you talk about a state, when you talk about a strategic plan are you talking about the state plan that comes every three years?

No, we are talking about the centers plan so each center, this is not the SPIL but the SILC does, but each center must also have some kind of a work plan. It is actually for the center specifically.

So when each of the panelists talked about the state review, is that the SILC reviews?

No, the SILC does not review the CILs, it is the designated state entity/that is the state of New Mexico's department.

Right. OK.

Paula, I just wanted to answer Jacoby's point, one of the things is that we do provide feedback on the QUILS to our state of independent living Council since the funding for that review does flow through them. As well as the DSC as well.

Thank you, and how many states on average have the state as the DSC?

Every state has a DSC,

(Multiple speakers)

But I only know of three states where it is not the Department of rehabilitation.


That is because her history and where we came from so to break free from that is not always something that makes sense.

It is not an easy thing and it is something, we are talking about in New Mexico.

Kobe, we need to get you on the SILC calls.

I would love that.

I think I sent you that information but if I will work on it and if I do not get it to you I will call you.

I'm glad to have this. In our state (indiscernible) (Unknown Name) living counsel will be going through a, what is going on in New Mexico? Why can't we keep an executive coordinator director?

Why don't you and I talk about that further. Because I want to be on that call. I need to answer couple of other questions

(Multiple speakers)

My point is it is so important not to do the (indiscernible) game, use my time to air my griefs. I just thought that was a great point and really needs to be emphasized and handled with care. Thank you Paula and the rest of you.

We will talk to you a little bit later, yes. Lois, you ask what the options are for the Plus2 services? It is a long list and it includes things that do not make any sense to me like psychological therapy, as in other at the end. So it includes just about everything you can imagine.

You can look at that reference that we had on the slide or I can send you a reference with the list.

Would you take a second, Kyle and explain how your QUILS process came about?

Oh boy, I am not as well versed on the history but it came about as a result of really wanting to look at best practice within Independent Living.

I believe it was the first review was done back in the 90s.

OK, I am old enough

(Laughter)I can give some of this.

So the centers just decided to be proactive about it. They looked around and saw that nobody was really reviewing about the things we think are important, let us put it together and review each other.

And it was done mostly by the state association of centers. That is who took the lead. It was Maureen Ryan who was the director there at the time, and took the lead on that.

And it really was, it filled a very important gap I think in review processes and was very useful in that way.

The question about whether you would do it quite the same way though now, I think there is already discussion right about the QUILS process being so different from the COMP process and that you would not necessarily set one aside from the other because they are complementary. Is that accurate?

Yes, that is accurate. Absolutely, we would still, I mean even if we use the COMP, we still feel that the QUILS review is a really helpful tool as well.

And as far as part B versus part C, the COMP system really does address the same, part B centers and part C centers are really not that different what they are required to provide, and they still have to meet the federal regulations. So the actual process of reviewing them with the COMP system is going to be the same and it is going to be virtually no differences between the two when you look at the review process.

So the things that are reviewed by both part B and part C, part C is usually who is reviewed directly by ACL, part B centers are reviewed by the DSC. These are the requirements they should meet, but your DSC may have another instrument that they are using, so be aware of that and find out what they are using. Talk them into using this (Laughs). Alright, other questions that we can answer?

I want to direct you to one in the chat section from Curtis.

I hear these reviews are awesome but other than making sure we are compliant and staff are documenting correctly I don't see the connection of how this lets you know how you can better improve services to consumers. (Reads chat)

There are elements we haven't talked in detail about, that have to do specifically with the consumer satisfaction with your process. You are looking at consumer satisfaction, you are looking at the quality of goal setting. Whether or not goals are being met by consumers, you are looking at several of those kinds of things.

We haven't emphasized that but we should have more. There are some very direct connections. But the other part of it is, as a center, isn't it cool to look at your whole set up at once? Really examine every piece over a week at the most. A few days. Look at it, make notes, and at the end, celebrated.

Bring everyone who wants to come in, and. If you are doing in person stuff, if you are not doing that, have an online party and celebrate here are the things we felt we were doing well. Here are the things we discovered that we want to improve. Let us all get on board, congratulations to everyone for such a good job. Thank you for participating in this... it's a way to encourage people for the things they are doing well and a way to solicit input from the consumers, your consumer surveys can fit right into the process.

And you can continually look at how to improve. Hopefully that is something that works for everybody. Further questions or comments? Last thoughts from Annetta? Did you have a comment?

I was going to say, using the COMP tool, there's a compliance review document upload section. It just gives you a checklist. One of the things that I never thought of, that is on the accessibility checklist part, is making sure there is Brailler raised markers on the microwave. We have a staff kitchen, we don't have one necessarily for consumers but that was something I hadn't thought of. There are little things in here that are helpful even if you don't go full bore on to make everything they are suggesting the way you do things. There was definitely a lot in here, that brought things to my attention. Or were helpful to me that I would definitely suggest people look into it.

I did a review with the center with a person I respect very much. As the executive director. I walked in and there were candles burning. -- Of course we want to keep our environments free of anything that will trigger negative reactions, allergies and so forth with people who have sensitivity around that.

So, I stopped to talk to each person at their desk about that. It is not a great idea, I went back to talk to the executive director about it and he was sitting there with the associate director and they looked at each other, (Laughs), And they said, "we have had a sewer smell in the back of the building and we thought it would make a worse impression. On the reviewers, then the candles. So we have all these candles burning." And I said, "you have to do what you think is right. And you have a policy, don't you? About scented items in your workplace? Let's take a look at that."

We have time for a couple more questions if you all have some.

Paula, I want to include one out last thought as well. One of the great things we do here in Wisconsin with the QUILS review, is we highlight the things you are doing great as well.

It's not just compliance, are you documenting? When you are really doing great stuff, the review highlights that and says, "you know you guys really rock when it comes to doing ..." it's not just looking at what your shortcomings are. It's looking at your strengths as well.

Good point. You really want to celebrate those. What about frequency of reviews? Are you doing them manually or doing less frequently than that?

I plan to do them annually, this is my first year. (Laughs) We are working on it. But I think it will probably be directly once a year but it is an ongoing process throughout the year when you get new programs. When anything you have that comes up that's an issue in your center, that's something you can go back to.

Go back and review.

See with the recommendations are. For me, being new, that's where I met with it.

It does not hurt to review it annually. I would say dig deep into it. At least every three years when you go to do your center strategic planning.

I think digging deep is important. So if that means every other year or every three years for you as you do your planning, I think that is certainly acceptable. You just need to make sure that it is meaningful review. Because if you don't do a meaningful review, your process is cursory. If you dig deep into each of these things and really ask yourself, "how do I prove this and show this? Is this something we can demonstrate that we are doing?" I think it really does make a big difference.

Jenny, I think we may be done.

OK. Great. We will go to the last slide. And make sure that people do fill out our survey. I will put it one more time into the chat. And then, I will come on video here.

If everyone could fill out the evaluation, thank you again for joining in. Have a great afternoon! Thanks all!

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