UNITED STATES DEPARTMENT OF EDUCATION OFFICE OF SPECIAL EDUCATION AND REHABILITATIVE SERVICES REHABILITATION SERVICES ADMINISTRATION Washington, D.C. 20202-2741 Center for Independent Living (CIL) Compliance Review Guide Sections 706 and 722, Chapter 1 of Title VII - CILs Program Rehabilitation Act of 1973, as amended Issued August 20, 1996 TABLE OF CONTENTS I - THE ON-SITE REVIEW PROCESS Purpose ........................................................i Applicable regulations..........................................i Preparation for and conduct of review..........................ii Report preparation............................................vii II - DETERMINING VALIDITY OF INFORMATION IN THE 704 REPORT....ix Required contents...............................................x Recommended contents............................................x III - IDENTIFY AND RECORD SOURCE OF DOCUMENTATION .........xi ON-SITE REVIEW INSTRUMENT Grantee/CIL identification form.................................1 Checklist of materials .........................................2 Part I - Standards and Assurances...............................3 Grantee is an Eligible Agency..............................3 Subpart II-A - Compliance Indicators Indicator 1 - Philosophy..............................3 Indicator 2 - Cross-Disability........................8 Indicator 3 - IL Goals................................8 Indicator 4 - Community Options and Capacity.........10 Indicator 5 - IL Services............................11 Indicator 6 - Resource Development...................11 Subpart II-B - Narrative of Reporting Year Activities.....11 Subpart II-C - Program and Financial Planning Objectives..12 Subpart II-F - No. and Types of Individuals Served........13 Subpart II-G - Types of Services Provided.................14 Part II - Organization and Administration......................15 Part III - Grant Management....................................20 Subpart II-D - Sources and Amounts of Funding I - THE ON-SITE REVIEW PROCESS (a) PURPOSE The purpose of this On-site Review Guide (ORG) is to establish uniform procedures and a format for the conduct of on-site compliance reviews of CILs required by 706 and 722 of the Rehabilitation Act of 1973, as amended (Act). The objectives of the on-site review are: (1) Assess compliance with the requirements of 725(b) and (c)(3) of the Act and Department regulations; (2) Study the program operation, organizational structure, and administration of the CIL, under 725(c)(1), (2), (5), and (6); (3) Review documentation sufficient to verify the accuracy of the information submitted in the most recent 704 Report; (4) Verify that the CIL is managed in accordance with Federal requirements under 725(c)(7) and the Education Department General Administrative Regulations (EDGAR); (5) Assess CIL conformance with its workplan, developed in accordance with 725(c)(4) of the Act and 34 CFR 366.50(d)(2); conditions of the approved application; and consistency with the State plan for independent living (SPIL); (6) Identify areas of suggested or necessary improvements in the CIL; and (7) Provide an opportunity to share information with experienced non-federal individuals involved in the operation of CILs and make available technical assistance to enhance the CIL operation or to minimize or eliminate problem areas. (b) APPLICABLE REGULATIONS (1) The EDGAR in 34 CFR Part 74 (Administration of Grants), Part 75 (Direct Grant Program), Part 77 (Definitions that Apply to Department Regulations, Part 79 (Intergovernmental Review of Department Programs), Part 80 (Uniform Administrative Requirements for Grants to State and Local Governments), Part 82 (New Restrictions on Lobbying), Part 85 (Governmentwide Debarment and Suspension [Nonprocurement] and Governmentwide Requirements for Drug-Free Workplace [Grants]), and Part 86 (Drug-Free Schools and Campuses, as appropriate). (2) The regulations of 34 CFR Parts 364, 365, 366, and possibly 367. (3) States may have State regulations, licensing, or certification requirements that apply to CIL operations in the State. (c) PREPARATION FOR AND CONDUCT OF THE SITE VISIT It is RSA's intent that, in the on-site review process and in the application of the CRG, there be appropriate latitude and flexibility to accommodate the variety of organizational settings and program variations that exist in the CILs funded under, and complying with, Title VII of the Act. The ORG and procedures were developed to allow this balance to be achieved while assuring uniformity in review practices and consistency of interpretation of policy. (1) Composition of Review Team. (706(c)(2) of the Act) The review team will usually consist of the following persons: (i) RSA staff from the Regional office (RO) representing both program and financial grant specializations; (ii) A non-federal reviewer from a different state or region having experience and expertise in the operation of CILs, who is selected by RSA RO staff and approved by the Central Office; (iii) Representatives from the SILC and DSU(s), if they choose to participate. (iv) RSA program staff when possible from Central Office. The RSA RO Independent Living Program Specialist is the team leader. The team leader has the responsibility of assuring all required components of the review process are completed and all reports are provided on a timely basis. (2) Involvement of the Statewide Independent Living Council (SILC). (705(c)(2) of the Act) (i) The RO will inform the SILC of the CIL review schedule and provide copies of all Federally generated materials to be used in the review. (ii) The SILC shall be invited to participate in any on-site review, at SILC expense. (iii) A copy of the draft on-site report is provided to the SILC for its review and comment, whether or not it participates in the review; and (iv) A copy of the final on-site report is provided to the SILC. (3) DSU Participation in On-site Reviews. (i) Where a CIL also receives State, part B, Chapter II or other Federal funding through the State, the on-site visit should be coordinated with the DSU to avoid duplication of effort and possible multiple site visits in the same year. (ii) The DSU shall be invited to participate in any on-site review, at DSU expense. (iii) In a CIL receiving State funds, part B, Chapter II or other Federal funds, the team may either include a member of the DSU, or include in the team's report a review of the use of State and other funds. (iv) If a CIL receives State, part B funding or other Federal funding through the State, a copy of the draft on-site report is provided to the DSU for its review and comment, and a copy of the final on-site report is provided to the DSU whether or not it participates in the review. (5) Preparation for the Review. (i) Sufficient notification to all participants in the review should be given by the RSA Regional independent living specialist to establish dates and schedules, to develop and request materials in preparation for the review, and to initiate contract development for payment of costs for the non-federal reviewer. (ii) Members of the review team must familiarize themselves with the funded grant application submitted by the grantee and the grantee's most recent 704 Annual Performance Report (704 Report)[1]. (iii) The participants should have available the following for pre-visit review and for use during the on-site survey: (A) The approved State SPIL for the reporting year under review. (B) The 704 Report, Part II from the CIL for the reporting year under review; and a (B) Copy of the CRG and all instructions. (iv) Applicable Department regulations shall be available for reference. (A) Latest revision of EDGAR - 34 CFR Part 74 etc.; and 34 CFR Parts 364, 365, 366, and 367 (a copy of each shall be available). (B) Any other relevant reports related to the project should be made available to team members. (6) Agenda and Activities Plan. An agenda is normally prepared and provided to all participants in advance of the arrival of review team. The director of the CIL should receive, as part of the agenda transmittal, all materials and information needed to prepare for the review. Materials should be provided as far in advance as possible but no less than fifteen working days before the review date. The agenda should include the schedule of planned activities, the approximate time for each, and the review team members involved. Materials transmitted must include a copy of the CRG. (7) Team Orientation and Utilization. (i) Team orientation. After the materials have been disseminated to the review team, but preferably prior to the arrival of the team on site, a review and discussion must be held regarding roles and functions, agreement on the assignment of tasks to team members, and to address any other issues or concerns. The discussion should include a review of the on-site review instrument and the manner in which it is to be completed, e.g., the Y, N, NA responses are to be circled (or, if completing the form by computer, delete inappropriate responses, BOLD, or underline), requested information inserted, and the numerical designation of each question used to both maintain the identity of notes in relation to the questions and for use as reference points to specific findings and recommendations. This pre-visit orientation is especially critical if team members have not had on-site review experience. The pre-meeting may be either by teleconference or on-site prior to the review; however, if the pre-meeting is conducted by teleconference, the team leader must arrange an opportunity for the team members to meet and become acquainted prior to the beginning of the on-site review. (ii) Team utilization. It is intended that the team leader will properly utilize the skills and abilities of all members of the team. The team leader must assure a fair and impartial review, while maintaining consumer confidentiality. The team leader will assign roles and responsibilities of the team members after discussion with the team. Interests and expertise should be considered in determining roles and functions in the review activity. (8) Review Activities On-Site. The nature and purpose of activities would usually include the following: (i) Entry conference. The purposes of the entry conference are: (A) Afford an opportunity for the review team and CIL folks to meet informally, e.g., "break the ice." (B) Introduce team members to the director, board members, and key staff of the CIL; (C) Describe the review process and answer any questions; and (D) Verify or modify the proposed agenda and schedule meetings with staff, board, and consumers to be interviewed. (ii) Orientation of the Review. This will generally consist of: (A) General information on the organizational structure of the CIL; (B) An overview of the CIL service delivery system; (C) A list of staff and their assignments; (D) A "walk through" of the CIL conducted by the director or a key staffperson to introduce the team to CIL staff, especially those to be interviewed during the review; to allow the team to assess accessibility; and to observe arrangements for the provision of services; (E) An orientation to the location of records and how team members may access them; and (F) Any other orientation activities suggested by the team or the CIL. (iii) Application of Compliance Review Guide (CRG) . Team members disperse as required to carry out their preassigned tasks in conducting the review according to the format of the CRG. (iv) Pre Exit Conference Meeting of Team. The team leader will arrange a place and time for the team to meet and share information to be included in the written report. This would normally include: (A) Discussions of findings, concerns, and tentative recommendations; (B) Review of information received for completeness, adequacy, and accuracy; (C) The formulation of content, impressions, and other details to be presented at the exit conference; (D) A discussion of activities, assignments, and timelines to enable members to prepare and issue the written report; (E) A discussion of any special commendations for positive contributions; and (F) Suggested resources for any needed technical assistance, if known and indicated. (v) Exit Conference. The purpose of the exit conference is to provide feedback to the CIL director, staff, and governing board. It will be the judgement of the team leader as to the exact nature and specificity of the topics to be discussed. Exemplary practices or obvious problems are usually appropriate for discussion. (d) REPORT PREPARATION (1) Report due dates. The draft of the report is to be completed by the Regional Office with input from the non-federal participants within 30 working days following the on-site review. The draft is distributed to the CIL, the review team members, the SILC chair, and RSA central office IL staff. If the CIL receives part B, Chapter 2 of Title VII of the Act, or other Federal funds through the State, a copy should be shared with the appropriate DSU. Any response to the draft is due 20 working days from the date the draft is mailed. The final report is due to the CIL, the SILC, Central Office RSA, and DSUs where appropriate, 20 working days from the due date of comments from reviewers of the draft on-site report. (2) Draft report (compliance problem). Where the review team determines the CIL may not be in compliance with applicable statutes and regulations: (i) The draft report must contain specific findings and recommendations regarding corrective action needed to address any existing or potential compliance problem and should offer technical assistance (TA) to the CIL; (ii) The CIL in its response to the draft should inform RSA whether it agrees or disagrees with each of the findings; (A) if it disagrees, the CIL should explain its differences; (B) if it agrees with the findings, the CIL should inform RSA what specific corrective action it contemplates and what time frame would be involved in completing actions necessary to address concerns. The CIL should also request TA if the CIL considers that additional help is necessary in order to develop an adequate corrective action plan. (3) Final report. With the exception of a brief general description of the CIL and recommendations, the CRG is intended to constitute the body of the report. Where specific substantive problems are addressed, TA is indicated, or exemplary practices are described, additional material may be included with the CRG. The CRG is designed to stand alone; measure compliance with the standards in 725(b) of the Act and the indicators of compliance with the standards in 34 CFR Part 366, Subpart G; and the assurances in 725(c) of the Act and 34 CFR Part 366, Subpart F. The final report includes: (i) A brief overview of the site visit (1-2 pages); (ii) Specific findings (only where changes are necessary or desirable) and recommendations, each identified by citation to the relevant section of the CRG (3-5 pages); (iii) A request for a corrective action plan(s) if findings include areas of non-compliance. (iv) Identification of areas of strengths and/or exemplary practices and programs; (v) Areas of needed TA or training and, if possible, suggestions of sources where TA or training may be available (with specific references to each finding in paragraph (ii)); and (vi) A copy of the completed CRG. (vii) Include in the final report sent to Central Office, RSA, a brief (one page or preferably less) extract of the on-site review sufficient for publication in the RSA 13 Annual Report. (4) Compliance Issues. (722(g) and 723(g) of the Act; 34 CFR 74.113, 366.38, Part 366, Subpart E) (i) If the procedures under paragraph (d)(2) are not complete, but the Regional Commissioner determines that approvable corrective actions have been agreed upon and will be completed in a reasonable time or will be included in the CIL's annual work plan for the next fiscal year, the final report may be issued by the Regional Commissioner. The final report will include information on the status of any corrective action. (ii) If the Regional Commissioner determines, after review of the draft report, consideration of the responses to the draft report, and after any other action the Regional Commissioner may deem appropriate, that the CIL is failing to comply with the provisions of section 725 of the Act; 34 CFR Part 366, Subpart F or G, the Regional Commissioner shall forward a proposed final on-site report to the Commissioner within 90 working days of the on-site review. In transmitting the report, the Regional Commissioner should review the compliance issues, what steps were taken in an effort to resolve the issues, and recommend that the Commissioner sign and transmit the report to the CIL as provided in 34 CFR 366.39. (5) Corrective Action Plans Section 722(g)(2) of the Act; 34 CFR 366.39. (i) Time periods. Corrective actions may fall into two time periods: (A) those problems which have already been addressed or that the CIL agrees to address and indicates can be addressed before September 30; and (B) those problems that will require a longer period of time to address, i.e., will extend into the next fiscal year. (ii) Current year corrections. For problems, which the CIL plans to address before September 30, the CIL should submit the corrective actions as an amendment to its current year work plan. The amendment does not need to be elaborate--it can be in the form of a letter. (iii) Corrections extending into future year. For corrective actions that will extend into the next fiscal year, the CIL must file an amended Attachment II - C(a), CIL Work Plan, to its next fiscal year work plan. (iv) Approval of the work plans or amendments to the work plans by the regional office meets the requirements of 34 CFR 366.39(b)(1) therefore rendering the CIL eligible for continuation of funding. Incorporation of corrective actions into the work plan is consistent with the assurance in Section 725(c)(4) of the Act, and the reporting and monitoring procedures adopted by RSA to carry out the provisions in Sections 722(g) and 706(c) of the Act. II - DETERMINING VALIDITY OF INFORMATION IN THE 704 PART II REPORT (725(c)(8) of the Act; 34 CFR 364.53) (a) Reviewing Consumer Service Records (CSRs). (1) Number of CSRs to be Reviewed. The review team should review sufficient CSRs to determine: (i) Whether the CIL is meeting the standards for cross-disability; (ii) That the CIL is providing IL services to eligible individuals or groups of individuals without restrictions based on the particular type or types of disabilities; (iii) That the CIL is providing the services reported in the 704 report Part II, Subpart IIG; (iv) That the narrative information provided in Subpart IIB regarding activities and accomplishments of the CIL is reflected in activities participated in by consumers or other information in the CSRs. (2) Required contents (34 CFR 364.53). CSRs must contain: (i) Documentation that the individual has a significant disability and has been determined eligible or ineligible for IL services, consistent with the CIL's policy on eligibility determination. (ii) Documentation that an offer was made to develop an independent living plan (ILP) and that a plan was developed or the CSR contains a written waiver of the offer; (iii) A record of the services actually provided to the individual. (iv) Information about the individual necessary to complete the 704, Part II, Subparts F and G; and (v) A record of the goals or objectives-- (A) Established with the consumer, whether or not in the ILP; and (B) Achieved by the consumer. (3) Recommended contents. CSRs should contain: (i) A statement of problems or needs as presented by the consumer; (ii) A record of the services requested by the consumer; (iii) Information on agreements with the consumers including: (A) Statements of personal goals adopted by the consumer during the reporting year to be achieved during the near term and objectives to be worked toward in the longer term; and (B) Agreements on services to be provided to meet the goals. (725(c)(8) of the Act; 34 CFR 364.53, 366.50) (4)[2] Evaluation of Consumer Goals/Objectives. (i) Are the goals/objectives set by consumers being met as anticipated? Y N (ii) If goals/objectives are being met, are they achieving the anticipated outcomes? Y N (iii) If the anticipated outcomes are being met, are those outcomes providing consumers what they need to be more independent members of their communities? Y N (b) CIL management information system. The team may also review the CIL's management information system for adequacy, accuracy of information, and protection of confidentiality of sensitive information. III - IDENTIFY AND RECORD SOURCE OF DOCUMENTATION USED TO VERIFY INFORMATION (34 CFR 366.63) Where the CRG requests identification of sources or documentation, unless specifically requested, it is not necessary to obtain copies; instead sufficiently identify the source or sources and location of the documentation so it can later be retrieved if needed. UNITED STATES DEPARTMENT OF EDUCATION OFFICE OF SPECIAL EDUCATION AND REHABILITATIVE SERVICES REHABILITATION SERVICES ADMINISTRATION Washington, D.C. 20202-2741 Center for Independent Living (CIL) On-Site Compliance Review FISCAL YEAR 19 NAME OF GRANTEE GRANT # NAME OF CIL 706 and 722 Chapter 1, Part C of Title VII Rehabilitation Act of 1973, as amended CHECKLIST[3] OF MATERIALS THAT MAY BE NEEDED FOR THE REVIEW The on-site review can be carried out more efficiently if the following materials are assembled and made available in one location. I - LEGAL Articles of incorporation 501(c)(3) certificate By-laws IRS Form 990 License(s) (where applicable) Contracts and/or written agreements with business, industry, and community agencies Contracts/Purchase of Service agreements with State agencies Insurance policies II - ORGANIZATIONAL Mission statement Administrative policy and procedure manual Office policies and procedures Organizational chart Roster of members of the governing board Staff roster Minutes of meetings of the governing board for the past twelve (12) months III - Other Descriptions of programs conducted by the CIL Service policies, procedures, I & R system, policies, procedures Appeal procedures for consumers Policy on confidentiality Information on consumers assistance program Consumer satisfaction assmnts Service area needs assessment Job descriptions Affirmative action/EEO plan Volunteer policies Staff performance reviews Equipment inventory Other relevant material (e.g., video tapes, media releases, newsletters, etc.) Latest 704, Part II report Annual workplan o Long-range plan o Financial plan o Advocacy plan o Resource development plan o Staff and board training plans PART I STANDARDS, INDICATORS, AND ASSURANCES FOR CILS (725 of the Act) GRANTEE IS AN ELIGIBLE AGENCY 725(c)(1) of the Act; 34 CFR 364.4(b). The CIL meets the definition of eligible agency as defined in the statute and regulations....................................Yes No Verificant Source: 704 SUBPART IIA: STANDARDS AND INDICATORS The purpose of this subpart is to measure the extent to which the CIL is in compliance with the standards in 725(b) of the Act. This subpart will also test compliance with many of the assurances in 725(c) of the Act. (725(b) and (c)(3) of the Act; 34 CFR Part 366, Subpart G; 704 Part II(IIA)) COMPLIANCE INDICATOR 1 - PHILOSOPHY 725(b)(1) of the Act; 34 CFR 366.63(a)) The indicator for this standard is composed of four parts. I - Consumer control. (702(2), 725(b)(1)(A), 725(c)(2) of the Act; 34 CFR 366.63(a)(1)) (a) Governing Board. (21(b)(5) and 725(c)(2) of the Act; 34 CFR 366.63(a)(1)(i)(A), 366.50(b)). (1) Verification of Consumer Control. (i) Number of persons on the governing board. (ii) Number of governing board members with significant disabilities. Paragraph (ii) is over 50% of paragraph (i) Y N (iii) Number of different disability groups (physical, mental, cognitive, sensory, multiple) represented by members of the governing board. (iv) Number of members from minority groups on the governing board.[4] (v) The CIL has a process for nominating and electing Board members. (vi) The nominating and/or election process provides for participation by consumers of CIL services. Y N Y N Verification source: (2) Board is Principal Decisionmaking Body. (i) The By-laws or other documents or practices of the CIL ensure that policy decisions are vested with the Governing Board? If decision or veto authority rests in a body other than the governing board describe: Y N (ii) Does the CIL have policies and procedures for Board members, which specify roles and responsibilities? If so, cite source. Y N (iii) The Governing board is the principal governing body of the CIL Y N (b) CIL employees. (21 and 725(c)(6) of the Act; 34 CFR 366.63(a)(1)(i)(B)) CIL Employees Total Persons Persons with Disabilities Num ber of Min ori ty Emp loy ees (1) Decisionmaking positions (2) Staff positions Over 50 [5]of the CIL's employees in decision-making positions are filled by individuals with disabilities; and Y N Over 50% of staff positions are filled by individuals with disabilities. Y N Verification Source: II - Self-help and self-advocacy. (725(b)(1)(B) of the Act; 34 CFR 366.63(a)(2)) The CIL promotes self-help and self-advocacy among individuals with significant disabilities (e.g., by conducting activities to train individuals with significant disabilities in self-advocacy)..................................Yes No Verification source: III - Development of peer relationships and peer role models. (725(b)(1)(C) of the Act; 34 CFR 366.63(a)(3)) The CIL promotes the development of peer relationships and peer role models among individuals with significant disabilities; ........Yes No Verification source: IV - Equal access. (725(b)(1)(D) of the Act; 34 CFR 366.63(a)(4)) The CIL-- (a) Ensures equal access of individuals with significant disabilities, including communication and physical access, to the CIL's services, programs, activities, resources, and facilities, whether publicly or privately funded. Equal access, for purposes of this paragraph, means that the same access is provided to an individual with a significant disability regardless of the individual's type of significant disability.........................................Yes No (b) Advocates for and conducts activities that promote the equal access to all services, programs, activities, resources, and facilities in society, whether public or private, and regardless of funding source, for individuals with significant disabilities. Equal access, for purposes of this paragraph, means that the same access provided to individuals without disabilities is provided in the CIL's service area to individuals with significant disabilities...........................Yes No (c) Makes available in alternative formats, as appropriate, all of its written policies and materials and IL services.............Yes No GENERAL ASSESSMENT OF HOW THE CIL COMPLIES WITH THE EQUAL ACCESS INDICATOR (725(b)(1)(D) of the Act; 34 CFR 366.63(a)(4)) (a) The CIL provides equal access to all services, programs, activities, resources, and facilities. Y N (b) The CIL is totally physically accessible for persons with mobility disabilities. Y N (c) There are TDDs/TTYs and/or other available means[6] of communication to ensure access at the CIL for persons with hearing disabilities. Y N (d) There are Braillers and/or other available means[7] of communication to ensure access at the CIL for persons with visual disabilities. Y N (e) There are picture boards and/or other means of communication available to assure access at the CIL for persons with reading disabilities. Y N (f) The CIL is accessible for persons with Environmental Illness (E.I.) and Multiple Chemical Sensitivity (MCS) or the CIL has alternative ways of ensuring access to CIL services. Y N (g) Type of reasonable accommodationFull-timePart-timeUpon Request Only NA (h) Interpreters are available at the CIL. (i) Readers are available at the CIL. (j) Personal attendants are available at the CIL. (k) Materials are produced by the CIL in different forms as needed (e.g., Braille, large print, tape.) Y N (l) Public relations materials stress equal access to society for all individuals with disabilities. Y N COMPLIANCE INDICATOR 2 - PROVISION OF SERVICES ON A CROSS-DISABILITY BASIS(725(b)(2) of the Act; 34 CFR 366.63(b)) The CIL-- (a) Provides IL services to eligible individuals or groups of individuals without restrictions based on the particular type or types of significant disability of an individual or group of individuals, unless the restricted IL service (other than the IL core services) is unique to the significant disability of the individuals to be served, e.g., Braille instruction for persons who are blind;.............Yes No (b) Provides IL services to individuals with a diversity of significant disabilities and individuals who are members of populations that are unserved or underserved by programs under Title VII of the Act; and....................Yes No (c) Provides IL core services to individuals with significant disabilities in a manner that is neither targeted nor limited to a particular type of significant disability.....................Yes No Verification source: COMPLIANCE INDICATOR 3 - INDEPENDENT LIVING GOALS (725(b)(3) of the Act; 34 CFR 364.53, 366.63(c)) Consumer Service Records (CSRs). (a) The CIL maintains a CSR for each consumer;..........................................Yes No (b) The CSRs contain: (1) Documentation showing that the individuals are eligible or ineligible for services (only those eligible are served); ........Yes No (2) Written ILPs or written waivers from the consumers stating that ILPs are unnecessary;...................................Yes No (3) Information on the services requested by, and the services provided to, or arranged for, the consumers; ...............Yes No (4) The IL goals or objectives established with the consumers, whether or not in the ILPs; and ...........................Yes No (5) The goals or objectives the consumers believe they have achieved...............Yes No (c) The CIL maintains documentation: (1) That the CIL notifies all consumers of their right to develop or waive the development of an ILP.................Yes No (2) On the number of ILPs developed by consumers receiving services from the CIL; .............................................Yes No (3) On the number of waivers signed by consumers receiving services from the CIL stating that an ILP is unnecessary.............Yes No (4) That the CIL facilitates the development and achievement of IL goals selected by individuals with significant disabilities who request assistance from the CIL; and ......................................Yes No (5) That the CIL provides opportunities for consumers to express satisfaction with the CIL's services and policies in facilitating their achievement of IL goals and provides any results to its governing board and the appropriate SILC. .................................Yes No COMPLIANCE INDICATOR 4 - COMMUNITY OPTIONS AND COMMUNITY CAPACITY (725(b)(4), (6), (c)(10) of the Act; 34 CFR 366.63(d)) In the reporting year, the CIL promoted the increased availability and improved quality of community-based programs that serve individuals with significant disabilities and promoted the removal of any existing architectural, attitudinal, communication, environmental, or other type of barrier that prevents the full integration of these individuals into society. During the reporting year, the CIL performed at least one activity in each of the following categories: (a) Community advocacy.............................Yes No (b) Technical assistance to the community on making services, programs, activities, resources, and facilities in society accessible to individuals with significant disabilities.......Yes No (c) Public information and education..............Yes No (d) Aggressive outreach to members of populations of individuals with significant disabilities that are unserved or underserved by programs under Title VII of the Act in the CIL's service area..........................Yes No (e) Collaboration with service providers, other agencies, and organizations that could assist in improving the options available for individuals with significant disabilities to avail themselves of the services, programs, activities, resources, and facilities in the CIL's service area.................................Yes No Verification source: COMPLIANCE INDICATOR 5 - IL CORE SERVICES AND OTHER IL SERVICES (725(b)(5) of the Act; 34 CFR 366.63(e)) The CIL-- (a) Provides information and referral services to all individuals who request this type of assistance or services from the CIL in formats accessible to the individual requesting these services; and..........Yes No (b) As appropriate in response to requests from individuals with significant disabilities who are eligible for IL services from the CIL, provides the following services: (1) Independent living skills training;.........Yes No (2) Peer counseling (including cross- disability peer counseling);.......................Yes No (3) Individual and systems advocacy; and........Yes No (4) A combination, as appropriate, of any two or more other IL services..................Yes No Verification source: COMPLIANCE INDICATOR 6 - RESOURCE DEVELOPMENT ACTIVITIES (725(b)(6) of the Act; 34 CFR 366.63(e)) The CIL during the reporting year conducted resource development activities to obtain funding from sources other than Chapter 1 of Title VII of the Act.............Yes No Verification source: SUBPART IIB: CIL NARRATIVE 725(c)(8)(F) of the Act; 34 CFR 366.50(i)(7)) (a) The discussion of activities and accomplishments supports the responses provided in Subpart IIA ..........................Yes No (b) The documentation reviewed during the course of the on-site visit supports the narrative in Subpart IIB.......................Yes No SUBPART IIC: PROGRAM AND FINANCIAL PLANNING OBJECTIVES (725(c)(4) of the Act; 34 CFR 366.50(d); 704II, Subpart IIC) CHECKSHEET (a) The CIL has established annual and 3-year program and financial planning objectives. Y N (b) The objectives include goals or a mission for the CIL. Y N (c) The CIL has a current work plan for achieving the goals or mission and has included specific activities planned to meet the requirements in the indicators. Y N (d) The work plan includes objectives and goals for obtaining and increasing funding from sources other than Title VII of the Act. Y N (e) The work plan includes specific service priorities, and types of services to be provided. Y N (f) The work plan includes plans for training governing board, employees, volunteers, and consumers. Y N (g) The objectives and work plan are consistent with the current SPIL. Y N 704II, SUBPART IIF: NUMBERS AND TYPES OF INDIVIDUALS WITH SIGNIFICANT DISABILITIES RECEIVING SERVICES THROUGH THE CIL (13, 704(m)(4)(B),(D), 725(c)(8)(B) of the Act; 34 CFR 364.36, 366.50(i)(2)) (a) The review of CSRs, data collection, and recording practices of the CIL demonstrate that the data reported in 704 IIF are statistically accurate...........................................Yes No (b) The CIL's management information system is adequately programmed to record the following data about consumers: (1) Consumers served during the reporting year;....................................Yes No (2) Consumers who became inactive during the year;...................................Yes No (3) Consumers served during the year who remained active at the end of the year;..............................................Yes No (4) How long the consumer has been in contact with the CIL;...........................Yes No (5) Consumer Achievements: (i) Number of ILPs waived;...................Yes No (ii) Number of ILPs developed;................Yes No (iii) Consumer goals set and met;..............Yes No (6) Age;........................................Yes No (7) Gender;.....................................Yes No (8) Race/ethnicity;.............................Yes No (9) Disability;.................................Yes No (10) Living Arrangements; and....................Yes No (11) Source of PAS (or availability).............Yes No 704II, SUBPART IIG: TYPES OF SERVICES PROVIDED THROUGH THE CIL AND THE NUMBER OF INDIVIDUALS WITH SIGNIFICANT DISABILITIES RECEIVING EACH TYPE OF SERVICE (704(m)(4)(D), 725(c)(8)(C) of the Act; 34 CFR 364.43, 366.50(i)(3)) (a) The review of CSRs, data collection, and recording practices of the CIL demonstrate that the data reported in 704 IIG are statistically accurate...........................................Yes No (b) The CIL recorded either total hours of FTE expended on community services or otherwise recorded whether or not activities were conducted in any of the areas indicated.........................Yes No (c) The CIL records the numbers of consumers provided individual services.............Yes No PART II ORGANIZATION AND ADMINISTRATION OF THE CIL (EDGAR - 34 CFR Parts 74 & 75) I - ORGANIZATION OF CIL (34 CFR Parts 74 & 75) (a) The CIL has an organizational chart indicating lines of authority and supervision. Y N (b) The CIL has job descriptions for all personnel, including volunteers. Y N (c) The staff know what is expected of them and it is consistent with job descriptions. Y N II - STAFF DEVELOPMENT AND TRAINING (34 CFR 364.24, 366.50(l)) (a) The CIL assures the training needs of its staff are met. Y N Describe the process in (a) (b) The CIL provides for staff development and training. Y N Give examples of staff training. (c) The CIL has Governing Board training and development sessions/programs Y N III - POLICIES AND PROCEDURES (364.53, 56, 366.50(e)) (a) The CIL has policies and procedures for staff covering; (1) consumer service record management (2) confidentiality (3) personnel policies (4) equipment purchase (5) travel policy and procedures (6) codes of conduct (34 CFR 74.42, 75.524, 525) Y N Y N Y N Y N Y N Y N Verification source: IV - PERSONNEL POLICIES (366.50(e)) (a) There are personnel policies covering: (1) vacation and sick leave (2) working hours (3) activity reports (time sheets) (4) fringe benefits (5) wage and salary administration (6) performance appraisals Y N Y N Y N Y N Y N Y N Verification source: V - CONFIDENTIALITY (364.56) (a) The CIL assures that all personal information about consumers served by the CIL, including names, addresses, photographs and other records are held confidential. (1) maintenance of records and files (2) conditions for releasing consumer data (3) confidential meetings at the CIL (4) publicity releases Y N Y N Y N Y N Verification source: VI - AFFIRMATIVE ACTION/NON-DISCRIMINATION (704(m)(2), 725(c)(5) of the Act; 34 CFR 364.31) The CIL takes affirmative action to employ and advance in employment qualified individuals with significant disabilities. Y N Verification source. VII - TRAVEL POLICIES (74.27) (a) The CIL has clearly defined staff and board travel policies. Y N (b) Policies for travel expense reimbursement using federal funds are in accordance with State and federal requirements. Y N (c) The policy provides for reimbursement by: (1) actual expense (2) per diem Y N Y N (d) All trips charged to the CIL are justified and documented by travel requests, time sheets, receipts, etc. Y N Verification source: VIII - PURCHASING (EDGAR - 34 CFR 74.40 - 74.48; OMB Circular A-110) (a) The CIL has a written purchasing policy. Y N (b) The policy complies with EDGAR Y N (c) The purchasing policies and procedures give adequate consideration to costs, quality, delivery, competitive bidding, inspection and acceptance. Y N (d) Specify person(s) responsible for purchasing equipment and supplies. (e) Executive staff/Board approval is needed for items over $ . Y N (f) The receipt of goods/services is documented to support payment for them. Y N (g) There is separation of responsibility for the authorization for purchasing and the subsequent payment. Y N (h) When using Part C grant funds to purchase equipment, the CIL has procedures to insure that such use is allowable and that the item is in the approved budget. Y N (i) Requisitions, purchase orders and receiving slips are prenumbered and safeguarded. Y N IX - INSURANCE COVERAGE (34 CFR 74.31) The CIL has equivalent insurance coverage for real property and equipment acquired with Federal funds as provided to property owned by the grantee. Y N X - NONDISCRIMINATION (34 CFR 75.500) The CIL does not deny services to persons on the basis of their race, color, national origin, sex, age or the existence of a disability. Y N XI - PROHIBITION AGAINST LOBBYING (34 CFR Part 82) The CIL has a policy and procedures to guard against using Federal funds to influence or attempt to influence any agency or Congress in connection with the making of any Federal grant, the entering into of any cooperative agreement and the extension, continuation, renewal, amendment or modification of any Federal grant of cooperative agreement. Y N Part III GRANT MANAGEMENT (725(c)(8)(D) of the Act; EDGAR - 34 CFR Parts 74, 75, 77, 81, 82, and 85) 704II, SUBPART IID: SOURCES AND AMOUNTS OF FUNDING FOR THE OPERATION OF THE CIL (725(c)(8)(D) of the Act; 34 CFR 366.50(i)(4)) I - Resources. (a) Federal Funds 1. Ch. 1, part B, Title VII $ 2. Ch. 1, part C, Title VII $ 3. Ch. 2, Title VII $ 4. Other Federal Funds $ (b) Other Government Funds (5) State government funds $ (6) Local government funds $ (c) Private Funds (7) Foundation, corporation or trust grants $ (8) Donations from individuals $ (9) Memberships $ (10) Investment income, endowment $ (11) Fees for service (program income) $ (12) Other gifts (in-kind items, etc.) $ (estimated fair value) (d) Total resources (Sum of lines 1--12) $ (e) Amount of total resources that "pass through" to consumers, e.g., personal assistant service funds $ II - GRANT RELATED INCOME (34 CFR 364.6, 74.24) (a) Program income is generated using federal funds. (34 CFR 74.2, 74.24) Y N (b) Such income is used for allowable and approved purposes. (34 CFR 74.24(b)) Y N (c) Verification source: III - BUDGET (34 CFR 74.21) (a) An individual has been designated to have clear responsibility to assure grant funds are properly used. - Names/Title(s) of designee. (b) Accounting records, including cost accounting records, are supported by source documentation. (34 CFR 74.21(b)(7); 75.702) Y N Y N (c) Required reports accurately account for the CIL's funds. (34 CFR 74.21(b)(2),(3),(4)) Y N (d) Procedures are followed to assure expenditures are consistent with the approved budget of the CIL. (34 CFR 74.21(b)(4)) Y N (e) Verification sources: (f) The agency providing funds to the CIL has approved any budget revisions prior to expenditure of funds. (34 CFR 74.25(b)) Y N (g) Verification source: (h) The CIL has written procedures that minimize the time elapsing between the transfer of funds and disbursement by the recipient (34 CFR 74,22(b)(1)(i), 34 CFR 74.52(a)(2)(iii)) Y N (i) Time and attendance records are kept on each employee paid with grant funds and the records meet the requirements of OMB A-122. (34 CFR 74.21) Y N (j) Actual time records are consistent with budgeted time. (34 CFR 74.21) Y N IV - FISCAL MANAGEMENT (34 CFR 74.52) (a) All financial status reports both of an internal nature and those required by the grant agency are current and accurate. Y N (b) Verification source. (c) The financial status report SF-269 required by ED of grantees reflects program income, cost sharing/matching indirect cost rates. (34 CFR 74.50) Y N (d) Name/Title of person responsible for preparation of SF-269. (e) The CIL distributes administrative costs among its various funding sources in an equitable manner as might be found in a cost allocation plan. Y N (f) If yes, and if a cost allocation plan has been developed, get a copy of the plan. (This is useful for future budget adjustments and is of value when providing TA to other grantees.) V - ACCOUNTING SYSTEMS (34 CFR 74.21) (a) The organization maintains a formal accounting system. Y N (b) The accounting system is computerized. If so, identify the accounting program software used. Y N (c) The elements of the formal accounting system are: (1) General Ledger (2) Grant Ledger (3) General Journal (4) Cash Receipts (5) Other (specify) Y N Y N Y N Y N Y N (d) The formal accounting system is maintained by: (34 CFR 74.21(b)(1)) (1) Cash basis (2) Accrual basis (3) Other (describe) Y N Y N Y N (e) Purchasing and payment functions are separated. Y N (f) Verification source. (g) Payments are made only if disbursements or checks are counter-signed. Y N (h) Verification source. (i) All funding sources are accounted for separately. (34 CFR 74.21(b)(4)) Y N (j) Verification source. (k) Expenditures are recorded by budget cost category and funding sources. (34 CFR 74.21(b)(3)(4), 34 CFR 75.702, 34 CFR 75.730) Y N (l) Verification source. (m) All accounting records are supported by adequate documentation and entries are made on a timely basis. (34 CFR 75.702, 34 CFR 75.707, 34 CFR 75.730) Y N (n) Verification source. (o) Payment vouchers are identified as to grant number, expense classification and transaction date, and funding sources. (34 CFR 74.21(b)(3)) Y N (p) Verification source. VI - PROPERTY (a) The CIL maintains current and complete records of all property purchased with grant funds. (34 CFR 74.34(2)(f)) Y N (b) Verification source. (c) The CIL has a system for controlling inventory (general ledger control account, card reports, property labels). (34 CFR 74.34(2)(f)) Y N (d) The CIL keeps duplicate records. Y N (e) Maintenance of property and equipment records are kept. (34 CFR 74.34(f)(5)) Y N (f) Records contain: description of each piece of equipment; purchase date/cost; mfr's serial #, model #, Federal stock #, national stock #, or other ID #; source of equipment including award #; where title vests; information from which Federal participation can be calculated; location and condition of the equipment, date information was reported; and ultimate disposition. (34 CFR 74.34(f)(1)) Y N (g) The CIL inventories property at least once every two years. (34 CFR 74.34(f)(3)) Y N (h) Date of last inventory (i) Adjustments to inventory accounts are made only on written authority of a designated official. Y N (j) Name/Title of designee. (k) The CIL guards against loss, damage or theft of property. (34 CFR 74.34(f)(4)) Y N (l) The CIL has policies, procedures and controls for purchasing and disposing of property. (34 CFR 74.34(f)(6)) Y N (m) Verification sources. VII - RECORD RETENTION (a) Fiscal and consumer records are maintained and retained in accord with federal requirements. (34 CFR 74.53(b)); 704II, page viii) Y N (b) Verification source. VIII - AUDIT (a) An annual non-federal audit has been conducted and includes the Federal funds received under Chapter 1 of Title VII of the Act. (Sec. 725(c)(7) of the Act; 34 CFR Part 74.26) Y N (b) Verification source (specify date of audit, relevant findings, and action taken). (c) A copy of the audit been submitted to the Federal Audit Clearinghouse as stated in Attachment C of the GAN? Y N (d) Verification source: IX - DRUG-FREE WORKPLACE (34 CFR 85.600) (a) The CIL conforms with the requirements of a drug-free workplace. Y N (b) A statement is published notifying employees that the unlawful manufacture, distribution, dispensing, possession or use of a controlled substance is prohibited at the CIL and specifying the actions that will be taken against employees for violating the prohibition. Y N (c) The CIL has established an on-going drug-free awareness program. Y N (d) Each grant funded employee has been given a copy of the prohibition statement, including a notification that conditions of employment at the CIL require abiding by the statement and informing the director of the CIL of any convictions under a drug statute. Y N (e) The CIL has taken appropriate personnel action against employees or has required employees to participate in a drug abuse assistance program or rehabilitation program when such employees were convicted under a criminal drug statute conviction. Y N 1. Where a CIL is operating one or more part C funded satellites receiving separate grant awards, the funded applications, 704 Reports, and operations of the satellite(s) is reviewed at the same time as the principal CIL is reviewed. 2. This section is guidance, provided as a tool to explore how effective the CIL is in assisting individuals to set goals or objectives, whether achievement of the goals and objectives are actually improving the ability of individuals to function, continue functioning, or move towards functioning independently in the family or community, and whether TA is needed to help the CIL improve or expand the number of successful outcomes. 3. This is a checklist--it is not to be interpreted as a list of required items; therefore, the absence of an item on the checklist does not mean a CIL is out of compliance with 725 of the Act. 4. Alaskan Native, American Indian, Asian American, Black (African American), Hispanic American, Native Hawaiian, and Pacific Islander. (34 CFR 364.4) 5. The determination that over 50 percent of a CIL's employees in decision-making and staff positions are filled by individuals with disabilities is based on the total number of hours (excluding any overtime) for which employees are actually paid during the last six months of the reporting year. A center must include in this determination its employees who are on unpaid family or maternity leave during this six-month period. For purposes of this section a CIL may exclude personal assistants, readers, drivers, and sign-language interpreters. 6. Available means may be either directly by the CIL or through a contract. 7. IBI