Are you spending your CARES Act funds?
After years of saying we don’t have enough funding, the Part C centers received a very generous infusion of cash. The purpose was to be able to offer flexible and immediate support to the vulnerable people we serve to meet their needs related to COVID-19. What needs could be funded were not defined – your center needs to figure out with people what they need to stay safe and healthy NOW. If you are not pushing funds out to benefit your consumers, you need to reassess and get things going. You were given some examples in the FAQ from ACL referenced below and in recent correspondence from them.
I have spoken to only a few of you about this. Some of you have said you want to wait – that the need isn’t that great yet in your area. Others that you think the next wave is going to be more serious and you want to save some for that. Still others that the state’s CILs are meeting to figure out what is needed. (ACL recommends that you not work on state redistribution until they provide guidance, but that you meet the needs of your community first and immediately.)
None of these are good reasons to let funds sit while people with disabilities are facing life-threatening situations as part of the response to the COVID-19 pandemic. Have you talked to your consumers? Have any of them expressed fear? Lost caregivers? Don’t know how to hold it all together right now? Some centers have lost people to this pandemic. Yes, people are dying, and those with fragile health or breathing disabilities are at very high risk. Some, even behind the closed doors of their home, are extremely fearful of this disease. If they need shared care givers who come in and out of their home, they are at substantially greater risk. What are you doing about it?
Remember – the purpose of the CARES Act was rapid response. Meetings don’t result in people getting assistance. If you anticipate more need is coming, go ahead and plan but also act. Secure supplies now. You can provide support now AND plan for further need. Buy PPE for individuals and their caregivers now, in anticipation, so you can give a same-day response when a consumer turns to you.
You received a “Dear Colleagues” letter this week from ACL. Were you as shocked as I was that less than 20% of centers have drawn down funds? The letter stated in part:
As of May 18, 2020, the PMS drawdown reports show that 82% of CILs have drawn down $0 of CIL CARES Act funds. Please be reminded that CILs were directed to utilize the entirety of the funds to respond to the COVID-19 pandemic and the surge of needs of individuals with disabilities to access or reconnect with the services and supports they need to remain safely in their communities. Surge needs are now. Guidance has been provided in the CIL CARES Act FAQ on allowable expenses and areas of emphasis that include:
- Service coordination during and after the COVID-19 pandemic;
- Services and activities that assist individuals with disabilities who are at risk of being institutionalized to remain in their communities;
- Services and activities that assist individuals with disabilities to move from an institutional setting to a home in a community-based setting;
- Services and activities that address the shortage of accessible housing;
- Partnerships with local agencies that address food insecurity; and
- Systems advocacy to ensure health equity in medical settings.
ACL strongly cautions CILs against delaying COVID-19 pandemic surge services and activities in your communities. The ACL Disaster Services Policy provides guidance on coordinating services and activities that may overlap existing service areas or reach into unserved areas. The Disaster Services Policy does not provide exceptions to CIL funding distributions (emergency or otherwise) or the recipient CIL’s responsibility for the use of funds. CILs who have received CIL CARES Act funds should not delay using the funds for services in their communities or in communities where disaster services agreements are in place.
I hope you are listening carefully to what your funder is saying. NOW, SURGE, IMMEDIATE, URGENT, EMERGENCY – I hope you get the picture. Identify how the need is COVID related and provide the much needed response NOW. When was the last time your center had the funds to assist people in such a concrete way? The CILs that are regularly checking in with their consumers are learning what is needed. They are responding with life sustaining food, safe water, soap, hand sanitizer, costs of food deliveries, communication, protective equipment, and more because they are providing what the consumers tell them is needed in this very scary time. How can we NOT respond NOW?