Make your plans now for the first IL Conference of 2019

Registration to the SILC Congress is now open. This gathering of SILC directors, members and chairs will be held February 25-27 at the Rosen Centre Hotel in Orlando, Florida.  You can register now to get your plans underway. SILC staff and members around the country need their own peer support, and this is where it happens each year. This is a great gathering for SILC staff, council members, and invited presenters.

And as you may already know, there is a lot of activity around a new template for the SPIL, whether your SILC is going to amend or extend your SPIL, and how the new Program Progress Report (PPR, or the former 704 report) will be generated.  ACL plans to attend and the Congress should be a great opportunity to learn the latest from our federal funders. Sessions will also include how-to discussions around the SILC’s duties, including their relationship with the other entities in the IL Network.

Getting out the vote

You already know that, as a recipient of federal funds, you can lobby, but can’t use those federal dollars to lobby. You know that your CIL or SILC can’t support or oppose any candidate for office because of  your tax-free status with the IRS. But did you know you can and should “Get out the vote”?

Voting is something every center should be addressing. I know it is late for some of these but some are coming up next week. These should routinely be a part of your conversations with an individual consumer.

  1. Are you registered to vote? Whatever your party and options, staff should be registered voters, and should encourage consumers to register to vote as well.  How can we be effective advocates and peer models if we don’t even take time to vote? Advocacy has many layers, but if we are disenfranchised because we don’t take time to be a voter, we are missing the very basis of our democracy. If you don’t know HOW people register, find out.  Many centers offer a voter registration card to consumers when they are first interviewed.  It is that important!
  2. How do you make your voting decisions? There are a lot of things on a ballot and not all of them are the people who are arguing so publicly about why you shouldn’t vote for the opposing candidate. A good class for the independent living skill of voting is to go over the voter information packet and make sure the voters have the information they need to make a decision. Some centers invite candidates to a public forum to address questions important to the disability community. Again, you cannot (with federally funded time) encourage a specific vote, but you can share the pros and cons that are published on the issues at hand.
  3. Do you know where to vote? Hopefully your center has helped with voter access to polling places (a service for which many centers get paid by their county). But to encourage your consumers to vote, and to vote yourself, you need to understand your accessibility options. Does your state allow mail-in ballots? That is an easy fix for many for mobility concerns.  It doesn’t give the voter a chance to really participate in voting, to go confidently to the polls and to wear that “I Voted” sticker proudly for the rest of the day. The visible presence of votes with disabilities is a powerful statement.  What are the options for blind voters?
  4. Do you know how to take action when there is a problem? What should voters do if their polling place is inaccessible? Who should they contact, and how can they resolve it? What can be done on election day and what advocacy needs to occur before the next election?
  5. Do you celebrate the process of voting? Not just the candidate, not only the outcomes, but that you are an active part of the process!

Just when you thought you were done with indirect cost rate proposals…

First a word to the wise — when you get anything in the mail that is related to your grant or your compliance with regulations, you need to read it carefully and do what it asks you to do. If what it asks is coming in the future in the form of a report or other information, be sure to put that date on your calendar. It may be the only reminder you will get.

A case in point is your Nonprofit Rate Agreement, which you received from the federal government some time in 2016 when your Indirect Cost Rate Proposal was accepted.  It probably said that your rate was provisional, and that the effective period was two or three years, depending on your local office. And on the second page of your approval, at the end of Section II: SPECIAL REMARKS is a note titled NEXT PROPOSAL DUE DATE. For most of you this date was March 2018, because it is roughly 6 months after your first trial or provisional year of your rate, which for most of you started September 30, 2017. Some of your dates will vary depending on how quickly your proposal was approved.

Then this week some of you received a letter saying that your Indirect Cost Rate Proposal is overdue. They are talking, not about the period of time your current plan is good, but about your responsibility to report back to them on how accurate it was.

Even if you haven’t received that letter yet, go to your approval letter and check that paragraph. If you are already late, and I suspect many of you are, do it as soon as possible.

You are to submit a new Indirect Cost Rate Proposal, this time based on your actual costs for the 2017 fiscal year. Use the same proposal, just update your numbers. Your percentage will very likely be a little off. Don’t worry about that — you have to put in your actual, so if it is off HHS will work with you to correct going forward. But do keep your indirect cost current. As we suggested in training, you want to run your own actuals anyway, because you want these to be accurate figures.

So take a deep breath and dive back in, because we probably will never be done with indirect cost rates.

11 Warning Signs of Gaslighting

Recent events have raised a national conversation about “gaslighting”, and I don’t know about you, but much of what is being said resonated with me, not just as a woman, but as a woman with a disability. I found this article by Stephanie Sarkis, an author with a book that addressed Gaslighting and some of the signs it is happening. First, her definition. She defines gaslighting as “a manipulation tactic used to gain power.” and goes on to say, “And it works too well.” Here is her article:

Gaslighting is a tactic in which a person or entity, in order to gain more power, makes a victim question their reality. It works much better than you may think. Anyone is susceptible to gaslighting, and it is a common technique of abusers, dictators, narcissists, and cult leaders. It is done slowly, so the victim doesn’t realize how much they’ve been brainwashed. For example, in the movie Gaslight (1944), a man manipulates his wife to the point where she thinks she is losing her mind.

In my book Gaslighting: Recognize Manipulative and Emotionally Abusive People – and Break Free I detail how gaslighters typically use the following techniques:

1. They tell blatant lies.

You know it’s an outright lie. Yet they are telling you this lie with a straight face. Why are they so blatant? Because they’re setting up a precedent. Once they tell you a huge lie, you’re not sure if anything they say is true. Keeping you unsteady and off-kilter is the goal.

2. They deny they ever said something, even though you have proof.

You know they said they would do something; you know you heard it. But they out and out deny it. It makes you start questioning your reality—maybe they never said that thing. And the more they do this, the more you question your reality and start accepting theirs.

3. They use what is near and dear to you as ammunition.

They know how important your kids are to you, and they know how important your identity is to you. So those may be one of the first things they attack. If you have kids, they tell you that you should not have had those children. They will tell you’d be a worthy person if only you didn’t have a long list of negative traits. They attack the foundation of your being.

4. They wear you down over time.

This is one of the insidious things about gaslighting—it is done gradually, over time. A lie here, a lie there, a snide comment every so often…and then it starts ramping up. Even the brightest, most self-aware people can be sucked into gaslighting—it is that effective. It’s the “frog in the frying pan” analogy: The heat is turned up slowly, so the frog never realizes what’s happening to it.

5. Their actions do not match their words.

When dealing with a person or entity that gaslights, look at what they are doing rather than what they are saying. What they are saying means nothing; it is just talk. What they are doing is the issue.

6. They throw in positive reinforcement to confuse you.

This person or entity that is cutting you down, telling you that you don’t have value, is now praising you for something you did. This adds an additional sense of uneasiness. You think, “Well maybe they aren’t so bad.” Yes, they are. This is a calculated attempt to keep you off-kilter—and again, to question your reality. Also look at what you were praised for; it is probably something that served the gaslighter.

7. They know confusion weakens people.

Gaslighters know that people like having a sense of stability and normalcy. Their goal is to uproot this and make you constantly question everything. And humans’ natural tendency is to look to the person or entity that will help you feel more stable—and that happens to be the gaslighter.

8. They project.

They are a drug user or a cheater, yet they are constantly accusing you of that. This is done so often that you start trying to defend yourself, and are distracted from the gaslighter’s own behavior.

9. They try to align people against you.

Gaslighters are masters at manipulating and finding the people they know will stand by them no matter what—and they use these people against you. They will make comments such as, “This person knows that you’re not right,” or “This person knows you’re useless too.” Keep in mind it does not mean that these people actually said these things. A gaslighter is a constant liar. When the gaslighter uses this tactic it makes you feel like you don’t know who to trust or turn to—and that leads you right back to the gaslighter. And that’s exactly what they want: Isolation gives them more control.

10. They tell you or others that you are crazy.

This is one of the most effective tools of the gaslighter, because it’s dismissive. The gaslighter knows if they question your sanity, people will not believe you when you tell them the gaslighter is abusive or out-of-control. It’s a master technique.

11. They tell you everyone else is a liar.

By telling you that everyone else (your family, the media) is a liar, it again makes you question your reality. You’ve never known someone with the audacity to do this, so they must be telling the truth, right? No. It’s a manipulation technique. It makes people turn to the gaslighter for the “correct” information—which isn’t correct information at all.

The more you are aware of these techniques, the quicker you can identify them and avoid falling into the gaslighter’s trap.

Book: Gaslighting: Recognize Manipulative and Emotionally Abusive People – and Break Free
Copyright 2017 Sarkis Media: www.stephaniesarkis.com

About the Author

Stephanie Moulton Sarkis, Ph.D., N.C.C., D.C.M.H.S., L.M.H.C., is the author of Gaslighting: Recognize Manipulative and Emotionally Abusive People—and Break Free.

Take time to listen to each other!

Is it just me, or does there seem to be more bickering in the world than there used to be? You can see it in almost every relationship — between countries, between races, between political parties and candidates, between other community members. A speech in the Madam Secretary TV show this past week caught my attention. The Secretary of State in the series said in part, “…we must never lose sight of our common humanity, our common values and our common decency. I was reminded recently of our nation’s founding motto, E pluribus unum. Out of many, one. Thirteen disparate colonies became one country. … governments can’t legislate tolerance or eradicate hate. That’s why each one of us has to find the beauty in our differences instead of the fear. Listen instead of reacting. Reach out instead of recoiling. It’s up to us. All of us.”

There is a disturbing reality that is reducing our effectiveness as the Independent Living Network. It isn’t new, but I am discouraged that it never seems to end. Because I am a neutral third party, sometimes I hear two sides of an issue that is plaguing our movement in a specific state or between specific centers or other partners. And sometimes it seems we are so quick to judge the “rightness” or “wrongness” of an idea don’t we don’t wait to hear each other out. Sometimes partners even develop intentional barriers so they can avoid listening to each other.

I used to shrug and say that we are all advocates and sometimes in our fervent advocacy we forget who our friends are. In the last couple of years I have looked at our political system, and thought maybe these very fixed opinions are part of our current culture. I hope we will see a shift back to being kinder to each other — the alternative is so very painful. And sometimes the divisions between members of our network are so long and wide that I am not sure they can be crossed. The philosophical interpretations are so important, but each party sees them dramatically differently.

I don’t have any easy answers. In a few cases the animosity runs so deep and has so much history that I don’t have a lot of hope. Still, I feel a need to offer a few thoughts.

  • Make a connection person to person, not agency to agency. Take time to know your partners as individuals who, like you, are a part of the Independent Living Network, even if you question their commitment to Independent Living Philosophy.
  • Be respectful and kind every time you can be. Our world needs a lot more kindness, and each of us can do a part in reacting in kindness, especially to others in our network.
  • Listen to what they have to say. Now if you are in one of those longer feuds, I am willing to guess that you are sure you already know their opinions and you disagree with them, so you don’t have to listen. I would challenge you, though — you can find a spark of what drew that person to IL in there somewhere. Listen, and then listen some more. They already know your protests, too, so if you discuss you will just keep cutting each other off. Listen without discussing and you may hear something new.
  • In every advocacy situation there are specific points that are of concern. When you can, focus on those points and not on specific personalities. Even if that individual moves on tomorrow, the issues and policies and practices will probably still be of concern. Work on those specifically.

I don’t need to give you lessons on advocacy — you know the many ways to effect change in your communities — but you usually start with education. Make sure the other party knows your concerns and why they are an issue. Educate the others first, giving them a chance to do the right thing.  Then, of course, you do what you must to bring about change.

And one last thought. If you are in one of these difficult situations, if you and a network partner are at odds, has the advocacy you are doing now worked to improve the situation? If not, I urge you to step back and try another way.

And to “… find the beauty in our differences instead of the fear. Listen instead of reacting. Reach out instead of recoiling. It’s up to us. All of us.”

 

Changes in purchasing thresholds in Uniform Guidance

As a recipient of federal funds, your center or SILC is required to have purchasing policies in place which meet the Uniform Guidance/Uniform Administrative Requirements. Your limits for each category can be less, but cannot exceed, these limits.  These changes are hot off the press and will be in our updated financial policies and procedures at http://www.ilru.org/il-net-sample-fiscal-policies-and-procedures-handbook

Micro purchases of supplies or services are those that do not exceed $10,000 (these limits will be updated periodically).
Small purchase requirements apply when purchases are between $10,000 and $25,000 (the current level of the Simplified Acquisition Threshold). These amounts will be indexed for inflation.
Micro purchases shall be distributed among qualified suppliers but don’t generally require competitive quotations.
Small purchases will be made only after price or rate quotations are obtained from an adequate number of qualified sources. Prices can be obtained from published or online price lists.
Purchases in excess of the Simplified Acquisition Threshold, including services, equipment or supplies, purchases, leased or contracted for require a cost or price analysis (costs analysis evaluates cost components, price analysis evaluates the total price). These purchases shall be made only after receiving, whenever possible, quotations from at least three vendors. Selections shall be recommended to the (finance director, CFO CEO) for approval with quotations attached. Recommendation and selection shall be based on the following criteria:
● A clear and accurate description of the product or service to be purchased
● Skill and experience of key personnel
● Experience providing products or services to THE ORGANIZATION
● Any specific requirements we have included in our solicitation of bids
● Demonstrated commitment to the nonprofit sector
● Information received from vendor references
● Commitment to our time deadlines
● Cost
● Woman- or minority-owned business or qualified small business
● Preference for products and services that conserve natural resources and protect the environment, to the extent possible

Construction services shall be procured by sealed bids following formal advertising. Contracts shall be awarded to the responsible bidder whose bid conforms with all the material terms and conditions of the request for bids and is the lowest in price. Vendor contracts shall include a written statement that they have not been suspended or debarred from doing business with any federal agency. Alternatively, the Organization shall check the SAM (System for Award Management) vendor database.

Have you checked your listing?

ILRU maintains directories for CIL partners — for the Centers and state associations of centers at http://www.ilru.org/projects/cil-net/cil-center-and-association-directory   and for SILCs at http://www.ilru.org/projects/silc-net/silc-directory

I am always a little surprised when I get a question from our ranks about where a center is and what the contact information is — until I look for myself. Then I sometimes find that the information in our directories is out of date.

So today I have a request for you. Please look at your state’s information in the directory, and let us know if anything needs to be changed. You can do this through the “Contact Us” tab on the website.

Our directory is well-used — by other centers, by funders, by consumers. Please help us keep it up do date. Your vattention to these details will help all of us.

Indirect Cost Questions and Answers

From https://www.doi.gov/ibc/services/finance/indirect-cost-services/faqs

Indirect Cost Services General Questions

Click here to view new Rate Options available in 2CFR Part 200

1. What is an indirect cost rate?

An indirect cost rate is a tool for determining the proportion of indirect costs each program should bear. It is the ratio (expressed as a percentage) of the indirect costs to a direct cost base.

2. What is an indirect cost pool?

The indirect cost pool is the accumulated costs that jointly benefit two or more programs or other cost objectives. Indirect cost pool expenditures typically include:

Administrative salaries and fringe benefits associated with overall financial and organizational administration;
Operation and maintenance costs for facilities and equipment; and,
Payroll and procurement services.

3. What is an indirect cost rate proposal?

An indirect cost rate proposal is the documentation prepared by an organization requesting an indirect cost rate. This package normally includes the proposal, related audited financial statements, and other detail supports such as general ledger, trial balance, etc.

4. What is a “Base” or “direct cost base”?

The term “Base” refers to the accumulated direct costs (usually (a) total direct salaries and wages with or without fringe benefits or (b) total direct costs exclusive of any extraordinary or distorting expenditures) used to distribute indirect costs to individual federal awards. The direct cost base selected should result in each award bearing a fair share of the indirect costs in reasonable relation to the benefits received from those costs.

5. What is an indirect cost negotiation agreement?

An indirect cost negotiation agreement is a document that formalizes the indirect cost rate negotiation process. This document typically contains:
The type of rate(s) negotiated;
The effective period(s) of the rate(s);
The location(s) to which the rate(s) is/are applicable; and,
The program(s) to which the rate(s) is/are applicable.
It also provides information on the base(s) used to distribute indirect costs, and the treatment of fringe benefits and paid absences.
The indirect cost negotiation agreement must be signed by both the organization‘s authorized representative and the DOI Indirect Cost Coordinator or authorized representative.

6. Is there a standard format that should be followed to compile an indirect cost proposal?

Indirect Cost Services has created sample proposal formats, checklists, and templates to assist you in completing the proposal package. Please scroll down and select the appropriate sample proposal for your type of organization (i.e., Nonprofit, tribal government, etc). Following our proposal format is not required; however, it will expedite the review process because our format contains the information needed.

7. In order to initiate the negotiation process, may we send in our Financial Statement Audit Report without the indirect cost proposal and follow-up with the proposal at a later date?

Indirect Cost Services will not initiate the negotiation process without the indirect cost proposal and supporting documentation (including the Financial Statement Audit Report). Please do not submit the audit report by itself, as we have limited storage space and cannot keep the document on file unless accompanied by an indirect cost proposal.

8. What are the different types of rates that can be negotiated?

There are four types of rates that can be requested in your proposal:
Provisional;
Final;
Predetermined; and,
Fixed (Fixed Carry-forward).

9. What is a Provisional Rate?

A Provisional rate is a temporary indirect cost rate that is applied to a limited time period that is used until a “final” rate is established for that same period. Provisional rates can be used for funding, interim reimbursement, and reporting of indirect costs on federal awards. They must be finalized by submitting an “Indirect Cost Rate Proposal for a Final Rate” once the actual costs for the specified time period are known and can be verified through audited financial statements.

10. What is a Final Rate?

A final rate is an indirect cost rate applicable to a specific time period that is based on the actual, allowable costs of that period. Once established, a final, audited rate cannot be adjusted.

11. What is a Predetermined Rate?

A predetermined rate is an indirect cost rate that applies to a specific current or future time period (usually the organization‘s fiscal year). Except under very unusual circumstances, a predetermined rate cannot be adjusted. Predetermined rates may be used with cooperative agreements and grants only. They may not be used for federal contracts due to legal constraints. Predetermined indirect cost rates may be negotiated for periods of up to 2 to 4 years.

12. What is a Fixed (Fixed Carry Forward) Rate?

A fixed rate (also known as a fixed carry forward rate) is an indirect cost rate that applies to a specific current or future time period (usually the organization‘s fiscal year). It differs from the predetermined rate in that it is subject to later adjustment. Initially, the fixed rate is based on estimated costs for a set, future time period. When the actual costs for that period become available, a carry forward adjustment is used. A carry forward adjustment is the amount required to reconcile the difference between the estimated costs and the actual costs incurred for the agreed-upon time period.

13. What typical types of distribution bases are available to calculate the indirect cost rate?

These are types of distribution bases:

  1. Modified Total Direct Costs (MTDC)
  2. Total Direct Salaries and Wages excluding Fringe Benefits (S&W)
  3. Total Direct Salaries and Wages, including Fringe Benefits (SWF)

Modified Total Direct Costs (MTDC) excludes capital expenditures and distorting items such as passthrough funds, major Subcontractors, etc. For nonprofit entities, MTDC includes the first $25,000 of sub grants/Subcontracts, while the remaining portion of Subgrants/Subcontracts over $25,000 is excluded.

14. What type of direct cost (distribution) base should my organization select?

The distribution base chosen should result in each award bearing a proportionate share of the indirect costs relative to the benefits received from those costs. For example, if several of your programs and grants do not pay salaries, then it might not be a good idea to use total salaries and wages as the direct cost base. If you do, those programs paying most of the salaries and wages would bear a larger, disproportionate share of the indirect costs. In this situation, it might be more appropriate to use modified total direct costs (exclusive of unusual or distorting expenditures). Please consult the Indirect Cost Services office if you need additional guidance.

15. What is considered adequate documentation to support the salaries and wages of personnel included in the indirect cost pool?

Federal regulations (2 CFR 225 & 230, A-87 & A-122) require that employee salaries and wages be properly documented and approved. The required documentation includes:

  1. Salary and Wage Certifications: Used when employees are expected to work on a single federal award or cost objective during the period being certified. The certifications should be:
    1. Prepared at least semi-annually and
    2. Signed by the employee or supervisory official with first-hand knowledge of the employees’ work.
  2. Personnel Activity Reports or equivalent documentation is required for employees who work on multiple activities, that is:
    1. More than one federal award or
    2. A federal and a non-federal award or
    3. An indirect and a direct cost activity or
    4. Two or more indirect activities with different cost allocation bases or
    5. An unallowable activity and a direct or indirect cost activity.
  3. Personnel Activity Reports or equivalent documentation must meet the following criteria:
    • Prepared at least monthly;
    • Signed by the employee;
    • Account for the total activity for which each employee is being compensated; and,
    • Reflect an after-the-fact distribution of the work that has actually been completed by each employee.

As the cognizant agency, we have the right to approve substitute systems for allocating salaries and wages in place of activity reports. Substitute systems may include random sampling that meets acceptable statistical sampling standards, case counts, or other quantifiable measures of employee effort. We may accept sampling that does not fully comply with sampling standards provided that the amounts involved are minimal or would result in a lower cost.

16. Should fringe benefits be allocated between direct and indirect costs?

Fringe benefits are allowable, “provided such costs are absorbed by all organization activities in proportion to the relative amount of time or effort actually devoted to each” (2 CFR 230 (A-122), Appendix B, Section 8.g. (1)).
“Whether treated as indirect or direct costs, [fringe benefits] shall be distributed to particular awards and other activities in a manner consistent with the pattern of benefits accruing to the individual or group of employees whose salaries and wages are chargeable to such awards and other activities” (Section 8.g. (2)).
Indirect Cost Services interprets the above to mean that if the position is classified as a direct position, then the salary – along with applicable fringe benefits – should also be treated as direct costs. If the position is classified as an indirect position, then the related fringe benefits are to be treated as indirect costs.

17. Are fundraising and lobbying costs allowable?

No – Federal regulations (2 CFR 225 & 230) specifically list fundraising and lobbying costs as unallowable. However, 2 CFR 230 (A-122), Appendix A, Section B.3 states, “Even though these costs are unallowable for purposes of computing charges to federal awards, they nonetheless must be treated as direct costs for purposes of determining indirect cost rates and be allocated their share of the organization‘s indirect costs if they represent activities which include the salaries of personnel, occupy space, and benefit from the organization‘s indirect costs.”
In addition, “All activities which benefit from the governmental unit‘s indirect costs, including unallowable activities and services donated to the government unit by third parties, will receive an appropriate allocation of indirect costs.” (2 CFR 225 (A-87), Appendix A, Section C.3.b)

18. Can we include all depreciation expenses in the indirect cost pool?

Yes – but only if these depreciation expenses are related to assets used by indirect-related personnel (i.e., accounting, human resources, etc.) and are purchased with non-federal dollars. Depreciation related to assets used by direct personnel should be direct-charged.

19. We submitted the proposal to Indirect Cost Services and the funding agency wants a confirmation, what should we do?

Please have the awarding official contact:

Indirect Cost Services
Phone: 916-930-3803
Email

Interior Business Center’s Indirect Cost Services will confirm receipt of the proposal.

20. Can we use the negotiated indirect cost rate for all of our federal programs?

Yes – the agreed upon rate(s) shall be accepted and made available to all federal agencies for their use unless prohibited or limited by statute. It is our understanding that state and local agencies will also accept the federally approved rate(s).

21. We have misplaced a copy of the signed negotiation agreement. How should we go about obtaining another copy?

Please fax a written request for a duplicate/replacement copy of your signed agreement to the fax number below. The request must be on your organization‘s letterhead and signed by an individual who is authorized to negotiate indirect cost rates. The Indirect Cost Services fax line number is 916-930-3803.

22. Who do we contact to obtain clarification or interpretation on the cost principles (2 CFR 225 and 2 CFR 230, formerly OMB Circulars)?

For assistance with interpretation and clarification on cost principles, please contact:
Indirect Cost Services
Phone: 916-930-3803
Email

For further clarification, you may also contact the Office of Management and Budget (OMB) directly. Please address your request to:

Mr. Gilbert Tran
Office of Federal Financial Management
Office of Management and Budget (OMB)
725 17th Street NW, Room 6026
Washington, DC 20503
Phone: 202-395-3052 (direct) / Phone: 202-395-3993 (main office)

23. Do you accept electronic submission (e-file) of indirect cost rate proposals and audited financial statements?

Yes, indirect cost rate proposals and audit financial statements can be sent by email. Please limit the number of files to no more than 3 files. These files maybe arranged like this:

File #1: Part 1 of the proposal (narrative portion) in Word or PDF format
File #2: Part 2 of the proposal (data portion) preferably in Excel format
File #3: Audited financial statements (for tribal entities, nonprofits, & local governments) in PDF format. For state entities, a copy of the general ledger in PDF format.

Hard copy of the proposal and audit report is NOT required. Submitting both the electronic copy and the hard copy will delay the processing of your proposal. The only item we required in the mail is the signed Certificate of Indirect Costs in original signature, everything else can be electronic. Our mailing address is 650 Capitol Mall, Suite 7-400, Sacramento, CA 95814.

24. What format shall I use for the electronic submission?

We accept proposals submitted in either the PDF, Word, or Excel format. Please note that if certain spreadsheets are very large and the font is very small, the PDF version may not show the figures clearly. In this case, we would ask the information to be submitted in Excel format.

25. The negotiated rate is already expired, what rate should I use?

The negotiated rate is only good for the 12-month period listed on the negotiation agreement. Whether you can continue using the expired rate is a decision that needs to be made by the awarding agency. Therefore, please contact your awarding official.

26. I am a consultant hired to prepare the entity’s indirect cost rate proposal and need a copy of the previous years’ negotiation agreement. Can you send the information to me?

Before we can release any information, we need the entity to send us a fax on letterhead authorizing our office to release the information to you. This fax needs to be signed by a representative of the entity that is either the CFO or someone in higher position.

27. I have submitted the proposal but have not heard anything yet? How do I check the status of the proposal?

You can check the status using one of the following ways:
By email
By phone: 916-930-3803

28. We are a small entity and receive less than $500,000 in federal funding thus not required to file for an A-133 single audit, what do I need to provide as support since there is no audit report?

For nonprofit entities: We need a copy of IRS Form 990. If Form 990 has not been file yet, then a copy of the profit & loss statement.
For all other entities: We need a copy of the general ledger, trial balance, or profit & loss statement that shows summarized expenditures by cost elements such as salaries, fringes, supplies, travel, etc.

29. Does Indirect Cost Services provide indirect cost training?

Depending on our workload, our office may provide formal training to a federal agency for a fee.  If you have general questions, we are available to assist you but we cannot prepare the proposal for you.  If you have general questions about our sample proposals, templates, allowability of costs, etc., you are welcome to contact our office by email or phone 916-930-3803.

So are CILs and the SILC required to get along?

In the State Plan for Independent Living section of the Act – 704 (i) — clearly requires the SPIL to include in the SPIL a plan for the cooperation between the SILC and CILs as well as others:

Sec. 704. State Plan.

(i) Cooperation, Coordination, and Working Relationships Among Various Entities. The plan shall set forth the steps that will be taken to maximize the cooperation, coordination, and working relationships among –

(1)  the Statewide Independent Living Council

(2)  centers for independent living

(3)  the designated State entity; and

(4) other State agencies or entities represented on the Council, other councils that address the needs and issues of specific disability populations, and other public and private entities determined to be appropriate by the Council.

Another pertinent reference from the law and regulations is implied every time the word “network” (which is not defined) is used; and since more than 50% of the CIL directors must sign the SPIL, is also necessary there. The SILC’s work with the CILs is found in authorities (which are optional and must be listed in the SPIL)

45 CFR §1329.16   Authorities of the SILC.

(a) The SILC may conduct the following discretionary activities, as authorized and described in the approved State Plan:

(1) Work with Centers for Independent Living to coordinate services with public and private entities to improve services provided to individuals with disabilities;

(2) Conduct resource development activities to support the activities described in the approved SPIL and/or to support the provision of independent living services by Centers for Independent Living;

Another aspect is that both the SILC and the CIL are addressed in Title VII, so they share the purpose statement that opens Title VII related to IL philosophy:

“The purpose of this chapter is to promote a philosophy of independent living, including a philosophy of consumer control, peer support, self-help, self-determination, equal access, and individual and system advocacy, in order to maximize the leadership, empowerment, independence, and productivity of individuals with disabilities, and the integration and full inclusion of individuals with disabilities into the mainstream of American society…”

Section 701 of the Rehabilitation Act of 1973, as amended

Are Electronic Signatures Allowed?

Note: Updated after initial post with additional information.

Question: Do the feds provide any instruction on keeping paper files versus digital records? I am asking this question because we are currently working on organizing files across our locations. I believe the feds require that we have paper copies of documents that require signatures but am not positive they forbid us from keeping them in digital format instead. And, what about other documents that end up in consumer files? Can we scan and store them in digital format or must they be on paper and in the consumer file.

Answer: This requirement is actually part of Uniform Administration Requirements, and now does allow electronic signatures or scanned documents for files. However, ILA/ACL hasn’t actually done any reviews under these regulations, so we are not certain they will agree. On the other hand, the review protocol being developed starts with a paper review, so we should know shortly. I have interpreted the regulation to mean that you can either scan and store actual signatures in digital format, and that you can use one of the electronic signature processes as well. Here is the reference:

§75.363   Methods for collection, transmission and storage of information.

In accordance with the May 2013 Executive Order on Making Open and Machine readable the New Default for Government Information, the HHS awarding agency and the non-Federal entity should, whenever practicable, collect, transmit, and store Federal award-related information in open and machine readable formats rather than in closed formats or on paper.

The context for this is financial records, but it references all Federal award-related information.

To be on the safe side, though, you may want to keep original documents signed by the consumer in a paper file, and scan the others into an electronic file. Make sure that your own policies and procedures match the practice you decide on.