What about prior approval for equipment or upgrades?

The Uniform Administrative Requirements found in the Code of Regulations (45 CFR 75) are the reference for questions related to how you handle things financially with federal grants. With the influx of CARES Act funds, some of you are considering capital improvements in order to have the phone system or server necessary for remote work, or other upgrades such as cables and wiring that might be required for these things. My understanding — based on what is below — is that if these costs exceed $5,000 you must secure prior approval from ACL/OILP. Be sure to contact your Program Officer about these expenses.

45 CFR § 75.439 Equipment and other capital expenditures.

(a) See § 75.2 for the definitions of Capital expenditures, Equipment, Special purpose equipment, General purpose equipment, Acquisition cost, and Capital assets.

(b) The following rules of allowability must apply to equipment and other capital expenditures:

(1) Capital expenditures for general purpose equipment, buildings, and land are unallowable as direct charges, except with the prior written approval of the HHS awarding agency or pass-through entity.

(2) Capital expenditures for special purpose equipment are allowable as direct costs, provided that items with a unit cost of $5,000 or more have the prior written approval of the HHS awarding agency or pass-through entity.

(3) Capital expenditures for improvements to land, buildings, or equipment which materially increase their value or useful life are unallowable as a direct cost except with the prior written approval of the HHS awarding agency, or pass-through entity. See § 75.436 for rules on the allowability of depreciation on buildings, capital improvements, and equipment. See also § 75.465.

(4) When approved as a direct charge pursuant to paragraphs (b)(1) through (3) of this section, capital expenditures will be charged in the period in which the expenditure is incurred, or as otherwise determined appropriate and negotiated with the HHS awarding agency.

(5) The unamortized portion of any equipment written off as a result of a change in capitalization levels may be recovered by continuing to claim the otherwise allowable depreciation on the equipment, or by amortizing the amount to be written off over a period of years negotiated with the Federal cognizant agency for indirect cost.

(6) Cost of equipment disposal. If the non-Federal entity is instructed by the HHS awarding agency to otherwise dispose of or transfer the equipment the costs of such disposal or transfer are allowable.

(7) Equipment and other capital expenditures are unallowable as indirect costs. See § 75.436. [79 FR 75889, Dec. 19, 2014, as amended at 81 FR 3018, Jan. 20, 2016]

As you purchase with federal funds…

With the influx of the CARES Act funds to Part C centers, you have been purchasing personal protective equipment, food, technology, internet or delivery services and more. Are you following your own procurement policies? And do they fall within the federal requirements? Let’s take a look.

First, why was a purchase COVID-19 related and why was it necessary? For example, did you upgrade your server or other internet or computer resources? Was that necessary for capacity for everyone working from home? Describe what was needed and how the purchase met that need.

Second, all of your costs must be reasonable, and you must document this by capturing similar costs from other venders and/or by making a case for the reason you are making the specific purchase. Often the rationale for “reasonable and necessary” is stated together.

Next, make sure your procurement policies are equal to or less than the limits for each area found in the federal regulations. It may make sense to use the federal terms and definitions in your financial policies and procedures. The first of those categories — the level where you use a simple purchasing process of approval without price comparisons* or bids — is call “micro-purchase” and applies to any purchase of supplies or services, in aggregate, that are under the threshold of $10,000. “In aggregate” means that you would be able to apply this simpler approval method only if all the purchases for that vendor for the year, when added together, are still under this threshold. To the extent practicable, you should distribute micro-purchases equitably among qualified suppliers. Micro-purchases may be awarded without soliciting competitive quotations if you consider the price to be reasonable

The category called “small purchase” applies to purchases over $10,000 and less than $250,000 . Small purchase procedures are those relatively simple and informal procurement methods for securing services, supplies, or other property that do not cost more than the Simplified Acquisition Threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources. Note, however, that theses are not necessarily formal bids. You can check prices by email or phone, or use posted prices on the internet, as long as you document your process assures that purchases are reasonable.

Above the small purchase amount of $250,000 you must secure sealed bids with formal advertising. There are a lot of requirements for that level of purchase, but I doubt the CARES Act funds will be sufficient to make purchases at this level. Refer to 45 CFR 75.329 for more details. Other considerations when purchasing include:

  • Contracting with small and minority businesses, women’s business enterprises and labor surplus area firms.
  • Following the executive order to “Buy American, Hire American”
  • Assure there is no conflict of interest related to the purchasing of goods or services.
  • Getting prior approval from ACL on equipment costs in excess of $5,000.

*I still recommend price comparisons to show reasonableness.

URGENT: Calling all Part C Centers

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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?

A follow up question on policies supporting your CARES Act decisions

The questions started as soon as the money did. ACL has published a comprehensive Frequently Asked Questions document that covers most of them. If you go to our site it is an alphabetical list of resources under ACL FAQs. Everything in this post is based on that document and the federal regulations found in 45 CFR 75.

Three ring binder labeled Policies, and a pen and paper.

Q: We’re reaching out for clarification on part of the FAQs for the CARES Act funding.  Under Question 8, it says policies and procedures need to be updated by May 31, 2020.  Does this only apply to expenditures that we choose to cover retroactively back to our state of emergency date or to all expenditures through September 30, 2021?  We want to plan appropriately, and since the current COVID-19 landscape is very fluid, we envision needing to update policies throughout the next year, in advance of expenditures, as necessary adaptations are made to how the CARES Act funds are used. 

A: Note this language at the end of Question 8:
“Due to the unprecedented nature of the COVID-19 pandemic, ACL understands that CILs may not have had all the policies and procedures in place that would address current and unusual circumstances.  CILs should actively develop and/or update their policies and procedures as necessary and have them in place no later than May 31, 2020. Policies and procedures may be made effective retroactive to January 20, 2020. “ (Emphasis mine.)

I think this recognizes that you may have been required to react very quickly due to shut downs by your state, and may have acted outside your written policies and procedures. This FAQ grants you a grace period to go back and update your policies to address any costs that weren’t clearly allowed, or to adjust approval procedures to match what you were required to do in these unusual circumstances. My read is that you can make sure you didn’t violate any of your own policies and procedures by modifying them now, to be retroactive to a date earlier than most centers closed their offices to the public. My first step would be to re-read all your policies to verify you followed them or identify when you did not. When you are reviewed for compliance, you will need to show that you followed your own policies and procedures. Examine your policies with that in mind, reviewing them regularly. And just this once, you can make them effective retroactively.

It seems likely that some of these new or revised policies will be related to the state of emergency. If you write them that way, they will be in place during any emergency, not just this one, and would be in force until your board chooses to change them. Yes, you may need to continue to update your policies and procedures – I suggest that at the end of each you carry a list of revision dates so that you also track how fluid the situation is. As far as we are aware, though, this is the only time that you can adjust policies retroactively. Be sure you take advantage of this opportunity to check your actions against your own policies and procedures.

Can I give staff more pay using CARES Act funds?

While the correct answer is “it depends”, my more honest reaction to this question is, “Do you think that is the intention of this funding?”

Because, first and foremost, the funding is for the purpose of assisting your consumers — people with a significant disability who approach you for aid and are enrolled in services — with a direct response to the COVID-19 pandemic. Read the FAQ on this topic carefully. The funds “must be focused on responding to needs that are the result of the COVID-19 pandemic.” These new dollars are not intended as a way for you to pay for your wish list. I have no doubt that we all wish we could pay staff more, but we know that this is one-time money, intended to assist people in crisis, and won’t sustain raises all around.

So I have received questions about bonuses and hazard pay. Here is another quote from the FAQ: “CILs are encouraged to have policies in place that adequately support hazard pay decisions including ensuring policies are fair and equitable across the agency.” Typically you are required to have these policies in place before any incentive or bonus or other special pay is invoked. Spontaneous bonuses have never been allowed. Rather you are expected to have a plan in place that everyone is aware of, and staff may choose to meet the requirements for the extra pay or not. Here is what Uniform Guidance says:

45 CFR  75.430 Compensation—personal services. (f) Incentive compensation. Incentive compensation to employees based on cost reduction, or efficient performance, suggestion awards, safety awards, etc., is allowable to the extent that the overall compensation is determined to be reasonable and such costs are paid or accrued pursuant to an agreement entered into in good faith between the non-Federal entity and the employees before the services were rendered, or pursuant to an established plan followed by the non-Federal entity so consistently as to imply, in effect, an agreement to make such payment.

As you can see in (f) Incentive compensation may be allowable if it meets the test of reasonable and if there was an “agreement entered into in good faith” with the employees in advance, before the service was rendered. This agreement would not necessarily be in writing, although an approved policy and procedure would be the typical way to agree in advance to such an item. An “established plan” would also typically be in either the budget or in policy or in some other way documented IN ADVANCE of the expenditure being made.  Hazardous pay seems to fit this category. Let’s look at the FAQ again:

“Not all work being done during current stay-at-home orders is considered hazardous. Hazard pay means that employees are paid additional wages for performing hazardous duty or work involving physical hardship, including exposure and potential exposure to the COVID-19 virus. Work duty that requires this hardship that is not adequately alleviated by alternative stations or protective devices are deemed to impose a physical hardship. It is possible and likely that an employee may have some hours that are worked in a hazardous condition and others that are not.”

I suggest that you approach any additional pay to employees very, very carefully. If I were in your shoes, I don’t think I would feel right about giving or taking extra pay.

I suggest caution because, when these funds are audited, I personally think one big red flag will be how much of your CARES Act allotment was used to pay current staff.

CARES Act funds for Part C centers — Spend wisely

The CARES Act funds for COVID-19 relief became available to Part C centers this past week. I would like to suggest some things to think about before you begin spending. If you plan well, your reporting and documentation will be more complete. These steps will not delay very long, but will help make sure your center is following guidance from ACL and good practices as you work on COVID-19 relief with these funds. Refer first to the FAQ. It is your bible re: what is allowable. I have expanded with some of my personal suggestions as you implement the FAQ and begin getting support out to your community.

  • Make sure your accounting system is set up to keep these funds separate and to maintain records so that you can justify expenses. If an expense is non-allowable under Part C, it is not allowable under these new funds. If it is allowable with Part C funds, it is allowable here as long as all expenses are reasonable and necessary and meet the requirements of 45 CFR 75. You have the responsibility to document how they are reasonable and necessary.
  • CARES Act activities should align with the CIL CARES Act FAQ guidance.  Most importantly, records should always clearly differentiate a Part C expense from a CARES Act expense. 
  • You must use procurement policies and procedures that agree with 45 CFR 75. These should already be in place for your Part C and other federal funding. Procurement levels and approvals in regulations are the same, and you should follow your current policies unless you the approval levels are less than what is required in federal regulations and you feel they might delay essential emergency support. In that case you must update your policies and procedures no later than May 31, 2020 and can backdate them to January 20, 2020.
  • Develop or update any policies and procedures related to paid disaster leave for staff and make sure the board approves them before you take any action. The policy must be approved and in place by May 31, or you will not be able to spend any of these funds on paid leave. If your policy is in place you can backdate to January 20 or the day you began responding to the COVID 19 crisis. Again, these payments must be reasonable and necessary.
  • Never forget that the CARES Act funds are for the COVID-19 response only. Again, refer to the CIL CARES Act FAQ if you have questions.  Whether or not you can use CARES Act funds to pay of a line of credit, buy a bunch of office furniture or in any way use the funds for regular operations depends heavily on whether or not any of these examples have a direct tie to the COVID-19 pandemic.
  • If your staff need additional equipment or other capacity to provide services remotely, address that need with these funds. Make sure they have the technology to contact and work with consumers from home. We suggest a specific policy/procedure on working remotely if you don’t already have one in place.
  • Develop or at least review any intake policies, and make any changes needed. Any direct support to individuals requires that they be consumers. You may also want to add an income criteria to make sure this support goes to those who need it most.
  • While  personal support – personal protective equipment, life-sustaining food, rent — may be allowed, some other things are also required. Any individual assisted must be a consumer, and if they are not already a consumer, must go through whatever intake process you use, including affirming a significant disability, agreeing to or waiving an IL plan, and having an established, measurable goal or goals. During this intake process you will learn if there are other needs that might be addressed. All support with CARES Act funds MUST be directly related to COVID-19.
  • Be strategic and when possible, utilize other resources. This is not a requirement – in fact, there are very likely life critical situations where waiting to facilitate other resources would fail to meet the immediate need for health and safety for the consumer. You do need to be aware of the current resources available through the local food bank, for example. Some business owners may be eligible for other support. In some states there is rent or mortgage protection or relief. Most people have received a personal stimulus check. Assist people with disabilities in gaining equal access to other benefits available, but first and foremost assist with the immediate and life critical needs.
  • You need an internal criteria – an approved, written policy — for determining who gets direct support of some kind. The support must clearly be directly related to the COVID-19 efforts. Your criteria for who gets direct financial aid might be income based, or some other determination such as  eligibility for SSI (no more than $2000 in the bank, low income). Whatever criteria you develop, it must be applied to all beneficiaries following your written and approved policy and procedures.
  • Typically staff and board would not be eligible as this direct cash aid may result in a conflict of interest. The CIL should have concrete policies and procedures in place to assure a conflict of interest does not occur. In other words, your policy should address how you assure that board or staff receive services in the same way as others; the steps to assure this lack of favoritism should be documented.

We will continue to discuss these issues as the next months unfold. Hopefully these tips will give you a strong and effective start to providing services through the CARES Act Funds to benefit the disability community.

Improve Your Ability to Work Remotely

As many of you have already discovered, working from home requires some upgrades in both hardware and software. Staff used to desktops are moving to laptops or tablets. Working with cloud-based documents or your consumer database may be new to you. Here are some resources for your consideration (brought to you by Tech Soup) through techsoup.org.

Tech Soup is offering charitable nonprofits 10 free licenses to Microsoft 365 Business-$5 monthly for additional users ($12.50 monthly for each license for the business world). Having the same version of Microsoft across all your devices may be useful. Having the latest version of Microsoft Teams and other cloud applications can really help remote workers who need to collaborate regularly.

Microsoft 365 includes the collaboration tool Teams (a bit like Zoom but more secure and more sharing capabilities) and additional cloud and mobile applications.

This will allow you to compose, edit and share documents in the various Microsoft formats such as Word Excel and PowerPoint.

Security updates are automatic, and employee’s devices can be remotely updated.

This version of Microsoft allows up to 300 licenses.  There are costlier enterprise versions but this version will serve most CILs and SILCs.

Each license allows a user to install Microsoft 365 Business on up to 5 devices – PCs, Macs, tablets, and smartphones.

The business version includes 1 TB (a lot) of file storage with Microsoft One Drive for Business.  There are also social and video sites, a scheduling app, a customer manager, Mile IQ-a really neat business versus personal travel calculator, and invoicing.

Techsoup is also providing a “Microsoft Cloud Starter Kit” subscription for $3 per user monthly.  This includes setup of your Microsoft 365 with help from their consultants, training courses and ongoing support including unlimited calls for support, help and questions.

When we get back to normal, it won’t be the normal we knew.  Some changes will be permanent.  This is the time to take advantage of technology and support that is being offered.

Program Income and COVID-19

Does income we generate from a program need to be used to reduce federal costs?

HHS regulations section 75.307 address how program income must be used.

The default for use of program income, earned during the period of performance, is to deduct it from total allowable cost to determine the net allowable costs. This reduces your Federal award.

Program income earned after the period of performance is not subject to federal requirements and may be used in any appropriate way (unless the HHS awarding agency regulations or the terms of the grant/award provide otherwise).

However, with the prior approval of your HHS awarding agency, program income may be added to the Federal award and used for similar purposes, allowing you to expand your program.

If you have any cost sharing or matching requirements, and you have prior approval of your HHS awarding agency, you may use program income to meet your cost-sharing or matching requirement.

The guidance for program income clarifies that the sale of property, equipment, or supplies purchased for the program are not considered program income. Agencies are required to obtain written approval from HHS about the proper procedure which may include retaining the property, selling the property, or transferring the property, and offsetting allowable costs.

And we had clients asking about the new contribution rules so I prepared this

Contribution Provisions of the CARES Act

The CARES Act added a few provisions to help charitable organizations including:

Individual Contributions

A personal deduction against income for up to a $300 monetary contribution to charitable organizations by individuals who do not itemize.  This does not apply to in-kind contributions.  It also does not apply to contributions to non-operating private foundations, supporting organizations, or donor advised funds. 

The regular contribution rules apply including the requirement to have written documentation for individual contributions of $250 or more.  Refer to IRS publication 1771.

Another benefit for individual donors is the ability to deduct 100% of their adjusted gross income in charitable contributions.  This applies for 2020 only.  Historically the limit was 50% and it was recently increased to 60%.  Now for a limited time only, it is increased to 100%.

Corporate Contributions

Before the CARES Act, corporate contributions were limited to 10% of pretax profits.  Charitable contributions of food were limited to 15%. 

For 2020 only, both of these limits have been increased to 25%.  As in the past, excess contributions can be carried forward to future years.

John F Heveron, Jr. Principal, Heveron and Company CPAs

Are you taking notes?

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We are experiencing a unique event — a world-wide pandemic. Much of our country has shut down (although my inbox indicates some CIL executive directors seem to have time right now to update policies, to think about planning, to do things they haven’t had time to do typically).

We have all discovered that our past disaster planning was too focused on the immediate events — evacuation mostly — and not the longer term. Here we are, weeks into social isolation and we have learned some things.

Have you learned what was missing in your ability to be productive away from the office? Some of you had to purchase equipment because what you had wasn’t portable. Some learned how to forward calls to staff cell phones without giving out personal numbers. You discovered how to manage remote access to key files. You have streamlined your intake process because it didn’t make sense in the new reality. You’ve learned whether or not staff can get any work done when they are also in charge of child care, or when their anxiety disability kicks into full gear. You have also learned who doesn’t have good access to electronic communication or even basic phone access.

Have you taken time to think about these discoveries? Stop today and write them down, because you will want to review your emergency policies and procedures after we return to whatever normal will be in the post-COVID days. Ask yourself:

  • Do you need to invest further in portable equipment? Can staff work from tablets or phones, or are laptops needed to work remotely?
  • Can confidentiality be maintained when staff work from home? What are the challenges that need to be addressed for the privacy of consumers?
  • Do you want staff to have remote access to consumer records?
  • Do you think staff should use their own equipment (phone, computer) for at-home work? What about wireless accounts or internet access?
  • How often do staff need to meet — virtually or in person — for lines of communication to be maintained?
  • Are small one or two person offices needed or could those staff work from home?
  • How can staff be held accountable for really working when they are out of sight?
  • Did you find that you could shift thinking from seeing people work to expecting specific tasks to be completed?
  • What about consumers? Do you have an advocacy role in assuring more equal access to communication for the people you serve?

Planning is one of the creative things you can do in this break from the office. Do it now before the press of “getting back to normal” sweeps us.

Is your CIL providing services from behind closed doors?

I know that some of you have been working remotely for a week, some for as long as three weeks, and others are just entering social isolation as the COVID-19 moves and grows. We now have another 30 days of social distancing ahead of all of us.

Frankly, we have never seen anything quite like this, affecting all of the CILs at the same time. Some of us have closed doors temporarily in the past, in a hurricane or blizzard or fire, but only one center at a time. With all of us impacted at roughly the same time, this is an opportunity to share strategies with each other. So here are a few questions to prompt discussion.

How are you continuing services to consumers and still socially isolating? Your federal grants expect you to continue to be available as the disability community works its way through this crisis. Some centers have the technology to forward all incoming calls from the CIL to a staff person, who in turn forwards messages to all the staff. Centers that don’t have that capability may have staff going into the office. The challenge there is to keep the office free of any contamination, which means a thorough cleaning of any spaces used, at the end of every shift. Most are not providing face to face services, but are finding other ways to assist consumers through this crisis.

Do you know that your consumers are safe and that they have what they need to shelter in place for the next month? Centers around the country are checking in with consumers any way that they can. Some are using a wellness checklist to make sure that they ask some of the urgent questions:

  • How do you feel? Do you have a way to check your temperature? Are you coughing? (You are not diagnosing, but are assisting with knowing if the individual should talk to their doctor.)
  • Do you have food? For how many meals?
  • Do you have medication for at least 30 days?
  • Are there other supplies you are out of?
  • Are you practicing social distancing? Staying home?

Whatever IL skills the person has, these are stressful times which demand some new skills. As you discover what each person needs, you can assist them in learning about your community resources. Some on-line resources will ship direct to your home. Amazon, Costco, Sam’s are just a few. Many pharmacies will mail prescription refills as well. Most restaurants and some grocery stores are delivering directly or through a delivery service. You should note what the choices are for your community and be ready to assist the person in connecting with these services so that they can stay safe at home.

What is your center doing to address this crisis with the people you serve. Please share your ideas here. If you aren’t subscribed to ILRU’s newsletter, go to ILRU.com and subscribe so you receive regular updates from funders and other centers related to the responses to COVID-19.