Tips for bringing a new CIL ED on board

I would probably customize a training plan based on what the new executive director already knows. If s/he has worked for a center in the past, s/he may not need history and philosophy but might need board and finance training. There is training for almost every item in the E.D.’s job description. You can search the website for a topic, or contact me and I will help you find what you are looking for. I like everything to be in the context of philosophy so I have included that.

 The Rapid Course on history and philosophy is three parts and found at http://www.ilru.org/training/foundations-independent-living-series or if they don’t love that read and test format, the short films at http://www.ilru.org/il-history-and-philosophy-orientation-for-il-staff are great.

The financial management workshop (15 hours) at http://www.ilru.org/training/financial-management-workshop-for-cils-regulations-and-beyond is great for financial regulations. The topics are broken down so the person can watch what is the most useful, in any order.

For the IL regs, the first item on this page. http://www.ilru.org/training/20th-annual-silc-congress-path-forward-greater-independence

For board recruitment, http://www.ilru.org/training/attract-and-retain-your-best-cil-board-members

I also suggest searching Board Cafe and Non-profit management for board related training as well. There is a lot out there in the mainstream that is useful.

There is also a monthly call for new executive directors. Be sure to let me know so I can sign them up for that call.

 How is that for starters? A new E.D. can request anything specific from me any time so make sure they have my name and number. 

Are Resource Development Costs direct or indirect?

First a refresher — while fund raising costs are not typically allowed with federal dollars, the Rehabilitation Act specifically requires centers, and allows SILCs, to conduct Resource Development.  Rule number one, always call your activities to increase your resources (including funds) Resource Development. If you are a SILC this must be addressed in your State Plan for Independent Living.

Rule number two — it is wise to identify and track these costs separately. We suggest this because it is easy to spend more than you bring in if this office is not effective, and you want to know that so you can improve your efficiency if needed.

If you have a separate cost center for resource development, treating it as a direct cost, it must include that cost center’s fair share of the indirect costs based on your indirect cost rate proposal.

Some of you included resource development totally as an indirect cost. If so, then the answer to the question is that resource development costs are indirect, and should be allocated back across your cost objectives.

So, as is so often the case, the answer to our question is “It depends.” And it depends on what you said you would do in your approved indirect cost proposal.

Who can we count in Peer Support or other group classes?

Question: I have a question about peer support groups or groups where we teach IL skills. For example, a small group where consumers can connect with one another or learn about resources (e.g., housing), or teaching skills such as money management. These are not community outreach services, but consumer groups. It was my understanding that people attending these groups would need to be consumers of our center and have a CSR. I’ve recently been told this is not the case and those groups can be open to anyone in the community who wants to attend. We are starting to increase the number and type of groups we offer and I want to confirm this as this has implications on how we move forward.

There is not a prohibition or a requirement around who can attend, but there is regarding who “counts”.  The answer varies based how you want to count them. You need to set up the structure for your groups in your policies and procedures, and centers vary greatly on how they treat this.

I like to see people with disabilities, with or without a Consumer Service Record, attend events and be part of the disability community that gathers at a center, so that is my bias.

To count the individual as receiving peer support or independent living skills training they do need a goal (which can be a goal set by and accepted by the group) and a CSR. But there is no prohibition to others attending and “auditing” the group, so to speak. You can’t count them as receiving the core service on your Program Progress Report, but they enhance the overall involvement of the disability community. They might be some of the peers offering support, even if they don’t have a goal to receive it.

If you have folks that dominate meetings and exclude others – then you might want or need a policy to help the meeting include everyone. One approach could be to only have folks attend who have CSRs.

For SILCs – How to request a technical amendment

ACL/ILA has asked the SILCs to either extend or amend their State Plan for Independent Living (SPIL) as we go into the new planning cycle. This most recent guidance allows for time to complete the review and acceptance process for a new SILC template, to be used in 2020 for the next three year cycle of your plan. The “state project officer” for all SILCs is Regina Blye. Her contact information is Regina.Blye@acl.hhs.gov Here are excerpts from the announcement letter which specifically tell you how to do a technical amendment — an amendment that doesn’t change the plan substantially, doesn’t change the Designated State Entity (DSE) and will carry your forward for the next year.

(Page 3) Required steps for a technical amendment to a SPIL are (in the following order):

 A written statement to ILA, via the state project officer, requesting a technical amendment to the FY2017–2019 SPIL.

  1. Submit an approvable SPIL amendment request that includes all required signatures to your project officer no later than July 31, 2019 (to allow adequate time for the PO to complete the SPIL amendment process before expiration of the current SPIL in effect on September 30, 2019).

 Amendments must be signed by three parties: the chair of the SILC, acting on behalf of and at the direction of the SILC; not less than 51 percent of the directors of the Centers in the state; and the director of the DSE.

(Page 4) Important information about these options

ACL strongly recommends you communicate the state’s intention to your state project officer by May 1, 2019. All requests and attachments for the SPIL amendment process should be submitted in accessible PDF formats or as Word documents.  The assigned state project officer will make amendments to the SPIL on behalf of each state.  A revised SPIL will be provided back to the state upon completion, no later than September 29, 2019. 

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.