We had a recent inquiry about the difference between at “satellite” and a “branch” center. Back in 2002 the Rehabilitation Services Administration produced a policy direction around the term “Satellite” for Centers for Independent Living.
The principle point of the directive from the former department overseeing IL grants, RSA, was that each center funded is a separate center. The centers with one board can refer to the second center as a branch of the first one but it is still a separate center from the funder’s perspective. They do not recognize “satellites”. Individual states may treat this differently with their SPIL and Part B funds, but at the federal level each Part C grant is its own center. The old directive states, in part, that:
There are two circumstances under which an existing CIL can expand by opening another office. First, a CIL can open an additional office located in and serving the center’s geographical service area, which is defined in the CIL’s application for funding. However, if an existing center opens an additional office in the geographical service area, the level of funding that the CIL receives cannot be increased in order to support the additional office because the service area is the same. Second, an existing CIL also can open an office that provides services outside the defined geographical service area specified in its grants. However, it may receive additional funds to do so only if the center successfully competes for the new funds through the procedures for establishing a new center under part C of title VII.1 According to section 366.2(b)(2), an applicant is eligible to apply as a new CIL if it proposes the expansion of an existing center through the establishment of a separate and complete center (except that the governing board of the existing center may serve as the governing board of the new center) at a different geographical location. . .
Section 366.22(a)(1) clearly states that this type of “satellite office” of an existing center is a new center rather than an existing center. Any funds received by an existing center to establish a new center at a different geographical location . . . are not included in determining the level of funding to the existing center . . .
Thus, an existing center may establish a “satellite office” that serves a different geographical area. However, the “satellite office” can use part C funds only if it applies for and receives the funds as a separate center. This is true even if the same recipient operates both centers.
If your center is able to have sufficient fund development to add offices or satellites, you need to make sure that you are following the rules for program income. If you raise the money with Part C resources — staff, office space, equipment, etc. — then the money raised has to follow the same requirements as the federal grant that paid for it. In other words, your Part C grant area and and other specifications will apply to the funds developed with those resources.
And if ACL informs us of a change in this interpretation, we will let you know!
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