Whether or not your SILC is a 501(c)(3) entity, you need written policies and procedures to guide how you do business.
Let’s take a moment to highlight the first of the Statewide Independent Living Council Indicators*, which is all about policies. (We will review the rest of the indicators, along with SILC and DSE Assurances, in later posts.)
These are indicators of minimum compliance for SILCs, and are an expansion of the content of Title VII of the Rehabilitation Act and regulations. Indicator #1 is that the SILC have written policies and procedures in a number of areas. Here is a list:
a. A method for recruiting members, reviewing applications, and regularly providing recommendations for eligible appointments to the appointing authority.
b. A method for identifying and resolving actual or potential disputes and conflicts of interest that are in compliance with State and federal law;
c. A process to hold public meetings and meet regularly as prescribed in 45 CFR 1329.15(a)(3)
d. A process and timelines for advance notice to the public of SILC meetings in compliance with State and federal law and 45 CFR 1329.15(3);
e. A process and timeline for advance notice to the public for SILC “Executive Session” meetings, that are closed to the public, that follow applicable federal and State laws;
i. “Executive Session” meetings should be rare and only take place to discuss confidential SILC issues such as but not limited to staffing.
ii. Agendas for “Executive Session” meetings must be made available to the public, although personal identifiable information regarding SILC staff shall not be included;
f. A process and timelines for the public to request reasonable accommodations to participate during a public Council meeting;
g. A method for developing, seeking and incorporating public input into, monitoring, reviewing and evaluating implementation of the State Plan as required in 45 CFR 1329.17; and
h. A process to verify centers for independent living are eligible to sign the State Plan in compliance with 45 CFR 1329.17(d)(2)(iii).
If you don’t have all these policies, you need to develop them or borrow them from a SILC that has them. Typically the Council approves all the policies and procedures. These areas are in addition to our recommended financial policies and procedures.
Join us next week for a discussion of the open meetings portion of this specifically.
*Statewide Independent Living Council (SILC) indicators of minimum compliance, required by WIOA, and assurances — for both the SILCs and the Designated State Entities (DSEs) — were sent from the Independent Living Administration to SILCs and DSEs. While the effective date has not yet been determined, ILA will be consulting with the network to develop a plan on setting effective dates for both the indicators and assurances. You can download the full text at http://www.ilru.org/federal-guidance-il-program, and click on “SILC Indicators and Assurances for the Designated State Entities” to open the document.
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