When your SILC accepts funds you agree to a set of assurances. You make a promise that you will do some specific things. We suggest that, whenever it fits, these promises be worked into your written policies and procedures. Sometimes you will tailor that policy to say more about your actual practice. For example, the first of the assurances is that you will meet regularly with the appointing authority in your state with recommendations for actual nominees to the council. How do you approach this? Do you assist people with getting and completing the application to serve on the SILC? Do you meet with the authority annually or quarterly? Do you keep a checklist or grid to indicate term limits and positions filled (like areas of the state)?
We suggest you expand your written policies and procedures further, and address these new assurances:
- The SILC regularly (not less than annually) provides the appointing authority recommendations for eligible appointments;
- The SILC is composed of the requisite members set forth in the Act (Sec. 705(b)(2), 29 U.S.C. Sec. 796 (b)(2));
- The SILC terms of appointment adhere to the Act (Sec. 705(b)(6), 29 U.S.C Sec 796(b)(6));
- The SILC is not established as an entity within a State agency in accordance with 45 CFR Sec. 1329.14(b);
- The SILC will make the determination of whether it wants to utilize DSE staff to carry out the functions of the SILC;
- The SILC must inform the DSE if it chooses to utilize DSE staff;
- The SILC assumes management and responsibility of such staff with regard to activities and functions performed for the SILC in accordance with the Act (Sec. 705(e)(3), 29 U.S.C. 796(e)(3)).
- The SILC shall ensure all program activities are accessible to people with disabilities;
- The State Plan shall provide assurances that the designated State entity, any other agency, office, or entity of the State will not interfere with operations of the SILC, except as provided by law and regulation and;
- The SILC actively consults with unserved and underserved populations in urban and rural areas that include, indigenous populations as appropriate for State Plan development as described in Sec. 713 (b)(7) the Act regarding Authorized Uses of Funds (29 U.S.C. Sec. 796e-2(b)(7)).
*Statewide Independent Living Council (SILC) indicators of minimum compliance, required by WIOA, and assurances — applicable to both the SILCs and the Designated State Entities (DSEs) — were sent from the Independent Living Administration to SILCs and DSEs in late September, 2017. 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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