Hi, my name is Paula and I provide technical assistance to centers, SILCs and DSEs nationally, focusing on the law, regulations and guidance that we are required to meet. Over the course of a year I answer hundreds of questions from staff and board at centers and SILCs, and from your DSEs. Most of these are in email. Even when we talk by phone, I often send a follow-up email. And when that email refers to a regulation, I provide you with the citation and even often say “Feel free to forward this email to others discussing this.”
Yesterday I had a disconcerting experience. A SILC council member called to ask if I had said something, saying that another person in the meeting left the room and when she returned, said she had talked with me, and then told the group what I had said in answer to the question at hand.
Except she didn’t call me. I keep notes, and I checked to see if perhaps she had called at an earlier time. She hadn’t. This person typically contacts me by email, and at the meeting in question it had been four months since we had email correspondence. (Yes, I keep that, too.) I know most of you are too ethical to outright lie — but you may hear my response through your own filters. If I don’t provide it, ask for it in writing so you have the references and clarity in front of you.
If someone tells you I said something, they may be accurate — or they may not. It is okay to ask to see the email correspondence. In another instance I heard from a council member, who asked a very specific question, and I gave a specific reply. Later he came back to me with SILC staff and the rest of the story — and that shifted the answer because the situation was different than what he supplied initially.
You may have heard me say this, but the first answer to almost any question is, “It depends.” State laws, multiple funding sources and your own bylaws and policies and procedures can impact how you must respond to a certain situation.
At the end of the day, though, what I provide to you is the best information we have available at that point in time. It is only accurate to the extent that we have all the facts at hand, and until something changes in the guidance we get from our key funder, ACL/ILA. While I research the law and regulations to decide what I say, it is my opinion and my own filters can affect my opinion. To read the regulations for yourself, here are the main references I use:
- The Rehabilitation Act as amended by WIOA
- The Independent Living regulations from 45 CFR 1329
- The Uniform Administrative Requirements for financial regulations
- Written guidance from ACL