Question from a SILC: Are the CIL’s considered a sub-recipient? Because I see where I should maintain the following on a sub-recipient. Is this a correct list that ensures they are eligible to participate in the SPIL?
- Articles of Incorporation
- Bylaws or other governing documents
- Determination letter from the IRS (recognizing the sub-recipient as exempt from income taxes under IRC section 501(c)(3))
- Last three years’ Forms 990 or 990-EZ, including all supporting schedules and attachments (also Form 990-T, if applicable)
- Copy of the most recent internally prepared financial statements and current budget
Reply: Actually the SILC and the Subchapter (Part) B funded centers are all subrecipients of the Designated State Entity (DSE), which receives the Subchapter B grant directly. The SILC doesn’t collect those items from CILs. That is up to the DSE. All CILs are supposed to share their Program Progress Report with the SILC, and the Subchapter B centers and DSE to work with the SILC on the report for how Subchapter B funds were used.
Subchapter (Part) C centers are direct recipients of their grants so do not fall under the category of “sub-recipient”.
If a center receives Subchapter (Part) B or C money we already know that the CIL is private, non-profit, community based, non-residential and consumer controlled. Therefore Subchapter (Part) B and C recipients of IL money are entities that sign the SPIL. An approved SPIL requires more than half the CILs sign to approve the SPIL. A center that receives both Subchapter B and C or has more than one C grant still only signs once. If another non-profit claims to be a CIL, you would ask for evidence that they meet the criteria of private, non-profit, community based, non-residential , cross-disability and consumer controlled and provide all the required core services.