The Office of Independent Living Programs, our funder, has begun its required reviews of Subchapter C Centers. They first tested the desk or document review process with volunteer centers. Last week they conducted several on-site reviews in Michigan — the first on-site reviews since 2014. They intend to move forward with additional reviews throughout the year, and have released their review process and tools for all to see.

So are you ready for this review? What tools do you need to get ready?

We advise all CILs to evaluate for themselves whether they are in compliance with the law and regulations that apply. A great way to conduct this self-evaluation is to use the review tools and apply them for yourself. You can find a description of the process and the forms that reviewers are using at https://acl.gov/programs/il-comp

There is a right way and a wrong way to conduct this self-evaluation. Don’t sit everyone down around a table and go through the instrument asking, “Are we doing this?” while you check things off the list. If you are reviewed, the reviewers won’t just ask you questions. They will ask you to show, not tell, how you are in compliance. They will follow up with others to see what is actually being done.

Take the time to review the instrument but also to thoroughly review your policies and procedures and the evidence that you are following them. I suggest you write all over that checklist. Write down the policy number that applies. Identify who is most in charge of the process so that they can document what you do to meet the requirements. Write down what documents or processes should be reviewed to show your conformance with the law, the regulations, and your own policies and procedures. If these include minutes of board meetings or staff meetings, write down the date of the meeting in your review instrument. THEN your team can sit down at a table and review what you still need to do to be fully in compliance.

Here is what ACL/OILP says about the purpose of the review process:

The purpose of the COMP is to improve program performance. The OILP relies on the COMP to provide consistent federal oversight of CIL grantees. Grantees may use the COMP to understand program and fiscal requirements and to conduct self-evaluations.  Non-federal reviewers will use the COMP as a resource to ensure consistency during onsite reviews. 

The objectives of CIL oversight and monitoring include:

  • Assess compliance with the assurances and evaluation standards in Sections 725(b) and 725(c)(3) of the Act;
  • Study the program operation, organizational structure and administration of the CIL, under Section 725(c)(1), (2), (5), and (6) of the Act;
  • Review documentation sufficient to verify the accuracy of the information submitted in the most recent annual program performance report (PPR);
  • Verify that the CIL is managed in accordance with federal program and fiscal requirements;
  • Assess CIL conformance with its work plan, developed in accordance with Section 725(c)(4) of the Act, conditions of the CIL’s approved application, and consistency with the State Plan for Independent Living (SPIL);
  • Identify areas of suggested or necessary improvements in the CIL’s programmatic and fiscal operation and provide TA resources available on the local, state, regional and national level; and
  • Identify areas of exemplary work, projects and coordination efforts and make this information available to the larger CIL community.

Is your center ready for review?

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