(Taken from the transcript of the SILC Speaks call on April 7, 2016 with Bob Williams and Tim Beatty of the Independent Living Administration within the Administration on Community Living, Department of Health and Human Services.)
Moderator: The next couple of questions have to do with the term “subgrantee” that shows up in the Uniform Guidance, those new rules around federal grants that took the place of the OMB Circulars. We want to know if the SILC is considered a subgrantee of the DSE under uniform guidance, or since the funds are specified in federal regulation for distribution to the SILC, is the SILC autonomous that from level of oversight by the DSE? And we can give more detail about what that level of oversight is for the people on the call who might not be aware. If the SILC is a subgrantee, then measuring their performance, setting objectives, setting an indirect cost rate, imposing certain conditions are all part of what might happen. So, of course, we’re very interested in whether the SILC is in that position or not.
Beatty: Okay. Let me preface my remarks and let you know that we’re still looking into this with our cost allocation services office to get more specific information, but what we do know at this point is that for the purposes of section 207 of the uniform guidelines, which is put out by OMB, the SILC is considered a subgrantee of the DSE because the DSE is the entity that, on behalf of the state, receives, accounts for and disburses Part B funds. More of the section 713 of the act outlines authorized uses of the Part B funds and those uses are not limited to providing funding to the SILC for its Resource Plans. So, therefore, the DSE is still responsible, according to the law, for oversight of these funds as they are the program grantees. This is an area we will continue to look at because, obviously, the DSE has specific responsibilities for the funding, and they will need information from the SILC in order to meet those responsibilities. So a long answer short, yes, the SILC is considered a subgrantee of the DSE. for the Part B funds.
Moderator: The second part of that question was, is the Part B center receiving those funds also considered a subgrantee of the DSE? I think I heard you say yes?
Beatty: Yes, it’s the same answer there because Part B centers are subgrantees of the DSE because they receive the Part B funds from the DSE, and so likewise, both parties have responsibilities for that funding. Additionally, in this case, it’s more clear that the DSE is the program grantee responsible for compliance, oversight, monitoring of the Part B funds as outlined is section 704(c)(1) of the act.