Request: I hoped you might be able to provide some guidance regarding start up funds for fee-for-service programs. I have reviewed the training available on ILRU but had some additional questions. Would it ever be allowable to use Part C funds to contribute to start up of a fee for service line? We are considering benefits planning as a fee for service in the fall.
You are allowed to develop funding options through time for staff paid for through your Part C grant. While fund raising is not typically allowed with federal funds, fund development is not only allowed, but is required for centers. While I will make a statement in a second about how some centers struggle with the philosophy of this particular project, it can fit under advocacy as a core services, and is fund development, so is allowed with Part C funds.
The staff time and the related benefits are typically the greatest cost. The indirect costs related to building occupancy would also be part of the cost. I would limit any new investments for space or equipment until you get a sense of how well the services are being received.
If you use any Part C money, though — indirect or direct — the profit that you make has to go back into the same things your Part C grant is used for, and the same “strings” of what is and is not allowable are applied–at least for the funding cycle of your Part C grant (which is at this time considered to be long term because the renewals are not competitive.)
I suggest, if you can, to use discretionary funds for this development because then you have a clear idea of its actual costs, and you know if it is feasible to continue. And, if all the direct and indirect costs are paid through discretionary funds or through proceeds from a project developed independently from Part C, then the proceeds that remain are discretionary and can be spent on otherwise non-allowable costs like lobbying.
I know of other centers who are taking this approach, and some make a small profit and others don’t. I suspect that depends on population base at least in part. How well trained the staff are is another. Some engage attorneys, for example, at a greater cost than less legally trained staff. To be successful you should approach this like any other business, and develop a business plan so that you know if you have a customer base that will support your new idea, what fee the market will allow, and where to tap your customers.
There is a discussion going on in IL around whether or not benefits counseling is appropriate for IL. For one thing, there are usually generic services that provide this support, We assist with self-advocacy, certainly, and assist individuals with navigating a difficult system. However, there is a real question of whether or not receiving these benefits assists the individual in achieving independence. Some centers have consciously chosen not to provide this service for that reason.
Response: I understand the concern about benefits counseling. We’ve had some of the same discussions at our center. The type of benefits counseling that we plan to do it “work incentive” benefits counseling. We have learned that there are limited options in our area for this service. Our DSE is supportive of us adding this service as well. We feel this works nicely with IL philosophy as we’ll also be helping folks with employment goals and getting back to work. One of our staff completed a fairly intensive training to receive her certification. I’m hopeful it will also serve to give our small center more viability too.