As Kelly Buckland, NCIL ED says it, “Affordable, accessible housing or the lack of it, is the biggest barrier to transitioning people from congregate settings.” He clarified with ACL/OILP that centers can use CARES Act funding to assist individuals transitioning from or avoiding institutionalization to obtain housing — including temporary housing such as hotels. Included are consumers who want to transition from congregate settings to the community, or those who need to avoid being sent to congregate settings.
If you weren’t aware of this, listen closely. Re-read it. Let it sink in. This is clarified in ACL’s FAQ issued June 12, 2020, regarding CARES Act funding. The response in FAQ Question 15 identifies the following services as allowable:
- Services and activities that assist individuals with disabilities who are at risk of being institutionalized to remain in their communities
- Services and activities that assist individuals with disabilities to move from an institutional setting to a home in a community-based setting
- Services and activities that address the shortage of accessible housing
Nationally 40% of the COVID-19 deaths in this country are linked to nursing homes, long term care or assisted living. There are other congregate settings that are also problematic — Intermediate Care Facilities (ICFs), correctional facilities, and other group living settings. Assisting people to get out or stay out of congregate living/institutional settings has never been more important. Our people are dying during this emergency, in greater number than we have known before.
You can find the full text of the FAQ on this page, under “CARES Act Funding”. Whether an expense is allowed or not is not a simple answer, because it’s not a simple question. You are “expected to make prudent, reasonable decisions regarding the allowability of CIL CARES Act service costs in the same manner the grantee would determine allowability of service costs funded by any other funding stream. We always recommend CILs do a quick read of the FAQ to help them identify questions they can ask themselves while developing or editing current CIL policies and decision points related to CIL CARES Act funding.” You need to make the case that the expense is for a qualified person (one who says they have a significant disability) and that the expense is related to assisting them in being safe and healthy in this difficult time.