Every state is required to develop and implement a State Plan for Independent Living (SPIL), developed jointly by all the Centers for Independent Living (CILs) in the state (signed by a majority of them) and the Council. Your Statewide Independent Living Council (SILC) is then responsible for monitoring and evaluating the progress your state is making regarding its state plan. This means that your SILC somehow tracks the progress being made on the specific plan goals. If the goals are related to service provision, the reporting will have to come from the CILs because the SILC is not allowed to provide direct services.

Young dark-haired man in a suit working with calculator and computer. The back of a wheelchair is visible at the edge of the photo.

As far as a center not reporting to the SILC on the SPIL goals and objectives – there isn’t a requirement that they do so on the SILC’s timeline, but they “gave their word”, so to speak, when they agreed to the SPIL. If the SPIL clearly identified those outcomes by CILs, they should be prepared to report. If you haven’t already, take the time at the next revision or development of a plan to be very clear on desired outcomes and how they will be measured, so that the centers are clear on what reporting is expected from the CILs.

Let me repeat this point, though – CILs are not required to report according to the SILC’s requirements, and there is no compliance process to force it. It is voluntary so you need to build on the agreement to the SPIL and negotiate if necessary. A lot of states find a way to have a single report with the Designated State Entity (DSE) shared by the SILC to reduce duplication.

That said, let me clarify that the SPIL applies to both Part B and Part C (Independent Living Program, ILP and CIL) funds, and reporting on the SPIL outcomes should include the full network for IL, including CIL services funded by both Part B and Part C. Both are federal funds, and reporting applies to both. Part B funds are not state funds, as some have mistakenly stated, but pass through the Designated State Entity to the CILs as directed in the SPIL. Part C funds are direct grants to CILs, but are still part of the statewide plan. In the past some SILCs have depended on the information submitted in the Program Performance Report (PPR – formerly the 704 report) which CILs are required to submit to the SILC as well as to ACL, but this year that report has been delayed by the Administration for Community Living (ACL), leaving the SILCs to request the data from a draft document since the official upload directions have not yet come out.

Let me clarify a related point. It is NOT the role of the SILC to monitor the Center itself. The DSE may monitor CILs receiving state or ILS Part B funds, as they are subgrantees of the DSE. The SILC, however, does not have compliance responsibilities with the centers. Sometimes the SILC is pressured by the DSE to monitor the Centers. I have even seen corrective action plans for a couple of SILCs where the DSE cited the SILC’s failure to monitor the CILs as a deficiency. Remember that each center is required to provide the SILC with the PPR and with progress on the SPIL. Any more can be negotiated by the IL network but is not required in federal regulations.

Is my CIL required to report to the SILC? Why? How?

2 thoughts on “Is my CIL required to report to the SILC? Why? How?

  • July 29, 2021 at 12:39 pm
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    Hi Paula –

    The following is confusing to me:

    “That said, let me clarify that the SPIL applies to both Part B and Part C (Independent Living Program, ILP and CIL) funds, and reporting on the SPIL outcomes should include the full network for IL, including CIL services funded by both Part B and Part C. Both are federal funds, and reporting applies to both.”

    It’s been my understanding that IL services whether, Part C or B funded, are to be reported by the CIL and not included in the SILC’s report, to avoid duplication. (This may be different for only Part B funded CILs.) This is specifically stated in Section II of the SILC’s PPR. I’m not sure how a CIL or SILC would make a determination on which entity reports what. Can you offer additional clarification?

    Reply
    • August 4, 2021 at 12:14 pm
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      You are correct that the CIL (Part C) reports all of its services on its PPR including Part B, and the SILC reports only Independent Living Services that are Part B, with no Part C. However, it is also true that the SILC has to report on all services and the progress on the SPIL — Part B and Part C and state funded — as part of the SPIL implementation and monitoring. You are required to provide your PPR to the SILC as part of this.

      Reply

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