As is so often the case, the answer is, “It depends.” Here are some of the issues to consider. Williams Mullen of jdsupra.com stated: Quote: While the EEOC and the CDC have not specifically stated that employers may mandate vaccination,
Have you completed your 1099s? There is a new form 1099 NEC
What is nonemployee compensation? by John Heveron If the following four conditions are met, you must generally report a payment as NEC. You made the payment to someone who is not your employee. You made the payment for services in
Be particular about Consumer Control
Consumer control is the foundation of Independent Living, and permeates the board, staff and management of Centers as well as the Statewide Independent Living Council (SILC). The requirements are clear: More than 50% (51% or more) of the board members
How can CARES Act dollars to CILs be spent?
First a little background. What are the CARES Act Funds? The CIL CARES Act funding went to the federally funded (Part C) centers for direct response to the COVID-19 crisis among people with disabilities in their service area. They have
As you purchase with federal funds…
With the influx of the CARES Act funds to Part C centers, you have been purchasing personal protective equipment, food, technology, internet or delivery services and more. Are you following your own procurement policies? And do they fall within the
Can I give staff more pay using CARES Act funds?
While the correct answer is “it depends”, my more honest reaction to this question is, “Do you think that is the intention of this funding?” Because, first and foremost, the funding is for the purpose of assisting your consumers —
Program Income and COVID-19
Does income we generate from a program need to be used to reduce federal costs? HHS regulations section 75.307 address how program income must be used. The default for use of program income, earned during the period of performance, is
Are we required to have an independent audit?
While your small center is not required by your federal funder to conduct an annual audit, typically you are by other funding sources (check your contracts) and it is best practice for all. The only federally required audit kicks in
Does the Hatch Act apply to CILs or SILCs?
The Hatch Act typically applies to federal employees, and may apply to state and local elected officials. It forbids intimidation or bribery of voters and restricts political campaign activities by federal employees. It does not apply to Title VII funded
Four key checks for SILCs
Your Statewide Independent Living Council operates under a set of rules found in section 705 of the Rehabilitation Act and in the SILC Indicators and SILC and DSE Assurances. Here are some key items that your SILC must not overlook: