CARES Act and Transition from Congregate Living

If I had a say, I would say to CILs, “Use CARES Act for transition!” Never have residents of congregate living been more at risk! Cases and deaths in group living settings account for from one third to one half the COVID-19 deaths. One way to protect our people from COVID-19 is to get them out of there!

While this is getting a little better as vaccines are given, many people with disabilities remain at risk. Especially if they have a home in the community to go back to (removing the very difficult barrier of finding affordable housing), you may be able to use CARES Act funds to help them get home where they will be safer and healthier than in their current setting. You can apply CARES Act funds to the needs they have for home modifications or other expenses around moving home.

The barrier that many CILs are running into is one of access — the CIL access to talk with residents as they assist them. Good news — from the ACL Blog, regarding ACL Advocacy: Visitation in Congregate Settings

From the ACL Blog

ACL Advocacy: Visitation in Congregate Settings

February 24, 2021

by Vicki Gottlich, Director, ACL’s Center for Policy and Evaluation

Throughout the COVID-19 pandemic, ACL has worked with the HHS Office for Civil Rights, the Centers for Medicare & Medicaid Services and other partners to protect the rights of people with disabilities and older adults. One issue on which we have been heavily engaged is visitation for people who live in a range of congregate settings, and we wanted to make sure our networks were aware of the latest guidance on this crucial topic. 

On Feb. 10, CMS issued guidance on visitation in Intermediate Care Facilities (ICF) for Individuals with Intellectual Disabilities and psychiatric residential treatment facilities (PRTF). This complements CMS’ guidance for visitation in nursing homes, which was issued in September.

The new guidance includes a number of provisions that are important for ACL’s partners in the aging and disability networks to be aware of. For example, although it allows facilities to restrict visitation in order to prevent the spread of COVID-19, it makes clear that visitation may not be restricted without a reasonable clinical or safety cause.  It further says that even if a facility is otherwise limiting in-person visitation, it should allow visits – with appropriate safety measures — by the following:  

  • Protection and Advocacy systems
  • People who provide in-person supports necessary for equal access to care and communication under disability rights laws
  • Long-Term Care Ombudsmen (for ICFs licensed as nursing facilities and certified under section 1919 of the Social Security Act)
  • Outside healthcare and service providers, including providers assisting with transition from a facility to the community
  • People providing support in a compassionate care situation.  The guidance further clarifies that compassionate care situations are not limited to end-of-life. The guidance offers several examples in which visitation by family and caregivers could be considered compassionate care and makes clear that the list should not be considered all-inclusive.  

The guidance also includes descriptions of key federal disability rights laws and P&A programs and provides best practices for allowing visitation safely. This new guidance augments the guidance CMS issued in December on infection control for ICFs, psychiatric hospitals, and PRTFs (which included strategies for transition to the community, where appropriate). 

As always, the HHS Office for Civil Rights stands ready to assist if in-person supports or visitation are being denied in violation of federal disability rights laws.  Complaints can be filed through OCR’s portal. If you have questions or need help filing a complaint, you can email OCR at or call toll-free at: 1-800-368-1019, TDD: 1-800-537-7697. OCR also provides materials in alternative formats (such as Braille and large print), auxiliary aids and services (such as a relay service), and language assistance.

ACL will continue to advocate for the needs of people with disabilities and older adults, and we’ll continue to share information from federal partners and our grantees, as well as resources we think may be useful to the aging and disability networks, and the people we all serve. Watch for the latest information and be sure to sign up for ACL Updates.

Related links:

Can we require staff to get tested for COVID-19? Take the COVID-19 vaccine?

As is so often the case, the answer is, “It depends.” Here are some of the issues to consider.

A needle is stuck into a vial of COVID-19 Vaccine

Williams Mullen of stated:

Quote: While the EEOC and the CDC have not specifically stated that employers may mandate vaccination, there are indicators that such a mandate would be legally permissible. Most importantly, the EEOC has confirmed that COVID-19 meets the “direct threat” definition under the ADA in many cases. Therefore, if the employer can show that, based on the unique circumstances of the work environment, a failure to be vaccinated would pose a “direct threat” to the health or safety of other co-workers or third parties with whom they interact, there would appear to be support for upholding mandatory vaccination programs. The EEOC has now confirmed, in its guidance specific to COVID-19 vaccination, that the ADA allows an employer to have a qualification standard that includes “a requirement that an individual shall not pose a direct threat to the health or safety of individuals in the workplace,” such as a vaccination requirement. However, if this requirement screens out or tends to screen out an individual with a disability, the employer must show that an unvaccinated employee would pose a direct threat due to a “significant risk of substantial harm to the health or safety of the individual or others that cannot be eliminated or reduced by reasonable accommodation.”

Here are a few quotes from the EEOC:

Quote: Because the CDC and state/local health authorities have acknowledged community spread of COVID-19 and issued attendant precautions as of March 2020, employers may measure employees’ body temperature. As with all medical information, the fact that an employee had a fever or other symptoms would be subject to ADA confidentiality requirements.

Quote: A.6. May an employer administer a COVID-19 test (a test to detect the presence of the COVID-19 virus) when evaluating an employee’s initial or continued presence in the workplace? The ADA requires that any mandatory medical test of employees be “job related and consistent with business necessity.” Applying this standard to the current circumstances of the COVID-19 pandemic, employers may take screening steps to determine if employees entering the workplace have COVID-19 because an individual with the virus will pose a direct threat to the health of others. Therefore an employer may choose to administer COVID-19 testing to employees before initially permitting them to enter the workplace and/or periodically to determine if their presence in the workplace poses a direct threat to others. The ADA does not interfere with employers following recommendations by the CDC or other public health authorities regarding whether, when, and for whom testing or other screening is appropriate. Testing administered by employers consistent with current CDC guidance will meet the ADA’s “business necessity” standard.

Quote: The ADA, which protects applicants and employees from disability discrimination, is relevant to pandemic preparation in at least three major ways. First, the ADA regulates employers’ disability-related inquiries and medical examinations for all applicants and employees, including those who do not have ADA disabilities.(7) Second, the ADA prohibits covered employers from excluding individuals with disabilities from the workplace for health or safety reasons unless they pose a “direct threat” (i.e. a significant risk of substantial harm even with reasonable accommodation).(8) Third, the ADA requires reasonable accommodations for individuals with disabilities (absent undue hardship) during a pandemic.(9)

So this tells us — in order to require a vaccine you must determine not receiving it poses a direct threat to your other staff and consumers; AND you must provide reasonable accommodation to those who do not wish to take the vaccine due to their disability. Quote: A “direct threat” is “a significant risk of substantial harm to the health or safety of the individual or others that cannot be eliminated or reduced by reasonable accommodation.”(20) If an individual with a disability poses a direct threat despite reasonable accommodation, he or she is not protected by the nondiscrimination provisions of the ADA.

Quote: May an employer covered by the ADA and Title VII of the Civil Rights Act of 1964 compel all of its employees to take the influenza vaccine regardless of their medical conditions or their religious beliefs during a pandemic?   No. An employee may be entitled to an exemption from a mandatory vaccination requirement based on an ADA disability that prevents him from taking the influenza vaccine. This would be a reasonable accommodation barring undue hardship (significant difficulty or expense). Similarly, under Title VII of the Civil Rights Act of 1964, once an employer receives notice that an employee’s sincerely held religious belief, practice, or observance prevents him from taking the influenza vaccine, the employer must provide a reasonable accommodation unless it would pose an undue hardship as defined by Title VII (“more than de minimis cost” to the operation of the employer’s business, which is a lower standard than under the ADA).(36) Generally, ADA-covered employers should consider simply encouraging employees to get the influenza vaccine rather than requiring them to take it.

What is Intensive Support?

What is Intensive Support and how does a CIL qualify?

The ILNet T/TA Center provides intensive support to individual Centers for Independent living when the CIL is referred from ACL or from the DSE based on compliance concerns. This is a specific area of technical assistance that requires full commitment from the leadership of the CIL to attain compliance and a higher level of quality performance.

ACL’s Office of Independent Living Programs (OILP) is committed to the COMP system (Compliance and Outcome Monitoring Protocol). The DSE (designated state entity) in each state may also conduct sub-recipient monitoring when a CIL receives state or Part B funds. Either of these processes may require corrective action on the part of the Center.  Either OILP or the DSE may refer the CIL to receive intensive support to correct the compliance issues.

It is possible for a CIL to cited by the DSE, but they DSE does not refer them for intensive support. In this case the CIL may request intensive support for completing the Corrections for those citations.

Criteria for Intensive Support services are as follows:

  • Referral from OILP Program Officer or DSE indicating areas of concern or lack of compliance. Services provided include:
    • Develop a Corrective Action Plan to address identified areas of non-compliance including outcomes and target dates
    • If the CIL denies the findings, assist in understanding what is required and how they can appeal.
    • Provide specific resources (typically training, peer support, or one-to-one TA) to assist the center in completing the Corrective Action Plan and returning to compliance.
  • Referral from OILP Program Officer or DSE of new executive directors. Services provided include:
    • Connecting the new executive director with peers in their state or region.
    • Connect the new individual with the national peer to peer support available in Conversations and Peer to Peer Calls and website resources.
    • Assist the individual in assessing their compliance with the COMP requirements.
    • Assist the new executive director in establishing a plan of action to identify weak areas for their CIL and to identify two or more desired outcomes to accomplish with T & TA.
    • Introduce the new director to the Peer Mentoring program if they express a desire for that support.

What is Intensive Support and how does a SILC apply?

 The SILC intensive support is defined as on-going requests for support that cannot be resolved in a call or two. While referrals may still come from the OIP Program Officer, self-referrals are also accepted.

 SILC T/TA support that takes place over more than sixty days and that has a plan of action will be considered intensive support.

Referrals can be made by the Program Officer at ACL, the DSE, the SILC chair or SILC staff. SILC intensive support will only be available to SILCs that are willing to set a plan with measurable outcomes. We will emphasize compliance with regulations in this process.

Process followed to apply for Intensive Support

  • Referrals or requests for intensive support will be in writing, by email to , from the Program Officer or from the CIL, SILC, or DSE. Related compliance review or other concerns must be submitted with the request.
    • For new executive directors, the request may be more general until the CIL or SILC and the T/TA Associate Director, can assess the need and establish two or more measurable outcomes that will advance the operational excellence of the CIL or SILC.
  • Once the initial goals are set, the T and TA Associate Director will work with the Consultant Team to assign the CIL or SILC to the most appropriate consultant for the development of a more comprehensive plan with steps to accomplish as they complete the identified outcomes.
  • The Consultant Team will provide monthly reports to the T and TA Associate Director on the progress toward desired outcomes and the identification of additional areas of need that have come to light.
  • While T and TA is always available on demand, this intensive support is specifically outcome driven and will be considered complete when the desired outcomes are met.
  • Once the T and TA is complete, the CIL or SILC will be given an opportunity to evaluate the intensive support provided.
  • ACL will receive a summary report of the results of all intensive support activities.

Is it time to re-open the Center?

While COVID-19 precautions are somewhat varied based on where you are located, one thing many centers have in common is that their office is closed or partially closed while staff primarily work from home. We are shifting, though, as the vaccines are distributed and communities begin to open. I see a wide variety of current status including:

  • Office remains closed, with staff primarily working for home. Staff are equipped for remote record keeping and to hold life skills classes, peer support groups and one to one meetings with consumers by Zoom or other video platform. Consumers are equipped with a device and digital access to participate.
  • Office is partially open, with staff rotating attendance at the office so that there is less crowding. They are instructed in new cleaning techniques and policies. The office has been upgraded to reduce the chance of transmission, including hand sanitizer stations, UV wands for disinfecting phones and bags, plexiglass screens added in face-to-face locations like the reception area, policy and method for checking temperatures for any person entering the office. Office is equipped with masks for use any time there is a face to face conversation. Staff rotate use of rest rooms, break room, and any other common areas so that there is not staff to staff transmission, whenever possible doors open hands free so that handles are touch free, etc. Handwashing and constant cleaning of surfaces take place.
  • Special arrangements are made for individuals who are at higher risk to continue to work from home if they feel that is necessary for their safety. This can be extended to include people with family members at high risk.
  • Office is open to consumers by appointment. Appointment times are staggered to reduce the likelihood of transmission between consumers. Staff also still staggered.
  • Office is fully staffed, open to consumers by appointment.
  • Office is open to the public. Temps, masks and hand sanitizers required. Proper hand washing and regular cleaning are emphasized. Due to the heavier use of cleaning supplies, people with multiple chemical sensitivities are consulted about what works best for them. (Home visits, visits first thing Monday morning so Friday’s cleaning chemicals have dissipated, etc.)

As you can see, “reopening” can mean different things. Whatever your policies, you need to develop and implement strategies for basic hand hygiene, cleaning and disinfecting surfaces, social distancing, identification and isolation of sick employees, workplace controls and flexibility, and employee training. There is also a balance needed so that shifting from working at home to working in the office occurs in an organized purposeful way. In other words, you need a plan.

Your plan can include equipment, supplies and procedures including deep or more frequent cleaning that you can fund with your CARES Act funds. You can install some automatic door openers to reduce touching door surfaces and barriers at windows. You can enhance the ventilation in the building. You can purchase a temperature station (one CIL I know of even connected the temp station to the door opener, so the door won’t open to anyone with a fever. The receptionist can help the person with a fever through the barrier at the front desk, but they do not enter the building, reducing contamination.) Hint: Don’t keep an individual record of temperatures. If you keep them you create a medical record that has to be kept 30 years beyond the end of the individuals employment.

As soon as you are open again, you increase the possibility of staff or consumers bringing the infection into the work place. You need to have a procedure for what happens in that case. Even if you take all precautions and everyone — staff, volunteers and consumers — uses the provided soap, water and paper towns to wash frequently and properly (for at least 20 seconds) someone may test positive who was recently in your office. OSHA’s guidance on Returning to Work states, “Establish a protocol for managing people who become ill in the workplace, including details about how and where a sick person will be isolated (in the event they are unable to leave immediately) while awaiting transportation from the workplace, to their home or to a health care facility, and cleaning and disinfecting spaces the ill person has occupied to prevent exposure to other workers, customers, or visitors. Employers may need to collaborate wit health officials to facilitate contact tracing and notification related to COVID-19 cases or possible exposures.” The CDC has information regarding this at Talk to your county health office or check the state or county web pages for guidance in how this is handled locally.

If staff have been exposed, they need to know how to isolate/quarantine and monitor their own health. You policies should address how long everyone stays at home, how the building is sanitized, and what is required to occur before people return to work.

For more information about COVID-19 as it relates to the ADA and other Equal Employment Opportunity Laws, see this reference:

Based on OSHA’s publication:

PPP Loans-Take Two

First, you should know that if you took a first-round PPP loan that did not exceed $150,000, SBA has just released a simplified forgiveness form-just one page with key information, but with no requirement to document payroll or other costs (although that documentation should be retained in case it is requested in the future). The form is called PPP Loan Forgiveness Application Form 3508S. It may be used for first and second round loans.

If you took an original PPP loan and spent it all on allowable expenses, you can apply for a second round loan.

However, to qualify for a second round loan, you must have been adversely affected by the pandemic and this is measured by a decline in your gross receipts.

The maximum loan amount for second round loans is based on 2.5 times the average monthly qualifying costs for payroll, payroll taxes, and fringe benefits, with an overall maximum of $2 million.

Applicants for second round loans must have no more than 300 employees and must have suffered a decrease in gross receipts of 25% or more in any quarter from 2019 to the same quarter 2020. Alternatively, a decrease of 25% for the full year will also qualify.

Unlike businesses, nonprofits use amounts collected to determine whether they had a 25% decrease.  This can be beneficial because a timing change could result in a qualifying decrease.

Contributions as well as funding and revenue are all included as amounts collected for nonprofits. PPP loan proceeds are not included.

SBA has guidance for organizations that were not in operation for a full year in 2019.

If you did not take an original PPP loan, you can apply for an initial loan under the new program.

The calculation for first round loans is essentially the same as described above for second round loans, with an overall limit of $10 million.

As in the past, first round loan borrowers need to maintain employee and compensation levels and spend the proceeds on payroll and other eligible costs such as mortgage interest, rent, utilities, and worker protection costs related to Covid-19.

In some circumstances, organizations are allowed to modify their first round loans if they did not receive all they were eligible for.

Either first or second round loans must be applied for by March 31, 2021. These loans will be made through banks.

SBA and the AICPA have extensive guidance on the loan process.

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 the course of your trade or business (including government agencies and nonprofit organizations).
  • You made the payment to an individual, partnership, estate, or, in some cases, a corporation.
  • You made payments to the payee of at least $600 during the year.

Trade or business reporting only.

 Report on Form 1099-NEC only when payments are made in the course of your trade or business. Personal payments are not reportable. You are engaged in a trade or business if you operate for gain or profit. However, nonprofit organizations are considered to be engaged in a trade or business and are subject to these reporting requirements.

Due Date.  Form 1099 is due January 31, 2020 (presumably February 1 because the 31st is a Sunday).  The due date doesn’t get extended with electronic filing.

Exceptions. Some payments do not have to be reported on Form 1099-NEC, although they may be taxable to the recipient. Payments for which a Form 1099-NEC is not required include all of the following.

  • Generally, payments to a corporation (including a limited liability company (LLC) that is treated as a C or S corporation). However.
  • Payments for merchandise, utilities, freight, storage, and similar items.
  • Business travel allowances paid to employees (report on Form W-2).
  • Cost of current life insurance protection (report on Form W-2 or Form 1099-R, Distributions From Pensions, Annuities, Retirement or Profit-Sharing Plans, IRAs, Insurance Contracts, etc.).
  • Payments to a tax-exempt organization including tax-exempt trusts (IRAs, HSAs, Archer MSAs, Coverdell ESAs, and ABLE (529A) accounts), the United States, a state, the District of Columbia, a U.S. possession, or a foreign government.

Tips for your first single audit

by John Heveron

Will this be the first year you are subject to compliance auditing?  If so, the following information will help you prepare.

If you expend (not receive) $750,000 or more of federal funds in a fiscal year, you will be subject to compliance auditing.  You can calculate that $750,000 amount on a cash or accrual basis regardless of your regular accounting method, but will need to be consistent with that method going forward.

The $750,000 threshold includes expended amounts that were received directly from the federal government or indirectly through other agencies.

Additional CARES Act funding that you received during the year is federal funding (Heath and Human Services (HHS) Provider Relief Fund), and so is the forgiveness of an EIDL (COVID-19 Economic Injury Disaster Loans) loan because it comes from the SBA (Small Business Administration) – a government agency.  However, PPP (Paycheck Protection Programs) loans come from banks and are not considered federal funding even though they are ultimately paid by the federal government.

So, if you expect to be subject to compliance auditing for this fiscal year because you will spend $750,000 in federal funds, here are some key things to do now:

  • First, make sure that your CPA firm is experienced and qualified with compliance auditing.  If they only do one or two compliance audits, you may want to consider another firm.  Ideally, they will be members of the AICPA Governmental Audit Quality Center (Association of International Certified Professional Accountants).  You may need to request proposals from other accounting firms
  • Schedule a meeting with your auditors in advance of the audit so that you can discuss their expectations of you.  Although there are certain procedures auditors must follow, they are permitted to use their professional judgment and conduct the audit in the way they feel is most appropriate.

Because compliance audits incorporate Governmental Auditing Standards and Generally Accepted Auditing Standards, your auditors will perform procedures to be sure that you have systems in place to:

  • comply with laws, regulations, contracts and agreements that will impact your financial statements, and have controls over that compliance
  • comply with requirements that have a direct and material effect on the funding you receive, and have controls over those areas of compliance.  These include items such as, who is eligible to receive services, what services can be provided, and during what time frame.

Uniform Guidance (2 CFR 200) and HHS regulations (45 CFR 75) refer to a process for controls which includes the following:

  1. The Control Environment–your commitment to integrity and ethical values, your oversight, and your commitment to competence and accountability (ongoing training is big)
  2. Risk Assessment–identifying and analyzing risks, and assessing fraud risks
  3. Control Activities–the policies and procedures you adopt for accounting and documentation, and your controls over technology
  4. Information and Communication–your internal communications and training and external communications about your policies, procedures, and values
  5. Monitoring Activities–your ongoing assessment of whether controls are appropriate for your current programs and whether they are being followed

This sounds somewhat unwieldy, but stated more simply, it says that you must (1) consider what could go wrong with your accounting, reporting, or the execution of your grants, (2) develop board approve policies to reduce the possibility of errors, and alert you about problems, (3) train staff involved with finances and grant administration about these policies, and (4) periodically check back to make sure your controls are still working and are still proper for your circumstances.

Some of the key policies you will need to have include:

  • an up-to-date personnel policy which incorporates current regulations and addresses whistleblower protection and conflicts of interest (these can be separate policies)
  • a procurement policy that meets requirements of Uniform Guidance and Uniform Administrative Guidance
  • procedures for carrying out federal awards, including for the management of any advance payments you receive, and
  • security for protection of confidential information, including employee and client information

Your auditors may also look into your procedures for:

  • Budget development and review,
  • Compliance with your indirect cost rate or other cost reimbursement procedure,
  • Identifying unallowable costs,
  • Verifying that costs are necessary and Reasonable
  • Records retention,
  • Securing property and equipment,
  • Dealing with subcontractors and subrecipients, and
  • Complying with the buy American and hire American Executive Order.

ILRU has several helpful resources including sample policies and procedures for procurement, records retention and the like.

CARES Act funds used for Transition, Diversion, and related Housing costs

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.

What has changed?

In any life there are events that change everything. We live in a world that shifts and changes as events impact us. Think about some events that have changed everything, for the foreseeable future. Post the Kennedy assassination motorcades for presidents were different. Following the Challenger disaster new safety was imposed on all space travel. Post 911 air travel changed forever: who could have imagined the TSA? Post Sandyhook schools everywhere strengthened their protections for school children.

And Post-COVID-19? We can almost see that finish line with the release of vaccines. What has changed forever? I have a few thoughts.

  • We will never take handshakes for granted. I am not sure we will return to them at all, but if we do I suspect no one will be judged for failing to extend their hand. Even fist bumps may be suspect, and elbow bumps may be the new protocol.
  • Signatures will not be expected as the only affirmation. Have you noticed that many businesses no longer require your signature at the time you purchase something with a card? And as Centers we know we can now use an electronic signature or have a staff person verify what used to be signed consumer statements. I suspect this is a long-term change, and we will see businesses and other entities much more comfortable with verification methods other than signatures.
  • Working remotely will be part of an individual work schedule, because we’ve learned we can be very effective working from home. We will have new ways to measure performance, other than just time.
  • Employers will be more involved in the health and well-being of staff. As staff have moved through their own challenges, employers have been beside them, adjusting work schedules, understanding when kids are working in the background, granting mental health days, discussing the fears and challenges of the pandemic. I hope this is a permanent change. It has made workplaces more welcoming and flexible.
  • We are better at using technology. A year ago there was talk about Artificial Intelligence displacing people; and about people who can’t adapt to technology being displaced. We are using technology tools better than ever, including people who struggled with the technology a few months ago. I think this is a permanent change — the world needs technology and is using it well.
  • We are better at creating a healthy environment. From cleaning techniques to mental health support, offices are better than they used to be.
  • People are more included, less marginalized. If your center has more than one office, or has board members from more than one county, you have already seen them responding to the new, more equal playing field of having everyone on the call have equal status. When two-thirds of the group is around the table, the ones participating by phone or video are never really equal in their opportunity to discuss things. Now that everyone is on video with an equal opportunity to participate, they are more included.

Share your thoughts — what else has changed that may have long-term impact?

The latest on Program Performance Reports (PPRs, formerly 704 reports) from ACL

Here is correspondence from your funder regarding your annual reporting, which is typically due December 31. Note that the CILs are submitting only CARES Act reporting in GrantSolutions at this time, and this is due no later than 12/31/2020 at 11:59 pm EST. We are not sure exactly when and how the other PPR reports will be submitted, but you are urged to go ahead and complete a copy of the instrument so you are prepared to submit with very short notice once we know how the report will be collected. Here is the “Dear Colleagues” letter from Corinna Stiles that was sent out this morning.

Dear Colleagues,

As a reminder, ACL has discontinued the use of ACLReporting.  Grantees will not be submitting annual PPRs through ACLReporting.  We are currently working to determine the most suitable web-based platform to meet our Program Performance Report (PPR) needs.    ACL does not anticipate having a web-based platform available prior to the current 12/31/20 PPR due date (723 States 1/31/21).  ACL will provide the PPR submission deadline once a new web-based platform is secured.  ACL strongly encourages you to complete the CIL and ILS annual PPR instrument before 12/31/20 (723 States 1/31/21) and keep in your records so that you can easily and TIMELY transfer data when a data submission platform comes online.  We will share more information as it becomes available.  Please note the following:


  • CIL CARES Act PPRs are due in GrantSolutions no later than 12/31/20 11:59 pm EST.
  • ACL strongly encourages you to complete the CIL annual PPR instrument before 12/31/20 so that you can easily and TIMELY transfer data when a data submission platform becomes available. 


  • ACL strongly encourages you to complete the ILS annual PPR instrument before 12/31/20 so that you can easily and TIMELY transfer data when a data submission platform comes online.

723 States:

  • ACL strongly encourages you to complete the annual PPR instrument before 1/31/21 so that you can easily and TIMELY transfer data when a data submission platform comes online.

Thank you for your patience,

Corinna Stiles

Corinna H. Stiles, PhD, JD, Director | Office of Independent Living Programs

Administration for Community Living  U.S. Department of Health and Human Services

330 C Street, SW. RM 1123 Washington DC 20201 | 202.795.7446 |

COVID-19 Information and Resources