How to initiate internal controls in your one-person SILC office

It is all about internal controls.  Internal controls assure that more than one person reviews all financial transactions, and that more than one person is involved in any chain of events related to a transaction. When there is a single person office, you need to accomplish separation of responsibilities by involving board/council members in your internal controls. When there aren’t internal controls, an inappropriate temptation is put in front of the employee.

Man holding up red wooden block with the words “internal control”. With his other hand he is halting the progress of falling dominoes.
White images of dollar, person, graphs, percentage etc. appear around the red block.

The board/council sets financial policy. You may be used to depending on your SILC staff for a lot of things including policy. When it comes to your responsibilities to the organization, you have a fiduciary duty (to oversee the finances), including setting the policy and procedure for internal controls. While the staff member may say, “Hey, don’t worry about it, I’ve got this”, this is one place you really must step up. and at a minimum review and approve the policies and procedures. We have a set of sample policies, geared to CILs but many apply to your SILC as well. Here is what we said about segregation of responsibilities, modified slightly to better apply to your SILC:

The council and staff of Anystate SILC will ensure the appropriate level of segregation of duties at all times. The board and staff will accomplish that by following the policies and procedures included in this manual.

Cash Receipts: Blank checks, checks or cash held for deposit, and checks held for employees or vendors will be kept in a locked area with access limited to the executive director and the treasurer (those whose responsibilities require access).

Incoming mail will be opened by the executive director. When checks or cash are received, he or she will perform the following tasks:

  • Stamp the back of any checks received “For Deposit Only.”
  • Count any cash received.
  • Complete a deposit slip.
  • Make a photocopy, or electronic copy of any checks received and any accompanying documentation.
  • Make timely bank deposits not more than a week from the receipt of the check.
  • Obtain an office copy of the receipted bank deposit.
  • Provide a copy of the checks and deposit slip and receipt (or check scanning report)to the accountant/bookkeeper or the treasurer to record in the accounting system. Under no circumstance shall the accountant (bookkeeper, treasurer) perform any of the above seven tasks, so that segregation of duties can be maintained.

Paying the bills. The Executive Director is responsible for processing any invoices for payment, including:

  • Open mailed invoices or print electronic invoices and mark them regarding allocation if the SILC has more than one funding source.
  • Assure that itemized receipts are included for credit card transactions and that each is reviewed.
  • Initial to show approval and forward to bookkeeper/accountant/DSE to initiate check payment.

The accountant/bookkeeper will enter the payment information and print a check or, if electronic payment is used, print the payment information. The accountant/bookkeper will then present the checks to the ED and treasurer to sign.

  • The documentation will be presented with the check (either paper or electronic) for review and signature.
  • All checks will be signed by both the executive director and the treasurer/other council member assigned.
  • At least quarterly the council chair shall reconcile the bank account by reviewing the check register and comparing payees and amounts to the actual check images on line.
  • Time documentation and payroll for the SILC executive director will be reviewed at least quarterly by the council chair.
  • Any check made out to the ED shall not be signed by the ED, but requires signature from an authorized board member.

The person doing to review should be familiar with the organization’s operations, and ideally have a budget but at the very least have a good sense for revenue sources and timing.

If this can’t be done, financial administration should be performed by an independent organization (another nonprofit or an organization that administers associations and nonprofits) or by a contracted accounting firm.

If you have found multiple signers a problem in the past there is good news. You can use a service like to allow remote signatures from multiple parties as expenses are approved and checks signed electronically.

New notes on 10% de minimus rate for indirect costs and Modified Total Direct Costs

A new FAQ is out for the overall regulations for spending of federal grant funds — Uniform Guidance found in 2 CFR 200 (and mirrors the regs from our HHS funder at 45 CFR 75 which have not yet been updated). You can find the full text here, where over 140 questions are addressed, but let’s look at a few key ones over the next few posts.

Modified Total Direct Costs

Q-114. If a non-Federal entity’s last negotiated indirect cost rate was 9 percent MTDC, and the rate has since expired, can the organization elect to use the de minimis rate going forward? Yes. Please inform your cognizant agency for indirect costs that you will be switching to the de minimis rate and will not be submitting indirect cost proposals for future years. Negotiated provisional rates and fixed rates need to be resolved and the carry-forward for the last year of the fixed-rate will need to be resolved with the cognizant agency for indirect costs.

Q-115. Does a non-Federal entity using the de minimis rate need to provide documentation to substantiate its costs? No. The de minimis rate was designed to reduce burden for small non-Federal entities. The non-Federal entity must report in its SEFA whether it elected to use the de minimis rate for its Federal awards. See §§ 200.414(f) and 200.510.

Q-116. If the subaward is made up of several individual funding agreements, does each individual subaward require including up to $25,000 in the MTDC base? The allowance of $25,000 is for one time during the period of performance of each individual subaward.

Q-117. Is the MTDC applied to the first $25,000 for an award’s period of performance or is it applied to each year of a multi-year agreement? The allowance of $25,000 is for one time during the period of performance of each individual subaward.

Q-118. Can a pass-through entity that paid actual or negotiated indirect costs to a subrecipient later impose the 10 percent de minimis rate on future subawards to the same subrecipient? The 10 percent de minimis rate is for non-Federal entities that do not have a current negotiated indirect cost rate (including provisional).

•If a pass-through entity paid negotiated or actual indirect costs to a specific subrecipient in the past, they should continue to negotiate and award indirect costs to that subrecipient in accordance with their prior practice.

•If a pass-through entity does not have a current awarded or negotiated actual indirect costs with that subrecipient, then the pass-through entity can provide the 10 percent de minimis rate or negotiate a rate with that subrecipient.

Q-119. Can a Federal awarding agency or pass-through entity restrict recipients or subrecipients use of indirect costs to the de minimis rate? No. Federal awarding agencies and pass-through entities must recognize a federally approved negotiated indirect cost rate. (NOTE from McElwee: This may be useful when the DSE as the pass-through entity doesn’t want you (as the subrecipient for Part B/ILS funding, to use your approved federal rate.)

Q-120. If a non-Federal entity allows its negotiated indirect cost rate to expire, is it eligible to request the de minimis rate? Yes. Please inform your cognizant agency for indirect costs that you will be switching to the de minimis rate and will not be submitting indirect cost proposals for future years. Negotiated provisional rates and fixed rates need to be resolved and the carry-forward for the last year of the fixed-rate will need to be resolved with the cognizant agency for indirect costs.

Q-121. If an organization elects to use the de minimis rate at the beginning of an award, is it applicable to the award’s entire period of performance? The de minimis rate may not be applicable during the entire period of performance of an award. If a non-Federal entity elects to negotiate an indirect cost rate and the negotiated rate begins prior to the end of an award’s period of performance, they may apply the negotiated rate to the award. The non-Federal entity should inform their Federal awarding agency or pass-through entity of the change prior to incurring costs on the award. Federal awarding agencies and pass-through entities are not required to reissue awards issued prior to the effective date of the indirect cost negotiation agreement. In fact, Federal agencies must use the IHEs’ negotiated rates in effect at the time of the initial award throughout the life 25of the Federal award.2 Accordingly, the de minimis rate may be applicable to the period of performance of the award if the total award amount is known and made available to the organization at the time of award.

Q-122. Can a recipient conducting a single function, funded predominately by Federal awards, elect to charge the de minimis rate if they currently only charge direct costs to their awards? No. If all costs are charged directly to the Federal award (e.g., space costs, utility and administrative costs), the recipient must not also charge the de minimis rate. Costs must be consistently charged as either indirect or direct cost, and may not be double-charged or inconsistently charge

Are you ready for a national call center to send vaccine questions your way?

All CILs should have received the following from Jennifer Johnson, Deputy Commissioner, Administration on Disabilities and Director, Office of Disability Service Innovations at Administration for Community Living. It provides information about a national call center — and you are part of the local resources that the national hotline will use to send local questions your way. Here is the text of the letter:

SUBJECT: Launch of Disability Vaccine Call Center

Dear colleagues,

In March, we announced a partnership with the Centers for Disease Control and Prevention (CDC) to increase vaccine access for people with disabilities and older adults. I’m happy to share that the national call center established through that partnership is now ready to serve people with disabilities. 

The Disability Information and Access Line (DIAL) can help people with disabilities find vaccine locations in their communities and assist with making appointments. When needed, the DIAL call center will refer individuals to state and/or local programs for additional supportive services. We will be publicly announcing the launch of DIAL in the coming weeks.  The call center is fully accessible.

We need your help to gradually build call volume so that we can fully test the call center’s systems and processes before the public launch. Could you please begin sharing the DIAL contact information with your clients and networks? Sample language you can use is found at the bottom of this email. We ask that, for now as the center gets established, you not post this information on websites or social media or send to broad lists of email subscribers. Rather, please share with clients who may need assistance and organizations in your network who may be a first point of contact for a person with a disability who may need help accessing vaccines. People can reach DIAL using email or by phone:


Phone number: 888-677-1199

Last week, DIAL started receiving referrals from the CDC hotline and will continue to raise awareness about the call center. As the number of callers increases, you may see increased referrals to your program. 

In preparation for receiving calls, the DIAL Call Center team has worked closely with an initial core group of disability partners (see below list) who have provided guidance on:

  • Training. Our trainings have covered effective communication; Independent Living philosophy; core services and how they can support the vaccination process; rights of people with disabilities, including during the vaccination process; and determining the most appropriate referrals for people with disabilities based on their stated needs.
  • Position descriptions. We have worked with our partners to ensure that we have developed position descriptions that will increase reach to applicants with disabilities.
  • Promotion. We are exploring how best to promote this resource to reach as many people with disabilities as possible. We will be in touch again after the public launch to ask for your support in this broader effort. 

If you have any questions, please let us know.

Thank you!

Sample DIAL Language for Partners
Because of the elevated risk of serious illness and death due to COVID-19, vaccination is critically important for people with disabilities. However, we know that many face significant barriers to getting vaccinated. The Administration for Community Living (ACL) has launched DIAL, the Disability Information and Access Line, to support the needs of people with disabilities seeking information and access to the COVID-19 vaccine in their communities. DIAL will connect people with disabilities to local resources that can provide information and assistance in obtaining the COVID-19 vaccine. In addition, DIAL can connect callers to information and services that promote independent living, including inquiries related to food, housing, transportation, and a need for advocacy or peer counseling that may arise due to COVID-19.

Email: Phone number: 888-677-1199

DIAL was launched as a partnership between the n4a and a consortium of organizations serving people with disabilities. These include:

  • Association of Programs for Rural Independent Living (APRIL)
  • Association of University Centers on Disabilities (AUCD)
  • Independent Living Research Utilization (ILRU)
  • National Association of Councils on Developmental Disabilities (NACDD)
  • National Council on Independent Living (NCIL),
  • National Disabilities Rights Network (NDRN), and
  • The Partnership for Inclusive Disaster Strategies.

This partnership combines the disability networks’ extensive knowledge and expertise in meeting the needs of people with disabilities across the U.S. and n4a’s decades of experience in operating a national call center to connect people to information and services. By leveraging these capabilities, ACL was able to launch this critical tool in less than six weeks.

Ok, we sometimes must provide paid leave — did we get it right? is a top notch website for non-profit executive directors and board members. In this post Mike Bishop summarizes the requirements and when they were/are in effect. (Reprinted in whole.)

Ask Rita: FFCRA Paid Leaves 2021—Help!

USA flag and families first coronavirus response act FFCRA law.

by Mike Bishop J.D. on May 20, 2021

Categories: Current Issue| HR and Employment Issues Topic Tags: Workplace Policies

Dear Rita,

In March of last year, when the pandemic hit, we spent a lot of time implementing the required Covid-19-related paid leaves of absence. We drafted leave forms and gave notice to our employees of the right to take these leaves, and we are very proud of our successful efforts in ensuring that employees were provided the leaves to which they were entitled.

Then, in December of 2020, with the required leaves coming to an end, we made the decision to voluntarily extend them to our employees until March, which we believed we should do given the opportunity to take advantage of the payroll tax credit that Congress had extended until March 31, 2021. Again, all went well.

We are now aware of the new laws that affect the FFCRA paid leaves after March. At this point, we are getting confused about what we must, or should, do considering this new set of laws. Could you please give us some idea of what these laws are about and what our continuing responsibilities are?


Dear Confused,

As if dealing with the pandemic weren’t difficult enough, the series of paid-leave laws enacted over the past year only increases that difficulty. The best way to understand what the new leave laws provide is to take a quick look back into the past.

The Families First Coronavirus Response Act, or FFCRA, went into effect on April 2, 2020. Among other things, it created two new forms of paid leave that employers of 500 or fewer employees were required to provide for employees who were dealing with Covid-19 “qualifying reasons.”

The first form of paid leave was the Extended Family Medical Leave (EFMLA), which provided up to 10 weeks of paid leave for one qualifying reason: to provide care for a child whose school was closed or caregiver unavailable due to Covid-19. The second was the Emergency Paid Sick leave (EPSL), which provided for 80 hours of paid leave. The primary qualifying reasons for this leave were the following:

  • The employee is subject to a federal, state, or local quarantine or isolation order related to COVID-19.
  • The employee has been advised by a health care provider to self-quarantine because of COVID-19.
  • The employee is experiencing symptoms of COVID-19 and is seeking a medical diagnosis.
  • The employee is caring for an individual subject or advised to quarantine or self-isolate.
  • The employee is caring for a child whose school or place of care is closed, or whose childcare provider is unavailable, due to Covid-19 precautions.

Both of these leaves were protected, meaning that on their return to work the employee was entitled to be restored to their position and that retaliation for taking leave was specifically prohibited. FFCRA also gave the employer a 100% payroll tax credit as reimbursement.

I’m glad your experience with administering and providing these leaves went well. In December 2020, however, with the expiration of the FFCRA leaves quickly approaching, employers had a decision to make. On December 27, 2020, new legislation was signed into law that did not renew the mandatory nature of the FFCRA leaves. In a bid to support employers, it did extend the reimbursement tax credit for employers who voluntarily chose to provide these leaves to employees who satisfied the previously described qualifying reasons. If employers chose to extend these leaves and to take the tax credit, the qualifying reasons established under FFCRA that allowed the employees to take this paid leave were applicable. That ability to use the tax credit lasted until March 31, 2021.

As you note, this paid-leave odyssey is not over. On March 11, 2021, the President signed the American Rescue Plan Act of 2021 (ARPA). Under ARPA, the employer still could voluntarily provide both of the FFCRA paid leaves on a voluntary basis by extending the reimbursement tax credit through September 30, 2021.

Perhaps most significantly, ARPA adds three more qualifying reasons that leave may be granted, reasons that reflect the more widespread availability of the Covid-19 vaccines, which did not exist when FFCRA was originally created. Leave may now be granted for these additional qualifying reasons:

  • Obtaining a Covid-19 immunization
  • Recovery from an injury, disability, illness, or condition related to immunization
  • Seeking or awaiting the result of a Covid-19 test or diagnosis when the employee has either been exposed to Covid-19 or the employer has requested the test or diagnosis

Clearly, the vaccine-related qualifying reasons help to encourage employees to consider vaccination.

In addition, if the employer extends these paid leaves, ARPA creates a new 10-day, 80-hour period of paid leave starting on April 1, 2021. Under this new category, where an employer has extended this leave after April 2021, employees who have already used all of their EPSL allotment have another 10-day, 80-hour period of paid sick leave available to them.

It is also important to note that many states and municipalities have enacted their own Covid paid sick leave laws that may track with, but not be identical to, what ARPA has created this year. For example, these state laws may be mandatory, whereas FFCRA remains strictly voluntary. By the same token, the states’ leave enactments do not, and cannot, provide the tax credit for reimbursement.

In your ongoing efforts to deal with these paid leaves and what you provide to your employees, you should first consider whether there is a state or local mandatory leave that you must comply with. If there is no such requirement, consider the benefits of extending the FFCRA leaves, such as encouraging reluctant employees to get vaccinated, which helps to keep other employees from being exposed, and working more efficiently overall to get Covid out of the workplace altogether, which protects everyone’s safety. Oh, yes, and don’t forget the extended tax credit.

Mike Bishop

Mike Bishop is a member of the State Bar of California and has been admitted to practice in a number of federal district courts in both California and Ohio. During his legal career, Mike worked for 32 years with a Sacramento law firm, where he focused on employment litigation in both state and federal courts. During that time, he defended employers in litigation. In 2016, he began his work as an Employment Risk Manager for the Nonprofits Insurance Alliance, assisting nonprofits in evaluating employment risks. Mike lives in Lakewood, Ohio, and is a graduate of the University of California, Davis, with a bachelor’s degree in political science, and a 1982 graduate of the University of the Pacific, McGeorge School of Law.

Articles on Blue Avocado do not provide legal representation or legal advice and should not be used as a substitute for advice or legal counsel. Blue Avocado provides space for the nonprofit sector to express new ideas. Views represented in Blue Avocado do not necessarily express the opinion of the publication or its publisher.

Frequently Asked Questions about spending Federal Dollars

A new FAQ is out for the overall regulations for spending of federal grant funds — Uniform Guidance found in 2 CFR 200 (and mirrors the regs from our HHS funder at 45 CFR 75). You can find the full text here, where over 140 questions are addressed, but let’s look at a few key ones over the next few posts.

Q-8. What is a risk-based framework that is used to alleviate compliance requirements? A risk-based framework is a critical component of a Federal awarding agency’s performance management framework, particularly as it relates to a Federal program. It helps identify risks that may affect advancement toward or the achievement of a project or sub-project’s goals and objectives. In addition, integrating risk management practices can assist Federal managers to determine an appropriate level of resources and time to devote to project oversight to monitor recipient progress and hold them accountable for good performance. A risk-based framework could also help Federal awarding agencies develop risk mitigation strategies emphasizing strong performance, and reprioritizing routine post award monitoring and oversight strategies. (See§200.102(d).)

If you haven’t looked at a process for identifying and responding to risks, you need to. When you identify risk you can monitor and mitigate those risks more easily. I suggest a risk management plan that includes compliance, safety and service provision risks, and may look a little like this.

Risk Management Plan worksheet:

Identified Risk  Current mitigating measuresWhat needs to be doneHow to monitor long term
         Someone is injured on the property Liability insurance
Safety postings around any work/wet surface
 Uneven surfaces repaired. A regular slip/fall inspection.
         Staff member sues for unfair bias. Staff training for all managers addressing bias, rights, justice. Require annual retraining. Designate a point person to discuss
issues as they arise
The chart for a risk management plan, with headings of Identified Risk, Current mitigating measures, What needs to be done and How to monitor long term.

While we usually suggest you “think positive”, for this process you and your leadership need to bring your disaster fantasies to the table. What are all the things that might go wrong and how can you reduce or remove the risk?

Digital Divide — how it effects people with disabilities and a May 12 date for applications to begin

A vibrant blue background of keys and rods with a plug pushing toward the rods.

Even the tech savvy among us are tired of video calls and email rather than in-person conversations, but let’s face it — we have made a shift in communication and we aren’t going back. My doctor routinely asks if I’d like a video appointment. We have apps for our favorite restaurants and are picking up food and eating at home. Center boards of directors have realized that video meetings provides equal access, and that the one or two who used to be in the background on a conference line are now full participants in the board meetings. Gaining access to vaccine appointments and necessary food have often been coordinated with on-line registration. Parents have learned that, like it or not, their children’s education also depends on broadband at least some of the time.

The CARES Act allowed centers to assist people with digital access to their services — remote Independent Living skills classes, face to face (peer support) calls, and as a bonus all the other digital access your community provides. CILs purchased or loaned tablets and laptops to consumers and were able to pay for some of their wireless bills. And CILs have realized that they can’t pay for this access long term, and something must be done to allow folks to continue to access their digital world. Centers who did not benefit from CARES Act and areas where their resources are spent are looking for other funding for consumers.

While it is not a complete answer to the digital divide, the FCC has announced an Emergency Broadband Benefit funded through the COVID-19 package passed in December. You can read the resulting announcement here. CILs can assist their consumers in knowing about and accessing this support, which is up to $50 a month, and $75 for households on qualifying Tribal lands. A one-time equipment discount of $100 is also available. There seems to be universal agreement that internet connectivity is essential these days. Let’s expand consumer knowledge about this new option.

This program is administered through local broadband providers, so individuals can go to their participating broadband provider directly and apply through them. Another choice is to go to and apply there. It is also possible to visit for a webinar that provides an overview, and to get other information. The ASL phone line is 844-432-2275

Your household qualifies for the Emergency Broadband Benefit if it has an income at or below 135% of the federal poverty guidelines OR any member of the household:

  • Qualifies for Lifeline benefits through participation in SNAP, Medicaid, Supplemental Security Income, Federal Public Housing Assistance, or Veterans and Survivors Pension Benefit;
  • Participates in one of several Tribal specific programs: Bureau of Indian Affairs General Assistance, Tribal Head Start (only households meeting the relevant income qualifying standard), Tribal Temporary Assistance for Needy Families (Tribal TANF), Food Distribution Program on Indian Reservations;
  • Experienced a substantial loss of income since February 29, 2020 with a total household income in 2020 at or below $99,000 for single filers and $198,000 for joint filers;
  • Received a federal Pell Grant in the current award year;
  • Received approval for benefits under the free and reduced-price school lunch program or the school breakfast program, including through the USDA Community Eligibility Provision, in the 2019-2020 or 2020-2021 school year; or
  • Meets the eligibility criteria for a participating provider’s existing low-income or COVID-19 program, and that provider received FCC approval for its eligibility verification process.

Only one monthly service discount and one device discount is allowed per household. Program rules acknowledge there may be more than one eligible household residing at the same address.

Employee Retention Tax Credits are available Even If You Got PPP Loan(s)

This credit just got a whole lot better so don’t stop reading because you decided this credit was not valuable for you.

Calculator, ledger and pen with a big blue sticky notes saying TAX Credits.

First, if you have not applied for your PPP loan, projections are that that money will run out by the first week in May, so apply now if you qualify.

You can claim the Employee Tax Retention Credit even if you got PPP loans, but, you cannot claim a credit for the same payroll used for your PPP loan forgiveness.

IRS says (in notice 2021-23) that for the first two quarters of 2021, organizations are eligible if they have a decline in gross receipts of 20% or more in the first or second quarter of 2021 (compared to the same quarters in 2019) or are subject to a full or partial government ordered shutdown due to Covid 19. For employers that were not in existence during 2019, they would calculate whether there was a decline from the first two quarters of 2020.

The 2021 credit is 70% of the first $10,000 of each employee’s wages ($7000 per employee) per quarter.

Employers with under 500 employees can request advance payment of the credit, while others will use the credit as a reduction of the employment taxes they are required to pay.  IRS form 7200 is used to claim the advance payment. Employers with over 500 employees will reduce the payroll taxes that they pay in quarterly.

The recently enacted American Rescue Plan extends the credit for the remainder of this calendar year, so there will be additional guidance from IRS on how this credit will apply on the 3rd and 4th quarters of 2021.

It is not too late claim the credit for 2020 if operations were fully, or partially suspended due to a government order or if your gross receipts in any quarter of 2020 were less than 50% of the same quarter in 2019. The 2020 credit is limited to 50% of up to $10,000 of wages, or a maximum of $5000 per employee per year. The 2020 credit also defined a small employer as one with 100 employees or less. For small employers all wages could count but for large employers, only salary continuation paid to employees who were not working could qualify.

So, if you looked at this credit before and said “nah”, look again. And if you decided that it was easier to apply for your PPP forgiveness using just payroll, think again because using less payroll and more other costs like rent will preserve more payroll for the Employer Retention Tax Credit.

You CAN continue spending CARES Act funds into next fiscal year!

On April 16, the Office of Independent Living Programs, Administration for Community Living, indicated they would provide a one-time, 12-month No Cost Extension automatically for some of its grants to Centers, specifically to the CARES Act and Independent Living Services (Part B) funds to centers. CIL funds (Part C) have not been extended. Please note this is breaking news and we may get more clarification as this unfolds.

Blocks of wood with letters and numbers spelling out BUDGET and then showing the years 2020, 2021, 2022.

This is described more specifically in the no-cost extension guidelines, and specifies the grants that are included are FFY2020 Independent Living Services Grants (ILSG): 2001XXILSG and Centers for Independent Living (CILs) CARES Act (ILC3): 20NNXXILC3.

A no-cost extension (NCE) allows a grantee to request additional time to extend the period of performance end date of a grant in order to complete the overall goals and performance outcomes originally proposed in the award funded by the Administration for Community Living. in this case the center’s one year extensions for CARES Act and ILS (Part B) funds are automatic, meaning no application is required. It is strongly recommended that each Center take the time to modify your budget to encompass these additional funds, spreading the remaining funds into next fiscal year if you wish. They still need to be spent for their original purpose, but you have a longer period of time to spend out the funds.

An important note about how this affects the CDC Vaccine funds. ACL indicated, “We understand that this information may change your CILs decision to pursue CDC Vaccine funds from decline to accept. If so please submit a new assurance indicating acceptance. The most recently received assurance will be the one ACL uses when awarding funds. As a reminder, the deadline to submit as assurance for those funds is 11:59 p.m. Eastern Time on April 23, 2021.

Let me summarize the grant sources and the status:

  • Direct CIL grants (Part C) — No change in deadlines or other requirements
  • ILS Grants through the SPIL/DSE — No cost extension to September 30, 2022 applies
  • CARES Act Funds — No cost extension to September 30, 2022 applies
  • CDC Vaccine funds — Deadline for accepting or refusing grant is still April 23, 2021; funds may be used through September 30, 2022.

Are you ready for the increased costs of a financial compliance audit?

John Heveron gave you some tips a few weeks ago on preparing for your financial audit. Just a reminder — if you spent $750,000 or more in federal funds last fiscal year, or will this fiscal year, you are required to have this more extensive audit. Any year that you spend $750,000 in federal funds, this audit is required. For many centers, the CARES Act funding pushed them over that threshold.

Auditor and executive review financial information on a computer screen.
Auditor and executive review financial information on a computer screen.

But an astute CIL director asked me , “How can I afford those audit costs next year when CARES Act funds are gone?”

This is a good question. We cannot typically carry over funds to the next year with either Part C or CARES Act. What can we do to cover the audit expenses when we are back to our basic pre-COVID budgets? The “single audit” costs are required specifically because the CARES Act funds temporarily increased your income over this two-year period. So can the CARES Act pay their share of those costs? It doesn’t make sense for Part C to pay for costs generated by the CARES Act funds, does it? In fact I might argue that you CANNOT use a funding source to pay an expense incurred by a different project or cost objective.

You are allowed to pay for actual expenses of your federal grants after their closing date IF those costs were encumbered during the grant year (Prior to September 30, 2021 in this case.) Encumbered funds are monies that are intentionally set aside to pay for future obligated or planned expenses. Although encumbered funds are not released until the payment for the future expenses is due, the funds cannot be used for anything other than their specified purposes.

It seems allowable, to us, to develop a contract now for your single audit, to sign it prior to the end of the fiscal year. This would then encumber those dollars so that they cannot be used for any other purpose. You should be able to draw them down prior to December 31 and utilize them to pay the CARES Act portion of the audit expenses.

Remember that you still have to properly allocate all your shared expenses, including this audit, so your other grants will pay a share as well. If you have not had single audit/compliance audits in the past, you should meet with your auditor or another auditor qualified to do this and ask them to explain the process, including what they would expect from you, and tell you what their fee would be.

Let’s talk about the new funding focused on vaccination

You had until April 23, 2021 to submit a letter to ACL to indicate if you want the funds, or if you choose to decline them. The next task — how will you use those funds on COVID-19 vaccine efforts?

There is a new funding source available to Part C centers, as described in the Federal Register. This is a much smaller, much more narrow and focused opportunity than CARES Act. ACL/Office of Independent Living Programs provided an FAQ which we will disseminate as soon as it is available. The same regulations of the allowable activities under this CDC funding apply. The expenditures of the funds must be related to vaccines specifically, including:

  • Education about the importance of receiving a vaccine
  • Identifying people unable to independently travel to a vaccination site
  • Helping with scheduling a vaccine appointment
  • Arranging or providing accessible transportation
  • Providing companion/personal support
  • Reminding people of the second vaccination appointment if needed
  • Providing technical assistance to local health departments or other entities on vaccine accessibility

You probably noticed that all of these are also allowable under the CARES Act and in fact all of these have been repeatedly messaged by OILP as things CILs could be doing with CARES Act funds. This new money is not a supplement to the CARES Act but can provide supplemental funding for vaccine related costs.

All the same Federal rules around allowability are exactly the same as any other funding source. There, like for all Federal funding, will be reporting requirements (TBD), and grantees should expect to be able to track activities and expenses accordingly.

It appears total of $5 million in funds will be distributed equally between the centers that wish to access the funds.