What CILs and SILCs need to know about the
American Recovery & Reinvestment Act (ARRA)
As we move forward in the 111th Congress, it is critical
that we demonstrate the power of the grass-roots independent living movement.
We will secure full civil rights for people with disabilities and create a
world in which people with disabilities are valued equally and participate
fully!
The NCIL staff and board have been in constant contact
with RSA, waiting for answers to our questions on the stimulus act (the ARRA).
RSA has been telling NCIL they will have paperwork describing how much each
state will receive and how soon.
The following questions have been submitted to the
Rehabilitation Services Administration, along with NCIL recommendations.
1. When does the funding become available? Once available,
is it subject to the same provisions as Part C, such as not having the ability
to carry over funding?
NCIL recommendation: Due to the pressing need to expend
funding within the existing year, and due to the fact that we are almost
half-way into fiscal year 2009, we suggest allowing flexibility with ARRA
funding so that it can be carried over into the following fiscal year. Most
CILs will have the capacity and infrastructure to utilize the funding over a
full fiscal year, but some may have difficulty in expending their allocation in
a short period of time. Therefore, waiving the carry-over restrictions for FY
09 and 10 would ensure the proper and efficient expenditure of funds.
2. How can a CIL that does not receive Title VII Chapter 1
Part B or C funding apply to receive funding?
NCIL recommendation: Assuming that the CIL meets the
standards and indicators as described within Section 725 of the Rehabilitation
Act of 1973, as amended, ARRA funding for Title VII Chapter 1, Parts B, C, and
Chapter 2 is subject to the goals set forth within a state’s approved
state plan for independent living (SPIL), which should also include a priority
for the distribution of new funding. RSA will ensure that monies are
distributed accordingly.
3. In states in which state money exceeds federal
allotment (723 states), will the funding be distributed through the Designated
State Unit (DSU)?
NCIL recommendation: Yes.
4. Is the funding restricted to a particular service?
NCIL recommendation: ARRA funding allocated through Title
VII Chapter 1 Part B and Chapter 2 will be subject to the goals, objectives and
priorities established within the state’s SPIL. ARRA funding allocated
through Title VII Chapter 1 Part C will be subject to the center’s
approved budget.
5. Will Part B and C funding allocated through the ARRA be
required to be consistent with SPIL?
NCIL recommendation: Yes. See numbers 3 and 4.
6. Several states have reported a reduction in the
appropriations to CILs because of the ARRA. Because of such, there is little
benefit in receiving ARRA funding despite its intention “to stabilize
state and local government budgets in order to minimize and avoid reductions in
essential services and counterproductive state and local tax increases.”
NCIL recommendation: A maintenance of effort clause or
regulation be implemented so that states do not reduce the amount of state
appropriations to CILs.
7. Can NCIL, RSA and ILRU develop training and technical
assistance designed to assist SILCs in amending their respective SPILs (if
needed) so that the money is distributed according to its intent and consistent
with the SPIL?
NCIL recommendation: Yes
8. Can NCIL, RSA and ILRU develop training and technical
assistance designed to assist CILs in entrepreneurial activities?
NCIL recommendation: Yes
9. Will ARRA funds be distributed according to the current
funding formula for Title VII, Part B and C funds?
NCIL recommendation: AARA funds will be distributed
according to existing formulas and SPIL recommendations.
10. How can I calculate how much money my organization
will receive?
NCIL recommendation: A guidance letter should be issued to
all CILs and SILCs informing them of the amount their state will receive in
Chapter 1 Parts B, C, and Chapter 2 funding. The letter should also provide
details of allowable expenditures, the opportunity to amend budgets and SPILs
as necessary and should include the intent language from the act. A letter
should be issued to NCIL detailing the overall amounts nationally as well as
per state and should also include details of expenditures, the opportunity to
amend budgets and SPILs as necessary, and it should include intent language
from the act.
11. In the unfortunate event that a state refuses to
follow guidance provided within the SPIL, should a grievance procedure be
included within the letter?
NCIL recommendation: Yes, The guidance should also be
uploaded on RSA’s Web site for reference purposes.
12. Can ARRA funds be used for capital expenses?
NCIL recommendation: ARRA funding can be used in
accordance with the CIL’s and SILC’s approved budget.
13. How will ARRA funded activities be monitored?
NCIL recommendation: ARRA funding should be monitored and
reported through the existing Annual 704 Report.
14. Is a state match required for Title VII Chapter 1 Part
B?
NCIL recommendation: ARRA funding is not subject to state
matching requirements. |
