SPIL Consumer and Public Input As of 5/5/16
Input from Roxanne Cogil, Epilepsy Foundation of Iowa, on 3/31/16
Basically, what I’d like to see from the Independent Living Centers is that when there are people with disabilities who need help in finding a place to live, place to work (with accommodations in place) and accessible, affordable public transportation, the staff from the CILs can provide meaningful service by simply helping these people truly finding a place to live, place to work and accessible/affordable transportation. All three pieces need to be in place for that person with a disability to live independent (with our without supports) out in the community. If the person with a disability doesn’t have an adequate funding stream for the supports out in the community through a waiver/MHDS Region/Medicaid, ect…, then the CIL staff can help the person with the disability find other funding streams if needed. Those with disabilities who fall through the gaps of the system do not have case managers and need a place like CIL to help them coordinate finding a place to live, work and travel. There is no other group in the state, which coordinates all three pieces. I’d like to see this as the core description of the Independent Living Network, and the proposed goals, objectives, activities, and expected outcomes to reflect the number of people they help find housing, find jobs and access transportation, that is if it fits the mission, vision and guidelines of what the CILs are to do.
Response:
Just so you know, the items you mentioned ARE things that CILs are supposed to do, and I believe they are doing this. If you have info to the contrary, please let me know.
The items you talked about are part of what CILs do as the five core services they provide. As such, this would not be something we would put into the SPIL, as the SPIL is a more overarching document dealing with collaboration, accountability, and advocating for what needs to be in place to help Iowans with disabilities to be independent.
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Input from Jane Gay of the Iowa Program for Assistive Technology, on 4/1/16
HI Dawn - just a few suggestions about how you might demonstrate how SILC and ILC are working with the Iowa Program for Assistive Technology, which is the state AT program funded under the Tech Act of 1988 a amended:
On page 22 or 23: You serve on the Iowa Council for Assistive Technology, the state AT Program funding under the Tech Act of 1989 as Amended.
On page 23: SILC and ILC coordinate with the Iowa Program for Assistive Technology and Easter Seals Iowa’s AT Center to provide assistive technology services related to independent living including device demonstration, short term device loan for decision making, device recycling, awareness and training.
Response: Added the following on page 23 of the SPIL in response to this input:
7) Representation of the SILC Executive Director on the Iowa Council for Assistive Technology, the State AT Program funding through the Tech Act of 1989, as amended.
8) CILs and DSE/DSUs coordinate with Iowa Program for Assistive Technology and Easter Seals Iowa AT Center to provide assistive technology services related to independent living, including device demonstration, short term device loan for decision making, device recycling, and AT awareness and training.
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Input from Page Eastin of the Client Assistance Program (CAP), on 4/7/16:
Goal #4 Outreach Education
Activity A states that CILs and DSUs will have an outreach plan and will conduct the outreach activities in that plan. This is vague and does not provide any information on what is entailed in the outreach plans. It would be helpful if each CIL included their outreach plan as part of the SPIL.
Response: Page, we are not required to put those individual outreach plans into the SPIL, and it would also make the SPIL unbearably long. Each entity has to put that plan into their annual 704 Report to the feds, and you can request a copy of the 704 Report from each CIL as well as the DSUs.
1.2B Describe the steps planned regarding outreach to populations in the State that are unserved or underserved by programs under title VII, including minority groups and urban and rural populations.
-The SPIL identifies all Iowans with significant disabilities as being either unserved or underserved by the CILs. This does not specify a population that can be designated for “targeted outreach efforts”. While it is important to recognize that the funding is inadequate, it may be more reasonable to specify a specific population within that group to designate targeted outreach efforts toward.
Response: Page, the SPIL identifies Iowans with disabilities who live in counties with no CIL services as unserved, and those who live in 26 counties where the CIL’s have no office as being underserved. As stated previously, each CIL and each DSU have to specify in their own outreach plans as to how they will specifically serve folks. As we are all so underfunded, CILs generally prioritize the underserved in their current counties. But they can also provide information and referral to those from counties unserved by CILs.
-The SPIL references the objective for all Iowans to be better educated on IL history and philosophy, and leadership and systems change advocacy. However, it does not provide specific information about how that will be achieved.
Response: Page, that is purposely left open as we will be collaborating with other groups to figure out how to achieve that. However, we will put in the following in this section to give some examples of activities that MAY happen:
Examples of various strategies which may be implemented include, but are not limited to, webinars; IL Community of Practice calls; information flyers that can be available at each CIL; website information; presentations at state conferences involving Iowa Rehabilitation Association, DD Council, etc.; Olmstead Activities; Youth Leadership Forum.
Describe how the needs of individuals with significant disabilities from minority backgrounds will be addressed.
The SPIL again references the individual CIL outreach plans and the 704 Report but does not specifically state the needs of individuals with significant disabilities from minority backgrounds or provide a description of how those needs will be addressed. Perhaps creating plans for partnering with organizations that serve minorities would be helpful and could be included in the SPIL. For example, partnering with Ethnic Minorities of Burma Advocacy and Resource Center (EMBARC) to identify the needs of, provide outreach to, and serve individuals from those populations who have significant disabilities. A Cooperative Agreement or Memorandum of Understanding between the CIL(s) and EMBARC would be one way to help foster collaboration. Additionally, if there is a plan for ensuring language access through CIL services, that would be helpful to include. The Iowa Department of Human Rights Division of Community of Advocacy and Services houses the following offices representing underserved populations: African Americans, Latinos, Women, Persons with Disabilities, Asian and Pacific Islanders, Deaf and Hard of Hearing, and Native Americans. This may be a helpful statewide resource and would specifically help demonstrate efforts to address the needs of individuals from minority backgrounds.
Response: Page, I think these are great ideas, but this is something that the CILs and the DSUs must address in their outreach plans. Since they all have different ways of doing their outreach plans, it would be difficult to put anything specific in the SPIL, which is why we refer to the individual outreach plans of each organization. These are certainly ideas I can pass on to the CIL Directors and the DSUs to consider as part of their outreach plans.
6.6 Client Assistance Program (CAP) Information- 34 CFR 364.30
What is the method identified by each CIL to ensure that consumers are notified of the availability of the Iowa Client Assistance Program and its corresponding contact information?
Response: Page, as stated in the SPIL, each CIL and DSU is responsible for identifying the method to ensure that consumers are notified of the availability of the CAP and its contact info. We do not put the specific method for each CIL and DSU in the SPIL. You can contact them and ask them to provide you with the method they use.
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Input from Amanda Diorio, Sioux City CIL Staff, on 4/19/16:
We received public comment that we needed to add in the cost of the new fifth core service to the chart showing the Adequate Level of Funding for each CIL.
Response:
Dawn contacted the CIL Directors to ask them if they wanted to do this, and developed a formula for this. Five of the six CILs were in agreement that this should be added into the SPIL. The CIL in Council Bluffs, Southwest Iowa Center for Independent Living – League of Human Dignity, made the comment they did not feel it was necessary to add this into the SPIL. As the majority of CILs were in favor of this change, it was added into the SPIL.
Here is the change, with the changes being in RED:
1. Federal Regular Part C Funds Funding Priorities
Priority #1 – Bring the existing 6 CILs up to the Adequate Level of Funding as specified below.
Whenever new federal Part C funds are appropriated, the amount of the new federal Part C funds OVER COLA (Cost of Living Adjustment) will be distributed to the six Iowa CILs based upon the current percentage of Part C that each CIL receives, until every CIL has reached 100% of its Adequate Level of Funding as specified in this SPIL. Once a CIL has reached 100% of Adequate Level of Funding, the remaining funds that would have gone to that CIL will be distributed proportionately (based on the current percent of Part C funds each receives) to the other CILs who are not yet at their Adequate Level of Funding. All CILs must be at their Adequate Level of Funding before any new federal Part C funds can be utilized to start a new Center, as specified below.
Formula For Adequate Level Of Funding
The Iowa CILs developed a Funding Formula that details an itemized budget of the minimum amount of funding required to operate a CIL with three or fewer counties. The minimum amount of funding was determined to be $250,000 (Adequate Level of Funding for 1-3 counties) based upon known operating costs of number of staff and their salaries and benefits, along with other costs of operation such as rent, supplies, mileage, insurance, and so forth.
The Iowa CILs then created a second detailed itemized budget that outlines costs associated with adding one county. The amount of additional funding was determined to be $50,000 per county based on hiring additional staff and the associated costs.
However, to provide a more fair distribution of funds overall for the total current counties that each CIL is serving, a formula was developed to distribute half of this $50,000 amount, per counties over 3, based on total number of counties served over three counties, and half on the disability population in the total counties served for all CILs, regardless of the number of counties they serve.
With the addition of the new 5th Core Service of Transition in 2014, the CILs have added in additional funding needed to provide this core service, specifically in terms of the costs for transitioning people out of institutions. CILs will need additional funding to hire staff to do transition, and to pay for the up-front costs to transition people (for example, first and last months rent, utility deposit, furniture, kitchen items, sheets, towels, and clothing).
Iowa CIL Funding Formula
· 1-3 Counties Served: A Minimum $250,000 budget, plus an additional amount based on the total disability population in the total counties served by each CIL, as a higher population will require additional funds to hire adequate staff to serve the population.
· For all counties served over 3, add $50,000 per county, with $25,000 based on the formula for number of counties served by each CIL over 3, and $25,000 based on the total disability population in the total counties served by each CIL for all CILs regardless of the number of counties they serve.
· New 5th Core Service of Transition: CILs will need funds for one additional staff person for CILs serving 3 or less counties and with a total disability population for their service area of less than 30,000. The other CILs will need funding for two additional staff persons for CILs serving 3 or more counties and with a total disability population for their service area of 30,000 or more. This would be a cost of $50,000 per staff person for staff salary, benefits, and mileage. Added to this amount would be $4,000 per person transitioned for the upfront transition costs, times an average of 10 people transitioned per year. This would allow CILs serving 3 counties and a total disability population for their service area of less than 30,000 to transition an average of 10 people per year, and CILs serving 3 or more counties with a total disability population for their service area of 30,000 or more to transition an average of 20 people per year.
Below is a chart which outlines the Adequate Funding Level needed for each CIL.
CALCULATION CHART FOR 100% ADEQUATE FUNDING LEVEL FOR EACH CIL