NCIL Encourages OSERs to Prioritize Training and Technical Assistance for CILs, SILCs, and Section 121 Program

Christine Marschall
U.S. Department of Education
400 Maryland Ave., SW., Room 5053
Potomac Center Plaza
Washington, DC 20202–2800
Sent via email: Christine.Marschall@ed.gov

Dear Ms. Marschall:

We are writing on behalf of the National Council on Independent Living (NCIL) in response to the Notice of Proposed Priority regarding the Rehabilitation Continuing Education Program (RCEP) published in Vol. 73, No. 19, Tuesday January 29, 2008 issue of the Federal Register.

NCIL is the oldest cross-disability, national grassroots organization run by and for people with disabilities. Our membership includes people with disabilities, Centers for Independent Living (CILs), Statewide Independent Living Councils (SILCs), and other disability rights organizations. As a membership organization, NCIL advances independent living and the rights of people with disabilities through consumer-driven advocacy. NCIL envisions a world in which people with disabilities are valued equally and participate fully.

We are concerned that in spite of current regulations defining RCEP’s responsibility (CFR 34 389.10) to provide training and technical assistance to Centers for Independent Living (CILs), few RCEPs currently do so. The proposed priority implies a continuation of the present situation.

In addition, American Indian Vocational Rehabilitation services (as defined under Title I Section 121(a) of the Rehabilitation Act of 1973, as Amended) grantees have clear responsibilities to provide vocational rehabilitation services to American Indians and Alaskan Natives with disabilities, yet there is no mention of these grantees in the proposed priority.

Therefore, NCIL strongly encourages OSERs to clearly specify and emphasize a priority to providing training and technical assistance to Centers for Independent Living, Statewide Independent Living Councils and Section 121 programs.

Thank you for your consideration. Please do not hesitate to contact Deb Cotter of NCIL’s policy staff at (202) 207-0334, ext. 1008 or deb@ncil.org if you have any questions.

Sincerely,

Kelly Buckland                                                           John A. Lancaster
President                                                                    Executive Director