NCIL: Celebrating 25 Years of Independent Living

What CILs and SILCs need to know about the American Recovery & Reinvestment Act (ARRA)

The following questions have been submitted to the Rehabilitation Services Administration, along with NCIL recommendations.

-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 FY 09, NCIL suggests 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 of the proper and efficient expenditure of funds.   

-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.  

-In states that state money exceeds federal allotment (723 states), will the funding be distributed through the Designated State Unit (DSU)?
NCIL Recommendation:  Yes.

-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 State Plan for Independent Living.  ARRA funding allocated through Title VII Chapter 1 Part C will be subject to the Centers approved budget.

-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.  

-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 in spite of 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: NCIL suggests a maintenance of effort clause or regulation be implemented so that state’s do not reduce the amount of state appropriations to CILs.

-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

-Can NCIL, RSA and ILRU develop training and technical assistance designed assist CILs in entrepreneurial type activities?
NCIL Recommendation: Yes  

-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

-How can I calculate how much money my organization will receive?  
NCIL Recommendation:  A guidance letter should be issued to all CILs / 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 should include intent language from the Act.  
In the unfortunate event that a state refuses to follow guidance provided within the SPIL, a grievance procedure should also be included within the letter.
The guidance should also be uploaded on RSA’s website for reference purposes.

-Can ARRA funds be used for capital expenses?
NCIL Recommendation:  ARRA funding can be used in accordance with the CIL / SILC’s approved budget.

-How will ARRA funded activities be monitored?
NCIL Recommendation:  ARRA funding should be monitored and reported through the existing Annual 704 Report.

-Is a State Match required for Title VII Chapter 1 Part B?

NCIL Recommendation:  ARRA funding is not subject to state matching requirements.