NCIL Comments on Notice of Proposed Priorities for Centers for Independent Living Program – Training and Technical Assistance

4 April 2007

 Mr. Sean Barrett
Independent Living Unit
Rehabilitation Services Administration
Office of Special Education and Independent Living Services
Department of Education
Rm. 5042, Potomac Center Plaza
400 Maryland Avenue
Washington, DC 20202-2800

Dear Sean:

The Department proposes to establish two separate priorities and award separate grants--one for CILs and one for SILCs.  NCIL believes this is a bad idea!

1)  Shortly after the reauthorization of the Rehabilitation Act in 1992, centers approached Congress and asked that the statute be revised the following year through a Technical Amendment.  This revision added SILCs to those who were eligible to receive training and technical assistance using these Part C funds.

Prior to the inclusion of this amendment, only CILs and agencies eligible to become CILs could receive training using these funds.  Centers felt strongly that SILCs deserved to be included in this program and that the shared training could only enhance the IL network and promote understanding between CILs and SILCs.

The Department believes that this approach “would encourage applicants to address completely and comprehensively the unique training and technical assistance needs of CILs and of SILCs.” 

Others have expressed concern that it is absolutely essential that no unnecessary lines be drawn between members of our independent living family.

NCIL knows through first-hand experience how our IL community has to work together to build a strong state network, and that partnership begins with a common understanding of who we are and why we’re here.  There continue to be states where the CILs and SILCs are not working in complete harmony.  Separate Training and Technical Assistance tracks will not help bring those entities together to work for the common good in their respective states, indeed it may enhance their differences, lack of communication and misunderstandings.  Let’s not allow any additional barriers to be placed between us. 

What the Department could do that would be helpful in problem states where difficulties still exist between the CILs and the SILCs is do training for the DSUs and Governors of those states on what Title VII says about CILs and SILCs and how to appoint a proper SILC and let it do its mandate without interference and with proper funding.

NCIL sees no gain in efficiency or costs by splitting the Training and Technical Assistance efforts into two grants.  Indeed, it appears that dual overheads, administrative costs, staffing patterns, etc. will only decrease efficiency and waste limited funds that could be better used for training programs and TA.

Additionally, NCIL does not believe the training and TA needs of CILs and SILCs are so unique and so different that they need to be or should be separated.  They both have common issues of solid organizational management.  They both have the need to know about developments and changes in independent living and the many issues involved in getting many people with diverse disabilities the services to function independently in the community.  They both need to be grounded in advocacy and community change.  They both need to be concerned about reporting and outcome measures.  There cannot even be effective conversations about the State Plan for Independent Living without the concerns and issues of both the CILs and SILCs being addressed.  The Independent Living Program, both Nationally and at the State level needs to be seen and treated holistically and not in separate silos.  Applicants for the Training and TA grant should be required to show considerable expertise and knowledge in the operation, issues and concerns, reporting and agendas of both CILs and SILCs.

2)  NCIL is equally concerned about the lack of substantive, as opposed to administrative, priorities for this Training and TA grant.  There are a number of areas were our CILs and SILCs could use additional training and TA to support their response to developing problems and increasing areas of concern.

Transitioning, both for young people with disabilities transitioning from school to independent living and work or higher education and for people with disabilities desiring to transition from institutional settings to the community, continues to be a major priority of the CILs and SILCs throughout the country.  They continue to request training and TA in this area, especially when major developments such as Money Follows the Person and other Medicaid changes take place.  There is a high likelihood that this Congress will finally reauthorize the WIA/Rehab Act.  The version of this act that almost passed in the last Congress, included a “fifth core service” for CILs – transitioning.  NCIL has strong reason, as we are sure the Department does, that any new version reauthorizing WIA/Rehab will also have this “fifth core service.”

There is nothing in the priorities pertaining to the significant numbers of severely disabled veterans returning from Iraq and Afghanistan.   These veterans are showing up in increasing numbers at CILs, especially those with traumatic brain injury and post traumatic stress syndrome.  They are seeking assistance in independent living supports that the VA seems unable to provide.  Our CILs and SILCs could benefit from a better understanding of their unique needs, veterans benefits, and resources to help address their problems.

Many CILS and SILCs still need and want training in reaching diverse populations including: racial and ethnic minorities, youth with disabilities, older adults, and Native Americans.  There are tremendous needs for training and TA in outreach, sensitivity and understanding, and culturally sensitive materials for these diverse populations.

In conclusion, NCIL strongly encourages the Department to seriously re-think these proposed priorities and modify them as we have advocated above.

Sincerely,

Kelly Buckland                                       John A. Lancaster

President                                              Executive Director