NCIL Comments on Proposed SILC Indicators Comment 1: The indicators under the first Standard, SILC membership reflects IL philosophy, are mis-numbered (there are two 1.3s) and this should be corrected. Comment 2: Indicators 1.2 & 1.3 assume that all SILCs are organized as 501(c)(3)s and have an executive director. Not only is this not the case – it is not required by law. NCIL recommends the following revisions: - 1.2 The SILC hires, supervises and evaluates its [insert] own staff [end insert] [strike] executive director [end strike]. - 1.3 [insert] If [end insert] The SILC [insert] has an [end insert] executive director, [strike] supervises and evaluates [end strike] SILC staff [insert] are hired, supervised, and evaluated by the executive director [end insert]. Comment 3: There is no standard regarding SILC Autonomy. NCIL recommends that indicator 1.8 be a standard, not an indicator. - [insert] Standard 6 – The SILC is not established within any state agency and is organized in a manner that ensures SILC autonomy [end insert]. Comment 4: Indicators 1.2, 1.3, & 1.9 (currently numbered 1.8) are more related to SILC autonomy than to IL philosophy and should be moved to the recommended sixth standard on SILC Autonomy. Comment 5: NCIL believes 1.4 exceeds the authority and responsibility of the SILC and recommends the following revision: - 1.4 The SILC provides training at least once a year to its members. [strike], CILs, and other providers, and other individuals eligible for services under Chapter 1 of Title VII of the Rehabilitation Act, as amended, [end strike] Comment 6: NCIL believes 2.1 b. & c. should be combined and clarified and recommends the following revision: - 2.1 b. Meeting locations must be physically accessible to [insert] all [end insert] people with disabilities, [insert] including but not limited to physical accessibility and [end insert] [strike] c. The SILC shall provide such [end strike] effective communication and accommodations, including auxiliary aids and services, necessary to make the meeting accessible to people with disabilities. Comment 7: NCIL believes 2.1 should clearly indicate that the draft SPIL should be made available to the public sufficiently in advance of any public meetings (or other forums) to receive public comment. Therefore, NCIL is recommending adding the following indicator: - [insert] 2.1.d. The SILC ensures the draft SPIL is made available to the public when the advance notice is provided of public meetings (or other forums) for gathering public comment/feedback on the draft [end insert]. Comment 8: NCIL believes that 2.2 b. cannot effectively, and should not, be achieved without the involvement of the CILs and recommends the following revision: - 2.2 b. The SILC has [insert] shall work with the CILs in the state, as defined in Sec. 702, develop [end insert] a process to determine which CILs are eligible to [insert] develop and sign the SPIL [end insert]. Comment 9: NCIL believes there should be due process for CILs when there are disagreements on the SPIL to prevent submission without their consent and recommends adding the following indicator: - [insert] 2.1.e. The SILC and CILs shall develop a process to resolve differences on SPIL content to ensure due process prior to SPIL submission [end insert]. Comment 10: NCIL believes 4.1 exceeds the requirements of the law and presumes all SILCs have a website. Therefore the revisions are recommended: - 4.1 The SILC meets quarterly [insert] as often as necessary to conduct business and fulfill SILC responsibilities, consistent with state law [end insert], and ensures that such meetings of the Council are open to the public and provides sufficient advance notice of such meetings, [insert] such as [end insert] [srike] including [end strike] posting advance notice of such meetings on the home page of the SILC website. All notices and meeting materials are available in accessible formats [insert] upon request [end insert]. Comment 11: NCIL strongly believes in accessibility and accommodations to ensure all SILC meetings and activities are fully accessible to the public, including all people with disabilities. Given the wide disparity in SILC resource plans and to ensure accountability of expenditures, the following revision is recommended: - 4.2 SILC meetings are open to the public except for confidential matters which the state's open meetings or sunshine law would allow to be held in closed session. The SILC holds meetings in locations accessible to people with disabilities. and provides Such effective communication and accommodations as are necessary to make the meeting accessible to people with disabilities are [insert] provided upon request [end insert]. Comment 12: NCIL believes the requirement of “minutes” proposed in 4.3 could result in hesitance on behalf of the public to fully participate in public hearings and forums and may even result in retaliation against those speaking out. Therefore, the following revision is recommended: - 4.3 The SILC maintains copies of advanced notice, registration lists and [strike] minutes and other [end strike] documentation of input gathered at hearings and forums conducted, as appropriate, and makes them available in accessible formats [insert] upon request [end insert]. Comment 13: The language in the law regarding the use of Part B funds for the SILC Resource Plan says: “ . . . may not use more than 30 percent of the funds paid to the state under section 712 for such resources (resources described in section 705 e.) unless the State specifies that a greater percentage of the funds is needed for such resources in a State plan approved under section 706 . . .” NCIL believes draft indicator 5.2 exceeds this requirement and recommends the following revision: - 5.2 If the resource plan includes Title VII, Part B funds, the SPIL provides justification of the percentage of Part B funds to be used, [strike] particularly [end strike] if the percentage exceeds 30%, with references to the SPIL.