Resource Development within the
Scope of SILC Duties
March 27, 2014
Presenter:
Ann McDaniel
SILC-NET, a project of ILRU – Independent Living Research Utilization
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Learning Objectives
• Describe the regulatory requirements regarding SILC resource
development
• Describe opportunities for SILCs to obtain allowable public and
private sources of funding
• Identify Examples of creative approaches to SILC resource
development
SILC-NET, a project of ILRU – Independent Living Research Utilization
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Clarifications
• Resource development is not within the scope of SILC Duties
• Cost principles published by the Office of Management and
Budget (OMB) preclude the use of federal funds to raise
money*
• There are ways for SILCs to obtain other funding, depending
on how the SILC is organized
• Restrictions are placed on the SILC Resource Plan
• Activities of SILC members and staff are less restricted when
funds from the SILC Resource Plan are NOT used
• Activities using other funds may not impede accomplishment of
SILC Duties
• *This is not true of centers for independent living who are actually required by Title VII to do
resource development.
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SILC Duties
• Jointly develop and sign the State Plan for Independent Living
(SPIL)
• Monitor, review, and evaluate the implementation of the SPIL
• Coordinate activities with the SRC and other councils that
address the needs of specific disability populations
• Ensure meetings are open to the public & provide notice
• Submit reports to RSA as requested & maintain records
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Additional Duties
• Prepare, in conjunction with the DSU, a resource plan for the
provision of resources, including staff and personnel.
• Ensure the proper expenditure of funds and use of resources
that it receives under the resource plan.
• Supervise and evaluate SILC staff and other personnel as may
be necessary to carry out SILC functions and duties.
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Other Activities within the Scope of SILC Duties
•The SILC may also conduct activities to maximize the
cooperation, coordination & working relationships among:
– SILS program
– CILs
– DSU
– Other State agencies represented on the SILC
– Other Councils that address the needs of specific disability populations
and issues
– Other public and private entities determined to be appropriate by the
SILC
•SILC Duties do not allow for the SILC to conduct
resource development activities
SILC-NET, a project of ILRU – Independent Living Research Utilization
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How is Your SILC Organized?*
• Is your SILC a 501 (c)(3) non-profit?
• Is your SILC staffed by your DSU?
• Is your SILC organized some other way?
*All SILCs are subject to the same federal requirements regardless of their
organizational status.
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501 (c)(3) Non-Profit SILCs
• Fulfill SILC duties as the designated SILC for the State utilizing
the SILC Resource Plan
• Conduct other activities allowable for a non-profit, providing
funding is available
SILC-NET, a project of ILRU – Independent Living Research Utilization
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SILC Staffed by DSU
• Fulfill SILC duties as the designated SILC for the State utilizing
the SILC Resource Plan
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SILC Organized Some Other Way
• Fulfill SILC duties as the designated SILC for the State utilizing
the SILC Resource Plan
• Conduct other activities allowable within the structure,
providing funding is available
SILC-NET, a project of ILRU – Independent Living Research Utilization
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Who Processes SILC funding?
• Federal funding is received and administered by the DSU
• Non-profit SILC receives funding from the DSU and administers
it according to the contract/grant/agreement for the SILC
Resource Plan
• DSU processes funding for SILC staffed by the DSU
• When a SILC is organized some other way, that may impact
how funding is processed
• How is your SILC funding processed?
SILC-NET, a project of ILRU – Independent Living Research Utilization
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SILC Resource Plan vs. Operating Budget
• Every SILC has a SILC Resource Plan, as required by Section
5.1 of the SPIL
• SILC Resource Plan may only be used for SILC
Duties/responsibilities
• If your SILC is a non-profit, you may have an operating budget
beyond the SILC Resource Plan
• If your SILC is organized some other way, you may have an
operating budget beyond the SILC Resource Plan
SILC-NET, a project of ILRU – Independent Living Research Utilization
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SILC Resource Plan
• Detailed in your State Plan for Independent Living (SPIL)
• May only be used to perform SILC duties/responsibilities
• Funding may include:
– Title VII, Part B funds
– Title I, I&E funds
– Funding from other public & private sources
SILC-NET, a project of ILRU – Independent Living Research Utilization
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SILC Operating Budget*
• Includes but is not limited to the SILC Resource Plan
• Includes all funding the Non-Profit (or otherwise organized)
SILC has
• Is not detailed in the SPIL
• May include funding from any public or private source
• May be used for:*
– Any purpose approved by the funding source; and
– Allowable under IRS regulations for non-profits
*SILC operating funds beyond the resource plan can only be used in a way that does not impair
or conflict with the SILC statutory duties and must be accounted for separately from resource
plan funds.
SILC-NET, a project of ILRU – Independent Living Research Utilization
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Questions & Answers
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What do you need new money for?
• What you need the funding for determines where you may be
able to find it
• Only seek funding that supports what you want to do –
activities/projects consistent with your SILC mission and/or
consistent with SILC Duties
– West Virginia SILC Mission Statement:
“To ensure persons who have disabilities have access to community-based
resources that promote personal choice and facilitate the achievement of
their independent living goals.”
• Do not tailor activities/proposed activities around what funding
you think you may be able to get
SILC-NET, a project of ILRU – Independent Living Research Utilization
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Additional Funding to Perform SILC Duties
• If your SILC needs additional funding in the SILC Resource
Plan in order to fulfill your SILC Duties – ALWAYS start by
negotiating with your DSU for more funding
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Additional Funding to Perform SILC Duties
• Section 705(e)(1) of the Rehab Act requires:
– The Council shall prepare, in conjunction with the designated State unit,
a plan for the provision of such resources, including such staff and
personnel, as may be necessary and sufficient to carry out the
functions of the Council under this section, with funds made available
under this chapter, and under section 110 (consistent with section
101(a)(18)), and from other public and private sources. The resource plan
shall, to the maximum extent possible, rely on the use of resources in
existence during the period of implementation of the plan.
SILC-NET, a project of ILRU – Independent Living Research Utilization
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Additional Funding to Perform SILC Duties
•Section 101(a)(18) requires
•The State plan shall
•(A) include an assurance that the State will reserve and use a portion of the
funds allotted to the State under section 110
– for the development and implementation of innovative approaches to expand and
improve the provision of vocational rehabilitation services to individuals with
disabilities under this title, particularly individuals with the most significant
disabilities, consistent with the findings of the statewide assessment and goals and
priorities of the State as described in paragraph (15); and
– to support the funding of
•(I) the State Rehabilitation Council, if the State has such a Council, consistent with the plan prepared
under section 105(d)(1); and
•(II) the Statewide Independent Living Council, consistent with the plan prepared under section
705(e)(1);
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Where else can you get new funding?
• As a non-profit SILC:
– From any public or private source that funds what you want to do
– From donations
• For Example:
–
–
–
–
–
–
Foundations
Corporations
Banks – Community Reinvestment Funds
Federal & State Grants
Local Service Organizations
Fundraising Activities
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Where else can you get new funding?
• As a DSU staffed SILC:
– From the DSU (when you negotiate the SILC Resource Plan during SPIL
development)
– From the State/Legislature – but the DSU would have to request
– From funders that will fund the DSU/a state agency
– From donations, if your state allows
• As a SILC organized within a non-profit:
– From sources for which the non-profit is eligible
SILC-NET, a project of ILRU – Independent Living Research Utilization
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Questions & Answers
SILC-NET, a project of ILRU – Independent Living Research Utilization
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How else can you get new funding?
• As a Non-Profit SILC:
–
–
–
–
–
Apply for grants that fund what you want to do
Seek donations and grants from Corporations
Seek donations from individuals
Apply for bank Community Reinvestment Funds
Partner with other organizations
• Caution:
– You may not use federal funding to seek other funding including:
• Paid staff time
• SILC computers, equipment, & supplies
• Other resources including office space & utilities
• BUT:
– SILC members may conduct all these activities on their own time without SILC
resources or reimbursement
SILC-NET, a project of ILRU – Independent Living Research Utilization
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How can you get new funding?
• As a SILC staffed by the DSU:
– Include additional funding when negotiating SILC Resource Plan with
the DSU
– Ask the DSU to seek State funding for the SILC
– Ask the DSU to accept donations to the SILC
– Write proposals to funders that will fund through DSU
• Caution:
– The SILC cannot solicit funds using federal funding to do so.
SILC-NET, a project of ILRU – Independent Living Research Utilization
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How can you get new funding?
• As a SILC organized some other way:
– Depends upon how you are organized
– If within another non-profit, you may collaborate with them to seek
grants, donations, and other funding
• Caution:
– The SILC cannot solicit funds using federal funding to do so.
SILC-NET, a project of ILRU – Independent Living Research Utilization
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Partnerships with Other Entities
• Activities to maximize the cooperation, coordination & working
relationships with others may present opportunities to secure
new funding to support the SPIL objectives through:
– Grant applications
– By serving as a fiscal agent
– By providing a service (i.e. bookkeeping or accounting)
• Caution:
– Be sure funding is included for the SILC in any of the above
– Be sure to track funding to be able to demonstrate SILC Resource Plan is
only used for SILC Duties and other activities/costs are covered by other
funding
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What West Virginia Has Done
• Partnerships:
– SRC
– Fair Shake Network
– CED
• Grants:
– Disability History Essay Contest
– Disability Caucus
– Advocacy Activities
– NOTE: Grant applications prepared outside SILC duties and without
using SILC Resource Plan
• Serve as fiscal agent for grants to the WV Commission for the Deaf & Hard
of Hearing
• Serve as bookkeeper for the Fair Shake Network
• All of the above include administrative costs for the SILC
SILC-NET, a project of ILRU – Independent Living Research Utilization
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Ideas from Other States
• Created a Development Committee/Subcommittee of the SILC
to define and discuss development issues for the Council
• SILC members are volunteers and write proposals and do
solicitation on their own time
• Raised “seed money” to support further development activities
• Document these activities verifying they occur at times and
with resources not included in the SILC Resource Plan
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A Barrier
• States indicate grant writing has been hampered by lack of
unrestricted funds to use as non-federal match and SILCs are
continuing to look for creative solutions to the problem.
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How to Manage All SILC Resources
• SILC Operating Budget and Financial Reports Must:
– Show all sources of funding
– Budget all sources of funding separately
– Track all expenditures by source of funding
• SILC must be able to demonstrate:
– Use of SILC Resource Plan is restricted to SILC Duties
– Other funding is available and is used for all other SILC activities
• In some cases, proposal costs are recoverable as indirect
costs. The SILC would need to have a pre-approved indirect
cost rate or cost allocation plan.
• Use of Funds beyond the SILC resource plans must not impair
or conflict with the SILC statutory duties and must be accounted
for separately from SILC resource plan funds.
SILC-NET, a project of ILRU – Independent Living Research Utilization
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Questions & Answers
SILC-NET, a project of ILRU – Independent Living Research Utilization
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Contact Information
– Ann McDaniel - [email protected]
SILC-NET, a project of ILRU – Independent Living Research Utilization
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Wrap Up and Evaluation
•Please click the link below to complete your evaluation
of this program:
https://vovici.com/wsb.dll/s/12291g55d18
SILC-NET, a project of ILRU – Independent Living Research Utilization
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SILC-NET Attribution
•Support for development of this training was provided by the
U.S. Department of Education, Rehabilitation Services
Administration under grant number H132B070001. No official
endorsement of the Department of Education should be
inferred. Permission is granted for duplication of any portion of
this PowerPoint presentation, providing that the following credit
is given to the project: Developed as part of the SILC-NET,
a project of the IL-NET, an ILRU/NCIL/APRIL National
Training and Technical Assistance Program.
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