CIL Justification

Office of Special Education and Rehabilitative Services

Rehabilitation Services Administration

Information Collection Request

Justification for this information collection:

Under the American Recovery and Reinvestment Act (ARRA), Federal agencies are required to ensure that:

• ARRA funds are awarded and distributed in a prompt, fair, and reasonable manner;

• The recipients of all ARRA funds are made known to the public, and the public benefits of ARRA funds are reported clearly, accurately, and in a timely manner;

• ARRA funds are used for authorized purposes and every step is taken to prevent instances of fraud, waste, error, and abuse;

• Projects funded under the ARRA avoid unnecessary delays and cost overruns; and,

• Programs meet specific goals and targets, and contribute to improved performance on broad economic indicators.

Since the passage of the Recovery Act, the Department has worked with States, Statewide Independent Living Councils (SILC), Centers for Independent Living (CILs), and other stakeholders to ensure that ARRA funds appropriated for the CILs program authorized by Title VII, Chapter 1, Part C of the Rehabilitation Act of 1973, as amended will be distributed in a prompt, fair, and reasonable manner that best meets the statutory purposes of the CIL program and the independent living needs of individuals with significant disabilities, particularly those individuals living in areas that are unserved or underserved by existing centers within States.  Through written guidance and teleconferences, the Department has stressed the objectives and requirements for the use of these funds to ensure that they are used consistent with statutory requirements to improve and expand independent living services for individuals with significant disabilities. In addition to providing general guidance on the appropriate use of Recovery Act funds, the Department believes that it is essential to collect information on how grantees propose to spend the Recovery Act funds before the funds are awarded in order to identify potential problems and ensure that funds are used appropriately for allowable purposes. 

 

As of this date, the Department anticipates that 332 of the 335 current CIL program grantees will be receiving Recovery Act funds in addition to their regular CIL program grant awards, with many grantees receiving Recovery Act awards that are larger than their regular grant awards.  Although these funds will be awarded as separate Recovery Act grants, these grants will be subject to the terms and conditions of the grants each entity receives for the fiscal year under the regular CIL program and are considered supplemental awards.  The Department’s Handbook for the Discretionary Grants Process (Handbook OS-01; http://connected/doc_img/acs_hb_os_01.doc), provides guidance on how grant awards in excess of the non-competitive continuation award amount should be administered.  On page 113 of the Handbook, Section 5.5.7 states that, for grants for which an official decides that a supplement is appropriate, the program official must obtain from the grantee a revised budget showing how the funds will be used and a description of the activities being supplemented. Requiring each grantee to submit a U.S. Department Of Education Budget Information Non-Construction Programs Form 524 showing how the Recovery Act funds will be used and including a narrative description of the activities to be supported with these funds would satisfy both Department guidelines for the supplemental grant awards and provide prospective information on the use of ARRA IL Part C funds that would enable program staff to better monitor grantee expenditures to ensure that fraud, waste, error, and abuse are prevented. The submission of the Form 524 for ARRA IL Part C funds will be in addition to the Form 524 the CILs have already submitted in order to receive their regular FY 2009 appropriation.

 

Attached are two letters to centers regarding the Department’s information collections requirements related to the award of ARRA IL Part C funds to grantees. Attachment A is a letter that will be transmitted to each CIL when the Department is ready to make an award of ARRA IL Part C funds to the CIL because the state in which the CIL is located has received the Department’s final determination on the distribution of ARRA IL Part C funds to existing centers in the state and any amendments to the State Plan for Independent Living (SPIL), required because of the distribution determination, have been approved. The letter provides the total amount of ARRA IL Part C funding, the time period for the use of the funds, and requires the submission of the ED 524 form sections A and C in order for the center to receive the IL Part C ARRA funds. Because not all State’s DSUs and SILCS have submitted their final proposals to RSA regarding the distribution of ARRA IL Part C funds in their states and some states will be submitting amendments to their State Plan for Independent Living (SPIL) for Departmental approval, the Department has prepared a slightly different letter to centers in these states informing them of the requirement to submit the ED 524 form when the Department is able to issue their ARRA IL Part C awards. This letter is Attachment B. The substance of the letters and the information RSA seeks to collect from the CILs is the same.

Attachments