State Independent Living Council Discussion Archive

NATSILC: Many SILCs Missing Area Of Responsibility

Posted by: Lou Diehl
Date Mailed: Tuesday, May 6th 2003 10:50 AM

From: ForCompliance@aol.com
Date: Mon, 17 Mar 2003 01:22:48 EST
Subject: MANY SILCS MISSING AREA OF RESPONSIBILITY

MOST SILCS ONLY ADDRESSING AND EVALUATING PART OF THEIR MISSION -- WHOLE
AREA OF RESPONSIBILITY AND OPPORTUNITY OFTEN OVERLOOKED

The following observations and comments are examples only.  They do not
apply to every state SILC, but they do apply to far too many.  This
information is intended to promote discussion, not argument. 

Chapter 1, Section 701, defines the purpose of Title VII of the
Rehabilitation Act is defined as follows: 

"to promote a philosophy of independent living, including a philosophy of
consumer control, peer support, self-help, self-determination, equal
access, and individual and system advocacy, in order to maximize the
leadership, empowerment, independence, and productivity of individuals
with disabilities, and the integration and full inclusion of individuals
with disabilities into the mainstream of American society, by

(1) providing financial assistance to States for providing, expanding, and
improving the provision of independent living services. 
       
(2) providing financial assistance to develop and support statewide
networks of centers for independent living; and
         
(3) providing financial assistance to States for improving working
relationships among State independent living rehabilitation service
programs, centers for independent living, Statewide Independent Living
Councils established under section 705, State vocational rehabilitation
programs receiving assistance under title I, State programs of supported
employment services receiving assistance under part B of title VI, client
assistance programs receiving assistance under section 112, programs
funded under other titles of this Act, programs funded under other Federal
law, and programs funded through non-Federal sources." 

Now most SILCs understand and address in their Statewide Plan for
Independent Living numbers 1 and 2.  But number 3?  Read it again. The law
also references "programs funded under other titles of this Act, programs
funded under other Federal law and programs funded through non-Federal
sources." 

Think about the potential impact should funds actually be allocated to to
efforts to "improve working relationships" among all of the various
programs funded under federal and otherwise.  Does your state's SPIL
address this bigger picture, does it talk about systemic advocacy among
other state agencies and federally-funded programs in your state? 

STATE VR AGENCIES DISCOURAGE ANY REAL PUBLIC POLICY WORK

NCIL Vice-Chair Kelly Buckland made the following statements at the recent
SILC Congress with respect to the first Congress, held in 1998 to help
SILCs understand their roles and responsibilities. 

"It seemed like a lot of people were very confused about what kind of
stuff they could do regarding advocacy, because VR agencies were telling
them they can't do any lobbying, they can't do anything about public
policy because they're using federal money (unclear)and so everybody
thought they couldn't do any legislative stuff." 

Buckland added the follow remarks about systems advocacy. "A lot of people
were essentially told that they couldn't do systems advocacy, because you
were lobbying with federal money.  There was some people in there who were
writing legislation and doing a lot of legislative work, and a lot of us
saw that as the primary role of the SILC was to be involved with
legislative activity, and so we essentially came out with a position paper
that really talks strongly about SILCs taking a consistent advocacy role." 

MANY SILCS WERE UNCLEAR ABOUT RESPONSIBILITIES

Buckland also spoke about confusion among SILCs about monitoring CILs: 

"SILCs are not supposed to be monitoring Centers for Independent Living,
and that's stated within this several times (referring to a document
prepared at the first SILC Congress.) It's not the SILC's responsibility
to look at the day to day operation of the Centers for Independent Living.
The SILC should monitor the activities of the state plan, but the day to
day operations of the center is the responsibility of the board and staff
of the Center for Independent Living.  I think that's real important that
everybody listen to that, because that's why Centers were created with
their own boards, with 51% people with disabilities, consumer control
issues, the CIL has people with disabilities in control of the centers. 
SILCs, that's not your role, that's the board's role. You'll get pressure
to do that as a SILC. But you can't be doing that, that has to happen on
the local level." 

Kelly Buckland explained that at the first SILC Congress Back in 1998, "A
lot of people came here thinking that their role as SILC members was to
monitor Centers for Independent Living, because VR told them that that's
what their role was.  Because in the law it says they're supposed to
monitor implementation of the state plan, but people were interpreting
that that they were supposed to be monitoring Centers for Independent
Living. 
 
MANY SILCS REMAIN UNCLEAR ABOUT THEIR RESPONSIBILITIES

Title VII, Section 704 (n) reads: 

"EVALUATION- The plan shall establish a method for the periodic evaluation
of the effectiveness of the plan in meeting the objectives established in
subsection (d), including evaluation of satisfaction by individuals with
disabilities." 

But since so many SPILs are relatively limited in scope (at least they do
not often address the kind of broad issues that the law allows, even if
the state DSU may have convinced them otherwise), many SILCs are confused
about the difference between monitoring and evaluating their plan and
monitoring and evaluating individual CILs. 
       
For example, the Texas State plan states: 

"The SILC recognizes that one of its primary roles is to evaluate and
monitor the effectiveness of the SPIL.  Accomplishments of goals and
objectives in the SPIL is dependent, to a large extent, on the successful
activities of the CILs.  Therefore, the SILC will monitor and evaluate on
a regular basis, the following documents or information provided by the
CILs: 

A.  Collect timely completed 704 evaluation forms. 
B.  Review newsletters as published by the Centers. 
C.  Review summaries of the results of any consumer satisfaction
    Surveys, or other methods used to evaluate consumer needs.
D.  Review quarterly progress reports

The Indiana SILC has repeatedly held that one of its responsibilities is
to monitor and evaluate individual Centers, and actively lobbied against
continued funding for a Center they simply didn't wish to support. 

The Indiana SILC has taken specific actions against Centers who were
actively demanding accountability by the Council, including unfounded
allegations of fiscal mismanagement and non-compliance with federal law. 

Since the Alliance has yet been unable to access recent Statewide Plans
for Independent Living approved by RSA, we cannot comment on other SPILs
at this point. 




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