Title VII, chapter 1 of the Rehabilitation Act of 1973, as amended (the Act), establishes the State Independent Living Services (SILS) program and the Centers for Independent Living (CIL) program. The purpose of these programs is to:
promote the independent living philosophy, based on consumer control, peer support, self-help, self-determination, equal access and individual and systems advocacy;
maximize the leadership, empowerment, independence and productivity of individuals with significant disabilities; and
promote the integration and full inclusion of individuals with significant disabilities into the mainstream of American society.
To receive federal funding for the SILS and CIL programs, section 704 of the Act requires states to submit a State Plan for Independent Living (SPIL) and obtain RSA approval of a SPIL every three years. The SPIL encompasses the activities planned by the state to achieve its specified independent living objectives and reflects the state's commitment to comply with all applicable statutory and regulatory requirements. In states with a separate agency or unit that administers the SILS program for individuals who are blind, the director of that agency/unit, along with the director of the DSU are required to jointly develop and sign the SPIL and cooperate in its implementation.
FY 2014-2016 SPIL
The Office of Management and Budget (OMB) has approved the format for the FY 2014-2016 State Plan for Independent Living (SPIL), which is unchanged from FY 2011-2013. Part I is a series of assurances based on legal and regulatory provisions governing the State Independent Living Services (SILS) and Centers for Independent Living (CIL) programs. Part II consists of narrative sections in which the state describes its independent living objectives, services, activities, financial plans and operational details. The SPIL instrument and instructions are posted below.
By July 1, 2013, the SPIL is to be submitted online through the RSA Management Information System (RSA MIS) at http://rsa.ed.gov, after joint development and signature by the designated state unit (DSU) director(s) and the Statewide Independent Living Council (SILC) chairperson, on behalf of the SILC. Please note that the SPIL includes a signed assurance by the DSU(s) and SILC that the SILC “meets the requirements of section 705 of the Act,” including that:
- a majority of its members are individuals with disabilities not employed by any state agency or CIL;
- a majority of its voting members are individuals with disabilities not employed by any state agency or (CIL); and
- no member has served more than two consecutive three-year terms.
Therefore, before submitting the SPIL, you must take any necessary steps to ensure that your state’s SILC is constituted in compliance with federal requirements.
SPIL Screening Tool
Rehabilitation Services Administration (RSA) staff will use this tool to review the 2014-2016 State Plans for Independent Living (SPILs). State Independent Living Councils (SILCs) and designated state units (DSUs) are encouraged to consult this tool before submitting their SPILs, to ensure compliance with federal requirements and expedite RSA approval. The screening tool is available for download:
MS Word (104K).
To enhance the approvability of your SPILs, please ensure that:
SPIL narratives explain how the federal requirements will be met, not simply re-state the Part I assurances, particularly in sections 5 (Statewide Independent Living Council) and 6 (Service Provider Requirements).
SILC activities are consistent with the duties authorized in 34 CFR 364.21(g)(h)(i)(j), especially in sections 1 (Goals, Objectives and Activities), 5 (Statewide Independent Living Council) and 7 (Evaluation). Please refer to the RSA Technical Assistance Circular-13-01, ”Federal Requirements Governing Roles and Responsibilities of SILCs,” available at http://rsa.ed.gov/policy.cfm (on the TAC tab) or http://www.ed.gov/policy/speced/guid/rsa/techassis-circular.html (under 2013).
DSU activities are consistent with roles and responsibilities in 34 CFR 364.21(a)(b), especially in sections 1 (Goals, Objectives and Activities), 2 (Scope, Extent, and Arrangements of Services), 4 (Designated State Unit) and 6 (Service Provider Requirements).
DSU and SILC activities are consistent with the restrictions on the use of federal funds for fundraising, in OMB Circular A-122, Attachment B, Item 17 (for the CILs and SILCs that are nonprofits) and OMB Circular A-87, Attachment B, Item 17 (for the DSUs and SILCs that are part of state government). OMB Circular A-122 is available at http://www.ed.gov/programs/cil/resources.html
DSU, SILC and CIL activities are consistent with the restrictions on the use of federal funds for lobbying, in OMB Circular A-122, Attachment B, Item 25 and OMB Circular A-87, Attachment B, Item 24.
Priorities for CIL network expansion, if additional Part C funds become available through the congressional appropriations process or grant relinquishment/termination, are consistent with sections 722(d) and 723(e) of the Rehabilitation Act and clearly outlined in section 3.2 (Expansion of Network).
Related sections are cross-checked for accuracy and consistency, especially sections:
1.2B (Outreach Plans), 2.1B (Service Provision Priorities) and 3.2 (Expansion of Network );
1.2A (Objectives and Time Frames), 1.3A (Financial Plan Tables), 1.3B (Financial Plan Narratives), and 7 (Evaluation); and
4.1 (Administrative Support Services), 1.3B(3) (In-kind resources) and 5.1A (Resource plan).
If you have questions about the SPIL submission, please contact the IL Unit representative for your state.
To access the RSA website, you must register through http://rsa.ed.gov/info_for_new_users.cfm. Please follow the directions in Obtain MIS Access. Further instructions will be provided upon completion of the registration process, including your user ID and password. Be sure to select Independent Living State Grants as the program, and State Plan for Independent Living as the form. If you have forgotten your password, click on the words Click Here If You Have Any Problems Logging In.
Do not mail hard copies of your SPIL to RSA. Instead, in Part I, Section 9 (Assurances), the DSU(s) and SILC certify that a signed hard copy of the SPIL is kept on file in the state, together with a signed copy of the Certification Regarding Lobbying. The lobbying form, ED 80-0013, is available at http://www.ed.gov/programs/8003/assurancesed80013.pdf
In addition to the tools listed above, SILC-NET has developed several SPIL-related resources in coordination with RSA:
Online SPIL Development Guide, providing step-by-step guidance and suggestions for completing each section of the SPIL. Its purpose is to maximize the quality of SPIL planning, development and evaluation. To access the guide, go to http://wiki.ilru.net/index.php?title=Online_SPIL_Development_Guide.
SPIL Development Tip Sheet, offering summary reminders and suggestions as well as additional resources such as disability statistics that we hope will be of benefit to your team. The tip sheet may be found at http://wiki.ilru.net/images/5/53/Tip_Sheet_for_SPIL_Development_FINAL_%283%29.pdf.
How-To Guide for Developing an Outcomes-Focused SPIL, a webinar available at http://www.ilru.org/html/training/webcasts/archive/2010/03-11-SILC-NET.html.
(February 11, 2013)