No Material/Non Sub Change Memo

To:

Julie Wise
Office of Information and Regulatory Affairs

Through:

Tomakie Washington
ACL PRA Portfolio Manager

From:

Erica McFadden Erica S. Mcfadden -S
Director, Office of Independent Living Programs

Re:

Non-Substantive Modifications to the Centers for Independent Living (CIL) Program
Performance Report (PPR) 0985-0061

Date:

August 23, 2022

Digitally signed by Erica S. Mcfadden -S
Date: 2022.09.13 09:22:03 -07'00'

The Office of Independent Living Programs (OILP) must update the currently approved Centers for
Independent Living (CIL) Program Performance Report (PPR) 0985-0061 to include reporting requirements
for Expanding Disabilities Network's (CILs) Access to COVID-19 Vaccines. ACL would like to request a nonsubstantive change to the currently approved CIL PPR.
Quick background on the currently approved CIL PPR 0985-0061
ACL uses the CIL PPRs to assess grantees’ compliance with Title VII and applicable provisions of the HHS
Regulations at 45 CFR part 75. The Rehabilitation Act requires three IL program reports: (1) State Plan for
Independent Living, (2) ILS Program Performance Report, and (3) Centers for Independent Living PPR. These
PPRs are primarily used to provide and design training technical assistance programs, further assess
compliance when appropriate, approve or deny continuations as appropriate, and terminate grants when
necessary.
ACL needs to update the CIL PPR to include guidance and an updated instrument, which highlights data
elements required by different CIL grantees to report all activities that the CIL grantees did with Expanding
Disabilities Network's (CILs) Access to COVID-19 Vaccines. Without clearly distinguishing activities done
with this funding from activities done with other funding, ACL will not know what services were provided
with this funding.
Updated data fields report activities used with the Expanding Disabilities Network's (CILs) Access to COVID19 Vaccines funding, outcomes, collaboration with other ACL partners (i.e., aging and disability resource
centers, area agencies on aging, centers for independent living, developmental disabilities councils,
protection & advocacy agencies, and university centers on excellence in developmental disabilities) and
other community-based organizations, lessons learned, and recommendations for future activities.

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With answers limited to 500 words per grantee per data field, any possible burden increase or decrease is
very minimal since CILs currently collect this information.
The data collection activity will be updated via a supplemental or separate reporting tool. OILP expressed
concerns that if these activities are lumped into the regular Part C PPR, the info will be lost or increase the
potential for fraud and/or abuse of funds. By highlighting the Expanding Disabilities Network's (CILs) Access
to COVID-19 Vaccines data elements as a supplemental instrument and providing a guidance document in
the currently approved CIL IC, ACL can more quickly identify Expanding Disabilities Network's (CILs) Access
to COVID-19 Vaccines activities from Part C funded activities. The Expanding Disabilities Network's (CILs)
Access to COVID-19 Vaccines reporting is due 90 days after September 30.
For these reasons, ACL thinks these updates fit the terms of clearance for a non-substantive/no material
change request under the PRA.

Cc:

Jill Jacobs
Commissioner, Administration on Disabilities

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