CENTERS FOR INDEPENDENT LIVING

COMPLIANCE REVIEW REPORT

Disability Network West Michigan Center for Independent Living

Grant Award Number: 1803MIILCL

Muskegon, Michigan 

REVIEW DATES:

Draft Report: August 15, 2020

CIL Response: September 11, 2020

Final Report: October 9, 2020
Contents

I. PURPOSE OF THE ONSITE MONITORING REVIEW........................................................................... 1

II. METHODOLOGY................................................................................................................................... 1

III. EXECUTIVE SUMMARY........................................................................................................................ 2

IV. OBSERVATIONS AND RECOMMENDATIONS.................................................................................... 3

V. FINDINGS AND CORRECTIVE ACTIONS.............................................................................................. 3

APPENDIX................................................................................................................................................................... 4
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I. PURPOSE OF THE ON-SITE MONITORING REVIEW

Sections 706(c) and 722 of the Rehabilitation Act of 1973, as amended (Rehabilitation Act) mandate that 

the Administration for Community Living (ACL) conduct reviews of centers for independent living (CILs) 

funded under Title VII, Part C, Section 722. The objectives of reviews are to:

 assess compliance with the requirements of Section 725(b) and (c)(3) of the Rehabilitation Act;

 study program operations, organizational structure,and administration of the CIL under Section 

725(c)(1), (2), (5) and (6) of the Rehabilitation Act;

 review documentation sufficient to verify the accuracy of the information submitted in the most 

recent CIL ProgramPerformance Report (PPR);

 verify that the CIL is managed in accordance with federal requirements;

 assess CIL conformance with its work plan, developed in accordance with Section 725(c)(4) of 

the Rehabilitation Act, conditions of the CIL’s approved application, and consistency with the 

State Plan for Independent Living (SPIL);

 identify areas of suggested or necessary improvements in the CIL’s programmatic and fiscal 

operation and provide technical assistance resources available on the local, state, regional and 

national level;

 identify areas of exemplary work, projects and coordination efforts and make this information 

available to the larger CIL community; and 

 identify technical assistance to enhance CIL operations or to minimize or to eliminate problem 

areas.

II. METHODOLOGY

Disability Network West Michigan (DNWM) volunteered to participate in a pilot onsite review to help ACL 

test the Compliance and Outcome Monitoring Protocol (COMP). As an incentive to volunteer, ACL 

modified components of the COMP. Namely, DNWM received an initial onsite review report that 

included all observations and findings identified by the review process. DNWM was able to respond and 

resolve findings prior to ACL issuing a final public report. Brief statements identify the observations and 

findings addressed or resolved prior to issuing the final report. If applicable, unresolved findings are 

noted with required corrective action steps.

Participation in this review does not preclude additional oversight activitiesrelated to these findings.

Future enforcement actions may include the recovery of funds, draw down restrictions, funds 

withholding, or grant terminations, pursuant to 45 CFR 1329.7(a).
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The review of Disability Network West Michigan (DNWM) was conducted December 9–10, 2019 and 

reviewed activitiesprovided from September 30, 2017 through September 29, 2018 (PY 181)with a 

focus on program and fiscal operations related to DNWM’s administration of Title VII, Part C funds. The 

review team conducted interviews with the center’s management, staff, consumers, and members of 

the board of directors. In addition to the interviews, program and financial documents were reviewed in 

accordance with the COMP, including written policies and procedures, a sample of consumer client 

information file (CIFs), and other documents that verified compliance with standards and indicators.

CIFs were randomly selected for review. The review team conducted an exit conference at the 

conclusion of the review to provide initial feedback from the review.

Observations and recommendations presented below are suggestions that the grantee is not required to 

follow. Findings are violations of laws or regulations that must be addressed and require a Corrective 

Action Plan (CAP). 

Review team participants included:

 Dr. Corinna Stiles, Director, Office of Independent Living Programs;

 David Wickstrom, Program Officer,Review Lead; 

 Peter Nye, Program Officer;

 Damian Francis, ACL Fiscal Specialist; 

 Dave Bulkowski, nonfederal reviewer 

III. EXECUTIVE SUMMARY

The DNWM missionis to advocate, educate, empower, and provide resources for persons with 

disabilities and promote accessible communities. DNWM reports serving Lake, Newaygo, Mason, 

Oceana, and Muskegon counties. In PY2018, DNWM hada net operating budget of $890,477, of which 

$138,390 was Title VII, Part C funding. At the time of the review, DNWM has 18 full-time equivalent 

staff; of these staff members, six are considered decision makers. Twelve staff members—including four 

of the decision-making staff—are people who identify as having disabilities. DNWM has ninemembers 

of the Board of Directors, of whomseven identify as having significant disabilities.

In PY2018, DNWM served a total of 697 individuals with significant disabilities. One hundred eightyeightof these individuals developed Independent Living Plans(ILPs), and 509 of these individuals waived

their right to develop an ILP. The most commonly serviced disability categorieswere cognitive, physical, 

and multiple disabilities. DNWM provided the followingcore services—information and referral(1,177),

independent living skills training (57), peer counseling (41), individual and systems advocacy (54), and 

transition services (for individuals in nursing homes and other institutions to transition to communitybased living (21), for individuals who are at risk of institutionalization to remain in the community, and 

for youth who are not attending school to transition to post-secondary life) (29).

 

1 which is the same as federal fiscal year 2017, which has the grant number 1703MIILCL.
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DNWM offers services in addition to core services that include: 

 Americans with Disabilities Act (ADA) Compliance Consultation and Education Service: This 

program educatesthe general public about rights and responsibilities provided in the ADA. This 

program includesa certified ADA Coordinator available to the community as a fee-for-service 

activity. The ADA coordinator receivesmore than100 hours of ADA training on physical 

accessibility, program accessibility,and the inclusion of persons with disabilities. The ADA 

Coordinator provides information and assistance to DNWM consumers and serves as 

coordinator of ADA Michigan (a state steering committee) and the local downtown advisory 

board. The ADA coordinator leads workshops on accessibility and advises local governments 

and businesses throughout the state promotingADA compliance.

 Transportation Voucher Program: This programprovides transportation vouchersfor 

individuals with disabilities living in the CIL’srural service area,where masstransit 

is unavailable. Drivers are chosen by the participants—either from the volunteers DNWM 

recruits or from individuals the participants recruit—andreceive reimbursement for 

mileage. This program wasfunded by the Federal New Freedom Transportation Programand by 

local funding; this program has supported community integration and participation, 

employment opportunities, and increased access to health care.

IV. OBSERVATIONS AND RECOMMENDATIONS

Observations and recommendations strengthen CIL operations and performance. Because observations 

are not compliance issues, a grantee is not required to accept the recommendations. 

ACL offered observations and recommendations in the following issue areas: 

1. Accessibility of office space; and

2. Board of Director term limits. 

DNWM provided thorough responses to both observations. 

V. FINDINGS AND CORRECTIVE ACTIONS

During its review activities, ACL identified compliance findings in the following issue areas:

1. Consumer Information Files and Independent Living Plans, and

2. Personnel files. 

DNWM provided ACL thorough responses, and ACL has determined the findings resolved. To ensure 

ongoing compliance, ACL will review implementation of the corrective action steps no later than 

December 30, 2020.
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Appendix: LEGAL REQUIREMENTS

This Appendix contains the full text of each legal requirement cited in Section VI of this report.

29 U.S.C. § 706(c)

ONSITE COMPLIANCE REVIEWS.—

(1) The Administrator shall annually conduct onsite compliance reviews of at least 15 percent of the 

centers for independent living that receive funds under section 722 and shall periodically 

conduct such a review of each such center . . . .

(2) QUALIFICATIONS OF EMPLOYEESCONDUCTINGREVIEWS.—TheAdministrator shall—

(A) to the maximum extent practicable, carry out a review described in paragraph (1) by using 

employees of the Department of Health and Human Services who are knowledgeable about 

the provision of independent living services;

(B) ensure that the employee of the Department of Health and Human Services with 

responsibility for supervising such a review shall have such knowledge; and

(C) ensure that at least one member of a team conducting such a review shall be an individual 

who—

(i) is not a government employee; and

(ii) has experience in the operation of centers for independent living.

29 U.S.C. § 722(b)(g)(1)

INGENERAL.—The Administrator shall periodically review each center receiving funds under this section 

to determine whether such center is in compliance with the standards and assurances set forth in 

section 725. If the Administrator determines that any center receiving funds under this section is not in 

compliance with the standards and assurances set forth in section 725, the Administrator shall 

immediately notify such center that it is out of compliance.

29 U.S.C. § 725(b)(3)

INDEPENDENT LIVING GOALS.—The center shall facilitate the development and achievement of 

independent living goals selected by individuals with significant disabilities who seek such assistance by 

the center.

29 U.S.C. § 725(c)(1–6)

ASSURANCES.—The eligible agency shall provide at such time and in such manner as the Administrator 

may require, such satisfactory assurances as the Administrator may require, including assurances that—

(1) the applicant is an eligible agency

(2) the center will be designed and operated within local communities by individuals with 

disabilities, including an assurance that the center will have a Board that is the principal governing body 

of the center and a majority of which shall be composed of individuals with significant disabilities;

(3) the applicant will comply with the standards set forth in subsection (b)

(4) the applicant will establish clear priorities through annual and 3-year program and financial 

planning objectives for the center, including overall goals or a mission for the center, a work plan for 

achieving the goals or mission, specific objectives, service priorities, and types of services to be 
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provided, and a description that shall demonstrate how the proposed activities of the applicant are 

consistent with the most recent 3-year State plan under section 704;

(5) the applicant will use sound organizational and personnel assignment practices, including taking

affirmative action to employ and advance in employment qualified individuals with significant 

disabilities on the same terms and conditions required with respect to the employment of individuals 

with disabilities under section 503;

(6) the applicant will ensure that the majority of the staff, and individuals in decisionmaking 

positions, of the applicant are individuals with disabilities

29 U.S.C. § 725(c)(8)

(8) the applicant will conduct annual self-evaluations, prepare an annual report, and maintain records 

adequate to measure performance with respect to the standards, containing information regarding, at a 

minimum—

(A) the extent to which the center is in compliance with the standards; 

(B) the number and types of individuals with significant disabilities receiving services through the center; 

(C) the types of services provided through the center and the number of individuals with significant 

disabilities receiving each type of service; 

(D) the sources and amounts of funding for the operation of the center; 

(E) the number of individuals with significant disabilities who are employed by, and the number who are 

in management and decisionmaking positions in, the center; and 

(F) a comparison, when appropriate, of the activities of the center in prior years with the activities of the 

center in the most recent year; 

45 CFR § 75.303(a–c)

(a) Establish and maintain effective internal control over the Federal award that provides reasonable 

assurance that the non-Federal entity is managing the Federal award in compliance with Federal 

statutes, regulations, and the terms and conditions of the Federal award. These internal controls should 

be in compliance with guidance in “Standards for Internal Control in the Federal Government,” issued by 

the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by 

the Committee of Sponsoring Organizations of the Treadway Commission (COSO).

(b) Comply with Federal statutes, regulations, and the terms and conditions of the Federal awards.

(c) Evaluate and monitor the non-Federal entity's compliance with statutes, regulations and the terms 

and conditions of Federal awards.

45 CFR § 75.342

(a) Monitoring by the non-Federal entity. . . . The non-Federal entity must monitor its activities under 

Federal awards to assure compliance with applicable Federal requirements . . . . Monitoring by the 

non-Federal entity must cover each program, function or activity.

(b) Non-construction performance reports.. . .

(1) The non-Federal entity must submit performance reports at the interval required by the HHS 

awarding agency . . . to best inform improvements in program outcomes and productivity. 

Intervals must be no less frequent than annually . . . .

45 CFR § 75.361
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Financial records, supporting documents, statistical records, and all other non-Federal entity records 

pertinent to a Federal award must be retained for a period of three years from the date of submissionof 

the final expenditure report. . . .