1

CIL Evaluation Tool FY2020

COMPLIANCE ANALYSIS 

Part I. Verification of Standards and Assurances 

1. Governing Board Sections 725(b)(1)(A) and 725(c)(2) of the Act

ITEM REVIEW PROMPT ANSWERS COMMENTS

1.a Number of persons on the governing board.

1.b Number of governing board members with significant disabilities.

1.c Is the number of board members with significant disabilities over 50 percent? Yes ☐ No ☐

1.d Is the CIL Board the Principal Decision-Making Body? Yes ☐ No ☐

1.e The CIL has policies and procedures specifying board members’ roles and responsibilities 

(Recommended Practice) 

Yes ☐ No ☐

1.f. The CIL has a written process for identifying and recruiting board members. Yes ☐ No ☐

2. CIL Employees Sections 725(b)(1)(A) and 725(c)(6) of the Act

ITEM REVIEW PROMPT ANSWERS COMMENTS

2.a Number of CIL employees.

2.b Number of CIL employees with disabilities.

2.c Number of decision-making positions.

2.d Number of people with disabilities in decision-making positions. 

2.e. Are more than 50 percent of staff positions filled by individuals with disabilities? Yes ☐ No ☐
2

COMPLIANCE ANALYSIS 

2.f. Are 50% or more of decision-making positions filled by individuals with disabilities? Yes ☐ No ☐

3. Self-help and Self-advocacy Sections 725(b)(1)(B) of the Act 

ITEM REVIEW PROMPT ANSWER COMMENTS

3.a Does CIL promotes self-help and self-advocacy among individuals with significant disabilities? Yes ☐ No ☐

4. Development of Peer Relationships and Peer Role Models Section 725(b)(1)(C)

ITEM REVIEW PROMPT ANSWER COMMENTS

4.a Does the CIL promotes the development of peer relationships and peer role models among 

individuals with significant disabilities?

Yes ☐ No ☐ 1.

5. Equal Access Section 725(b)(1)(D) of the Rehabilitation Act

ITEM REVIEW PROMPT (See Accessibility Checklist) ANSWER COMMENTS

5.a Does the CIL promote equal access for individuals with significant disabilities within their 

communities, and to all services, programs, activities, resources and facilities, whether public or 

private, and regardless of funding source? Equal access, for the purposes of this question, means 

that the same access provided to individuals without disabilities is provided in the center’s service 

area to individuals with significant disabilities.

Yes ☐ No ☐

5.b To the maximum extent feasible, does the CIL makes available information and services in the 

native languages of individuals with significant disabilities whose English proficiency is limited 

and who apply for or receive IL services?

Yes ☐ No ☐

5.c Does the CIL make available in alternate formats, as appropriate, all of its written policies, 

materials and IL services (e.g., Braille, large print, audio tape, electronic). 

Yes ☐ No ☐

5.d Is the CIL is physically accessible for individuals with significant disabilities, for example, 

individuals with mobility disabilities (e.g., signage, doors, bathrooms, parking lots) or individuals 

with Environmental Illness and Multiple Chemical Sensitivity (e.g., no-fragrance policy or use of 

“green” cleaners)?

Yes ☐ No ☐
3

COMPLIANCE ANALYSIS 

6. Provision of Services on a Cross Disability Basis Section 725(b)(2) of the Act

ITEM REVIEW PROMPT ANSWER COMMENTS

6.a Does the CIL provide IL services to eligible individuals with a range of significant disabilities? Yes ☐ No ☐

6.b Does the CIL provide IL services to individuals with range of significant disabilities who are 

members of populations that are unserved or underserved by programs under Title VII of the 

Act?

Yes ☐ No ☐

7. Independent Living Goals Section 725(b)(3) of the Act 

ITEM REVIEW PROMPT (See CIF Checklist) ANSWER COMMENTS

7.a Does the CIL maintains a consumer information files (CIF) for each consumer? Yes ☐ No ☐

7.b Does the CIL have documentation showing that the individuals are eligible or ineligible for 

services (only those eligible are served)? 

Yes ☐ No ☐

7.c Does the CIL have documentation showing notification to consumers of their right to develop, or 

waive the development, of an ILP?

Yes ☐ No ☐

7.d Does the CIL have written Independent Living Plans (ILPs) or written waivers from the consumers 

stating that ILPs are unnecessary?

Yes ☐ No ☐

7.e Do the CIL notes indicate the services requested by, and the services provided to, or arranged 

for, the consumers?

Yes ☐ No ☐

7.f Do the notes indicate the development and achievement of IL goals selected by individuals with 

significant disabilities who request assistance from the CIL?

Yes ☐ No ☐

7.g Do the notes indicate the IL goal or objectives were established with the consumer, whether or 

not in the ILP? 

Yes ☐ No ☐

7.h Do the notes indicate that the consumer believes they have achieved the goals or objectives? Yes ☐ No ☐

7.i Does the CIL provide consumers information on the process to express satisfaction or 

dissatisfaction with the CIL’s services?

Yes ☐ No ☐
4

COMPLIANCE ANALYSIS 

7.j Does the CIL notify the consumer was provided information on the existence of, the availability 

of, and how to contact the client assistance program?

Yes ☐ No ☐

7.k Does the CIL maintain documentation on the number of ILPs developed by consumers receiving 

services from the CIL?

Yes ☐ No ☐

7.l Does the CIL maintain documentation on the number of waivers signed by consumers receiving 

services from the CIL stating that an ILP is unnecessary?

Yes ☐ No ☐

7.m Do the ILPs indicate the goals or objectives established, the services to be provided and the 

anticipated duration of the services?

Yes ☐ No ☐

7.n Do the ILPs indicate the ILP was developed jointly and signed by the appropriate CIL staff 

member and the individual with a significant disability/legally authorized representative? 

Yes ☐ No ☐

7.o Are ILPs provided in accessible formats, as needed? Yes ☐ No ☐

7.p Are the ILPs reviewed at least annually to determine whether services should be continued, 

modified or discontinued and/or whether the individual should be referred to another program? 

Yes ☐ No ☐

7.q Does the CIL have written CIF management policies and procedures? Yes ☐ No ☐

8. Community Options and Community Capacity Section 725(b)(4), (6), and (c)(10) of the Rehabilitation Act

ITEM REVIEW PROMPT ANSWERS COMMENTS

8.a Has the CIL performed at least one activity in community advocacy during the reporting year? Yes ☐ No ☐

8.b Has the CIL performed at least one activity of technical assistance to the community on making 

services, programs, activities, resources and facilities in society accessible to individuals with 

significant disabilities during the reporting year?

Yes ☐ No ☐

8.c Has the CIL performed at least one activity in public information and education during the 

reporting year?

Yes ☐ No ☐

8.d Has the CIL performed aggressive outreach to populations of individuals with significant 

disabilities that are unserved or underserved by programs under Title VII of the act in the CIL’s 

service area during the reporting year?

Yes ☐ No ☐

8.e Has the CIL collaborated with service providers, other agencies, and organizations that could 

assist in improving opportunities for individuals with significant disabilities to avail themselves of 

Yes ☐ No ☐
5

COMPLIANCE ANALYSIS 

the services, programs, activities, resources and facilities in the CIL’s service area during the 

reporting year?

8.f Has the CIL performed outreach to unserved or underserved populations include minority 

groups and urban and rural populations during the reporting year?

Yes ☐ No ☐

9. IL Core Services and Other IL Services Section 725(b)(5) of the Rehabilitation Act

ITEM REVIEW PROMPT ANSWER COMMENTS

9.a Does the CIL provide information and referral services in accessible formats to all individuals 

who request this type of assistance from the CIL?

Yes ☐ No ☐

9.b During the reporting year, did the CIL provide independent Living Skills Training? Yes ☐ No ☐

9.c During the reporting year, did the CIL provide Individual and System Advocacy? Yes ☐ No ☐

9.d During the reporting year, did the CIL provide services that facilitate the transition of individuals 

with significant disabilities from nursing homes and other institutions to home and communitybased residences, with the requisite supports and services?

Yes ☐ No ☐

9.e During the reporting year, did the CIL provide services that provide assistance to individuals with 

significant disabilities who are at risk of entering institutions so that the individuals may remain 

in the community?

Yes ☐ No ☐

9.f During the reporting year, did the CIL provide services that facilitate the transition of youth who 

are individuals with significant disabilities, who were eligible for IEPs, and who have completed 

their secondary education or otherwise left school, to postsecondary life?

Yes ☐ No ☐

9.g During the reporting year, did the CIL provide a combination, as appropriate, of any two or more 

of the IL services defined in Section 7(18)(B) of the Act?

Yes ☐ No ☐

10. Resource Development Section 725(b)(7) of the Rehabilitation Act

ITEM REVIEW PROMPT ANSWER COMMENTS

10.a During the reporting year, did the CIL conduct resource development activities to obtain funding 

from sources other than Part C, Chapter 1, Title VII, of the Act?

Yes ☐ No ☐

11. Program and Financial Planning Objectives 
6

COMPLIANCE ANALYSIS 

ITEM REVIEW PROMPT ANSWER COMMENTS

11.a Does the CIL have an established annual and three-year program and financial planning 

objectives?

Yes ☐ No ☐

11.b Do the objectives include the CIL’s goals and mission? Yes ☐ No ☐

11.c Does the CIL have a current work plan for achieving the goals or mission and has included 

specific activities to meet the requirements in the standards and assurances?

Yes ☐ No ☐

11.d Does the CIL’s work plan include specific services, priorities and types of services to be provided? Yes ☐ No ☐

11.e Are the CIL’s work plan and objectives consistent with the current SPIL? Yes ☐ No ☐

11.f Does the CIL’s work plan includes objectives and goals for obtaining or increasing non-Title VII 

funding? (Recommended Practice)

Yes ☐ No ☐

11.g Does the CIL’s work plan work plan addresses board, staff and/or volunteers training?

(Recommended Practice)

Yes ☐ No ☐

12. PPR Accuracy and Documentation Section 725(b)(c) of the Rehabilitation Act

ITEM REVIEW PROMPT ANSWER COMMENTS

12.a Has the CIL implemented internal controls and procedures (including training and quality 

assurance) to ensure CIL PPR accuracy and documentation?

Yes ☐ No ☐

12.b Does a review of CIL data provides support for the accuracy of the most recent CIL PPR? Yes ☐ No ☐

12.c Did the CIL submit to the SILC a copy of its most recent CIL PPR? Yes ☐ No ☐

COMPLIANCE ANALYSIS 

Part II. Verification of Organization and Administration of the CIL 

1. Organizational and Personnel Practices Sections 704(m)(2) and 725(c)(5) of the Rehabilitation Act

ITEM REVIEW PROMPT ANSWERS COMMENTS
7

COMPLIANCE ANALYSIS 

1.a Does the CIL use sound organizational and personnel assignment practices (including 

organizational chart indicating lines of authority, job descriptions, and performance 

appraisals)?

Yes ☐ No ☐

1.b Does the CIL have a policy addressing affirmative actions to employ and advance in 

employment qualified individuals with significant disabilities?

Yes ☐ No ☐

1.c Does the CIL have personnel policies addressing such areas as wage and salary, fringe benefits, 

vacation and sick leave, extended absences from the work place, etc.? 

Yes ☐ No ☐

2. Staff Development and Training Section 725(c)(11) of the Rehabilitation Act

ITEM REVIEW PROMPT (See Personnel Checklist) ANSWERS COMMENTS

2.a Does the CIL include personnel who are specialists in the development and provision of IL 

services?

Yes ☐ No ☐

2.b Does the CIL provide new staff training and continued staff development opportunities

directed at improving the skills in the provision of IL services, including knowledge of and 

practice in the IL philosophy and cross-disability awareness training?

Yes ☐ No ☐

2.c Does the CIL staff receive training on how to serve unserved and underserved populations, 

including minority groups and urban and rural populations?

Yes ☐ No ☐

2.d Does the CIL have a new governing board member training and development program? Yes ☐ No ☐

3. Conflict of Interest 

ITEM REVIEW PROMPT ANSWERS COMMENTS

3.a Does the CIL have policies that safeguard against a person (employee, board member, 

volunteer) from participating in an administrative decision regarding business of the CIL if the 

decision is likely to benefit that person or a member of his or her immediate family and that

person is a public official or has a family or business relationship with the CIL?

Yes ☐ No ☐

3.b Does the CIL have policies that safeguard against any person using his or her position for a 

purpose that is, or gives the appearance of being, motivated by a desire for a private financial 

gain for that person or for others?

Yes ☐ No ☐

4. Confidentiality 

ITEM REVIEW PROMPT ANSWERS COMMENTS

4.a Has the CIL has adopted and implemented policies and procedures to safeguard the 

confidentiality of all personal information, including photographs, publicity releases and lists of 

names that comply with federal requirements?

Yes ☐ No ☐
8

COMPLIANCE ANALYSIS 

4.b Has the CIL has adopted and implemented policies and procedures to protect current and 

stored personal information?

Yes ☐ No ☐

4.c Has the CIL adopted and implemented policies and procedures to inform IL applicants or 

consumers, authorized representatives, service providers and others, as appropriate, about the 

confidentiality of personal information and the conditions for gaining access to and releasing 

this information?

Yes ☐ No ☐

4.d Does the CIL use meeting space that ensures that consumers’ confidentiality is protected when 

meeting with staff? 

Yes ☐ No ☐

5. Drug Free Workplace 

ITEM REVIEW PROMPT ANSWERS COMMENTS

5.a Does the CIL have a drug-free workplace policy? Yes ☐ No ☐

5.b Are employees informed of a drug-free workplace policy? Yes ☐ No ☐

6. Nondiscrimination 

ITEM REVIEW PROMPT ANSWERS COMMENTS

6.a Is there evidence to suggest the CIL denies services to persons on the basis of their race, color, 

national origin, sex, age or the existence of a disability?

Yes ☐ No ☐

7. Prohibition Against Lobbying 

ITEM REVIEW PROMPT ANSWERS COMMENTS

7.a Is there evidence to suggest the CIL uses federal funds to influence or attempt to influence any 

federal agency or Congress through lobbying activities?

Yes ☐ No ☐

7.b Does the CIL have written policies and procedures that prevent the use of federal funds to 

influence or attempt to influence any federal agency or Congress through lobbying activities? 

Yes ☐ No ☐