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CENTERS FOR INDEPENDENT LIVING

COMPLIANCE REVIEW REPORT

Harlem Independent Living Center 

Grant Award Numbers: 2021NYILCIL 

New York, New York 

REVIEW DATES: July 19–21, 2022

Draft Report: December 16, 2022

CIL Response: January 18, 2023 

Final Report: February 17, 2023 
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Table of Contents

I. PURPOSE OF THE ONSITE COMPLIANCE REVIEW...................................................................... 3

II. METHODOLOGY....................................................................................................................................3

III. BACKGROUND.......................................................................................................................................5

IV. FINDINGS AND CORRECTIVE ACTIONS...............................................................................................5

V. OBSERVATIONS AND RECOMMENDATIONS...................................................................................15

Appendix: Legal Requirements.......................................................................................................................20
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I. PURPOSE OF THE ONSITE COMPLIANCE REVIEW

29 U.S. Code § 796d–1 and 29 U.S. Code § 796f–1 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 29 U.S. Code § 796f–4(b) and (c)(3) of the

Rehabilitation Act;

- study program operations, organizational structure and administration of the CIL under 29 U.S.

Code § 796f–4(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 Program Performance Report (PPR);

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

- assess CIL conformance with its work plan, developed in accordance with 29 U.S. Code § 796f–

4(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

The Office of Independent Living Programs (OILP) identified Harlem Independent Living Center (HILC) to 

participate in a comprehensive onsite review because of failure to submit any reporting over the last 

two years. By the time of the site visit, one report from 2020 had been received, but OILP still had not 

received the 2019 report. Furthermore, there were multiple compliance issues identified in HILC’s 2020 

program performance report. The review team intended to complete this review in person and planned 

to switch to a remote review if COVID levels in the county where HILC’s office is located significantly 

increased. Two weeks before the review, the Centers for Disease Control and Prevention indicated that 

the COVID level in the county where HILC’s office is located was high, so the review team completed the

review remotely.

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

Future enforcement actions may include the recovery of funds, drawdown restrictions, funds 

withholding, or grant terminations, pursuant to 45 CFR 1329.7(a).
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ACL did a remote review of HILC on July 19–21, 2022. ACL reviewed activities from September 30, 2020 

to September 29, 2021 (program year [PY] 211

) (hereafter “the review period”) with a focus on program 

and fiscal operations related to HILC’s administration of Title VII, Part C funds. ACL conducted interviews 

with the center’s management, staff, consumers, and members of the board of directors. In addition to

the interview, ACL reviewed program and financial documents in accordance with the Compliance and

Outcome Monitoring Protocol (COMP), including written policies and procedures and other documents

that verified compliance with standards and indicators. ACL requested access to consumer information

files (CIFs) for twenty-four consumers whom HILC had served in the review period, and HILC—long after

ACL’s multiple requests—gave ACL access to twenty-four consumer information files (CIFs), many of

which do not adequately document independent living plans (ILPs), goals, services and their

relationships to the goals, and progress toward the goals.2The review team provided feedback to HILC 

staff throughout the review. Additionally, the non-federal reviewer, Kimberly Tissot, shared resources 

via email with the CIL Executive Director immediately following the site visit. Some of the feedback 

provided included the definition of “disability,” advocacy and lobbying, institutional transition, youth 

transition, peer support, personal assistance services, plain language, and information to collect in the 

CIFs. At the end of the review, the ACL team gave a presentation about how to work with Chinese 

Americans, which is an identified demographic group in need of increased outreach. 

The ACL review team participants were 

- Peter Nye, ACL program officer, review lead

- Jennifer Martin, ACL program officer

- Sherry Cochran, ACL fiscal specialist

- Bora Mpinja, ACL fiscal specialist

- Vincent Woodard, ACL fiscal specialist

- Kimberly Tissot, non-federal reviewer

This final report includes the grantee’s comments and revisions that the Administration for Community 

Living made in response. 

HILC Response: 

In response to the above, HILC had concerns as to the delivery method with regard to the CIFs since the 

review was done virtually. After a few back-and-forth discussions ACL and HILC agreed on a safe process 

to deliver the CIFs, and the files were then delivered as per request. HILC does appreciate the feedback 

given which relates to working with the Chinese American community and will continue reaching out to 

this community to address cultural barriers.

ACL Response:

ACL requested access to consumer information files (CIFs) for twenty-four consumers whom HILC had 

served in the review period. HILC gave ACL access to twenty-four CIFs more than a month later after 

multiple requests. 

1 Federal fiscal year (FFY) 20; grant number 2021NYILCL. The fiscal review also included 2121NYILCL. 2 The requirement is to review at least 10% of the consumer information files; 24 was slightly more than 10% of 

the 233 consumers the grantee served in the review period.
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III. BACKGROUND

The Harlem Independent Living Center (HILC) mission is to be a disability-focused organization that 

advocates for community change and empowers people to be independent. HILC reports serving Bronx, 

Kings, Nassau, New York, Queens, Richmond, and Suffolk counties. In Program Year 2021, HILC had a net 

operating budget of $613,167, of which $349,478 was Part C funding.

In PY2021 (which was the review period), HILC served a total of 233 consumers. The largest racial or 

ethnic category was Black or African American. The largest disability category was mental or emotional. 

The service that HILC provided most was IL skills training and life skills training.

IV. FINDINGS AND CORRECTIVE ACTIONS

During its review activities, ACL/OILP identified compliance findings that are discussed in this section. 

Within 30 calendar days of receipt of the final report, HILC must submit a corrective action plan (CAP) 

to ACL/OILP for review and approval. The CAP should include: (1) the specific corrective actions that 

the CIL will undertake in response to each finding; (2) the methodology that the CIL will utilize to 

evaluate if each corrective action has been effective; and (3) the timetable for the implementation 

and evaluation of the corrective action.

ACL/OILP reserves the right to pursue enforcement action related to these findings as it deems 

appropriate, including the recovery of funds, draw down restrictions, funds withholding, or grant 

terminations, pursuant to HHS policy and Uniform Guidance.

Programmatic Compliance Findings

Finding 1: HILC has not demonstrated that it provided all the required IL core services during 

the review period.

Legal Requirement: 29 U.S.C. § 705(17); 29 U.S. Code § 796f–4(b)(5) 

Discussion: HILC did not provide transition from nursing homes or other institutions and did not 

facilitate transition of youth who were individuals with significant disabilities who had left secondary 

education. When the review team asked HILC about nursing homes or other institutions, HILC staff 

explained that it had not provided transition from nursing homes or other institutions because housing 

in its service area is prohibitively expensive and because HILC had narrowly interpreted “nursing homes 

and other institutions” to mean only nursing homes. When the review team asked HILC about transition 

of youth, HILC staff stated that HILC had not provided that service during the review period. In addition, 

the HILC Personnel Policy & Procedures Manual, which is the only manual that HILC provided the review 

team, does not describe how to provide these required core services. The team discussed with HILC how 

this service may be provided, how institution is defined, and provided different options on how they 

could begin to provide transition services to individuals leaving high school. 

Finding: HILC is not in compliance with 29 U.S. Code § 796f–4(b)(5) (which is part of the Rehab Act). HILC 

has not been providing the required core services that are transition from nursing homes or other 
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institutions and did not facilitate transition of youth who were individuals with significant disabilities 

who had left secondary education.

Corrective Actions/Milestones: 

1) Within 30 calendar days of receipt of the final report, HILC should start either revising its

personnel policy and procedures manual (to specify how to identify and transition individuals

with significant disabilities from nursing homes or other institutions and how to facilitate

transition of youth who are individuals with significant disabilities who have left secondary

education) or drafting a manual for provision of core services (to specify how to achieve the

aforementioned core services).

2) Within 30 calendar days of receipt of the final report, HILC should plan how they will identify

people with disabilities in nursing homes and other institutions (including correctional facilities,

hospitals, rehabilitation facilities, intermediate care facilities, psychiatric hospitals, etc.) in its

service area who seem to be good candidates for transitioning to independent living and how to

engage with people in order to transition them to independent living.

3) Within 30 calendar days of receipt of the final report, HILC’s recent staff member whose job is to

transition youth should be working with youth who have left secondary education to transition

them to independent living.

4) Within 90 calendar days of receipt of the final report, HILC should have a draft of a manual for

provision of core services (which may be part of the personnel policy & procedures manual).

This manual should include how to identify people in a wide variety of institutions who may be

good candidates for transitioning to independent living, how HILC can support them, and how to

look broadly for housing options for transitioning to independent living.

5) Within 90 calendar days of receipt of the final report, HILC will document that it has identified

people with disabilities in nursing homes and other institutions in its service area who seem to

be good candidates for transitioning to independent living and has started working with them

and related organizations to identify and explore options for transitioning to independent living.

HILC will document that it has explored opportunities to work with the New York nursing-home

transition-and-waiver program and opportunities to use resources that the ACL Housing &

Services Resource Center (https://acl.gov/HousingAndServices) informs people about.

HILC Response:

Accessible Affordable Housing has been a challenge for many years. Transitioning PWD from nursing 

homes – the question is “where are they going to?” The fact is a for one person to qualify for a studio 

apartment his/her household income must be between $25- $37 thousand annually to afford a residence 

which cost $665 a month. The average participant’s fixed income is approximately $900.00 monthly. A 

request for transitioning from a nursing home is rare for HILC. HILC is a consumer driven, consumer focused 

organization which must follow the goals the person specifies to achieve.

Additionally, during the pandemic, it has been exceedingly difficult to gain contact with most facilities. 

Visits to most institutions/ agencies were denied and some are still being denied. During the year review 

period HILC had a new staff member working with youth transiting. Moving forward this IL core service 

will be addressed.
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HILC was unaware that transitioning people with mental illness and/or substance abuse disorders from 

institutions was acceptable as an IL core service. It was during the ACL review we were told it is 

permissible. 

Corrective Action:

HILC will make the necessary adjustments to have transitioning from a nursing home or institution 

reflected as an IL core service.

HILC will create a list of agencies as indicated such as hospitals, rehabilitation facilities, intermediate care 

facilities, psychiatric hospitals to contact those within Harlem.

HILC currently has a youth transition advocate collaborating with the DOE, ACCES-VR and OPWDD to 

achieve the required IL core service.

HILC will update its Personnel Policy & Procedures Manual to reflect those required core services.

HILC will also reach out to ILRU for training pertaining to the IL core services for all staff.

Methodology:

HILC has started outreach methods such as phone calls, virtual meetings and mass mailings within the 

northern Manhattan and the central Harlem area.

HILC will continue to collaborate with the schools within Harlem.

Timetable:

This will be an ongoing process for HILC working with transiting for both institutions and youth.

Over the next 30 to 90 days HILC will start the process of updating the Personnel Policy & Procedures 

Manual. 

ACL Response:

The corrective action plan (CAP) needs to include more details about the youth transition advocate and 

the person’s roles and responsibilities. This CAP should be completed no later than March 2, 2023.

ACL concurs with all the other aspects of this response.

Finding 2: HILC’s building is not fully accessible to all people with all disabilities.

Legal Requirement: 29 U.S.C. § 796f–4(b)(1)(D) and 42 U.S.C. § 35.101

Discussion: HILC put together a virtual tour of its office that would be helpful to visitors to access before 

they come to HILC. The team suggested that the staff post the video on their website and social media 

channels. Separately, the Harlem staff gave the review team a live tour. During the review, the team 

identified a few areas where accessibility could be improved, although they were not significant 

compliance issues. For example, the CIL’s waiting room does not have a designated wheelchair area, 

although HILC staff told the review team that HILC staff rearrange furniture when wheelchair users need 

the space. During the tour, the review team recommended that HILC designate a wheelchair area in the 

waiting room to prevent accessibility issues. 

There were also a number of accessibility concerns identified at the HILC location. 

- The outside of the building that HILC is in does not contain a visible sign that identifies that HILC

is in the building, making it difficult to find.
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- The door to the building does not automatically open, nor does it have a sign that instructs HILC

visitors on what to do if they cannot open the door. HILC staff state that consumers schedule

visits, but the set up discourages walk-ups.

- The rooms lack tactile signage.

- The pipes under the bathroom sink are not insulated; that lack of insulation may cause people

with sensory impairments to burn themselves by hot water.

- The hand dryer in the HILC bathroom is at a height that most wheelchair users would struggle to

reach.

Finding: HILC is not in compliance with 29 U.S. Code § 796f–4(b)(1)(D) (which is part of the Rehab Act) 

or with the Americans with Disabilities Act, because individuals with some disabilities cannot 

conveniently access all the parts of the HILC building to fully use HILC’s resources. 

Corrective Actions/Milestones: 

1) Within 90 calendar days of receipt of the final report, HILC should put a visible HILC sign outside

its building explicitly stating that HILC staff can assist when entering or leaving the office and

providing instructions on how to do so.

2) Within 90 calendar days of receipt of the final report, HILC should put tactile signage outside all

its rooms that consumers are to use.

3) Within 90 calendar days of receipt of the final report, HILC should insulate the pipes under the

bathroom sink or establish a physical barrier to protect people with sensory impairments from

burning themselves.

4) Within 90 calendar days of receipt of the final report, HILC should either provide a hand dryer

(in the bathroom) that is accessible to most wheelchair users or place a small table with paper

towels in the bathroom (for wheelchair users).

HILC Response:

HILC has been located at its current location for over fifteen years, and during this time we have never had 

any participants unable to find or access our location. Instructions are always given to social workers, 

participants and referring agencies about how to gain access into the building. In some instances, staff 

members will meet consumers at the entrance of the building upon request. The building does not have a 

designated area for a visible sign to be posted. 

The main door to the building does not automatically open due to security and safety concerns, but there 

is a list at the entrance of all occupant organizations and their corresponding suite numbers to guide 

persons entering the building. 

"Walk-ins are discouraged” is correct – public safety and health is a top priority for HILC, especially since 

there is no security guard on site unlike other organizations. Therefore, visits are by appointment only and 

this is especially important that NYC is currently dealing with a “tridemic” after the recent pandemic, so it 

is best for the health of all consumers to not to have walk-ins.
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As per the New York State Commission for the Blind there is a smaller percentage of people who actually 

use tactile or Braille. Again, out of safety concerns participant are not allowed to walk around arbitrarily 

and are therefore usually escorted to the main area or location being utilized. 

Corrective Action:

HILC will reach out to the property owner again for any updates on allowances for posting signage at the 

entrance of the building.

HILC will contact Commission for the Blind for advice on best practices on signage for consumers in office 

space. 

HILC will take the necessary measures in covering the pipes under the sink.

HILC will place a small table with paper towels for wheelchair access.

Methodology

HILC will compare prices between hardware stores to find the best suited and most economical pipe 

covers.

Timetable

HILC will work to correct/update this over the next thirty to ninety days.

ACL Response:

The CAP will need more details. This CAP should be completed no later than March 2, 2023.

ACL concurs with all the other aspects of this response.

Finding 3: HILC is not adequately recording services in consumer information files (CIFs) and

Independent Living Plans (ILPs).

Legal Requirement: 29 U.S. Code § 796f–4(b)(2–3) and 29 U.S. Code § 796f–4(c)(8)(B–C)

Discussion: ACL reviewed policies and procedures and twenty-four (24) active CIFs (10% of HILC’s 233 

active CIFs). They also interviewed multiple staff members about administering CIFs and Independent 

Living Plans (ILPs). Grantees are required to demonstrate active internal controls necessary to assure 

that they are managing the awards in compliance with Federal statutes, regulations, and the terms and 

conditions of the award (45 CFR § 75.303 (a–c)). Part C CILs are also required to prepare annual reports 

(CIL PPRs) and demonstrate that they are maintaining records that are adequate to measure 

performance (45 CFR § 75.342) with respect to the standards (29 U.S. Code § 796f–4(c)(8)) set forth in 

the Act. 

All twenty-four (24) CIFs that ACL reviewed had deficiencies in at least one of the following areas: 

Eligibility, anticipated service duration, signed release of information, notification of opportunity to 

express satisfaction or dissatisfaction, notification of opportunity to appeal, notification of ability to 

utilize or waive creation of an independent living plan or waiver, notification to the consumer of the 

availability of the Client Assistance Program, and notification about goals met resulting in CIF closure. 

For PY2021, Harlem ILC reports having developed 233 ILPs with no additional individuals having waived 

their right to develop an ILP. Yet, they also report that 487 consumers received IL Skills Training, and 325 
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received Advocacy/Legal Services, which is significantly more than the number of ILPs they developed. 

The consumer data reported was not substantiated with a waiver or an ILP. 

Of the documentation received, information contained within the files was inconsistent. Every file was 

missing required information, per the Rehab Act. Many of the CIFs that the team reviewed do not 

adequately document ILPs, goals, services and their relationships to the goals, evidence of required core 

services, and progress toward the goals. Specifically,

- Many CIFs do not adequately connect services to goals.

- Some of the CIFs substitute a staff signature for the consumer’s signature, which is

supposed to indicate that the consumer accepts the ILP or waiver; however, no HILC policy

allows that substitution.

- Some CIFs indicate that the consumers requested ILPs but that HILC established goals

without establishing ILPs.

- Some CIFs briefly mention activities that they do not adequately document.

- One CIF indicates services but no goals.

- Many of the CIFs did not provide documentation of peer counseling, a required core service.

After further discussion with HILC staff, it was clear that peer counseling as a service was

defined too narrowly by the team.

In addition, HILC’s Consumer Grievance Procedures shared with consumers list the wrong contact 

information when appealing to ACL. 

HILC should require a CIF checklist that is uniformly applied, and the supervisors should routinely review 

the CIFs for accuracy. There also should be an internal process to assure accuracy of the data reported 

with the content of the CIFs and the ILPs. 

Finding: HILC is not in compliance with 45 CFR § 75.303(a–c), because it does not have sufficient internal 

controls related to CIFs/ILPs. As a result, HILC cannot assure that information submitted on official 

Federal reports is an accurate reflection of agency performance (45 CFR § 75.342) and is therefore 

unable to demonstrate it is meeting standards set forth in the Act (29 U.S. Code § 796f–4(c)(8)).

Corrective Actions/Milestones: 

1) Within 30 calendar days of receipt of the final report, HILC should revise its Consumer Grievance

Procedures to list the Administration for Community Living email address as the federal contact

to appeal grievances.

2) Within 30 calendar days of receipt of the final report, HILC should begin working with the TA

provider to establish standards of practice for required CIF/ILP components including

development and maintenance of ILP goals and services.

3) Within 90 calendar days of receipt of the final report, HILC should implement these practices

through all relevant agency policies and procedures, including staff training, evaluation, and any

relevant board activities. These practices should include a quality-assurance component
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necessary to assure ongoing implementation and validity of numbers submitted from CIFs/ILPs. 

This finding will be closed when HILC can document that this step has been completed, and the 

FY 19 PPR has been submitted. 

4) Within 90 calendar days of receipt of the final report, all HILC’s CIFs and ILPs should properly

reflect all services that HILC is providing to all its consumers and all progress that all of them are

making. (This factor will be the key compliance indicator.)

HILC Response:

In reviewing the CIFs sent to be reviewed, HILC realized most of the files were created over fifteen years 

ago and were not updated as participants continue reaching out for services. The database used did not 

reflect most of the updates the new databases such as NetCil or CilSuite currently provide.

With reference to the comment that “CIFS include a staff signature as a proxy for the consumer;” there 

was no policy which allowed that to occur. HILC would like clarification on this statement.

Corrective Action:

Since the review HILC has reached out to NetCiL , who installed a database program as of October 1, 2022; 

this is currently in use with ongoing training.

HILC has updated the Consumer Grievance procedure with the ACL email as the federal contact to appeal 

grievances. 

HILC will work with TA providers as suggested.

HILC will continue updating its policies and procedures, training for staff and all the necessary activities to 

be in full compliance.

Methodology

HILC will reach out to ILRU and ACL for guidance in recommending the specific trainings as needed.

Timetable

Ongoing. 

ACL Response:

The CAP needs to include this updated Consumer Grievance Procedure. This CAP should be completed no 

later than March 2, 2023. ACL agrees with all other aspects of this response.

Fiscal Findings

In addition to the programmatic review conducted by OILP, staff from the Office of Fiscal Operations 

(OFO) conducted the fiscal review of HILC’s policies and procedures. The purpose of the fiscal review 

was to assess the HILC’s ability to administer the formula grant programs funded by ACL and to provide 

technical assistance to the grantee.

Finding 4: HILC Policies and Procedures have insufficiencies. 

Legal Requirements: 45 CFR Part 75.303

Discussion: There are several areas of concern identified by ACL through the review of the fiscal 

policies and procedures submitted by HILC, which are as follows: 1) The payroll policies and procedures 
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appear to be out of date, as they reference pay dates within calendar year 2021, 2) the travel policies 

and procedures address travel reimbursement but they do not address prior travel authorization 

approval or limitations on allowable travel costs (i.e., per diem), 3) the policies and procedures indicate 

that telework is allowable with prior approval from the Executive Director, however they do not address 

the specific requirements for telework (i.e., time and attendance record keeping), and 4) the policies 

and procedures submitted do not address the management of federal grants.

Finding: HILC is out of compliance with 45 CFR 75.303, as the policies provided do not demonstrate that 

effective internal controls are in place to provide reasonable assurance that HILC is managing their 

federal awards in compliance with federal statutes, regulations, and terms and conditions of the awards.

Corrective Actions: 

1) Within 30 calendar days of the issuance of the final report, HILC should start revising their

internal policies and procedures for payroll, travel, and telework, as well as drafting policies and

procedures related to the management of federal grants.

2) Within 90 calendar days of the issuance of the final report, HILC should submit the revised draft

policies and procedures to ACL, for review and feedback.

HILC Response:

Attached are HILC’s comprehensive board approved policies that cover in much more detail how fiscal 

operates. We feel these where not part of the review. If the attached are not updated to ACL 

requirements HILC will take the necessary steps to do so.

ACL Response: 

HILC provided its Fiscal Policy Manual, Fiscal Manual – Cash Receipts (7), and Federal Procurement Policy 

(6). ACL staff confirmed that the provided Fiscal Policy Manual was reviewed during the monitoring. ACL 

has reviewed the provided documents and confirms that the stated Finding remains unchanged. To 

resolve this finding, HILC needs to implement the outlined corrective actions. Further, ACL advises the 

grantee to review its Fiscal Policy Manual in whole, because it was last updated nearly nine years ago 

and includes no mention of HHS-ACL funding, the Payment Management System (PMS), or the prevailing 

regulations, statutes, and requirements for the Federal funds received through the ILCL program.

Finding 5: SF-425s have not been submitted in the Payment Management System (PMS). 

Legal Requirements: Term and condition on award for 2021NYILC3

Discussion: As part of the review, HILC submitted a consolidated SF-425 via email, however, per the 

terms and conditions of the award, the SF-425s for 2021NYILC3 must be submitted in PMS.

Finding: HILC is out of compliance with the term and conditions on 2021NYILC3, as the SF-425 has not 

been submitted in PMS.

Corrective Action: 

1) Within 30 calendar days of the issuance of the final report, HILC must submit the SF-425 for

2021NYILC3 in PMS for review and approval.
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HILC Response:

All PMS reports have been certified in PMS

ACL Response:

ACL has approved the annual FFR for 2021NYILC3, but the final FFR has not yet been approved. ACL is 

working with HILC on a Notice of Award (NoA) amendment and a final award reconciliation which is 

delaying review of the final FFR. 

Finding 6: Questionable Costs were identified on 2021NYILCL.

Legal Requirements: 45 CFR 75.432 and 45 CFR 75.437 

Discussion: OFO reviewed the general ledger HILC provided for 2121NYILCL in coordination with the 

supporting documentation submitted for the costs associated with meals and determined these costs 

are unallowable, as they do not seem to meet any of the required exemptions contained within 45 CFR 

75.432 and 45 CFR 75.437. 

Finding: HILC is out of compliance with 45 CFR 75.432 and 45 CFR 75.437 as the meals charged to the 

award occurred at HILC and are not associated with a conference or consistent with documented 

internal employee health and welfare costs policies and procedures.

Corrective Action: 

1) Within 60 calendar days of the issuance of the final report, HILC must return the funds 

associated with the questioned meals to 2121NYILCL.

HILC Response:

All meal charges are correct and relate to meeting\conference trainings at HILC. They are all or grant and 

agency purposes.

ACL Response:

HILC provided the statement that “all meal charges are correct and relate to meeting/conference 

trainings at HILC”. This statement does not adequately address the finding and ACL maintains its position 

that the identified costs are unallowable. ACL will only be able to reevaluate this determination if HILC 

provides supporting documentation for the specific costs showing what was purchased and how HILC 

determined these costs to be allowable under the prevailing award rules and requirements. 

Finding 7: The reasonableness and allocability of costs on 2121NYILCL were unable to be 

determined.

Legal Requirements: 45 CFR 75.404 and 45 CFR 75.405

Discussion: OFO reviewed the general ledger HILC provided for 2121NYILCL in coordination with the 

supporting documentation submitted for a sampling of costs associated with each cost category under 

this award. Through this review OFO was able to determine the allowability of the sampled costs but 

unable to determine if the costs were reasonable and allocable to 2121NYILCL. The supporting 

documentation submitted did not provide sufficient information for these determinations to be made. 
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For example: a copy of a worker’s compensation statement in the amount of $1,687.68 was provided 

for supporting documentation of this cost charged to 2121NYILCL. Fringe benefits are allowable; 

however, it is unclear how HILC determined the portion of costs attributable to 2121NYILCL. This 

example is consistent with all the supporting documentation submitted in response to the sampling of 

costs. 

Finding: HILC is out of compliance with 45 CFR 75.404 and 45 CFR 75.405 as OFO was unable to 

determine whether the sampled costs charged to 2121NYILCL are reasonable and allocable to the grant. 

Corrective Action: 

1) Within 30 calendar days of the issuance of the final report, HILC must submit documentation for 

the sampled costs for 2121NYILCL from the OFO email dated September 26, 2022, that 

demonstrates the receipt of payment from the vendor as well as an explanation of how HILC 

determined the associated costs charged to the grant.

HILC Response:

HILC at year end 9/30/21 allocated total fringe by employee staff hours and time allocated across grant 

lines. The federal approved FTE and gross payroll allocation follows total fringe cost to each grant so in 

the end if HILC’s total agency fringe is 27.24% all grants payroll allocation will be adjusted to 27.24% of 

allocated payroll per grant.

ACL Response:

ACL reviewed HILC’s response and understands that HILC charges fringe costs as a percentage of the 

salary costs. HILC did not provide policies and procedures or a cost allocation plan to support this 

methodology nor did ACL find policy in the Fiscal Policy Manual to support this methodology. ACL 

observed that HILC made a single payment for worker’s compensation costs, which does not align with 

that stated percentage methodology. The finding and corrective action remain unchanged, ACL needs to 

see supporting documentation for the questioned costs including the fringe costs policies and 

procedures, applicable cost allocation plan, and explanation of how the identified worker’s 

compensation expenditure aligns with the policy for charging fringe.

Finding 8: HILC has significant deviations from their internal policies and procedures for time 

and attendance.

Legal Requirements: 45 CFR Part 75.404 (e) and HILC’s internal policy and procedure for time and 

attendance 

Discussion: OFO reviewed the sampling of timecards submitted for 2121NYILCL. OFO noticed that one 

of the timecards submitted included telework hours and was not signed by the employee’s supervisor. 

Additionally, HILC did not submit copies of the pages from the internal daily sign-in log that correspond 

to the dates of the timesheets submitted. HILC’s policy and procedure states that this log is kept at the 

front desk and employees must sign in and out daily. Therefore, OFO has determined non-compliance 

with HILC’s internal policy and procedure for time and attendance from this review.

Finding: HILC is out of compliance with 45 CFR Part 75.404 (e) as HILC’s internal policies and procedures 

relating to time and attendance were not consistently followed.
15

Corrective Action: 

1) Within 60 calendar days of the issuance of the final report, HILC must re-submit copies of the

timecards requested, all signed by the employee’s supervisor along with the portion of the signin log that corresponds to each timecard submitted.

HILC Response:

Attached are copies of HILC timecard & sign-in log

HILC was unaware of this not included in the initial request.

ACL Response: 

HILC provided its Fiscal Policy Manual which includes timekeeping policy, and they provided a timesheet 

attachment which included one sign in sheet, and four timesheets (two date periods). ACL reviewed an 

additional timekeeping policy document during the monitoring that included the physical sign in sheet 

requirement. ACL’s finding is unchanged. HILC’s timesheet attachment included one sign page from 2021 

that did not match the 2022 time period of the provided timesheets, therefore ACL was unable to 

determine if employees completed the sign-in requirement as outlined in HILC’s policy. In addition, the 

timesheet samples provided did not clarify when an individual was teleworking and what timekeeping 

policy was being used to manage teleworking staff. Because of the identified inconsistencies, ACL is 

requesting the grantee to provide supporting documentation for the sampled time periods and the 

applicable HILC timekeeping policy for teleworking. Further, the timesheet sample provided identifies an 

employee’s time spent on ACL projects but does not distinguish the award served. In its corrective action 

plan, ACL is requesting that HILC additionally provide clarification on how timesheets are utilized to 

determine appropriate award charging.

V. OBSERVATIONS AND RECOMMENDATIONS

In addition to the compliance findings outlined above, the review team identified a number of concerns 

with HILC’s operations and has made recommendations for addressing these concerns. 

Observation 1: HILC does not apply a clear definition of “significant disability” when 

classifying staff.

Observation: At the time of the review, HILC had a staff of eight people and demonstrated confusion 

about how to classify whether the staff had disabilities. HILC had five board members, three of whom 

self-identified as having disabilities. 29 U.S. Code § 796f–4(c)(6) requires CILs to have a majority staff and 

those of decision-making positions to be people with disabilities. It also requires the CIL to record the 

number with significant disabilities employed by the CIL, including in management and decision-making 

positions (29 U.S.C. § 796f–4(c)(8)(E)). HILC lists some staff as having “disabilities” and some as having 

“chronic illness.” When the review team asked HILC staff how HILC distinguishes “disability” from 

“chronic illness”, the answer suggested they are not aware of the “disability” and “significant disability” 

definition in the Rehab Act under 29 U.S. Code § 705(21)(B).
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Recommendation: ACL recommends that HILC receive training from ILRU on understanding, and 

applying, the definition of “significant disability” in the Rehabilitation Act to ensure they meet the 

requirement that a majority of staff, decision-making positions, and board members be persons with a 

disability, including those with significant disabilities. The training needs to include how to attract and 

retain staff with significant disabilities.

HILC Response: 

We do not clearly understand what ACL meant by “demonstrated confusion about how to classify whether 

the staff had disabilities.”

According to the ADA, “If you are applying for a job, an employer cannot ask you if you are disabled or 

ask about the nature or severity of your disability. An employer can ask if you can perform the duties of 

the job with or without reasonable accommodation. An employer can also ask you to describe or 

to demonstrate how, with or without reasonable accommodation, you will perform the duties of the 

job.”

Corrective Action: 

HILC will contact ILRU to receive the training necessary 

HILC Board and staff will attend these trainings 

Timetable 

Within the next 30 to 90 days 

ACL Response:

ACL concurs with this response. ACL encourages HILC to pay attention to this report’s revised statement 

about asking about disability status when recruiting and hiring to ensure that it is meeting the 

statutory requirement that a majority of staff positions, a majority of decision-making positions, and a 

majority of board positions are held by people with disabilities.

Observation 2: HILC does not have adequate job descriptions.

Observation: HILC’s job descriptions are vague; they do not clearly indicate: 

- The staff members’ roles, responsibilities, and daily duties to ensure adequate staffing for core

service delivery.

- The lines of communication between supervisory and front-line staff to ensure accountability.

29 U.S. Code § 796f–4(c)(5) requires the organization to use sound organizational and personnel 

assignment practices, however, that is not supported with the CILs current job descriptions. For 

example, the associate director’s job description states that they report to the board president. When 

the review team asked about this reporting, HILC staff replied that this issue was an error and that HILC 

would send the review team a revised job description, yet that has not occurred. 

Recommendation: It is recommended that HILC contact ILRU for assistance with defining job 

descriptions that adequately capture CIL operations and core functions. 
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HILC Response: 

HILC would greatly appreciate a sample of an adequate job description so we can thoroughly review and 

compare what is currently lacking. HILC will then revise/update to ensure we are reflecting all the 

necessary component relating to service delivery. 

Corrective Action: 

HILC will contact other CIL to compare and review areas lacking information 

HILC will also contact ILRU for assistance and make the necessary updates / correction to current job 

descriptions.

Timetable

Over the 30 to 90 days

ACL Response:

ACL concurs with this response. ACL encourages HILC to ask ILRU for sample job descriptions and other 

information that would enable HILC to strengthen its job descriptions. 

Observation 3: HILC does not show evidence of aggressive outreach to unserved and

underserved communities.

Observation: 29 U.S. Code § 796f–4(c)(10) requires CIL to engage in aggressive outreach to individuals

with significant disabilities that are unserved or underserved. There were a number of issues identified 

when staff were reviewing the CIL’s outreach materials. 

- HILC’s social media had not been updated in more than a year and had a minimal number of

followers (e.g., approximately 10 or less).

- HILC’s outreach materials do not explicitly mention the IL core services.

- HILC relies primarily on word of mouth for outreach.

When the review team asked HILC about its outreach, HILC staff could not provide evidence that they 

were currently engaging in aggressive outreach to unserved or underserved communities; however, 

they did identify who the underserved communities were – Chinese Americans. In response, the review 

team offered HILC information on how to reach out to Chinese Americans and LGBTQIA+ populations. 

Recommendation: ACL has a significant number of recommendations to improve aggressive outreach to 

unserved and underserved communities. HILC should: 

- Understand that word of mouth, although it can be useful, is not aggressive outreach.

- Increase social media usage (including Facebook, YouTube, Instagram, and Twitter) at least

monthly and when there is significant news.

- Update their social media platforms to include language on the services the CIL provides

(including the IL core services) and how people with disabilities can benefit from these services.
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- Seek service or input from social media experts. Part of this input needs to pertain to what

geographic and demographic groups social media can reach well; this aspect of the input does

not lessen the recommendation about HILC using social media.

- Connect with the State to correct the contact information and website the State has for the CIL.

- Develop outreach materials with assistance from an expert, that explicitly state the IL core

services.

- Reflect that HILC is consumer driven around the core services in all outreach materials and

platforms.

- Use ILRU’s materials on aggressive outreach to develop additional and more effective outreach

strategies to underserved communities.

- Implement ACL’s input about how to reach out to Chinese American consumers. Include them in

HILC’s outreach plan. ACL’s most important recommendations for HILC to implement are:

• Seek staff, board members, and volunteers who are Chinese American and/or proficient

in Mandarin, Cantonese, etc.

• Partner with civic organizations that consist mostly of Chinese Americans and to the

branch of New York Public Library that specializes in Chinese materials.

• Reach out to schools that teach Chinese languages to ask for advice, referrals, and help.

• Seek and offer trainings.

- Consider exploring opportunities to form, and/or work with lesbian, gay, bisexual, transgender,

queer, intersex, asexual, etc. (LGBTQIA+) peer support groups (especially on issues that pertain

to intersectionality of sexual orientation, gender identity, gender expression, disability, and

other demographic characteristics) to expand work with youth leaving high school and to

address the unserved populations in their area who have intersectional identities.

HILC Response:

Due to some ongoing technical difficulties HILC’s website was under construction, upon resolving those 

issues HILC was able to launch an updated website. There is continuous work being done to increase 

outreach coverage. The community that HILC currently serve does not look at social media to the same 

extent as our peers who are more focused on technology. It is a proven fact the those above 96th street

(in the urban areas) does not have access to technology in the same way and therefore do not rely on it 

in the same manner. HILC still relies on the methodology that has been proven to work within the 

community it serves which is Word of mouth which means the religious institutions, community board, 

CBO etc. 

HILC flyer has a list of all the services provided which was design to reflect the community we serve and 

to ignite a conversation. 

Thank you for your assistance in reaching out to HILC on the Chinese American community but 

historically people of color and the Asian community do not get along even ACL agree to that. When it 

comes to reaching out to the Chinese American this will be an ongoing plan of action. 

HILC has been working with the LGTBQIA for years now and will continue to do so 

Corrective Action:
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HILC will continue to update and be more active in the social media arena. 

HILC will assign a social media person. 

HILC will reach out to ILRU for material and trainings to cover this area of concern. 

Reaching out the Chinese American will be an ongoing effort for HILC. 

Timetable 

Ongoing efforts to achieve our outreach potential 

ACL Response:

If the corrective action plan includes—and/or relies on—document the statement that “those above 96th

street (in the urban areas) does not have access to technology in the same way and therefore do not rely 

on it in the same manner,” then the CAP needs to document this statement. This CAP should be 

completed no later than March 17, 2023.

ACL requires the CAP to include improved social-media presence and to follow best practices for social 

media. 

ACL requires the CAP to include aggressive outreach that is more aggressive than “word of mouth,” e.g., 

“HILC will give presentations to” and “HILC will attend [events].” Word of mouth is too passive to be 

adequate aggressive outreach. 

ACL requires the CAP to share (details of) a plan (and a strategy) for how to deal with tensions between 

“people of color and the Asian community.”
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Appendix: Legal Requirements

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

29 U.S.C. § 705(17) 

INDEPENDENT LIVING CORE SERVICES.—The term “independent living core services” means— 

(A) information and referral services;

(B) independent living skills training;

(C) peer counseling (including cross-disability peer counseling);

(D) individual and systems advocacy; and

(E) services that—

(i) facilitate the transition of individuals with significant disabilities from nursing homes

and other institutions to home and community-based residences, with the requisite

supports and services;

(ii) provide assistance to individuals with significant disabilities who are at risk or

entering institutions so that the individuals may remain in the community; and

(iii) facilitate the transition of youth who are individuals with significant disabilities, who

were eligible for individualized education programs under section 614(d) of the

Individuals with Disabilities Education Act (20 U.S.C. 1414(d)), and who have

completed their secondary education or otherwise left school, to post-secondary life.

29 U.S.C. § 796d–1(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 796f–1 and shall

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

(2) QUALIFICATIONS OF EMPLOYEES CONDUCTING REVIEWS.—The Administrator 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. § 796f–1(g)(1) 

IN GENERAL.—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 796f–4 of this title. 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 796f–4 

of this title, the Administrator shall immediately notify such center that it is out of compliance.

29 U.S.C. § 796f–4 
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(b)(1)(D) equal access for individuals with significant disabilities, within their communities, to 

all services, programs, activities, resources, and facilities, whether public or private and 

regardless of the funding source.

(b)(2) PROVISION OF SERVICES.—The center shall provide services to individuals with a range of significant 

disabilities. The center shall provide services on a cross-disability basis (for individuals with different 

types of significant disabilities, including individuals with significant disabilities who are members of

populations that are unserved or underserved by programs under this title). Eligibility for services at

any center for independent living shall be determined by the center, and shall not be based on the 

presence of any one or more specific significant disabilities. 

(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. Code § 796f–4 

(c) 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 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

decision making positions, of the applicant are individuals with disabilities

29 U.S. Code § 796f–4(c)(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;
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(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 decision-making 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

29 U.S.C § 796f–4(c) 

(10) aggressive outreach regarding services provided through the center will be conducted

in an effort to reach populations of individuals with significant disabilities that are unserved or

underserved by programs under this title, especially minority groups and urban and rural

populations;

(11) staff at centers for independent living will receive training on how to serve such

unserved and underserved populations, including minority groups and urban and rural

populations

2 CFR § 200.303

The non-Federal entity must: 

(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.

(d) Take prompt action when instances of noncompliance are identified including noncompliance

identified in audit findings.

(e) Take reasonable measures to safeguard protected personally identifiable information and other

information the HHS awarding agency or pass-through entity designates as sensitive or the nonFederal entity considers sensitive consistent with applicable Federal, state, local, and tribal laws

regarding privacy and obligations of confidentiality.

SF-425 Term and Condition for 2021NYILC3

Updated SF-425 Financial Reporting: All grantees must submit Federal Financial Report (SF-425) 

matching the dates listed in the PPR Reporting above, except a final 425 report is due within 120 

calendar days after the project period end date of September 30, 2022 or by January 31, 2023. 

Beginning with this FFY2020 grant, the SF-425 shall be submitted using the HHS Payment 

Management System (PMS). PMS website is located at: https://pms.psc.gov.

2 CFR § 200.432

A conference is defined as a meeting, retreat, seminar, symposium, workshop or event whose primary 

purpose is the dissemination of technical information beyond the non-Federal entity and is necessary 
23

and reasonable for successful performance under the Federal award. Allowable conference costs paid 

by the non-Federal entity as a sponsor or host of the conference may include rental of facilities, 

speakers' fees, costs of meals and refreshments, local transportation, and other items incidental to 

such conferences unless further restricted by the terms and conditions of the Federal award. As 

needed, the costs of identifying, but not providing, locally available dependent-care resources are 

allowable. Conference hosts/sponsors must exercise discretion and judgment in ensuring that 

conference costs are appropriate, necessary and managed in a manner that minimizes costs to the 

Federal award. The HHS awarding agency may authorize exceptions where appropriate for programs 

including Indian tribes, children, and the elderly. 

45 CFR 75.437

(a) Costs incurred in accordance with the non-Federal entity's documented policies for the

improvement of working conditions, employer-employee relations, employee health, and employee

performance are allowable.

(b) Such costs will be equitably apportioned to all activities of the non-Federal entity. Income

generated from any of these activities will be credited to the cost thereof unless such income has

been irrevocably sent to employee welfare organizations.

(c) Losses resulting from operating food services are allowable only if the non-Federal entity's

objective is to operate such services on a break-even basis. Losses sustained because of operating

objectives other than the above are allowable only:

(1) Where the non-Federal entity can demonstrate unusual circumstances; and

(2) With the approval of the cognizant agency for indirect costs.”

45 CFR 75.404

A cost is reasonable if, in its nature and amount, it does not exceed that which would be incurred by a 

prudent person under the circumstances prevailing at the time the decision was made to incur the 

cost. The question of reasonableness is particularly important when the non-Federal entity is 

predominantly federally funded. In determining reasonableness of a given cost, consideration must be 

given to: 

(a) Whether the cost is of a type generally recognized as ordinary and necessary for the operation of

the non-Federal entity or the proper and efficient performance of the Federal award.

(b) The restraints or requirements imposed by such factors as: Sound business practices; arm's-length

bargaining; Federal, state, local, tribal, and other laws and regulations; and terms and conditions of

the Federal award.

(c) Market prices for comparable goods or services for the geographic area.

(d) Whether the individuals concerned acted with prudence in the circumstances considering their

responsibilities to the non-Federal entity, its employees, where applicable its students or membership,

the public at large, and the Federal Government.

(e) Whether the non-Federal entity significantly deviates from its established practices and policies

regarding the incurrence of costs, which may unjustifiably increase the Federal award's cost.

45 CFR 75.405
24

(a) A cost is allocable to a particular Federal award or other cost objective if the goods or services

involved are chargeable or assignable to that Federal award or cost objective in accordance with

relative benefits received. This standard is met if the cost:

(1) Is incurred specifically for the Federal award;

(2) Benefits both the Federal award and other work of the non-Federal entity and can be distributed

in proportions that may be approximated using reasonable methods; and

(3) Is necessary to the overall operation of the non-Federal entity and is assignable in part to the

Federal award in accordance with the principles in this subpart.

(b) All activities which benefit from the non-Federal entity's indirect (F&A) cost, including unallowable

activities and donated services by the non-Federal entity or third parties, will receive an appropriate

allocation of indirect costs.

(c) Any cost allocable to a particular Federal award under the principles provided for in this part may

not be charged to other Federal awards to overcome fund deficiencies, to avoid restrictions imposed

by Federal statutes, regulations, or terms and conditions of the Federal awards, or for other reasons.

However, this prohibition would not preclude the non-Federal entity from shifting costs that are

allowable under two or more Federal awards in accordance with existing Federal statutes, regulations,

or the terms and conditions of the Federal awards.

(d) Direct cost allocation principles. If a cost benefits two or more projects or activities in proportions

that can be determined without undue effort or cost, the cost must be allocated to the projects based

on the proportional benefit. If a cost benefits two or more projects or activities in proportions that

cannot be determined because of the interrelationship of the work involved, then, notwithstanding

paragraph (c) of this section, the costs may be allocated or transferred to benefitted projects on any

reasonable documented basis. Where the purchase of equipment or other capital asset is specifically

authorized under a Federal award, the costs are assignable to the Federal award regardless of the use

that may be made of the equipment or other capital asset involved when no longer needed for the

purpose for which it was originally required. See also §§ 200.310 through 200.316 and 200.439.

(e) If the contract is subject to CAS, costs must be allocated to the contract pursuant to the Cost

Accounting Standards. To the extent that CAS is applicable, the allocation of costs in accordance with

CAS takes precedence over the allocation provisions in this part.

HILC Personnel Policies and Procedures Manual

Timesheets: Maintaining an accurate record of time worked is an employee requirement in order to 

process time- sheets and salary payments promptly. Time- sheets must be used to record all hours 

worked: straight, overtime, personal and sick time and submitted in the original form to the Associate 

Director with employee signature. In addition, employees must use the Daily Book- located at the 

front desk-to input morning arrivals, lunch breaks, and sign- outs on a daily basis. It is important all 

entries are filled out in the Daily Book as employee’s run the risk of getting docked by the number of 

empty entries in the book.