**FREQUENTLY ASKED QUESTIONS**

**Independent Living Emergency Preparedness and Disaster Response Services**

**Introductory Note:**Centers for Independent Living (CILs) and Statewide Independent Living Councils (SILCs) are increasingly playing a pivotal role in addressing the often daunting challenges individuals with disabilities and their families face during and following a disaster or other emergency.  ACL recognizes the enormous importance of CILs providing inclusive emergency preparedness and disaster response services to the lives and independence of individuals with disabilities and their families.  Moreover, a key element of effective emergency preparedness is to take action and put steps in place that are essential to responding to disaster before it strikes.  The following FAQ is provided as guidance to assist in emergency preparedness and disaster response efforts.  

**Q 1:  Under what circumstances may a CIL provide Title VII independent living (IL) services to individuals with disabilities living in disaster or emergency zones that are outside its designated service area?**

**A 1:**It needs noting at the start that a CIL that receives Part C funding can provide IL services to individuals with disabilities living inside its service area at any time, including during and after a disaster or emergency situations.  

We also recognize and applaud the fact that Centers for Independent Living frequently rely on each other during such periods to meet the critical needs of people with disabilities.  For this reason, ACL strongly encourages CILs and SILCs to develop memorandums of agreement (MOAs) within their states that specify steps Centers can take to assist people with disabilities in affected disaster areas, including service areas not approved in a CIL’s original Part C grant application and/or supporting documentation.  With an approved MOA in place, a CIL will be allowed to use its Part C funds to engage in disaster response activities outside its service area.  A CIL also can  engage in disaster response activities outside its service area without an MOA in place by using non-Part C funds.  

**Q 2:  What kind of information does ACL require in an MOA for a CIL to provide disaster response services to individuals located outside their approved service area?**

**A 2:**  ACL will allow CILs to provide Part C funded independent living services to individuals during and after disasters in communities located outside their approved service area when a written MOA on emergency preparedness and relief has been submitted to ACL that includes:

· Signatures of all Part C CILs that want to offer such services in a state;   

· Conditions under which one or more CILs can provide IL services in a disaster area where no other Center has previously provided such services;  

· Conditions under which a CIL providing services to individuals with disabilities in a disaster impacted area requests and agrees to one or more other CILs providing IL services in its assigned service area; and

· Duration of allowable services, not to exceed six (6) months.

**PLEASE NOTE:** Agreements can be extended for up to the same period if deemed necessary and mutually acceptable to all signatories to the agreement, and if it is approved by the ILA Director.  ACL requires that such agreements be included in the State Plan for Independent Living (SPIL). 

**Q 3:  In a state with no MOA in place, what is the process for requesting approval from the ILA director to provide disaster response services outside a CIL’s approved service area using Part C funds?**

**A 3:**  A CIL requesting to provide disaster response services outside their approved service area using Part C funds must submit a written request to the ILA director through their project officer (PO) before the CIL carries out such activities.  The request must include information and documentation adequate to enable the ILA director make a time sensitive determination.  The PO will process the request and respond to the CIL no later than 24 hours after approval or disapproval by the ILA director.     

**Note:**  This process should occur whenever possible as far in advance of when a disaster or emergency occurs.  

**Q 4: In a state with no MOA in place, what criteria will the ILA director consider before approval is granted to a CIL requesting to provide disaster response services outside their approved service area using Part C funds?**

**A 4:**  Criteria the ILA director will consider during the interim include the following:

· Whether the affected area is served by an existing Part C or Part B CIL;

· Whether the CIL requesting approval to provide disaster response services has contacted and received approval from the existing CIL serving the area to do so;

· Any information in the SPIL indicating prior agreements among IL partners in the State, i.e., the SILC, DSE and other CILs to collaboratively provide disaster response services; and

· Whether the CIL requesting approval to provide disaster response services is able to do so without jeopardizing IL core and other services to eligible individuals within its own approved service areas.

**Note:**  This process should occur whenever possible as far in advance of when a disaster or emergency occurs.  

**Q 5:  What is the effective date for implementing the interim process for CILs to provide independent living services to individuals during and after disasters in communities located outside their approved service area using Part C funds?**

**A 5:** The processes provided in the FAQ are effective immediately.  Over the coming months, ACL will refine the guidance as we will seek stakeholder feedback.  Further guidance may include developing typical MOAs regarding disaster response services and steps to include the MOA in the SPIL.  As appropriate, in accordance with Federal requirements, this process may require approval by the Office of Management and Budget if additional information collection by ILA is required to report on the results of these efforts and their impact on the ILA-funded programs.

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