APRIL 2014
84.169
INDEPENDENT LIVING STATE GRANTS
State Project/Program:
EASTERN NORTH CAROLINA CENTER FOR
INDEPENDENT LIVING, INC.
U. S. DEPARTMENT OF EDUCATION
OFFICE OF SPECIAL EDUCATION AND REHABILITATIVE SERVICES
Federal Authorization:
Rehabilitation Act of 1973, as amended, Title VII, Chapter 1, Part B.
N. C. Department of Health and Human Services
Division of Vocational Rehabilitation Services
Agency Contact Person – Program
N. C. DHHS Confirmation Reports:
Mark Steele
(919) 855-3525
Mark.Steele@dhhs.nc.gov
SFY 2014 audit confirmation reports for payments made
to Counties, Managed Care Organizations (MCOs or,
formerly, Local Management Entities), Boards of
Education, Councils of Government, District Health
Departments and DHSR Grant Subrecipients will be
available by early September at the following web
address:
http://www.ncdhhs.gov/control/auditconfirms.htm.
At
this site, click on the link entitled “Audit Confirmation
Reports (State Fiscal Year 2013-2014)”. Additionally,
audit confirmation reports for Nongovernmental entities
receiving financial assistance from the DHHS are found at
the same website except select “Non-Governmental Audit
Confirmation Reports (State Fiscal Years 2012-2014)”.
Agency Contact Person – Financial
Patricia Harper
(919) 855-3592
Trish.Harper@dhhs.nc.gov
The auditor should not consider the Supplement to be “safe harbor” for identifying audit
procedures to apply in a particular engagement, but the auditor should be prepared to justify
departures from the suggested procedures. The auditor can consider the Supplement a “safe
harbor” for identification of compliance requirements to be tested if the auditor performs
reasonable procedures to ensure that the requirements in the Supplement are current. The
grantor agency may elect to review audit working papers to determine that audit tests are
adequate.
I. PROGRAM OBJECTIVES
The objective of the Development Disabilities Basic Support and Advocacy Grant funds
disbursed to Eastern North Carolina Center for Independent Living, Inc. is to support a Center
for Independent Living in Greenville, NC. The Contractor will provide independent living core
services, in accordance with The Rehabilitation Act of 1973, as amended, Sections 702 and 705
standards and assurances, to persons with disabilities residing in the following counties: Pitt,
Wilson, and Beaufort.
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EASTERN NORTH CAROLINA CENTER FOR INDEPENDENT LIVING INC.
II. PROGRAM PROCEDURES
Eastern North Carolina Center for Independent Living, Inc. has agreed to:

Plan, conduct, administer, and evaluate a Center for Independent Living consistent with the
standards and assurances identified in section 725(b) and (c) of the Rehabilitation Act, and
subparts F and G of 34 CFR part 366;

Serve eligible consumers within Pitt, Wilson, and Beaufort counties which have been
identified as unserved or underserved counties by the 2014-2016 NC State Plan for
Independent Living;

Ensure that the majority of the Center’s staff and individuals in decision making positions
are individuals with disabilities;

Provide equal access to the four Independent Living Core [ (1) Information and Referral, (2)
Peer Counseling, (3) IL Skills Training, and (4) Individual and Systems Advocacy] services
for eligible consumers who are members of groups that have been traditionally underrepresented (including, members of racial or ethnic minority groups, women, elderly
individuals, children and youth);

As part of nondiscriminatory employment practices, Eastern North Carolina Center for
Independent Living shall ensure that its personnel are selected for employment without
regard to race, color, national origin, gender, age or disability; and to the extent that it will
encourage application for employment from persons who are members of groups that have
been traditionally under-represented, including members of racial or ethnic minority groups,
women, elderly individuals;

Eastern North Carolina Center for Independent Living shall ensure that individuals with
significant disabilities will be substantially involved in planning policy direction, and
management of the center, and those individuals with significant disabilities will be
employed by the center; and

Eastern North Carolina Center for Independent Living shall ensure that over 50% of the
Center’s decision makers, board members and staff shall be individuals with significant
disabilities.
III. COMPLIANCE REQUIREMENTS
A. ACTIVITIES ALLOWED OR UNALLOWED
Funds are used to support a Center for Independent Living in Greenville, NC. Funds will be
used to provide independent living core services, in accordance with The Rehabilitation Act
of 1973, as amended, Sections 702 and 705 standards and assurances, to persons with
disabilities residing in the following counties: Pitt, Wilson, and Beaufort.
B. ALLOWABLE COSTS/COST PRINCIPLES
Activities/services described in I., Program Objectives, are allowable activities of a
developmental disabilities grant. These include promoting systems change that contribute to
a coordinated consumer- and family-directed, comprehensive system of community services,
individualized supports, and other forms of assistance that enable individuals with
developmental disabilities to exercise self-determination, be independent, be productive, and
be integrated and included in all facets of community life (PL 106-402, Sec. 121(1)(2)).
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EASTERN NORTH CAROLINA CENTER FOR INDEPENDENT LIVING INC.
Activities described in the program narrative, a unique narrative included in each approved
developmental disabilities grant, are also allowable activities. Activities specifically not
allowed are construction and major renovation. (PL 106-402, Sec. 123)
Costs in the approved application budget are allowable costs of a developmental disabilities
grant. These include the following budget categories: salaries, fringe benefits, supplies, staff
travel, cost of space, equipment, contracted services, “other” (“other” is defined in the grant
application), and indirect costs. Each budget category may have explanatory remarks.
Expenditures / costs are limited to those outlined in the approved budget in the application.
Basic Considerations, Indirect Costs, Direct Costs, Allowable Costs, and Unallowable Costs
may be found in the latest version of the federal Office of Budget and Management (OMB)
Circular 122 or OMB Circular A-87 available from the OMB website at
www.whitehouse.gov/OMB/circulars.
C. CASH MANAGEMENT
Not less than monthly a “Request for Reimbursement” or a “Report of Outlays” (for projects
receiving monthly advances) showing expenditures will be submitted to the NC Division of
Vocational Rehabilitation Services. While no moneys may have been expended (in such
case all entries will be zeros), these monthly requests are mandatory. Expenditures in arrears
more than sixty (60) days, or two months of the period, for which the project is funded, will
not be reimbursable.
E. ELIGIBILITY
An eligible recipient under a Developmental Disabilities grant must conduct activities for
people with developmental disabilities that are defined as severe and chronic and:
1. Are attributable to a mental or physical impairment or combination of mental and
physical impairments,
2. Are manifested before the person reaches the age of 22,
3. Are likely to continue indefinitely,
4. Result in substantial functional limitations in three or more of the following areas of
major life activity:
a) self-care
b) receptive and expressive language
c) learning
d) mobility
e) capacity for independent living
f) economic self-sufficiency
g) self-direction
5. Reflect the need for a combination and sequence of special, interdisciplinary, or generic
services, individualized supports or other forms of assistance that are of lifelong or
extended duration and are individually planned and coordinated.
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EASTERN NORTH CAROLINA CENTER FOR INDEPENDENT LIVING INC.
G. MATCHING, LEVEL OF EFFORT, EARMARKING
Funds used to match developmental funds must be either State or local. Federal funds, even
though channeled through a State agency, may not be used as match (PL 106-402, Sec. 126 b
(1)).
H. PERIOD OF AVAILABILITY OF FEDERAL FUNDS
The Performance Agreement and budget incorporated therein will define the period of
availability of federal funds. Federal funds may be spent over multiple years; however,
Performance Agreements and project budgets are written for one year at a time, and project
budgets are one-year budgets. The beginning and ending dates of the project are
incorporated into the Performance Agreement, and all expenditures must occur within these
dates.
L. REPORTING
In addition to the monthly fiscal reports described in Section C. Cash Management above, a
final fiscal report must be prepared by the local service providing agency and submitted to
the Council on Developmental Disabilities no later than 30 calendar days after the grant
period ends (PL 106-402, Sec. 103 and ASSURANCES). Assurances are signed by the
grantee and are a part of the grant application defining the terms of the grant and
expectations of the grantee and grantor. Final Requests for Reimbursement received by the
N. C. Division of Vocational Rehabilitation Services after 60 calendar days may not be
reimbursable.
The Center shall submit a completed 704, Annual Performance Report for Centers for
Independent Living Program, Part II Instrument to the N. C. Statewide Independent Living
Council’s Expanding the Network of Centers Committee by no later than December 31 of
each year.
M. SUBRECIPIENT MONITORING
The N. C. Division of Vocational Rehabilitation Services “Monthly Performance Report”
accomplishes subrecipient monitoring. This report provides information on the number of
consumers provided with IL Core Services. The Center is also required to provide a
Quarterly and Annual Performance Report to the Division detailing information on the
number of consumers provided with IL Core Services.
N. SPECIAL TESTS AND PROVISIONS
1. Compliance Requirement
Eastern North Carolina Center for Independent Living is required by the N. C.
Department of Health and Human Services’ basic records retention policy to retain all
records for a minimum of five years. Policy further requires that records be retained for
a period of five years following the submission of the final Federal Financial Status
Report, if applicable, or five years following the submission of a revised final Federal
Financial Status Report. Also, if any litigation, claim, negotiation, audit, disallowance
action, or other action involving these funds has been started before expiration of the five
year retention period, the records must be retained until the completion of the action and
resolution of all issues which arise from it, or until the end of the regular five year
period, whichever is later. Therefore, Eastern North Carolina Center for Independent
Living shall not destroy, purge or dispose of records related to these funds without the
express written consent of the Division of Vocational Rehabilitation.
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EASTERN NORTH CAROLINA CENTER FOR INDEPENDENT LIVING INC.
Audit Objective
To ensure the N. C. Department of Health and Human Services’ record retention policy
is followed.
Suggested Audit Procedures
Verify that records are kept for a minimum of three years related to the Development
Disabilities Basic Support and Advocacy Grant funding disbursed by the Division to
Eastern North Carolina Center for Independent Living.
2. Compliance Requirement
Conflict of Interest and Certification Regarding No Overdue Tax Debts
All non-State entities (except those entities subject to the audit and other reporting
requirements of the Local Government Commission) that receive, use or expend State
funds (including federal funds passed through the N. C. Department of Health and
Human Services) are subject to the financial reporting requirements of G. S. 143C-6
effective July 1, 2007. These requirements include the submission of a Notarized
Conflict of Interest Policy (see G. S. 143C-6-23(b)) and a written statement (if
applicable) that the entity does not have any overdue tax debts as defined by G. S.
105-243.1 at the federal, State or local level (see G. S. 143-6-23(c)). All non-State
entities that provide State funding to a non-State entity (except any non-State entity
subject to the audit and other reporting requirements of the Local Government
Commission) must hold the sub-grantee accountable for the legal and appropriate
expenditure of those State grant funds.
Audit Objective
Before receiving and disbursing State funds, determine whether the grantee (1) has
adopted a conflict of interest policy and has it on file and (2) whether the grantee has any
overdue tax debts at the federal, State or local level.
Suggested Audit Procedures
1. Ascertain that the grantee has a conflict of interest policy as described above.
2. Check the policy and verify through board minutes that the policy was adopted
before the grantee received and disbursed State funds.
3. Verify as to whether or not the grantee has any overdue tax debts at the federal, State
or local level by reviewing tax reports filed with the appropriate government
agencies and confirming via an inspection of the accounting records that all taxes
were paid timely.
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