Swtcie Il Q and A

Question and answers will be posted as they are received. All questions must be submitted prior to May 22, 2023.

Q: What is a 14(c) Department of Labor Certificate?
1. Section 14(c) of the Fair Labor Standards Act authorizes employers, after receiving a certificate from the Department of Labor Wage and Hour Division, to pay subminimum wages - wages less than the Federal minimum wage - to workers who have disabilities for the work being performed. The certificate also allows the payment of wages that are less than the prevailing wage to workers who have disabilities for the work being performed on contracts subject to the McNamara-O'Hara Service Contract Act (SCA) and the Walsh-Healey Public Contracts Act (PCA). SubMinimun Wage Fact Sheet
Q: How does our agency apply for a 14(c) certificate through the Department of Labor?
1. Employers who wish to apply for a section 14(c) certificate may submit their application to the Wage and Hour Division in one of two ways: (1) completing their application online or (2) mailing forms WH-226 and WH-226A. 14(c) Certificate Application Website
Q: Will you please explain the following funding priority: Only organizations that hold or have applied for certificates issued under section 14(c) of the Fair Labor Standards Act, and not currently funded as DRS community Rehabilitation Program (CRP) providers or who have contracts less than $250,000 and meet or agree to meet DHS CRP accreditation requirements will be eligible to apply.
1. Under this funding priority, a successful applicant will meet the following criteria:
  - An applicant must hold or have applied for a certificate issued by the Department of Labor under section 14(c) of the Fair Labor Standards act, and
  - An applicant must not be currently funded as a DRS Community Rehabilitation Provider (CRP), or
  - An applicant must annually receive, be reimbursed, through a DRS CRP contract less than $250,000 (The Division will consider spending in both FY22 and FY23); and
  - An applicant must meet or agree to meet DRS CRP accreditation requirements.
Q: If a grantee participates in the project, will they be expected to have 14c work activities fully eliminated by the end of the four year grant period?
1. Grantees are expected to commitment to work in collaboration with and under the guidance of the SWTCIE Illinois team to create and adopt an innovative business model that focuses on CIE, eliminates the use of the 14(c) certificate, and increase the use of Vocational Rehabilitation Contracts. Grantees are required to affirm to decrease enrollment in Subminimum Wage Certificate 14(c) activities and move toward elimination of SMW activities by the end of the grant term.
Q: If a grantee is selected, is there any opportunity to accept/decline at the time of selection?
1. If a grantee is selected, the State grantmaking agency will release a Notice of State Award (NOSA) to the applicant from the Catalog of State Financial Assistance (CSFA). The applicant shall review the NOSA and determine whether it will accept the specified terms of the award. The applicant may accept or decline through the CSFA system. Please refer to 44 IL Admin. Code 7000.360
Q: Can funding be used to help create integrated, minimum wage jobs, in the community? I.E. Starting a business that employs individuals of all abilities.
1. Yes, funding can be used to create new CIE opportunities as long as the new positions meet the CIE requirements as defined in 34 CFR § 361.5(c)(9).
Q: Do the two Full-time staff dedicated to SWTCIE Illinois have to relinquish other current responsibilities if already hired by the agency?
1. Yes. The staffing requirements as outlined in the Notice of Funding Opportunity requires agencies to hire or reassign at least two agency personnel to become ACRE certified Employment Specialists and dedicate 100% of their efforts to SWTCIE Illinois project activities.
Q: Is it expected for the wages of the two Full-time staff dedicated to SWTCIE Illinois be taken out of the project budget?
1. The grant will cover areas such as personnel, training/certification, accreditation, outreach, and other enhancements to programs which focus on CIE outcomes. Proposed budgets may include Personnel costs, directly associated with SWTCIE Illinois project activities- salaries and fringe (SFY 24- SFY 27). If personnel costs are not included on the proposed budget, an explanation in the budget narrative is required supporting how your agency shall fund the two required positions.
Q: Does "engagement" of eight individuals with disabilities mean participating in the program? If our agency has clients already enrolled in Supported Employment or Milestone contract in July of 2023, do they count toward the "engagement of eight individuals"?
1. The expectation would be eight NEW participants who are not already engaged with Division of Rehabilitation Services as customers.
Q: How do you define "engagement"?
1. Our intended project outcomes are optimized CIE, enhanced quality of life, and increased economic self-sufficiency, independence, and inclusion in society among SWTCIE Illinois participants; increase the opportunity for SWTCIE Illinois participants to obtain CIE; provide Vocational Rehabilitation and wrap-around services that will enable SWTCIE Illinois participants to transition from subminimum wage employment to CIE.
Q: How does one qualify someone as "contemplating" 14c subminimum wage employment?
- A: "Contemplating subminimum wage employment" means that the SWTCIE project participant has in mind, as a probable though not certain intention, to enter subminimum wage employment. (Section 437(d)(1) of GEPA.) U.S. Department of Education Notice Inviting Applications: SWTCIE
Q: Could the funding be used to support expanding into another area in Illinois to support Community Resource Provider (CRP) services:
1. Yes, funding can be used to increase CRP services as long as the services provided are in support of CIE as defined in 34 CFR § 361.5(c)(9).
Q: I was unable to attend the Technical Assistance session on May 2nd. Is a recording of the session available?
1. Yes. You may find a recording of the session here SWTCIE IL Technical Assistance-20230502 1539-1
Q: If we serve in multiple regions. Can we submit multiple applications?
1. Yes. Successful applicants agree to provide program services as described throughout this Funding Notice. Applicants may choose to submit one application for all geographic areas to which they are applying, or they may choose to submit a separate application for each of the geographic areas to which they are applying.
Q: What is the process for Association of Community Rehabilitation Educators (ACRE) training certificates? Will the training be offered virtually or in person?
1. The SWTCIE Illinois team will facilitate the ACRE certification training. The exact training protocol is under development. The training team expects a hybrid of virtual and in-person training sessions. For more information on ACRE training certificates.
Q: Define "participation fee" as it relates to Section 3: Deliverables,10.Grantees cannot charge participation fees as part of the SWTCIE Illinois project.
1. Services and/or grantee time supporting SWTCIE funded activities should not be charged to a Medicaid Waiver program.
Q: When will the innovative business models created from the grant be available to agencies not participating in the demonstration project?
1. Access to the complete models will be available at the end of the grant term September, 2027. However, materials and resources for public use will be posted on a SWTCIE Illinois website hosted by University of Illinois, Urbana-Champaign as early as October 2023.
Q: Is ACRE training based off of the Individual Placement and Support evidence-based model?
1. ACRE Training Certificates are competency-based trainings modeled after the Association of People Supporting Employment First (APSE). The competencies set forth cover the knowledge and skills needed to work effectively in the field of employment for people with disabilities, including Customized Employment, supported employment, transitional employment, etc.
Q: Are their fees associated with ACRE training?
1. No, all training and certification fees will be covered as regular grant project activities. Agencies will not be responsible for any fees associated with ACRE training.
Q: What is the expected timeline for ACRE training?
1. The SWTCIE Illinois team anticipates ACRE training to begin by October 2023. Our goal is for all Employment Specialists for all agencies hired and receive training together. We understand that several factors may influence our ability to accomplish this goal.
Q: Has the Department of Labor, provided a final date for issuing 14(c) certificates?
1. To our knowledge, the Department of Labor has not issued a date.
Q: Is there a minimum number of youth or adults with disabilities are required to participate in the SWTCIE Illinois demonstration project?
1. Year one performance measures require engagement of at least eight (8) youth and adults (combined) with disabilities who are contemplating or currently employed under a 14(c) subminimum wage certificate. At least ten (10) participants are expected to engage in each project year 2-4.
Q: If not currently accredited, how soon does an agency need to become accredited?
1. Per 89 Il Admin. Code 530.5 agencies who have not yet received national accreditation may be operate under a provisional status for three years, at which time National accreditation is required.
Q: Can you define transformative Business Model?
1. Transformative business models intend to make changes to an organization's people and processes to adapt or incorporate changes in industry and society. The SWTCIE Illinois demonstration project will create six individualized and localized models to improve participation in competitive integrated employment for people with disabilities. Although there will be no prescriptive, singular model for adoption, our hope is to develop models that will be replicable for agencies with similar geographic and demographic characteristics.
Q: How will an award under the SWTCIE IL grant impact grantees who are already operating as DRS CRPs?
1. The SWTCIE Il Team will work with grantees to ensure full utilization of their current DRS CRP contract, or will assist the agency on increasing their DRS CRP contract as appropriate. SWTCIE Il project activities are intended to increase the number of participants eligible to work toward a CIE VR outcome. The SWTCIE Illinois team will assist grantees with selecting qualified participants for the demonstration project. We anticipate grantees selecting individuals they are currently serving under SMW to be the primary participants in the demonstration project.
Q: In what order should the proposal narrative be submitted? Section 3 Application requirements and Section 5 Other submission requirements are in conflict of one another.
1. The proposal narrative should be submitted in the following order:
  - Executive Summary (Appendix D)
  - Need- Description of Need
  - Capacity- Agency qualifications/Organizational Capacity
  - Quality- Description of Program Design and Services
  - Budget Narrative
Q: Can individuals who qualify for Medicaid Waiver funding participate in the grant activities?
1. Yes, we encourage Medicaid Waiver recipients to participate in the SWTCIE Il grant project. The SWTCIE Il team will assist agencies to ensure customers are receiving the maximum benefit while also remaining compliant with Federal regulations.
  2 CFR 200.412 Classification of Costs indicates no universal rule for classifying certain costs however, it is essential that each item of cost incurred for the same purpose be treated consistently to avoid double-charging Federal awards. Keeping appropriate records and cost documentation as required by 2 CFR 200.302 "Financial Management" and 2 CFR 200.334 "Retention requirements for records", will be critical.
Q: What certificate will employees receive as a result of ACRE training?
1. Employment Specialists will receive the Basic Employment Services Certificate.
Q: Under the Personnel portion of the budget, are we able to include wages of other staff associated with the grant besides the two fulltime Employment Specialists such as supervisor time and/or other positions in our Community Employment Program?
1. Yes, if the additional personnel costs are necessary and reasonable based on the activities contained in the Scope of work and justified in the budget narrative. Section 8 a) and b) of the NOFO indicate allowable and unallowable costs.
Q: Are additional staff, outside of the two required, able to participate in the ACRE training?
1. Yes.
Q: Do we need to budget in the grant the fees associated with ACRE training?
1. Agencies will incur no costs for the ACRE training, therefore do not need to be included in the budget.
Q: Could Community Day Service attendees receiving 31U be billed for 31U during Competitive Integrated Employment programming time?
1. Federal Regulations do not allow double-dipping, charging the same cost to two separate funding sources.
  2 CFR 200.412 Classification of Costs indicates no universal rule for classifying certain costs however, it is essential that each item of cost incurred for the same purpose be treated consistently to avoid double-charging Federal awards. Keeping appropriate records and cost documentation as required by 2 CFR 200.302 "Financial Management" and 2 CFR 200.334 "Retention requirements for records", will be critical.
Q: Are costs for renovations to current space to be dedicated for use to the program use allowed?
1. No. Section 8 b)iii): Capital expenditures for improvements to land, buildings, or equipment which materially increase their value or useful life (2 CFR 200.439).
  Section 8 a) and b) of the NOFO indicate allowable and unallowable costs.
Q: Are costs for program dedicated technological equipment?
1. Yes, if the program dedicated technological equipment costs are necessary and reasonable based on the activities contained in the Scope of work and justified in the budget narrative. Section 8 a) and b) of the NOFO indicate allowable and unallowable costs.
Q: Are costs for a vehicle dedicated to the program allowed?
1. No. Section 8 b)ii): Capital expenditures for general purpose equipment, including any vehicle regardless of cost, buildings, and land (2 CFR 200.439).
  Section 8 a) and b) of the NOFO indicate allowable and unallowable costs.
Q: Once a SWTCIE IL participant obtains community employment, can we utilized Medicaid Waiver funding for long-term supported employment?
1. For supported employment, DRS is the first stop. The duration of DRS VR services vary - someone in Milestone may be supported for 90+ days after hire while someone in Customized Employment or DRS Supported Employment may be supported for 9 months or more. A request for DDD SEP Individual must be made within 90 days following a successful DRS closure. Regardless of DRS case type (Milestone, SEP, CE or other), the request for DDD SEP Individual can be made as soon as the DRS case closure has been initiated. Once initiated, cases are monitored no less than 90 to ensure stability prior to closing. In this period the referral to DDD can be made to ensure that no gap in service will happen.
Q: When is a program participant considered a successful closure from SWTCIE IL?
1. All SWTCIE IL program participants will be tracked through the duration of the grant period 7/1/23-6/30/27. Participants will participate in DRS VR services and will follow the rules for closure (89 ILCS 595). Participants needing extended supports through DDD, will continue to be eligible for SWTCIE IL program activities.
Q: If we do not have a current 14c certificate, but have applied for one, are we eligible to apply for the SWTCIE IL grant?
1. If you have applied for a 14c certificate with the Department of Labor, you MAY apply for the grant. Your grant application would require proof of your 14c application with the Department of Labor. If you do not have a certificate and HAVE NOT applied for one, then you are ineligible for the grant opportunity.
Q: Will SWTCIE IL program participants working with Employment Specialists under the SWTCIE IL grant be enrolled in a DRS VR contract?
1. SWTCIE IL program participants will need to meet the eligibility requirements of DRS (89 ILCS 553). Any participant interested in CIE who is determined ineligible for DRS VR services will be support by SWTCIE IL to identify services to best support the customers employment needs.
Q: Will the agencies be allowed to accept payments for placement of SWTCIE IL participants under the DRS VR contract?
1. Yes. The intent of SWTCIE IL is to encourage 14(c) certificate holders to transform their business models and leverage DRS VR contracts to increase business revenue. SWTCIE IL grant funds are largely intended to support operational and personnel costs of transforming the business model, not for employment-based fee for service. Grantees may continue to bill on their vendor contracts.
  Please remember Federal Regulations do not allow double-dipping, charging the same cost to two separate funding sources. 2 CFR 200.412 Classification of Costs indicates no universal rule for classifying certain costs however, it is essential that each item of cost incurred for the same purpose be treated consistently to avoid double-charging Federal awards. Keeping appropriate records and cost documentation as required by 2 CFR 200.302 "Financial Management" and 2 CFR 200.334 "Retention requirements for records", will be critical.
Q: How many individuals are required to be enrolled in the SWTCIE IL project?
1. The SWTCIE IL grant project indicates the following objective: "At least eight STWCIE Illinois participants per each of the six 14c entities will participate the pilot of the model in year two (October 1, 2023-Sept 30, 2024). At least 10 SWTCIE Illinois participants per each of the six 14c CRP agencies per year will participate in project years 3-5 (October 1, 2024- September 30, 2027)".
Q: How often do grantees have to report on participant data?
1. Data and reporting requirements are listed in Section 4 Performance Measures, e) Data and reporting:
  Data and Reporting
  1. Using SWTCIE Illinois developed protocols, grantees will maintain data and records on SWTCIE Illinois project activities.
  2. Grantees will be required to participate in the formal evaluation of the SWTCIE Illinois project, conducted by UIUC on at least a quarterly basis. Grantees must cooperate in the collection of data for this purpose.
  3. Using a SWTCIE Illinois developed protocol, submit quarterly and year-end reports regarding program performance measures and outcomes.
Q: What type of criteria is intended to identify "need" of youth and adults with disabilities?
1. SWTCIE IL would consider any youth or adult that is a current subminimum wage employee, or one who is contemplating subminimum wage employment, in "need" of project participation regardless of whether they qualify for VR services. Initial and ongoing assessments will be conducted to determine a customer's individual needs regarding employment. One of the goals of the project is for the agency and other stakeholders to provide wraparound services to allow the customer the best chance at a successful employment outcome. This could include on the job support, benefits planning, customized/supported employment, counseling and guidance, longer term support (DDD, etc.), transportation, housing, home services, etc., the service "needs" of each individual may be different and should be individualized.
Q: Is there an industry standard or criteria for CIE placements?
1. Please refer to the full CFR definition 34 CFR § 361.5(c)(9).
  Abridged definition: For a position to be considered competitive, it must be work that is 1) performed on a full or part-time basis (including self-employment) at which the individual is a) compensated at least minimum wage, b) pay is commiserate to non-disabled workers doing a similar job, c) is eligible for the same level of benefits; 2) is in a location typically found in the community and the person with disabilities interacts/works alongside workers without disabilities; and 3) presents opportunities for advancement.
Q: In completing the Uniform Grant Budget Template for FY24, is the expectation that all $125,000 be delegated at the time of application?
1. DRS can only award the amount that is approved and justified in your proposed budget.
Q: Does ACRE training have an associated curriculum to utilize for CIE implementation?
1. ACRE training is comprised of employment services competencies. The SWTCIE IL team will provide resources and guidance on selecting an appropriate curriculum.
Q: Can budget money be used for vehicle leases?
1. Allowable costs are those that are necessary, reasonable, and allocable based on the activity(ies) contained in the Scope of Work, are justified in the Budget Narrative, and are allowable under Subpart E of 2 CFR 200. The grantee would have to outline a method of allocation whereby only allocable costs of the vehicle lease directly related to the SWTCIE grant were charged to the grant.
Do we only submit a budget for FY24 or do we submit a combined budget for all four fiscal years with the application? If it is a combined budget, do we submit four budgets, one for each year?
1. The applicant's proposed budget for FY24 (Period 1) must be entered into the CSA system. The completed budget must be electronically signed and submitted in the CSA system, and a printed copy of the signed and submitted budget must be included with the application. The budget for the remaining periods 2-4, may be on a non-CSA entered budget on the template (Appendix G).