The creation of the Independent Living Administration and the transition of Centers for Independent Living to the U.S. Department of Health and Human Services under the Workforce Investment and Opportunity Act

Below are comments submitted regarding the creation of the Independent Living Administration and the transition of Centers for Independent Living to the U.S. Department of Health and Human Services under the Workforce Investment and Opportunity Act

Submitted via e-mail on September 12, 2014 by Amber Smock, Director of Advocacy

To whom it may concern:

Access Living is the Center for Independent Living (CIL) serving metropolitan Chicago. Since 1980, we have been proud to be at the forefront of change for people with disabilities not only in Chicago but nationwide. We have proudly maintained excellence in the traditional four core service areas of peer support, information and referral, independent living skills and advocacy. We are excited about the creation of the fifth core service of transition for people in nursing homes and youth. Our staff of 75 served 1,217 people with direct service in our latest annual count, and fought for systems change to provide better lives for the nearly two million Illinoisans living with disabilities.

The creation of the Independent Living Administration (ILA) and the housing of CIL oversight within this administration is of paramount importance to us. We would like to offer the following points of comment:

* It is vital that the person appointed to lead the ILA have experience within a Center for Independent Living and an understanding of CIL administration, service and advocacy needs and challenges. We would prefer, since CILS are required to be run by a majority of people with disabilities, that the new head of the ILA be a person who has a disability. There is no shortage of experienced CIL staff who would serve as viable candidates, and who also have bureaucratic/political acumen. Failing to appoint someone with these credentials will be an extremely negative signal to the hundreds of CILs across the country, invalidating our collective effort to put people with disabilities in the driver's seat in all areas of our work.

* Care must be taken to remain vigilant that the independent living model of service is not overridden or subsumed by the aging model of service. There is a profound workplace cultural difference between those that serve primarily aging groups and those that focus on independent living. The founding philosophy of independent living---cross disability, peer-based services, consumer control , advocacy and services under one roof, and social change--- must be preserved and enriched.

* We are concerned that ILA's home within the U.S. Department of Health and Human Services signals an attitude of medicalization of the social needs of people with disabilities. As a CIL we have long held that it is society that creates barriers for people with disabilities, and that disability itself is not something that needs to be cured to end those barriers. ILA must do everything it can to prevent the medicalization of our work.

* We urge the ILA to continue CILs' focus on cross-disability work, making sure to serve anyone with any kind of a disability as well as possible. Cross-disability work allows us to build a better society across all disability types, and take advantage of opportunities that may not be present when we work through one type of disability alone. Plus, lots of people have multiple disabilities, and a cross-disability environment is the most welcome for these people.

* Advocacy led by CILs continues to be one of the most powerful vehicles for disability rights, because it unites grassroots problems we see in our services with grasstops leadership for systems change. ILA needs to make sure that CILs' ability to advocates for our community remains strong and supported into the future.

In addition, we support the points made by our national membership umbrella organization, the National Council on Independent Living:

* We expect RSA to provide a seamless, transparent and non-disruptive system when transferring the Independent Living program, Assistive Technology (AT) program and NIDDR to HHS/ACL

* Ensure all contracts and grants remain in place and are paid in a timely manner.

* Ensure ALL parts of the AT Act; PAATs, AFPs and the AT Act programs are transferred together. This also includes the Telework Programs which were developed with the AFP programs.

* Permanently suspend all site reviews of CILs and SILCs until transfer is complete.

We appreciate this opportunity to provide public comment. Follow up questions may be directed to Amber Smock, Director of Advocacy, Access Living, at

Amber Smock
Director of Advocacy