CSBG ARRA Questions and Answers, Part I
Does the provision of the Recovery Act which allows States to revise the income limit, not to exceed 200 percent of the official poverty line, also apply to the regular 2009-2010 CSBG appropriations in addition to Recovery Act Funds?
Yes, the Recovery Act authorizes States to revise the income limit for eligibility ceiling from 125 to 200 percent of the Federal poverty level for CSBG services furnished during fiscal years 2009 and 2010, including services furnished with the State’s regular CSBG appropriations during those years.
Does the State have to increase their eligibility level to 200 percent? The Recovery Act states: "That for services furnished under such Act during fiscal years 2009 and 2010, States may apply the last sentence of section 673(2) of such Act by substituting ‘200 percent’ for ‘125 percent.’”
States are not required to increase the eligibility level to 200 percent of the poverty line. The Recovery Act authorizes States to revise the income limit for eligibility ceiling from 125 to 200 percent of the Federal poverty level for CSBG services furnished during fiscal years 2009 and 2010, including services furnished with the State’s regular CSBG appropriations during those years.
Reporting and Monitoring
Are the reporting requirements for Recovery Act Funds the same as reporting requirements for regular CSBG block grant funding?
Current reporting requirements apply, but there will be additional reporting requirements associated with Recovery Act Funds. As part of the efforts to ensure transparency and accountability, the Recovery Act requires Federal agencies and grantees to track and report separately on expenditures from funds made available by the Recovery Act (see subtitle A, section 1512 on accountability and transparency). OCS will be providing additional guidance regarding reporting requirements for Recovery Act funds.
Are there any special requirements regarding how States and eligible entities track Recovery Act Funds and activities?
Yes, States and eligible entities are required to track Recovery Funds and activities so that they are clearly distinguishable from non-Recovery Act funds. Funds must be accounted for separately from regularly appropriated funds, and will have a separate CFDA number, a separate CAN number, and separate draw-downs in the Payment Management System. Two separate audits will be required, one for Recovery Act Funds and one for non-Recovery Funds.
What type of spending and performance data are States and eligible entities required to track and report as it relates to Recovery Act Funds?
The Office of Management and Budget (OMB) published memorandum Initial Implementing Guidance for the American Recovery and Reinvestment Act of 2009 includes information on page 15 regarding specific reporting requirements that will be incorporated into CSBG guidance materials specific to the Recovery Act Funds. The memorandum is available online at http://www.recovery.gov/files/Initial%20Recovery%20Act%20Implementing....
It is expected that OCS will issue additional guidance on reporting requirements and formats to adapt these reporting requirements to the CSBG program.
Are States and eligible entities required to continue meeting reporting requirements related to regular CSBG?
Yes, the reporting requirements under the Recovery Act do not modify Section 678E of the CSBG Act or the accountability and reporting requirements of the CSBG Act. States and eligible entities must continue to fulfill all reporting requirements in the CSBG legislation in addition to those of the Recovery Act.
Are there any other special circumstances States should be aware of regarding reporting requirements?
The ACF Grants Management Office will issue an adjusted award document to States which will include requirements for the submission of both a SF269 report and annual report for Recovery Act Funds.
Are States required to monitor eligible entities’ administrative, financial and program operations as it relates to the Recovery Act Funds?
Yes, States are required to monitor eligible entities’ administrative, financial and program operations as prescribed in the CSBG Act.