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CSBG Q & As ARRA Part I

Published: May 29, 2009
Audience:
Community Services Block Grants (CSBG)
Category:
Guidance, Policies, Procedures, Q & As

 

The American Recovery and Reinvestment Act (Recovery Act)
Community Services Block Grant (CSBG) Program
Frequently Asked Questions

Application procedures

1.  Question:
Are States required to modify their State plan? 

Answer:
States are not required to modify existing plans for ongoing CSBG programs funded through regular appropriations.  However, States that receive Recovery Act Funds are required to submit a separate plan to the Office of Community Services (OCS) for FY 2009 Plan for Recovery Act (ARRA) Funds by May 29, 2009.  This requirement is in accordance with Section 676(e) of the CSBG Act which requires submission of revised plans to the Secretary. 

2.  Question:
Are States required to conduct a public hearing for purposes of the use of Recovery Act Funds?

Answer:
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.

3.  Question:
Are there any restrictions or limitations as to how States modify current 2009 agreements with eligible entities for receipt of Recovery Act Funds? 

Answer:
Currently States include language in their contract agreements with Community Action Agencies that specifies reporting requirements, and outlines requirements related to the State monitoring process.   Similar to the current CSBG Act, there is nothing in the ARRA that would prohibit States from continuing this practice.

4.  Question:
How prescriptive can States be in defining services and strategies to be carried out by the eligible entities with Recovery Act Funds? 

Answer:
Additional CSBG funding appropriated under the Recovery Act is required to be used “for carrying out activities under sections 674 through 679 of the Community Services Block Grant Act…” including the CSBG activities described in Section 676(b) of the CSBG Act.  In addition, due to the unique nature and purposes of the Recovery Act and to support the President’s unprecedented effort to jumpstart the economy, States should encourage eligible entities to use Recovery Act Funds for employment-related services and activities that create and sustain economic growth in communities in keeping with the requirements of the CSBG Act. 

5.  Question:
Will OCS and/or the Department issue additional guidance regarding Recovery Act Funds?

Answer:
Yes, States should keep in mind that program guidance will continue to be clarified and developed as new information is received and new implementation questions emerge.

6.  Question:
Who is eligible to apply for CSBG Recovery Act Funds?

Answer:
Each of the 50 States, the District of Columbia, and the Commonwealth of Puerto Rico are eligible for funding.  Federal and State-recognized Indian Tribes and Tribal Organizations that currently receive CSBG funding directly from OCS are eligible for these funds.

7.  Question
How does one apply for CSBG Recovery Act Funds?

Answer:
States are required to submit to the Office of Community Services (OCS) a FY 2009 Plan for Recovery Act (ARRA) Funds by May 29, 2009. States will receive CSBG Recovery Act Funds under the same formula used for allocating regular CSBG annual appropriations.   

DISTRIBUTION OF FUNDS

1.  Question:
How will CSBG Recovery Act Funds be distributed and when will States receive allocations?

Answer:
States will receive CSBG Recovery Act Funds as a separate allocation under the same formula used for funds allocated under regular annual appropriations.  The Recovery Act Funds will be provided to States in one lump sum allotment. The 50 States, the District of Columbia, the Commonwealth of Puerto Rico, and Federal and State-recognized Indian Tribes and Tribal Organizations that submitted plans for FY 2009 will receive $985 million in Recovery Funds.  The Recovery Act mandates that States pass through no less than 99 percent of their Recovery Act allocations for grants to “eligible entities” under the CSBG Act, commonly referred to as Community Action Agencies (CAAs). States that receive Recovery Act Funds are required to submit a separate plan to the Office of Community Services (OCS) for FY 2009 Plan for Recovery Act (ARRA) Funds by May 20, 2009.  The remaining $15 million of CSBG Recovery Act Funds are reserved for Federal Training, technical assistance, planning, evaluation, investigations, assistance to States in carrying out corrective action, monitoring, reporting and data collection, and development of performance measurement systems.

2.  Question:
How much of their Recovery Act allocations are States required to distribute to eligible entities?

Answer:
States are required to distribute no less than 99 percent of their Recovery Act allocations for grants to eligible entities.

3. Question:
Do States need to account for Tribal allotments from Recovery Act Funds allocation?

Answer:
Yes, States must take into account Tribal allotments as a best business practice.

4.  Question:
Are there any Recovery Funds allocated specifically for use at the State level?

Answer:
Yes, the Recovery Act requires States to reserve one percent of their Recovery Funds allocation for benefits enrollment coordination activities relating to the identification and enrollment of eligible individuals and families in Federal, State, and local benefit programs. 

5.  Question:
What is the methodology used to determine the allocations for Recovery Act Funds?

Answer:
States will receive Recovery Act Funds under the same formula used for allocating funds under regular CSBG annual appropriations.

6.  Question:
When will the Recovery Act Funds be available for draw down? 

Answer:
States will be able to draw down their Recovery Act Funds within two to three days after awards are made.

7.  Question:
Will there be changes in the criteria for State use of funds?

Answer:
States will need to account for restrictions in use of Recovery Act Funds at the State level.  While ordinarily under Section 675C(b)(1) and (2) of the CSBG Act, States are permitted to use remainder funds for administrative expenses and to conduct statewide discretionary activities, the Recovery Act does not provide for such expenses.  Specifically, the Recovery Act directs that 99 percent of the State’s allocation be provided to eligible entities by the State.  The remaining one (1) percent of Recovery Act Funds must be used by States for coordination activities relating to the identification and enrollment of eligible individuals and families in Federal, State, and local benefit programs.

8.  Question:
Are there any Recovery Act Funds allocated specifically for the CSBG State Associations?

Answer:
No, the Recovery Act does not provide any funds specifically for CSBG State Associations. 

9.  Question:
Will any of the Recovery Act Funds reserved by the Secretary for Training and Technical Assistance be set aside for the State Associations to provide training and technical assistance? 

Answer:
OCS is in the process of developing a plan to assess the training and technical assistance needs of those grantees that receive Recovery Act Funds.   It is expected that State Associations will be eligible to apply for an OCS discretionary grant activity focused on developing technical assistance capacity and promoting Statewide coordination of Recovery Act efforts.  This announcement will be posted under grant announcement HHS-2009-ACF-OCS-EQ-0037, on the Administration for Children and Families website. 

10.  Question:
How much money is appropriated to the Community Services Block Grant in the American Recovery and Reinvestment Act of 2009 (Recovery Act)?

Answer:
The Recovery Act provides for $1 billion in additional funds (“Recovery Act Funds”) to the CSBG program.

11.  Question:
What is the time frame for availability of funds?

Answer:
The authorization allows for the obligation of Recovery Act Funds in FYs 2009 and 2010, the fiscal year funds were made available and the subsequent fiscal year.  States have until September 30, 2010 to obligate the additional funds.  Normal liquidation requirements under the program would apply.

USE OF FUNDS

1.  Question:
Does the Recovery Act provide any funds to help States cover the cost of administrative services and activities?

Answer:
No, the Recovery Act specifically directs that 99 percent of the additional funds provided to States be distributed to eligible entities; the remaining one (1) percent of Recovery Act Funds must be used by the State for benefits enrollment coordination activities relating to the identification and enrollment of eligible individuals and families in Federal, State, and local benefit programs.  

2.  Question:
Can States use a portion of the one percent designated for benefit enrollment and coordination activities to cover administrative costs?

Answer:
No, States are required to use the designated one percent for the purposes of benefit enrollment and coordination activities.  The block grant gives States flexibility to administer benefits enrollment activities in a manner that best meets the needs of individuals, families and communities in their State.  States will be required to submit a plan for benefits enrollment and coordination as part of their FY 2009 Plan for Recovery Act (ARRA) Funds.

3.  Question:
Can eligible entities use a portion of the Recovery Act Funds to cover administrative costs related to Recovery Act services and activities?  

Answer:
The Recovery Act does not prohibit eligible entities from using a portion of Recovery Act Funds for administrative costs associated with delivery of new community services and activities funded by those funds.  Under an efficiency measure approved by the Office of Management and Budget, a goal for the CSBG program is to reduce total amount of sub-grantee CSBG administrative funds expended each year as a percentage of total community funds.   Therefore, eligible entities are strongly encouraged to minimize their expenditure of Recovery Act Funds for administrative expenses.

4.  Question:
What types of services and activities can be supported with CSBG Recovery Act Funds?

Answer:
As with regularly appropriated CBSG funds, Recovery Act Funds may be used for the reduction of poverty, the revitalization of low-income communities, and the empowerment of low-income families and individuals in rural and urban areas to become fully self-sufficient.  However, consistent with the intent of the Recovery Act, States and eligible entities are expected to focus assistance provided with Recovery Act Funds on activities geared towards the preservation and creation of jobs to promote economic recovery and the provision of assistance to those most impacted by the recession.  Short-term and long-term services and activities should be directed towards innovative projects that help targeted populations to achieve economic self-sufficiency for the long-term.

5.  Question:
What activities and services are covered under the “…benefits enrollment and coordination…?” Are there examples of what States should do to address the intent of this requirement?  

Answer:
As a block grant program, the CSBG Act provides States with flexibility in identifying and addressing the specific needs of their States.  To that end, States have flexibility to determine what types of benefits enrollment coordination activities best meet the needs of individuals, families and communities in their States.  States must identify benefits enrollment and coordination activities as part of their FY 2009 Plan for Recovery Act (ARRA) Funds.

6.  Question:
Can States use their one percent of Recovery Act Funds for benefits enrollment coordination activities related to non-CSBG funded benefit programs?

Answer:
The Recovery Act does not limit use if the one (1) percent available to States for benefits enrollment coordination activities only to CSBG funded programs.  Instead the Recovery Act expressly provides that such funds be used for “identification and enrollment of eligible individuals and families in Federal, State and local benefit programs.

7.  Question:
Is there a match requirement for the dollar amount a Community Action Agency may receive?

Answer:
There is no Federal match requirement associated with CSBG funds.

INCOME ELIGIBILITY

1.  Question:
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? 
 
Answer:
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.

2.  Question:
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.’”

Answer:
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


1.  Question:
Are the reporting requirements for Recovery Act Funds the same as reporting requirements for regular CSBG block grant funding?

Answer:
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.  

2.  Question:
Are there any special requirements regarding how States and eligible entities track Recovery Act Funds and activities?

Answer:
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.

3.  Question:
What type of spending and performance data are States and eligible entities required to track and report as it relates to Recovery Act Funds?

Answer:
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.

4.  Question:
Are States and eligible entities required to continue meeting reporting requirements related to regular CSBG?

Answer:
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.

5.  Question:
Are there any other special circumstances States should be aware of regarding reporting requirements?

Answer:
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.

6.  Question:
Are States required to monitor eligible entities’ administrative, financial and program operations as it relates to the Recovery Act Funds?

Answer:
Yes, States are required to monitor eligible entities’ administrative, financial and program operations as prescribed in the CSBG Act.

OBLIGATION AND EXPENDITURES

1.  Question:
How long do States and eligible entities have to obligate and expend Recovery Act Funds?

Answer:
The authorization allows for the obligation of Recovery Act Funds in 2009 and 2010, the fiscal year funds were made available and the subsequent fiscal year.  States have until September 30, 2010, to obligate the additional funds.  Normal liquidation requirements under the CSBG program would apply.

2.  Question:
Does the obligation deadline differ based on the type of accounting system used?

Answer:
No, if using an accrual accounting system, services must be provided on or before September 30, 2010; and liquidated on or before December 29, 2010.  A final report is due on or before December 29, 2010.  If using a cash accounting system, funds for services must be obligated on or before September 30, 2010 and final report is due on or before December 29, 2010.

RELATED Q&As for TRIBES AND TRIBAL ORGANIZATIONS

1.  Question:
Will Tribes and Tribal Organizations that did not submit a FY 2009 CSBG application for regular annual CSBG block grant funding receive Recovery Funds from the Federal government?

Answer:
Only Indian Tribes and Tribal Organizations that submitted a FY 2009 CSBG application for the regular annual CSBG block grant funding will automatically receive Recovery Act funds. 

2.  Question:
Are Indian Tribes and Tribal Organizations subject to the same program requirements as States (e.g. required to submit an amended FY 2009 application and plan, have additional reporting requirements, etc.)?

Answer:
As outlined in 45 CFR 96.42(a), Tribes and Tribal Organizations that receive block grant funds are subject to all statutory requirements that apply to a State to the extent that such requirements are relevant to an Indian Tribe or Tribal Organization.

3.  Question:
Are Indian Tribes and Tribal Organizations required to set aside one percent of their Recovery Funds allotment for purposes of benefits enrollment coordination activities?

Answer:
Indian Tribes and Tribal Organizations that receive Recovery Act Funds and that do not play a role in benefits enrollment are not required to reserve one percent of funds for benefits enrollment activities. 

4.  Question:
Can Indian Tribes and Tribal Organizations access services as a result of States’ benefits enrollment coordination activities?

Answer:
Members of Indian Tribes or Tribal Organizations may access services and benefits as a result of State benefit enrollment efforts and as outlined in 45 CFR 96.42(f) may not be denied access to intangible services (i.e. consulting services) in the State funded by CSBG.