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CSBG Q & As ARRA Part II

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

 

CSBG ARRA Questions, V.2 5/21/2009

Benefits Enrollment

Q1.      What does the Office of Community Services expect States to include as benefit enrollment coordination activities?  Does it include monitoring?
A.        How States administer benefit enrollment coordination activities may vary, but the Recovery Act states that funds are reserved to support identification and enrollment of eligible individuals and families in Federal, State, and local benefit programs.    For example, benefits enrollment coordination activities may help to: 1) educate the public on the eligibility requirements for the various benefits programs; 2) simplify the process of identifying and enrolling individuals and families eligible for benefit programs; 3) direct individuals and families to the most appropriate program; 4) account for individuals and families whose initial contact is through eligible entities or other non-State agencies; and 5) avoid losing individuals and families before, during and after the referral process. 

Additional references for guidance regarding Federal Benefit programs and eligibility include Information Memorandum (IM) #30 - Guidance on the Interpretation of “Federal Public Benefit” Under the Personal Responsibility and Work Opportunity Reconciliation Act of 1996 (PRWORA), P.L. 104-193 and Summary of Immigrant Eligibility Restrictions Under Current Law As of 2/25/2009, http://aspe.hhs.gov/hsp/immigration/restrictions-sum.shtml.

Routine monitoring of eligible entities would not be an allowable use of benefits enrollment coordination funds, since routine monitoring would not clearly support identification and enrollment of eligible individuals and families in Federal, State, and local benefit programs.    

Q2.      Can more that 1% of the funds be used for benefits enrollment, via CAA funds?
A.        Eligible entities may conduct some types of benefits enrollment coordination activities (e.g. linkages to community services), but the State may not reserve more than 1% of CSBG ARRA funds at the State level for benefits enrollment coordination activities.  The Recovery Act requires that States distribute 99 percent of the Recovery Act allocations to “eligible entities” as defined by Section 673(1) of the CSBG Act.  States are also reminded that pursuant to Section 676(b)(8) of the CSBG Act, “any eligible entity in the State that received [FY 2008 CSBG] funding in the previous fiscal year through a [CSBG] grant … will not have its funding terminated …or reduced below the proportional share of funding the entity received in the previous fiscal year unless, after providing notice and an opportunity for a hearing on the record, the State determines that cause exists for such termination or such reduction, subject to review by [HHS]….”
Q3.      Is it possible to use some of the benefit enrollment coordination funds for coordination of a homelessness prevention data network?
A.        No, this activity would not be allowable without a clear and specific justification of how a data network would support the identification and enrollment of eligible individuals and families in Federal, State, and local benefit programs.   For example, how would a data network: 1) educate the public on the eligibility requirements for the various benefits programs; 2) simplify the process of identifying and enrolling individuals and families eligible for benefit programs; 3) direct individuals and families to the most appropriate program; 4) account for individuals and families whose initial contact is through eligible entities or other non-State agencies; and 5) avoid losing individuals and families before, during and after the referral process. 

Q4.      Can the State use the 1% of ARRA funds to either purchase software specifically designed for benefits coordination and/or training to all CAAs for the benefits coordinator?
A.        Yes, software designed for benefits coordination and/or training to all CAAs for benefits coordination is an allowable use of funds.

 

Administrative Costs

Q5.      The American Recovery and Reinvestment Act of 2009 (ARRA) does not allow States to retain a portion of the Community Services Block Grant (CSBG) funds appropriated under ARRA for State administrative purposes as specified in Section 675C(b)(2) of the CSBG Act.  Are States allowed to use administrative funds from regularly-appropriated (non-ARRA) CSBG funds for administration and monitoring of ARRA CSBG funds?
A.        Within existing funding limits, States may use regularly-appropriated administrative funds from the CSBG grant for general administration and monitoring of all CSBG activities in the State.  While States are not permitted to utilize CSBG ARRA funds for State administrative purposes, it is appropriate to incorporate oversight and monitoring of CSBG ARRA funds and activities into the State’s existing CSBG monitoring and oversight.  For example, staff members who are supported by regularly-appropriated funds as authorized in Section 675B may monitor both regularly-appropriated and ARRA activities.   The State’s administrative funds must not exceed the Administrative Cap outlined in Section 675C(b)(2), which means that States may not spend more than the greater of $55,000, or 5%, of their regularly-appropriated (non-ARRA) funds for administrative and monitoring activities.   In addition, States may not comingle funds appropriated under regular appropriations with ARRA funds.