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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

Plans and Reporting

Q6.      How much detail will be required when submitting the State plan and application?
A.        A model plan for ARRA funds has been provided on the CSBG website.  The link is as follows:

http:www.acf.hhs.gov/programs/ocs/csbg/outlinemodel.htm.

States should provide sufficient detail to provide publicly-available documentation of the implementation plan in a manner that is responsive to the elements of the model plan.

 

Q7.      Who is the CSBG ARRA plan submitted to at HHS?
A.        CSBG ARRA plans should be mailed to your current OCS program specialist at the following address:

Attention: Community Services Block Grant Program
Division of State Assistance
Office of Community Services
Administration for Children and Families
U.S. Department of Health and Human Services
370 L'Enfant Promenade S.W., 5th Floor West
Washington, D.C. 20447

Q8.      Does the State/Territory/Tribal organization have to provide a new letter that designates the lead agency for CSBG ARRA funds?
A.        Unless the Governor's/CEO’s office has designated a different office to manage ARRA than the lead office which manages the regular CSBG, that designee should be able to sign off on the transmittal of the Plan for Recovery Act.  If there is a new office delegated with the management of the program the Governor/CEO would need to transmit this delegation; however, a State/Territory/Tribal organization should not wait to send in the plan.  The letter of delegation will be added to the plan if it arrives after submission of the plan.

 

Appropriation

Q9.      Do all entities have to use the same poverty guidelines throughout the State?
A.        The Recovery Act allows States to revise the eligibility criteria to not to exceed 200 percent of the poverty line for CSBG services furnished during fiscal years 2009 and 2010.  There is no separate authority for eligible entities to set different guidelines.  However, eligible entities may prioritize specific services and populations based on local needs assessments.

Q10.    Does the State have the option of changing the poverty level for regular CSBG funds as well as the Recovery Act Funds?
A.        Yes. States may increase individual eligibility for services furnished by the CSBG program during fiscal years 2009 and 2010 to up to 200 percent of the official poverty guidelines.  This eligibility adjustment reflects an increase from 125 percent of the poverty guidelines as currently provided in Section 673(2) of the CSBG Act and applies to all CSBG services furnished during fiscal years 2009 and 2010.

Public Inspection

Q11.    Please provide guidance regarding the process for public inspection of the State plan for Recovery Act Funds.
A.        The CSBG ARRA plan should provide evidence that the lead agency of the State’s CSBG program made available the CSBG ARRA plan for public inspection.  The public inspection period should be in sufficient time to provide for public response and comment (it is suggested at least 1 week but not more than 2 weeks).  States should include the date(s) the CSBG ARRA plan was available for inspection to the public and documentation of public notice for the public inspection (e.g. copies of public notices, letters, newspaper articles, link to website posting, e-mail, etc.)

Q12.    Do we need a separate public notice for CSBG ARRA funds or does the FY’09 public notice suffice?
A.        Yes, a separate public notice for CSBG ARRA funds is required.  The CSBG Act requires that each plan “be made available for public inspection within the State in such a manner as will facilitate review of, and comment, on the plan.” per Section 676(e).

Q13.    What is the acceptable public inspection period for comments on the CSBG ARRA plan since the required 30 days is unattainable given the May 29, 2009 submission deadline? Does public inspection also have to include a public hearing?
A.        The public inspection period should be in sufficient time to provide for public response and comment (i.e. minimum of one week).  States are not required to conduct a public hearing for the CSBG ARRA plan.

Other

Q14.    How will OCS utilize the $15 million of T/TA funds appropriated under ARRA?
A.        Approximately half of the T/TA funds are made available through a new program announcement that will support strategic planning efforts focused on the following areas: 1) ensuring Statewide coordination of CSBG Recovery Act projects;  2) informing communities of available projects and services supported with Recovery Act funds in response to local needs; 3) documentation of community results; and 4) preparing communities to sustain the impact of Recovery Act funds after additional Federal support received through the Recovery Act ends.   The announcement can be found on the ACF website.
The title of the announcement is “Community Services Block Grant Training and Technical Assistance Program: Capacity-Building for Ongoing CSBG Programs and Strategic Planning and Coordination Supported by the American Recovery and Reinvestment Act of 2009” (HHS-2009-ACF-OCS-EQ-0037)
The remaining CSBG Recovery Act funds will be utilized in manner consistent with sections 676A and 678B of the CSBG Act, and will support 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.  OCS has determined that key technical assistance challenges under the Recovery Act will include fiscal management for increased funding, adaptation of data collection systems to ensure responsiveness to reporting requirements under the Recovery Act, and State-wide strategic planning focused on ensuring State-wide coordination of Community Action Program Recovery Act projects.

Q15.    What are examples of employment related services that create and sustain economic growth?
A.        Employment-related services that create and sustain economic growth should assist individuals in securing employment or acquiring or learning skills that promote opportunities for employment.  Component services or activities may include employment screening, assessment, or testing; structured job skills and job seeking skills; specialized therapy (occupational, speech, physical); special training and tutoring, including literacy training and pre-vocational training; provision of books, supplies and instructional material; employment counseling, transportation; and referral to community resources.
States and eligible entities should consider a variety of employment-related outcomes to help assess whether the services can potentially create and sustain economic growth (e.g. part-time vs. full-time jobs, average hourly starting wage, number of low-income recipients trained, number of Temporary Aid to Needy Families (TANF) recipients trained, number of full-time jobs that offer health care benefits, retirement benefits, paid sick leave, etc.)

Q16.    What is the role of State Community Action Associations in CSBG ARRA and how should State Associations and State CSBG Offices work together in this effort?
A.        State CSBG agencies are responsible for administering the CSBG program, developing the State plan, conducting reviews of Community Action Agencies (CAAs), and ensuring CSBG funds are directed towards the statutory purposes of the CSBG program.  State Associations are responsible for providing training and technical assistance and increasing the capacity of local CAAs to carry out the mandate of the CSBG Act; improve or enhance their overall or specific capability to plan, deliver, manage and measure results. As a part of the CSBG Network, both the State CSBG agencies and State Associations should work together to help ensure the mobilization of additional resources to combat the central causes of poverty.   State Associations may also apply for discretionary grant funding under the program announcement entitled “Community Services Block Grant Training and Technical Assistance Program: Capacity-Building for Ongoing CSBG Programs and Strategic Planning and Coordination Supported by the American Recovery and Reinvestment Act of 2009” (HHS-2009-ACF-OCS-EQ-0037).
The announcement can be found on the ACF website. 

Q18.    What are some allowable uses of CSBG Recovery Act Funds?

  • Under the regular CSBG program, grantees use funds to provide services and activities addressing employment, education, better use of available income, housing, nutrition, emergency services and/or health to combat the central causes of poverty.  Such services continue to be supportable under the CSBG Recovery Act fund.  In recognition of the intent of Recovery Act funds, States/Territories/Tribal organizations should encourage local CSBG service providers to support employment-related services and activities that create and sustain economic growth in keeping with the expressed purpose of ARRA. 

States and eligible entities are strongly encouraged to develop strategic uses of ARRA funds to support projects and activities that can be accomplished in a timely manner and that will have a substantial and sustained impact on community employment and economic development.  States and eligible entities must also plan for services that target individuals and families within the percentage of the poverty line established by the State as eligibility criteria for the CSBG program.

The table below provides some examples of the types of activities that have been supported at the community level in prior CSBG programs.  The examples provided below are intended as a general guideline rather than prior approval of particular expenditures.  In practice, the allowability of specific costs may very depending on the facts in any particular instance.  For example, since expenditures are subject to criteria in OMB cost principles, such as whether costs are reasonable, allocable to the grant objectives and adequately documented, even costs in these categories may be unallowable under circumstances that do not meet these criteria.  OMB Cost Principles may be obtained on the following website link:

http://www.whitehouse.gov/omb/circulars/a122/a122.html