CSBG ARRA Technical Assistance: Risk Assessment and Mitigation for CSBG - Tribes
September 24, 2009
Community Services Block Grant (CSBG)
Risk Assessment and Risk Mitigation for CSBG ARRA Funds
Script for Recorded Call for Tribes
Note: The text below is the prepared script for the technical assistance conducted on Thursday, September 24, 2009. Minor wording changes may have occurred during recording.
- Good afternoon.
- I’m Seth Hassett, Director of the Division of State Assistance in the Office of Community Services.
- I’m Frances Harley, Team Lead for Financial Operations.
- Thank you for joining us for this follow-up technical assistance conference call focused on risk assessment and risk mitigation for the Community Services Block Grant.
- The purpose of this call is to review questions from the technical assistance call to Tribal governments and organizations that took place on Thursday, September 10.
- Please note that if you have not already listened to the September 10 call, viewed the accompanying slide presentation, and reviewed Information Memoranda 113, it is recommended that you do so prior to listening to this call.
- In response to the September 10 technical assistance call, OCS received three questions from the field. In addition, we have two general questions based on input from a recent presentation at a national conference.
- Although all but one question came from State CSBG offices, we have included the questions and answers in this conference call for Tribal grantees because the responses apply to Tribes as well as States.
- We will read each question, followed by a response.
- We’ll begin with Question Number One, which was received from a Tribal representative.
- The question reads as follows . . . “I got on to the Teleconference on 9/10 I want to know if there are forms available for our tribe to sign or do we develop our own from the slide presentation? I am administering the CSBG ARRA Project and the contact.”
- The answer to this question is that a template for a Tribal assurance is provided in IM-113, which is available on the OCS website.
- Our Second question came from State representative and has been adapted for Tribes.
- The question is as follows . . . “There are questions on the sample risk assessment template I found confusing. Can adjustments be made to the template?”
- The answer to this question is, yes.
- Adjustments can be made to the template.
- The template is provided as a simple example of a tool for certifying that a risk assessment has been conducted.
- IM 113 allows for flexibility on the format for a risk assessment certification. This is particularly important because tribal governments may already have risk assessment procedures in place that can be utilized, as long as they address the items included in IM-113.
Other certification formats may be used, as long as the Tribe provides the following certification statement signed by the Tribal chief executive and Tribal chairperson:
- “I certify that a risk assessment has been conducted to assure appropriate expenditures of Community Services Block Grant funds received through the American Recovery and Reinvestment Act of 2009. This risk assessment addressed previous audit or monitoring findings within the last three years, a review of existing internal controls, a review of statutory and regulatory compliance, and a review of equipment and property procedures to assure a direct relationship to CSBG services. Where potential risks have been identified, appropriate risk mitigation measures and compensating controls have been identified.”
- We now move to our third question, which is also adapted from a question received at a State conference.
- What is signified by the signature of the Tribal leadership? If the Tribal Chairperson or Chief indicates that a risk assessment has been conducted, and funds are later spent inappropriately by an individual or organization receiving funds from the Tribe, who is responsible?
- The answer to this question is that responsibility for any inappropriate expenditures will differ based on circumstances.
- However, the most important thing to emphasize about IM 113 and the risk assessment and mitigation process, is that the goal is to prevent inappropriate expenditures and assure compliance with the CSBG Act and Recovery Act requirements.
- IM-113 emphasizes shared accountability for this process, beginning with the leadership of Tribes and Tribal organizations, with additional risk analysis taking place at the Federal level.
- The Office of Community Services will also be conducting its own analysis of risks, utilizing information available at the Federal level, including information from other Federal programs.
- The expectation is that through multiple levels of review, it will be possible to address concerns early in order to assure appropriate expenditures and minimize negative findings in later reviews.
- Tribes are encouraged to use this opportunity to identify any potential risks and to use this comment process to also provide information on technical assistance needs as appropriate.
- This will help the Office of Community Services to tailor technical assistance to meet specific Tribal organization challenges to the extent possible with available resources.
- Please note that any follow-up related to specific Tribes and organizations will be done in consultation and partnership with the CSBG Lead Agencies for each Tribe.
- We now move to our fourth question, which was submitted directly by a State office.
- On the Sample Risk Assessment Template - Question #3 the template asks “Does the entity have in place clearly stated and current administrative, fiscal and programmatic policies and operating procedures in accordance with the CSBG Statute?” Where is that specifically located in the CSBG Act?
- The overall intent of question #3 on the risk assessment template is to assure that organizational policies and procedures are reviewed to assure that they are compliant with all statutory requirements outlined in the CSBG Act, not a specific section.
- It is recommended that Tribal leadership assign staff to routinely review the requirements of the CSBG Act and any specific changes as a result of the Recovery Act —such as the increase in income eligibility.
- The CSBG Act should be reviewed as a whole. However, some examples of CSBG Act requirements that should be considered in the risk assessment process are the following:
- Income Eligibility – Section 673 (2) of the CSBG Act defines the poverty line and limits funds to 125% of the poverty line. The American Recovery and Reinvestment Act allows States to increase income eligiblity to 200% of the Federal poverty line.
- The question to ask is . . . Have these provisions been reviewed in program operational procedures? If the Tribe has increased the income eligiblity to 200% of the poverty line, how has this been officially communicated?
- Limitations on Use of Funds – Section 678 F of the CSBG act for the purchase or improvement of land, or the purchase, construction, or permanent improvement (other than low-cost residential weatherization or other energy-related home repairs) of any building or other facility. The act provides a waiver authority for extraordinary circumstances.
- The question to ask is . . . Have all activities been reviewed to assure adherence to this requirement?
Our fifth question is “is it possible to get the written script to accompany the power point presentation? Having the script would be helpful. “
A written script from the first presentation will be posted on the CSBG website along with the script from this call. We will work to assure that the script is posted within one week of this call.
This concludes our call.
Thank you for your participation and thank you for your ongoing work on behalf of children, families, and communities