< Back to Search

CSBG IM No. 122 Final Liquidation and Closeout Expectations of FY 2009 CSBG American Recovery and Reinvestment Act (ARRA) Funds

Published: May 1, 2012
Audience:
Community Services Block Grants (CSBG)
Category:
Guidance, Policies, Procedures, Information Memorandums (IM)
Tags:
authority, guidelines

 

 

COMMUNITY SERVICES BLOCK GRANT PROGRAM

Information Memorandum

U.S. Department of Health and Human Services
Administration for Children and Families
Office of Community Services
Division of State Assistance
370 L'Enfant Promenade, S.W.
Washington, D.C. 20447

 

Transmittal No. 122

Date: December 3, 2010

 

TO:

State Community Services Block Grant Program (CSBG) Administrators, U.S. Territories and Tribal Organizations

SUBJECT:

Final Liquidation and Closeout Expectations of Fiscal Year (FY) 2009 CSBG American Recovery and Reinvestment Act (ARRA) Funds

PURPOSE:

To provide final guidance and clarification for close out, liquidation and reporting requirements of the FY 2009 CSBG Recovery Act funds. This information is based on current guidance from the Executive Office of the President and the Office of Management and Budget (OMB).

RELATED REFERENCES:

Community Services Block Grant Act, 42 U.S.C. § 9901 et seq.; American Recovery and Reinvestment Act of 2009, Pub. L. 111-5; OMB Circular A-122; OMB Circular A-133; OMB M-09-10, Initial Implementing Guidance for the American Recovery and Reinvestment Act of 2009.

BACKGROUND:

On April 10, 2009, the Department of Health and Human Services (HHS) announced the release of $985 million in Community Services Block Grant funds appropriated as a result of the American Recovery and Reinvestment Act of 2009 (ARRA). Funds were released to States, U.S. Territories, and eligible Indian Tribes and Tribal organizations based on a statutorily-defined formula outlined in the Community Services Block Grant (CSBG) Act. Concurrent with the release of funds, the Office of Community Services (OCS) issued Information Memoranda (IM)109, Application for Fiscal Year (FY) 2009 CSBG Appropriation of American Recovery and Reinvestment Act (Recovery Act) Funds with initial guidance for implementation. Funds were released contingent on specific terms and conditions of award with the requirement that CSBG ARRA plans be provided for Federal review. On August 2, 2010, OCS communicated with States and U.S. Territories, via letter, and provided a reminder of required time frames for expenditure of CSBG funds received through supplemental appropriation under the ARRA.

Timelines for Expending, Obligating, Liquidating funds and Close-Out Reports*
In CSBG IM # 109, issued April 9, 2009, and available online at the OCS website, the OCS outlined requirements for expenditure of CSBG ARRA funds. Based on that guidance, if a grantee uses an accrual accounting system, services must have been 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, services must have been paid on or before September 30, 2010. The final report is due on or before December 29, 2010. The timelines for expenditures and close-out reports are based on a combination of statutory and regulatory requirements related to the obligation and liquidation of CSBG funds.

The obligation timeframes for CSBG are outlined in Section 675C(a)(2) of the CSBG Act, 42 U.S.C. § 9907(a)(2). The CSBG Act specifies that “Funds distributed to eligible entities through grants . . . for a fiscal year shall be available for obligation during that fiscal year and the succeeding fiscal year. . ..” The requirement is that CSBG ARRA funds, which were awarded in FY 2009, must have been obligated by September 30, 2010, which is the end of the succeeding fiscal year. The Administration for Children and Families (ACF) does not have authority to approve an extension.

*Note: States and eligible entities must fulfill all reporting requirements in the CSBG Terms and Conditions in addition to the 1512 reporting required by the Recovery Act. The timelines addressed here are not the same timelines for 1512 reporting as required in FederalReporting.gov.

Requirements for Liquidation of Funds and Close-Out Reports*
Section 678D(a)(1)(B) of the CSBG Act, 42 U.S.C. § 9916(a)(1)(B), requires grantees to apply the cost and accounting standards of the Office of Management and Budget (OMB) which HHS has codified in part at 45 CFR Part 92. 45 CFR § 92.50(b) requires grantees to liquidate obligations within 90 days after the end of the fiscal year. Recipients shall submit, within 90 calendar days, after the date of completion of the award, all financial, performance, and other reports as required by the terms and conditions of the award. Liquidation of funds refers to actual payments for services delivered or products received. ACF has authority to approve an extension to this time when requested by the recipient. For CSBG ARRA funds, ACF will consider requests for extensions of up to 90 days only when justified based on extraordinary circumstances, such as operational interruptions directly related to a major disaster. Unless ACF authorizes an extension, however, grantees shall liquidate all obligations incurred under the award no later than 90 calendar days after the funding period, or the date of completion, as specified in the terms and conditions of the award or in agency implementing instructions.

*Note: States and eligible entities must fulfill all reporting requirements in the CSBG Terms and Conditions in addition to the 1512 reporting required by the Recovery Act. The timelines addressed here are not the same timelines for 1512 reporting as required in FederalReporting.gov

Supplemental ARRA Reporting Requirements
There are supplemental reporting requirements for all Recovery Act funds. This is in addition to the CSBG Act reporting requirements and those set forth in the Terms and Conditions of the supplemental ARRA funding.

As part of the efforts to ensure transparency and accountability, ARRA required recipients to track and report separately on expenditures from funds made available by the stimulus bill. On September 24, 2010, OMB provided updated Guidance on the Recovery Act, specifically, Part IV: Improving Transparency on Narrative Descriptions in Recipient Reporting (OMB Guidance: M-10-34). Submissions on Award and Project descriptions input to the 1512 FederalReporting.gov system must provide a clear enough understanding for the general public. Information on the award purpose, scope and nature of activities, outcomes and status of activities must be provided in a clear and complete narrative. Specific examples of goals that the State initially set out to accomplish in the Award description must be provided along with details on the wide range of activities mentioned in the Project description.

If you need additional information, contact your assigned OCS CSBG Program Services - Regional Contacts (Attachment). This contact information is available on the CSBG program website.

__/s/________________
Yolanda J. Butler, Ph.D.
Acting Director
Office of Community Services