Slide Presentation: Corrective Action, Termination or Reduction of Funding for CSBG Eligible Entities Slides

1. Community Services Block Grant (CSBG)

Corrective Action, Termination or Reduction of Funding for CSBG Eligible Entities

2. CSBG Information Memorandum 116 Corrective Action, Termination, or Reduction of Funding of CSBG-Eligible Entities

• Issued December 4, 2009

• Step-by-step description of necessary procedures for corrective actions, quality improvement plans, termination or reductions in funding for cause

• Emphasis on corrective actions and quality improvement

• No new deadlines or program requirements

3. CSBG Distribution Essentials

• States, U.S. Territories, and Tribes receive CSBG allocation based on statutory formula

• States may retain up to 10% of allocation for discretionary projects (5% administrative cap)

• Eligible entities must receive 90% of funding

• Recovery Act appropriation specified that 99% of CSBG supplemental appropriation must go to eligible entities

4. What Are Eligible Entities?

• Nonprofit or public organizations

• Tripartite board representing low-income community, public officials, and community representatives

• State established lists of eligible entities are typically consistent from year-to-year

• Changes to the distribution of funds to eligible entities must follow procedures outlined in the CSBG Act

5. Proportional Share

• The “proportional share” of CSBG funds is the amount of non-discretionary grant funds allocated to an eligible entity compared to the amount allocated to other eligible entities

• If an entity received 1/10th of the funds distributed to all eligible entities in a prior year, that entity would receive 1/10th of funds in the following year.

• Changes to proportional share may take place only in compliance with the CSBG Act

6. Cause for Changes to Proportional Share

• Statewide Redistribution of Funds – Changes due to census data, other appropriate data (e.g. poverty data), designation of new eligible entity, or severe economic dislocation – CSBG Act, Section 676(c)(1)(A)

• Failure to Comply with State Plan, Standard, or Requirement – CSBG Act Section 676(c)(1)(B) and Section 676(c)(2)

7. 10 Key Steps in Termination or Reduction for Performance-Related Cause

1. State review and monitoring

2. Determination of performance deficiency

3. Notification of performance deficiency

4. Communication of corrective action requirements

5. Technical assistance determination

6. Training & technical assistance offer (if appropriate)

7.Report on training and technical assistance offered

8. Quality improvement plan (discretionary)

9. Opportunity for hearing

10. Initiation of  proceedings to terminate or reduce funding

8. Step 1: State Review and Monitoring

• Full On-Site Review At least once every three years for all eligible entities

• New Entities On-site review immediately after completion of 1st year

• Follow-Up Reviews Prompt return visits to eligible entities that fail to meet goals, standards, and requirements established by the State

• Other Reviews as Appropriate Includes reviews of entities that have had other Federal, State, or local grants terminated for cause

Key References: §678C(a),  42 U.S.C. §9915(a)

9. Note: Responsibility to Investigate Issues

• Review when funds are terminated for cause in related programs (e.g. Head Start, Low Income Home Energy Assistance Program (LIHEAP), and the Weatherization Assistance Program) to assure similar issues or concerns do not exist with CSBG funds

• Investigate any “whistleblower” allegations of fraud or abuse of CSBG funds and notify Federal authorities

• HHS Hotline: 1-800-447-8477

10. Step 2: Determination of Performance Deficiency

• State determines based on review that an eligible entity

Fails to comply with terms of an agreement

Fails to comply with State plan,

Fails to provide CBSG services, or

Fails to meet appropriate standards, goals, and other requirements, including performance objectives

References: §678C(a), 42 U.S.C. §9915(a)

11. Step 3: Notification of Performance Deficiency

• Notification should be specific and documented

• Maintain record of dates and method of notification

12. Step 4: Communication of Corrective Action Requirements

• Specific actions required to correct performance deficiency must be communicated

• Maintain record of date and method of communications

• Maintain record of any deadlines and documentation requirements