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SSBG Q & As General and Supplemental Information

General Information

Published: January 1, 2009
Audience:
Social Services Block Grants (SSBG)
Category:
Guidance, Policies, Procedures, Q & As

SSBG Questions & Answers

General Information

Question:
Is the purchase of food cards an allowable cost under SSBG regulations?
Answer
Yes, SSBG funds can be used to purchase food cards.  The program serves families with multiple, complex problems who are in crisis and at high risk for family separation and this satisfies one of the five statutory goals of “preventing or remedying neglect, abuse, or exploitation of children and adults unable to protect their own interests, or preserving, rehabilitating, or reuniting families.” The costs of food cards can be categorized as Protective Services for Adults. The Uniform Definitions of Services established in Federal Regulations for the Social Service Block Grant program at 45 CFR Subtitle A, 96.14(a) defines Protective Services for Adults as “those services or activities designed to prevent or remedy abuse, neglect, or exploitation of adults who are unable to protect their own interests. Examples of situations that may require protective services are injury due to maltreatment or family violence; lack of adequate food, clothing, or shelter; lack of essential medical treatment or rehabilitation services; and lack of necessary financial or other resources.” As such, SSBG funds could be used to pay for the food card costs as described.

Question:
Are “illegal aliens” eligible for services funded by SSBG?
Answer:
As you know, the process of eligibility for SSBG services is determined by the State. However, States are to ensure that their eligibility criteria are in compliance with Federal requirements for the SSBG program and that services are provided only to qualified immigrants.

First some background information to put the question of eligibility for SSBG services in context. The Personal Responsibility and Work Opportunity Reconciliation Act of 1996 (PRWORA), Public Law 104-193, was signed into law by the President on August 22, 1996. PRWORA, popularly known as the welfare reform law, established the Temporary Assistance to Needy Families (TANF) program to replace the Aid to Families with Dependence Children (AFDC) program. PRWORA restricts the access of certain categories of immigrants to specified Federal public benefits, including some benefits administered by the U. S. Department of Health and Human Services (HHS). HHS published general guidance on what constitutes a "Federal public benefit," and applicable programs for which the restrictions apply on August 26, 1997 (62 FR 45256) and August 4, 1998 (63 FR 41658).

HHS identified SSBG as one of the programs where these restrictions apply. As such, even though States set their eligibility requirements for SSBG-funded services, they are to ensure that Federal provisions related to verification of qualified immigrant status in providing services are in full compliance. States may review the U.S. Department of Justice's (DoJ) proposed rule issued on August 5, 1998 (63 FR 41662), in conjunction with the Interim Guidance on Verification of Citizenship, Qualified Alien Status and Eligibility under Title IV of the Personal Responsibility and Work Opportunity Reconciliation Act of 1996 published on November 17, 1997 (62 FR 61344) by DOJ and the HHS guidance referenced. You can view the relevant interim regulations at http://www.gpoaccess.gov
Question:
What costs should be included on line 31 “Administrative Costs” on the SSBG post-expenditure report form?
Answer:
States may use the SSBG for administrative costs including planning and evaluation, personnel training and retraining directly related to the provision of services, licensing activities, and the overhead costs of providing services as authorized under Title XX of the Social Security Act, as amended and codified at Section 2002 (a)(2)(B)[42 U.S.C.1397a]. States may pay for these administrative functions entirely with the SSBG. Some States include administrative costs within the expenditures reported for particular service categories.

SSBG 2009 Supplemental Questions & Answers

I. TIME LIMIT
Question:
What is the time period to expend these relief funds?
Answer: The Consolidated Security, Disaster Assistance, and Continuing Appropriations Act, 2009, [Public Law (P.L.) 110-329] was signed into law on September 30, 2008.  The States must obligate and expend the SSBG Supplemental Funds by September 30, 2010.

II. ALLOWABLE COSTS
Question:
What services can the supplemental 2009 SSBG funds cover?
Answer:
States may use the supplemental SSBG funds for the usual array of human services. In addition, the funds may be used to help meet the health care, mental health, and child care needs of people affected by the hurricanes, floods, and other natural disasters occurring during 2008 for which the President declared a major disaster, and from Hurricanes Katrina and Rita. The funds may also be used for the repair, renovation and construction of health facilities, including mental health facilities, child care centers, and other social service facilities.

Question:
Does all of SSBG supplemental funding have to be spent on natural disaster victims?
Answer:
Yes, the statute states that these funds are for necessary expenses related to the consequences of the hurricanes, floods, and natural disasters occurring between January 1, 2008, and September 30, 2008 or Hurricanes Katrina and Rita.

Question:
Can replacement of vans and equipment at nonprofits be funded with SSBG Supplemental Emergency Funds?
Answer:
Yes, these funds are for necessary expenses related to the consequences of the natural disasters. Funds may be used to help meet the needs of people affected by these natural disasters in order to access services, or obtain medical care or employment.

Question:
Can the cost of medications or durable medical equipment for an individual be covered by SSBG Supplemental Emergency Funds?
Answer:
Yes, these funds are intended to be available to help meet the health care needs of people affected by the natural disasters.

Question:
Can this money be used to purchase future supplies and/or equipment which will aid in future disasters? 
Answer:
No, the SSBG Supplemental 2008 funds cannot be used to purchase supplies and/or equipment which will aid in future disasters.  The additional funds to the Social Services Block Grant program are to address necessary expenses resulting from floods and other natural disasters occurring from January 1, 2008 ‑ September 30, 2008 that the President declared a major disaster. 

Question:
Can this money be used for Man‑Made Disasters or only Natural Disasters? 
Answer:
These funds are not available to be used for man‑made disasters. SSBG Supplemental 2008 funds are to be used by States "to address necessary expenses resulting from floods and other natural disasters occurring during 2008 for which the President declared a major disaster..." as stated in Public Law 110‑329. 
 
Question:
Can expenditures incurred by community agencies qualify as a reimbursable expense?
Answer:
These funds may be used to provide social, health, and mental health services for individuals. Yes, supplemental funds can be used to reimburse units of local governments, emergency responders, faith-based agencies and consortiums that incurred expenditures providing social services to people affected by the disasters in your State.

Question:
Can these funds be used for computer equipment (hardware & software) to develop a data base for the impacted flood areas - identification of the people and services affected by the flood which will in turn improve our response capabilities for future events? 
Answer:
Funds can not be used for computer equipment to develop a database with the purpose of preparing for future disasters.  The additional funds to the Social Services Block Grant program are to address necessary expenses resulting from floods and other natural disasters
occurring from January 1, 2008 - September 30, 2008 that the President declared a major disaster.  These funds were not allocated for preparation for future disasters. Therefore funds shall not be used for this purpose.  If the purpose of a database is to track and coordinate
services to people and organizations impacted by the flood, hardware and software could be purchased for this purpose.

Question:
If an individual lost their house to one of the approved floods would temporary housing be an allowable cost under SSBG 2009 Supplemental?
Answer:
Yes, these funds may be used to pay for temporary housing for someone displaced due to flooding in one of the presidentially declared disaster areas.  This cost can be categorized as Housing Services. The Uniform Definitions of Services established in Federal Regulations for the Social Services Block Grant program at 45 CFR Subtitle A, 96.14(a) defines Housing Services as "services or activities designed to assist individuals or families in locating, obtaining, or retaining suitable housing."

Question:
A long term recovery committee still has expenses for which they have not been reimbursed.  Are the expenses covered under this funding?
Answer:
Yes, expenses which have not yet been reimbursed related to presidentially declared disasters  occurring from January 1, 2008 – September 30, 2008 are allowable costs. However, the funds are not allocated for preparation for future disasters. 

Question:
Is a State limited to using the Supplemental appropriation of disaster assistance funds awarded in FY 2009 to only those counties in the State for which the President declared a major disaster and in which FEMA Individual Assistance programs were authorized?
Answer:
No, there is no specific guidance or requirement to limit the use of the Supplemental appropriation for disaster assistance awarded in FY 2009 to only those counties for which the President declared a major disaster and FEMA Individual Assistance programs were authorized.  In some circumstances, disaster victims may have relocated from one area to another.  The State should conduct its own assessment of needs, geographic locations, and priority areas in order to support services for affected populations of disasters and to repair, renovate and construct health care facilities (including mental health facilities), child care centers, and other social services facilities. 

Question
Is FEMA Individual Assistance registrant data available by county for use by the State?
Answer:  
Yes, please refer to the FEMA website http://www.fema.gov/news/disasters.fema for information on Individual Assistance registrant data. 

Question:
Can SSBG Supplemental Funds be used to pay for insurance deductibles (home, vehicle or renters)?
Answer:
Unfortunately SSBG Supplemental funds cannot be used for the payment of insurance deductibles for homes or vehicles.  States are advised to utilize SSBG Supplemental funds for housing services, or services designed to assist families in locating, obtaining or retaining suitable housing, as defined in the regulations governing the SSBG program. Transportation services may include special travel arrangements such as special modes of transportation and personnel to accompany or assist individuals or families to utilize transportation. The additional funds to the Social Services Block Grant program are to address necessary expenses resulting from hurricanes, floods, and other natural disasters occurring from January 1, 2008 - September 30, 2008 that the President declared a major disaster.

Question:  
Can home repairs, mold removal, repairs to septic systems and water lines, purchase of appliances and furniture, bedding, and debris removal be covered by SSBG Supplemental Emergency Funds?
Answer:
If the State determines payments for home repairs, repairs to septic system and water lines, purchase of appliances and furniture, bedding, and debris removal are integral but subordinate to the services to help meet the health care needs of people affected by the hurricanes, these repairs would be covered.

Question:
Can SSBG Supplemental Funds to be used to pay for staff traveling to remote locations for eligibility determination purposes?
Answer:
Yes, SSBG Supplemental Funds can be used to pay for staff traveling for eligibility determination purposes. This would fall under the case management service category.  Component services and activities may include individual service plan development; counseling; monitoring, developing, securing, and coordinating services; monitoring and evaluating client progress; and assuring that client’s rights are protected.

Question:
Does the Davis-Bacon Act apply to SSBG Supplemental disaster funds?
Answer:
The Department of Health and Human Services has concluded that the Davis-Bacon Act does not apply to construction activities paid for in whole or in part with SSBG Supplemental disaster funds. A Federal grant program can only require a grantee to follow provisions of the Davis-Bacon Act if the statute authorizing the program requires it.  However, the State law must be followed in States that require construction grant projects to follow the Davis-Bacon Act. The Administration for Children and Families recommends that States check with their own Attorney General to determine whether State construction projects supported by Federal funds are subject to prevailing wage rate requirements under State law.

III. CONSTRUCTION ACTIVITIES / NFI

Question:
Is prior Federal approval required to use SSBG Supplemental Emergency funds for construction or renovation of health care facilities?
Answer:
No, prior approval is not required for the State to use SSBG Supplemental Emergency funds for repair, renovation or construction of health facilities, including mental health facilities. Appropriation language included in the Consolidated Security, Disaster Assistance, and Continuing Appropriations Act, 2009, [Public Law (P.L.) 110-329] allows the use of the supplemental funds for these purposes.

Question:
How do you calculate the dollar threshold in repairs to a property that triggers the requirement for a Notice of Federal Interest (NFI)?
Answer:
When undertaking renovations that cost more than the lesser of $150,000 or 25 percent of the approved project budget of total repairs to the property, the property owner must file an NFI. Renovation costs that fall below this threshold are not covered by the requirement. However, all real property purchases and new construction are covered regardless of dollar level.

Question:
Can SSBG Supplemental funds help with repairs to a school district?
Answer:
Unfortunately, SSBG Supplemental funds are not designated explicitly for repairs to school facilities. The law authorizing SSBG Supplemental funds, the Consolidated Security, Disaster Assistance, and Continuing Appropriations Act, 2009, [Public Law (P.L.) 110-329], states, that funds may be used for “…necessary expenses resulting from hurricanes, floods, and other natural disasters occurring during 2008 for which the President declared a major disaster, and from Hurricanes Katrina and Rita, including social, health, and mental health services for individuals, and for repair, renovation and construction of health facilities, including mental health facilities” School district facilities repair, renovation and construction are not identified as an allowable use under this authority.

A State may request a construction waiver from the Office of Community Services under the authority at Section 2005 of Title XX of the Social Security Act to use funds for this purpose. [42 U.S.C. 1397d] If seeking such a waiver, the State should identify the extenuating circumstances that warrant the need to use SSBG funds for this purpose, and the associated social service need(s) to be impacted by granting such a waiver. A letter requesting a waiver should be submitted to Ms. Yolanda J. Butler, Ph.D., Acting Director, Office of Community Services, Administration for Children and Families, Department of Health and Human Services, 370 L’Enfant Promenade, SW, Washington, DC, 20447 for consideration.

States should also note that SSBG Supplemental funds may be utilized for Education and Training Services to help meet the social service needs of affected individuals. The Uniform Definitions of Services established in Federal Regulations for the Social Services Block Grant program at 45 CFR Subtitle A, 96.14(a) defines Education and Training Services as follows: "those services provided to improve knowledge or daily living skills and to enhance cultural opportunities. Services may include instruction or training in, but are not limited to, such issues as consumer education, health education, community protection and safety education, literacy education, English as a second language, and General Educational Development (G.E.D.). Component services or activities may include screening, assessment, and testing; individual or group instruction; tutoring; provision of books, supplies, and instructional material; counseling; transportation; and referral to community resources."

Question:
Does a State follow its own administrative rules in regards to bidding as it applies to the use of SSBG Supplemental funds for construction?
Answer:
Yes, bidding is covered by the two qualifications for States to utilize when they intend to use SSBG Supplemental funding authority for private, as well as public and non-profit entities, to repair, renovate or construct health care facilities.

1. States will apply their own administrative standards when they issue sub-awards under the  Consolidated Security, Disaster Assistance, and Continuing Appropriations Act, 2009, [Public Law (P.L.) 110-329] for construction. This means State standards relating to the protection and disposition of real estate purchased or constructed with grant funds are applicable to funds awarded.

2. States must establish, as a condition of funding to all entities receiving SSBG funds under the Consolidated Security, Disaster Assistance, and Continuing Appropriations Act, 2009 [Public Law (P.L.) 110-329] for construction, the requirement that a Notice of Federal Interest (NFI) is filed as a condition of the award. In this way, the NFI officially recognizes the Federal government's continuing financial interest in the property.

Question:
When the Notice of Federal Interest is completed and notarized do we have the benefiting facility just keep it on file?
Answer:
The requirement is that all entities receiving SSBG funds under the Consolidated Security, Disaster Assistance, and Continuing Appropriations Act, 2009 [Public Law (P.L.) 110-329] for construction file a Notice of Federal Interest (NFI) with the State as a condition of the award. As such, the State retains the NFI and a copy is mailed to Administration for Children and Families, Division of Mandatory Grants, 370 L'Enfant Promenade, SW, 6th floor east, Washington, DC 20447.

Question:
Can a provider repay the funds in the future to satisfy the NFI? If so, are there any penalties or will the provider be required to pay any interest?
Answer:
Yes, the funds can be repaid at the appraised price of the facility which is the current market value. Funds repaid should be proportional to the initial Federal investment. For example, if 30% of the invested construction cost for a facility was from Federal government funds, then the Federal government should receive 30% of the fair market value of the facility.
If the provider pays the Federal government fair market value for its share in the facility at the time of a sale, there is no question of interest or penalties on the amount.

IV. REPORTING REQUIREMENTS

Question: 
Can the intended use plan (pre-expenditure report) submitted in Fiscal Year (FY) 2009 be amended for SSBG Supplemental funds?
Answer:
Yes, States that received these SSBG Supplemental funds were required to submit an amendment to their FY 2009 pre-expenditure report (intended use plan) regarding the use of the SSBG Supplemental Funds.  The deadline for submission of the amendment was within 30 days of receiving funds.  This requirement is in accordance with Section 2004 of Title XX of the Social Security Act [42U.S.C.1397c] which governs reporting requirements for the SSBG program, and requires updates for substantial changes in activities supported.

States receiving SSBG Supplemental Funds are also required to submit a post-expenditure report for the annual SSBG funding and a separate report for the SSBG Supplemental. Due to the unique nature of the SSBG Supplemental, some of the construction activities and health services may not fit the State’s definition of services or the Uniform Definition of Services provided by HHS.  In such cases, the States are advised to note the activity of services as “Other Services” and differentiate between construction costs, health care or mental health costs and include  details in the SSBG Supplemental post-expenditure report using the definition provided below.

States are reminded to track SSBG Supplemental Fund expenditures separately from the annual SSBG allotments and submit expenditure data for Supplemental funds using the required OMB No.: 0970-0234 form. In cases where no fit is possible between the State-defined services and the Uniform Definitions of Services, States are advised to note expenditures using item 29, “other services.”  States should clearly define all expenditures noted under “other services,” including construction, health care and mental health services.

Definitions for construction services should include the type of construction service (e.g. repair and/or renovation) as well as the number and type of facilities (e.g. health and/or mental health) for which Supplemental funds were used. Health care and mental health services should include the types of activities (or services) supported, and the categories or characteristics of individuals served (such as children, adults 59 and younger, adults 60 and older) (42 U.S.C.1397c).