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SSBG IM 01-2009 Linking the SSBG Pre- and Post-Expenditure Reports

Published: December 31, 2008
Audience:
Social Services Block Grants (SSBG)
Category:
Guidance, Policies, Procedures, Information Memorandums (IM)

SOCIAL 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.  01-2009                                                   Date: December 31,2008

TO:                    Social Services Block Grant (SSBG) State Officials and State Program Contacts
                            
SUBJECT:         Linking the Social Services Block Grant (SSBG) Pre- and Post-Expenditure Reports

PURPOSE:        To provide guidance to States on how to link reporting of intended and actual use of SSBG funds 

The Office of Management and Budget (OMB) approved the continued use of OMB Form No. 0970-0234 (post-expenditure report) until July 31, 2011.  The renewal of the post-expenditure report form allows for the continued collection of important data about the Social Services Block Grant (SSBG) program.  OMB also granted approval to request that States voluntarily use the post-expenditure report as part of the required annual pre-expenditure report.  This decision does not modify pre-expenditure reporting requirements; States should continue to include the narrative format of the intended use plan as OMB Form No. 0970-0234 does not replace this information.

The SSBG program provides funds to the 50 States, the District of Columbia, the Commonwealth of Puerto Rico, and the Territories of Guam, American Samoa, the Virgin Islands, and the Northern Mariana Islands (hereinafter referred to as States).  States have substantial discretion in the use of funds and may determine what services will be provided, who will be eligible, and how funds will be distributed among the various services (42 U.S.C. §1397d).  Therefore, the Office of Community Services (OCS) is providing guidance on the use of the post-expenditure report to estimate expenditures and recipients, by service category, as part of the required annual pre-expenditure report.  Furthermore, OCS is affirming the importance of linking SSBG pre- and post-expenditure reports due to the relatively unusual flexibility States have in funding SSBG services.

Background

Each year, States are required to submit a pre-expenditure report or intended use plan as a prerequisite to receiving SSBG funds, and a post-expenditure report on the actual expenditures of SSBG funds subsequent to the end of the fiscal year (42 USC §1397e).  Both reports help to clarify the planned and actual use of SSBG funds for the provision of services in each State.  OCS analyzes SSBG expenditure and recipient data from the pre- and post-expenditure reports to develop the SSBG Annual Report.  This information also assists OCS in developing performance measures for the SSBG program.

 

Pre- and Post-expenditure Reporting Requirements for the SSBG Program

Pre-expenditure Report

Before a State receives a SSBG allotment, it must submit an annual pre-expenditure report that describes how the State plans to administer its SSBG funds for the coming year.  This report must be submitted 30 days prior to the start of the fiscal year (June 1 if the State operates on a July-June fiscal year, or September 1 if the State operates on a Federal fiscal year).  States must report on the intended use of SSBG funds, including the types of activities (or services) to be supported, and the categories and characteristics of individuals to be served (such as children, adults 59 and younger, adults 60 and older, and the disabled) (42 U.S.C. §1397c).  While no specific format is required for the pre-expenditure report, States typically provide a narrative of the proposed activities and individuals to be served or a chart with this information by service area.  States are also required to submit a revised pre-expenditure report if the planned uses of SSBG funds change during the year.

Post-expenditure Report

States are to report on their expenditures and recipients of services within 29 service categories that are defined in the Uniform Definition of Services.  If the State’s definition of a service differs from the Uniform Definitions, the State should clearly explain this in the pre-expenditure report.  States are required to submit expenditure and recipient data for each service that is supported, in whole or in part, by SSBG funds.  States must submit the post-expenditure report within 6 months of the end of the period covered by the report.  Post-expenditure reporting requirements for SSBG are codified in the Code of Federal Regulations at 45 C.F.R §96.74.  States are required to report expenditures of SSBG funds using OMB Form No. 0970-0234.   The form requires States to provide data for:

The number of individuals (broken out by children, adults age 59 and younger, adults age 60 and older, and adults of unknown age) who receive services paid for in whole, or in part, with Federal funds under the SSBG;

The amount of SSBG funds spent in providing each service;
The amount of funds transferred into SSBG from the Temporary Assistance for Needy Families (TANF) block grant;

The total amount of Federal, State and local funds spent in providing each service, including SSBG funds; and
The method(s) by which each service is provided, showing separately the services provided by public and private agencies.

Using OMB Form No. 0970-0234 to Report Estimates of Expenditures and Recipients

The pre-expenditure report is the only reporting mechanism for providing information on the intended use of SSBG funds.  Additionally, the post-expenditure reporting form is the only instrument that collects data regarding expenditures and recipients for the 29 SSBG service categories.  Some States are already using this form to provide estimates of expenditures and recipients.  This additional documentation will provide for a more accurate analysis of the extent to which SSBG funds are spent by States “in a manner consistent” with each of the States’ plans for their use, as required by 42 U.S.C. §1397e(a).  The reporting form should be completed with estimated expenditures and recipient data rather than actual expenditures and recipient data as done for the post-expenditure report data.

Other Related Information Regarding SSBG Reporting

Information Memorandum (IM) 02-2008: Definition and Allowability of Direct and Administrative Costs.
Services funded by the Social Services Block Grant (SSBG) sometimes have managerial and administrative qualities.  IM 02-2008 clarifies for States the definition and allowability of direct program and administrative costs.  IM 02-2008 is available on the Office of Community Services (OCS) website at https://www.acf.hhs.gov/programs/ocs/resource/definition-and-allowabi....

Information Memorandum (IM) 09-2001: Reporting Funds Transferred From Temporary Assistance to Needy Families (TANF) to the Social Services Block Grant. When funds are transferred to SSBG from TANF, and expended during a reporting period, these expenditures must be included with SSBG expenditures on the SSBG post-expenditure report.  IM 09-2001 clarifies for grantees how States should report expenditures of TANF transfer funds on the annual SSBG post-expenditure report.  IM 09-2001 is available on the OCS website at https://www.acf.hhs.gov/node/6061.

Information Memorandum (IM) 03-2007: Reporting of SSBG Supplemental Emergency Fund Expenditures. Additional funding in FY 2006 was awarded to States to address to address the social and health services of individuals affected by the 2005 gulf coast Hurricanes.  States are required to submit a post-expenditure report for SSBG funding and a separate report for the SSBG Supplemental Emergency funding.  IM 03-2007 is available on the OCS website at http://www.acf.hhs.gov/node/6036.

Please address inquiries to:

Marsha Werner
Social Services Program Specialist
Office of Community Services
U.S. Department of Health and Human Services
370 L’Enfant Promenade, S.W.
Washington, D.C.  20447
Telephone: (202) 401-5281
Fax: (202) 401-5718
Email: Marsha.Werner@acf.hhs.gov

or

Latasha Abney
Social Services Program Specialist
Office of Community Services
U.S. Department of Health and Human Services
370 L’Enfant Promenade, S.W.
Washington, D.C.  20447
Telephone: (202) 401-5324
Fax: (202) 401-5718
Email: Latasha.Abney@acf.hhs.gov

___________/s/____________
Josephine B. Robinson
Director
Office of Community Services