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SSBG IM 01-2010 Pre- and Post-Expenditure Reporting for the SSBG Program

Published: June 7, 2010
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. 01-2010  Date:  June 7, 2010


TO: Social Services Block Grant (SSBG) State Officials and Program Contacts

SUBJECT:  Pre- and Post-Expenditure Reporting for the SSBG Program

RELATED REFERENCES:
The SSBG program is authorized under Title XX of the Social Security Act, as amended, and is codified at 42 USC 1397 through 1397e.  The implementing regulations for this and other block grant programs authorized by Omnibus Budget Reconciliation Act of 1981 are published at 45 CFR Part 96.  Those regulations include both specific requirements and general administrative requirements in lieu of 45 CFR Part 92 (the HHS implementation of the A-102 Common Rule) for the covered block grant programs.  Requirements specific to SSBG are found in 45 CFR Sections 96.70 through 96.74.  Each State is responsible for designing and implementing its own SSBG program, within very broad Federal guidelines.  States must administer their SSBG program according to their approved plan, along with amendments, and in conformance with their own implementing rules and policies.

PURPOSE:
To share with States the requirements and provide guidance for the preparation of SSBG pre- and post-expenditure reports.

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. Both reports help to clarify the planned and actual use of SSBG funds for the provision of services in each State. The Office of Community Services (OCS) analyzes SSBG expenditure and recipient data reported through the pre- and post-expenditure reports in order to develop the SSBG Annual Report. This information also assists OCS in developing performance measures for the SSBG program.

PRE- EXPENDITURE REPORT
 

DUE  DATE:
An annual pre-expenditure report that describes how the State plans to administer its SSBG funds for the coming year must be submitted prior to receipt of a SSBG allotment. 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). 

CONTENT:    
States must report on the intended or planned uses 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). (See sample Attachment A and Attachment B.)  While no specific outline is required for the pre-expenditure report, a narrative of the proposed activities and individuals to be served or a chart with this information by service area should be provided in pdf format. If the planned uses of SSBG funds change during the year, a revised pre-expenditure report must be submitted to the OCS.

The pre-expenditure report is the only reporting mechanism for providing information on the intended or planned use of SSBG funds. States are encouraged to include OMB Form No. 0970-0234 (Pre-expenditure Reporting Form) with the pre-expenditure report. This additional documentation will provide for a more accurate analysis of the extent to which SSBG funds are spent by States. The reporting form should be completed with estimated expenditures and recipient data rather than actual expenditures and recipient data.

POST- EXPENDITURE REPORT
 

DUE  DATE:
States must submit the post-expenditure report within six months after the end of the period covered by the report. For example, Federal Fiscal Year 2009 ended September 30, 2009 with post-expenditure reports due by March 30, 2010.  

CONTENT: 

  
States are to report on expenditures and recipients of services within the 29 service categories that are defined in the Uniform Definition of Services found at 45 CFR Part 96, Appendix A.  Submit expenditure and recipient data for each service that is supported, in whole or in part, by SSBG funds.  Report expenditures of SSBG funds using OMB Form No. 0970-0234.   The form requires that data be provided for:

the number of individuals (identified 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 through the SSBG;
the amount of SSBG funds spent providing each service;
the amount of funds transferred into SSBG from the Temporary Assistance for Needy Families (TANF) block grant program;
the total amount of Federal, State and local funds spent providing each service, including SSBG funds;
the method(s) (public, private, etc.) by which each service is provided; and,
the types of services provided by public and private agencies.
 
VALIDATION:


Annually validation questions are sent to States during the month of August. Responses to the validation questions are due within two weeks and are sent directly to the contractor.

Process: States are requested to answer specific validation questions to ensure that data is accurate. Validation questions  include: confirmation of the SSBG contact person; the percentage of total expenditures for each service supported, in whole or in part, with SSBG funds; and, the number of recipients supported by the total expenditures.

Additionally, States will receive State-specific questions based on the 16 data validation checks of each post-expenditure report. (See Attachment C.) There are three different types of data issues that can arise from a data validation process. These include: (1) errors, (2) flaws, and (3) flags. Errors indicate issues with the data that must be changed. An example of a data error: State reports expenditures for a particular service category, but does not report any recipients for that service category. Flaws indicate issues that may remain unchanged, but require an explanation from the State. An example of a flaw: State reports total adults for a specific service category, but does not provide the number of adults in the specific age categories of 59 years and younger or 60 years and older.Flags indicate data that may raise administrative issues and may warrant further review. An example of a flag: State reports administrative costs exceeding nine percent of SSBG expenditures.

The final component of the validation check is a comparison of projected expenditures and actual expenditures. Each States’ pre-expenditure report is further analyzed and compared to the post-expenditure report to determine the extent to which funds were spent in a manner consistent with the plan presented in the pre-expenditure report. A table comparing State pre-expenditure report estimates with actual expenditures reported on the State post-expenditure report is provided as a part of the validation process. Changes in funding from the projected expenditures to the actual expenditures, as reported, requires an explanation.

Once responses to validation questions are received by the contractor, follow-up questions raised by the responses are submitted to the State. Clarifications are required to be provided within two weeks. Validation must be complete by late September to ensure that the SSBG Annual Report is completed in a timely manner.

During the month of November data pages are sent to the State’s contact person. Once responses to validation questions have been received, corrections and adjustments are made to expenditure and recipient data based on the State’s clarifications. A copy of the State’s data, as it will appear in the SSBG Annual Report, is then sent to the SSBG contact person. The State should confirm that the data are correct or submit any additional changes to the contractor  within two weeks. 

ADDITIONAL
INFORMATION:


In order to ensure that the data are accurate, use the Microsoft Excel pre-expenditure and post-expenditure reporting forms to provide estimates and final totals of expenditures and recipients. Use of the Microsoft Excel forms helps ensure the completeness and accuracy of the data, and increases the efficiency of the data validation process.

The narrative section of the pre-expenditure report and any additional documentation should be submitted in PDF format.

Address inquiries for HHS Regions I, II, III, IV, VI, and VII 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


Address inquiries for HHS Regions V, VIII, IX, and X to:
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/________________
                                                            Yolanda J. Butler, Ph.D.
                                                            Acting Director
                                                            Office of Community Services

 

Attachments:

A. Model SSBG Pre-Expenditure Report

B. Critical Elements of the Pre-Expenditure Report

C. SSBG Data Validation Checks

Links to pre- and post-expenditure reports:
https://www.acf.hhs.gov/programs/ocs/resource/pre-expenditure

https://www.acf.hhs.gov/programs/ocs/resource/post-expenditure-reports