Fiscal CSBG Frequently Asked Questions
Can CSBG funds be carried over from one fiscal year to another?
Yes. Under the current appropriation law, an eligible entity is permitted to carry over into the next fiscal year any remaining CSBG funds that have not been expended in the current fiscal year. See IM 61 for additional information.
What is the administrative cap for CSBG funds?
No state, tribe, or tribal organization may spend more than the greater of $55,000, or 5 percent, of the grant received under section 675A or state allotment received under section 675B for administrative expenses, including monitoring activities.
What are indirect costs?
Indirect costs are eligible entity costs that have been incurred for common objectives benefitting all programs and cannot be readily identified or assignable to a particular final cost in a program (45 CFR 75.414). Indirect costs relate to central management and administrative functions that are necessary and beneficial to all programs administered by the grantee organization. See IM 37 for additional information.
What is a Technical Assistance Plan (TAP)?
A TAP is a technical assistance plan that targets training and technical assistance resources and outlines a time frame for an eligibility entity to meet a specific standard or set of standards. CSBG IM 138 reports that a state is expected to develop a TAP in circumstances where eligible entities are not meeting the CSBG organizational standards.
What is a Quality Improvement Plan (QIP)?
A QIP is a plan by an eligible entity to correct a deficiency identified by the state, consistent with the requirements outlined in Section 678C of the CSBG Act. This section focuses on corrective action, termination, and reduction of funding. Prior to terminating or reducing funding to an eligible entity, the CSBG Act requires that, at the discretion of the state (taking into account the seriousness of the deficiency and the time reasonably required to correct the deficiency), the state allow the entity to develop and implement, within 60 days after being informed of the deficiency, a quality improvement plan to correct such deficiency within a reasonable period of time, as determined by the state.
What is the process for de-designation?
An organization can only have its eligible entity status terminated for cause according to a process outlined in the CSBG Act. Please see IM 116 Corrective Action, Termination, or Reduction of Funding, for a detailed description of the necessary steps for the de-designation process.
How often are the CSBG funded states, and territories monitored by OCS?
OCS conducts annual standard state monitoring reviews as required under Section 678B(c) of the CSBG Act. During the fiscal year, OCS provides a schedule of which states will be monitored for federal and state planning purposes. OCS contacts each state directly to discuss requirements and preparations for in-person and desk monitoring.
Can CSBG funds be used for construction of facilities or permanent improvements to property?
No. Grants made under the CSBG Act may not be used by the state, or any other person with which the state makes arrangements to carry out the purposes of the CSBG Act for the purchase or improvement of land or the construction or permanent improvement of land of any building or other facility. (CSBG Act Sec. 678F(1), (CSBG IM Transmittal No.2, Date-April 14, 1993 and IM 3)
Can the limitation on construction or purchase of land be waived?
Yes. In rare instances the Secretary may waive the limitation upon a state request if the Secretary finds that the request describes extraordinary circumstances to justify the purchase of land or the construction of facilities and that permitting the waiver will contribute to the ability of the state to carry out the purposes of the CSBG Act, Sec. 678F(2). See IM 3 for additional information.
Can unobligated CSBG funds be recaptured and redistributed by states?
Section 675(C)(a)(3) of the CSBG Act, 42 U.S. C. § 9907 (a)(3), permit states the discretion to recapture and redistribute unobligated funds in excess of 20 percent of the amount distributed to an “eligible entity” to another eligible entity or to a private nonprofit organization. However, the Consolidated Appropriations Act, 2005, Pub. L. 108-447, and all subsequent annual legislation appropriating funds for CSBG have contained language that supersedes Section 675(C)(a)(3) of the CSBG Act. Funds that have not been spent by the eligible entity shall remain with the entity for carryover into the next fiscal year.
What are CSBG direct program costs?
Direct program costs can be identified with delivery of a particular project, activity, service undertaken by a grantee and intended to achieve an objective of the grant award. Direct costs include expenditures on some activities with administrative qualities, including salaries and benefits of program staff and managers, equipment and training, conferences, travel and contracts, as long as those expenses relate specifically to a particular program or activity, not to the general administration of the organization. Additional information and description is available in the Uniform Administrative Requirements, Subpart E — Cost Principles, specifically in 2 CFR 200.412 Classification of Costs and CFR 200.413 Direct Costs.
What are examples of CSBG disallowed costs?
CSBG’s purpose differs from most grants because it does not focus on funding a particular service. CSBG does not function solely as a “stand alone” program, rather, CSBG funding can support 1) creation of new programs and services; 2) augmentation of existing programs and services; and 3) organizational infrastructure required to coordinate and enhance the multiple programs and resources that address poverty conditions in the community.
Eligible entities are subject to the Uniform Administrative Requirements, Subpart E — Cost Principles. Within the cost principles certain costs have been determined to be unallowable. Examples of these unallowable costs include but are not limited to the following:
• Bad debt expenses
• Fines and/or penalties
• Certain interest or other financial costs
• Loan processing costs
• Ineligible acquisition or construction of shelter
• Preparation of work activities that would result in displacement of a place of business, and
• Lobbying or other political activities
Can CSBG funds be used to transport voters to polling stations for voting?
No. The statute prohibits the use of CSBG funds by a grantee to transport any voter to the polls.
Can CSBG funds be used for disaster response or recovery?
Although additional funding is not routinely available within CSBG appropriations, regular state CSBG funding may be used by eligible entities to support disaster response, as long as it aligns with the statutory allowable activities. While eligible entities may need state approval to modify Community Action plans, they do not have to request a federal waiver to utilize their existing CSBG funding to support disaster and assistance to eligible low-income individuals and families.
While CSBG funds may not be used for the permanent improvements to property, Section 678F(a)(2) of the CSBG Act allows the Secretary of HHS to waive restrictions on the use of CSBG funds for purchase or improvement of land, or the purchase, construction, or permanent improvement of property if doing so will contribute to the ability of the state to carry out the purposes of the grant. See IM 154 for additional information.