ACF-OCS-CSBG-DCL-24-09 Annual Report 3.0 Revisions

Community Services Block Grant

Dear Colleague Letter

DCL#: ACF-OCS-CSBG-DCL-24-09

DATE: April 22, 2024

TO: CSBG Network

SUBJECT: CSBG Annual Report 3.0 Revisions

ATTACHMENT(S):        Attachment A: CSBG Annual Report 3.0, Attachment B: Service to Outlook Plan, Attachment C: Indicator Disposition Report, Attachment D: CSBG Annual Report 2.1, Attachment E: CSBG Annual Report 3.0 Tribal Annual Report, Attachment F: CSBG Annual Report 3.0 Tribal Short Form

Dear Colleague,

In 2021, after grant recipients and subrecipients voiced concerns about the burden associated with the Community Services Block Grant (CSBG) Annual Report, the Office of Community Services (OCS) committed to examining the utility of and potential burden associated with each data point in the Annual Report. As part of OCS’ commitment to lifting up voices from the field, fully examining the information we collect to maximize utility and significantly reduce burden to the public, and in compliance with the requirements of Section 506(c)(2)(A) of the Paperwork Reduction Act (PRA) of 1995, OCS is requesting feedback from the CSBG Network on proposed changes to the CSBG Annual Report (Attachment A). The notice for this information collection activity was posted to the Federal Register  in Volume 89, No. 78, Office of Management and Budget (OMB) #0970-0492, pages 29339-29340 on April 22, 2024.

During the 60-day comment period, and as soon as possible, we invite you to review the proposed CSBG Annual Report information collection and submit your comments, as described below.

Proposed Revisions to the CSBG Annual Report

Section 678E of the CSBG Act requires states, the District of Columbia, the Commonwealth of Puerto Rico, and U.S. Territories to annually prepare and submit a report on the measured performance of the state and the eligible entities in the states. To meet the CSBG Annual Reporting requirement, states collect information from the eligible entities and report to OCS on or before March 31 each year on the uses and results of CSBG for the prior reporting period. 

The CSBG Annual Report, as part of a national effort to strengthen the performance management culture of the CSBG Network, is intended to guide the collection and organization of meaningful performance data. This data showcases the programs and strategies grant recipients and subrecipients are using to address the causes and consequences of poverty, as well as initial outcomes, and it serves as a basis for program analysis at the local, state, and federal levels to increase understanding of what combination of services or strategies produce the best outcomes for specific populations, family types, and communities. OCS stands committed to ensuring the data collected is not only meaningful, equitable, and compliant, but also focuses on the key information needed tell the CSBG story.   

Based on OCS’ examination of the Annual Report and feedback shared from state administrators, local agencies, and partners through one-on-one and small group meetings, site visits, conferences, and training and technical assistance on the CSBG Annual Report, OCS has laid out a series of proposed revisions to the CSBG Annual Report as detailed below:

1) Annual Report 2.1 — Revisions include replacement of the Data Universal Numbering System (DUNS) number with the Unique Entity Identifier (UEI) and clarifications to improve understanding. 

2) Annual Report 3.0 — The following revisions and additions are proposed in the new CSBG Annual Report 3.0:

• Streamlining Reporting Period: The CSBG Annual Report for all four (4) modules will be based on activities and outcomes on the federal fiscal year (FY) timeline of October 1-September 30. This does not constitute changes for how grant recipients allocate resources within the funding year, but is simply to align outcomes across all funded grant recipients. 

• Reorganization of Report: To aid in a simplified reading of the report, the chronology of the report will be updated as follows:
  

• Alignment of Individual and Family Services to Individual and Family National Performance Indicators: To clearly align service delivery with performance outcome indicators, most services captured in the Individual and Family Services (currently Module 4 Section B) are expected to link to the revised Individual and Family National Performance Indicators (currently Module 4 Section A). Included is a Service to Outcome Plan (Attachment B) to illustrate the proposed linkages of services to outcomes. Additionally, OCS has streamlined existing indicators for clear identification as a concrete community support^[1] to quantify the support provided to individuals and families.

• Decreased Burden of Data Collection: In an effort to reduce the burden and ensure the data collected is accurate, helpful, and ideal for its proposed use, OCS has eliminated a total of 161 indicators within the report for the purpose of collection by the federal office. The elimination of indicators is based on national reporting trends of grant recipients, utility for national reporting, comporting to the statutory requirements, and how the indicators converge to measure performance. Included is an Indicator Disposition Report (Attachment C) that details all indicators that were removed, revised, or repurposed. 

• Increased Plain Language: The proposed annual report has been updated to simplify the reading and structure of the report. Additionally, each service and indicator explicitly lists the population and/or unit of measurement. 

3) CSBG Tribal Annual Report — CSBG Annual Report 3.0 Tribal Annual Report, an expansion of the current Tribal Annual Report, derived from the above described CSBG Annual Report 3.0, for CSBG directly funded tribal grant recipients receiving $50,000 or more. Tribes receiving $50,000 or more would be required to report their FY2024 CSBG Tribal Annual Report using this form beginning on March 31, 2025. 

4) Annual Report 3.0 Tribal Short Form — A shortened or abridged version derived from subsections of the above revised Annual Report 3.0. The Tribal Annual Report Short Form enables OCS to collect performance information from CSBG directly funded tribal grant recipients receiving less than $50,000. Tribal grant recipients receiving less than $50,000 would be required to report their FY2024 CSBG Tribal Annual Report using this form beginning on March 31, 2025.

The CSBG Annual Report represents the information collection content OCS will request states submit in response to the annual reporting requirements. The format of the updated information collection will appear differently than the online version of the CSBG Annual Report. All implementation training and technical assistance will demonstrate the report’s appearance in a manner that mirrors the actual collection environment.

Timeline for Implementation and Reporting

CSBG Annual Report 2.1 — States and territories will be required to use CSBG Annual Report 2.1 (the report that replaces their DUNS number with their UEI and includes text edits to improve clarity and understanding) to submit their FY2024 CSBG Annual Report on March 31, 2025. Subsequently, states and territories will have the option to use CSBG Annual Report 2.1 to submit their FY2025 CSBG Annual Report on March 31, 2026 OR use the CSBG Annual Report 3.0 (the realigned report with the pared down indicators and data requirements) to submit their FY2025 CSBG Annual Report on March 31, 2026.

Annual Report 3.0 — The changes in the CSBG Annual Report are significant enough that a phased implementation could take approximately two fiscal years. This phased timeline considers grant recipients who utilize an external system to collect the information and those that utilize OCS-provided SmartForms to submit information into the Online Data Collection (OLDC). Pending approval from OMB, OCS intends to enhance all its technical assistance to support states in a phased implementation. Beginning with the FY2025 CSBG Annual Report (due March 31, 2026), this proposed information collection will be optional for grant recipients and it will become required for the FY2026 CSBG Annual Report (due March 31, 2027). 

Tribal Annual Report 3.0 and Short Form (TSF) — Tribal grant recipients will be required to use the CSBG Annual Report 3.0 or TSF to submit their FY2024 CSBG Tribal Annual Report on March 31, 2025 and subsequent fiscal years thereafter.

Reporting Burden

OCS is keenly aware of the burden data collection, analysis, and reporting may have on the CSBG Network. We also believe that these tasks are investments that can help agencies improve, grow, and produce breakthrough results. To estimate the reporting burden (the collection and review of performance data as well as the development of any necessary technology) on the CSBG Network to produce the proposed Annual Report 3.0, OCS factored in several variables:

1. Whether the data being requested is new or is “usual and customary” for each section of the proposed Annual Report (e.g. local agencies are already legally required to collect much of the demographic data to determine eligibility of participants).

2. How the data collection effort differs at the state versus the local level (e.g. the states are responsible for reporting on the Administrative Module including performance against the State Accountability Measures as set in each state’s Annual Plan, and for reviewing and analyzing the data collected from the local agencies, while the local eligible entities are responsible for tracking participants served and outcomes achieved.

3. The current capacity to collect, report, and review the requested data, and how that varies throughout the network (e.g. some organizations currently have sophisticated technology and trained staff; others will need to upgrade their technology; and some number will need to develop new systems and train staff.

4. Over time the burden will decrease as systems are developed or modified and as staff gain experience with reporting and analysis.

OCS has calculated burden hours based on states that utilize a third-party system and those that rely on OCS-issued SmartForms to estimate burden hours for Modules 2-4. OCS has reduced burden hours for Module 1 as it is a direct data entry into OLDC. Finally, OCS is planning a phased-in implementation approach for the new reporting requirements to allow the states and local agencies time to adjust systems, update processes and procedures, and train staff.

OMB PRA Clearance Process

• Federal Register Notice # 1: April 22, 2024 (60-day comment period)

• Federal Register Notice # 2: June 28, 2024 or before (30-day comment period)

• Anticipated OMB Clearance: Winter 2024

At the end of the 60-day PRA comment period, OCS will complete a review of all comments and submit a revised CSBG Annual Report to OMB. During the second phase of the PRA process, which includes a 30-day comment period, OMB will review the comments. Once OMB determines it is appropriate to approve the information collection, the collection will be approved for a three-year period. Concurrently, OCS will be working with technology partners and the CSBG Network to modify systems that support the collection of the CSBG Annual Report information.

To ensure adequate records management, grant recipients and local agencies should maintain existing state data collection and reporting processes until final OMB approval. We encourage states and entities to consider the draft version of the CSBG Annual Report 3.0 (Attachment A) to assess collection processes and technology needs for future report submissions.

Listening Sessions for the Network

OCS in partnership with the Office of Planning, Research, and Evaluation (OPRE) and Mathematica will host a series of listening sessions with the CSBG Network to preview the proposed changes, gather feedback, and field questions about the FRN process. OCS will not respond to feedback or questions during the listening sessions; however, in accordance with the PRA process, OCS will provide a written response to the public on feedback and comments provided through the FRN process and during the listening sessions after the 60-day FRN period closes. Advance registration is required to participate in the listening sessions. Please note the sessions are limited to 350 participants. Given the number of CSBG grant recipients and subrecipients, there will be five listening sessions on the state and territory CSBG Annual Report 3.0 and one session for the tribal CSBG Annual Reports, including Annual Report 3.0 and the short form. Participants are strongly encouraged to review the attachments prior to attending a listening session. Register for one of the sessions below. 

Feedback and Comments

The Federal Register Notice requests feedback on the following questions, and we especially invite comments on the content, format, and order of the information in the revised CSBG Annual Report. When reviewing the proposed indicators, consider the following topics:

1. Whether the proposed collection of information is necessary for the proper performance measurement of federal, state, or local agencies.

2. The quality of the information to be collected.

3. The clarity of the information to be collected.

4.  Does the information to be collected produce significant burden? If so, how could the burden be minimized on respondents, including through the use of automated collection techniques or other forms of collection.

5. The accuracy of the agency’s estimate of the burden of the proposed collection of information.

6. What, if any, additions, revisions, or modifications to the information collection would you suggest?

Please include supportive comments as well as suggestions for improvement, so that we can get a balanced perspective on what works and what needs revision. Please clearly reference your comments by proposed module, section, and page number, as appropriate. We welcome automation suggestions as well, particularly from those who are familiar with data collection systems.

Please submit your comments to infocollection@acf.hhs.gov, as directed in the Federal Register Notice, within the 60-day comment period that began April 22, 2024. We encourage you to submit your comments as soon as possible, in order to expedite the clearance process.

If you have questions in reference to the CSBG Annual Report, please email CSBGData@acf.hhs.gov. 

Thank you for your commitment to increase accountability across the CSBG Network. Together we can make positive impacts for communities, families, and individuals with low income. OCS looks forward to continuing to provide high-quality services to OCS partners.

/s/
Charisse Johnson
Director, Division of Community Assistance
Office of Community Services