CSBG AT-2020-08 Application for FFY 2021 Funds for States and Territories

Publication Date: August 19, 2020

Community Services Block Grant

Action Transmittal

AT#: CSBG-AT-2020-08

DATE: August 19, 2020

TO: CSBG States and Territories

SUBJECT: Application for FFY2021 CSBG Funds for States and Territories

ATTACHMENT(S): FY2021 CSBG State Plan Submission Group; CSBG Letter of Intent Requirements

 

RELATED REFERENCES:

Community Services Block Grant Act, Title VI, Subtitle B, of the Omnibus Budget Reconciliation Act of 1981, Public Law 97-35, as amended; Human Services Amendments of 1994, P.L.103-252; the FY 1996 CSBG Appropriation Legislation, P.L.104-134; CFR Title 45, Part 96; Coats Human Services Reauthorization Act of 1998, P. L. 105-285; Department of Health and Human Services Block Grant Regulations and Current Poverty Income Guidelines.

PURPOSE:

To inform states and U.S. territories of the Community Services Block Grant (CSBG) application requirements for Federal Fiscal Year (FFY) 2021. To qualify for FFY2021 CSBG funding, states and territories must submit their state plan applications to the Office of Community Service (OCS) by December 1, 2020 using the approved online CSBG State Plan format. States and territories shall submit their information electronically through the Administration for Children and Families (ACF) On-Line Data Collection system (OLDC).

BACKGROUND:

According to Section 676(b) of the CSBG Act, states[1] must prepare and submit a State Plan for CSBG funding. OCS provides funds to CSBG grantees based on the determination that their State Plan, which also serves as an application, is complete and in accordance with all requirements of the CSBG Act.

The CSBG State Plan is a critical document for both state and federal oversight of CSBG. The CSBG State Plan — submitted through OLDC — integrates and aligns requirements from the CSBG Act with elements of the overall CSBG Performance Management and Accountability framework.

This framework includes: 1) organizational standards for CSBG eligible entities; 2) accountability measures at the state and federal levels; and 3) Results Oriented Management and Accountability (ROMA) (or another performance management system). Ultimately, this framework will enable the CSBG Network (local, state, and federal levels) to continuously improve their programs and generate breakthrough outcomes for families, individuals, and communities with low-incomes. Operation of CSBG in accordance with these state plans will be contingent on enactment of FFY2021 appropriations supporting CSBG.

For more information about the CSBG Performance Management and Accountability Framework, see the following Information Memoranda (IM):

IM 138: State Establishment of Organizational Standards for CSBG Eligible Entities;

IM 144: CSBG State and Federal Accountability Measures and Data Collection Modernization; and

IM 152: CSBG Annual Report.

SUBMISSION AND REQUIREMENTS:

Consistent with the CSBG Act, CSBG state plan applications are typically due by September 1. However, due to Office of Management and Budget (OMB) allowable flexibilities the CSBG state plan applications for FFY2021 are due to OCS by December 1, 2020. In order to allow this flexibility and ensure that states are still funded on time, OCS has put other requirements in place, including submitting the SF-424M and a Letter of Intent by September 1, 2020.

For FFY2021, states are divided into three groups:

Group A: states that submitted a two-year plan on September 1, 2019 for FY2020 and FY2021;

Group B: states that submitted a one-year plan on September 1, 2019 for FY2020; and

Group C: sates that submitted a two-year plan on September 1, 2018 for FY2019 and FY2020.

Please find the submission groups further defined in the attachment: FFY2021 CSBG State Plan Submission Groups.

The requirements for FFY2021 are:

  1. SF-424M — required for all groups, due September 1, 2020;
  1. Letter of Intent — required for Groups B and C, due September 1, 2020;
  1. CSBG Eligible Entity Master List — Groups B and C, as applicable, due prior to initializing the CSBG State Plan; and
  1. CSBG State Plan — required for Group C and optional for Group B, due by December 1, 2020.

SF-424M — Required for all states; due September 1, 2020

As of FFY2020, the Office of Grants Management (OGM) will issue the Notice of Grant Award electronically via email distribution to the Authorized Official noted within OLDC on the SF-424M. Therefore, all states must ensure that the Authorized Official email contact information is accurate.

In order to ensure the prompt issuance of funds upon appropriation of CSBG for FFY2021, OCS requires all states to submit the SF-424M as a separate document through OLDC for this year.

The Authorized Official or the Authorized Official’s designee must certify the SF-424M. This must match the designation letter as attached to the CSBG State Plan, Section 1, 1.3. Please note: the certifier will receive the Notice of Grant Award.

Letter of Intent — Required for Groups B and C; due September 1, 2020

Given the extended due date for the CSBG State Plan, Groups B and C are required to submit a Letter of Intent confirming their intentions for the FFY2021 CSBG State Plan per the requirements in CSBG Action Transmittal (AT) 2020-06 and detailed below.

Please see the full requirements for the Letter of Intent in the attachment: CSBG Letter of Intent Requirements.

CSBG Eligible Entity Master List — Groups B and C, as applicable; due prior to initializing CSBG State Plan

The CSBG Eligible Entity Master List (introduced in 2018) is available within OLDC. States are required to revise the Master List if there were changes to the eligible entities within the state since the last submission of the CSBG State Plan. States must submit the CSBG Eligible Entity Master List prior to initializing the CSBG State Plan. For more information, review CSBG-AT-2020-07 FFY2021 Eligible Entity Master List Submission.

While Group A is not required to revise their CSBG Eligible Entity Master List this year, OCS recommends reviewing and revising, as applicable.

CSBG State Plan — Required for Group C, optional for Group B; due December 1, 2020

States have the option of submitting a state plan annually (covering one federal fiscal year) or biannually (covering two federal fiscal years) as per the CSBG statute. States must submit their plans electronically through OLDC, which is currently available for entry.

As with last year, states will not be able to “clone” their previous submission in developing this year’s submission. Rather, responses from the last state plan submission will pre-populate in most questions.

A full submission includes the: 1) CSBG Eligible Entity Master List (a separate form available in OLDC); 2) SF-424M [the cover page of the CSBG State Plan][2]; 3) CSBG State Plan Sections 1 — 13; 4) Assurances as defined by the CSBG statute (Section 14); and 5) Certifications as defined by the CSBG statute (Section 15).

Once all forms are complete, the authorized official, or as designated in the designation letter (Section 1, Question 1.3), must certify the CSBG State Plan within OLDC per CSBG statute.

The Office of Management and Budget (OMB) approved the streamlined and automated CSBG State Plan through the Paperwork Reduction Act (PRA) process for a three-year period (FFY 2019 — FFY 2021). There are no additions or revisions to the plan for FFY 2021. For background information about the development and content of the CSBG State Plan, please see the following Dear Colleague messages:

CSBG State Plan Revision: Open Comment Period; and

CSBG State Plan Revisions: Second Open Comment Period.

Content areas for the FFY 2020 CSBG State Plan submission:

CSBG Cover Page (SF-424M)

Section 1: CSBG Administrative Information

Section 2: State Legislation and Regulation

Section 3: State Plan Development and Statewide Goals

Section 4: CSBG Hearing Requirements

Section 5: CSBG Eligible Entities

Section 6: Organizational Standards for Eligible Entities

Section 7: State Use of Funds

Section 8: State Training and Technical Assistance

Section 9: State Linkages and Communication

Section 10: Monitoring, Corrective Action, and Fiscal Controls

Section 11: Eligible Entity Tripartite Board

Section 12: Individual and Community Income Eligibility Requirements

Section 13: Results Oriented Management and Accountability (ROMA) System

Section 14: CSBG Programmatic Assurances and Information Narrative

Section 15: Federal Certifications

Group B

For the FFY2021 CSBG State Plan, OCS will consider the FFY2020 CSBG State Plan as a ’Pro Forma’ FFY2021 CSBG State Plan if there are no changes to the allocation rate of funds or changes to the eligible entities within the state.

If there are changes to the eligible entities or the allocation, the state must submit a new CSBG State Plan for FFY2021 meeting the requirements defined above and hold a public hearing as required by the CSBG Act.

The state reserves the option to submit a new CSBG State Plan for FFY2021, meeting all the requirements defined above, even if there are no changes to the eligible entities list or allocation formula. OCS is offering the opportunity to consider the FFY2020 as a ’Pro Forma’ FFY2021 CSBG State Plan to reduce additional burden to the states.

Group C

For the FFY2021 CSBG State Plan, these states must complete a full submission as defined above. The plan is subject to all requirements of the CSBG Act, including the public hearing requirement.

Group A

For FFY2021, states are not required to submit the CSBG State Plan but have the option to revise their accepted FFYs 2020 and 2021 CSBG State Plan submitted on September 1, 2019.

If the state elects to submit revisions, the revisions should be made to the previously submitted on September 1, 2019 and is subject to the requirements of a submitted a full plan as detailed above, including having the Authorized Official certify the report[3].

If the state is changing its distribution formula for eligible entities, adding or removing eligible entities, or reducing or terminating the proportionate share of funding to an eligible entity, the state must hold a new hearing. Regardless of whether there is a hearing, the state should distribute the revised plan to eligible entities.

TRAINING AND TECHNICAL ASSISTANCE:

OCS will host a webinar(s) in September 2020 to provide training and technical assistance for the submission of the FFY2021 CSBG State Plan. Please look for an official announcement in the upcoming weeks.

OLDC SUPPORT:

OCS encourages all states to review OLDC access information, ensuring that state staff have been registered in the correct roles for the state plan submission process. Please keep in mind:

states should have at least one individual assigned as the Grant Administrator

This person can submit, un-submit, and enter data into all CSBG forms within OLDC.

States should also have at least one individual assigned as the Authorized Official. The Authorized Official must be the individual (e.g., director, secretary, or commissioner) designated in the CSBG state designation letter, or that person’s official designee. OCS will not accept any CSBG State Plan that does not include a designation letter that clearly specifies the designated lead agency and the title of the official who is authorized to certify the CSBG State Plan.

To request OLDC access for CSBG staff, or to make changes to an existing account, please complete the OLDC Access Form.

An individual who already has access to OLDC for another program (e.g., LIHEAP), must still submit an official request to add CSBG to their account. (The individual will use one username and password to login to OLDC, and then may select from the menu of programs included in their account.)

FFY2020 ANNUAL REPORT REQUIREMENT:

Section 678E(a)(2) of the CSBG Act requires states to prepare and submit an annual report on the activities and performance of the state and its eligible entities. As of 2019, states submit the CSBG Annual Report through OLDC. Submitting the CSBG Annual Repot annually through OLDC fulfills CSBG statute requirements as outlined above. States are no longer required to send OCS an email or letter detailing how they plan to submit their Annual Report. OCS will provide additional information about the submission of the FY2020 CSBG Annual Report in the upcoming months.

ADDITIONAL CSBG ACT REQUIREMENTS:

Capital Improvement and Construction Waivers

In accordance with Section 678F(a)(2) of the CSBG Act, OCS must approve waivers, in writing, before block grant funds can be used for capital improvement and construction purposes. If a state anticipates the need for a waiver, a waiver request must be submitted to OCS by the state, not the eligible entity. If there is a need for a waiver request, such requests should address the requirements referenced in Section 678F(a)(2) of the CSBG Act and IM 60: Duties and Interests with Respect to Property, Purchased, Constructed, or Improved by an Eligible Entity.

Proportionate Share of Funding

States are required to provide each eligible entity, currently in good standing within the state, its proportionate share of any CSBG funding received by the state. A decision by a state not to provide a proportionate share in funding to an eligible entity will be considered as a reduction of funding under Sections 676(b)(8) and 678C of the CSBG Act. Reduction of funding must be for cause and is subject to statutory requirements as described in IM 116: Corrective Action, Termination, or Reduction of Funding.

Collaboration with Faith-Based Organizations

States must provide an assurance (included in the CSBG State Plan under Section 9, Question 9.6) that is signed by the CSBG State Designated Official and addresses the requirements of Section 679 of the CSBG Act, entitled “Operational Rule:”

“a) Religious Organizations Included as Nongovernmental Providers. — For any program carried out by the Federal Government, or by a State or local government under [the CSBG Act], the government shall consider, on the same basis as other non-governmental organizations, religious organizations to provide the assistance under the program, so long as the program is implemented in a manner consistent with the Establishment Clause of the first amendment of the Constitution. Neither the Federal Government nor a State or local government receiving funds under this subtitle shall discriminate against an organization that provides assistance under, or applies to provide assistance under, this subtitle, on the basis that the organization has a religious character.

“b) Religious Character and Independence.

“(1) In General. — A religious organization that provides assistance under a program described in subsection (a) shall retain its religious character and control over the definition, development, practice, and expression of its religious beliefs.

“(2) Additional Safeguards. — Neither the Federal Government nor a State or a local government shall require a religious organization—

“(A) To alter its form of internal governance, except (for purposes of administration of the community services block grant program) as provided in section 676B; or

“(B) To remove religious art, icons, scripture, or other symbols; in order to be eligible to provide assistance under a program described in subsection (a).

“(3) Employment Practices. — A religious organization's exemption provided under section 702 of the Civil Rights Act of 1964 (42 U.S.C. 2000e-1) regarding employment practices shall not be affected by its participation in, or receipt of funds from, program described in subsection (a).

“c) Limitations on Use of Funds for Certain Purposes. — No funds provided directly to a religious organization to provide assistance under any program described in subsection (a) shall be expended for sectarian worship, instruction, or proselytization.

“d) Fiscal Accountability. —

“(1) In General. — Except as provided in paragraph (2), any religious organization providing assistance under any program described in subsection (a) shall be subject to the same regulations as other nongovernmental organizations to account in accord with generally accepted accounting principles for the use of such funds provided under such program.

“(2) Limited Audit. — Such organization shall segregate government funds provided under such program into a separate account. Only the government funds shall be subject to audit by the government.

“e) Treatment of Eligible Entities and Other Intermediate Organizations. — If an eligible entity or other organization (referred to in this subsection as an 'intermediate organization'), acting under a contract, or grant or other agreement, with the Federal Government or a State or local government, is given the authority under the contract or agreement to select nongovernmental organizations to provide assistance under the programs described in subsection (a), the intermediate organization shall have the same duties under this section as the government.”

For questions regarding OLDC including access and submission, please contact Niki Frazier and Monique Alcantara. Please copy CSBGStates@acf.hhs.gov on all email correspondence.

For questions regarding CSBG State Plan content, contact your respective Federal CSBG Program Specialist. Please copy CSBGStates@acf.hhs.gov on all email correspondence.

Thank you for your attention and OCS looks forward to continuing to provide high quality services to OCS grantees.

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


[1] For the purposes of this communication, the term “states” include the 50 continental states (including Alaska and Hawaii), Washington D.C., Puerto Rico, and territories that are eligible for CSBG funds, including American Samoa, Guam, Northern Mariana Islands, and US Virgin Islands.

[2] Group B (as applicable) and Group C will submit the SF-424M twice this year: 1) as a separate form on September 1, 2020, and 2) through the FFY2021 CSBG State Plan Submission on December 1, 2020.

[3] OCS does not require states to revise their accepted CSBG State Plan and only suggests doing so for major revisions. Major revisions include but are not limited to revising the state’s usage of funds (Section 7), significant proposed changes to state CSBG policies/procedures (Section 3, Section 10, etc.), and/or revising how the state intends to assess Organizational Standards (Section 6).

Current as of: