CSBG AT-2020-10 Application for FY 2021 CSBG Funds for Tribes

Community Services Block Grant

Action Transmittal

DCL#: CSBG-AT-2020-10

DATE: August 20, 2020

TO: Tribes and Tribal Organizations

SUBJECT: Application for Fiscal Year (FY) 2021 Community Services Block Grant (CSBG) Based on the Availability of CSBG Funds

ATTACHMENT(S): N/A

PURPOSE: To inform tribes and tribal organizations of the CSBG application requirements for FY2021.

BACKGROUND: The Office of Community Services (OCS) funds Community Services Block Grant (CSBG) grantees based on the determination that their applications and plans are complete in accordance with the requirements of the CSBG Act and regulations. Federally- or state-recognized tribes and tribal organizations may apply for funding under the CSBG Act by submitting an application that meets the requirements of Sections 676 and 677 of the Act. CSBG provides tribes with funds to decrease poverty in communities by providing a range of services and activities to address the needs of tribal members with low income. CSBG has funded core services in tribal communities including employment and training, youth services, health, education (e.g., adult literacy, early childhood development, and drug prevention programs), housing and nutrition.

CSBG focuses on strengthening the efficiency and effectiveness of tribal programs through improved performance measurement, fiscal accountability, monitoring, and reporting. Operation of CSBG in accordance with these applications will be dependent on enactment of Fiscal Year (FY) 2021 appropriations supporting this program.

SUBMISSION GROUPS

Tribes or Tribal Organizations with Accepted One-or Two-Year Plans ending September 30, 2020.

For Tribes that submitted a one-year Tribal plan on September 1, 2019, OCS will consider the FY 2020 plan as a ’Pro-Forma’ FY 2021 plan. The Tribal CSBG Authorized Official must submit a signed letter to the OCS Director by September 30, 2020 affirming that the Tribe’s FY 2020 plan can be considered a “Pro-Forma” plan for FY2021.

For Tribes that submitted a two-year Tribal plan on September 1, 2018, a new Tribal plan is due by December 1, 2020. By September 30, 2020, the Tribal CSBG Authorized Official must submit a signed Letter of Intent to the OCS Director affirming or describing:

• That the Tribal plan will be a one-year or two-year Tribal plan.

Tribes or Tribal Organizations with Accepted Two-Year Plans ending September 30, 2021

For Tribes that submitted a two-year plan on September 1, 2019, an updated SF-424M is required. A CSBG Tribal Plan is not required for the current period.

First Time Applicants/Prospective Grantees: Any federally- or state-recognized tribe or tribal organization that is interested in receiving CSBG funds directly must first contact OCS at csbgtribes@acf.hhs.gov to receive specific instructions.

First-time applicants/prospective grantees should submit the following before completing a CSBG Tribal Plan and Application on or before September 1, 2020:

• Employer Identification Number (EIN); and
• A signed statement of agreement between the tribe or tribal organization and the state confirming the tribal population and the percentage of tribal poverty in the state.

REQUIREMENTS

Submission: On October 1, 2013, the Administration for Children and Families (ACF) directed its program offices, including OCS, to require all mandatory grantees to submit applications electronically. For more information, see 78 FR 60285-60286.

To meet this responsibility, OCS requires tribes and tribal organizations to use the On-Line Data Collection system (OLDC) to submit the Application for Federal Assistance SF-424 Mandatory (SF-424M) form and attach all CSBG Tribal Plan and Application materials. OCS will only consider applications submitted via OLDC. To receive or update access to OLDC, please complete and return the OLDC Access Form.

Application and Plan Due Date: All new tribal CSBG grantees must submit a complete CSBG Tribal Plan and Application no later than September 30, 2020 through OLDC.

Applications submitted later than September 30, 2020, will be ineligible for direct funding from OCS, without written approval from the respective state CSBG office. (The tribe or tribal organization is located in the respective state, and generally, this will be the state CSBG lead agency.) According to CFR Title 45, Part 96.42(e), “Beginning with fiscal year 1983, any request by an tribe or tribal organization for direct funding by the Secretary must be submitted to the Secretary, together with the required application and related materials, by September 1 preceding the federal fiscal year for which funds are sought. A separate application is required for each block grant. After the September 1 deadline, tribal applications will be accepted only with concurrence from the state (or states) in which the tribe or tribal organization is located.” OCS will return to the tribe or tribal organization applications that do not meet the required application criteria stated above.

Application Content and Requirements: Tribes and tribal organizations have the option to revise their FY2020 two-year state plan to documents major revisions, such as a change to allocations or submit a new CSBG State Plan by December 30, 2020. The CSBG Authorized Official must submit a letter to the OCS Director confirming their intent no later than September 30, 2020.

Tribes that submitted a two-year state plan on September 1, 2019 for FY2020 and FY2021; no further action required as it relates directly to the CSBG State Plan. An SF-424M is due September 30, 2020.

Instructions for Tribes or Tribal Organizations submitting a new plan:

CSBG tribes and tribal organizations have the option of submitting CSBG applications covering a one- or two-year period.

1-Year Plans submitted in FY 2020 will cover October 1, 2020 — September 30, 2021 (FY 2021).
2-Year Plans submitted in FY 2020 will cover October 1, 2020 — September 30, 2022 (FY 2021 and FY 2022).

A complete CSBG Tribal Plan and Application should contain the information outlined below. OCS encourages the use of the CSBG Training and Technical Assistance (T/TA) Tool created by Lux and this tool is acceptable as the plan and application. In the case that a grantee prefers to create their own plan and application, OCS requests that the plan follows the outline below.

1. An electronic SF-424M: As described above, each grantee must complete and submit this form through OLDC. The form requires name and contact information for the tribe or tribal organization’s authorizing official and the contact information for the CSBG tribal point of contact.

1. Transmittal Letter: A signed letter that includes the following:

1. The name of the tribe or tribal organization;
2. The fiscal year(s) to be covered;
3. Contact information for the tribe’s authorized official;
4. Contact information for the CSBG program contact person within the tribe; and
5. Delegation of authority by the tribal CEO/Chairman or President (if applicable).

1. Evidence of Public Hearing (Public Review): The applicant should hold at least one public hearing and show evidence that the CSBG Tribal Plan and Application was made available for public review and comment in conjunction with development of the plan, as required by Section 676(a)(2)(B) of the CSBG Act.

1. Tribal Resolution: If appropriate, the application should include a resolution pursuant to 45 CFR 96.42(b): “A tribal organization representing more than one tribe will be eligible to receive block grant funds on behalf of a particular tribe only if the tribe has by resolution authorized the organization’s action.”

1. Federal or State Recognition: CSBG tribal applicants must provide proof of federal or state recognition. If applicable, the application should include documentation according to 45 CFR 96.44(b):“An organized group of Indians is eligible for direct funding based on state recognition, if the state has expressly determined that the group is an Indian tribe. In addition, the statement of the state’s chief executive officer (Office of the Governor) verifying that a tribe is recognized by that state will also be sufficient to verify state recognition for the purpose of direct funding.”

1. Tribal CSBG Administrative Structure: The CSBG Tribal Plan and Application should include a description of the following:

1. Mission and responsibilities of the agency or department within the tribe or tribal organization that will administer CSBG;
2. CSBG goals and objectives; and
3. Planned allocation of CSBG funds.

1. Individual and Community Income Eligibility Requirements: CSBG requires that services be provided to those who meet specific CSBG income guidelines. IM#157 revises the income limit for eligibility ceiling from 125% to 200% of the federal poverty level for CSBG services furnished during fiscal years 2020 and 2021, including services furnished with the state’s regular CSBG appropriations during those years. The CSBG plan must detail the following:

1. Policies and/or procedures for determining eligibility;
2. Policies and/or procedures when individual income verification is not possible or practical; and
3. Description of how the tribe or tribal organization services target and benefit low-income communities for those services that provide a community-wide benefit.

1. Statement of CSBG Assurances: The CSBG Tribal Plan and Application should include the specific programmatic, administrative, and fiscal assurances precisely as they appear in the CSBG Act. Effective FY 2020, all Statement of CSBG Assurances will be valid for two years unless there is a change in the tribal organization and/or tribal authorizing official.

1. Programmatic Assurances: subsections 676(b) (1) (A) — (C) of the CSBG Act.
2. Administrative and Fiscal Assurances: subsections 678D(a)(1)(A) through (B) of the CSBG Act, including certification that cost and accounting standards of the Office of Management and Budget (OMB) shall apply (OMB Circulars A-110 and A-122). If the authorized official has delegated signature authority, a signed confirmation of such delegation by the authorized official must be submitted with the application (as stated in the Action Transmittal Letter).

1. Implementation of CSBG Programmatic Assurances: The CSBG Tribal Plan and Application must include a narrative description of how the tribe or tribal organization will carry out the required programmatic assurances. The narrative should include a description of the following:

1. The CSBG service delivery plan, including information about geographical areas and categories of individuals to be served, description of the distribution of CSBG funds, and a description of the activities to be supported with CSBG funds;
2. The plan for the provision of emergency services;
3. Linkages to fill identified gaps in services;
4. Coordination with other public and private resources;
5. Innovative community and neighborhood-based initiatives; and
6. Performance management and accountability systems.

1. Implementation of CSBG Administrative and Fiscal Assurances: The CSBG Tribal Plan must include a narrative description of how the tribe or tribal organization will carry out the required administrative and fiscal assurances. The plan should detail how CSBG funds are spent on the direct delivery of services and the dates of those services. Provide the date of the most current audit undertaken and the period for which the audit covers, in compliance with the Single Audit Act of 1984 (P.L. 98-502).

1. Assurance on Limitations: The tribe or tribal organization acknowledges and assures that they will abide by the CSBG limitations outlined in Section 678F of the CSBG Act (PDF). (PDF)

1. CSBG Annual Report: The Annual Report is due on December 30, 2020. Annual Reports are required for all Tribes and Tribal Organizations that received the CSBG during FY 2020. The CSBG Annual Report should detail the following:

1. An accounting of how funds were spent on the delivery of services;
2. Information on the number of and characteristics of clients served;
3. Information on the way the CSBG program met its goals and objectives;
4. Information on the types of projects/activities supported by CSBG funds;
5. Information on CSBG accomplishments; and
6. Outcome data that addresses progress toward the implementation of the CSBG national goals.

1. Certifications: The CSBG Tribal Plan and Application must include the four required signed and dated certifications, including the following:

1. Drug-free Workplace (PDF); (PDF)
2. Debarment, Suspension, and Other Responsibility Matters; (PDF)
3. Environmental Tobacco Smoke (PDF);  (PDF)and
4. Lobbying.

Effective FY 2020, all certifications are valid for two years unless there is a change with the tribal authorizing official and/or tribal organization.

TRAINING AND TECHNICAL ASSISTANCE

Since 2011, OCS has supported a training and technical assistance (T/TA) initiative to strengthen tribal and tribal organizations’ administration of CSBG. This T/TA provides information on issues such as regulatory requirements, program administration, and communication to eligible tribal entities. The Tribal T/TA Team develops T/TA tools and products in consultation with tribal representatives and continuously updates the tools to meet the current needs of tribes and tribal organizations.

Applicants who need assistance and are interested in applying for CSBG may contact our tribal support contractor, LUX Consulting, at 301-244-3557 or TribalTA@luxcg.com.

Technical Assistance Tools: Technical assistance tools, including a CSBG Tribal Plan & Application Fillable-PDF Tool & Tool Guide are available to assist grantees in producing the CSBG Tribal Plan and Application materials as required by Section 676 of the CSBG Act. In addition, a webinar series on the CSBG application process is available on the CSBG Tribal Training and Technical Assistance Program website: CSBG Tribal Application TA Tools & Templates .

Please send an email with any questions or requests for additional information to CSBGTribes@acf.hhs.gov. The list of OCS staff and contact information is also on the OCS website at CSBG Federal Staff by Region.

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

/s/
J. Janelle George
Deputy Director
Office of Community Services