CSBG DCL-2021-19 CSP: 30 Day Comment Period

Publication Date: July 8, 2021

Community Services Block Grant

Dear Colleague Letter

DCL#: CSBG-DCL-2021-19

DATE: July 8, 2021

TO: CSBG Grantees

SUBJECT: CSBG State Plan: 30-Day Comment Period (FRN 2)

ATTACHMENT(S): CSBG State Plan Template 3.0, CSBG State Plan Fillable Tool, ACSI Survey, CSBG Eligible Entity List


Dear Colleagues,

The Office of Community Services is requesting feedback from the Community Services Block Grant (CSBG) Network on the proposed revisions to the CSBG State Plan Application (State Plan), CSBG Eligible Entity List (formerly the CSBG Eligible Entity Master List), and the American Customer Satisfaction Index (ACSI) Survey for CSBG Eligible Entities. On June 28, 2021, the Office of Management and Budget (OMB) published the second notice for public comment on these forms, which is available here Visit disclaimer page .

As described in the published second notice, send written comments and suggestions directly to the Office of Management and Budget, Paperwork Reduction Act Visit disclaimer page Find this information collection by selecting “Currently under 30-day Review—Open for Public Comments” or by using the search function.

As noted, “OMB is required to make a decision concerning the collection of information between 30 and 60 days after publication of this document in the Federal Register. Therefore, a comment is best assured of having its full effect if OMB receives it within 30 days of publication.”

CSBG State Plan 60-Day Comment Period

OCS originally presented these revisions to the public April 26, 2021 — June 25, 2021. During the notice and comment period, OCS received one set of comments from two commenters. The comments and OCS’ responses are below:

  1. 5.1. CSBG Eligible Entities. The CSBG Eligible Entity list in the State Plan should include the same fields as in the Master List so states can easily see if they need to make revisions. Also, the process for making revisions is not clear. The note under chart 5.1 of the State Plan states that all revisions should be made in the Master List, but the State Plan document provides for the opportunity for the states to add rows and provide detail on changes to the list. Providing the information twice is unnecessary. Changes should be made only in the Master List.

OCS Response:

OCS reviewed the comment and believes that the question should remain as is, -however, OCS will provide additional training and technical assistance. OCS also reviewed the instructions associated with the question. The instructions indicate that CSBG state lead agencies must update the Master List to revise 5.1. and are unable to add rows or edit this information within the CSBG State Plan.

  1. 7.9. Remainder/Discretionary Funds: The chart describing how a state plans to use their remainder/discretionary funds is not clear and unnecessary. While the CSBG Act requires states to provide a “description of how the state intends to use discretionary”, there is no requirement that a state provide the exact dollar amount that they plan to spend on various activities. Dollar amounts outlined in these charts are created prior to final allocation, and therefore provide little utility to states or OCS. To fulfill the requirement of the Act and reduce burden on states, we recommend OCS revise this chart to request states to identify the planned percent of state allocation (up to 10%) to support discretionary activities, identify which of the fund uses their discretionary allocation will support via check boxes with an optional narrative, and eliminate the specific dollar amounts from this chart. Adjusting the chart to be reflective of these changes will help to reduce burden for states and improve quality of the data obtained. Should this type of edit not be possible, OCS could consider specifying that dollar amounts included in this chart are projections only and may be subject to change once a state has its final allocation or as state needs and priorities change.

OCS Response:

OCS reviewed the comment and determined that the question should remain the same. Per, the CSBG Act, Section 676(2)(B), CSBG state lead agencies are required “to provide to the public an opportunity to comment on the proposed use and distribution of funds”. OCS interprets this as providing the intended use of funds, including the proposed dollar amount for all activities. OCS will continue to provide training and technical assistance to address this area.

  1. 8.1 Training and Technical Assistance Plan. The instructions need clarification as to what CSBG funds should be included in this chart. The explanation document states that OCS “revised this question to request information about all trainings supported by CSBG and the state lead agency…”; it is unclear if this includes RPIC funds and the coordination between the activities in that plan and the T/TA described in this section. OCS could clarify by clearly stating this chart is specific to training and technical assistance funded with any funds from the state’s CSBG allocation.

OCS Response:

OCS revised the question to provide additional clarity that CSBG state lead agencies should only provide T/TA activities as funded by the CBSG mandatory grant, funded by either administrative or remainder/discretionary funds, as described under Section 7 of the CSBG State Plan. OCS will continue to provide training and technical assistance.

  1. 9.2 State Linkages and Coordination at the Local Level. While OCS states the intent of the question remains unchanged, we feel the revised language substantially changes the question asked. The original question asks states to describe the linkages and coordination the state intends to create or maintain, while the new question is asking the state to describe how it will encourage partnerships and collaborations. Creating partnerships and collaborations denotes a different level of engagement from both partners than creating linkages and coordinating services. Linkage and coordination are the terms used within the CSBG Act; linkage and coordination are also the terms used within the CSBG Annual Report. Furthermore, the revised question removes language that specifies states should link and coordinate with antipoverty programs, which a specific assurance within the CSBG Act. To assure alignment of the State Plan with the CSBG Act and the CSBG Annual Report, OCS should use the existing language for this question.

OCS Response:

OCS reviewed the comment and believes that the question should remain the same. In the past several years, CSBG state lead agencies requested that OCS provides more clarity in their interpretation of the CSBG Act. This is OCS’ first step in providing additional clarity to the intent of this question. OCS does not agree that this changes the intent of the question. OCS will continue to provide training and technical assistance to ensure that the question aligns with the intent of the CSBG Act.

  1. 9.3 State Assurance of Eligible Entity Linkages and Coordination. OCS’ revision added language that requires eligible entities collaborate with public and private sector organizations, however the assurance referenced requires that eligible entities create linkages between government and other social services programs. We recommend OCS use the existing language for this question to align with the CSBG Act.

OCS Response:

OCS reviewed the comment and believes that the question should remain the same. In the past several years, CSBG state lead agencies requested that OCS provides more clarity in their interpretation of the CSBG Act. This is OCS’ first step in providing additional clarity to the intent of this question. OCS does not agree that this changes the intent of the question. OCS will continue to provide training and technical assistance to ensure that the question aligns with the intent of the CSBG Act.

  1. 9.9. Communication with Eligible Entities and the State Community Action Association. While we see the value in supporting states to think strategically about their planned communication with their networks, this table is cumbersome, complicated, and creates undue administrative burden for State Offices. This table could be simplified and still gather much of the same information by including a checklist for methods, frequency, and topics with a short narrative description of the communication plan.

OCS Response:

OCS reviewed the comment and adjusted the table to remove the add-a-row function. OCS will not implement additional changes as we determined the changes that the commentators proposed will result in increasing the burden to states because the state would need to respond to multiple questions, and provide a narrative text describing the different topics of communications. OCS will continue to provide training and technical assistance.

  1. 10.13a Federal Investigation Policies. This is an unnecessary additional question to the Assurance on Federal Investigations. States already certify and provide assurance that they will permit and cooperate with federal investigations; there is no further requirement for state procedures. There is no requirement that states create a policy for how they comply with a federal investigation. In the case a state became subject to a federal investigation, the federal government would be responsible for detailing the procedures and requirements for the state to cooperate with the investigation, which would supersede any state policy. Requiring a state create such a policy is therefore unnecessary and could create unnecessary confusion should a state be subject to a federal review. 

Further, it is unclear why any state procedure around permitting, and cooperating would need to be included in state monitoring policies of local CAAs as suggested by this question. If OCS will require such a policy, it would be helpful to define what is meant by a “federal investigation” and how this is different than monitoring of local CAAs.

OCS Response:

OCS reviewed the comment and believes that the question should remain. The purpose is to inform OCS whether the CSBG state lead agency includes this information in their policies. If the CSBG state lead agency indicates “yes”, the CSBG financial analyst can look for this information. OCS does not believe this adds additional burden to CSBG state lead agency, while also providing additional information to OCS. OCS is not requesting that the CSBG State Lead Agency takes any additional action.

  1. 10.13b Closing Findings Procedures. The title does not match the question; if OCS will require such a policy, it should be renamed to more appropriately align with the question being asked about procedures to permit and cooperate with federal investigations. Also, this question should be a subset of 10.13a. The [agency] does not believe this policy is necessary and creates undue and unnecessary burden on states.

OCS Response:

OCS removed this question in response to the comment.

OCS also reverted 6.4a to its original format. OCS did not make any additional revisions to the CSBG State Plan.

Training and Technical Assistance

OCS is preparing a webinar schedule to provide additional training and technical assistance for the CSBG State Plan and the CSBG Eligible Entity List.

Additionally, attached a fillable version of the CSBG State Plan for CSBG state lead agencies to use as a tool for CSBG grantees as they plan for the administration of CSBG for Fiscal Year (FY) 2022. CSBG grantees can use this tool for planning purposes including, but not limited to: consultation with stakeholders, and meeting public and legislative hearing requirements (Section 676(a)(2)(B) and Section 676(a)(3) of the CSBG Act). Please see more instructions about the purpose and use of this tool on Page 2 of the attachment.

Thank you for your attention to these matters. 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

Files

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