CSBG-DCL-2021-23 Reminder of COVID-19 Related Flexibilities and Respective Timeframes

Community Services Block Grant

Dear Colleague Letter

DCL#: CSBG-DCL-2021-23

DATE: August 13, 2021

TO: CSBG Network

SUBJECT: Reminder of COVID-19 Related Flexibilities and Respective Timeframes

ATTACHMENT(S): N/A

Dear Colleagues,

This guidance serves as a reminder regarding the timeframes of available flexibilities issued by the Office of Management and Budget (OMB) and the Administration for Children and Families in response to the pandemic.

RELATED REFERENCES

Community Services Block Grant Act, 42 U.S.C. 9901 et seq.; Coronavirus Aid, Relief, and Economic Security Act, 2020, Public Law 116-36

BACKGROUND

Community Services Block Grant (CSBG) Coronavirus Aid, Relief, and Economic Security Act (CARES Act) Funds provided $1 billion in supplemental  funds to states, territories, and tribes authorized under the CSBG Act. These funds were intended to address the consequences of increasing unemployment and economic disruption as a result of the Coronavirus Disease 2019 (COVID-19). The CARES Act allowed for an increased eligibility level of up to 200 percent of the federal poverty level (FPL).

ELIGIBILITY THRESHOLD OF 200% FPL

As detailed in IM 2020-57 “Immediate Guidance on COVID-19 Response,” the CARES Act authorized states to revise the income limit for eligibility from 125 to 200 percent FPL for CSBG services furnished during fiscal years 2020 and 2021, including services furnished with the state’s regular CSBG appropriations during those years (italics added). 

As included in the Terms and Conditions of each grantee’s Notice of Award, the CARES Act provisions regarding the eligibility level end on September 30, 2021. Therefore, beginning October 1, 2021, income eligibility for CSBG CARES and for regularly appropriated CSBG reverts back to a limit of 125% FPL.

OMB FLEXIBILITIES

As a reminder, last year OMB published Memo M-20-17  (PDF)[] and ACF published IM-ACF-OA-2020-02 (PDF) “Important Updates to Administrative Flexibilities.” These memos provided short-term relief for administrative, financial management, and audit requirements; however, these flexibilities expired in 2020.

OPTION TO UTILIZE VIRTUAL MONITORING

Lastly, CSBG grantees have the option to utilize virtual monitoring for the duration of the public health emergency . Please see CSBG IM-2021-160 “Virtual Monitoring” for more detail on ACF’s decision to exercise this authority under the Stafford Act.

For additional resources on CSBG CARES Act funding, implementation, monitoring, and reporting, please visit our CSBG CARES Act Grantee Toolkit. 

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