CSBG-DCL-2022-39 State Plan Preparation FY 2023

Publication Date: June 30, 2022
Current as of:

Community Services Block Grant

Dear Colleague Letter

DCL#: CSBG-DCL-2022-39

DATE: June 30, 2022

TO: CSBG States and Territories

SUBJECT: FFY 2023 CSBG State Plan Preparation

ATTACHMENT(S): CSBG State Plan 3.0, CSBG State Plan 3.0 Fillable

Dear Colleague,

The purpose of this communication is to provide an update on the Community Services Block Grant (CSBG) State Plan clearance and next steps for the Federal Fiscal Year (FFY) 2023 CSBG State Plan.

Revisiting the Purpose of the CSBG State Plan

The CSBG Act, Section 676 (42 U.S. Code § 9908), requires each CSBG state lead agency to submit “an application and State plan … [that]shall contain such information as the Secretary shall require…, including —” how the CSBG state lead agency will guarantee 14 assurances while administering CSBG.

When OCS introduced the CSBG State Plan template in FFY 2015 as part of the Performance Management Framework, the intent was to have CSBG state lead agencies — and the CSBG Network — use the CSBG State Plan as a tool to help plan for the administration of CSBG within the state. This includes guaranteeing the 14 assurances, as specified by the CSBG Act as well as going beyond those 14 assurances to ensure CSBG is administered effectively and efficiently. With input from the CSBG-eligible entities and stakeholders within each state, the CSBG State Plan can be used to establish procedures in the absence of a state regulation or statute — such as designation, de-designation, and termination procedures (CSBG State Plan Items 10.8 — 10.10) — and to further expand on state regulations or statutes to ensure that there are sufficient processes in place.

In addition, OCS uses the information provided in the CSBG State Plan to prepare for monitoring visits, regional calls, and T/TA. Providing specific and detailed information in the CSBG State Plan helps OCS in our efforts to support the CSBG Network, and the overall T/TA Learning Agenda as described in CSBG-DCL-2022-28, Training and Technical Assistance Resources FY 2023.

CSBG State Plan Clearance History

In Fiscal Year (FY) 2021, in accordance with the Paperwork Reduction Act (PRA) , the Office of Community Services (OCS), Division of Community Assistance (DCA) announced proposed revisions to the CSBG State Plan and CSBG Eligible Entity List.

Brief History

  • May 14, 2021: OCS released CSBG-Dear Colleague Letter (DCL)-2021-14, CSBG State Plan: 60 Day Public Comment Period, announcing the proposed revisions to the CSBG State Plan and the CSBG Eligible Entity List, as well as the 60-day public comment period (or Federal Register Notice [FRN] 1) via the Office of Management and Budget (OMB) Federal Register.

NOTE: The American Customer Service Index (ACSI) survey for CSBG-eligible entities is also included as part of this FRN, but OCS did not propose any revisions.

  • July 8, 2021: OCS released CSBG-DCL-2021-19, CSBG State Plan: 30 Day Comment Period describing the next steps of the PRA, the comments received during FRN 1, and OCS’ response to those comments. OCS also committed to providing additional training and technical assistance on what to submit in the CSBG State Plan and how to submit the CSBG State Plan.  
    • Comments Received during FRN 1: OCS received eight (8) comments from two (2) commenters during FRN 1, and our response to each comment is included in the CSBG-DCL-2021-19.
    • Comments Received during FRN 2: OCS received six (6) additional comments from two (2) commenters during FRN 2.
      • Five (5) of the comments reiterated five (5) of the comments received during FRN 1. To view the comments and our responses to those comments, please see CSBG-DCL-2021-19, specifically comments 2, 4, 5, 6, and 7. As a reminder, these comments assert that since the proposed changes are not identified as specific requirements in the CSBG Act, they should not be included in the CSBG State Plan.
        • OCS’ Response: As noted within CSBG-DCL-2021-19, OCS understands the commenters’ concerns, but maintains that the CSBG State Plan is intended to be a tool to help CSBG state administrators administer CSBG and for OCS to effectively support grant recipients and provide federal oversight. As such, there is a need to maintain the proposed changes. OCS will provide further clarity and training and technical assistance in upcoming webinars on these changes.
      • The sixth comment OCS received requested that we add language to the ACSI survey to clarify that the questions are specific to CSBG and not all programs administered by the state.
        • OCS’ Response: As part of the OCS review of training and technical assistance strategies noted in CSBG-DCL-2022-28, Training and Technical Assistance Resources, OCS is also reviewing the content and use of the ACSI survey. Future iterations of the ACSI survey will specify that the survey is specific to the administration of CSBG.
  • August 5, 2021: OCS announced that CSBG state lead agencies will submit their FFY 2022 CSBG State Plan using the version previously approved by OMB (version 2.0) as we had not received OMB approval for CSBG State Plan 3.0. OCS made this announcement in CSBG-DCL-2021-21, FFY 2022 CSBG State Plan Update. This DCL also confirmed the immediate opening of the CSBG State Plan in GrantSolutions to allow CSBG state administrators to submit their FFY 2022 CSBG State Plan by September 1, 2021.

CSBG State Plan OMB Approval and Next Steps

On August 25, 2021, OCS received approval from OMB for the revised CSBG Eligible Entity List (version 2.0), CSBG State Plan (version 3.0), and the ACSI.

CSBG Eligible Entity List

OCS revised the CSBG Eligible Entity List to include two additional data points to identify the Executive Director (or a comparable position) and the website address of each CSBG-eligible entity. This is to ensure that OCS has the most up-to-date information for each CSBG-eligible entity.

Unique Entity Identifier

On April 4, 2022, the U.S. Government implemented the Unique Entity Identifier (UEI), which replaces the DUNS number. According to the U.S. General Services Administration (GSA) , the UEI is assigned by SAM.gov , and “is now the authoritative identifier for those doing business with the federal government. The DUNS Number is no longer valid for federal award identification.” According to GSA, the U.S. Government has implemented the UEI to have one identifier across multiple government systems.

How does this affect the CSBG Eligible Entity List?

In brief, the CSBG Eligible Entity List will eventually need to be revised to include the UEI.

  • Current Status: Currently, the CSBG Eligible Entity List includes the DUNS number for each CSBG-eligible entity. OCS uses the DUNS number as the identifier for each CSBG-eligible entity within the SmartForms, state databases, XMLs, GrantSolutions.gov , and the forthcoming CSBG Performance Management website. OCS included the DUNS number to ensure that if information about the CSBG-eligible entity changes (such as the name), we are still able to track the CSBG-eligible entity to appropriately maintain the data reported within the CSBG Annual Report.

If the CSBG-eligible entity is an established business and already has a DUNS number, the business would technically have both numbers. However, a new business would not be required to procure a DUNS number to do business with the U.S. government, and would receive a UEI during their SAM.gov registration.

  • Immediate Next Steps: We have worked with our Grant Solutions colleagues to ensure there will be no mandated revisions to the CSBG Eligible Entity List for FFY 2023. Unless there are changes to the CSBG-eligible entities within your state between October 1, 2021 — September 30, 2022, OCS requests that you do not revise your CSBG Eligible Entity List prior to the acceptance of your FFY 2023 CSBG State Plan.

OCS will send each state their current list of CSBG-eligible entities no later than Thursday, July 7, 2022, to verify whether a revision needs to be made. NOTE: If you make a revision to this list, you must also update the Executive Director and website for each entity.

  • Longer Term Next Steps: OCS will submit a non-substantive change request to OMB to add a column for the UEI to the CSBG Eligible Entity List (see attachment CSBG Eligible Entity List 2.1). The non-substantive change request is a 30-day process in which OMB decides whether the change is truly non-substantive. OCS will request the non-substantive change in July 2022. This will have no effect on the FFY 2023 CSBG State Plan or FY 2022 CSBG Annual Report, but it will have an impact on future plans and reports, which is why we are starting the process so early.
    • Revisions in GrantSolutions.gov: OCS has already begun work with GrantSolutions to update the CSBG Eligible Entity List, which will be available for revisions in FFY 2023, Quarter 2.
    • Revisions to SmartForms, Databases, and XMLs: After receiving the non-substantive change approval from OMB, OCS will work with the National Association for State Community Services Programs (NASCSP) to update all necessary forms in preparation for the FFY 2024 CSBG State Plan and FY 2023 CSBG Annual Report.

CSBG State Plan

OCS revised questions and guidance within the CSBG State Plan for additional clarity and conciseness. However, the intent of these questions did not change. Examples of these revisions is updating the wording to ensure that the word “Plan” is capitalized throughout when referring to the CSBG State Plan, replacing the word “plan” with “intend” to clarify that the question is referring to an “action” the state is taking and not the form itself.

OCS also made some additional revisions to provide further clarity based on feedback and questions that we received from the CSBG state lead agencies during previous submissions:

  • 8.1 Training and Technical Assistance Plan: Based on feedback from the CSBG state lead agencies, OCS revised this question to include all training and technical assistance administered by the state and/or through partnerships and funded either through the state’s administrative or remainder/discretionary funds.
  • 8.2 Organizational Standards Technical Assistance: OCS removed Quality Improvement Plans (QIPs) from this question. Per the CSBG Act, QIPs are intended as the final step before potential de-designation. As noncompliance with the CSBG Organizational Standards are not intended to be the sole reason for the de-designation, OCS removed the mention of QIPs from the question.
  • 9.2. State Linkages and Coordination at the Local Level and 9.3. State Assurance of Eligible Entity Linkages and Coordination: Based on feedback from the CSBG state lead agencies, OCS revised both questions to better clarify OCS’ interpretation of “linkages and coordination.” As OCS has tried to exemplify in the past few years, linkage and coordination is about how the CSBG Network is working with others, within our communities to provide the best opportunities to the individuals, families, and communities that we serve.

OCS also added two new questions to the CSBG State Plan:

  • 7.3a. Distribution Method:  Select the option below that best describes the distribution method the state uses to issue CSBG funds to eligible entities:
    • Reimbursement: A payment made to an entity after expenses have been incurred
    • Advance: A payment made to an entity prior to expenses being incurred
    • Hybrid: Either a one-time advance or advances that are recovered by the state over time
    • Other: A different distribution method that is not defined above. If selected, OCS requests that the state defines their distribution method.

OCS added this question to better define and understand distribution methods across the CSBG Network.

  • 10.13a. Federal Investigation Policies: Are state procedures for permitting and cooperating with federal investigations included in the state monitoring policies attached under 10.2?

OCS added this question to verify whether the CSBG state lead agency has these policies in place. OCS added this question to verify whether the CSBG state lead agency has these policies in place. The DCA Monitoring Team will verify this information prior to future monitoring visits. However, please note states are not required to have these policies in place.

Training and Technical Assistance

To assist you with the submission of the FFY 2023 CSBG State Plan, we have attached to this DCL a fillable form of the CSBG State Plan Version 3.0.

Lastly, to provide additional T/TA on the changes to the CSBG State Plan, what to submit, and how to submit, OCS will host a CSBG State Plan webinar series. For more information about the webinar series, please see CSBG-DCL-2022-35, State Plan Webinar Series FY 2023. The presentations and recordings are available on the CSBG Webinars webpage.

Additional Information

Based on FFY 2022 CSBG State Plan submissions, 26 states are required to submit the FFY 2023 CSBG State Plan. Attached are the list of states that are required to submit new plans. The CSBG State Plan is now available for submission via GrantSolutions.gov .

Thank you for your attention to these matters. 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