CSBG-DCL-2023-15 Hurricane Preparedness and Response FY 2023

Community Services Block Grant

Dear Colleague Letter

DCL#: CSBG-DCL-2023-15

DATE: June 2, 2023

TO: CSBG Network

SUBJECT: Use of CSBG to Address Hurricane Preparedness and Response

ATTACHMENT(S): N/A

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Dear Colleague,

The National Oceanic and Atmospheric Administration (NOAA) predicts up to nine hurricanes during this Atlantic hurricane season. The Office of Community Services (OCS) is committed to ongoing partnership with Community Services Block Grant (CSBG) state, territory, and tribal lead agencies, CSBG eligible entities, and other agencies involved in major disaster recovery efforts that are consistent with the purpose and allowable uses of CSBG funding. The purpose of this communication is to remind CSBG lead agencies and eligible entities of the flexibilities of CSBG as well as other resources to support hurricane preparedness and response. In addition, this guidance is a supplement to CSBG IM #154 Disaster Flexibilities and Waivers.

To ensure an efficient response to community needs before, during, and after disasters, OCS supports state and community efforts in planning for and removing disaster recovery barriers. Throughout the CSBG Network, a critical goal is meeting the needs of all individuals and families affected by unforeseen circumstances due to a disaster, including those with disabilities, seniors, families affected by disasters (including unexpectedly displaced individuals and families), those without access to fresh food, potable water, or other immediate family needs.

INVOLVEMENT IN IMMEDIATE RELIEF EFFORTS

CSBG eligible entities serve a critical role in supporting individuals and families with low incomes through the course of major disasters. In response to a disaster, areas of priority for immediate support for CSBG eligible entities may include:

• Central Point of Services — In many communities, CSBG eligible entities serve as a central point for community-based services. CSBG lead agencies and CSBG eligible entities are encouraged to support families in accessing local, state, and federal relief, including exercising the inherent block grant flexibility to redirect CSBG funding to address emergency needs.
• Access to Facilities for Urgent Needs — CSBG eligible entities that have operable facilities may support supervised access to those facilities, including to kitchens, rest areas, computer labs, bathrooms, laundry, and power sources for re-charging phones and other communication devices.
• Connection and Referral — CSBG eligible entity program staff can support families in meeting basic needs, including nutrition, health, and mental health support, and in sharing information regarding alternative or supplementary non-government organization (NGO) providers and non-profit organizations for immediate aid.

ADMINISTRATIVE FLEXIBILITIES

Built into CSBG is administrative flexibility for efficiently and effectively meeting the immediate needs of individuals, families, and communities with low-income following a disaster.

Eligibility Determination
Section 673(2) of the CSBG Act specifies that the Federal Poverty Line (FPL) shall be used as a criterion of eligibility in CSBG and that the state may revise the poverty line to not exceed 125 percent of the official poverty line.^[1]  While no federal waiver exists for this requirement, states have substantial discretion in defining the procedures for determining if an individual or family meets the requirements, including the timeframes for review and the necessary documentation appropriate to the services or strategies being implemented.

As noted in CSBG IM #154 Disaster Flexibilities and Waivers, in a disaster, CSBG lead agencies may consider circumstances where individuals may experience low-incomes due to the disaster, including disaster-related unemployment, and may establish appropriate procedures based on individual and family needs. CSBG lead agencies are encouraged to review existing procedures and to establish emergency procedures to streamline the eligibility determination process following a disaster. If a displaced individual or family does not have immediate access to the eligibility documentation, emergency procedures may include flexibility in accepting signed statements attestations to the necessary eligibility information pending future availability of necessary documents.

Funding

Given CSBG’s block grant structure, CSBG lead agencies have the flexibility to rapidly adjust current programs and/or implement new programs to respond to disasters without obtaining prior approval from OCS. An example may be the shifting of CSBG funds to provide mortgage assistance following a disaster to support individuals and families in retaining their homes (see Information Memorandum #163 Mortgage Payment Assistance). Although prior approval is not required, CSBG lead agencies are encouraged to contact their assigned CSBG Program Specialist if significant policy or program changes are occurring.

Additional funding for disasters is not readily available within CSBG appropriations. However, federal funding may be provided to support CSBG eligible entity services through disaster supplemental appropriations. Within existing allocations, CSBG funding may be used to support disaster response, if it aligns with the statutorily allowable activities.

Waiver Requests

Under the CSBG Act, Section 678F (Limitation on Use of Funds) indicates that CSBG funds may not be used for the purchase or improvement of land, or purchase, construction, or permanent improvement (other than low-cost residential weatherization or other energy-related home repairs) of any building or facility. Concurrently, Section 678F(a)(2) of the CSBG Act allows the Secretary of the Department of Health and Human Services (HHS) to waive restrictions on the use of CSBG funds for purchase or improvement of land, or the purchase, construction, or permanent improvement of property in extraordinary circumstances and if doing so will contribute to the ability of the state to carry out the purposes of the grant.

OCS will consider expediting responses to waiver requests for emergency repairs to service facilities directly impacted by a disaster and for repairs that are not covered by other federal disaster assistance or sources such as assistance through the Federal Emergency Management Agency (FEMA) or property insurance. The responsible CSBG official must submit a waiver request describing the extraordinary circumstances that justify the waiver and how the waiver will contribute to the ability to meet and carry out the purposes of CSBG in disaster circumstances. The waiver request must be signed by the CSBG Authorizing Official and addressed to the Secretary of HHS with attention to the Director of OCS. Prior to submission of a waiver request, CSBG lead agencies should assist CSBG eligible entities in identifying and accessing all other available sources of support. Use of CSBG funds under this waiver creates a reversionary federal interest in the property, and requirements for a Notice of Federal Interest will be included in a waiver approval.

RESOURCE GUIDES ON EMERGENCY PREPAREDNESS AND RESPONSE

In September of 2022, OCS released its The Disaster Flexibilities Hub [ ^[2]  to support CSBG grant recipients, individuals, and families during emergencies and natural disasters. The Disaster Flexibilities Hub is an information management tool that visually tracks and displays key data, guidance, and resources on declared disasters, disaster preparedness efforts, and the flexibilities built into OCS’ block grant programs. The hub includes spotlight videos showcasing how OCS grant recipients have utilized program flexibilities during water crises, heat waves, hurricanes, floods, and wildfires. It also includes a tab to help individuals and families find assistance in their communities. For more detail on the Disaster Flexibilities Hub, please see OCS DCL 2022-18 OCS Launches the Disaster Flexibilities Hub and Celebrates National Preparedness Month.

The following additional resources are available from federal sources to assist programs, individuals, and families in preparing for and responding to future emergencies or disasters:

• The Office of Human Services Emergency Preparedness and Response (OHSEPR) website provides up-to-date information on a myriad of topics including ways to ensure equity when responding to disasters.
• The Federal Emergency Management Agency (FEMA) hosts a webpage to help Get Assistance After a Disaster , connecting individual citizens and public groups with assistance programs to help support disaster recovery.
• The Centers for Disease Control and Prevention’s (CDC) Natural Disasters and Severe Weather  webpage provides several resource guides and tip sheets related to natural disaster and severe weather preparedness and response, including information on Coping with a Disaster or Traumatic Event .
• The Department of Homeland Security (DHS) provides a series of tip sheets and checklists for Disaster Preparedness and Response , including resources for preparing and speaking with children about natural disasters. 
• The Substance Abuse and Mental Health Services Administration (SAMHSA) provides several behavioral health resources for Disaster Preparedness, Response, and Recovery . In addition, SAMHSA’s Disaster Distress Helpline , 1-800-985-5990, is a 24/7, 365-day-a-year, national hotline dedicated to providing immediate crisis counseling for people who are experiencing emotional distress related to any natural or human-caused disaster. This toll-free, multilingual, and confidential crisis support service is available to all residents in the United States and its territories.
• Psychological First Aid  is an evidence-informed approach for assisting children, adolescents, adults, and families in the aftermath of disaster. The field manual developed by the National Child Traumatic Stress Network (NCTSN) includes handouts for parents, caregivers, as well as children from birth to 5-years-old.

In preparation for the upcoming hurricane season, we encourage the CSBG Network to review the Human Service Needs and Disaster Displacement report (PDF) published by the ACF Office of Planning, Research and Evaluation (OPRE) discussing the critical human services needs people face in the wake of a disaster — such as housing, income support, transportation, employment and education.

In the case of a disaster, please contact your CSBG Program Specialist at the Division of Community Assistance (DCA), as well as CSBG training and technical assistance (T/TA) national partners for T/TA or to answer questions regarding administrative flexibility and waiver requests.

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