CSBG DCL Model State Plan Revision: Open Comment Period

U.S. Department of Health and Human Services
Administration for Children and Families
Office of Community Services
Division of State Assistance
370 L'Enfant Promenade, S.W.
Washington, D.C. 20447
www.acf.hhs.gov/programs/ocs/programs/csbg

Community Services Block Grant
Dear Colleague Letter

Re: CSBG Model State Plan Revision: Open Comment Period

Date: January 29, 2015

Dear Colleagues:

The Office of Community Services (OCS) is requesting feedback from the Community Services Block Grant (CSBG) Network on the proposed revision of the CSBG State Model Plan Application (Model State Plan).  On January 26, 2015, a Paperwork Reduction Act (PRA) notice for public comment was posted to the Federal Register in volume 80, number 16, page 3967.  During the 60-day comment period, and as soon as possible, we invite you to review the proposed revised Model State Plan and submit your comments, as described below.

Modernization and Revisions to the CSBG Model State Plan

Over the last several years, OCS and the CSBG Network — comprised of CSBG eligible entities, State CSBG Lead Agencies, State CAA associations, national partners, and others — have collaborated to create a new performance management and accountability framework for CSBG.  This framework includes 1) organizational standards for eligible entities, 2) accountability measures for States and OCS, and 3) CSBG outcome measures (National Performance Indicators).  These elements are designed to increase accountability across all three levels of the network (Federal, State and local) and enable us to make better program decisions based on data.  Ultimately, this framework will help OCS and the CSBG Network to generate stronger results for the low-income people and communities we serve.

In light of the performance management and accountability effort, OCS has revised, and is in the process of automating, the CSBG Model State Plan to make it easier to submit and more effective as a planning and accountability tool.

The proposed changes to the Model State Plan include:

• Streamlining:  We have retained all the elements of the previous Model State Plan, as required by the CSBG Act, including all of the CSBG assurances, but have simplified, clarified, and streamlined the content.

• Automation:  We are currently creating an online version of the Model State Plan. States will submit their State plan through the Online Data Collection (OLDC) system; the same system States use to submit their annual online application forms (the SF-424 Mandatory).  A streamlined and automated plan will be much easier to use.  For example, automation will allow data to pre-populate elements of the State plans and, eventually, CSBG Annual Reports.  An automated plan will also generate better data for States and OCS to use for performance management and oversight purposes.

• Performance Management Integration: We have revised the Model State Plan to collect critical performance management information on organizational standards and State accountability measures.  This week, OCS published two important Information Memoranda (IM): 1) IM 138, State Establishment of Organizational Standards for CSBG Eligible Entities and 2) a draft IM on State and Federal Accountability Measures and Data Collection Modernization.  These IMs describe the central role of the Model State Plan in implementing these performance management efforts.

The attached document is a representation of the content of the online form, specifically the questions, the answer formats (e.g., check boxes, tables, text boxes), and the order of the information.  The draft includes some automation elements (e.g., instructions, definitions, CSBG Act citations, and State Accountability Measures), and information that may pre-populate between sections (e.g., the list of eligible entities).  Keep in mind, the online version of the Model State Plan will look very different from this draft.  In upcoming webinars and training, we will provide draft screen shots to give a better idea of the “look and feel” of the online form.

Your Feedback

We have developed this initial draft Model State Plan in consultation with a representative group of stakeholders, including our information technology team and a small group of State CSBG administrators.  Now we need your input.

The Federal Register notice requests feedback on the following:

“(a)   Whether the proposed collection of information is necessary for the proper performance of the functions of the agency, including whether the information shall have practical utility;

(b)     The accuracy of the agency’s estimate of the burden of the proposed collection of information

(c)     The quality, utility, and clarity of the information to be collected; and

(d)     Ways to minimize the burden of the collection of information on respondents, including through the use of automated collection techniques or other forms of information technology."

We especially invite comments on the content, format, and order of the information in the revised Model State Plan.  Please include supportive comments as well as suggestions for improvement, so that we can get a balanced perspective on what works and what needs revision.  Please clearly reference your comments by section, question, or page number, as appropriate.  We welcome automation suggestions as well, particularly from those who are familiar with OLDC or other online systems.

Please submit your comments to infocollection@acf.hhs.gov, as directed in the Federal Register notice, within the 60-day comment period that began January 26.  We encourage you to submit your comments as soon as possible, in order to expedite the clearance process.

Clearance Process and Use of the Revised Model State Plan

At the end of the 60-day comment period, OCS will complete review of any remaining comments and submit a revised Model State Plan to the Office of Management and Budget (OMB).  Concurrently, OCS will complete the automated version of the Model State Plan.  During the second phase of the PRA process, which includes a 30-day comment period, OMB will review and approve the online Model State Plan for a three year period.

Once OMB approves the online Model State Plan and we complete the testing of the online form, States will use the new system to submit their State plan for Federal Fiscal Year (FY) 2016.  While States may need additional time to complete the new form in the first year, we expect this burden to be significantly reduced in subsequent years.  OCS will provide technical assistance and training for all States to facilitate the transition to the online form.

States should proceed with their usual State plan formulation process even as we wait for final OMB approval.  We encourage States to consider the draft version of the Model State Plan, attached here, to plan for their FY2016 State plan submissions.

Additional Information

OCS will host a webinar series to discuss the proposed revised Model State Plan and the comment process in February 2015.

If you have questions, please contact an OCS CSBG program specialist.  The list of OCS staff and contact information is posted on the OCS website at www.acf.hhs.gov/programs/ocs/resource/csbg-staff-assignments-by-region.

Thank you for your commitment to increase accountability across the CSBG Network.  Together we can help lift people and communities up and out of poverty.

Jeannie L. Chaffin                                                   Seth Hassett
Director                                                                      Director, Division of State Assistance
Office of Community Services                               Office of Community Services