CSBG Dear Colleague 2020-14 Community-Level Transformation (Module 3) Guidance

Publication Date: February 21, 2020

Dear Colleagues,


This guidance provides the following:

  1. Information about an additional Quality Assurance Year for Module 3;
  2. Operational definition of Community-Level Transformations[1] Visit disclaimer page in the Community Services Block Grant (CSBG); and
  3. Phases of Community-Level Transformations and when to submit Module 3 of the CSBG Annual Report based these phases.

Additional Quality Assurance Year

Efforts to address community conditions that contribute to the cycle of poverty have been a key expectation for Community Action Agencies for over 50 years starting with the original Economic Opportunity Act of 1964[2] Visit disclaimer page . Beginning in 2012, as part of its development of a new comprehensive Performance Management Framework for CSBG, OCS began work to create new tools and methodologies for documenting the activities and results of community-level transformations.

In 2016, as part of a comprehensive overhaul of CSBG reporting requirements, OCS obtained clearance for a new CSBG Annual Report that included a new tool for documenting community-level initiatives. Known as “Module 3,” this tool allows CSBG eligible entities to report on efforts intended to achieve community-level outcomes.

In 2018, OCS announced a staged implementation for Module 3, in which the first year of submissions (FY 2018 reporting period) would be considered part of a quality assurance year[3] Visit disclaimer page . After receipt and review of its first round of submissions, OCS noted significant variation in the range of activities, timelines, and understanding of community-level activities. In part, this was the result of an overly general description of community initiatives. While OCS and its technical assistance partners have provided significant technical assistance since the creation of Module 3, we concluded that OCS needed to:

  1. Issue a new operational definition and more specific parameters for reporting in Module 3;
  2. Provide an additional quality assurance year with emphasis on state review of Module 3 submissions prior to submission to OCS; and
  3. Emphasize that the annual report should only include community-level transformations that are in an active implementation phase.

Therefore, OCS decided that FY2019 submissions would be considered part of a second quality assurance year. As part of this ongoing effort, OCS will continue to review and refine its guidance and technical assistance support for community-level efforts. The operational definition and guidance on when to report using Module 3 is provided below.

Operational Definition of Community-Level Transformations in CSBG

For the purpose of reporting within Module 3 as part of the CSBG Performance Management Framework, OCS is providing the following operational definition for Community-Level Transformations in CSBG:

A community-level transformation is a project designed to create measurable community-wide improvement affecting one or more cause or condition of poverty within a defined geographic area. The project has clearly defined and measurable goals and one or more strategic activities designed to achieve that goal. The CSBG eligible entity must be an active participant with a clearly defined role that complements those of any other organizational partners with the necessary expertise and capacity to affect change in community conditions.

Phases of Community-Level Transformations and When to Submit

While there are many potential steps in the development of community-level transformations, for the purposes of this guidance, OCS focused on four phases for the purpose of reporting in Module 3: (1) formative, (2) formal planning, (3) active implementation, and (4) maturity. These phases, along with reporting expectations for Module 3, are described below.

  1. Formative Phase — This phase refers to any community-level efforts that are in the early stages of development and may include community needs assessment work, focus groups, consensus-building meetings, “brainstorming” work with multiple organizational stakeholders to identify issues and discuss potential solutions, and early planning meetings to identify potential collaborative activities.

Do not submit: Eligible entities should not complete and submit Module 3 at this phase of work since there is no agreement or commitment to clearly defined and measurable goals, and strategic activities designed to achieve that goal. Eligible entities may choose to seek technical assistance at this phase.

  1. Formal Planning Phase This phase refers to a work process in which the eligible entity is actively engaged (either in a leadership or clearly-identified supportive role) in a community-level planning effort in which there is general agreement upon one or more cause or condition of poverty in the community as well as a commitment by the eligible entity and any necessary community partners to identifying and implementing strategies to address the identified issues. The participating organizations may have identified initial resources to support the planning effort and at minimum have committed necessary staff time for the planning and design of new community-level solutions. At the initiation of this phase of work, an eligible entity may develop a draft Module 3 submission and may consult with other community stakeholders, the state, and seek technical assistance in identifying potential community-level strategies and applicable performance measures. OCS recognizes that many planning efforts will require mid-course adjustments and that even after an initial year of implementation there may be changes in performance management information.

Submit to the state[4] Visit disclaimer page : An eligible entity should develop and submit Module 3 for state review once there is general agreement on clearly defined and measurable goals and a commitment among any necessary organizational partners to implement strategies to achieve that goal.

  1. Active Implementation Phase — During this phase of work, the eligible entity and any organizational partners have launched necessary working groups, developed a formal plan of action with an ultimate goal, and established shared metrics (indicators, measurements, and a shared approach to collecting and analyzing performance data). While organizational partners may be working to identify and secure additional resources for the effort, there is an initial commitment of resources, identification of organizational roles, and at least one agreed-upon strategy for accomplishing common goals. The eligible entity is an active participant and has a clear role in implementation efforts.

Submit to OCS: Once a community-level transformation is ready to move into active implementation, an eligible entity should again submit the Module 3 report to the state. After review, the state should submit the Module 3 report to OCS. The state may seek additional technical assistance prior to submitting[5] Visit disclaimer page . The eligible entity should submit updates on an annual basis until maturity, and the state should provide updates to OCS.

  1. Maturity Phase — When an eligible entity and any community partners have successfully implemented a community-level strategy, an effort may reach a “maturity level” in which the initial or ultimate goal(s) has been accomplished and the ongoing effort is focused on sustaining outcomes. For example, an effort to address a shortage of affordable housing may have reached its initial goal(s) of creation of a specified number of affordable housing units or a job creation effort may have successfully created new employment opportunities.

Final Submission to OCS: An eligible entity should submit Module 3 for a final year. In the case that the initial goal was not reached for whatever reason, such as lack of funding or a change in the needs of the community, the eligible entity should submit Module 3 for a final year. In the case that a new goal(s) is defined and agreed-upon, the eligible entity may submit a new community-level transformation once it is in the Formal Planning Phase.

Documenting Adjustments

OCS recognizes that many community-level efforts may undergo mid-course adjustments and may need to respond to new and changing community conditions. Therefore, eligible entities that submit reports under Module 3 may need to make adjustments to goals, measures, and strategic plans, especially if a community-level transformation takes place over multiple years. Therefore, at the outset of a community-level transformation, there should be a commitment to a formal process for adjusting and documenting changes and reporting these changes in Module 3.

The eligible entity should not submit Module 3 after what is deemed the final year of submission, but may document ongoing maintenance of effort in Module 2 or Module 4 if appropriate. If a community-level transformation was not able to accomplish its goals, or is suspended or modified in a way that it is no longer addressing the originally-identified problem area (cause or condition of poverty), eligible entities should document these efforts in a final submission since there may be important lessons learned for future efforts.

State Checklist

State CSBG lead agencies play a critical role in the oversight of performance management activities in CSBG. OCS will review submissions under Module 3 after a state review and quality assurance process. Eligible entities should use the attached checklist to assess whether a Module 3 submission is complete[6] Visit disclaimer page . States should also use the checklist prior to submitting Module 3.

Additional Guidance and Technical Assistance

For more background information about these efforts, please see the attachment Background on Community-Level Transformations and the CSBG Performance Management Framework.

As noted above, OCS is committed to a continuous improvement approach to individual, family and community level improvements to address the causes and conditions of poverty. OCS will issue additional instructions for annual submission of Module 3 via Action Transmittals or “Dear Colleague” letters. Eligible entities are encouraged to seek input and/or technical assistance from State CSBG Lead Agencies, State Community Action Associations, Regional Performance and Innovation Consortia (RPICS), national technical assistance providers, and OCS staff regarding potential implementation plans. Any future adjustments to data collection requirements will undergo clearance by the Office of Management and Budget (OMB) and include an opportunity for public input.

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

J. Janelle George
Acting Deputy Director
Office of Community Services

[1] Visit disclaimer page Please note that while earlier materials have generally discussed “community initiatives,” OCS will adapt future materials to focus on “Community-level Transformations” to emphasize that projects reported in Module 3 are in an active implementation phase to address a specified community need.

[2] Visit disclaimer page The full text of the original Economic Opportunity Act is available online on the following website: https://www.govinfo.gov/content/pkg/STATUTE-78/pdf/STATUTE-78-Pg508.pdf Visit disclaimer page

[4] Visit disclaimer page OCS recommends that the state define a date for eligible entities to submit to the state outside of the CSBG Annual Report submission period. This date should allow the state enough time to review, provide feedback, and seek additional technical assistance, as needed.

[5] Visit disclaimer page OCS recommends that the state lead agency define a date for eligible entities to submit to the state lead agency outside of the CSBG Annual Report submission period. This date should allow the state enough time to review, provide feedback, and seek additional technical assistance, as needed.

[6] Visit disclaimer page Complete: the eligible entity is able to complete at least 1 — 12 of the Community Initiative Status Form.

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