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CSBG Dear Colleague State Plan Revisions: Second Open Comment Period

Published: March 22, 2018
Audience:
Community Services Block Grants (CSBG)
Category:
Guidance, Policies, Procedures, Dear Colleague Notices

U.S. Department of Health and Human Services
Administration for Children and Families
Office of Community Services
Division of Community Assistance
330 C Street, SW, 5th Floor
Mail Room 5425
Washington, D.C. 20201

www.acf.hhs.gov/programs/ocs/programs/csbg

Community Services Block Grant
Dear Colleague Letter

Re: CSBG State Plan Revisions: Second Open Comment Period

Date: March 22, 2018

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 Plan Application (State Plan). On March 16, 2018, a Paperwork Reduction Act (PRA) notice for public comment was posted to the Federal Register in volume 83, number 52, and page 11753. During the 30-day comment period, and as soon as possible, OCS invites you to review the proposed revised State Plan and submit your comments, as described below. This comment period will close April 15, 2018.

Action Requested – Your Feedback

As per the PRA, OCS is required to seek a renewal every three years. 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."

OCS presented original revisions to the public November 17, 2017 – January 16, 2018. OCS made additional revisions based on the feedback the Network sent during that timeframe. OCS especially invites comments on the additional revisions to the State Plan, detailed in Attachment B (Revisions to the CSBG State Plan). Please include supportive comments as well as suggestions for improvement, to provide a balanced perspective on what works and what needs revision. Please clearly reference your comments by section, question, or page number, as appropriate.

In addition, OCS has added a revised template for a CSBG Eligible Entities Master List, and the instrument for the ACSI survey of eligible entities. The Master List will serve as a tool to update the eligible entities within your state in a more efficient manner, and will populate into the State Plan and the Annual Report. Eligible entities will submit the next ACSI survey in 2019. Please find both documents attached to this letter.

Please submit your comments to infocollection@acf.hhs.gov, as directed in the Federal Register notice, within the 30-day comment period, March 16, 2018 – April 15, 2018. We encourage you to submit your comments as soon as possible, in order to expedite the clearance process.

Revisions to the CSBG State Plan

OCS and the CSBG Network – comprised of CSBG eligible entities, State CSBG Lead Agencies, State CAA associations, national partners, and others – collaborated to modernize and revise the State Plan as part of the performance management and accountability framework for CSBG.[1] In Federal Fiscal Year (FFY) 2016, states submitted their newly streamlined and automated CSBG State Plan through the On-Line Data Collection system (OLDC).

The content, format, and order of this State Plan have remained consistent with the last version. However, there have been small revisions based on technological improvements, such as skip logic (which ensures that states only need to complete certain fields when applicable), pre-population (which loads information on eligible entities from a master list) and cloning (which allows states to revise and edit responses from prior-year state plans). In addition, OCS made original revisions based on your responses in the FFY 2016 and FFY 2017 State Plans, adding clarity and conciseness to the plan.

Clearance Process and Use of the Revised State Plan

At the end of the 30-day comment period, OCS will complete review of all the comments received and make any additional revisions deemed necessary. After which, the Office of Management and Budget (OMB) will review and approve the online State Plan for a three year period (FFY 2019 – FFY 2021). OMB requests about 30 days for their review.

Once OMB approves the revised State Plan and OCS completes the testing of the online form, OLDC will open for states to submit their FFY 2019 State Plan. OCS anticipates OLDC will open July 2, 2019. OCS will provide more details as the opening draws nearer to approval. OCS does not believe that the revised online State Plan will cause additional burden to the states, given the cloning and pre-population features of OLDC and other efficiencies due to the automation and routine use. OCS will provide technical assistance and training for all states to facilitate the submission process.

Since the overall content of the State Plan has not changed significantly, states should proceed with their usual State Plan formulation process prior to final OMB approval. OCS encourages states to consider the revisions of this State Plan, attached here, to plan for their FFY 2019 State Plan submissions.

Additional Information

OCS will host a webinar series to discuss the proposed revised State Plan and the comment process in the upcoming months. Please find the schedule for the webinar here. The webinar entitled Great! We Made It! will discuss the final revisions to the CSBG State Plan based on your feedback.

If you have questions, please contact your OCS CSBG program specialist as listed on the OCS website. OCS also asks that you copy CSBGStates@acf.hhs.gov on any correspondence to ensure a prompt response.

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.

J. Janelle George                                          Seth Hassett
Acting Director                                              Director, Division of Community Assistance
Office of Community Services                      Office of Community Services

Attachment A: Revised CSBG State Plan
Attachment B: Revisions to the CSBG State Plan
Attachment C: CSBG Eligible Entity Master List
Attachment D: ACSI Eligible Entity Survey


[1] The CSBG Performance Management Framework and Accountability effort includes: 1) organizational standards, 2) state and federal accountability measures, and 3) National Performance Indicators. See Information Memoranda IM No. 138 State Establishment of Organizational Standards for CSBG Eligible Entities and IM No. 144 CSBG State and Federal Accountability Measures and Data Collection Modernization for more information.

Last Reviewed: August 14, 2018