State Community Services Block Grant (CSBG) Office Policies and Procedures

Transcription

1 State Cmmunity Services Blck Grant (CSBG) Office Plicies and Prcedures Intrductin The Cmmunity Services Blck Grant Act (CSBG) (49 U.S.C et seq.) was created, T prvide assistance t States and lcal cmmunities, wrking thrugh a netwrk f cmmunity actin agencies and ther neighbrhd-based rganizatins, fr the reductin f pverty, the revitalizatin f lw-incme cmmunities, and the empwerment f lw-incme families and individuals in rural and urban areas t becme fully self-sufficient The CSBG Act mandates certain aspects f hw state CSBG ffices will perate in carrying ut their defined rles as administratrs f CSBG but leaves significant authrity and flexibility in the hands f the states. This respnsibility, which is fulfilled by each state individually, can mre easily be met when the state establishes clear plicies and prcedures fr implementatin f the Act. Backgrund In 2012, NASCSP was requested by its members t prvide guidance, identify cmmn state CSBG plicy and prcedure practices, and identify what shuld be included in a Plicy and Prcedure Manual used by state ffices t administer CSBG. At that time, NASCSP, after cnducting a survey with CSBG state ffices, develped an Issue Brief that cntained recmmended cntents fr a CSBG Plicy and Prcedures Manual. Mre recently, the membership requested an update t that dcument. T that end, a small grup f state ffice representatives frm AR, MN, NE, NV, VA, WA, and WI met in 2017 t review the riginal dcument develped by NASCSP and make revisins. Need fr Plicies and Prcedures A distinctin must be made between plicies and prcedures. Plicies are the rules r guidelines gverning state CSBG peratins while prcedures determine the specific means t implement the plicies. Plicies prvide the state with a methd t ensure cmpliance, set standards that demand high quality, minimize risk, and define peratins. Plicies alne can be subject t interpretatin and implementatin that may nt ensure cnsistency and maintain quality. Fr example, it is a plicy (law) that all Cmmunity Actin Agencies (CAAs) must submit an applicatin fr funding t the state. Withut prcedures n hw the applicatin is t be submitted, each CAA culd submit an applicatin that may r may nt have the cmpnents the state feels necessary t fund the agency. CSBG plicies and prcedures serve fur main purpses: 1) t cmply with the authrizing legislatin f the Omnibus Recnciliatin Act f 1982 (Public Law 97-35), Title VI, Subtitle B (CSBG Prgram), and Title XVII, Chapter 2 (Blck Grant Funds), and its subsequent amendments (Octber 1998, The Cats Human Services Reauthrizatin Act f 1998, Title II Cmmunity Services Blck Grant Prgram), and the blck grant rules issued by the Department f Health and Human Services; 2) t assist states and lcal entities t cmply with the authrizing legislatin f the Omnibus; 1

2 3) t assist states and lcal entities in cmplying with authrizing state legislatin; and 4) t prvide assistance t states in implementing the CSBG Act in a cnsistent manner t ensure quality and minimize risk thrugh nn-cmpliance. Thus, plicies and prcedures are a way t cmmunicate directives in an rganized manner. The develpment f plicies and prcedures is nt a ne-time event. Creating a dcument that just sits n a shelf next t a stagnant strategic plan, is nt adequate. Rather, plicies and prcedures are a living dcument that changes as new infrmatin and issues are identified and practices are adjusted. In additin, plicies and prcedures need t be easily readable and accessible s that they can be readily applied. Appraches Plicies and prcedures cmmunicatin des nt always cme in a single frmat, such as a manual. State CSBG ffices have used a variety f methds t cmmunicate plicies and prcedures. Sme states have pted t publish a CSBG Plicies and Prcedures Manual t cncisely cnvey expectatins t eligible entities while thers have used a cmbinatin f the fllwing dcuments t cmmunicate their expectatins: CSBG Applicatin and State Plan CSBG State Law CSBG Act CSBG Entity Cntracts CSBG Special Terms and Cnditins Additinally, sme states use a frm f memrandums, directives r guidelines, fr the purpse f cmmunicating plicies, prcedures and similar infrmatin t eligible entities. Memrandums r ther tls are ften prepared by state staff, hwever sme states may select t use Office f Cmmunity Services (OCS) issued Infrmatin Memrandum (IM). Cmpliance with these plicies can be a standard prvisin in each CSBG grant cntract. The number and type f memrandums varies frm state t state depending n each state s plicies, prcedures and methdlgy fr management f the CSBG. The fllwing infrmatin prvides guidance t CSBG state ffices regarding what items can be included in a CSBG plicy and prcedures manual. Recmmended Plicy and Prcedure Manual Cntents General: Missin and Purpse f State Office: State Offices shuld establish and cmmunicate the missin and purpse f utilizing CSBG funds in the state. Definitin f Eligible Entity: The state defines and includes definitins f the fllwing: Cmmunity Actin Agency (CAA) CSBG Eligible Entity (CEE) 2

3 Limited Purpse Organizatin (LPO) Migrant/Seasnal Farmwrker Organizatin Tribal Organizatins/Tribes Other Frmula and CEE Allcatins: Describe and cmmunicate the distributin frmula and the current practice fr allcating funds t eligible entities. The state may als want t include the percent f funds used fr administratin and discretinary. Designatin and Re-designatin f Eligible Entities: Establish and cmmunicate prcedures fr designating eligible entities in accrdance with the CSBG Act. Funding Terminatin and Reductins: Establish and cmmunicate prcedures fr terminatin r reductin f CSBG funding t eligible entities in accrdance with the CSBG Act. Cntract/Grant Mdificatin Prcedures: Describe prcedures t secure apprval f cntract amendments, mdificatins r changes in budget line items. These prcedures shuld cver any limitatins n the number f changes during a cntract perid the state wishes t impse, the extent f line item flexibility allwed, any deadlines fr submissin and ther prcedural guidelines. [States may als reference anther dcument that cntains mre specific infrmatin related t these prcedures such as the state cntract] Results Oriented Management and Accuntability (ROMA): Describe the Perfrmance Management Framewrk (State Accuntability Measures, Federal Accuntability Measures, Organizatinal Standards, and the CSBG Annual Reprt) f which ROMA is a cmpnent. Include infrmatin abut eligible entities integrating all the phases f the ROMA cycle int their agency management and administrative prcesses frm cnducting a cmmunity needs assessment, ding agency wide strategic planning, implementing services and strategies, and reprting and analyzing data. Prvide infrmatin abut ROMA Next Generatin, including the Natinal Thery f Change, lcal theries f change, as well as an increased fcus n analysis and use f data. Mnitring: Mnitring Philsphy and Principles: Establish and cmmunicate the state s mnitring principles and guidelines. Mnitring Practices: Develp and cmmunicate the state s mnitring practices and prcesses, including: Mnitring cmpnents and schedule (full n-site reviews) Desk Review prcess Mnitring Reprts Risk Assessment dcument and prcess that is used Annual Organizatinal Standards Assessment prcedures Crrective Actin: Establish and cmmunicate the prcesses, steps, frms, and timelines the state 3

4 ffice uses fr the fllwing: Technical Assistance Plan (TAP) Quality Imprvement Plan (QIP) Refer t IM 116 fr further guidance. Training and Technical Assistance (T/TA): Establish and cmmunicate any training and technical assistance the state ffice prvides, including T/TA prvided in cllabratin with the State Assciatin and ther partners, if applicable. Eligible Entity: Private CAA Bard Cmpsitin: Establish and cmmunicate infrmatin abut what the state expects frm a nnprfit CAA bard and its rles and respnsibilities including: bard cmpsitin requirements demcratic selectin prcess bard functins and respnsibilities, including the plicy rle f the bard, principles f due diligence, bedience and lyalty requirements fr meetings by-laws and cnflicts f interest plicies rientatin f new members and regular training f all members plicies fr filling bard vacancies including recmmendatins fr hw lng a bard seat shuld remain pen prcedures fr petitining fr representatin The Organizatinal Standards specify requirements fr nnprfit bard members that include many f the abve activities such as cnflict f interest plicies, bard training, and bard rientatin. Als refer t the CSBG Act and IM #82. Public CAA Bard Cmpsitin: The manual shuld cntain infrmatin abut public CAA bard cmpsitin requirements and bard functins and respnsibilities. Alng with the abve nted elements fr nnprfit CAA Bards, this sectin shuld include the rle f the public CAA bard in the develpment, planning, implementatin, and evaluatin f lcal CSBG prgrams as specified in the federal CSBG legislatin. As with private CAA bard cmpsitin, the Organizatinal Standards specify requirements fr public bard members that include items such as cnflict f interest plicies, bard training and bard rientatin. Als refer t the CSBG Act and IM #82. Cmmunity Actin Plan: This is smetimes als referred t as an applicatin. Describe the prcess, time frame, and items that shuld be included in the cmmunity actin plan/applicatin. Custmer Privacy: This addresses requirements t prtect the privacy f CSBG custmer 4

5 infrmatin. This shuld be a written plicy and it shuld state hw access t custmer infrmatin by unauthrized persns will be prevented. There are a variety f ways t d this depending n whether the infrmatin is stred in hard cpy r electrnically. An attrney shuld be cnsulted cncerning the prvisins f the Privacy Act that shuld be incrprated int this plicy. [States may wish t reference anther dcument, r sectin, that cntains mre specific infrmatin related t this plicy and prcedure such as the state cntract.] Persnnel Plicy: Establish expectatins that the bard f directrs (nn-prfits nly) develp and apprve written persnnel plicies fr the CAA that has been reviewed by an attrney and apprved by the bard within the last five years, per the Organizatinal Standards. The persnnel plicies shuld include ther standard prvisins such as equal emplyment, discipline, and grievance, jb classificatins, prmtins, training and similar prvisins. In the case f public agency CAAs, the CAA shuld be required t specify the persnnel plicies under which it perates and make thse available t the state CSBG ffice upn request. The Organizatinal Standards specify Human Resurce requirements t meet many f the items abve. Client Incme Eligibility: Establish the client incme eligibility level t be used statewide and what incme eligibility dcumentatin the state will accept t verify husehld incme. The eligibility level must be based upn the federal pverty incme guidelines. Many states use 125% f the federal pverty line. Custmer incme eligibility shuld be updated yearly as the pverty incme levels are revised and released. Client Incme Eligibility Verificatin: The state ffice shuld prvide expectatins n what dcumentatin the state will review t ascertain hw the CAA determines client eligibility. Fr instance, states may want t share their expectatins n hw CAAs cnduct due diligence in the cases f self-declaratin f incme. States may want t refer t the dcument published by CAPLAW n client eligibility. Cnflict f Interest: Establish an expectatin that CAAs have a cnflict f interest plicy. This plicy shuld cver staff, bard members and vlunteers. The plicy shuld fcus upn the preventin f self-dealing where an individual takes advantage f their psitin within the rganizatin t enrich themselves r gain ther advantage. Organizatinal Standard 5.6, specifies a bard member cnflict f interest plicy is required every tw years. Plitical Activity: Establish an expectatin that CAAs have a plitical activity plicy that addresses partisan plitical activity and transprting vters t the plls. Cnsult Sectin 678F (b) f the CSBG Act. States may als want t refer t the CAPLAW Publicatin, D's and Dn'ts f Vter Registratin and the Hatch Act, which restricts plitical activity f emplyees, even if CSBG funds are nt used. Wrkfrce Innvatin and Opprtunity Act (WIOA): Develp and cmmunicate expectatins regarding eligible entity linkages and partnerships t assure training and emplyment activities t individuals with lw-incmes. Refer t Sectin 676 f the CSBG Act. Child Supprt Services and Referrals: Include infrmatin that agencies must infrm single parent families they serve abut available child supprt services and make referrals. Refer t Sectin 678G(b) f the CSBG Act. 5

6 Referrals t Drug Treatment Services: Include infrmatin that if an agency cnducts drug testing n any f its prgram participants, the agency must infrm and refer any participant wh tested psitive t apprpriate treatment services. Refer t Sectin 678G(a) f the CSBG Act. Reprting: Include infrmatin abut the CSBG Annual Reprt. As part f the new Perfrmance Management framewrk, a new CSBG Annual Reprt was develped t better tell the stry f the impact CSBG netwrk has in cmmunities acrss the cuntry. On January 12, 2017, the Office f Management and Budget (OMB) granted apprval fr the CSBG Annual Reprt. The CSBG Annual Reprt cntains fur mdules: Mdule 1, State Administratin, is cmpleted and submitted by CSBG State Offices; Mdule 2, CSBG Eligible Entity Expenditures, Capacity and Resurces; Mdule 3, Cmmunity Level; and Mdule 4, Individual and Family Level, are cmpleted by eligible entities and submitted t the State Office annually [insert date]. The Natinal Perfrmance Indicatrs (NPI) are rganized under three Natinal Gals: Gal 1: Individuals and families with lw incmes are stable and achieve ecnmic security. Gal 2: Cmmunities where peple with lw incmes live are healthy and ffer ecnmic pprtunity. Gal 3: Peple with lw incmes are engaged and active in building pprtunities in cmmunities. [The state may want t include any additinal reprting requirements fr eligible entities and any reprts that the state develps.] CSBG Organizatinal Standards: States establish and cmmunicate infrmatin addressing the Organizatinal Standards, including expectatins f annual assessments, and dcumentatin requirements and prcess fr submitting dcumentatin. Refer t IM 138 State Establishment f Organizatinal Standards. In alignment with OCS s recgnitin that in sme instances and fr sme eligible entities, Organizatinal Standards expected cmpliance may nt be apprpriate. In these specific instances, states may issue exceptins/waivers t certain eligible entities fr specific rganizatinal standards. These agencies culd include Limited Purpse Organizatins, state-funded tribal rganizatins, and Migrant and Seasnal Farmwrker Organizatins. Cmprehensive Cmmunity Needs Assessment: Describe and cmmunicate any state requirements r guidance fr needs assessments. Tribes/Tribal Entities: If CSBG funds are prvided t tribes/tribal entities thrugh the state ffice, prvide any specific state requirements r guidance. 6

7 Fiscal Administrative and Indirect Csts: Define administrative csts. Cnsult the CSBG federal legislatin and OCS IM #37 Definitin and Allwability f Direct and Administrative Csts. States may als want t reference HHS Grants Plicy Statement. Invicing and Requests fr Payment Instructins: Prvide prcess and plicies CAAs and ther grantees are t use t invice fr grant funds. Include requests fr advance payments, deadlines fr final invices, allwable csts (refer t IM #37), line item flexibility, and recvery f csts after a cntract is clsed (if yur state wants t allw this). Emphasize the timely submissin f invices and the need t allw adequate time t prcess the invices by the state ffice. Additinally, states may want t include specific guidelines regarding budget revisin requests. [States may wish t reference anther dcument, r sectin, that cntains mre specific infrmatin related t these plicies and prcedures such as the state cntract] Equipment Dispsitin and Equipment Purchases: Establish and cmmunicate the state s plicies with regard t prcess fr equipment purchases and dispsitin when using CSBG funds. Audit Requirement: Per 2CFR, part 200, sub-part F - Cmmunicate that all eligible entities have an annual Single Audit, cnducted by an independent accunting firm, and submit a cpy f the audit t the CSBG State Office. [States may wish t reference anther dcument, r sectin, that cntains mre specific infrmatin related t this plicy such as the state cntract.] Fidelity Bnds and Insurance: Establish requirements fr fidelity bnds and liability insurance. This shuld include fidelity bnding fr all persns invlved with handling funds and executing financial transactins. Liability insurance shuld include directrs and fficers insurance, vlunteer and special event insurance, emplyment practices liability, and general liability at a minimum. Sme agencies may want t carry ther types f insurance that are specific t prgrams and activities. Presentatin f the Manual: While the cntents f a manual are vital, the clarity f their presentatin als is imprtant. Making the manual useful requires a balance between sufficient detail and accessibility f infrmatin. A multi-vlume, cmprehensive dcument may cntain guidance fr every pssible issue, but may make finding answers t specific questins difficult fr users. The state CSBG ffice shuld determine the level f detail prvided n any given subject and the additinal dcuments that culd be included in the manual such as the CSBG Act and OCS IMs. February,