CSBG ARRA Questions, V.2 5/21/2009

Benefits Enrollment

Q1.      What does the Office of Community Services expect States to include as benefit enrollment coordination activities?  Does it include monitoring?
A.        How States administer benefit enrollment coordination activities may vary, but the Recovery Act states that funds are reserved to support identification and enrollment of eligible individuals and families in Federal, State, and local benefit programs.    For example, benefits enrollment coordination activities may help to: 1) educate the public on the eligibility requirements for the various benefits programs; 2) simplify the process of identifying and enrolling individuals and families eligible for benefit programs; 3) direct individuals and families to the most appropriate program; 4) account for individuals and families whose initial contact is through eligible entities or other non-State agencies; and 5) avoid losing individuals and families before, during and after the referral process. 

Additional references for guidance regarding Federal Benefit programs and eligibility include Information Memorandum (IM) #30 - Guidance on the Interpretation of “Federal Public Benefit” Under the Personal Responsibility and Work Opportunity Reconciliation Act of 1996 (PRWORA), P.L. 104-193 and Summary of Immigrant Eligibility Restrictions Under Current Law As of 2/25/2009, http://aspe.hhs.gov/hsp/immigration/restrictions-sum.shtml.

Routine monitoring of eligible entities would not be an allowable use of benefits enrollment coordination funds, since routine monitoring would not clearly support identification and enrollment of eligible individuals and families in Federal, State, and local benefit programs.    

Q2.      Can more that 1% of the funds be used for benefits enrollment, via CAA funds?
A.        Eligible entities may conduct some types of benefits enrollment coordination activities (e.g. linkages to community services), but the State may not reserve more than 1% of CSBG ARRA funds at the State level for benefits enrollment coordination activities.  The Recovery Act requires that States distribute 99 percent of the Recovery Act allocations to “eligible entities” as defined by Section 673(1) of the CSBG Act.  States are also reminded that pursuant to Section 676(b)(8) of the CSBG Act, “any eligible entity in the State that received [FY 2008 CSBG] funding in the previous fiscal year through a [CSBG] grant … will not have its funding terminated …or reduced below the proportional share of funding the entity received in the previous fiscal year unless, after providing notice and an opportunity for a hearing on the record, the State determines that cause exists for such termination or such reduction, subject to review by [HHS]….”
Q3.      Is it possible to use some of the benefit enrollment coordination funds for coordination of a homelessness prevention data network?
A.        No, this activity would not be allowable without a clear and specific justification of how a data network would support the identification and enrollment of eligible individuals and families in Federal, State, and local benefit programs.   For example, how would a data network: 1) educate the public on the eligibility requirements for the various benefits programs; 2) simplify the process of identifying and enrolling individuals and families eligible for benefit programs; 3) direct individuals and families to the most appropriate program; 4) account for individuals and families whose initial contact is through eligible entities or other non-State agencies; and 5) avoid losing individuals and families before, during and after the referral process. 

Q4.      Can the State use the 1% of ARRA funds to either purchase software specifically designed for benefits coordination and/or training to all CAAs for the benefits coordinator?
A.        Yes, software designed for benefits coordination and/or training to all CAAs for benefits coordination is an allowable use of funds.

 

Administrative Costs

Q5.      The American Recovery and Reinvestment Act of 2009 (ARRA) does not allow States to retain a portion of the Community Services Block Grant (CSBG) funds appropriated under ARRA for State administrative purposes as specified in Section 675C(b)(2) of the CSBG Act.  Are States allowed to use administrative funds from regularly-appropriated (non-ARRA) CSBG funds for administration and monitoring of ARRA CSBG funds?
A.        Within existing funding limits, States may use regularly-appropriated administrative funds from the CSBG grant for general administration and monitoring of all CSBG activities in the State.  While States are not permitted to utilize CSBG ARRA funds for State administrative purposes, it is appropriate to incorporate oversight and monitoring of CSBG ARRA funds and activities into the State’s existing CSBG monitoring and oversight.  For example, staff members who are supported by regularly-appropriated funds as authorized in Section 675B may monitor both regularly-appropriated and ARRA activities.   The State’s administrative funds must not exceed the Administrative Cap outlined in Section 675C(b)(2), which means that States may not spend more than the greater of $55,000, or 5%, of their regularly-appropriated (non-ARRA) funds for administrative and monitoring activities.   In addition, States may not comingle funds appropriated under regular appropriations with ARRA funds. 

 

Plans and Reporting

Q6.      How much detail will be required when submitting the State plan and application?
A.        A model plan for ARRA funds has been provided on the CSBG website.  The link is as follows:

http:www.acf.hhs.gov/programs/ocs/csbg/outlinemodel.htm.

States should provide sufficient detail to provide publicly-available documentation of the implementation plan in a manner that is responsive to the elements of the model plan.

 

Q7.      Who is the CSBG ARRA plan submitted to at HHS?
A.        CSBG ARRA plans should be mailed to your current OCS program specialist at the following address:

Attention: Community Services Block Grant Program
Division of State Assistance
Office of Community Services
Administration for Children and Families
U.S. Department of Health and Human Services
370 L'Enfant Promenade S.W., 5th Floor West
Washington, D.C. 20447

Q8.      Does the State/Territory/Tribal organization have to provide a new letter that designates the lead agency for CSBG ARRA funds?
A.        Unless the Governor's/CEO’s office has designated a different office to manage ARRA than the lead office which manages the regular CSBG, that designee should be able to sign off on the transmittal of the Plan for Recovery Act.  If there is a new office delegated with the management of the program the Governor/CEO would need to transmit this delegation; however, a State/Territory/Tribal organization should not wait to send in the plan.  The letter of delegation will be added to the plan if it arrives after submission of the plan.

 

Appropriation

Q9.      Do all entities have to use the same poverty guidelines throughout the State?
A.        The Recovery Act allows States to revise the eligibility criteria to not to exceed 200 percent of the poverty line for CSBG services furnished during fiscal years 2009 and 2010.  There is no separate authority for eligible entities to set different guidelines.  However, eligible entities may prioritize specific services and populations based on local needs assessments.

Q10.    Does the State have the option of changing the poverty level for regular CSBG funds as well as the Recovery Act Funds?
A.        Yes. States may increase individual eligibility for services furnished by the CSBG program during fiscal years 2009 and 2010 to up to 200 percent of the official poverty guidelines.  This eligibility adjustment reflects an increase from 125 percent of the poverty guidelines as currently provided in Section 673(2) of the CSBG Act and applies to all CSBG services furnished during fiscal years 2009 and 2010.

Public Inspection

Q11.    Please provide guidance regarding the process for public inspection of the State plan for Recovery Act Funds.
A.        The CSBG ARRA plan should provide evidence that the lead agency of the State’s CSBG program made available the CSBG ARRA plan for public inspection.  The public inspection period should be in sufficient time to provide for public response and comment (it is suggested at least 1 week but not more than 2 weeks).  States should include the date(s) the CSBG ARRA plan was available for inspection to the public and documentation of public notice for the public inspection (e.g. copies of public notices, letters, newspaper articles, link to website posting, e-mail, etc.)

Q12.    Do we need a separate public notice for CSBG ARRA funds or does the FY’09 public notice suffice?
A.        Yes, a separate public notice for CSBG ARRA funds is required.  The CSBG Act requires that each plan “be made available for public inspection within the State in such a manner as will facilitate review of, and comment, on the plan.” per Section 676(e).

Q13.    What is the acceptable public inspection period for comments on the CSBG ARRA plan since the required 30 days is unattainable given the May 29, 2009 submission deadline? Does public inspection also have to include a public hearing?
A.        The public inspection period should be in sufficient time to provide for public response and comment (i.e. minimum of one week).  States are not required to conduct a public hearing for the CSBG ARRA plan.

Other

Q14.    How will OCS utilize the $15 million of T/TA funds appropriated under ARRA?
A.        Approximately half of the T/TA funds are made available through a new program announcement that will support strategic planning efforts focused on the following areas: 1) ensuring Statewide coordination of CSBG Recovery Act projects;  2) informing communities of available projects and services supported with Recovery Act funds in response to local needs; 3) documentation of community results; and 4) preparing communities to sustain the impact of Recovery Act funds after additional Federal support received through the Recovery Act ends.   The announcement can be found on the ACF website on the following link:
http://www.acf.hhs.gov/grants/recovery.html
The title of the announcement is “Community Services Block Grant Training and Technical Assistance Program: Capacity-Building for Ongoing CSBG Programs and Strategic Planning and Coordination Supported by the American Recovery and Reinvestment Act of 2009” (HHS-2009-ACF-OCS-EQ-0037)
The remaining CSBG Recovery Act funds will be utilized in manner consistent with sections 676A and 678B of the CSBG Act, and will support training, technical assistance, planning, evaluation, investigations, assistance to States in carrying out corrective action, monitoring, reporting and data collection, and development of performance measurement systems.  OCS has determined that key technical assistance challenges under the Recovery Act will include fiscal management for increased funding, adaptation of data collection systems to ensure responsiveness to reporting requirements under the Recovery Act, and State-wide strategic planning focused on ensuring State-wide coordination of Community Action Program Recovery Act projects.

Q15.    What are examples of employment related services that create and sustain economic growth?
A.        Employment-related services that create and sustain economic growth should assist individuals in securing employment or acquiring or learning skills that promote opportunities for employment.  Component services or activities may include employment screening, assessment, or testing; structured job skills and job seeking skills; specialized therapy (occupational, speech, physical); special training and tutoring, including literacy training and pre-vocational training; provision of books, supplies and instructional material; employment counseling, transportation; and referral to community resources.
States and eligible entities should consider a variety of employment-related outcomes to help assess whether the services can potentially create and sustain economic growth (e.g. part-time vs. full-time jobs, average hourly starting wage, number of low-income recipients trained, number of Temporary Aid to Needy Families (TANF) recipients trained, number of full-time jobs that offer health care benefits, retirement benefits, paid sick leave, etc.)

Q16.    What is the role of State Community Action Associations in CSBG ARRA and how should State Associations and State CSBG Offices work together in this effort?
A.        State CSBG agencies are responsible for administering the CSBG program, developing the State plan, conducting reviews of Community Action Agencies (CAAs), and ensuring CSBG funds are directed towards the statutory purposes of the CSBG program.  State Associations are responsible for providing training and technical assistance and increasing the capacity of local CAAs to carry out the mandate of the CSBG Act; improve or enhance their overall or specific capability to plan, deliver, manage and measure results. As a part of the CSBG Network, both the State CSBG agencies and State Associations should work together to help ensure the mobilization of additional resources to combat the central causes of poverty.   State Associations may also apply for discretionary grant funding under the program announcement entitled “Community Services Block Grant Training and Technical Assistance Program: Capacity-Building for Ongoing CSBG Programs and Strategic Planning and Coordination Supported by the American Recovery and Reinvestment Act of 2009” (HHS-2009-ACF-OCS-EQ-0037).
The announcement can be found on the ACF website on the following link:
http://www.acf.hhs.gov/grants/recovery.html

 

Q18.    What are some allowable uses of CSBG Recovery Act Funds?

• Under the regular CSBG program, grantees use funds to provide services and activities addressing employment, education, better use of available income, housing, nutrition, emergency services and/or health to combat the central causes of poverty.  Such services continue to be supportable under the CSBG Recovery Act fund.  In recognition of the intent of Recovery Act funds, States/Territories/Tribal organizations should encourage local CSBG service providers to support employment-related services and activities that create and sustain economic growth in keeping with the expressed purpose of ARRA. 

States and eligible entities are strongly encouraged to develop strategic uses of ARRA funds to support projects and activities that can be accomplished in a timely manner and that will have a substantial and sustained impact on community employment and economic development.  States and eligible entities must also plan for services that target individuals and families within the percentage of the poverty line established by the State as eligibility criteria for the CSBG program.

The table below provides some examples of the types of activities that have been supported at the community level in prior CSBG programs.  The examples provided below are intended as a general guideline rather than prior approval of particular expenditures.  In practice, the allowability of specific costs may very depending on the facts in any particular instance.  For example, since expenditures are subject to criteria in OMB cost principles, such as whether costs are reasonable, allocable to the grant objectives and adequately documented, even costs in these categories may be unallowable under circumstances that do not meet these criteria.  OMB Cost Principles may be obtained on the following website link:

http://www.whitehouse.gov/omb/circulars/a122/a122.html

Projects that focus on complex financial transactions may be subject to additional State or Federal review or monitoring to assure availability of appropriate financial expertise, monitoring capacity, internal controls, and risk management.  

Employment Programs  -- Examples of these services may include:

Support for job retention, including counseling, training, and supportive services, such as transportation, child care, and the purchase of uniforms or work clothing;

Skills training, job application assistance, resume writing, and job placement;

On-the-job training and opportunities for work;

Job development, including finding employers willing to recruit through the agency, facilitating interviews, creating job banks, and providing counseling to employees, and developing new employment opportunities in the community;

Vocational training for high school students and the creation of internships and summer jobs; and/or

Other specialized adult employment training.

Education Programs – Examples of these services may include:

Adult education, including courses in English as a Second Language (ESL) and General Education Development (GED) preparation with flexible scheduling for working students;

Child care classes, providing both child development instruction and support for working parents or home child care providers;

Alternative opportunities for school dropouts and those at risk of dropping out;

Scholarships for college or technical school;

Guidance about adult education opportunities in the community;

Programs to enhance academic achievement of students in grades K–12, while combating drug or alcohol use and preventing violence; and/or

Computer-based courses to help train participants for the modern-day workforce.

Income Management Programs -- Examples of these services may include:

Development of household assets, including savings;

Assistance with budgeting techniques;

Consumer credit counseling;

Business development support;

Homeownership assistance;

Energy conservation and energy consumer education programs, including weatherization;

Tax counseling and tax preparation assistance; and/or

Assistance for the elderly with claims for medical and other benefits.

Housing Programs – Examples of these services may include:

Homeownership counseling and loan assistance;

Counseling and advocacy about landlord/tenant relations and fair housing concerns;

Assistance in locating affordable housing and applying for rent subsidies and other housing assistance;

Transitional shelters and services for the homeless;

Support for management of group homes; and/or

Rural housing and infrastructure development.

Emergency Services Programs – Examples of these services may include:

Emergency temporary housing;

Projects to obtain rental or mortgage assistance and provide intervention with landlords;

Projects to obtain emergency assistance through loans, grants, or other means to meet immediate and urgent family and individual needs;

Energy crisis assistance and utility shut-off prevention;

Emergency food, clothing, and furniture;

Crisis intervention in response to child or spousal abuse;

Emergency heating system repair;

Crisis intervention telephone hotlines;

Linkages with other services and organizations to assemble a combination of short-term resources and longer-term support; and/or

Nutrition Programs –  Examples of these services may include::

Organizing and operating food banks;

Assisting food banks of faith-based and civic organization partners with food supplies and/or management support;

Counseling regarding family and children’s nutrition and food preparation;

Preparing and delivering meals, especially to the homebound elderly;

Providing meals in group settings; and/or

Initiating self-help projects, such as community gardens, community canneries, and food buying groups.

Linkages –  Examples of linkage initiatives may include:

Coordination among programs, facilities, and shared resources through information systems, communications systems, and shared procedures;

Community needs assessments, followed by community planning, organization, and advocacy to meet these needs;

Creation of coalitions for community changes, such as reducing crime or partnering businesses with low-income neighborhoods in order to plan long-term development;

Efforts to establish links between resources, such as transportation and medical care and programs that bring services to the participants, such as mobile clinics or recreational programs, and management of continuum-of-care initiatives; and/or

The removal of barriers, such as transportation problems, that hinder low-income individuals’ abilities to access their jobs or other necessary activities.

Self-Sufficiency Programs – Examples of these services may include:

An assessment of the issues facing a family or family members and the resources to address these issues;

A written plan for becoming more financially independent and self-supporting; and/or

Services that are selected to help the participant implement sufficiency plans (i.e. clothing, bus passes, emergency food assistance, career counseling, family guidance counseling, referrals to the Social Security Administration for disability benefits, assistance with locating possible jobs, assistance in finding long-term housing, etc.).

Health Programs – Examples of these services may include::

Recruitment of volunteer medical personnel to assist uninsured low-income families;

Prenatal care, maternal health, and infant health screening;

Assistance with pharmaceutical donation programs;

Immunization;

Periodic screening for serious health problems, such as tuberculosis, breast cancer, HIV infection, and mental health disorders;

Health screening of all children;

Treatment for substance abuse;

Other health services, including dental care, health insurance advocacy, CPR training, and education about wellness, obesity, and First Aid; and/or

Transportation to health care facilities and medical appointments.

Programs for Youth and Seniors – Services noted under these categories may be targeted exclusively to children and youth from ages six to 17 or persons over 55 years of age.

Youth programs supported include:

Recreational facilities and programs;

Educational services;

Health services and prevention of risky behavior;

Delinquency prevention; and/or

Employment and mentoring projects.

Seniors’ programs help seniors to avoid or ameliorate illness or incapacity; address absence of a caretaker or relative; prevent abuse and neglect; and promote wellness.  Services supported may include:

Home-based services, including household or personal care activities that improve or maintain well-being;

Assistance in locating or obtaining alternative living arrangements;

In-home emergency services or day care;

Group meals and recreational activities;

Special arrangements for transportation and coordination with other resources;

Case management and family support coordination; and/or

Home delivery of meals to ensure adequate nutrition.