CSBG Policy and Procedures A Multi-Faceted and Useful Tool

CSBG Policies and Procedures • States Communicate Expectations in a

Number of Ways– State Plan– State Law– Contracts– Directives/Guidelines– Memorandums

– Manual – Policy or Policy and Procedures

What’s the Value?• Helps the State & Subrecipients

– By Establishing & Concisely Communicating Expectations• What the State Expects of Subrecipients• What Subrecipients Can Expect of the State

– Comply w/Enabling Legislation– Comply w/State Requirements

• Elaborates on Contract Language– Saves Time

What’s the Value?• Helps the State & Subrecipients

– Ensures Continuity in the State’s Implementation

– Provides an Explanation of How CSBG is Implemented in Kansas• A-133 Audits• OCS & Other Federal Reviews

Policy Manual for the Kansas CSBG

● CSBG Legislation• OMB Circulars• Information Memoranda• CSBG Terms & Conditions• Shared Information (Colleagues & NASCSP)

– As a Discussion Point or a Policy• The Kansas Experience

Policy Manual for the Kansas CSBG• Sections

– Topic Areas • Requirement and/or Discussion

Section 4 – Grant Administration4100 Monitoring

4101 Monitoring is an on-going process and is not limited to the periodic “on-site monitoring visit.” The on- going process includes review of . . .. 4102 On-site monitoring may occur at anytime and without

notice. . . .

Policy Manual for the Kansas CSBG• Expectations Beyond the Federal

Requirements– ED Performance Appraisals – Planning Calendar– Community Needs Assessment Contents– Strategic Plan– Professional Development for Key Staff– On-Going Board Training

A Living Document• Updated About Every 3 Years

– Align w/Practice– Sync w/Requirements – Respond to the Current Environment

• In Consultation w/the Network

• Bound Copies to Each Eligible Entity• Web-Posted

A Relevant Document• It Is Referenced

– Notice/Agreement (Contract)– Order of Precedence

– Worksheet for On-Site Review – Reports of On-Site Review (Monitoring)– When Responding to Questions (TA)– Encouraged Read – Prof. Devlp. Plans (Policy

10010)

• It Is Followed– State Practice Syncs w/the Manual

Referenced in Notice/AgreementIV. Grantee Performance

A. Grantee shall, in a satisfactory manner as determined by the Grantor, and in accordance with the governing statutes, regulations, and documents listed herein and the approved Grantee application, develop and implement a program in order to assist low-income residents of Kansas.

1. 42 U.S.C. § 9901 et seq.

2. U. S. Office of Management and Budget (OMB) Circulars A-87, A-102, A-110, A-122 and A-133, as applicable.

3. ACF Community Services Block Grant Term and Conditions. (Posted at http://www.acf.hhs.gov/programs/ocs/csbg/index.html)

4. The Kansas Policy Manual for the Community Services Block Grant. (Posted at http://www.kshousingcorp.org/forms-and-publications.aspx)

Order of Precedence – Kansas

1. CSBG Enabling Legislation2. OMB Circulars, as Applicable3. Kansas Form D-146a 4. The Notice of Financial Award and Grant

Agreement5. The Kansas Policy Manual for the

Community Services Block Grant

Monitoring Is Tied to Policy6109 The board has established procedures to ensure that board members are not

related to one another or to the executive director as defined within Policy 6107. Yes No6109 The board has established procedures to ensure that it is compliant with Policy

6108 (eligible to serve). Yes No

6501 A documented process ensures initial and continued board training which includes, as applicable, non-profit board responsibilities, ROMA, program & service information, causes/effects of poverty, emerging issues, the origin, source and impact of CSBG funding. Yes No

7200A calendar of planning activities exists and insures systematic and annual performance of key board activities. Yes No

9104 GTR matches system-produced documentation. Yes No

9102D GTR submissions meet the due date – 15th of the month. Yes No

9102B GTR contains an original signature of authorized signatory – non-fiscal. Yes No

Compliance Matter 5.1 Evidence of an annual performance appraisal of the Executive Director was not identified within personnel files. Kansas CSBG Policy 6204 states, “The governing board of each private, non-profit eligible entity shall undertake an annual performance evaluation of the entity’s executive director. This evaluation shall include a statement of outcomes for which the executive is responsible and shall provide a progress statement relative to the achievement of those outcomes. Dated evidence of the evaluation shall be contained within the executive director’s personnel file.”

 

Compliance Matter 5.2Policy 10006 requires eligible entities to “maintain an employee-signed and dated job description indicating current tasks for which the employee is held accountable.” No such job description was observed for the agency’s Executive Director.

 

“Eight (8) items within the report are identifiedas Compliance Matters.

“Please prepare and submit a quality improvement plan addressing each item. The plan is to be provided in a table format with, at minimum, the following column headers.”

Compliance Matter Action Plan Responsible

Position(s)

Anticipated Completion Date

Documenta-tion to Support Completion

Comments

NASCSP Issue Brief: State CSBG Office Policies and Procedures

http://nascsp.org/data/files/csbg_publications/issue_briefs/policies_and_procedures_10-27_final.pdf

NASCSP a CSBG a CSBG Issues Briefs

Policy Manual for the Kansas CSBGwww.kshousingcorp.org

KHRC a Special Needs a Community Services a Forms & Publications

To Continue the Tool Analogy . . .

Thank you.