effective oversight

Effective OversightCSBG Oversight: An

Operational Continuum

Effective Oversight

Contracts

Effective OversightPolicies and Procedures

Effective OversightHolistic

Monitoring

5

Federal Law and

Applicable Regs

Effective Oversight

Monitoring

Tool

Policies and Procedures

State Plan

A Systems View of Monitoring

Brown Buckley Tucker

CSBG

Head Start

LIHEAP

WAPWIA

IM 49

IM 94

Monitoring Practices and Principles

Why Use a System’s Approach

I.M. 94 ‘State CSBG Lead Agencies …should …

ensure …that agency Head Start programs have ongoing systems of oversight and monitoring.’

‘It is important to stress that quick fixes to identified problems typically result in a reoccurrence of the problems. Most areas needing improvement are often linked to major systems that often require thoughtful planning and time to implement needed changes.’

I.M. 94, cont.

‘…the Community Services Network must continue to focus its efforts on strengthening overall agency governance and administration, fiscal control, program effectiveness and accountability to assure capacity to comply with all program requirements of the various programs administered by the agency.’

I.M. 49 “Recognizing that CSBG does not succeed as an individual program…

Special attention will be paid to State capabilities to identify the…needs

among eligible entities, particularly those related to strengthening

OVERALL program administration, fiscal management,…”

I.M. 49, cont. “…State…officials …(should)

reinforce the importance of effective management SYSTEMS…”

“…As part of …oversight, we should implement on-going…SYSTEM-WIDE actions…to assure continued administrative and fiscal integrity, program effectiveness, and accountability among ALL PROGRAMS administered by CAAs.”

I.M. 49, cont.

“…Agencies in the past have often focused their energies on ‘preparing for the monitoring test’ instead of implementing on-going SYSTEMS that identify areas needing improvement…”

I.M. 49, cont.

“…Agencies that choose to operate each of their programs separately without a coordinated strategy to address the multi-faceted causes and conditions of poverty…are meeting neither the letter nor the spirit of the CSBG act.”

“…Community Action is one agency with one mission.”

I.M. 49, cont. “…Most areas needing improvement

are often linked to major SYSTEMS…”

“…State …officials (should) …reinforce the importance of effective management SYSTEMS…”

NASCSP’s Standard Monitoring Principles and Practices for CSBG

“…State monitors should look at more than compliance with program rules and regulations.”

“…State monitors need to take a SYSTEMS view of each CAA…”

Monitoring Principles and Practices

Any State MonitoringStructure

ABC Community ActionBoard of Directors

Executive Director

CSBG

CSBG Staff

Head Start

Head Start Staff

Weatherization

Weatherization Staff

LIHEAP

LIHEAP Staff

Housing

Housing Staff

Finance

Finance Staff


A System for Monitoring

Integrated Monitoring Structure

Monitoring Tool

CollaborativeRelationships

Staff Training

Dynamics of Change

HUD Head StartWeatherization


ABC Community ActionGovernance

Fiscal Policies & Procedures Planning:

Mission & PlanningAdmin. Systems & Procedures

Programs EvaluationPartnerships

Outcomes

Monitoring as oversight…

23

Federal Law and

Applicable Regs

Effective Oversight

Monitoring

Tool


State Plan

Guides states in assuring that all federal and state laws/regulations, policies and procedures, and the contract are followed References key areas Simplifies monitoring report/corrective

action by having citations readily in hand

Effective Oversight: Monitoring Tool

CSBG Reference

CEAP Reference

CSBG/CEAP Questions

OMB Cir. A-110, Subpart C_.21 & OMB Cir. A-102 & A-87(if app), 1 § 5.14

OMB Cir. A-110, Subpart C_.21 & OMB Cir. A-102 & A-87(if app)CEAP Contract Sect 6, 1 § 5.14

5. Are Monthly Expenditure Report () financial figures reconciled from the general ledger or accounting work papers?Methodology: Compare for two months provided by Subrecipient with copy of brought by Program Officer. Also, review General Ledger and working papers and/or reports used to compile figures for the in review.

Referenced Monitoring Question

CSBG Reference Question

42U.S.C. §9901 et seq. Sect 676 (b)(11), and 10 § 5.3 and § 5.210, Contract Sect 33

CAP Plan 111. Has the Department received and accepted the current year Plan?Methodology: Review current year CAP Plan and check approval date.


Monitoring ItemThere is an analysis of the agency’s poverty needs and problems, the client groups at risk in its geographic area, and an analysis of the resources available to address those identified needs. (42 U.S. C9908 (b) (11); CSBG State Plan; Contract Section 2.01.5)


Topic Question GuidancePlanning Is there a community

needs assessment for the community served?

According to the CSBG statute, needs assessment refers to a systematic effort aimed at evaluating what the service requirements of the community are. It is aimed at determining what services it is essential to provide, what is available, and what is missing. A best practice for conducting a needs assessment would be for the agency to be conducting a needs assessment that is used agency-wide versus individual programs completing program-specific assessments. Needs assessments can be conducted through several methodologies including surveys, all-staff meetings, one-on-one interviews, focus groups, or community meetings. There is a regularly conducted, broad-based community needs assessment and a system is in place to utilize data in developing the agency strategic plan and in formulating program goals and objectives. Information from the needs assessment is used in formulating agency goals and objectives in which the board members were involved and approved. Information is also shared with the community, local policy makers and legislators. The agency’s needs assessment and strategic plan are utilized in seeking funding through governmental and private funding sources.


Topic Question GuidanceCustomer Service Complaints

What is the system for handling customer complaints/grievances? Is this system/process written? How are customers made aware of the procedures?

In an excellent agency, there are opportunities for customers to provide feedback to the agency, including complaints. This system includes ways in which to handle and assess complaints. CSBG contract requirement item # 27; LIHEAP contract requirement item # 4.


On-Site Monitoring

Follow-Up

Board Meeting Minutes

AuditReview of Documents

Phone Calls

Reports from

Partner Agencies

Monitoring Process is Ongoing

Checking the boxes is not enough

Reflect back on the monitoring practices, which include state monitors should: Look at more than compliance with program rules

and regulations Assess the effectiveness of the board of directors. Assess the administrative and leadership capacity

of agency management as it relates to meeting the Board of Director’s goals.

CAUTION…..

NASCSP Monitoring Principles and Practices Congress Calls For More

Accountability

Monitoring Tool

Monitoring PracticesMonitoring

Principles

Joint Problem Solving

More thanCompliance Board

EffectivenessMutualRespect

OpenCommunications

Systems to Inform& Follow Up Administrative

Capacity

33

Federal Law and

Applicable Regs

Effective Oversight

Monitoring

Tool


State Plan