Arkansas Administrative Code
Agency 016 - DEPARTMENT OF HUMAN SERVICES
Division 20 - Division of County Operations
Rule 016.20.15-003 - CSBG State Plan 2016

A cover letter is included with the final plan and will be submitted to the Office of Community Services (HHS/OCS) by September 1, 2015. The letter is addressed to the OCS Director and includes the State CSBG official who is to receive the CSBG Grant Award with complete address, telephone, email address and fax number.

The State of Arkansas hereby submits the Community Services Block Grant State Plan and Application for Fiscal Years 2016-2017. This plan contains the necessary provisions, which adequately describe the programs for which assistance is sought under this subtitle, and which are consistent with the requirements of the CSBG Act.

[GREATER THAN] Funding applications submitted to the State lead agency for funds;

[GREATER THAN] The eligible entity's most recent Articles of Incorporation, by-laws, board membership list, needs assessment and Statement of Purposes and Strategy;

[GREATER THAN] All contracts (including funding, consulting, goods and services) pertaining to State lead agency funds;

'y All final reports (including audits) made to the State lead agency on projects funded with State lead agency funds;

[GREATER THAN] Minutes of the meetings of the Board of Directors;

[GREATER THAN] Position titles, salary ranges and job descriptions for all compensated positions.

Opportunity Officer and a description of his/her duties; a description of duties of the Equal Opportunity Governing Board (if any) and a list of its members; a numerical analysis of the composition of the agency's work force by position type and the Governing Board membership on the basis of sector represented.

The agency may not appoint as its Equal Opportunity Officer the Executive Director. The eligible entity shall have this information available for review by OCS Monitors or available upon request by OCS.

the following is intended to provide guidance to eligible entities as to appropriate standards of conduct relative to political activities, as well as to the use of any funds administrated by the State Office of Community Services for political purposes.

Community Services for Lobbying Activities. Such funds of a contract or grant recipient may not be used to pay the salary or expenses of any staff member or agent acting for such recipients to engage in activity designed to influence legislation or appropriations pending before the U. S. Congress or the Arkansas Legislature.

Eligible entities shall provide the State lead agency and/or its authorized representative access to all books, records, documents and compilations of data relating to any programs administered by the State Office of Community Services.

Improvement Plan (QIP) when OCS determines that an eligible entity has failed to comply with and meet the requirements contained in regulations or published administrative requirements of OCS, has failed to fulfill its funded work program, or has breached the terms of its funding agreement with OCS.

If the OCS Assistant Director determines that an emergency situation exists due to threat of imminent loss or waste of OCS funds and that immediate action is required due to the seriousness of the violation and/or is necessary to protect OCS funds or property:

If the DCO Director denies the appeal, the eligible entity may appeal to the DHS Director, in writing within ten days. The DHS Director shall schedule such an appeal to be held within ten days of receipt of the request and shall issue written findings within ten days of adjournment of the appeal hearing. If the DHS Director denies the appeal, OCS may initiate termination of status of the agency as an eligible entity according to procedures as set forth in 3200 C. If entity requests review by HHS, no funds determination is final until HHS reviews.

C Termination.

An eligible entity may request and OCS may approve voluntary suspension of the status of the eligible entity for a stated period of time. OCS shall make arrangements it deems necessary to assure the continued provision of services during the period of voluntary suspension. The voluntary status of suspension shall be lifted at the agreed upon time. If upon completion of the period of voluntary suspension, OCS determines that suspension shall continue, normal steps for corrective action prior to suspension shall apply, including the rights of appeal by the eligible entity. The eligible entity may request and OCS may approve an extension of the period of voluntary suspension.

If an existing eligible entity terminates its service, the Governor will solicit applications from eligible entities and designate an eligible entity to provide services in the unserved area. The eligible entity shall be:

Arkansas Statutes Section 5-713 provides subgrantees the right to appeal this decision to the Circuit Court of any County in which the eligible entity is located or does business or to the Circuit Court of Pulaski County. This request must be filed within thirty days of receipt of the appeal decision.

Planning, Funding Application, and Reporting Requirements (Section 4140, State CSBG Policy)

For purposes of this paragraph, administrative services are considered to be management and operating functions which span several or all agency functions. With the approval of the Assistant Director of OCS, a different definition for administrative services may be used by an eligible entity for purposes of this paragraph.

All requests to use CSBG funds for administration must include full justification. Additionally, where application is made to utilize CSBG funds for administrative support of programs funded from other sources than CSBG, the agency shall:

[GREATER THAN] submit the total eligible entity budget

[GREATER THAN] list the amount and sources of funds in (1) above

[GREATER THAN] indicate the amount of funds from each source in (2) above which are actually to be used for administrative costs, and

[GREATER THAN] document efforts by the agency to obtain the use of funds for administrative costs from each source in (2) above

When the CSBG section of OCS has completed review of the application work program and budgets, the Assistant Director of OCS will determine whether the application should be approved as submitted, or he may place special conditions on the grant, or he may require changes. He will notify the applicant agency of his decision in writing. The state agency shall reply to the eligible entity within forty five days of receipt of a completed application. If no response is sent by the state agency within forty five days, the application shall be deemed to be complete and acceptable as submitted. The state agency shall issue a Notice of Grant Award within fifteen days after a work program has been approved, subject to receipt of federal funds.

In the event the eligible entity does not accept any stated conditions or does not agree to any required changes, the eligible entity may appeal, in writing, to the Assistant Director of OCS within ten days, stating the reasons why the stated conditions or changes should not be required. If the Assistant Director does not agree with the appeal, he will so notify the eligible entity, in writing, within ten days. At this point, the eligible entity, within ten days, may request the Assistant Director of OCS to seek the advice of an appeals body to be appointed by him. The body shall be appointed and directed to meet within ten days of receipt of the request by the OCS Assistant Director. The appeals body shall consist of two eligible entity directors and a staff member of the Division of County Operations not previously involved in the decision. The appeals body shall review the application file, discuss, deliberate and issue a written recommendation to the OCS Assistant Director within five days of adjournment. If the appeals body cannot reach a consensus, dissenting members may submit separate written recommendations within the same five day period. After reviewing the advice of the appeals body, the Assistant Director of OCS will make his finding to the eligible entity, in writing, within ten days. At this point, within ten days, the eligible entity may appeal, in writing, to the DCO Director. The DCO Director shall notify the eligible entity of his finding within ten days. The eligible entity may appeal his finding, within ten days, to the Director of DHS. The Director of DHS shall respond within ten days. The findings of the Director of DHS shall be final.

Reports will meet this requirement if postmarked by the tenth (10th) of the month. Additionally, at the end of each quarter of its program year, the eligible entity shall report on the status of the implementation and operation of its work programs. This report is to be submitted to be received in OCS not later than thirty calendar days after the end of the period covered by the report and is required for the release of funds for the second month of each program quarter. All reports submitted to OCS subsequent to the last board meeting shall be presented for review and approval by the board.

Failure to comply with this requirement by a timely and accurate reporting of financial and program activity in the format requested may result in corrective action prior to suspension of funding for the respective project. Where an eligible entity has a history of failure to comply with reporting requirements, OCS may suspend all funding to the eligible entity which fails to submit any required report in a timely and complete manner or fails to respond to any other reasonable request by OCS regarding their program. Any financial or program report at least thirty days in arrears may serve as the basis for the initiation of corrective action proceeding prior to suspension of all funding.

Monitoring and audit reports shall be submitted to the Board for review and approval.

approved work program. When an agency submits its quarterly program reports, it shall adequately explain any variances of twenty percent or more from the approved work program in any activity or objective when the goal was not met. The agency shall include any necessary corrective actions the agency intends to make to satisfy the work program activity or objective where the goal was not met. The Assistant Director of OCS shall determine the adequacy of the explanation and of the intended corrective actions. If they are not adequate, he will inform the agency of any steps necessary to meet the requirements of the grant and set a time for their accomplishment. If the agency does not agree to the corrective actions or fails to meet them in the stated time, the Assistant Director of OCS may withhold any further funding to the agency until such time as the conditions are met, or he may institute corrective action proceedings prior to suspension of agency funds. If no notification is sent by the OCS within thirty working days after receipt of quarterly reports, the report shall be deemed to be accepted as submitted.

Administrative Procedures Manual which outlines management and operating procedures.

The Act requires the designated lead agency to conduct at least one Public Hearing to provide an opportunity for comment on the proposed use and distribution of funds, in conjunction with development of the State Application and Plan. Arkansas held one public hearing,________________________. Notice of the hearing was published in the statewide daily newspaper for three consecutive days and posted on the Arkansas Department of Human Services website. The public was offered the opportunity to comment on the proposed use and distribution of funds for the plan period (fiscal years 2016-2017).

The Act requires the State to hold at least one legislative hearing every three (3) years in conjunction with the development of the State Plan. The Arkansas Legislative Council of the Arkansas General Assembly conducted a legislative hearing for fiscal years 2016-2017 on ____________. The Legislative Council also held a legislative hearing in conjunction with the development of the 2016-2017 State Plan on_________________.

The Act requires the State to make the Plan available for public inspection, to facilitate review of and comment on the plan. The State Plan for fiscal years 2016-2017 was made available for public inspection and comment from__________-__________, at the Arkansas Department of Human Services website. Those who wished to comment could respond orally at the Public Hearings or submit comments directly to the Arkansas Department of Human Services, Division of County Operations, Office of Community Services. Notice of the public hearing and comment period was provided in the Arkansas statewide daily newspaper and via the Arkansas Department of Human Services website.

Copies of the plan will be made available at the Arkansas State Library, Arkansas Department of Human Services, Legislative Council, Community Action Agencies, and the Arkansas Department of Human Services website www. dhs.arkansas.gov.

Category One: Consumer Input and Involvement

Community Action is rooted in the belief that people with low incomes are in the best position to express what they need to make a difference in their lives. CSBG eligible entities work in partnership with the people and communities they serve. Community Action works in a coordinated and comprehensive manner to develop programs and services that will make a critical difference in the lives of participants. Individuals and families are well attuned to what they need, and when Community Action taps into that knowledge, it informs our ability to implement high-impact programs and services.

Research shows that through engagement in community activities such as board governance, peer to peer leadership, advisory bodies, volunteering, and other participatory means, the poor build personal networks and increase their social capital so that they are able to move themselves and their families out of poverty. Community Action is grounded in helping families and communities build this social capital for movement to self-sufficiency.

Standard 1.1 - The organization demonstrates low-income individuals' participation in its activities.

Standard 1.2 -The organization analyzes information collected directly from low-income individuals as part of the community assessment.

Standard 1.3 - The organization has a systematic approach for collecting, analyzing, and reporting customer satisfaction data to the governing board.

Category Two: Community Engagement

No CSBG eligible entity can meet all of a community's needs independently. Through formal and informal partnerships, ongoing community planning, advocacy, and engagement of people with low incomes, partners ranging from community and faith-based organizations, educational institutions, government, and business work together with Community Action Agencies and other CSBG eligible entities to successfully move families out of poverty and revitalize communities.

Community Action is often the backbone organization of community efforts to address poverty and community revitalization: leveraging funds, convening key partners, adding the voice of the underrepresented, and being the central coordinator of efforts. It is not an easy role to play, but a vital one for families and communities.

Standard 2.1 - The organization has documented or demonstrated partnerships across the community, for specifically identified purposes; partnerships include other anti-poverty organizations in the area.

Standard 2.2 - The organization utilizes information gathered from key sectors of the community in assessing needs and resources, during the community assessment process or other times. These sectors would include at minimum: community-based organizations, faith-based organizations, private sector, public sector, and educational institutions.

Standard 2.3 - The organization communicates its activities and its results to the community.

Standard 2.4 -The organization documents the number of volunteers and hours mobilized in support of its activities.

Category Three: Community Assessment

Local control of Federal CSBG resources is predicated on regular comprehensive community assessments that take into account the breadth of community needs as well as the partners and resources available in a community to meet these needs. Regular assessment of needs and resources at the community level is the foundation of Community Action and a vital management and leadership tool that is used across the organization and utilized by the community to set the course for both CSBG and all agency resources.

Standard 3.1 - The organization conducted a community assessment and issued a report within the past 3 years.

Standard 3.2 -As part of the community assessment, the organization collects and includes current data specific to poverty and its prevalence related to gender, age, and race/ethnicity for their service area(s).

Standard 3.3 -The organization collects and analyzes both qualitative and quantitative data on its geographic service area{s) in the community assessment.

Standard 3.4 - The community assessment includes key findings on the causes and conditions of poverty and the needs of the communities assessed.

Standard 3.5 - The governing board formally accepts the completed community assessment. 2. VISION AND DIRECTION

Category Four: Organizational Leadership

Community Action leadership is exemplified at all levels across the organization and starts with a mission that clarifies Community Action's work on poverty. A well-functioning board, a focused chief executive officer (CEO)/executive director, well-trained and dedicated staff, and volunteers giving of themselves to help others will establish Community Action as the cornerstone and leverage point to address poverty across the community. Ensuring strong leadership both for today and into the future is critical.

This category addresses the foundational elements of mission as well as the implementation of the Network's model of good performance management (ROMA). It ensures CAAs have taken steps to plan thoughtfully for today's work and tomorrow's leadership.

Standard 4.1 - The governing board has reviewed the organization's mission statement within the past 5 years and assured that:

Standard 4.2 - The organization's Community Action plan is outcome-based, anti-poverty focused, and ties directly to the community assessment.

Standard 4.3 - The organization's Community Action plan and strategic plan document the continuous use of the full Results Oriented Management and Accountability (ROMA) cycle or comparable system (assessment, planning, implementation, achievement of results, and evaluation). In addition, the organization documents having used the services of a ROMA-certified trainer (or equivalent) to assist in implementation.

Standard 4.4 - The governing board receives an annual update on the success of specific strategies included in the Community Action plan.

Standard 4.5 - The organization has a written succession plan in place for the

CEO/executive director, approved by the governing board, which contains procedures for covering an emergency/unplanned, short-term absence of 3 months or less, as well as outlines the process for filling a permanent vacancy.

Standard 4.6 - An organization-wide, comprehensive risk assessment has been completed within the past 2 years and reported to the governing board.

Category Five: Board Governance

Community Action boards are uniquely structured to ensure maximum feasible participation by the entire community, including those the network serves. By law, Community Action boards are comprised of at least 1/3 low-income consumers (or their representatives), 1/3 elected officials (or their appointees), and the remainder private-sector community members. To make this structure work as intended, CAAs must recruit board members thoughtfully, work within communities to promote opportunities for board service, and orient, train, and support them in their oversight role. Boards are foundational to good organizational performance and the time invested to keep them healthy and active is significant, but necessary.

Standard 5.1 - The organization's governing board is structured in compliance with the CSBG Act:

Standard 5.2 - The organization's governing board has written procedures that document a democratic selection process for low-income board members adequate to assure that they are representative of the low-income community.

Standard 5.3 - The organization's bylaws have been reviewed by an attorney within the past 5 years.

Standard 5.4 - The organization documents that each governing board member has received a copy of the bylaws within the past 2 years.

Standard 5.5 - The organization's governing board meets in accordance with the frequency and quorum requirements and fills board vacancies as set out in its bylaws.

Standard 5.6 - Each governing board member has signed a conflict of interest policy within the past 2 years.

Standard 5.7 - The organization has a process to provide a structured orientation for governing board members within 6 months of being seated.

Standard 5.8 - Governing board members have been provided with training on their duties and responsibilities within the past 2 years.

Standard 5.9 - The organization's governing board receives programmatic reports at each regular board meeting.

Category Six: Strategic Planning

Establishing the vision for a Community Action Agency is a big task and setting the course to reach it through strategic planning is serious business. CSBG eligible entities take on this task by looking both at internal functioning and at the community's needs. An efficient organization knows where it is headed, how the board and staff fit into that future, and how it will measure its success in achieving what it has set out to do. This agency-wide process is board-led and ongoing. A "living, breathing" strategic plan with measurable outcomes is the goal, rather than a plan that gets written but sits on a shelf and stagnates. Often set with an ambitious vision, strategic plans set the tone for the staff and board and are a key leadership and management tool for the organization.

Standard 6.1 - The organization has an agency-wide strategic plan in place that has been approved by the governing board within the past 5 years.

Standard 6.2 - The approved strategic plan addresses reduction of poverty, revitalization of low-income communities, and/or empowerment of people with low incomes to become more self-sufficient.

Standard 6.3 - The approved strategic plan contains family, agency, and/or community goals.

Standard 6.4 - Customer satisfaction data and customer input, collected as part of the community assessment, is included in the strategic planning process.

Standard 6.5 - The governing board has received an update(s) on progress meeting the goals of the strategic plan within the past 12 months.

The human element of Community Action's work is evident at all levels of the organization and the relationship an organization has with its staff often reflects the organization's values and mission. Oversight of the chief executive officer (CEO)/executive director and maintaining a strong human resources infrastructure are key responsibilities of board oversight. Attention to organizational elements such as policies and procedures, performance appraisals, and training lead to strong organizations with the capacity to deliver high-quality services in low-income communities.

Standard 7.1 - The organization has written personnel policies that have been reviewed by an attorney and approved by the governing board within the past 5 years.

Standard 7.2 - The organization makes available the employee handbook (or personnel policies in cases without a handbook) to all staff and notifies staff of any changes.

Standard 7.3 - The organization has written job descriptions for all positions, which have been updated within the past 5 years.

Standard 7.4 -The governing board conducts a performance appraisal of the CEO/executive director within each calendar year.

Standard 7.5 - The governing board reviews and approves CEO/executive director compensation within every calendar year.

Standard 7.6 - The organization has a policy in place for regular written evaluation of employees by their supervisors.

Standard 7.7 - The organization has a whistleblower policy that has been approved by the governing board.

Standard 7.8 - All staff participate in a new employee orientation within 60 days of hire.

Standard 7.9 - The organization conducts or makes available staff development/training (including ROMA) on an ongoing basis.

Category Eight: Financial Operations and Oversight

The fiscal bottom line of Community Action is not isolated from the mission, it is a joint consideration. Community Action boards and staff maintain a high level of fiscal accountability through audits, monitoring by State and Federal agencies, and compliance with Federal Office of Management Budget circulars. The management of Federal funds is taken seriously by CSBG eligible entities and the Standards specifically reflect the board's oversight role as well as the day-to-day operational functions.

Standard 8.1 - The organization's annual audit (or audited financial statements) is completed by a Certified Public Accountant on time in accordance with Title 2 of the Code of Federal Regulations, Uniform Administrative Requirements, Cost Principles, and Audit Requirement (if applicable) and/or State audit threshold requirements.

Standard 8.2 - All findings from the prior year's annual audit have been assessed by the organization and addressed where the governing board has deemed it appropriate.

Standard 8.3 - The organization's auditor presents the audit to the governing board.

Standard 8.4 - The governing board formally receives and accepts the audit. Standard 8.5 - The organization has solicited bids for its audit within the past 5 years.

Standard 8.6 - The IRS Form 990 is completed annually and made available to the governing board for review.

Standard 8.7 * private The governing board receives financial reports at each regular meeting that include the following:

Standard 8.8 - All required filings and payments related to payroll withholdings are completed on time.

Standard 8.9 - The governing board annually approves an organization-wide budget.

Standard 8.10 -The fiscal policies have been reviewed by staff within the past 2 years, updated as necessary, with changes approved by the governing board.

Standard 8.11 - A written procurement policy is in place and has been reviewed by the governing board within the past 5 years.

Standard 8.12 - The organization documents how it allocates shared costs through an indirect cost rate or through a written cost allocation plan.

Standard 8.13 - The organization has a written policy in place for record retention and destruction.

Category Nine: Data and Analysis

The Community Action Network moves families out of poverty every day across this country and needs to produce data that reflect the collective impact of these efforts. Individual stories are compelling when combined with quantitative data: no data without stories and no stories without data. Community Action needs to better document the outcomes families, agencies, and communities achieve. The Community Services Block Grant funding confers the obligation and opportunity to tell the story of agency-wide impact and community change, and in turn the impact of the Network as a whole.

Standard 9.1 - The organization has a system or systems in place to track and report client demographics and services customers receive.

Standard 9.2 - The organization has a system or systems in place to track family, agency, and/or community outcomes.

Standard 9.3 - The organization has presented to the governing board for review or action, at least within the past 12 months, an analysis of the agency's outcomes and any operational or strategic program adjustments and improvements identified as necessary.

Standard 9.4 - The organization submits its annual CSBG Information Survey data report and it reflects client demographics and organization-wide outcomes.

Boy/Girl Scouts Churches

Community Coalitions County Resource Councils Domestic Violence Programs Faith-based organizations Family Day Care Homes Food Banks/Food Pantries Homeless Shelters Job Training Programs Local Initiative Support Group (LISC) Literacy Councils Red Cross Salvation Army Soup Kitchens

Single Parent Scholarship Fund Statewide CAAs United Way

Adult Education and Literacy Councils

Arkansas Development Finance Authority

Childcare Programs

Colleges and Universities

Community Colleges/Technical Schools

County DHS Offices

County Extension Offices

County Health Departments

Educational Cooperatives

Employment Security Department/Workforce Services

Health Education Centers

Home Instruction Program for Pre-school Youngsters

Local government agencies

Postal Service

Public Housing Authority

School Districts

Transitional Employment Assistance Programs

Workforce Investment Boards/Workforce Alliance

Junior Auxiliary Kiwanis Lions Clubs Realtors Associations Rotary Clubs Sheriffs Associations

Chambers of Commerce

Foundations and Corporations

Financial Institutions

Health Professionals

Legal Services

Local Businesses

Media

Utility Providers

Planned activities of eligible entities will assist low-income persons to achieve greater community participation in community affairs. Low-income program participants are encouraged to become involved in programmatic policy and procedures through community programs, including:

* Head Start/Early Head Start Policy Advisory Council

* Federal Emergency Management Assistance Advisory Board

* Senior Wellness Centers Policy Advisory Committee

* County Resource Councils

* CAA Board of Directors

* Section 8 Resident Advisory Board

* Housing & Urban Development Advisory Board

* Local Emergency Food and Shelter Board

* Single Parent Scholarship Program

* Community Action Teams

* Community Involvement Workshops

* Local Advisory Board and Committees

The Assistant Director or his/her designee attends the monthly meeting of the eligible entities Executive Director and the Executive Director of the Arkansas Community Action Agencies Association. Feedback and updates of funding or program status are provided to the entities, and concerns are addressed at the meetings. Communication on a less formal basis is on-going in the form of email, telephone and mailings.

The State lead agency will report on State Accountability measures in order to ensure accountability and improve program performance. The state lead agency will provide feedback within 60 calendar days to local entities and the State Community Action Association regarding performance on State Accountability Measures. This feedback may be in various forms, including but not limited to, meetings and presentations, mailings, emails or social media.

[GREATER THAN] The private nonprofit eligible entity shall administer the Community Services Block Grant Program through a tripartite board that fully participates in the development, planning, implementation, and evaluation of the program to serve low-income communities

[GREATER THAN] The members of the board shall be selected by the entity

[GREATER THAN] The board shall be composed so as to assure that a. elected public officials or their permanent representatives shall comprise one-third of the board b. representatives of low-income persons shall comprise at least one-third of the board c. representatives of business, industry, labor, religious, law enforcement, education or other major groups and interests in the community shall comprise the remainder of the board

Corrective Action, Termination or Reduction of Funding

The State will comply with the requirements of Section 678C of the Act, in regard to corrective action, termination, or reduction of funding. Section 3200 of CSBG policies outlines these procedures in a section entitled, "Corrective Action, Suspension, Termination and Establishment of Eligible Entity Status". The policy is as follows:

Corrective Action: OCS shall require an agency to submit a Quality Improvement Plan (QIP) when OCS determines that an eligible entity has failed to comply with and meet the requirements contained in regulations or published administrative requirements of OCS, has failed to fulfill its funded work program, or has breached the terms of its funding agreement with OCS.

If the OCS Assistant Director determines that an emergency situation exists due to threat of imminent loss or waste of OCS funds and that immediate action is required due to the seriousness of the violation and/or is necessary to protect OCS funds or property:

The procedures for termination of status as an eligible entity of a sub grantee shall be as follows:

[GREATER THAN] OCS shall provide the eligible entity with written notice (by certified mail) of OCS' intent to terminate the status of the eligible entity and the reasons for the termination. The notice shall specify the effective date of termination of status and termination of all OCS funded activities, which date shall be no sooner than sixty days from the time of sending such notice to the eligible entity. The notice shall also provide necessary program instructions, including any restrictions on eligible entity expenditures, pending the effective date of termination of status.

[GREATER THAN] The eligible entity may appeal, in writing, to the DCO Director within twenty calendar days following receipt of the notice of OCS'intent to terminate status. This appeal shall address the reasons for termination and, where appropriate, any corrective action taken, or proposed to be taken, by the eligible entity. The appeal may also include a request by the eligible entity that the DCO Director or his/her designee hold a public hearing before making a decision, in which case such a public hearing "on the record" shall be held within twenty days. At this hearing the eligible entity shall have the right to present evidence and argument on all issues contained in the appeal.

[GREATER THAN] The DCO Director shall make specific written findings of fact and conclusions of law and enter one of the following decisions:

The CSBG Act of 1998 requires the State CSBG office to monitor local community action agencies at least once every three years (the Arkansas State CSBG office monitors CAAs annually).

DHS/OCS staff will conduct, at a minimum, an annual on-site program evaluation and compliance review of eligible entities in order to determine whether eligible entities meet the performance goals, administrative standards, financial management requirements and other requirements of the State.

As established in Section 678 B, the State will also conduct:

* an on-site review of each newly designated entity immediately after the completion of the first year in which such entity receives funds

* follow-up reviews including prompt return visits to eligible entities, and their programs, that fail to meet the goals, standards, and requirements established by the State

* other reviews as appropriate, including reviews of entities with programs that have had other Federal, State, or local grants (other than CSBG) terminated for cause

The State lead agency conducts financial and compliance audits of block grant funds, which the State receives under the CSBG Act. Each audit will cover a one-year period and will be conducted in accordance with standards established by the Comptroller General for the audit of the governmental organizations, programs, activities and functions. Use of the Office of Management and Budget cost and accounting standards will apply.

A copy of the audit conducted by the Legislative Audit staff will be made available to the State Legislature 30 days after completion, a copy is provided the Legislative Audit Committee, and a copy will be forwarded to the Secretary. Appropriate documents, papers, and records shall be made available to the Secretary and Comptroller General of the United States, or any duly authorized representatives.

Monitoring of Eligible Entities

Before funds will be released to an eligible entity receiving an initial contract using OCS funds, the eligible entity shall submit a statement to OCS certifying that its accounting system meets OCS financial requirements and standard acceptable accounting practices. The accounting system must have internal controls adequate to safeguard their assets, check the accuracy and reliability of accounting data, promote operating efficiency, and encourage compliance with OCS policies. The certification must be furnished by an independent Certified Public Accountant (CPA).

Reporting - As a condition for funding, the eligible entity signs assurances that it will provide monthly financial reports and quarterly progress reports, in the form and at the time the Office of Community Services requires. State policy 4140 M requires that the eligible entity shall provide monthly fiscal reports on the operation of funded project. This policy also states at the end of each quarter of its program year, the eligible entity shall report on the status of the implementation and operation of its work programs. All quarterly reports submitted to OCS subsequent to the last board meeting shall be presented for review and approval by the board. In addition to other safeguards, assurances are signed that the agency will, on an annual basis, conduct a single agency audit in accordance with OMB circular A-133 covering all funds received by the agency. A copy of the report will be provided to the Department of Health and Human Services.

In accordance with section 678, below is a description of monitoring activities:

Eligible entities must provide monthly financial reports documenting expenditure of funds requested. Reports are reviewed by OCS and fiscal staff to ensure funds requested are consistent with planned expenditures. Payment is made based on the monthly requests.

As part of the eligible entities community action plan (application), a budget is submitted detailing the proposed use of funds. The community action plan containing the proposed budget is reviewed and approved by the Office of Community Services.

The State Office of Community Services monitors will conduct, at a minimum an annual on-site program evaluation and compliance review of eligible entities in order to determine whether eligible entities meet the performance goals, administrative standards, financial management requirements, and other requirements of the State.

* Official Notification - The Office of Community Services monitor contacts the eligible entity by telephone to establish monitoring dates for the program evaluation or compliance review. Follow-up correspondence is sent to the agency as official notification of the monitoring dates.

* Entrance Conference - The entrance conference is held with the executive director or designee(s) to discuss the purpose, process, format, and procedures to be followed during the monitoring visit.

* Exit Conference - An exit conference is held with the executive director or designee(s) to report findings during the monitoring visit. The executive director or designee(s) is given the opportunity to provide comments and present additional evidence where a finding may be disputed by the agency.

* Report to Agency - A monitoring report is forwarded to the agency. All monitoring reports must be reviewed and approved by the agency's Board of Directors.

* Grantee Action Plans - When there are Findings, the eligible entity will be notified in writing, provided suggested recommendations for improvement, and required to submit a plan detailing the actions it will take to correct monitoring findings. Plans should be submitted within the timeframe specified by OCS. Plans are reviewed by OCS to ensure all findings have been adequately addressed. Where findings are not adequately addressed, OCS will make necessary contacts with the eligible entity until all findings have been appropriately addressed, and will notify the agency when their plan is accepted.

The Program Evaluation - The program evaluation is primarily concerned with the quality of program reporting and service delivery as indicated by records and client interviews. During the on-site program evaluation, agency records are reviewed in order to support actual services provided by the eligible entity and reported to OCS. Case management records are reviewed to determine agency and client's progress made in reaching the client's established self-sufficiency goals. Monitors verify documentation at the eligible entities sites, and interviews with randomly selected clients are conducted to verify that services were provided as reported and to determine whether clients are satisfied with services received. A satisfaction survey is completed on each randomly selected client interviewed.

Compliance Review - The compliance review is primarily concerned with the review of eligible entity program administration and planning, financial functions, board leadership and development, agency director leadership and other requirements of the State.

During the on-site compliance review, agency records are reviewed in order to determine compliance in specific areas including but not limited to: obligation to provide services in designated area; adequate board representation; board powers, responsibilities and training; composition of board committees; by-laws requirements; public hearings; statement of purposes and strategy, and needs assessment requirement; eligible activities; eligible populations and residency; requirements for funding application; grant award; citizens access; code of conduct; and financial record keeping. During the on-site review, monitors verify records to determine agency compliance with CSBG policies and procedures. Board members, and in some instances the Executive Director, are interviewed to determine the level of knowledge of board powers, roles and responsibilities, as well as responsibilities of the Executive Director.

Monitoring of newly designated entities - OCS will conduct an on-site review of each newly designated entity immediately after the completion of the first year in which such entity receives funds. Follow-up reviews will be conducted including prompt return visits to eligible entities, and their programs, that fail to meet the goals, standards, and requirements established by the State. Other reviews will be conducted as appropriate, including reviews of entities with programs that have had other Federal, State or local grants (other than CSBG) terminated for cause.

Designation of New Eligible Entities

If an existing eligible entity terminates its service, the Office of Community Services will solicit applications from eligible entities and designate an eligible entity to provide services in the non-served area. The eligible entity shall be:

* The private non-profit eligible entity shall administer the Community Services Block Grant Program through a tripartite board that fully participates in the development, planning, implementation, and evaluation of the program to serve low-income communities

*

* The members of the board shall be selected by the entity

* The board shall be composed so as to assure that:

The board shall be constituted so as to assure that no less than one-third of the members are representatives of low-income individuals and families in the neighbourhoods and that they reside in the neighbourhoods served.

Corrective Action, Termination or Reduction of Funding

The State will comply with the requirements of Section 678C of the Act, in regard to corrective action, termination, or reduction of funding. Section 3200 of CSBG policies outlines these procedures in a section entitled, "Corrective Action, Suspension, Termination and Establishment of Eligible Entity Status". The policy is as follows:

Corrective Action: OCS shall require an agency to submit a Quality Improvement Plan (QIP) when OCS determines that an eligible entity has failed to comply with and meet the requirements contained in regulations or published administrative requirements of OCS, has failed to fulfil its funded work program, or has breached the terms of its funding agreement with OCS.

If the OCS Assistant Director determines that an emergency situation exists due to threat of imminent loss or waste of OCS funds and that immediate action is required due to the seriousness of the violation and/or is necessary to protect OCS funds or property:

* OCS shall provide the eligible entity with written notice (by certified mail) of OCS' intent to terminate the status of the eligible entity and the reasons for the termination. The notice shall specify the effective date of termination of status and termination of all OCS funded activities, which date shall be no sooner than sixty days from the time of sending such notice to the eligible entity. The notice shall also provide necessary program instructions, including any restrictions on eligible entity expenditures, pending the effective date of termination of status.

* The eligible entity may appeal, in writing, to the DCO Director within twenty calendar days following receipt of the notice of OCS'intent to terminate status. This appeal shall address the reasons for termination and, where appropriate, any corrective action taken, or proposed to be taken, by the eligible entity. The appeal may also include a request by the eligible entity that the DCO Director or his/her designee hold a public hearing before making a decision, in which case such a public hearing "on the record" shall be held within twenty days. At this hearing the eligible entity shall have the right to present evidence and argument on all issues contained in the appeal.

* The DCO Director shall make specific written findings of fact and conclusions of law and enter one of the following decisions:

* Mutual Respect

In working with CAA boards, staff, and consultants, the Arkansas State CSBG office values and recognizes the unique knowledge, ability, and independence of each person. The State CSBG office is committed to treating all persons fairly and maintaining credibility by matching actions with words.

* Open Communication

Effective communication is key in facilitating good working relationships with partners and the State CSBG office is committed to keeping lines of communication open. The purpose of communication is to assist in developing solutions to problems, to share program improvement ideas, and to provide information on new developments in the anti-poverty field.

* Joint Problem Solving

The State CSBG office operates under the basic belief that a team approach to problem solving is in the best interest of all parties involved. The State CSBG office want to promote an environment in which the office and all Community Action partners will be open to change and can work together in exploring options and developing mutually agreeable solutions.

CAAs often focus their energies on 'preparing for the monitoring test', instead of implementing on-going SYSTEMS that will identify areas needing improvement.

The State CSBG office will assess the health of the entire agency, not just program-by-program compliance. This assessment will include general oversight, desk reviews, and on-site reviews of the following: community action plan, needs assessments, service delivery systems, administration/management systems, board and governance systems and financial systems.

Governance - CSBG Law. Section 676B and Section 676(b)(10)

* Board of Directors - composition, training, effectiveness, knowledge of roles and responsibilities, and attendance.

Planning- CSBG Law. Section 676B(a)(l). Section 676B(b)(2). and Section 676(b)(U)

* Agency Mission, Vision and Values

* Strategic planning, evaluation, and community assessment

Evaluation - CSBG Law. Section 678E and Section 676(b)(12)

* ROMA Implementation (Board and staff) on an agency-wide basis as a framework for sound management

* Agency outcomes and performance measures

* Reporting to funders and to the Board of Directors

Partnerships - CSBG Law. Section 676(b)(9)

* Coordination, collaborations and linkages with relevant partners

Administrative systems and procedures - CSBG Law, Section 678D, Section 678F

* Human Resources and personnel polices

* Procurement and inventory records

* Policies and Procedures Manuals

* CSBG Assurances and Prohibitions

Fiscal Systems and Procedures - CSBG Law. Section 678D and 678F

* Review monitoring reports for other funding sources

* Review Chart of Accounts and financial reports

* Review purchases and support documents

Governance - CSBG Law. Section 676B and Section 676f bMl(»

Composition

* Is the Board fully seated?

* How many openings are on the board and from which sectors?

* How long have these vacancies been open?

* Describe procedure used to fill vacancies.

* Board members representing a specific geographic area reside within the community he/she represents? Describe method used to verify residence.

* Has any board member exceeded the ten-year service limitation requirement?

* What is the board orientation process for new members?

Training

* Does the board have an awareness of ROMA concepts as a result of ROMA training?

* Does the agency have an approved Board and Staff Development Training Plan?

Effectiveness

* How does the board exercise oversight and ensure accountability for agency outcomes and fiscal integrity?

* Do the bylaws accurately reflect current practices including: elections, committee composition, attendance policy, annual meetings and vacancies?

Knowledge of roles and responsibilities

* Does the board conduct an annual evaluation of the Executive Director?

* Is there a job description for the Executive Director?

*

* What reports are provided to the board to keep it informed about progress, problems or changes needed in agency programs (listen for types of reports)

Attendance

* If a review of the board minutes indicates low attendance, what efforts are being made to increase board member attendance? (Listen for familiarity with recruitment processes)

Planning - CSBG Law, Section 676B(aKl), Section 676B(b)(2),

ancj gectjgn tfttM 11)

Agency Mission, Vision and Values

* The agency has a written mission statement that is understood by staff and board

Strategic planning, evaluation, and community assessment

* The agency has a current written strategic plan

* The strategic plan reflects understanding and application of ROMA goals and measures

* The strategic plan includes all programs and activities

Evaluation - CSBG Law. Section 678E and Section 676(b)(12)

* ROMA Implementation (Board and staff) on an agency-wide basis as a framework for sound management

* Agency outcomes and performance measures

* Reporting to funders and to the Board of Directors

Partnerships - CSBG Law, Section 676(b)(9)

* Coordination, collaborations and linkages with relevant partners

Administrative systems and procedures - CSBG Law, Section 678D, Section 678F

* Human Resources and personnel polices

* Procurement and inventory records

* Policies and Procedures Manuals

* CSBG Assurances and Prohibitions

* Pending and past litigation

Fiscal Systems and Procedures - CSBG Law, Section 678D and 678F

* Monitoring reports for other funding sources

* Chart of Accounts and financial reports

* Purchases and support documents

* Audit and results of previous/other monitoring/fiscal issues

* Entrance meeting - Executive Director and other Agency Staff

* Schedule and conduct interviews with Board, Clients and Partners

* Schedule dates and times for review of CSBG Program documentation

* Schedule dates and times for review of Agency finance documentation

* Schedule exit meeting - Executive Director and other Agency Staff

* No findings will be added to the monitoring report that was not discussed at the exit interview.

* The CAAs will receive a timely written report after the on-site visit which will officially inform the agency of any findings and/or deficiencies.

* When there are findings, the CAA must submit a corrective action plan detailing actions it will take to address monitoring findings. Plans must be submitted to OCS for approval, within the timeframe specified.

* The State CSBG office and ACAAA will be available to provide training and technical assistance as deemed necessary.

Department of Human Services

Office of Quality Assurance - Internal Audit

Certification of Receipt of Services

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There are 16 Community Action Agencies in the State of Arkansas, which will provide statewide coverage for all 75 counties. A range of programs and services for low-income and elderly residents will address the following components, in accordance with the CSBG Act: self-sufficiency, employment, education, income maintenance, housing, emergency services, nutrition, community participation, health, and welfare independence. Conditions addressed are a result of needs assessments conducted by eligible entities.

In addition to CAA Offices, the service delivery system will include the following facilities to maximize the reach and impact of eligible entities:

County Outreach Offices

Community Development Corporations

Emergency Homeless Shelters

Family and Community Service Centers

Family Planning Clinic

Food Banks/Food Pantries

Head Start/Early Head Start Centers

Neighborhood Service Centers

Non-profit Technical Center

Resource Centers

Senior Citizens Centers

Substance Abuse Centers

WIA One-Stop Center

Community Dental Clinic

Additionally, eligible entities will offer the following programs, services and activities, including advocacy, counseling, family development, and case management:

As a condition for funding, Arkansas CSBG Policy 4140 requires eligible entities to establish linkages between governmental and other social services programs to assure the effective delivery of such services to low-income individuals, identify gaps in services through the provision of information, referrals, case management and follow-up consultation, including the organizations listed below. Also, eligible entities will continue to partner with, as well as support innovative community and neighborhood-based initiatives related to the purposes of the CSBG Act.

The State will not approve an application which does not address a minimum number of designated services called for in Section 676 (b)(l)(A-C) of the Act and no activities are approved which are outside the scope of services called for in that section of the Act. In that way, the requirements of Section 676(b)(l)(A-C) about use of the funds for provision of allowable community services are met from a planning aspect.

The State requires, as a condition of continued funding, that eligible entities provide monthly fiscal reports and quarterly program reports to assure that the programs and expenditures are progressing consistently with the approved plans. Any downward program variances of 20% or more where eligible entities did not meet their plan must be satisfactorily explained. Corrective actions must be supplied where appropriate. In addition to the reports submitted and reviewed, each eligible entity is visited at least once annually for an on-site evaluation of program performance, as well as compliance monitoring of Federal and State Policies and Procedures regulatory requirements. This is intended to assure that funds are used to provide community services to low-income clients as in the approved plan. Spot checks of client records are carried out to verify the documentation provided by the eligible entities, and interviews with randomly selected clients are conducted to verify that services were provided as reported and to see whether clients are satisfied with services received. A satisfaction survey will be completed on each randomly selected client. The program reviews will be conducted annually, at a minimum, as stated earlier, in accordance with the Act.

Training and technical assistance are provided during the course of a year to further enhance the quality of the services and programs.

A Community Action Agency Peer Review will be conducted on at least six eligible entities annually. The purpose of the Peer Review is to assess the design, performance, efficiency, and effectiveness of the agency's management systems, to ensure compliance with applicable laws, rales and regulations to safeguard the agency's assets, ensure that planned outcomes are achieved, and to project eligible entity vision/values through the organization into its community.

Compliance with Section 676 (b) (2) Use of Discretionary Funds

No more than 5% of the grant will be spent as a discretionary fund within the State agency to fund activities deemed to be useful to advance the purposes of the Act. In fiscal years 2014-2015, approximately 20% of CSBG funds will be set aside for victims of natural disasters who meet the poverty guidelines. Approximately 50% will be used to provide technical assistance and training needed by eligible entities and organizations which serve the low-income communities, which training and assistance would not otherwise be available to them. The remaining 30% will be used to fund discretionary projects of CAAs, nonprofit agencies and organizations. The percentages are only estimates of discretionary fund usage. The State's needs will dictate the criteria and guidelines for such projects.

Compliance with Section 676 (b) (3) Secure Information from Eligible Entities

Compliance with Section 676 (b) (4) Nutrition and Emergency Assistance

The State will require eligible entities to include in community action plans how they will comply with the federal requirement to provide, on an emergency basis, for the provision of such supplies and services, nutritious foods, and related services, as may be necessary to counteract conditions of starvation and malnutrition among low-income individuals.

Compliance with Section 676 (b) (5) Coordination and Linkages

The State and eligible entities will coordinate and establish linkages between, governmental and other social services programs to assure the effective delivery of such services to low-income individuals and to avoid duplication of such services. As a condition for funding, Arkansas CSBG Policy 4140 requires eligible entities to establish linkages between governmental and other social services programs to assure the effective delivery of such services to low-income individuals, identify gaps in services through the provision of information, referrals, case management and follow-up consultation. Eligible entities also describe in their community action plans how they will coordinate with other programs and leverage additional public and private resources.

CAAs will continue to serve on local Workforce Investment Boards, as a result of the Office of Community Services' participation in the statewide workgroup to assist in the development of the Workforce Investment Act Unified State Plan.

Compliance with Section 676 (b) (6) Coordination of Anti-Poverty Programs

Both the CSBG program and the State HEAP program for Emergency Crisis Intervention are located in the same agency of State Government (Arkansas Department of Human Services). The Governor and the Director of the Department of Human Services have made it clear to both programs that they support and encourage the coordination of local anti-poverty activities with the crisis intervention program. This has been in effect for several years. The eligible entities have utilized the HEAP Program in both assuring appropriate disbursals of crisis funds to eligible persons, and also in supporting weatherization services through this program.

Compliance with Section 676 (b) (7) Cooperation with Federal Investigations

The director and staff persons of the State Agency are directed and required to cooperate fully with any federal investigation relative to State use or eligible entity use of CSBG funds. Any additional resources of State Government necessary to assist in such investigations are pledged, and will be provided. Each eligible entity is required, as a condition of funding, to provide written assurances they will allow and cooperate with any Federal or State investigation relative to the use of CSBG funds.

Compliance with Section 676 (b) (8) Termination of Funding

As outlined in section 678C (b) of the Act, the State will comply with the hearing review requirement when the State determines an eligible entity's designation will be terminated or funds reduced.

Compliance with Section 676 (b) (9) Program Coordination and Partnerships

The State Agency and eligible entities will, to the maximum extent possible, coordinate programs with and form partnerships with other organizations serving low-income residents of the communities and members of the groups served by the State, including religious organizations, charitable groups, and community organizations. As a condition for funding, eligible entities will describe how they will coordinate programs.

Compliance with Section 676 (b) (10) Petition for Board Representation

Each eligible entity will be required to establish procedures for a low-income individual, community organization, or religious organization, or representative of low-income individuals that considers its organization, or low-income individuals, to be inadequately represented on the board (or other mechanism) of the eligible entity to petition for adequate representation.

Compliance with Section 676 (b) (11) Community Needs Assessments

The State will comply with the requirement to secure from each eligible entity in the State, as a condition for funding, a community action plan. Each community action plan will include: a community needs assessment for the community served; a description of the service delivery system targeted to low-income individuals and families in the service area; a description of how linkages will be developed to fill identified gaps in services through information, referral, case management if applicable, and follow-up consultation; a description of outcome measures to be used to monitor success in promoting self-sufficiency, family stability, and community revitalization. Community needs assessments may be coordinated with community needs assessments conducted for other programs.

Compliance with 676 (b) (12) Participation in ROMA

The State and all eligible entities in the State are participating in the Results Oriented Management and Accountability System that meets requirements.

The State and eligible entities began implementation of ROMA in fiscal year 1997. Fiscal year 2012 will be the 15th year the State and eligible entities have been participating in ROMA at the state level.

Eligible entities are mandated to report outcomes for the six national goals and performance indicators. Eligible entities must report outcome measures under each appropriate goal for all major programs and activities administered. Reporting on

measures is an important component of the broader community action initiative to revitalize and strengthen the community services network.

Case management is one process used by agencies to assist clients to reach their established goals and move them toward self-sufficiency. Although outcomes are reported under the measures selected, the range of activities and services provided by the agency to assist clients are reported by program components (i.e. education, housing, emergency services, etc.).

Case management activities are monitored annually as a part of the regular program evaluation of agencies. Statewide training sessions are provided to all CAAs. If there is a need for training and technical assistance during routine monitoring visits, state monitors will provide training or provide needed assistance. Additionally, statewide trainings are scheduled for all CAAs as needed, and a ROMA Workgroup consisting of CAAs, State OCS, and ACAAA staff meet quarterly.

Compliance with 676 (b) (12) Implementation of Assurances

The "Plan for Compliance with Federal Statutory Assurances" describes how the State will implement and comply with the assurances outlined in the Act, as agreed.

Statement for Loan Guarantees and loan Insurance

The undersigned states, to the best of his or her knowledge and belief, that:

If any funds have been paid or will be paid to any person for influencing or attempting to influence an officer or employee of any agency, a Member of Congress, an officer or employee of Congress, or an employee of a Member of Congress in connection with this commitment providing for the United States to insure or guarantee a loan, the undersigned shall complete and submit Standard Form-LLL, "Disclosure Form to Report Lobbying," in accordance with its instructions. Submission of this statement is a prerequisite for making or entering into this transaction imposed by section 1352, title 31, U.S. Code. Any person who fails to file the required statement shall be subject to a civil penalty of not less than $10,000 and not more than $100,000 for each such failure.

Signature

Title

DHS/DCO/Office of Community Services_____

Organization

CERTIFICATION REGARDING ENVIRONMENTAL TOBACCO SMOKE

Public Law 103227, Part C Environment Tobacco Smoke, also known as the Pro Children Act of 1994, requires that smoking not be permitted in any portion of any indoor routinely owned or leased or contracted for by an entity and used routinely or regularly for provision of health, day care, education, or library services to children under the age of 18, if the services are funded by Federal programs either directly or through State or local governments, by Federal grant, contract, loan, or loan guarantee. The law does not apply to children's services provided in private residence, facilities funded solely be Medicare or Medicaid funds, and portions of facilities used for inpatient drug or alcohol treatment. Failure to comply with the provisions of the law may result in the imposition of a civil monetary penalty of up to $1000 per day and/ or the imposition of an administrative compliance order on the responsible entity. By signing and submitting this application the applicant/grantee certifies that it will comply with the requirement of the Act.

The applicant/ grantee further agrees that it will require the language of this certification be included in any sub awards which contain provisions for the children's services and that all sub grantees shall certify accordingly.

Signature

_________Assistant Director___________________

Title

DHS/DCO/Office of Community Services Organization

CERTIFICATION REGARDING DEBARMENT, SUSPENSION AND OTHER

RESPONSIBILITY MATTERS

Certification Regarding Debarment, Suspension, and Other Responsibility Matters-Primary Covered Transactions

Instructions for Certification