Arkansas Administrative Code
Agency 016 - DEPARTMENT OF HUMAN SERVICES
Division 20 - Division of County Operations
Rule 016.20.17-003 - Community Service Block Grant

Section I - Program Scope Mission, Roles and Responsibilities

The mission of the Arkansas Department of Human Services is to improve the quality of life of all Arkansans by protecting the vulnerable, fostering independence, and promoting better health.

The Arkansas Department of Human Services, Divison of County Operations, Office of Community Services (DHS/DCO/OCS) is the agency designated by the Governor to administer and distribute Community Services Block Grant (CSBG) funds.

In its second role, the State Lead Agency is responsible for performance-based reporting of Community Services Block Grant funds. This entails the collection of data from each agency, then compiling the data and submitting reports to the federal agency that is responsible for the funds. In the case of CSBG funds, the performance-based element is referred to as ROMA -Results Oriented Management and Accountability.

A third role, or responsibility, that the State Lead Agency has is that of providing training and technical assistance to the eligible entities' executive directors, board members and staff. Training and technical assistance covers a wide range of subjects including, but not limited to, workshops on succession planning, ROMA, case management, financial management, CSBG Organizational Standards, reporting, OMB guidance, monitoring and board governance. Technical assistance is provided both as a response to requests and as a result of monitoring reviews that indicate weaknesses. The State Lead Agency strongly encourages all of the eligible entities to request technical assistance if they encounter issues or situations in which they feel guidance is needed. The State Lead Agencies' primary goal, exceeded only by the programmatic assurances set forth in the act, is to ensure that all CSBG funds and programs are administered to all sub-grantees in accordance with the law.

The fourth role of the State Le-ad Agency is determining if funds are used in accordance with applicable federal and state laws, rales, regulations, or policies. The determination is made through monitoring reviews as well as audit reports. In those instances where it is determined that the use of funds was not m compliance with applicable laws, rales, regulations, or policies, then corrective action must be determined. If the determination includes disallowed costs that must be repaid, then the sub-grantee will be required to reimburse those funds to the State. The State will, in turn, remit the reimbursed funds to the funding source.

The State Lead Agency's fifth role with respect to eligible entities is that of partner. DHS/DCO/OCS works in partnership with not only the entities, but also; with other funding sources, state agencies, and the Arkansas Community Action Agencies Association (ACAAA).

The partnerships serve as a means to provide the mddest range possible of services to the low-income iri the most cost- effective and efficient maimer. DSH/DCO/OCS will work directly with

each eligible entity and its board pertaining to contractual matters or the affairs of that particular

agency.

Revision of Rules and Procedures

Periodically it will be necessary to change or revise procedures and requirements. This may be in response to new Federal or State regulations, changing circumstances among the low-income population, or resources available to low-income citizens. Therefore, the State Lead Agency will review the procedures contained in this manual on a regular basis and issue any changes in the form of DHS/DCO/OCS Policy Letters.

A Policy Letter is an official means of communication in which pertinent policy and procedure changes are distributed to each eligible entity across Arkansas and to the Arkansas State Association. The State Lead Agency will ensure that all entities receive notice of policy/procedure changes via Policy Letters, and will make the appropriate revisions to the CSBG Policies and Procedures manual as needed under the guidance of the DHS/DCO Director.

Severability

The provisions of these regulations are severable, and if any provision is held unconstitutional or a violation of statute by any court of competent jurisdiction, or shall otherwise cease to be effective, all other provisions of these regulations shall remain in effect.

Implementation

Each eligible entity shall take all necessary steps, including but not limited to the adoption of amendments to existing by-laws, in order to comply with the requirements of these regulations at their effective date

Citizen Access and Privacy

The following documents must be made available for public inspection:

Funding applications submitted to the State Lead Agency;

! The eligible entity's most recent Articles of Incorporation, by-laws, board membership list, needs assessment and strategic plan; *t* All contracts (including funding, consulting, goods and services) pertaining to CSBG

funds; *l* All final reports (including audits) made to the State Lead Agency on projects funded with CSBG funds;

Minutes of the meetings of the Board of Directors;

Position titles, salary ranges and job descriptions for all compensated positions.

These documents may be made available to the public at the eligible entity's office at a reasonable time scheduled by the eligible entity and as agreed to by the person requesting the information.

If the requesting person wishes copies of the document and it is feasible to provide such copies, the eligible entity may request a reasonable fee, not to exceed actual costs; for the copying of such documents.

State and federal regulations shall apply for privacy of personal data held by the eligible entity relative to CSBG supported personnel, programs and activities.

Programmatic Assurances

"The purposes of the Community Services Block Grant Program are:

Section II - State Plan and Appropriation of Funis

State Plan

The State Lead Agency must develop an application and State plan to submit to the Department of Health and Human Services covering a period of no less than one fiscal year and no more than two fiscal years. This plan must be submitted no later than thirty days prior to the beginning of the fiscal year covered by this plan.

The State Lead Agency is required to hold at least one public hearing in the state giving sufficient time and notice of the hearing to provide the public the opportunity to comment on the proposed use and distribution of funds prior to the submission of the State plan to the Department of Health and Human Services.

hi order to be eligible to receive CSBG funding, the State shall conduct one legislative hearing every three years in conjunction with the development of the State plan,

Annual AUocation

Funds appropriated for the purpose of the Community Services Block Grant shall be allocated annually to eligible entities in proportion to the size of the poverty-level population served by the agency when compared to the size of the poverty-level population and available resources in the state. "Poverty-level population" means the number of people whose household income is below the official poverty line established by the United States Director of the Office of Management and Budget (0MB). Arkansas has used a funding formula that has taken into account the poverty-level population served by the agency, but that also contained a factor identified as a "hold-harmless" indicator. This formula will remain in place for the FY 2018.

During FY 2018, the State Lead Agency will research funding formula from other states, will identify (in accordance with CSBG IM 116) and adopt the funding formula that will best support the work of the Arkansas CSBG network. This new formula will be implemented in the year following its adoption.

All of the Arkansas eligible entities must operate its CSBG related programs on a reimbursement basis. Full documentation of expenses must accompany requests for reimbursement.

Section III - Policies of Governing Boards

Legislative Mandate

CSBG Act (42 U.S.C. 9901 et seq.) as amended in 1998, requires the State Lead Agency to provide assurance that each community action agency or non-profit organization administering the Community Ser\4ces Block Grant Program have a tripartite board which will be constituted as follows:

Section IV - State Community Services Program Implementation

Program Overview

The Service Delif ery System- The provision of CSBG services to individual low-income persons statewide is carried out primarily through Arkansas's eligible entities (community action agencies). The State Lead Agency will provide 90 percent of its CSBG allocation to these sixteen (16) community action agencies (eligible entities) for the provision of services in each applicable CSBG assurance area. These entities provide services to low-income people in each of the state's seventy-five (75) counties.

Linkages- A programmatic element of the work plans submitted by the eligible entities will include the development of linkages and cooperative agreements locally.

Coordination with Other Pubiic and Private Resources- Other public and private funding resources are submitted with estimated amounts leveraged as part of each community action agency's plan. The State Lead Agency requires each local entity to submit coordination plans for their grant activity. The coordination plan describes how local entities have conferred with area service providers and established working relationships, how linkages have been developed to fill identified gaps in services, how funding will be coordinated with other public and private resources, and how all the above will result in a multi-program impact on the client's progress toward self-sufficiency. As The State Lead Agency becomes aware of available grants, the information will be disseminated to the eligible entity network either directly or through the Arkansas State Community Action Agencies Association (ACAAA).

Innovative Community and Neighborhood-Based Initiatives- Local entities use these funds to support iimovative community and neighborhood-based initiatives related to the purpose of the Community Services Block Grant, including fatherhood initiatives and other initiatives with the goal of strengthening families and encouraging effective parenting.

Community Assessment

As a condition of ftxnding, each sub-grantee is required to submit every three (3) years a comprehensive community needs assessment for the community served. The community assessment may be coordinated utilizing assessments conducted for other programs; however, a single funding source needs assessment may not be substituted for the required three (3) year CSBG Conamunity Assessment (CSBG Org. Standard Category 3). Each entity is responsible for conducting or securing its own needs assessment. The needs assessment of each entity shall describe how the assessment was conducted and provide aggregate results. The goals and objectives of each entity are based upon the findings of the assessment. The State Lead Agencies realizes that eligible entities require flexibility in conducting a local needs assessment, as each area varies in the resources available and the services provided.

The CSBG Act (Section 676(b) (11)) requires an "assurance from the State that each Community

Action Agency must conduct a community-needs assessment for thecommunity served,

which may be coordinated with community-needs assessments conducted for other programs,,."

The assessments must be updated at least annually or when major changes occur within that agency's geographic sendee area (i.e., loss of major employer, iiatttral disaster, etc.)

A Community Assessment is an instrameat utilized by the agency to gather information and data about a service area's opinions, needs, challenges and available resources to assist the agency in developing a plan to strategically address the needs identified at the conclusion of the assessment.

The eligible entity should begin by designating a staff member or members to an assessment committee. This employee/committee should possess knowledge of ail the social ser\'ice providers, community-based organizations, government agencies, and other pertinent

organizations within their service area that are willing to collaborate and share information with the agency about present and emerging needs facing the area. The following are some beneficial community assessment tools:

** Interview - Collect information from community members who are in a position to be very familiar with community needs. These people might be community leaders, professionals, clients, or other individuals who have affiliations with particular organizations or agencies.

Public Fomm - Assemble a wide range of community members at public meetings to gather information via group discussions.

Focus Group - Obtain opinions and ideas from a small, targeted group of community members.

** Survey - Use a formal survey instrument or questioxmaire to collect data from community members and clients.

Secondary data analysis - Review and analyze data that has already been collected regarding community issues and needs by social service and partner agencies.

*** Asset mapping - Gather information about existing community assets and resources.

Some factors that might influence the type of assessment an eligible entity selects will include time, cost, target audience, and agency capacity. Ideally a community assessment should consist of a combination of data collection methods. The assessment shouldinclude:

A community assessment team;

J* Purpose of the assessment (goals and objectives, parties involved, data collection dates, etc.);

Needs assessment tools and methodologies (focus groups, key informants, surveys, forums, etc.);

A plan for the assessment (who, what, when, where, how);

Implementation of the assessment using the selected tools;

An analysis of the results;

An executive summary including key findings and priorities; and

Utilize report to determine agency response.

A community action guide for conducting comprehensive community assessments is available at

www.NASCSP.org.

The type of information gathered will depend on the entities' service area and its specific needs. However, the follom-ing information must be gathered in all community assessments:

* Description of the entities' service area and statistical profile of the area including charts,

graphs, maps, etc.;

Needs identified by community leaders and members;

*l*Community Perspectives (Recurring themes, key quotes, etc.);

*t*Current action being taken to meet community needs;

Local resources available to help meet community needs, and their scope of sendees;

Opportunities for projects;

Challenges to projects (gaps in services, duplication, etc): Involvement of the community in the project; and

[GREATER THAN] Long-term sustainability of the project by the community.

The data collected during the community assessment must be analyzed and compiled into a report and presented to the entities' board of directors. Prior to submitting the assessment to the board, these findings should be refined and translated into key findings and emerging trends affecting the service area. Based upon the needs identified during the assessment, entities can select areas within their service area which may require additional services or issues that have emerged since the last assessment which will need to be prioritized by the entity.

Section V - Community Action Plan (CAP) and Procedures Introduction

In order to receive funding for an upcoming fiscal year, eligible entities are required to submit a Community Action Plan (CAP) to the State Lead Agency as a part of the annual application plan. The State Lead Agency has developed a supplemental Community Action Plan (CAP) manual which thoroughly demonstrates what each community action agency will be required to submit each year in order to be eligible to receive CSBG funding. This section merely serves as a reference for agency compliance with State application requirements.

Requirements

Section VI - CSBG Grant Operation

CSBG Allowable Activities/Costs

Community Services Block Grant (CSBG) allowable costs are those that support services and activities which are targeted to the low-income population to alleviate poverty and to promote self-sufficiency for those individuals and families.

For CSBG program reporting requirements, the HHS Office of Community Services (OCS) defines "direct" program and "administrative" costs in accordance with three criteria;

Section VII - Sub Grantee Requirements

Agency Personnel Policies and Procedures

Category 7 of the CSBG Organization Standards require each eligible entity to have a comprehensive personnel policy for their agency that has been reviewed by an attorney and approved by the governing board within the past 5 year. The entity will be solely responsible for the development of their own personnel policy; however, each entity's policy will be required to address the following tenets:

Section VIII - Financial Policies and Procedures

Financial Guidelines

All eligible entities are required to maintain an updated Financial Procedures Manual which establishes procedures to meet each fiscal standard as set forth in these requirements. This manual will set forth the procedures for the authorization of purchases, approval of obligations, preparation of vouchers, the signing of checks, the recording of financial data in books or record, inventory control and, in general, the safeguarding of assets and records. The completed manual must be reviewed by staff every two years, and any amendments thereto must be approved by the eligible entity's Board of Directors. (CSBG Org Standard Category 8)

Fidelity Bond

Each entity is required to have a current fidelity bond providing coverage at a minimum 10% of any funds in which the agency is liable for the reimbursement of Federal and/or State funds to the grantor. HHS reserves the right to require agencies to maintain adequate bonding and insurance if the current bonding or insurance is deemed inadequate to protect the interests of the Federal Government.

The eligible entity must, as a condition for the receipt of CSBG funds, secure fidelity bond coverage for appropriate eligible entity officials. Coverage must be secured for each person authorized to sign or countersign checks or to transport, maintain custody of, or disburse sizable amounts of cash (such as for payrolls) in the minimum amount equal to ten percent of the total funds awarded to be disbursed.

Prior to its initial agreement with the State Lead Agency for funding, each eligible entity shall submit assurance that this condition has been met. This assurance shall take the form of a letter from a bonding company or agent stating the type of bond, amount and period of coverage, positions covered, and the annual cost of the bond that has been obtained. The State Lead Agency must be notified by the eligible entity within thirty days of any changes in bonding coverage.

The Employee Retirement Income Security Act of 1974 (ERISA) is a federal law that sets minimum standards for most voluntarily established pension and health plans in private industry to provide protection for individuals in these plans.

The State Lead Agency also requires the each eligible entity provide proof of adequate coverage under ERISA and a Director's and Officer's policy.

Fiiiancial Management

Federal awarding agencies shall require recipients to relate fmancial data to performance data and develop unit cost information whenever practical. The following requirements have been cited from 0MB Circular. Strict adherence to these regulations will be verified through agency monitoring visits. Agencies are required to maintain a cash receipts journal, cash disbursement journal, and a general ledger. Each eligible entity is mandated to meet the minimum requirements of CSBG Organizational Standard Category 8 as it pertains to financial management-

Agencies' financial management systems shall provide for the following.

Accurate, current and complete disclosure of the financial results of each federally-sponsored project or program.

Records that identify adequately the source and application of funds for federally-sponsored activities. These records shall contain information pertaining to Federal awards, authorizations, obligations, unobligated balances, assets, outlays, income and interest.

[GREATER THAN] Effective control over and accountability for all funds, property and other assets.

Recipients shall adequately safeguard all such assets and assure they are used solely for authorized purposes. t* Comparison of outlays widi budget amounts for each award. Whenever appropriate,

financial information should be related to performance and unit cost data.

Written procedures for determining the reasonableness, allocability and allowability of costs in accordance with the provisions of the applicable Federal cost principles and the terms and conditions of the award.

Accounting records including cost accounting records that are supported by source documentation.

Audit to determine, at a minimum, the fiscal integrity of financial transactions and reports, and the compliance with laws, regulations, and administrative requirements. The eligible entity will schedule and complete such audits amiually.

Agencies will be responsible for maintaining a cash receipts journal in which all transactions are recorded thoroughly with the correct corresponding amounts. In the instance there is some type of refund, this credit will be recorded in the journal accompanied by an explicit explanation of this transaction.

In addition to a cash receipts journal, all agencies must maintain a cash disbursement journal documenting all expenditures.

In accordance with OMB Subpart C § 21 (b) (3), all agencies are encouraged to have dual signature checks. DHS/DCO/OCS encourages one of these signatures be that of a designated

Board Member and the other a designated staff member. Agency checks should always be kept in a secure area that can be locked to prohibit access from unauthorized personnel.

The State Lead Agency prohibits the use of signature stamps due to the iminhibited potential for fraud.

The eligible entity must ensure all checks are numbered consecutively with any missing checks accounted for by financial staff,

The Eligible Entity Executive Director shall receive a monthly budget to compare budgeted costs with actual costs. When possible, financial information should be related to performance data.

All entities will be required to maintain all accounting documentation as well as supporting documentation to augment any expenditures and/or credits as deemed necessary. The following documentation must always be maintained by the agency:

J* Initialed invoices validating prior approval of payment

hvoices with the grant number and grant name clearly identified on the document

Invoices shall include a description of the services rendered or items purchased. The invoice will also include the identification of the vendor, unit price (if applicable), and total cost to be charged to CSBG fimds.

Personnel charges will be documented with time and attendance records. Records must be based on an after-the-fact determination of the actual activity of each employee. Budget estimates do not qualify as support for charges to awards.

All contracts utilizing CSBG funds must be in writing

Travel costs will be thoroughly documented indicating time, purpose, mode, point(s) of destination and expense. All travel must have prior approval from the appropriate agency official and retained for documentation.

Although not mandated by OMB, in order to conform with GAAP best practices the State Lead Agency recommends that all entities develop a program to back-up financial documents. Each entity can develop its own contingency procedures as deemed necessary, as long as some type of procedure is enacted for the protection of financial records.

There is no match requirement.

Any eligible entity whose bookkeeping/accounting is being performed by an independent accounting firm may not use the same firm for auditing purposes.

Carryover Funds

Eligible entities will be allowed to reprogram up to 20% CSBG funds from their annual CSBG budget. Eligible entities are encouraged to conduct periodic internal evaluations of programs, compare actual expenditures with budgets and develop appropriate programs in order to ensure a pattern of reprogramming funds is not a practice.

ProcMrement Procedttres

All agencies are required to establish written procurement procedures. The procedures will, at a miHimEiii, ensure:

*l* Recipients avoid purchasieg unnecessary items

*t* Where appropriate, an analysis is made of lease and purchase alternatives to determine which would be the most economical and practical procurement for the Federal Government.

Solicitations for goods and services provide for all the following.

A deal' and accurate description of die technical requirements for the material, product or service to be procured. In competitive procurements, such a description shall not contain features which undiilv restrict competition,

J IT

Requirements which the bidder/offeror must fulfill and ail other factors to be used in evaluating bids or proposals.

A description, whenever practicable, of technical requirements in terms of functions to be performed or performance required, including the range of acceptable characteristics or minimum acceptable standards.

J* The specific features of "brand name or equal" descriptions that bidders are required to meet when such items are included in the solicitation. *[GREATER THAN] The acceptance, to the extent practicable and economically feasible, of products and services dimensioned in the metric system of measurement. [GREATER THAN] Preference, to the extent practicable and economically feasible, for products and services diat conserve natural resources and protect the environment and are energy efficient.

All procurement transactions shall be conducted in a manner to provide, to the maximum extent possible, open and free competition. The agencies should be cognizant of organizational conflicts of interest in addition to noncompetitive practices among contractors that could potentially obstruct fair competition or fair trade.

All agencies shall comply with the nonprocurement debarment and suspension common nde implementing E.O.s 12549 and 12689, "Debarment and Suspension." This common nile restricts sub awards and contracts with certain parties that are debarred, suspended or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Agencies will be required to properly vet all potential contractors/vendors utilizing the Federal website, https://www.sam.gov/portaI/public/SAM/.

Expenditure Reports

Expenditure reports are to be submitted to the State Lead Agency on a monthly basis. The reports must be received no later Uian the 15* of the month following the month covered by the report. The report must contain the invoice page, expenditure documentation form and documentation for the expenditures.

Budget Modifications

Budget modifications must be submitted to the State Lead Agency whenever a budget line item is overspent by 10% or more. Expenditure Reports will not be processed if the expenditure backup form indicates line items are overspent by 10% or more, unless a budget modification has been received by the State Lead Aeencv.

Budget modifications may be submitted by email to the CSBG Manager.

Piirchase or Permanent Improvements of Real Propertf

The use of CSBG funds are prohibited for the purchase or improvement of land, or the purchase, construction or permanent improvement (other than low cost residential weatherization or other energy related home repairs) of any building or other facility except as defined in Section 678 (F) of the Community Services Block Grant Act.

PnrciiMing Gnidelines

Any single item purchase of $500 or more, with funds from CSBG, will require the prior approval of the State Lead Agency. This approval may be requested via e-mail, or US mail, but written approval from the State Lead Agency must be obtained prior to the purchase.

Inventory Procedures:

The eligible entity shall maintain an inventory list of all property (with a unit cost of $500.00 or more) purchased with CSBG funds.

The inventory list shall include the date of purchase, inventory number, cost, portion of CSBG

funds used to purchase the property, if not fully paid for by CSBG fimds, procurement procedures used for purchase, and location of the property.

The inventory list shall be submitted to the State Lead Agency staff during the annual on-site monitoring.

The entity will also be required to conduct an annual inventory inspection to ensure accountability for all items in possession of the agency that were purchased with CSBG funds.

If the entity intends to dispose of any property purchased with CSBG funds, a written request must be made and a written approval from the State Lead Agency must be received prior to the disposition of any property.

Lease and purchase of Equipment

Lease or purchase of vehicles, office equipment and furniture and expenditures from this category must have the written approval of the State Lead Agency prior to purchase. Items are considered to be equipment which has a unit cost of $L000.00 or more and a life of two years or more. Each entity must maintain an inventory of fixed assets which can be reconciled to the accoimting records. The approval should be maintained in the property records for audit purposes.

Retention of Records

Each eligible entity is required in accordance to CSBG Organizational Standard Category 8 to have a policy in place for record retention and destruction of said records. The policy must define the minimum and maximum holding period for each category of records for the entity. If any litigation, claim or audit is started before the expiration of the retention period, the records shall be retained until all litigation, claims, or audit findings involving the records have been resolved.

The eligible entity will provide the State Lead Agency, the Federal Office of Community Services, the Comptroller General of the United States or any of their authorized representatives, access to any pertinent books, documents, papers, or other records in order to make audits, examinations, excerpts and transcripts.

Indirect Costs

Indirect costs are those that have been incurred for common or joint objectives and cannot be readily identified with a particular final cost objective. Direct cost of minor amounts may be treated as indirect costs under the conditions described in 0MB Circular. After direct costs have been detemiined and assigned directly to awards or other m'ork as appropriate, indirect costs are those remaining to be allocated to benefiting cost objectives,

A cost may not be allocated to an award as an indirect cost if any other cost incurred for the same purpose, in like circumstances, has been assigned to an award as a direct cost.

Because of the diverse characteristics and accounting practices of non-profit organizations, it is not possible to specify the types of cost which may be classified as indirect cost in all situations.

However, typical examples of indirect cost for many non-profit organizations may include depreciation or use allowances on buildings and equipment, the costs of operating and maintaining facilities, and general administration and general expenses, such as the salaries and expenses of executive officers, personnel administration, and accounting.

Unless different arrangements are agreed to by the entities concerned, the Federal agency with the largest dollar value of awards with an organization will be designated as the cognizant agency for the negotiation and approval of the indirect cost rates and, where necessary, other rates such as fringe benefit and computer charge-out rates.

Once an agency is assigned cognizance for a particular non-profit organization, the assignment will not be changed unless there is a major long-term shift in the dollar volume of the Federal awards to the organization.

All concerned Federal agencies shall be given the opportunity to participate in the negotiation process but, after a rate has been agreed upon, it will be accepted by all Federal agencies. When a Federal agency has reason to believe that special operating factors affecting its awards necessitate special indirect cost rates in accordance with 0MB, it will, prior to the time the rates are negotiated, notify the cognizant agency

Termination of the Agreement, Reduction, or Suspension of Funding

In the event that the State Lead Agency elects to, for cause, terminate reduce or suspend funding to the sub recipient, it shall do so in accordance with the provisions of CSBG hiformation Memorandum 116 of 2012. Causes for termination, reduction or suspension of funds by DHS/DCO/OCS may include:

Failure of the sub recipient to fulfill its obligations under the CSBG grant agreement and the agency work plan;

*t* Ineffective or improper use of funds provided under the CSBG grant agreement;

# Failure to provide assurance that, in the case of a community action agency or nonprofit private organization, each board will be constituted so as to assure that one-third of the board are elected public officials, currently holding office, or their representatives, except that if the number of elected officials reasonably available and willing to serve is less than one-third of the membership of the board, membership on the board of appointed public officials may be counted toward meeting such one-third requirement; at least one-third of the members are persons chosen in accordance with democratic selection procedure adequate to assure that they are representative of the poor in the area served; and the remainder of the members are officials or members of business, industry, labor, religion, welfare, education, or other major groups and interests in the community; *X* Failure to provide a range of services and activities having a measurable and potentially major impact on causes of poverty in the community or those areas of the community where poverty is a particularly acute problem;

Failure to follow any of the assurances of the CSBG Program as defined in the Community Services Block Grant Amendments of 1998; and

If the sub recipient is unable or unwilling to comply with the terms of the CSBG grant agreement or such additional conditions as may be lawfully applied by the State of Arkansas.

Where the State Lead Agency determines, pursuant to Section 678B of the Community Services Block Grant Act, that it will terminate present and future funding of any sub recipient which received funding in the previous fiscal year, the State Lead Agency must provide the organization with notice and an opportimity for a hearing on the record prior to terminating funding. If a review by the Secretary of Health and Human Services of the State Lead Agency's final decision to terminate funding is requested pursuant to Section 67 8C of the CSBG Act, the request must be made in writing within thirty (30) days of notification by DHS/DCO/OCS of its final decision to terminate funding.

The Department of Health and Human Services (federal Office of Community Services) will confirm or reject the State Lead Agency's finding of cause, normally within ninety (90) days.

If a request for a review has been made, the State Lead Agency may not discontinue present or future funding until the Department of Health and Human Services (federal Office of Commimity Services) confirms the State Lead Agency's findings of cause.

If no request for a review is made within the 30-day limit, the State Lead Agency's decision will be effective at the expiration of that time.

HEARING ON APPEAL.

Prior to the suspension of funds, or termination of the grant agreement for non-compliance with grant conditions, the sub recipient shall be granted a hearing by the State Lead Agency upon written request made by the sub recipient within ten (10) days from the date of Notification of

Intent to Suspend or Terminate the CSBG Grant Agreement.

The hearing shall be conducted at the State Lead Agency's offices in Little Rock, AR, or any other appropriate location at the State Lead Agency's discretion, with a written notification of the time, place, and subject matter by the State Lead Agency to the sub recipient.

Section IX - Eeporting Requirements ROMA/IS Report

The ROMA/IS Report is cumulative and tracks the progress for each national indicator. Entities will report for indicators only where outcomes are achieved. There may be some indicators that will not have any results in the first quarterly report but may be reflected by the end of the year.

The ROMA report is due quarterly. The report is due on the 30 of each month following the end of a quarter. Should the 30* fall on a weekend, then the report is due on the following Monday.

The CSBG IS report is due annually. This report is due in January or February, following the end of the federal fiscal year, with actual date determined by the State Lead Agency.

FY 2017 is the final year for the eligible entities to report on the Information Survey. Entities will report FY 2018 and beyond on the January, 2017 OMB approved Annual Report with report due dates in January or February following the end of the federal fiscal year.

Board and Committee Reporting

All Board and Committee meeting minutes must be submitted to the State Lead Agency 30 days following the meeting in which the minutes are approved. The following documents must also be included with their corresponding minutes:

* Agenda

* Sign-in sheets

* Reports presented during the meet

Financial Expenditure Reporting

Financial expenditure reports are to be submitted to the State Lead Agency on a monthly basis. The reports must be received no later than the 15* of the month following the month covered by the report. The report must contain the invoice page, expenditure documentation form and documentation for the expenditures.

Section X - Required Referrals

This is to be in compliance with CSBG Act Section 678g(b) regarding child support and CSBG

Act Section 676(b) regarding the Workforce Investment Act of 1998 (career centers).

The required referrals must be completed when there are households that are eligible for child support but not receiving it. See Appendix A., B and Cfor sample policy, procedure and referral

notice documents.

Child Support

* A client is marked as a Single Parent male or female with children

* No income recorded under Child Support

* Entity staff will give client the agency child support information and application

* The date of the referral for Child Support will be made along with any necessary notes in the client file about the referral and will be entered into the agency client tracking software.

Workforce Investment Act of 1998

* A client is marked unemployed or no income source

* Entity staff will give the client a referral.

* The date of the referral will be made along any necessary notes about the referral.

Section XI - Agency Audit Reports Sub-recipient Audit Requirements.

This DHS/DCO/OCS Audit Policy requires the State Lead Agency sub-recipients to follow the guidelines outlined below to determine the sub-recipient's audit requirements.

Local Government, Institution of Higher Education, Hospital, and Non-Profit Organization Sub-recipients

A sub-recipient that expended $750,000 or more of federal awards during its fiscal year accepts the responsibility to provide a single audit at the conclusion of that fiscal year.

When a sub-recipient expends $300,000 or more of federal awards

Each eligible entity shall arrange for an annual audit to confirm that the financial statements present fairly and accurately the financial position of the eligible entity, that the eligible entity is complying with applicable OCS requirements and with general and special contract conditions, and that appropriate financial and administrative procedures and controls have been installed, are operating effectively, and are consistent with the eligible entity's Financial Procedures Manual. The audit shall cover the eligible entity's prior fiscal year in total and shall be submitted to OCS no later than 120 days after the eligible entity's program year ends.

The services of an independent Certified Public Accountant shall be secured.

An eligible entity receiving an initial DHS/DCO/OCS contract shall within thirty days following the contract starting date, supply the State Lead Agency with the name of the auditor or auditing firm which it has selected.

*l* Each eligible entity shall followed CSBG Organizational Standard Category 8 and OMB

regulations for procurement requirements when selecting an auditor for the annual audit

OMB Circular No, A- igle Audit Reqiirements. The audit shall cover the entire operations of the sub-recipient or, at the option of the sub-recipient, such audit shall include a series of audits that cover departments, agencies, and other organizational units which expended or otherwise administered federal awards during such fiscal year, provided that each such audit shall encompass the financial statements and schedule of expenditures of federal awards for each such department, agency, and other organizational unit, which shall be considered to be a nonfederal entity. The financial statements and schedule of expenditures of federal awards shall be for the same fiscal year.

[GREATER THAN] Financial Statements. The auditor shall determine whether the financial statements of the sub-recipient are presented fairly in all material respects in conformity with generally accepted accounting principles. The auditor shall also determine whether the schedule of expenditures of federal awards is presented fairly in all material respects in relation to the sub-recipient's financial statements taken as a whole.

** Internal Control. In addition to the requirements of Government Auditing Standards (the Yellow Book), the auditor shall perform procedures to obtain an imderstanding of internal control over federal programs sufficient to plan the audit to achieve a low assessed level of control risk for major programs (major program determination process is defined in A-133 §.520).

Except as provided in paragraph 2 below, the auditor shall:

Plan the testing of internal control over major programs to achieve a low assessed level of control risk for the assertions relevant to the compliance requirements for each major program.

Perform testing of internal control over major programs as planned in paragraph l(i) above.

[LESS THAN] When internal control over some or all of the compliance requirements for a major program are likely to be ineffective in preventing or detecting noncompliance, the planning and performing of testing described in paragraph 1. above are not required for those compliance requirements. However, the auditor shall cite a reportable condition (including whether any such condition is a material weakness), assess the related control risk at the maximum, and consider whether additional compliance tests are required because of ineffective internal control.

** NOTE: This guidance on the audit requirement to document and test the internal control stracture is from A-133, §.500(c).

** Compliance. In addition to the requirements of Government Auditing Standards (the Yellow Book), the auditor shall determine whether the sub recipient has complied with laws, regulations, and the provisions of sub grant agreements that may have a direct and material effect on each of its major programs:

t* The principal compliance requirements applicable to most federal programs and the compliance requirements of the largest federal programs are included in the compliance supplement.

For the compliance requirements related to federal programs contained in the compliance supplement, an audit of these compliance requirements will meet the requirements of this part. Where there have been changes to the compliance requirements and the changes are not reflected in the compliance supplement, the auditor shall determine the current compliance requirements and modify the audit procedures accordingly. For those federal programs not covered in the compliance supplements, the auditor should use the types of compliance requirements contained in the compliance supplement as guidance for

identifying the types of compliance requirements to test, and determine the requirements governing the federal program by reviewing the provisions of the contracts and sub grant

agreements and the laws and regulations referred to in such contracts and sub grant agreements.

The compliance testing shall include tests of transactions and such other auditing procedures necessary to provide the auditor sufficient evidence to support an opinion on compliance.

** Major Program Determination: The auditor shall use a risk-based approach to determine which federal programs are major programs. This risk-based approach shall include consideration of:

*t* Current and prior audit experience.

Oversight by federal agencies and pass-through entities (i.e., evidence of monitoring, etc.).

*t* Inherent risk of the federal program (federal agencies with concurrence of OMB may identify federal programs which are higher risk. According to A-133 §.525, OMB plans to provide this identification in the compliance supplement). The auditor shall follow the four (4) step major program determination process as described in A-133 §.525. As part of this process, the auditor shall also consider the risk analysis criteria for federal program risk that is outlined in A-133 §.525. This section states that the auditor's determination process shall include an overall evaluation of the risk of noncompliance occurring which could be material to a federal program. As suggested in §.525, the auditor may wish to discuss risk factors associated with a particular ADECA federal program with the Audit Section staff and/or the applicable ADECA program manager. For example, oversight by ADECA through monitoring or other reviews may have disclosed significant problems with an ADECA program; this would indicate a higher risk. However, if the results of monitoring or reviews indicated no significant problems with a particular ADECA program, this would indicate a lower risk. ADECA encourages this communication when planning a single audit of an ADECA sub recipient to be performed in accordance with this Policy. One method that can alert auditors of high risk or potential high risk ADECA federal programs will be through the periodic letters to auditors of ADECA siibrecipients from the ADECA Chief Auditor,

** Audit.....FoJlowrUB. The auditor shall follow-up on prior audit findlHgs, perform procedures to assess the reasonableness of the summary schedule of prior audit findings prepared by the sub recipient in accordance with A-133 §.315(b), and report, as a current year audit finding, when the auditor concludes that the summary schedule of prior audit findings materially misrepresents the status of any prior audit finding. The auditor shall perform audit follow-up procedures regardless of whether a prior audit finding relates to a major program in the current year,

** Reporting on Single Audits of Subrecipients. The auditor's reports shall conform to the guidance provided in SOP 98-3 and any subsequent revision and state that the audit was conducted in accordance with A-133 and Government Auditing Standards (the Yellow Book). The minimum reporting requirements for a single audit conducted in accordance

with A133.§505 are as follows:

An independent auditor's report (opinion or disclaimer of opinion) on the financial statements and the supplementary schedule of expenditures of federal awards which states whether they are presented fairly in all material respects in conformity with generally accepted accounting principles.

The financial statements required by generally accepted accounting principles.

[LESS THAN] The notes to the financial statements reflecting all the necessary information essential to fair presentation of the financial statements.

A schedule of expenditures of federal awards that meets the minimum requirements of A-133 §.310 (b) and includes the applicable activity defined in A-133 §.205.

[LESS THAN] An independent auditor's report on compliance with requirements applicable to each major program and internal control over compliance in accordance with 0MB Circular A-133 and, when applicable.

An independent auditor's report on compliance and on internal control over financial reporting based on an audit of financial statements performed in accordance with the Government Auditing Standards (the Yellow Book).

A schedule of findings and questioned costs which shall include the following three (3)

Section XII - Monitoring

Desk and Field Reviews

The CSBG Act SEC. 678B

In order to determine whether eligible entities meet the performance goals, administrative standards, financial management requirements, and other requirements of a State, the State shall conduct the following reviews of eligible entities:

A full onsite review of each such entity at least once during each three-year period.

An onsite review of each newly designated entity immediately after the completion of the first year in which such entity receives funds through the CSBG.

The State Lead Agency will, at a minimum, conduct an on-site review of each eligible entity at least once annually.

Reviews may be conducted as a combination of desk reviews and field reviews, and may be specialized or general in nature.

Entities will be notified in writing with a letter to the Executive Director. The timing of the notification, and areas to be reviewed, will be in accordance with the policies of the Community Services Block Grant,

Both an entrance and an exit conference will be conducted for onsite reviews with the executive director and other designated staff.

The monitoring process will address prior review findings, agency eligibility, governance, planning process, fiscal, audit reports, program administration, persormel, ROMA implementation, data collection, and reported performance.

Monitoring may include, but is not limited to a review of:

Program policies and procedures.

Income guidelines and verification procedures.

Intake forms and procedures.

Program work plans and activities.

CSBG administrative files.

*l*Personnel policies, files and job descriptions.

[LESS THAN]Inventory and procurement procedures.

Cooperative agreements and contracts, including consultant contracts.

Organizational structure and lines of authority.

Board member files, bylaws and meeting documentation.

Adherence to Federal and State guidelines and requirements.

Fiscal policies and practices.

Service activity reports, data tracking and reporting systems and supporting documentation.

Compliance with the CSBG Organizational Standards

Monitoring may also include:

Interviews with program staff regarding program operations and job functions.

Interviews with administrative and fiscal staff.

Interviews with members of the governing/administering board.

A letter will be issued to the executive director, by the State Lead Agency stating the results of the review. It will include comments on all areas reviewed and detail any concerns and/or findings.

All findings will cite the law, rale, regulation or policy for which noncompliance has been determined.

The letter will set a deadline for a response to the concerns/findings in accordance with the

division/program policies utilized for the review.

Responses must include appropriate documentation,

After receipt and review of responses by the State Lead Agency, if findings are not resolved, then corrective actions will be determined in accordance with CSBG regulations.

On a monthly basis, CSBG program monitors will perfomi a desk audit of each agency.

This review consists of examining budgets and expenditure reports, quarterly ROMA reports, board rosters and board meeting minutes.

An on-site review of a newly designated entity will be conducted immediately after the completion of the first six months in which such entity receives funds through the CSBG program.

A subsequent visit will be conducted at the end of the first twelve months of operation.

Additional on-site reviews will be conducted when specific concerns are identified that require attention beyond the Corrective Action Plan.

Monitoring Corrective Action Plan

In those instances when findings cannot be resolved through additional information or supporting documentation, a corrective action plan must be implemented in a manner that is consistent and fair.

Resolution of minor, first time findings, shall be through certification from the board chairman and executive director stating that the correction was made through whatever means that were used. The certification should also state that the finding will not reoccur because of the actions taken to preclude it.

If requested, the State Lead Agency will provide technical assistance to the entity so as to address any weakness the agency has identified as needing clarification or training. Requests for technical assistance should be made in writing.

Actions (Items) that require additional monitoring

The State Lead Agency may perform additional on-site monitoring and/or technical assistance if determined appropriate based on prior monitoring, that the eligible entity is not financially stable, has a management system which does not meet management standards, or has not conformed to terms and conditions of previous awards.

Examples of indicators that may lead to additional monitoring or technical assistance include but are not limited to:

Entity is unresponsive to and noncompliant with requests and requirements to

correct compliance findings.

Management systems do not contain data driven strategic plans and work plans. The entity's adherence to its approved operating documents (including bylaws,

personnel policy and fiscal policy) is inconsistent. ** Record keeping related to board and committee activity is not systematic.

The corporate record is, as a result, incomplete. Abrupt departure of the executive director and/or the fiscal officer.

The audit conducted in accordance with the requirements of the applicable 0MB Circular contains one or more significant findings relevant to the entity's capacity to successfully administer its programs.

Failure without cause to meet performance targets defined within the entity's approved Community Action Plan.

CSBG percent of revenue exceeds one-third of the entity's total revenue.

*l* Entity lacks connection and a demonstrated commitment to the broader community action network.

Eligible entities will be notified in writing as to the specific findings or deficiencies and shall be required to remedy the situation within a specific timeline or to develop and implement a technical assistance plan and/or quality improvement plan.

Technical assistance and training will be provided by the State Lead Agency with the goal of preventing any reoccurrences.

The designation will remain in place for a specified time and will not be removed until a follow-up review, conducted by the State Lead Agency, clearly indicates that all weaknesses that resulted in the designation have been corrected.

Information Memorandum 116 (http://www.acf.hhs.gov/programs/ocs/resource/no-116-corrective-action- termination-or-reduction-of-funding) and revisions thereto will guide the designation and de-designation of CSBG-eligible entities.

Community Services Block Grant State Plan FY 2018 and FY 2019

Click here to view image

Community Services Block Grant(CSBG) Policy and Procedures Manual and State Plan

FY 2018-2019 Summary of Changes

Purpose: To Identify the changes from the FY2016 - 2017 Community Services Block Grant State Plan and Policy and Procedures Manual for FY 2018-2019.

Details of changes:

The entire policy manual has been developed to include current language as found in the Community Services Block Grant Performance Management Framework. This framework Includes the Community Services Block Grant Organizational Standards, The ROMA Next Generation (Annual Report), State and Federal Accountability Measures.(see Attachment A; and Section IX, p.30 of Policy Manual)

The policy manual was updated to include required referrals to Workforce and Child Support to be in compliance with the CSBG Act. Included sample policy, procedure and referral notice documents for Child Support (Section X, p.31 of Policy Manual and Section 16)

The policy manual also was updated in the area of board requirements to include regulations set forth in Information Memorandum 82.(Section III, p.6 -11 of Policy Manual)

The State Plan for FY 2018 and FY 2019 includes updated Lead Agency goals and training and technical assistance needs. (Section 3 of State Plan)

The State Plan for FY 2018 and FY 2019 includes updated requirements for monitoring by the State Lead Agency and terms of corrective actions plans that could be issued as a result.(Sectlon XII, p.39- 41 of Policy Manual)

Attachment A

* Community Services Block Grant Information Memorandum Transmittal Number 138

* Community Services Block Grant Information Memorandum Transmittal Number 144

* Community Services Block Grant Information Memorandum Transmittal Number 149

* Community Services Block Grant Information Memorandum Transmittal Number 152

* Community Services Block Grant Public Law 105-285

TO:State Community Services Block Grant (CSBG) Administrators, U. S.

Territory CSBG Administrators, Eligible Entities, and State Community Action Associations

SUBJECT:State Establishment of Organizational Standards for CSBG Eligible

Entities under 678B of the CSBG Act, 42 U.S.C. § 9914

RELATEDCommunity Services Block Grant Act 42 U.S.C. § 9901 etseq., hereafter

REFERENCES: referred to as "the CSBG Act."

This information memorandum (IM) provides guidance and describes State and Federal roles and responsibilities for the establishment of organizational standards as a component of a larger perfoimance management and accountability system for CSBG. Consistent with the authority and responsibilities the CSBG Act establishes for the Federal office and States, OCS is requiring States, no later than FY 2016, to establish and report on their organizational standards for CSBG eligible entities as part of an enhanced system for accountability and performance management across the CSBG Network.

While States have discretion on the set of standards they may use, OCS recommends States use the organizational standards (Appendices 2 and 3) developed by the OCS-supported CSBG Organizational Standaitis Center of Excellence (COE), which reflect the requirements of the CSBG Act, good management practices, and the values of Community Action. These standards will ensure CSBG eligible entities have appropriate organizational capacity to deliver services to low-income Individuals and communities.

The guidance in this IM applies to States, the District of Columbia, and U.S. Territories that support CSBG eligible entities. Tribal governments and organizations that receive CSBG directly from the Federal government are not included in this guidance, but will receive future guidance on a separate accountability and reporting process.

State Authority and Responsibil% to Establish Organizational Standards

Under the block grant framework established in the CSBG Act, States have both the authority and the responsibility for effective oversight of eligible entities that receive CSBG funds.

Section 678 B of the CSBG Act (42 U.S.C. § 9914) requires State CSBG Lead Agencies to

establish "perfoimance goals, administrative standards, financial management requirements, and other requirements" that ensure an appropriate level of accountability and quality among the State's eligible entities. In order for States to meet these responsibilities under the CSBG Act,

States must establish and communicate clear and comprehensive standards and hold eligible entities accountable according to the standards as part of their oversight duties.

Federal Authority and Responsibility for Organizationai Standards

As the Federal office responsible for oversight of CSBG, the Office of Community Services (OCS) is responsible for monitoring to assure State compliance with die requirements of the CSBG Act and for providing training and technical assistance to help States carry out the requirements of the CSBG Act. Section 678B(c) (42 U.S.C. § 9914(c)) directs the U.S. Department of Health and Human Services (HHS) to conduct evaluations of the use of CSBG fiinds received by the States. Section 678A(a) (42 U.S.C 9913(a)) requires HHS to support training and technical assistance activities to assist States in monitoring activities to correct programmatic deficiencies of eligible entities, and for rejxirting and data collection activities.

Several sections of the CSBG Act provide authority or require OCS to collect information from States as part of the State plan or annual report regarding how the State will meet requirements of the CSBG Act. Section 676(b) (42 U.S.C. § 9908(b)) outlines authority for the collection of necessary information as part of a State application and plan. The statute provides the authority to collect "such information as the Secretary shall require," including a series of detailed assurances based on the requirements of the CSBG Act. To assure effective use of fiinds to meet the putposes of the statute, section 676(d) (42 U.S.C. § 9908(d)) states that the "Secretary may prescribe procedures for the purpose of assessing effectiveness of the eligible entities in carrying out the purpose of [the CSBG Act]."

Performance Management for CSBG

Budget constraints, high poverty levels, changing demographics, and income inequality demand that the CSBG Network remain vigilant in our shared mission of creating opportunity and security for all Americans. We must look at all levels of the CSBG Network - local, State, and Federal - to assess and increase CSBG's impact. The CSBG Network is far-reaching and nationwide. Together, we have the potential to achieve even greater results, in every community, by improving our accountability to one another, our customers, and our communities.

In an effort to help the CSBG Network increase accountability and achieve results, OCS launched several initiatives in 2012. One focused on establishing organizational standards for eligible entities. Under this effort, CSBG Network leaders developed and reeommended a set of organizational standards to strengthen the capacity of the more than 1,000 eligible entities providing services across the country.

A second performance management initiative focused on enhancing the CSBG Network's performance and outeomes measurement system for local eligible entities - identified in the CSBG Act as Results Oriented Management and Accountability System (ROMA). Finally, a third initiative focused on creating State and Federal-level accountabilit[GREATER THAN]' measures to track and measure organizational performance by State CSBG Lead Agencies and OCS.

TTiese three efforts are complementary and integrated; together they comprise a network-wide accountability and management system for CSBG. They will ensure eligible entities, States, and OCS operate within Federal law and regulation and will build accountability and continuous management improvement into all three levels of the network (local. State and Federal). As shown in Appendix I, Measuring the Success of Community Action and CSBG, these efforts will help us answer the questions, 'How well did the Network perform?* and 'What difference did the Network make?' Ultimately, using these new and enhanced tools and information, the CSBG Network will make better program decisions and generate stronger results for low-income families and communities.

Organizational Standards for CSBG Eligible Entities - Background

In 2012, OCS funded a cooperative agreement for the CSBG Organizational Standards Center of Excellence (COE). The two-year cooperative agreement coordinated - with input from local, State, and national partners - the development and dissemination of a set of organizational standards for eligible entities for the purpose of ensuring that all CSBG eligible entities have the capacity to provide high-quality services to low-income individuals and communities.

To begin the project, the COE expanded an existing CSBG Working Group from its original 20 members to over 50 individuals. The expanded working group included a balanced representation from eligible entities, State CSBG Lead Agencies, Community Action State Associations, national partners, technical assistance providers, and external content experts.

The working group's first task was a thorough environmental scan and analysis of existing organizational oversight tools and resources, internal and external to the CSBG Network. The group found that while there are many similarities across States in how State CSBG Lead Agencies monitor eligible entities, substantial differences also exist.

The project continued through a nine-month development process that provided numerous opportunities for input by the CSBG Network, including financial and legal experts, on draft organizational standards. All together, the network invested over 3,500 documented hours in Working Group and committee meetings and in national and regional listening sessions. The final phase included a pilot that engaged a subset of State CSBG Lead Agencies and eligible entities in a field test of draft organizational standards and tools.

In March, 2014, OCS published a draft information memorandum with the draft organizational standards. OCS received 29 sets of comtnests (approximately 160 individual comments) from 3 broad range of individuals and organizations, including six CAAs; 12 states; five state associations; and six national organizations and individuals, and intepated all of this feedback into the final set of organizational standards.

TTie final result of the COE and OCS efforts is a comprehensive set of organizational standards developed by the CSBG Network for the CSBG Network. The CSBG Network is to be commended for its commitment to ongoing performance improvement and strengthening accountability.

The COE-developed Oranizational Standards

The COE-developed standards are organized In three thematic groups comprising nine categories and totals of 58 standards for private, nonprofit eligible entities and 50 for public entities.

Section 3: State Plan Developnnent and

Statewide Goals state Plan Goals

The State Lead Agency has established the following Community Services Block Grant goals

and strategies:

Administration of the Community Services Block Grant

Goal: to administer the State of Arkansas Community Services Block Grant Program

Strategy: to provide assistance to local communities through a network of eligible entities (Community Action

Agencies) for the reduction of poverty and the revitalization of low-income communities, as well as the empowerment of low-income families and individuals in rural and urban areas to become fully self-sufficient; and to support other Federal Statutory purposes and goals of the CSBG Act.

Workforce Systems

Goal: to increase workforce development opportunities for CSBG participants

Strategies: To partner with the Department of Workforce to coordinate the Workforce Investment and Opportunity

Act activities to provide a one-stop approach to workforce development services by partnering CSBG eligible entities with the Workforce offices to address barriers to employment.

Organizational Standards

Goal: To ensure that all eligible entities are 100% compliant with the CSBG Organizational Standards as

prescribed in CSBG IM 138.

Strategies: to partner with the Arkansas Community Action Agencies Association to provide peer-to-peer assistance and training resources to assist with the development and implementation of deficient standards:

Organization-wide comprehensive risk assessment

Uniform Guidance

Succession Planning

ROMA

Strategic Planning

CSBG Monitoring

Goal: to strengthen CSBG Program and Fiscal monitoring

Strategies: Update all CSBG monitoring tools to incorporate the CSBG organizational standards, ROMA Next

Generation and Financial Management requirements to ensure eligible entity compliance.

State Lead Agency Professional Development

Goal: To increase the professional development of the State Lead Agency staff

Strategies: All three CSBG Grants Analysts become Nationally Certified ROMA Implementers during the period of this State Plan. Ensure that all State Lead Agency Staff have access to and are utilizing current educational materials

(as related to CSBG), and are exposed to professional growth opportunities, by means of training on the local, state and national level.

State Distribution Formula to the eligible Entities

Goal: to revise the state distribution formula

Strategies: The State Lead Agency will research funding formula from other states, will identify and adopt the funding formula (in accordance with CSBG IM 116) that will best support the work of the Arkansas CSBG network.

This new formula will be implemented in the year following its adoption.

State wide Data Collection System

Goal: to implement a state wide data collection system for Arkansas eligible entities

Strategies: Coordinate with the eligible entities and the State Association to identify, purchase and implement a state wide data collection system for eligible entities by the end of FY 2019.

Section 4: CSBG Hearing Requirennents

Section 5: CSBG Eligible Entities

Section 6: Organizational Standards for

Eligible Entities

Organizational Standards for CSBG Eligible Entities - Background

In 2012, OCS fiinded a cooperative agreement for the CSBG Organizational Standards Center of Excellence (COE). The two-year cooperative agreement coordinated - with input from local, State, and national partners - the development and dissemination of a set of organizational standards for eligible entities for the purpose of ensuring that all CSBG eligible entities have the capacity to provide high-quality services to low-income individuals and communities.

To begin the project, the COE expanded an existing CSBG Working Group from its original 20 members to over 50 individuals. The expanded working group included a balanced representation from eligible entities. State CSBG Lead Agencies, Community Action State Associations, national partners, technical assistance providers, and external content experts.

The working group's first task was a thorough environmental scan and analysis of existing organizational oversight tools and resources, internal and external to the CSBG Network. The group found that while there are many similarities across States in how State CSBG Lead Agencies monitor eligible entities, substantial differences also exist.

The project continued through a nine-month development process that provided numerous opportunities for input by the CSBG Network, including financial and legal experts, on draft organizational standards. All together, the network invested over 3,500 documented hours in Working Group and committee meetings and in national and regional listening sessions. The final phase included a pilot that engaged a subset of State CSBG Lead Agencies and eligible entities in a field test of draft organizational standards and tools.

In March, 2014, OCS published a draft information memorandum with the draft organizational standards. OCS received 29 sets of comments (approximately 160 individual comments) from a broad range of individuals and organizations, including six CAAs; 12 states; five state associations; and six national organizations and individuals, and integrated all of this feedback into the final set of organizational standards.

The final result of the COE and OCS efforts is a comprehensive set of organizational standards developed by the CSBG Network/or the CSBG Network. The CSBG Network is to be commended for its commitment to ongoing performance Improvement and strengthening accountability.

The COE-developed Organizational Standards

The COE-developed standards are organized in three thematic groups comprising nine categories and totals of 58 standards for private, nonprofit eligible entities and 50 for public entities. 1.Maximum Feasible Participation

Consumer Input and Involvement

Community Engagement

Community Assessment

Section 678 B of the CSBG Act (42 U.S.C. § 9914) requires State CSBG Lead Agencies to establish "performance goals, administrative standards, financial management requirements, and other requirements" that ensure an appropriate level of accountability and quality among the State's eligible entities. The purpose of States using the organizational standards is to ensure each eligible entity has appropriate organizational capacity to fulfill the purposes of the CSBG Act. As noted belov. States have discretion to determine how organizational standards will be implemented as part of their overall oversight strategy. Assessment of Standards

In order to be widely applicable across the CSBG Network, the standards are defined differently for private and public eligible entities. The complete description and list of private and public organizational standards are attached as Appendices 2 and 3, respectively. All of the COE-developed organizational standards work together to characterize an effective and healthy organization. Some of the standards have direct links to the CSBG Act, such as the standards on the tripartite board structure and the democratic selection process. Some standards link with U.S. Office of Management and Budget (0MB) guidance, such as the standards on audits. As a whole, the standards reflect many of the requirements of the CSBG Act, applicable Federal laws and regulations, good management practices, and the values of Community Action. The purpose of the organizational standards is to ensure that all eligible entities have appropriate organizational capacity, not only in the critical financial and administrative areas important to all nonprofit and public human service agencies, but also in areas of unique importance for CSBG-funded eligible entities. To fulfill the promise of the standards, States must provide consistent and high-quality oversight and technical assistance related to organizational standards. In addition, based on information about organizational capacity, States must work with the eligible entities to make informed programmatic decisions about how the agencies can best meet the needs of local low-income families and communities.

State Oversight

Section 678 B of the CSBG Act (42 U.S.C. § 9914) requires State CSBG Lead Agencies to establish "performance goals, administrative standards, financial management requirements, and other requirements" that ensure an appropriate level of accountability and quality among the State's eligible entities. The purpose of States using the organizational standards is to ensure each eligible entity has appropriate organizational capacity to fulfill the purposes of the CSBG Act. As noted belov. States have discretion to determine how organizational standards will be implemented as part of their overall oversight strategy. Assessment of Standards

Once the expectations for organizational standards are established and communicated to the eligible entities across a State, the State CSBG Lead Agency is responsible for assessing the status of standards among all of the eligible entities annually and for reporting to OCS on the standards in the CSBG Annual Report. States may design an approach for assessing organizational standards that fits within the oversight framework in their State. Many States may integrate standards assessment into their regular CSBG monitoring procedures, while other States may choose different oversight approaches, such as peer-review, assessment by a consultant or third party, or self-assessment. Some States may also choose a hybrid approach involving two or more strategies. Regardless of the approach. States must ensure the assessment of standards is independently verified by the State or a third party.

For example, a State on a triennial monitoring cycle may decide to assess the standards as part of their full onsite financial, administrative, and programmatic monitoring protocol, hi the years between monitoring visits, the State may require entities to do self-assessments that are independently verified by a third party. In another example, a State may develop a process that includes peer review assessment that is then verified annually during regular State monitoring visits or a State desk review process.

States are responsible for ensuring that the eligible entities meet all State-established organizational standards. Some standards (i.e., strategic planning, developing an agency-wide budget, etc.) may take several years for eligible entities to meet, but every entity must make steady progress toward the goal of meeting all standards.

Corrective Action

During the assessment process, if a State finds an eligible entity is not meeting a standard or set of standards, the State's response will depend on the circumstances. In cases where the eligible entity may be able to meet the standard in a reasonable time frame contingent on some targeted technical assistance, the State and entity may develop a technical assistance plan to target training and technical assistance resources and outline a time frame for the entity to meet the standard(s). If appropriate in other situations, the State may initiate action in accordance with section 678C of the CSBG Act (42 U.S.C, § 9915), including the establishment of a Quality Improvement Plan (QIP) with clear timelines and benchmarks for progress.

Section 7: State Use of Funds

State Use of Funds

The State of Arkansas is required to make available to eligible entities a, no less than 90 percent of the funds received through the Community Services Block Grant to accomplish the goals set forth in the programmatic assurances. No more than 5 percent may be utilized for administrative costs.

The State Lead Agency is required to make available to eligible entities, no less than 90 percent of the funds received through the Commrmity Services Block Grant to accomplish the goals set forth in the programmatic assurances. No more than 5 percent may be utilized for administrative costs.

90% Eligible Entity - Funds appropriated for the purpose of the Community Services Block Grant shall be allocated annually to the eligible entities. Arkansas has in place a historical allocation formula that was based on poverty, population and a "hold-harmless" indicator number. The formula will stay in place for the period of FY2018.

During FY 2018, The State Lead Agency will research funding formula from other states, will identify (in accordance with CSBG IM 116) and adopt the funding formula that will best support the work of the Arkansas CSBG network. This new formula will be implemented in the year following its adoption.

5% Administrative - U.S.C. Section 675C (b)(2) states, "No State may spend more than the greater of $55,000, or 5 percent, of the grant received under section 675A or State allotment received under Section 675B for administrative expenses, including monitoring activities. Funds to be spent for such expenses shall be taken from the portion of the grant under section 675 A or State allotment that remains after the State makes grants to eligible entities under subsection (a)".

5% Discretionary - The remaining funds will be allocated in accordance with U.S.C. Section 675(b) (2) states, the remaining 5% of the funds can be used for a variety of CSBG-related purposes. Examples of these purposes include awarding funds to CSBG-network organizations to provide training and technical assistance to CAAs and awarding funds on a competitive basis to organizations conducting community economic development activities, rural community development activities, case management, fatherhood initiatives, disaster relief and neighborhood innovation projects. Arkansas will also use these funds to provide for the identification, adoption, purchase and implementation of a state-wide data collection system for the eligible entities.

COMMUNITY SERVICES BLOCK GRANT DISCRETIONARY GRANT APPLICATION

CSBG Discretionary Application

The Community Services Block Grant (CSBG) Program is funded by the U.S. Department of Health and Human Services and is administered by the Arkansas Department of Human Services, Division of County Operations, and Office of Community Services. Per 42 U.S.C. 106 (the CSBG Act) the Secretary of the Department of Health and Human Services received authority to make grants to the States with the intent to ameliorate the causes of poverty in communities. Under the CSBG Act, the state may utilize five (5) percent of the federal allocation as discretionary funding to support a wide range of activities and programs conducted by community action agencies or other non-profit organizations to eliminate poverty, promote self-sufficiency, and promote community revitalization. Additionally, the funds may be used to provide training and technical assistance for and support coordination and communication among community action agencies.

Eligible Applicants:

Entities eligible to apply include Community Action Agencies, nonprofit organizations that serve or target individuals and families that have incomes at or below 125% of poverty, and nonprofit organizations who support and serve the Arkansas Community Action Agencies. The applicant's proposed program must display measurable outcomes which help families and individuals move toward self-sufficiency or the role that a request for technology upgrades will play in achieving those outcomes.

Eligible Projects and Activities:

Eligible projects include:

[GREATER THAN] Training and Technical Assistance Programs that provide Arkansas' Community Action Agencies with quality training, technical assistance, best practices, and tools to build capacity and strengthen the role of Community Action Agencies in the provision of anti-poverty initiatives.

[GREATER THAN] Asset Building/Volunteer Income Tax Preparation Program (local or statewide) targeting innovative programs that provide asset building services as well as expanding the awareness and utilization of the EITC and other tax credits among working families.

[GREATER THAN] Jobs Initiatives, including green jobs and other targeted employment training.

[GREATER THAN] Innovative Programs to address poverty on a community level.

[GREATER THAN] Technology upgrades to assist in achieving agency outcomes to move families and individual toward self-sufficiency.

[GREATER THAN] Educational Scholarships

[GREATER THAN] State-wide Data Collection System

Eligible Activities include:

[GREATER THAN] Case management

[GREATER THAN] Promotional outreach costs

[GREATER THAN] Disaster Assistance

Funding

Approved applicants will receive a grant award with purchase order information and grant assurances and guidelines. Please note that these grants will be monitored the same as the regular CSBG grant awards.

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PART 4 - PROPOSAL BUDGET

Please provide a budget for the requested project. Include any additional sources of income to support the project.

Application Format and Submission Information

Please provide two (2) copies of the Discretionary Grant Application.

Applications should be mailed or delivered to:

The Arkansas Department of Human Services

DCO/OCS

ATTN: Lorie Williams, Assistant Director

PO Box 1437, Slot S330

Little Rock, AR 722031437

Section 8: State Training and Teclinical

Assistance

Section 9: State Linkages and Communications

The Arkansas Department of Human Services, DCO/Office of Community Services administers the CSBG grant along with the Low-Income Home Energy Assistance Program (LIHEAP). DHS/DCO/OCS also administers the State's Emergency Solutions Grant. The DCO/Office of Community Services is in contact with regional Head Start Offices and share information during the monitoring process. DCO/Office of Community Services plans to become involved in improving coordination between CSBG and WIOA programs to provide better services to the eligible entity clients.

CSBG Law requires CSBG eligible entities to coordinate funds at the local level. The annual community action plan has to describe how the entities coordination efforts with city, county, schools, non-profits, and other organizations. Eligible entities coordinate services and work to avoid duplication of services with other providers. The eligible entities also participate in local social service and homeless coalitions whose goal is to coordinate services.

Section 10: Monitoring, Corrective Action,

and Fiscal Controls

Monitoring

Desk and Field Reviews

The CSBG Act SEC. 678B

In order to determine whether eligible entities meet the performance goals, administrative standards, financial management requirements, and other requirements of a State, the State shall conduct the following reviews of eligible entities:

A full onsite review of each such entity at least once during each three-year period.

An onsite review of each newly designated entity immediately after the completion of the first year in which such entity receives funds through the CSBG.

The State Lead Agency will, at a minimum, conduct an on-site review of each eligible entity at least once armually.

Reviews may be conducted as a combination of desk reviews and field reviews, and may be specialized or general in nature.

Entities will be notified in writing with a letter to the Executive Director. The timing of the notification, and areas to be reviewed, will be in accordance with the policies of the Community Services Block Grant.

Both an entrance and an exit conference will be conducted for onsite reviews with the executive director and other designated staff.

The monitoring process will address prior review findings, agency eligibility, governance, planning process, fiscal, audit reports, program administration, personnel, ROMA implementation, data collection, and reported performance.

Monitoring may include, but is not limited to a review of: *l* Program policies and procedures.

Income guidelines and verification procedures.

Intake forms and procedures.

Program work plans and activities.

CSBG administrative files.

*t* Personnel policies, files and job descriptions.

Inventory and procurement procedures.

*l*Cooperative agreements and contracts, including consultant contracts.

[LESS THAN] Organizational structure and lines of authority.

*t*Board member files, bylaws and meetiag documentation.

* Adherence to Federal and State guidelines and requirements.

*t*Fiscal policies and practices.

Service activity reports, data tracking and reporting systems and supporting documentation.

Compliance with the CSBG Organizational Standards

Monitoring may also include:

Interviews with program staff regarding program operations and job functions. *l* Interviews with administrative and fiscal staff.

Interviews with members of the governing/administering board.

A letter will be issued to the executive director, by the State Lead Agency stating the results of the review. It will include comments on all areas reviewed and detail any concerns and/or findings.

All findings will cite the law, rule, regulation or policy for which noncompliance has been determined.

The letter will set a deadline for a response to the concerns/findings in accordance with the division/program policies utilized for the review.

Responses must include appropriate documentation.

After receipt and review of responses by the State Lead Agency, if findings are not resolved, then corrective actions will be determined in accordance with CSBG regulations.

On a monthly basis, CSBG program monitors will perform a desk audit of each agency.

This review consists of examining budgets and expenditure reports, quarterly ROMA reports, board rosters and board meeting minutes.

An on-site review of a newly designated entity will be conducted immediately after the completion of the first six months in which such entity receives funds through the CSBG program.

A subsequent visit will be conducted at the end of the first twelve months of operation.

Additional on-site reviews will be conducted when specific concerns are identified that require attention beyond the Corrective Action Plan.

Monitoring Corrective Action Plan

Eepresentatives of the low-income population may be democratically selected either to represent a specific area or community served by the agency, or at large to represent the entire area served by the agency. The following democratic selection procedures may be used, either separately or in combination:

Resolution of minor, first time findings, shall be through certification from the board chairman and executive director stating that the correction was made through whatever means that were used. The certification should also state that the finding will not reoccur because of the actions taken to preclude it.

If requested, the State Lead Agency will provide technical assistance to the entity so as to address any weakness the agency has identified as needing clarification or training. Requests for technical assistance should be made in writing.

Actions (Items) that require additional monitoring

The State Lead Agency may perform additional on-site monitoring and/or technical assistance if determined appropriate based on prior monitoring, that the eligible entity is not financially stable, has a management system which does not meet management standards, or has not conformed to terms and conditions of previous awards.

Examples of indicators that may lead to additional monitoring or technical assistance include but are not limited to:

Entity is unresponsive to and noncompliant with requests and requirements to correct compliance findings.

Management systems do not contain data driven strategic plans and work plans.

The entity's adherence to its approved operating documents (including bylaws, personnel policy and fiscal policy) is inconsistent.

Record keeping related to board and committee activity is not systematic. The corporate record is, as a result, incomplete.

Abrupt departure of the executive director and/or the fiscal officer.

The audit conducted in accordance with the requirements of the applicable 0MB Circular contains one or more significant findings relevant to the entity's capacity to successfully administer its programs.

Failure without cause to meet performance targets defined within the entity's approved Community Action Plan.

CSBG percent of revenue exceeds one-third of the entity's total revenue.

Entity lacks connection and a demonstrated commitment to the broader community action network.

Eligible entities will be notified in writing as to the specific findings or deficiencies and shall be required to remedy the situation within a specific timeline or to develop and implement a technical assistance plan and/or quality improvement plan.

Technical assistance and training will be provided by the State Lead Agency with the goal of preventing any reoccurrences,

The designation will remain Ih place for a specified time and will not be removed until a follow-up review, conducted by the State Lead Agency, clearly indicates that all weaknesses that resulted in the designation have been corrected.

Information Memorandum 116 (http://www,acf.hhs.gO¥/programs/ocs/resource/no-116-corrective-action- termination-or-reduction-of-funding) and revisions thereto will guide the designation and de-designation of CSBG-eligible entities.

Section 11: Eligible Entity Tripartite Board

Policies of Governing Boards

Legislative Mandate

CSBG Act (42 U.S.C. 9901 et seq.) as amended in 1998, requires the State Lead Agency to provide assurance that each community action agency or non-profit organization administering the Community Services Block Grant Program have a tripartite board which will be constituted as follows:

Section 12: Individual and Connnnunity Eligibility Requirements l- Income EliaibUity

To be eligible for CSBG scn'ices or benefits, clients must be at or below 125% of the federal poverty line as detcmiiiied by the federal Office of Management and Budget (OMB) based on the most recent federal Census data and as revised annually by the U.S. Department of Health and Human Services. The guidelines are calculated on a sliding scale based on the number of persons in a client's family. To calculate 125% of the federal poverty line, use the amount stated in the poverty guidelines relating to the number of persons in the client's household and multiply that number by 1.25.

The community action agencies may adopt its own written procedures for determining client eligibility for CSBG services. These procedures may, based on the eligible entity's community needs assessment, give priority to certain populations within the applicable income limit such as: people with disabilities; people who are homeless; the elderly: people who are unemployed; and people with children under age 18.

The State Lead Agency recognizes that neither the HHS poverty guidelines, the federal CSBG Act, nor applicable HHS regulations define the term "family." Following are two examples of how the term family might be defined. Other reasonable definitions arc also acceptable.

The income of all members of each family unit must be included in determining the income eligibility. A family unit may be either:

The term "unrelated individual" means an individual who is not an inmate of an institution;

Section 13: Results Oriented Management and Accountability (ROMA) System

ROMA

The Department has incorporated ROMA principles in the areas of reporting, community action plans, strategic planning, community needs assessment, goal and target setting, case management, and board trainings. Eligible entities report quarterly on outcomes for family, agency and community goals. This report format will be updated to include the new national performance goals implemented in January, 2017 under ROMA Next Generation. The State CSBG Manager is a Nationally Certified ROMA Trainer and the three (3) CSBG Grants Analysts (2 program and 1 fiscal) are positioned to enter the Fall, 2017 class for NCRI certification.

The Arkansas Community Action Agency Association has one (1) Master NCRT on staff and there are fourteen (14)NCRTs who are on staff at the eligible entity level. Arkansas also is preparing for the certification over the next two years of an additional twenty (20) NCRI candidates at the eligible entity level.

There will be multiple state-wide ROMA focused trainings over the next twenty-four months as the State prepares to fully implement the changes from ROMA I to ROMA Next Gen. All of the state eligible entities have access to a ROMA trainer through this network of NCRTs and NCRIs that will be coordinated by the State Association in collaboration with the State Lead Agency.

In year two of this State Plan, the State will assign entities a goal for the number of persons to transition out of poverty each year. This will be defined as the household achieving an income above the 125% threshold for CSBG eligibility through use of agency wide bundling of case management services and programs.

All of the eligible entities can request training and technical assistance at any time in addition to the regular planned trainings.

Section 14: CSBG Programmatic Assurances and Information Narrative

FEDERAL AND CSBG STATUTORY ASSURANCES

As required by Section 676 of the Community Services Block Grant, as amended (42 U.S.C. 9901 et seq.), the Arkansas Department of Human Services, Division of County Operations, Office of Community Services, as the designated State Lead Agency, hereby agrees to the Assurances in Section 676 of the Act, which includes the following:

Section 15: Federal Certifications

CERTIFICATION REGARDING LOBBYING

Certification for Contracts, Grant, Loans, and Cooperative Agreements

The undersigned certifies, to the best of his or her knowledge and belief, that;

Section 16: Appendices

Appendix A

[CAA] Child Support Referral Policy

To ensure that the CSBG statute regarding child support referral procedures is being implemented within all CSBG supported programs, [CAA] has included this procedure in its intake process. During the client's initial intake, the client is asked if he or she is the custodial parent in a single-parent family. If this status is confirmed, then the caseworker/intake worker will:

Inform the custodial parent about the availability of child support services.

Refer the custodial parent to the [state child support enforcement agency].

Have available for all clients the [state child support enforcement agencyj's [child support intake form & application for full child support services].

Staff should not act in a manner to be interpreted as giving legal advice but should assure that custodial parents in single-parent families are referred to the [state child support enforcement agency].

Appendix B

[CAA]Child Support Referral Procedure

If a client is a single parent, who has custody of a child under the age of 18 the client may be eligible for help from the state child support enforcement agency with obtaining child support from the father or mother of their child.

Assessing Eligibility