CSBG Model State Plan: Major Revisions



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CSBG Model State Plan: Major Revisions June 8, 2:30 pm to 4:00 pm Office of Community Services and National Association for Community Services Program 1

Presenters National Association for State Community Services Programs David Knight, CSBG Director Office of Community Services Jeannie Chaffin, Director OCS Division of State Assistance Seth Hassett, Director Jonna Holden, Program Manager 2

What you need for this Webinar 1. May 20 CSBG Dear Colleague Letter: Model State Plan Revision: OMB Clearance and 30-Day Comment Period Attachment A: Summary of Major Public Comments and OCS Response Attachment B: Revised CSBG Model State Plan Attachment C: Draft State Accountability Measures 2. Access to web-ex to submit comments/questions 3. Optional: Previous draft of the CSBG Model State Plan (published January 29 under the CSBG Dear Colleague Letter: Model State Plan Revision: Open Comment Period ) 3

Background Agenda Summary of major revisions to the CSBG Model State Plan Next steps and technical assistance Questions and answers 4

Background 5

Revised Model State Plan Revised and automated CSBG Model State Plan Incorporates the 3 performance management efforts Accessible on the ACF Online Data Collection System (OLDC) Minimizes burden, increases efficiency, improves data analysis Will integrate with the CSBG Annual Report OMB Clearance expected summer 2015 New state plan used for applications due Sept. 1, 2015 (for FY 2016) 6

Automation and Analysis Opportunities Automation: First year investment of time for a long term benefit Automated responses (e.g. system-generated tables and calculations) Validation system identifies missing information CSBG administrators (state and federal) can focus on substance, not administrative tasks Data analysis: Greater access to data across the CSBG Network Data will integrate with the CSBG Annual Report The Network can use data better to inform management decisions and promote continual program improvement 7

How Far We ve Come Fall 2014: Drafted new version of the CSBG Model State Plan in collaboration with state agency workgroup and NASCSP January 29, 2015: Published Draft CSBG Model State Plan January 26 March 27: 60 Day Paperwork Reduction Act (PRA) comment period 21 sets of comments submitted through the PRA system Dozens of informal comments during 4 webinars and NASCSP Mid- Winter Conference May 20: Published revised CSBG Model State Plan May 22: Start of the 30 Day PRA comment period 8

Summary of major revisions to the CSBG Model State Plan 9

Major Revisions 1. Statewide vision and goals 2. State reporting on CSBG eligible entity serious deficiencies 3. Section 14: Programmatic Assurances 4. Timeline for state distribution of CSBG funds to eligible entities 5. Estimated Paperwork Reduction Act (PRA) burden 6. Annual assessment of CSBG eligible entities on organizational standards 7. Quality Improvement Plans (QIPs) and Technical Assistance Plans (TAPs) 8. FY 2015 2016 state plans (Submission of new FY16 plan elements for states that submitted a two year plan in FY15) 9. State accountability measure on overall satisfaction 10

Statewide Vision and Goals Revision: Changed terminology from vision and goals to goals and strategies and clarified that these refer to state administration of CSBG and not local activities MSP: Section 3, question 3.2 State accountability measure: 1Sa(i) 11

1. Statewide Vision and Goals Previous Version: 3.2. State Plan Vision and Goals: Describe the State s vision (which encompasses the use of CSBG) and CSBG-specific goals under this State Plan. Revised Version: 3.2. State Plan Goals: Describe the State s CSBG-specific goals for State administration of CSBG under this State Plan. 12

Revised Accountability Measure 1Sa(i) During the performance period The State s Community Services Block Grant (CSBG) State Plan included CSBG-specific goals and strategies for State administration of CSBG 13

Revised Accountability Measure 1Sa(i) Goals are related to statewide administration of CSBG Strategies are activities that support specific goals and are related to the content areas of the Model State Plan. 14

Revised Account. Measure 1Sa(i) - Examples Data Systems Goal: All eligible entities are using a statewide data system by 2017 Strategies: Allocation of discretionary/remainder funds for IT purchases and/or data system training and technical assistance for eligible entities. (As detailed in Sec. 7, Use of Funds, and Section 8, training and technical Assistance, respectively.) Workforce systems Goal: Increase workforce system opportunities for CSBG participants Strategies: Collaborate with State workforce partners to participate in a Workforce Innovation and Opportunity Act Combined State Plan (as described in Sec. 9 of the State plan) and/or distributing articles on workforce opportunities as part of a communication plan (described in Sec. 9). Organizational Standards Goal: Support eligible entities in meeting all organizational standards Strategy: Targeted training and technical assistance (as described in Sec. 8). 15

2. State Reporting on CSBG Eligible Entity Serious Deficiencies Revision: Removed the term serious deficiency from the state plan and accountability measures; Revised question now asks for total number of QIPs, not for list of individual entities with serious deficiencies OCS will collect corrective action information on individual entities in a separate state report, cleared through OMB MSP: Section 10, question 10.5 State accountability measures: 4Sa(iii) and 6Sb 16

State Reporting on Serious Deficiencies Eligible Entity Previous Version 10.5 Serious Deficiencies: In the table below, include each eligible entity that has one or more unresolved serious deficiencies as of the date of the submission of the State Plan. Include all the information requested on the table. Drop down choices from 4.1 Serious Deficiency or deficiencies Please describe text Is the entity on a Quality Improvement Plan? Are any of the deficiencies related to organizational standards? Expected resolution data Yes/No Yes/No Date picker ADD a ROW function Note: you will be able to add as many rows as needed 17

State Reporting on Serious Deficiencies Revised Version 10.5. Quality Improvement Plans (QIPs): How many eligible entities are currently on Quality Improvement Plans? 18

3. Section 14: Programmatic Assurances Revision: Revised section 14 to use exact statutory language (Section 676(b) of the CSBG Act) Created more questions in Section 9, Linkages and Communication, that correspond to required elements from state plan section 14 MSP: Section 14 (in entirety); Section 9, questions 9.1-9.7 State accountability measure: n/a 19

4. Timeline for State Distribution of CSBG Funds to Eligible Entities Revision: Revised state distribution timeframe to encompass the entire state process (starting from after the federal award, not after state authority) Added a question to allow states to describe state procedures that may not technically meet the 30 day time frame but still effectively make funds available on an ongoing basis MSP: Section 7, questions 7.3 and 7.4 State accountability measure: 2Sa 20

Distribution of Funds Previous Version 7.3. Contracts: Describe the contracting mechanism and timeframe the State uses to distribute funds to the eligible entities. 7.4. Must the State get State legislative approval (annually or more frequently) or other types of administrative approval before distributing 90 percent funds to eligible entities? Y/N 7.4a. If yes was selected, how many business days does this process generally take? 7.4b. Please describe the approval process. 7.5. Distribution Timeframe after State Authority: After getting State authority, the State expects to make funds available to eligible entities within how many calendar days? 7.5a. Please describe the process. 21

Distribution of Funds Revised Version 7.3. Distribution Process: Describe the specific steps in the State s process for distributing 90 percent funds to the eligible entities and include the number of days each step is expected to take; include information about State legislative approval or other types of administrative approval (such as approval by a board or commission). 7.4. Distribution Timeframe : Does the State plan to make funds available to eligible entities no later than 30 calendar days after OCS distributes the Federal award? Y/N 7.5a. If no, describe State procedures to ensure funds are made available to eligible entities consistently and without interruption. 22

Revised Accountability Measure 2Sa During the performance period The State made funds available to eligible entities within 30 calendar days after the Federal award was provided, or consistently and without interruption. 23

5. Estimated Paperwork Reduction Act (PRA) Burden Revision: Revised burden estimate from 10 hours to 33 hours per state plan (a 3 year average) to account for planning and implementation of new automated state plan MSP: n/a State accountability measure: n/a 24

6. Annual Assessment of CSBG Eligible Entities on Organizational Standards Response: No change to the Model State Plan A form of annual assessment of organizational standards is critical to the success of the new CSBG performance management framework OCS is committed to supporting states and eligible entities in implementing the standards, as described in IM 138, State Establishment of Organizational Standards for CSBG Eligible Entities OCS and OCS-funded TA providers will support states in finding solutions that work for the unique conditions of each state MSP: Section 6 State accountability measure: n/a 25

7. Quality Improvement Plans (QIPs) and Technical Assistance Plans (TAPs) Revision: In order to clarify terminology, revised the MSP by simplifying the questions and accountability measures; We are not defining the terms beyond the CSBG Act MSP: Sections 6, 8 and 10, questions 8.1, 8.2, 10.5, 10.6, and 11.2 State accountability measure: 4Sa(iii), 4Sc, 6Sb 26

Quality Improvement Plans (QIPs) Sect. 678C of the CSBG Act: Corrective Action; Termination and Reduction of Funding 678C(4)(A): at the discretion of the State (taking into account the seriousness of the deficiency and the time reasonably required to correct the deficiency), allow the entity to develop and implement, within 60 days after being informed of the deficiency, a quality improvement plan to correct such deficiency within a reasonable period of time, as determined by the State. 27

Account. Measure 6Sb Previous Version During the performance period The State had in place (i) Technical assistance plans (TAPs) for all assessed eligible entities with unmet standards that could be resolved within one year; and (ii) Quality Improvement Plans (QIPs) for all assessed eligible entities with serious deficiencies in meeting the state-adopted organizational standards. 28

Account. Measure 6Sb Revised Version During the performance period The State had in place Technical Assistance Plans (TAPs) and/or Quality Improvement Plans (QIPs) for all eligible entities with unmet standards. Footnote: If the State, according to the State s corrective action procedures, does not plan to put a QIP in place for an eligible entity with one or more unmet organizational standards, the State should institute a TAP to support the entity in meeting the standard. 29

8. States with FY 2015/2016 State Plans Revision: OCS will provide technical assistance to these 13 states to submit at least baseline performance management information in FY 2016 MSP: Section 1 and approximately 20 other data elements throughout the plan State accountability measure: Most measures 30

9. State Accountability Measure on Overall Satisfaction Revision: Included a new overall grantee satisfaction measure MSP: Section 3, question 3.5 State accountability measure: 8S Resource: Appendix 4: American Customer Satisfaction Index and CSBG Accountability (in the draft IM on State and Federal Accountability Measures and Data Collection Modernization, see CSBG Dear Colleague Message, January 27, 2015) 31

Next Steps and Technical Assistance 32

Model State Plan (Automated) FY 2015 First Federal Register Notice 1/26/15 End of 60 day comment period 3/27/15 Second Federal Register Notice 5/22/15 End of 30 day comment period 6/21/15 States submit new automated State Plans 9/1/15 December 2014 Quarter 2 Quarter 3 Quarter 4 October 2015 OMB/PRA Clearance Available for FY 2016 applications (Online) 33

Next Steps Training and technical assistance to states, including assistance to 13 states on 2 year FY 2015-16 plans Online systems testing and completion OMB final approval of automated CSBG Model State Plan State access to state plan on ACF s Online Data Collection (OLDC) system Publication of final Accountability Measures IM ACSI workgroup 34

Training and Technical Assistance Systems training on OLDC webinar(s) Publication of FY 2016 state plan submission guidance FY 2016 state plan submissions webinar Targeted outreach to 13 states on 2YR plans 35

36