Detailed Information on the
Community Services Block Grant Assessment

Working with Congress to eliminate the program due to the program's minimal performance standards and overlapping services with other Federal programs.

Restructuring program monitoring and evaluation to improve program administration, accountability, and outcomes of state and local agencies that serve the poor.

Improve program effectivness and efficiency by refocusing the reporting efforts of the CSBG Network (states, CSBG-funded local entities) to identify the conditions of poverty that are reduced and eliminated through interventions of the Network as demonstrated in data submitted via the Results Oriented Management and Accountability (ROMA) performance measures tool and the National Performance Indicators.

Restructuring program monitoring and evaluation to improve program administration, accountability, and outcomes of state and local agencies that serve the poor. Milestone: Distribute data collection tools to grantees, and receive feedback on them.

Working with Congress to eliminate the program due to the program's minimal performance standards and overlapping services with other Federal programs. Milestone: The President's budget for FY 2008 recommends the elimination of the CSBG program.

Restructuring program monitoring and evaluation to improve program administration, accountability, and outcomes of state and local agencies that serve the poor. Milestone: Fully implement monitoring tools.

Measure: Number of conditions of poverty reduced.

Explanation:

Measure: Reduce total grantee and sub-grantee CSBG administrative expenditures per individual served.

Explanation:

Is the program purpose clear?

Explanation: The program's purpose is to reduce poverty, revitalize low-income communities and empower low-income families and individuals to be self-sufficient. To accomplish this purpose, CSBG provides flexible core or foundational funding to over 1000 community-based organizations (Community Action Agencies, or CAAs) in almost every county in the nation to promote innovative, community-generated and location-specific actions to reduce the incidence and severity of poverty.

Evidence: Community Opportunities, Accountability, and Training and Educational Services Act of 1998 (Coats Human Services Reauthorization Act of 1998)--title II, Subtitle B--Community Services Block Grant Program (42 U.S.C. 9901 et seq); Community Services Block Grant Program Fact Sheet; and History, Purpose and Perspective Information Sheet.

Does the program address a specific and existing problem, interest, or need?

Explanation: Poverty in America remains a persistent and complex problem, often rooted in market or societal conditions, especially unemployment, inadequate housing, and a lack of educational opportunity.

Evidence: U.S. Census Bureau, OMB Poverty Thresholds for 2002, CSBG Act (42 U.S.C. 9902--Poverty Line) and CSBG Act (42 U.S.C. 9910--tripartite Boards).

Is the program designed so that it is not redundant or duplicative of any Federal, state, local or private effort?

Explanation: The program is designed to empower communities to address local needs via the tripartite Board governance structure of CAAs. Consisting of three groups--public officials, members of the low-income community, and private community leaders--tripartite boards enable CAAs to allocate resources to complement and coordinate with other programs. No other program provides a stable dynamic platform for sustained community-based creativity and flexibility in addressing the multi-faceted problem of poverty.

Evidence: Draft CSBG Statistical Report FY 2001: Chart titled, "FY 2001 CSBG-Funded Local Agency Resources in 49 States, DC, and Puerto Rico (in millions of dollars)" and list of program funding sources. Also, CSBG Act (42 U.S.C. 9901--tripartite Boards)

Is the program design free of major flaws that would limit the program's effectiveness or efficiency?

Explanation: Current law does not require minimum performance standards of CAAs as a condition of continued funding. In very rare circumstances, States have designated CAAs as deficient and terminated funding to the entity, but only infrequently. As a result, CAAs are a largely static group unchallenged by competitive pressures for continous performance improvement.

Evidence: Economic Opportunity Act of 1964; 1981 CSBG Act; CSBG Act reauthorizations in 1984, 1986, 1990, 1994 and 1998.

Is the program effectively targeted, so program resources reach intended beneficiaries and/or otherwise address the program's purpose directly?

Explanation: Resource targeting is accomplished by needs assessments. Case management intake processes ensure that intended beneficaries are reached and unintended subsidies are avoided. All of the activities of CSBG-funded community agencies are focused on low-income individuals.

Evidence: Community Services Block Grant Program (42 U.S.C. 9902 - Definitions..Poverty Line) ; (42 U.S.C. 9908 - Application and Plan); CSBG Statistical Report; sample Intake Form; and sample Needs Assessment Instrument.

Does the program have a limited number of specific long-term performance measures that focus on outcomes and meaningfully reflect the purpose of the program?

Explanation: A new measure is under development, and may be included in the FY 2005 GPRA Plan. While this measure represents an encouraging step toward a singular national performance indicator, there remain unresolved technical concerns with the measure. Most importantly, the developmental measure aggregates some national performance indicators which track absolute numbers and do not measure relative success.

Evidence: Information Memorandum 49, ROMA Guide: Family Agency Community Outcomes; proposed 2005 GPRA measures; and, National Performance Indicators (draft).

Does the program have ambitious targets and timeframes for its long-term measures?

Explanation: Baseline data for newly developed long-term targets are being collected.

Evidence: Draft U.S. HHS FY 2005 OMB Request for Information and GPRA Performance Plan - Administration for Children and Families - Community Services Block Grant Section.

Does the program have a limited number of specific annual performance measures that demonstrate progress toward achieving the program's long-term measures?

Explanation: A new measure is under development, and may be included in the FY 2005 GPRA Plan. States and local agencies report outcomes for six long-term national goals that reflect the needs of particular service areas. While various outcomes for each goal are reported by States and local agencies annually, there is no set of national outcome measures for which all states and local agencies must report.

Evidence: Annual Report of Performance Outcomes from the CSBG Program and Proposed 2005 GPRA measures.

Does the program have baselines and ambitious targets and timeframes for its annual measures?

Explanation: While targets have been established for existing CSBG GPRA performance measures, actual performance exceeds even future targets by such an extent that they are not ambitious.

Evidence: U.S. HHS FY 2004 OMB Request for Information and GPRA Performance Plan-ACF - Community Services Block Grant Section and Proposed 2005 GPRA measures.

Do all partners (including grantees, sub-grantees, contractors, cost-sharing partners, etc.) commit to and work toward the annual and/or long-term goals of the program?

Explanation: New long-term and annual measures are under development. While various outcomes for each goal are reported by States and local agencies annually, there is no set of national outcome measures for which all states and local agencies must report. However, CSBG performance measurement strategies (Results Oriented Management and Accountability, or ROMA) were initiated in 1994, and became mandatory on October 1, 2001. All States met that statutorily required deadline, and the first report of CSBG outcomes was released in early 2003. ROMA was developed collaboratively among Federal, State and local agencies over a nine year period.

Evidence: Annual Report of Performance Outcomes from the CSBG Program, Regional Meeting Summary: ROMA Implementation by 2003, Information Memorandum 49 (specifies the requirements for undertaking performance measurement and reporting) and proposed FY2004 specifications for CSBG reauthorization.

Are independent and quality evaluations of sufficient scope and quality conducted on a regular basis or as needed to support program improvements and evaluate effectiveness and relevance to the problem, interest, or need?

Explanation: There are currently no independent evaluations for CSBG. No funds are appropriated for this purpose. However, data is collected annually from States on both program inputs (resources, services) and outputs (impact on beneficiaries and communities). States may use this information to assess local agency effectiveness.

Evidence: Program Implementation Assessment Instrument; CSBG Act (42 U.S.C. 9913 - Training, Technical Assistance and Other Activities); and CSBG Act (42 U.S.C. 9914 - Monitoring of Eligible Entities).

Are Budget requests explicitly tied to accomplishment of the annual and long-term performance goals, and are the resource needs presented in a complete and transparent manner in the program's budget?

Explanation: CSBG annual budget requests, as do those of most all ACF programs, include a budget linkage table that displays outputs and outcomes associated with the aggregate program budget authority. This table does not provide a presentation that makes clear the impact of funding, policy, or legislative decisions on expected performance nor does it explain why the requested performance/resource mix is appropriate.

Evidence: CSBG Act (42 U.S.C. 9917 - Accountability and Reporting Requirements).

Has the program taken meaningful steps to correct its strategic planning deficiencies?

Explanation: The CSBG program has been engaged in a nine year initiative to use performance based management as a tool for strategic program planning, programming and accountability. New national measures are currently being developed for CAAs. OCS is undergoing a restructuring process to better address the needs of all OCS programs. Finally, the reauthorization proposal will strengthen outcome reporting.

Evidence: Information Memorandum 49; Regional Meeting Summary: ROMA Implementation by 2003; CSBG National Performance Indicators (draft); and OCS Restructuring Plan (to be published in the Federal Register).

Does the agency regularly collect timely and credible performance information, including information from key program partners, and use it to manage the program and improve performance?

Explanation: The CSBG program utilizes annual program output and performance information from States and local CSBG-funded community agencies to identify training and technical assistance needs. A number of States now use performance-based management and outcome information to guide State and local CSBG strategic planning, programming, evaluation and reporting.

Evidence: CSBG Statistical Report; Annual Report of Performance Outcomes from the CSBG Program and OCS Restructuring Plan

Are Federal managers and program partners (grantees, subgrantees, contractors, cost-sharing partners, etc.) held accountable for cost, schedule and performance results?

Explanation: The Director of OCS and other ACF managers are held accountable for their performance through their Employee Performance contract for cost, schedule, and performance results, as required by GPRA. CAA Executive Directors are held accountable by tripartite Boards for cost, schedule, and achieving program outcomes through annual performance appraisals.

Evidence: CSBG Act (42 U.S.C. 9913 - T/A); CSBG Act (42 U.S.C. 9914 - Monitoring) ; CSBG Act (U.S.C. 9915 - Corrective Action); OCS Director's performance plan; Mid-Iowa Comm. Action's (MICA) Performance Accountability Plan; MICA's Qtrly. Personal Development Plan; State/local Audits; and CAA Executive Handbook pgs. 96-98.

Are all funds (Federal and partners') obligated in a timely manner and spent for the intended purpose?

Explanation: CSBG funds are allocated to States by formula. States must "pass through" at least 90% of their allocation to eligible local entities based on distribution formulae based on census or other demographic data concerning poverty. With few exceptions, funds are allocated to local eligible entities as soon as they are made available, and in accordance with a State-approved program plan.

Evidence: Financial Status Reports (SF 269A); Grant Award Letters; disbursement summaries; FY 2001 Statistical Report Highlights; Payment Center "draw down" data from 1993 to 2002; Subgrantee (Sandhills CAP) contract with the State of NC and State monitoring review form; Subgrantee Project Review Report; A-133 Compliance Supplement for CSBG (CFDA 93.569); & State/local Audits.

Does the program have procedures (e.g., competitive sourcing/cost comparisons, IT improvements, approporaite incentives) to measure and achieve efficiencies and cost effectiveness in program execution?

Explanation: While the program does have procedures in place to achieve efficiencies and cost effectiveness, there are no procedures in place by which to measure such efficiencies at the program level. For example, competitive sourcing and IT improvements are used to improve efficiency and cost effectiveness in program execution. OCS plans to include a CSBG financial resource leveraging efficiency measure to the FY 2005 GPRA Plan.

Evidence: FY 2004 OMB Request for Info. & GPRA Perf. Plan-ACF - CSBG Section; CT's IT sharing plan; CSBG Act (42 U.S.C. 9901-Sec 672(2)(E)); "MMDB" Team and report at: www.roma1.org/documents/mmdb/decision-makers-guide.pdf; History, Purpose & Perspective Info. Sheet; ACF Competitive Sourcing Plan; and OCS MIS Plan.

Does the program collaborate and coordinate effectively with related programs?

Explanation: CSBG work is unique by virtue of its extensive Federal, State and local coordination and collaboration in response to multiple needs of low-income households. For example, some 37% of Head Start classes and more than 40% of LIHEAP programs are managed by CAAs. These and other coordinated efforts secure and maintain employment, education, income management, housing, emergency services, nutrition, health and other services that respond to the needs of low-income individuals and families. Without such partnerships, community action would not be able to achieve and sustain favorable family, community and agency outcomes.

Evidence: Child Support Memorandum of Understanding (MOU); Head Start (2 MOU's); IRS (2 MOU's); HUD Lead Hazard Control (MOU); DOL Workforce Investment Act Partnership; CSBG Act (42 U.S.C. 9908 - Application and Plan -Assurances 5&6); and, FY 2000 CSBG Statistical Report pages 49 through 68.

Does the program use strong financial management practices?

Explanation: ACF has received a clean audit opinion from FY 1999 to 2002 (the last stand alone audit conducted), identifying no material internal control weaknesses. However, State agencies have primary responsibility for insuring the integrity and strength of financial management of funds by local CSBG grantees. States practices include: conducting periodic on-site review of financial management practices and recordkeeping/reporting practices of local agencies as part of routine program monitoring; receipt and review of interim and final expenditure reports submitted by local agencies; and periodic independent financial audits of local agencies, for not only the CSBG program but also for other programs administered by local CAAs. Finally, because local agencies have unique vulnerabilities, HHS has utilized its discretionary grant authority to provide special assistance to States and local agencies focused on continuous monitoring and improvement of financial management.

Evidence: CSBG T/TA Program Announcements; Program Implementation Assessments (PIA); CSBG Act: (42 U.S.C. 9913 - T/TA); (42 U.S.C. 9914 - Monitoring); (42 U.S.C. 9915 - Corrective Action); (42 U.S.C. 9916 - Fiscal Controls); CAA Executives' Handbook; State/local Audits; ACF audits; Federal Financial Management Improvement Act; and, ACF Audit Workgroup Questionnaire.

Has the program taken meaningful steps to address its management deficiencies?

Explanation: Federal, State and local CSBG authorities utilize a variety of mechanisms to identify and correct management deficiencies, including: annual on-site monitoring of local programs that focuses on program and management requirements of the law; national leadership training and inservice programs for local managers; intensive on-site remediation of significant deficiencies within at-risk agencies; and the ongoing effort to establish linkages between management protocols and program performance measurement and reporting.

Evidence: CSBG T/TA Program Announcements; Program Implementation Assessments; CSBG Act: (42 U.S.C. 9913 - T/TA); (42 U.S.C. 9914 - Monitoring); (42 U.S.C. 9915 - Corrective Action); (42 U.S.C. 9916 - Fiscal Controls) and CSBG Report to Congress.

Does the program have oversight practices that provide sufficient knowledge of grantee activities?

Explanation: Oversight is achieved through a variety of Federal and State mechanisms, including application review, annual on-site monitoring, fiscal reports and audits, performance measurement and reporting, and techical assistance.

Evidence: Program Assessments (PIA); CSBG Act: (42 U.S.C. 9908 - State Plan, 9913 - T/TA, 9914 - Monitoring, 9915 - Corrective Action, 9916 - Fiscal Controls); ACF Audit Questionnaire; subgrantee Project Review Report; State Internal Review Form; State Grantee Review & Assmt. Report; and, State/local audits.

Does the program collect grantee performance data on an annual basis and make it available to the public in a transparent and meaningful manner?

Explanation: As required by the CSBG Reauthorization Act of 1998, all States submitted ROMA-generated performance data for Fiscal Year 2001. A report of this data has been published and has been made available to the public both in print and electronically.

Evidence: Annual Report of Performance Outcomes from the CSBG Program and CSBG Statistical Report.

Has the program demonstrated adequate progress in achieving its long-term outcome performance goals?

Explanation: As noted in 2.1, these measures are under development, and as such, there is not yet any progress toward the goals. CSBG has successfully installed a universal system for tracking and reporting performance outcomes at the individual, local agency, State, and Federal levels. The program is changing its GPRA measures to be more outcome oriented and the Administration's proposed reauthorization language calls for more accountability at the grantee level.

Evidence: Information Memorandum 49; Annual Report of Performance Outcomes from the CSBG Program; U.S. HHS FY 2004 OMB Request for Information and GPRA Performance Plan -ACF - CSBG Section; proposed FY 2004 Specifications for CSBG reauthorization; and, proposed FY 2005 GPRA measures.

Does the program (including program partners) achieve its annual performance goals?

Explanation: As noted in 2.3, these measures are under development, and as such, there is not yet any progress toward the goals.

Evidence: Draft HHS FY 2005 OMB Request for Information & GPRA Performance Plan - ACF - CSBG Sec.; ROMA Guide: Family Agency Comm. Outcomes; and, FY 2004 Performance Plan/FY 2002 Performance Report (GPRA).

Does the program demonstrate improved efficiencies or cost effectiveness in achieving program performance goals each year?

Explanation: As noted in 3.4, while the program does have procedures in place to achieve efficiencies and cost effectiveness, there are no measures in place by which to capture such efficiency gains.

Evidence: Draft U.S. HHS FY 2005 OMB Request for Information and GPRA Performance Plan - Administration for Children and Families - CSBG Section.

Does the performance of this program compare favorably to other programs, including government, private, etc., that have similar purpose and goals?

Explanation: CSBG is the only program that has the statutory mission and flexibility to accomplish multiple tasks through varied strategies and partnerships. No other program corresponds to CSBG in terms of its broad anti-poverty mission and goals. CSBG effectiveness is measured not only by the services directly provided, but more importantly, by revitalizing low-income communities.

Evidence:  

Do independent and quality evaluations of this program indicate that the program is effective and achieving results?

Explanation: There are currently no independent evaluations for CSBG. No funds are appropriated for this purpose. However, an HHS grant supports an annual assessment and reporting of CSBG performance outcomes.

Evidence: Annual Report of Performance Outcomes from the CSBG Program.