CSBG DCL State Plan Revision: Open Comment Period

U.S. Department of Health and Human Services
Administration for Children and Families
Office of Community Services
Division of Community Assistance
330 C Street, SW, 5th Floor
Mail Room 5425
Washington, D.C. 20201
www.acf.hhs.gov/programs/ocs/programs/csbg

Community Services Block Grant
Dear Colleague Letter

Re: CSBG State Plan Revision: Open Comment Period

Date: November 22, 2017

Dear Colleagues:

The Office of Community Services (OCS) is requesting feedback from the Community Services Block Grant (CSBG) Network on the proposed revision of the CSBG State Plan Application (State Plan). On November 17, 2017, a Paperwork Reduction Act (PRA) notice for public comment was posted to the Federal Register in volume 82, number 221, and page 54348. During the 60-day comment period, and as soon as possible, we invite you to review the proposed revised State Plan and submit your comments, as described below.

Revisions to the CSBG State Plan

OCS and the CSBG Network — comprised of CSBG eligible entities, State CSBG Lead Agencies, State CAA associations, national partners, and others — collaborated to modernize and revise the State Plan as part of the performance management and accountability framework for CSBG.[1] In FY 2016, states submitted their newly streamlined and automated CSBG State Plan through the On-Line Data Collection system (OLDC).

The content, format, and order of this State Plan have remained consistent with the last version. However, there have been small revisions based on technological improvements, such as skip logic (which ensures that certain fields only need to be completed when applicable), pre-population (which loads information on eligible entities from a master list) and cloning (which allows states to revise and edit responses from prior-year state plans). In addition, revisions were made based on your responses in the FY 2016 and FY 2017 State Plans, adding clarity and conciseness to the plan.

Action Requested — Your Feedback

As per the PRA, OCS is required to seek a renewal every three years. The Federal Register notice requests feedback on the following:

“(a) Whether the proposed collection of information is necessary for the proper performance of the functions of the agency, including whether the information shall have practical utility;

(b) The accuracy of the agency’s estimate of the burden of the proposed collection of information

(c) The quality, utility, and clarity of the information to be collected; and

(d) Ways to minimize the burden of the collection of information on respondents, including through the use of automated collection techniques or other forms of information technology."

We especially invite comments on the revisions to the State Plan as detailed in Attachment B (Revisions to the CSBG State Plan). Please include supportive comments as well as suggestions for improvement, so that we can get a balanced perspective on what works and what needs revision. Please clearly reference your comments by section, question, or page number, as appropriate.

In addition, we have added a template for a CSBG Eligible Entities Master List, as well the instrument for the ACSI survey of eligible entities. The Master List will serve as a tool to update the eligible entities within your state in a more efficient manner, and will populate into the State Plan. The next ACSI survey will be administered in 2019. Both documents are attached to this Letter.

Please submit your comments to infocollection@acf.hhs.gov, as directed in the Federal Register notice, within the 60-day comment period that began November 17, 2017. We encourage you to submit your comments as soon as possible, in order to expedite the clearance process.

Clearance Process and Use of the Revised State Plan

At the end of the 60-day comment period, OCS will complete review of all the comments received and submit a revised State Plan to the Office of Management and Budget (OMB). During the second phase of the PRA process, which includes a 30-day comment period, OMB will review and approve the online State Plan for a three year period (FFY 2019 — FFY 2021).

Once OMB approves the revised State Plan and we complete the testing of the online form, OLDC will open for states to submit their FY 2019 State Plan. More details about the opening of OLDC for submission will be provided as we draw nearer to approval. It is not anticipated that the revised online State Plan will cause additional burden to the states, given the cloning and pre-population features of OLDC and other efficiencies due to the automation and routine use. OCS will provide technical assistance and training for all states to facilitate the submission process.

Since the overall content of the State Plan has not changed significantly, states should proceed with their usual State Plan formulation process prior to final OMB approval. We encourage states to consider the revisions of this State Plan, attached here, to plan for their FY 2019 State Plan submissions.

Additional Information

OCS will host a webinar series to discuss the proposed revised State Plan and the comment process in the upcoming months. More details are forthcoming.

If you have questions, please contact an OCS CSBG program specialist as listed on the OCS website: www.acf.hhs.gov/programs/ocs/resource/csbg-staff-assignments-by-re....

Thank you for your commitment to increase accountability across the CSBG Network. Together we can help lift people and communities up and out of poverty.

J. Janelle George                                                      Seth Hassett
Acting Director                                                          Director, Division of Community Assistance
Office of Community Services                                   Office of Community Services

Attachment A: Revised CSBG State Plan
Attachment B: Revisions to the CSBG State Plan
Attachment C: CSBG Eligible Entity Master List
Attachment D: ACSI Eligible Entity Survey

[1] The CSBG Performance Management Framework and Accountability effort includes: 1) organizational standards, 2) state and federal accountability measures, and 3) National Performance Indicators. See Information Memoranda IM No. 138 State Establishment of Organizational Standards for CSBG Eligible Entities and IM No. 144 CSBG State and Federal Accountability Measures and Data Collection Modernization for more information.