Closing of the 30-day Comment Period on the CSBG Annual Report What’s Next?

The Federal Register Notice #2 (FRN#2) 30-day comment period for the CSBG Annual Report started on November 1 and ended on November 30, 2016. This marks the end of the third and final official comment period in the Office of Management and Budget (OMB) clearance process. The next step in the process is for OMB to make a decision on CSBG Annual Report. As stated in the Federal Register Notice, “OMB is required to make a decision concerning the collection of information between 30 and 60 days after publication” of the notice in the Federal Register. This means OMB should provide a decision on the CSBG Annual Report by early January 2017. Once a decision is provided, NASCSP will be ready to assist the CSBG Network in adapting accordingly and will provide critical training and technical assistance.

NASCSP submitted a feedback letter to the Office of Management and Budget (OMB) on November 30, 2016. You can read the full letter here. NASCSP offered the following recommendations for ensuring successful implementation:

  • Phased-In Approach to the Implementation of Module 1: States will need to complete Module 1 in the On-Line Data Collection (OLDC) system for the FY16 and FY17 Annual Reports. Due to this, it is critical that OCS consider a phased in approach for Module 1 that clearly identifies the questions that must be answered for the FY16, FY17, and FY18 Annual Reports.
  • State Consultation and Involvement in the Implementation of Module 1: NASCSP supports OCS’ decision to establish a beta testing workgroup comprised of State CSBG Administrators to assist OCS in the development and finalization of Module 1 in the OLDC system.
  • Ongoing Consultation from the State CSBG Lead Agencies and the full CSBG Network: NASCSP recognizes that input from the CSBG Network is critical to the development of high quality CSBG data that will support a culture of continuous learning and improvement. We support OCS’ decision to create a CSBG Annual Report Task Force to continue the work of the Information System Task Force (ISTF), comprised of members from local Community Action Agencies, State Associations, Regional Performance Innovation Consortia, State Lead Agencies, and National and Federal Partners to continuously evaluate and improve the CSBG Annual Report.
  • Ongoing Training and Technical Assistance: NASCSP appreciates OCS’ recognition of the critical training and technical assistance elements that are necessary to successfully implement the CSBG Annual Report and capture quality, meaningful data. NASCSP supports OCS’ plan for training and technical assistance and looks forward to continued partnership in these efforts.

NASCSP was not the only National Partner organization to submit comments to OMB during the FRN#2 30-day comment period. Read the Community Action Partnership (CAP)’s letter here. Read the National Community Action Foundation’s (NCAF) letter here. These letters provide further insights on the variety of viewpoints shared by the full CSBG Network.

While we await OMB’s decision, check out the numerous resources we have developed on our website regarding the CSBG Annual Report. These resources include a CSBG Annual Report/CSBG IS Survey Crosswalk, Annotated CSBG Annual Report, National Theory of Change Graphic, and Module 1 Word Document. We also have number of webinars regarding the changes made to the CSBG Annual Report. Webinar topics include a general update on the changes that were made, specific 30-minute guides to each module, a discussion on how to prepare for the CSBG Annual Report in your state, and a dialogue on the CSBG Annual Report with OCS and the National Partners.

Wondering about the timeline for reporting CSBG data? Check out the CSBG Reporting Timelines for States and local CSBG Eligible Entities Chart. This chart helps illustrate what the data submission timeline for both States and local CSBG Eligible Entitles in FY16, FY17, and FY18 based on the State’s reporting period.