Feedback from the National Partners during the 60-day Comment Period on the CSBG Annual Report

Over the past year, the CSBG Network has spent countless hours reviewing the proposed CSBG Annual Report and the framework for the next generation of ROMA. After completing an Initial Feedback Period (March 2016-April 2016) and an official OMB 60-day comment period (June 2016-August 2016), a third iteration of the CSBG Annual Report was released on October 25, 2015 and the third and final 30-day comment period began on November 1, 2016. The newly released CSBG Annual Report  includes revisions that reflect the feedback received from local agencies, State Associations, State Offices, and the National Partners during the 60-day comment. The National Association for State Community Services Programs (NASCSP), the Community Action Partnership (CAP), the National Community Action Foundation (NCAF), and the Association for Nationally Certified ROMA Trainers (ANCRT) all submitted comments during the 60-day comment period. The feedback letters from the National Partners shared many of the same concerns expressed in the hundreds of comments submitted by the Network during 60-day comment period. This post provides an overview of how the key concerns included in the feedback from the National Partners were addressed in this version of the CSBG Annual Report. To support your review, we have color coded the revisions based on the following:

  • Green represents changes made.
  • Purple represents compromises.
  • Red represents no changes made.

NASCSP appreciates the ongoing efforts across the Network and encourages you to reach out to us with questions about ROMA Next Generation and the CSBG Annual Report. Please contact us at If you are planning to submit comments during the 30-day comment period, we suggest you do so by November 30, 2016 to ensure full consideration by the Office of Management and Budget. Comments must be submitted to the following: Office of Management and Budget, Paperwork Reduction Project, Email: OIRA_SUBMISSION@OMB.EOP.GOV, Attn: Desk Officer for the Administration for Children and Families.

 Comments on Module 1: State Administration

  • B.2 and B.3 Eligible Entity Satisfaction Targets: There are issues related to completing B.2 and B.3. These issues are related to the need for statistically significant data, guidance from OCS, and consistent administration and dissemination of the survey and the results. States will need guidance and additional time to work with their agencies and prepare reports on their use of the ACSI.
    • Source: NASCSP
    • Revision: Instructional note and a link to IM 150 was added. Click here to review the revision.
  • B.7 Summary Analysis: Analysis is contextual and therefore, these questions should not be mandated. Limited data sharing across programs creates challenges for meaningful analysis of trends and results.
    • Source: CAP, NASCSP
    • Revision: Question B.7 was removed and some questions were attached to question I.4. Click here to review Section I, ROMA System.
  • D.2 Organizational Standards Performance: Modify the options CSBG State Lead Agencies/grantees have when reporting to OCS on CSBG Organizational Standards to allow for a broader range of responses.
    • Revision: Revised table to allow reporting on number of entities meeting 90-99% of standards, 80-89%, and 70-79%. An additional table was added for reporting on percentage of entities meeting specific categories of standards. Click here to review the revision.
  • D.3 Technical Assistance Plans and Quality Improvement Plans: Modify the language to reflect the stated intent as well as the spirit of IM 138 to reflect the preference for a Technical Assistance Plan when Organizational Standards are not met.
    • Source: CAP, NASCSP
    • Revision: Note was revised to clarify that this is at the state’s discretion and refers to the guidance in IM-138. Click here to review the revision.
  • I.4 State Feedback on Data Collection, Analysis, and Reporting: Reinstate the ROMA Goal related to agency capacity.
  • Implementation and Timeline: Modify projected implementation timeline to allow for the necessary training and technical assistance and systems upgrades.
    • Source: NASCSP
    • Rational: The implementation timeline for Module 1 is unchanged at this time.

Comments on Module 2: Agency Expenditures, Capacity, and Resources

  • CSBG Expenditures used for Administration: NASCSP recommends further conversation on where and how CSBG administrative expenditures are reported to align with CSBG Network feedback and OCS guidance in the form of IM 37.
    • Source: ANCRT, NASCSP
    • Rational: Reporting on administrative expenditures remains consistent with current reporting in the CSBG IS. Click here to review the CSBG Expenditures Report.
  • Staff Certifications: Family worker credentialing returned to the list (is in current IS reporting) as this is an area where we need to see skills and attitude development for our direct service workers.
    • Source: ANCRT
    • Revision: Added Number of Family Development Staff who are Certified. Click here to review the CSBG Eligible Entity Capacity Building.

Comments on Module 3: Community Level

  • Remove “Collective Impact” options from the reporting tool.
    • Source: CAP, NCAF
    • Revision: Collective Impact language was removed from the Community Level Initiative State page. Click here to review the revised Community Level Initiative Status page.
  • Baseline Data: Remove/modify this sentence to remove the word justify, “When reporting a baseline number (Column II), agencies will have the option to provide a baseline number when the information is available, feasible, and reasonable to collect and track. In situations where the baseline is not available, agencies must provide a narrative justifying the need for the initiative…”
    • Source: CAP
    • Revision: The instructions were modified to remove the word “justify” and the community level indicators were reorganized into Rates of Change and Counts of Change. Only the rates of change indicators will require a baseline. Click here to read the revised instructions.
  • Social Indicators: Remove or revise the Community Outcome Indicators/Social Indicators that include percent or rates. Many of the indicators used here are inappropriate for reporting by local sub-grantees to States and by States to OCS and will produce data of limited utility.
    • Source: CAP & NCAF (recommended removal) ANCRT & NASCSP (recommended revisions)
    • Revision: The community National Performance Indicators (NPIs) were reorganized into two sections: 1) Counts of Change and 2) Rates of Change. Baseline data is only necessary for the Rates of Change indicators. Click here to review the community NPIs in the employment domain.
  • Reporting Requirements: Most of the forms in this portion of the report should be designated as voluntary, not required, tools for local use.
    • Source: NCAF
    • Revision: While this is not a voluntary report, the indicators are optional and CAAs will report on indicators that were identified through the CAP plan process.

 Comments on Module 4:  Individual and Family Level

  • New Characteristics Report: Remove the Characteristics for NEW Individuals and Households Report in its
  • NPIs Tracking 90 and 180 days: The proposed indicators tracking outcomes for 90 and 180 days should remain in the CSBG Annual Report, however the instruction and guidance for these indicators should be modified. The instructions should clearly state that CAAs are only expected to report on these outcomes if tracking these indicators is already a part of programs that are designed specifically to include follow up.
    • Source: CAPNASCSP
    • Revision: The instructions were revised and the 90/180 day indicators were reorganized within the module. Click here to read the revised instructions.
  • “Other Outcome Indicator”: Add an “Other Outcome Indicator” to the list of Individual and Family Level NPIs.
    • Source: ANCRTNASCSP,  NCAF
    • Revision: The option of “Other Outcome Indicator” was added as an option for the individual and family indicators. Click here to see an example in the Housing Domain.
  • Stability Indicators: Remove the proposed stability indicators from the Individual and Family NPIs.
    • Source: CAP, ANCRTNASCSP
    • Revision: The indicator multiple outcome indicator is now listed under Outcomes Across Multiple Domains. The financial well-being stability indicator was moved to the income and asset domain. Click here to see this revision.