The 60-Day Comment Period for the Community Services Block Grant (CSBG) Annual Report ended on Monday, August 15, 2016. We would like to thank you all for your continued engagement in this process, with particular thanks to those of you who submitted comments to the Office of Community Services (OCS) during the past two months. OCS and NASCSP are in the process of reviewing the comments and are looking forward to incorporating sugge
stions into the Annual Report. During the comment period many good questions were raised about ROMA Next Generation (NG) and the CSBG Annual Report. We compiled the most frequently asked questions and will cover these questions in a three-part series, focusing on general questions, as well as questions specific to particular modules of the CSBG Annual Report. Today’s post addresses general questions about ROMA NG and the CSBG Annual Report.
General Questions
1. How do I explain ROMA Next Generation (NG) and the CSBG Annual Report compared to ROMA?
ROMA Next Generation is a re-focusing of efforts on the full implementation of the ROMA cycle throughout the community action network. This includes clarification and expansion of National Performance Indicators for individual/family and community outcomes achieved by the network, identification of services and strategies used to achieve the outcomes, and demographic information about individuals and families served – all being reported in the new CSBG Annual Report. The ROMA NG principles and practices support the use of performance data to achieve major goals for individuals, families and communities across the country. This includes greater stability and economic security for individuals and families with low incomes, healthy communities that offer economic opportunity, and engagement of people with low incomes in building opportunities in their communities.
ROMA NG will support all levels of the CSBG Network in using data from the CSBG Annual Report (proposed during the OMB PRA Clearance 60-day comment period) on people, services, strategies, and outcomes for decision-making. The CSBG Annual Report will provide clearer descriptive data that will demonstrate outcomes at both the Individual/Family, and Community levels. Improved data will help us to think about data and analysis as a profit center, helping us do our best for families and communities with low incomes, rather than as cost center, and will support agencies in becoming better learning organizations. The CSBG Annual Report will eventually replace the CSBG IS Survey.
NASCSP has a variety of tools and resources available on its website to support these conversations, like a graphic overlay of how ROMA connects to the ROMA NG, discussion guides, and posters that break down the key elements.
2. Is CSBG data and annual reporting required?
The current CSBG Act passed in 1998 establishes requirements for OCS, states and eligible entities to collect data and report to Congress on the planned and actual uses of CSBG. The CSBG Act requires each state and eligible entities in the state to participate in a performance management system by October 1, 2001[1]. Each state must submit a report on performance, expenditure of funds spent by the state and eligible entities, delivery of direct services, characteristics of clients served and training and technical assistance provided to eligible entities[2]. From the information provided by states and eligible entities OCS must annually prepare a report[3] on the planned and actual uses of CSBG funds by states, as well as information on delivery of services, number of eligible entities, demographics of clients, performance results, and other information considered appropriate by the Secretary of HHS[4]. Since FY 2005, OCS has accepted the CSBG Information System Survey (CSBG/IS) as the information necessary to meet the CSBG Act requirement for states to provide an annual report[5]. The CSBG IS Survey was developed by a group of stakeholders (State CSBG offices, Community Action Agencies (CAAs), State CAA Associations, and national partners) in 1983.
Currently, all 50 States plus Puerto Rico and the District of Columbia provide information through the CSBG IS Survey on the funding level, allocations, and expenditures of CSBG funds. CAAs also report on other sources and uses of other funding administered by CAAs.
3. What is the CSBG Performance Management Framework and how do the CSBG State Plans and CSBG Annual Report support the Framework?
Over the last several years, OCS and the CSBG Network – comprised of CSBG eligible entities, state CSBG Lead Agencies, state Community Action (CAA) Associations, national partners, and others – have collaborated to create a new Performance Management Framework for CSBG. The graphic below (or the following graphic) illustrates this framework.
These elements are designed to increase effectiveness and accountability across the CSBG Network (Federal, state, and local) and generate more robust results for the people and communities served. Implementing a comprehensive CSBG Performance Management Framework not only strengthens the CSBG Network to meet today’s challenges, but positions the Network for future growth and increased capabilities to achieve breakthrough outcomes.
The online CSBG State Plan, used by State CSBG Lead Agencies for the first time in FY 2016, integrates and aligns requirements from the CSBG Act, with elements of the overall CSBG Performance Management and Accountability Framework, which includes 1) Organizational Standards for CSBG eligible entities, 2) accountability measures for States and OCS, and 3) Results Oriented Management and Accountability (ROMA). Ultimately, this framework will enable the CSBG Network, at the local, state and federal levels, to continuously improve their programs and generate breakthrough outcomes for families with low-incomes and communities.
The CSBG Annual Report will complete the Performance Management Framework and allow us to measure the impact of the Organizational Standards, the State and Federal Accountability Measures, as well as new National Performance Measures and ROMA Next Generation analysis practices. The CSBG Annual Report is a tool to hold the CSBG Network accountable for all the elements comprised in the Performance Management Framework.
4. Why does the CSBG Annual Report need OMB clearance?
As OCS moves forward with an improved Performance Management Framework, CSBG State Plans and Annual reports collect data on elements of the framework including the Organizational Standards, State and Federal Accountability Measures (including the American Customer Satisfaction Index) and ROMA Next Generation. The CSBG State Plan forms were cleared by OMB in 2015 and OCS started using the forms for FFY 2016. The final element in the framework is the new Annual Report identified above. The Annual Report ties together all the elements of the Performance Management Framework and includes elements of the current CSBG Information Survey (IS) report that is submitted to NASCSP. The CSBG IS Survey, which did not go through the OMB clearance process, has been used as the vehicle to meet the CSBG statutory requirements related to annual reporting and will be replaced by the new Annul Report to meet these requirements going forward.
5. What are the next steps in the OMB Clearance Process?
The CSBG Annual Report is currently in the OMB Paperwork Reduction Act (PRA) Clearance Process. The 60-day comment period was held from June 16, 2016 to August 15, 2016. Following the 60-day comment period, OCS has the responsibility to review all comments received. OCS will make additional modifications to the CSBG Annual Report and then submit the revised CSBG Annual Report to begin a final 30-day comment period. Following the 30-day comment period, OMB will conduct a 30-day review of the CSBG Annual Report and comments before issuing a final decision.
6. How long does the OMB PRA clearance last?
It is important to note that once approved by OMB, the CSBG Annual Report will be approved for a 3-year period. At the end of the 3-year approval, OCS must seek a new clearance which includes the same public comment process as OCS is currently conducting. Following the end of the 3-year approval, changes can be made to the CSBG Annual Report based on lessons learned from the initial implementation period.
7. The New CSBG Annual Report seems to require much more information. Won’t this diminish local determination and cause an increased burden on agencies?
No, many of the data elements are optional and are included to allow maximum flexibility. Because CSBG is a block grant, many data elements are needed to allow full flexibility. Requiring agencies to select from a small number of data elements might appear to reduce burden, but would inappropriately limit agencies. The CSBG Annual Report incorporates both existing elements from the CSBG IS Survey (for example, the CSBG Expenditures, Resources Administered by the CSBG Network, Demographics, and reporting on National Performance Indicators, as well as targeting) and new elements (like the New Individuals and Households Characteristics Report, Services and Strategies, Stability Measures, and more data collection on Community Level Initiatives). The CSBG Annual Report maintains local determination and the context of the block grant. As such, the CSBG IS Survey has been modified and renamed the CSBG Annual Report to provide a greater number of options for reporting outcomes achieved, describing the people who come to CAAs for assistance and what kinds of services they are provided, as well as the variety of community initiatives and strategies that are used to address the complex needs in a community. One example of greater flexibility in reporting is the addition of “Other Outcome Indicator” in Module 3, on Community Level work. Recognizing the unique set of needs and approaches in each community, the “Other Outcome Indicator” was added to make sure agencies have an opportunity to report community outcomes if none of the outcomes listed are a match.
While there are more data elements in the CSBG Annual Report overall than the CSBG IS Survey; no agency will report on all, or even most, of the elements. Agencies will only report on what services they provide and what outcomes they are trying to achieve for the people they serve. For example, in the new Services and Strategies reports, there are a wide range of options provided for reporting, but agencies will report only on those that apply to their work. Over the past year, we expanded the original List of Services, based on feedback received from the Network, to cover the broad range of services that Community Action provides across the country. It is important to remember that this list is a menu meant to provide options and not to add work. We expect this list will enhance the story we are able to tell about Community Action and its efforts.
8. I was told that I would have to report on all of the data points. Is that true?
Absolutely not. An Agency will report only on the data points that apply to its agency. It is critical to note that CAAs will continue to report only on data elements that are relevant to their work and are not required to report on all data elements. One example is in Module 3 (Community Level) and Module 4, (Individual and Family): no agency would be expected to report on all the indicators listed. Agencies will only report on the indicators that are appropriate or the best measure to assess the services and strategies the agency is implementing.
9. The report includes a standard set of elements – such as in the services and strategies and also in the NPIs. Doesn’t this reduce the rich variety of diverse CAA achievements from across the network?
When the National Performance Indicators were originally developed (2001 – 2004) it was with the understanding that the Community Action Network was moving to balance the localized nature of its work with the need to create a more uniform and accurate national accounting of how the entire network of community action agencies improves conditions and opportunities for low-income families and their communities. To enable greater aggregation and national reporting of the most universal and significant CSBG results among states and local agencies, common categories of community action performance were identified from Fiscal Year 2001-2003 data. That set of NPIs has been used over the past 12 years. An analysis of those NPIs and the additional indicators that were entered by local agencies over the years informed the creation of the set of NPIs included in the new Annual Report. Information about the data collected from other agencies servicing families with low-incomes was also used.
The standardization of the information makes it possible to speak about a national impact of CSBG funding and the other resources it leverages. The option to add “other indicators” in the Community-Level module provides the opportunity for ongoing input from local agencies to continue to promote the variety and diversity of anti-poverty work.
10. Where are the six ROMA Goals?
The six ROMA goals were reviewed as a part of the ROMA Next Generation development process.It was clear from discussions with CAA professionals across the country that a refinement of the national goals was due. For instance, the creation of partnerships, which has been a national goal, has long been recognized as more of a strategy to achieve both family and community level outcomes than a goal in itself. It is a way to improve agency functioning. Partnerships are created for a purpose – and that purpose has to do with addressing the anti-poverty intentions of the CSBG funding. (Partnerships are being reported in Module 2, section B of the Annual Report and reference to outcomes resulting from partnerships is found in Module 3, Community Level work).
Ongoing discussion related to agency capacity (another national goal) was identified to be the foundation upon which the CAA work is built. It is not a goal of the agency to maintain its own capacity, but it is the means by which all of its goals are achieved. Agency capacity development is appropriately addressed in local agency strategic plans and is supported fully by CSBG funding (as indicated by revised expenditure reporting in Module 2 of the proposed Annual Report), and is evidenced by components of Module 2 in the CSBG Annual Report and other elements of the Performance Management Framework, such as the Organizational Standards. As previously discussed, agency capacity is represented in the Performance Management Framework and is a vehicle by which Community Action Agencies (CAA) achieve their anti-poverty mission. The NPIs in the CSBG Annual Report help us demonstrate how CAAs are achieving the national goals.
Therefore, three National Goals are proposed in the Theory of Change and these are cited in the CSBG Annual Report. The proposed goals are about the people and the communities we serve.
- Individuals and families with low incomes are stable and achieve economic security.
- Communities where people with low incomes live are healthy and offer economic opportunity.
- People with low incomes are engaged and active in building opportunities in their communities.
11. How has the Office of Community Services (OCS) estimated the additional effort that will be required to transition from the CSBG IS Survey to the CSBG Annual Report?
OCS is aware of the burden data collection, analysis and reporting may have on the CSBG Network. OCS also believes that these tasks are investments that can help agencies improve, grow and produce breakthrough results. To estimate the reporting burden (the collection and review of performance data as well as the development of any necessary technology) on the CSBG Network to produce the proposed Annual Report, OCS factored in several variables:
- Whether the data being requested is new or is “usual and customary” for each section of the proposed Annual Report (e.g. local agencies are already legally required to collect much of the demographic data to determine eligibility of participants, while the services and strategies are new);
- How the data collection effort differs at the state versus the local level (e.g. the states are responsible for reporting on the Administrative Module including performance against the State Accountability Measures as set in each State’s Annual Plan, and for reviewing and analyzing the data collected from the local agencies. The local eligible entities have the burden of tracking participants served and the outcomes they achieve);
- The current capacity to collect, report and review the requested data, and how that varies throughout the network (e.g. some organizations currently have sophisticated technology and trained staff; others will need to upgrade their technology, and some number will need to develop new systems and train staff); and,
- Over time the burden will decrease as systems are developed or modified and as staff gain experience with reporting and analysis.
Estimated Annual Burden Hours
| Instrument | Number of respondents | Number of responses per respondent | Average burden hours per response | Total burden hours |
| CSBG Annual Report | 52 Grantees | 1 | 164 | 8,551 |
| 1,035 Sub-Grantees | 1 | 242 | 250,585 |
Aware of the reporting burden the proposed Annual Report will entail, OCS will decrease that burden by establishing an on-line automated system for use by the states and – at the discretion of the states – the local agencies, for reporting that allows in many instances auto-populating data from one year to the next and a variety of data entry processes (e.g. manual entry and automatic upload). OCS can begin development of the on-line forms once OMB Clearance is achieved.
OCS has also taken care to assure that as much of the data requested as possible aligns with the data collection requirements of other federal agencies to which the network already reports. Finally, OCS is planning a phased-in implementation approach for the new reporting requirements to allow the states and local agencies time to adjust systems, update processes and procedures, and train staff.
12. What Training and Technical Assistance will be provided to CAAs to implement ROMA NG/CSBG Annual Report?
OCS believes that ROMA Next Generation is a critical part of strengthening the CSBG Network and has made substantial investments in ROMA Next Generation/CSBG Annual Report. OCS has a Cooperative Agreement with NASCSP to develop ROMA Next Generation and a web-based system for collecting and sharing data, which runs from 2014-2017. Additionally, OCS has announced new funding opportunities to support the T/TA strategy for the Organizational Standards, State Accountability Measures, and ROMA Next Generation at the local, state, and regional levels of the network. These funding opportunities include the Community Services Block Grant (CSBG) Training and Technical Assistance (T/TA) Organizational Standards Center of Excellence (COE) ($600,000) and the Community Services Block Grant (CSBG) Training and Technical Assistance (T/TA) Program: Regional Performance and Innovation Consortium (RPIC) ($4.4 million).
OCS also recognizes that consistent reporting is critical to quality data collection. NASCSP currently maintains the Instructions Manual and the Lexicon for the CSBG IS Survey and will update these documents to support the changes in the CSBG Annual Report.
13. What support will be provided for cost investments related to data systems and capacity building?
OCS is aware that investments for improved data systems and capacity are important to the Network and essential to support Network capacity. OCS recognizes that some agencies and states are in different places in terms of their data systems and capacity, and as such continues to analyze ways to both reduce burden and provide as many options as possible for how to collect and provide the data and adjust data systems. The CBSG Network will need to work within the existing appropriations and allocations to transition to the CSBG Annual Report. This awareness of the funding needs in the network led OCS to the language included in the FY17 Budget Proposal. The Administration proposed new flexibility for the state administrative portion of CSBG to exceed 5 percent to implement State Plans, approved by the Secretary, that include one-time investments in data systems modernization, data analysis capacity, and improved information exchange and interoperability of data systems. This proposal was an effort by the Administration to increase state flexibility to increase local agency capacity where challenges might exist. OCS is open to additional recommendations and approaches to achieve these goals via other avenues. This language and funding adjustments are only proposed, and will be subject to decisions made at the Congressional levels during the coming months.
OCS is working with states and local agencies to identify future training and technical assistance needs via several focus group opportunities and data from two recent customer satisfaction (ACSI) surveys. OCS will be listening to hear what types of supports might help local agencies to make wise and efficient system investments and will consider if there are ways to support these needs. This information will be analyzed and later this year OCS will release a strategic prioritization of future training and technical assistance needs as well as decisions about how OCS CSBG training and technical assistance resources will be allocated to meet the needs.
14. What is the timeline and format for reporting? Why are the reporting dates different for States and CAAs?
The changes in ROMA NG/CSBG Annual Report are significant enough that implementation will take approximately three fiscal years (FY). The majority of the data collection and reporting on ROMA Next Generation will begin in Fiscal Year (FY) 2018. CAAs will start collecting data for Modules 2, 3, and 4 for the FY18 Annual Report. States will submit Module 1 for the FY16 Annual Report, due March 2017, and will submit Modules 1, 2, 3, and 4 for the FY 18 Annual Report by March 31, 2019. Module 1 is well aligned with data already submitted in the Model State Plan in the ACF On-Line Data Collection (OLDC). As such, the reporting timeline for Module 1 is earlier than for Modules 2, 3, and 4. To view your State’s reporting period for FY 18 click here.
Over the next two years, OCS plans to replace the current CSBG-IS reporting approach with an online data system in which States will upload data directly to OCS. The goal of this effort will be to improve data analysis at the local and state levels, expedite national reporting, and ultimately, to support additional public communication about the results achieved by the CSBG Network. OCS and NASCSP will also develop a flexible reporting form for optional use by states and agencies when entering data into the ACF OLDC system. OCS has a cooperative agreement with NASCSP to develop a web-based system that will allow for greater analysis and transparency of the CSBG data once submitted to OCS. OCS plans for this web-based system to maintain information that will be publicly available.
15. What guidance will be provided for the reporting of NPIs and definitions of key terms to ensure consistency across the network?
The Instructions Manual and Lexicon for the current CSBG IS will be updated based on the CSBG Annual Report. In addition to these tools, OCS will support ongoing T/TA efforts through two funding opportunities Community Services Block Grant (CSBG) Training and Technical Assistance (T/TA) Organizational Standards Center of Excellence (COE) and the Community Services Block Grant (CSBG) Training and Technical Assistance (T/TA) Program: Regional Performance and Innovation Consortium (RPIC).
[1] CSBG Act Sec. 678E(a)(1)
[2] CSBG Act Sec. 678E(a)(2)
[3] The CSBG FY 2014 report is in clearance at ACF and the FY 2015 report is under development. States submitted data for the FY2015 report by March 31, 2016.
[4] CSBG Act Sec. 678E(b)(2)
[5] CSBG Information Memorandum No. 79 Application for CSBG Funds for FY 2005, http://www.acf.hhs.gov/ocs/resource/im-no-79-application-for-fiscal-year-2005-community-services-block-grant
