The 60-Day Comment Period for the Community Services Block Grant (CSBG) Annual Report ended Monday, August 15, 2016. We would like to thank all of you 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. We look forward to working with OCS to review your comments and incorporate suggestions into the CSBG Annual Report.

Like many of you, we reviewed the proposed CSBG Annual Report and provided our public comments to be considered as part of the formal 60-day comment feedback to OMB. In our feedback, we identified both the strengths and potential weaknesses of the Annual Report, addressed the key questions posed by OCS, and integrated module-specific observations. We thank OCS for the opportunity to comment on the proposed CSBG Annual Report and to be engaged with this process as part of our collaborative relationship with OCS. To read the full letter, click here. The key points addressed in our letter are highlighted below.

Highlights of NASCSP Feedback on the CSBG Annual Report

We believe that the proposed CSBG Annual Report will ultimately help showcase robust results achieved by the CSBG Network for individuals, families, and communities with low incomes. The CSBG Annual Report will help us meet the latest reforms and expectations for performance management across the government and private sector in order to focus on analyzing results and using the data to improve programs and the outcomes achieved. We recognize the significant improvements within the proposed CSBG Annual Report, namely the addition of the Strategies and Services reports, the expanded section on community level work, modernized language and indicators, and the intent to automate State level reporting in OLDC. At the same time, we urge OCS to recognize and take into account the critical training and technical assistance elements necessary to successfully implement the CSBG Annual Report and capture quality, meaningful data. Listed below is a high level summary of areas of concern as related to the CSBG Annual Report.

Implementation and Timeline

The completion of the CSBG Annual Report will require substantial investments in staff time and resources at the Federal, State, and Community Action Agency (CAA) levels. In order for this important endeavor to succeed, it is essential for OCS to modify the projected implementation timeline to allow for the necessary training and technical assistance and systems upgrades.

Estimated Burden

While we support the revised/automated forms and the eventual creation of an online data collection system, and agree they will yield efficiencies in the States’ processes for completing the annual report (which replaces the IS Survey), the new process also increases State accountability and places new demands on systems and software. Because the content (in the form of the CSBG Annual report) is still in its draft form, it is and will be difficult to accurately project costs and time investments needed to implement the final format.

Module 1

1. B.2 and B.3 Eligible Entity Satisfaction Targets: There is the need for statistically significant data, guidance from OCS, and consistent administration and dissemination of the ACSI survey and the results.
2. 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.
3. D.2 Organizational Standards Performance: It is an unreasonable standard for CAAs to meet 100% of the Organizational Standards in a reporting period. We acknowledge this standard is set in the CSBG State Plan, but believe it should not be the single reporting measure.
4. D.3 QIPs and TAPs: Additional guidance will be necessary to ensure consistent practices throughout the CSBG Network for creating and implementing TAPs and QIPs.
5. H.4 and H.5 QIPs: States will require additional training and technical assistance and guidance from OCS before implementation of Module 1.

Module 2

1. Section A, CSBG Expenditures: We recommend 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.

Module 3

1. Section A, Numerical Baseline Data: We believe these sections must undergo additional streamlining. As such, we recommend removing numerical baseline data as a data point on the data entry forms and suggest alternate options detailed later in the letter.
2. Section B, Social/Population Indicators: We recommend categorizing the social/population level indicators as developmental indicators that could be assessed and modified.
3. Social B, Civic Engagement and Community Involvement: The Civic Engagement and Community Involvement goal should be strengthened to further spotlight the involvement of people with low incomes.

Module 4

1. Section A, Characteristics for NEW Individuals and Households: We recommend eliminating this report.
2. Section C, NPIs Tracking 90 and 180 days: We support keeping 90 and 180 day time frames, but 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.
3. Section C, Stability Measures: We recommend dropping Stability Measure #2.

We commend OCS for the evolution of the CSBG IS Survey into the CSBG Annual Report and for taking steps to ensure our CSBG Network is fully prepared to move forward in the ever-changing work to end poverty; however, the modifications we have discussed are critical in ensuring the CSBG Annual Report can be successfully implemented. Our recommendations include the removal of the New Characteristics Report, simplification of the community measures, and addition of developmental measures. These revisions will greatly alleviate the burden of data collection at all levels while still meeting the requirements of legislation and launching the CSBG Network forward into a learning culture rather than a compliance and reporting culture and further the goals laid out in the CSBG Act.