1. Reauthorizing CSBG: How & Why? Presented by David Bradley Executive Director, National Community Action Foundation 1

2. Background: CSBG Created in 1981 Last reauthorized in 1998 (through FY2003) Coming up in 2013: The 9 th Anniversary of Community Action with no CSBG law in effect! 2

3. Why Are CAAs Still Here? 3 Because appropriations bills say, “Fund the CSBG Act of 1998!”

4. Why Update CSBG? Address for current needs Use words that work today Affirm national commitment to local decision-making 4

5. Why Update CSBG? Cont. Allow innovation Support the comprehensive approach to fighting poverty Achieve and measure results 5

6. The Structure of This Presentation Current LawProposed Change Rationale Language from the statute currently in effect (in teal) The proposed reauthorization bill (in blue) Why the proposed change is a good idea (in bright pink) 6

7. Name of the Act Current LawProposed Change Rationale The “COATS” (Community Opportunities, & Training, & Educational Services) Act of 1998 “The Sargent Shriver Community Economic Opportunity Act”* Focus on the main mission: “Create Opportunity” Honor Shriver and our heritage 7

8. What’s New In Proposed Bill? Promotes innovation by requiring states to budget (2%) for a Community Action Innovations Program Flexibility on length of project Uses of Funds (property-) 8

9. What’s New In Proposed Bill? Cont. Clarify needs assessment, strategic and operating plans Makes CAA Annual Plan(s) the basis for State Plan 9

10. What’s New In Proposed Bill? Cont. Professionalization Requires training for CAA, State, and Federal level staff Aligns eligibility so that no client can be dropped before completing a program due to an increase in income 10

11. PURPOSES AND GOALS Current Law ‘‘(1) to provide assistance to States & local communities, working through a network of community action agencies & other neighborhood-based organizations 11

12. PURPOSES AND GOALS Proposed Changes CSBG funds are for supporting the activities of Community Action Agencies which reduce the causes & conditions of poverty & persistent economic insecurity by: 12

13. PURPOSES AND GOALS Current Law ‘‘…for the reduction of poverty, the revitalization of low-income communities, & the empowerment of low-income families & individuals… 13

14. PURPOSES AND GOALS Proposed Changes providing individuals & families with opportunities to become economically secure expanding opportunities for & revitalizing the communities in which low- & moderate - income Americans live; & ensuring maximum participation of residents…in the governance of the CAA. 14

15. PURPOSES AND GOALS Current Law (cont’d) …in rural & urban areas to become fully self-sufficient sufficient (particularly families who are attempting to transition off a State program carried out under part A of title IV of the Social Security Act (42 U.S.C. 601 et seq.)” 15

16. PURPOSES AND GOALS Rationale CSBG is not for support of general state or local gov’t programs that CAAs are told to run. CSBG allows local choice in how all other resources should be used to fight poverty Balances family services and community-wide improvements Brings back “maximum feasible participation” as a core principle of community action 16

17. Current Law 2% for T&TA evaluation, and performance measurement, assist States in corrective action monitoring, and reporting and data collection activities … OCS TRAINING, TECHNICAL ASSISTANCE, AND OTHER ACTIVITIES 17

18. Proposed Change 2% Set Aside: 1% For CAAs, State/Reg’l Assocs, States Required $ to all State assocs 1% for these PLUS National Orgs & others 18 TRAINING, TECHNICAL ASSISTANCE, AND OTHER ACTIVITIES

19. Proposed ChangeRationale carrying out and replicating innovative initiatives carrying out professional development activities that expand the capacity of eligible entities Prioritize: professional development, organizational capacity, and innovation 19 OCS TRAINING, TECHNICAL ASSISTANCE, AND OTHER ACTIVITIES

20. Proposed Changes Federal T&TA to be guided by a public, collaboratively developed HHS plan: OCS will develop a strategic plan developed every three years in consultation with the Community Service Network Organizations (Section 678A(b)(2). 20 OCS TRAINING, TECHNICAL ASSISTANCE, AND OTHER ACTIVITIES

21. Proposed Change OCS will work with CAAs, Assocs, States Have 3 year T/TA Plans 21 OCS TRAINING, TECHNICAL ASSISTANCE, AND OTHER ACTIVITIES

22. ALLOTMENTS AND PAYMENTS TO STATES Current Law ½ of 1% (.005) to Territories Formula stays same except: Minimum grant is ½ of 1% (Could be less if CSBG cut is ½) 22

23. 23 ALLOTMENTS AND PAYMENTS TO STATES Proposed ChangeRationale ‘‘(1) MINIMUM ALLOTMENTS.— No State will have less that ½ of 1% We rise and fall together.

24. Proposed ChangeRationale Minimum small state share of federal formula raised to 0.75% (Section 675B(a)(2)(B) if appropriations equals [$850] million or more. The proposed change helps ensure that every state will get enough to run an effective program and no state would lose compared to previous year. 24 ALLOTMENTS AND PAYMENTS TO STATES

25. Current Law ‘‘(a) GRANTS TO ELIGIBLE ENTITIES AND OTHER ORGANIZATIONS.— ‘‘(1) IN GENERAL.—Not less than 90 percent of the funds... shall be used by the State to make grants … to eligible entities. … [STATE] USES OF FUNDS 25

26. Proposed Summary of Changes Use of State Discretionary Funds Still 10% of total, 40% of that may be reserved for T&TA 20% must be used for community innovations fund = grants to CAAs, associates Admin funds max. =40% of the state discretionary budget (4% of CSBG) State must use admin for CSBG management 26 [STATE] USES OF FUNDS

27. Proposed ChangeRationale Requires Professional development training for the CAA employees & Boards & State employees. Focuses State T&TA on professional and organizational development Improves both sectors. 27 [STATE] USES OF FUNDS

28. Proposed ChangeRationale To help local agencies develop data for needs assessments More requirements for serious long-term assessments and more focus in the local plan as the purpose for CSBG funds means more resources should go to community assessments 28 [STATE] USES OF FUNDS

29. [STATE] USUES OF FUNDS Proposed Change All training must have measured results. Future funding based on performance. 29

30. Proposed Change Guided by: a 3-year innovations and training and technical assistance plan, developed in consultation with the community service network organizations in the State 30 [STATE] USES OF FUNDS

31. Proposed ChangeRationale 20% of the State discretionary fund is set aside for states to fund CAAs innovative projects. CAAs need flexible funding to create and adapt innovative approaches. 31 [STATE] USES OF FUNDS

32. Rationale Need predictability about funding availability, and Common understanding about what equals useful training 32 [STATE] USES OF FUNDS

33. Proposed ChangeRationale The bill will repeal the charity tax credit provisions of 1998 reauthorization. Allows CSBG funds to offset State revenue losses from state charity tax credit. This power has never been used as written in the current law. Change gives States more certainty. 33 [STATE] USES OF FUNDS

34. New Requirements: Good Management Proposed Change- Management Measures Each State shall adopt performance requirements that are measured by annual benchmarks. 34

35. New Requirements: Good Management Proposed Change- Management Measures Cont. These are about the State Office: Timely $$$ distribution Effective management of Federal Funds Compliance with the requirements for State personnel State monitoring of CSBG activities; and Annual public reports. 35

36. Current Law ‘‘(1) DESIGNATION.— Governor designates… an appropriate State agency…to act as a lead agency for … carrying out State activities … STRONGER STATE AGENCY 36

37. Proposed Changes Must have Authority: 1)to convene all state programs that deliver services through CAAs 2)to ensure greater coordination 37 STRONGER STATE OFFICE

38. [STATE] APPLICATION AND PLAN Proposed Change Create separate bill sections defining State responsibility and Local program responsibility. 38

39. [STATE] APPLICATION AND PLAN Rationale Only descriptions of CAA uses of CSBG = State Plan Assurances. Our framework makes CAA’s the “deciders” on priorities. 39

40. Proposed ChangeRationale States shall not reject CAA plans which meet the requirements of this Act. Uniqueness of Community Action is that local community’s leaders decide how to best use the funds to get maximum impact. 40 [STATE] APPLICATION AND PLAN

41. Rationale CSBG uses be driven by CAA decisions- but the decisions must be based on a serious needs assessment and planning process. Boards have more responsibility. 41 [STATE] APPLICATION AND PLAN

42. Current Law ‘‘(2) DUTIES.—The lead agency shall— ‘‘(A) develop the State plan to be submitted to the Secretary; ‘‘(B) hold at least one hearing in the State with sufficient time and statewide distribution of notice ‘‘(C) conduct reviews of eligible entities under section 678B. … [STATE] APPLICATION AND PLAN 42

43. [STATE] APPLICATION AND PLAN Current Law Draft State Plan circulates to CAA’s 30 days before public hearing on the record. 43

44. Current Law The plan submitted to HHS 45 days prior to the beginning of the FFY. [STATE] APPLICATION AND PLAN 44

45. [STATE] APPLICATION AND PLAN Proposed ChangeRationale Due to HHS 30 days before FFY There were 30 days to work on it, at least in public. 45

46. Proposed ChangeRationale Keeps Service Categories Coordination, multiple services, Our: specific “programs” where they occur like “TANF”, “WIA”, “Fatherhood,” “LIHEAP,” or subgroups like “at-risk youth.” Current law is packed with categorical programs and populations to ‘address.’ CAAs must determine the right partners, resources and areas of focus. 46 CLEAN UP CAA PROGRAM

47. Proposed Change- New Legislation CAA program may include service to individuals and families and activities to increase economic opportunities. Why? Clarify CAAs ≠ Social Services only. 47 COMMUNITY ACTION PROGRAM PLAN

48. Proposed Change- New Legislation ‘‘(i) activities that increase employment, including activities in which eligible entities maintain partnerships; ‘‘(ii) activities that establish linkages among organizations to maximize use of community resources; ‘‘(iii) activities that mobilize new investments in reducing poverty. 48 COMMUNITY ACTION PROGRAM PLAN

49. Proposed ChangeRationale Measurement results must (also) measure performance in meeting one-year “benchmarks” outlined in Community action & State Plans. CAAs report 100’s of agency program results. Need to have information on reaching planned targets, operational quality, and organizational assessment. 49 [STATE] APPLICATION AND PLAN

50. Current Law (cont’d) ‘‘(c) FUNDING TERMINATION OR REDUCTIONS.— ‘‘(1) a funding reduction, the term ‘cause’ includes— ‘‘(A) a statewide redistribution of funds (NO CHANGE) ‘‘(B) the failure of an eligible entity to comply SEE CORRECTIVE ACTION SLIDES AT END. APPLICATION AND PLAN 50

51. Proposed Change Public CAA is not an option as a replacement. Options are: 1.) Another private CAA nearby, or 2.) A Private Non-Profit in the area with a Tripartite Board. 51 DESIGNATION AND REDESIGNATION

52. Rationale Citizen control of CSBG is not assured under Public CAA governance. CSBG loses its character. 52 DESIGNATION AND REDESIGNATION

53. Current Law ‘‘(a) PRIVATE NONPROFIT ENTITIES.— ‘‘(1) BOARD.—to be an eligible entity …..[the entity] shall administer the CSBG program through a Tripartite board … that fully participates in the development, planning, implementation, & evaluation of the program to serve low income communities‘‘ … TRIPARTITE BOARDS 53

54. Current Law (cont’d) ‘‘(2) SELECTION AND COMPOSITION OF BOARD.— ‘‘(A) 1⁄3 = elected public officials, ‘‘(B) 1⁄3, or more, of the members are representative of low-income individuals and families in the neighborhood served; and ‘‘(C) the remainder = members of business, industry, labor, religious, law, education, or other major groups and interests in the community served. TRIPARTITE BOARDS 56

55. Proposed Changes- New Legislation Board of Directors will: Participate in the development, planning, implementation, oversight, and evaluation of the program. Why? Make it clear that Boards will work and Ask Questions. 55 TRIPARTITE BOARDS

56. Proposed Changes- New Legislation Specific Board duties: Legal and financial responsibility, Establish term limits for officers, Adopt code of ethics, Participate in community needs assessments and plan, Evaluate the performance of CAAs 56 CAA TRIPARTITE BOARDS

57. Proposed Changes-New Legislation Specific duties (con’t): Ensure compliance with ALL laws Adopt financial management policies and budget Review all policies and documents including personnel policies Adopt conflict of interest policies Evaluate ED annually. 57 CAA TRIPARTITE BOARDS

58. Current Law (b) PUBLIC ORGANIZATIONS. In order for a public organization to be considered to be an eligible entity for purposes of section 673(1), the entity shall administer the CSBG program through— ‘‘(1) a tripartite board, not fewer than 1⁄3 of the members [selected] are persons [whom]— ‘‘(A) represent low-income individuals; ‘‘(B) reside in the neighborhood served; and ‘‘(C) are able to participate actively; or ‘‘(2) another mechanism specified by the State PUBLIC ENTITIES 58

59. PUBLIC CAA Proposed Change Public CAA Board Composition: Only 1/3 rd can be employees of the public agency Other 2/3rds described exactly like CAA (low-income, private sector). 59

60. Proposed ChangesRationale Change authority of Boards of public CAAs to final decision authority regarding CSBG needs, plan, & budget. Public CAA’s need to be as accountable to the Community as Private CAA’s with respect to CSBG money. 60 PUBLIC CAA

61. Current Law ‘‘(a) OFFICE.—The Secretary shall carry out the functions … through an Office of Community Services, … established in the Department of Health and Human Services. ‘‘(b) GRANTS, CONTRACTS, AND COOPERATIVE AGREEMENTS.— The Secretary shall carry out functions of this subtitle through grants, contracts, or cooperative agreements. OFFICE OF COMMUNITY SERVICES 61

62. Proposed ChangeRationale HHS develops agency-wide coordination of all programs that reduce poverty by fund CSNOs to monitor together. This changes implements OMB directives; responds to GAO recommendations and makes government efficient. 62 OFFICE OF COMMUNITY SERVICES

63. Proposed Change- New Legislation OCS Sets: knowledge, skills, and abilities required provide technical assistance monitor ensure State & Fed Staff quality acquire knowledge, skills, and abilities 63 STATE AND FEDERAL PERFORMANCE: PROFESSIONALIZATION

64. Rationale This ensures qualified persons oversee CSBG, leading to better outcomes. 64 OFFICE OF COMMUNITY SERVICES

65. Proposed Change- New Legislation New Federal/OCS Performance Targets for: Timeliness of CSBG funds Plan approvals or revisions Definition/oversight state corrective action Coordinate HHS monitoring Implement uniform Admin rule 65 PERFORMANCE BY ALL ‘LEVELS’

66. Proposed Changes New Standardized Monitoring Process: per federal guidance. Implement new uniform grant management & financial rules Include Corrective Action 66 STATE MONITORING OF LOCAL AGENCIES

67. Rationale Need for standard requirement benchmarks at the level of detail that monitors review. CAAs must know what is expected. 67 STATE MONITORING OF LOCAL AGENCIES

68. PROBLEM STATES/ PROBLEM AGENCIES Proposed Changes The following are all intended to set process for improvement first, but end the attempts when they fail. 68

69. Current Law The State shall— ‘‘(1) inform the entity ‘‘(2) require the entity to correct the deficiency; ‘‘(3)(A) offer training and technical assistance, or (B) submit to the Secretary a report … CORRECTIVE ACTION PLANS & TERMINATION 69

70. Current Law (cont’d) at the discretion of the State, within 60 days, a quality improvement plan to correct such deficiency within a reasonable period of time, after providing adequate notice, initiate proceedings to terminate or reduce funding … CORRECTIVE ACTION PLANS & TERMINATION 70

71. Proposed Changes If serious deficiency threatens federal funds- may require immediate action, otherwise states require a corrective action plan with timetable: at least 90 days to implement, State must offer T/TA If entity fails, state may defund; Reviewable, on appeal, to Secretary. 71 NEW TIME TABLE

72. Rationale Administration says CSBG supports weak agencies because it’s “too hard” to defund a CAA. This assures a competent effort is made to strengthen weak CAAs but, ensures process is finite. 72 TERMINATION & REDUCTION OF FUNDING

73. Current Law (cont’d) IN GENERAL.—The Secretary shall withhold funds from any State that does not utilize the grant or allotment FED’S OVERSIGHT OF STATES 73

74. Proposed Changes OCS authority to develop state Corrective Action Plans requests Penalty: states can lose admin funding if changes are not implemented. 74 FED’S OVERSIGHT OF STATES

75. Rationale OCS has little oversight power New penalty hurts state office but not the poor. Credible threat. 75 FED’S OVERSIGHT OF STATES

76. Proposed Change Discretionary programs (Rural Economic Development & Community Economic Development) are authorized separately. No longer a % of CSBG. 76 OTHER UPDATES: DISCRETIONARY PROGRAMS

77. Rationale Authorizing these programs separately institutionalizes current practice. Congress has specified line-item appropriations for each provision, will make CSBG formula for states more stable. 77 OTHER UPDATES: DISCRETIONARY PROGRAMS