Organizational Standards 7-9

Organizational Standards 7-9
By Joey Samudio

Purpose To provide clarity around the organizational standards
To provide information and assistance on the organizational standards self- assessment packet

Definitions Private CSBG-Eligible Entity: Nonprofit 501(c)(3) organizations serving local communities that are eligible to receive Community Services Block Grant funding. These nonprofit entities are governed by a tripartite board of directors. Run operationally by an Executive director or CEO [Public CSBG Eligible Entity]: [Units of local governmental entities, such as a county or city government, eligible to receive Community Services Block Grant Funding. Many “Public CEEs” operate programs directly out of the government/ municipal department while others subcontract to nonprofits in their communities to provide services. They are advised by a tripartite board/ advisory board.] From here on out these will be referred to as CEEs

Format Section A: Definition and intent
Section B: Compliance and Documentation Section C: Questions and Resources

Operations and Accountability: Human Resource Management
Category 7 Operations and Accountability: Human Resource Management

STANDARD 7.1, 7.2, &7.7 HR Policies and PROCEDURES
Standard 7.1 Private / [Public]: The organization has written personnel policies that have been reviewed by an attorney and approved by the governing board within the past 5 years. [Not Applicable] Standard 7.2 Private / [Public]: The organization makes [department follows local governmental policies in making] available the employee handbook (or personnel policies in cases without a handbook) to all staff and notifies staff of any changes. Standard 7.7 Private / [Public]: The organization has a whistleblower policy that has been approved by the governing board. [The department provides a copy of any existing local government whistleblower policy to members of the tripartite board/advisory body at the time of orientation.]

STANDARD 7.1, 7.2, & 7.7 A. Definition and Intent
Definition and Intent of 7.1, 7.2 & 7.7: These Standards refer to what are often called HR Policy and Procedure Manuals, Personnel Policies, and Employee Handbooks. All of these fall under the definition of communication tools hat help managers and staff understand what is expected of them. The intent behind standards 7.1, 7.2 & 7.7 come from 3 primary sources, Department of Labor (DOL), Office of Management and Budget (OMB), and The Society for Human Resource Management. 7.1: The intent of this Standard is to ensure uniformity across states for the maximum time period between Personnel Policy updates and approvals. Previously each State determined the monitoring and compliance requirements for HR-related policies 7.2: The intent of this Standard is to promote effective and consistent communication of employee-relevant information to staff, to help ensure HR compliance and performance. 7.7: The intent of this Standard is to ensure that agencies are in compliance with federal law, and that they protect employees at all levels from retaliation in cases where individuals act to protect the organization and community from illegal or unethical activities.

Standard 7.1, 7.2, & 7.7 B. Compliance and Documentation
7.1: Organization has an attorney review policies Organization has personnel policies Organization reviews policies within specified timeframe 7.1: Invoice from an attorney 7.2: Process map for staff notification 7.1 & 7.7: Board Meeting minutes, pre board packet Personnel policies/ employee handbook

Standard 7.1, 7.2, & 7.7 C. Questions and resources
Summary of DOL laws Toolkit, sample polices, & sample employee handbook A federal compliance membership site

STANDARD 7.4 & 7.5 Effective HR governance
Standard 7.4 Private / [Public]: The governing board conducts a performance appraisal of the CEO/executive director within each calendar year. [The department follows local government procedures for performance appraisal of the department head.] Standard 7.5 Private / [Public]:The governing board reviews and approves CEO/executive director compensation within every calendar year. [The compensation of the department head is made available according to local government procedure.]

STANDARD 7.4 & 7.5 A. Definition and Intent
Definition and Intent of 7.4 & 7.5: Building upon Organizational Standards Category 5, Board Governance, these Standards clarify the expectation of the governing board to provide appropriate HR oversight. Overseeing and maintaining a strong human resources infrastructure are key responsibilities of the board. One of the greatest risks to both private and public CEEs is unethical or fraudulent behavior between individuals with access and power, in most cases the governing body and executive director / CSBG Manager. Standard 7.4 and 7.5 are intended to provide a foundation for seated executives that help support the accountability and transparency goals of the CSBG Network. The intent behind requiring federally funded agencies to have the board appraise executive performance comes from two primary sources – the DOL Center on Executive Compensation, and the OMB’s Compensation-Personal Services regulations

Standard 7.4 & 7.5 B. Compliance and Documentation
Board has conducted a performance appraisal of executive director/ CSBG manager Board has reviewed and approved the executive director compensation Board meeting minutes Tools/ resources used to conduct performance review Tools/ resources used to review executive director salary

Standard 7.4 &7.5 C. Questions and resources
Executive compensation tools nonprofit-compensation-report Board executive director relationship

STANDARD 7.3, 7.6, & 7.8-7.9 Effective hr management
Standard 7.3 Private / [Public]: The organization [department] has written job descriptions for all positions, which have been updated within the past 5 years. [Updates may be outside of the purview of the department.] Standard 7.6 Private / [Public]: The organization has a policy in place for regular written evaluation of employees by their supervisors. [The department follows local governmental policies for regular written evaluation of employees by their supervisors.] Standard 7.8 Private / [Public]: All staff participate in a new employee orientation within 60 days of hire. [The department follows local governmental policies for new employee orientation.] Standard 7.9 Private / [Public]: The organization [department] conducts or makes available staff development/training (including ROMA) on an ongoing basis.

STANDARD 7.3, 7.6, & 7.8-7.9 A. Definition and Intent
Definition and Intent of 7.3, 7.6, & : These four Standards reflect the foundations of effective HR management and should be focal points for agencies in achieving basic compliance for effective and efficient administration of personnel functions. 7.3: The intent of this standard is to ensure direction and accountability for all staff through standardized and up-to-date job descriptions. 7.6: The intent of this standard is to ensure agency accountability for staff supervision and performance reviews through a written policy. 7.8: The intent of this standard is to ensure that organizations follow through on the investment in employees and avoid costly turnover by providing new hires with the information, training, and resources necessary to be successful in the culture and in their job roles. 7.9: The intent of this standard is to ensure that training and technical assistance (T&TA) is appropriately provided to staff to support the purpose and goals of CSBG in local programs.

Standard 7.3, 7.6, & 7.8-7.9 B. Compliance and Documentation
The organization has updated job descriptions for every position within timeframe The organization has a policy for supervisors to evaluate their employees New staff participates in an orientation Staff has opportunity to participate in training 7.3: Organizational Chart, job descriptions 7.6: a blank copy of your evaluation tool 7.8: Employee handbook/ orientation materials 7.9: Training plans, training registration, sign in sheets, conference materials, personnel files

Standard 7.3, 7.6, 7.8-7.9 C. Questions and resources
No additional resources

Operations and Accountability: Financial Operations and Oversight
Category 8 Operations and Accountability: Financial Operations and Oversight

STANDARD 8.1 A. Definition and Intent
Standard 8.1 Private / [Public]: The Organization’s annual audit (or audited financial statements) is completed by a Certified Public Accountant on time in [department’s annual audit is completed through the local governmental process] accordance with Title 2 of the Code of Federal Regulations, Uniform Administration Requirements, Cost Principles, and Audit Requirement (if applicable) and/or State audit threshold requirements. [This may be included in the municipal entity’s full audit.] Definition and Intent of 8.1: CEEs are required to have a Single Audit. This differs from a financial statement audit in that additional procedures are conducted to assess the entity’s use of internal controls and its adherence to compliance with laws, regulations and specific grant or contract requirements.

Standard 8.1 B. Compliance and Documentation
The single audit is conducted by a CPA The audit is conducted utilizing the proper requirements The audit is conducted within the proper time frame. A copy of the audit report and related information An electronic “receipt” from the Federal Clearinghouse showing the date the audit report was submitted A letter or from a state agency acknowledging receipt of the audit

Standard 8.1 C. Questions and resources
Electronic CFR idx?SID=0d9415f781ec5b75b44308ee5b21b67e&mc=true&tpl=/ecfrbrowse/Title0 2/2chapterII.tpl Webinar: Audit Essentials: What Every Board Needs to Know CAA Leaders Guide

Standard 8.2 Private / [Public]: All findings from the prior year’s annual audit have been assessed by the organization and addressed where the governing board has deemed it appropriate. [The department follows local government procedures in addressing any audit findings related to CSBG funding.] Definition and Intent of 8.2: The conduct of the audit and receipt of the related audit report is the first step in the accountability cycle of a CEE. When the audit is complete, the board should receive the audit report and management should provide any plans necessary to address any findings noted in the audit. The Department of Health and Human Service’s Grants Policy Statement states very clearly “Recipients must follow a systematic method for ensuring timely and appropriate resolution of audit findings and recommendations, whether discovered as a result of a Federal audit or a recipient-initiated audit. Failure to submit timely responses may result in cost disallowance or other actions by HHS.”

the corrective action plan is submitted to the correct organization to ensure that the deficiency can be appropriately cleared. The board has reviewed audit to identify areas where a corrective action plan is needed. A copy of all corrective action plans Board meeting minutes documenting review of the audit and acceptance of a corrective action plan

All relevant resources for this standard have already been listed

Standard 8.3 Private / [Public]: The organization’s auditor presents the audit to the governing board. [The department’s tripartite board/advisory body is notified of the availability of the local government audit.] Definition and Intent of 8.3: The importance of the auditor reporting directly to the board cannot be overstated. As the board is ultimately responsible for the performance of the organization, they have a fiduciary responsibility to ensure their role in financial oversight of the organization is fulfilled. This transparency in the audit process means there is no room for misinterpretation of what the auditor said or meant. By requiring the auditor to report to the board at the conclusion of the audit, the board is made aware of any issues that it will need to pursue and ensure these issues are remedied.

The auditor must present the audit to the governing body Must take place with full governing body not just a committee Board meeting minutes Pre-meeting materials/ pre-meeting packet A copy of the report

Standard 8.4 Private / [Public]:The governing board formally receives and accepts the audit. [The department’s tripartite board/advisory body is notified of any findings related to CSBG funding.] Definition and Intent of 8.4: The Board serves an important role to ensure the adequacy of the financial stewardship of the organization. This is exemplified through the audit process, which serves as an outside validation of the financial reporting, internal control and compliance of the organization.

The board must receive and accept the audit Board minutes Communication from the board to the audit agency confirming it has received and accepted the audit

Standard 8.5 Private / [Public]: The organization has solicited bids for its audit within the past 5 years. [Not Applicable] Definition and Intent of 8.5: The board has the relationship with the auditor and accordingly is responsible for selection of the auditor. Instead of contracting with last year’s auditor automatically, the board should determine how long the current auditor has been conducting the audit. If the auditor has been providing audit services for five years or more since a procurement of the services was last conducted, a new procurement process should be initiated. The purpose of this process is to ensure that the auditor still possesses the unique qualifications and skills to conduct this particular type of engagement – a single audit.

An official bid solicitation process must happen at least every 5 years Simply asking the current auditor to provide a price quotation for the audit would not qualify as soliciting the audit. Asking a single provider to bid for services would not meet the intent of Federal requirements A copy of the request for proposals (RFP) Responses from all replying CPAs/ Firms Scoring grid/ evaluation used to review bids

Audit Practice etoolsaids/pages/default.aspx Sample request for proposal

Standard 8.6 Private / [Public]: The IRS Form 990 is completed annually and made available to the governing board for review. [Not Applicable] Definition and Intent of 8.6: In addition to the year-end audit, an information tax return must also be prepared as part of the conclusion of an agency’s fiscal year. Part of the social contract an agency has with the public is that it will be exempt from paying income taxes as long as it continues to adhere to its approved tax exempt purpose. Unlike a typical tax return, the form 990 has a focus on accountability and governance of the non-profit organization

The 990 form is submitted annually to the IRS The whole governing body reviews the form Board meeting minutes Pre-board packet A copy of the 990

990 Form 990 Instructions GuideStar

Standard 8.7 Private / [Public]: The governing board receives financial reports at each regular meeting that include the following: 1. Organization-wide report on revenue and expenditures that compares budget to actual, categorized by program; and 2. Balance sheet/statement of financial position. [The tripartite board/advisory body receives financial reports at each regular meeting, for those program(s) the body advises, as allowed by local government procedure.] Definition and Intent of 8.7:The governing board should be involved in monitoring the financial stability and use of financial resources on an on-going basis. At a minimum, the Board should receive two reports – budget versus actual for revenues and expenditures and the balance sheet or statement of financial position.

The standard is very clear that both reports must be received for each regular meeting. In order to be in compliance, these have to be given at regular board meetings, as defined by your bylaws. Board meeting minutes Pre-meeting board packet The actual report

“Must Have” Financial webinar Fiscal fundamentals for executive directors _fundamentals_for_executive_directors.pdf

Standard 8.8 Private / [Public]: All required filings and payments related to payroll withholdings are completed on time. [Not applicable] Definition and Intent of 8.8:All CEEs employ personnel to carry out the programs and activities they are charged to deliver. Accordingly, this means that agencies have a requirement to comply with the employment laws of the United States and the further state requirements.

All required filings and payments are submitted on time Payroll tax returns Copies of checks or bank statements documenting payment Retirement plan documentation as required by law Health plan documentation as required by law

IRS Form 941 IRS Form 940 W-2 & W-4

Standard 8.9 Private / [Public]: The governing board annually approves an organization-wide budget. [The tripartite board/advisory body has input as allowed by local governmental procedure into the CSBG budget process.] Definition and Intent of 8.9: All grants have a budget in order to be funded. However, the art of preparing an agency-wide budget is not quite as simple as adding the results of all grants together and calling it an agency-wide budget. This agency-wide approach also provides management, the board, and funders the ability to see the full cost of the programs offered.

The whole board needs to review and approve the budget The budget that is reviewed must be an agency wide budget, not a bunch of individual programs A copy of the agency wide budget Board meeting minutes documenting agency wide budget approval

Agency wide budget webinar cb43224a4e787c03bb3683d1fb7dd486

Standard 8.10 Private / [Public]:The fiscal policies have been reviewed by staff within the past 2 years, updated as necessary, with changes approved by the governing board. [Not Applicable] Definition and Intent of 8.10: This Standard requires that an agency has adequate policies and procedures in place to appropriately administer the fiscal side of running an organization. The Standard requires that there are appropriate oversight processes in place for the process of keeping policies and procedures current and up to date.

Policies must be reviewed within timeframe Any changes must be approved by the governing body A copy of fiscal policies Board meeting minutes when any changes are approved

Sample Policies

Standard 8.11 Private / [Public]: A written procurement policy is in place and has been reviewed by the governing board within the past 5 years. [Not applicable] Definition and Intent of 8.11: The procurement policy is the guidance provided to all internal staff of an agency on the appropriate procedures to follow in securing goods and services. As a user of public resources, CEEs have a responsibility to acquire goods and services at a reasonable price in a transparent manner. Good procurement polices do not require an agency to purchase the lowest cost goods or services. A prudent procurement policy balances securing a fair and reasonable price for a quality good or service that allows the agency to deliver its mission at the expected level of quality

Agency has a procurement policy, many CEEs include the procurement policy as a fiscal policy Nothing in the standard requires a “standalone” procurement policy The procurement policy has been reviewed within the timeframe The procurement policy needs to meet federal and state requirements, when conflicting must go with stricter of the two A copy of the procurement policy Board meeting minutes documenting review of procurement policy

Sample Procurement Policy ent_ModelProcurementPolicy.pdf

Standard 8.12 Private / [Public]: The organization documents how it allocates shared costs through an indirect cost rate or through a written cost allocation plan.[Not applicable] Definition and Intent of 8.12: Indirect costs are those costs that benefit most or all of the programs of an agency. Federal grants can only be charged expenses to the extent that the program benefits, however indirect costs benefit all or most of the programs so they rightfully deserve some amount of charge for these agency-wide functions. Organizations have three options for handling these indirect costs: Cost Allocation, De Minimus Indirect, and Indirect Cost Rate.

Agency must have a cost allocation plan in place Cost allocation method is in compliance with the federal regulations If a negotiated Federal cost rate is selected, the entity should have an approval letter from cognizant agency responsible If cost allocation is used, the entity should have an updated cost allocation policy document laying out the methodology If your agency is using the de minimus indirect cost rate, this should be indicated on the grant forms

CAPLaw Operations.html

Standard 8.13 Private / [Public]: The organization has a written policy in place for record retention and destruction. [The department follows local governmental policies for document retention and destruction.] Definition and Intent of 8.13: The Organizational Standards require an entity to have a written policy in place for the retention and destruction of records. An entity produces a large amount of information and correspondence in a given year. There is a cost to retain such records, so it is prudent to have a policy in place that requires a minimum and maximum amount of time that records must be maintained. The IRS Form 990 asks “Did the organization have a written document retention and destruction policy?”

Agency must have a policy in place The policy includes retention and destruction of records The policy meets federal requirements A copy of the policy

Sample Record Retention Policy rdRetentionPolicy.pdf

Operations and Accountability: Data and Analysis
Category 9 Operations and Accountability: Data and Analysis

Standard 9.1 Private / [Public]: The organization [department] has a system or systems in place to track and report client demographics and services customers receive. Definition and Intent of 9.1: The intention of this Standard, in collaboration with the Information Systems (IS) report, is to ensure that the agency reports the demographic information of those they are serving, and what strategies/services are utilized. The organization may or may not have a single organization-wide data system in place. The key for this standard is to have a larger organizational policy or established system of procedures for tracking and reporting both client demographics and client services

Agency has a system to track client demographics as well as services provided Agency utilizes system to track required data Client or customer is clearly defined throughout the agency Forms used to collect data Screen shots of data collection program Data collection policy Copy of section G of the IS report

Instructions for the IS Report ona-g_instructions_nascsp_2014.pdf Lexicon for IS Report on_nascsp_2014.pdf

Standard 9.2 Private / [Public]: The organization [department] has a system or systems in place to track family, agency, and/or community outcomes. Definition and Intent of 9.2: The intention of this standard is to ensure that agencies are in alignment with the six CSBG national goals, and measuring the outcomes of their work at the family, agency, and/or community level. It is important to note the distinction between organizational outputs and outcomes, namely that outcomes speak to changes. Thus the standard requires identifying the changes among individuals or family groups.

Agency has system in place to track family, agency and community level goals. Agency utilizes system to track required data Forms used to collect data Screen shots of data collection program Data collection policy

Toolkit: Measuring Client Well-being for county and community-based organizations id=846&Itemid=17 Performance Improvement and Outcomes Monitoring

Standard 9.3 Private / [Public]: The organization [department] has presented to the governing board [tripartite board/ advisory body] for review or action, at least within the past 12 months, an analysis of the agency’s outcomes and any operational or strategic program adjustments and improvements identified as necessary. Definition and Intent of 9.3: This standard establishes that the agency is analyzing its own data for the purpose of making suggestions for improvement. It also ensures that the agency’s board is involved in making meaningful decisions about agency performance based on accurate and well analyzed data.

Board members are presented and involved in determining agency outcomes The organization documents that it conducted an analysis and had board level discussions about outcomes Copy of report/ analysis given to the board Pre-meeting board packet Board meeting minutes

Standard 9.4 Private / [Public]: The organization [department] submits its annual CSBG Information Survey data report and it reflects client demographics and organization-wide outcomes. Definition and Intent of 9.4: The intent of 9.4 is that accurate and timely reports are produced. Specifically, that each agency has submitted accurate and appropriate data for the CSBG Information Systems (IS) Data Report to the State CSBG office.

The IS report is submitted on time and with the correct information Copy of the IS report from State CSBG Office documenting receipt

Additional resources Community Action Partnership
d=96&Itemid=291 CAPLAW rdsHome.html National Association of State Community Service Programs IM 138 standards-fy-2015.pdf

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Organizational Standards 7-9

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