Community Services Block Grant Subrecipient Guide

What is CSBG?
The Community Services Block Grant (CSBG) is a federally funded block grant in the Office of Community Services, Administration for Children and Families, United States Department of Health and Human Services that provides funds to states, territories, and tribes to administer to support services that alleviate the causes and conditions of poverty in under resourced communities. Tribes, territories, and over 1,000 local eligible entities provide CSBG funded services and activities including housing, nutrition, utility, and transportation assistance; employment, education, and other income and asset building services; crisis and emergency services; and community asset building initiatives, among other things. Over 9 million individuals are served by CSBG-funded programs annually.

Eligible Applicants:
States, the District of Columbia, the Commonwealth of Puerto Rico, U.S. territories (America Samoa, Guam, Northern Mariana Islands, and Virgin Islands), and federally recognized tribes and tribal organizations.

Target Population:
Individuals and families with income levels at or below 125% Federal Poverty guidelines.

Uses:
Block Grants — States receive funds according to a statutory formula. In turn, states fund a network of local eligible entities with 90 percent of their CSBG grant award. These local eligible entities include, but are not limited to, local governments, migrant and seasonal farm worker organizations, tribes and tribal organizations, and Community Action Agencies (CAAs). The local entities provide services and activities addressing employment, education, income & asset building services, housing, nutrition, emergency services, and/or healthcare based on community needs assessments conducted by the County.

COLORADO:
The Colorado Department of Local Affairs (DOLA) is the pass-through entity for the federal CSBG with the U.S. Department of Health and Human Services, Administration for Children and Families, Office of Community Services. It has 32 eligible local entities working under nine Community Services Block Grant federal objectives including housing, nutrition, utility, and transportation assistance; employment, education, and other income and asset building services; crisis and emergency services; and community asset building initiatives.

ADAMS COUNTY:
Adams County receives an estimated amount of $515,000. Currently, Adams County utilizes the funds between program staff, training/technical assistance, and subrecipients.

APPLICATION PROCESS
Please review the entire guide before starting your application to ensure that your organization meets the eligible criteria and the purposes of the CSBG program (See Exhibit 1).

Organizational Eligibility:
CSBG funds are allocated to non-profit organizations who serve Adams County residents with annual incomes at or below 125 % of the Federal Poverty Guidelines.

Please apply if your organization is:

• Fiscally sound, compliant with 2 CFR Part 200
• Serves Adams County residents with 125% or below poverty of the Federal Poverty Guidelines
• Verify and document income and Adams County residence
• Track the following demographics: applicant gender, date of birth, disability status, health insurance status, education level (for household members whose age is equal to or greater than 24), family size, income and income types (source) for all household earners. THESE ARE FEDERALLY REQUIRED DEMOGRAPHICS THAT MUST BE TRACKED.
• Administrative capacity to track client demographics and services provided, submit reports, invoices and supporting documentation in a timely manner
• Providing services within these CSBG Federal Objectives:
  • Employment
  • Education and Cognitive Development
  • Income, Infrastructure, and Asset Building
  • Housing
  • Health and Social/Behavioral Development (includes Nutrition)
  • Case Management
  • Other (e.g. emergency management/disaster relief)

NOTE: Priority will be given to programs that assist individuals with low income around needs identified in the Needs Assessment.

Documentation Required with Application:

• Proof of being a Colorado Corporation in good standing
• Proof of 501(c) (3) tax-exempt status from the Internal Revenue Service (IRS)
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• Certificate of Insurance
• Most recently audited financial statements, include Single Audit if applicable
• Board of Directors Information (Occupations and/or Community Affiliations)
• Names and Qualifications of Key Staff
• Final Certification Form
• Client Intake and Client Income Verification Policies and Procedures
• Grievance Policies
• Financial Policies and Procedures
• Documentation Policies and Procedures
  • NOTE: Financial records, supporting documents, statistical records and all other records, in whatever format pertinent to a CSBG grant award are covered by these retention requirements: Records must be retained for a minimum of five (5) years, or longer if required by law.

Application Criteria:
Criteria to be used by Adams County Community Services Block Grant (CSBG) staff and CSBG Advisory Council when reviewing and recommending applicants to Adams County Board of County Commissioners (BOCC) for final approval will be the following:

• Compliance (submitted on time, completed application, fits grant criteria)
• Relationship to county goals and providing services around county’s needs
• Performance Measures
• Organizational Capacity
• Budget (clear explanation on application)

AGREEMENTS
Once subrecipients awards are approved by the BOCC, CSBG Staff send agreements to subrecipients for review and signature. Please review the entire agreements by all staff involved with the CSBG program at your agency before signing to ensure ability to remain compliant. The agreements are then presented at public hearing and signed by BOCC Chair. They are then sent to subrecipients by email.

CSBG eligible subrecipients are expected to maintain files (electronic or physical) on clients served by the CSBG program to confirm client eligibility and review use of funds in monitoring visits or upon request. Files are only required for clients who receive support through CSBG funds.

Client intake documents must solicit, at a minimum, the following information:

• Date of application for support
• Applicant name and address
• Applicant gender, date of birth/age, disability status, health insurance status, education level (for household members whose age is equal to or greater than 24), family size, income and income types (source) for all household earners
• Applicant signature
• Income verification documents
• Name and title of the person performing the intake

The demographic and service outcome data will be requested at end of year for all CSBG participants served.

A record of service provision must be included in the applicant/participant files of each eligible applicant/participant. The record must include the initial date of service and the services provided, as well as the date and services provided for on-going or repeated services. Records of service provision may be maintained electronically if the agency is able to maintain separate records on each program participant.

Client Income Eligibility Verification

Each eligible entity is responsible for establishing, documenting, and adhering to its own income qualification policies and procedures which include how income is calculated, how long clients’ qualifications apply, policies regarding recertification if applicable.

Client files must contain copies of documents used to certify income along with the staff calculation used to determine eligibility. If such documentation is not included, the file must contain a statement detailing the documents reviewed and how the household income was calculated. In the case of applicants reporting zero income, the file must contain a written explanation of why there is no income. A staff member must sign off on the income evaluation.

In determining household income, self-declaration of income must be used only as a method of last resort. If this method is used, notation must be on file stating the reason(s) why other verification methods could not be used. The signature of the applicant must appear on the self-declaration statement. A staff member must sign off on the self-declaration.

Per the CSBG Act, CSBG program eligibility is limited to individuals who earn an annual household income at or below 125% Federal Poverty Level, which is released by the U.S. Department of Health and Human Services annually as published in the Federal Register. The guidelines are calculated on a sliding scale based on the number of people in a client’s family. Unique situations, such as the CARES Act, may change the FPL for eligibility. Eligible entities and subrecipients are to comply with the most up-to-date legislation pertaining to this requirement.

The most current Federal Poverty Guideline published annually by the US Department of Health and Human Services in the Federal Register, typically in January, is the sole and only acceptable method of establishing financial eligibility.

Household Size

Eligible entities must determine how they define a household for the purpose of administering the local CSBG program and evaluating eligibility. In general, DOLA defines a household as an individual or group of individuals who are living together in a dwelling unit as one economic unit. Children receiving foster care services are allowed to represent a household of one for the purpose of eligibility determination.

Household Income

CSBG staff must verify income as established by the eligible entity within the program policies and procedures.

• In general, household income includes gross (pre-tax) income from employment, net income if self-employed, public assistance cash benefits, alimony, child support, net rental income, gaming or lottery winnings, SSI, interest, and taxable income. It is calculated without consideration of taxes paid or anticipated.
• Household income does not include capital gains; any assets drawn down as withdrawals from a bank, the sale of property, a house or a car, or tax refunds, gifts, 8 loans, lump sum inheritances, one-time insurance payments, or compensation for injury. Also excluded are non-cash benefits, such as the employer-paid or union-paid portion of health insurance or other employee fringe benefits; food or housing received in lieu of wages; the value of food and fuel produced and consumed on farms; the imputed value of rent from owner-occupied non-farm or farm housing; and such Federal non-cash benefit programs as Medicare, Medicaid, food stamps, school lunches, and housing assistance, and certain disability payments made to disabled children of Vietnam veterans as prescribed by the Secretary of Veterans Affairs.

Invoices will be due the 10th of the month. If the 10th falls during weekend, please submit the Monday after. Please ensure all forms are completed timely, accurately and demonstrate all formulas, percentages, indirect cost rate, in all monthly invoices. Each invoice must also include supporting documentation of all expenses. The Subgrantee Expense Summary Sheet must contain all formulas and methods the agency came up with the expense amounts.

Please note: Do not include program or client information in monthly submissions. This includes items such as copies of intake forms, affidavits of legal residency, letters from landlords/utility companies/medical providers or other client-specific forms. These forms should be retained in client files and be available for review if there are questions about client or expense eligibility. See HHS Privacy Act for additional details.

All subrecipients are required to track the following demographics: applicant gender, date of birth, disability status, health insurance status, education level (for household members whose age is equal to or greater than 24), family size, income and income types (source) for all household earners. THESE ARE FEDERALLY REQUIRED DEMOGRAPHICS THAT MUST BE TRACKED.

The ability for Adams County to work with subrecipients in each community allows for specific needs to be supported directly and through localized support via subrecipients already familiar with the community’s needs.

Per Federal guidelines CSBG-eligible entities/counties must monitor subrecipients annually around client income eligibility and programmatic and financial documentation. Subrecipients, at a minimum, should maintain client files that mirror the requirements for the eligible entities as detailed in the “Client Intake” section.