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CSBG Policies and Procedures • States Communicate Expectations in a Number of Ways • State Plan • State Law • Contracts • Directives/Guidelines • Memorandums • Manual – Policy or Policy and Procedures
What’s the Value? • Helps the State & Subrecipients • By Establishing & Concisely Communicating Expectations • What the State Expects of Subrecipients • What Subrecipients Can Expect of the State • Comply w/Enabling Legislation • Comply w/State Requirements • Elaborates on Contract Language • Saves Time
What’s the Value? • Helps the State & Subrecipients • Ensures Continuity in the State’s Implementation • Provides an Explanation of How CSBG is Implemented in Kansas • A-133 Audits • OCS & Other Federal Reviews
Policy Manual for the Kansas CSBG ● CSBG Legislation • OMB Circulars • Information Memoranda • CSBG Terms & Conditions • Shared Information (Colleagues & NASCSP) • As a Discussion Point or a Policy • The Kansas Experience
Policy Manual for the Kansas CSBG • Sections • Topic Areas • Requirement and/or Discussion Section 4 – Grant Administration 4100 Monitoring 4101 Monitoring is an on-going process and is not limited to the periodic “on-site monitoring visit.” The on- going process includes review of . . .. 4102 On-site monitoring may occur at anytime and without notice. . . .
Policy Manual for the Kansas CSBG • Expectations Beyond the Federal Requirements • ED Performance Appraisals • Planning Calendar • Community Needs Assessment Contents • Strategic Plan • Professional Development for Key Staff • On-Going Board Training
A Living Document • Updated About Every 3 Years • Align w/Practice • Sync w/Requirements • Respond to the Current Environment • In Consultation w/the Network • Bound Copies to Each Eligible Entity • Web-Posted
A Relevant Document • It Is Referenced • Notice/Agreement (Contract) • Order of Precedence • Worksheet for On-Site Review • Reports of On-Site Review (Monitoring) • When Responding to Questions (TA) • Encouraged Read – Prof. Devlp. Plans (Policy 10010) • It Is Followed • State Practice Syncs w/the Manual
Order of Precedence – Kansas 1. CSBG Enabling Legislation 2. OMB Circulars, as Applicable 3. Kansas Form D-146a 4. The Notice of Financial Award and Grant Agreement 5. The Kansas Policy Manual for the Community Services Block Grant
Compliance Matter 5.1 Evidence of an annual performance appraisal of the Executive Director was not identified within personnel files. Kansas CSBG Policy 6204 states, “The governing board of each private, non-profit eligible entity shall undertake an annual performance evaluation of the entity’s executive director. This evaluation shall include a statement of outcomes for which the executive is responsible and shall provide a progress statement relative to the achievement of those outcomes. Dated evidence of the evaluation shall be contained within the executive director’s personnel file.” Compliance Matter 5.2 Policy 10006 requires eligible entities to “maintain an employee-signed and dated job description indicating current tasks for which the employee is held accountable.” No such job description was observed for the agency’s Executive Director.
“Eight (8) items within the report are identified as Compliance Matters. “Please prepare and submit a quality improvement plan addressing each item. The plan is to be provided in a table format with, at minimum, the following column headers.”
NASCSP Issue Brief: State CSBG Office Policies and Procedures http://nascsp.org/data/files/csbg_publications/issue_briefs/policies_and_procedures_10-27_final.pdf NASCSP a CSBG a CSBG Issues Briefs Policy Manual for the Kansas CSBG www.kshousingcorp.org KHRC a Special Needs a Community Services a Forms & Publications