CSBG Organizational Standards Guide
Introduction
The CSBG Organizational Standards (the Standards) are a comprehensive set of performance measurement criteria for Community Action Agencies (CAAs). The purpose of the Standards is to ensure CAAs have the proper organizational capacity to fulfill the mission and purpose of the federal Community Services Block Grant (CSBG) Act.
Every Standard reflects a critical element of Community Action and are, as a whole, uniquely tailored to the CSBG Act and CAAs. The Standards help set baseline requirements for CAAs across the country to ensure all are meeting performance expectations regardless of location. State CSBG agencies also use the Standards as a framework for monitoring CAAs. For more information about the CSBG review process, see CAPLAW’s Monitoring Map for CSBG.
This guide includes (i) a brief history of the development of the Standards; (ii) an explanation of the legal framework underlying the Standards; and (iii) the text of every Standard for both nonprofit and public CAAs. For most Standards, this guide also links to related resources developed by CAPLAW, the National Association for State Community Services Programs (NASCSP), and the National Community Action Partnership (NCAP).
History
Prior to the implementation of the Standards, no national or overarching framework existed for either the foundational capacity of a CAA or the evaluation of CAAs by their state CSBG agency. While the CSBG Act and its predecessor, the Economic Opportunity Act, provided the federal rules applicable to the entire Network, states had developed a patchwork of their own specific requirements for monitoring CAAs.
CSBG is a block grant; states are the primary grantees and are responsible for administration of the funds. States have considerable flexibility to implement CSBG programming but still must follow the requirements of federal law, including the CSBG Act and block grant regulations. The CSBG Act includes a framework for the use of funds and directs states to monitor CAAs, but does not include specific rules for evaluating CAAs or CSBG programs. Each state gives the same assurances in its State Plan with respect to the use and monitoring of CSBG funds, but may interpret the fulfillment of those responsibilities differently.
Comparison of CAA performance and results before the Standards was complicated by the variety of benchmarks and tools used at the state level to define programming and operational success. As a result, the Office of Community Services (OCS) identified a need for consistency in reporting and evaluation between states to enforce the shared mission and goals of the Network.
In 2012, OCS launched an initiative to establish a set of standards for CAAs as part of a multi-prong process to overhaul the Network’s performance management systems. Pursuant to a cooperative agreement between OCS and NCAP, the CSBG Organizational Standards Center of Excellence (the COE) was founded.
The COE led efforts to collect information from across the Network about existing oversight tools used to evaluate CAA capacity and accountability. These efforts included input from NCAP and other national partners (including CAPLAW and NASCSP), public and nonprofit CAAs, state CSBG agencies, state associations, and external parties such as legal and financial experts. The COE spearheaded the creation of draft standards that were workshopped and reworked by the many COE working groups; a pilot program field tested a near-final draft with a subset of state CSBG agencies and CAAs. OCS reported that over 3,500 hours were invested by the Network in this process.
In March 2014, OCS published a draft information memorandum (IM) that included draft standards. OCS collected comments from the Network and incorporated this feedback into the final draft, which was released in the form of guidance from OCS as IM 138, State Establishment of Organizational Standards for CSBG Eligible Entities under 678B of the CSBG Act, 42 U.S.C. § 9914 in January 2015.
The Standards, as laid out in IM 138, consist of 58 standards for private, nonprofit CAAs and 50 for public CAAs, split across 3 groups and 9 subcategories:
| Maximum Feasible Participation | Consumer Input & Involvement | Community Engagement | Community Assessment |
| Vision & Direction | Organizational Leadership | Board Governance | Strategic Planning |
| Operations & Accountability | Human Resource Management | Financial Operations & Oversight | Data & Analysis |
NCAP maintains a resource hub that includes the many toolkits and other publications they have produced to support the Network’s adoption and ongoing compliance with the Standards.
Applicability
Authority to Form the Standards
The CSBG Act is the authority under which OCS instituted the creation and implementation of the Standards. States, under the CSBG Act, are responsible for the oversight of CAAs. States must conduct regular monitoring of CAAs to determine if they “meet the performance goals, administrative standards, financial management requirements, and other requirements of a [s]tate”.
OCS is responsible for monitoring state compliance with the requirements of the CSBG Act. The Act directs OCS to conduct evaluations of the use of CSBG funds received by states and collect information from states on how they are meeting their responsibilities. In particular, the CSBG Act permits OCS to “prescribe procedures for the purpose of assessing effectiveness of [CAAs]” in fulfilling the purposes of the Act.
Implementation of the Standards
Following the development process led by COE discussed in History above, OCS released the final Standards in IM 138. An IM is non-binding guidance that assists CAAs and state CSBG agencies in understanding how OCS interprets the CSBG Act and other relevant laws. IM 138 directed states to “establish and report on their organizational standards for CSBG eligible entities” by fiscal year 2016.
The requirements of IM 138 have been implemented by every state, in part due to the inclusion of the following language in the 2016 Consolidated Appropriations Act:
the Secretary shall issue performance standards for nonprofit organizations receiving funds from State and territorial grantees under the CSBG Act, and such States and territories shall assure the implementation of such standards prior to September 30, 2016, and include information on such implementation in the report required by section 678E(2) of such Act
With this, Congress required every state to implement a version of the Standards and the requirements of IM 138. Many states have incorporated the Standards into their state CSBG laws, policies, or contracts and OCS has added essential elements to the State Plan and Annual Report based on the Standards.
Use of the Standards by States
Section 6 of the CSBG State Plan, Organizational Standards for Eligible Entities, requires states to confirm if they use the Standards as described in IM 138 or a modified or alternative version. If a state is using a modified version, the state must provide its rationale for modifying the Standards. If a state is using an alternative version, the state must describe its reasons for using alternative standards and how they are at least as rigorous as the COE-developed Standards.
A majority of states use the COE-developed Standards rather than a modified or alternative version. States that use a modified version, like Indiana, Maine, Mississippi, or Wyoming, typically include additional standards that are aligned directly with state CSBG laws or policies of the state CSBG agency. Modifications to the Standards can vary in depth and breadth. Indiana has added 26 additional operational and fiscal standards that reflect requirements in its state law, state CSBG agency policies, and agreements with CAAs. Mississippi’s State Plan indicates they use versions of Standards 3.1, 5.5, and 9.4 that align with existing state policies.
States must adopt their standards in a manner consistent with the state administrative procedures act. This is a state law that governs how state agencies create rules, issue binding policies, and adjudicate disputes. The State Plan includes three general options for adopting the Standards: regulation, policy, or contracts with eligible entities. State CSBG agencies may use one or all of these options or may describe another method that aligns with state law. Iowa, for example, includes the Standards in its annual CSBG application process for CAAs. The majority of states incorporate their standards into their contracts with CAAs. A smaller number of states, including Kentucky, Massachusetts, and Texas, have codified their standards via regulation.
The CSBG State Plan also requires states to describe how they will assess CAAs against the Standards. The options include peer-to-peer review, self-assessment, and regular on-site monitoring by the state CSBG agency.
The Standards are only one piece of the monitoring and compliance puzzle for CAAs. A majority of states also have CSBG statutes and/or regulations that the state CSBG agency monitors CAAs on compliance with. CAAs may also be monitored on other requirements in their agreement/contract with the state for CSBG funds or contained in a program guide or manual.
This resource was originally created by CAPLAW with support from the National Community Action Partnership. This material is supported by Grant Number 90ET0505-03 from the ACF Office of Community Services, Community Services Block Grant within the Administration for Children and Families, a division of the U.S. Department of Health and Human Services. Neither the Administration for Children and Families nor any of its components operate, control, are responsible for, or necessarily endorse this material (including, without limitation, its content and any services or tools provided). The opinions, findings, conclusions, and recommendations expressed are those of the author(s) and do not necessarily reflect the views of the Administration for Children and Families and the ACF Office of Community Services, Community Services Block Grant.