CSBG Organizational Standards
This webpage links resources developed by CAPLAW to specific Community Services Block Grant (CSBG) Organizational Standards to help Community Action Agencies (CAAs) in their compliance efforts. For some Standards that we regularly receive inquiries about, we also include links to resources developed by the national Community Action Partnership. All of the resources developed by the national Community Action Partnership on the Standards are available on its website.
Note: CAPLAW is in the process of revising some of its resources pursuant to updates in the law; however, the concepts in these resources generally remain applicable.
5. Board Governance
Standard 5.1
Private
The organization’s governing board is structured in compliance with the CSBG Act:
1. At least one third democratically-selected representatives of the low-income community;
2. One-third local elected officials (or their representatives); and
3. The remaining membership from major groups and interests in the community.
Public
The department’s tripartite board/advisory body is structured in compliance with the CSBG Act, by either:
1. Selecting the board members as follows:
• At least one third are democratically-selected representatives of the low-income community;One-third are local elected officials (or their representatives); and
• The remaining members are from major groups and interests in the community; or
2. Selecting the board through another mechanism specified by the State to assure decision-making and participation by low-income individuals in the development, planning, implementation, and evaluation of programs.
CAPLAW Resources:
• CSBG Training Tools for Nonprofit Boards: Governance(2013). This Tool provides a nonprofit CAA board with the guidance and information it needs to teach itself about the CSBG tripartite board requirements. The Tool consists of questions, quizzes, exercises and resources that the board is instructed to work through with the help of a board member facilitator
CSBG Training Tools for Public CAA Boards: Governance (2013). This Tool provides a public CAA board with the guidance and information it needs to teach itself about the CSBG tripartite board requirements. The Tool consists of questions, quizzes, exercises and resources that the board is instructed to work through with the help of a board member facilitator.
• Introduction to CSBG Training Module (2010). This interactive Module with voiceovers and quizzes walks through the entire CSBG Act. Chapter 3: Tripartite Boards of the Module includes a discussion of the federal CSBG Act tripartite board composition and selection requirements.
• Purely for Public CAAs Training Module (2011). This interactive Module with voiceovers and quizzes covers provisions in the Federal CSBG Act specific to public CAAs. Chapter 3: Tripartite Boards of the Module includes a discussion of the federal CSBG Act tripartite board composition and selection requirements
• Sample Board Composition Matrix. A CAA board may edit this excel spreadsheet to reflect its current recruitment strategies and using it may help focus the board on its most pressing board member composition needs. It is important to note, when using a board matrix, a CAA must be careful to not focus on who people are to the extent that it loses sight of what people will do for the organization.
CAPLAW/Partnership Resource:
• CAA Leader’s Legal Guide (2016). This Guide provides CAA leaders with an overview of some of the legal requirements they will work with on a regular basis. Chapter Two: Community Services Block Grant Act of the Guide includes a discussion of the federal CSBG Act tripartite board composition and selection requirements.
Standard 5.2
Private
The organization’s governing board has written procedures that document a democratic selection process for low-income board members adequate to assure that they are representative of the low-income community.
Public
The department’s tripartite board/advisory body either has:
- Written procedures that document a democratic selection process for low-income board members adequate to assure that they are representative of the low-income community, or
- Another mechanism specified by the State to assure decision-making and participation by low-income individuals in the development, planning, implementation, and evaluation of programs.
Please note under IM 82 for Public Entities the law also requires that a minimum of 1/3 of tripartite board membership be comprised of representatives of low-income individuals and families who reside in areas served.
CAPLAW Resource:
- Raising the Low-Income Voice: Case Studies in Democratic Selection Procedures (2015). These case studies address various ways that CAAs are meeting the CSBG Act’s requirement that the low-income sector of the tripartite board be selected in accordance with “democratic selection procedures.”
Standard 5.3
Private
The organization’s bylaws have been reviewed by an attorney within the past 5 years.
Public
Not applicable: Review of bylaws by an attorney is outside of the purview of the department and the tripartite board/advisory body, therefore this standard does not apply to public entities.
CAPLAW Resources:
- Working With Attorneys Guidebook (2016 edition). This Guidebook examines how CAAs can find, hire, pay for, and work with an attorney.
- Bylaws Toolkit (2009). This Toolkit outlines key concepts for a CAA’s bylaws and includes sample language addressing topics such as the authority of the board, petitions for board representation, vacancies, quorum and voting policies, officers, conflicts of interest, and more. We recommend providing a copy of the Toolkit to the attorney reviewing your CAA’s bylaws to help that attorney better understand the impact of federal grant laws, in particular the Federal CSBG Act and the Head Start Act (if applicable), on your CAA’s bylaws.
Standard 5.4
Private
The organization documents that each governing board member has received a copy of the bylaws within the past 2 years.
Public
The department documents that each tripartite board/advisory body member has received a copy of the governing documents, within the past 2 years.
Standard 5.5
Private
The organization’s governing board meets in accordance with the frequency and quorum requirements and fills board vacancies as set out in its bylaws.
Public
The department’s tripartite board/advisory body meets in accordance with the frequency and quorum requirements and fills board vacancies as set out in its governing documents.
Standard 5.6
Private
Each governing board member has signed a conflict of interest policy within the past 2 years.
Public
Each tripartite board/advisory body member has signed a conflict of interest policy, or comparable local government document, within the past 2 years.
CAPLAW Resources:
- Roadmap for Resolving CAA Conflicts of Interest (2012). This Webinar reviews sample conflicts of interest policies and provides practical tips for drafting, implementing and using such policies to resolve problematic situations.
- Sample Conflict of Interest Policy for Board of Directors of a CAA with a Head Start Program
- Sample Conflict of Interest Policy for Senior Staff of a CAA with a Head Start Program
- Sample Conflict of Interest Policy for Board of Directors of a CAA without a Head Start Program
- Sample Conflict of Interest Policy for Senior Staff of a CAA without a Head Start Program
- Do the Right Thing: How to Cultivate a Culture of Compliance and High Ethical Standards (2016 edition). This Guide demonstrates – through interviews with CAAs, links to resources from compliance and ethics experts, and sample documents – practical steps CAA boards and management can take to ensure that their organizations operate effectively and in compliance with the many requirements that apply to them. In particular, throughout the Guidebook are discussions about the importance of conflict of interest policies, the vital role they play in establishing an ethical environment, and their practical impact on a CAA.
- Tools for Top-Notch CAAs (2010). This six-section Tool is intended to assist boards and management in their collaborative efforts to build well-governed and effective CAAs. Section 5. Dealing with Conflicts of Interest of the Tool specifically discusses the elements of a conflicts of interest policy and the implementation of such policies.
Standard 5.7
Private
The organization has a process to provide a structured orientation for governing board members within 6 months of being seated.
Public
The department has a process to provide a structured orientation for tripartite board/advisory body members within 6 months of being seated.
CAPLAW resources that may be used as part of the board orientation to help board members understand the federal CSBG Act:
- Introduction to CSBG Training Module (2023). This interactive Module with voiceovers and quizzes walks through the entire federal CSBG Act.
- Purely for Public CAAs Training Module (2011). This interactive Module with voiceovers and quizzes covers provisions in the federal CSBG Act specific to public CAAs.
Standard 5.8
Private
Governing board members have been provided with training on their duties and responsibilities within the past 2 years.
Public
Tripartite board/advisory body members have been provided with training on their duties and responsibilities within the past 2 years.
These resources may be used by board members to help train and educate the board about its role and responsibilities.
CAPLAW Resources:
- CAA Leaders’ Legal Boot Camp (2016). This five-part Webinar Series is mostly based on the CAA’s Leader’s Legal Guide and aims to provide new and seasoned CAA Leaders with an overview of the many legal requirements that they will work with on a regular basis. The series address: (i) federal grant law; (ii) the Community Services Block Grant Act; (iii) financial management of federal grants; and (iv) general tax-exempt organization requirements. The series also includes a webinar directed specifically at issues particular to public CAAs.
- Tools for Top-Notch CAAs (2011). This tool is intended to assist boards and management in their collaborative efforts to build well-governed and effective CAAs. This Tool addresses how boards conduct and maintain board meeting minutes; build financial capacity; prepare organization-wide budgets; get the most out of financial statements; address conflicts of interest and draft and implement effective whistleblower policies.
- CAPLAW Governance Case Studies (2008). These Case Studies are designed to educate board members and nonprofit managers about the challenges involved in creating an effective, well-managed board. Each Case Study includes discussion questions and suggested solutions to the issues discussed.
CAPLAW/Partnership Resources:
- CAA Leader’s Legal Guide (2016). This Guide provides CAA leaders with an overview of the many legal requirements that they will work with on a regular basis. The Guide covers topics such as the federal grant life cycle; the legal authority underlying federal grants; the federal CSBG Act; federal financial management requirements; and tax rules specific to nonprofit CAAs operating as 501(c)(3) tax-exempt organizations.
- Dynamic Duo: A Guide to Enhancing the Board & Executive Director Partnership (2016). This Guide analyzes the board and executive director relationship including roles and responsibilities; board recruitment and development; internal and external communications; the executive director and board chair relationship; executive director transition; executive director compensation; and executive director supervision and evaluation.
Standard 5.9
Private
The organization’s governing board receives programmatic reports at each regular board meeting.
Public
The department’s tripartite board/advisory body receives programmatic reports at each regular board/advisory meeting.
CAPLAW Resources:
- Tools for Top-Notch CAAs (2010). This six-section Tool is intended to assist boards and management in their collaborative efforts to build well-governed and effective CAAs. Section 1. Making Board Meetings Matter of the Tool specifically discusses the structure of board meetings and provides some guidance as to how and when discussions relating to programmatic reports and updates may occur.
- Constructing a Community Action Dashboard (2012). Dashboards are one option for presenting information to the board and enabling them to focus, with greater clarity, on the most relevant information for making strategic decisions. An effective dashboard report distills data to some key measures and makes meaningful comparisons to benchmarks and goals.
This resource was created by Community Action Program Legal Services, Inc. (CAPLAW) in the performance of the U.S. Department of Health and Human Services, Administration for Children and Families, Office of Community Services Cooperative Agreement – Grant Award Number 90ET0441-02. Any opinion, findings, and conclusions, or recommendations expressed In this material are those of the author(s) and do not necessarily reflect the views of the U.S. Department of Health and Human Services, Administration for Children and Families.