State and Federal Accountability Measures

COMMUNITY SERVICES
BLOCK GRANT

Information Memorandum

U.S. Department of Health and Human Services
Administration for Children and Families
Office of Community Services
Division of State Assistance
370 L'Enfant Promenade, S.W.
Washington, D.C. 20447

Transmittal No. 144

Date: October 2, 2015

TO:

State Community Services Block Grant (CSBG) Administrators, U. S.
Territory CSBG Administrators, Eligible Entities, and State Community
Action Associations

SUBJECT:

State and Federal Accountability Measures and Data Collection
Modernization

RELATED
REFERENCES:

Community Services Block Grant Act 42 U.S.C. § 9901 et seq., hereafter
referred to as “the CSBG Act.”

In collaboration with the Community Services Block Grant (CSBG) Network, the Office of
Community Services (OCS) developed State and Federal Accountability Measures to track
organizational performance by State CSBG Lead Agencies and OCS. These measures are part
of an enhanced framework for accountability and performance management across the CSBG
Network.
OCS will require States, no later than FY 2016, to collect data and prepare to analyze and report
on State CSBG Accountability Measures through their online State plan and annual reports.
Concurrently, OCS will collect data and prepare to analyze and report on Federal CSBG
Accountability Measures in FY 2016.
Performance Management for CSBG
Budget constraints, high poverty levels, changing demographics, and income inequality demand
that the CSBG Network remains vigilant in our shared mission of creating opportunity and
security for all Americans. We must look at all levels of the CSBG Network – local, State, and
Federal – to assess and increase CSBG impacts. The CSBG Network is far-reaching and
nationwide. Together, we have the potential to achieve even greater results, in every community,
by improving our accountability to one another, our customers, and our communities.
In an effort to help the CSBG Network increase accountability and achieve results, OCS
launched several initiatives in 2012. One focused on establishing organizational standards for
eligible entities. Under this effort, CSBG Network leaders developed and recommended a set of
organizational standards to strengthen the capacity of the more than 1,000 eligible entities
providing services across the country. In FY 2016, States are implementing organizational
standards across the Network. (See Information Memorandum 138: “State Establishment of
Organizational Standards for Eligible Entities.”)
A second performance management initiative, currently underway, is focused on enhancing the

Page 2
CSBG Network’s performance and outcomes measurement system for local eligible entities –
identified in the CSBG Act as Results Oriented Management and Accountability System
(ROMA). Finally, a third initiative focused on creating State and Federal-level accountability
measures to track, measure, and improve organizational performance by State CSBG Lead
Agencies and OCS.
These three efforts are complementary and integrated; together they comprise a network-wide
accountability and performance management system for CSBG. They will ensure eligible
entities, States, and OCS operate within Federal law and regulation, and will build accountability
and continuous management improvement into all three levels of the Network (local, State and
Federal). As shown in Appendix 1, Measuring the Success of Community Action and CSBG,
these efforts will help us answer the questions: How well did the Network perform? and What
difference did it make? Ultimately, using these new and enhanced tools and information, the
CSBG Network will make better program decisions and generate stronger results for low-income
families and communities.
State and Federal Accountability Measures - Background
OCS developed the State and Federal accountability measures, with guidance and assistance
from the Urban Institute and in consultation with the CSBG Network, in two phases. The initial
development phase, starting in 2013, included multiple listening sessions (conducted online and
in-person), three CSBG Performance Management Task Force meetings with representatives
from all three levels of the Network, and two expert meetings. At the end of this process, OCS
published a Dear Colleague Letter on February 28, 2014 to solicit comments on an initial list of
proposed State and Federal accountability measures. In response, the Network – including
States, State associations, national organizations, and eligible entities – submitted thirty eight
sets of comments to OCS.
In the second phase, OCS worked with a small working group of States and eligible entities to
rework the State accountability measures in response to the comments OCS received on the
initial version of the State measures. On January 28, 2015, OCS published the revised State and
Federal accountability measures in draft Information Memorandum (IM), State and Federal
Accountability Measures and Data Collection Modernization, and requested a second round of
feedback.
Concurrently, OCS published a draft revised CSBG Model State Plan and sought input from the
CSBG Network through a 60-day Paperwork Reduction Act (PRA) comment period that ran
from January 26 to March 27. (See Dear Colleague Letter: CSBG Model State Plan Revision:
Open Comment Period, January 29, 2015.) The draft revised CSBG Model State Plan included
information on State accountability measures using the version of the measures published in the
January 28 draft IM.
In response to the draft IM and the PRA 60-day comment period on the Model State Plan, OCS
received dozens of extensive comments from a broad group of States, eligible entities, State
associations, and national CSBG partners. (See Dear Colleague Letter: CSBG Model State Plan
Revision: OMB Clearance and 30-Day Comment Period.) OCS carefully considered all these

Page 3
comments and consulted further with National and State partners before finalizing the State and
Federal measures in this guidance.
State and Federal Accountability Measures
The final State and Federal accountability measures are designed to create transparency and
accountability for performance at the State and Federal levels, and to help OCS and the States
identify successful practices and areas for improvement.
The State accountability measures capture performance data about the critical activities and
functions performed at the State level. They indicate how efficiently and effectively a State
implements the activities described in their State plan, and what impact the State’s efforts have
on the performance of local eligible entities.
The State accountability measures address efficiency and effectiveness characteristics such as
timeliness, accuracy, standards, and stakeholder satisfaction in the critical activities and functions
listed below:
•
•

Development of the State plan
Implementation of the State plan, including:
 Distribution of funds
 Use of remainder/discretionary funds
 Grantee monitoring and corrective action
 Data collection, analysis, and reporting
 Organizational standards for eligible entities
 State linkages and communication

See Appendix 2 for the State accountability measures.
The Federal accountability measures are tied to the critical roles and responsibilities of OCS,
and, where applicable, align with the State measures. The Federal accountability measures
indicate OCS’s effectiveness and efficiency as well as OCS’s impact on improving the
performance of State Lead CSBG Offices.
Like the State measures, the Federal measures address such efficiency and effectiveness
characteristics as timeliness, accuracy, standards, and stakeholder satisfaction in the following
critical activities:
• State plan review and acceptance
• Distribution of funds
• Grant monitoring and corrective action
• Data collection, analysis, and reporting
• Organizational standards
• Training and technical assistance
• Communications
See Appendix 3 for the Federal accountability measures.

Page 4
These State and Federal accountability measures are implemented within current Federal and
State administrative authorities. The CSBG Act requires States to report on performance,
according to the annual reporting provision in Section 678E (42 U.S.C. § 9917), and allows OCS
to request additional information through the State plan, as described in Section 676(b) (42
U.S.C. § 9908(b)).
State Accountability Measures - Data Collection
State accountability measures data will be collected using three mechanisms: 1) the CSBG
Model State Plan, 2) the State CSBG Annual Report, and 3) a nationally administered survey.
Generally, States will not need to collect accountability measures data outside of the State plan
and annual report. Because OCS will manage the national survey, there will be no survey-related
costs or burden for the States. States will collect data on the majority of measures on an annual
basis, and, at some point in the future, more frequently on a very small number of measures, as
noted in Appendix 2.
States will collect accountability data in a seamless, integrated fashion, through regular planning
and reporting processes and through the national survey. For example, States will enter
information in the State plan about planned performance in critical activity areas (e.g.,
development of the State plan, use of funds, grant monitoring, and training and technical
assistance). In the annual report, States will enter information on the actual performance in these
same areas, and strategies for improving performance as appropriate and necessary. Finally, the
States will receive feedback on their performance in these activity areas from the national
survey.
Revision of State Plan and Annual Report Forms, Including OMB/PRA Clearance
Over the past year, and with extensive input from the CSBG Network, OCS revised the Model
State Plan for the FY 2016 application cycle (for applications due September 1, 2015) to
streamline and automate content and to incorporate items related to State accountability
measures. Similarly, OCS, through a cooperative agreement with our national partner the
National Association for State Community Services Programs (NASCSP), plans to revise the
annual report forms in the coming year to include State accountability measures data, among
other changes.
OCS is automating these revised forms through ACF’s On-Line Data Collection (OLDC)
system. The OLDC Model State Plan and annual report forms will include definitions and
instructions and will apply data logic and validity checks to assure that data are reported
accurately and consistently. Automation provides new opportunities for integration of data
sources and for using data to make program and resource decisions by comparing results over
time. While States may need additional time to complete the new automated Model State Plan
and annual reports in the first year, they will save time significantly in subsequent years and
benefit from the host of new automated performance management tools and resources.
As part of the revision process, OCS obtained approval for the revised and automated Model

Page 5
State Plan from OMB, as required under the Paperwork Reduction Act of 1995 (PRA), and will
also seek PRA approval for the revised annual report form. The PRA requires Federal agencies
and OMB to ensure that information collected from the public minimizes burden and maximizes
practical utility. The OMB/PRA review and approval process includes a 60-day and a 30-day
public comment period for each submission. For more information about the OMB/PRA
clearance process, please see the Frequently Asked Questions on the U.S. Department of Health
and Human Service’s website.
During the PRA approval process for the Model State Plan, OCS collaborated closely with the
CSBG Network. The Network’s robust, thoughtful, and helpful participation in the PRA process
directly contributed to the effectiveness and smooth implementation of the new Model State
Plan. OCS looks forward to the continued engagement of the field in the development of the
annual report.
The American Customer Satisfaction Index (ACSI)
In 2012, OCS used the American Customer Satisfaction Index (ACSI) as the methodology for
surveying States’ perceptions of OCS performance. OCS plans to use this same methodology for
the nationally administered survey of CSBG eligible entities that will collect information on
State and Federal accountability measures.
The ACSI provides an independent, cost-effective, highly valid and reliable measure of
satisfaction. The ACSI methodology is the “gold standard,” and allows for the collection of
consistent, uniform information. It will provide OCS and the States with actionable insights to
assure strong working relationships at all levels of the CSBG network and, ultimately, boost
program results.
OCS engaged members of the CSBG Network in both the development of the survey and in
discussions about how the results will be used to improve State and OCS performance. OCS is
preparing to conduct the first survey of CSBG eligible entities in October, 2015. After the
survey is completed, each State will receive a report detailing the results of the survey with
recommendations for where to focus follow-up actions. OCS will not distribute data comparing
States. For more information about OCS’ use of the ACSI see Appendix 4.
Data Reporting and Analysis
Once States have collected data on accountability measures through the Model State Plans,
annual reports, and nationally administered survey, States will 1) analyze the data, 2) identify
performance strengths and weaknesses, 3) make performance management decisions (to improve
the effectiveness and efficiency of their CSBG operations), 4) report on these efforts to OCS and
their eligible entities, and 5) use the data as part of their ongoing strategic planning.
States and OCS can use State accountability measures data to identify areas for improvement and
determine if program changes are appropriate. For example, a State’s accountability measures
might indicate the State is not meeting the timeframes for disseminating monitoring reports or
distributing funds. The State could then take actions to improve performance in those areas. By

Page 6
collecting consistent data over time, OCS and States will illuminate performance issues and
encourage continuous improvement. In the short-term, States can aim for performance
improvement over the previous year. In the longer term, consistent performance data across the
entire CSBG Network can provide network-wide information about performance and best
practices.
To assist with data analysis, OCS will provide each State with State-specific feedback on
accountability measures after States have completed their annual reports. OCS expects States to
communicate their performance data to their eligible entities, and to use the data as part of their
ongoing strategic planning. We encourage States to do additional analysis to supplement the
State-specific feedback. Under the new CSBG cooperative agreement mentioned earlier,
NASCSP will help create web-based tools that in future years will make it easy for States and
other CSBG Network partners to produce reports that compare the State’s performance over time
with national averages and with selected groups of similar States. OCS will engage States in
discussions of data configurations and reporting that will guide decisions about State program
performance.
OCS will use the State accountability data and analysis in its oversight of and guidance to States
to encourage States to improve their performance. OCS will communicate progress on State
accountability measures to CSBG stakeholders through the OCS website and other means, as
appropriate.
Federal Accountability Measures - Data Collection and Analysis
For the Federal accountability measures, OCS will collect data on critical Federal activities from
1) a nationally administered survey, 2) automated State plans and reports, and 3) other Federal
grants systems. OCS will begin to collect data on the Federal measures in FY 2016.
For example, in order to collect data for OCS performance in the State plan review process, OCS
will use the Federal OLDC system to track timeframes for OCS review and acceptance of State
plans. In addition, OCS will gather data on OCS’s State plan review performance through the
nationally administered survey.
As with the State measures, OCS will use the ACSI methodology as the nationally administered
survey to collect information from States on Federal accountability measures. OCS plans to
conduct the first national survey to States about Federal performance in the Fall of 2015.
OCS is committed to a system that focuses on improved Federal accountability as a part of the
national performance management framework. Like the States, OCS will analyze and use the
data on the Federal accountability measures to improve our performance. We will communicate
progress on the measures to the States and other stakeholders through the OCS website and other
methods.

Conclusion

Page 7
We look forward to the Network’s continued partnership in implementing the Federal and State
accountability measures. OCS appreciates that the shared work of implementing accountability
measures, and the new framework for accountability and performance management overall, can
be challenging. To assist States in this change process, OCS and our national providers will
provide training and technical assistance through webinars, presentations at conferences, and
other communications to provide support on an on-going basis.
In the meantime, if you have questions, please contact an OCS CSBG program specialist. The
list of OCS staff and contact information is posted on the OCS website
at www.acf.hhs.gov/programs/ocs/resource/csbg-staff-assignments-by-region.
Together we must insist upon accountability and performance management across the CSBG
Network. The CSBG State and Federal Accountability Measures have the potential to protect
and enhance the structural integrity of this national network by assuring that all States that
receive CSBG funds, as well as the Federal office responsible for CSBG, are performing as
efficiently and effectively as possible to support CSBG’s response to the complex social
problems that contribute to poverty. We look forward to working with the CSBG Network to
successfully implement the State and Federal accountability measures and the performance
management framework overall.

____________/s/_______________________
Jeannie L. Chaffin
Director
Office of Community Services

Appendices:
Appendix 1:
Appendix 2:
Appendix 3:
Appendix 4:

Measuring the Success of Community Action and CSBG
State Accountability Measures
Federal Accountability Measures
American Customer Satisfaction Index and the CSBG State and Federal
Accountability Measures

Page 8
Appendix 1: Measuring the Success of Community Action and CSBG