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This report contains the Module 2
Content for the following comments:
1,2,3,4,6,8,9,10,11,12,13,14,16,17,18,19,20,21,22,23,25,29,30,31,32,33,34,35,36,37,38,39,40,41,42,43,45,46,47,48,49,50,53,55,56,58,59,60,61,63,64,65,67,68,71,72,73,74,75,77,78,79,80,81,82,83,84,85,86,87,89,91,94,96,98,100,101,102,103,104,106,107,108,109,110,111,113,114,115,116,118,119,120,121,123,124,125,126,129,130,131,132,133
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Comment 1 ( Arizona Department Of
Economic Security, Division Of Aging And Adult Services, Community
Action Programs And Services (Daas/Caps) ; State in AZ)
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Module 2: Module 2 –
Agency Expenditures, Capacity, and Resources: (pages 23-27)
The
State CSBG Office is interested in knowing the mechanism by which
this data will be collected from the Network, and over which
period, FFY or SFY? Will there be Excel spreadsheet forms, and/or
a database (Access) type of tool for State reporting? Will these
elements be entered into OLDC also? The concern on the part of the
Network is the volume of manual data collection required on the
part of the CAAs, and if technical assistance resources will be
available to the State and the CAAs. The State CSBG Office finds
the data elements of Module 2 largely satisfactory and
self-explanatory.
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Comment 2 ( Clarity, Impact And
Performance Project Steering Committee; RPIC in ID)
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Module 2: Module 2 –
Agency Expenditures, Capacity, and Resources: (pages 23-27)
Module 2, Section B:
(page # 25)
Need more clarity on the language “only
report partnerships here that contribute to the agency capacity”,
Is this an MOU level partnership or agencies who are partners at
any level?
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Comment 3 ( Hill Country Community
Action Association, Inc. ; Eligible Entity/Local Agency in TX)
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Module 2: No Comment
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Comment 4 ( Sacramento Employment And
Training Agency (Seta) ; Other/Unknown in CA)
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Module 2: No Comment
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Comment 6 (Action For Boston
Community Development Inc.; Other/Unknown in MA)
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Module 2: No Comment
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Comment 8 (Ashtabula County Community
Action Agency; Eligible Entity/Local Agency in OH)
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Module 2: No Comment
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Comment 9 (Association Of Nationally
Certified Roma Trainers ; Eligible Entity/Local Agency in N/A)
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Module 2: We support the
expanded agency capacity items in this module, including the use
of CSBG funding for this purpose and a way to identify the
capacity activities that are supported in this way. This module
section is the place where we see the importance of and the
support for building and maintaining Agency Capacity that is
needed as the foundation of all of the network's outcomes. We like
the additional elements of staff credentialing, but want to see
the family worker credentialing returned to the list (is in
current IS reporting) as this is an area where we need to see
skills and attitude development for our direct service
workers.
We question the placement of administrative
expenditures in Module 2 Section A. We have heard from our fiscal
colleagues that CSBG administrative expenditures should not be
included in the other domain areas of report and then taken out to
be reported separately. It has been stated that either an
expenditure is related to a service domain or it is administration
in nature (according to OCS 1M 37). This was the proposal in the
discussions over the past two years, but in the report as it is
presented for comment administration dollars are first included
and then separated which is how this has been reported in the IS.
This requires additional clarity.
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Comment 10 (Blue Valley Community
Action Partnership; Other/Unknown in NB)
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Module 2: I am concerned how
as a Community Action Partnership at the local level in Nebraska,
we will meet some of the reporting based on expenditures by
function, which no federal source separates out for budget
purposes. No line items exist on most federal budget pages for
planning, coordination, administration, etc. In fact most
administrative costs are tied to indirect costs for the sole
purpose that these areas are difficult to track.
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Comment 11 (California Community
Action Partnership Association; Other/Unknown in CA)
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Module 2: No Comment
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Comment 12 (Cap Service ;
Other/Unknown in WI)
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Module 2: Agency Expenditures,
Capacity and Resources - Module 2 Pages 23-27: The current IS
survey includes 300+ data elements to report. The proposed CSBG
Annual Report includes more than 1,000. This increased burden of
reporting comes with no new resources. The agency’s'
estimated time burden of 242 hours per sub-grantee (local
Community Action Agency) is significantly under estimated.
Based
on our calculations, the burden to our local agency would be
closer to three times that (in part due to CAP's large platform of
services and because of the inconsistent data elements across
programs and the need to recapture what is needed for CSBG serve
about 2,500 households per year (over $15,000), which represents
over 4% of our CSBG allocation. The additional data points and the
proposed community indicators we believe will result in costs of
$40,225 without inclusion of collective impact reporting or any
new software systems to manage
this.
Several of the
elements to be collected as described are not available in smaller
geographic areas usually targeted by local agencies in their
community work and if created by local agencies, lose validity.
CAP Services' footprint is predominantly rural and as such, easily
finding base data with which to compare or track changes is
already challenging.
In addition, our agency lacks a
cost-effective management information systems and the staff
capacity to create and maintain it to disaggregate this type of
data from its overall customer database, or struggle to integrate
the required data given our use of multiple (and sometimes
incompatible) reporting systems as I'd described earlier. Our
Board would stand opposed to investing precious resources in
management of data over delivery of services to meet the needs
identified in our needs survey. Lacking a definition of "new'
clients being provided for review, our network will be unable to
implement this report consistently. Defining an individual or
family is challenging when they may receive different services
over a number of years.
I would note the reference to
an online automated system may benefit State Lead Agencies but
will not likely CAP Services, Inc. or our peers in the State and
Nation. This will still require systems that track customers,
services, outcomes, and given the requirement of many funding
sources (including other federal Department of Health and Human
Services funding) requires additional and sometime separate data
collection systems as I described earlier. We have assessed
available systems and none are designed to capture all of our
current reporting obligations. CAP Services' Board is hard pressed
to invest in something less than workable or the staff resources
for even more data re-collection or sorting that brings no
additional value to our achievement of our mission.
Module
2 Section B: (page # 25) 1. Hours of Agency Capacity Building —
As commented by our state monitor, this will be very difficult to
provide an accurate count of all hours spent in capacity building.
Providing hours spent in training as in the current IS Survey is
relatively straightforward, but counting all of the hour's staff
and board members spend in "planning and assessment"
activities would be much more complicated and time consuming. For
some staff members, that could be a majority of their work hours
and for board members, much of their time in regular board
meetings and committee meetings could be considered capacity
building activities. This would also be very much dependent on how
agencies interpret the terms "planning and assessment".
In addition to the burden of tracking these hours, the practical
utility of this information is questionable. Given the potential
for very large numbers, that could lead one to question the
validity of the data
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Comment 13 (Cattaraugus Community
Action, Inc.; Eligible Entity/Local Agency in NY)
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Module 2: No Comment
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Comment 14 (Center For Community
Future ; Other/Unknown in N/A)
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Module 2: No Comment
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Comment 16 (Central Missouri
Community Action ; Other/Unknown in MO)
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Module 2: Module 2 –
Agency Expenditures, Capacity, and Resources: (pages 23-27)
Module 2, Section B: (page # 25)
• If
community partnerships are no longer a part of the NPIs tracked on
a regular basis, there is concern about this information getting
lost as agencies focus more on NPIs that are required to be
tracked quarterly versus being tracked annually. We feel this
information is important
Module 2, Section C: (page #
26-27)
• There is nowhere to report how CSBG
dollars are used to support or advance the capacity of the agency
and other programs.
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Comment 17 (Central Nebraska
Community Action Partnership; Other/Unknown in NE)
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Module 2: No Comment
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Comment 18 (City Of Austin Health And
Human Services ; State in TX)
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Module 2: No Comment
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Comment 19 (Colorado Community Action
Association; State Association in CO)
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Module 2: Agency Expenditures,
Capacity, and Resources: (pages 23-27)
Module 2,
Section A: (page # 24)
· Table 1 –
“Administration” should be a category in Table 1, not
as a secondary question below the table. Additionally, the
secondary question makes no sense as “administration”
in CSBG cannot be directly tied to an activity or domain (and thus
could not be contained in another domain in the Table 1 above).
When asked why this was the case, NASCSP responded that if
“Administration” was a category in Table 1, the figure
would be too big and would not look good on the network, which is
not a good reason to retain a reporting measure as currently
stated. Out of all of the changes to Module 2, Section A, removing
this secondary question regarding administration and making
administration its own domain in Table 1 was my greatest
suggestion and it was not incorporated.
Module 2,
Section B: (page # 25)
· Item 3 – Add “on
staff” to the end of each of these certifications so that
agencies understand that these are certifications held by their
internal staff and not a partner agency (such as the State
Association or a subcontractor).
· Item 4 –
Should this be partnerships “maintained or developed”?
As currently stated, only partnerships developed during the
reporting period would be counted, not all partnerships in the
community.
Module 2, Section C: (page # 26-27)
N/A
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Comment 20 (Colorado Department Of
Local Affairs ; Other/Unknown in CO)
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Module 2: No Comments
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Comment 21 (Combined Community Action
; Eligible Entity/Local Agency in TX)
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Module 2: No Comment
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Comment 22 (Community Action Agency ;
Other/Unknown in NE)
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Module 2: Module 2, Section A:
(page # 24)
There will difficulty in separating out
the CSBG funds used for Agency Capacity Building, as several
people are involved but only a part of their work. How to track
this without being cumbersome financial reporting is the concern.
Module 2, Section B:
(page # 25)
This same concern lies with tracking the
hours that board members, agency staff and volunteer staff spend
on capacity building activities.
Module 2, Section C:
(page # 26-27)
There is no problem with this. Take
straight from our audit!!!!!
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Comment 23 (Community Action Agency
Of Beaver County ; Eligible Entity/Local Agency in PA)
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Module 2: I am concerned how
as a Community Action Partnership at the local level in Nebraska,
we will meet some of the reporting based on expenditures by
function, which no federal source separates out for budget
purposes. No line items exist on most federal budget pages for
planning, coordination, administration, etc. In fact most
administrative costs are tied to indirect costs for the sole
purpose that these areas are difficult to track.
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Comment 25 (Community Action Agency
Of North Alabama ; Other/Unknown in AL)
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Module 2: No Comment
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Comment 29 (Community Action Agency
Of Southern New Mexico; State Association in NM)
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No Module 2 Content for this
comment.
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Comment 30 (Community Action
Association ; State Association in NM)
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Module 2: No Comment
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Comment 31 (Community Action
Commission Of Erie, Huron, & Richland Counties ; Eligible
Entity/Local Agency in N/A)
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Module 2: No Comment
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Comment 32 (Community Action
Committee Of Victoria, Texas; Eligible Entity/Local Agency in TX)
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Module 2: No Comment
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Comment 33 (Community Action Council
; Eligible Entity/Local Agency in KY)
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Module 2: The Council has
systems in place that will allow the organization to easily adopt
this report format within the existing system. It would be most
advantageous for the local community action agencies to have
access to the database to ensure validity of the data.
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Comment 34 (Community Action Council
Of Lexington-Fayette, Bourbon, Harrison And Nicholas Counties ;
Eligible Entity/Local Agency in KY)
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Module 2: Module 2 –
Agency Expenditures, Capacity, and Resources: (pages 23-27)
The
Council has systems in place that will allow the organization to
easily adopt this report format within the existing system. It
would be most advantageous for the local community action agencies
to have access to the database to ensure validity of the data.
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Comment 35 (Community Action Council
Of Portage County; Other/Unknown in OH)
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Module 2: NO Comment
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Comment 36 (Community Action
Partnership ; National Partner in DC)
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Module 2: No Comment
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Comment 37 (Community Action
Partnership Of Kern ; Other/Unknown in CA)
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Module 2: No Comment
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Comment 38 (Community Action
Partnership Of Orange County; Eligible Entity/Local Agency in CA)
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Module 2: No Comment
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Comment 39 (Community Action
Partnership Of Riverside County; Eligible Entity/Local Agency in
CA)
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Module 2: Section A: Table 2 –
Details on Agency Capacity Building (page # 24)
“Community
Needs Assessment” does not appear to be consistent, as an
option to choose in Table 2 – Details on Agency Capacity
Building Activities, with either the information requested in
Module 2, Section B: Local Agency Capacity Building or with the
categories listed for the Organizational Standards (where
“Community Needs Assessment” is referenced under the
Categories of Consumer Input and Involvement, Community
Engagement, Community Assessment, or is foundational for the
Community Action Plan and Strategic Plan. Therefore, it would more
naturally fall under the option of “Strategic Planning,”
than to be an option of its own.
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Comment 40 (Community Action
Partnership Of San Luis Obispo County, Inc.; Eligible Entity/Local
Agency in CA)
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Module 2: No Comment
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Comment 41 (Community Action Planning
Council Of Jefferson County, Inc.; Eligible Entity/Local Agency in
NY)
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Module 2: – Agency
Expenditures, Capacity, and Resources: (pages 23-27)
Module
2, Section A: (page # 24)
• No Comments
Module
2, Section B: (page # 25)
• No Comments
Module
2, Section C: (page # 26-27)
• No Comments
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Comment 42 (Community Action Program
Associations For Community Action Agencies; State Association in
WI)
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Module 2: No Comment
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Comment 43 (Community Renewal Team ;
Eligible Entity/Local Agency in CT)
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Module 2: No Comments
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Comment 45 (Del Norte Senior Center,
Inc.; Eligible Entity/Local Agency in CA)
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Module 2: Module 2 –
Agency Expenditures, Capacity, and Resources: (pages 23-27)
Module 2, Section B: (page # 25)
This
information has previously been reported as part of the NPI
reporting. There does not appear to be a valid reason for
requiring a separate report for this information.
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Comment 46 (Delaware Opportunities
Inc.; Eligible Entity/Local Agency in DE)
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Module 2: No Comment
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Comment 47 (Department Of Community
Service And Development ; State in CA)
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Module 2: The Agency
Expenditures, Capacity and Resources module is similar to what is
currently reported under the CSBG IS. This continuity in reporting
is appreciated. Also, streamlining the reporting to include agency
capacity under this section will assist in viewing agency
administrative contributions at a glance. This will be helpful and
will reduce the amount of crosswalk between fiscal and
programmatic elements currently provided in the annual CSBG IS
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Comment 48 (Department Of Housing And
Community Development ; State in MA)
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Module 2: No Comment
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Comment 49 (Department Of Human
Services ; State in AR)
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Module 2: Module 2 –
Agency Expenditures, Capacity, and Resources: (pages 23-27)
Further conversation is recommended on where and how
CSBG administrative expenditures are reported to align with
Network feedback and OCS guidance in the form of IM 37.
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Comment 50 (Department Of Social
Services Office Of Community Services ; State in CT)
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Module 2: Module 2 –
Agency Expenditures, Capacity, and Resources: (pages 23-27)
Module 2, Section A: (page # 24)
o
See reference to Table 2 in inquiry below at Module 2, Section
B.4.
Module 2, Section B: (page # 25)
o
“1.a Hours of Board Members in capacity building activities”
– This may be challenging or burdensome to some CAAs as
staff responsible for tracking Board Member volunteer hours may
not have the facility to determine when an individual’s time
is specifically focused on capacity building activities. If such
an activity were to occur during a regular Board meeting, it may
be complicated to separate and calculate the timing (e.g. Planning
Committee Member presents report/minutes to full Board regarding
activities/update – Is the Committee Member conducting a
capacity building activity by informing the whole Board about
progress? Is the whole Board participating due to their receipt of
information and discussion/feedback that follows?).
O “1.b
Hours of Agency Staff in capacity building activities” –
This may be burdensome to staff especially those that are paid
through multiple funding streams. Staff in this situation already
must track their time to be compliant with funding requirements
(percentages of time devoted to certain activities must align with
payroll allocations). Adding “capacity building activities”
into existing tracking systems may not be feasible or practical.
It is a layer that may cross over some funding streams or parts of
funding streams. It may be more practical to report/estimate the
number of FTE participating in “capacity building
activities” throughout the year (if specific
activities/projects are assigned to personnel).
O “3.
Staff Development and Certification Attainment” – It
is not clear if this section is asking for existing information or
information limited to newly attained status for the year. For
example, at “a. Number of Nationally Certified ROMA
Trainers”, is the CAA meant to enter the number of existing
ROMA Trainers at the agency whether they received their national
certification in the reporting year or prior? Or is the CAA meant
to only report those that attained their certification within the
reporting year?
O “4. Partnerships Developed to Expand
Agency Capacity…only report partnerships that contribute to
the agency’s capacity” – As Module 2, Section A
Table 2 defines Capacity Building as Community Needs Assessment,
Data Management, Strategic Planning, Training and Technical
Assistance and Other, it may be presumed that CAAs will list all
partners and not make a differentiation between capacity building
and non-capacity building. It is expected that a CAA will collect
and utilize information to assess community needs through all of
its partnerships (part of ROMA cycle). CAAs would be hesitant to
admit a partnership existed without an understanding that useful
data would be a component of such a relationship.
O In addition, does
the inclusion of the word “developed” in the heading
suggest that the report should only include those partnerships
initiated within the reporting year or is the CAA supposed to
report on all existing partners?
Module 2, Section C:
(page # 26-27)
o “Federal Resources Allocated
(Other than CSBG)” – There is a possibility of
duplicative reporting in this section if it is not made clear
which entity shall report on dollars received. For example, if one
CAA receives federal money and subcontracts to another CAA in the
same State, which entity reports the resource allocation? Grantee
or sub-grantee?
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Comment 53 (Division Of Sate Service
; State in DE)
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Module 2: No Comment
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Comment 55 (Florida Department Of
Economic Opportunity ; Other/Unknown in FL)
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Module 2: * Changes will take
place mostly on a state level, but we need to remember that
changes made at that level could eventually affect us at the local
level. Module 2 is information that we already gather and provide
as the total amount of
* CSBG funding expended during
the reporting period based on the various domains.
*
Allowing state agencies to only provide a 100% or fail to local
agencies for CSBG Organizational Standards doesn’t provide a
true picture of the agencies standards. States should be able
allowed to report how many agencies met 100%, 90%, 80%, etc. in
order to truly reflect a state’s performance. Also, it would
allow for focused technical assistance on agencies with the most
need.
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Comment 56 (Four Square Community
Action ; Other/Unknown in NC)
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Module 2: No Comment
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Comment 58 (Greater Bergen Community
Action; Eligible Entity/Local Agency in NJ)
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Module 2: Module 2 –
Agency Expenditures, Capacity, and Resources: (pages 23-27)
Module 2, Section A: (page # 24)
Adding
Agency Capacity Building to the list of CSBG expenditures not only
underlines the importance of these activities, but also creates a
funding stream that wasn’t available before. Great change.
The Annual Report should also be listed as an activity.
Module
2, Section B: (page # 25)
Increasing the list of Staff
Development and Certification Attainment provides a better picture
of the steps agencies are taking to provide opportunities for
staff to grow.
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Comment 59 (Greater Bergen Community
Action ; Eligible Entity/Local Agency in NJ)
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Section A: (page # 24)
Adding Agency Capacity Building to the list of CSBG
expenditures not only underlines the importance of these
activities, but also creates a funding stream that wasn’t
available before. Great change. The Annual Report should also be
listed as an activity.
Module 2, Section B: (page # 25)
Increasing the list of Staff Development and
Certification Attainment provides a better picture of the steps
agencies are taking to provide opportunities for staff to grow.
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Comment 60 (Hinds County Human
Resources Agency ; Other/Unknown in MS)
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Module 2: No Comments
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Comment 61 (Illinois Association
Community Action Agency ; Other/Unknown in IL)
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Module 2: No Comment
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Comment 63 (Indiana Housing And
Community Development Authority ; State in ID)
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Module 2: No Comment
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Comment 64 (Iowa Community Action
Association; Eligible Entity/Local Agency in IA)
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Module 2: No Comment
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Comment 65 (Kceoc Community Action
Partnership; Eligible Entity/Local Agency in KY)
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Module 2: Agency Expenditures,
Capacity, and Resources: (pages 23-27)
Module 2,
Section A: (page # 24) See Section B comments
Module 2,
Section B: (page # 25)
*Additional staff time to now
keep up with staff hours in planning & assessment (In addition
to training). I’m not sure why this matters. What does it
matter how much time we spend completing our community needs
assessment or strategic plan? What matters is that we do complete
it. Agencies function at different capacities. If we were
struggling in these areas I could see this as a recommendation to
review to help improve, but not as ongoing everyday reporting
criteria. Again, this is process, not results.
*Q4-How
is agency capacity defined in terms of partnerships? Why have a
partner if it not improving your ability to meet agency goals or
programmatic requirements?
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Comment 67 (Lorain County Community
Action Agency ; Other/Unknown in OH)
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Module 2: No Comment
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Comment 68 (Louisville Metro
Community Service ; State in KY)
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Module 2: Module 2 –
Agency Expenditures, Capacity, and Resources: (pages 23-27)
Module 2, Section A: (page # 24)
·
“Services supporting multiple domains” and “Agency
Capacity Building” are welcomed additions to the traditional
service categories.
Module 2, Section B: (page # 25)
· Building Performance Institute professionals
are no longer a requirement for Weatherization. As a result, this
data element seems unnecessary.
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Comment 71 (Maine Community Action
Association ; Other/Unknown in NE)
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Module 2: No Comment
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Comment 72 (Massachusetts Community
Action Agency Planners’ Group; State Association in MA)
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Module 2: No Comment
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Comment 73 (Maui Economic Opportunity
Inc. ; Other/Unknown in HI)
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Module 2: No Comment
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Comment 74 (Merced County Community
Action Agency ; Other/Unknown in CA)
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Module 2: No Comment
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Comment 75 (Michigan Community Action
; Eligible Entity/Local Agency in MI)
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Module 2: Module 2 - Agency
Expenditures, Capacity, and Resources: (pages 23-27)
•
The current reporting is already significant and should remain
unmodified.
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Comment 77 (Minnesota Valley Action
Council, Inc. ; Eligible Entity/Local Agency in MN)
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Module 2: Module 2 –
Agency Expenditures, Capacity, and Resources: (pages 23-27)
Module 2, Section B: (page # 25) Recommend not only
reporting how many, but how many added in report period to see how
agency capacity is growing / changing.
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Comment 78 (Missouri agency Inc. ;
Other/Unknown in MO)
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Module 2: No Comment
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Comment 79 (Missouri Community Action
Network (Can); State Association in MI)
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Module 2: Module 2 –
Agency Expenditures, Capacity, and Resources: (pages
23-27)
Module 2, Section B: (page # 25)
·
If community partnerships are no longer a part of the NPIs tracked
on a regular basis, there is concern that this information will be
lost as agencies focus more on NPIs that are required to be
tracked quarterly versus being tracked annually. We feel this
information is important.
Module 2, Section C: (page #
26-27)
· There is nowhere to report how CSBG
dollars are used to support or advance the capacity of the agency
and other programs.
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Comment 80 (Montgomery County
Community Action Development Commission; Other/Unknown in PA)
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Module 2: No Comment
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Comment 81 (Multi-Service Center
(MSC) ; Eligible Entity/Local Agency in WA)
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Module 2: No Comment
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Comment 82 (National Association For
State Community Service Program ; Other/Unknown in N/A)
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Module 2: a. Section A, CSBG
Expenditures: NASCSP recommends further conversation on where and
how CSBG administrative expenditures are reported to align with
CSBG Network feedback and OCS guidance in the form of IM 37.
Module 2 – Agency Expenditures, Capacity, and
Resources
NASCSP supports the reorganization and
expansion of Module 2. Sections A and B were updated and modified
to better capture the agencies’ investments using CSBG funds
and other leveraged resources to provide effective services and
strategies, and support quality performance evaluation. During the
Initial Feedback Period, Module 2, Section A, Table 1, contained
the Administrative portion of CSBG funds expended by the CAA
within the larger table of CSBG Expenditures. Data collected
during this Initial Feedback Period showed a high level of support
for the inclusion of administrative dollars within Table 1. NASCSP
recommends further conversation on where and how CSBG
administrative expenditures are reported to align with CSBG
Network feedback and OCS guidance in the form of IM 37.
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Comment 83 (National Community Action
Foundation ; Eligible Entity/Local Agency in N/A)
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No Module 2 Content for this
comment.
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Comment 84 (National Community
Partnership ; Other/Unknown in ND)
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Module 2: No Comment
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Comment 85 (Nek-Cap, Inc. (Northeast
Kansas Community Action Agency); Eligible Entity/Local Agency in
KS)
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Module 2: – Agency
Expenditures, Capacity, and Resources:
Data elements
in Module 2 Sections A-C provide clarity, focus and the prospect
for improving agency capacity and resources. The agency currently
collects several of the data elements and has the capacity to
utilize existing CAP 60 database system to collect other data
elements indicated. Data elements demonstrate the opportunity for
increasing funding and building enhanced partnerships. The data
elements do not include capacity building of the agency through
advocacy and public policy endeavors, unless those activities are
to be reported under other.
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Comment 86 (New England Community
Action Partnership (NECAP) ; State Association in CT)
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Module 2: No Comment
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Comment 87 (New York Department Of
Youth And Community Development ; State in NY)
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Module 2: No Comment
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Comment 89 (Ninth District
Opportunity, Inc.; Eligible Entity/Local Agency in GA)
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|
Section A: (page # 24)
Financial categories should match service/outcome categories
exactly so that agencies are able to easily make a connection
between what is provided and what is expended. From the
perspective of a planner and data analyst, this absolutely
imperative! You MUST be able to easily draw the line for every
service/outcome.
Module 2, Section B:
As
Head Start data is expected to be included in the report, staff
certifications for this program should be listed under question 3.
This is especially true of those required in the PIR.
Module
2, Section C:
This section should allow for the
documentation of leveraged dollars for client services (not
donated to the agency, but paid at the request of the agency
through referrals and other networking activities).
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Comment 91 (North Dakota Community
Action ; State Association in ND)
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Module 2: No Comment
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|
Comment 94 (Northeast Kansas
Community Action Agency; Eligible Entity/Local Agency in KS)
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Module 2: Module 2 –
Agency Expenditures, Capacity, and Resources:
Data
elements in Module 2 Sections A-C provide clarity, focus and the
prospect for improving agency capacity and resources. The agency
currently collects several of the data elements and has the
capacity to utilize existing CAP 60 database system to collect
other data elements indicated. Data elements demonstrate the
opportunity for increasing funding and building enhanced
partnerships. The data elements do not include capacity building
of the agency through advocacy and public policy endeavors, unless
those activities are to be reported under other.
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Comment 96 (Northern Tier Community
Action Corp. ; Eligible Entity/Local Agency in PA)
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|
Module 2: No Comment
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|
Comment 98 (NORWESCAP; Eligible
Entity/Local Agency in NJ)
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|
Module 2: No Comment
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|
Comment 100 (Nothing Compares;
Other/Unknown in NC)
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|
Module 2: Module 2 Agency
Expenditures, Capacity and Resources
Module 2, Section
A: (page # 24)
The current proposal does not include a
national goal for agency capacity. Specifications of expenditures
and activities surrounding agency capacity building as indicated
in Table I and Table 2 support the need for a national goal
regarding agency capacity.
Module 2, Section B: (page #
25)
The current proposal does not include a national
goal for agency capacity. Specifications of activities surrounding
agency capacity building as indicated Items 1, 2, 3 and 4 supports
the need for a national goal regarding agency capacity.
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Comment 101 (Ohio Association Of
Community Action Agencies; Other/Unknown in OH)
|
|
Module 2: No Comment
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|
Comment 102 (Opportunities For
Otsego, Inc. ; Other/Unknown in NY)
|
|
Module 2: No Comment
|
|
Comment 103 (Oregon Housing And
Community Services ; Other/Unknown in OR)
|
|
Module 2: No Comment
|
|
Comment 104 (People Incorporated Of
Virginia; Other/Unknown in VA)
|
|
Module 2: No comment
|
|
Comment 106 (Project Bravo; Eligible
Entity/Local Agency in TX)
|
|
Module 2: No Comment
|
|
Comment 107 (Pueblo County Housing
And Human Services; Other/Unknown in CO)
|
|
Module 2: Module 2: Agency
Expenditures, Capacity, and Resources / No Comments
1.
Whether the proposed collection of information is necessary for
the proper performance of the functions of the agency, including
whether the information shall have practical utility
2.
The accuracy of the agency’s estimate of the burden of the
proposed collection of information
3. The quality,
utility, and clarity of the information to be collected; and
4.
Ways to minimize the burden of the collection of information on
respondents, including through the use of automated collection
techniques or other forms of information technology.
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Comment 108 (Redwood Community Action
Agency ; Eligible Entity/Local Agency in CA)
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|
Module 2: Module 2 —Section
B: Capacity Building —
The first part of this
Section B (#1 and 4) requires reporting on capacity building
activities for Board, staff and volunteers as well as partnerships
specific to this activity which is currently not tracked. This
will present more of a burden for information collection than is
anticipated in the proposed rule. The collection of
this
information is not necessary for the proper performance of the
functions of the agency services and will unnecessarily generate
increased reporting and staff costs without any discernable
benefit.
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Comment 109 (Sa Howell, LLC ;
Other/Unknown in GA)
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|
Module 2: Module 1.
State
offices should have the option to report multiple benchmarks
concerning the achievement of OS compliance to demonstrate
progress over time rather than insinuating failure for those not
performing at a rate of 100%.
Many state employees are
not qualified to provide ROMA oversight, technical support, and
monitoring. State offices should be held accountable for access to
a ROMA professional (NCRT, NCRI, or Master Trainer) and document
regular participation in ROMA training, along with
agencies.
Module 1, Section B
This section
requires states to demonstrate an understanding of ROMA. States
will more than likely be required to hire better qualified staff
(data analysts) or contract these activities out. This is expected
to result in a strong, more productive network along with more
accurate data on a national level.
Module 1, Question
E3a is especially important, as some states have been holding
allocations until late in the Fiscal year, making it difficult for
agencies to spend within appropriate timelines. Some states have
even gone so far as to modify allocations without notifying
agencies and the refusing to provide an explanation of the
changes. This level of accountability is absolutely imperative to
the proper operation of the network.
Module 2, Section
A
Financial categories MUST match service/outcome
categories EXACTLY so that agencies are able to easily make a
connection between the services provided and the monies expended.
If no other changes are made to the document, this MUST!!
Module
2, Section B
As
Head Start data is expected to be included in the report, staff
certifications for this program should be listed under question 3.
This is especially true for those documented in the PIR.
Module
2, Section C
This section should
allow for the documentation of leveraged dollars for client
services (not donated to the agency, but paid at the request of
the agency through referrals and other networking activities) and
to include matching funds. If private sector resources under 22F
allows for collecting these dollars, it should be modified for
clarification. As no other indicator now includes a place to
capture this data, this is absolutely imperative to show the
importance of the network in the local community and the scope of
dollars leveraged on behalf of customers.
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Comment 110 (SEMCAC; Eligible
Entity/Local Agency in MN)
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|
Section A: (page # 24)
·
No Comments
Module 2, Section B:
(page # 25)
· No Comments
Module 2,
Section C: (page # 26-27)
· No Comments
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|
Comment 111 (South Plain Community
Action Association ; State Association in TX)
|
|
Module 2: No Comment
|
|
Comment 113 (Southern New Hampshire
Services ; Eligible Entity/Local Agency in NH)
|
|
Module 2: Module 2 –
Agency Expenditures, Capacity, and Resources: (pages 23-27)
Module 2, Section B: (page # 25)
Does
“partnership” refer solely to arrangements which
includes a Memorandum of Agreement or a Memorandum of
Understanding, or does it include more informal relationships
which are not defined by any documentation? Local agencies
collaborate with many entities on various levels, and the value of
some of these collaborations, while worthwhile and effective, is
difficult to quantify. Also, the concept of expanding Agency
Capacity is potentially problematic in that it could mean a
variety of things. This could lead agencies to omit some
collaborations in which an agency plays an important role but any
increase in agency capacity is difficult or impossible to
quantify.
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|
Comment 114 (Southwest Oklahoma
Community Action ; Other/Unknown in OK)
|
|
Module 2: No Comment
|
|
Comment 115 (State Of North Carolina;
State in NC)
|
|
Module 2: Module 2 Agency
Expenditures, Capacity and Resources
Module 2, Section
A: (page # 24)
The current proposal does not include a
national goal for agency capacity. Specifications of expenditures
and activities surrounding agency capacity building as indicated
in Table I and Table 2 support the need for a national goal
regarding agency capacity.
Module 2, Section B: (page #
25)
The current proposal does not include a national
goal for agency capacity. Specifications of activities surrounding
agency capacity building as indicated Items 1, 2, 3 and 4 supports
the need for a national goal regarding agency capacity.
|
|
Comment 116 (Texas Association Of
Community Action Agencies, Inc. (TACAA); Other/Unknown in TX)
|
|
Module 2: No Comment
|
|
Comment 118 (The State Of New York
Community Action Association ; State Association in NY)
|
|
Module 2: No Comment
|
|
Comment 119 (TN Department Human
Services ; State in TN)
|
|
Module 2: No Comment
|
|
Comment 120 (Tompkins Community
Action ; Eligible Entity/Local Agency in NY)
|
|
Module 2: No Comment
|
|
Comment 121 (Total Action For
Progress ; Other/Unknown in VA)
|
|
Module 2: No Comment
|
|
Comment 123 (Tri County Community
Action ; Other/Unknown in MN)
|
|
Module 2: No Comment
|
|
Comment 124 (U.S Department Of Health
And Human Service ; Eligible Entity/Local Agency in DC)
|
|
Module 2: No Comment
|
|
Comment 125 (Vermont Community Action
Partnership ; Other/Unknown in VT)
|
|
Module 2: No Comment
|
|
Comment 126 (Vernon Community Action
Council, Inc.; Eligible Entity/Local Agency in LA)
|
|
Module 2: No Comment
|
|
Comment 129 (Western New York
Community Action Agency; Eligible Entity/Local Agency in NY)
|
|
Module 2: No Comment
|
|
Comment 130 (Wisconsin Community
Action Program Association ; State Association in WI)
|
|
Module 2: * The ROMA: Next
Generation requirement for an increased level of demographic
characteristics to be collected will create an undue burden on the
low-income families seeking out services - even to the point where
such a burden may cause a family to “walk away” from
receiving assistance
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|
Comment 131 (Wisconsin Department Of
Children And Families; Eligible Entity/Local Agency in WI)
|
|
Section B: (page # 5-6)
p.
6 – B.7 Summary Analysis: The first six bullet points all
seem like they will be easy for states to answer and will provide
useful information.
The last two bullet points appear
to place new expectations on the State office that are not
included in the State Accountability Measures. They may be
problematic on two levels: 1) they would increase the workload for
our state’s CSBG administration, which is currently handled
by one staff person; and 2) our state’s network of eligible
entities values local control and is not looking to the State for
directives on their programming decisions.
“Based
on analysis, what services, strategies, or administrative
practices were identified to be shared across the State?”
The passive voice makes it confusing. Is the State CSBG office
charged with identifying best services, strategies, and
administrative practices to share across the state? Is this a new
requirement from OCS?
“Based on analysis of
performance data, what changes will the State encourage and
support with the local eligible entities?” Is this question
referring to 5.Sii? from the State Accountability Measures, which
requires States to provide individual written feedback on the each
eligible entity’s performance in meeting ROMA goals, or does
it refer to a new requirement?
Module 1, Section E:
(page # 10-14)
p. 14 - E.9b. Carryover for this Fiscal
Year: Wisconsin's CSBG contracts operate on the calendar year and
the agencies have 90 days after the end of December to close out
their contracts. Therefore, the State did not have the final data
to report at the time the Annual Report is due at the end of
March. Our office will be able to send the correct Carryover
amount during April, a few weeks after the Annual Report is
submitted.
Module 1, Section H: (page # 20-21)
p.
21 – H.6 Single Audit Review: Does “Audit Number”
mean “Report ID”?
Module 1, Section I:
(page # 22)
p. 22 – “State and Eligible
Analysis of Data: Describe how the State validated that the
eligible entities used data to improve service delivery.”
Would
this be addressed by monitoring the agencies for CSBG
Organizational Standard 9.3, which states, “The organization
has presented to the governing board for review and action, at
least within the 12 months, an analysis of the agency’s
outcomes and any operational or strategic program adjustments and
improvements identified as necessary.”?
What
other expectations would there be relating to how the State
validates that the eligible entities used data to improve service
delivery?
, Section A: (page # 24)
p. 24 –
Table 2 – Details on Agency Capacity Building Activities
Funded by CSBG: I’d recommend including “Volunteer
Coordination” and “Grant Writing” to the list of
activities.
Module 2, Section B: (page # 25)
1.
Hours of Agency Capacity Building - This will be very difficult to
provide an accurate count of all hours spent in capacity building.
Providing hours spent in training as in the current IS Survey is
relatively straightforward, but counting all of the hours staff
and board members spend in “planning and assessment”
activities would be much more complicated and time consuming. For
some staff members, that could be a majority of their work hours
and for board members, much of their time in regular board
meetings and committee meetings could be considered capacity
building activities. This would also be very much dependent on how
agencies interpret the terms “planning and assessment”.
In addition to the burden of tracking these hours, the practical
utility of this information is questionable.
4.
Partnerships Developed to Expand Agency Capacity – It is
unclear what agencies would be counting here. The top row says
Partnerships, but the column header says it’s an
unduplicated count of organizations. This will cause confusion if,
for example, an agency works on a taskforce with five other
agencies. Would the agency count the taskforce as five
organizations, or one partnership?
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|
Comment 132 (Work And Family Support
Bureau; Other/Unknown in NM)
|
|
Module 2: No Comment
|
|
Comment 133 (WSOS Community Action;
Eligible Entity/Local Agency in OH)
|
|
Module 2: No Comment
|
|