Community Services Block Grant Program: HHS Should Improve Oversight by Focusing Monitoring and Assistance Efforts on Areas of High Risk

In August 2009, the Department of Health and Human Services' Inspector General (IG)issued a report on CSBG's progress in implementing six recommendations from this report and the related agency correspondence. The IG conducted this review in response to the CSBG program being appropriated $1 billion through the American Recovery and Reinvestment Act of 2009. The IG found that the Office of Community Services (OCS) had implemented this recommendation. Specifically, OCS had used six factors for conducting a risk-based assessment of state CSBG. These factors were: (1) the number of local grantees identified by a state as vulnerable, in crisis, terminated, or having corrected past problems; (2) the complexity each state's monitoring efforts in relation to the state's physical size, number of eligible grantees, and personnel allocations to the CSGB program; (3) poverty in the state; (4) the total number of people served the grantees in the state in relation to the total number of eligible grantees in the state; (5) Office of Management and Budget Circular A-133 audit reports; and (6) the timeliness of state CSGB plans. This IG performance audit was conducted in accordance with GAGAS.

In August 2009, the Department of Health and Human Services' Inspector General (IG)issued a report on CSBG's progress in implementing six recommendations from this report and the related agency correspondence. The IG conducted this review in response to the CSBG program being appropriated $1 billion through the American Recovery and Reinvestment Act of 2009. By the time of the IG report issuance, the Office of Community Services (OCS) established written policies and procedures to ensure that on-site monitoring was focused on states with the highest risk. According to these policies and procedures, OCS's future triennial schedules for state assessments will place a priority on assessing states at highest risk.

The Office of Community Services issued an information memorandum on October 10, 2006, to state CSBG agencies on their responsibilities to monitor local agencies, and updated it on November 27, 2006. In this memo, OCS stated that state agencies must monitor eligible entities no later than three years after the last compliance review and illustrated its expectations by stating that if an compliance review had occurred in September 2005 that the next review should occur by September 2008.

The agency stated that, in fiscal year 2009, Administration for Children and Families (ACF) grantees, including those who receive grantees monitored by the Office of Community Services (OCS), will start using the Standard Form-Performance Progress Report (SF-PPR) for required performance progress reports. According to OCS, the SF-PPR will begin for all awards (new and continuing) made by ACF in fiscal year 2009. At a minimum, grantees will be required to submit the ACF's Office of Grants Management's version of the SF-PPR coversheet and SF-PPR Appendix B Program Indicators, which are specific to ACF performance progress reports. In July 2010, ACF provided us with a copy of the SF-PPR which includes the mentioned appendix that requires grantees to report on performance progress to date and to provide a final performance report within 90 days of the project's completion. Furthermore, the form provides details on what information is expected to be in the performance reports, including major activities and accomplishments and problems faced, and defines what is meant by these expectations.

In October 2007, HHS stated that the Office of Community Services (OCS) worked with the Monitoring and Assessment Task Force -- a consortium of federal, state and local officials associated with Community Service Block Grant (CSBG) programs -- to develop a comprehensive strategic plan for providing training and technical assistance to state and local CSBG-funded entities that focus on Program Leadership, Program Integrity, and Program Accountability. OCS' "Training, Technical Assistance, and Capacity Building for the Community Services Block Grant Program" (July 26, 2007) includes the OCS Strategic Plan for CSBG Program Improvement - FY 2007-2009, which OCS noted was developed in response to GAO's recommendation. The strategic plan briefly focuses on improvement initiatives, such as training and technical assistance funding accountability. In July 2010, HHS provided us with a copy of this strategic plan, which explicitly mentions that it was developed in response to our recommendation.