Effective Oversight

CSBG Oversight: An Operational Continuum

Effective Oversight

Contracts

Effective Oversight

Policies and Procedures

Effective Oversight

Holistic Monitoring

Federal Law and Applicable Regs Monitoring Tool Effective Oversight State Plan

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Policies and Procedures

A Systems View of Monitoring

LIHEAP CSBG Head Start WIA

Brown Buckley Tucker

WAP

Why Use a System’s Approach

 IM 49  IM 94  Monitoring Practices and Principles

I.M. 94

  ‘State CSBG Lead Agencies …should … ensure …that agency Head Start programs have ongoing systems of oversight and monitoring.’ ‘It is important to stress that quick fixes to identified problems typically result in a reoccurrence of the problems. Most areas needing improvement are often linked to major systems that often require thoughtful planning and time to implement needed changes.’

I.M. 94, cont.

 ‘…the Community Services Network must continue to focus its efforts on strengthening overall agency governance and administration, fiscal control, program effectiveness and accountability to assure capacity to comply with all program requirements of the various programs administered by the agency.’

I.M. 49

 “Recognizing that CSBG does not succeed as an individual program…Special attention will be paid to State capabilities to identify the…needs among eligible entities, particularly those related to strengthening OVERALL program administration, fiscal management,…”

I.M. 49, cont.

  “…State…officials …(should) reinforce the importance of effective management SYSTEMS…” “…As part of …oversight, we should implement on-going…SYSTEM-WIDE actions…to assure continued administrative and fiscal integrity, program effectiveness, and accountability among ALL PROGRAMS administered by CAAs.”

I.M. 49, cont.

 “…Agencies in the past have often focused their energies on ‘preparing for the monitoring test’ instead of implementing on-going SYSTEMS that identify areas needing improvement…”

I.M. 49, cont.

 “…Agencies that choose to operate each of their programs separately without a coordinated strategy to address the multi faceted causes and conditions of poverty…are meeting neither the letter nor the spirit of the CSBG act.”  “…Community Action is one agency with one mission.”

I.M. 49, cont.

 “…Most areas needing improvement are often linked to major SYSTEMS…”  “…State …officials (should) …reinforce the importance of effective management SYSTEMS…”

NASCSP’s Standard Monitoring Principles and Practices for CSBG

 “…State monitors should look at more than compliance with program rules and regulations.”  “…State monitors need to take a SYSTEMS view of each CAA…”

Monitoring Principles and Practices CSBG Act And OMB circulars OCS Information Memorandums NASCSP Monitoring Principles IM 49 ROMA IM 82 Tripartite Board IM 94 Head Start PRISM Reviews

Monitoring Standards Monitoring Practices Monitoring Topic Areas

Any State Monitoring Structure Program Monitor Program Administrator Fiscal Monitor Program at Agency #1 Program at Agency #2 Program at Agency #3 Program Finances at Agency #1 Program Finances at Agency #2 Program Finances at Agency #3

ABC Community Action CSBG Board of Directors Executive Director Head Start Weatherization LIHEAP Housing Finance CSBG Staff Head Start Staff Weatherization Staff LIHEAP Staff Housing Staff Finance Staff

Brown Buckley Tucker

A System for Monitoring Monitoring Tool Staff Training Dynamics of Change Integrated Monitoring Structure Collaborative Relationships HUD Weatherization Head Start

ABC Community Action Governance Fiscal Policies & Procedures Admin. Systems & Procedures Programs Planning: Mission & Planning Evaluation Partnerships Outcomes

Brown Buckley Tucker

Monitoring as oversight…

Federal Law and Applicable Regs Monitoring Tool Effective Oversight State Plan

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Policies and Procedures

Effective Oversight: Monitoring Tool

 Guides states in assuring that all federal and state laws/regulations, policies and procedures, and the contract are followed   References key areas Simplifies monitoring report/corrective action by having citations readily in hand 

Referenced Monitoring Question

CSBG Reference CEAP Reference CSBG/CEAP Questions OMB Cir. A-110, Subpart C_.21 & OMB Cir. A-102 & A-87(if app), 1 § 5.14

OMB Cir. A-110, Subpart C_.21 & OMB Cir. A-102 & A-87(if app) CEAP Contract Sect 6, 1 § 5.14

5. Are Monthly Expenditure Report () financial figures reconciled from the general ledger or accounting work papers?

Methodology: Compare for two months provided by Subrecipient with copy of brought by Program Officer. Also, review General Ledger and working papers and/or reports used to compile figures for the in review.

Referenced Monitoring Question

CSBG Reference

42U.S.C. §9901 et seq. Sect 676 (b)(11), and 10 § 5.3 and § 5.210, Contract Sect 33

Question CAP Plan

111. Has the Department received and accepted the current year Plan?

Methodology: Review current year CAP Plan and check approval date.

Referenced Monitoring Question

Monitoring Item

There is an analysis of the agency’s poverty needs and problems, the client groups at risk in its geographic area, and an analysis of the resources available to address those identified needs. (42 U.S. C9908 (b) (11); CSBG State Plan; Contract Section 2.01.5)

Referenced Monitoring Question

Topic Question

Planning Is there a community needs assessment for the community served?

Guidance

According to the CSBG statute, needs assessment refers to a systematic effort aimed at evaluating what the service requirements of the community are. It is aimed at determining what services it is essential to provide, what is available, and what is missing. A best practice for conducting a needs assessment would be for the agency to be conducting a needs assessment that is used agency-wide versus individual programs completing program-specific assessments. Needs assessments can be conducted through several methodologies including surveys, all-staff meetings, one-on-one interviews, focus groups, or community meetings. There is a regularly conducted, broad-based community needs assessment and a system is in place to utilize data in developing the agency strategic plan and in formulating program goals and objectives. Information from the needs assessment is used in formulating agency goals and objectives in which the board members were involved and approved. Information is also shared with the community, local policy makers and legislators. The agency’s needs assessment and strategic plan are utilized in seeking funding through governmental and private funding sources.

Referenced Monitoring Question

Topic Question Guidance

Customer Service Complaints What is the system for handling customer How are customers made aware of the procedures?

In an excellent agency, there are opportunities complaints/grievances? Is for customers to provide this system/process written? feedback to the agency, including complaints. This system includes ways in which to handle and assess complaints. CSBG contract requirement item # 27; LIHEAP contract requirement item # 4.

Monitoring Process is Ongoing

CAUTION…..

 Checking the boxes is not enough  Reflect back on the monitoring practices, which include state monitors should:    Look at more than compliance with program rules and regulations Assess the effectiveness of the board of directors.

Assess the administrative and leadership capacity of agency management as it relates to meeting the Board of Director’s goals.

NASCSP Monitoring Principles and Practices Congress Calls For More Accountability

Monitoring Tool

Mutual Respect

Monitoring Principles Monitoring Practices More than Compliance Joint Problem Solving

Open Communications Systems to Inform & Follow Up

Board Effectiveness Administrative Capacity

Federal Law and Applicable Regs Monitoring Tool Effective Oversight State Plan

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Policies and Procedures