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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.

Standard 7.1

Private
The organization has written personnel policies that have been reviewed by an attorney and approved by the governing board within the past 5 years.

Public
Not applicable: Local governmental personnel policies are outside of the purview of the department and the tripartite board/ advisory body, therefore this standard does not apply to public entities.

CAPLAW Resource:

  • Working With Attorneys Guidebook (2016 edition). This Guidebook examines how CAAs can find, hire, pay for, and work with an attorney.
  • Practical NLRB Guidance Regarding Personnel Policies, eNews Bulletin, June 2015. This article briefly discusses a National Labor Relations Board report which analyzes a wide range of policies contained in an employee handbook as they relate to the National Labor Relations Act Section 7. Section 7 provides that all workers, both unionized and non-unionized, with a right to engage in concerted (or group) activity for purposes of collective bargaining, mutual aid or protection.

Standard 7.2

Private
The organization makes available the employee handbook (or personnel policies in cases without a handbook) to all staff and notifies staff of any changes.

Public
The department follows local governmental policies in making available the employee handbook (or personnel policies in cases without a handbook) to all staff and in notifying staff of any changes.

Standard 7.3

Private
The organization has written job descriptions for all positions, which have been updated within the past 5 years.

Public
The department has written job descriptions for all positions. Updates may be outside of the purview of the department.

Standard 7.4

Private
The governing board conducts a performance appraisal of the CEO/executive director within each calendar year.

Public
The department follows local government procedures for performance appraisal of the department head.

CAPLAW/Partnership Resource:

Standard 7.5

Private
The governing board reviews and approves CEO/executive director compensation within every calendar year.

Public
The compensation of the department head is made available according to local government procedure.

CAPLAW/Partnership Resource:

  • CAA Leader’s Legal Guide (2016). This Guide provides CAA leaders with an overview of many of the legal requirements that they will work with on a regular basis. Section F of Chapter Four: General Tx-Exempt Organization Requirements, addresses the IRS requirements that apply when setting an executive director’s salary and the process to follow for such compensation to be presumed reasonable.
  • Dynamic Duo: A Guide to Enhancing the Board & Executive Director Partnership (2015). This Guide generally addresses how CAAs can navigate the relationship between the board and executive director. Section VI. Executive Director Compensation of the Guide specifically discusses the legal considerations and process to be sued when reviewing and setting the executive director’s compensation.

Standard 7.6

Private
The organization has a policy in place for regular written evaluation of employees by their supervisors.

Public
The department follows local governmental policies for regular written evaluation of employees by their supervisors.

Standard 7.7

Private
The organization has a whistleblower policy that has been approved by the governing board.

Public
The department provides a copy of any existing local government whistleblower policy to members of the tripartite board/advisory body at the time of orientation.


CAPLAW Resources:

  • Sample Whistleblower & Complaint Resolution Policy (2012). This sample Policy should be reviewed carefully, preferably with your local attorney, to determine how to tailor it to meet your CAA’s needs and the requirements of current state laws, if applicable.
  • Sample Whistleblower & Complaint Resolution Policy for Head Start Grantees (2012). This sample Policy should be reviewed carefully, preferably with your local attorney, to determine how to tailor it to meet your CAA’s needs and the requirements of current state laws, if applicable.
  • Whistleblower Polices (2012). This Webinar addresses the legal requirements for whistleblower policies and how to create and implement effective policies for your CAA.
  • Do the Right Thing: How to Cultivate a Culture of Compliance and High Ethical Standards (2016 edition). This Guidebook 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. Throughout the Guide are discussions about the importance of whistleblower policies, the vital role they play in establishing an ethical environment, and the practical impact of such polices 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 6. Adopting a Whistleblower Policy of the Tool specifically addresses the legal background behind whistleblower policies, the elements of a policy, the internal process for addressing whistleblower complaints, the role of legal counsel, the documentation and tracking of whistleblower reports and the establishment of an environment that supports whistleblower reporting.

Standard 7.8

Private
All staff participate in a new employee orientation within 60 days of hire.

Public
The department follows local governmental policies for new employee orientation.

Standard 7.9

Private
The organization conducts or makes available staff development/training (including ROMA) on an ongoing basis.

Public
The department conducts or makes available staff development/training (including ROMA) on an ongoing basis.

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.