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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 8.1

Private
The organization’s annual audit (or audited financial statements) is completed by a Certified Public Accountant on time in accordance with Title 2 of the Code of Federal Regulations, Uniform Administration Requirements, Cost Principles, and Audit Requirement (if applicable) and/or State audit threshold requirements.

Public
The department’s annual audit is completed through the local governmental process in accordance with Title 2 of the Code of Federal Regulations, Uniform Administrative Requirements, Cost Principles, and Audit Requirement (if applicable) and/or State audit threshold requirements. This may be included in the municipal entity’s full audit.

CAPLAW Resource:

  • 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 2. Improving a CAA’s Financial Capacity of the Tool specifically addresses the role of an audit, how to get the most out of an audit, management’s role in preparing for the audit, the audit committee and management letters.

CAPLAW/Partnership Resources:

  • 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 I of Chapter Three: Financial Management of Federal Grants addresses the Single Audit requirements under the Uniform Guidance including the role of board and management in a Single Audit.
  • 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 I. Roles and Responsibilities of the Guide includes a brief discussion of board and management roles around the audit.

Standard 8.2

Private
All findings from the prior year’s annual audit have been assessed by the organization and addressed where the governing board has deemed it appropriate.

Public
The department follows local government procedures in addressing any audit findings related to CSBG funding.

Resource:

  • See Standard 8.1

Standard 8.3

Private
The organization’s auditor presents the audit to the governing board.

Public
The department’s tripartite board/advisory body is notified of the availability of the local government audit.

Resource: 

  • See Standard 8.1

Standard 8.4

Private
The governing board formally receives and accepts the audit.

Public
The department’s tripartite board/advisory body is notified of any findings related to CSBG funding.

Resource:

  • See Standard 8.1

Standard 8.5

Private
The organization has solicited bids for its audit within the past 5 years.

Public
Not applicable: The audit bid process is outside of the purview of tripartite board/advisory body therefore this standard does not apply to public entities.

Resource:

  • See Standards 8.1 and 8.11

Standard 8.6

Private
The IRS Form 990 is completed annually and made available to the governing board for review.

Public
Not applicable: The Federal tax reporting process for local governments is outside of the purview of tripartite board/advisory body therefore this standard does not apply to public entities.

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 G of Chapter Four. General Tax-Exempt Organization Requirements provides a brief overview of the Form 990.

Standard 8.7

Private
The governing board receives financial reports at each regular meeting that include the following:

  1. Organization-wide report on revenue and expenditures that compares budget to actual, categorized by program; and
  2. Balance sheet/statement of financial position.

Public
The tripartite board/advisory body receives financial reports at each regular meeting, for those program(s) the body advises, as allowed by local government procedure.

CAPLAW Resources:

  • Helping Boards Be Responsible Fiscal Stewards, Fall 2011 CAPLAW Update. This Article discusses the level of financial awareness board members should have and the receipt of information that will improve that awareness.
  • More than Math: The Board’s Role in Financial Oversight and Monitoring (2011). This Webinar emphasizes why all CAA board members must focus on their CAA’s finances if the board is to avoid problems and properly discharge its fiduciary duties. The Webinar is designed to give board members, who are not experts in finance or accounting, tools that enable them to participate in the discussion of their CAA’s financial issues.
  • 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 4. Getting the Most Out of Your Financial Statements of the Tool uses scenarios and examples to discuss how management and boards use financial statements and also examines the information included in such statements.

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. Chapter Three: Financial Management of Federal Grants focuses on the requirements applicable to the federal funds CAAs receive and covers topics such as the history and applicability of the Uniform Guidance to financial management systems and treatment of costs; Single Audit requirements; nonprofit CAA financial statements; and annual budgets.

Standard 8.8

Private
All required filings and payments related to payroll withholdings are completed on time.

Public
Not applicable: The payroll withholding process for local governments is outside of the purview of the department, therefore this standard does not apply to public entities.

Standard 8.9

Private
The governing board annually approves an organization-wide budget.

Public
The tripartite board/advisory body has input as allowed by local governmental procedure into the CSBG budget process.

CAPLAW Resources:

  • Budget Builders: Who Does What? Why is it Important (2011). This Webinar provides practical strategies to organize your annual budget development and approval process amidst uncertainty and ongoing financial stress. This Webinar also explores multiple approaches to obtain meaningful board and staff input on key choices and build buy-in and support for the budget which emerges.
  • Agency-wide Budgeting: Counting Every Dollar Because Every Dollar Counts (2011). This Webinar uses a model, agency-wide budget to help attendees learn how to diagnose occurrences of duplicate funding; identify the size and timing of funding gaps; establish timelines and contingency plans if case funding doesn’t materialize; recognize vulnerable positions and the appropriate personnel actions that may be required; and use advance knowledge and planning to mitigate financial risk.
  • 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 3. Creating the Annual Budget of the Tool uses examples to walk though the building of an annual budget and includes information about identifying and allocating cost as well as complying with grant requirements.

CAPLAW/Partnership Resources:

  • CAA Leader’s Legal Guide (2016). This Guide provides CAA leaders of CAAs with an overview of many of the legal requirements that they will work with on a regular basis. Section J. of Chapter Three: Financial Management of Federal Grants provides a brief overview of an organization’s annual budget.
  • 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 I. Roles and Responsibilities of the Guide includes a brief discussion of board and management roles in creating the annual budget.

Standard 8.10

Private
The fiscal policies have been reviewed by staff within the past 2 years, updated as necessary, with changes approved by the governing board.

Public
Not applicable: The fiscal policies for local governments are outside of the purview of the department and the tripartite board/advisory body, therefore this standard does not apply to public entities.

Standard 8.11

Private
A written procurement policy is in place and has been reviewed by the governing board within the past 5 years.

Public
Not applicable: Local governmental procurement 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/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 Three: Financial Management of Federal Grants includes a discussion of the procurement requirements in the Uniform Guidance.

CAPLAW Resource:

  • Sample Procurement Policy (2020). This policy includes sections on code of conduct, requirements and considerations, procurement methods and procedures, contract provisions, and documentation, and may serve as a starting point for your CAA in reviewing and updating its procurement policy.

Standard 8.12

Private
The organization documents how it allocates shared costs through an indirect cost rate or through a written cost allocation plan.

Public
Not applicable: A written cost allocation plan is outside of the purview of the department and the tripartite board/advisory body, therefore this standard does not apply to public entities.

CAPLAW Resources:

CAPLAW/Partnership Resource:

  • Cost Allocation: Red Flags and Remedies (2012). Generally, the issuance of the Uniform Guidance affected neither the ability of CAAs to use cost allocation plans nor the general principles that govern the allowability of cost allocated pursuant to such plans. This Toolkit, though not updated for the Uniform Guidance, still provides CAAs with ways to develop and implement effective and sound approaches to cost allocation.

Standard 8.13

Private
The organization has a written policy in place for record retention and destruction.

Public
The department follows local governmental policies for document retention and destruction.

CAPLAW Resources:

  • Records Management 101, Summer 2012, CAPLAW Update. This Article discusses the basics of record management including a brief discussion of legal compliance and record management systems.
  • Records Management 101: First Steps to a Successful Record Management Program (2012). This Webinar considers some basic records management concepts, initial steps to take in planning and organizing records, how to create a file plan, and, how to create a record retention schedule.
  • Sample Record Retention Policy (2012). Even though this Policy has yet to be updated for the Uniform Guidance, many of the concepts in the Policy were not affected by the issuance of the Uniform Guidance. Thus, the Policy may still serve as a starting point for your CAA in reviewing and updating its own record retention policy.

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.