Community Action Organizational Standards and Performance Management Update

1. Community Action Organizational Standards and Performance Management Update Denise Harlow dharlow@communityactionpartnership.com Region 8/10 Conference May 13-15, 2014 Boise, ID

2. Agenda • DRAFT IM on Standards Implementation • Content Highlights • OSCOE Year 2 activities • Tool and resource development • Next steps for Working Group and Committees • Dear Colleague Letter on DRAFT State and Federal Accountability Measures • Content Highlights Related to Organizational Standards • Dear Colleague Letter-April 10th • CSBG Accountability and Performance Management • Organizational Standards Walk Through • Private CAA and Public CAA Standards

3. PARTNERS’ 2013 TIMELINEMajor Milestones Quarter 1 (January – March) Quarter 2 (April - June) Quarter 3 (July - September) Quarter 4 (October - December) Third task force, detailed local, state, federal analyses, expert panels, draft recommendations Consultation on implementation/ finalization of performance framework Recommended Performance Management tools and protocols Completion of first two task forces Released and pilot tested organizational standards National listening sessions and work group process Presentation of organizational standards Training and technical assistance on standards Detailed policy brief and input process with recommendations for data changes Pilot testing updated CSBG-IS/NPI materials Revisions and updates to theory of change Revised data tools for pilot testing

4. Draft IM

5. Draft IM • Dear Colleague Letter introducing the IM in Draft form • Released March 24th • Comments were due April 25th • Main Document plus Appendices • Appendix 1: State Implementation Key Considerations • Appendix 2: COE Proposed Private Agency Standards • Appendix 3: COE Proposed Public Agency Standards Emphasis on slides has been added by the Partnership

6. Center of Excellence Submission to OCS • Four Part Document • Executive Summary • History, Background and Process • Implementation Recommendations and Framework • 56 Organizational Standards • www.communityactionpartnership.com

7. Draft IM - Introduction • Issuing Draft IM to provide guidance to the CSBG Network on the use of Organizational Standards by States. • OCS will seek authority to pursue implementation of national organizational standards for CSBG via changes in legislative authority, but has determined that voluntary implementation does not need to be delayed.” • The development of the Organizational Standards has been a collaborative process across the CSBG Network and in this spirit, OCS is first providing this guidance in draft form to solicit feedback.

8. They Went With the Standards As Is… • “This comprehensive set of organizational standards, developed by the CSBG Organizational Standards Center of Excellence (COE), has been established to ensure that all CSBG eligible entities have the capacity to provide high-quality services to low-income individuals and communities.” • No changes to the proposed language

9. Draft IM – Summary-Move Quickly • “OCS expects States to report on the establishment and implementation of organizational standards, no later than Fiscal Year 2016, in coordination with the local eligible entities, in order to increase accountability for CSBG-eligible entities” • “All State CSBG Lead Agencies are strongly encouraged to review the COE developed standards and proceed immediately with plans to coordinate with partners in the State on the establishment and implementation of organizational standards”

10. Draft IM – Summary-If Not These, Then… • “If a State establishes a different set of organizational standards, the standards must encompass requirements of the CSBG Act and other Federal requirements, such as those found in the relevant OMB Circulars, and will be subject to OCS review during the application review process. States must ensure that these alternative organizational standards are at least as rigorous and comprehensive as the COE-developed organizational standards.” • “OCS will implement new procedures for State reporting on organizational standards in upcoming CSBG Plans and CSBG Annual Reports.”

11. Draft IM – State Authority and Responsibility • Under Section 678B of the CSBG Act, 42 U.S.C § 9914, State CSBG Lead Agencies have the authority to establish and monitor goals, standards and requirements that assure an appropriate level of accountability and quality among the State’s eligible entities. • “In order to meet CSBG Act State responsibilities, all State CSBG Lead Agencies must establish and communicate standards and requirements to eligible entities. Critical areas for organizational standards are based on the requirements of the CSBG Act and the values of Community Action and include: consumer input and involvement; community engagement; community assessment; organizational leadership; board governance; strategic planning ; human resource management; financial operations and oversight; and data and analysis.”

12. Draft IM – State Authority and Responsibility • “Although a State may establish and communicate a different set of organizational standards for its eligible entities, the State must ensure that alternative organizational standards are at least as rigorous and comprehensive as the organizational standards developed by the COE. If a state establishes a different set of organizational standards, the alternative standards must encompass requirements of the CSBG Act and other Federal requirements, such as those found in the relevant OMB Circulars, as well as the critical areas noted above. Alternative standards will be subject to OCS review during the application review process.”

13. Draft IM – OCS Expectations • “The establishment of new organizational standards should include a fair and reasonable process. Whether States elect to use the COE-developed organizational standards or a different set, they should allow for input from the board and leadership of eligible entities on the timing and procedures for implementing, documenting, and reporting on the standards.” • “In addition, States have authority to supplement the COE-developed organizational standards, provided that additions or changes are implemented in a manner consistent with the CSBG Act and other applicable Federal and State requirements” • See Key Considerations in Appendix 1

14. Draft IM – OCS Expectations • “Organizational standards should be clearly communicated prior to State monitoring activities, and consistently reiterated in State CSBG plans, contracts with eligible entities, funding documents, monitoring instruments, and monitoring reports.” • Once established, a State’s organizational standards should only be modified based on established State rules and procedures that are publicly communicated and transparent.

15. Draft IM – Monitoring, Corrective Action, Reduction of Funding and Termination • States monitor whether an eligible entity meets established goals, standards, and requirements. If, as a result, State determines that that an eligible entity has deficiencies, then State must assess whether technical assistance is warranted, provide the needed training and technical assistance, and require corrective action based on a QIP. • “Failure to meet multiple requirements or standards may reflect widespread or systemic issues that cannot feasibly be corrected within a reasonable time frame. In such cases, States must assess whether additional actions are necessary, including reduction or termination of funding.” • “States may reduce funding or terminate eligibility for CSBG funding when an eligible entity fails to: 1) comply with the terms of an agreement or State plan; 2) provide services; or 3) meet appropriate standards, goals, and other requirements established by the State, including performance objectives.”

16. Draft IM – Monitoring, Corrective Action, Reduction of Funding and Termination • “Clear instances or organizational fraud, systemic abuse of funds, or criminal activity may be considered as cause for an immediate hearing on termination without the opportunity for training, technical assistance, or corrective action. On the end of the spectrum, failure to meet a single requirement or standard may more appropriately result in technical assistance or renegotiation of future performance goals.” • State CSBG agency must comply with requirements as outlined in IM 116 for terminating organizational eligibility or otherwise reducing the share of funding.

17. Draft IM - Boards • “The primary responsibility of the board is to assure that the eligible entity not only meets all Federal and State requirements, but also provides high quality services to low income people and the community served. Board members serve to protect the interests of the low-income community by making sure the eligible entity has the capacity to be successful.” • “Eligible entity boards must look beyond basic compliance to assure that the organization meets high standards of quality, accountability, and effectiveness. Therefore the organizational standards established by States should provide one basis for board review of the organization but the board must also use other accountability and oversight tools.”

18. Draft IM – State Reporting on Organizational Standards • Upcoming submissions of State CSBG plans will require a description of standards. • If using COE developed standards, will be asked to describe a timeline for implementation, and process for input and reporting from eligible entities and other stakeholders • If not using COE developed standards, will be required 1) to explain reason for using alternative standards; 2) describe alternative standards, timeline, and reporting procedures; 3) ensure that alternative standards are at least as rigorous and comprehensive • “OCS will ask all States to explain and address the absence of any standards related to the following critical areas: • consumer input and involvement; community engagement; community assessment; organizational leadership; board governance; strategic planning; human resource management; financial operations and oversight; and data and analysis”

19. Draft IM - Conclusion • Concludes with re-iterating call to action - that “State CSBG Lead Agencies are strongly encouraged to review the organizational standards developed by the CSBG Organizational Standards COE, and should proceed immediately with plans to coordinate with partners in the State on the establishment and implementation of organizational standards.”

20. Draft IM – Appendix 1 • State Implementation of Organizational Standards – Key Considerations • Table of 9 Critical Action Areas with description and Critical Partners and Available Resources

21. Draft IM – Appendix 1

22. Draft IM – Appendix 1

23. Draft IM –Appendix 1

24. Draft IM – Appendix 1

25. Draft IM - Appendices 2 & 3 • Standards as proposed – no changes in language or organization • Presented as separated between Private and Public standards

26. OSCOE Year 2 Activities in Response

27. Year 2 OSCOE Activities • National Webinar- April 11th (recording and slides posted on Partnership website) • Regional Webinars as requested • Upcoming Conference Presentations • Tools and Resources • Guide that links each Standard to an existing tool/resource • Drafting Additional Written Guidance • Drafting Definitions List • Learning Cluster for States on Implementation • Offering to hold State Webinars on Standards • Held NASCSP-Sponsored Webinar on March 19th • Track Implementation

28. Next Steps for Working Group and Committees

29. Committee Next Steps • Identify Terms and Phrases needing definitions to assist with consistency • Develop Guidance by Category • List of Tools/Resources by category • Board Module and/or videos • Change Management • Implementation Framework/Where do I start? • Training Modules for State Monitors • ID Agencies who do a good job – peer-to-peer learning

30. How Can CAAs, Associations, and State CSBG Offices Prepare? • Keep lines of communication open between State CSBG Offices, CAAs, and State Associations • CAAs - establish Staff Committee to assess the CAA against the proposed Organizational Standards and develop plan of action • Department Heads, Fiscal, HR, Planning, etc. • Keep Board of Directors informed of efforts through formal reporting • Include the Standards in organizational and department strategic planning discussions and work plans • Work with your State Association to inform and train CAAs in your state on Standards • Include ramp-up to meet Standards in CSBG work plans • Review CSBG State Plans and CAA Contracts for where Standards language will be appropriate in include • Assess current state rules and regulations for needed changes.

31. Tools Already Available to Help CAAs Meet the Standards

32. www.communityactionpartnership.com

33. CSBG T/TA Resource Center • www.csbgtta.org • Many more toolkits, webinars, and print resources • Consultant Bank • Training Calendar • Discussion Forum • Shared Calendar • Individual registrations for Board and Staff

34. State and Federal Accountability Measures Related to Organizational Standards

35. State and Federal Accountability Measures • Dear Colleague Letter-2/28/14 • Comments due to csbg-feedback@urban.org by April 4, 2014 • Core Areas: • State Plans, Contracts, Fund Disbursement, T/TA, Monitoring, Corrective Action Plans • States: 23 in Year 1; 32 in Year 3 • Federal: 16 in Year 1; 21 in Year 3 • Uses FFY 2015 Baseline • Using counts, measures, yes/no • Limited number of measures • “These proposed measures are intended to ensure that both State and Federal administrators of CSBG are accountable to high standards of performance management.” Emphasis on slides has been added by the Partnership

37. 6S Organizational Standards-STATES

38. 7S. Training and Technical Assistance-STATES

39. 5F. Organizational Standards-FEDERAL

40. 6F. Training and Technical Assistance-FEDERAL

41. April 10th Dear Colleague Letter

42. Clarity on Timing for States for State Plans and Annual Reports • “OCS understands that States are beginning to develop State Plans and applications for FY 2015 funding, due on September 1, 2014. States may have concerns about whether and how to integrate the new accountability and performance management strategies into their plans.” • “States will not be required to include the CSBG Organizational Standards, the State Accountability Measures, or the new ROMA reporting requirements in their applications and State Plans until FY 2016. We encourage States to prepare for implementation of these accountability and performance management strategies for FY 2016 and take advantage of training and technical assistance opportunities in the coming months and during FY 2015.” • Note: FY 2016 begins 10/1/15

43. Timing on Other Components • For State and Federal Accountability Measures • “We expect implementation of these measures by FY 2016.” • “OCS, along with the Urban Institute, will host future webinars and disseminate information about implementation of these measures.” • For ROMA Next Generation • “We are targeting full implementation of new ROMA tools and reporting by FY 2016.”

44. Where Does That Leave Us... • October 1, 2015 will be a very important date • This is only 17 months away • For perspective…. • 17 months ago today, we had already convened the CSBG Working Group to start the development of the Organizational Standards • 17 months ago last week, the CSBG Working Group Committees were meeting for the first time • 17 months ago this week, the first Performance Management Task Force Meeting that was being held December 5-6, 2012 • What can be in place October 1, 2014?

45. Where Does That Leave Us… • Be ready for Standards as soon as possible so that when changes on reporting come out, this work is well underway • Keep lines of communication between CAAs, Associations, and State Offices Open • Convene regular statewide conference calls or meetings • CAAs-Invest now in shoring up those areas where your CAA may fall short. • CAAs-Develop a formal plan to meet the Standards • States-Look at current monitoring tools and identify where the Standards components need to be added; talk with Legal Departments now to have your language/documents vetted where needed • States- Take a close look at the State and Federal Accountability Measures to see where to invest now to shore up areas where your State may fall short

46. Organizational Performance Standards Operations and Accountability Fiscal Human Resources Data and Analysis • Maximum Feasible Participation • Consumer Input • Community Engagement • Community Assessment • Vision and Direction • Leadership • Governance • Strategic Planning

47. Maximum Feasible Participation Category 1: Consumer Input and Involvement

48. Maximum Feasible ParticipationConsumer Input and Involvement • Standard 1.1 • private The Organization demonstrates low-income participation in its activities. • Standard 1.1 • public The Department demonstrates low-income participation in its activities.

49. Maximum Feasible ParticipationConsumer Input and Involvement • Standard 1.2 • private The Organization analyzes information collected directly from low-income individuals as part of the Community Assessment. • Standard 1.2 • public The Department analyzes information collected directly from low-income individuals as part of the Community Assessment.

50. Maximum Feasible ParticipationConsumer Input and Involvement • Standard 1.3 • private The Organization has a systematic approach for collecting, analyzing, and reporting customer satisfaction data to the governing board. • Standard 1.3 • public The Department has a systematic approach for collecting, analyzing, and reporting customer satisfaction data to the tripartite/advisory board, which may be met through broader local government processes.