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
5
Effective
Oversight
Policies and Procedures
State Plan
A Systems View of
Monitoring
WIA
CSBG
LIHEAP
Head
Start
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 multifaceted 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
NASCSP
Monitoring
Principles
OCS Information
Memorandums
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
Administrator
Program
Monitor
Program at
Agency
#1
Program at
Agency
#2
Fiscal Monitor
Program at
Agency
#3
Program
Finances at
Agency #1
Program
Finances at
Agency #2
Program
Finances at
Agency #3
ABC Community Action
Board of
Directors
Executive
Director
CSBG
CSBG Staff
Head Start
Head Start
Staff
Weatherization
Weatherization
Staff
LIHEAP
LIHEAP Staff
Brown Buckley Tucker
Housing
Housing Staff
Finance
Finance Staff
A System for Monitoring
Integrated Monitoring
Structure
Monitoring
Tool
Staff
Training
Collaborative
Relationships
Dynamics of
Change
HUD
Weatherization Head Start
ABC Community Action
Governance
Fiscal Policies
& Procedures
Planning:
Mission & Planning
Admin. Systems
& Procedures
Programs
Evaluation
Partnerships
Outcomes
Brown Buckley Tucker
Monitoring as oversight…
Federal Law and
Applicable Regs
Monitoring
Tool
23
Effective
Oversight
Policies and Procedures
State Plan
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
Are Monthly
OMB Cir. A-110, OMB Cir. A-110, 5.Expenditure
Report ()
Subpart C_.21 & Subpart C_.21 & financial figures reconciled
the general ledger or
OMB Cir. A-102 OMB Cir. A-102 from
accounting work papers?
Methodology: Compare for
& A-87(if app), 1 & A-87(if app)
two months provided by
§ 5.14
CEAP Contract
Subrecipient with copy of
brought by Program Officer.
Sect 6, 1
Also, review General
§ 5.14
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
Customer Service What is the system for
Complaints
handling customer
complaints/grievances? Is
this system/process written?
How are customers made
aware of the procedures?
Guidance
In an excellent agency,
there are opportunities
for customers to provide
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
Monitoring
Principles
Monitoring
Practices
More than
Compliance
Mutual
Respect
Joint Problem
Solving
Open
Communications
Systems to Inform
& Follow Up
Board
Effectiveness
Administrative
Capacity
Federal Law and
Applicable Regs
Monitoring
Tool
33
Effective
Oversight
Policies and Procedures
State Plan