Page 1 of 73
Page 2 of 73
Table of Contents
Information Memoranda ............................................................................................................................. 4
Preface .......................................................................................................................................................... 6
SECTION 1 – NONDISCRIMINATION ............................................................................................................. 7
1000 NONDISCRIMINATION .............................................................................................................. 7
SECTION 2 – PROGRAM SCOPE .................................................................................................................... 8
2000 SERVICES AND ACTIVITIES ........................................................................................................ 8
SECTION 3 – STATE PLAN, FUNDING AND PROGRAM CYCLES .................................................................. 10
3000 CSBG STATE PLAN ................................................................................................................... 10
3100 FUNDING CYCLE ...................................................................................................................... 11
3200 ALLOCATION ........................................................................................................................... 11
3300 PROGRAM YEAR ..................................................................................................................... 12
SECTION 4 – GRANT ADMINISTRATION ..................................................................................................... 14
4000 TRAINING AND TECHNICAL ASSISTANCE ............................................................................... 14
4101 MONITORING ......................................................................................................................... 14
4200 CSBG ORGANIZATIONAL STANDARDS ................................................................................... 16
4300 CORRECTIVE ACTION .............................................................................................................. 17
4400 DESIGNATION AS “HIGH RISK” ............................................................................................... 19
4500 DESIGNATION AND DE-DESIGNATION ................................................................................... 20
4600 PROGRAM REPORTS ............................................................................................................... 21
SECTION 5 – GRANT APPLICATION AND PROCEDURES ............................................................................. 24
5000 APPLICATIONS for CSBG Non-Discretionary and/or CSBG Discretionary Funds .................. 24
5100 APPLICATION REVIEW ............................................................................................................ 25
5200 GRANT AWARD ...................................................................................................................... 25
5300 GRANT REVISIONS .................................................................................................................. 26
5400 AWARD AMOUNTS................................................................................................................. 27
5500 CARRY-OVER FUNDS .............................................................................................................. 28
SECTION 6 – GOVERNING BOARDS ............................................................................................................ 30
6100 BOARD COMPOSITION ........................................................................................................... 30
6200 BOARD ROLES AND RESPONSIBILITIES .................................................................................. 33
6300 BYLAWS’ REQUIREMENTS ...................................................................................................... 35
6400 ALLOWABLE COSTS ................................................................................................................. 38
6500 GENERAL ................................................................................................................................. 38
Page 3 of 73
6600 ADMINISTERING BOARDS ..................................................................................................... 39
SECTION 7 – PLANNING .............................................................................................................................. 41
7000 COMMUNITY ASSESSMENT.................................................................................................... 41
7100 STRATEGIC PLAN ..................................................................................................................... 42
7200 CALENDAR OF PLANNING ACTIVITIES .................................................................................... 43
SECTION 8 – SERVICE DELIVERY ................................................................................................................. 44
8000 GENERAL ................................................................................................................................. 44
SECTION 9 – FISCAL POLICIES AND PROCEDURES ...................................................................................... 49
9000 GENERAL ................................................................................................................................. 49
9100 GRANT TRANSACTION REPORTING ........................................................................................ 50
9200 EXPENDITURES........................................................................................................................ 52
9300 PROPERTY MANAGEMENT ..................................................................................................... 53
9400 BONDING AND INSURANCE ................................................................................................... 54
9500 RETENTION OF RECORDS ........................................................................................................ 55
9600 AUDITS .................................................................................................................................... 55
SECTION 10 – PERSONNEL POLICIES AND PROCEDURES ........................................................................... 57
10000 GENERAL ................................................................................................................................. 57
10100 CODE OF ETHICS ...................................................................................................................... 60
10200 THE FEDERAL HATCH ACT ....................................................................................................... 61
SECTION 11 – GENERAL .............................................................................................................................. 65
11000 CITIZEN ACCESS AND PRIVACY ............................................................................................... 65
11200 COORDINATION WITH Kansas LIEAP ..................................................................................... 65
11300 COORDINATION WITH OTHERS INCLUDING WORKFORCE SYSTEMS .................................... 66
11400 COMPLAINTS/APPEALS .......................................................................................................... 67
SECTION 12 – DISCRETIONARY FUNDS ...................................................................................................... 69
12000 GENERAL ................................................................................................................................. 69
12200 FUNDING GUIDANCE .............................................................................................................. 70
12300 REPORTING REQUIREMENTS .................................................................................................. 70
12400 MONITORING .......................................................................................................................... 70
DEFINITIONS ............................................................................................................................................... 71
Page 4 of 73
Information Memoranda
The Office of Community Services, Division of State Assistance, publishes Information
Memoranda (IM) for distribution to CSBG program administrators. An Information
Memoranda (IM) provides guidance to assist in implementing the CSBG legislation, program
instruction and policy clarification, in addition to disseminating information and program
practices to stakeholders.
2018
IM No. 154 CSBG Flexibilities and Waiver Requests, March 7, 2018
2017
IM No. 152 CSBG Annual Report, January 19, 2017
IM No. 151 CSBG Training and Technical Assistance Strategy, January 19, 2017
2016
IM No. 150 Use of the American Customer Satisfaction Index (ACSI) to Improve Network
Effectiveness, August 22, 2016
IM No. 149 Strengthening Outcomes Through Two-Generation Approaches, August 15, 2016
IM No. 144 CSBG State and Federal Accountability Measures and Data Collection
Modernization, October 2, 2016
2015
IM No. 138 State Establishment of Organizational Standards for CSBG Eligible Entities , January
26, 2015
2011
IM No. 123 Reorganization of CSBG T/TA Resources – A New Strategy for Excellence, May 2011
2010
IM No. 116 Corrective Action, Termination, or Reduction of Funding, April 2, 2010
2005
IM No. 82 Tripartite Boards, March 23, 2005
Page 5 of 73
Page 6 of 73
Preface
The Kansas Housing Resources Corporation (KHRC) has been designated by the Governor
as the lead agency for purposes of carrying out Kansas activities under the Community
Services Block Grant (CSBG). Responsibility for the implementation of CSBG rests within
KHRC’s Community Solutions Division.
KHRC’s administration of CSBG is governed by the Coats Human Services Reauthorization
Act of 1998 (commonly referred to as the CSBG Reauthorization Act of 1998), 42 USC §
9901, et seq., as amended, Notices of Financial Award and Grant Agreements, this Kansas
Community Services Block Grant Manual of Policies and Procedures and OMB Uniform
Guidance. In the case of ambiguity or conflict, the following order of precedence must
govern.
1. Enabling CSBG Legislation
2. Applicable OMB Uniform Guidance or Circulars
3. Kansas Form DA-146a
4. Applicable Department of Health and Human Services Terms and Conditions
5. Notice of Award (NOA) and Grant Agreement
6. Kansas Community Services Block Grant Manual of Policies and Procedures
Organizations granted CSBG funds must conform to the applicable laws, policies and
procedures contained within these documents. Failure to do so jeopardizes CSBG funding.
KHRC is pleased to administer CSBG; we know that the work that CSBG supports changes
people’s lives, embodies the spirit of hope, improves communities, and makes Kansas a
better place. We care about our great state and through many KHRC programs, including
CSBG, share with our partners a dedication to helping people gain the skills, assets and
supports that promote economic mobility and greater independence.
Sincerely,
Ryan Vincent, Executive Director
Kansas Housing Resources Corporation
Page 7 of 73
SECTION 1: NONDISCRIMINATION
1000 NONDISCRIMINATION
1001. The Federal Civil Rights Act of 1964 as amended (42 USC § 2000d) and the Kansas Act
Against Discrimination prohibit discrimination on the grounds of color, religion, sex, or
national origin. No person may be discriminated against on these grounds in applying for or
participating in Federal or State funded assistance or programs.
1002. Any program or activity supported by funds from KHRC must comply with these Acts as
well as other Federal and State statutes relating to nondiscrimination, including but not
limited to:
A. Title IX of the Education Amendments of 1972 which states that no person, on the basis
of sex, shall be excluded from participation in, be denied the benefits of or be subjected
to discrimination under any education program or activity receiving Federal financial
assistance.
B. Americans and Disabilities Act (ADA) as amended (42 USC § 12101 et seq.) which
requires that any person otherwise qualified with a disability shall not be excluded from
participation in or denied the benefits of or otherwise subjected to discrimination in any
program or activity receiving Federal assistance, by reason of that disability.
C. The 1975 Age Discrimination Act as amended (42 USC § 6101 et seq.) provides that no
person shall be excluded from participation, denied program benefits, or subjected to
discrimination on the basis of age, under any program or activity receiving Federal
funds.
D. Other Federal, State, or local nondiscrimination statutes which may apply.
Page 8 of 73
SECTION 2: PROGRAM SCOPE
2000 SERVICES AND ACTIVITIES
2001. The Community Action Program was established over 50 years ago through the
Economic Opportunity Act of 1964 as a centerpiece in the War on Poverty. The purpose was
“to provide stimulation and incentive for urban and rural communities to mobilize their
resources to combat poverty.”
2002. President Reagan, through the Omnibus Budget Reconciliation Act of 1981, consolidated
domestic social programs into several large block grants, including the Community Services
Block Grant. Responsibility for administering the block grant programs was delegated to the
states.
2003. The Community Services Block Grant (CSBG) was most recently authorized in 1998
through Title II of the Coats Human Services Reauthorization Act of 1998. The legislation’s
purpose is “to provide assistance to States and local communities, working through a
network of community action agencies and other neighborhood-based organizations, for
the reduction of poverty, the revitalization of low-income communities, and the
empowerment of low- income families and individuals in rural and urban areas to become
fully self- sufficient.” This is to be accomplished through:
A. “The strengthening of community capabilities for planning and coordinating the use of a
broad range of Federal, State, local and other assistance (including private resources)
related to the elimination of poverty, so that this assistance can be used in a manner
responsive to local needs and conditions,
B. “The organization of a range of services related to the needs of low- income families and
individuals, so that these services may have a measurable and potentially major impact
on the causes of poverty in the community and may help the families and individuals to
achieve self- sufficiency,
C. “The greater use of innovative and effective community-based approaches to attacking
the causes and effects of poverty and of community breakdown,”
D. “The maximum participation of residents of the low-income communities and members
of the groups served by programs assisted through the block grants . . . to empower
such residents and members to respond to the unique problems and needs within their
communities and
Page 9 of 73
E. “The broadening of the resource base of programs directed to the elimination of
poverty so as to secure a more active role in the provision of services for private,
religious, charitable and neighborhood-based organizations; and individual citizens and
business, labor and professional groups, who are able to influence the quantity and
quality of opportunities and services for the poor.”
2004. CSBG activities are carried out by a national network of nearly 1,000 CSBG Eligible
Entities, mostly Community Action Agencies, which provide a diverse array of services for,
and advocacy on behalf of, low-income individuals and families. Eight such entities exist in
Kansas.
A. An eligible entity is one that carried a designation as a CSBG Eligible Entity (Community
Action Agency) or was a qualifying organization serving migrant or seasonal farm
workers as of the day before the enactment of the Coats Human Services
Reauthorization Act of 1998, has retained that designation and has a tripartite board or
one that, subsequent to and in accordance with statute, has been designated by the
Governor.
2005. Three overarching community action goals from the National Theory of Change for
Community Action guide the work of the CSBG network:
A. Individuals and families with low incomes are stable and achieve economic security.
B. Communities where people with low incomes live are healthy and offer economic
security.
C. People with low incomes are engaged and active in building opportunities in
communities.
Page 10 of 73
SECTION 3: STATE PLAN, FUNDING AND PROGRAM CYCLES
3000 CSBG STATE PLAN
3001. The CSBG legislation requires that states submit state plans to the Office of Community
Services (OCS), U.S. Department of Health and Human Services (HHS). State plans are to
describe the states’ proposed use of CSBG funds and include assurances that CSBG will be
used in accordance with legislative intent. State plans are due on or before September 1
preceding the start of the Federal fiscal year for which funds are granted from HHS to the
states.
3002. KHRC, in consultation with the Kansas CSBG Network, will prepare a draft State Plan, by
August 1 or as soon as possible after receiving instructions from OCS.
A. The draft Kansas State Plan will be posted to the KHRC website. KHRC will alert the
Community Action Agencies and Kansas Association of Community Action Programs
(KACAP) to the posting.
B. Prior to the submission of the Kansas State Plan to OCS, KHRC will identify a date, time,
and location for two public hearings. The first public hearing will be held in conjunction
with the KACAP Board of Directors meeting and will solicit input from the attendees on
the draft of the state plan. The second public hearing will be held at KHRC or alternative
location and/or virtually. During the final public hearing, KHRC will present the final
state plan and receive comments. Both hearings will be open to the public.
C. Notice of the State Plan public hearings will be published in the Kansas Register. The
Community Action Agencies and KACAP will be provided written notice of the public
hearing at least thirty (30) days in advance of the hearing.
D. Written comments will be accepted by KHRC up to the date of the final public hearing.
Written comments received accordingly, and testimony provided at the public hearing
will be reviewed by the CSBG Program Manager. Written comments and testimony
received during the public hearings must be submitted to OCS with the State Plan and
made available upon request.
E. Revisions to the Kansas State Plan may be made in response to written and verbal
comments.
Page 11 of 73
F. The Plan will cover a period of not less than one Federal fiscal year and not more than
two Federal fiscal years.
3003. The State holds at least one legislative hearing every three years in conjunction with the
development of the State Plan. These hearings usually take place in the first quarter of the
calendar year. KHRC will present testimony on the uses and value of CSBG funds at the
legislative hearing.
3004. Within three business days of receiving notification that the legislative hearing has been
scheduled, KHRC will notify all Community Action Agencies and KACAP of the time and place
of the hearing. Notice of the legislative hearing will be posted to the KHRC website.
Interested parties may be invited to offer testimony. Testimony and legislator comments
are considered in drafting the subsequent Kansas State Plan.
3100 FUNDING CYCLE
3101. States are required to pass through 90 percent of their CSBG allocation to Community
Action Agencies. No more than 5 percent of the allocation may be used for the State’s
administrative expenses. The remaining CSBG funds may be used at the State’s discretion to
support activities consistent with the purposes of the CSBG legislation.
3102. The funding cycle for CSBG, Federal to State, is the Federal fiscal year. Though the
Federal fiscal year starts on October 1, Federal budget dynamics often delay, by several
months, the allocation of CSBG dollars to the states.
3103. Community Action Agencies may request funds prior to the start of the new program
year. Advance payment requests must be submitted in writing to the CSBG Program
Manager with an explanation of the need for the advance payment.
3200 ALLOCATION
3201. The CSBG allocation formula considers total population for whom poverty status is
determined, low-income population (below poverty level) and territory (square mileage)
and is re-calculated each year prior to submission of the State Plan. Using the current
America Community Survey 5-year estimates (S1701), total population for whom poverty
status is determined and low-income population is identified for each county. Counties
are grouped by eligible entity. Each agency’s percentage share of the State’s total
population and the percentage share of the State’s low-income population is calculated.
Territory is determined by using square mileage as calculated for use with the most
recent Census (http://www.indexmundi.com/facts/united-states/quick-
Page 12 of 73
facts/kansas/land-area#table). Counties are grouped by eligible entity. Each agency’s
percentage share of the State’s total square mileage is calculated.
Each element (total population, low-income population, and territory) is assigned a
weight: total population at one percent; low-income population at ninety percent and
territory at nine percent; these weighted values are summed to achieve the agency’s
proportionate share.
For each agency, the total of the assigned values (total population value plus low-income
population value plus territory value) is multiplied by the estimated pass-through amount
(90% of current year Kansas CSBG allocation). The result is the agency’s FFY 20XX
proportionate share in dollars.
*Note: Allocations were not recalculated during 2021 due to COVID.
CSBG Eligible Entity
2019 Proportionate
Share of pass- through
amount
2020 Proportionate
Share of pass-
through amount
2022 Proportionate
Share of pass-
through amount
WSCCAP
17.91%
18.70%
17.93%
SEK-CAP
8.59%
8.83%
8.73%
Economic Opportunity
Foundation
8.84%
8.70%
9.32%
ECKAN
18.21%
18.02%
18.59%
NEK-CAP
10.29%
10.51%
11.24%
Mid-KS CAP
10.89%
11.21%
11.68%
Community Action, Inc
13.07%
11.66%
10.61%
Harvest America
Corporation
12.20%
12.37%
11.89%
3300 PROGRAM YEAR
3301. The program year for Kansas CSBG is April 1 through March 31. To mitigate delays
typical within the Federal budget process, KHRC issues pass-through CSBG grants to
Community Action Agencies six months after the start of the Federal fiscal year;
continuation grants coincide with the Kansas CSBG program year. Accordingly, Community
Action Agencies must build their budgets and structure their use of the annual awards on
the twelve-month (April through March) program year. Community Action Agencies are,
however, provided a grant period of eighteen months (April through September) to
disburse/expend their CSBG awards.
3302. At the request of an agency, due to need, advance payments can be made on a case-by-
case basis any time after the CSBG allocation has been made to the state.
Page 13 of 73
(This page is intentionally left blank)
Page 14 of 73
SECTION 4: GRANT ADMINISTRATION
4000 TRAINING AND TECHNICAL ASSISTANCE
4001. KHRC, as the lead state agency, has responsibility for providing entities receiving CSBG
funds with a range of technical assistance and training in order to establish and maintain
sound grants management and program practices. KHRC works in collaboration with KACAP
to determine the training and technical assistance needs of the CSBG network. Technical
assistance may be provided by KHRC, KACAP or through a contract with a third party.
4002. As part of the application and budget process, KHRC staff will be available to assist with
the development of Community Action Plans and budgets that meet application standards.
Technical assistance will be responsive to individual need.
4101 MONITORING
4101. Monitoring is an on-going process and is not limited to the periodic “on-site monitoring
visit.” The on-going process includes review of grant applications, KanDo! ROMA quarterly
reports, monthly Grant Transaction Reports, independent audit reports, governing board
meeting notices, agendas and minutes and the review of monitoring reports from other
oversight and funding entities.
4102. To the extent feasible, KHRC incorporates the CSBG Monitoring Standards, as published
by NASCSP (September 2017), in the KHRC monitoring process.
A. KHRC will follow the three monitoring principles described in the NASCSP’s CSBG
Monitoring Standards guidance.
I. Mutual Respect – State CSBG offices value and recognize the unique knowledge,
ability, and independence of each person. State CSBG offices are committed to
treating all persons fairly and maintaining credibility by matching actions with
words.
II. Open Communication – Effective communication is key in facilitating good
working relationships with partners, and State CSBG offices are committed to
keeping lines of communication open. The purpose of communication is to assist
in developing solutions to problems, to share program improvement ideas, and
provide information on new developments in the anti-poverty field. State CSBG
offices communicate frequently through tools and media. State CSBG offices
should be open to contact and are committed to listening to
Page 15 of 73
suggestions/concerns. This aids the State CSBG office in gaining an
understanding of local operations and assisting CAAs in pursuing priorities.
III. Joint Problem Solving - State CSBG offices operate under the basic belief that a
team approach to problem solving is in the best interest of all parties involved.
State CSBG offices sincerely believe that collectively the State CSBG office and
the CAA can arrive at the best solution to any situation. Through a team
approach to problem solving, State CSBG offices think outside traditional
methods and come up with the best strategies for program development,
conflict resolution, or compliance issues. State CSBG offices want to promote an
environment in which the State CSBG office and all Community Action partners
will be open to change and can work together in exploring options and
developing mutually agreeable solutions. The goal is to have agencies function
independently— with State CSBG office support—to meet the needs of local
communities within the parameters set by legislation.
4103. On-site, CSBG monitoring may occur at any time and without notice. Typically, however,
written notice of the monitoring visit will be provided, at a minimum, one week in advance
of the visit.
4104. Community Action Agencies can anticipate an on-site review by KHRC staff for the
purposes of monitoring every other year if in good standing or more frequently as
necessary. KHRC will conduct an on-site of each newly designated eligible entity
immediately after the completion of the first year in which such entity receives CSBG funds.
A typical visit can be expected to require two to five days. The monitor(s) will:
A. Offer both an entrance and exit interview.
B. Provide a written summary of the visit no more than 60 days following the visit. This
summary will be distributed to the entity’s Executive Director/CEO and to the
chairperson of the governing board and/or one other designated staff as appointed by
the Executive Director/CEO. The written summary will clearly identify deficiencies, if
any, as compliance issues and/or findings and may include a discussion of best practice,
concerns, and opportunities.
4105. Monitoring may include, but is not limited to a review of:
A. Program policies and procedures.
B. Income guidelines and verification procedures.
C. Intake forms and procedures.
D. Program work plans and activities.
Page 16 of 73
E. CSBG administrative files.
F. Personnel policies, files, and job descriptions.
G. Inventory and procurement procedures.
H. Cooperative agreements and contracts, including consultant contracts.
I. Organizational structure and lines of authority.
J. Board member files, bylaws, and meeting documentation.
K. Adherence to Federal and State guidelines and requirements.
L. Fiscal policies and practices.
M. Service activity reports, data tracking and reporting systems and supporting
documentation.
N. Prior assessments of CSBG Organizational Standards.
O. Data security.
4106. Monitoring may also include:
A. Interviews with program staff regarding program operations and job functions.
B. Interviews with administrative and fiscal staff.
C. Interviews with members of the governing/administering board.
D. Anyone else identified by KHRC or agency.
4200 CSBG Organizational Standards
4201. Information Memorandum 138 describes the States authority and responsibility to
establish and assess organizational standards. Section 678B of the CSBG Act requires States
to establish “performance goals, administrative standards, financial management
requirements, and other requirements that ensure an appropriate level of accountability
and quality among the states Community Action Agencies.
4202. Kansas utilizes the Center of Excellence’s CSBG Organizational Standards to measure the
accountability and quality of the Community Action Agencies. The COE developed
organizational standards are organized in three thematic groups containing nine categories
and 58 standards for private entities and 50 standards for public.
Page 17 of 73
4203. KHRC is responsible for assessing each Community Action Agencies’ compliance with the
organizational standards annually and for reporting the aggregate results of the reviews to
OCS in the applicable sections of the CSBG Annual Report, Module 1.
4204. KHRC describes the State’s approach for assessing the Organizational Standards in the
CSBG State Plan.
4205. Community Action Agencies will use the system selected and/or approved by KHRC for
tracking and reporting their compliance with the CSBG Organizational Standards.
A. Community Action Agencies will submit or make available for review documentation
sufficient to demonstrate compliance with the standards.
4300 CORRECTIVE ACTION
4301. Compliance Matter(s)/Finding(s) identified through the CSBG on-site monitoring or the
assessment of the CSBG Organizational Standards and included in the monitoring report
require an entity response. At KHRC’s discretion, the response must take the form of a
written Technical Assistance Plan (TAP) and/or a Quality Improvement Plan (QIP) and must
specify the steps the entity will take to correct the Compliance Matter(s)/Finding(s) and the
timeframe, as proposed by the agency and approved by KHRC, for completing the plan. A
TAP is a technical assistance plan that targets training and technical assistance resources and
outlines a time frame for an eligibility entity to meet a specific standard or set of standards. CSBG
IM 138 reports that a state is expected to develop a TAP in circumstances where eligible entities
are not meeting the CSBG organizational standards. A QIP is a plan by an eligible entity to correct
a deficiency identified by the state, consistent with the requirements outlined in Section 678C of
the CSBG Act. This section focuses on corrective action, termination, and reduction of funding.
Prior to terminating or reducing funding to an eligible entity, the CSBG Act requires that, at the
discretion of the state (considering the seriousness of the deficiency and the time reasonably
required to correct the deficiency), the state allow the entity to develop and implement, within 60
days after being informed of the deficiency, a quality improvement plan to correct such deficiency
within a reasonable period of time, as determined by the state.
Alternately, the entity may
provide documentation that will allow the need for the TAP and/or a QIP for the issue in
question to be waived.
A. The provision of documentation allowing waiver of a TAP and/or a QIP must occur
within fifteen (15) days following the issuance of the monitoring report/summary or a
mutually agreed upon deadline.
1. KHRC will respond within ten (10) days.
B. The TAP and/or QIP is due to KHRC within 30 days following the issuance of the
monitoring report. The due date will be communicated at the time the monitoring
report is issued.
Page 18 of 73
1. Upon request, assistance in the development of a TAP and/or a QIP will be provided.
2. A TAP will be required for minor compliance issues. A QIP will be required for
serious compliance issues or compliance issues that are repeated or of long
duration.
3. KHRC will notify the entity whether a TAP or a QIP is required at the time the
monitoring report is issued.
4. KHRC may make available training and technical assistance, if appropriate, to help
the eligible entity correct identified deficiencies or failures in meeting State and/or
Federal requirements.
C. KHRC staff will review and respond to the TAP and/or QIP within 30 days of its receipt.
1. The Federal Office of Community Services (OCS) will be advised of KHRC’s
acceptance of the QIP within 30 calendar days of KHRC’s acceptance of the plan.
D. Entity implementation of a technical assistance plan and/or quality improvement plan
must occur within 30 days following KHRC’s acceptance of the TAP or QIP.
E. KHRC staff will monitor progress toward the completion of the TAP or QIP.
1. Entities must provide reports detailing progress in completing the technical
assistance plan and/or quality improvement plan as prescribed within KHRC’s
notification of the plan’s acceptance.
a. At a minimum, KHRC must prescribe a quarterly report detailing progress in
completing the technical assistance plan and/or quality improvement plan.
The due dates of the reports will be determined by KHRC and communicated
when the TAP or QIP is accepted.
2. KHRC personnel will review reports on submission and will issue a closure notice
when satisfied that any compliance matter/finding has been resolved. Agencies
must continue to provide progress reports until KHRC provides notification that all
Compliance Matters are resolved.
3. Once all Compliance Matters/Findings addressed within a quality improvement plan
have been resolved, KHRC staff will advise OCS within 30 days of the closure of the
plan.
Page 19 of 73
4302. Uncorrected Compliance Matters/Findings may cause the State, in accordance with 42
CFR § 9915 and IM 116, to remove the entity’s designation as a CSBG-eligible entity. (Item
4501)
4400 DESIGNATION AS “HIGH RISK”
4401. KHRC may designate an eligible entity to be “high risk” if KHRC determines that it has a
history of unsatisfactory performance, is not financially stable, has a management system
which does not meet management standards, has not conformed to terms and conditions
of previous awards or is not otherwise responsible. Examples of indicators that may lead to
a designation of “high risk” include:
A. Uncorrected Compliance Issues/Findings.
B. Entity is unresponsive to and/or noncompliant with KHRC requests and requirements.
C. Management systems do not contain data driven strategic plans and community action
plans.
D. Entity consistently fails to meet deadlines.
E. The Entity’s adherence to its approved operating documents (including bylaws,
personnel policy, and fiscal policy) is significantly inconsistent.
F. Record keeping related to board and committee activity is not systematic. The corporate
record is, as a result, incomplete.
G. Abrupt departure of the Executive Director/CEO and/or the fiscal officer.
H. The audit conducted in accordance with the requirements of the applicable OMB
Circular contains one or more significant findings relevant to the entity’s capacity to
successfully administer its programs.
I. Failure without cause to meet multiple performance targets defined within the entity’s
approved Community Action Plan.
J. CSBG percent of revenue exceeds one half of the entity’s total revenue.
K. Entity lacks connection and a demonstrated commitment to the broader community
action network.
4402. Entities designated as “high risk” will be notified in writing as to the specific findings or
deficiencies and must be required to remedy the situation within a specific timeline or to
develop and implement a quality improvement plan.
Page 20 of 73
4403. Special sanctions may apply to entities assigned high risk status and may include, among
other sanctions:
A. Payment of grant funds on a reimbursement basis.
B. A requirement to provide additional and/or more detailed financial reports.
C. The establishment of a need to gain additional prior approvals as determined by KHRC.
D. Additional monitoring.
E. A requirement to obtain technical and/or management assistance and, as a result,
demonstrate improvement.
F. The consideration of CSBG discretionary grant proposals only for projects convincingly
designed to alleviate the condition that resulted in the designation of high risk.
4404. The Office of Community Services, HHS, will be notified of any eligible entity that is
designated high risk within 30 days.
4405. Entities emerging from a KHRC designation of high risk will be so notified in writing. A
copy of this notification will be submitted to the Office of Community Services, HHS within
30 days.
4406. Failure to emerge from high-risk status in accordance with established timelines may
result in the cessation of CSBG funding and designation as a CSBG-eligible entity (Item
4501).
4500 DESIGNATION AND DE-DESIGNATION
4501. Information Memorandum 116 provides a step-by step description outlining necessary
actions and considerations for terminating or reducing funds to a CSBG eligible entity for
cause and revisions thereto will guide the designation and de-designation of Community
Action Agencies.
A. The steps outlined in IM 116 are repeated below:
Step 1: State conducts monitoring review pursuant to section 676B.
Step 2: State determines, on the basis of a final decision in a monitoring review that the
eligible entity fails to comply with the terms of an agreement, or the State plan, to
provide services under this subtitle or to meet appropriate standards, goals, and other
requirements established by the State (including performance objectives).
Page 21 of 73
Step 3: State informs the entity of the deficiency to be corrected.
Step 4: State requires the entity to correct the deficiency.
Step 5: State determines whether training or technical assistance are appropriate.
Step 6: (if appropriate): State offers training and technical assistance, if appropriate, to
help correct the deficiency.
Step 7: State either (A) prepares and submits to the Secretary a report describing the
training and technical assistance offered; or (B) if the State determines that such
training and technical assistance are not appropriate, prepares and submits to the
Secretary a report stating the reasons for the determination.
Step 8: At the discretion of the State, the State allows the entity to develop and
implement, within 60 days after being informed of the deficiency, a quality
improvement plan to correct such deficiency within a reasonable period of time, as
determined by the State.
Step 9: State provides adequate notice and an opportunity for a hearing.
Step 10: State initiates proceedings to terminate the designation of or reduce the
funding under this subtitle of the eligible entity unless the entity corrects the deficiency.
4502. In the event the State terminates the designation of an organization as an eligible entity,
any resulting funding may be awarded only to an organization that is an eligible entity for
CSBG funds. In accordance with the CSBG Act, a State may solicit applications and designate
as an eligible entity an organization that demonstrates effectiveness in meeting the goals of
the CSBG Act and may give priority to an eligible entity in a contiguous area that is already
providing related services in the un-served area.
4600 PROGRAM REPORTS
4601. Program reports consist of quarterly reports (module 4 and narrative reports) and year-
end reports (modules 2 and 3). Each recipient of CSBG funds must submit reports on
activities supported by CSBG funds. The reporting requirements, description of modules 1 –
4, and reporting guidance are found in the KanDo! ROMA Plan. Where CSBG funds are
used to support the entity infrastructure, CSBG is considered to impact all programs and
services. Community Action Agencies are, therefore, guided to provide information
reflective of the total entity impact on the causes and effects of poverty.
4602. KHRC recognizes the national goals (currently three), the goal indicators and sub-
indicators as established by the national community action network and as defined within
Page 22 of 73
the KanDo! ROMA Plan. Each entity is guided to report on all performance indicators
identified within its Community Action Plan and is encouraged to report on any secondary
activity.
4603. Quarterly reports and year-end reports are to be submitted in SharePoint in accordance
with the KanDo! ROMA Plan unless otherwise indicated within the grant agreement. Entities
must maintain documentation that can authenticate report data. Entities must use the
reporting forms identified and/or provided by KHRC.
A. Module 4 quarterly reports and Narrative reports are due as follows:
October through December Due January 31
January through March Due April 30
April through June Due July 31
July through September Due January 15
B. Module 4 quarterly reports will be cumulative reports, including data reported in
previous quarter(s) plus new data from the current quarter.
C. Module 2 data will be reported annually. The module 2 year-end report is due on or
before January 15, although subject to change upon notification of Annual Report due
date and availability of Smart-Forms from Federal partners.
D. Module 3 data will be reported annually. The module 3 year-end report is due on or
before January 15, although subject to change upon notification of Annual Report due
date and availability of Smart-Forms from Federal partners.
4604. In the event that an entity fails to submit reports in compliance with provisions set
forth in this section, the following steps may be taken:
A. KHRC staff will communicate with the entity director to inform him or her of the issue.
B. A letter documenting the initial communication may follow.
C. The chairperson of the board of directors may be notified of the failure to submit
reports if the failure is significant and/or a recurring issue.
D. Grant funds may be withheld until the issue is corrected.
Page 23 of 73
(This page is intentionally left blank)
Page 24 of 73
SECTION 5: GRANT APPLICATION AND PROCEDURES
5000 APPLICATIONS for CSBG Non-Discretionary and/or CSBG Discretionary Funds
5001. To be eligible for a proportionate share of the 90 percent pass-through funding, an
applicant must meet and have retained the eligibility requirements specified in 42 USC Ch.
106, as amended.
5002. In order to receive funding for a given program year, Community Action Agencies are
required to submit an annual application to KHRC.
A. Prior to the start of the program year, KHRC will provide Community Action Agencies
with application instructions and information.
1. To allow sufficient time for entities to prepare the application and to receive board
approval of the application, the release of instructions, including the announcement of
the due date, will be targeted sixty days prior to the due date. Entities can anticipate a
due date in late February/early March.
5003. Typical refunding applications must include the following required elements.
A. Application summary.
B. A response to the triennial community assessment requirement including:
1. The date of publication (month/day/year) and the title of the current, full
community assessment.
2. Planning for the next full assessment.
3. Annual update during intervening years.
C. A Community Action Plan including program outcome projections (performance targets)
as defined in the KanDo! ROMA Plan and the funding instructions.
D. Financial information including a budget and a non-profit rate agreement, cost
allocation plan or indirect cost rate proposal.
E. Information regarding changes to entity operating documents including CSBG inventory
per applicable OMB circular, bylaws, personnel policies, fiscal policies, standards of
operations for programs operated in whole or part with CSBG funds.
Page 25 of 73
F. Certifications and assurances as prescribed by HHS.
G. Additional information as may be required.
5004. The complete CSBG refunding application and budget, including all elements as
submitted to KHRC, must be approved by the full board preferably prior to submission.
A. If meeting schedules and the timeline for submission of the annual application do not
allow consideration and/or approval of the application by the full board, the applicant
may submit an executive summary and complete budget to its governing board for
comments prior to the submission of the application. The highest-ranking officer of the
board, through his or her signature on the application submission, attests to the
consideration and/or approval at the next possible full board meeting.
B. The CSBG application and budget, including all elements and as submitted to KHRC,
must be approved by the full board (rather than a committee) prior to the acceptance of
the grant award. The highest-ranking officer of the board present at that meeting must
attest, through his or her signature, to board approval of the complete CSBG
application.
5005. The submission of one originally signed copy of the application will typically be required.
Community Action Agencies should submit one complete signed copy of the application in
SharePoint, or if necessary, via email. The eligible entity must ensure the submission is
legible, complete and contains all appropriate signatures.
5100 Application Review
5101. Upon receipt, KHRC staff will review the application to ensure that all required elements
have been supplied. Entities submitting incomplete applications will be notified and
required to submit the missing element(s). A Notice of Award will not be issued when
required information is identified as absent.
5200 Grant Award
5201. All grant awards will be administered in accordance with applicable Federal and State
rules and regulations.
5202. Upon acceptance of the refunding application, KHRC will issue a notice of funding and
grant agreement which will include contractual provisions, notification of special grant
conditions (if applicable) and other documentation which, from time to time, may be
applicable. The accepted application is considered part of the binding agreement.
Page 26 of 73
5203. Grant award documents are issued based on the information submitted within the
entity’s application and subsequent modifications accepted by KHRC.
5204. Grant award documents will specify the amount of funds that the eligible entity is to
receive and will stipulate the beginning and ending date of the grant period.
5205. Grant award documents are not complete until all authorizing signatures have been
added. These include the signatures of:
A. Cognizant KHRC officials,
B. The chair or, in the case of incapacity, the vice-chair of the entity’s governing board and
C. The entity’s Executive Director/CEO or designee as authorized by the agency.
5206. Grant payments generally cannot be made in the absence of fully signed, complete
grant award documents. However, under certain circumstances and at KHRC’s discretion,
advances may be paid.
5207. The grant award documents are legally binding and set forth the manner in which the
entity must, in accordance with the Order of Precedence, administer its CSBG award.
5300 Grant Revisions
5301. Prior approval for any change to the scope or objectives of the approved project must
be obtained. No deviations are authorized without a signed grant award revision, with the
exception of budget line-item variances in accordance with allowable percentages as
stipulated in item 5302.
5302. An entity is bound by the budget accepted by KHRC. However, the transfer of funds
between personnel, non-personnel and administration is allowable, up to 20 percent of the
greater of a populated line item, not to exceed 5 percent of the total approved budget,
except when such a transfer results in a change to the scope or objectives enumerated in
the application. Community Action Agencies must notify KHRC in writing in advance of the
budget line adjustments.
5303. Any adjustment of budget line items above the allowed percentage requires a written
request and written acceptance by KHRC prior to the adjustment. Unauthorized changes in
the budget may be disallowed.
Page 27 of 73
5304. Requests to revise a budget and/or change scope must be submitted to KHRC in writing.
The request must include:
A. Detailed information addressing the need for the proposed change,
B. Description of the impact that the change will have on services to low-income people,
C. Updated budget sheets and budget narrative, as applicable,
D. Updated community action plan, if applicable,
E. Updated performance targets, if applicable, and
F. Evidence that the board of directors/administering board has reviewed and approved
the amendment/revision.
1. If meeting schedules and the timeline for the submission of the amendment/revision
do not allow consideration of the amendment/revision by the full board, the
applicant may secure approval for the amendment/revision from a duly authorized
committee of the Board as defined within the entity’s bylaws.
5305. Revisions may be requested any time prior to the final 60 days of the grant period.
Revision requests submitted within this time frame which require correction must be
corrected and received by KHRC in an acceptable form no later than 30 days prior to the
end of the grant period. Only under special conditions, and with a written KHRC waiver, will
a revision request be accepted during the last 60 days of the grant period.
5306. Grants with effective periods of four months or less may not be modified unless a
waiver is granted by KHRC.
5307. KHRC will respond in writing to revision requests within 30 days of the receipt of the
request.
5400 AWARD AMOUNTS
5401. The amount of each eligible entity’s grant funded by the 90 percent pass- through will
be based upon a funding formula determined by KHRC. The funding formula will include
among its variables the number of low- income people in the eligible entity’s service area.
Page 28 of 73
Each eligible entity’s proportionate share may change in response to changes in the low-
income population or to additions to or deletions from the number of Community Action
Agencies within the State.
5402. Payment of grant funds must be in accordance with applicable Federal regulations and
KHRC disbursement procedures. The Grant Transaction Report (see Section 9) must be used
to report expenses and receipts and to initiate a grant payment.
5500 CARRY-OVER FUNDS
5501. Though legislation (1998) allows the carry-over of CSBG funds from the fiscal year of
allocation to the succeeding fiscal year, the grant period typically assigned to Kansas CSBG
pass-through grants does not allow carry-over of funds from one grant to the next.
5502. KHRC retains the right to recapture funds not obligated by an eligible entity at the
conclusion of any fiscal year pursuant to 45 USC § 9907.
Page 29 of 73
(This page is intentionally left blank)
Page 30 of 73
SECTION 6 – GOVERNING BOARDS
6100 BOARD COMPOSITION
6101. By statute, CSBG Eligible Entities (Community Action Agencies) are required to have
governing boards (or in the case of a public entity, an administering board). To receive or
continue to receive CSBG funds, Community Action Agencies must comply with applicable
federal and state regulations policies pertaining to board composition and operation.
Information Memorandum 82 provides guidance on policy questions regarding
composition, role, and responsibilities of local community action tripartite boards.
Resources
Information Memorandum (IM) 82. Tripartite Boards. Issued March 23, 2005
http://www.acf.hhs.gov/programs/ocs/resource/im-no-82-tripartite-boards
CAPLAW. Bylaws Toolkit, Updated 2009.
http://caplaw.myshopify.com/products/caplaw-bylaws-toolkit-electronic-copy
CSBG Act, Section 9910 on Tripartite Boards
http://codes.lp.findlaw.com/uscode/42/106
CAPLAW. CSBG Training Tools for Public CAA Boards
http://caplaw.org/resources/PublicationDocuments/CSBGTrainingToolsforPublicCAABoards.ht ml
CAPLAW. Raising the Low-Income Voice: Case Studies in Democratic Selection Procedures. 2015.
http://www.caplaw.org/resources/PublicationDocuments/CAPLAW_RaisingtheLowIncomeVoice
_Sept2015.pdf
6102. The board must consist of a number of member positions divisible by three. It must
have, at a minimum, nine members chosen in compliance with the following:
A. One-third of the members must be comprised of elected public officials holding office
on the date of selection or their representatives, except that if the number of such
elected officials reasonably available and willing to serve on the board is less than one-
third of the membership of the board, membership on the board of appointive public
officials or their representatives may be counted in meeting such one-third
requirement. These members shall hereafter be referred to as public sector
representatives.
1. Each public official may choose one representative to serve on the board in his or
her stead. This member need not be a public official himself or herself, but he or she
must assume the elected (or appointed) official’s seat on the board.
Page 31 of 73
2. Entities wishing to exercise the seating of an appointed public official or their
representative rather than an elected public official or their representative must
secure approval from KHRC. Documentation will be required to support the claim
that the number of elected officials reasonably available and willing to serve, or
appoint a representative to serve, is less than one-third of the membership.
B. Representatives of low-income persons chosen in accordance with democratic selection
procedures must comprise at least one-third of the board. These members shall
hereafter be referred to as low-income sector representatives.
C. Representatives of business, industry, labor, religious groups, welfare, education and
other groups or interests in the community must comprise the remainder of the board.
These members shall hereafter be referred to as private sector representatives.
6103. Low-income sector representatives must be chosen by low-income individuals in
accordance with democratic selection procedures adequate to assure that they represent
the low-income persons in the geographic area served by the eligible entity. Among the
selection procedures which may be used, either separately or in combination, are the
following:
A. Nominations followed by an election either within the neighborhood or within the
community as a whole.
B. Selection at a meeting or conference of low-income persons, such that the date,
time and place of the meeting or conference have been adequately publicized.
6104. Community Action Agencies must retain records documenting the democratic selection
of low-income representatives seated on the board.
6105. Low-income sector representatives selected to represent a specific geographic area
within the community must reside within the area he or she represents.
6106. To ensure an independent body, board members must not be related to one another or
to the Executive Director/CEO. The following individuals meet the definition of “related”:
domestic partner and biological-, adoptive-, foster- or step- father, mother, brother, sister,
aunt, uncle, first cousin, son, daughter, mother-in law, father-in-law, brother-in-law, sister-
in-law, and grandparent.
6107. No person may serve on the eligible entity’s board who is:
Page 32 of 73
A. A board member or employee of a delegate agency, except a delegate agency which is
responsible for comprehensive community programming and planning for low-income
areas served by the eligible entity.
B. An employee of the eligible entity, KHRC or HHS.
6108. The board must establish procedures to ensure compliance with the requirements of
Items 6106 and 6107.
A. Evidence demonstrating compliance with this procedure must be maintained by the
agency.
6109. Prospective board members should be informed of the entity’s expectations of their
board and its members prior to their being seated as a member of the Board.
6110. Prospective board members’ names must be checked annually against the Federal
government’s “Excluded Parties List System” online database to ensure members are not
suspended or disbarred from participating in Federal grant or contract programs. (2 CFR
180) This database is available online at https://sam.gov.
A. Evidence supporting members’ eligibility to serve should be maintained by the
agency.
6111. A waiver to the minimum board size (Item 6102) may be granted annually upon the
presentation of written evidence that clearly demonstrates that the entity has been unable
to identify 9 individuals willing to serve and that a lesser number is able to allow for full
deliberation and diversity of thinking on governance and other organizational matters and
can execute the roles and responsibilities contained herein. If granted, the waiver is
temporary and expires at the conclusion of the grant period. Waiver requests must be
accompanied with a detailed plan for reaching the minimum number of board members.
A. Examples of documentation that could be submitted with the waiver request are
minutes showing the agency discussed vacant seats at a Head Start policy council, media
posts, community minutes, etc.
B. Waiver requests must include an attestation that the governing board has approved the
request.
C. Waiver requests are to be submitted to KHRC prior to the start of the program year.
D. KHRC will respond to such requests within 30 days of receipt.
Page 33 of 73
6200 BOARD ROLES AND RESPONSIBILITIES
6201. By statute, boards of directors/administering boards of CSBG-Community Action
Agencies must fully participate in the development, planning, implementation and
evaluation of programs and operations supported by CSBG funds.
6202. Members of boards of directors have legal obligations as follows:
A. Duty of Care – The duty of care describes the level of competence that is expected of a
board member and is commonly expressed as the duty of “care that an ordinarily
prudent person would exercise in a like position and under similar circumstances.” A
board member must exercise reasonable care when he or she decides as a steward of
the organization.
B. Duty of Loyalty – Board members owe the organization their undivided allegiance when
making decisions. This means that a board member can never use information obtained
as a result of board membership for personal gain.
C. Duty of Obedience – The duty of obedience requires board members to be faithful to
the organization’s mission. They are not permitted to act in a way that is inconsistent
with the central goals of the organization.
(Legal responsibilities have been extracted from Strengthening Board Governance, Kentucky Association for Community Action,
undated.)
6203. Basic responsibilities of effective non-profit boards: *
A. Determine the organization’s mission and purpose.
B. Selection of the executive.
C. Support the executive and review his or her performance.
D. Ensure effective organizational planning.
E. Ensure adequate resources.
F. Manage resources effectively.
G. Determine and monitor the organization’s programs and services.
H. Enhance the organization’s public image.
Page 34 of 73
I. Serve as a court of appeal.
J. Assess its own performance.
*The Training Book for Community Action, R. and N. Alemán, 2010.
1. Additional information on the duties and responsibilities of a tripartite board can be
found on the CAPLAW website.
6204. The governing board of each private, non-profit eligible entity must undertake an annual
performance evaluation of the entity’s Executive Director/CEO. This evaluation must include
a statement of outcomes for which the executive is responsible and must provide a
progress statement relative to the achievement of those outcomes. Dated evidence of the
evaluation must be contained within the Executive Director/CEO’s personnel file.
A. Organizational Standard 7.4 for private entities states, “The governing board conducts a
performance appraisal of the Executive Director/CEO within each calendar year.”
6205. A succession plan must be in place for the Executive Director/CEO, which contains
procedures for covering an emergency/unplanned, short-term absence of 3 months or less,
as well as the process for filling a permanent vacancy. Board approval of the plan is required
of private, non-profit Community Action Agencies. (Organizational Standard 4.5)
A. The plan should direct that the names of candidates for the position of CEO/Executive
Director be checked against the Federal government’s “Excluded Parties List System”
online database to be sure that they are not suspended or disbarred from participating
in Federal grant or contract programs.
6206. The board must be aware of CSBG’s role within the organization and must receive all
pertinent information related to CSBG grant operations, monitoring, and reporting.
6207. The governing board or the administering board, as applicable, must be immediately
informed of any sanctions or disciplinary action that KHRC takes against the entity.
6208. Any decision, policy change or action by the board which would result in a change in
program scope or in the approved line-item budget, beyond the allowable variance, must
be reported to KHRC within 10 days of the board action. Examples of such policy changes or
actions include (but are not limited to) addition or deletion of programs or staff positions
supported wholly or partly with CSBG funds. This requirement is independent of, and in
addition to, the requirements contained within Item 5300.
Page 35 of 73
6300 BYLAWS’ REQUIREMENTS
6301. The governing board must develop and approve bylaws by which the board shall
operate, and which meet, at minimum, the requirements stated herein.
6302. Each Community Action Agency must, on the submission of the annual refunding
application, ensure that KHRC is in possession of a current, dated copy of the entity’s
bylaws.
6303. The bylaws must list the total number of seats on the board and the allotment of seats
to public officials, low-income sector representatives and private sector representatives.
6304. The bylaws must define a term not to exceed three years for each member position.
Term limits, if desired, may be expressed as multiples of a term.
6305. The bylaws must include procedures for the selection of board members.
A. Procedures for the selection of representatives of low-income persons must
demonstrate an aspiration that all areas of the low-income community will be
represented.
B. Selection procedures for low-income sector representatives, if by vote, must include
safeguards to limit voting to low-income adults who reside in the area served, with one
vote per person.
6306. The bylaws must require that the board elect (i.e., vote to seat) all members, no matter
the selection method used to identify prospective members.
6307. The bylaws must describe any performance standards (such as attendance, etc.) and
standards of conduct for members of the board, the violation of which may be grounds for
removal.
6308. The bylaws must describe specific procedures to be followed for the board to remove
any director or officer for cause.
6309. The bylaws must include procedures for selecting new board members in the case of a
vacancy on the board and must prescribe that those procedures are to commence within 30
days of the creation of the vacancy. For the purpose of this paragraph, there is a vacancy
when a member has been notified of his or her official removal by the board, a member
Page 36 of 73
submits his or her resignation, a member dies, a member who is an elected public official
leaves office, a member who is an appointed public official is removed from office or a
member is the representative of a public official and the public official leaves office.
6310. Vacant board seats must be filled within nine months of the seat becoming vacant. For
the purpose of this paragraph, a vacant seat is filled when the board votes to seat the new
board member.
A. Board seats that are vacant for more than nine months will be considered a compliance
issue and may result in the Community Action Agency being placed on a Quality
Improvement Plan to fill the vacancy.
6311. If extenuating circumstances exist that prevent the vacant seat being filled within the
nine-month timeframe, agencies may request an extension from KHRC. The extension must
include the following information.
A. Description of the efforts the agency has made to fill the vacancy within the established
timeframe.
B. Explanation of why the vacant seat has not been filled within the timeframe.
C. Assurance the board will be able to function effectively with the extension.
D. Action plan for how agency will fill vacancies in the future within the timeframe.
6312. With respect to low-income sector representatives, the bylaws must include a method
for filling a vacancy that demonstrates the involvement of low-income individuals. The
selection procedure may be repeated, or alternately, the remaining low-income
representatives may recommend a replacement to serve for the remainder of the term. In
the latter case, the person selected must, to the maximum extent possible, represent the
same constituency as the original representative.
A. Members filling a low-income sector vacancy must stand for democratic selection for
any subsequent term.
6313. Should the seat of a representative of a public official become vacant, the board must
request that the public official, or appointing authority, name a replacement.
6314. Should the seat of a representative of the private sector become vacant, the board may
reflect on its skill set needs and recruit accordingly. A board nominating committee, or
equivalent, may be tasked with recommending a candidate for board approval.
Page 37 of 73
6315. The board must be advised of progress in filling a vacancy at each subsequent meeting
until such time as the vacancy is filled.
6316. KHRC must be notified when the board seat becomes vacant and notified when the seat
is filled using the KHRC supplied reporting/tracking form(s).
6317. The agency bylaws must set the quorum for a meeting of the board. Quorum must be
at least 51 percent of the non- vacant seats on the board. A quorum must be present for all
decisions requiring a vote.
6318. The agency bylaws must specify the board must meet on a regular basis. At a minimum,
the board must meet six times annually. The meetings must be scheduled for the
convenience of its members and of the general public. The eligible entity must provide
notice (in writing) of any regular meeting and an agenda to all members at least three
calendar days in advance. Electronic notices and agendas, in lieu of paper copies, are
encouraged provided all members receiving electronic notices have agreed to accept this
form of notification.
A. Meeting notices and agendas must be submitted in SharePoint to KHRC at the time they
are distributed to members of the board.
6319. Notices of special meetings must be issued in the manner described within the entity’s
bylaws.
6320. The agency bylaws must specify the board may establish any committee it considers
necessary for carrying out its business. For governing boards, at a minimum, a finance/audit
committee is recommended.
6321. The bylaws may define and empower an executive committee, drawn from the entity’s
board members, to transact business for the full board. The executive committee must
provide a written report of its actions at the next meeting of the full board. The quorum for
the executive committee may not be less than 51 percent of the non-vacant seats on the
committee.
6322. Voting by proxy is not permitted at meetings of the board or of its committees. This
prohibition applies to all members of the board.
6323. Alternates may be elected/selected under the following conditions:
A. Selection and service of alternates must be described in the bylaws.
Page 38 of 73
B. Alternates must be elected/selected in the same manner, at the same time, and by the
same people who have elected/selected the representative.
6324. All alternates must be listed on the membership roster of the board.
6325. In accordance with the Model Business Corporation Act, the default rule for Kansas non-
profit organizations, alternatives are not granted voting privileges.
6326. No alternate may hold an office of the board. It is permissible, however, for appointed
representatives of public officials, who by virtue of their appointment, and election to the
board, are fully seated, to serve as officers of the board.
6327. Procedures must be established within bylaws under which a low-income individual,
community organization or religious organization or representatives of low-income
individuals that considers its organization or low-income individuals to be inadequately
represented on the board of the eligible entity, may petition for adequate representation.
6400 ALLOWABLE COSTS
6401. The allowable board costs include:
A. Reasonable and actual expenditures incurred solely as a result of attending a scheduled
board meeting or a meeting of an appointed committee of the board.
B. The reasonable costs of necessary meals furnished by the eligible entity for participants
in scheduled meetings. Such costs are allowable only if the board members are not
reimbursed – as per diem or otherwise.
6500 GENERAL
6501. Community Action Agencies must have a documented process that ensures initial and
continued board training to include, as applicable: non-profit board responsibilities (within
the past 2 years) including fiduciary responsibilities, results oriented management and
accountability (ROMA), program and service information, the causes and effects of poverty,
emerging issues and the origin, source, and impact of CSBG funding. (Organizational
Standard 5.8)
6502. As applicable, meetings of the governing/administering board are subject to the Kansas
Open Meetings Act.
Page 39 of 73
6503. The board must keep written minutes for each meeting. Minutes must be made
available to the public upon request. The board must also make available to the public,
upon request, translations of the minutes in the appropriate language where a significant
portion of the low-income population does not speak English.
6504. Copies of the signed, ratified minutes for each meeting of the governing/administering
board, along with the respective financial report received by the board, must be submitted
in SharePoint to KHRC no later than ten calendar days after the date of the meeting at
which the minutes were approved. Community Action Agencies utilizing a board portal may
choose to notify KHRC the ratified board minutes are uploaded to the portal as an
alternative to submitting the minutes to KHRC, if the entity has given KHRC access to the
board portal.
A. Organizational Standard 8.7 requires that the governing board of private entities receive
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. The Standard requires
that the tripartite board/advisory body of a public entity receive financial reports at
each regular meeting, for those program(s) the body advises, as allowed by local
government procedure.
B. Approved minutes submitted to KHRC must be signed by a board officer and must
include the date of the meeting at which the minutes were approved.
6600 ADMINISTERING BOARDS
6601. In those communities where the local political jurisdiction (city, county, etc.) has
designated itself as the CSBG-eligible entity, the governing officials are required to establish
an administering board. The administering board is constituted in the same manner as a
governing board. Unlike the governing board, the administering board is not the source of
all authority, nor is it the legal embodiment of the entity. The board’s actual authority
depends on the powers delegated to it by the governing officials of the political jurisdiction.
Administering boards must, however, demonstrate that members actively participate in the
development, planning, implementation, and evaluation of the community action program
rather than merely providing advice.
6602. Administering boards are subject to all pertinent and applicable requirements contained
within the federal regulations and the Kansas Community Services Block Grant Manual of
Policies and Procedures.
Page 40 of 73
6603. The political jurisdiction must prepare and maintain bylaws for its CSBG administering
board. These bylaws are to contain a delineation of power between the governing body and
the administering board.
(This page is intentionally left blank)
Page 41 of 73
SECTION 7 – PLANNING
7000 COMMUNITY ASSESSMENT
7001. As required by the Coats Human Services Reauthorization Act of 1998 and as a condition
of funding, Community Action Agencies must produce and maintain a community needs
assessment.
7002. A full community assessment must be completed, and a report issued, at a minimum,
once every three years (Organizational Standard 3.1); updates addressing significant
variances must be provided in intervening years. The full assessment must include elements
identified within Organizational Standards including:
A. A statistical profile (charts, graphs, maps, . . .) including current data specific to poverty
and its prevalence related to gender, age, and race/ethnicity for their service area(s).
(Organizational Standard 3.2)
B. Both qualitative and quantitative data on the geographic service area(s) which may
include community perspectives (common themes, key quotes, . . .). (Organizational
Standard 3.3)
C. Customer satisfaction data and customer input. (Organizational Standard 6.4)
D. Key findings on the causes and conditions of poverty and the needs of the communities
assessed. (Organizational Standard 3.4)
7003. Legislation allows that the assessment may be coordinated with community
assessments conducted for other programs. An assessment so conducted must contain all
elements listed in Item 7002; it must address the entire service area and be clearly
applicable to the work of the eligible entity.
7004. Community Action Agencies must, on the submission of the annual refunding
application, ensure that KHRC is in possession of a current, dated copy of the community
assessment. An update detailing significant variances, if any, must be provided in
intervening years.
7005. The Community Needs Assessment must be published within the three-year period.
Page 42 of 73
7100 STRATEGIC PLAN
7101. Each eligible entity must have a strategic plan in place that has been approved by the
governing/administering board within the past five years (Organizational Standard 6.1). The
plan must meet the following minimum specifications.
1. The strategic plan must be drawn from the findings contained within the community
assessment.
2. The strategic plan must clearly define the period of time covered by the plan.
3. The strategic plan must contain a mission statement succinctly defining the reason the
organization exists.
4. The plan may contain a vision statement which succinctly defines the desired future the
entity envisions. The entity may wish to include a vision for individuals and families, the
community, and the agency.
5. The plan may include a list of core values. Core values are the absolutes that define the
organization. Values give an organization its soul. They can clarify and resolve issues;
help determine direction and build community.
6. The plan must contain family, agency and/or community goals. (Organizational Standard
6.3) Goals are those overarching and broad statements of what the organization hopes
to achieve.
7. The plan must identify strategies. Strategies are statements of major approaches that
will be used to achieve each goal. Three to five strategies for each goal may be
adequate.
8. The plan must include initiatives. Initiatives are specific programs, projects or activities
planned to occur over the course of the planning cycle to advance each strategy.
9. The plan must contain a process for evaluating elements within the plan.
7102. Community Action Plan / Logic Models that identify the targeted tasks involved in
operationalizing the strategies/initiatives contained within the strategic plan are a
suggested tool for moving the organization toward its goals.
7103. The governing/administering board must receive, at a minimum, an annual update on
progress in meeting the goals of the strategic plan. (Organizational Standard 6.5)
Page 43 of 73
7104. Community Action Agencies must, on the submission of the annual refunding
application, ensure that KHRC is in possession of a current, dated copy of the board-
approved strategic plan.
7200 CALENDAR OF PLANNING ACTIVITIES
7201. Each eligible entity must establish and maintain a calendar of activities which will ensure
that the board:
A. Reviews the entity’s accomplishments and the strategic plan at a minimum, annually.
B. Annually reviews its bylaws and membership needs.
C. Annually reviews the entity’s fiscal policy and procedures (alternately, administering
boards may review fiscal reporting practices).
D. Annually reviews the entity’s personnel policy (administering boards exempt).
E. Annually reviews recurring grant applications including the CSBG application.
F. Annually conducts an evaluation of the entity’s Executive Director/CEO per Item 6204
and annually reviews and approves Executive Director/CEO compensation.
(Organizational Standards 7.4 and 7.5)
G. Receives and reviews an organization-wide, comprehensive risk assessment at minimum
once every two years. (Organizational Standard 4.6)
H. Addresses other time sensitive CSBG Organizational Standards and entity processes.
I. Receives training on their duties and responsibilities at a minimum of once every other
year.
J. Receives an overview of ROMA training for members and staff.
Page 44 of 73
SECTION 8 – SERVICE DELIVERY
8000 GENERAL
8001. Entities must develop and implement written standards of operation, including program
policies and procedures, to govern programs operated in whole or part with CSBG funds.
A. Community Action Agencies must, on submission of the annual refunding application,
ensure that KHRC is provided a current, dated copy of the approved program policies
and procedures.
8002. Program policies and procedures must include:
A. Intake procedures, including instructions for using the entity’s intake and application
documents and/or digital systems.
B. Eligibility criteria, including the income verification period, income guidelines, eligibility
period and residency verification procedures and criteria.
C. Procedures for recertification of eligibility.
D. A definition of family in accordance with a prevailing definition. (E.g., 45 CFR § 1305.2)
E. Safeguards to ensure that eligible staff or staff members’ families do not realize an
undue advantage as they seek services.
F. A process to identify and inform custodial parents in single-parent families that
participate in programs, activities or services carried out or provided through CSBG
about the availability of child support services and to refer eligible parents to the child
support offices of State and local governments.
G. For those activities and services for which eligible applicants exceed capacity, a process
for prioritizing applicants and for notifying applicants of their status.
H. A statement indicating that no person shall, on the basis of race, color, national origin,
or sex be excluded from participation in, be denied the benefits of, or be subjected to
discrimination under, any program or activity funded in whole or in part with funds
made available through CSBG. Any prohibition against discrimination on the basis of
age under the Age Discrimination Act of 1975 (42 USC 6101 et seq.) or with respect to
Page 45 of 73
an otherwise qualified individual with a disability as provided in section 504 of the
Rehabilitation Act of 1973 (29 USC 794), or title II of the Americans with Disabilities Act
of 1990 (42 USC 12131 et seq.) shall also apply to any such program or activity. (CSBG
Reauthorization Act of 1998, Section 678F)
I. An appeal procedure which includes a process through which applicants for service are
made aware of their right to appeal a decision related to their determination of
eligibility and addressing claims of discrimination.
8003. Material aid provided and programs operated solely with CSBG funds must follow
poverty guidelines established annually by the Federal Office of Management and Budget
(OMB) when qualifying customers. Customers whose family income, indexed for size, is at
or below 125 percent of the poverty guideline, by Federal law, qualify for such services.
A. A categorical determination of eligibility may be acceptable if evidence of eligibility for a
companion program demonstrates family income, indexed for size, is at or below 125
percent of the poverty guideline.
8004. Each eligible entity must establish criteria for verification of family income, which must
be used uniformly among all centers.
A. The income period and verification procedures used to determine eligibility must be
clearly defined within the written program policies and procedures.
B. The intake worker must verify income as established within the program policies and
procedures.
C. Family income means total cash receipts before taxes from all sources, with the
exceptions noted below. Income includes money wages or salary before deductions; net
income from non-farm self-employment; net income from farm self-employment;
regular payments from Social Security or railroad retirement; payments from
unemployment compensation, strike benefits from union funds, workers'
compensation, veterans benefits (with the exception noted below), public assistance
(including Temporary Assistance for Needy Families, Supplemental Security Income,
Emergency Assistance money payments, and non-Federally funded General Assistance
or General Relief money payments); training stipends; alimony, child support, and
military family allotments or other regular support from an absent family member or
someone not living in the household; private pensions, government employee pensions
(including military retirement pay), and regular insurance or annuity payments; college
or university scholarships, grants, fellowships, and assistantships; and dividends,
interest, net rental income, net royalties, and periodic receipts from estates or trusts;
Page 46 of 73
and net gambling or lottery winnings for all family members living in the household
(non-relatives, such as housemates, are not included). It is calculated without
consideration of taxes paid or anticipated.
D. For purposes of CSBG income verification, family income does not include capital gains;
any assets drawn down as withdrawals from a bank, the sale of property, a house, or a
car; or tax refunds, gifts, loans, lump-sum inheritances, one-time insurance payments,
or compensation for injury. Also excluded are noncash benefits, such as the employer-
paid or union-paid portion of health insurance or other employee fringe benefits; food
or housing received in lieu of wages; the value of food and fuel produced and consumed
on farms; the imputed value of rent from owner-occupied non-farm or farm housing;
and such Federal non-cash benefit programs as Medicare, Medicaid, food stamps,
school lunches, and housing assistance, and certain disability payments made to
disabled children of Vietnam veterans as prescribed by the Secretary of Veterans Affairs.
E. In determining family income, self-declaration of income must be used only as a method
of last resort. The signature of the applicant must appear on a self-declaration
statement.
8005. The poverty guideline is not a consideration when non-consumer-specific, community
development activities are undertaken to alleviate the causes and effects of poverty.
8006. Should CSBG funded staff, through collaborative agreements entered into with a
primary purpose to alleviate the causes and effects of poverty, have access to material aid
that is distributed using a funder-defined income guideline different from that required of
CSBG, the funder’s income guideline must prevail.
8007. When case management activities, and other non-material aid, are funded by multiple
funding streams, a pro rata share of cases qualifying at the 125 percent level must be
equivalent to, or greater than, the percent of CSBG funding supporting the activities.
8008. Applicant intake documents and/or digital systems must be uniform among all centers
and must solicit, at a minimum, the following information:
A. Date of application.
B. Applicant name and address. And, for family members – name, gender, date of birth,
disability status, health insurance status, education level (for family members whose age
is equal to or greater than 24), family size, income, and income types (source) for all
household earners, family type, housing type, ethnicity, and race.
Page 47 of 73
C. Applicant’s signature.
D. An identification of the intake worker.
8009. Consumer files need not contain copies of documents used to certify income. If such
documentation is not included in the file, the file must contain a statement detailing those
documents observed and how the family income was calculated. The statement must be
signed by the person evaluating the income. When an applicant is deemed ineligible, a
statement must include reason(s) for ineligibility.
8010. The entity must verify that the applicant is a resident of the State of Kansas. Services
funded in whole or in part by Kansas CSBG funds or provided by CSBG funded staff must not
be provided to individuals who are not residents of the State of Kansas.
A. Consumer files need not contain copies of documents used to determine residency. If
such documentation is not included in the file, the file must contain a statement
demonstrating how residency was determined.
8011. Applications for CSBG services can be accepted only from adults (18 years or older) or
emancipated minors. It is noted that children receiving foster care services represent a
household of one for the purpose of eligibility determination. In some cases, it might be
appropriate to list the foster child as the applicant; entity policy will prevail.
8012. The period for which a consumer is eligible for CSBG funded services and material aid
must be defined in the eligible entity’s written procedures and must be uniformly applied at
all centers and service points.
A. In lieu of a published definition of “eligibility period,” the eligibility period must be the
same length as the period used for income verification.
8013. A statement of eligibility recertification must be completed at the time of the first
service request following expiration of the previous eligibility period. All requirements
applicable to eligibility certification, including income verification, apply to recertification.
The criteria established by the eligible entity for income verification must be used for
income recertification. Other pertinent information (such as household size, address, etc.)
should be updated, as applicable.
8014. A record of service provision must be included in the service record of each eligible
applicant. This record must include the initial date of service and the services provided, as
well as the date and services provided for each succeeding service contact. Records of
Page 48 of 73
service provision are encouraged to be maintained electronically, if the entity agency is able
to maintain separate records on each program participant.
8015. Services provided for applicants who are determined to be ineligible are restricted to
information and referral.
Page 49 of 73
SECTION 9 – FISCAL POLICIES AND PROCEDURES
9000 GENERAL
9001. Entities expending CSBG resources must be guided by 45 CFR Part 75 – Uniform
Administrative Requirements, Cost Principles, and Audit Requirements for HHS Awards
unless a more stringent practice is required by KHRC.
9002. Each Community Action Agency must maintain a fiscal operation manual, preferably
digital, that details all fiscal policies and procedures for the entity, including maintenance of
records, procedures for disbursement, maintenance of property records, procurement
procedures and all other relevant policies and procedures.
A. Community Action Agencies must, on the submission of the annual refunding
application, ensure that KHRC is in possession of a current, dated copy of the approved
fiscal policies.
9003. As a condition for receipt of CSBG funds, Community Action Agencies must have a
financial management system that meets the following standards prescribed by the Federal
OMB, including:
1. Each entity must be able to make accurate, current, and complete disclosure of each
CSBG award.
2. Each entity must maintain records that adequately identify the source and application of
funds for each CSBG award.
3. Each entity must maintain effective control over and accountability for all funds,
property and other assets and must adequately safeguard all such assets and must
assure that they are used solely for authorized purposes.
4. Each entity must have established, written procedures for determining the
reasonability, allowability and allocability of costs in accordance with the provisions of
the applicable cost principles and the terms of its contracts.
5. Each entity must make comparison of actual outlays with budget amounts for each
grant or other agreement.
Page 50 of 73
6. Each entity must maintain accounting records that are supported by source
documentation.
9004. Each entity must provide assurances that any organization to which CSBG funds are
sublet has a financial system which meets the standards identified in Item 9003.
9100 GRANT TRANSACTION REPORTING
This section prescribes procedures to summarize expenditures made and grant funds
unexpended for each CSBG award, report the status of grant cash received, and request
advances and reimbursements.
9101. Payments to Community Action Agencies for grants funded with the 90 percent pass-
through funds will generally be made on an advance basis.
9102. Entities report CSBG expenditures and receipts and initiate a grant payment using the
Grant Transaction Report (GTR) as provided by KHRC.
A. Payments will typically be in the amount requested.
1. Unless a unique circumstance is communicated, cash-on-hand in excess of two-
and-one-half times the size of the entity’s to-date, average monthly
expenditures, must typically require an inquiry as to the need for the requested
payment.
B. Payments will be processed to arrive on or near the first day of the month.
9103. The CSBG Grant Transaction Report must:
A. Contain an accurate, current, and complete disclosure of the financial results related to
the identified CSBG grant.
B. Contain the original or digital signature of the Executive Director/CEO or other individual
identified by the eligible entity as an authorized signatory on the Authorized Signatories
form submitted to KHRC with the refunding application.
1. Fiscal staff will not be recognized as an authorized signatory for this purpose.
2. The authorized signatories list retained by KHRC may be amended or revised as
needed through the attestation of the Executive Director/CEO and the chair of
the governing board.
Page 51 of 73
C. Be submitted to the CSBG Program Manager, KHRC for each month during which funds
are received or disbursed.
D. Be received in SharePoint by KHRC no later than the 15th day of the month following
the month for which the report has been prepared. The 15
th
day of the month
requirement may be extended by the Program Manager per an approved email request.
1. Signed e-mailed (PDF) versions are acceptable.
9104. Revised Grant Transaction Reports may be submitted, as needed and with explanation,
prior to the submission of the “FINAL” report.
9105. Each entity must retain a copy of submitted Grant Transaction Reports. Worksheets
and/or ledgers which support the information contained within the report must be attached
to the entity’s copy.
9106. Entities will be contacted if reports contain errors or insufficient information. Those
impacted may be required to submit corrected reports. Changes to correct obvious errors
will be allowed on verbal agreement made between the entity’s representative and KHRC
staff. Such changes are to be noted on the KHRC copy by staff. This notation is to be
initialed and dated. Should a subsequent disagreement occur regarding Grant Transaction
Reports so altered, the entity must be required to submit, for KHRC consideration, a revised
Grant Transaction Report for the affected period.
9107. Grant Transaction Reports which are late or require correction or additional information
delay the processing of payments. In the event that a report is late or inaccurate, payment
may be delayed until the following month’s payment cycle.
9108. KHRC may, at its discretion, respond to an off-cycle payment request.
9109. At the point that all funds for a particular award have been received, receipted, and
expended, the entity must submit a clearly identified “FINAL” Grant Transaction Report to
KHRC. The final report must contain all expenditures and receipts for the grant period.
A. Final reports on non-discretionary CSBG awards will be due no later than 60 days after
the end of the grant period.
9110. As part of its closeout of the grant and based upon final reports and its own accounting,
KHRC will determine the final payment to the entity or repayment amount, if any, due
KHRC. Results of this closeout review will be delivered to the respective entity.
Page 52 of 73
9200 EXPENDITURES
9201. Expenditures must be in accordance with the accepted budget except when allowable
variances are applicable.
9202. If an eligible entity expends grant funds contrary to the provisions of the grant award,
such action must require the repayment of those funds if the expenditure violated statutory
provisions. KHRC may require repayment of expenditures that do not conform to the
provisions of the grant award even if the expenditures are determined allowable by
statutory provisions.
9203. Community Action Agencies must not give CSBG-funded staff raises/incentive pay from
CSBG funds after the entity’s CSBG budget has been approved unless such raises are in
keeping with the entity’s policy on salary increases. CSBG funds may only be used to pay for
the pro rata share of vacation leave, sick leave, retirement, and other fringe benefits of
CSBG funded positions.
9204. Community Action Agencies must reimburse staff and volunteers for travel at uniform
rates and in accordance with the entity’s written procedures. No staff member or volunteer
shall be paid a higher reimbursement rate than any other staff member or volunteer.
9205. Procurements made in whole or part with CSBG funds are to be made in accordance
with 45 CFR Part 75 – Uniform Administrative Requirements, Cost Principles and Audit
Requirements for HHS Awards.
9206. Where an eligible entity proposes to enter into a sole source contract or a contract
where only one bid or proposal is received, such contract shall be subject to prior approval
by KHRC if the aggregate expenditure for all items to be procured from the bidder/offeror
will exceed $3,000 in a 12-month period. The eligible entity may submit the request for
approval to KHRC in writing. KHRC will respond to the request within 60 days.
9207. To the greatest extent practicable, all equipment and products purchased with funds
made available by CSBG should be American made.
9208. All consulting contracts to be funded, in whole or part, with CSBG funds must receive
prior approval from KHRC. The request for approval must be in writing, and must include:
A. The need expected to be met by hiring a consultant.
B. The name and address of the individual(s) to be hired.
Page 53 of 73
C. The resumé of the consultant(s) to be hired.
D. A description of the work to be conducted by the consultant including deliverables.
9209. Expenditures proposed for consulting contracts and submitted with the eligible entity’s
budget require the detail identified in Item 9208.
9210. An entity wishing to subcontract or delegate any part of its CSBG grant for service
activity must receive prior approval from KHRC. Subcontracted activity is bound by State
and Federal requirements.
9211. A contract award (see 2 CFR 180.220) must not be made to parties listed on the
government wide Excluded Parties List System in the System for Award Management
(SAM), in accordance with the OMB guidelines at 2 CFR 180 that implement Executive
Orders 12549 (3 CFR Part 1986 Comp., p. 189) and 12689 (3 CFR Part 1989 Comp., p. 235),
‘‘Debarment and Suspension.’’ SAM is the Official U.S. Government system that
consolidated the capabilities of CCR/FedReg, ORCA, and EPLS.
A. Evidence supporting the contractor’s eligibility to enter into a contract must be
maintained by the contracting agency.
9212. KHRC may require the Grantee to enter into a security agreement or similar instrument,
to be provided by KHRC, granting KHRC a secured interest in any personal property
purchased with the grant funds.
9300 PROPERTY MANAGEMENT
9301. CSBG funds may not be used for the purchase or improvement of land, or the purchase,
construction, or permanent improvement (other than low-cost residential weatherization or
other energy-related home repairs) of any building or other facility.
A. The Secretary, HHS, may waive this limitation upon a State request for such a waiver, if
the Secretary finds that the request describes extraordinary circumstances to justify the
purchase of land or the construction of facilities (or the making of permanent
improvements) and that permitting the waiver will contribute to the ability of the State
to carry out the purposes of CSBG.
9302. Community Action Agencies must adhere to the following inventory procedures:
Page 54 of 73
A. Each eligible entity must maintain a dated inventory listing of all property with a unit
cost of $5,000 or more purchased in whole or part with CSBG funds. The listing must
include those elements prescribed by 45 CFR Part 75 – Uniform Administrative
Requirements, Cost Principles, and Audit Requirements for HHS Awards.
B. Community Action Agencies must take a physical inventory of equipment and reconcile
the results with the equipment records in accordance with the requirements of 45 CFR
Part 75 – Uniform Administrative Requirements, Cost Principles, and Audit
Requirements for HHS Awards.
9303. Community Action Agencies must, on submission of the annual refunding application,
ensure that KHRC is in possession of the current, dated inventory listing showing all
property with a unit cost of $5,000 or more, purchased in whole or part with CSBG funds.
9304. When property purchased with CSBG funds is no longer needed for the approved
project, the eligible entity must request from KHRC disposition instructions or permission to
use that property in other programs consistent with CSBG purposes. This provision applies
to property having a current, fair market value of $5,000 or more per unit. The eligible
entity may submit the request in writing for approval to KHRC. KHRC will respond to the
request within 60 days.
9400 BONDING AND INSURANCE
9401. Community Action Agencies must procure fidelity bonding or other protection covering
those who are authorized to sign checks, certify vouchers and/or handle or control funds
(beyond petty cash), checks, securities, or property. The amount of the bond/coverage
required must be adequate to insure the security of CSBG funds or the maximum amount
held in bank accounts at any one time, whichever is higher.
9402. Each eligible entity must maintain documentation assuring that the condition described
in Item 9401 has been met. This assurance may take the form of a letter from a bonding
company or agent stating the type of bond, amount and period of coverage, positions
covered and the annual cost of the bond that has been obtained.
9403. Community Action Agencies are responsible for assuring that delegate agencies
receiving CSBG funds meet the terms of this bonding coverage requirement.
9404. Community Action Agencies must maintain appropriate liability insurance which should
include, at a minimum, directors and officer’s insurance, volunteer and special event
insurance, employment practices liability and general liability.
Page 55 of 73
A. Insurance deductible amounts should not exceed the eligible entity’s unrestricted,
reserve funds.
9500 RETENTION OF RECORDS
9501. Financial records, supporting documents, statistical records, and all other records, in
whatever format, pertinent to a CSBG award must be retained for a period of three years
from the date of submission of the final expenditure report.
9502. If any litigation, claim, or audit is started before the expiration of the three- year period,
the records must be retained until all litigation, claims, or audit findings involving the
records have been resolved and final action taken. (45 CFR § 75.361)
9600 AUDITS
9601. Entities receiving $750,000 or more in Federal funding during fiscal years beginning after
December 26, 2014 must have a Single Audit annually using OMB- defined
methodology.
A. Entities that sublet CSBG funds must ensure that entities to which funds are sublet and
who receive $750,000 or more in Federal funding during fiscal years beginning after
December 26, 2014 are audited annually using OMB-defined methodology.
B. Under certain circumstances, KHRC may require agencies receiving under $750,000 in
Federal funding to have an Independent Audit of their financial statements completed.
9602. Community Action Agencies and subrecipients must allow auditors and State and
Federal personnel to have access to records and financial statements as necessary to
comply with audit and monitoring responsibilities.
9603. KHRC requests a courtesy notification of the completion of annual audits conducted
under Uniform Administrative Requirements, Cost Principles, and Audit Requirements.
A. In response to requests by a Federal agency or pass-through entity, auditees must
submit a copy of any management letters issued by the auditor. (45 CFR § 75.512(e))
9604. KHRC’s Finance Division issues applicable KHRC management decisions following its
review of the Audit Clearinghouse submissions.
Page 56 of 73
9605. Each entity must have in place a systematic method to assure timely and appropriate
resolution of audit findings and recommendations.
(This page is intentionally left blank)
Page 57 of 73
SECTION 10 – PERSONNEL POLICES AND PROCEURES
10000 GENERAL
10001. To provide for the consistent and equitable treatment of employees and to ensure that
all such employees fully understand the terms and conditions of their employment, each
eligible entity must issue published policies which include:
A. Entity rules governing vacations, sick leave, periodic salary increases and other
conditions of employment.
B. A description of any benefit plans with details on entity and employee contributions to
those plans.
C. Any rules governing promotion, separation, resolution of grievances and employee
conduct.
D. A whistleblower policy responsive to the requirements of the Sarbanes-Oxley Act.
10002. Community Action Agencies must, on submission of the annual refunding application,
ensure that KHRC is in possession of a current, dated copy of the approved personnel
policies.
10003. Community Action Agencies must adhere to the following standards governing the
selection of personnel for employment in CSBG supported programs:
A. Employ persons who can perform their duties with competence.
B. Consideration must be given to providing employment opportunities to qualified, low-
income persons.
C. No entity shall discriminate in its hiring and personnel procedures against any applicant
for employment or any employee because of race, creed, color, national origin, religion,
handicap, gender, or age.
10004. Community Action Agencies must adhere to the following practices:
A. The salary and benefits for each position must be in accordance with prevailing practice
in comparable local public or private nonprofit agencies.
Page 58 of 73
B. Agencies must maintain evidence of efforts to ensure salary and benefits are in
accordance with prevailing practice.
C. Time and effort/personnel activity records for all employees paid in whole or part with
CSBG resources, directly or indirectly, including the Executive Director / CEO must be
maintained and must be signed and/or digitally authorized by both the employee and a
supervisor with first-hand knowledge of the employee’s work. (While many non-Federal
entities may still find that existing procedures in place such as personal activity reports
and similar documentation are the best method for them to meet the internal control
requirements, this final guidance does not specifically require them. (COFAR on
Compensation))
1. With regard to the Executive Director/CEO/ officer, the Chairperson of the
Board of Directors may serve as signatory or may appoint another member, or
members, to be the signatory for the purpose of certifying the time and
effort/personnel activity record.
D. An entity may provide a plan for KHRC review and acceptance should it desire an
alternate approach to 10004B for meeting the internal control requirements
appropriate to compensation for personnel services (45 CFR § 75.430).
E. Community Action Agencies must have an established employee grievance procedure.
Employee grievances must be given prompt and fair consideration. Entities must make
provision for review of personnel actions by the Executive Director / CEO in any case in
which there is a claim of unfair treatment or of dismissal without cause.
10005. Individual personnel files must, at a minimum, contain the following records on each
employee:
A. Documentation of all personnel actions including hiring, termination, promotion, and
discipline.
B. Records of the salary and any salary increase received by each full- time and part-time
employee.
10006. Community Action Agencies must maintain an employee-signed and dated job
description, indicating current tasks for which the employee is held accountable.
Organizational Standard 7.3 requires private entities to have job descriptions which have
been updated within the past five years.
Page 59 of 73
10007. Private non-profit entities must maintain on file an attestation that each employee has
received and reviewed the Community Action Code of Ethics
(https://www.caplaw.org/resources/modelpoliciesDocuments/CAPLAW_SampleCodeofEthi
cs.pdf). Public entities must maintain on file an attestation that each employee within the
CSBG operational unit has received and reviewed the Community Action Code of Ethics.
10008. No person shall hold a position of employment over which a family member exercises
supervisory authority.
10009. Within three business days of the occurrence or the notification of resignation
(whichever may be earlier), the eligible entity must advise KHRC in writing of the voluntary
or involuntary termination or the hire of key leadership to include, at a minimum, the
following positions:
A. Executive Director / CEO
B. Fiscal Officer
C. Community Services Director
D. Personnel Officer
E. Head Start Director (if applicable)
F. Weatherization/Housing Director (if applicable)
10010. Community Action Agencies must provide a written professional development plan for
newly hired or newly appointed key CSBG leadership including, at a minimum, those
positions identified in Item 10009 (A-D). This plan must consider the employee’s previous
training and experience. The plan must include a meeting with KHRC staff if applicable and,
as relevant, may include statewide and national conferences such as the Community Action
Partnership (CAP) Convention, CAP Management Intensives, CAPLAW events, the Kansas
Conference on Poverty, Kansas Housing Conference and Wipfli trainings. The plan may also
include the pursuit of the Certified Community Action Professional credential and/or
certification as a ROMA professional.
A. Community Action Agencies shall use the template provided by KHRC or alternative
template approved by KHRC for the professional development plan. The template should
include the timeframe of the professional development plan, the topics for the trainings,
budget, and the location of the trainings.
B. Professional Development plans must be created for key staff that have been at the agency
for two years or less and for staff that have been identified by the agency or KHRC as lacking
the necessary skills.
Page 60 of 73
C. The professional development plan must be reviewed during its term and must be
maintained within the employee’s personnel file.
10100 CODE OF ETHICS
10101. Community Action Agencies must develop written policies which observe the following
minimum standards governing the conduct of board members, employees, and their
immediate families:
A. Board members, employees and members of their immediate families must not solicit
or accept gifts, gratuities, or favors of a monetary value which exceed State of Kansas
Governmental Ethics threshold (currently $40) and courtesy meals which exceed State
of Kansas Governmental Ethics threshold (currently $25) in accordance with Kansas
governmental ethics laws (Statute 46-237a) and specifically from:
1. Any contractor, potential contractor, or subcontractor of the eligible entity,
2. Any person applying for or receiving benefits or services through or from the
eligible entity and,
3. Any person in a position to benefit otherwise from the activities of the eligible
entity.
B. Any board member, employee, or member of his or her family having a financial interest
in a contract with the eligible entity which is supported by CSBG funds must make
complete disclosure of such interest to a responsible and objective eligible entity
official.
C. A board member or employee of an eligible entity must refrain from all participation in
any matter involving CSBG funds which affects, to his or her knowledge, the financial
interest of:
1. His or her business partner(s) or a business organization with which he or she is
associated.
2. Any person or organization with whom he or she is negotiating or has any
arrangement concerning prospective employment.
Page 61 of 73
10102. Board members and employees of Community Action Agencies must refrain from
conduct which violates any of the above standards or gives the appearance of violating the
standards.
10200
THE FEDERAL HATCH ACT
10201. The Coats Human Services Reauthorization Act of 1998 makes non-profit, Community
Action Agencies subject to certain provisions of the Federal Hatch Act. Unless superseded
by Federal statute, guidelines, directives or regulations, the following is intended to provide
guidance to affected Community Action Agencies concerning the appropriate standards of
conduct relative to political activities, as well as to the use of CSBG funds for political
purposes.
A.
Programs must be administered in a politically nonpartisan manner and must avoid
actions which can reasonably be construed as intended to favor one political party over
another or to influence the outcome of an election for public or political office. The use
of CSBG funds, the provision of services and the assignment of personnel must not
result in the identification of the program with any partisan political activity designed to
further any election or defeat of a candidate for public or party office. In addition, CSBG
funds may not be used for the provision of services or the assignment of personnel to
provide transportation in connection with voter registration or electoral activity.
(Guidance at IM No. 81 –
https://www.acf.hhs.gov/sites/default/files/documents/ocs/im_no_81_updated_guidance_on_voter_regi
stration_activities_0.pdf
B. Political issues in many communities will often include activities which may become the
subject of political controversy. Entities, of course, undertake activities dealing with
issues related to their basic program responsibilities, such as organizing and advocating
for the needs of low-income persons. In carrying out their basic mission and goals,
entities may actively engage in campaigns connected with constitutional amendments,
referenda, municipal ordinances, law reform and lawful attempts to influence
government officials to respond to the grievances of persons in poverty. Entities need
not avoid such activities merely because partisan officials or candidates for public office
may take or have taken positions with respect to the issue. Agency officials acting in
their official capacities, however, deal with questions which have become a subject of
political controversy on their merits and not because they are supported or opposed by
a particular party or candidate.
C. Except as set forth in these requirements, employees are free to engage in various kinds
of political activities during their off-duty hours and in their private capacities. A broad
range of participation in elections is permitted. These restrictions apply to the use of
CSBG funds, the provision of services and the assignment of agency personnel in a
Page 62 of 73
manner which identifies any CSBG funded programs with partisan political activity,
nonpartisan activity associated with a candidate or faction in an election for public office
and the transportation of voters to the polls. These restrictions are, in a broad sense,
designed to prohibit the use of CSBG funds for certain purposes. In so far as the
individual employee is concerned, these restrictions deal only with what he or she does
as an employee.
10202. The following restrictions apply to all employees, volunteers, and board members:
A. Employees, volunteers, and board members must not use their official positions,
authority, or influence with the agency for the purpose of interfering with or affecting
the result of an election or nomination for a party or public office.
B. Employees, volunteers, and board members must not directly or indirectly coerce,
attempt to coerce, command, or advise an employee or any other person who is subject
to these restrictions to pay, lend or contribute personnel services to a party, committee,
organization, agency, or person for political purposes.
C. Employees, volunteers, and board members must not use CSBG funds for any political
purpose or to influence any election for public or party office.
D. Employees, volunteers, and board members must not permit the use of equipment or
premises purchased or leased with CSBG funds for any political purpose or to influence
the outcome of any election for public office.
E. Employees, volunteers, and board members must not discriminate, threaten, or promise
discrimination against or in favor of any employee or beneficiary in the program or any
potential employee or beneficiary because of his or her political affiliations or beliefs or
require any applicant, employee, or beneficiary to disclose his or her political affiliation.
F. Employees, volunteers, and board members must not offer any person employment,
promotion, or benefits under the program as a reward for the support or defeat of any
political party or candidate for public or party office or threaten or create disadvantage
in employment or deprivation of benefits as a penalty of such support, except that such
a person may be deprived of employment or subject to lesser penalties for engaging in
activities which are forbidden by this section.
G. Where consistent with State law and local procedures, employees, volunteers, and
board members may engage in voter registration activity. However, CSBG funds may not
be used to transport voters in connection with voter registration or electoral activity.
This restriction applies to the use of CSBG funds as well as the provision of CSBG services
Page 63 of 73
and the assignment of CSBG funded personnel. All persons may provide such
transportation during their off-duty hours so long as they avoid identification of such
off-duty activities with the funded entity.
H. Citizenship education, which includes as part of the curriculum information about the
mechanics and functions of voter registration, may be conducted.
I. Candidates’ meetings, even if all rival candidates for one or more public offices appear,
must not be sponsored, or conducted with CSBG funds or within CSBG purchased or
leased facilities. This restriction on use of CSBG funds does not, however, limit the rights
of employees, volunteers, or board members to participate in candidates’ meetings.
J. An employee is not permitted to be a candidate for public elective office, except that
nonpartisan candidacies and candidacy for political party office are permitted. Thus, no
employee may run in a primary or general election for public office, except as provided
below. An employee planning to be a candidate for partisan public elective office must
resign his or her position prior to announcement of his or her candidacy or
commencement of substantial activities intended directly to promote said candidacy,
whichever occurs first. This restriction applies only to employees. Volunteers and board
members are not subject to these restrictions. This section applies to employees even
though they are on leave or without pay. The prohibitions are lifted only when
employment is terminated.
Page 64 of 73
(This page is intentionally left blank)
Page 65 of 73
SECTION 11 – GENERAL
11000 CITIZEN ACCESS AND PRIVACY
11001. Personal data held by the eligible entity relative to the CSBG supported personnel,
programs and activities and participants must be maintained in accordance with applicable
standards set forth in the Privacy Act of 1974, as amended.
11002. The following documents must be made available for public inspection at the eligible
entity’s central office at a reasonable time. If the requesting person wishes copies of the
document, the eligible entity may request a reasonable fee, not to exceed the actual cost of
preparing such documents. Actual cost may include supply, copying, staff and mailing costs.
The Kansas Open Records Act (KORA) recognizes that certain records contain private or
privileged information. Content identified by the Act as exempt need not be disclosed.
A. CSBG applications as submitted to KHRC.
B. Articles of Incorporation, bylaws, and board membership list.
C. All contracts (including funding, consulting, goods and services and delegate contracts)
pertaining to CSBG funds.
D. Quarterly and annual reports (including audit reports) made to KHRC on projects
supported by CSBG funds.
E. Minutes of meetings of the governing board.
F. Position titles, salary ranges and job descriptions for all compensated positions.
G. All other information required by KHRC to be maintained by the eligible entity not
otherwise exempt under KORA.
11200 COORDINATION WITH
Kansas LIEAP
11201. CSBG legislation (1998) requires “an assurance that the State will ensure coordination
between anti-poverty programs in each community in the State, and ensure, where
appropriate, that emergency energy crisis intervention programs (relating to low-income
home energy assistance) are conducted in such community.” KHRC will meet the assurance
in the following manner:
Page 66 of 73
A. At least once each year, KHRC staff will meet with LIEAP (Low- Income Energy Assistance
Program) staff to support ongoing collaboration and to explore avenues for further
cooperation between the two programs.
B. To the maximum extent possible, KHRC and LIEAP staff will jointly participate in
interagency task forces. Through these efforts, KHRC staff will seek further avenues
through which CSBG and LIEAP can work together.
11202. Community Action Agencies must execute the assurance in the following manner:
A. Community Action Agencies must maintain communication with Kansas Department for
Children and Families area offices that distribute LIEAP funds.
B. Community Action Agencies must make reasonable efforts to establish procedures for
sharing information on recipients of energy assistance services with local LIEAP
programs so that a duplication of energy assistance services can be avoided.
11203. KHRC staff may review efforts to coordinate services with LIEAP through its monitoring
of Community Action Agencies.
11300 COORDINATION WITH OTHERS INCLUDING WORKFORCE SYSTEMS
11301. Kansas Community Action Agencies must coordinate, and establish linkages between,
governmental and other social services programs to assure the effective delivery of such
services to low-income individuals and to avoid duplication of such services. Entities must
coordinate the provision of employment and training activities with entities providing
activities through statewide and local workforce investment systems.
11302. KHRC staff may review efforts to coordinate services with others including workforce
systems through its monitoring of Community Action Agencies.
11303. The Workforce Innovation and Opportunity Act (WIOA) improves job opportunities
through an integrated, job-driven public workforce system. This system encourages state
and local leaders to work together to reshape the workforce system so that it serves the
needs of the nation’s most vulnerable citizens. The WIOA demonstrates a renewed focus
on serving youth and adults who have limited skills, lack work experience and face barriers
to economic success. CSBG is incorporated into the WIOA in the following ways
A. CSBG employment and training activities are included as a required partner for WIOA
one-stop career centers. Under WIOA, the required partners of the WIOA one-stop
Page 67 of 73
career centers may be required to share in infrastructure costs.
(https://caplaw.org/resources/faqs/GrantLaw/CAPLAW_FAQ_WIOA_Sept2015.pdf)
B. CSBG employment and training activities may be included, at the option of the state, in
a WIOA Combined State Plan.
C. Community Action Agencies are encouraged to review the WIOA, and the information
found on the CAPLAW website for more information about the opportunities and
requirements of WIOA as it applies to CSBG Eligible Entities.
11400 COMPLAINTS/APPEALS
11401. Community Action Agencies must have an appeal procedure (Item 8002) which includes
a process through which applicants for service are made aware of their right to appeal a
decision related to their determination of eligibility and addressing claims of discrimination.
11402. Citizen complaints reaching KHRC, including those regarding the denial of a CSBG-
funded service and/or claims of discrimination, will be handled in the following manner.
A. A request for administrative review of the adequacy and equitable application of the
eligible entity’s process must be submitted, in writing, to the Kansas CSBG Program
within 30 days of notice of action/event. Upon receipt of the request, KHRC staff will
copy the request for the subgrantee whose decision/action is in question. The
subgrantee will be requested to supply documents relevant to its decision/action within
seven business days of KHRC’s receipt of the complaint.
B. KHRC CSBG staff will review supporting documents and will respond in writing to the
complainant within 30 days of receipt of the request.
C. If the complainant is dissatisfied with the decision of the CSBG staff, he/she may appeal
to the Executive Director of KHRC and may include additional documentation
appropriate for review. The Executive Director will respond in writing to the appellant
within 30 days of receipt of the appeal.
D. The decision of the Executive Director of KHRC is the final administrative remedy in the
process. If the complainant is dissatisfied with the final decision, he/she may seek
remedy through the court system.
11500 FEDERAL INVESTIGATIONS
11501 The state will permit and cooperate with Federal investigations undertaken in accordance with
Section 678D of the CSBG Act, as required by the assurance under Section 676(b)(7) of the CSBG Act.
Page 68 of 73
(This page is intentionally left blank)
Page 69 of 73
SECTION 12 – DISCRETIONARY FUNDS
12000 GENERAL
12001. 42 USC § 9901, et seq., as amended, requires that 90 percent of each State’s allocation
be distributed to Community Action Agencies. No more than 5 percent may be used by the
State to cover the cost of administering the grant. The remainder may be used at the State’s
discretion for discretionary projects that are consistent with the purposes of the CSBG
legislation.
12002. KHRC may award discretionary grants for a wide variety of projects as indicated within
the CSBG State Plan.
12003. Discretionary funds may be awarded through a competitive Request for Proposal (RFP)
process or awarded directly to the Community Action Agencies, KACAP or other eligible
entity based on an identified need of the network.
12004. KHRC may issue more than one RFP per year, depending on availability of funds.
12005. Organizations eligible to receive grants supported through discretionary funds include
Community Action Agencies providing services in Kansas, KACAP and other organizations
with the primary purpose of ameliorating the causes and conditions of poverty in Kansas.
A. Sections within the Kansas Community Service Block Grant Manual of Policies and
Procedures, which address requirements specific to Community Action Agencies, may
not apply to all recipients of grants supported through the State’s CSBG discretionary
funds.
B. Organizations selected to receive a CSBG discretionary award will be assessed for
eligibility by checking the government-wide Excluded Parties List System in the System
for Award Management (SAM), in accordance with the OMB guidelines at 2 CFR 180
that implement Executive Orders 12549 (3 CFR Part 1986 Comp., p. 189) and 12689 (3
CFR Part 1989 Comp., p. 235), ‘‘Debarment and Suspension.’’
C. Organizations selected to receive a CSBG discretionary award will be informed of audit
requirements and will be assessed for the applicability of the requirements.
D. Non-community action agencies must demonstrate how they have coordinated with the
community action agency in their service area to avoid duplication of efforts.
Page 70 of 73
E. KHRC will complete an assessment of risk on agencies receiving discretionary funding.
Documentation of the risk assessment will be maintained in the agency’s program file.
12100 AVAILABILITY OF FUNDS
12101. By statute up to 5 percent of the State’s CSBG allocation may be used for discretionary
projects. In the event that the State does not use the entire 5 percent of the total reserved
for KHRC’s administrative expenses, the remainder may be used to fund discretionary
projects.
12200 FUNDING GUIDANCE
12201. As prescribed within the State Plan and if applicable, KHRC will, near the start of each
program year, issue funding guidance describing the forms, procedures, and deadlines for
submission of discretionary proposals. Notice will be sent to each eligible entity and will be
posted to the KHRC web site.
12300 REPORTING REQUIREMENTS
12301. Projects supported by sublet discretionary funds are subject to reporting requirements
defined within the contractual agreement.
12400 MONITORING
12401. Discretionary awards are subject to a modified system of CSBG monitoring. Information
regarding reporting requirements and monitoring will be identified by KHRC within the
Notice of Award.
Page 71 of 73
DEFINITIONS
Abrupt - Change without preparation or warning.
Case Management - Case management is the process used to move clients from where
they are now to increased self-sufficiency. The process includes a variety of strategies,
techniques and resources designed to build on existing strengths while overcoming
barriers.
CAA – Community Action Agencies are nonprofit corporations or public entities funded
by the federal Community Services Block Grant. To receive CSBG funding, the eligible
entity must maintain a tripartite board and be capable of providing a broad range of
services designed to eliminate poverty and foster self-sufficiency.
CAP – Community Action Partnership is a national organizational that provides technical
assistance, training, and other resources to the Community Action network.
CAPLAW – Community Action Program Legal Services, a tax exempt, nonprofit
membership corporation dedicated to providing the legal, governance, and
management resources to the national Community Action Agency network.
CCAP – Certified Community Action Professional program is a peer recognition program
that provides national recognition for meeting the standards to be identified as a CCAP.
Conflict of Interest – a situation in which there is a personal or financial interest that
compromises or could compromise a person’s independence of judgement in exercising
his or her responsibilities.
Compliance Matter/Finding - KHRC’s designation for a CSBG deficiency.
Consulting - Consulting refers to the practice of helping organizations improve their
performance, primarily through the thorough analysis of existing business problems and
the development of plans for improvement. Organizations hire the services of
consultants for a number of reasons including, for example, to gain external and
presumably more objective advice and recommendations, to gain access to the
consultants' specialized expertise or simply as temporary help during a one-time
project, where the hiring of permanent employees is not required.
Eligible Entity - One that carried a designation as a Community Action Agency or was a
qualifying organization serving migrant or seasonal farm workers as of the day before
Page 72 of 73
the enactment of the Coats Human Services Reauthorization Act of 1998, has retained
that designation and has a tripartite board or one that, subsequent to and in accordance
with the Act, has been designated by the Governor, has retained that designation, and
has a tripartite board. Community Action Agencies are eligible to receive a proportional
share of an amount equal to 90 percent of the Kansas CSBG allocation.
ESG – Emergency Solutions Grant. A federal grant funded by Housing and Urban
Development and administered by Kansas Housing Resources Corporation. ESG funds
may be used for street outreach, emergency shelter, homelessness prevention, rapid
rehousing and HMIS. (https://www.hudexchange.info/programs/esg/esg-
requirements/)
Executive Director / CEO - For the purposes of this manual, the Executive Director / CEO
is that individual who is the senior leader responsible for the day-to-day operation of
the CSBG-eligible entity or in the case of a public entity, the senior leader responsible
for the day-to-day operation of the CSBG funded operational element.
Family - A family can be a single individual. For families of more than one individual, the
definition of “family” is a group of two or more persons related by birth, marriage, or
adoption who live together; all such related persons are considered as members of one
family. For instance, if an older married couple, their daughter, her husband and two
children, and the older couple’s nephew all lived in the same house or apartment; they
would all be considered members of a “family.”
(CSBG Information System (IS) Instruction Manual; Sections A – G, updated October 2015)
A. Agencies may choose to use this definition of family or use another definition.
Agencies must document the definition of family in their policies and
procedures. The definition of family could include people who are related by
birth, marriage, adoption, or self-determination. Different funding sources may
have their own definition of family. Agencies must clearly identify the definition
of family used and use it consistently with the program.
Federal Fiscal Year - October 1 through September 30.
KACAP - Kansas Association of Community Action Programs. KACAP is the state
association of community action agencies in Kansas. (www.kacap.org)
Information Memorandum (IM) – Guidance issued by the Office of Community Services
to assist in implementing the CSBG legislation, program instruction and policy
clarification.
Page 73 of 73
KanDo! ROMA Task force – a statewide taskforce comprised of representatives from the
eight community action agencies, Kansas Housing Resources Corporation, and the
Kansas Association of Community Action Programs. The KanDo! Taskforce’s mission is
to develop and implement an outcomes-based system that will enable the Network to
demonstrate Community Action’s effectiveness and fiscal accountability to the people
of Kansas, community partners, funders, staff, Board of Directors, and policy makers.
KanDo! ROMA Plan – a fluid document that was developed to ensure the Kansas
Network remains current with all national and state reporting requirements. The
KanDo! plan provides guidance on ROMA Next Gen as it relates to the Kansas Network.
Kansas Resident - Black’s Law Dictionary defines residency as “bodily presence as an
inhabitant in a given place.”
Material Aid - Tangible goods and or cash assistance provided with the primary purpose
of alleviating a cause or effect of poverty. Cash assistance may be provided in the form
of a prepaid debit card, a voucher or direct vendor payment. Within the Kansas CSBG
network, goods given as material aid have included such things as school supplies, liquid
nutrition, calculators, and food vouchers.
Organizational Standards - Standards for CSBG Community Action Agencies as defined
within the U. S. Dept. of Health and Human Services, Administration for Children and
Families, Office of Community Services, Division of State Assistance Information
Memorandum (IM) 138 (http://www.acf.hhs.gov/programs/ocs/resource/csbg-im-138-
state-establishment-of-organizational-standards-for- csbg-eligible-entities).
Program Year (Kansas CSBG) - April 1 through March 31.
Property - Property means, unless otherwise stated, real property, personal property,
equipment, intangible property, and debt instruments.
WIOA – Workforce Innovation and Opportunity Act – Signed into law in 2014, the WIOA
is designed to help job seekers access employment, education, training, and support
services to succeed in the labor market and to match employers with the skilled workers
they need to compete in the global economy.
