CAPLAW eNews Bulletin - October 2015 No Images? Click here

This Attorney Network webinar is intended to help attorneys better understand the rules that apply to CAAs proposing to subgrant federal funds. In it we discuss the framework that applies when determining whether a subrecipient or a contractor (vendor) relationship is created. In addition, we cover the applicable rules that affect the drafting of a subgrant agreement and walk through a sample agreement to highlight key contractual provisions.

To access this webinar and related materials click here.


In this webinar series we examine specific compliance issues surrounding the employer mandate, focusing first on how to identify who is full-time employee covered by the mandate and then on how to meet the new reporting requirements, using new IRS Forms 1094 and 1095. Learn more about the series.


Indirect Cost FAQ

This FAQ is a series of 34 questions and answers about indirect costs, covering a range of topics including the 10% de minimis rate, federally negotiated indirect cost rates, and cost allocation. The FAQ is available here.


The new Workforce Innovation and Opportunity Act (WIOA) FAQ, addresses frequently asked questions about the implementation of WIOA and how it differs from its predecessor the Workforce Investment Act (WIA). The FAQ is available here

Explore the FAQ Archive.

2016 National Training Conference

Update on the Uniform Guidance

In September 2015 the Office of Management and Budget (OMB) and the Council on Financial Assistance Reform (COFAR) issued two important updates to the Uniform Guidance. First, OMB published “correcting amendments” to the Uniform Guidance. While most of the changes are technical in nature, OMB appears to have made a few more substantive revisions.  The correcting amendments were published in the Federal Register at 80 F.R. 54407, and can be viewed on the Federal Register website here or in PDF format here.  Second, COFAR updated its Frequently Asked Questions (FAQ) about the Uniform Guidance. COFAR originally created the FAQ to provide information on implementation of the Uniform Guidance and the recent update contains 25 new questions and several amended questions. The updated FAQ can be viewed on COFAR’s websiteRead more.


IRS Releases New Forms and Guidance for ACA Reporting

The IRS has issued final forms and instructions for 2015 reporting under the Affordable Care Act (ACA). The forms and instructions are similar to the drafts issued earlier this year, with several clarifications. The IRS has also published a number of other resources to assist employers in complying with ACA requirements, addressing issues such as electronic reporting under the Affordable Care Act Information Return System.  Additionally, the IRS introduced a new web page to assist Applicable Large Employers complying with the ACA. To learn more about these updates, including how to access the new IRS resources and webpage, see the Health Care Reform Alert from the law firm Ballard Spahr.


Head Start Guidance on Child Abuse Reporting and Supervision

On September 18, 2015, the Office of Head Start (OHS) released two Information Memoranda (IMs) addressing program issues that Head Start grantees commonly face.   ACF-IM-HS-15-04: Mandated Reporting of Child Abuse and Neglect discusses reporting suspected child abuse or neglect to the appropriate state child protection agency where there is a reasonable suspicion that such abuse or neglect has occurred or there is a substantial risk that it may occur, either in the care of a Head Start agency or outside of the program.  ACF-IM-HS-15-05: Supervision and Transitions discusses a variety of strategies to help programs ensure that children are not left unsupervised at a Head Start program, on playgrounds, or on buses.  The IM also addresses reporting incidents of unsupervised children and OHS’s role in the investigation process. Read More.


Using CSBG Funds for ACA Information and Referrals

The federal Office of Community Services (OCS) recently issued guidance in the form of Information Memorandum (IM) 143 regarding the use of CSBG resources to support the provision of information and referrals for Affordable Care Act (ACA) benefits and services. Making the connection between the core intentions of the CSBG Act and the lack of health insurance coverage for many living in poverty, IM 143 encourages CAAs to use CSBG funds to support a community-coordinated response to improving health outcomes that may impact the causes and conditions of poverty. A number of specific ACA-related activities are suggested, including disseminating information about the ACA, displaying materials from, incorporating a question about health insurance coverage into the intake process, connecting individuals to community health centers, or facilitating access to local ACA Navigators. CAAs may provide referrals to ACA resources even when a CAA determines, in the course of an intake process, that an individual is not eligible for CSBG services. However, the IM reminds CAAs that, if an individual is not CSBG-eligible, the CAA can only refer the individual to non-CSBG services, since providing ongoing CSBG services would not be appropriate.  Read the IM here


This e-News Bulletin is part of the Community Services Block Grant (CSBG) Legal Training and Technical Assistance (T/TA) Center. It was created by Community Action Program Legal Services, Inc. (CAPLAW) in the performance of the U.S. Department of Health and Human Services, Administration for Children and Families, Office of Community Services Cooperative Agreement – Grant Award Number 90ET0441-01. Any opinion, findings, conclusions, or recommendations expressed in this material are those of the author(s) and do not necessarily reflect the views of the U.S. Department of Health and Human Services, Administration for Children and Families.