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State CSBG Lead Agencies follow direction from Information Memorandum 138 on establishing a methodology for assuring implementation of the full set of organizational standards. Regarding the State’s responsibility, the IM dictates:
“Once the expectations for organizational standards are established and communicated to the eligible entities across a State, the State CSBG Lead Agency is responsible for assessing the status of standards among all of the eligible entities annually and for reporting to OCS on the standards in the CSBG Annual Report. States may design an approach for assessing organizational standards that fits within the oversight framework in their State. Regardless of the approach, States must ensure the assessment of standards is independently verified by the State or a third party.”
Additionally, the IM is clear that States are to ensure the accountability of all CSBG eligible entities in meeting the Standards. “States are responsible for ensuring that the eligible entities meet all State-established organizational standards. Some standards (i.e., strategic planning, developing an agency-wide budget, etc.) may take several years for eligible entities to meet, but every entity must make steady progress toward the goal of meeting all standards.”