CSBG Reporting Requirements & ROMA Guide

The CSBG Reporting Landscape

CSBG reporting operates at two levels: state reporting to OCS and local reporting to the state. As a CAA director or grants manager, you are primarily responsible for reporting to your state CSBG office. The state then aggregates local data and submits federal reports to OCS. However, understanding the full reporting chain helps you appreciate why certain data points are required and how your local reporting feeds into the national picture.

The reporting framework is built on ROMA — Results Oriented Management and Accountability — which provides the standardized outcome measures, the National Performance Indicators (NPIs), and the logic for connecting services to results. ROMA is not separate from reporting; it is the foundation on which all CSBG reporting rests.

ROMA: The Foundation of CSBG Reporting

ROMA was mandated by the 1998 reauthorization of the CSBG Act. It requires every eligible entity to implement a performance management framework that measures results — not just activities. The distinction matters: ROMA pushes agencies beyond counting how many people walked through the door and toward measuring what changed in their lives because of the services they received.

ROMA Next Generation

ROMA Next Generation (ROMA NG) is the current iteration of the framework, developed by the Community Action Partnership with support from OCS. It refined the original ROMA cycle and introduced standardized tools and training resources. The core ROMA cycle remains the same five steps described in the Application Guide: Assessment, Planning, Implementation, Achievement of Results, and Evaluation.

ROMA implementation is assessed as part of the organizational standards (Category 9: Data and Analysis). Agencies that cannot demonstrate active ROMA use — not just data collection, but data-driven decision making — will receive findings during their organizational standards assessment.

National Performance Indicators (NPIs)

National Performance Indicators are the standardized measures used across the CSBG network to track outcomes. They are organized by the three levels of CSBG's theory of change: individual and family, community, and agency capacity. Every CSBG-eligible entity reports on NPIs, and the aggregated data forms the basis of the national CSBG performance picture.

Individual and Family Level Outcomes (NPI 1)

NPI 1 tracks changes in the conditions of low-income individuals and families served by CSBG-funded programs. These are the most granular outcomes and require individual-level data collection. The major domains include:

Individual and family outcomes require that you track each participant through intake, service delivery, and follow-up to document the change that occurred. This is where your data systems and case management tools are critical. You cannot report NPI 1 outcomes if you only collect intake data and never follow up to measure change.

Community Level Outcomes (NPI 2)

NPI 2 tracks changes at the community level — improvements in conditions that affect the broader low-income population in your service area. These outcomes are typically harder to measure than individual outcomes because they involve systemic or environmental changes rather than individual status changes.

• NPI 2a — Community Improvement: New community facilities or infrastructure, new or expanded services, increased community resources, strengthened partnerships
• NPI 2b — Community Quality of Life: Increased community safety, improved neighborhood conditions, expanded transportation options, increased civic participation
• NPI 2c — Community Revitalization: New jobs created, businesses started or expanded in low-income areas, affordable housing units created or preserved

Community-level outcomes often require different data sources than individual outcomes — community surveys, partner reports, public data on housing starts, economic indicators, or service utilization data from other agencies. Build relationships with community partners and public data sources that can help you document these changes.

Agency Capacity Outcomes (NPI 3)

NPI 3 measures the agency's own capacity to serve the community. These indicators recognize that strengthening the organization itself is a legitimate CSBG outcome:

• NPI 3.1 — Mobilized Resources: Additional funding leveraged, volunteer hours contributed, in-kind resources secured. This indicator demonstrates CSBG's leverage effect — the ability of CSBG dollars to attract additional resources.
• NPI 3.2 — Partnerships: Number and types of partnerships established or maintained, including formal MOUs, collaborative service delivery arrangements, and advocacy coalitions
• NPI 3.3 — Number of Volunteers: Total volunteers mobilized and volunteer hours contributed to agency programs

The CSBG Annual Report

The CSBG Annual Report is the primary vehicle through which states report to OCS on CSBG performance across their networks. As a local eligible entity, you report to your state, and the state compiles the data for federal submission. The Annual Report is organized into modules, each serving a distinct purpose.

Module 1: State Administration

Module 1 captures state-level CSBG administration data — how the state distributed funds, state plan compliance, T/TA activities, and oversight actions taken during the reporting period. This module is primarily the state's responsibility, but the information reflects the health of the network in which you operate. States report on the number of eligible entities in their network, organizational standards assessment results across all entities, and any adverse actions taken.

Module 2: Individual and Family Data

Module 2 is where your NPI 1 data lives. It captures the individual and family outcomes achieved through CSBG-funded services, organized by the domains listed above. This module requires:

• Demographic data: Age, gender, race/ethnicity, household size, income level, and other characteristics of individuals and families served
• Service data: Types and volume of services provided, categorized by NPI domain
• Outcome data: The actual changes measured for individuals and families, reported as counts of people achieving specific outcomes within each NPI category

Module 3: Community Level Data

Module 3 captures NPI 2 data — community-level improvements and revitalization outcomes. This module asks agencies to report on community conditions that changed as a result of CSBG-funded initiatives. It includes new or expanded community resources, infrastructure improvements, policy or systems changes, and other community-level outcomes.

Module 4: Agency Capacity Data

Module 4 captures NPI 3 data — agency capacity, resource mobilization, partnerships, and organizational outcomes. This is where you report the total additional funding leveraged through CSBG, the volunteer hours mobilized, and the partnerships maintained. Module 4 data is particularly important for demonstrating CSBG's return on investment, as it quantifies the multiplier effect of CSBG dollars.

The CSBG Information System (IS) Survey

The CSBG IS survey is an annual data collection conducted by the National Association for State Community Services Programs (NASCSP) to capture comprehensive information about the CSBG network. The survey collects data beyond what the Annual Report captures, including:

• Total agency budgets: Not just CSBG funding, but the total resources managed by each eligible entity across all funding sources
• Funding source breakdowns: CSBG, LIHEAP, Head Start, WAP, CDBG, state, local, private, and other sources
• Staffing data: Number of employees, volunteers, and their roles
• Service delivery data: Total individuals and families served across all programs, not just CSBG-funded activities

The IS survey data is published annually and provides the most comprehensive picture of the Community Action network's scope and impact. If you have ever seen statistics like "Community Action served X million people" or "the CSBG network leverages $Y for every federal dollar," those numbers come from the IS survey. Your state will provide specific instructions on data submission.

State vs. Federal Reporting Requirements

Your direct reporting obligation is to your state CSBG office, not to OCS. However, state reporting requirements often exceed the federal minimum because states have their own accountability needs. Understanding both layers helps you prioritize your data collection and reporting efforts.

Building Effective CSBG Reporting Systems

Reporting quality depends entirely on the data systems and processes you build into your program operations. Agencies that treat reporting as an end-of-year scramble will always produce weaker data than those that integrate data collection into daily operations. Here are the structural elements that support strong reporting:

Case Management and Data Collection

Your case management system is the engine of your NPI 1 reporting. It needs to capture participant demographics at intake, document services provided, and — critically — record outcomes at follow-up. Common gaps include:

• No baseline measurement: If you do not document a participant's status at intake (employment status, income level, housing situation), you cannot measure change
• No follow-up protocol: Outcomes require checking back with participants after services to see if the change held. Many agencies deliver services but never follow up.
• Service-NPI misalignment: Your intake form collects data that does not map to the NPIs you are reporting on, creating a disconnect between data systems and reporting requirements

Staff Training on Data Quality

Frontline staff who enter data into your systems are the foundation of your reporting quality. If they do not understand why certain fields matter, they will skip them or enter inaccurate information. Invest in training that connects data entry to reporting outcomes — show staff how the intake form they complete becomes the NPI data that goes to the state and federal level. When staff understand the purpose behind data collection, compliance improves dramatically.

Quarterly Internal Reviews

Do not wait until the annual reporting deadline to review your data. Conduct quarterly internal reviews to check data completeness, identify gaps, and course-correct. Compare your year-to-date outcomes against the targets set in your Community Action Plan. If you are tracking behind, you have time to investigate why and adjust. Presenting these quarterly reviews to your board also satisfies organizational standards requirements for board oversight of program performance.

Common Reporting Challenges and Solutions

Undercounting Outcomes

Many agencies undercount their outcomes because they do not have systems to capture all the changes that occur. If a participant in your energy assistance program also connects with a budgeting workshop and subsequently opens a savings account, that is both an NPI 1d (housing/energy) and NPI 1c (asset building) outcome. Train staff to look for and document secondary outcomes that arise from service coordination.

Distinguishing Outputs from Outcomes

"We provided 500 families with energy assistance" is an output. "350 of those families maintained utility service throughout the winter" is an outcome. The NPI framework is outcomes-focused. If your reports are dominated by service counts without corresponding change measurements, your ROMA implementation will be flagged. Restructure your data collection to capture both what you delivered and what resulted from that delivery.

Multi-Funder Attribution

When a program is funded by CSBG plus other sources (LIHEAP, state funds, private grants), determining which outcomes to attribute to CSBG can be confusing. The general approach is that outcomes achieved through programs funded in part by CSBG can be reported as CSBG outcomes, even if CSBG was not the sole funder. However, check your state's guidance on attribution rules, as practices vary. Some states require proportional attribution; others allow full reporting of outcomes from any CSBG-supported program.

Reporting Calendar

While specific deadlines depend on your state, the general CSBG reporting calendar follows this pattern:

Build these deadlines into your organizational calendar at the beginning of each grant year. Do not rely on state reminders — proactively track your reporting obligations and allow adequate time for data compilation, quality review, and board presentation before each deadline.