Transcript CDBG 2009 FINANCIAL MANAGEMENT
YOUR 2010 CDBG Grant Administration, Procurement, & Financial Management
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2010 CDBG Recipients’ Workshop
2010 COMPETITION STATS
• • • • • App’s received: 159 @ $74,459,378 CDBG’s awarded: 75 @ $35,643,405 47% of applications were funded 54,540 beneficiaries, 50,163 LMI (92%) 11 more awards & $3+ million more than in 2009
Congratulations !!!
!!!
2010 CDBG Recipients’ Workshop
Page 2 September 30, 2010
What We Will Cover…
1.
2.
3.
4.
5.
6.
7.
Grant Award Package Setting up Your CDBG Bank Account CDBG Compliance with Your Field Rep Start-Up, Citizen’s Participation & Fair Housing Procurement Financial Management Closeout
2010 CDBG Recipients’ Workshop
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GRANT AWARD PACKAGE
1. Statement of CDBG Award 2. Budget Summary 3. General & Special Conditions 4. Statement of Revisions 5. Civil Rights Compliance Certification 6. Authorized Signature Card 7. Authorization Agreement for Automatic Deposits (ACH)
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1. STATEMENT OF CDBG AWARD
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Your CONTRACT with DCA
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Include GRANT # on ALL forms & correspondences to DCA
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GRANT PERIOD: An Important Timeline to Keep Sign & Return WHITE COPY to DCA.
KEEP PINK COPY FOR YOUR FILES.
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Award Package, Cont.
2. BUDGET SUMMARY
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Your Official Budget
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Use THIS budget (not application’s) to create your ledger, accounting records
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Local match/leverage is listed at bottom; keep documentation of it – it will be monitored
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DO NOT SIGN & RETURN this form w/award pckg
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Award Package, Cont.
3a. GENERAL CONDITIONS
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Included in ALL CDBG awards
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Includes standard, mandatory CDBG compliance responsibilities (Environmental, Section 3, Conflict of Interest, etc.)
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Must be signed & returned in award package
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Award Package, Cont.
3b. SPECIAL CONDITIONS
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Specific to each CDBG Award
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Elected Official’s Signature = “I agree to clear these conditions ASAP.” Signature ≠ clearance
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SC is not cleared until you receive a “Grant Adjustment Notice” (no clearance, no $$$)
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Must be signed & returned in award package
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Award Package, Cont.
4. STATEMENT OF REVISIONS
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Your Statement of Award might say, “This award is subject to revisions” →
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Changes to proposal were made (usually budget)
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Review thoroughly, sign & return with award pckg
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Award Package, Cont.
5. CIVIL RIGHTS COMPLIANCE
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To be completed by employee responsible for personnel
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Explain any civil rights complaints in space provided
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Preparer of form plus Chief Elected Official should sign
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Must be signed & returned in award package
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Award Package, Cont.
6a. AUTHORIZED SIGNATURE CARD
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Nothing to do with Bank Account, Everything to do with Draw-Downs.
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Local authorization to sign & submit draws
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Up to 4 people can be authorized; should be readily available to sign when needed
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Gives option of 1 or 2 signatures on draws
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At least one local gov signature is required (employee or official)
2010 CDBG Recipients’ Workshop
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Award Package, Cont.
6b. AUTHORIZED SIGNATURE CARD
• •
DCA requires TWO signatures on draw downs if either… Elected official authorizes him/herself on draw downs, or Grant administrator is authorized to sign Additional Points:
1.
2.
Important to keep a signed copy Signers go on vacation, get sick, etc. Authorize enough people to fill in when needed.
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Award Package, Cont.
7. AUTOMATIC DEPOSITS (ACH)
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Draw-Downs deposited electronically to your CDBG bank account
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To complete:
1.
Attach voided check 2.
Fill in bank & account info, CDBG number, authorized signatures, etc.
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Will take a couple of weeks to set up E-process
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Must be signed & returned in award package
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Award Package, Cont.
IMPORTANT FINAL REMINDERS
Keep copies of your entire award package
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Sign & Return Grant Award Package docs* by November 1 st
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Remember: No Signed Award Pckg = No $$$
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YOUR CDBG BANK ACCOUNT
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Separate, non-interest bearing bank acct for each CDBG award
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Acct is for CDBG $$$ ONLY (no match or any other project funds) Tips:
1.
Check with bank for minimum balance; if local $ is used to open, it can be reimbursed later 2.
CDBG will not pay insufficient fund charges 3.
Regular $ on hand should be $5K* or less
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CDBG Compliance with Your Field Rep (
Chapter 1: Section 4)
2010 CDBG Recipients’ Workshop
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CDBG Compliance with your Field Rep Your responsibility is to…
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Keep project on schedule
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Stay on top of Quarterly Reports, Draw-Downs, Special Conditions…all can create delays
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Field Rep will monitor at least once per 6 months
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Communicate problems/delays on your QR’s and to your Field Rep
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Violations will result in sanctions (see Ch.1, section 15)
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2010 CDBG Recipients’ Workshop
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Your Field Rep’s Project Review Checklists are in APPENDIX 2…
• • •
These are the forms we use when we visit Use them as a cheat sheet to prepare for monitorings Ask in advance what we will be looking for
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2010 CDBG Recipients’ Workshop
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2010 CDBG Recipients’ Workshop
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Within 60 Days of Grant Award
Elected Official City or County Clerk
Grant Administrator Interested Parties
Low/Mod Surveys
September 30, 2010
Start-Up Site Visit, cont.
2010 CDBG Recipients’ Workshop
Your Field Rep will look for…
• • •
The CDBG Application Citizen Participation plan Financial records including QR’s, bank statements, invoices, & bank register showing receipts & disbursements in chronological order (i.e., CDBG Check Book)
• •
Environmental Review Record Other pertinent information such as engineering plans or floor plans
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Citizen’s Participation
(Ch. 1, Sec. 8) Mandatory Public Hearings*
1.
Prior to application submission (“pre-award PH”) 2.
Within 60 days of Grant Award Date (“post-award PH”) 3.
At time of Project Completion (“close-out PH”) 4. Plus a PH only if CDBG program is amended
2010 CDBG Recipients’ Workshop
* See sample PH notices in Appendix 1)
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Citizen’s Participation, cont.
Public Hearing Protocol
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A full 5 CALENDAR DAYS must pass from publication date to public hearing date.
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DO NOT count publication date or public hearing date as part of the 5
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DO NOT publish in legal section
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Convenient times, locations
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Both handicap & foreign language accessible
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Citizen’s Participation, cont.
Things to Remember…
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Post-Award PH Must be held within 60 days of award (by
November 30
th )
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Notify your Field Rep at least 1 week in advance
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A Good Idea: why not schedule your PH’s in tandem with Start-Up & Close-Out Monitorings?
2010 CDBG Recipients’ Workshop
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Fair Housing
Complete at Least 2 to “affirmatively further Fair Housing”
• • • •
Resolution supporting State/Federal FH Law Public Information Campaign on FH FH Discussion on Public Hearing Agenda* Other?
• • •
Distribute FH brochures at public meeting Post FH Posters at City/County Buildings* Provide FH info to relocatees * Most Common
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Procurement
“ALL procurement transactions will be conducted in a manner providing full & open competition.” (Ch. 3, Sec. 4[c])
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Procurement
3 BROAD TYPES: 1.
2.
3.
Small Purchases < $100K Professional Services from the Private Sector (grant administrator, engineer, architect) Public Works Construction For Your Reference: --Chapter 3, Section 4 --Appendix 2
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24 CFR 85.36
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CONFLICT OF INTEREST REGULATIONS
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Georgia Local Government Public Works Construction Law
2010 CDBG Recipients’ Workshop
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Procurement, cont.
• • • •
AVOID CONFLICTS OF INTEREST WITH OFFICIALS AND STAFF Applies to Procurement of ALL goods & services Officials & Staff should not benefit from CDBG by
1.
Having a financial interest 2.
3.
Receiving a direct program benefit Having family or business ties to CDBG project
NO EXCEPTIONS with a Procurement C.O.I.*** Much more detail to come (see Rick Huber Presentation from this Workshop)
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Procurement, cont.
Type # 1: Small Purchases < $100K
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Bargain Shop
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Get price quotes from several different qualified sources
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Keep documentation in file
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This method cannot be used for Professional Services
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Procurement, cont.
Type # 2: Professional Services
• • • • •
“Competitive Negotiations” Advertise RFP or RFQ (include “evaluation factors”) in newspaper and/or “publication with adequate circulation & exposure” Request proposals via U.S. Mail from “known providers” (at least 7 for grant admin; at least 10 for engineer or architect) Allow minimum of 30 days response time KEEP DOCUMENTATION (ads, mail receipts, etc.)
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Procurement of Prof Services, cont.
Prepare written evaluation plan with method for scoring proposals EXAMPLE: Evaluation Factor #1 “Grant administrator’s knowledge of CDBG guidelines and regulations”.
Score range 4, 3, 2, 1, 0 4 points = 5 or more years of training 3 points = 3-4 years of training 2 points = 2 years of training 1 point = 1 year of training 0 points = less than 1 year of training
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Procurement of Prof Services, cont.
FINAL NOTES: 1.
2.
3.
4.
5.
Include Evaluation Factors in RFP/RFQ Scoring involves Elected Officials & Staff After evaluating/scoring, notify legal council & obtain official approval from Council or Commission If Procurement of Prof Services process was executed for a previously denied application, re advertising is not necessary to retain same firm (if ≤ 1 CDBG year) KEEP RECORDS of all required actions – it will be monitored (ads, mail-outs, evaluations).
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• • •
Procurement of Public Works Construction
Advertise for “Competitive Sealed Bids” Traditional “Design-Bid-Build” model vs. Non Traditional “Design-Build” or “Construction Management” models If non-traditional, you must first consult with Legal Counsel & DCA
• i.
ii.
Reference Appendix 2
Georgia Local Government Public Works Construction Law 24 CFR Part 85 (“Common Rule”)
2010 CDBG Recipients’ Workshop
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Procurement of Public Works Construction, cont.
What’s Included in the Bid Advertisement?
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Work hand-in-hand with engineer to prepare complete & specific CDBG project description
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Seek a “firm-fixed price” contract*
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Selection of winner is “principally based on price”
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Bid ads must include mandatory bonding requirements, pre-qualifications, & pre-bid conferences
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All bids must be opened publicly at time & place specified in bid ad
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• •
Procurement of Public Works Construction, cont.
The Bid Advertisement, cont.
Include Alternates to the “Base Bid”
“DEDUCTS” (you’d prefer to keep but can do without) “ADD’S” (non-essential but you’d like to have) ▪ ▪ ▪
List them by priority because…
When bids come in too close to call, these can make difference in determining lowest bidder It levels playing field for pool of contractors Addresses “change-order” issues in advance
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• •
Procurement of Public Works Construction, cont.
Bid Advertising Requirements Advertise at least 4 consecutive weeks prior to bid opening Specifications must also be available at local gov office from 1 st day of advertising Advertising Options: 1.
▪ ▪
“Legal Organ” (newspaper)
1 st ad “at least 4 weeks prior to the opening of the sealed bids or proposals” 2 nd ad “shall follow no earlier than 2 weeks from the first advertisement”*
2.
▪
Internet
At least 4 consecutive wks continuously prior to bid opening on local gov website or other site “identified by the governmental entity”
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Procurement, cont.
▪ ▪
If bids come in really low or too high, formally request DCA approval to:
Change Project Scope (increase or decrease) DCA reserves right to approve or reject ▪ ▪
If you only get one bid for contract (professional
▪
service or construction)
It’s called “non-competitive” procurement (Ch. 3, Section 4) You must request DCA’s “sole source approval” by providing: 1.
2.
Advertisement documentation, dates Response date 3.
List of firms who received solicitation Wait to receive DCA letter before proceeding
2010 CDBG Recipients’ Workshop
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Procurement, final
• • • •
Contracts paid with CDBG $
Administrative Contract Requirements see Ch. 1 Section 18 For all contracts paid with CDBG $:
Appendix 2 → Project Review Checklists → #4 Procurement Review → “CDBG CONTRACT & CONTRACTOR PROCUREMENT REVIEW CHECKLIST”
This matrix is key to required clauses & bonds for your contracts All contracts should include compensation amount (“firm-fixed price”)
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FINANCIAL MANAGEMENT
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Financial Management
“…financial records should be established & maintained in such a manner as to facilitate the reporting and monitoring of expenditures and obligations by activity.” --Ch. 3, Financial Management & Administration
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Bottom Line: You need a good ledger and financial filing system for your project – please review Chapter 3 carefully.
You will be monitored for Financial Management
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Financial Management, cont.
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Draw-Downs: Separate, non-interest bearing bank account with automatic deposit
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DCA processes draws on Tuesdays & Thursdays
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Time your draw-downs accordingly; “funds should be in your bank 6 days from the day DCA processes request”
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Match signatures to those on Authorized Signature Card
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Funds should be paid out of your account no later than 3 days after they are deposited
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Financial Management, cont.
Note Mailing Address for Draw Down Requests* Office of Community Development Georgia DCA P.O. Box 15523 Atlanta, GA 30333
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Financial Management, cont.
You cannot Draw Down funds until you… 1.
Complete and submit grant award package to DCA 2.
Clear your special conditions through GAN’s 3.
Receive DCA environmental clearance for non exempt activities 4.
…are caught up on Quarterly Reports 5.
Verify required cash match (for final draw down)
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Financial Management, cont.
• • •
Required Cash Match Formula: 5% of every $ between $300,001 & $500K; 10%of every $ between $500,001 & up Must be verified by Field Rep to receive final draw CDBG Housing-only awards exempt from Match
• •
Required Local Leverage We gave you bonus points for this Field Rep will monitor by Close-Out Each of these items are found in the Budget Summary of your Grant Award Package
2010 CDBG Recipients’ Workshop
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Financial Management, cont.
• •
“Program Income” Recall “non-interest bearing” checking account If the CDBG generates $, you have to return it to DCA
▪ See Ch.3, Section 3 for income examples • •
Exceptions to that Rule: CDBG Revolving Loan Fund (typical with Econ Dev) Permissible CDBG checking acct balance up to $5K
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Financial Management, cont.
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Program Amendments, Budget Revisions or Other Adjustments (Ch. 3, Section 9) You must receive formal DCA Approval to…
1.
Add a new activity or delete an approved activity 2.
3.
4.
Decrease scope of activity by 10% or more Propose activity in area other than approved CDBG Target Area Transfer funds from one activity to other by 10% or more • •
DCA will consider effect on match/leverage If proposed change is substantial, you must hold another public hearing
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Financial Management, cont.
Quarterly Reports
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Due 30 days after end of each Qtr (4/30, 7/30, 10/30, 1/30* )
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Failure to comply = No $ Draw Down
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Fill out Narrative Section WELL – makes life easier
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Check “Final” QR only after all activities & expenditures are complete & beneficiaries recorded
2010 CDBG Recipients’ Workshop
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Financial Management, cont.
Audit Requirements (Ch. 3, Section 2) “Must contract for annual independent audit” and submit to DCA
▪ If Recipient spend $500K or more in total Federal funds (CDBG plus other)… • Follow OMB Circular A-133 ▪ If $500K or less in total Federal funds… • Recipient is exempt from Federal Audit requirements but not from State Audit Requirements
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Close-Out
Your field Rep will need to see the following:
1.
2.
3.
4.
Final Public Hearing (at least one week advance notice); we will keep copied documentation Final Quarterly Report Final Wage Compliance Report Surveys & Beneficiary Data (very low income, low income, moderate income, above moderate income)
This will result in “Conditional Closeout” Letter
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Closeout, cont.
After audit requirements satisfied, you will receive “Final Closeout Letter” Retention of Records (Ch. 1, Section 10)
▪ ▪ Retain for at least 3 years after Final Closeout Letter For “non-expendable property”, retain records for 3 years after final disposition of property
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1.
2.
3.
Immediate Action Items:
COMPLETE & RETURN grant award package by Nov. 1st!
SCHEDULE & HOLD post-award public hearing within 60 days of award (by November 30 th , notify field rep).
OPEN non-interest bearing checking account.
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