CITIZEN PARTICIPATION PLAN

Sets forth the policies and procedures to be used for citizen participation 1

MUST PROVIDE AND ENCOURAGE CITIZEN PARTICIPATION  During the development of the consolidated plan  Regarding substantial amendments  To review performance reports 1

CON PLAN DEVELOPMENT  Describe how & when citizens will be informed of: 1

CON PLAN DEVELOPMENT 1.

2.

3.

Amount of assistance expected to be received Range of activities Plans to minimize displacement (even if no displacement is expected) 1

CON PLAN DEVELOPMENT How citizens will be given opportunity to examine proposed Con Plan including where copies may be examined and obtained 1

CON PLAN DEVELOPMENT  At least one public hearing during the development process  Description of how notice of that hearing will be provided 1

CON PLAN DEVELOPMENT  Public comment period  Not less than 30 days, prior to adopting the final consolidated plan 1

CON PLAN DEVELOPMENT Comments:  Written or orally at public hearing will be considered  Summary of comments attached to final con plan 1

AMENDMENTS  Specify criteria to be used to determine what constitutes a substantial amendment  How citizens will be given opportunity to comment with comment period and summary 1

PERFORMANCE REPORTS  Reasonable notice for review and comment  Comment period prior to submission is not less than 15 days 1

PUBLIC HEARINGS Citizen participation plan must:  State how / when notice is given  Describe how needs of non English speaking will be met 1

PUBLIC HEARINGS Citizen participation plan must:  Provide hearings at convenient times and locations, with accommodations for persons with disabilities AND describe how this will be done 1

MEETINGS AND RECORD AVAILABILITY / ACCESS  Citizen participation plan must provide reasonable and timely access to local meetings  Consolidated Plans, substantial amendments, and performance reports must be available to public 1

TECHNICAL ASSISTANCE

Citizen participation plan must describe how technical assistance will be provided to appropriate groups that request assistance to develop proposals 1

COMPLAINTS

Written description of how complaints regarding:    Consolidated plans Substantial amendments Performance reports 1

CONSULTATION

Public Agencies  Govt. Depts.

   Health Dept.

Public Housing Community Action Private Agencies  Advocates of   special needs Senior citizen organizations Faith-Based 1

24 CFR 91

US Department of Housing & Urban Development – Office of Community Planning & Development

Consolidated Plan & Strategy

A planning document which builds on a participatory process at the lowest levels… an application for federal funds under HUD’s formula grant programs… a strategy to be followed in carrying out HUD programs… and an action plan that provides a basis for assessing performance

Identify community

conditions and needs

Identify existing

$ $ $ resources $ $ $

Identify

g a p s

between resources and needs Identify

local priorities

for CPD Funding

C O N T E N T P R O C E S S

 Consultation with service organizations  Consultation with government agencies  Participation of residents of lower income neighborhoods

CPS DEVELOPMENT AND REVIEW

Local community consultation and citizen participation process Public Hearing: Identification of Needs and Priorities Submission of Final CPS and Public Comments to HUD 45 days before Start of Program Year Minimum 30-Day Public Comment Period on Proposed CPS Review and Action on Comments received on Proposed CPS

CONSULTATION WITH SERVICE ORGANIZATIONS 24 CFR 91.001(a) Public and private organizations that provide assisted housing, health services, and social services for: •

children

• elderly persons • persons with disabilities • persons with HIV/AIDS

and their families

• homeless persons

HOUSING AND HOMELESS NEEDS ASSESSMENT Analysis of housing needs by household type :  Housing cost burden   Overcrowding Substandard housing Analysis of housing needs of renters by income categories Determination if 10% higher rate of any housing needs experienced by racial or ethnic group compared to entire population

HOUSING AND HOMELESS NEEDS ASSESSMENT

Analysis of the nature and extent of homelessness Analysis of facility needs of homeless:   Emergency Shelters Transitional Shelters   Permanent Supportive Housing Permanent Housing Analysis of supportive service needs of homeless Estimated homeless subpopulations

HOUSING MARKET ANALYSIS •Supply, demand, condition and cost of housing stock with detail on housing available for persons with disabilities, persons with HIV/AIDS, lower income areas and areas of minority concentration •Number and condition of public and assisted housing, targeting of units, and whether assisted units are expected to be lost •Inventory of facilities and services for the

homeless and persons in need of supportive housing

•Barriers to affordable housing

s t r a t e g i c p l a n

RENTER AND OWNER HOUSING NEEDS

Homeless Facilities and Services

PUBLIC FACILITIES

public services

INFRASTRUCTURE

Economic Development

PLANNING AND OTHER NEEDS

S T R A T E G I C D A T A

CENSUS, HMDA, REALTOR’S ASSOC.

Homeless Providers

PARKS & REC. DEP.

public service agencies

PUBLIC WORKS / ENGINEERING

Chamber of Commerce / ED Dept.

PLANNING DEPT. / NBHD GROUPS

priority levels

Grantees must identify general priority levels and projected funding levels for each of the eligible activities:

•High - Activity will be funded •Medium - Funded if monies available •Low - No funding, but letter of support •No Need - No funding or letter

r

equired the

e

lements of

s

trategic

p

lan      GEOGRAPHIC DISTRIBUTION ACROSS PRIORITY NEEDS BASIS FOR ASSIGNING PRIORITY LEVELS OBSTACLES TO MEETING UNDERSERVED NEEDS USE OF EXPECTED FUNDS MEASURES FOR PROPOSED ACCOMPLISHMENTS

o

ther

c

onsolidated

p

lan

r

equirements

     Reduction Plan for Lead-Based Paint Hazards Poverty Reduction and Affordable Housing Strategies Organizational Capacity and Coordination Assessment for Delivery of Community Development Activities Public - Private Partnerships Public Housing Resident Management and Homeownership Initiatives

neighborhood revitalization strategy Residents, business owners, non-profits and community groups from a qualified, lower income residential area may seek HUD approval for a NRS after assessing economic needs and developing a revitalization and economic empowerment strategy for their area. Benefits of an NRS can include:  Job Creation/Retention Qualified as Area Benefit Activity  Aggregation of Assistance to Housing in Area  Exemption of ED Public Benefit Standards for Area  Exemption of Public Services in Area from 15% Cap

ACTION PLAN ELEMENTS

STANDARD FORM 424; BUDGET AND RESOURCES:

• Federal resources. • Other non-Federal public sources • Other private resources • Program Income • Float Funds

ACTIVITIES TO BE UNDERTAKEN. GEOGRAPHIC DISTRIBUTION HOMELESS AND OTHER SPECIAL NEEDS ACTIVITIES. ACTIONS TO ADDRESS OBSTACLES TO:

•meeting underserved needs, •foster and maintain affordable housing, •remove barriers to affordable housing, •evaluate and reduce lead-based paint hazards, •reduce the number of poverty level families, •develop institutional structure, and •enhance coordination between public and private providers

Notice 03-09: Performance Measures

GOALS: Proposed solutions to problems identified Preserve existing housing stock INPUTS: Resources dedicated or consumed by the program/project Money, Staff, Contractors, Equipment ACTIVITIES: What the program does with the inputs to fulfill its mission Screen applicants, prepare specifications, underwrite loans, progress inspections OUTCOMES: Benefits that result from the program Increased percent of housing units in standard condition OUTPUTS: The direct products of projects/activities # of homeowners assisted, # of homes rehabilitated

CONSOLIDATED PLAN WEBSITE www.hud.gov/offices/cpd/about/conplan/ index .

•

Links to Census and CHAS data

•

Links to local housing costs and maps

•

Link to other local con plans

•

Download Guidelines and certifications

•

Link to the CPII site

FAIR HOUSING PLANNING IN YOUR COMMUNITY

Presenter: Pamela D.Walsh

Director, Program Standards Division Office of Fair Housing and Equal Opportunity 37

Fair Housing Planning in Your Community

 “Ensure Equal Opportunity and Access to Housing” means:

-- Reducing Housing Discrimination -- Promote public awareness of fair housing laws -- Improving the accessibility of housing to persons with disabilities

1

Fair Housing Planning in Your Community

 Fair Housing Planning - A Comprehensive Strategy to ”Ensure Equal Opportunity and Access to Housing”  FH Planning contributes to “Ensure Equal Opportunity and Access to Housing” 1

Fair Housing Planning in Your Community

  Fair Housing Planning is part of the Consolidated Plan Section 808 (e) (5) of the FH Act… “The Secretary shall administer the programs and activities relating to housing and urban development in a manner to affirmatively further the policies of the Act.” 1

FAIR HOUSING PLANNING GUIDE More information is available in the Fair Housing Planning Guide, Volume I, that is available through the following website: http://www.hud.gov/fhe/fhplan.ht

ml 1

FAIR HOUSING PLANNING IN YOUR COMMUNITY  Objectives of Affirmatively Furthering Fair Housing – – – –

Eliminate housing discrimination Promote fair housing choice Provide opportunity for racially and ethnically inclusive occupancy patterns Promote accessibility for persons with disabilities

1

Fair Housing Planning in Your Community

What is Fair Housing Choice?

The ability of persons regardless of race, color, religion, sex, disability, familial status or national origin to have available to them the same housing choices.

1

Fair Housing Planning in Your Community - AFFH Certification    Conducting an Analysis of Impediments to Fair Housing Choice Taking Actions to Address the Impediments Identified in the AI Maintaining Records; Sources: 24 CFR 91.225(a) [Localities]; 91.325(a)[States]; 91.425[Consortia].

1

Fair Housing Planning in Your Community - What is an AI?

 Comprehensive Review of: – –

Laws, Regulations and Administrative Procedures Affecting the:

  

Location Availability Accessibility of Housing Assessment of Conditions Affecting Fair Housing Choice

1

What Do We Mean By Impediments to Fair Housing Choice?

Any actions, omissions or decisions taken because of race, color, religion, sex, national origin, disability or familial status that restrict housing choice or the availability of housing choice.

(Source: Fair Housing Planning Guide, Volume 1, Page 2-17) 1

Fair Housing Planning Examples of Impediments      Racial segregations/steering Lack of Affordable Housing/Financing Lack of support for facilities serving persons with disabilities Lack of local fair housing enforcement, focus, or support Lack of financial support for fair housing enforcement and education and outreach activities 1

Fair Housing Planning Examples of Impediments  Zoning barriers to affordable housing  Intolerance toward minorities moving into non-minority neighborhoods. [NIMBYISM; Hate and Violence Crimes] 1

Examples of Actions to Address Impediments     Provide Cultural Sensitive training -- Ensure Safety of Families Moving to Non-traditional Neighborhoods Enact/Enforce Substantially Equivalent Laws Provide Financial Support for Fair Housing Enforcement Equalize Conditions Between Minority/Non minority Areas through HUD funds 1

Fair Housing Planning Examples of Actions

    Promote homeownership through Housing Counseling Remove barriers to affordable housing Conduct and promote fair housing testing Conduct and promote fair housing education and outreach 1

FAIR HOUSING PLANNING EXAMPLES OF ACTIONS, CONT.

  Translate crucial information into different languages to better serve the limited English proficient population Create a FH coordinator within your organization 1

FAIR HOUSING PLANNING EXAMPLES OF ACTIONS, CONT.

 Partner with local Fair Housing Initiatives Program (FHIP) organizations and Fair Housing Assistance Program (FHAP) organizations 1

Fair Housing Planning Maintaining Records  Supporting documentation should include: – – – –

The AI Actions undertaken to address any identified impediments Records such as transcripts of public hearings and citizen comments Progress reports on implementation

1

FAIR HOUSING PLANNING HUD’S ROLE   Technical Assistance Review of AI at many points in Consolidated Plan Life Cycle – – – –

Annual Plan or Five-Year Consolidated Plan Comprehensive Annual Performance and Evaluation Report Consultation with Local/State Officials Monitoring Visit

1

Fair Housing Planning – Recipients Evaluation

 The AI  The milestones and timetables  The fair housing actions (Source: Fair Housing Planning Guide, Part 1, Page 2-24) 1

Fair Housing Planning HUD Evaluation

 SUBSTANTIALLY INCOMPLETE – –

Impediments plainly inconsistent w/generally available facts and data Incomplete where facts/data indicate the presence of an impediment not identified in the AI (Source: Fair Housing Planning Guide, Part 1, Page 2-24)

1

Fair Housing Planning HUD Evaluation (Cont.)

 ACTIONS PLAINLY INAPPROPRIATE

-- Examples:

–

Fair housing poster contest addresses lending discrimination

–

Citizen participation notices in English only when 25% of the population is limited English proficient (Source: Fair Housing Planning Guide, Part 1, Page 2-24)

1

Fair Housing Planning HUD Evaluation (Cont.)

   Provide notice and opportunity for comment Working with the jurisdiction on actions to: – –

make the AI complete overcome the effects of the identified impediments

Include a timetable for accomplishing the actions 1

FAIR HOUSING PLANNING CONCLUSION

 Training and Technical Assistance  Target date for new AIs 1

CDBG DESIGN CATEGORIES

 CDBG Characteristics  Local Considerations  CDBG Management Issues 1

Community Development Block Grant (CDBG) Program Eligible Activities

1

“6 Steps” Determining Whether CDBG Can Assist an Activity

1

Step One



Is the activity included within the list of eligible activities in the CDBG regulations?



Reference: §570. 201 – 570.206

1

Step Two



Is the activity included in one of the categories of explicitly ineligible activities?



Reference: §570.207

1

Step Three



Does the activity meet the criteria of at least one of the national objectives of the CDBG program?



Reference: §570.208

1

Step Four

  Ensure that the grantee remains in compliance with its certification that at least 70% of its CDBG expenditures over a 1, 2, or 3 year period will be for activities benefiting low/mod-income persons.

Reference: §570.200 (a) (3) 1

Step Five

 

Do the proposed costs for the activity appear necessary and reasonable and would those costs conform to requirements of applicable OMB Circulars?

Reference: §570.502 and Parts 84 & 85

1

Step Six



Have the environmental review and clearance procedures been completed for the project of which the activity is a part?



Reference: 24 CFR Part 58

1

ACQUISITION – 570.201(a) 

Includes air rights, water rights, rights of way, and easements.



Purchase, long-term lease (at least 15 years), or donation.



Carried out by the grantee or a public or private nonprofit organization.

1

CLEARANCE – 570.201(d)  Clearance, demolition, and removal of buildings and improvements.

 Physical removal and treatment of contaminants.

 Includes the movement of structures to other sites.

1

REHABILITATION – 570.202

Types of buildings that may be assisted: . residential buildings . public or privately owned commercial or industrial buildings with limitations . non-profit owned, nonresidential buildings not public facilities . manufactured housing that is part of permanent housing stock.

1

REHABILITATION – 570.202

Code Enforcement • • • • Pay Salaries of Enforcement Personnel Legal enforcement proceedings In Deteriorated Area Must arrest the decline 1

DISPOSITION – 570.201(b)  Real property acquired with CDBG may be disposed of by sale, lease, donation, or otherwise.

 Reasonable costs of temporarily managing the property are allowed.

 Proceeds are program income.

1

PUBLIC FACILITIES & IMPROVEMENTS – 570.201(c) • Acquisition, construction, reconstruction, rehabilitation, or installation. Examples: •

Day Care Centers

• • •

Libraries Street Improvements Improvement of parks and playgrounds

1

PUBLIC SERVICES – 570.201(e)



Wide range of services, including but not limited to:

– – – – – Employment Crime prevention Child care Health Education 1

PUBLIC SERVICES – cont.

  To qualify, an activity must be either a new service or a quantifiable increase in the level of an existing service.

Funds expended cannot exceed 15% of the grant plus 15% of last year’s program income.

1

HOMEOWNERSHIP ASSISTANCE –570.201(n)      

Pay 50% of the downpayment All reasonable closing costs Pay the mortgage insurance premium subsidizing interest rates and mortgage principal Finance the cost of acquiring property already occupied by the household Limited to low and moderate income households.

1

ASSISTANCE TO MICROENTERPRISES – 570.201(o)     A business with five or fewer employees, including the owner.

Facilitate the establishment, stabilization, and expansion of microenterprises.

Technical assistance, advice and business support services.

General support services such as child care and transportation.

1

Special Economic Development Activities

 Commercial or industrial buildings or improvements carried out by the grantee or nonprofit subrecipient.

1

Special Economic Development Activities

Con’t.

  Assistance to a for-profit business to carry out an economic development project.

Related economic development services.

Reference: §570.203

1

Public Benefit Standards

 Apply to activities individually and in the aggregate.  Measured either based on jobs created/retained, or providing goods and services to low-mod residents of an area. 1

New Construction  Not generally eligible; allowed only in certain circumstances.

–

Reference: §570.207(b)(3)

1

New Construction  Most common - “Special Activities by Community-Based Development Organizations (CBDOs).” –

Reference: §570.204

 Also allow various “support” activities.

1

Planning Activities §570.205



Eligible planning, urban environmental design and policy planning-management-capacity building activities.

1



Program Administrative Costs - §570.206

Program Administrative Costs – eligible costs include general management, oversight and coordination; public information; fair housing costs; administrative expenses to facilitate housing.

1

Eligibility Summary

  

Wide range of eligible activities, but there are limits. (570.201 – 570.206) General Rule -- If it’s not part of a listed category, it’s not eligible.

Some activities are explicitly ineligible. (570.207)

1

National Objectives Segment

87

NATIONAL OBJECTIVES



Where are the National Objective regs. found?

 24 CFR §570.208

Important Web Sites

 Code of Federal Regulations – CDBG Program @ 24 CFR 570  CDBG Regulations – www.hud.gov/offices/cpd/ communitydevelopment/ rulesandregs/index.cfm

1

Important Web Sites

 Guide to National Objectives and Eligible Activities for Entitlement Communities – www.hud.gov/offices/cpd/ communitydevelopment/ library/deskguid.cfm

1

What are the three National Objectives?

–

Principally benefit low/mod income persons

–

Prevent or eliminate slums and blight

–

Meet an urgent community development need having a particular urgency…

1

Urgent Need



…

existing conditions pose a serious and immediate threat to the health or welfare of the community where other financial resources are not available to meet such need.

1

Urgent Need

 Existing conditions are recent or recently became urgent (within the last 18 months) 1

INCOME LIMITS

 CDBG Moderate Income - Section 8 low

income limits = at or below 80% of median income.

 CDBG Low Income - Section 8 very low

income limits = at or below 50% of median income.

 CDBG Extremely Low Income - Section 8

extremely low income limits = at or below 30% of median income.

1

FAMILY

 All persons living together who are related by birth, marriage or adoption.

1

HOUSEHOLD

 All persons living together in a housing unit. This could be a single family, one person living alone, two or more families living together, or any other group of related or unrelated persons who share living arrangements.

1

AREA BENEFIT – 570.208(a)(1)

To qualify, the grantee must determine that the activity is: 1.

2.

3.

Available to all residents of the service area, where at least 51% are Low/Mod Located in a primarily residential area, and Located in a defined service area 1

AREA BENEFIT (cont.)



DETERMINING SERVICE AREA

– – Nature of the activity Location of the activity – – Accessibility Availability of comparable activities 1

AREA BENEFIT (cont.)

 

EXCEPTION CRITERIA

Grantee qualifies when fewer than one quarter of the block groups in its jurisdiction contains 51% or more low and moderate income persons.

Referred to as the Upper Quartile exception criteria.

1

LIMITED CLIENTELE – 570.208(a)(2)

 Limited clientele activities must meet one of four tests:

1. Benefits a clientele who are generally presumed to be principally low and moderate income

1

LIMITED CLIENTELE – 570.208(a)(2) – – – – – –

abused children elderly persons battered spouses homeless persons illiterate adults adults meeting the Census definition of severely disabled

– –

persons with AIDS migrant farm workers

1

LIMITED CLIENTELE – cont.

2. 51% of participants are low and moderate income persons.

3. Participation limited to low and moderate income persons.

4.

Nature and location indicate activities will primarily benefit low and moderate income persons.

1

LIMITED CLIENTELE – cont.

5. Owners and persons developing microenterprises who are low and moderate income can qualify under this category for up to 3 years.

1

HOUSING – 570.208(a)(3)

 To meet the low and moderate income housing national objective, the following apply: 1

–

One-unit structure – occupied by low/mod income household

–

Two-unit structure - 1 unit must be occupied by a low/mod income household

–

Three-plus-unit structure - 51% of units must be occupied by low/mod income households

1

HOUSING (cont.)

 Rents in CDBG assisted housing units must be affordable to low and moderate income households. If not, the assisted units do not meet the low and moderate income housing national objective criteria.

1

JOBS – 570.208(a)(4)

 In order to meet the low and moderate income National Objective under JOBS, activities must: 1

JOBS – 570.208(a)(4)

1. Create or retain permanent jobs,

AND

2. 51% of the jobs created/ retained must be made available to or held by low- and moderate- income persons –

Jobs counted on full time equivalent (FTE) basis (using 40 hour week).

1

Slums and Blight



Slum or Blighted Areas



Spot Blight



Urban Renewal Completion

1

Slum/Blight Area §570.208(b)(1)



Area must be designated by the grantee as a slum/blighted area and

– Meet a definition of slum, blight, deteriorated or deteriorating under State or local law, and 1

Slum/Blight Area §570.208(b)(1)

– Have a substantial number of buildings or public improvements in a state of deterioration.

1

Slum/Blight Area §570.208(b)(1)

 

Maintain documentation on area boundaries and conditions which qualified the area at the time it was designated.

Assisted activity must address one or more of the conditions which contributed to the areas’ deterioration.

1

Slum/Blight Area §570.208(b)(1)



Residential rehab considered to meet this criterion if:

– –

Each building is considered substandard under local definition; and Deficiencies making building substandard are corrected before less critical work is done.

1



Spot Blight §570.208(b)(2) Activities located outside a designated slum/blight area.



Only certain activities can qualify.

1

Spot Blight §570.208(b)(2)



Building rehab is limited to extent necessary to eliminate specific conditions detrimental to public health and safety.

1

Slum Blight/Urban Renewal - §570.208(b)(3)

  

Activities must be in a Federal Urban Renewal (UR) or Neighborhood Development Program action area Activities must be necessary to complete an Urban Renewal Plan Not commonly used

1

SUBRECIPIENT DEFINED

  Reg. cite §570.500(c) Public or private nonprofit organization/ agency receiving CDBG funds from grantee for eligible activities 1

SUBRECIPIENT DEFINED Cont.

– –

A for-profit agency assisting microenterprises may be a subrecipient Institutions of higher learning may be subrecipients

1

SUBRECIPIENT DEFINED Cont.

– –

CBDOs not automatically subrecipients Contractors not subrecipients

1

SUBRECIPIENT AGREEMENTS Cont.

 What are the required elements of the subrecipient agreement?

1

SUBRECIPIENT AGREEMENTS Cont.

–

Statement of work -work to be performed, scheduled, & a budget in sufficient detail to monitor

–

Records to be maintained and reports to be submitted

1

SUBRECIPIENT AGREEMENTS Cont.

–

Program income - what’s to be remitted back to recipient AND what may be revolved

–

Uniform administrative & other federal requirements per §570.502 + §570 Subpart K

1

SUBRECIPIENT AGREEMENTS Cont.

–

Suspension/termination & reversion of assets

1

CBDOs v. SUBRECIPIENTS

 A CBDO is not automatically a subrecipient; a grantee must decide how to treat the organization 1

CBDOs v. SUBRECIPIENTS Cont.

 Implications: – – –

Program income Written agreement requirements Uniform administrative requirements, incl. reversion of assets

1

1

TWO TOPICS

 Availability of Resources  Importance of Reporting Accomplishments 1

THE 10 MOST IMPORTANT THINGS YOU NEED TO KNOW ABOUT

IDIS

1

10. A plethora of resources are available to assist you in performing functions in IDIS.

129

9. Join the IDIS User Group by e-mailing:

[email protected]

1

8. Use the IDIS Matrix Code Definitions at:

www.hud.gov/offices/cpd/ systems/idis/pdf/refmanual/ ref_man_b.pdf

AND 131

The Matrix Code/National Objective Code Table at:

www.hud.gov/offices/cpd/ systems/idis/resources/ cdbg_xref.cfm

132

7. Read Guidance for Reporting IDIS Accomplishments at:

www.hud.gov/offices/cpd/ communitydevelopment/cleanup/guida nce/index.cfm

133

TELLS HOW TO:

 Report information on IDIS screens  When and how often to Report accomplishments 1

TELLS HOW TO:

 Avoid double counting activities  Select accomplishment codes 1

Accomplishment Types:

01 People 04 Households 08 Businesses 1 

Accomplishment Types:

09 Organizations 10 Housing Units 11 Public Facilities 13 Jobs 1

6. Use the IDIS Reference Manual at:

www.hud.gov/offices/cpd/syste ms/idis/resources/ reference_manual.cfm

138

5. Contact your CPD Field Office representative.

139

4. Contact the IDIS Technical Assistance Unit (TAU) at:

1-800-273-2573 140

3. HUD is required to collect accurate and timely accomplishment information.

1

 Government Performance and Results Act of 1993 (GPRA)  Office of Management and Budget directives  Program legislation and regulations 1

2. Most annual reporting requirements are met by the data you enter into IDIS.

1

 Activity Summary Report (PR03), and  Financial Summary Report (PR26) explained at: www.hud.gov/offices/cpd/ systems/idis/pdf/ explnfinsum.pdf

1

1. Information on the results and benefits of CDBG-assisted activities validate the success of your program in fulfilling its mission to…

1

assist low- and moderate-income persons.

1

Grantee Expenditures:

www.hud.gov/offices/cpd/ communitydevelopment/ budget/ disbursementreports/ index.cfm 1

Grantee Accomplishments:

www.hud.gov/offices/cpd/ communitydevelopment/ library/accomplishments/ index.cfm

1

CDBG grantees continue to improve the quality of data in IDIS through our Data Cleanup Initiative at:

149

www.hud.gov/offices/cpd/ communitydevelopment/ cleanup/index.cfm

1

CDBG & IDIS

THE END

151

WHICH HARDWARE/ SOFTWARE

‘www.hud.gov/offices/cpd/ systems/idis/start/index/ cfm 152

COMMUNICATING WITH IDIS

‘www.hud.gov/offices/cpd/ systems/idis/start/access/ firewall_ports.cfm

153

USER IDs

 Two User IDs required ‘www.hud.gov/offices/cpd/ systems/idis/start/index/ cfm 1

IDIS ASSISTANCE

 IDIS Technical Assistance Unit  (800)273-2573  8 AM – 5 PM Eastern Time 1

RECORD KEEPING

 WHY record keeping is important  WHAT kinds of records need to be maintained  HOW can you best handle record keeping responsibilities 1

HUD AND COMPLIANCE

 HUD must ensure grantees use CDBG funds in compliance with program rules  HUD determines whether grantees use CDBG funds in furtherance of their Consolidated Plan priority goals and objectives 1

FIRST STEP TO COMPLIANCE

 First step to compliance is KNOWLEDGE  Compliance tests are “open book tests”  Seek compliance direction in specific regulations 1

WHY YOU NEED RECORDS

 First, to facilitate HUD monitoring  570.900(b)(3) – A recipient’s failure to maintain records in the prescribed manner may result in a finding that the recipient has failed to meet the applicable requirement to which the record pertains.

1

WHY YOU NEED RECORDS

 Second, to keep local officials informed  Local officials want to know what the community is getting out of the CDBG Program  Outputs and Outcomes 1

WHY YOU NEED RECORDS

 Third, to report to local citizens & stakeholders and HUD in the CAPER  Records are essential to show progress in meeting Consolidated Plan goals & objectives and in implementing your CDBG Program 1

WHAT KINDS OF RECORDS?

TEN Broad Categories of Records 1. Records showing progress in meeting Consolidated Plan priority goals and objectives 2. Financial records 1

WHAT KINDS OF RECORDS

3. Records of CDBG accomplishments (outputs) – how many jobs, etc.

4. Records on CDBG beneficiaries (incomes data on persons and households) 1

WHAT KINDS OF RECORDS

5. Additional records for Eligibility,National Objectives, and Overall Benefit 6. Records of compliance with Environmental Review Requirements (24 CFR Part 58) 1

WHAT KINDS OF RECORDS

7. Records pertinent to flexibilities in regulations – neighborhood revitalization strategy areas 8. Records of compliance with Other Federal Requirements (like equal opportunity rules) 1

WHAT KINDS OF RECORDS

9. Records of compliance with general responsibilities (like citizen participation rules) 10. Records on OUTCOMES – benefit to community as a whole 1

HOW TO DO THE JOB

 The first step to compliance is knowledge  What specific records do grantees need to maintain?

 Where do grantees look?

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WHERE DO GRANTEES LOOK?

 CDBG regulations – section 570.506 (“Records to be maintained”)  Elsewhere in CDBG and Consolidated Plan regulations (requirement = records) 1

WHERE DO GRANTEES LOOK?

 Your Consolidated Plan – what are your goals and objectives?

 Your Certifications – what did you commit to do? (for example, affirmatively further fair housing) 1

WHERE DO GRANTEES LOOK?

 Reporting requirements (91.520 and other direction)  IDIS screens  HUD Field Office – CPD Rep 1

AFTER KNOWLEDGE, WHAT?

 Second step to compliance – TRAINING  Third step to compliance – SYSTEMS & PROCEDURES  Remember - you are not alone!

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FINANCIAL MANAGEMENT OF THE CDBG PROGRAM

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GOVERNMENT WIDE REQUIREMENTS

Financial management of the CDBG program is based on government wide requirements:  Uniform administrative requirements (aka the “Common Rules”)  OMB Circulars 1

APPLICATION OF REQUIREMENTS TO ENTITLEMENT PROGRAM

Government wide requirements are applied to CDBG entitlement recipients/subrecipients at 24 CFR §570.502 (but with lots of exceptions) 1

CATEGORIES OF RECIPIENTS/ SUBRECIPIENTS

Requirements vary according to nature of recipient/subrecipient:    Governmental entities Educational institutions Other private, non-profit entities 1

Uniform Administrative Requirements

Implemented in HUD title of CFR: 

States, Local Governments, and Indian Tribes (24 CFR Part 85)



Institutions of Higher Education, Hospitals, and Other Non-profit Organizations (24 CFR Part 84)

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OMB Circulars

Cost principles 

A-87 (Recipients/subrecipients that are governmental entities)



A-21 (subrecipients that are educational institutions)



A-122 (non-governmental subrecipients)

Audits 

A-133 (Audits of States, Local Governments, and Non-Profit Organizations)

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Uniform Administrative Requirements

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Standards for Financial Management System

Standards for recipients/subrecipients that are governmental entities are specified at 24 CFR §85.20

Comparable standards for recipients/subrecipients that are private, non-profit organizations are specified at 24 CFR §84.21) 1

(1)Financial reporting –

Accurate, current, and complete disclosure of the assisted activities 1

(2) Accounting Records

Must adequately identify the source and application of funds 1

(3) Internal Control

Effective control and accountability must be maintained for all grant and sub-grant cash, real and personal property, and other assets.

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(4) Budget Control

Intended to maintain integrity of budget process  Actual expenditures must be compared with budgeted amounts  Financial information must be related to performance or productivity data (when required by grant agreements) 1

(5) Allowable Costs

Three sets of cost principles: 

OMB Circular A-87 for recipients and subrecipients that are governmental entities



OMB Circular A-21 for subrecipients that are educational institutions



OMB Circular A-122 for non governmental subrecipients

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(6) Source Documentation

Accounting records must be supported by source documents; examples are: – – – – –

Canceled checks Paid bills Payrolls Time and attendance records Contracts

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(7) Cash Management

Procedures to minimize the time elapsed between withdrawal of grant funds from the Federal Treasury and disbursement of those funds in payment of activity related costs 1

PAYMENT

Payment requirements for governmental entities are specified at 24 CFR §85.21

Payment requirements for subrecipients that are not governmental entities are specified at 24 CFR §84.22

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PAYMENT (cont.)

CDBG recipients are paid on an advance basis via IDIS    Depositories – not required to be Federally insured (although a good idea) Separate bank accounts not required Bank accounts for subrecipients required to be interest bearing (with certain exceptions) 1

PROCUREMENT

 Procurement requirements for governments are at 24 CFR 85.36

 Procurement requirements for non-profits are at 24 CFR 84.40 – 84.48

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PROCUREMENT (cont.)

Procurement methods for governmental entities:  Small Purchases (simplified acquisition procedures)    Sealed Bids (formal advertising, use of IFB’s) Competitive Proposals (use of RFP’s) Non-competitive Proposals 1

PROCUREMENT (cont.)

Procurement methods for non governmental entities less prescriptive  “Section 3” requirements should be taken into account in procurement process  Cost plus percentage-of-cost pricing not allowed 1

Other Uniform Administrative Requirements

Notable administrative requirements are:  Section 85.32/84.34 Equipment  Section 85.33/84.35 Supplies 1

PROGRAM INCOME

What is CDBG Program Income?

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PROGRAM INCOME

What is CDBG Program Income?

 Gross income received by a grantee or subgrantee that is directly generated, in whole or in part, by use of CDBG funds; examples are: –

Proceeds from sale or lease of property purchased/improved with CDBG

– –

Proceeds from lease of equipment purchased with CDBG Gross income from use/rental of real or personal property acquired, constructed, improved (less costs incidental to generation of income)

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PROGRAM INCOME cont.

What is program income (cont.) – – – –

Payments of principal & interest on CDBG loans Proceeds from the sale of loans or obligations secured by loans made with CDBG Interest earned on program income pending its disposition Funds collected through special assessments on properties not owned/occupied by LMI persons

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PROGRAM INCOME cont.

When isn’t it program income?

– – – – –

Income in a single year not exceeding $25,000 Income generated by some Section 108 activities Proceeds of subrecipient fundraising Funds collected through special assessment Subrecipients’ proceeds from disposition of property five years or more after grant close out.

cont.

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PROGRAM INCOME cont.

When isn’t it program income? (cont.) – – – –

Interest earned on grant advances - that must be remitted to the U.S. Treasury, including: interest earned from initial investment of a grant advance interest earned on activities later determined to be ineligible or not meet a national objective interest earned on funds reimbursed to the program account before it has been used for an eligible activity.

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PROGRAM INCOME cont.

In a CDBG revolving loan program, when does a subrecipient have to return program income to the grantee and when may it request additional CDBG funds from the grantee?

1. Whenever the subrecipient agreement stipulates it or at the end of the on-going relationship with the recipient.

2. Any program income on hand in a revolving fund must be substantially disbursed before additional cash withdrawals can be made for the same activity.

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 

RETURN OF PROGRAM INCOME

Reg. cite §570.504(b)(2)(iii) Under what circumstances and when must a grantee return program income to its CDBG line of credit?

–

Excess must be returned to grantee’s line of credit

–

Any program income amounts not in revolving funds in excess of 1/12 of the most recent grant must be remitted to HUD.

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HOW TO CALCULATE EXCESS INCOME

(1) Determine aggregate amount of program income held by grantee and subrecipients (2) Subtract immediate cash needs, revolving fund loan balances, lump sum drawdown balances, and cash used as security for Section 108 (3) Anything in excess of 1/12 of recent entitlement must be remitted 1

SAMPLE CALCULATION

Program income at end of PY: Immediate cash needs Revolving loan fund balance Lump sum draw down Cash held for 108 Annual CDBG entitlement: Amount to be remitted Balance retained: $450,000 $ 20,000 $180,000 -0 -0 $1,920,000 ?

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SAMPLE CALCULATION

Program income: Less: Immediate cash needs Revolving loan fund balance Lump sum draw down Cash held for 108 Balance: $450,000 ($ 20,000) ($180,000) ($0) _____($0) $ 250,000 Annual CDBG entitlement: 1/12 annual entitlement Amount retained: $1,920,000 $ 160,000 Amount to be remitted ($250,000-$160,000) $ 90,000 $160,000 + $200,000 = $ 360,000

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OMB Circular A-133 Audit Requirements

Recipients/subrecipients expending $500,000 or more in a Program Year must have a single or program specific audit 1

HOW THE CDBG FORMULA WORKS

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HOW THE CDBG FORMULA WORKS  CDBG funds are allocated in accordance with Section 106(a)(3) of the Housing and Community Development Act of 1974, as amended, which provides that grants will be based on a formula approach.

 The formula(s) are “share” formula(s), meaning a grantee’s allocation will decrease or increase to the extent that its share of all metropolitan areas changes. 1

HOW THE CDBG FORMULA WORKS

Q: How many formulas does CDBG use to calculate the grant amount for each CDBG entitlement recipient?

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ANSWER

2

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FORMULA A



Formula A is based on shares of population (weighted at 25%), poverty (weighted at 50%), and overcrowded housing (weighted at 25%).

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FORMULA B



Formula B is based on shares of poverty (weighted at 30%), age of housing (weighted at 50%), and growth lag* (weighted at 20%).

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