2009 cdbg financial management and grant administration

2009 CDBG/CHIP Recipients’ Workshop

2009 CDBGFINANCIAL MANAGEMENT

ANDGRANT ADMINISTRATION

$?$?$

Page 22009 CDBG/CHIP Recipients’ Workshop CDBG Financial Management

2009 COMPETITION• CDBG’s received: 149 @ $71,590,222• CHIP’s received: 43 @ $12,411,811• STIMULUS received: 68 @ $30,110,460

• CDBG’s awarded: 64 @ $32,575,404• CHIP’s awarded: 15 @ $4,381,605• STIMULUS (CDBG–R) awarded: 23 @ $10.3 mil

!!!!!!

Page 32009 CDBG/CHIP Recipients’ Workshop CDBG Financial Management

WHAT’S INVOLVED??

• LAWS (Federal, State, and Local)

• RULES• REGULATIONS• FORMS • DEADLINES

Page 42009 CDBG/CHIP Recipients’ Workshop CDBG Financial Management

CHAPTER 1

CHAPTER 3

Appendix I

Appendix II

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GRANT AWARD PACKAGE

1. STATEMENT OF CDBG AWARD 2. General & Special Conditions 3. Statement of Revisions 4. Budget Summary (CDBG $ + Recipient $) 5. Civil Rights Compliance Certification 6. Authorization Agreement for Automatic

Deposits 7. Authorized Signature Card

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Grant Award Package should be signed and returned by OCTOBER 25th!!• Georgia Department of Community Affairs• Office of Community Development• 60 Executive Park South, NE• Atlanta, Georgia 30329-2231

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STATEMENT OF CDBG AWARD• CONTRACT between you and DCA “in accordance

with the plan set forth in the application”. Provided it is accepted and returned to DCA by October 25!!!!!!!

• GRANT NUMBER assigned to your new CDBG should appear on ALL correspondence submitted to DCA.

• GRANT PERIOD: request a grant extension prior to end of grant period if more time is necessary!

NOTE: SIGN and RETURN WHITE COPY to DCA.KEEP PINK COPY FOR YOUR FILES.

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GENERAL CONDITIONS for ALL grants (CDBG/EIP/CHIP):

ENVIRONMENTAL REVIEW - CHAPTER 2 of Recipients’ Manual RICK HUBER 404-679-3174 huber@dca.state.ga.us

Once all requirements have been satisfied, DCA will issue a letter environmentally releasing grant funds.

NOTE: form must be signed and returned with Statement of CDBG Award.

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SPECIAL CONDITIONS

• Special Conditions are specific to each CDBG and must be cleared by a Grant Adjustment Notice prior to drawing down construction funds.

• Form must be signed by Chief Elected Official and returned with Statement of CDBG Award. By signing, you acknowledge special condition issues will be adequately addressed as soon as practical. This does not clear S.C.

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STATEMENT OF REVISIONS

• Review STATEMENT OF CDBG AWARD to see if “This award is subject to revisions” is checked.

• If so, after a thorough review of your budget by DCA, changes were made.

NOTE: form must be signed and returned with Statement of CDBG Award.

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BUDGET SUMMARY• This is your OFFICIAL BUDGET. Set up your

CDBG accounting records using this budget; it may be different from DCA-8 as submitted with your application.

• Local financial participation appears at the bottom of the page. Documentation MUST be maintained and will be monitored at close-out of the grant.

• NOTE: DO NOT RETURN THIS FORM TO DCA.

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CIVIL RIGHTS COMPLIANCE• Person responsible for personnel practices should

complete this form.

• Have any written civil rights complaints been filed against your community? If so, please explain in space provided.

• Person preparing the form should sign along with Chief Elected Official.

• NOTE: Return to DCA with Statement of CDBG Award.

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AUTHORIZED SIGNATURE CARD• This has NOTHING TO DO WITH BANK ACCOUNT.

Everything to do with DRAW DOWN form. NO ERASURES. NO CORRECTIONS.

• Local elected official authorizes person(s) to draw down funds.

• Local option: ONE or TWO signatures on draw down forms. Space for 4 signatures on signature card.

• Person(s) authorized to sign draw downs should be someone readily available when needed.

• Make sure to have an adequate number of persons authorized in case of illness and vacation.

• At least one local government representative At least one local government representative (elected official or employee) must sign draw downs.(elected official or employee) must sign draw downs.

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AUTHORIZED SIGNATURE CARD

DCA requires TWO signatures on draw downs IF:

• Elected official authorizes himself to draw down funds.• Grant administrator (RDC or private consultant) is

authorized to sign.

NOTE: Make yourself a copy before returning signature card to DCA.

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AUTOMATIC DEPOSITS (ACH)• DCA deposits funds electronically to your CDBG checking

account.

ATTACH VOIDED CHECK

Provide CDBG bank account information: bank name/location; account number; authorized signatures.

CDBG GRANT NUMBER.

• It will take a couple of weeks to set-up the electronic process.

Make yourself a copy before returning form to DCA.

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CDBG BANK ACCOUNTChapter 1: Cash

Depositories

• Separate non-interest bearing bank account for each CDBG project you have.

• Only CDBG funds deposited into this account. Match and other funds should not be deposited into this account.

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CDBG CHECKING ACCOUNT TIPS

• Check to see if a minimum balance is required to keep account open.

• If local money is used to open account, it can be reimbursed later.

• AFTER 3 WORKING DAYS OF RECEIVING GRANT FUNDS CASH ON HAND SHOULD NOT EXCEED $5,000!

• CDBG will NOT PAY INSUFFICIENT FUNDS CHARGES!

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REMEMBER……. IF NO GRANT AWARD

PACKAGE ........... NO $$$$$

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Monitoring Program Performance and Compliance

(Chapter 1: Section 4)

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LOCAL RESPONSIBILITY

• Keep project on track with time schedules as described in the approved CDBG application! Complete project within 24 months.

• Adhere to all federal and state requirements. • Report problems, delays, or adverse

conditions on page 2 of quarterly report.

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PLEASE READ CLOSELY!!!

•CHAPTER 1• Section 15:

SANCTIONS

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CDBG PROJECT REVIEW CHECKLISTS are located in APPENDIX 2….

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START-UP SITE VISITElected OfficialCity or County ClerkGrant administratorInterested Parties Low/Mod Surveys

START-UP SITE VISIT

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PUBLIC INSPECTION• The CDBG Application

• Citizen Participation plan

• Financial reports - including quarterly reports, bank statements, invoices, and bank register showing receipts & disbursements in chronological order (e.g., CDBG Check Book)

• Environmental review record

• Other pertinent information such as engineering plans or floor plans

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CITIZEN PARTICIPATIONChapter 1: Section 8

PUBLIC HEARINGS1. PRIOR TO SUBMISSION OF APPLICATION2. WITHIN 60 DAYS OF GRANT AWARD (by

November 24th!)3. FINAL - AT PROJECT COMPLETION4. and if PROGRAM AMENDED

Page 282009 CDBG/CHIP Recipients’ Workshop CDBG Financial Management

Public Hearing Notices

• A full 5 CALENDAR days must pass from the publication date to the public hearing date.

• HINT: DO NOT COUNT DATE PUBLISHED OR DATE OF HEARING

• DO NOT PUBLISH IN LEGAL SECTION

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CONSIDERATIONS TO KEEP IN MIND WHEN PLANNING A PUBLIC HEARING

• Times and locations convenient to potential or actual beneficiaries.

• Accessible for handicapped persons.• Interpreter for non-English speaking

residents.

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POST-AWARD PUBLIC HEARING

• Must be held within 60 days of award (by November 24th)

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FINAL PUBLIC HEARING

• Your Program Representative MUST be notified at least one week before the final public hearing

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PROCUREMENT• CHAPTER 3, Section 4, page 59

-Section 4A(2), page 60 = Standards of Conduct CONFLICT OF INTEREST

-Section 4B, page 62 METHODS OF PROCUREMENT

• APPENDIX 2▪ 24 CFR 85.36▪ CONFLICT OF INTEREST REGULATIONS▪ Georgia Local Government Public Works Construction

Law

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Conflict of Interest

• Not necessarily a “Deal Killer”• Applies to Procurement of ALL goods and

services.• No persons with the following factors can

be party to CDBG business or any contract:▪ Have a financial interest;▪ May receive a benefit;▪ Have family or business ties from the CDBG

project.

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Conflict of Interest continued• This applies during tenure or for 1 year after.• The following persons are included in this

prohibition:▪ Elected officials▪ Staff with decision making authority▪ Consulting firms such as Administration,

Engineering/Architect▪ Grant sub-recipients▪ Any person associated with LG that have financial,

family or business ties

Page 352009 CDBG/CHIP Recipients’ Workshop CDBG Financial Management

Conflict of Interest continued• Exceptions to the Conflict of Interest policy:

▪ Granted on case by case basis▪ Must be a written request▪ Must be before CDBG money has spent obligated ▪ Only granted if DCA determines that the situation will

benefit the CDBG program▪ Granted if DCA determines that said individual will not

receive any greater benefit from the project▪ Denial would cause undue hardship on LG▪ Public disclosure and abstention from CDBG business▪ Certified by LG Attorney

Page 362009 CDBG/CHIP Recipients’ Workshop CDBG Financial Management

Conflict of Interest continued• Examples of Conflict of Interest:

▪ Mayor owns the sole provider of a service in the area.▪ Administrator is married to County Clerk.▪ Engineer steers LG to procure services of business

partner.▪ Engineer is daughter of the Grant Administrator.▪ City Manager serves on the Board of Directors for

sub-recipient▪ Mayor is married to Officer of company that owns

property in Target Area▪ Engineering firm owns a construction company

soliciting bid for construction

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Conflict of interest continued

• Remember that full and early disclosure is best.

• Keep in mind that we are sensitive to this issue.

• If it smells fishy, get it out in the open!!• Let’s maintain the integrity of the CDBG

program.• We want to avoid a situation to hit the

newspapers and evening news.

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METHODS OF PROCUREMENTChapter 3: Section 4 (B)

Small PurchasesCompetitive sealed bidsCompetitive negotiationsSole Source

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PROCUREMENT STANDARDS

• ALL procurement transactions shall be conducted in a manner so as to provide maximum full-fair and open competition.

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SMALL PURCHASES(for procurements less than $100,000)

Bargain shop---get price quotes from several qualified sources.

Keep documentation in grant files.

• NOTE: cannot be used for administration or professional services

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COMPETITIVE SEALED BIDS(formal advertising)

“GEORGIA LOCAL GOVERNMENT PUBLIC WORKS

CONSTRUCTION LAW”(APPENDIX 2 )

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COMPETITIVE SEALED BIDS

POST construction contract opportunity conspicuously at governing authority’s office.

ADVERTISE in legal organ of the County at least twice during four weeks before bid opening. Keep newspaper tearsheets in grant file.

OR …..advertise by electronic means on an Internet website (run for four continuous weeks). Keep print-out of electronic ad in grant file.

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First ad should be four weeks prior to bid opening. Second ad should follow two weeks after first.

Bids shall be solicited from an adequate number of known suppliers (e-mail, fax, mail – retain proof).

• YES - Firm-fixed-price contract• NO - Cost + % of cost method

COMPETITIVE SEALED BIDS

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COMPETITIVE SEALED BIDS

To ensure a level playing field for all contractors……

INCLUDE ALTERNATIVES DEDUCTS

and ADDITIONS

LIST IN ORDER OF PRIORITY

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IF BIDS COME IN TOO HIGH OR VERY LOW

•DCA approval is needed before eliminating items of significance….ex: reducing size of building, eliminating streets or reducing level of benefit on streets.•DCA approval is needed before adding additional streets, increasing beneficiaries, etc.•DCA approval is needed if scope of work is modified!!

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Relatively NEW:Monitoring Checklist in APPENDIX 2….

PROCUREMENT REVIEW for PUBLIC WORKS CONSTRUCTION

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COMPETITIVE NEGOTIATIONS Grant Administrator & Engineer Or Architect

PUBLICIZE the RFP/RFQ (include “evaluation factors”) in a newspaper with adequate circulation.

ALLOW a minimum of 30 days response time. Request proposals via U.S. Mail from qualified sources.

7 ----- administration 10 ----- engineering or architectural

KEEP DOCUMENTATION IN GRANT FILE.

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• Prepare written evaluation plan that establishes reasons for the choice (aka a “score sheet”).

• Maintain documentation to verify when the RFP’s were mailed out.

• Once proposals are evaluated; attorney should be consulted and full council or commission approval should be obtained.

COMPETITIVE NEGOTIATIONS

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WRITTEN EVALUATION PLAN

1. Decide what is important to your project. Establish selection criteria or “evaluation factors” (prior to receipt of offers).

2. For consistency among evaluating panel members, develop a method for the award of points. Must have “reason” for points given.

Page 502009 CDBG/CHIP Recipients’ Workshop CDBG Financial Management

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 training3 points = 3-4 years of training2 points = 2 years of training1 point = 1 year of training0 points = less than 1 year of training

AWARDING POINTS

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ADMINSTRATIVE CONTRACTREQUIREMENTS

1. Include a clear description of scope of work.2. Listing of specific responsibilities, tasks, goals,

milestones, deadlines. Provisions for recourse if consultant fails to perform by the deadlines imposed.

3. References to applicable CDBG Applicants’ and Recipients’ manuals requiring that consultants adhere to all requirements in the manuals & other DCA directives.

4. Applicable dates of the contract & provisions for termination.

Refer to CHAPTER 1......SECTION 18

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Non-competitive or “SOLE SOURCE”

• PRIOR DCA APPROVAL REQUIRED(Construction and/or professional services)

• Provide the following information:

1. advertisement date(s)2. response date3. list of firms who received

solicitation

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PROCUREMENT

• ALL contracts should include amount of compensation.

• NOT ALLOWED: cost plus percentage of cost compensation.

Page 542009 CDBG/CHIP Recipients’ Workshop CDBG Financial Management

COMPETITIVE NEGOTIATIONS

IF an acceptable procurement process was followed within the last year for an application that was denied within the past year, it is NOT necessary to readvertise for professional services if you choose to retain the same firm for the same application. If the procurement is more than 1-year old, a new advertisement and solicitation of RFP’s IS required.

Please reference 2009 CDBG APPLICANTS’ MANUAL (page 33)

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!TO DO LIST!1. COMPLETE and

RETURN grant award package by October 25th! Return all ITEMS at the same time.

2. SCHEDULE and HOLD post award public hearing within 60 days of award (by November 24th).

3. OPEN non-interest bearing checking account.

Page 562009 CDBG/CHIP Recipients’ Workshop CDBG Financial Management

!!return by OCTOBER 25th!!

• Georgia Department of Community Affairs• Office of Community Development• 60 Executive Park South, NE• Atlanta, Georgia 30329-2231