Community Development Block Grant (CDBG) Program 2009-10

Pre-application Orientation

10:00 A.M.

January 22, 2009

Strother Conference Room

Lee‟s Summit City Hall

City of Lee‟s Summit

Agenda Staff presentation

o CDBG --- general introduction

o Consolidated Plan and Action Plan

o Core process

o Project proposals

o Eligible activities & ineligible activities

o Technical assistance upon request and standard procedure

o Project selection process and criteria

o Consolidated Plan, Annual Action Plan & CAPER

o Environmental review

o Conflict of interest

Agenda Cont.

Staff presentationo Subrecipient grant agreement

o Timeliness

o Performance measurements & recordkeeping & reporting burdens

o Subrecipient performance monitoring program

o City‟s general requirements for subrecipients

o Application Form and Attachments A&B

o Important dates & mandates

Questions & comments

CDBG – Community Development Block Grant

Federal entitlement program under the Department of Housing and Urban Development (HUD) that “provides annual grants on a formula basis to entitled cities and counties to develop viable urban communities by

– providing decent housing

– Providing a suitable living environment

– expanding economic opportunities, principally for low- and moderate-income persons.”

CDBG Grant History –Lee‟s Summit

Year Grant Amt.

1995 $344,000

1996 $318,000

1997 $341,000

1998 $345,000

1999 $348,000

2000 $357,000

2001 $375,000

2002 $367,000

2003 $370,000

2004 $367,000

2005 $351,780

2006 $318,234

2007 $319,531

2008 $309,700

Total $4,831,245

Grant Amt.

$270,000

$290,000

$310,000

$330,000

$350,000

$370,000

$390,000

1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008

Consolidated Plan & Action Plan

Entitlement communities are required to develop a 5-year consolidated plan (CON Plan) through a public participation process

The CON Plan identifies and prioritizes the needs of the community and establishes goals and objectives as a basis for grant allocation

Entitlement communities are also required to develop an annual action plan to implement the CON Plan by allocating the annual grant funds to execute eligible activities to achieve the established goals and objectives

Core

Process

Project Proposals – Important Points to Remember

With few exceptions, do not aggregate activities– Activities with different service areas

– Activities with different clientele

– Activities with different scope of work

– Activities with drastic timing difference

Avoid „bundling‟ activities that meet different

national objectives (Example: Providing job training for LMI persons

and financial assistance to those who need to replace their home heating and cooling system)

Do not bundle activities some of which are eligible and some are not (Example: Reconstructing a parking lot and filling

some minor cracks in the sidewalk)

Evaluate your recordkeeping and reporting burdens

Evaluate your staff capacity

Evaluate your real needs and timing (Receiving funds one

year does not increase your chances to receive them again the following year for the same program. Skipping a year, likewise, does not mean that you are less likely to receive funds in future years for the same program)

Eligible Activities and Ineligible Activities

Eligible Activities– Acquisition of real property (for a public purpose other than the

general conduct of government)

– Public facilities and improvements (all facilities and

improvements either publicly owned or owned and operated by a nonprofit open to the general public)

– Privately-owned utilities

– Public services

– Interim assistance

– Rehab of residential and non-residential structures

– Homeownership assistance

– Administration cost of running an eligible CDBG program and activity

– Planning and capacity building

Eligible Activities and Ineligible Activities Cont.

Ineligible Activities

– Activities not meeting a National Objective, even if they are listed by HUD as eligible activities

– Acquisition, construction or reconstruction of buildings for the general conduct of government

– Political activities

– Construction of new housing (unless by authorized

Community-based Development Organizations)

– Any costs not directly related to the implementation of the activity described in the approved application

– Administrative costs that are considered excessive and unreasonable

Technical Assistance Upon Request

Starting this year, staff assistance will be made available to those prospective applicants who make a formal request to the City

To be fair, staff assistance is available to everyone

Assistance will be limited to the following– Informing, interpreting, and explaining to the clients of the

eligibility rules and regulations

– Helping the clients in their understanding of a desirable CDBG activity administration system

– Helping the clients in their understanding of their record-keeping and reporting responsibilities

– Helping the clients with their drafted proposals in the area of meeting the national objectives and eligibility

Technical Assistance Upon Request

Technical assistance will not do the following– Draft a program or project for clients

– Do a complete review of clients‟ proposals and offering feedback

– Do cost estimates for clients

– Provide a guarantee that the proposal or a portion of it will be funded under prescribed conditions

– Provide surveys and engineering services

– Conduct cost-benefit analysis for clients

Project Selection Process

Staff reviews the applications for completeness and eligibility

Staff tabulates the requests

Staff performs in-depth reviews and provides funding recommendations

Council CDBG Committee holds a public hearing for application presentation and recommendation (3/25 in Council Chambers)

Staff compiles the complete Action Plan draft

30-day public review and comment period

City Council (full council) ordinance to approve the Action Plan (5/7)

Selection Criteria

Meeting both HUD‟s eligibility criteria and the National Objectives

Meeting the community needs identified in the CON Plan

Meeting the goals and objectives established in the CON Plan

Funding availability and caps

Applicant‟s ability to execute the program

Applicant‟s readiness and timeliness

Other risk factors, such as past performance

CON Plan, Action Plan & CAPER

What are they?

– CON Plan --- We already know

– Action Plan --- We also know

– CAPER --- Stands for Consolidated Annual Performance and Evaluation Report

An annual report prepared by the City and due to HUD 90 days after every program year

Summary of all the activities that incurred costs within the program year

Summary of accomplishments

Summary of financial transactions and obligations

Report of beneficiaries

CON Plan Goals and Objectives

Eliminating and Preventing Homelessness

Preserving Affordable Housing

Develop Quality Housing

Adequate Public Housing

Promote Accessibility

Economic Development

Historic Preservation

Public Facilities

Public Infrastructure

Public Services

Anti-Poverty Strategy

Other Community Development Needs

Environmental Review

The Grantee (City) is required by HUD to complete an environmental review for every activity to be funded with CDBG

No other persons or agencies should assume the responsibility of environmental reviews

No activities should start and incur costs before the required environmental review is complete

Environmental Review

CDBG-assisted activities fall under the following categories:

– Exempt (no compliance required)

– Categorically excluded activities not subject to 58.5 (may be converted to Exempt)

– Categorically excluded subject to 58.5 (Statutory Checklist, Public Hearing and Request for Release of Funds required)

– Activities requiring full environmental assessment

Federal Law on Conflict of Interest

The law 24 CFR 570.611:– Is intended to protect the reputation of the CDBG program

from even the appearance of providing special treatment or serving a special interest

– Says “The conflict of interest provisions of …apply to any person who is an employee, agent, consultant, officer, or elected official or appointed official of the recipient, or of any designated public agencies, or of subrecipients that are receiving funds under this part.”

– As HUD interprets, says that “all employees (regardless of the departments that they work for) of 1) an Entitlement; 2) a State; 3) a unit of general local government receiving CDBG funds from the State or 4) a subrecipient, [along with the other persons described at 570.611(c)] are considered covered persons under the conflict of interest provisions

Subrecipient Grant Agreement

All subrecipients must review, understand and sign grant agreements pertaining to their projects as a condition to use CDBG funds

Grant agreements outline the scope of the projects to be executed, funds budgeted, rules to follow and responsibilities of the subrecipients throughout the execution of the projects

Timeliness

HUD requirements

Grantee responsibilities

Subrecipient responsibilities

What does this all mean?

How can un-timeliness be prevented?

Performance Measurements & Recordkeeping and Reporting

Performance measurement system – key indicators

– to show the program‟s effectiveness and results

– to increase service quality

– to improve public accountability

– to measure accomplishments

Recordkeeping and reporting requirements are an important component of the system

In addition to the basic recordkeeping requirements, subrecipients are required to maintain and report beneficiary records in the following key areas (not all of the following applicable to all activities):

– Racial categorization

– Number of persons in the family and total annual family income

– Female head of households

– Number of persons having access to new facilities or services

– Number of persons having access to improved facilities or services

Performance Measurements & Recordkeeping and Reporting

Things to consider as an applicant– Does your agency like this system and all the requirements?

– Does your agency have a system already in place to comply with those requirements?

– Will your clients object to giving away that information in order to receive that service to be funded with CDBG grant?

– Does your agency have the staff level to bear the burden?

– Does your agency‟s available resources allow you to do that?

– Can you get your board of directors to support using the agency‟s resources to do all this?

– And so forth

Subrecipient Performance Monitoring Program

City is required to incorporate a subrecipient monitoring plan in its annual action plan

Monitoring can happen anytime during the program year Normally monitoring plan is also incorporated in the

subrecipient grant agreement Subrecipients are notified in advance about the

monitoring and what to monitor Monitoring is not intended to be a „gotcha‟ but rather a

preventive and corrective measure to improve performance and ensure compliance

City‟s General Requirements for Subrecipients

Attend required orientations, education workshops and meetings to discuss subrecipients‟ projects

Execute the projects in a timely manner Maintain and report project records and data per

HUD regulations Invoice the City at least quarterly with all the

required documentation Report beneficiary information to the City on a

quarterly basis satisfactory to HUD Communicate with the City on a regular basis

Quotes from HUD

“Both partners (Grantees and subrecipients) must accept the fact that there is no such thing as a „free lunch‟. In return for Federal funding, grantees and subrecipients agree to comply with the laws and regulations governing the use of those funds” –Playing by the Rules, p. vi

“In using Federal funds the cardinal rule is: documentation. The achievement of program goals and the completion of activities must be supported by adequate documentation of the facts.” – Playing by

the Rules, p. vi

2009 Application Form and Attachments A & B

This year‟s application form includes one form and two attachments (A & B)

A complete application must include all three

Major changes this year – no significant changes from last year

2008 Application Form and Attachments A&B

Review the form and attachments

2009 Application

Information Packet

•The application information packet and the forms are available on the City‟s website for download in both Microsoft Word and pdf formats

•There is also information on this website that will help you understand CDBG and helpful links are also provided there for you to review HUD regulations and requirements

•Web address: www.lees-summit.mo.us and follow CDBG program on the left-hand side of the screen

If your program is funded

You must sign a subrecipient agreement with the City

HUD will issue an Activity Number for your program and you are required to refer to that number every time anything needs to be processed for that activity

You are required to keep records of everything required by HUD and the City

You are required to submit to the City data on the records you maintain at least every quarter

Important Dates

Event Date Notes

Application Deadline Feb 27 Before 5:00 P.M.

CDBG Community Public Hearing March 25 3:30 P.M. Council Chambers

Council Ordinance Approving Action Plan

May 7 Council Regular Meeting Time

Action Plan Submitted to HUD May 15 45 days prior to the starting date of the program year

Grant Award Letter to Applicants After Council Ordinance Approval

Program Year Starts July 1

Environmental Review Before or After July 1

Grant Agreement Meetings After City Receives Approval from HUD

Approved Activity Can Start After ER is Complete Usually on-going public services do not need to stop for HUD approval.

CDBG Pre-Application Orientation

Thank you for your participation

Questions & Comments