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Operational Function Summaries

TABLE OF CONTENTS

Operational Function Summaries ...................................................................................................................... 1

Grants Management .......................................................................................................................................... 2

Policy and Planning ........................................................................................................................................... 5

Program Operations .......................................................................................................................................... 8

Financial Management .................................................................................................................................... 11

Procurement and Contract Management ......................................................................................................... 14

IT and Data Systems ....................................................................................................................................... 17

Training and TA ............................................................................................................................................... 19

Compliance and Monitoring ............................................................................................................................. 21

Human Resources ........................................................................................................................................... 24

Communications .............................................................................................................................................. 26



Grants Management

ROLE Lead and offer overall strategic direction for the implementation of the recovery program, including managing the various CDBG-DR program teams and functions.

CRITICAL RESPONSIBILITIES

Oversee, track, and evaluate program progress. Provide general management of all CDBG-DR recovery staff and functions. Make/approve and track significant policy and program decisions. Serve as the liaison between the recovery staff and political leaders and related agency

staff.

PRE-AWARD TASKS

1. Selection of initial key staff: Assign or hire senior members of the Grants Management leadership, as well as the managers of all key functions. If the organizational structure is not initially identified, appoint existing grantee staff with applicable skills to serve in interim or advisory capacities.

2. Needs assessment: Work with the Policy staff to assess size and scope of the disaster and types/locations of needed assistance.

3. Capacity assessment: Given the needs, work with the Policy and Human Resources staff to assess the capacity of the existing grantee and potential subrecipient staff and organizational systems to undertake the recovery activities. See the Staffing Analysis Worksheet.

4. Administrative approach: Given the needs and capacity assessment, determine how the grantee will generally approach CDBG-DR program administration (in-house staff, contractors, subrecipients, sister agencies, nonprofits, hybrid). This approach may differ by activity type. Determine the role that will be played by existing CDBG program staff. See the staffing model summary.

5. Organizational chart: Based on the chosen administrative approach, with the Human Resources staff develop a CDBG-DR recovery team organizational chart indicating key functions.

6. Pre-award plan: Develop a pre-award implementation plan including all the required elements listed in the applicable Federal Register Notice (once published), such as designation of key staff, communications plan, TA requirements, and designation of accountability.

7. Schedule: Develop a realistic roadmap of the overall program’s priorities, direction, and timeline.

8. Outreach: Coordinate with the Communications manager to begin initial outreach plans for affected households, businesses, landlords, and local governments.

9. Initial contracting: Once funding amounts and general program approach are known, determine what, if any, initial contracting or external expertise is needed regarding program planning or start up. Work with Contracts staff to develop RFPs and procure contractors.

https://www.hudexchange.info/resources/documents/CDBG-DR-Staffing-Analysis-Worksheet.xlsx

https://www.hudexchange.info/resources/documents/CDBG-DR-Organizational-Models-And-Potential-Partners-Summary.pdf



PLANNING/PROGRAM DESIGN TASKS

1. Program design: Lead the process to outline programs that will address unmet needs related to the disaster event. Consider what, if any, existing programs can be adapted to work in the CDBG-DR context. Work with other government agencies, local governments, and nonprofits to see how they can assist to implement CDBG-DR programs and/or what advice they can provide regarding the design of the programs. See the Program Design Toolkit.

2. Public engagement and action plan: Oversee and approve the work of the Planning and Communications teams to conduct public outreach, collect public comments, and develop and submit the Action Plan to HUD.

3. Staffing plan: Based on the organization chart and planned administrative approach, work with Human Resources to determine staffing needs and select the most appropriate staffing model. Approve job descriptions developed by Human Resources. Establish functional divisions, lines of reporting, and authority. If administrative functions will be undertaken by outside entities, approve the contractor procurement or subrecipient selection process.

4. Grants management plan: Create Grants Management Plan that provides basis for monitoring, controlling, and reporting on progress, schedule, costs, and milestones. Topics might include: activity prioritization; workload planning; meetings and schedule management; risk identification; change management; reporting; status reports; and coordination and communication with other functions. Identify or develop technology that will track these grants management functions.

5. IT and reporting needs assessment: Work with Financial Management and IT and Data Systems staff to assess existing system capacity to: manage applications, interactions with applicants, and calculate awards; track partner activities; and interface with Federal reporting systems (DRGR) and grantee financial systems to obtain payments and submit required reports. If existing systems cannot be adapted, coordinate with IT and Data Systems and Contracting staff to procure an IT contractor and/or software.

6. Track overall program Low and Moderate Income (LMI) Benefit: Ensure that budgeted and actual CDBG-DR funding will meet overall Low- and Moderate-Income (LMI) benefit requirement.

OPERATIONS TASKS

1. Program operations: Manage other Functions to ensure the program’s overall priorities and direction are being implemented and meet national objectives. Track progress toward meeting program expenditure deadlines, LMI targets, and other requirements established in the Federal Register notice and help remove roadblocks that may impede program execution.

2. Timelines and prioritization: Develop a detailed timeline for key recovery milestones. Prioritize which programs are most urgent and the order of implementation. Track progress toward milestones and work with Functional teams to adapt programs if schedules are not met.

3. Progress and Outcomes: Communicate program goals to staff, subrecipients, and contractors and identify the metrics that will be used to measure and assess progress. Identify the critical measures that will be used to measure, manage, and communicate progress of the program:

a. Process measures – measures used to measure the program’s progress; often measureable benchmarks in the process flow of program (e.g., beneficiary eligibility determined, environmental review completed, etc.); and

https://www.hudexchange.info/programs/cdbg-dr/toolkits/

https://www.hudexchange.info/programs/drgr/guides/#drgr-user-manual



b. Outcome measures – measures used to determine the success of program at achieving the desired results (performance metrics).

4. Risk management: Evaluate risks to compliant and effective program operations, including any proposed program changes. Assess risks of proposed significant changes to programs and make final decision before changes are made.

5. Coordination: Manage ongoing coordination and communication with agency and political leadership. Oversee communication with subrecipients and partners by Operations staff. Review the public outreach efforts of the Communications team and ensure effective, ongoing citizen participation.

6. Constituent services, complaints, and appeals: Implement procedures for: addressing concerns and questions from constituents; addressing any complaints received against grantee or any subrecipients, contractors, or partners, including a timeframe for response; and appealing program decisions. Ensure that timely written responses are provided for all citizen complaints.

REPORTING, COMPLIANCE, MONITORING, AND CLOSEOUT

TASKS

1. HUD concerns and findings: Work with Compliance and Monitoring and Policy and Planning staff to respond to all HUD and OIG monitoring findings and concerns and work with various Operational Functions to take appropriate actions to address and resolve any findings.

2. Program closeout: As specific activity types are concluded, work with the applicable Program Operations and the Monitoring staff to ensure files are complete, funds are disbursed, and the program activity is closed. Once all CDBG-DR funds are disbursed and all activities are complete, work with Monitoring staff to close out the overall program.



Policy and Planning

ROLE Serve as the central technical resource for the interpretation and application of Federal, State, and Local requirements related to the grantee’s program implementation.


Plan for the use of CDBG-DR funds.

Develop program policies, procedures, and processes.

Address grantee and partner questions related to rules and regulations.

Track and disseminate Federal guidance.

Coordinate QPR reporting and data collection.

PRE-AWARD TASKS

1. Regulatory understanding: Coordinate with HUD staff to access start up resources and understand basic regulatory framework, including how CDBG-DR is similar to and different from CDBG.

2. Needs assessment: Manage the assessment of recovery needs across all technical areas: housing; economic development; infrastructure; and services. Evaluate: (a) types of needs (for example rehabilitation vs. new construction), including needs of LMI and under-served populations; (b) financial estimates of recovery costs; (c) geographic location of needs; and (d) capacity of potential administrative partners.

3. Execute data memorandums of understanding: Work with SBA, FEMA, and insurance companies to receive data regarding extent of damage and existing recovery assistance.

4. Interagency coordination: With Grants Management staff, meet other agencies with a role in recovery and develop coordination plans. Communicate with other grantees, as well as previous CDBG-DR recipients, to understand regional needs and opportunities to collaborate.


1. Staffing: In concert with the Grants Management staff, determine level and types of policy staff. Work with Human Resources to develop job descriptions and hiring requisitions and interview and hire staff. The policy staff may be drawn or borrowed from the existing CDBG program staff. If this is the plan, ensure that the loaned staff understand the differences between CDBG and CDBG-DR and are familiar with recovery activities.

2. Conduct unmet needs assessment and develop the Action Plan: Lead the development of the unmet needs assessment and the writing of the Action Plan. Coordinate with the Communications staff to conduct public hearings and consult with stakeholders.

3. Design effective programs: Based on the needs assessment, work with Grants Management and Program Operations staff to design compliant recovery programs.

4. Seek policy interpretations and draft waiver requests: As needed for program design (or implementation), seek HUD interpretations of eligibility and submit waiver requests when appropriate.

https://www.hudexchange.info/programs/cdbg-dr



5. Develop policies and procedures: Serve as advisor to Grants Management and assist all other functions to conduct process mapping and write policies and procedures, flow charts, forms, and checklists for overall grants management and all proposed programs, projects, and related processes. At a minimum, general grants management procedures must include: procurement; financial management and audits; appeal process; complaints; compliance and monitoring; crosscutting Federal regulations and requirements; and equal opportunity and citizen participation.

6. Environmental review requirements: In coordination with Program Operation, ensure that every project/activity undergoes the appropriate level of environmental review and receives clearance and Authorization to Use Grant Funds (AUGF) prior to expending any funds.

7. Ensure accessibility: Write Section 3 Plan and Language Access Plan.

8. Agreements: Assist in the drafting of subrecipient agreements and inter-agency MOUs.

9. DRGR set-up: Assist Financial Management and IT and Data Systems operational functions with Action Plan set up in DRGR.

OPERATIONS TASKS

1. Create duplication of benefits process: Develop and implement clear procedures for assessing and avoiding duplication of benefits by activity type.

2. Serve as CDBG-DR regulatory expert: Provide policy clarifications and interpretations to program staff and partners.

3. Provide guidance on how to categorize and track costs: Working with Finance function, create guidance on how to charge costs as either administrative, planning, activity delivery, or direct program costs; ensure expenditures are compliant; and track time.

4. Maintain and update policies and procedures: Update policies and procedures, ensure that there are mechanisms in place to capture policy changes over time and maintain an overall repository of the program’s policies and procedures.

5. Action plan amendments: Update the action plan and submit to HUD as necessary program changes occur.


TASKS

1. QPR and other HUD reporting: Work with Finance and Compliance functions to develop forms and procedures for QPR reporting. Assist Compliance division to compile, write, and submit the reports.

2. Prevention of fraud, waste, and abuse: Work with Compliance function to develop procedures to detect, track, and report program violations.

3. Preparation and response to HUD monitoring or auditing concerns: Work with Grants Management and Compliance and Monitoring staff to prepare for HUD monitoring visits. Assist in responding to any concerns.

https://portal.hud.gov/hudportal/HUD?src=/program_offices/fair_housing_equal_opp/section3/section3

https://www.lep.gov/

https://www.hudexchange.info/resources/documents/CDBG-DR-Subrecipient-Agreement-Template.pdf


https://www.hudexchange.info/resource/2083/duplication-benefits-requirements-stafford-act-cdbg-dr/

https://www.hudexchange.info/resource/3725/notice-cpd-13-07-allocating-staff-costs-program-administration-delivery-costs-cdbg/


https://www.hudexchange.info/resource/3688/cdbg-disaster-recovery-drgr-qpr-review-guide/



4. Develop closeout procedures: In concert with Program Operations, Financial Management, and Compliance and Monitoring functions, develop procedures for documenting completion for individual beneficiaries. Work together to develop and implement activity and program closeout procedures.



Program Operations Note: each grantee will likely have multiple operations teams, depending on the range of recovery activities it has chosen to undertake based on the needs assessment.

ROLE Design, implement, and manage individual CDBG-DR activities. Provide services to beneficiaries to foster their recovery.


Apply applicable technical expertise to program design and implementation.

Manage the delivery of recovery services to households, landlords, businesses, local governments, and other partners.

Ensure effective, timely, and compliant program operations.

Document and report program activity status and outcomes.

Adapt programs as needs change or hurdles are determined.

PRE-AWARD TASKS

1. Needs and initial program design: Coordinate with Grants Management and Policy staff to assess depth, type, and location of needs within the given activity type (e.g., housing rehabilitation, infrastructure, business assistance, buy-outs).

2. Program options: Assess options and models for program design. Reach out to similar program activity staff at other CDBG-DR grantees to understand what works and learn about various program administration approaches. Evaluate local program opportunities and constraints.

3. Regulatory framework: Review and build expertise in the CDBG-DR and crosscutting Federal requirements for applicable activity types.


1. Action plan: Work with Policy staff to develop sections of the Action Plan related to the applicable activity type. Contribute to public comment responses for applicable activity types.

2. Program design: Coordinate with Grants Management and Policy and Planning staff to design the applicable CDBG-DR housing, economic development, infrastructure, and/or services program that address unmet needs identified in Action Plan. Consider issues such as: level and type of assistance; beneficiary eligibility; implementation timeline; LMI targeting; applicant outreach methods including outreach to Limited English Proficient (LEP) individuals; ensuring program access to all persons impacted by the disaster; application processing approaches; construction management (as applicable); and need for staff and expertise.

4. Waivers: When required for program design or implementation, work with Policy and Planning and HUD to write and submit waiver requests to HUD. Coordinate with grantee legal staff as needed for interpretations of State/local law.

5. Policies and procedures: Work with Policy staff to develop detailed written flowcharts, processes, and policies for programs and projects.

6. Staffing: In concert with the Grants Management staff and based on the chosen organizational model, determine level and types of staffing needs for that specific program activity. Work with Human


https://www.hudexchange.info/cdbg-dr/cdbg-dr-laws-regulations-and-federal-register-notices/






Resources to develop job descriptions and hiring requisitions and assign, interview, and hire these staff.

7. Contracted administrators or experts: If contractors will be used, work with Contract Management staff to develop RFP, procure firms, and execute contracts.

8. Subrecipients: If nonprofit or public subrecipients will manage the program activity, work with Contract Management staff to develop NOFA, select awardees, and execute subrecipient agreements.

9. Staff and contractor/subrecipient training: Work with Training and TA staff to build applicable staff skills and convey program design and expectations to staff, contractors, and subrecipients.

10. Program outreach: Coordinate with Communications staff to determine appropriate approaches to engage potential program beneficiaries and solicit program applications.

OPERATIONS TASKS

1. Manage programs: Implement and manage program activities according to the agreed upon procedures, ensuring outcomes and timelines are achieved. If deficiencies are determined, propose suggested changes to program design or procedures. Upon approval from Grants Management (when the change is significant), implement process changes and track revisions. If the grantee has chosen to allow subrecipients or contractors to administer the activity, actively monitor and manage their implementation of all of the tasks outlined below.

2. Application: Create beneficiary applications, collecting the information outlined in program policies and procedures. Stand up and operate call center and/or intake centers to handle questions and help process applications for beneficiaries (as needed depending on activity types and program design).

3. Access: Provide language translation and interpretation services in accordance with Language Access Plan to all applicants and interested parties. Ensure all services and facilities are accessible to persons with disabilities.

4. Applicant coordination: Develop adequate procedures to inform applicants of the status of their applications for recovery assistance at all phases, indicate methods of communication, ensure accessibility and privacy of applicant information, indicate the frequency of applicant status updates, and identify which personnel or unit is responsible. Work with Communications team to ensure regular and appropriate outreach to potential beneficiaries, applicants, local towns, the media, etc.

5. Eligibility review: Review all applications for tie to the disaster event, duplication of benefits, eligibility, consistency with program requirements, property title, failure to maintain NFIP (when applicable), and needs. Determine appropriate level of assistance, which may require onsite inspections for some activity types.

6. Environmental review: Ensure that every project/activity undergoes the appropriate level of environmental review and receives clearance and Authorization to Use Grant Funds (AUGF) prior to expending any funds.

7. Beneficiary agreement: Execute a written agreement with each beneficiary outlining the scope of work and program requirements. Consider whether subrogation agreements, land covenants, deed restrictions, or legal recordation of the agreement are needed.


https://www.hudexchange.info/resources/documents/Disaster_Recovery_Small_Business_Program_Subrogration_Agreement.docx



8. Construction management: Depending on program type and local laws, procure construction contractors (not applicable under all situations). Review appraisal, architectural, engineering, and construction documents, as applicable. Ensure that construction projects are carried out in accordance with Davis-Bacon and Section 3 rules and requirements.

9. Other Federal requirements: Ensure compliance with all other crosscutting Federal requirements, including but not limited to: Uniform Relocation Act, Fair Housing and Equal Opportunity, Lead-Based Paint, and One-for-One Unit replacement (if applicable).

10. Coordination: Develop mechanisms for coordinating with other local, regional, and nonprofit planning and funding efforts to ensure consistency and complementary actions such as working groups and monthly meetings.


TASKS

1. QPR and other HUD reporting: Work with Finance, Compliance, and Policy functions to submit information for Quarterly Progress Reports.

2. Documentation and record-keeping: In partnership with IT and Data Systems and Compliance and Monitoring staff, create system for maintaining all documents and information related to individual project and activity files.

3. Monitoring: Respond to HUD monitoring and HUD OIG audits and adapt program activity based on HUD concerns.

4. Individual and program activity closeout: Track when household projects are complete and ensure final financial reconciliation (ensure no recapture is needed). Close out individual files and program files once all activities are complete.

https://www.hudexchange.info/resource/2640/davis-bacon-act-40-usc-3141-et-seq/

https://portal.hud.gov/hudportal/HUD?src=/program_offices/fair_housing_equal_opp/section3/section3

https://www.hudexchange.info/resource/34/cdbg-crosscutting-issues-toolkit-contents/

https://www.hudexchange.info/onecpd/assets/File/DRGR-User-Manual-Section-6-Quarterly-Performance-Report.pdf



Financial Management Note: Some grantees may establish new financial management teams and some may choose to add capacity to existing financial management divisions at the State or local government. If existing teams are used, ensure that that these staff understand how CDBG-DR differs from other programs.

ROLE Manage the transparent, efficient disbursement of CDBG-DR funds and ensure the financial system and processes are compliant.


Disburse and receive CDBG-DR funds, including use of DRGR.

Ensure that all CDBG-DR costs are appropriately documented, tracked, and reported.

Oversee periodic program audits and financial reviews.

PRE-AWARD TASKS

1. Risk analysis: Develop/document financial controls that are a part of the Risk Analysis Documentation and must be completed and returned by Grantee to HUD within 30 days of the effective date of the Federal Register Notice publishing the award of funds.


1. Financial policies and procedures: Develop detailed, written policies and procedures which cover (at a minimum): review of invoices to ensure allowable costs incurred during the period of performance and authorized pre-award costs; disbursement of funds; accounting records regarding award, authorizations, obligations, unobligated balances, assets, liabilities, expenditures, and interest; cost reasonableness; source documentation; encumbrances/obligations; adequate control over all funds, property, and other assets; self-assessment of internal control system; fidelity bond coverage; receipt and use of program income; management of grant advances (when permitted by HUD and applicable); documentation of in-kind or matching funds (if required by grantee); and audits.

2. DRGR and IT system: Create policies and tools for drawing funds from and reporting in DRGR. With the IT staff, determine whether a separate or new financial and tracking system is needed for the CDBG-DR award or whether existing grantee financial systems will be adapted. Ensure the chosen system can interact seamlessly with the application tracking systems used by the Program Operations teams.

3. Personal information: Enact policies to protect Personally Identifiable Information (PII) and information designated as sensitive, consistent with applicable Federal, State, local, and tribal laws regarding privacy and obligations of confidentiality.

4. Timeliness: Create tracking systems to evaluate and report the timeliness of the grantee’s overall CDBG-DR expenditure rate as well as progress towards meeting outcome measures and the comparison of obligations to expenditures. Develop standards to ensure the timing and amount of funds transfers as close as is administratively feasible to the actual cash outlay for direct program costs and the proportionate share of any allowable indirect costs.



5. Staffing: In concert with the Grants Management staff and based on the chosen administrative model, determine level and types of staffing needs for the financial function, depending on how it will integrate or work with the grantee’s existing financial staff. Work with Human Resources to develop job descriptions and hiring requisitions and assign, interview, and hire these staff.

6. Administrative and indirect costs: Develop an administrative cost budget and determine how that budget is allocated by function or task. If the grantee will charge indirect costs to CDBG-DR, develop an indirect cost rate plan and submit it to the cognizant Federal agency for approval (if not already in place). For guidance consult this HUD Notice on Administrative and Activity Delivery Costs.

7. Budgets: Once programs are designed, work with each function and program activity operational team to develop a detailed budget. Ensure that all teams understand their budget constraints, including limitations on administrative or activity delivery costs.

8. Financial guidance: Develop tools and guidance for CDBG-DR program staff regarding key financial issues such as timekeeping, administrative vs. activity delivery costs, timeliness, and cost documentation. Set up and distribute to all recovery staff a detailed billing code structure that allows staff to track costs by activity and cost type.

OPERATIONS TASKS

1. Expenses and payments: Review invoices and make timely payments to vendors, contractors, subrecipients, beneficiaries, and other government agencies. Adhere to cost principles as detailed in 2 CFR §200.400 – §200.475 as applicable. Maintain project financial files for each disbursement.

2. Funds received: Manage, document, and report all funds received back to the grantee, such as program income; funds recaptured from beneficiaries, contractors, or subrecipients; or miscellaneous revenue.

3. DRGR expenditures and receipts: Set up DRGR activities. Issue requests for drawdowns from US Treasury via DRGR, as supported by eligible costs and invoices. Submit information to DRGR on financial obligations, expenditures, program income, and other funds receipts.

4. DRGR reporting: Work with the Program Operations staff to ensure that outcome information is submitted to DRGR. Support the Policy team to develop and submit the QPR. Ensure that the QPRs and other applicable reports are reconciled with Grantee’s accounting records for the time periods reviewed.

5. Systems reconciliation: Ensure that the financial transactions in the grantee’s IT system are consistent with DRGR. Work with the IT staff to identify and correct any systems issues.

6. Financial status: Track and report financial activities and expenditures to Grants Management and other teams. Items to track include but are not limited to: total CDBG-DR expenditures; burn rate, projections and timeliness; administrative versus program delivery costs by eligible activity; funds identified as benefitting LMI persons; and receipt and use of program income.

7. Budget amendments: As programs change, amend budgets and DRGR set-up over time. Ensure that an Action Plan amendment has been developed and HUD has approved it before establishing new programs, eliminating existing programs, or reallocating more than one million dollars between programs.


https://www.ecfr.gov/cgi-bin/text-idx?node=2:1.1.2.2.1#sp2.1.200.e





TASKS

1. Audits: Ensure annual audits are conducted and submitted to the Federal government. Review all audits and correct any financial system deficiencies noted by the accountant.

2. Monitoring: Ensure that financial files are organized and accessible for periodic HUD monitoring. If financial deficiencies are found, amend existing policies, procedures, and systems.

3. Closeouts: Upon notification of a project or beneficiary closeout by the Program Operations team, verify that all funds have been disbursed and financial files are complete and if yes, close out that file. Provide documentation and final financial reports for the CDBG-DR program closeout.



Procurement and Contract Management Note: For many grantees, this function will be conducted by existing grantee procurement or contracts staff. This is acceptable so long as those functions comply with all CDBG-DR contracting requirements.

ROLE Manage the compliant, efficient selection of contractors and subrecipients and ensure the execution of complete contracts with all CDBG-DR awardees.


Ensure that all supplies, materials, services, and equipment are procured in compliance with Federal requirements and in a manner that encourages full and open competition.

Verify and document that all contracts are awarded for eligible, necessary, and reasonably priced goods and services.

Execute subrecipient and contractor agreements that conform to statutory and regulatory requirements.

PRE-AWARD TASKS

1. Procurement framework: If the grantee is a State CDBG-DR recipient, in concert with the Grants Management team, decide and document in its procedures whether it will follow Federal procurement rules and regulations or if it will follow State procurement laws. State procurement policies and procedures must still demonstrate compliance with Federal cost principles. Note that this option is not applicable to local government grantees or subrecipients of State agencies. Local government subrecipients must follow the Federal procurement laws and subrecipients must follow whichever option is chosen by their State. Also, note that even if a State chooses to follow the Federal procurement standards, this does not necessarily negate State or local requirements. Grantees must consult with their program counsel regarding applicable rules.


1. Procurement policies and procedures: Work with the policy team to develop and maintain detailed contract management and procurement policies and procedures that are compliant with Federal, State, and local rules and regulations. At a minimum, ensure that the procedures cover: acceptable methods of procurement (e.g., small purchase, sealed bid/formal advertising, competitive proposals, non-competitive proposals); standards of conduct for employees engaged in contract award and administration; preferences for or outreach to small, minority, women, veteran, and Section 3 businesses; cost reasonableness and where applicable developing independent cost estimates; and a process for solicitation and acceptance of bids. It may be acceptable to use existing grantee procurement procedures IF these procedures are complete and accurate for CDBG-DR. If required by the CDBG-DR Federal Register notice, submit these procedures to HUD for approval. The final procurement policies and procedures must be posted to the grantee’s comprehensive CDBG-DR website.

2. Contracting policies and procedures: Establish policies and procedures for creating and managing subrecipient agreements, private entity contracts, and memorandums of understanding with other public agencies. Ensure that all subrecipient agreements are compliant with 2 CFR Part 200 Appendix II and contain all clauses required by Federal statutes, executive orders, and implementing regulations. Ensure all private contracts include all clauses required by Federal statues, executive orders, and

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implementing regulations (24 CFR 570.487, 24 CFR 570.489). Grantees should review and revise existing agreements that may have been in place prior to disaster before utilizing them for CDBG-DR program administration.

3. CDBG-DR Grant agreement: Work with Grants Management staff and program legal counsel to review and execute the HUD grant agreement and ensure all parties understand its clauses.

4. Procurement plan: Coordinate with Grants Management and all functional teams to understand the program administration decisions and intended procurements and/or subrecipient decisions. Develop a plan indicating the timeline, scope, and approximate value of intended procurements and subrecipient partnerships. Update this plan as program design decisions are modified.

5. Initial external expertise: If directed by the Grants Management team, procure the initial external experts as needed to assist with program design and start-up.

6. Staffing: In concert with the Grants Management staff and based on where the grantee has decided to locate the contracts function, determine level and types of staffing needs. Work with Human Resources to develop job descriptions and hiring requisitions and assign, interview, and hire these staff.

OPERATIONS TASKS

1. Contractor registry: Maintain a contract registry of vendors, contractors, and subcontractors by date and type of procurement (e.g., micro-purchases, small purchases, requests for proposal, and sole-source and competitive bids), funding source, amount of the contract, and scope of work

2. Procurement implementation: Implement the policies and procedures to procure and select companies and subrecipients as requested by functional teams and approved by Grants Management. Complete an independent cost estimate for every procurement action prior to commencing procurement. Issue procurement opportunities pursuant to 2 CFR 200.318 - 200.326 and applicable Federal Register notices. Review all bids, including cost reasonableness, and choose winning bidders.

3. Small, minority, women, veteran’s, and Section 3 businesses: Follow the grantee’s procedures regarding preferences for contracting with small, minority-, and/or women-owned businesses. Track and document compliance with the grantee’s Section 3 policy on hiring of local and LMI businesses.

4. Conflict of interest: Ensure that procurement policies and procedures outline standards of conduct for employees engaged in the award or administration of contracts. Verify that all employees involved in CDBG-DR program are aware of and comply with conflict of interest rules. Where needed, work with the Training and TA team to provide technical assistance on procurement and conflict of interest rules.

5. Debarment: Work with Financial Management team to ensure that no awards are made to a debarred contractor by checking the list of debarred contractors located at https://www.sam.gov.

6. Contract awards: Make awards to the winning bidder following the procurement policy. Every award letter must contain the 13 specific elements specified in 2 CFR §200.331.

7. Subrecipient awards: For subrecipient agreements, conduct due diligence on the following prior to making awards: financial stability; management systems in place to ensure compliance with Federal and State requirements; history of prior performance; prior audit findings and resolution; and ability to effectively implement statutory, regulatory, and other grant requirements.

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https://www.sam.gov/

https://www.ecfr.gov/cgi-bin/retrieveECFR?gp=&SID=f3d0f025ad857c0d46aeab9de36b48a9&mc=true&n=pt2.1.200&r=PART&ty=HTML#se2.1.200_1331




8. Contract implementation: Prepare contracts with contractors and agreements with subrecipients and other government agencies, including a penalty clause for non-compliance pursuant to 2 CFR §200.338 in all contracts and subrecipient agreements. Negotiate contract terms and ensure that all contracts include provisions required under CDBG-DR, including performance requirements and period of performance or date of completion. All contracts must adhere to cost principles outlined in 2 CFR §200.402-200.410. Assign a Contracting Officer to each contract to monitor scope and performance. All contracts using CDBG-DR funds, as well as a summary of all contracts including those procured by grantee, recipients, or subrecipients, must be posted to grantee’s comprehensive website. The status of all services or goods currently being procured by grantee must also be posted to grantee’s comprehensive CDBG-DR website.

9. Construction contracts: Work with applicable Program Operations staff to bond and insure work involving large construction contracts. Ensure compliance with Davis-Bacon.

10. Contract amendments: Work with Program Operations and Grants Management staff when contract amendments are required and ensure that all amendments are reasonable, necessary, and appropriate.


TASKS

1. Contracts reports: Complete HUD required contracts reporting, including: Section 3 reports; FFATA – Federal Funding Accountability and Transparency Act (any contract $25k or more); and Davis-Bacon reports.

2. Contract conclusion: When notified of work completion by the Program Operations team, verify that all contract clauses have been met before approving the closeout.

https://www.ecfr.gov/cgi-bin/retrieveECFR?gp=&SID=f3d0f025ad857c0d46aeab9de36b48a9&mc=true&n=pt2.1.200&r=PART&ty=HTML#se2.1.200_1338

https://www.ecfr.gov/cgi-bin/retrieveECFR?gp=&SID=f3d0f025ad857c0d46aeab9de36b48a9&mc=true&n=pt2.1.200&r=PART&ty=HTML#sg2.1.200_1401.sg12

https://www.ecfr.gov/cgi-bin/retrieveECFR?gp=&SID=f3d0f025ad857c0d46aeab9de36b48a9&mc=true&n=pt2.1.200&r=PART&ty=HTML#sg2.1.200_1401.sg12

https://www.hudexchange.info/resource/2640/davis-bacon-act-40-usc-3141-et-seq/



IT and Data Systems Note: Some grantees do not establish a separate IT function within the CDBG-DR team but rather rely upon and expand the existing technology department within the grantee organization.

ROLE Develop and maintain the technical systems which enable the flow of information within the CDBG-DR grantee, document program expenditures, and track program status.


Assess the needed system functions and architecture.

Make, buy, or adapt existing systems in order to achieve this functionality.

Update the systems as programs and needs change.

Manage the quality of the system data.

Assist with systems use, including production of reports.

Become knowledgeable of HUD’s data systems.

PRE-AWARD TASKS

1. System needs and potential options: In concert with the Grants Management and Program Operations staff, outline the likely types of system functions that will be needed. Inventory existing grantee IT systems and determine the potential for adapting those existing systems. Reach out to other CDBG-DR grantees to obtain input on existing systems and software packages.


1. IT approach and specifications: Once the beneficiary needs have been determined and general recovery programs have been designed, reach out to all functional areas to confirm and update the IT systems specifications. Once the IT and Data Systems team has a solid understanding of system needs, work with the Grants Management team to decide the information systems approach (modify existing systems, procure off-the-shelf, hire IT firm to program a custom system, hire staff to develop the system, etc.).

2. Staffing: In concert with the Grants Management staff and based on the chosen IT approach, determine level and types of grantee staffing needs for the systems function. If the grantee has chosen to contract out the IT function, it will still need existing technical staff to review and manage the work of these contractors. Work with Human Resources to develop job descriptions and hiring requisitions and assign, interview, and hire these staff.

3. IT contractor: If the grantee will purchase software or an IT firm, work with the Contracts staff to procure that firm.

4. Systems development: Program systems to track applications, interactions with beneficiaries, calculate awards, and interface with Federal reporting systems to obtain payments. Ensure that the system can integrate with grantee’s financial management systems and DRGR. The system design should be done in close coordination with the Grants Management, Financial Management, and Program Operations teams to verify that the system will effectively ensure that all HUD required information is captured and to outline how different users will access the system.



5. System security: Create security protocols for handling confidential data and Personally Identifiable Information (PII).

6. Data reporting: Develop related reporting functions that: track status of programs, projects, and applications; extract raw data to excel or CSV format for further analysis; can easily be updated and upgraded to accommodate changes to program design and/or to add new data elements; and enable easy reports and dashboards to track program progress and metrics.

7. Website: With the Communications team, adapt or develop a new CDBG-DR website sharing critical information with the public and partners.

OPERATIONS TASKS

1. Staff guidance: Develop, distribute, and train staff on procedures for data format and submission into the IT system. Provide guidance to applicable program staff regarding what data needs to be submitted on a monthly and quarterly basis and in what format data should be submitted.

2. Systems maintenance: Periodically monitor systems functions and identify when programmatic changes dictate IT or data changes. Complete upgrades and make enhancements to data and reporting systems as needed.

3. DRGR interface: Work with Financial Management staff to oversee DRGR and IT system interface. Assist the Finance team to set up and manage projects and activities in DRGR and enter progress and outcome metrics that need to be tracked for all proposed projects and activities.

4. Data management: Enter and, as needed, clean data received from SBA, FEMA, and insurance companies for duplication of benefits analysis.

5. Data quality: Develop and follow process for conducting quality assurance and quality control of all data elements.


TASKS

1. Analytic reports: Develop and distribute periodic status reports based on information in the IT system. Provide guidance to program staff on how to use data and reports.

2. QPR and other HUD reporting: Work with Financial Management and Monitoring and Compliance functions to develop forms and procedures for QPR reporting. Assist Compliance division to compile, write, and submit the reports.

https://www.hudexchange.info/onecpd/assets/File/DRGR-User-Manual-Section-6-Quarterly-Performance-Report.pdf



Training and TA Note: For some grantees, the training function is combined with human resources and it may be conducted under an existing department.

ROLE Provide process, regulatory, programmatic, and systems training to grantee staff, subrecipents, contractors, and beneficiaries.


Ensure that all CDBG-DR participants understand the regulations and requirements of the program and their responsibilities.

Help to address deficiencies in critical skills or knowledge.

Foster communication and shared understanding of roles across staff, functions, and partners.

Help beneficiaries and partners to effectively participate in the program.

PRE-AWARD TASKS

1. Preliminary training needs and resources: As the Grants Management and Program operations teams begin to make decisions about the program types and administrative plans, consider the types of possible training needs. Collect and assess existing training resources and communicate with other CDBG-DR grantees to understand their approach.


1. Training and TA needs assessment: Once the programs are determined and the staff hired, conduct an assessment of training needs. Identify the knowledge gaps: What do people need to know, do better, or do differently? What are the priorities for providing knowledge transfer?

2. Staffing: In concert with the Grants Management staff and based on the decision about whether the Training staff are separate or a part of the grantee’s existing Human Resources function, determine level and types of staffing needs. Work with Human Resources to develop job descriptions and hiring requisitions and assign, interview, and hire these staff.

3. Training and TA plan: Develop a plan and schedule for the initially identified training and TA needs. This schedule will be adapted and amended as program operations begin.

4. Kick-off training: Hold an initial training session for all recovery staff regarding the basic CDBG-DR requirements. If feasible, invite staff from other agencies and known subrecipients to attend. Repeat this session periodically during the first six months as new staff are hired, subrecipients, and contractors are hired and programs become operational.



OPERATIONS TASKS

1. Standing and repeated courses and TA: Develop a stable of basic courses that are taught over time due to staff turnover or program changes. These topics might include: program procedures and policies; Federal regulations including but not limited to Davis-Bacon, Uniform Relocation, Fair Housing, Environmental Review, duplication of benefits, PII confidentiality, conflict of interest, procurement, language access for LEP populations, and national objectives. Work with the Policy team to offer follow-up or interim TA between course deliveries. Update training materials and conduct training refreshers as program policies and procedures are updated. Grantees can use existing HUD CDBG-DR Training materials as a basis for developing training.

2. Continual needs assessment: Assess new and ongoing training and TA needs based on feedback from Grants Management, Policy, or Operations leaders; HUD monitoring concerns; or new program requirements or options.

3. Training material development: When a need is identified, develop audience-specific training materials. In developing the materials clarify the audiences for the class or TA and define the objectives. Determine the appropriate modality for providing training which may include: shadowing/mentoring, visits with other grantees, webinars, Workshops/classroom training sessions, conference calls, talk and text assistance, mailing lists, or job aides (fact sheets, implementation guides, toolkits, etc.). Adapt existing materials or protocols such as webinar slides or mentoring plans to meet objectives of knowledge sharing.

4. Implement and track: Carry out the training and technical assistance. Using performance metrics, pre- and post- assessments, or other tools, determine what worked, what did not, and how to improve knowledge transfer process in future.

5. Job aids: Create job aids for various functions and program staff to assist with implementation. In coordination with Policy and Planning and Program Operations Teams, develop checklists that ensure staff are following same set of processes.


TASKS

1. QPR and other HUD reporting: All training and technical assistance provided must be entered into DRGR Quarterly Progress Reports as part of grantee’s oversight responsibilities for CDBG-DR programs.

https://www.hudexchange.info/news/2016-cdbg-dr-webinar-series/

https://www.hudexchange.info/news/2016-cdbg-dr-webinar-series/

https://www.hudexchange.info/programs/drgr/



Compliance and Monitoring

ROLE Ensure that the grantee’s CDBG-DR recovery programs comply with all Federal rules and recommend improvements that enhance programmatic efficiency, effectiveness, and documented results.


Ensure ongoing compliance with Federal, State, and local regulations through the review of policies and procedures, applicant eligibility and award determinations, and program activity files.

Conduct regular self-monitoring and report results to Grants Management and Program Operations leaders.

Respond to external audit and HUD monitoring findings.

Identify and investigate potential fraud and refer cases, as appropriate, to the State Attorney General’s office or Federal Attorney’s office.

PRE-AWARD TASKS

1. Regulatory understanding: Coordinate with HUD staff to access start-up resources and understand basic compliance framework and monitoring process, including how CDBG-DR is similar to and different from CDBG.

2. Initial function approach: Reach out to other CDBG-DR grantees to understand how the monitoring function was organized and conducted. Consult with HUD on common monitoring findings and implementation issues and review HUD Monitoring Handbook for additional guidance on what program areas and topics HUD is likely to review during monitoring visits. Build these lessons into both the grantee’s chosen organizational structure and its program plans.


1. Staffing: In concert with the Grants Management staff and based on the chosen administrative model, determine level and types of monitoring staffing needs. Work with Human Resources to develop job descriptions and hiring requisitions and assign, interview, and hire these staff. The Compliance and Monitoring staff should be a distinct team working independently of staff involved in designing and carrying out programs. Grantees may have available internal auditing staff that can be assigned to this role.

2. Compliance and monitoring procedures: Work with the Policy and Planning team to develop and maintain detailed compliance and monitoring policies and procedures. At a minimum, ensure that the procedures cover: role and independence of the monitoring function; process for internal monitoring; timelines for monitoring; types of items reviewed during monitoring; and development, submission, and use of monitoring reports. If required by the CDBG-DR Federal Register notice, submit these procedures to HUD for approval.

3. Program tools: Create checklists and CDBG-DR requirement summaries to share with Program and Financial Management staff to assist them to comply. Develop checklists that will be used during self- monitoring and share those checklists with the staff charged with designing, implementing, and managing programs.


https://www.hudexchange.info/resource/290/hud-community-planning-and-development-monitoring-handbook-65092-rev7/



4. Subrecipient tools: Review all subrecipient agreements for completeness and inclusion of compliance clauses. Create file checklists for subrecipients to ensure appropriate program documentation is collected and preserved.

5. Staff training: Train all Compliance staff on the details of the CDBG-DR requirements and common monitoring issues, as well as effective monitoring techniques. Once these Monitoring staff are trained, deliver training to all other CDBG-DR recovery staff, other government agencies, and subrecipients covering compliance expectations and the internal monitoring approach.

OPERATIONS TASKS

1. Annual compliance and monitoring plan: At the beginning of each program year, develop and distribute the plan for self-monitoring during that year, including the timelines for program reviews. This plan should also address how the grantee intends to monitor contractors and subrecipients.

2. Internal self-monitoring: Conduct internal monitoring of all programs and functions including the work of all partner agencies (subrecipients, contractors, and other government agencies). Internal audits may consist of a combination of onsite monitoring and desk reviews. Use a risk-based approach to monitoring ensuring higher risk programs and partners are monitored more closely and frequently.

3. Monitoring reports: Prepare detailed reports from each self-monitoring activity, explaining what corrective actions are required. Meet with the applicable grantee staff to explain the issues and needed corrective actions. Submit summary reports to the Grants Management team. If trends emerge across programs or within a specific program over time, work with the Grants Management team to diagnose the issues and implement changes.

4. On-call or ongoing quality assessments: On an ongoing basis throughout the year, conduct quality assurance reviews of a selected sample of all program files where funds are disbursed to individuals and eligibility is determined. Conduct QA/QC of eligibility and award calculation decisions. Note that some grantees choose to have the Compliance staff review 100% of the determinations made by the Program Operations teams prior to allowing a beneficiary agreement to be signed. Along with the Policy and Planning team, be available to answer compliance questions as they arise during the Programs’ application intake and review process.

REPORTING, COMPLIANCE, MONITORING AND CLOSEOUT

TASKS

1. QPR and other HUD reporting: Work with Finance and Policy functions to develop forms and procedures for QPR reporting. Assist to compile, write, and submit the reports.

2. Recordkeeping: Manage the overall recordkeeping process and share standards and checklists with all functional teams, including subrecipients, contractors/subcontractors, recipients, and units of local government. Major categories of records that should be kept include: administrative, financial, project/activity specific documents, national objective compliance, subrecipient and contractor information, and other Federal requirements. Retain all records for at least 3 years following grant closeout or longer if required by local, State, and Federal regulations.

3. Financial audits: Review the required annual financial audits to determine if any significant issues were identified. If yes, work with Financial Management and Grants Management to make procedure and program corrections as needed.


https://www.hudexchange.info/programs/drgr/



4. HUD Monitoring: Assist the Program and Finance staff to prepare for external monitoring including HUD on-site and remote reviews and OIG audits. When preparing for external assessments, utilize HUD CDBG-DR monitoring exhibits to help ensure that staff are ready for a detailed review.

5. Fraud prevention: Investigate allegations of potential fraud, identify cases that may involve potential fraud, and when appropriate refer those cases to State Attorney General’s or Federal Attorney’s office.

6. Closeout procedures: Develop closeout CDBG-DR process for program, beneficiaries, projects, and activities pursuant to CPD-14-02 and other relevant HUD guidance or Federal Register notices.

https://portal.hud.gov/hudportal/HUD?src=/program_offices/administration/hudclips/handbooks/cpd/6509.2

https://www.hudexchange.info/resources/documents/Notice-CPD-14-02-Closeout-Instructions-for-CDBG-Program-Grants.pdf



Human Resources Note: Many grantees run their CDBG-DR human resources tasks via the agency’s existing HR department. This is an acceptable approach but be advised that the CDBG-DR hiring is often a rapid and significant workload and may require hiring additional HR professionals.

ROLE Recruit and retain a workforce capable of carrying out the CDBG-DR program.


Assist with the analysis of staffing needs and organizational structure.

Develop job descriptions and hiring requisitions.

Interview candidates and finalize job offers.

Orient new hires and ensure compliance with labor laws.

PRE-AWARD TASKS

1. Capacity assessment: Work with Grants Management staff to determine whether current staffing is adequate to carry out CDBG-DR programs in a timely and compliant manner or if additional staff need to be hired to implement program. See the Staffing Analysis Worksheet.


1. Organizational chart: Make recommendations to Grants Management regarding options for the recovery organizational structure and lines of communication.

2. Administrative approach: Advise the Grants Management staff on the most effective administrative approach (in-house staff, contractors, subrecipients, sister agencies, hybrid depending on activity type).

3. Staffing plan: Based on the final organization chart and planned administrative approach, work with Grants Management and Planning to determine staffing needs, including the number of positions, specific expertise required, and projection of duration of various staff positions. Based on this data, advise Grants Management on the most cost effective staffing models (e.g., new full time hires, staff augmentation with temporary workforce, contracted consultant services, subrecipients, or some combination of these models).

4. HUD Implementation Plan: Work with Grants Management to address HUD’s requirement that grantee’s implementation plan identify personnel required to be in place to perform the following functions:

a. Case management in proportion to applicant population; b. Program managers for housing, economic revitalization, and infrastructure programs; c. Personnel to carry out policy and planning tasks; d. Personnel to carry out procurement and contract management; e. Personnel to carry out environmental compliance activities and other applicable requirements; f. Personnel to carry out monitoring and quality assurance; g. Personnel to carry out data reporting; h. Personnel to carry out training activities; i. Personnel to carry out human resources; and j. Personnel to carry out financial management functions.




5. Job descriptions: Draft job descriptions for all new positions, in concert with other functional area staff. Work with Grants Management to establish functional divisions, lines of reporting, and authority.

6. Recruitment and hiring: Advertise for CDBG-DR program staff positions and recruit and interview staff. Hire or contract for the staff necessary to implement CDBG-DR program.

7. New staff training: Work with the Training team to conduct orientation for new hires.

OPERATIONS TASKS

1. Ongoing hiring: As needed, hire additional staff to replace turnover or address program expansion needs.

2. Section 3 hiring: Ensure that Section 3 plan is followed.

3. Conflict of interest: Require all staff engaged in CDBG-DR program to sign an annual conflict of interest disclosure and assurance form.

4. Performance review: Oversee the performance review process of CDBG-DR program staff.

5. Labor laws: Ensure compliance with applicable labor laws including overtime and Federal regulations related to prevailing wages and hiring low- and moderate-income populations.


TASKS

1. Staff exiting: As the CDBG-DR program winds down upon completion, manage the exit process for staff who will not be retained.



Communications

ROLE Serve as the hub and distribution resource for information communicated internally and between the grantee and the public, media, applicants, and communities.


Ensure that the media, public, applicants, and political leaders receive timely and easy to understand information about the program.

Develop and implement a communications plan.

Manage the public engagement process, being sure to include under-served communities.

Oversee the public hearings needed for the Action Plan.

PRE-AWARD TASKS

1. Interim communications approach: Work with the Grants Management team to develop a short-term communications approach to reassure persons, businesses, and communities affected by the disaster and help them to prepare for next steps.


1. Staffing: In concert with the Grants Management staff and based on the chosen approach to the communications function, determine level and types of staffing needs. Work with Human Resources to develop job descriptions and hiring requisitions and assign, interview, and hire these staff.

2. Communications plan: Develop a detailed communications plan that takes into account the specific needs of each stakeholder audience. The most critical are those communications plans developed to address the specific needs of potential applicants of the beneficiary-focused recovery programs (e.g., homeowners, renters, businesses). The plan should include the following elements:

a. Key audiences and stakeholders, including impacted local units of government and subrecipients. Describe their communications needs and interests.

b. Communications strategy, including preferred communications vehicles/delivery channels for each audience. Define timelines and the frequency of communications for each stakeholder type.

c. The plan to develop communications materials and content and conduct communications events to engage stakeholders in the communications process.

d. Measure effectiveness, including the need for changes or adjustments in communications messages and/or delivery methods.

3. Public engagement: Either as a part of the communications plan or as a separate process, develop a public engagement approach. Engage local community leaders, community based organizations, and impacted citizens and ensure awareness of, and obtain feedback on, ongoing and planned activities. Incorporate consistent messaging that focuses on transparency and engages the various stakeholders to become part of the overall process. Continue this engagement throughout the operations phase.

4. Action Plan: Advertise the availability of the Action Plan and Substantial Amendments to the Action Plan to solicit feedback on the plan(s) from the public. Organize required Action Plan and Substantial Action Plan Amendment public hearings. Provide interpreters as needed for public meetings.



5. HUD certification: With or on behalf of the Grants Management team, certify to the grantee’s capacity to ensure timely communication to all disaster recovery program applicants regarding their status at all phases.

6. Website: With the IT team, develop and maintain a public facing website that provides clear, concise, and up-to-date information to applicants, interested citizens, media, and government agencies regarding: details of all contracts; ongoing procurement policies; public facing program descriptions, applications, and appeal processes; Action Plan and all amendments; and all Quarterly Performance Reports. Work with Data Systems and Reporting Team to determine what data and metrics should be shared on public facing website.

7. Program policies and procedures: Working with the Program Operations staff, incorporate within the activity policies and procedures the methods for communication to applicants (e.g., website, telephone, case managers, letters). Ensure accessibility and privacy of all individualized information for all applicants. Define the frequency of applicant status updates and describe the unit and/or personnel responsible for these communications.

8. Language Access Plan: Work with the Policy staff on the development of the Language Access Plan including the best means for engagement and outreach to Limited English Proficient (LEP) individuals and households based on the language access needs of potential applicants in areas most impacted by the disaster.

OPERATIONS TASKS

1. Continued outreach and citizen engagement: Throughout the life of the CDBG-DR award, facilitate effective community meetings and utilize a variety of communication methods to reach citizens, stakeholders, and program partners.

2. Media relations: Serve as point of contact for all media inquiries about program. Write and publish press releases about the program.

3. Program summaries: Periodically develop, post, and share summaries of recovery program status with the public. In addition, share your stories with HUD.


TASKS

1. Freedom of Information Act: Serve as the grantee’s primary point of contact for the receipt of Freedom of Information Act requests for materials. Work with other functions to compile and distribute appropriate, non-PII information.

2. Status reporting: Periodically provide updates to Grants Management staff on the status of outreach, engagement, and media efforts.

https://www.hudexchange.info/programs/cdbg/project-profiles/

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