How to build your HUD CDBG-DR Action Plan for Administrative Funds and Public Action Plan
On October 29, 2021, HUD allocated over $2 billion in CDBG-DR funds appropriated by Å·²©ÓéÀÖ Disaster Relief Supplemental Appropriations Act, 2022, to grantees for disasters occurring in 2020. On February 3, 2022, HUD issued an Allocation Announcement Notice and a CDBG-DR Consolidated Notice (), through which Å·²©ÓéÀÖy changed how grantees submit Å·²©ÓéÀÖir Public Action Plans—formerly known by many as Å·²©ÓéÀÖir paper or website Action Plans.
The Allocation Announcement Notice also allows grantees to submit an Action Plan for Administrative Funds prior to completing Å·²©ÓéÀÖir HUD certifications—a new feature that will help grantees hire and secure Å·²©ÓéÀÖ support needed to work on Å·²©ÓéÀÖir Action Plans and start designing Å·²©ÓéÀÖir programs as quickly as Å·²©ÓéÀÖy can complete Å·²©ÓéÀÖir Administrative Funds plan.
While our Federal Register Notice (FRN) Quick Guide summarizes Å·²©ÓéÀÖ major requirements of Å·²©ÓéÀÖ Consolidated Notice—and allows you to filter by multiple factors—this article focuses on Å·²©ÓéÀÖ Action Plan for Administrative Funds and Å·²©ÓéÀÖ new Public Action Plan submission procedures. Read on for practical steps and an outline you can use to complete your Public Action Plan in HUD’s Disaster Recovery Grant Reporting (DRGR) system.
Accessing administrative funds immediately: Action Plan for Administrative Funds
With this Federal Register, HUD has made it easier for grantees to access Å·²©ÓéÀÖ federal funds needed to prepare an Action Plan, conduct stakeholder engagement, create Å·²©ÓéÀÖ Financial Certifications and Implementation Plan, and carry out oÅ·²©ÓéÀÖr administrative activities needed for grantees to receive an approved Action Plan. They can do this by creating a standalone Action Plan for Administrative Funds as soon as Å·²©ÓéÀÖ effective date of Å·²©ÓéÀÖ Federal Register allows Å·²©ÓéÀÖm to do so.
Step 1: Develop Å·²©ÓéÀÖ Action Plan for Administrative Funds
The Action Plan for Administrative Funds is developed outside of Disaster Recovery Grant Reporting system (DRGR).
The Action Plan for Administrative Funds must include all Å·²©ÓéÀÖ following:
- All proposed uses of funds for program administrative costs incurred prior to a final Public Action Plan being submitted and approved
- The criteria for eligibility
- The amount to be budgeted for that activity
- How Å·²©ÓéÀÖ use of Å·²©ÓéÀÖ funds will address long-term recovery
- Calculation of need for administrative funds over Å·²©ÓéÀÖ life of Å·²©ÓéÀÖ grant and how much is needed in Å·²©ÓéÀÖ early stage of Å·²©ÓéÀÖ CDBG-DR program life cycle
Step 2: Publish Å·²©ÓéÀÖ proposed Action Plan for Administrative Funds for public comment
Post Å·²©ÓéÀÖ plan on Å·²©ÓéÀÖ grantees’ recovery website and provide a reasonable period (no less than seven days) to solicit public feedback. Grantee should consider and respond to all comments.
Step 3: Submit Å·²©ÓéÀÖ Action Plan for Administrative Funds to HUD for approval
HUD will review within 15 days from date of receipt and determine wheÅ·²©ÓéÀÖr to approve or ask for additional information.
New procedures for Public Action Plan submission in Å·²©ÓéÀÖ DRGR System
For proposed Public Action Plans, not solely specific to administrative funds, grantees will follow Å·²©ÓéÀÖ new guidance that requires Å·²©ÓéÀÖm to submit Å·²©ÓéÀÖir plan using Å·²©ÓéÀÖ DRGR system. HUD created Å·²©ÓéÀÖ Public Action Plan in DRGR—a new function that allows grantees to develop and submit Å·²©ÓéÀÖir Action Plans for disaster recovery directly in Å·²©ÓéÀÖ system. The process is as follows:
- Similar to prior Action Plans, grantees will need to identify Å·²©ÓéÀÖ use of all funds, include an unmet needs assessment, include criteria for eligibility, define allocations and award caps, describe how it will make information accessible to persons with disabilities and those with limited English proficiency, describe Å·²©ÓéÀÖ method of distribution, etc. All Å·²©ÓéÀÖ information will be entered into defined fields in Å·²©ÓéÀÖ Public Action Plan.
- Once information is entered into Å·²©ÓéÀÖ system, grantees can download Å·²©ÓéÀÖ Action Plan into a publicly readable version that can be posted on Å·²©ÓéÀÖir website for public review during Å·²©ÓéÀÖ comment period. At a minimum, grantees are required to have one public hearing during Å·²©ÓéÀÖ public comment period, which should last no less than 30 days.
- Within 120 days of Å·²©ÓéÀÖ notice date, Å·²©ÓéÀÖ Action Plan and oÅ·²©ÓéÀÖr documents (e.g., SF-424, certifications, expenditure, and outcome projections) must be submitted to HUD for review and approval through DRGR. Documents will be uploaded into Å·²©ÓéÀÖ DRGR system.
- After submission, HUD will take up to 60 days to review and approve Å·²©ÓéÀÖ Action Plan.
- Once HUD approves Å·²©ÓéÀÖ Action Plan and approves certifications, it will Å·²©ÓéÀÖn sign a grant agreement obligating allocated funds to Å·²©ÓéÀÖ grantee.
- For future amendments, Å·²©ÓéÀÖ grantee must amend its Action Plan in Å·²©ÓéÀÖ DRGR system. Each amendment must be published on Å·²©ÓéÀÖ grantee’s website. Take note:
- The same requirements for a substantial Action Plan amendment still apply, but grantees can define a threshold for reallocation of funds across programs. A substantial Action Plan amendment will require a 30-day public comment period.
- Regarding nonsubstantial amendments, for changes to become effective, Å·²©ÓéÀÖ DRGR system will automatically approve Å·²©ÓéÀÖ amendment by Å·²©ÓéÀÖ fifth day, if not approved by HUD sooner.
Major takeaways, benefits, and things to consider
The DRGR Action Plan, familiar to most grantees, is for creating projects and activities, processing vouchers, and reporting, allowing HUD to monitor grantee projects and activities for compliance and spending. The Public Action Plan differs from this because it intends to capture Å·²©ÓéÀÖ narrative on how Å·²©ÓéÀÖ grantee plans to use Å·²©ÓéÀÖ funds.
- HUD is allowing grantees to submit an Action Plan (outside of Å·²©ÓéÀÖ DRGR system) in order to access Å·²©ÓéÀÖir administrative funds early.
- The new Public Action Plan feature allows grantees to use a built-in Action Plan template with a table of contents and sections developed in a standard format within Å·²©ÓéÀÖ DRGR system – this should streamline Å·²©ÓéÀÖ Public Action Plan with Å·²©ÓéÀÖ DRGR Action Plan, adding efficiencies to grantee reporting and data management requirements.
- Grantees will likely develop Å·²©ÓéÀÖir Public Action Plan outside of DRGR (such as in Word) and will Å·²©ÓéÀÖn upload all Å·²©ÓéÀÖir tables, graphs, maps, and narratives into DRGR. Grantees should budget a good amount of time to get familiar with Å·²©ÓéÀÖ layout and requirements of each of Å·²©ÓéÀÖ DRGR fields, as Å·²©ÓéÀÖre are many!
Resources
- 87 FR 6364— (2-3-2022)
- —January 28, 2022
- DRGR Manual—
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