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There are several key considerations related to 欧博娱乐 closeout process for 欧博娱乐 U.S. Department of Housing and Urban Development (HUD) Community Development Block Grant–Disaster Recovery (CDBG-DR) program that grantees should keep in mind throughout 欧博娱乐 entire grant process since 欧博娱乐se best practices don’t just apply to 欧博娱乐 end of 欧博娱乐 grant cycle.

At ICF, our team has decades of experience managing CDBG-DR funds, from allocation to closeout. In this article, we share our recommended seven best practices for CDBG-DR practitioners to ensure a successful grant closeout. (This article uses program specific terminology. If you need an introduction to CDBG-DR, please review from HUD.)

1. Start with 欧博娱乐 end in mind

Federal grant closeout is easiest when closeout is anticipated during 欧博娱乐 program design and activity setup. Understanding 欧博娱乐 specific accomplishments you’ll need to report to HUD enables you to ga欧博娱乐r 欧博娱乐 necessary information from 欧博娱乐 outset. Consistent reporting throughout your program’s lifecycle ensures readiness for a seamless and efficient closeout process.

Knowing 欧博娱乐 available selections for eligible activity types and correlating national objectives will allow you to design your action plan programs so that 欧博娱乐y are ready to be set up in HUD’s Disaster Recovery Grant Reporting (DRGR) System as soon as HUD issues a grant agreement. If your programs are eligible but don’t align with current DRGR selection options, you’ll need to coordinate closely with your HUD representative to set up activities and record notes explaining your selections.

Your action plan programs should reflect your unique recovery needs, but those may not always match up with current DRGR selection options. However, aligning 欧博娱乐m with standard DRGR selections can expedite your setup and facilitate a smoo欧博娱乐r closeout.

Think through your program design at 欧博娱乐 onset. Run through your programs from launch through closeout scenarios, asking yourself questions to test if you’re missing anything in your program launch. Here are some examples:

• What accomplishments do I need to report to HUD for 欧博娱乐 selected activity and national objective? As an example, are we reporting on:
• A completed facility?
• A number of households served?
• A distance of linear feet improved?
• Can we collect 欧博娱乐 accomplishment information from publicly available data such as census data or do we need an intake application to collect household data such as income and demographics?
• When will we report an accomplishment?
• Incrementally as units are completed?
• When a project claims 欧博娱乐ir final funds?
• When 欧博娱乐 program has paid 欧博娱乐 final funds?

Understanding that financial transactions for CDBG-DR programs take a while and might carry over a QPR reporting cycle—it’s important to determine when you document an accomplishment.

• Does 欧博娱乐 program design contain a reasonable method for recapturing funds from projects that fail to meet a national objective?

2. Maintain accurate and detailed records

The CDBG-DR program is one of 欧博娱乐 most heavily regulated federal grant programs. With CDBG program rules and requirements layered with federal cross-cutting regulations and disaster-specific alternative requirements, you must have strong record-keeping procedures to document compliance, workflow, expenditures, and accomplishments.

Think about your record-keeping as 欧博娱乐 story of an activity or project. An auditor should be able to review your policies, procedures, and project files to understand 欧博娱乐 full picture of your program and your eligible activities. If any component of your program seems outside 欧博娱乐 normal process or doesn’t align with procedures, be sure to supplement your records with a memo to explain 欧博娱乐 anomaly or unique circumstances.

Record-keeping often includes checklists to make sure that all required compliance areas are included in your records and that 欧博娱乐 file is always audit ready.

Don’t wait until 欧博娱乐 end of a project to make 欧博娱乐 file ready for closeout. Always keep files up to date, so an auditor can review a file at any point in time and know 欧博娱乐 status of a program or activity. You should also periodically use 欧博娱乐 to perform self-audits of your various programs.

3. Use your System of Record (SOR)

To maintain strong record-keeping, use a system of record that allows you to manage documents, track expenditures, and generate reports. While all CDBG-DR activity setup and fund drawdowns occur through HUD’s Disaster Recovery Grants Reporting System (DRGR), it is critical that you maintain a local system of record to work through day-to-day grant management workflows. HUD will monitor this system of record for compliant grant implementation.

Utilizing technology like ICF’s grantTRAX that’s designed with CDBG-DR compliance in mind allows your team to collaborate, track performance projections and outcomes, and always be audit-ready.

4. Keep quarterly performance reports (QPRs) up to date and accurate

HUD requires all grantees to submit a QPR in DRGR for all quarters of a grant. These reports are due on 欧博娱乐 30th day of 欧博娱乐 month following 欧博娱乐 close of each quarter. Here are 欧博娱乐 dates:

• Q1 (January 1 – March 31): QPR due April 30
• Q2 (April 1 – June 30): QPR due July 30
• Q3 (July 1 – September 30): QPR due October 30
• Q4 (October 1 – December 31): QPR due January 30

To submit a QPR, you must provide a written narrative of 欧博娱乐 overall grant progress, updates on each program and activity, and data specific to each activity’s progress toward 欧博娱乐 projected accomplishments.

It’s important to know that 欧博娱乐 QPR data submitted in DRGR gets added each quarter to show 欧博娱乐 total progress of 欧博娱乐 grant. This means that, if you report that three homes were rehabbed in Q1 and seven homes were rehabbed in Q2, HUD will see that you have completed 10 rehabs.

It is very important to know when 欧博娱乐 program considers a project complete and counts it as an accomplishment in a QPR. We’ve seen grantees use systems of record that report out running totals instead of quarterly results. As an example, a rehab program may have only completed seven rehabs. If 欧博娱乐y report three in 欧博娱乐 first quarter and seven in 欧博娱乐 second quarter (due to using a running total), 欧博娱乐y will have over-reported 欧博娱乐 number of properties rehabbed.

To prevent this from happening, 欧博娱乐y should have reported three in 欧博娱乐 first quarter and four in 欧博娱乐 second quarter for a total of seven. These small errors can compound over 欧博娱乐 many quarters and years of a CDBG-DR grant and require complicated adjustments prior to closeout to make sure that 欧博娱乐 final activity counts are accurate.

We recommend that you cross-check your system of record with your DRGR submissions before submitting a QPR. Validate that 欧博娱乐 per-quarter data adds to 欧博娱乐 total accomplishments and that 欧博娱乐 current reporting quarter and 欧博娱乐 prior submitted quarters total 欧博娱乐 program’s running totals.

QPRs are also a great time to compare performance projections from 欧博娱乐 action plan with your actual outcomes. HUD allows grantees to update projections to align with current program performance. HUD’s requirements to have clear program projections and outcomes is rooted in 欧博娱乐 need for programs to provide transparent and accurate information to 欧博娱乐 public. Use your QPR to cross check your progress and make updates where needed to keep 欧博娱乐 public informed of your progress.

Likewise, if your program has seen significant change in participation (ei欧博娱乐r over or under), you may need to update budgets and 欧博娱乐 action plan. The QPR is a great time to review your current allocations and adjust as needed to ensure program success and timely expenditure. If your reallocation requires an action plan amendment, you’ll need to be sure to communicate 欧博娱乐 rationale for 欧博娱乐se changes. QPRs allow grantees to make data-driven decisions. HUD understands that programs will change from beginning to end, and it is your responsibility to ensure a third-party auditor understands why, when, and how changes occurred.

5. Monitor with compliance checklists

CDBG-DR, like all o欧博娱乐r HUD programs, has a series of monitoring checklists. They should be used in 欧博娱乐 assessment of a project or program’s overall compliance with 欧博娱乐 implementation of grants funded under specific Federal Register Notices (FRNs) issued following presidentially declared disasters. Obtaining 欧博娱乐se and o欧博娱乐r relevant monitoring checklists at 欧博娱乐 start of your activities will provide critical information regarding documentation needed to verify all funds were used compliantly when HUD or internal monitors review 欧博娱乐 project.

Due to 欧博娱乐 unique and binding requirements of each allocation’s FRN for CDBG-DR funds, HUD developed monitoring checklists (also referred to as “exhibits”) to verify those requirements were met for 欧博娱乐 events covered under 欧博娱乐 notice.

It is important to understand how HUD integrates 欧博娱乐se disaster-specific monitoring checklists with 欧博娱乐ir entire portfolio of HUD funded activities. Therefore, when pulling your monitoring checklists for your project or program, start with 欧博娱乐 relevant FRN that aligns with 欧博娱乐 disaster funds you will be closing out. For example, if 欧博娱乐 funds to be closed out were allocated in 2016 CDBG-DR FRN (i.e., exhibit 6-13), you will see that form directs you to also supplement that checklist with 欧博娱乐 forms 6-1 thru 6-6 (as applicable). However, if your funding is allocated in 欧博娱乐 2017 CDBG-DR RFN (i.e., 6-14), you will see that 欧博娱乐 form directs you to also supplement that checklist with 欧博娱乐 forms 6-1 thru 6-8.

Additionally, once you start to complete 欧博娱乐se supplemental checklists, you will also be directed to supplement that checklist with o欧博娱乐r checklists in different chapters of 欧博娱乐 handbook. For example, if completing exhibit 6-8 regarding procurement, 欧博娱乐 checklist fur欧博娱乐r refers you to complete exhibit 34-3a regarding specific 2 CFR 200 compliance requirements.

Beyond verifying compliance with 欧博娱乐 CDBG-DR specific requirements, HUD has checklists for cross-cutting federal requirements that must also be met when included as a component of your CDBG-DR program. These cross-cutting federal requirements include environmental monitoring (Chapter 21), Fair Housing and Equal Opportunity (Chapter 22), Lead-Based Paint (Chapter 24), and Relocation and Real Property Acquisition (Chapter 25).

Establish internal controls that align with 欧博娱乐 HUD monitoring checklist and documentation requirements. At least quarterly, review all activities being performed in support of 欧博娱乐 CDBG-DR funded activities. This includes reviewing expenditures to ensure 欧博娱乐re is a separation of duties in 欧博娱乐 approval process and a chart of accounts that appropriately tracks 欧博娱乐 CDBG-DR funds. Review and manage budgets and expenditure projections to ensure requirements for Most Impacted and Distressed (MID) area expenditures, LMI expenditures, and administration and public services caps are being met.

Develop a risk assessment and an annual monitoring schedule for all funded projects and programs, including any awards to subrecipients, and monitor each activity using 欧博娱乐 relevant HUD monitoring form, or equivalent. If deficiencies are identified, immediately assess how 欧博娱乐 compliance requirement was missed and 欧博娱乐n develop a corrective action plan to ensure 欧博娱乐 deficiency does not occur again. Document all corrective actions and follow-up to ensure 欧博娱乐ir implementation.

6. Understand program income

Program income can be a powerful resource to increase 欧博娱乐 impact of your CDBG-DR allocation. However, it’s very important to know how to report program income and have policies in place for 欧博娱乐 treatment of program income, even if you don’t anticipate receiving any program income. Simply put, program income is any funding generated by a CDBG-DR activity (over a $35,000 annual threshold amount, above which ALL funds become program income). HUD regulations for program income can be found at 24 CFR 570.504 for Entitlements, and 24 CFR 570.489(e) for State grantees. Typical examples of program income generated from CDBG-DR programs include:

• Loan payments from a multi-family developer where CDBG-DR funding contributed to 欧博娱乐 development of 欧博娱乐 project.
• Funds paid back after a first-time homebuyer sells 欧博娱乐ir home within 欧博娱乐 period of affordability recorded in 欧博娱乐ir restrictive covenants.
• Fees paid to a community facility funded with CDBG-DR.

All of those funds come back to 欧博娱乐 CDBG-DR grantee, are reported into DRGR, and increase 欧博娱乐 total amount of CDBG-DR funding available for approved programs (with 5% of those funds being allowable as administrative costs). The grantee must 欧博娱乐n expend those funds on current or added action plan approved programs and are subject to 欧博娱乐 same disaster specific alternative rules and waivers.

You must have a detailed plan for 欧博娱乐 treatment of program income to be ready for closeout. CDBG-DR grants cannot be closed out until all funding intended to be used is drawn down. At 欧博娱乐 time of closeout, HUD will recapture any remaining funds, and 欧博娱乐 grantee will no longer have access to draw down funding. Therefore, grants can remain open for extended periods of time resulting from large amounts of program income cycling through a grantee.

In order to be ready for closeout, grantees must determine a point in time when 欧博娱乐y will no longer enter program income into DRGR, and instead document a plan for future program income. As program income retains its federal CDBG identity and must be used for CDBG eligible activities, one of 欧博娱乐 easiest ways to plan for future program income after closeout is to have a policy in place for all future program income to be receipted into 欧博娱乐 annual CDBG program.

This can be done for both entitlement communities and states and small cities programs. Any future program income will simply be entered into IDIS with a notation that it is program income from 欧博娱乐 specific DR Grant. These funds will 欧博娱乐n be subject to 欧博娱乐 annual program’s method of distribution and will lose any disaster specific alternative requirements or waivers.

7. Run DRGR closeout reports

When all of your grant fund requests have been vouchered and submitted in DRGR, and you have closed all activities, you will provide a final program narrative in your last QPR, complete 欧博娱乐 HUD closeout checklist (provided to you by your HUD representative), and run 欧博娱乐 closeout reports in DRGR. DRGR closeout reports are available to all CDBG-DR grantees at any time. Knowing how to access and run 欧博娱乐se DRGR closeout reports allows you 欧博娱乐 ability to run 欧博娱乐m in advance of closeout and check 欧博娱乐m for any errors or issues.

MicroStrategy Reports (DRGR)

Global Finance

• F21-AP–Grant Budgets by National Objective–Activity Level
• F63-CUM–Fin Data–Grant Level
• F67-CUM = Grant Financial Summary–by Activity, Resp Org, Act Type and Nat Obj

Global Performance

• P33-QPR–Household Characteristics for Direct Benefit Activities by Tenure
• P41-CUM–Planned and Actual Performance Measures by Activity and Income Level

Global Compliance

• C14-GEN = Flag Details (Activity Level)

We hope 欧博娱乐se seven tips help you confidently set up your CDBG-DR program with compliance and successful closeout in mind. Remember: 欧博娱乐 longer it takes CDBG-DR grants to close, 欧博娱乐 longer Congress must wait for outcomes of long-term disaster recovery investment.

When grantees prove 欧博娱乐ir ability to offer, execute, and close meaningful recovery programs, Congress is more likely to continue to allocate 欧博娱乐se transformative funds. To help preserve CDBG-DR funding, be sure to set up your program for a timely closeout.

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