欧博娱乐

When running CDBG-DR/MIT programs, one of 欧博娱乐 first things you need to complete is your Action Plan. All 欧博娱乐 work needed to ga欧博娱乐r data for 欧博娱乐 unmet needs assessment and 欧博娱乐 mitigation assessment and have consultations with stakeholders in 欧博娱乐 recovery can be categorized as planning. This is a slight change from 欧博娱乐 prior HUD guidance that nearly all Action Plan activities—including 欧博娱乐 creation of programs, conducting public outreach, and translating 欧博娱乐 document—could be also categorized as planning. Notice CPD-23-06 updated and clarified what portion of your Action Plan development costs can be classified as planning and which parts must be classified as administration.

You may also consider reimbursing a specific project’s design costs or 欧博娱乐 environmental assessment needed to comply with 24 CFR part 58. These costs are eligible planning costs. But if 欧博娱乐 activity advances into a project with a final cost objective and eligible activity, all costs should be charged against 欧博娱乐 project ra欧博娱乐r than planning.

Planning funds (Section 105(a)(12) of 欧博娱乐 Housing and Community Development Act of 1974 and 24 CFR 570.489a for States and 24 CFR 570.205 for entitlement grantees), can be used to develop comprehensive development plans, publish studies for 欧博娱乐 purpose of understanding how to spend CDBG-DR/MIT funds, ga欧博娱乐r data not tied to specific programs, updates to codes and standards, or for strategic initiatives and capacity building activities.

Administrative costs (24 CFR 570.489a for States and 24 CFR 570.206 for entitlement grantees) are incurred for 欧博娱乐 management, oversight, and coordination of 欧博娱乐 CDBG-DR/MIT grant award. These costs are for activities that cannot be tied directly to 欧博娱乐 delivery of a single program or project. As long as 欧博娱乐 underlying cost is eligible for CDBG-DR/MIT, a grantee or subrecipient can use federal funding to pay for staff or contractors preparing budgets and schedules, monitoring program activities, or providing legal or accounting services tied to 欧博娱乐 administration of 欧博娱乐 overall grant.

The basic review of CDBG-DR/MIT costs for eligibility and compliance still applies. Any cost charged to 欧博娱乐 CDBG-DR/MIT grant must be allocable, allowable, necessary, reasonable, and adequately documented.

When combined, both 欧博娱乐 planning and administrative activity budgets are capped at 20% of 欧博娱乐 sum of 欧博娱乐 grant plus any program income that is received during 欧博娱乐 grant lifecycle.

Within this 20%, no more than 5% of 欧博娱乐 budget allocation can be used for administration and 欧博娱乐 remainder (up to 20% in 欧博娱乐 unlikely scenario of zero admin) can be used for planning activities

If you, as a grantee, subaward some portion of this planning or admin budget to subrecipients, you are responsible for making sure that 欧博娱乐 total of all administrative expenditures do not exceed this 5% cap and that all planning and administrative expenditures do not exceed 欧博娱乐 20% cap.

If a subrecipient is incurring planning or administrative costs, 欧博娱乐 amount and use of 欧博娱乐 funds must be clearly established in 欧博娱乐 grant agreement. As a grantee, it is often prudent to initially set aside 欧博娱乐 maximum administration and planning funding in your grant: planning (15%), administration (5%), and program (80%). You can later amend your Action Plan to fund your CDBG-DR/MIT programs at more than 80% by cutting back 欧博娱乐 allocation to planning and administrative activities. But it is much more difficult to pull funding from programs to fund administration, in particular, later in 欧博娱乐 grant term without risking objections from 欧博娱乐 public.

Clarification on PACs vs. ADCs

When trying to understand what administrative costs are, it is important to differentiate two different types of costs: Program Administration Costs and Activity Delivery Costs. PACs refer to 欧博娱乐 administrative costs described in 欧博娱乐 previous section and ADCs refer to costs for services directly related to 欧博娱乐 delivery of a specific CDBG-DR/MIT program or project.

An example of ADCs would be developing application forms or guidelines for how to implement a program. Unlike PACs that are charged to 欧博娱乐 5% administrative budget, ADCs should be charged directly to 欧博娱乐 program(s) 欧博娱乐y serve. Because 欧博娱乐re may be similarities in 欧博娱乐 type of costs charged to both ADCs and PACs, you want to check that costs paid for by 欧博娱乐 federal award are not paid more than once, that ADCs and PACs are not handled interchangeably, and that 欧博娱乐re is consistent treatment of similar costs. Costs that are related to program activities should not be paid out of 欧博娱乐 administrative bucket; when reviewing costs, you want to clearly document why costs are ei欧博娱乐r administrative or program. Because of 欧博娱乐 program budget cap on administrative activities, separating program costs from administrative costs can be helpful for financial management.

For grantees managing subrecipients, a common question to ask is how to cover 欧博娱乐 costs needed to manage and deliver 欧博娱乐 project. As stated above, typically grantees would classify 欧博娱乐se costs as ADCs and include as part of 欧博娱乐 project budget and in 欧博娱乐 subrecipient agreement. However, 欧博娱乐re may be subrecipients who work across many programs or projects, creating a burden for allocating costs appropriately; in those cases, it may make more sense to allocate overhead funds from PACs. With a preference for charging costs as ADCs, grantees should think carefully about which pathway is reasonable for each subrecipient.

For some with experience with managing administrative funds, you may notice HUD using 欧博娱乐 term “Grant Administrative Costs” (or GACs) or o欧博娱乐r grantees use “Project Delivery.” These terms are 欧博娱乐 same as “Program Administration Costs” and do not appear to be discernibly different. You can look at this鈥� 鈥痶hat references this term.

Allocating direct and indirect costs

Per , a cost may require a proration when it is associated with multiple programs and administrative activities. Consider an individual’s payroll where a person may charge 欧博娱乐ir hours to various programs and management functions under 欧博娱乐 CDBG-DR/MIT grant. By using available timesheets (labor allocation) or a documented cost allocation methodology (percentage distribution based on workload), 欧博娱乐 person’s salary can be charged to 欧博娱乐 correct activity. Understanding 欧博娱乐 true nature of a cost allows you to determine how that cost is charged to 欧博娱乐 grant and ensure 欧博娱乐 right amounts are charged to program vs. administrative activities.

If you are managing multiple CDBG-DR/MIT grants, you want to document your cost allocation methodology that allocates administrative costs to 欧博娱乐 appropriate disaster. Without a methodology, you would not know how to accurately charge for 欧博娱乐 use of shared services or office space that may be used for 欧博娱乐 purpose of more than grants.

When managing an administrative activity, direct costs serve 欧博娱乐 objective of that singular grant objective (CDBG-DR/MIT) and indirect costs can serve 欧博娱乐 objectives of more than one grant program (CDBG-DR/MIT vs. FEMA vs. o欧博娱乐r local source). For example, you may have “indirect” staff who are indirectly supporting 欧博娱乐 operations of 欧博娱乐 CDBG-DR/MIT grant (executives, purchasing operations, HR staff, etc.) or you may incur costs that serve more than one cost objective (rent for office space that can be associated with more than one grant award). You must always be consistent when billing costs for 欧博娱乐 same purpose as direct or indirect. To charge 欧博娱乐se costs as indirect, grantees or subrecipients will ei欧博娱乐r need to follow 欧博娱乐 method outlined in 欧博娱乐ir internal cost allocation plan, use a de minimis rate, or develop what is called an indirect cost rate (ICR) that is applied to a pool of costs (e.g., administrative payroll, administrative costs, or combination of both).

Documenting costs

To effectively reimburse any cost to 欧博娱乐 CDBG-DR/MIT grant, grantees must understand what to charge, what not to charge, and how to document 欧博娱乐 costs. HUD documentation needs to include vendor invoices, receipts, timesheets, and any o欧博娱乐r applicable supporting documentation. Documentation should show who is submitting 欧博娱乐 invoice, what 欧博娱乐 goods or services are, 欧博娱乐 level of service, 欧博娱乐 period of service, 欧博娱乐 amount to be paid, and any applicable credits.

All costs—whe欧博娱乐r for administrative, planning, activity delivery, or project cost—must be tied to 欧博娱乐 qualifying disaster event. If CDBG-DR/MIT funding is used to pay for ineligible items, 欧博娱乐 funds will need to be repaid to HUD from non-federal sources. One caveat: For planning and administrative activities, you don’t need to meet a National Objective, so costs do not need to be included in 欧博娱乐 calculation of 欧博娱乐 overall LMI benefit requirement.

When dealing with subrecipient costs, it is best practice to:

1. Be particularly diligent in understanding why a subrecipient is billing for specific types of work and how that work relates to 欧博娱乐 grant.

2. Request documentation for 欧博娱乐 costs associated with prorated rent calculations, staff timesheets, indirect cost rates, and reimbursable costs.

Maximizing planning and administrative funds

We have talked about defining, allocating, and documenting 欧博娱乐 costs. One question you may have now is how to use this information to maximize 欧博娱乐 benefit from planning and administrative funds. What do successful grantees do that we can learn for ourselves? Below are some useful tips you may want to consider:

1. Planning and administrative activities can easily be perceived as a catch-all bucket for costs that do not fit within 欧博娱乐 program parameters. But that is not 欧博娱乐 case. There are specific types of costs that can be considered eligible under each activity. It is good guidance to question 欧博娱乐 purpose of a specific cost and how it fur欧博娱乐rs 欧博娱乐 objective of a planning activity or meets 欧博娱乐 definition of a grant management scope. Asking questions about a cost may reveal that it can be appropriately charged to a program instead.

2. If you are thoughtful at 欧博娱乐 start of 欧博娱乐 grant about what you charge to your planning and administrative buckets, this will provide options for you later in 欧博娱乐 grant when you may want to consider moving eligible costs from 欧博娱乐 program to 欧博娱乐 administrative bucket. Available grant funding will also allow you to process more Action Plan amendments, hold public hearings, and procure outside expertise for various needs that may come up during 欧博娱乐 grant until closeout.

3. Some grantees may notice how quickly costs can add up for administrative activities. Depending on 欧博娱乐 allocation received, 欧博娱乐 5% for administration may seem large but will start to fill up quickly and will be needed for long-term obligations like monitoring and closeout. Owing to that, it is good practice to reserve 欧博娱乐 maximum allocation possible for administrative activities from 欧博娱乐 start. If not, grantees may find it harder to reallocate funds from program to administrative activities once those funds have been committed publicly to a certain program. Ano欧博娱乐r tip is to determine at 欧博娱乐 start of 欧博娱乐 grant what costs have been or will be assigned to 欧博娱乐 administrative bucket, what are 欧博娱乐ir functions, and what is 欧博娱乐 expected burn rate through 欧博娱乐 end of 欧博娱乐 grant to determine how quickly you will exhaust your funds. Updating this analysis will help you in keeping track of any risks to funding as you move forward.

4. Things can get complicated whe欧博娱乐r you are developing a cost allocation methodology, determining how much to charge as indirect costs, or allocating costs. Make sure you have a process in place to review on 欧博娱乐 invoice, contract, or DRGR voucher and how your planning and administrative funds are being affected. This limits 欧博娱乐 chance of going above your budget but, more importantly, will help track 欧博娱乐 pace of spending against your activities.

5. This last tip depends on 欧博娱乐 applicable Federal Register Notice (FRN), but usually 70% of funds must meet a National Objective and 80% of funds must address needs within 欧博娱乐 HUD-identified Most Impacted and Distressed (MID) areas. Administration and planning activities are 欧博娱乐 only CDBG-DR/MIT activities that do not need to meet a National Objective, such that 欧博娱乐 70% only applies to 欧博娱乐 grant amount after deducting administrative and planning funds. For 欧博娱乐 MID requirement, HUD allows planning and administrative funds to count towards 欧博娱乐 percentage required but will require justification in 欧博娱乐 Action Plan for how 欧博娱乐 funds are used. Refer to 欧博娱乐 applicable FRN or your local HUD representative for questions you make have on meeting 欧博娱乐se requirements.

For more on this topic, refer to 欧博娱乐 recent guidance in published in August 2023. The notice is an update of 欧博娱乐 original guidance in鈥�.

Also, check out 欧博娱乐se helpful presentations (, , , , and additional tools () provided from HUD on 欧博娱乐 HUD Exchange.