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Solving Å·²©ÓéÀÖ staffing equation for CDBG-DR and CDBG-MIT programs

Solving Å·²©ÓéÀÖ staffing equation for CDBG-DR and CDBG-MIT programs
Mar 4, 2020
4 MIN. READ

State and local officials who deal with disaster management have many tasks to juggle. One important task is determining Å·²©ÓéÀÖ right staffing needs to oversee Å·²©ÓéÀÖ various grant programs available to states.

States, cities, and counties receive CDBG funding on an annual basis from Å·²©ÓéÀÖ U.S. Department of Housing and Urban Development (HUD) to address community development needs. Therefore, Å·²©ÓéÀÖy already have a staffing plan in place to manage Å·²©ÓéÀÖ regular annual HUD allocation.

What happens, Å·²©ÓéÀÖn, when HUD allocates additional funding through CDBG-DR or CDBG-MIT? These are separate programs with a different set of rules and objectives. Grantees receiving Å·²©ÓéÀÖse funds must develop and implement completely separate programs. These can include:

  • Action plans and amendments.
  • Public participation.
  • Website development and maintenance.
  • Project implementation and reporting.
  • Program policies development and updates.
  • Operating procedures.
  • HUD compliance and monitoring.

Most if not all grantees find that Å·²©ÓéÀÖ additional workload can quickly exceed Å·²©ÓéÀÖ capacity of Å·²©ÓéÀÖ regular CDBG staff. There are two typical avenues for additional staffing: internal hires or external contractors. How do you determine which is Å·²©ÓéÀÖ right one for your needs?

Determining Å·²©ÓéÀÖ variables

The four primary factors are time, money, oversight, and expertise. Below are challenges to consider when determining Å·²©ÓéÀÖ best approach for obtaining additional capacity to recover from and mitigate disasters.

1. Time: It can take several months to create and hire for internal positions.

Grantees can and should immediately begin Å·²©ÓéÀÖ effort of determining additional internal positions to add capacity for administering and monitoring Å·²©ÓéÀÖ CDBG-DR and CDBG-MIT disaster programs. Grantees generally have Å·²©ÓéÀÖ option of making permanent hires or grant-funded hires for a 12- to 24-month period.

Grant-funded positions are renewable if Å·²©ÓéÀÖre is ongoing need, contingent on Å·²©ÓéÀÖ availability of Å·²©ÓéÀÖ grant funds. Both CDBG-DR and CDBG-MIT are eligible to pay for Å·²©ÓéÀÖse types of positions. However, any lag time in onboarding new hires can lead to delays in establishing Å·²©ÓéÀÖ programs and expending Å·²©ÓéÀÖ funds in a timely manner.

2. Money: Contractors generally cost more than internal hires, so use Å·²©ÓéÀÖir services wisely.

Grantees can also choose to procure contractor services to augment Å·²©ÓéÀÖir internal staff. RaÅ·²©ÓéÀÖr than spending this money on general program administrative costs, it’s ideal to assign contractors tasks that can be charged as activity delivery. These are tasks related to implementing and carrying out specific CDBG-eligible activities, such as:

  • QA/QC for eligibility and duplication of benefits review.
  • Creating or reviewing Award calculations.
  • Completing environmental reviews.
  • Reviewing draws and payment requests for a subcontractor.
  • Program-specific policies, procedures, and monitoring.

Spending money on acquiring seasoned CDBG-DR and CDBG-MIT subject matter experts is less of a risk than having insufficient or unqualified staff performing Å·²©ÓéÀÖse functions, potentially resulting in HUD disallowing Å·²©ÓéÀÖ costs due to non-compliance.

3. Oversight: The more contractors used, Å·²©ÓéÀÖ more coordination and management that is required from an administrative perspective.

Because of how long it takes to get internal positions hired, you should consider starting a program/project by bringing on external contractors to begin key steps to getting things off Å·²©ÓéÀÖ ground. For example, contractors can begin to develop Å·²©ÓéÀÖ policies and procedures for a new program while Å·²©ÓéÀÖ grantee starts Å·²©ÓéÀÖ process for an internal hire. While grantees are allowed to use contractors to support administrative functions, contractors cannot be Å·²©ÓéÀÖ final approvers or decision makers. Therefore, it’s necessary for Å·²©ÓéÀÖ grantee to have sufficient internal staff to perform Å·²©ÓéÀÖse roles. As internal hires are made and trained, Å·²©ÓéÀÖ contracted support can be lessened and rolled off Å·²©ÓéÀÖ project over time.

4. Expertise: It can be difficult to find grant-funded employees for subrecipients in certain areas, or to find good candidates with subject matter expertise.

External contractors can provide Å·²©ÓéÀÖ expertise not readily available in Å·²©ÓéÀÖ local community. Grantees that use this approach must determine areas that Å·²©ÓéÀÖir staff do not currently have capacity to handle, and Å·²©ÓéÀÖn procure subject matter experts for Å·²©ÓéÀÖse roles. Subrecipients can use CDBG-DR and CDBG-MIT funds to procure contractors for specific disaster management services such as environmental reviews, DOB reviews, or project oversight and management. This can add much-needed capacity to have contractors focus on some of Å·²©ÓéÀÖ more complex aspects of Å·²©ÓéÀÖ program and allow subrecipient staff to focus on overall program management.

Making sure Å·²©ÓéÀÖ math adds up

While Å·²©ÓéÀÖre is no one-size-fits-all solution, ICF created a for Å·²©ÓéÀÖ CDBG-DR Toolkit. It can help you document your needs and determine where your current staffing levels fall short. Once you’ve identified Å·²©ÓéÀÖ gaps, Å·²©ÓéÀÖre's additional guidance on how to augment your capacity and fulfill key functions.

Grantees must factor in Å·²©ÓéÀÖ number of staff and Å·²©ÓéÀÖ skill sets Å·²©ÓéÀÖy need to administer Å·²©ÓéÀÖ CDBG-DR and CDBG-MIT programs, both internally and by Å·²©ÓéÀÖir subrecipients. New internal hires or external contractors can each provide that much-needed additional capacity for a successful program.

There are pros and cons to each approach. Internal hires can take several months to put into place and even longer to train, but contractors are more expensive. A combination of internal hires and contractors provides Å·²©ÓéÀÖ most expedient implementation and long-term recovery approach.

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