Financial Grant Management 3 Grant Agreement Application Certifications Program Regulations Approved Budget Uniform Administrative Requirements OMB Circulars
Uniform Administrative Requirements 4 For each type of recipient, there is a set of Federal principles, called Uniform Administrative Requirements, which determine allowable costs for grants. 24 CFR part 84 –Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations; 24 CFR part 85 –State, Local, and Federally Recognized Indian Tribal Governments
OMB Circulars 5 In Addition, the Office of Management and Budget (OMB) publishes the allowable costs for all grant recipients in their Circulars. 2 CFR part 230 - Cost Principles for Non-Profit Organizations (OMB CircularA-122) 2 CFR part 225 – Cost Principles for State, Local and Indian Tribal Governments (OMB Circular A-87)
Drawing Funds Drawing funds to reimburse the recipient for eligible costs incurred and already paid…..OR Drawing funds for eligible costs incurred but not yet paid. 6
Tips on Drawing Funds Draw consistently (develop a process to draw every month or at a minimum every quarter) Draw the pennies (VRS will let you draw cents, so be a * and draw the exact amount you need) Track exactly what costs are being paid with the drawn funds 7
More Documentation Tenant Rent Calculations and Payments TIME SHEETS (Detailed as possible, i.e. client #s, description of work performed, budget item charged, etc) Transportation Logs Contracts with providers 9
What This Grant Reviewer Likes To See Well organized files – I really like to ask and receive all documentation for a particular draw in one bundle Spreadsheets – I feel the love when I see spreadsheets with real time data tracking expenses and payments by approved budget line items. 13
Policies and Procedures 14 Policies – Write it Down! Organize It! Share it with Staff! Policies/Procedures I ask about on Monitoring Review (Questions on Checklist) 1.Recording Financial Transactions/Accounting Manual/Chart of Accounts 2.Authority for Approving Financial Transactions 3.Controlling Expenditures/Purchasing Requirements/Travel Authorizations 4.Maintenance of Accounting Records
Documenting Match 15 The match requirements under the CoC Program interim rule are simplified from the SHP and the S+C program. All eligible funding costs, except leasing, must be matched with no less than a 25 percent cash or in-kind contribution. No match is required for leasing. Resident Rent can no longer be used for match.
Documenting Match 16 Cash Sources May use funds from any source, including any other federal sources (excluding Continuum of Care program funds), as well as State, local, and private sources, provided that funds from the source are not statutorily prohibited to be used as a match. Must ensure that any funds used to satisfy the matching requirements of this section are eligible under the laws governing the funds in order to be used as matching funds for a grant awarded under this program.
Documenting Match 17 In-Kind For an in-kind match, the value of property, equipment, goods, or services contributed to the project may be used, provided that, if such items were paid for with grant funds, the costs would have been eligible. If third-party services are to be used as a match, the recipient or subrecipient and the third-party service provider that will deliver the services must enter into a memorandum of understanding (MOU)before the grant is executed.
Documenting Match 18 Keep records of the source and use of cash and in- kind contributions used to satisfy the 25 percent match requirement (24 CFR part 578.73). Match records must indicate the grant and fiscal year for which each matching contribution is counted.
Does My Grant Require An Environmental Review? 21 All grants require an Environmental Review 24 CFR 578.31 (CoC Program) 24 CFR 583.230 (SHP Program) 24 CFR 582.230 (S+C Program) 24 CFR 576.407(d) (ESG Program) A responsible entity (RE) (Part 58) or HUD (Part 50) must complete the review and make a determination of the level of review. The RE must create an environmental review record with verifiable resources and documented findings for each project. A non-profit may not act as an RE.
Responsible Entities 22 Responsible Entity Certifying Officer Evaluates the environmental review Is responsible for scope and content Makes environmental finding Goes to court in a lawsuit Responsible Entity (RE) assumes federal responsibilities RE = a unit of general local government, tribe or State
What Is an Environmental Review? Analysis of the impact of a project on the surrounding environment and vice versa Ensures that HUD-funded projects provide decent, safe, and sanitary housing MUST be conducted BEFORE funds are committed 23
HUDs Environmental Regulations 24 CFR 50 – HUD Review Environmental review requirements for HUD staff 24 CFR 51 – Manmade Hazards Noise Explosive or Flammable Hazards Runway Clear Zones 24 CFR 55 – Floodplains & Wetlands 24 CFR 58 – Local Government Review Environmental review requirements for units of general local government (Responsible Entity/RE) 24
Part 58 vs Part 50 Part 58 Program legislation permits local government to conduct ER RE certifying that environmental review is complete Accepts comments. After public comment period, RE applies to HUD for release HUD authorizes release of funds Part 50 HUD conducts environmental review HUD determines that local government does not have capacity or refuses to accept responsibility for review Grantee may collect any information required to complete the review from applicant, as long as HUD staff remain responsible for accuracy of the review 25
When Part 50 Reviews Are Required If a responsible entity, other than a recipient, objects to performing an environmental review... HUD may designate another responsible entity to conduct the review in accordance with this part or may itself conduct the environmental review in accordance with the provisions of 24 CFR part 50. (24 CFR 58.11(d)) HUD assumes responsibilities for environmental reviews for SNAPS projects only where (1) a nonprofit is the recipient and (2) no responsible entity can be found. 26
Level of Review 27 Environmental Impact Statement Environmental Assessment Categorically Excluded Subject to 58.5/50.4 Categorically Excluded Not Subject to 58.5/50.4 Exempt 27
Limited Scope Environmental Reviews Used for leasing, project- based rental assistance Require minimal analysis: 1. Coastal Barrier Resources 2. Coastal High Hazard Area, Floodway, and Floodplain 3. Toxic Hazards 29
Conducting a Limited Scope Review HUD will request information for each site from recipient using the new form. HUD will review the information and documentation and confirm that project conforms to HUDs environmental policies. HUD will certify the review. 30
Coastal Barrier Resources and Coastal High Hazard Areas Coastal Barrier Resources Long, narrow islands and back bay barriers – the first line of defense for storm surges. Coastal High Hazard Areas (V Zone): area subject to high velocity waters from hurricanes or tsunamis. HUD will reject any project located in the Coastal Barrier Resources System or Coastal High Hazard Areas. 32
Floodways and Floodplains Floodways: portion of floodplain which is effective in carrying flow, where the flood hazard is generally greatest, and where water depths and velocities are highest. 100-Year Floodplains: areas where each year there is a 1 percent chance of flooding. Being in these areas puts people at risk HUD will reject any project located in a Floodway and may reject projects in 100-year floodplains. 33
Toxic Chemicals and Radioactive Material It is HUD policy that all property proposed for use in HUD programs be free of hazardous materials, contamination, toxic chemicals and gases, and radioactive substances, where a hazard could affect the health and safety of occupants or conflict with the intended utilization of the property 24 CFR 50.3(i) & 58.5(i)(2) 35 A report of nearby toxic sites using EPAs mapping service at http://www.epa.gov/enviro/index.html or similar service
Examples of Site Contamination Landfills Underground Tanks Unexplained dirt piles Buried Waste 36
Take-Away Messages 37 All grants require an environmental review Funds cannot be committed, obligated, or expended prior to the completion of the environmental review. The RE must create an environmental review record with verifiable resources and documented findings for each project.
Emergency Solutions Grant [ESG] RENT REASONABLENESS AND FAIR MARKET RENT
Rent Reasonableness And Fair Market Rent Does not exceed the Fair Market Rent (FMR) established by HUD for each geographic area; and Complies with HUDs standard of rent reasonableness. This requirement is in the ESG program Interim Rule at 24 CFR 576.106(d). 40 ESG allows short-and medium-term rental assistance to be provided to eligible program participants only when the rent, including utilities (gross rent), for the housing unit:
Rent Reasonableness And Fair Market Rent HPRP & ESG: Key Difference HPRP: Rent must meet rent reasonableness standards. ESG: Rent must meet rent reasonableness standards and cannot exceed HUDs published FMRs for the area. In some communities, the reasonable rent for a specific unit may be lower than the FMR that has been established for the community. Bottom line: The rent for the unit assisted with ESG funds must not exceed the lesser of the FMR or the rent reasonableness standard. 41
Calculating the Gross Rent 42 To calculate Gross Rent: Total contract rent amount of the unit Add any fees required for occupancy under the lease (excluding late fees and pet fees) Add the monthly utility allowance
What Is The FMR Requirement 43 HUD establishes FMRs to determine payment standards or rent ceilings for HUD-funded programs that provide rental assistance Published annually for metropolitan areas and non-metropolitan county areas. Published on October 1 each year www.huduser.org/portal/datasets/fmr.html
What Is The Rent Reasonableness Requirement 44 HUDs rent reasonableness standard is designed to ensure that rents are reasonable in relation to rents for comparable unassisted units in the same market. If a rent reasonableness determination supports a lower rent, then ESG funds may not be used to rent the unit (unless the landlord is willing to lower the rent). ESG funds could be used to assist the program participant to move to a different unit.
Determining and Documenting Rent Reasonableness 45 Recipients are responsible for determining what documentation is required in order to ensure the rent reasonableness standard is met. A market study of rents. Advertisements for comparable rental units. Written verification signed by the property owner, on letterhead, affirming that the rent is comparable to current rents charged for similar unassisted units managed by the same owner.
Determining and Documenting Rent Reasonableness 46 Recipients must establish their own written policies and procedures for documenting comparable rents and ensure that they are followed when documenting rent reasonableness in the case file. A sample Rent Reasonableness Checklist and Certification form is available at: www.hud.gov/offices/cpd/affordablehousing/ library/forms/rentreasonablechecklist.doc
Determining and Documenting Rent Reasonableness 47
Determining and Documenting Rent Reasonableness 48 Before conducting its own study of rent levels, a recipient/subrecipient should consult existing sources of rental housing data that can be used to establish comparable rents. Public Sources (PHA, Chamber) Real estate advertisements and contacts Rental market study Rental market survey Rental database
Rural Housing Data Sources 49 While there may be fewer rental units in rural areas than in urban and suburban areas, it is possible to find comparable rents for different unit types located in these areas using various data sources, including: U.S. Department of Agricultures Rural Development Agency (USDA) PHAs Real estate agents
Components Of An Effective Policy 50 Policies and procedures must be transparent and consistently applied across the program, and result in decisions that comply with HUD requirements. At a minimum, an effective policy includes: methodology, documentation requirements, staffing assignments, and strategies for addressing special circumstances.
Components Of An Effective Policy 51 Policies and procedures should provide step-by-step guidance on making comparisons between the program participants rent, the FMR, and the rent reasonableness standards for comparable units in that community. This includes the documentation to be included in each case file, such as forms and/or case notes.