PROGRAM MANAGEMENT: TIMELINESS 2018 Winter Legislative Conference NCDA Carmen Gandulla, Director City of Jersey City Division of Community Development

Overview Timeliness Rule Reasons for not Meeting Timeliness Developing Workout Plan Jersey City’s Method & Strategies

The Timeliness Rule HUD will consider an entitlement recipient to be failing to carry out its CDBG activities in a timely manner if, 60 days prior to the end of the grantee’s current program year, the amount of entitlement grant funds available to the recipient, but undisbursed by the U.S. Treasury, is more than 1.5 times the entitlement grant for its current program year.” [24 CFR §570.902(a)]

Reasons for Failing the Timeliness Test Staff turnover / staff capacity Lack of focus/direction of program Poor activity pipeline Program Management/Poor Subrecipent Management Shovel readiness Financial management Unexpected cash

Reasons for Failing the Timeliness : Application Process Subrecipient Management Program Management Financial management

Application Process Consider Establishing a competitive application process – evaluate based upon readiness to proceed, capacity, etc. Include an implementation timeline as part of the application Provide technical assistance to applicants that are new to the program Preview model programs developed by other grantees Try to anticipate potential time delays and plan accordingly

Subrecipient Management Make sure you know the requirements up front before applying for funds Require subrecipients to submit quarterly progress reports and monthly invoices Maintain regular contact and provide technical assistance whenever necessary Be willing to reallocate funds from underperforming projects

Program Management Draw down funds on a regular basis; at least quarterly Review expenditure of funds for each activity on a regular basis Incorporate regularly the running of the IDIS PR56 report into your program management Reallocate funds as necessary Try to anticipate program income and plan for its use

Developing a Schedule of expenditures is important Financial Management Financial management equals Project Management divide Compliance Management. FM =PM /CM Developing a Schedule of expenditures is important A very important concept in administering CDBG activities is planning for the timely expenditure of funds

Designing the Workout Plan

HUD Resources https://www. hudexchange

https://www.hudexchange.info/resource/2177/cdbg-timeliness-bulletin/

https://www. hudexchange https://www.hudexchange.info/resource/2178/developing-and-implementing-a-cdbg-workout-plan/

HUD Timeliness Letter

IDIS – PR56 Timeliness Report

Jersey City Staff turnover & capacity Shovel readiness Program management Poor subrecipient management Outstanding audit requirements

Response Letter to HUD

Workout Plan Requirements Clearly show how you will meet the 1.5 timeliness standard by a specific date Identify all of the actions the grantee expects to take to meet the specified timetable Include all projects as well as finds available for reprogramming Submit monthly report to HUD Revise the Workout Plan as often as necessary to reflect actual progress.

Workout Plan

CDBG-WORK OUT PLAN APRIL, 2017 MAY, 2017 JUNE, 2017 JULY, 2017 AUGUST, 2017 SEPTEMBER, 2017 OCTOBER, 2017 NOVEMBER, 2017 DECEMBER, 2017 JANUARY, 2018 CDBG-PS $66,693.87 $56,513.94 $84,115.24 $72,746.50 $72,786.86 $54,706.53 $217,113.28 CDBG-REHAB $89,160.05 $1,200,000.00 $88,158.09 $45,000.75 $48,977.55 $300,465.75 $23,887.22 RELOCATION $1,150.00 $2,755.00 $15,030.00 $7,867.25 $1,792.50 $9,740.05 $7,605.31 HORP $2,544.00 $1,576.00 $31,292.75 $14,821.75 $1,289.94 ADMIN $1,487.27 $26,724.35 $30,320.93 $2,147.25 $1,385.71 $19,351.92 $124,702.59 $6,872.87 ECON DEVELOP $100,000.00 $171,061.73 $53,938.27 TOTAL $158,491.19 $1,388,537.29 $302,103.90 $216,990.11 $85,546.46 $157,730.58 $490,904.86 $255,478.68

Reprograming Available Funds Identify the activities for which you plan to use the funds you will have available from modified or terminated projects. Include also a description of how you will use unprogrammed funds from completed projects or from program income one or more projects previously included in your action plan as backup projects or new projects not previously identified in an action plan. List these activities, the amount of the freed-up funds you expect to use on each, and the time within which you expect those funds to be expended.

Reprograming Available Funds Don’t forget to include time for citizen participation, when necessary, to amend your action plan to add a new activity or materially change another

Alternative Methods Float Loans Lump Sum Draw Down Section 108 Loan

Lump Sum Drawdown Read the regulation carefully A grantee may draw funds in advance to fund the rehabilitation of privately owned properties under 24 CFR §570.513 of the CDBG regulations. The funds must be deposited in a financial institution that will agree to provide certain benefits to your community in exchange for receiving the deposit. You must begin making use of the funds within 45 days after their deposit. Plus, a substantial amount of the funds must be used by 180 days after the account is established, and all funds in the account must be put to use by the end of 24th month. Read the regulation carefully

Lump Sum Drawdown (Cont’d) You already have one or more successful rehabilitation loan programs and have the staff and program criteria already in place. The amount of unspent funds programmed for rehabilitation, together with any additional funds you expect to program, would make a substantial contribution to the reduction of your CDBG funds backlog. You are able to find a financial institution willing to participate and negotiate an agreement that meets the regulatory requirements within a reasonable time period. You are likely to spend the funds that will be deposited, along with the interest to be paid on the deposit, for rehabilitation activities by the deadlines required in the regulations.

Briefing & Buy In

Jersey City’s Method & Strategies Created DCD Reporting Dashboard Redesigned Program Schedule Project Management Software Include All Schedules in all areas Changed Staff Meetings Using the Integrity Bulletins Hired Key Staff Internal Auditor In house Counsel Require Work Plan in House

2017-2018 Program Schedule

Reporting Dashboard

Questions ?