1. Grant Based Accounting and Managing HOME Deadlines January 20, 2016 U.S. Department of Housing and Urban Development

2. HOME along with other CPD formula programs historically committed and disbursed funds on a first-in first-out (FIFO) basis in IDIS This was to ensure the oldest uncommitted/ undisbursed grant funds were committed and expended without grantee/PJs having to identify funds from specific grants or subgrants For HOME, FIFO operation in IDIS necessitated the use of a cumulative method of determining compliance with HOME deadlines – 24 CFR 92.550(d)(2) Background

3. July 2013 - GAO decision determined that the cumulative method was not in compliance w/HOME statute September 2013 - OMB determined that HUD should stop using the FIFO method of committing and disbursing funds from IDIS September 1, 2014 - IDIS release 11.10 removed FIFO processing for all 2015 and future CPD formula block grants (i.e., CDBG, HOME, ESG, HOPWA) – No rulemaking necessary for FIFO Ch-ch-ch-changes

4. Because of the GAO decision, HUD must undertake rulemaking to change the method of determining compliance with HOME deadline requirements from a cumulative to a grant specific method – Requires further IDIS changes Future

5. IDIS allows PJs to fund activities with: – FIFO funds (1992-2014) and/or – Grant-specific funds (2015+) FIFO funds will continue to be committed and disbursed FIFO Grant-specific funds will be committed based on the specific grant or subgrant selected by the PJ and the same funds will be disbursed at drawdown Program income differences for FIFO and grant- specific PI IDIS Functionality

6. FIFO 6 2012 2013 2014 2012 2013 2014 Activity Funding Drawdown

7. Grant-specific 7 2016 2015 Activity Funding Drawdown 2017

8. FIFO and Grant-specific 8 2012 2013 2014 2012 2013 2014 2016 2015 Activity Funding Drawdown FIFO

9. Currently continue to be measured cumulatively because that is what the regulation requires Implemented changes to CHDO reservation requirement and new CHDO expenditure requirement in calendar year 2015 Currently, commitments, CHDO reservations, CHDO expenditures, and expenditures from 2015 (and soon 2016) grants are counted toward cumulative requirements HUD will not reduce CHDO subfunds on FY 2015 and future grants HOME Deadline Requirements

10. HOME funds from each grant must be committed within 24 months of receiving the grant After the deadline passes funds becoming uncommitted must be deobligated by HUD – Completing a project for less than the amount committed – Project cancellation – Auto-cancellation – Disbursing PI, HP, or IU in place of EN 15% of each grant must be reserved to CHDOs (i.e., committed to a specific CHDO project) Grant-Specific Issues

11. Check HOME Deadline Compliance Status Report each month without fail (posted to HUD Exchange) Run IDIS PR27 and PR49 reports after HOME funds are committed and disbursed to see impact Check PR21 HOME Auto Cancel Report monthly to ensure no activities were auto-cancelled by IDIS Establish policies that enable you to commit all grant funds + funds in local account each year Have a pipeline of projects that could quickly receive uncommitted funds Must Do List

12. For more information, visit the Grant Based Accounting website at: https://www.hudexchange.info/man age-a-program/grant-based- accounting/

13. Questions? U.S. Department of Housing and Urban Development