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

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

3. 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 § (a)]

4. 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

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

6. 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

7. 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

8. 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

9. 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

10. Designing the Workout Plan

11. HUD Resources https://www. hudexchange

13. https://www. hudexchange

14. HUD Timeliness Letter

15. IDIS – PR56 Timeliness Report

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

17. Response Letter to HUD

18. 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.

19. Workout Plan

20. 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

21. 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.

22. 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

23. Alternative Methods
Float Loans
Lump Sum Draw Down
Section
108 Loan

24. 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 § 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

25. 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.

26. Briefing & Buy In

27. 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

28. Program Schedule

29. Reporting Dashboard

30. Questions ?