1. 2011 CDBG Recipients’ Workshop What’s New? Keeping current with the changing landscape

2. Page 2 2011 CDBG Recipients’ Workshop Minimum Performance Expectations 1 st Year ▪Conditions cleared ▪Funds released ▪Engineering/Architectural designs complete and submitted to cognizant agencies ▪For Housing and Multi-Activity, policies and procedures submitted and approved

3. Page 3 2011 CDBG Recipients’ Workshop Minimum Performance Expectations 2 nd Year ▪50% of funds spent 3 rd Year ▪100% of funds spent

4. Page 4 2011 CDBG Recipients’ Workshop Reporting Results Absolutely critical ▪Quarterly reports need to be timely and complete ▪Quarterly reports need to reconcile ▪Update results early and often Especially match and leverage and units ▪We will be auditing for errors ▪Sanctions may be applied for late reports, undocumented reports, or inaccurate reports

5. Page 5 2011 CDBG Recipients’ Workshop Reporting Results Absolutely critical ▪Remember that changes in scope must be approved by DCA 10% reduction in beneficiaries Other significant reductions in benefit ▪New temporary job reporting requirement

6. Page 6 2011 CDBG Recipients’ Workshop HB 87—Illegal Immigration and Reform Act of 2011 Disclaimers first—DCA does not/will not provide legal advice You must rely on your local attorney

7. Page 7 2011 CDBG Recipients’ Workshop HB 87—Illegal Immigration and Reform Act of 2011 Revisions to Code Section OCGA 13-10 13-10 is about E-verify Applies to “physical performance of service” between contractors/subcontractors/ subsubcontractors and public employers This applies to CDBG contracts

8. Page 8 2011 CDBG Recipients’ Workshop HB 87—Illegal Immigration and Reform Act of 2011 Revisions to Code Section OCGA 13-10 Prior to entering into any contract, a unit of local government must verify that the contractor participates in the federal work authorization program Have the right affidavit from the contractor! See your local attorney

9. Page 9 2011 CDBG Recipients’ Workshop HB 87—Illegal Immigration and Reform Act of 2011 Revisions to Code Section OCGA 13-10 Applies to subcontractors and sub- subcontactors Their affidavits must be forwarded to subcontractors and contractors and from contractors to units of local government

10. Page 10 2011 CDBG Recipients’ Workshop HB 87—Illegal Immigration and Reform Act of 2011 Revisions to Code Section OCGA 13-10 As of August 1, 2011, the Department of Audits and Accounts is to post form affidavits on its web site No later than December 31, public employers shall submit reports to the state auditor certifying compliance

11. Page 11 2011 CDBG Recipients’ Workshop HB 87—Illegal Immigration and Reform Act of 2011 Revisions to Code Section OCGA 13-10 Failure to comply could result in loss of QLG status Contractors could also be debarred DCA will monitor for the affidavit in the primary CDBG contract

12. Page 12 2011 CDBG Recipients’ Workshop HB 87—Illegal Immigration and Reform Act of 2011 Revisions to Code Section OCGA 13-10 See General Condition regarding compliance with OCGA 13-10

13. Page 13 2011 CDBG Recipients’ Workshop HB 87—Illegal Immigration and Reform Act of 2011 Revisions to Code Section OCGA 50-36 Local governments providing public benefits shall require every applicant to ▪provide at least one secure and verifiable document as defined by 56-36-2 see Attorney General’s web page for acceptable IDs ▪signed and sworn affidavit of lawful presence see State Auditor’s web page for acceptable affidavits

14. Page 14 2011 CDBG Recipients’ Workshop HB 87—Illegal Immigration and Reform Act of 2011 Revisions to Code Section OCGA 50-36 Note all local governments must register with Systematic Alien Verification of Entitlement (SAVE) program List of public benefits is issued annually by the Attorney General On or before January 1, reports are due to DCA that identifies public benefits administered by the local government

15. Page 15 2011 CDBG Recipients’ Workshop HB 87—Illegal Immigration and Reform Act of 2011 Revisions to Code Section OCGA 50-36 See General Condition regarding compliance with OCGA 50-36

16. Page 16 2011 CDBG Recipients’ Workshop HB 87—Illegal Immigration and Reform Act of 2011 Immigration Enforcement Review Board shall have the authority to investigate and review any complaint Legal penalties may be imposed for failure to follow the law SEE YOUR ATTORNEY!

17. Page 17 2011 CDBG Recipients’ Workshop Leverage See new cash match verification/leverage assessment form. (See Appendix II, Project Review Checklists.) ▪Will be prepared by the field representative prior to the last CDBG draw. Will also require the field representative to make a recommendation regarding payment of the final CDBG draw in light of progress toward leverage requirements. ▪Match and leverage will again be reviewed/verified at the closeout site visit.

18. Page 18 2011 CDBG Recipients’ Workshop Leverage For Quarterly Reports ▪Leverage includes Match

19. Page 19 2011 CDBG Recipients’ Workshop Non-compliance of CDBG Professionals Whenever DCA determines that a Recipient has failed to comply with the requirements of the CDBG Program, including those requirements listed in this Manual, causing delays in implementation or findings, due to the actions or inaction of its Grant Administrator, Engineer/Architect, or other CDBG Professional, DCA shall notify the Recipient of the CDBG Professional’s noncompliance and shall require appropriate action by the Recipient.

20. Page 20 2011 CDBG Recipients’ Workshop Non-compliance of CDBG Professionals Temporarily or permanently terminate payments to the Recipient for administrative/professional activities; Require the Recipient to repay some or all the CDBG payments made to the Recipient for CDBG administrative/professional activities; Refer the matter to the Attorney General with a recommendation that an appropriate action be instituted; or Take such other action as may be provided by law or regulation.

21. Page 21 2011 CDBG Recipients’ Workshop Housing and Multi-Activity Grants Policies and Procedures Special Condition No housing activity may be undertaken until a draft copy of the Policies and Procedures (P/P) has been submitted to DCA for review and approval

22. Page 22 2011 CDBG Recipients’ Workshop Housing and Multi-Activity Grants Please note that extension and amendment requests must indicate why an extension/amendment is required AND provide a synopsis as to the status of all proposed units ▪New units, substitute units, conversion from rehab to reconstruction, costs exceeding 20% of approved unit budget must all be approved by DCA See the Rehabilitation Manual for detailed requirements regarding grant modifications

23. Page 23 2011 CDBG Recipients’ Workshop Questions: Steed Robinson - 404.679.3168 steed.robinson@dca.ga.gov Glenn Misner – 404.679.3138 glenn.misner@dca.ga.gov