Comprehensive Update on CARES Act Implementation
Update on key aspects of the CARES Act including Periods of Performance, Spending Statistics, and Amendments to Grant Requirements. Details provided for CDBG-CV, ESG-CV, HOPWA-CV programs. Insights on nationwide and Florida spending patterns, and National Objectives fulfillment percentages highlighted.
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CARES Act Update Tom Rowley CPD Rep / CARES Lead HUD Jacksonville Field Office With special thanks to CARES Act Representative Carla Spradlin 1
Overview Updated Periods of Performance Ineligible Activities Amending Your Plan CDBG-CV Monitoring Common Issues Resources Questions/Conversations CDBG-CV Spending CDBG-CV: Time to Pivot? PPR Tieback Things to Consider Activities That May Meet PPR 2
HOPWA-CV Period of Performance HOPWA-CV grants have a three-year Period of Performance (POP) starting on date of grant agreement execution. After PoP ends, grantees have 120 days to reconcile financial information and make final draws in IDIS. Grantees should make final draws for costs incurred during PoP and work with HUD Field Office Representative to begin closeout procedures outlined in CPD-23-04, Closeout Instructions for HOPWA Program Grants. https://www.hudexchange.info/news/important-hopwa-reminder-period-of-performance-and-financial- drawdowns-for-hopwa-grants/ 4
CDBG-CV Period of Performance FR-6218-N-02 - April 2023 Notice of Change to an Expenditure Deadline Under the CARES Act for Community Development Block Grant Program Coronavirus Response Grants Removes 3-year requirement to expend 80 percent of CDBG CV funds Keeps 6-year requirement to expend 100 percent of CDBG CV funds https://www.hud.gov/sites/dfiles/CPD/documents/FR-Document-2023-08158.pdf 5
CDBG-CV Spending Nationwide Accepted Disbursed Amount Amount Percent Average Median $4,988,713,675 $2,957,478,769 59.3% 70.3% 78.4% Florida Accepted Disbursed Amount Amount Percent Average Median $284,712,358 $107,877,785 37.9% 57.1% 57.9% Source: Power BI September 1, 2023 6
CDBG-CV Spending 77 73 69 65 61 57 Florida Grantees 53 49 45 Average=57.1% Median=57.9% 41 37 33 29 25 21 17 13 9 5 1 0% 20% 40% 60% 80% 100% 120% Disbursed Source: Power BI September 1, 2023 7
CDBG-CV Spending National Objective Percent of Voucher Draws Nationwide 64.4% 6.7% 13.5% 10.0% 5.1% .3% Florida 52.2% 6.9% 24.1% 9.2% 7.7% 0% LMC LMJ URG LMA LMH SB Source: Power BI September 14, 2023 8
CDBG-CV Spending Florida grantees have drawn: Public Services - $71.8m Economic Development - $16.2m Public Facilities and Improvements - $11.6m Housing - $6.5m $ Source: Power BI September 14, 2023 9
CDBG-CV Spending Public Service Activities with Vouchers - Florida Subsistence Payment 45.8% Other Public Services Not Listed in 05A-05Y, 03T 12.5% Health Services 5.8% Operating Costs of Homeless/AIDS Patients Programs 5.8% Food Banks 4.9% Legal Services 4.1% Senior Services 3.8% Mental Health Services 3.0% Employment Training 2.9% Rental Housing Subsidies 2.5% Youth Services 2.4% Child Care Services 2.0% Housing Information and Referral Services 1.6% Services for Persons with Disabilities 1.1% Substance Abuse Services 0.8% Housing Counseling only, under 24 CFR 5.100 0.5% Abused and Neglected Children 0.2% Services for victims of domestic violence, dating violence, sexual assault or stalking 0.1% Fair Housing Activities (if CDBG, then subject to 15% cap) 0.0% Source: Power BI September 14, 2023 10
Maybe Time to FCDA-September 28, 2022
Pivot Which Way? 1. Update unmet needs assessment to determine target(s) 2. Meet with partners and subrecipients to assess capacity 3. Remember the Oreo! FCDA-September 28, 2022
Can we do _____? The Oreo Test Don t forget to document your test! FCDA-September 28, 2022 13
PPR Tieback Must document how CDBG-CV activities tie back to coronavirus - Project and/or individual files should tell how activities meet PPR - Rationales will vary but should be documented in file as part of project review and eligibility analysis 14
PPR Tieback CDBG and CDBG-CV eligible activities with PPR tieback Key is to focus on documented coronavirus effects or risks to overall economic, service, housing and infrastructure serving LMI neighborhoods and communities Consider both backward-looking and potential forward-looking risks or vulnerabilities to coronavirus https://www.hud.gov/sites/dfiles/CPD/documents/Quick-Guide-CDBG-CV-PPR-Tieback-Flexibilities- 043020212.pdf 15
Things to Consider No cap on public services to PPR. (Also applies to regular 2019 and 2020 CDBG used to PPR.) Extension of emergency payments for individuals/families from 3 to 6 consecutive months. Purchase of personal property, fixtures, and equipment allowed when items constitute all or part of a public service. Examples: ventilators or other medical equipment and supplies used in providing health care at field clinic, vehicle outfitted with medical equipment to provide mobile health care. 24 CFR 570.207(b)(1) Difference between general program administrative costs (overall program planning and CDBG admin) and activity delivery costs (implementing and carrying out specific CDBG- eligible activities) https://www.hud.gov/sites/documents/13-07CPDN.PDF FCDA-September 28, 2022 16
Activities That May Meet PPR Provide training to workers for jobs in expanding business sectors in communities hit by coronavirus-related job loss. Rehabilitate building for use as non-congregate shelter for the homeless. Extend broadband in underserved area to support remote learning and telemedicine. Provide up to six consecutive months of emergency subsistence payments (e.g., rent, mortgage, or utilities) on behalf of individual/family to prevent eviction. Construct park serving LMI area to provide suitable outdoor fitness and social space where insufficient facilities available to support social distancing guidance. 17
Activities That May Meet PPR Upgrade HVAC in public facilities to improve air quality and limit transmission of coronavirus. Provide grants/loans to for-profit businesses to acquire, convert, construct, or reconstruct commercial spaces to create jobs and revitalize communities and local economies affected by business/job losses resulting from coronavirus. Assist microenterprises to manufacture PPE and hand sanitizer necessary to respond to coronavirus. Increase capacity of available daycare and/or after-school services in LMI areas where parents had to leave workforce due to coronavirus so they may return to work. 18
Ineligible Activities Payment for cost overruns. Adding CDBG-CV funds to an activity already in progress. 19
Amending Your Plan Amend same AAP or Con Plan as original CDBG-CV amendment (2019 or 2020) Amend if: (1) Making change in allocation priorities or change in method of distribution of funds; (2) Carrying out an activity not previously described in the action plan; or (3) Changing purpose, scope, location, or beneficiaries of an activity. Substantial Amendment threshold is determined by your citizen participation plan criteria. FCDA-September 28, 2022
CDBG-CV Monitoring FR-6218-N-01 III.B.2. Responsible Use of CARES Act Funds CDBG CV funds are subject to additional measures designed to prevent fraud, waste, and abuse. HUD will conduct regular oversight and monitoring activities to determine that use of CDBG CV funds is consistent with grant requirements and limited to the necessary and reasonable costs of activities to prevent, prepare for, and respond to coronavirus. https://www.hud.gov/sites/dfiles/CPD/documents/CDBG- CV_Notice_Federal_Register_Publication_2002-08.pdf 21
CDBG-CV Monitoring CPD Monitoring Handbook and Exhibits (6509.2) CDBG: Chapter 3 CDBG (State): Chapter 4 Environmental: Chapter 21 Lead-Based Paint: Chapter 24 2 CFR 200: Chapter 34 CDBG-CV: Chapter 36 https://www.hud.gov/program_offices/administration/hudclips/handbooks/cpd/6509.2 22
CDBG-CV Monitoring Chapter 36: CARES Act Monitoring CDBG-CV - Exhibits 36-1 and 36-2 HOPWA-CV - Exhibits 36-3A-3C ESG-CV - Exhibits 36-4A-4H https://www.hud.gov/sites/dfiles/OCHCO/documents/65092CH36.pdf 23
Common Issues FR-6218-N-01 III.B.5.(a) Use of Funds for CARES Act Purposes III.B.5.(c)(iv) Mandatory Evaluation of Special EDA III.B.5.(f) Eligible Activities III.B.9 Duplication of Benefits Additional CDBG-CV Requirements 11 Items attached to Funding Approval/Agreement 24
Common Issues Eligibility and National Objective Lack of internal review process Unclear procedure or process to assess activity eligibility Core CDBG Eligibility National Objective selection 24 CFR 570.208(a)(2)(A) HUD Matrix Codes and National Objective Definitions https://files.hudexchange.info/resources/documents/Matrix-Code-Definitions.pdf https://files.hudexchange.info/resources/documents/Matrix-Code-National-Objective-Table.pdf 25
Common Issues Subrecipient Agreements 2 CFR 200.332(d)(4) Subrecipient audit oversight 2 CFR 200.318 General Procurement Standards 24 CFR 570.506(a) Records to be maintained https://www.hudexchange.info/resource/6577/managing-cdbg-guidebook-for-cdbg-grantees-on- subrecipient-oversight/ 26
Common Issues Supporting Documentation Lack of CDBG-CV policies and procedures Need for policies and procedures updates Client Files IDIS Documentation 24 CFR 570.506 - Records to be maintained https://www.ecfr.gov/current/title-24/subtitle-B/chapter-V/subchapter-C/part-570/subpart- J/section-570.506 27
CDBG-CV Resources CDBG-CV Webinar Series https://www.hudexchange.info/trainings/cdbg-cv-webinars/ CDBG-CV Toolkit https://www.hudexchange.info/programs/cdbg-cv/cdbg-cv-toolkit/ Case Studies / Best Practices https://www.hudexchange.info/news/cdbg-cv-best-practices-webinar-series/ https://www.hud.gov/sites/dfiles/CPD/documents/CDBG-CV-Best-Practices-Report-Summer-2022.pdf CDBG-CV Problem Solving Clinics https://www.hudexchange.info/news/2023-cdbg-cv-problem-solving-clinics/ 28
ESG-CV Resources Emailed by HUD HQ to you September 9, 2023 29
Questions You re in a room full of experts: your peers. Speak up! Tom Rowley CPD Rep / CARES Lead Thomas.D.Rowley@hud.gov Please cc your CPD Rep 30
