COMMUNITY PLANNING AND DEVELOPMENT MONITORING HANDBOOK. Departmental Staff and Program Participants HANDBOOK REV-6
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1 HANDBOOK REV-6 U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT Office of Community Planning and Development Departmental Staff and Program Participants APRIL 2010 COMMUNITY PLANNING AND DEVELOPMENT MONITORING HANDBOOK CHAPTER 8 Economic Recovery Programs
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3 CHAPTER 8 TABLE OF CONTENTS ECONOMIC RECOVERY PROGRAMS 8-1 APPLICABILITY REVIEW OBJECTIVES MONITORING THE HOMELESSNESS PREVENTION AND RAPID RE-HOUSING PROGRAM (HPRP) MONITORING THE NEIGHBORHOOD STABILIZATION PROGRAM 1 (NSP-1) MONITORING THE NEIGHBORHOOD STABILIZATION PROGRAM 2 (NSP-2) MONITORING THE COMMUNITY DEVELOPMENT BLOCK GRANT RECOVERY PROGRAM (CDBG-R) 8-8 EXHIBIT 8-1 EXHIBIT 8-2 EXHIBIT 8-3 EXHIBIT 8-4 EXHIBIT 8-5 EXHIBIT 8-6 EXHIBIT 8-7 EXHIBIT 8-8 EXHIBIT 8-9 EXHIBIT 8-10 EXHIBIT 8-11 EXHIBIT 8-12 EXHIBIT 8-13 EXHIBIT 8-14 EXHIBIT 8-15 EXHIBIT 8-16 EXHIBIT 8-17 EXHIBIT 8-18 Guide for Review of HPRP Program Progress Guide for Review of HPRP-Assisted Housing Guide for Review of HPRP Financial Assistance and Housing Relocation and Stabilization Services Guide for Review of HPRP Program Participants Guide for Review of HPRP Subgrantee Management Guide for Review of HPRP Overall Grant Management Guide for Review of HPRP Financial Management Guide for Review of HPRP Cost Allowability Guide for Review of HPRP Other Federal Requirements Guide for Review of NSP-1 Program Progress Guide for Review of NSP-1 National Objective of Benefit to Low-, Moderate-, and Middle-Income Persons Guide for Review of NSP-1 Cooperative Agreements Guide for Review of NSP-1 State Requirements Guide for Review of NSP-1 Continued Affordability Guide for Review of NSP-1 Eligible Use C: Establish Land Banks Guide for Review of NSP-1 Fair Housing and Equal Opportunity Requirements Guide for Review of NSP-2 Program Progress Guide for Review of CDBG-R Activities i 04/2010
4 REV-6 CHAPTER 8 ECONOMIC RECOVERY PROGRAMS 8-1 APPLICABILITY. The procedures outlined in this chapter are designed to provide guidance for monitoring funds provided under the Housing and Economic Recovery Act of 2008 (HERA) and the American Recovery and Reinvestment Act of 2009 (Recovery Act), specifically, for these programs: the Homelessness Prevention and Rapid Re-Housing Program (HPRP), the Neighborhood Stabilization Program 1 (NSP-1), the Neighborhood Stabilization Program 2 (NSP-2), and the Community Development Block Grant Recovery Program (CDBG-R). These funds have been appropriated for activities that will create jobs, restore economic growth and help those in greatest need, as a result of an unprecedented economic downturn. The expectation is that these funds will be spent with some degree of urgency. Therefore, monitoring and oversight by CPD Field Office staff is a critical function to protect this investment. 8-2 REVIEW OBJECTIVES. HUD reviewers are to follow the risk analysis process as referenced in Chapter 2, Section 2-3, of this Handbook. Guidance specific to these programs is contained in the Notice, Implementing Risk Analyses for Monitoring Community Planning and Development Grant Programs in FY 2010 and 2011, dated August 4, 2009 (see: While the guidance for the specific programs listed in Section 8-1 above is contained within this Chapter, each program has its own separate Exhibits to be used when conducting monitoring. It is important to note that the NSP-1, NSP-2, and CDBG-R Exhibits require the reviewer to use the existing CDBG Exhibits that are in Chapters 3 and 4 of this Handbook. 8-3 MONITORING THE HOMELESSNESS PREVENTION AND RAPID RE-HOUSING PROGRAM (HPRP). This part of Chapter 8 provides guidance for conducting comprehensive monitoring of the Homelessness Prevention and Rapid Re-Housing Program (HPRP). It contains nine Exhibits specific for monitoring the HPRP program, covering: HPRP Program Progress; HPRP-Assisted Housing; HPRP Financial Assistance and Housing Relocation and Stabilization Services; HPRP Program Participants; HPRP Subgrantee Management; HPRP Overall Grant Management; HPRP Financial Management; HPRP Cost Allowability; and HPRP Other Federal Requirements /2010
5 REV-6 A. Program Overview. HUD awards funds for HPRP on a formula basis, for the purpose of providing financial assistance and/or housing relocation and stabilization services to either prevent individuals and families from becoming homeless or help those who are experiencing homelessness to be quickly re-housed and stabilized. HUD awarded HPRP funds through the approval of the Substantial Amendment to the Consolidated Plan 2008 Annual Action Plan submitted by eligible grantees. Eligible grantees are States, Metropolitan Cities, Urban Counties and Territories. Generally, grantees may only subgrant to non-profit organizations and local governments. However, a local government grantee that obtains a waiver from HUD may subgrant to a public housing agency. (Note: For purposes of this program, term grantee means the direct recipient of the HUD award. The term subgrantee means the organization that is responsible for carrying out the proposed project activities. The term program participant means the individuals and adults in families who received assistance during the operating year.) B. Preparing for Monitoring HPRP. The specific HPRP program areas or requirements to be monitored are determined as part of the risk assessment process (see additional guidance provided in Chapter 2 and Section 8-2 above). Before monitoring, the reviewer should be familiar with the HPRP requirements and the design and operation of the grantee s project, particularly those areas that have been identified as high risk or are the focus of the monitoring. Information that will assist in successful HPRP monitoring includes: the authorizing legislation, Title XII of Division A of the American Recovery and Reinvestment Act of 2009 ( Recovery Act ); the Notice of Allocations, Application Procedures, and Requirements for Homelessness Prevention and Rapid Re-Housing Program Grantees under the American Recovery and Reinvestment Act of 2009 (HPRP Notice); the grant agreement(s) for the program(s) being monitored; any HUD-approved waivers; the most recent Annual Performance Report (APR); the most recent HPRP Quarterly Performance Report; Integrated Disbursement and Information System (IDIS) draw-down information; the approved HPRP Substantial Amendment to the Consolidated Plan 2008 Annual Action Plan; and the Homeless Information Management System (HMIS) (examining usage of system for HPRP). 04/
6 REV-6 C. File Selection and Sampling. As described in Chapter 2, the risk analysis process will be used to determine which grantees and areas should be reviewed. The term files for compliance monitoring purposes, includes files from the grantee, the subgrantee, or a combination of both, as applicable. Once that process has been completed, where it is indicated that a file review is necessary to answer Exhibit questions, the HUD reviewer should consider the following factors when determining the specific files that will comprise the review sample: 1. Where feasible, initial file selection should be made using a random selection method. 2. The reviewer would consider adding more files to this selection in order to: i. Include a file or files from each staff person working in the respective program area being monitored. ii. Expand the sample, if possible, to include additional files with the same characteristics, if indicated by the severity or nature of any problems(s) noted during the review of the initial selection (for example, same problem category, same staff person, same activities or other characteristics). This expanded sampling aids in determining whether problems are isolated events or represent a systemic problem. Note, however, that Exhibit 8-4, Guide for Review of HPRP Program Participants, is mandatory for all HPRP projects. 3. The reviewer may also add files to the selection from any HPRP program that the HUD reviewer has reason to believe may have compliance problems or that is substantially different in terms of size, complexity, or other factors from other projects the HPRP grantee has undertaken. 8-4 MONITORING THE NEIGHBORHOOD STABILIZATION PROGRAM 1 (NSP-1). This part of Chapter 8 provides guidance for conducting comprehensive monitoring of Neighborhood Stabilization Program 1 (NSP-1) projects. It contains seven Exhibits specific to monitoring this Program, covering: NSP-1 Program Progress; NSP-1 National Objective of Benefit to Low-, Moderate-, and Middle-Income Persons; NSP-1 Cooperative Agreements; NSP-1 State Requirements; NSP-1 Continued Affordability; NSP-1 Eligible Use C: Establish Land Banks; and NSP-1 Fair Housing and Equal Opportunity Requirements. A. Program Overview. HUD awarded funds for NSP-1 on a formula basis, for the purpose of providing emergency assistance for redevelopment of abandoned and foreclosed homes and residential properties. HUD awarded NSP-1 funds through the approval of a Substantial Amendment to the 2008 Consolidated Annual Action Plan. The submission of the substantial amendment required grantees to design their program around a set of NSP-1 eligible uses that correlated with a number of eligible activities from the CDBG entitlement regulations /2010
7 REV-6 Eligible grantees are entitlement communities, States, the State of Hawaii, and the insular areas. Grantees may subgrant to non-profit organizations and local governments. (Note: For purposes of these monitoring exhibits, term Program Participant means the direct recipient of the HUD award (Grantee) and the organization that is responsible for carrying out the proposed project activities.) B. Preparing for Monitoring NSP-1. The specific NSP-1 program areas or requirements to be monitored are determined as part of the risk assessment process (see additional guidance provided in Chapter 2 and Section 8-2 above). Before monitoring, the reviewer should be familiar with the NSP requirements and the design and operation of the grantee s program, particularly those areas that have been identified as high risk or are the focus of the monitoring. Information that will assist in successful NSP-1 monitoring includes: the authorizing legislation, Title III of Division B of the Housing and Economic Recovery Act of 2008 (HERA); the authorizing legislation, Title XII of Division A of the American Recovery and Reinvestment Act of 2009 ( Recovery Act ); the authorizing legislation, Title I of Division A of the Helping Families Save Their Homes Act of 2009 (HFSTHA); the Notice of Allocations, Application Procedures, Regulatory Waivers Granted to and Alternative requirements for Emergency Assistance for redevelopment of Abandoned and Foreclosed Homes Grantees Under the Housing and Economic Recovery Act, 2008 (NSP Notice); the Notice of Allocations, Application Procedures, Regulatory Waivers Granted to and Alternative requirements for Emergency Assistance for redevelopment of Abandoned and Foreclosed Homes Grantees Under the Housing and Economic Recovery Act, 2008; Revisions to Neighborhood Stabilization Program (NSP) and Technical Corrections ( Bridge Notice ); the approved NSP-1 Substantial Amendment to the 2008 Consolidated Annual Action Plan; the Notice of Change in Definitions and Modification to Neighborhood Stabilization Program (NSP) published at 75 Fed. Reg ; the State s Public Law minimum allocation substantial amendment (if applicable); the grant agreement(s) for the project(s) being monitored; any HUD-approved waivers; the most recent Disaster Recovery Grant Reporting System (DRGR) Quarterly Performance Report (QPR); the Integrated Disbursement and Information System (IDIS) draw-down information (if NSP-1 funds are being combined by other HUD funds); and 04/
8 REV-6 other applicable chapters of this Handbook as the NSP-1 Exhibits contain only NSP-1 specific questions, whereas the grants are to be considered Community Development Block Grant (CDBG) funds. Therefore, Chapter 3, Community Development Block Grant (CDBG) Entitlement, Small Cities, Non Entitlement CDBG Grants in Hawaii, and Insular Area Programs; and Chapter 4, State Community Development Block Grant (CDBG) Program, are to be used in conjunction with the NSP-1 specific Exhibits for monitoring purposes. C. File Selection and Sampling. As described in Chapter 2, the risk analysis process will be used to determine which grantees and areas should be reviewed. The term files for compliance monitoring purposes, includes files from the grantee, the subgrantee, or a combination of both as applicable. Once that process has been completed, where it is indicated that a file review is necessary to answer Exhibit questions, the HUD reviewer should consider the following factors when determining the specific files that will comprise the review sample: 1. Where feasible, initial file selection should be made using a random selection method. 2. The reviewer would consider adding more files to this selection in order to: i. Include a file or files from each staff person working in the respective program area being monitored. ii. Expand the sample, if possible, to include additional files with the same characteristics, if indicated by the severity or nature of any problems(s) noted during the review of the initial selection (for example, same problem category, same staff person, same activities or other characteristics). This expanded sampling aids in determining whether problems are isolated events or represent a systemic problem. 3. The reviewer may also add files to the selection from any project that the HUD reviewer has reason to believe may have compliance problems or that is substantially different in terms of size, complexity, or other factors from other projects the NSP-1 grantee has undertaken. 8-5 MONITORING THE NEIGHBORHOOD STABILIZATION PROGRAM 2 (NSP-2). This part of Chapter 8 provides guidance for conducting comprehensive monitoring of the Neighborhood Stabilization Program 2 (NSP-2) projects. A. Program Overview. HUD awarded funds for NSP-2 on a competitive basis, for the purpose of providing emergency assistance for redevelopment of abandoned and foreclosed homes and residential properties. HUD awarded NSP-2 funds through the competitive process, using a separate grant agreement. The submission of the NSP-2 grant application required grantees to design their program around the requirements set forth in the NSP-2 Notice of Fund Availability (NOFA), using NSP eligible uses that correlated with a number of eligible activities from the CDBG entitlement regulations /2010
9 REV-6 Eligible grantees are state governments, units of general local government, Indian tribes, public housing authorities, nonprofit entities (public and private), or consortium of nonprofits (public and private). Grantees may subgrant to non-profit organizations and local governments. (Note: For purposes of these monitoring Exhibits, term Program Participant means the direct recipient of the HUD award (Grantee) and the organization that is responsible for carrying out the proposed project activities.) B. Preparing for Monitoring NSP-2. The specific NSP-2 program areas or requirements to be monitored are determined as part of the risk assessment process (see additional guidance provided in Chapter 2 and Section 8-2 above). There is a single NSP-2 Exhibit, 8-17, in this Chapter for monitoring program progress. Before monitoring, the reviewer should be familiar with the NSP-2 requirements and the design and operation of the grantee s program, particularly those areas that have been identified as high risk or are the focus of the monitoring. Information that will assist in successful NSP-2 monitoring includes: the authorizing legislation, Title III of Division B of the Housing and Economic Recovery Act of 2008 (HERA). the authorizing legislation, Title XII of Division A of the American Recovery and Reinvestment Act of 2009 ( Recovery Act ); the Notice of Definition Revision to Notice of Fund Availability (NOFA) for Fiscal Year 2009: Neighborhood Stabilization Program 2 (NSP-2) under the American Recovery and Reinvestment Act of 2009; Change in Definitions; the Notice of HUD s Fiscal Year (FY) 2009 Notice of Funding Availability (NOFA); Policy Requirements and General Section to HUD s FY 2009 NOFAs for Discretionary Programs ; the Notice of Fund Availability (NOFA) for the Neighborhood Stabilization Program 2 under the American Recovery and Reinvestment Act, 2009 (NSP-2 NOFA); the three NSP-2 NOFA Correction Notices: o the Notice of Fund Availability (NOFA) for Fiscal Year 2009 Neighborhood Stabilization Program 2 under the American Recovery and Reinvestment Act of 2009; Correction [Docket No. FR-5321-C-02, June 11, 2009]; o the Notice of Fund Availability (NOFA) for Fiscal Year 2009 Neighborhood Stabilization Program 2 under the American Recovery and Reinvestment Act of 2009; Correction [Docket No. FR-5321-C-03, November 9, 2009]; o the Notice of Fund Availability (NOFA) for Fiscal Year 2009 Neighborhood Stabilization Program 2 under the American Recovery and Reinvestment Act of 2009; Correction [Docket No. FR-5321-C-04, January 21, 2010]; 04/
10 REV-6 the consortium agreement (if applicable) for the project(s) being monitored; the grant agreement(s) for the project(s) being monitored; any HUD-approved waivers; the most recent Disaster Recovery Grant Reporting System (DRGR) Quarterly Performance Report (QPR); the Integrated Disbursement and Information System (IDIS) draw-down information (if NSP-2 funds are being combined by other HUD funds); and other applicable chapters of this Handbook as the NSP-2 exhibit contains only NSP-2 specific questions, and the grants are to be considered Community Development Block Grant (CDBG) funds. Therefore, Chapter 3, Community Development Block Grant (CDBG) Entitlement, Small Cities, Non Entitlement CDBG Grants in Hawaii, and Insular Area Programs, Chapter 4, State Community Development Block Grant (CDBG) Program, and the NSP-1 Exhibits in this Chapter outline the NSP-specific requirements that are applicable to both programs and are to be used in conjunction with the NSP-2 specific Exhibit for monitoring purposes. C. File Selection and Sampling. As described in Chapter 2, the risk analysis process will be used to determine which grantees and areas should be reviewed. The term files for compliance monitoring purposes, includes files from the grantee, the subgrantee, or a combination of both as applicable. Once that process has been completed, where it is indicated that a file review is necessary to answer Exhibit questions, the HUD reviewer should consider the following factors when determining the specific files that will comprise the review sample: 1. Where feasible, initial file selection should be made using a random selection method. 2. The reviewer would consider adding more files to this selection in order to: i. Include a file or files from each staff person working in the respective program area being monitored. ii. Expand the sample, if possible, to include additional files with the same characteristics, if indicated by the severity or nature of any problems(s) noted during the review of the initial selection (for example, same problem category, same staff person, same activities or other characteristics). This expanded sampling aids in determining whether problems are isolated events or represent a systemic problem. Note, however, that Exhibit 8-17, Guide for Review of NSP-2 Program Progress, is mandatory for all NSP-2 projects and must be used in conjunction with the NSP-1 Exhibits contained in Chapter 8 of this Handbook and all other aforementioned applicable CDBG Chapters and Exhibits as necessary to monitor the selected sample /2010
11 REV-6 3. The reviewer may also add files to the selection from any project that the HUD reviewer has reason to believe may have compliance problems or that is substantially different in terms of size, complexity, or other factors from other projects the NSP-2 grantee has undertaken. 8-6 MONITORING THE COMMUNITY DEVELOPMENT BLOCK GRANT RECOVERY PROGRAM (CDBG-R). This part of Chapter 8 provides guidance for monitoring the Community Development Block Grant Recovery Program (CDBG-R). It contains a single Exhibit, 8-18, for review of CDBG-R activities. A. Program Overview. HUD awarded funds for CDBG-R on a formula basis, for the purpose of providing financial assistance for infrastructure improvements that meet the overall goals of the American Recovery and Reinvestment Act ( Recovery Act ) of 2009, which are to stimulate the economy through measures that modernize the nation s infrastructure, improve energy efficiency, and expand educational opportunities and access to health care. HUD awarded CDBG-R funds through the approval of a Substantial Amendment to the 2008 Consolidated Annual Action Plan. The submission of the substantial amendment required grantees to design their program based on the aforementioned purposes of the Recovery Act. Moreover, the Recovery Act requires that CDBG-R follow the requirements of the Buy American provision, that is, any project that includes the construction, maintenance, or repair of a public building or public work must use iron, steel, and manufactured goods that are produced in the United States, unless an official waiver has been given. Eligible grantees are entitlement communities, States, the State of Hawaii, and the insular areas. Entitlement grantees may subgrant to non-profit organizations and State grantees will subgrant to units of general local government. (Note: For purposes of these monitoring Exhibits, term Program Participant means the direct recipient of the HUD award (Grantee) and the organization that is responsible for carrying out the proposed project activities.) B. Preparing for Monitoring CDBG-R. The specific CDBG-R program areas or requirements to be monitored are determined as part of the risk assessment process (see additional guidance provided in Chapter 2 and Section 8-2 above). Before monitoring, the reviewer should be familiar with the CDBG-R requirements and the design and operation of the grantee s program, particularly those areas that have been identified as high risk or are the focus of the monitoring. Information that will assist in successful CDBG-R monitoring includes: the authorizing legislation, Title XII of Division A of the American Recovery and Reinvestment Act of 2009 ( Recovery Act ); the Notice of Program Requirements for Community Development Block Grant Program Funding Under the American Recovery and Reinvestment Act of 2009 (CDBG-R Notice); 04/
12 REV-6 the Requirements for Implementing Sections 1512, 1605, and 1606 of the American Recovery and Reinvestment Act of 2009 for Financial Assistance Awards ( OMB Interim Guidance ); the Buy American Exception Under the American Recovery and Reinvestment Act of 2009: Notice of National Exceptions of Section 1605 (Buy American Requirement) of the American Recovery and Reinvestment Act of 2009 Applicable to Community Planning and Development Recovery Act Funds (CPD Buy American Waiver Notice); the CPD Implementation Guidance for the Buy American Requirement of the American Recovery and Reinvestment Act of 2009 including the Exception Process (NOTICE: CPD-09-05); the approved CDBG-R Substantial Amendment to the 2008 Consolidated Annual Action Plan; the grant agreement(s) for the project(s) being monitored; any HUD-approved waivers; the most recent Consolidated Action Performance Evaluation report (CAPER) or Performance Evaluation report (PER); Integrated Disbursement and Information System (IDIS) draw-down information; and other applicable chapters of this Handbook as the CDBG-R Exhibit contains CDBG-R specific questions, and the grants are to be considered Community Development Block Grant (CDBG) funds. Therefore, Chapter 3, Community Development Block Grant (CDBG) Entitlement, Small Cities, Non Entitlement CDBG Grants in Hawaii, and Insular Area Programs, and Chapter 4, State Community Development Block Grant (CDBG) Program, are to be used in conjunction with the CDBG-R exhibit for monitoring purposes. C. File Selection and Sampling. As described in Chapter 2, the risk analysis process will be used to determine which grantees and areas should be reviewed. The term files for compliance monitoring purposes, includes files from the grantee, the subgrantee, or a combination of both as applicable. Once that process has been completed, where it is indicated that a file review is necessary to answer Exhibit questions, the HUD reviewer should consider the following factors when determining the specific files that will comprise the review sample: 1. Where feasible, initial file selection should be made using a random selection method. 2. The reviewer would consider adding more files to this selection in order to: /2010
13 REV-6 i. Include a file or files from each staff person working in the respective program area being monitored. ii. Expand the sample, if possible, to include additional files with the same characteristics, if indicated by the severity or nature of any problems(s) noted during the review of the initial selection (for example, same problem category, same staff person, same activities or other characteristics). This expanded sampling aids in determining whether problems are isolated events or represent a systemic problem. 3. The reviewer may also add files to the selection from any project that the HUD reviewer has reason to believe may have compliance problems or that is substantially different in terms of size, complexity, or other factors from other projects the CDBG-R grantee has undertaken. 04/
14 Exhibit REV-6 Homelessness Prevention and Rapid Re-Housing Program (HPRP) Name of Grantee: Guide for Review of HPRP Program Progress Staff Consulted: Project Name/Number: Name(s) of Reviewer(s) Date NOTE: All questions that address requirements contain the citation for the source of the requirement (statute, regulation, or grant agreement). If the requirement is not met, HUD must make a finding of noncompliance. All other questions (questions that do not contain the citation for the requirement) do not address requirements, but are included to assist the reviewer in understanding the participant's program more fully and/or to identify issues that, if not properly addressed, could result in deficient performance. Negative conclusions to these questions may result in a "concern" being raised, but not a "finding." Instructions: This Exhibit is designed to review HPRP programs to determine if overall program deadlines are being met. 1. Did the grantee sign and return the grant agreement to HUD within 15 days of the date that HUD signed the grant agreement? [HPRP Notice Section IV. Requirements for Funding (F) Review and Approval of Applications (4) Grant Agreement] 2. Did the grantee award or enter into legally binding grant agreements with all of its subgrantees by September 30, 2009? [HPRP Notice Section V. Post-Award Process Requirements, (A) Deadlines for Using Grant Amounts (1) Grantee Obligation] 3. Do the IDIS drawdown records demonstrate that the grantee is drawing down HPRP funds at least quarterly? [HPRP Notice - Section V. Post-Award Process Requirements, (C) Timeliness Standards] /2010
15 REV-6 Exhibit 8-1 Homelessness Prevention and Rapid Re-Housing Program 4. Did the grantee expend at least 60% of its HPRP funds within 2 years from the date that HUD signed the grant agreement? [HPRP Notice - Section V. Post-Award Process Requirements, (A) Deadlines for Using Grant Amounts, (2) Expenditure, and Division A, Title XII of the American Recovery and Reinvestment Act of 2009 ( Recovery Act )] 5. Did the grantee expend all of its HPRP funds within the term of the grant? (Note: Drawdowns for eligible costs that were incurred during the grant period may be drawn down for up to 90 days after the expiration of the grant.) [HPRP Notice Section V. Post-Award Process Requirements (A) Deadlines for Using Grant Amounts, (2) Expenditure, and Division A, Title XII of the Recovery Act] 6. Did the grantee submit all of its HPRP quarterly reports by the deadline in this review period? [HPRP Notice Section VI. Reporting Requirements (C) Performance Reports, (2)(b), and Division A, Section 1512 of the Recovery Act] 04/
16 Exhibit REV-6 Homelessness Prevention and Rapid Re-Housing Program (HPRP) Name of Grantee: Guide for Review of HPRP-Assisted Housing Staff Consulted: Project Name/Number: Name(s) of Reviewer(s) Date NOTE: All questions that address requirements contain the citation for the source of the requirement (statute, regulation, or grant agreement). If the requirement is not met, HUD must make a finding of noncompliance. All other questions (questions that do not contain the citation for the requirement) do not address requirements, but are included to assist the reviewer in understanding the participant's program more fully and/or to identify issues that, if not properly addressed, could result in deficient performance. Negative conclusions to these questions may result in a "concern" being raised, but not a "finding." Instructions: This Exhibit is designed to review the housing assistance provided, including meeting habitability standards. Follow guidance on program participant file sampling in Section 8-3.C in the introductory text to this Chapter as well as Section 2-7.C in Chapter 2 of this Handbook. This same sample of files can also be used for Exhibit 8-3, Guide for Review of HPRP Financial Assistance and Housing Relocation and Stabilization Services. Questions: 1. Do the records indicate that rental assistance paid for the unit(s) does not exceed actual rental cost and that the actual rental cost(s) is/are in compliance with HUD s standard for rent reasonableness? [HPRP Notice Section IV. Requirements for Funding (A) Eligible Activities (1) Financial Assistance (a) Rental Assistance (4)] 2. When HPRP funds were used to assist program participants with financial assistance in a unit into which they were moving, is there evidence that the units were inspected prior to occupancy and that the habitability standards were met? [HPRP Notice Section VII. Other Federal Requirements (C) Habitability Standards and HPRP Notice Appendix C] /2010
17 REV-6 Exhibit 8-2 Homelessness Prevention and Rapid Re-housing Program 3. Does the grantee have a written termination policy and provide a formal process that recognizes the rights of individuals receiving assistance to due process of law? [HPRP Notice Section V. Post-Award Process Requirements (E) Termination of Housing Assistance] 4. If program participants have been terminated from receiving housing assistance, does a review of their files reveal that the minimum due process requirements for termination were followed? [HPRP Notice Section V. Post-Award Process Requirements (E) Termination of Housing Assistance] 04/
18 Exhibit REV-6 Homelessness Prevention and Rapid Re-Housing Program (HPRP) Name of Grantee: Guide for Review of HPRP Financial Assistance and Housing Relocation and Stabilization Services Staff Consulted: Project: Name(s) of Reviewer(s) Program Year: Date NOTE: All questions that address requirements contain the citation for the source of the requirement (statute, regulation, or grant agreement). If the requirement is not met, HUD must make a finding of noncompliance. All other questions (questions that do not contain the citation for the requirement) do not address requirements, but are included to assist the reviewer in understanding the participant's program more fully and/or to identify issues that, if not properly addressed, could result in deficient performance. Negative conclusions to these questions may result in a "concern" being raised, but not a "finding." Instructions: This Exhibit is designed to assess the grantee s performance in providing the homelessness prevention assistance or rapid re-housing assistance activities related to Financial Assistance and Housing Relocation and Stabilization Services. In order to ensure a good mix of activities for review, select both completed and underway activities. The instructions for sample program participant file selection are included in Section 8-3.C in the introductory text to this Chapter. The same files randomly selected and used for this Exhibit can also be used to complete Exhibit 8-2, Guide for Review of HPRP-Assisted Housing, and Exhibit 8-4, Guide for Review of Program Participants. Questions: 1. Do the program participants files indicate that HPRP assistance has been limited to a maximum of 18 months of rental assistance, 18 months of utilities assistance and 18 months of supportive services for each program participant reviewed? [HPRP Notice - Section IV. Requirements for Funding (A) Eligible Activities (1) Financial Assistance and (2) Housing Relocation and Stabilization Services] 2. If HPRP funds were used to pay rental and/or utility arrears, was that assistance limited to six months for each type? [HPRP Notice - Section IV. Requirements for Funding (A) Eligible Activities (1)Financial Assistance (a) Rental Assistance (3)] /2010
19 REV-6 Exhibit 8-3 Homelessness Prevention and Rapid Re-Housing Program (HPRP) 3. If HPRP funds were used to pay rental/utility arrears, were the number of months of arrears assistance included within the 18-month limitation of assistance? [HPRP Notice - Section IV. Requirements for Funding (A) Eligible Activities (1) Financial Assistance (a) Rental Assistance (3)] 4. Do the program participant records indicate that participants who are receiving rental assistance are evaluated and certified for eligibility every three months? [HPRP Notice - Section IV. Requirements for Funding (A) Eligible Activities (1) Financial Assistance (a) Rental Assistance (1), and (D) Eligible Program Participants] 5. Do the program participants files document the delivery of HPRP-eligible financial assistance and supportive services? [HPRP Notice - Section IV. Requirements for Funding (A) Eligible Activities] 6. For program participants receiving motel or hotel vouchers, do their files document the lack of appropriate shelter beds available to house the individual or homeless family, that a subsequent residence was identified before placing the program participant into the motel or hotel, and that the voucher assistance did not exceed 30 days? (Note: If a domestic violence provider serves the program participant, it is not required that a subsequent residence be identified before placement of the household in a motel or hotel.) [HPRP Notice - Section IV. Requirements for Funding (A) Eligible Activities (1) Financial Assistance (e) Motel and Hotel Vouchers] 04/
20 Exhibit REV-6 Homelessness Prevention and Rapid Re-Housing Program (HPRP) 7. For participants receiving moving assistance, is there evidence that the moving costs were reasonable and, if storage fees were paid, that they were limited to no more than three months? [HPRP Notice - Section IV. Requirements for Funding (A) Eligible Activities (1) Financial Assistance (d) Moving cost assistance] 8. For participants receiving legal assistance, is there evidence that the legal services were only used to help people stay in their homes and did not involve any mortgage-related issues? [HPRP Notice - Section IV. Requirements for Funding (A) Eligible Activities (2) Housing Relocation and Stabilization Services (d) Legal Services] 9. Is there evidence in the participants files to indicate that the participants are not also receiving another federal, state or local housing subsidy for the same HPRP cost type and period of time? [HPRP Notice - Section IV. Requirements for Funding (A) Eligible Activities (1) Financial Assistance (a) Rental Assistance (5)] 10. Is there evidence that no HPRP funds are being used for operating costs or to assist persons residing in transitional housing? [HPRP Notice - Section IV. Requirements for Funding (A) Eligible Activities (1) Financial Assistance (a) Rental Assistance (1), (5)] 11. Is there a process in place to ensure that payments for financial assistance were made only to third parties? [HPRP Notice - Section IV. Requirements for Funding (A) Eligible Activities (1) Financial Assistance] /2010
21 Exhibit REV-6 Homelessness Prevention and Rapid Re-Housing Program (HPRP) Name of Grantee: Guide for Review of HPRP Program Participants Staff Consulted: Project Name/Number: Name(s) of Reviewer(s) Date NOTE: All questions that address requirements contain the citation for the source of the requirement (statute, regulation, or grant agreement). If the requirement is not met, HUD must make a finding of noncompliance. All other questions (questions that do not contain the citation for the requirement) do not address requirements, but are included to assist the reviewer in understanding the participant's program more fully and/or to identify issues that, if not properly addressed, could result in deficient performance. Negative conclusions to these questions may result in a "concern" being raised, but not a "finding." Instructions: This review is mandatory for all HPRP programs. This Exhibit is designed to review the eligibility documentation that the grantee or subgrantees collected and evaluated to determine whether or not the program participants meet all of the eligibility criteria upon entry in the HPRP program. HUD reviewers should: Request a listing of program participants (current and past), including their entry dates, from the selected programs. Choose randomly from this list and then request the selected program participant files to complete your review. File selection should represent a cross-section of each homelessness prevention assistance and/or rapid re-housing assistance activity identified in the approved Consolidated Plan s Annual Action Plan HPRP Substantial Amendment, the Integrated Disbursement and Information System (IDIS) completion screens, and the Homeless Management Information System (HMIS). Additional guidance regarding File Selection and Sampling can be found in Section 8-3.C in the introductory text to this Chapter. Files selected for this review may concurrently be used to answer questions in Exhibit 8-2, Guide for Review of HPRP-Assisted Housing, and Exhibit 8-3, Guide for Review of HPRP Financial Assistance and Housing Relocation and Stabilization Services. Questions: 1. Does a review of the selected program participant files reveal adequate documentation that the individuals or families had at least one initial consultation with a case manager or other authorized representative who determined the appropriate type of assistance to meet their needs prior to being accepted into the program? [HPRP Notice Section IV. Requirements for Funding (D) Eligible Program Participants (2) Requirements for all Program Participants (1)] /2010
22 REV-6 Exhibit 8-4 Homelessness Prevention and Rapid Re-Housing Program (HPRP) 2. Does a review of the program participant files reveal adequate documentation that all individuals or families served are at or below 50 percent of the Area Median Income (AMI) upon entry into the program? [HPRP Notice Section IV. Requirements for Funding (D). Eligible Program Participants (2) Requirements for all Program Participants (2)] 3. Does a review of the program participant files reveal adequate documentation that the individuals or families were either homeless or at risk of losing their housing and were (1) without appropriate subsequent housing options and (2) without financial resources and support networks needed to obtain immediate housing or remain in its existing housing? [HPRP Notice Section IV. Requirements for Funding (D) Eligible Program Participants (2) Requirements for all Program Participants (3)] 04/
23 Exhibit REV-6 Homelessness Prevention and Rapid Re-Housing Program (HPRP) Guide for Review of HPRP Subgrantee Management Name of Grantee: Staff Consulted: Program Year: Name(s) of Reviewer(s) Date NOTE: All questions that address requirements contain the citation for the source of the requirement (statute, regulation, Consolidated Plan/IDIS, or grant agreement). If the requirement is not met, HUD must make a finding of noncompliance. All other questions (questions that do not contain the citation for the requirement) do not address requirements, but are included to assist the reviewer in understanding the participant's program more fully and/or to identify issues that, if not properly addressed, could result in deficient performance. Negative conclusions to these questions may result in a "concern" being raised, but not a "finding." Instructions: This Exhibit is designed to review the HPRP grantee s management and oversight of its subgrantees. It is separated into two sections (Subgrantee Program Management and Subgrantee Financial Management). HUD reviewers should select a sample of subgrantees for a program year following the instructions for sampling in Section 8-3.C of the introductory text to this Chapter. The information in the file documentation, supplemented with grantee and subgrantee staff interviews, is to be used to answer the questions below. If the monitoring is onsite and time and resources permit, HUD reviewers should supplement this review with on-site subgrantee visits. Questions: A. SUBGRANTEE PROGRAM MANAGEMENT 1. Did the grantee select subgrantees in accordance with 24 CFR part 85, and the grantee s plan for distribution, administration, and oversight of funds identified in its Substantial Amendment to the Consolidated Plan 2008 Action Plan for HPRP? [HPRP Notice Section V. Post-Award Process Requirements (F) Responsibility for Grant Administration, Section VII. Other Federal Requirements (G) Uniform Administrative Requirements, and 24 CFR 85.37] /2010
24 REV-6 Exhibit 8-5 Homelessness Prevention and Rapid Re-Housing Program (HPRP) 2. Has the grantee executed written agreements with subgrantees to carry out the activities proposed in the grantee s approved Substantial Amendment to the Consolidated Plan 2008 Annual Action Plan for HPRP? [HPRP Notice Section V. Post-Award Process Requirements (F) Responsibility for Grant Administration, (I) Monitoring, Section VII. Other Federal Requirements (G) Uniform Administrative Requirements, and 24 CFR 85.37] 3. Does a review of the subgrantee written agreements show that the agreements contain sufficient information regarding the subgrantees assigned HPRP activities to enable the grantee to conduct effective compliance monitoring reviews? [HPRP Notice Section V. Post-Award Process Requirements (F) Responsibility for Grant Administration (I) Monitoring, Section VII. Other Federal Requirements (G) Uniform Administrative Requirements, and 24 CFR 85.40(a)] 4. Does the grantee have procedures in place to monitor the subgrantees submission of information required for the Quarterly and Annual Performance Reports? [HPRP Notice Section V. Post-Award Process Requirements (F) Responsibility for Grant Administration, (I) Monitoring, and Section VI. Reporting Requirements (C) Performance Reports] 5. Is there evidence that the grantee has procedures in place for ensuring that their subgrantees are compliant with the HPRP confidentiality requirements for participants? [HPRP Notice Section V. Post-Award Process Requirements (D) Confidentiality, (F) Responsibility for Grant Administration] 04/
25 Exhibit REV-6 Homelessness Prevention and Rapid Re-Housing Program (HPRP) 6. If the grantee conducts risk assessments of its subgrantees, is there evidence to show that the grantee performs compliance monitoring reviews in accordance with the risk assessment results? (If the grantee does not conduct a risk assessment, provide a brief narrative regarding its monitoring selection procedures.) [HPRP Notice Section V. Post-Award Process Requirements (I) Monitoring, Section VII. Other Federal Requirements (G) Uniform Administrative Requirements, and 24 CFR 85.40(a)] 7. If monitoring discloses subgrantee deficiencies, does the grantee take appropriate and necessary follow-up actions to ensure that corrective actions are taken by its subgrantees? [HPRP Notice Section V. Post-Award Process Requirements (I) Monitoring, Section VII. Other Federal Requirements (G) Uniform Administrative Requirements, and 24 CFR 85.40] 8. Does the grantee have a method for verifying the accuracy and confidentiality of the participants data in the Continuum of Care (CoC) HMIS system or other centralized intake system, and other documents maintained by the subgrantees? [HPRP Notice Section V. Post-Award Process Requirements (D) Confidentiality (F) Responsibility for Grant Administration, (I) Monitoring, Section VII. Other Federal Requirements (G) Uniform Administrative Requirements, and 24 CFR 85.40(a)] 9. Does the grantee have a method for verifying that participant data is being submitted into the CoC HMIS system or other centralized intake system? [HPRP Notice Section V. Post-Award Process Requirements (F) Responsibility for Grant Administration, (I) Monitoring, Section VI. Reporting Requirements (B) HMIS and Section VII. Other Federal Requirements (G) Uniform Administrative Requirements, 24 CFR 85.40(a)] /2010
26 REV-6 Exhibit 8-5 Homelessness Prevention and Rapid Re-Housing Program (HPRP) B. SUBGRANTEE FINANCIAL MANAGEMENT 10. As a condition for reimbursement of HPRP expenses to subgrantees, does the grantee require, and receive, documentation from its subgrantees sufficient to ensure that payments are for eligible, actual and incurred expenditures? [HPRP Notice Section V. Post-Award Process Requirements (F) Responsibility for Grant Administration, Section VII. Other Federal Requirements (G) Uniform Administrative Requirements, 24 CFR 84.5, 84.21, and 24 CFR 85.37] 11. Does the grantee have procedures for determining subgrantee compliance with applicable program regulations regarding record retention and fiscal management requirements? [HPRP Notice Section V. Post-Award Process Requirements (F) Responsibility for Grant Administration, (I) Monitoring, Section VII. Other Federal Requirements (G) Uniform Administrative Requirements, 24 CFR 84.5, 84.21, 84.53, 85.20, 85.40(a), and 85.42] 12. Does the grantee have a tracking system or other method of documenting the need for, and actual submission of, subgrantee audits required under OMB Circular A-133? [HPRP Notice Section V. Post-Award Process Requirements (F) Responsibility for Grant Administration, (I) Monitoring, Section VII. Other Federal Requirements (G) Uniform Administrative Requirements, 24 CFR 84.5, 84.26, 85.26, 85.40(a)] 04/
27 Exhibit REV-6 Homelessness Prevention and Rapid Re-Housing Program (HPRP) 13. Does the grantee have a tracking system or other method of documenting subgrantee compliance regarding procurement and/or subcontracting requirements? (If the response is NO, this may warrant further review using Exhibit 9-10 of this Handbook as a guide.) [HPRP Notice Section V. Post-Award Process Requirements (F) Responsibility for Grant Administration, (I) Monitoring, Section VII. Other Federal Requirements (G) Uniform Administrative Requirements, 24 CFR 84.5, , 85.36, 85.40(a)] 14. Does the grantee ensure that subgrantees maintain adequate records for property and assets acquired with grant funds? (If response is NO, this may warrant further review using Exhibit 9-11 of this Handbook as a guide.) [HPRP Notice Section V. Post-Award Process Requirements (F) Responsibility for Grant Administration, (I) Monitoring, Section VII. Other Federal Requirements (G) Uniform Administrative Requirements, 24 CFR 84.5, 84.34(f), 85.32(d), 85.40(a) ] 15. Is there evidence that the grantee has safeguards for preventing loss, damage, or theft of subgrantee-held property? [HPRP Notice Section V. Post-Award Process Requirements (F) Responsibility for Grant Administration, (I) Monitoring, Section VII. Other Federal Requirements (G) Uniform Administrative Requirements, 24 CFR 84.5, 84.34(f), 85.32(d), 85.40(a)] /2010
28 Exhibit REV-6 Homelessness Prevention and Rapid Re-Housing Program (HPRP) Guide for Review of HPRP Overall Grant Management Name of Program Participant: Staff Consulted: Name(s) of Reviewer(s) Date NOTE: All questions that address requirements contain the citation for the source of the requirement (statute, regulation, NOFA, or grant agreement). If the requirement is not met, HUD must make a finding of noncompliance. All other questions (questions that do not contain the citation for the requirement) do not address requirements, but are included to assist the reviewer in understanding the participant's program more fully and/or to identify issues that, if not properly addressed, could result in deficient performance. Negative conclusions to these questions may result in a "concern" being raised, but not a "finding." Instructions: This Exhibit is designed to evaluate the Homelessness Prevention and Rapid Re- Housing Program (HPRP) grantee s management systems and HPRP administration. HUD reviewers should select a sample of files and records, as appropriate, following the sampling instructions in Section 8-3.C in the introductory text to this Chapter. A combination of the information in the file documentation and program participant staff interviews is to be used to answer the questions below. Questions: 1. Does the grantee have a management plan or standard operating procedures (SOP) for ensuring that HPRP funds are used in accordance with all program requirements? 2. Are the duties for administrative personnel defined by job descriptions that reflect eligible HPRP administrative costs? [HPRP Notice Section IV. Requirements for Funding (A) Eligible Activities (4) Administrative Costs] /2010
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