Jefferson Parish Department of Community Development Hurricane Isaac Community Development Block Grant- Disaster Recovery Funding

Transcription

1 Jefferson Parish Department of Community Development Hurricane Isaac Community Development Block Grant- Disaster Recovery Funding Policies and Procedures Manual Version 3.0 June 2017

2 Version Date Summary of Changes 1.0 July 2016 Completed CDBG-DR Manual 2.0 December 2016 Updated to reflect updated requirements 3.0 June 2017 Additional updates to ensure compliance with regulations and certifications, and to correct clerical and formatting changes. 2

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4 Table of Contents Policies and Procedures Manual Introduction Administrative Structure Public Law Requirements Timely Expenditure of Funds and Funding Deadlines Obligation Deadline Expenditure Deadline Timely Expenditure of Funds Citizen Participation and Website Management Action Plan Reporting Website Maintenance Citizen Complaints for Hurricane Isaac Disaster CDBG Grant Action Plan and Amendments Initial Action Plan Unmet Needs Analysis Action Plan Amendments Non-Substantial Action Plan Amendments Substantial Action Plan Amendments HUD Approval CDBG-DR Program Goals National Objective National Objective Documentation and Records Eligible Activities Tie to the Qualified Disaster Administrative and Planning Costs Program Delivery Activities Memorandums of Understanding Funding Restrictions Reporting DRGR Reporting Record Keeping, Retention and File Management

5 4.9.1 Personally Identifiable Information File Security Record Retention Access to Records Logistics Financial Management General Requirements Establish Internal Controls Federal Cost Guidelines Jefferson Parish Financial System Requests for Payments Subrecipients Vendors Subrecipient Pay requests Advance Payments Invoice Payment Process Step 1: Invoice Received by Jefferson Parish Step 2: Distribution Step 3: Project set up Step 4: Request Listing Step 5: Request Listing Approval Step 6: Saving Invoices on the Shared Drive Step 7: Invoice Upload to the Financial System Step 8: Requesting the Requisition Step 9: Approval of the Requisition Step 10: Invoice Package Step 11: Post Receipt Step 12: Complete Invoice Package Program Income Fidelity Bond Salaries and Wages Audits Procurement

6 6.1 Methods of Procurement Small Purchase Procedures Competitive Sealed Bids/Formal Advertising Sealed Bid Procedures Competitive Negotiation: Request for Proposals Qualification Statements Noncompetitive Negotiation/Sole source Request for Proposals Advertisement and Submission General Advisory Board Technical Evaluation Committee Contracting Contract Pricing Procurement Records Formal Council Approval Bonding Information Surety Bond Bid Bond Performance Bond Payment Bond Duplication of Benefits General Infrastructure Housing Assistance Program and Elevation Support Program Environmental Review Adoption of another Agency s Environmental Review Environmental Review for Housing Building Standards Green Building Standards Construction Standards Monitoring/Compliance Overview of Monitoring Objectives Roles and Responsibilities Risk Assessment

7 10.4 Entities to Monitor Contractors/Vendors Subrecipients Grantee Implemented Programs Areas to Monitor Program Review Financial Review Program Applicant Files Invoices Checklists to Utilize Monitoring Schedule Checklist Monitoring Checklists Types of Monitoring Desk Review Vendors/Contractors Subrecipients Grantee Implemented Programs Technical Assistance Onsite Monitoring Preparing for a Review Monitoring Strategy Letter Advance Review Performing a Review Entrance Conference Monitoring Process Exit Conference Monitoring Report Monitoring Response Monitoring Follow Up Anti Fraud Waste and Abuse Program Applicants Vendors Subrecipients

8 11.4 Internal Audit Cross-Cutting Federal Regulations Pre-Agreement Allowance Americans with Disabilities Act (ADA) Insurance and Property Management Davis-Bacon Labor Standards Force Account Labor Equal Employment Opportunity Fair Labor Standards Act of 1938, as Amended (FLSA) Minority- and/or Women-Owned Business Enterprises Section Fair Housing Limited English Proficiency (LEP) Uniform Relocation Act and Real Property Acquisition Real Property Acquisition of Real Property Civil Rights Requirements Equal Opportunity and Non-discrimination Inclusion of Equal Employment Opportunity ( EEO ) Provisions in Construction Contracts Section 504 Requirements Conflict of Interest Applicability Conflicts prohibited Closeout Final Performance Report Cover Sheet Financial Summary Status of Audits Program Benefits, Actual Accomplishments, and Direct Benefits Displacement (if applicable) Acquisition/Relocation (if applicable) Final Wage Compliance (if applicable) Interim and Final Closeout

9 Record Retention Closeout Introduction On May 29, 2013, HUD issued 79 FR 32262, allocating Jefferson Parish, Louisiana $16,453,000 of Community Development Block Grant Disaster Recovery (CDBG DR) funds from the Disaster Relief Appropriations Act of 2013 (Public Law 113 2). Following 79 FR and previous applicable Federal Register Notices under Public Law 113-2, Jefferson Parish Department of Community Development (JPDCD) will administer this funding to address the unmet needs that resulted from Hurricane Isaac, which struck Louisiana in August of This Policies and Procedures Manual provides guidance to the Parish and recipients that have received grant funding based on the methods of distribution described in the Action Plan. The manual covers housing administered by the Parish and infrastructure administered by its grantee, Jefferson Parish Department of Sewerage. The manual provides implementation detail to supplement the program information as provided in the Action Plan. 1.1 Administrative Structure The day-to-day management of the CDBG-DR funds will be administered by the Administrative Management Specialist IV (Disaster Recovery Program Manager) and the current staff of JPDCD staff will assist as needed. In addition, consultants will be retained to assist the staff with project management and monitoring. JPDCD will work closely with HUD and the State of Louisiana Office of Community Development Disaster Recovery Unit (OCD-DRU) as needed. 2. Public Law Requirements 2.1. Timely Expenditure of Funds and Funding Deadlines JPDCD has adopted procedures to ensure the timely expenditure of funds, track expenditures in each month, monitor expenditures of recipients, reprogram funds in a timely manner, and project expenditures over time. These tasks will be performed by the Disaster Recovery Program Manager. JPDCD is committed to ensuring that CDBG-DR funds are spent in a timely manner and within the statutory two-year period. To ensure such commitment, JPDCD establishes strict timelines and milestones within each of the agreements entered into with subrecipients, contractors, consultants and recipients of funds. These requirements and milestones will be specifically outlined in each agreement and will be designed to be specific to categories of funding Obligation Deadline Under PL 113-2, all grantees are required to obligate all CDBG-DR funds by September 30, 2017 unless a waiver is submitted and approved by HUD Expenditure Deadline 9

10 Per the March 5, 2013 Federal Register Notice 78 FR 14329, all grantees are required to expend funds within two years of obligation of funds. If a grantee will not meet this requirement, a written explanation must be submitted to HUD for approval. Following all deadlines, all funds under PL 113-2, all funds must be expended by September 30, 2019, unless applicable waivers are submitted and approved by HUD Timely Expenditure of Funds The Disaster Recovery Program Manager is responsible for ensuring the timely expenditure of all CDBG-DR funds including but not limited to tracking proposed expenditure versus actual expenditures, verifying all agreements have a clearly stipulated period of performance or completion date, and that all expected completion dates are accurately recorded in HUD s Disaster Recovery Grant Reporting (DRGR) system. If any target dates are not met, a reason will be documented in the DRGR narrative. The Disaster Recovery Program Manager works in conjunction with the Accounting Team, and Executive Director as needed to meet expenditure goals. 2.2 Citizen Participation and Website Management Public Law and subsequent Federal Register notices, requires Jefferson Parish and all grantees to maintain a public Web site which provides information accounting for how all grant funds are used, and managed/administered, including details of all contracts and ongoing procurement policies. 1 As grantees of Community Development Block Grant Disaster Recovery (CDBG-DR) funds, Jefferson Parish Government will use the JPDCD Disaster Recovery website as a tool provide transparency for all CDBG-DR projects. JPDCD s disaster recovery webpage provides a space for sharing with the public current information on CDBG-DR projects, the progress of individual projects, and updated reporting tracking allocations and expenditures for all CDBG-DR programs and projects. The Parish strives to provide a wide audience of stakeholders and other interested observers a real-time account of the recovery efforts being undertaken in their communities and a clear understanding of the how the Parish administers the efforts. JPDCD s website will also allow for input both from citizens of the Parish and other individuals and groups interested in the Parish s recovery. To that end, the Parish s webpage provides information on how individuals can provide feedback or ask questions related to the Parish s Hurricane Isaac recovery Action Plan JPDCD will make available via its Disaster Recovery website its initial Action Plan, all amendments to the initial Action Plan, and a master version of the Action Plan, which will be inclusive of all amendments. In addition, JPDCD will provide for the ability for the public to submit comments relative to the items covered in the initial Action Plan and subsequent amendments. JPDCD accepts comments on Action Plans and amendments via US mail, courier, facsimile, in person at public hearings, and via . ed comments are accepted through the Community Development address provided on the website Initial Action Plan The initial Action Plan will be posted to the Disaster Recovery website and made available for the public s review in accordance with federal regulations. Once the public comment period has expired, the Action 1 Allocations, Common Application, Waivers, and Alternative Requirements for Grantees Receiving Community Development Block Grant Disaster Recovery Funds in Response to Hurricane Sandy. Federal Register Vol. 78, No. 43,

11 Plan will be submitted to HUD for review and approval. Upon receiving approval from HUD, the date of approval will be clearly indicated on the Parish s website Amendments Substantial amendments to the initial Action Plan (i.e. those that result in a change in program benefit or eligibility criteria, the allocation or re-allocation of more than $1 million, or the addition or deletion of an activity) will be posted to the Disaster Recovery website and made available for the public s review in accordance with federal regulations. Once the public comment period has expired, the amendment will be submitted to HUD for review and approval. Upon receiving approval from HUD, the date of approval will be clearly indicated on the Disaster Recovery website. All substantial amendments will be translated into the languages identified by the Parish s four-point language analysis. JPDCD will notify HUD of non-substantial amendments to the initial Action Plan but will not post them to the Parish s website for public comment. Once HUD has acknowledged receipt of a non-substantial amendment or after five days have elapsed since the submission to HUD, JPDCD will post the nonsubstantial amendment to its website. All amendments (substantial and non-substantial) will be numbered sequentially and incorporated into the Parish s Master Action Plan Master Action Plan The Parish will maintain a Master Action Plan that will serve as a single point of reference with regards to its plans for utilizing the CDBG-DR appropriation. The Master Action Plan will incorporate all amendments and will be made available to the public via JPDCD disaster recovery website Public Comments In accordance with federal regulations and in the interest of ensuring that the public is afforded ample opportunities to provide feedback to JPDCD on its plans for the recovery effort, the Parish will make available multiple methods by which public comments can be submitted: address for a JPDCD Fax number for the JPDCD Office Mailing address for the JPDCD Office In-person at any public hearing The website will clearly identify the individual serving as the primary point of contact for all public comment related communications Link to Public Notices Links to HUD s webpage containing all of the applicable Public Laws, Federal Register Notices, and other related materials will be included in the Disaster Recovery Website. 11

12 2.2.2 Reporting Quarterly Performance Reports As required by HUD, JPDCD will complete a Quarterly Performance Report (QPR) detailing the expenditures, accomplishments, and beneficiaries associated with the appropriation of funding over each quarter. All quarterly reports are due to HUD on the 30 th of each month after a quarter ends. JPDCD will post the each QPR when it is submitted to HUD. Initially, the report will be labeled as Pending HUD Approval until the JPDCD receives notification from HUD that the QPR has been reviewed and accepted Expenditure Reporting JPDCD will also provide expenditure reports for each Disaster Recovery funded grant. Each report will be updated quarterly in the DRGR with the QPR and outline the obligated amount, expended amount, and remaining balance for the quarter CBDG-DR Programs JPDCD will provide a thorough list of Frequently Asked Questions that answer citizen s questions regarding on-going CDBG-DR funded projects Contracts JPDCD will post a link to the Jefferson Parish Contracts website where all copies of all executed contracts are available to the public. In addition, any substantial amendments to those contracts (e.g. contract value is increased or scope of services is revised) will be posted to the Parish s contract website. All postings will occur within 30 days of the contract (or amendment) being fully executed Points of Contact JPDCD Disaster Recovery Program Manager s (Disaster Recovery Program Manager) contact information will be posted to the Disaster Recovery webpage along with an address for all disaster recovery inquiries. If a material staffing change occurs, JPDCD will update the applicable item(s) within 30 days of the official change Accessibility of Information JPDCD recognizes the diversity of the residents of the Parish. To that end, JPDCD will translate vital program documents into the languages as needed and as determined by the completion of a Limited English Proficiency four factor analysis and make available individuals (both staff members and through a designated social service agency) that are able to communicate effectively with non-english speakers. In addition, the Jefferson Parish website as well as the Community Development, and Disaster Recovery website will utilize features allowing for automatic translation into the language of the reader s choice via Google translation services and for the adjustment of font size in order to accommodate the visually impaired Website Maintenance The Disaster Recovery Manager and the Community Development Director directs and supervises the content of the website. The Disaster Recovery Manager develops the narrative and visual content and is responsible for working with Jefferson Parish IT department to update the website, usually on a quarterly basis. 12

13 2.2.4 Citizen Complaints for Hurricane Isaac Disaster CDBG Grant Citizen complaints concerning activities carried out utilizing CDBG-DR funds can be submitted via one of the following contacts: Tamithia Shaw, Director Parish of Jefferson Department of Community Development 1221 Elmwood Park Blvd., Suite 605 Jefferson, LA (504) Christi Langoni Parishof Jefferson Department of Community Development Disaster Recovery Program Manager 1221 Elmwood Park Blvd., Suite 605 Jefferson, LA (504) Action Plan and Amendments 3.1 Initial Action Plan In accordance with Public Law and Federal Register Notice 79 FR issued May 29, 2013, the Parish must submit its initial action plan for Hurricane Isaac Recovery to HUD within 90 days after the release of the Federal Register Notice by HUD Unmet Needs Analysis Per the March 5, 2013 and May 29, 2013 Federal Register Notices, each grantee must conduct an unmet needs analysis. JPDCD with the assistance of consultants will develop the unmet needs analysis assessment to follow the HUD methodology and requirements in the notices. Each grantee must develop a needs assessment to understand the type and location of community needs to enable it to target limited resources to areas with the greatest need. At a minimum, the needs assessment must evaluate three core aspects of recovery housing, infrastructure, and the economy (e.g., estimated job losses). The assessment of emergency shelter needs and housing needs must address interim and permanent; owner and rental; single family and multifamily; public, HUD assisted, affordable, and market rate. For purposes of this Notice, HUD-Assisted Multifamily Housing is defined as housing that: (1)(a) is part of a multifamily housing property (defined as five units or more), and (b) assisted by FHA insurance; or (2)(a) Housing that receives project-based rental assistance under HUDs section 202, 811 or Section 8 programs; or (b) receives other HUD project-based rental assistance (e.g., Rent Supplement contracts, Rental Assistance Payments (RAP) contract Interest Reduction Payments (IRP) Agreements; or (3) properties that have active Deed Restrictions and/or a Use Agreement as a result of past HUD assistance. 3.2 Action Plan Amendments Non-Substantial Action Plan Amendments Per the March 5, 2013 Federal Register Notice, 78 FR 14329, Action Plans must also be amended to reflect any subsequent changes, updates, or revision of the projections. Amending Action Plans to accommodate these changes is not considered to be a substantial amendment Non-substantial amendment. The 13

14 grantee must notify HUD, but is not required to undertake public comment, when it makes any plan amendment that is not substantial. HUD must be notified at least five days before the amendment becomes The Department will acknowledge receipt of the notification of non-substantial amendments via within 5 business days. Non-Substantial Amendments provide clarity to current action plans and programs described with in them. The Disaster Recovery Program Manager will work with department leadership to draft all non-substantial amendments. All non-substantial amendments will be submitted to the Parish Council for approval prior to submission to HUD. The Disaster Recovery Program Manager will work with Parish IT staff the APA (and approval if it is in writing) posted it to the website Substantial Action Plan Amendments Per the March 5, 2013 Federal Register Notice, 78 FR 14329, At a minimum, the following modifications will constitute a substantial amendment: a change in program benefit or eligibility criteria; the allocation or reallocation of more than $1 million; or the addition or deletion of an activity. The grantee may substantially amend the Action Plan if it follows the same procedures required in this Notice for the preparation and submission of an Action Plan for Disaster Recovery. Prior to submission of a substantial amendment, the grantee is encouraged to work with its HUD representative to ensure the proposed change is consistent with this Notice, and all applicable regulations and Federal law. Additionally, as amended in the November 18, 2013 Federal Register Notice, 78 FR 69104, 8 FR of the March 5, 2013 Notice is modified to require grantees to publish substantial Action Plan Amendments for comment for 30 days prior to submission to HUD. Grantees are reminded of both the citizen participation requirements of that Notice and that HUD will monitor grantee compliance with those requirements and the alternative requirements of this Notice. In addition, this Notice establishes the requirement that at least one public hearing must be held regarding any substantial Action Plan Amendment submitted after the effective date of this Notice... Citizens and other stakeholders must have reasonable and timely access to these public hearings. Grantees are encouraged to conduct outreach to community groups, including those that serve minority populations, persons with limited English proficiency, and persons with disabilities, to encourage public attendance at the hearings and the submission of written comments concerning the Action Plan Amendment. When program and department leadership has determined that a new program will be created, change in beneficiaries for a program, or movement of over $1 million dollars as outlined in the federal register, it will be the Disaster Recovery Program Manager s responsibility to draft the substantial amendment. All substantial amendments are required to be approved by the Jefferson Parish Council prior to release for public comment. A public notice is required for the public comment period Public Comment Period All substantial amendments require a public comment period as outline above. Prior to a substantial amendment being released, the following items must be completed to ensure the Parish is prepared for the public comment period. Translation: Per the requirements of the Federal Notices, Jefferson Parish is required to translate all amendments into the languages which are identified through their LEP analysis and according to their 14

15 Language Assistance Plan (LAP). Jefferson Parish will utilize the translation tool on the Parish website and translate all documents with this function. Website: JPDCD will provide an address for the submission of public comments. Mail: Public comments may be received by mail or delivery service to the JPDCD office. Public Hearings: The following questions should be answered as the public hearings are finalized 1. When will the public hearing occur? 2. Where will the public hearing occur? 3. Who will staff the public hearing? DR team or JPDCD Planner? 4. Who will speak at the public hearings? DR team or JPDCD Planner? 5. Who will track the sign in information and ensure all that all who are there will speak or have their public comment accepted? 6. Who will take the written transcript of the public comments, then organize them and categorize for response in the APA? Public Notices: An Action Plan Amendment Summary should be written to be utilized in the public notices. The Disaster Recovery Program Manager will draft the summary and provide the necessary information to the JPDCD Planner to have the notice published in the Parish journal of record. Compiling of Public Comment: The Disaster Recovery Program manager is responsible for compiling and sorting all public comment into a data base that can then be responded to in an orderly manner. Note: many comments that will be received might not have and any connection with the Action Plan and should be noted in the public comment and then directed to the program (HAP, ESP or infrastructure). Response to the Public Comment: The Disaster Recovery Program Manager will draft all the responses to public comments Submission to HUD Once the amendment is finalized and all public comments are addressed, the action plan amendment will be submitted to HUD via the disaster recovery inbox. The Disaster Recovery Program Manager will be responsible for the submission and maintaining all electronic copies of the amendment HUD Approval A Non-Substantial Amendment is deemed approved after 5 days of receipt of the amendment by HUD. In every instance, receiving an approval from HUD in writing is the preferred method of communication, which the Disaster Recovery Program Manager will attempt to obtain. Per the November 18, 2013 notice, HUD has 60 days to approve all substantial amendments. It will be the responsibility of the Disaster Recovery Program Manager to track this timeline. The final date to submit substantial action plan amendments to HUD is June 1, 2017 to ensure approval prior to the September 30, 2017 obligation deadline. 15

16 4. CDBG-DR Program Goals To meet the U.S. Department of Housing and Urban Development s (HUD) disaster recovery objectives, Jefferson Parish has specifically designed programs to help impacted residents and communities to recover from the damage inflicted by Hurricane Isaac. As expressed in the Federal Housing and Community Development Act, the primary objective of the general CDBG program is the development of viable urban communities by providing decent housing and a suitable living environment and expanding economic opportunities, principally for persons of low and moderate income (LMI). CDBG funding appropriated in response to disasters must meet those general goals of the CDBG program. 4.1 National Objective All CDBG-DR funded activities, must meet one of the three national objectives required under the authorizing statute of the CDBG program: Benefit Low and Moderate Income (LMI) persons Aid in the prevention or elimination of slums or blight (Slum and Blight) Meet a need having a particular urgency (Urgent Need) Activities must also meet at least one CDBG-DR program eligible activity and funded projects must demonstrate a tie to one of the presidentially declared disaster events outlined in the Federal Register Notices, as well as within this manual. The CDBG-DR regulations state that a project is not considered as meeting a national objective until it is complete. This will require JPDCD to track each match project through completion and closeout phase National Objective Documentation and Records Program records must demonstrate that funded activities meet one of the national objectives. Depending on the national objective, the files must contain, at a minimum, the specific documentation in the table below. This specified documentation may also be used in reporting performance measures information. 4.2 Eligible Activities Activities must also meet at least one CDBG-DR program eligible activity listed below and funded projects must demonstrate a tie to one of the presidentially declared disaster events outlined in the Federal Register Notices. For a detailed overview of all CDBG, please refer to Title 24: Department of Housing and Urban Development Part 570 Community Development Block Grants Subpart C Eligible Activities. 2 Additionally, all CDBG-DR funded activities must meet one of the eligible activities outlined in Section 105(a) of the Housing and Community Development Act of 1974 (HCDA). 3 Eligible Activities include but are not limited to the following items: Disposition Public Facilities and Improvements Clearance Public Services 2 24 CFR Part 570 Community Development Block Grants

17 Interim Assistance Relocation Loss of Rental Income Rehabilitation Construction of Housing Code Enforcement Special Economic Development Activities Microenterprise Assistance Special Activities by CBDOs Homeownership Assistance Planning and Capacity Building Program Administration Costs Miscellaneous Other Activities Generally, the following types of activities are ineligible: Acquisition, construction, or reconstruction of buildings for the general conduct of government Political activities Certain income payments Construction of new housing (with some exceptions) 4.3 Tie to the Qualified Disaster All applicants and programs funded with CDBG-DR dollars must be able to demonstrate that they were impacted by Hurricane Isaac. 4.4 Administrative and Planning Costs Administrative costs are for staff-time and overhead costs for planning and general administration of the CDBG-DR program. Administrative costs cover the cost of planning, general management, oversight, coordination, and implementation of the CDBG program as a whole. These costs are capped at 5% of the overall grant. 4.5 Program Delivery Activities Program Delivery costs are allowable costs incurred for implementing and carrying out eligible CDBG-DR activities. Program delivery covers the costs of staff directly carrying out the activity in addition to equipment and supplies that are necessary for successful completion of the activity. These costs usually run about 15% of the activity costs. 4.6 Memorandums of Understanding JPDCD will enter into a written Memorandum of Understanding with any internal department implementing a CDBG-DR program. For Hurricane Isaac, JPDCD has entered into agreements with Floodplain Management and Hazard Mitigation and the Sewerage Department. 4.7 Funding Restrictions In addition to the 5% cap on administrative costs, all DBG-DR funds also have a 15% cap on Public Service activities. 17

18 4.8 Reporting As a recipient of CDBG-DR funds, JPDCD establishes reporting requirements for all subrecipients and contractors in their respective subrecipient and contractor agreements and contracts in accordance with 24 CFR (b)(2). Generally speaking, JPDCD monitors reporting requirements as required, but at least once during the life of a program. Subrecipients and contractors submit the documents and reports to the JPDCD at the times indicated in the subrecipient and grant and/or contract agreement, and in the format approved by JPDCD DRGR Reporting HUD uses the DRGR as the reporting and financial management system for HUD CDBG-DR grantees. Grantees use the system to drawdown funds and report program income. The Disaster Recovery Program Manager is responsible for all DRGR reporting outlined below. Figure 1-1 outlines JPDCD s DRGR process DRGR Action Plan In addition, each grantee is required to submit an Action Plan in DRGR describing the process that will be used to determine the areas of greatest need; the distribution and eligible uses of funds; a program budget; and the expected outcomes and benefits to low-, moderate-, and middle- income families Quarterly Performance Reporting Once an Action Plan is approved JPDCD may submit Quarterly Performance Reports (QPRs), which contain information about the uses of funds, activity types, demographics of households benefitted, budgets and locations of activities. QPRs are submitted via DRGR, and the data can then be used by HUD staff to review funded activities, prepare reports to Congress and other interested parties, and monitor program compliance. 18

19 Figure 1-1 JPDCD CDBG-DR Process JPDCD HUD Jefferson Parish Department of Community Development CDBG-DR DRGR Process Process for submitting updates to the DRGR Action Plan Estimated 30 days for Action Plan Process (including time for drafting, resubmittal and HUD approval). Updates to the DRGR Action Plan Do the budgets match the submitted Action Plan? Have all programs been updated with any changes? Once the DRGR Action Plan is submitted to HUD, the DRGR will be locked until approval or rejection by HUD. Submit DRGR Action Plan to HUD HUD review of DRGR Action Plan JPDCD program mangers and accounting staff make necessary edits to the Action Plan for resubmittal HUD approval of DRGR Action Plan OR HUD rejection of DRGR Action Plan Once the DRGR Action Plan is approved, the DRGR is unlocked and QPRs may be submitted to HUD. Process for submitting Quarterly Performance Reports QPR Data Gathering: program managers and accounting team provide the following information at the end of each quarter: Expenditures for the quarter. Beneficiaries receiving assistance for the quarter. Amount of program income generated. Narrative of activities performed for each program during the quarter. Estimated 60 days for each QPR Process (including time for JPDCD data gathering and submittal (or resubmittal if necessary) and HUD approval). JPDCD program managers and accounting team gathers all data and inputs it into the DRGR for the previous quarter. JPDCD program managers and accounting team reviews and submits QPR to HUD. (note: QPR is due 30 days after each quarter ends). QPR is posted on the parish Disaster Recovery Webpage (with the note: pending approval from HUD) JPDCD program managers, and accounting staff make necessary edits to the QPR for resubmittal HUD reviews QPR HUD Approves QPR OR HUD rejects QPR Infrastructure Reporting JPDCD will be the primary administrative entity for the Emergency Pump Out (EPO) Instillation Initiative and will be in charge of ensuring that program requirements and eligibility standards are met. The Department of Sewerage will report to JPDCD for overall oversight of the funding. The Jefferson Parish Department of Sewerage will submit Progress Reports as requested by JPDCD. Project activity will be reported only in the quarter in which it occurred and until completion of the activity. The Progress Report should provide: Recipient Implementation Schedule Project Status by Contracts Awarded Minority Business Status / Historically Underutilized Businesses Status 4.9 Record Keeping, Retention and File Management In accordance with HUD regulations, JPDCD as a grantee and recipient of CDBG-DR funds, follows the records retention as cited in 2 CFR Part , which includes financial records, supporting documents, statistical records and all other pertinent records are maintained for five years. JPDCD established requirements in its subrecipient and contractor agreements for compliance with all HUD cross cutting requirements outlined in 2 CFR 200 Appendix II, including record keeping requirements. For all 19

20 subrecipients, their retention of records shall be kept in accordance with 2 CFR Part , as modified by 24 CFR (a)(16), which requires for records to be maintained at least for a period of five years following the close out of all activities associated with each program. Every subrecipient and contractor is required to establish and maintain at least three major categories of records: Administrative, Financial, and applicant files (if applicable). Administrative records: These are files and records that apply to the overall administration of the subrecipient s CDBG-DR activities. They include the following: Personnel files; Property management files; General program files: Files relating to the subgrantee, subrecipient s, or contractor s application to the grantee, the subrecipient agreement, program policies and guidelines, correspondence with grantee and reports, etc.; and, Legal files: Articles of incorporation, bylaws of the organization, tax status, board minutes, contracts and other agreements. Financial records: These include the chart of accounts, a manual on accounting procedures, accounting journals and ledgers, source documentation (purchase orders, invoices, canceled checks, etc.), procurement files, bank account records, financial reports, audit files, etc. Project/applicant files: These files document the activities undertaken with respect to specific individual beneficiaries, property owners, and/or properties Personally Identifiable Information All files containing personally identifiable information (PII) which must be handled in a secure measure. To protect PII, files should be given a unique identification number. This identification number allows the programs to reference their files at any point in the program File Security Files should be safely secured in the JPDCD s office, a vendor, or a subrecipient s office. Files are secured to ensure privacy of all applicant PII located within the files. Originals and hard copies of records containing PII will be secured in locked filing cabinets Electronic files containing PII will be secured in password protect electronic folders Required reports to Stakeholders may include applicant names but will not include unique identifiers such as employee ID number, etc Record Retention Record retention is a requirement of the JPDCD. Records are maintained to document compliance with Program requirements and federal, State, and local regulations and to facilitate an audit review by HUD. Records are maintained in accordance with 24 CFR 570.3, which states they must be maintained for a period of 5 years following the closeout of the award to the Parish. Proper records management ensures that: 20

21 The Parish complies with all requirements concerning records and records management practices under Federal and State regulations; The Parish has the records it needs to support and enhance ongoing business and citizen service, meet accountability requirements and community expectations; These records are managed efficiently and can be easily accessed and used for as long as they are required; and These records are stored as cost-effectively as possible and when no longer required they are disposed of in a timely and efficient manner based on HUD Handbook , Records Disposition Schedules and HUD Handbook Access to Records The filing system the grantee establishes to keep records should be easy to use while providing a historical account of activities for examination and review by HUD, auditors, and JPDCD staff. The CDBG-DR records are subject to the Freedom of Information Act and relevant state laws regarding public availability. 24 CFR Recordkeeping requirements: (c) Access to records. (1) Representatives of HUD, the Inspector General, and the General Accounting Office shall have access to all books, accounts, records, reports, files, and other papers, or property pertaining to the administration, receipt and use of CDBG funds and necessary to facilitate such reviews and audits. (2) The State shall provide citizens with reasonable access to records regarding the past use of CDBG funds and ensure that units of general local government provide citizens with reasonable access to records regarding the past use of CDBG funds consistent with State or local requirements concerning the privacy of personal records Logistics The filing system should be established on a project by project basis. Files should, to the extent possible, be maintained in a central location. Files stored at offsite locations (e.g. a subrecipient s office or a Parish facility) must be made available to reviewers on an as needed basis Hard Copy Files JPDCD maintains hard copy (i.e. physical) files for all programs and projects. Hard copy files should contain all relevant records detailed in the checklists included in this section Electronic Files Electronic (i.e. digital) files serve as backups for all hard copy files and will contain additional documentation not required or not practical to include in hard copy files (e.g. informal correspondence and detailed draw request supporting documentation). To the greatest extent possible, JPDCD digitally stores all program and project records in accordance with the following workflow: 21

22 Document Received or Generated Document Electronically Imaged Document Saved in Electronic File Document Added to Physical File Establishing Project Files The checklists are crucial in maintaining orderly files. Appendix A provides examples of file checklists which represent the major file categories that should be maintained and a listing of materials that should be kept in each physical file. Electronic files should contain, at a minimum, identical documentation to the physical files; however, it is the physical files that must be complete and accurate at all times. Once complaints are received, the respective office will investigate and refer to the appropriate party. If required a written response will be provided within days of completion of the investigation. 5. Financial Management The financial requirements for recipients and vendors receiving CDBG-DR grants or funds are governed by regulations issued by the Federal Office of Management and Budget ( OMB ) and HUD. Recipients are required to comply with the uniform administrative requirements as defined in the regulations. 5.1 General Requirements Separate accounting records must be maintained for all CDBG-DR project funds (i.e., separate from regular municipal/parish funds or other entity funds). These records should, to the extent possible, be developed to be consistent with the recipient s general accounting system. JPDCD uses the AS400 financial management system. The AS400 is the system of record for Jefferson Parish. All federal and non-federal funds are tracked through this system. JPDCD Accountants and key program staff are responsible for ensuring all items listed in this section are followed and implemented per this manual. Additionally, they are responsible for responsible for communicating upward to the JPDCD Director any operating problems or noncompliance with laws and regulations. Further detail around reporting fraud, waste, and abuse is outlined in section 11 of this manual. As the grantee, JPDCD, as well as those administering CDBG-DR disaster recovery resources; continuously demonstrate conformity with financial management requirements as required by the HUD in 78 FR (published March 5, 2013). These requirements include, but are not limited to, areas covering: Financial Management; Advances; Internal Controls; Accuracy of Report Information; Program Income; Salaries and Wages; Indirect Costs; Lump Sum Drawdowns; and 2 CFR 200. The Jefferson Parish Financial System is consistent with and in compliance 2 CFR Part 200, and 570 (as applicable), which ensures that the Parish s CBDG-DR funds are managed with high levels of accountability and transparency. 5.2 Establish Internal Controls The recipient should establish internal controls that provide for responsible management of the DR funds. The JPDCD Accountant III (Account Supervisor) is responsible for ensuring the internal controls of the 22

23 department are documented and followed by all staff members. The system of internal controls should meet the following criteria: All conflict of interest provisions apply. No person who has carried out any functions as part of the CDBG-DR Program, or who are able to participate in a decision-making process, or gain inside information on such activities, may obtain a financial interest or benefit from the activity. No person will have complete control over every phase of a significant transaction. For example, the person who authorizes payments to contractors should not draft and issue the payment check. Fiscal record-keeping for the DR contracts should be maintained separately from the general accounting operations. Monthly bank reconciliation and/or direct deposit monthly statements should be made by someone who is not responsible for handling cash or issuing checks. Persons issuing checks for grant expenses should not also handle payroll preparation/issuance of paychecks. 5.3 Federal Cost Guidelines The financial requirements for local governments and vendors receiving CDBG-DR grants or funds are governed by regulations issued by the OMB and HUD. Costs will be reviewed to ensure they are both necessary and reasonable. 2 CFR 200 outlines these costs guidelines. JPDCD Accounting and Program team work together to ensure that all CDBG-DR expenditures meet the federal costs guidelines. 5.4 Jefferson Parish Financial System The AS400 is the current platform used by Jefferson Parish to manage all accounting processes. The JPDCD Accountants are responsible for ensuring the data entered into the Financial System is accurate and up to date. The JPDCD Accountants coordinate with the Parish Accounting Department to set up all projects in the Financial System. The AS400 includes a full chart of accounts for the entire parish. Specifically, JPDCD has a complete chart of accounts for all federal funding including CDBG-DR funding in the system. Additionally, the JPDCD Accountants are responsible for entering any budget adjustments and change orders into the system. The Parish provides ongoing training to staff to ensure that all finance are tracked properly into the AS Requests for Payments Subrecipients Subrecipients (i.e. the Department of Sewerage) may drawdown for eligible costs as often as is actually needed, with the provision of a minimum amount for a draw down request. The exceptions to this rule are as follows: The drawdown exceeds 25% of a budgeted line item and the recipient is requesting funds only for that line item; The recipient is requesting funds for the final retainage of a construction contract; The recipient has received prior approval from the Disaster Recovery Program Manager; or The request is the final drawdown. Subrecipients must disburse funds within a maximum of three calendar days from the time of receipt/deposit of funds to the time of actual local disbursement. Subrecipients should base their draw downs on local cash needs to facilitate prompt disbursement and avoid monitoring findings. 23

24 A grantee should submit the Request for Payment and the Purchase Voucher along with any back-up documentation. The back-up supporting documentation must justify payment for each budget line-item from which CBDG-DR funds will be drawn. Requests for payment will not be processed unless acceptable back-up supporting documentation is provided. Any questions relating to the preparation of invoice forms should be referred to the Parish. The primary reviewing of pay requests submitted by subrecipients is the responsibility of the Program Managers. The Accountant Supervisor follows up to review the account coding before submission of the Direct Expenditure Requests to the Parish Accounting Department Vendors Vendors may invoice for eligible costs once per month per grantee. There is no minimum that a vendor may drawdown monthly as long as the billing doesn t exceed the eligible amount per milestones. Specific invoicing instructions for vendors will be provided by the Parish Subrecipient Pay requests All requests for payment from governmental and non-governmental subrecipients for JPDCD must be supported by the following documentation: Request must be accompanied by a completed Jefferson Parish Finance Payment Request Form which has the Program Director s signature approving the contents of the Request for Payment. Support for the Requests for Payment should be submitted in duplicate; one copy for Community Development files and one to be forwarded for the Accounting Department approval. o Non-payroll expenses should be supported by paid invoice or periodic bill for service. If o unavailable, a copy of canceled check with a written description will be acceptable. Claims for salaries and wages must be supported by copies of attendance, gross pay, pay rate time hours worked, and payroll tax. Allocated expenses in an approved budget must be documented by a written description of the method of allocation and a summary of the expenses allocated. Invoices and payroll records are required to be retained at the subrecipient s place of business for monitoring examination for a minimum of three years after expiration of the subrecipient agreement Advance Payments It is not standard practice for JPDCD to request a funding advance from the federal government. However, if there are circumstances where advances are needed by a subrecipient, the Parish will consider these on a case by case basis. If approved, subrecipients must deposit all funds in a non-interest bearing account, and provide the parish with bank statements or cancelled checks within 15 business days of the receipt of the advance. 24