Community Development Block Grant (CDBG) Program 2009-10 City of Lee s Summit Pre-application Orientation 10:00 A.M. January 22, 2009 Strother Conference Room Lee s Summit City Hall
Agenda Staff presentation o o o o o o o o o o CDBG --- general introduction Consolidated Plan and Action Plan Core process Project proposals Eligible activities & ineligible activities Technical assistance upon request and standard procedure Project selection process and criteria Consolidated Plan, Annual Action Plan & CAPER Environmental review Conflict of interest
Agenda Cont. Staff presentation o Subrecipient grant agreement o Timeliness o Performance measurements & recordkeeping & reporting burdens o Subrecipient performance monitoring program o City s general requirements for subrecipients o Application Form and Attachments A&B o Important dates & mandates Questions & comments
CDBG Community Development Block Grant Federal entitlement program under the Department of Housing and Urban Development (HUD) that provides annual grants on a formula basis to entitled cities and counties to develop viable urban communities by providing decent housing Providing a suitable living environment expanding economic opportunities, principally for low- and moderate-income persons.
CDBG Grant History Lee s Summit Year Grant Amt. 1995 $344,000 1996 $318,000 1997 $341,000 1998 $345,000 1999 $348,000 2000 $357,000 2001 $375,000 2002 $367,000 2003 $370,000 2004 $367,000 2005 $351,780 2006 $318,234 2007 $319,531 2008 $309,700 Total $4,831,245 $390,000 $370,000 $350,000 $330,000 $310,000 $290,000 $270,000 Grant Amt. 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008
Consolidated Plan & Action Plan Entitlement communities are required to develop a 5-year consolidated plan (CON Plan) through a public participation process The CON Plan identifies and prioritizes the needs of the community and establishes goals and objectives as a basis for grant allocation Entitlement communities are also required to develop an annual action plan to implement the CON Plan by allocating the annual grant funds to execute eligible activities to achieve the established goals and objectives
C o r e P r o c e s s
Project Proposals Important Points to Remember With few exceptions, do not aggregate activities Activities with different service areas Activities with different clientele Activities with different scope of work Activities with drastic timing difference Avoid bundling activities that meet different national objectives (Example: Providing job training for LMI persons and financial assistance to those who need to replace their home heating and cooling system) Do not bundle activities some of which are eligible and some are not (Example: Reconstructing a parking lot and filling some minor cracks in the sidewalk) Evaluate your recordkeeping and reporting burdens Evaluate your staff capacity Evaluate your real needs and timing (Receiving funds one year does not increase your chances to receive them again the following year for the same program. Skipping a year, likewise, does not mean that you are less likely to receive funds in future years for the same program)
Eligible Activities and Ineligible Activities Eligible Activities Acquisition of real property (for a public purpose other than the general conduct of government) Public facilities and improvements (all facilities and improvements either publicly owned or owned and operated by a nonprofit open to the general public) Privately-owned utilities Public services Interim assistance Rehab of residential and non-residential structures Homeownership assistance Administration cost of running an eligible CDBG program and activity Planning and capacity building
Eligible Activities and Ineligible Activities Cont. Ineligible Activities Activities not meeting a National Objective, even if they are listed by HUD as eligible activities Acquisition, construction or reconstruction of buildings for the general conduct of government Political activities Construction of new housing (unless by authorized Community-based Development Organizations) Any costs not directly related to the implementation of the activity described in the approved application Administrative costs that are considered excessive and unreasonable
Technical Assistance Upon Request Starting this year, staff assistance will be made available to those prospective applicants who make a formal request to the City To be fair, staff assistance is available to everyone Assistance will be limited to the following Informing, interpreting, and explaining to the clients of the eligibility rules and regulations Helping the clients in their understanding of a desirable CDBG activity administration system Helping the clients in their understanding of their recordkeeping and reporting responsibilities Helping the clients with their drafted proposals in the area of meeting the national objectives and eligibility
Technical Assistance Upon Request Technical assistance will not do the following Draft a program or project for clients Do a complete review of clients proposals and offering feedback Do cost estimates for clients Provide a guarantee that the proposal or a portion of it will be funded under prescribed conditions Provide surveys and engineering services Conduct cost-benefit analysis for clients
Project Selection Process Staff reviews the applications for completeness and eligibility Staff tabulates the requests Staff performs in-depth reviews and provides funding recommendations Council CDBG Committee holds a public hearing for application presentation and recommendation (3/25 in Council Chambers) Staff compiles the complete Action Plan draft 30-day public review and comment period City Council (full council) ordinance to approve the Action Plan (5/7)
Selection Criteria Meeting both HUD s eligibility criteria and the National Objectives Meeting the community needs identified in the CON Plan Meeting the goals and objectives established in the CON Plan Funding availability and caps Applicant s ability to execute the program Applicant s readiness and timeliness Other risk factors, such as past performance
CON Plan, Action Plan & CAPER What are they? CON Plan --- We already know Action Plan --- We also know CAPER --- Stands for Consolidated Annual Performance and Evaluation Report An annual report prepared by the City and due to HUD 90 days after every program year Summary of all the activities that incurred costs within the program year Summary of accomplishments Summary of financial transactions and obligations Report of beneficiaries
CON Plan Goals and Objectives Eliminating and Preventing Homelessness Preserving Affordable Housing Develop Quality Housing Adequate Public Housing Promote Accessibility Economic Development Historic Preservation Public Facilities Public Infrastructure Public Services Anti-Poverty Strategy Other Community Development Needs
Environmental Review The Grantee (City) is required by HUD to complete an environmental review for every activity to be funded with CDBG No other persons or agencies should assume the responsibility of environmental reviews No activities should start and incur costs before the required environmental review is complete
Environmental Review CDBG-assisted activities fall under the following categories: Exempt (no compliance required) Categorically excluded activities not subject to 58.5 (may be converted to Exempt) Categorically excluded subject to 58.5 (Statutory Checklist, Public Hearing and Request for Release of Funds required) Activities requiring full environmental assessment
Federal Law on Conflict of Interest The law 24 CFR 570.611: Is intended to protect the reputation of the CDBG program from even the appearance of providing special treatment or serving a special interest Says The conflict of interest provisions of apply to any person who is an employee, agent, consultant, officer, or elected official or appointed official of the recipient, or of any designated public agencies, or of subrecipients that are receiving funds under this part. As HUD interprets, says that all employees (regardless of the departments that they work for) of 1) an Entitlement; 2) a State; 3) a unit of general local government receiving CDBG funds from the State or 4) a subrecipient, [along with the other persons described at 570.611(c)] are considered covered persons under the conflict of interest provisions
Subrecipient Grant Agreement All subrecipients must review, understand and sign grant agreements pertaining to their projects as a condition to use CDBG funds Grant agreements outline the scope of the projects to be executed, funds budgeted, rules to follow and responsibilities of the subrecipients throughout the execution of the projects
Timeliness HUD requirements Grantee responsibilities Subrecipient responsibilities What does this all mean? How can un-timeliness be prevented?
Performance Measurements & Recordkeeping and Reporting Performance measurement system key indicators to show the program s effectiveness and results to increase service quality to improve public accountability to measure accomplishments Recordkeeping and reporting requirements are an important component of the system In addition to the basic recordkeeping requirements, subrecipients are required to maintain and report beneficiary records in the following key areas (not all of the following applicable to all activities): Racial categorization Number of persons in the family and total annual family income Female head of households Number of persons having access to new facilities or services Number of persons having access to improved facilities or services
Performance Measurements & Recordkeeping and Reporting Things to consider as an applicant Does your agency like this system and all the requirements? Does your agency have a system already in place to comply with those requirements? Will your clients object to giving away that information in order to receive that service to be funded with CDBG grant? Does your agency have the staff level to bear the burden? Does your agency s available resources allow you to do that? Can you get your board of directors to support using the agency s resources to do all this? And so forth
Subrecipient Performance Monitoring Program City is required to incorporate a subrecipient monitoring plan in its annual action plan Monitoring can happen anytime during the program year Normally monitoring plan is also incorporated in the subrecipient grant agreement Subrecipients are notified in advance about the monitoring and what to monitor Monitoring is not intended to be a gotcha but rather a preventive and corrective measure to improve performance and ensure compliance
City s General Requirements for Subrecipients Attend required orientations, education workshops and meetings to discuss subrecipients projects Execute the projects in a timely manner Maintain and report project records and data per HUD regulations Invoice the City at least quarterly with all the required documentation Report beneficiary information to the City on a quarterly basis satisfactory to HUD Communicate with the City on a regular basis
Quotes from HUD Both partners (Grantees and subrecipients) must accept the fact that there is no such thing as a free lunch. In return for Federal funding, grantees and subrecipients agree to comply with the laws and regulations governing the use of those funds Playing by the Rules, p. vi In using Federal funds the cardinal rule is: documentation. The achievement of program goals and the completion of activities must be supported by adequate documentation of the facts. Playing by the Rules, p. vi
2009 Application Form and Attachments A & B This year s application form includes one form and two attachments (A & B) A complete application must include all three Major changes this year no significant changes from last year
2008 Application Form and Attachments A&B Review the form and attachments
2009 Application Information Packet
The application information packet and the forms are available on the City s website for download in both Microsoft Word and pdf formats There is also information on this website that will help you understand CDBG and helpful links are also provided there for you to review HUD regulations and requirements Web address: www.leessummit.mo.us and follow CDBG program on the lefthand side of the screen
If your program is funded You must sign a subrecipient agreement with the City HUD will issue an Activity Number for your program and you are required to refer to that number every time anything needs to be processed for that activity You are required to keep records of everything required by HUD and the City You are required to submit to the City data on the records you maintain at least every quarter
Important Dates Event Date Notes Application Deadline Feb 27 Before 5:00 P.M. CDBG Community Public Hearing March 25 3:30 P.M. Council Chambers Council Ordinance Approving Action Plan May 7 Council Regular Meeting Time Action Plan Submitted to HUD May 15 45 days prior to the starting date of the program year Grant Award Letter to Applicants Program Year Starts July 1 After Council Ordinance Approval Environmental Review Before or After July 1 Grant Agreement Meetings After City Receives Approval from HUD Approved Activity Can Start After ER is Complete Usually on-going public services do not need to stop for HUD approval.
CDBG Pre-Application Orientation Thank you for your participation Questions & Comments