COMMUNITY DEVELOPMENT BLOCK GRANT (CDBG) Subrecipient Workshop

COMMUNITY DEVELOPMENT BLOCK GRANT (CDBG) Subrecipient Workshop

CDBG Subrecipient Training CDBG Overview Grant Requirements Client Files Administration Monitoring Considerations Anticipated Timeline Application

CDBG Program & Purpose Authorized under Title I of the Housing and Community Development Act of 1974 US Department of Housing and Urban Development (HUD) Develop viable urban communities by providing decent housing, a suitable living environment, and expanding economic opportunities, principally for persons of low and moderate income Provides flexibility to address a wide range of community needs

CDBG Overview

CDBG Overview Entitlement Community Annual CDBG Allocation (FY 2016-17 allocation $5,286,263) 15 % Public Service Cap Subrecipients: Entities that are provided CDBG funds to use in carrying out agreed upon eligible activities

Requirements Public Services eligible under 24 CFR 570.201(e) National Objective Benefit to Low and Moderate Income Individuals or Households City of Santa Ana Strategic Plan Goal Consolidated Plan Priority Need Crime prevention, intervention, and/or suppression efforts for children, youth and/or families Minimum funding request of $30,000

National Objective Activities that benefit low- and moderate-income persons 24 CFR 570.208(a) 51 % of participants must be low- and moderate-income Failure to document compliance with the National Objective specified for your grant may result in the disallowance of costs (i.e. the repayment of grant funds or the denial of invoices submitted)

National Objective - LMC Presumed Groups 24 CFR 570.208(a)(2)(i)A Abused Children, battered spouses, elderly persons, individual with disabilities, homeless persons, illiterate adults, persons living with AIDS, and migrant farm workers Documentation Identification, drivers license, or birth certificate to document age Documentation establishing that the facility or service is designed for and used by the presumed group Intake assessment during the application process *Example: a senior meal program or domestic violence shelter

National Objective - LMC Require Information on Family Size and Income 24 CFR 570.208(a)(2)(i)B & C Require income so that it is evident that at least 51% of the clientele are persons whose family income does not exceed the L/M limit Documentation Data showing the number of household members and annual income of EACH MEMBER over the age of eighteen, living in the household, that contributes income to the household Check stubs, public assistance documentation *Most common for public services

National Objective - LMC Nature and Location 24 CFR 570.208(a)(2)(i)D Have income eligibility requirements which limit the activity exclusively to L/M persons Documentation Documentation describing how the nature and the location of the facility or service establishes its use, predominantly by L/M income persons * Example: Providing services in an affordable housing development to affordable housing development residents

National Objective - LMA Area Benefit 24 CFR 570.208(a)(1) An activity, the benefits of which are available to all the residents in a particular area where at least 51% of the residents are low and moderate income Documentation The boundaries of the service area generally defined using census tracts and block groups Logs of activities conducted in the area and justification for how they benefit all residents * RARE FOR PUBLIC SERVICES - Example: A neighborhood watch program

Reimbursement Grant Cost Reimbursement Agreement Insurance Required: General Liability in the amount of $1,000,000 naming the City of Santa Ana as Additional Insured, Auto, Workers Compensation Santa Ana Business License Quarterly request for reimbursement for direct costs associated with the program Only eligible expenses listed in the agreement budget will be reimbursed

Reimbursement Invoices due quarterly for reimbursement Q1: JUL 1 - SEP 30 (Due OCT 15) Q2: OCT 1 - DEC 30 (Due JAN 15) Q3: JAN 1 - MAR 30 (Due APR15) Q4: APR 1 - JUN 30 (Due JUL 15) Invoices must provide documentation of expenditures Invoices paid 30 days upon receipt. *ERRORS ON INVOICES OR MISSING DOCUMENTATION WILL DELAY THE REIMBURSEMENT. INCORRECT OR INCOMPLETE INVOICES MAY BE RETURNED FOR CORRECTIONS.

Reimbursement Documentation Must provide documentation for expenses for reimbursement: Salaries: Timecards with all hours worked, payroll records, benefits statements, canceled checks Material and Supplies: Invoices, canceled checks, procurement documentation Other Costs Must present a cost allocation plan to be approved by City of Santa Ana Finance Department Indirect Costs: Federally approved Indirect Cost Rate or a 10% de minimus applied per 2 CFR 200

Client Files Client file should include the following items: Intake Form containing all HUD-required information Client-Qualifying Documentation (If Applicable) Proof of service provided to the client sign-in sheets, case worker s write-ups, etc.

Client Intake Does the intake form collect all HUD-required information? Household Size Household Income Name, age and income of all family members residing in the household Female Head of Household Race/Ethnicity Age Verification (if Presumed Benefit 62 or over) Disability (if Presumed Benefit)

John Smith 07/15/14 123 Main St. Santa Ana XXXXX 000 000-0000 myemailaddress@yahoo.com 00/00/00 14 X X The participant name must be that of the person who is receiving the service. Please verify that one (1) box is checked in each section. X X The date must be within the current CDBG Program Year (07/01/17-06/30/18) Please verify that Verify the that applicant the applicant signs, or circles head of the household correct is household signing the size intake and form income if the amount. applicant is under 18 years old. Applicant Name Guardian Name Staff Name X Guardian Sign Staff Sign 07/15/14 07/15/14 07/15/14 The person who verifies that the information on the intake form is correct must date, print and sign their name

SAMPLE PAYSTUB Use gross not net amount when calculating income. Weekly - 7 day pay period, multiply avg. gross by 52 Bi-Weekly 14 day pay period, multiply avg gross by 26 Bi-Monthly - 1st 15th and 16th to 30th/31st multiply avg. gross by 24

An example of a person who receives a week, bi-weekly and semi-monthly paycheck. Please obtain three (3) paystub amounts. 400.0 0 423.0 8 John Smith Sr. 375.0 378.8 0384.6 5 2 500.0 Brenda Smith 0461. 0.00 54 208.3 Stacy Smith 3 0.00 208. 0.00 33 1,153. 85 20,00 0.24 923. 12,00 08 0.04 208. 4,999.9 33 2 2 1 384.6 2 461. 54 208. 33 Please be sure to verify the household size and income are correct on the applicant intake form. $ 37,000.02

Qualifying Documentation If presumed, client eligibility supporting documentation: Statement of abuse (abused children/battered spouses) Age verification (elderly persons) Statement of disability (severely disabled persons) Statement of homelessness (homeless persons) Program Determination of Literacy (illiterate adults) Statement of Medical Condition (persons living with AIDS) Verification of Migrant Farm Worker Status (migrant farm workers) If limited clientele: Income documentation for all persons working in the household

Income Limits Program must serve at minimum 51% low- and moderateincome individuals. The HUD Income Limits are revised each program year. Typically this has been in the month of December. The income limits are based on the area median income (AMI) adjusted for household size. For the CDBG Program, the maximum household income allowable is 80% of the AMI adjusted for household size.

HUD FY 2016 Income Limits FY 2016 Income Limit Area Median Income FY 2016 Income Limit Category Persons in Family 1 2 3 4 5 6 7 8 Very Low (50%) Income Limits ($) 34,150 39,000 43,900 48,750 52,650 56,550 60,450 64,350 Orange County Effective 2/28/16 $85,000 Extremely Low Income Limits ($)* 20,500 23,400 26,350 29,250 31,600 33,950 36,730 40,890 Low (80%) Income Limits ($) 54,600 62,400 70,200 78,000 84,250 90,500 96,750 103,000

Proof of Service Documentation demonstrating dates and/or services provided: Sign-in sheets Case worker write-ups Access to client tracking database/or printouts

Quarterly Performance Reports Required to report programmatic accomplishments by the 15th day of the month following the end of each quarter Reports must report new clients served Q1: JUL 1 - SEP 30 (Due OCT 15) Q2: OCT 1 - DEC 30 (Due JAN 15) Q3: JAN 1 - MAR 30 (Due APR15) Q4: APR 1 - JUN 30 (Due JUL 15) NOTE: If the 15th falls on a weekend or a City-recognized holiday, the documents must be submitted on the following business day no later than 9:00 A.M.

Administration Program files must be maintained by the subrecipient: Contract/Amendments Program Polices and Procedures Financial Data Quarterly Performance Reports

Program Polies and Procedures Overview of program Client eligibility requirements Client intake and client files Annual income guidelines Submittal of Quarterly Performance Reports

Financial Policies and Procedures Internal Controls Financial Procedures Time and Effort Procurement

Federal Requirements CDBG program requirements 24 CFR 570 Eligible activities, ineligible activities, national objectives, grant administration, other program requirements, record keeping Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards 2 CFR 200 Cost principles, standards for financial and program management, procurement standards, record retention, audit requirements, indirect costs

Personnel Expenses - 2 CFR 200 Standards for Documentation of Personnel Expenses 200.430 Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: Be supported by a system of internal control - accurate, allowable, and properly allocated Be incorporated into the official records Reasonably reflect the total activity for which the employee is compensated Encompass both federally assisted and all other activities compensated by the nonprofit Comply with the established accounting policies and practices Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award;

Procurement Standards - 2 CFR 200 General procurement standards 200.318 Must use organizations policy and procedure AND Must comply with federal requirements SAM.gov check for contracts Competition 200.319 Full and open completion Methods of procurement to be followed 200.320* Micro Purchase (Under 3K) - No soliciting competitive quotes Small Purchase (3K+) - Quotations (3 recommended) Competitive proposals (150K+) - Formally advertised *MUST ENSURE ORGANIZATIONS POLICY IS FOLLOWED

Allowable Expenses Necessary, allocable and reasonable for the administration of the program. Salaries (timecards, payroll record, proof of payment) Benefits (statements, proof of payment) Material & Supplies (invoices, proof of payment) Rent (cost allocation plan must be approved by the City) *MUST BE INCURRED DURING THE AGREEMENT PERIOD TO BE ELIGIBLE FOR REIMBURSEMENT

Unallowable Expenses Equipment Food - except for a meal program Late fees, fines Political activities/lobbying * SEE GENERAL PROVISION FOR SELECTED ITEMS OF COST FOR FULL LISTING 200.420 et. al.

Subrecipient Monitoring The City is required to monitor subrecipients. It fulfills this responsibility by: Desk Monitoring: Examination of QPRs and Reimbursement Requests Technical Assistance: Provision of workshops and/or individualized technical assistance On-Site Monitoring: A comprehensive on-site programmatic and financial monitoring visit Single Audit Review: For organizations expending $750K+ in federal funds

Subrecipient Monitoring What happens if a subrecipient monitoring results in findings? Subrecipient will receive detailed explanation of the regulatory violation and a required corrective action to resolve the deficiency City may provide technical assistance May require third-party professional service providers to resolve (i.e. accountants) May have CDBG grant suspended or terminated if left unresolved

Considerations Does your organization have the capacity to administer the program: Internal controls Experienced staff Cash flow due to quarterly reimbursements Will your organization be able to document the national objective of a benefit to low and moderate income individuals: Collection of income documentation for all family members Documentation of a presumed benefit activity

Anticipated Timeline Date MAR 8 MAR 9 Action Applications Due by 5:00 PM Staff Review MAR 10 Community Redevelopment & Housing Commission (CRHC) review MAR 22 CRHC Public Hearing & Nonprofit Presentations MAR 29 CRHC Ratings Due APR 5 APR 18 JUN 15 CRHC funding recommendations City Council Public Hearing & Recommendations Execute Agreements

www.santa-ana.org/cdbg

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Tips Ensure questions are thoroughly answered Ensure correct and complete documents are uploaded *Excel budget templates have TWO worksheets/tabs that must be complete. Don t wait until the last minute to submit the application *City will not accept late applications. It is the nonprofits responsibility to ensure sufficient time is allotted for unexpected computer glitches.

Q&A Q&A will be posted on: www.santa-ana.org/cdbg Summit questions via email to: CDBG-ESGgrants@santa-ana.org

Thank You