FY2015 States
& Small Cities
CDBG Update
for
COSCDA
March 17, 2015
Pamela Glekas Spring, Director
States & Small Cities Division
Office of Block Grant Assistance
State CDBG
Update
Key topics that were
covered included:
OMB Super Circular
Moving from FIFO to
Grant-Based
Accounting
Section 108 Fee-based
Summary
Using the American
Community Survey
data for CDBG projects
Demo on the Low
Moderate Income
tate CDBG– Key Topics
 National Disaster
Resilience
Competition
 FY2015 Program
Budget
 Section 108 FeeBased Summary
 LMISD Notice and
Data
 OMB Super
Circular
Implementation
 Moving from FIFO
to Grant-Based
National Disaster
Resilience
Competition
Announced by the President June 14, 2014
• Qualifying disaster in 2011, 2012, or 2013
• 67 potential applicants – states, local
governments, District of Columbia, and
Puerto Rico
• Includes local governments that received
HUD CDBG-DR funding under PL 113-2
• Applicants must tie proposal to qualifying
disaster
• Competitive program with a focus on
resilience and recovery
Resilience
Competition
(continued)
Notice of Funding Availability (NOFA)
• Launch – NOFA release,
webinars, etc
• Total of $1 billion
available - $181
million reserved to
Sandy-region
• Geographic diversity
considered in the
selection
• Minimum grant size
$1M – Maximum $500M
• Deadline for applications extended to March 27,
2015 & review of the applications will begin late soon
thereafter
FY 2015 CDBG
Program Budget
• President’s CDBG
Request - $2.8
billion
• Final Budget
figure - $3
billion for
States &
Entitlement
areas (~ 1.5% less
than 2013)
• $900 million for
States & Small
Section 108 FeeBased Summary
Background
 2014 HUD Appropriations Act authorizes HUD to collect fees
from borrowers
 Proposed rule would amend Section108 regulations to permit
HUD to collect fees from borrowers to offset the costs of Section
108 loan guarantees
 Fee is intended solely to offset credit subsidy cost, and
determined accordingly
Current Status
 A Rule/Notice published in Federal Register Thursday 2/5/15 as a
proposed rule w/30-day public comment period (shortened public
comment period to ensure HUD will not exhaust credit subsidy prior to
Rule being in place);
 Comment period expires Monday 3/9/15
Low/Moderate
Income Summary
Data
 Historically, Low/Moderate Income (LMI) data was derived from
decennial long-form census
 In 2010 – Census’s long form was replaced by American Community
Survey (ACS).
 American Community Survey (ACS) is a mandatory, ongoing statistical
survey that samples a small percentage of the population every year -giving communities the information they need to plan investments and
services.
 This was a problem for Entitlement grantees since CDBG regulation
requirements are based on block groups as geographic building blocks.
 So far a while grantees were told to keep using 2000 Census-derived data.
 A VICTORY! HUD appealed to Census & (for the most part)
won, so HUD received 2006-2010 ACS data at the block group, but not for
split block groups.
 Ultimately, as a result of ACS replacing the Census long form, IDIS had to
be revised to accommodate more frequent/multiple years’ worth of data
 In June 2014, HUD issued CPD Notices 14-10 and 14-11, implementing new
LMISD for States and Entitlements (respectively).
Income Summary
Data
(continued)
 Census Bureau releases new data each year — you can get the latest on
American FactFinder website, or get advice on choosing the right tool or
data table for your needs. Learn more about the annual Census data
releases or browse the supporting documentation. Go to
www.census.acs.gov
 The new ACS data must be used to qualify all LMI area benefit activities
for which funds are first obligated after July 1, 2014 (meaning under
contract for a specific activity and a specific dollar amount)…
 …unless it meets the 4-part test to determine whether the old data can
still be used:
1.
2.
3.
4.
Funds were obligated before July 1
For a specific activity identified in the Action Plan
For a specific dollar amount
With a clearly defined service area.
Income Summary
Data
(continued)
For the future
 Presently, HUD intends to issue new LMISD every 5
years. Census has advised us that it is not a good
thing to use data sets that have overlapping years,
that we should run data based on mutually-exclusive
5 year datasets.
 HUD has observed that the ACS data jumps around a
lot. We will continue to monitor the ACS data over
time to determine if it still makes sense to issue new
LMISD every 5 years.
New Government Wide
Financial Management
Requirements
aka “OmniCircular”
The “Omni Circular” or Super Circular replaces
multiple existing regulations and OMB circulars: A87, A-110, A-122, A-133, Parts 84 & 85
Also included in this circular are updated
requirements that apply consistently to grantees,
subrecipients, nonprofit organizations, across all
grant programs
State CDBG remains partially exempt because they
were never subject to Part 85 – but are subject to
the provisions that replace A-87, A-133, etc.
Federal Agencies were directed to have
implementing regulations in place by 12/26/14.
Financial Management
Requirements
aka “OmniCircular”
(continued)
This means HUD will be issuing regulations that
replace Parts 84 & 85 and incorporate the other
Circulars.
These changes will also require conforming
regulation changes to other regulations that crossreference the various financial management
requirements…like recordkeeping requirements.
OMB & various other sources already have
webinars, training materials, FAQs, etc.
HUD anticipates the need for cross-programmatic
training for grantees once these are out.
(FIFO) & Moving to
Grant Based
Accounting
HUD’s OIG and OMB have determined that the First In
First Out (FIFO) drawdown process does not comply
with federal financial standards. The FIFO
drawdown process predates IDIS – it’s been used since
the beginning of the CDBG program in 1975.
A memorandum detailing this change was sent on May
9, 2014 to all CDBG grantees from Acting Assistant
Secretary Cliff Taffet
This will affect all formula CPD programs beginning
with FY15 funding. FY14 and earlier funding will
stay on a FIFO drawdown process. This means the
drawdown process will become a bit more complicated
First Out (FIFO) &
Moving to Grant Based
Accounting (continued)
For FY15 funding and thereafter, you will draw down
money for a specific activity (as you do currently, but
rather than drawing on all available money from your line
of credit, you will designate a specific year allocation in
funding an activity.
As an example, if you are drawing down $100,000 for
an FY15 Action Plan activity, the money will come out of
your FY15 allocation amount.
For the States grantees, you an breathe a small sigh of
relief – this means somewhat less of an imposition for you
because states have always operated more on a discrete
grant year by grant year basis than on a cumulative
approach.
Stabilization
Program (NSP)
Closeout Update
• Notice & Guide
• Website
materials
• Readiness checks
• Progress to date
• No deadline to
close your grant
• Special note for
NSP-2 grantees
Recent Policy
Issuances
 Some relevance for States as a reference: CPD Notice 13-07
issued August 2013: Clarifies the distinction between Activity
Delivery Costs and Program Administrative Costs.
A State may decide to adopt or follow the notice in allowing their UGLG’s to have
“activity delivery costs” State may also use this guidance as an “interpretive
reference” for their program admin costs
 Closeout Notice 14-02 issued February 2014: Closeout
instructions for NSP, for CDBG-R, for State CDBG and for Entitlement
CDBG. All but 19 CDBG-R grants closed out as of 9/30/14.
 Code Enforcement: CPD Notice 2014-16, issued October
2014. Clarifies use of national objectives, delineating
‘deteriorated/deteriorating areas’ that code enforcement must be
targeted to, issues of eligible/allowable costs & documentation.
 HUD plans to issue a companion set of FAQs related to the Code
Enforcement Notice
.
HUD’s Future
Directions
 HUD’s New Secretary -Julian Castro
 Secretary Castro well versed w/CDBG funding
as a former Mayor of San Antonio & has
publically stated his support for the program
 The FY2016 budget will be the first policy
imprint Secretary Castro has on longer term
directions for HUD’s programs
40th Anniversary
of CDBG Program





HUD’s Housing & Community Development Act enacted into law Aug
22,1974 as one of the first acts of former President Gerald Ford
HUD launched a 40th Anniversary Page in 2014 featuring your best
practices! HUD Launched 5 new video and multimedia products that
showcase the CDBG program and its flexibility
Collaborating with TA Provider to bring 20 more learning products
in 2015-2016!!!!
Coming Soon – New Web portal on the HUD Exchange to submit
project profiles. HUD encourages grantees to showcase how your
community has been helped by CDBG by either emailing
CDBGturns40@hud.gov or tweet it with the hashtag
#CDBGturns40
THANK YOU – for sharing your inspirational stories that remind
people what a great program CDBG is.
Wrap-Up
Pamela Glekas
Spring
Director
State and Small Cities Division