Symposium on Homelessness
Homeless in the Heartland
GRANT ADMINISTRATION
August 2013
Financial
Management
SHOW ME THE MONEY
Financial Grant Management
3
 Grant Agreement
 Application
 Certifications
 Program Regulations
 Approved Budget
 Uniform Administrative
Requirements
 OMB Circulars
Uniform Administrative Requirements
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For each type of recipient, there is a set of Federal
principles, called Uniform Administrative
Requirements, which determine allowable costs for
grants.
 24 CFR part 84 –Institutions of
Higher Education, Hospitals, and
Other Non-Profit Organizations;
 24 CFR part 85 –State, Local,
and Federally Recognized Indian
Tribal Governments
OMB Circulars
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In Addition, the Office of Management and Budget
(OMB) publishes the allowable costs for all grant
recipients in their Circulars.
 2 CFR part 230 - Cost Principles for
Non-Profit Organizations (OMB
CircularA-122)
 2 CFR part 225 – Cost Principles
for State, Local and Indian Tribal
Governments (OMB Circular A-87)
Drawing Funds
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 Drawing funds to
reimburse the recipient for
eligible costs incurred and
already paid…..OR
 Drawing funds for eligible
costs incurred but not yet
paid.
Tips on Drawing Funds
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 Draw consistently (develop a process to draw every
month or at a minimum every quarter)
 Draw the pennies (VRS will let you draw cents, so be
a * and draw the exact amount you need)
 Track exactly what costs are being paid with the
drawn funds
Source Documentation
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 Utility Bills
 Supply Invoices
 Maintenance





Receipts
Equipment Receipts
Leases
Insurance Bills
Cost Allocations
Time Sheets
More Documentation
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 Tenant Rent Calculations and Payments
 TIME SHEETS (Detailed as possible, i.e. client #s,
description of work performed, budget item
charged, etc)
 Transportation Logs
 Contracts with providers
What This Grant Reviewer Likes To See
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 Well organized files – I really like to ask and receive
all documentation for a particular draw in one
bundle
 Spreadsheets – I feel the love when I see
spreadsheets with real time data tracking expenses
and payments by approved budget line items.
Policies and Procedures
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 Policies – Write it Down! Organize It! Share it with
Staff!
 Policies/Procedures I ask about on Monitoring
Review (Questions on Checklist)
1. Recording Financial Transactions/Accounting
Manual/Chart of Accounts
2. Authority for Approving Financial Transactions
3. Controlling Expenditures/Purchasing
Requirements/Travel Authorizations
4. Maintenance of Accounting Records
Documenting Match
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 The match requirements under the CoC Program
interim rule are simplified from the SHP and the
S+C program.
 All eligible funding costs, except leasing, must be
matched with no less than a 25 percent cash or
in-kind contribution.
 No match is required for leasing.
 Resident Rent can no longer
be used for match.
Documenting Match
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Cash Sources
 May use funds from any source, including any other
federal sources (excluding Continuum of Care program
funds), as well as State, local, and private sources,
provided that funds from the source are not statutorily
prohibited to be used as a match.
 Must ensure that any funds used to satisfy the matching
requirements of this section are eligible under the laws
governing the funds in order to be used as matching
funds for a grant awarded under this program.
Documenting Match
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In-Kind
 For an in-kind match, the value of property,
equipment, goods, or services contributed to the
project may be used, provided that, if such items
were paid for with grant funds, the costs would have
been eligible.
 If third-party services are to be used as a match, the
recipient or subrecipient and the third-party service
provider that will deliver the services must enter into
a memorandum of understanding (MOU)—before
the grant is executed.
Documenting Match
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 Keep records of the source and use of cash and in-
kind contributions used to satisfy the 25 percent
match requirement (24 CFR part 578.73).
 Match records must indicate the grant and fiscal year
for which each matching contribution is counted.
Questions
19
Environmental Reviews &
Continuum of Care
Does My Grant Require An Environmental
Review?
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 All grants require an Environmental Review

24 CFR 578.31 (CoC Program)

24 CFR 583.230 (SHP Program)

24 CFR 582.230 (S+C Program)

24 CFR 576.407(d) (ESG Program)
 A responsible entity (RE) (Part 58) or HUD (Part 50) must
complete the review and make a determination of the
level of review.
 The RE must create an environmental review record with
verifiable resources and documented findings for each
project.
 A non-profit may not act as an RE.
Responsible Entities
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 Responsible Entity (RE) assumes federal
responsibilities
 RE = a unit of general local government, tribe or
State
 Responsible Entity Certifying Officer
Evaluates the environmental review
 Is responsible for scope and content
 Makes environmental finding
 Goes to court in a lawsuit

What Is an Environmental Review?
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 Analysis of the impact of a
project on the surrounding
environment and vice versa
 Ensures that HUD-funded
projects provide decent, safe,
and sanitary housing
 MUST be conducted
BEFORE funds are
committed
HUD’s Environmental Regulations
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 24 CFR 50 – HUD Review
 Environmental review requirements for
HUD staff
 24 CFR 51 – Manmade Hazards
 Noise
 Explosive or Flammable Hazards
 Runway Clear Zones
 24 CFR 55 – Floodplains & Wetlands
 24 CFR 58 – Local Government Review
 Environmental review requirements for units of general local
government (“Responsible Entity”/”RE”)
Part 58 vs Part 50
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Part 58
 Program legislation
permits local government
to conduct ER
 RE certifying that
environmental review is
complete
 Accepts comments. After
public comment period,
RE applies to HUD for
release
 HUD authorizes release of
funds
Part 50
 HUD conducts
environmental review
 HUD determines that
local government does not
have capacity or refuses to
accept responsibility for
review
 Grantee may collect any
information required to
complete the review from
applicant, as long as HUD
staff remain responsible
for accuracy of the review
When Part 50 Reviews Are Required
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 “If a responsible entity, other than a recipient,
objects to performing an environmental
review... HUD may designate another
responsible entity to conduct the review in
accordance with this part or may itself
conduct the environmental review in
accordance with the provisions of 24 CFR part
50.” (24 CFR 58.11(d))
 HUD assumes responsibilities for
environmental reviews for SNAPS projects
only where (1) a nonprofit is the recipient
and (2) no responsible entity can be found.
Level of Review
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Environmental Impact
Statement
Environmental
Assessment
Categorically Excluded
Subject to 58.5/50.4
Categorically Excluded
Not Subject to 58.5/50.4
Exempt
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REFERENCE GUIDE FOR COC LEVELS OF REVIEW
Reference Guide for CoC Program Component Levels of Review
Levels of environmental review:
EXEMPT : Subject to §58.6
CENST :
Categorically Excluded, Not Subject to §58.5 (Still subject to §58.6)
CEST :
Categorically Excluded, Subject to §58.5 (Also subject to §58.6)
EA :
Environmental Assessment (May require an Environmental Impact Statement (EIS) if any conditions in §58.37 apply; also subject to §58.5 and §58.6)
* Where the Level of Environmental Review is labeled as “EXEMPT or CENST” the responsible entity has the discretion to determine whether the activity is more appropriately categorized
as an activity listed at §58.34(a)(4) (Exempt) or §58.35(b)(2) (CENST). Part 50 does not include an EXEMPT category – all applicable activities should be categorized as CENST.
CoC Program Components and Activities
Level of Environmental Review
Applicable §58/§50 Citations
PERMANENT HOUSING (including PSH & RRH) & TRANSITIONAL HOUSING
Acquisition (§578.43), Leasing (§578.49), Sponsor-Based Rental
Assistance, & Project-Based Rental Assistance (§578.51(d), (e))
CEST (If your project includes acquisition, leasing, sponsor-based rental assistance or
project-based rental assistance, the level of environmental review increases to CEST.)
§58.35(a)(5)
§50.20(a)(4)
New construction (§578.47, 578.37)
CEST (If your project includes: a) new construction of up to 4 housing units with
maximum of 4 units on any one site; or b) 5 or more housing units on scattered sites
2,000 ft. apart and not more than 4 units on any one site, the level of environmental
review increases to CEST.)
§58.35(a)(4)(i);
§58.35(a)(4)(ii)
§50.20(a)(3)(i);
§50.20(a)(3)(ii);
EA (If your new construction project does not meet the criteria at §50.20(a)(3) or
§58.35(a)(4), the level of environmental review increases to EA.)
§58.36
§50.16
CENST
§58.35(b)(1)
§50.19(a)(11)
CEST (Required for rehabilitation projects that do not result in a change in land use or
will not change the size or capacity by more than 20 percent)
CEST:
§58.35(a)(3)
CEST:
§50.20(a)(2)
Tenant-Based Rental Assistance (§578.51(c))
Rehabilitation (§578.45)
EA (Required for rehabilitation projects where the criteria at §50.20(a)(2) or §58.35(a)(3) §58.36
are not met.)
Supportive Services (§578.53)
EXEMPT or CENST*
Operating Costs (except repair and scheduled payments to a
reserve for replacement of major systems of housing) (§578.55)
CENST
§50.16
§58.34(a)(4) or
§58.35(b)(2)
§50.19(a)(4)
§50.19(a)(12)
§58.35(b)(3)
§50.19(a)(13)
Limited Scope Environmental Reviews
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 Used for leasing, project-
based rental assistance
 Require minimal analysis:
1.
2.
3.
Coastal Barrier Resources
Coastal High Hazard Area,
Floodway, and Floodplain
Toxic Hazards
Conducting a Limited Scope Review
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 HUD will request information for each site from
recipient using the new form.
 HUD will review the information and documentation
and confirm that project conforms to HUD’s
environmental policies.
 HUD will certify the review.
Request & Review Info from Recipient
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Coastal Barrier Resources and
Coastal High Hazard Areas
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 Coastal Barrier
Resources Long, narrow
islands and back bay
barriers – the first line of
defense for storm surges.
 Coastal High Hazard
Areas (V Zone): area
subject to high velocity
waters from hurricanes or
tsunamis.
 HUD will reject any project
located in the Coastal
Barrier Resources System
or Coastal High Hazard
Areas.
Floodways and Floodplains
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 Floodways: portion of floodplain
which is effective in carrying flow,
where the flood hazard is generally
greatest, and where water depths
and velocities are highest.
 100-Year Floodplains: areas
where each year there is a 1 percent
chance of flooding. Being in these
areas puts people at risk
 HUD will reject any project
located in a Floodway and may
reject projects in 100-year
floodplains.
Example of a FIRM
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Toxic Chemicals and Radioactive Material
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 It is HUD policy that all property
proposed for use in HUD programs be
free of hazardous materials,
contamination, toxic chemicals and
gases, and radioactive substances, where
a hazard could affect the health and
safety of occupants or conflict with the
intended utilization of the property
 24 CFR 50.3(i) & 58.5(i)(2)
 A report of nearby toxic sites using EPA’s mapping
service at http://www.epa.gov/enviro/index.html or
similar service
Examples of Site Contamination
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36
Landfills
Unexplained dirt piles
Buried Waste
Underground Tanks
Take-Away Messages
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 All grants require an environmental review
 Funds cannot be committed, obligated, or expended
prior to the completion of the environmental review.
 The RE must create an environmental review record
with verifiable resources and documented findings
for each project.
Questions
38
Emergency
Solutions Grant
[ESG]
RENT REASONABLENESS AND FAIR MARKET RENT
Rent Reasonableness And Fair Market Rent
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ESG allows short-and medium-term rental assistance
to be provided to eligible program participants only
when the rent, including utilities (gross rent), for the
housing unit:
 Does not exceed the Fair Market Rent
(FMR) established by HUD for each
geographic area; and
 Complies with HUD’s standard of rent
reasonableness.
This requirement is in the ESG program
Interim Rule at 24 CFR 576.106(d).
Rent Reasonableness And Fair Market Rent
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HPRP & ESG: Key Difference
 HPRP: Rent must meet rent reasonableness
standards.
 ESG: Rent must meet rent reasonableness standards
and cannot exceed HUD’s published FMRs for the
area.
 In some communities, the reasonable rent for a
specific unit may be lower than the FMR that has been
established for the community.
 Bottom line: The rent for the unit assisted with ESG
funds must not exceed the lesser of the FMR or the
rent reasonableness standard.
Calculating the Gross Rent
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To calculate Gross Rent:
Total contract rent amount of the unit
 Add any fees required for occupancy under
the lease (excluding late fees and pet fees)
 Add the monthly utility allowance

What Is The FMR Requirement
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HUD establishes FMRs to determine payment
standards or rent ceilings for HUD-funded
programs that provide rental assistance
 Published annually for metropolitan areas
and non-metropolitan county areas.
 Published on October 1 each year
 www.huduser.org/portal/datasets/fmr.html
What Is The Rent Reasonableness Requirement
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HUD’s rent reasonableness standard is designed to
ensure that rents are reasonable in relation to rents for
comparable unassisted units in the same market.
 If a rent reasonableness determination supports a
lower rent, then ESG funds may not be used to rent
the unit (unless the landlord is willing to lower the
rent).
 ESG funds could be used to assist the
program participant to move to a
different unit.
Determining and Documenting Rent Reasonableness
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 Recipients are responsible for determining what
documentation is required in order to ensure the
rent reasonableness standard is met.
A
market study of rents.
 Advertisements
 Written
for comparable rental units.
verification signed by the property owner,
on letterhead, affirming that the rent is comparable
to current rents charged for similar unassisted
units managed by the same owner.
Determining and Documenting Rent Reasonableness
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 Recipients must establish their own written policies
and procedures for documenting comparable rents
and ensure that they are followed when documenting
rent reasonableness in the case file.
 A sample “Rent Reasonableness Checklist and
Certification” form is available at:
www.hud.gov/offices/cpd/affordablehousing/
library/forms/rentreasonablechecklist.doc
Determining and Documenting Rent Reasonableness
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Determining and Documenting Rent Reasonableness
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 Before conducting its own study of rent levels, a
recipient/subrecipient should consult existing
sources of rental housing data that can be used to
establish comparable rents.
 Public Sources (PHA, Chamber)
 Real estate advertisements and contacts
 Rental market study
 Rental market survey
 Rental database
Rural Housing Data Sources
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 While there may be fewer rental units in rural areas
than in urban and suburban areas, it is possible to
find comparable rents for different unit types located
in these areas using various data sources, including:
 U.S. Department of Agriculture’s Rural
Development Agency (USDA)
 PHAs
 Real estate agents
Components Of An Effective Policy
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 Policies and procedures must be transparent and
consistently applied across the program, and result
in decisions that comply with HUD requirements. At
a minimum, an effective policy includes:
 methodology,
 documentation
 staffing
requirements,
assignments, and
 strategies
for addressing special circumstances.
Components Of An Effective Policy
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 Policies and procedures should provide step-by-step
guidance on making comparisons between the
program participant’s rent, the FMR, and the rent
reasonableness standards for comparable units in
that community.
 This includes the documentation to be included in
each case file, such as forms and/or case notes.
Questions
52