Recent IDIS Changes Affecting
HOME Participating Jurisdictions
Presenters
• Ginny Sardone, Acting Director, Office of Affordable
Housing Programs (OAHP)
• Peter Huber, Director, Financial & Information
Services Division (OAHP)
• Vashawn Banks, Affordable Housing Specialist
(OAHP)
• Kevin Roddy, Technical Director, ICF International
Agenda
• Open Activity Flags
– Open Activities Report (IDIS PR48)
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Edit to activity completion date
Changes to the commitment certification
New CHDO certification
Program income enhancements
New Deadline Compliance Status Report
– (IDIS PR49)
• Questions
Open Activity Flags
• Background
IDIS Landing Screen
Activity Flags Page
Activity Flags Page, Continued
Activities with Infrequent Draws
• This edit applies to all open HOME activities.
• The system flags activities with some funds
disbursed, but no disbursements in the past
12 months.
– Activities with $0 disbursed are auto-cancelled after 12
months.
• The PJ must enter a reason and narrative
explanation or its ability to set up or commit
funds to HOME activities is suspended.
Activities with Infrequent Draws
• Reasons from the dropdown menu include:
• project progressing toward completion
• project start was delayed
• project is stalled.
• The system will require the PJ to update the
reason and narrative every 180 days until the
activity is completed.
Activities with Infrequent Draws
Activities with Infrequent Draws
Potential Solutions:
• Identify multiple eligible costs to reimburse
over the development/construction phase
– Do not limit to single item i.e. acquisition
• Consider charging “project delivery” for staff
costs over project development/construction
phase
• If multiple sources of funding – develop
project draw schedule
Activities in Final Draw > 120 Days
• This edit applies to all open HOME activities.
• 24 CFR 92.502(d)(1) states: Complete project
completion information must be entered into
the disbursement and information system, or
otherwise provided, within 120 days of the
final project drawdown. If satisfactory project
completion information is not provided, HUD
may suspend further project set-ups or take
other corrective actions.
Activities in Final Draw > 120 Days
• The system flags activities that have been in
final draw for 120 days.
– Warning flags appear when an activity has been in final
draw for 30 days and 90 days.
• If the activity is not completed or cancelled
after 120 days in final draw, the PJ’s ability to
set up and commit funds to new HOME
activities will be suspended.
Activities in Final Draw > 120 Days
Activities in Final Draw > 120 Days
Potential Solutions:
• Hold final payment of developer fee until
initial occupancy (rental) or sale (homebuyer)
• Include “project delivery” costs for staff labor
effort up front at activity set up
• Consider disbursements on a “pro-rata” basis
for project with multiple funding sources
Involuntarily Terminated Activities
• This is a project completion deadline.
• The system flags all open HOME activities with
initial funding dates more than four years old.
• These open activities are considered
terminated before completion and, absent an
extension or a waiver, HOME funds repaid.
• Currently, edit applies only to all 2012 HOME
activities.
• Edit will apply to all activities committed after
the new HOME rule is in effect.
Involuntarily Terminated Activities
• For all other activities the flag is currently for
information purposes only.
• Does this mean you don’t have to do anything?
– Yes. As long as the activity is progressing toward
completion, not in final draw, and not disbursing funds
infrequently.
– No. If the activity will not be moving forward or is
temporarily stalled, please contact your field office
CPD rep. to discuss options.
• Activities meeting this criteria will be blocked by
HUD and will require repayment and cancellation.
Involuntarily Terminated Activities
Involuntarily Terminated Activities
Potential Solutions:
• Develop detailed project schedules that reflect
milestones to monitor project progress
• Incorporate clear enforcement mechanisms in
written agreements to hold funded entity to
realistic, clear project schedule
• Use “reduction of developer fee” as possible
sanction for slow projects
Open Activities Report
• The IDIS PR48 Open Activities Report now
identifies the three categories of flagged
HOME activities.
– Activities in final draw for more than 120
days.
– Activities with infrequent disbursements.
– Activities considered involuntarily
terminated.
Open Activities Report
Completion Date Edit
• Implemented May 4, 2012 for all activities.
• Completion date defaults to current date the
first time the activity status is changed to
“completed”.
• Completion date defaults to the current date
if the activity is re-opened and completed
again.
• System will not allow the user to enter a
completion date prior to the initial
completion date.
Completion Date Edit
Potential Solutions:
• Establish formal “trigger” mechanism for
rental projects to start affordability period –
incorporate IDIS completion process step
• Incorporate “trigger” mechanism in written
agreement
– Formal notification – “start of affordability period”
– Including “vacant” units OK
Revised Commitment Certification
• Currently applies to 2012 HOME activities
only.
• User must certify that it has conducted an
underwriting review; assessed developer
capacity and fiscal soundness; and examined
neighborhood market conditions to ensure
adequate need for project prior to committing
funds to a HOME activity in the system.
Revised Commitment Certification
CHDO Capacity Certification
• The system will require a user certify that a
CHDO has demonstrated development
experience prior to receiving an award of
CHDO set aside funds in the system.
• The certification will appear each time CR
funds are subgranted to a CHDO eligible
organization in IDIS.
• Currently applies to FY 2012 CHDO
reservations (subgrants) only.
CHDO Capacity Certification
Program Income: PA Fund Type
• A new fund type called “PA” allows up to ten
percent of PI receipted by PJs to be expended
on admin activities
• PJs can also subgrant PA funds to state
recipients and subrecipients
– Functionality only available for 2012 HOME grants
and later
• Background on PA Subfund
Program Income: PA Fund Type (cont.)
Program Income: PA Fund Type (cont.)
Subgranting Program Income
• PJs are now able to subgrant program income
to state recipients and subrecipients
– Applies to any grant year that has PI funds
available
• Process is almost identical for subgranting
both PI and PA
– same screens as CHDO Reservations and SU
subgrants
Subgranting Program Income
Home Deadline Compliance
• HOME Deadline Compliance Status
Report implemented as the IDIS PR49
report.
• Allows for near “real-time” compliance
checking.
• HUD will continue to post this report to
the HOME Reports website monthly.
Home Deadline Compliance
How to Ask a Question
• Change status in Live Meeting from green to
purple
• Press *1 to ask a question through Premiere
Conference
– Provide Name and Organization
– If question already answered, press *2 to
remove from queue
• Change status back to green after question
answered
• Can also use Live Meeting Q&A function
• We may not get to every question asked
Questions?
• For more help:
– Field Office CPD Rep.
– www.hud.gov/homeprogram/
– www.hometa.info
– Help Desk
• 877-483-8282
• IDIS.HELP@hud.gov