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The Ins and Outs of CDBG Homeowner ReimbursementApril 2, 2015; 8:30 a.m. – 10 a.m.
Leslie Bean, Housing Manager
Agenda
• Introduction
• Federal Requirements
• Program Implementation
• Best Practices
• Lessons Learned
• Document Guide
Introduction
• Federal Register Volume 78, No. 43, March 5, 2013 states “ The provisions of 24 CFR 570.489(b) are applied to permit a State to reimburse itself for otherwise allowable costs incurred by itself or its recipients sub-grantees or sub-recipients on or after the incident date of the covered disaster.
•
Introduction
• CPD-13-05 B. Generally Applicable Terms:
HUD will permit grantees to charge to grant the pre-award and pre-applications costs of homeowners for eligible costs they have incurred in response to a Presidentially-declared disaster.
For Rehabilitation and Reconstruction costs, grantees mayonlycharge costs for activities completed within the same footprint of the damaged structure.
Costs must be adequately documented
A duplication of benefits check must be completed before providing assistance.
Introduction
• “The ultimate measure of a man is not where he stands in moments of comfort, but where he stands at times of challenge and controversy.”
Martin Luther King Jr.
Federal Requirements
• National Objectives:
Low and Moderate Income (LMI)
Urgent Need
• Davis-Bacon
Not required but check with local/state building code departments
• Civil Rights Requirements
504, Americans w Disabilities Act, Fair Housing
Federal Requirements
• Environment Grantee is responsible for completing the environmental reviews in
accordance to Federal laws including Section 106
Lead-Based Paint Rule applies to homes built prior to January 1978. A housing unit can be exempt if:
The homeowner undertook CDBG-eligible activities that qualify as emergency actions necessary to safeguard against imminent danger to human life, health /safety, or to protect the property from further structural damage. (see 24 CFR 35.115(a)(9).
The rehab did not disturb any painted surface
An inspection performed found to property contained no lead-based paint
Lead paint had been identified, removed and cleared.
Property is meets the “housing for the elderly definition” or “persons with disabilities” but no child 6 years or under resides in the home. (see 24 CFR 35.110)
Federal Requirements
• Duplication of Benefits (DOB)
Section 312 of the Robert T. Stafford Disaster Assistance and Emergency Relief Act (42 U.S.C. 5155) prohibits any person, business concern, or other entity from receiving financial assistance with respect to any part of a loss resulting from a major disaster as to which he has received financial assistance under any other program or from insurance or any other source
Program Implementation
• Develop program policies
The policies should reflect the action plan.
Be careful not to include procedures in the policies
Consult with other communities
Ensure the policies are approved by all applicable parties
*Remember-You must have procedures identifying how you plan to verify and monitor the policies.
Program Implementation
• Develop Procedures DOB
Acceptable Documentation
Verification of Sources
Allowable/Unallowable Expenses
Income
Part 5
1040
Self Certification
Document Control
MIS
Paper Files
Version Control
Program Implementation
• Develop Procedures (cont….)
Due Diligence
Homeowners that apply but never provide appropriate documentation
Unable to verify documents through a 3rd Party
Appeals
Process, Forms, Letters, Tracking
Quality Control
One level or Two levels?
Beginning, Middle, End?
Best Practices
• Develop program policies and procedures before starting program and accepting applications
• Streamline the process
• Promote program through various avenues
• Develop Tracking Systems
• Develop program policies and procedures before starting program and accepting applications
Lessons Learned
• Do not set up this program to mimic a rehab/reconstruction program
• Policies should not more stringent that local/state/federal requirements
• Properly review the receipts the first time
• Hire extra staff to just make copies of receipts
Document Guide(Index)
• CPD-13-05, July 30, 2013
• Disaster Relief Appropriations Act, 2013
• 24 CFR 58.5 and 58.6
• 2 CFR part 225
• FR Vol. 78 No. 43, March 5, 2013
• FR Vol. 76 No. 221, November 16, 2011
• www.hud.gov