Fiscal Year 2014 Indian Community Development Block Grant
Fiscal Year 2014 Indian Community Development Block Grant (ICDBG) Program NOFA Training Part 1 1
What’s New in 2014 • • • Two categories of funding New way to slice the pie New ways to determine LMI Points for spending past funds Points for shovel-ready projects Points if not funded in the recent years 2
Today’s Agenda • Part 1 - “Regular” ICDBG grants • Part 2 - New funds for mold remediation and prevention 3
Today’s Agenda (cont) • Part 1 – Purpose and overview of ICDBG – Eligible applicants, uses, and requirements – How to submit applications – Screening and rating factors 4
Today’s Agenda (cont) • Part 2 – Criteria in NOFA – definitions, rating factors, scoring – Overview of mold health effects, assessment and remediation – Where to find help 5
Two Categories • Can apply for and receive both • Can use both categories for same project or different types of projects 6
Available Funds • • Total is $70, 000 Single Purpose Grants - $56, 219, 222 Imminent Threat - $3, 960, 000 Mold Remediation - $10, 000 7
Authority • Title I of the Housing & Community Development Act of 1974 (42 U. S. C. 5301 et seq) • ICDBG regulations, 24 CFR part 1003 8
Program Description To develop viable Indian and Alaska Native communities by creating decent housing, suitable living environments & economic opportunities primarily for LMI persons 9
Types of Grants • Imminent Threat Grants • Single Purpose Grants (including grants for mold remediation and prevention) 10
Imminent Threat Grants • No Area Office allocations • Funds used to remove imminent threats to health or safety • Must meet regulatory criteria 11
Imminent Threat Grants • Criteria for funding – Threat must be independently verified – Must not be recurring – Must impact entire service area – Only granted if other tribal or federal funds not available 12
Imminent Threat Grants • Application – Area ONAP will issue Letter to Proceed only if no environmental impact and for improvements to control or arrest threat – Reimbursement only if HUD approves application – Applications must include information in NOFA 13
Imminent Threat Examples • • • Asbestos removal Replacement of failed water system Home repairs from floods Mold remediation Uranium in wells 14
New Definitions • Mold Remediation and Prevention – Mold is visible growth of fungi on surfaces – Remediation includes long term solutions – Prevention means action taken if mold is present in minute amounts to prevent more 15
New Definitions • Tribally owned or operated housing – Means housing that is currently owned or operated by an Indian tribe or TDHE, or was previously assisted with HUD funding – Applies to Category Two projects for mold remediation 16
Old but Key Definition • New Applicant – An applicant who has never received an ICDBG or whose grants have been closed for more than 12 months prior to application deadline date 17
Single Purpose Grants Allocations • HUD allocates funds to six Area ONAP regions • Based on a regulatory formula (24 CFR 1003. 101) 1. Allocate $1 M to each region 2. Allocate the remaining based on each region’s share of tribal population (40%), poverty (40%), and overcrowding (20%) 18
Allocation By Region Eastern Woodlands Southern Plains Northern Plains Southwest $4, 441, 622 $13, 343, 479 $8, 580, 551 $19, 867, 953 Northwest Alaska $3, 029, 710 $6, 955, 906 19
Changes to Allocation • In FY 14, HUD replaced old 2000 Census data with new Census data from the American Community Survey (ACS) • State-recognized tribes are excluded from the calculation (except for few grandfathered tribes) 20
What Is the ACS? • Evolution of the Decennial Census “long form” survey, which collected demographic, housing and socio-economic information from a sample of all households that were counted in the Decennial Census. 21
What is the ACS? cont… • Instead of sampling once every 10 years, the Census samples a smaller share of the population each year with the ACS and produces multi-year estimates • In FY 2014, HUD is using ACS estimates from 2007 -2011 for allocations and estimates from 2006 -2010 for new LMI data 22
Changes to Allocation • More details: http: //www. huduser. org/portal/icdbg/ho me. html • Data used to determine need also found on this website 23
Measuring LMI Area Benefit • In FY 2014 there are seven options – Primary Option – old way w/new data (1 option) • Standard ICDBG LMI data from the ACS, all people in tribal areas – Other tribal area options (2 options) • AIAN LMI data from the ACS, all HH alone or incombo 24
Measuring LMI Area Benefit cont… • Neighborhood level options (3 options) – Standard CDBG LMI data from the ACS, all people (1 option) – AIAN LMI households from the ACS (2 options) • Applicant generated data per NOFA 25
Measuring LMI – More Info • Additional training on LMI data on July 2 • Website for data downloads – http: //www. huduser. org/portal/icdbg/home. html • HUD User website will be revised to include data in all options 26
Applicant Data • If applicant believes that neither option truly measures need, or if the HUDprovided options are substantially inaccurate or incomplete, applicant may submit other data that meet the criteria of 1003. 208(a)(3) and the NOFA 27
Applicant Data cont… • Data must meet this criteria – Be collected systematically – Be independently verifiable – Differentiate between reservation and BIA service area population where applicable 28
3. Applicant Data cont… • Must submit – Explanation of number of people benefitting from project and number of LMI – Sample copy of survey form – Explanation of methods used to collect data – Listing of incomes by household and size 29
Grant Ceilings • Grant ceilings apply to entire application • One of the screening factors • If exceeded, application not rated 30
Grant Ceilings • • Eastern Woodlands Southern Plains Northwest Alaska $600, 000 $800, 000 $500, 000 $600, 000 31
Grant Ceilings • By Population – Northern Plains = $900, 000 - $1. 1 million – Southwest = $605, 000 - $5. 5 million (only one tribe) 32
Grant Ceilings • If funded under both categories, may not receive more than the combined ceiling of both categories 33
Housing Rehab Cost Limits Eastern Woodlands Southern Plains Northern Plains Southwest Northwest Alaska $35, 000 $50, 000 $65, 000 $50, 000 $75, 000 34
Regulations and Requirements • If funded, must comply with regulations, guidelines and requirements of the ICDBG program • Regulations apply to both categories of funding 35
Eligible Applicants • Indian tribe, band, group, or nation including Alaska Indians, Aleuts and Eskimos and any Alaska Native Village • Tribal organizations submitting on behalf of tribes 36
Period of Performance • Based on the Implementation Schedule and must be approved by HUD • Required under Rating Factor 1 37
Cost Sharing or Matching • Not required for ICDBG • Points awarded for leveraging • ICDBG can be used as match for other programs 38
Threshold Requirements • HUD Thresholds in General Section • Program-Related Thresholds in ICDBG NOFA • Project-Specific Thresholds in ICDBG NOFA 39
General Section Thresholds • Ineligible Applicants • Resolution of Civil Rights Matters • Economic Opportunities for very low- and lowincome (Section 3) • Limited English Profiency and Accessible Technology • Accessible Technology 40
Nondiscrimination • Compliance with Fair Housing and Civil Rights Laws • Affirmatively furthering fair housing • Special rules apply to tribes and their instrumentalities 41
Other HUD Requirements • • • Outstanding Delinquent Federal Debts Pre-award accounting system survey No debarments and/or suspensions No False statements Do Not Pay Website Review 42
Other HUD Requirements • Code of Conduct • Prohibition against lobbying • Conflicts of interest 43
Other HUD Requirements • Ensuring participation of small businesses • Equal access for sexual orientation, gender, marital status • Faith-based requirements • Uniform Relocation Act 44
National Policy Requirements • • Procurement of Recovered Materials Participation in HUD evaluation Environmental requirements OMB Requirements – Some new 45
National Policy Requirements • • Drug-free workplace Safeguarding client files Compliance with Transparency Act Compliance with Duncan Hunter Act 46
Requirements That May Prohibit Award • Name Check Review • False Statements • Do Not Pay. gov Review 47
Program-Related Thresholds • Outstanding ICDBG Obligation • Compliance with Fair Housing and Civil Rights Laws 48
Project-Specific Thresholds • Housing Rehabilitation • New Construction • Economic Development 49
Housing Rehab Threshold • Rehab standards and policies adopted • Homebuyer’s payments are current for HUD-assisted housing 50
New Housing Construction Thresholds • Document that implementing entity is a Community Based Development Organization (CBDO) • Must have a tribal resolution adopting construction standards 51
New Housing Construction Thresholds • • No other suitable housing available No other sources (including IHBG) Rehab not economically feasible Household is overcrowded, or has no current residence 52
Economic Development Thresholds • Financial analysis must demonstrate project is financially feasible and has a reasonable chance of success • Show public benefit of ICDBG More requested = greater public benefit demonstrated 53
Economic Development Thresholds • Grant will not reduce non-federal funds • Not more than a reasonable rate of return on investment is provided • Grant will be disbursed on pro-rata basis with other funds 54
Project Thresholds No project thresholds for: • • Homeownership Assistance Land to Support New Housing Microenterprises Public Facilities and Improvements 55
Public Service Projects • Limited to 15% of grant request • Must be a new service or increase existing service • Can not be a “stand alone” project • Need not be related to other activities 56
Eligible Activities • 24 CFR Part 1003, Subpart C • Section III. C. 5 of ICDBG NOFA • Rating Factors 2 and 3 57
Eligible Activities Most Common Activities: • Housing Rehabilitation • Land Acquisition for New Housing • Homeownership Assistance • Public Facilities & Improvements • Economic Development • Microenterprise Programs 58
Other Eligible Activities • • • Acquisition of Property – also housing units Clearance and Demolition Comprehensive Planning Lead-based Paint Evaluation/Hazard Control Non-Federal Share Privately and Publicly Owned Commercial or Industrial Buildings • Mold 59
Eligible Activities • New Housing Construction may only be implemented through a Community Based Development Organization (CBDO) 60
Documenting a CBDO (Option 1) • • Socially oriented non-profit Board represents community Free to procure Not subject to reversion of assets 61
Documenting a CBDO • • (Option 2) Section 301(d) of Small Business Investment Act entities SBA approved entities HOME Community Housing Development Organization (CHDOs) Tribal-based community development nonprofit 62
Documenting a CBDO (Option 3) • Similar to Option 1 and 2 Example: - Has all characteristics as 1 but cannot find board with 1/3 or less public officials • TDHE or IHA not automatically considered a CBDO 63
Eligible Activities Housing Rehabilitation – Rental or homebuyer – Publicly/privately owned – Grants, loans, guarantees, interest supplements – Multiple activity types – Labor, materials, principal fixtures, security devices 64
Eligible Activities Land Acquisition – In conjunction with Housing, Public Facilities & Improvements, Economic Development – Land alone can be acquired for future housing development 65
Eligible Activities Homeownership Assistance – Only for LMI households – Subsidize interest/principal – Acquire guarantees from lenders – Up to 50% of down-payment – Pay reasonable closing costs – Eligible activity vs. public service 66
Eligible Activities Public Facilities & Improvements – Community Facilities – Special Needs Facilities – Infrastructure 67
Eligible Activities Economic Development • Acquisition, construction, rehabilitation or installation of bldgs or equipment • Assistance to non-profit and for profit organizations • Special requirements for-profits 68
Eligible Activities Microenterprises • Owner must be LMI and have five or fewer employees • Funds used for grants, loans, TA, and general support • No 15% public service cap 69
Eligibility of Government Facilities • Depends where services are provided • Police stations, jails, libraries = eligible • Courthouses, local government offices and other government headquarters = not 70
Ineligible Activities • Maintenance & Operations • New housing construction, unless carried out by a CBDO • Furnishings and personal property • Construction tools/equipment • Income payments 71
How to Apply 72
Application & Submission Information can be found in: • General Section (Section IV) • ICDBG NOFA (Section IV) 73
Application & Submission General Section • Review General Section • Applications must be submitted electronically, via Grants. gov unless waiver is granted 74
TA - Electronic Applications • Grants. gov Customer Support: http: //www. grants. gov/contactus. jsp • Technical Problems: support@grants. gov or 800 -518 -4726 75
TA Electronic Applications • www. hud. gov/offices/adm/grants/fundsa vail. cfm • www. hud. gov/webcasts/index. cfm • Portal. hud. gov/hudportal/HUD? src=/Pro gram_offices/administration/foia/highsc ore 76
TA Electronic Applications • Always call grants. gov helpdesk first • Then Roberta in headquarters if all else fails 77
Application Submission Five Steps • • • Obtain a DUNS Number Register with the SAM Register with Grants. gov Grant approval to submit Check AOR status 78
Download Application • • Several ways to do so -Go to www. grants. gov Browse by agency Or search by CFDA number (14. 862) or Funding Opportunity Number (FR-5800 -N 10) 79
Electronic Submission Adobe Reader • Check if your Adobe Reader is compatible http: //www. grants. gov/web/grants/support/technicalsupport/software/adobe-reader-compatibility. html • Adobe Reader is free and available at http: //www. adobe. com/reader/otherversions 80
Submission Dates and Times • • 11: 59 pm on July 29, 2014 Confirmation of Submission Application Submission Validation check Application Validation & Rejection Notification 81
Submission Grace Period • In 2014, applicants again have a 1 day grace period to resubmit applications • Applies if application submitted before deadline and time and receive a rejection notice. 82
Reasons for Rejection • • • Invalid DUNS Number Password ID Mixup Not authorized to submit Virus detected SAMS registration not current 83
Electronic Submission Waiver • Waivers only granted for cause • Submit request in writing with explanation • Examples: lack of available Internet access in rural communities 84
Electronic Submission Waiver • Waiver must be submitted 7 days prior to application deadline date • Send waiver to your Area ONAP Administrator and include good cause for waiver 85
What to Submit 86
Forms and Required Elements • Narrative to five rating factors – and one page summary • Application for Assistance (SF-424) • Applicant/Recipient Disclosure Update Report, HUD-2880 87
Forms and Required Elements • Cost Summary, HUD-4123 - Planning and admin cannot exceed 20% of grant - Only with physical development - Broken down by project - Don’t include costs related to project - Indirect costs comply OMB Circulars 88
Forms and Required Elements • Tribal resolution on citizen participation • Map • Low- and moderate-income (LMI) benefit 89
Measuring LMI Benefit (Area Benefit) • Activities that benefit all residents of an area where at least 51% of residents are LMI persons • Area must be primarily residential 90
Measuring LMI Benefit (Limited Clientele) • • Clientele presumed to be 51% LMI 51% of surveyed participants are LMI Participation limited to LMI Nature of activity/location indicates LMI benefit 91
Measuring LMI Benefit (Housing) • Residential structures provided/improved must be occupied by LMI persons – Single family structure - LMI occupancy – One unit of duplex - LMI occupancy – Structures w/3 or more units must have at least 51% LMI 92
Measuring LMI (Job Creation/Retention) • Activities must create or retain permanent jobs and • 51% of jobs created/retained must be available to or held by LMI persons 93
Forms and Required Elements • Can submit own demographic data that must – Be collected systematically – Be independently verifiable – Differentiate between reservation and BIA service area where applicable – Include # of people, listing of incomes by HH 94
Required Submissions • • Code of Conduct SF-LLL on lobbying HUD fax form Evidence of mold (for Category Two) 95
Rating Factors 1. 2. 3. 4. 5. Capacity of the applicant Need/Extent of the Problem Soundness of Approach Leveraging Resources Comprehensiveness and Coordination 96
Rating Factors • Have been changed slightly from 2013 • Vary slightly between categories – in this part of the webcast we will discuss Category One • Review table in Section V. A. 2 of the NOFA 97
Bonus Points • In 2014, 2 bonus points for working with Promise Zones • Must submit letter from lead organization of Zone • See V. A. 1. of General Section and www. hud. gov/promisezones 98
Rating Factors • Applicants must score a minimum of 70 points to be funded • Cut off for most Area ONAPs is much higher • Points vary if current or new applicant 99
Factor 1 – Capacity • Up to 33 points in total • If funded this year, progress will be measured • If funded in past years, lack of progress will = fewer points 100
Subfactor 1 Managerial, Technical & Administrative Capacity • 14 points current grantees / 30 points new • Possess or can obtain managerial, technical or administrative capacity to carry out proposed project • Identify who will administer project 101
Subfactor 1. a. - Managerial & Technical Staff • 7 points current grantees / 8 points new • Describe roles and responsibilities of project director and staff • Experience must be relevant, recent, and successful 102
Subfactor 1. b. - Implementation Plan • 3 points current grantees / 8 points new • Identify specific tasks and timelines for completing project • Two projects = two plans • Two categories requested = two plans • Full points if project can start within 180 days 103
Subfactor 1. c. - Financial Management • 2 points for current grantees / 7 points for new • Financial management systems must meet 24 CFR part 85 and 1003 • Seriousness/significance of open findings • Current audit if required 104
Subfactor 1. d. - Procurement/Contract Mgmt • 2 points current grantees / 7 points new • Describe how policies and procedures regulatory requirements • Findings related to procurement & contract management • Current audit or letter from IPA 105
Factor 1, Subfactor 2, Past Performance • 19 points for current grantees/new applicants not rated here (0 pts. ) – (a) Implementation/Expenditures (more points if faster spending) (7 pts. ) – (b) Reports (3 pts. ) 106
Subfactor 2 - Past Performance – (c) Close-outs (3 pts. ) – (d) Audits (3 pts. ) – (e) Findings (3 pts. ) 107
Unfunded Applicants • To spread funds around applicants who have not received a grant in recent years will receive points • Three, two, or one point 108
Rating Factor 2 Need/Extent of Problem • Total of 16 points • Subfactor 1 - Need and Viability - up to 4 points • Subfactor 2 - Project Benefit - up to 12 points 109
Subfactor 2. a. - Public Facilities and Improvements • Up to 12 points • In 2014, several options for determining need – CDBG data or ACS data OR • Information or unpublished data that meets certain criteria 110
Public Facilities & Improvement Projects At least 85% LMI At least 75% but < 84% LMI At least 55% but < 74% LMI Less than 55% 12 points 8 points 4 points 0 points 111
Subfactor 2. b. - Economic Development • Beneficiaries are persons served, employed by project, jobs created or retained • Submit census data or other data as explained on earlier slide • Points given are identical to those on previous slide 112
Subfactor 2. c. Housing Construction and Rehab, Land Acquisition for Housing and Homeownership Based on 2014 IHBG formula data $327 - $750 $751 - $1, 250 $1, 251 - $3, 999 $4, 000+ 12 pts 8 pts 4 pts 0 pts 113
Rating Factor 3 Soundness of Approach • Up to 33 points • Address quality/effectiveness of project to enhance community viability, meet identified needs, and sustain the project 114
Rating Factor 3 1. 2. 3. 4. Soundness of Approach Description & Rationale for Proposed Project (10 pts) Budget & Cost Estimates (9 pts) HUD Policy Priorities (2 pts) Commitment to Sustain Activities (12 points) 115
Subfactor 1 Description and Rationale for Project • Up to 10 points • Describe your project • Describe how project will address identified need • Describe how project will enhance community’s viability 116
Subfactor 2 - Budget & Cost Estimates • 9 points • Include cost breakdowns by line item (including planning & admin) • Include cost estimates and describe qualifications of person(s) who prepared the estimate(s) 117
Subfactor 3 - HUD Policy Priorities – Promote Economic Development and Economic Resilience – 1 point – Increase Energy Efficiency and Health and Safety of Homes – I point • Include narrative on which priorities you are addressing with the project and how 118
HUD Policy Priorities Economic Development • How project will create jobs • How it will create business opportunities • Create a flow of investment into small business or nonprofit activities serving low income people 119
HUD Policy Priority Increasing Energy Efficiency • Must meet one of two standards – Green building standard – Renewable energy standard 120
Subfactor 4 - Commitment to Sustain Activities • Up to 12 points • Demonstrate commitment to community’s viability • Criteria varies by type of project 121
Subfactor 4. a. (Public Facilities/Improvements) • Up to 12 points • Provide statement that tribe or “entity other than tribe” has adopted/developed O&M Plan and commits funds for those responsibilities 122
Subfactor 4. a. (Public Facilities/Improvements) • O&M Plan must addresses maintenance, repairs, insurance, security & replacement reserves & include cost breakdown • Buildings must show operating funds for services • Service providers submit commitments for operating and space needs 123
Subfactor 4. b. (New Housing Construction, Housing Rehabilitation, Homeownership Assistance Projects) • Up to 12 points • Identify tribal and/or participant’s maintenance responsibilities • Describe responsibilities and provide written commitment to undertake 124
Subfactor 4. c. (Economic Development) • For up to 12 points describe: – How the project will operate – Why it is needed – How it will succeed 125
Subfactor 4. d. (Microenterprises) • For up to 12 pts describe how program will operate • Include types of assistance offered and entities eligible for assistance • Describe process for selecting applicants and analyzing business plans 126
Subfactor 4. e. (Land Acquisition to Support New Housing) • Up to 12 pts • Show that proposed site has: – Suitable soil conditions – Potable drinking water – Access to utilities, vehicular access, drainage, services, and no environmental problems 127
Rating Factor 4 Leveraging Resources • Up to 8 points • HUD will award points based on % of non-ICDBG funds relative to total project cost 128
Leveraging Resources Points Less than 4% At least 4% but less than 11% At least 11% but less than 18% At least 18% but less than 25% or more 0 pts 2 pts 4 pts 6 pts 8 pts 129
Leveraging Resources Allowable Non-ICDBG Resources • • • Tribal trust or other funds Private & public loans/guarantees IHBG funds & other grants Donated goods/services Land needed for project Direct admin costs 130
Leveraging Resources Disallowed Leverage • Indirect admin costs • Operations & maintenance costs for project • Value of existing facility if expansion is proposed 131
Leveraging Resources • Submit information with application • Written statement identifying & committing tribal funds • Approved IHP on file with resources committed or written commitment for future IHBG funds • Letter of commitment from non-tribal entity • Comparable costs for goods, services & land 132
Leveraging Resources • Commitment must be received within 6 months • Letter from contributing entity must: Indicate why commitment cannot be made Provide assurance project is eligible for $ Provide date when funding decision will be made 133
Factor 5 Comprehensiveness & Coordination • Up to 10 points • How your project planning and implementation reflects a coordinated community based process of identifying needs 134
Subfactor 1 - Coordination • Up to 2 pts • How you coordinated with those not providing funds but who share your goals • Do not include leverage partners 135
Subfactor 2 – Outputs, Outcomes, and/or Goals • Up to 8 points • Outputs include – – – No. of houses rehabilitated No. of jobs created Square feet of public facility No. of homeownership units built/financed No. of businesses assisted 136
Subfactor 2 • Outcomes include: – – Reduction in families in substandard housing Increased income resulting from employment Increased quality of life due to public facility Increased economic self sufficiency of beneficiaries 137
What HUD Does 138
Review and Selection Process • Application received by deadline and per requirements • Applicant is eligible • Proposed project is eligible • Application contains all required components • At least 70% of funds must benefit LMI persons 139
Review & Selection Process • Threshold compliance • Past Performance evaluated under Factor 1 • Rating • Minimum Points 140
Review & Selection Process • Ranking – All types of projects ranked against all others • Tiebreakers – Standardized across AONAPs – Projects selected that can be fully funded over those that cannot be 141
Technical Deficiencies • Errors/oversights that would not alter rating if corrected • Only successful applicants asked & required to correct • 14 calendar days to respond • No funding if no response 142
Pre-Award Requirements • Additional supporting documentation required before award can be made • Delinquent Federal Debt Review • Name Check Reviews • 14 calendar days to respond • No funding if no response or inadequate response 143
Errors • Reviewer judgments not subject to claims of error • Bring arithmetic errors to ONAP attention within 30 days • If warranted, funding may be provided in next funding round 144
Anticipated Award Dates • • Pre-awards must be met Congressional release Awards announced in October Execute grant agreement – special conditions 145
Post Award Reporting Requirements • Quarterly Federal Financial Reports (SF 425) • Annual Status & Evaluation Report • Minority Business Enterprise Reports • Close-Out Report 146
General Questions • Area ONAP • Electronic Submission – call 800 -518 -4726 or support@grants. gov 147
Area ONAPs • Alaska: (907) 677 -9860 • Eastern Woodlands: 1 -800 -735 -3239 • Northern Plains: 1 -888 -814 -2945 • Northwest: (206) 220 -5270 148
Area ONAPs • Southern Plains: (405) 609 -8532 • Southwest (Phoenix): (602) 379 -7200 • Southwest (Albuquerque): (505) 346 -6923 149
Technical Assistance (TA) • HUD Reform Act (Section 103) • TA only until NOFA publication • TA includes general guidance about NOFA terms and regulations 150
Area ONAP NOFA Training • Contact your Area ONAP for specific locations and to register for NOFA training • Online ICDBG training: http: //www. hud. gov/offices/pih/ih/grants/ icdbg. cfm 151
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