Fiscal Year 2015 Indian Community Development Block Grant
Fiscal Year 2015 Indian Community Development Block Grant (ICDBG) Program Mold NOFA Training May 5, 2015 1
What’s New in 2015 • • NOFA just for mold $12, 400, 000 available in total Application ceiling increased Points if not funded in the recent years 2
What’s New in 2015 • Broader definition of eligible housing • Must affirmatively state tribe has housing codes • Bonus points for Promise Zones and Sustainability Communities 3
What’s The Same in 2015 • National competition • Tribes and tribal organizations may apply • Five rating factors • Can request waiver of electronic application requirement 4
Today’s Agenda • Eligible applicants, activities, and requirements • How to submit applications • Screening and rating factors 5
Available Funds • Total is $12, 400, 000 – $6. 4 million from FY 2014 – $6 million from FY 2015 6
Legislative Authority • Title I of the Housing & Community Development Act of 1974 (42 U. S. C. 5301 et seq) • ICDBG regulations, 24 CFR part 1003 7
Definition • 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 8
New Definitions • Tribally owned or operated housing – Means housing that is currently owned or operated by applicants eligible under 24 CFR 1003. 5 or housing currently or previously assisted with HUD funding 9
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 10
Measuring LMI Area Benefit • In FY 2015, like 2014, there are several options – Primary Option • Standard ICDBG LMI data from the ACS, all people in tribal areas – Other tribal area options • AIAN LMI data from the ACS, all HH alone or incombo 11
Measuring LMI Area Benefit cont… • Neighborhood level options – Standard CDBG LMI data from the ACS, all people – AIAN LMI households from the ACS • Applicant generated data per NOFA 12
Measuring LMI – More Info • Website for data downloads – http: //www. huduser. org/portal/icdbg/home. html • HUD will rate your application on the data most beneficial to your community 13
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 14
Applicant Data cont… • Data must meet this criteria – – Be collected systematically – Be independently verifiable – Differentiate between reservation and BIA service area population where applicable 15
Applicant Data cont… • Must submit all of the below – 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 16
Grant Ceilings • $800, 000 for all regions • One of the screening factors • If exceeded, application not rated 17
Housing Rehab Cost Limits Eastern Woodlands Southern Plains Northern Plains Southwest Northwest Alaska $35, 000 $50, 000 $65, 000 $50, 000 $75, 000 18
Regulations and Requirements • If funded, must comply with regulations, guidelines and requirements of the ICDBG program 19
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 20
Period of Performance • Based on the Implementation Schedule and must be approved by HUD • Required under Rating Factor 1 21
Cost Sharing or Matching • Not required for ICDBG • Points awarded for leveraging 22
Threshold Requirements • HUD Thresholds in General Section • Program-Related Thresholds in ICDBG NOFA • Project-Specific Thresholds now requirements 23
FY 2015 General Section • Applies to all HUD grants • Posted in October 2014 • Found at http: //portal. hud. gov/hudportal/HUD? src=/pro gram_offices/administration/grants/fundsavai l/2015 gensec 24
General Section • Some terminology changed from 2014 • Two thresholds now Ø Timely Submission of Applications Ø Resolution of Civil Rights Matters 25
General Section Requirements • Tribes must comply with four nondiscrimination and related requirements Ø Fair housing and civil rights Ø Section 3 Ø Access for limited English Ø Accessible technology 26
Other Requirements • Could prevent award to successful applicants – Ø Outstanding Delinquent Federal Debts Ø Pre-award accounting system survey Ø Debarments and/or suspensions Ø False Statements 27
Other Requirements Ø Do Not Pay Website Review Ø Code of Conduct – Ethical Standards Ø Prohibition against Lobbying (only applies to TDHEs established under state law) 28
National Policy Requirements • Ensuring participation of small businesses • Equal access for sexual orientation, gender, marital status • Faith-based requirements • Uniform Relocation Act 29
National Policy Requirements • • Procurement of Recovered Materials Participation in HUD evaluation Environmental requirements OMB Requirements – No longer in Circulars but in 2 CFR part 200 30
National Policy Requirements • • Drug-free workplace Safeguarding resident/client files Compliance with Transparency Act Physical Accessibility 31
Program-Related Thresholds • Outstanding ICDBG Obligation • Compliance with Fair Housing and Civil Rights Laws 32
Project-Specific Threshold • Called a “requirement” in this NOFA • Mold projects considered housing rehabilitation • Must state that housing codes were adopted prior to application submission 33
Housing Rehab Requirement • Rehab standards must be at least as stringent as HUD Section 8 HQS • Homebuyer’s payments must be current for HUD-assisted housing 34
How to Apply 35
Application & Submission Information can be found in: • General Section (Section IV) • ICDBG NOFA (Section IV) 36
Application & Submission General Section • Review General Section • Applications must be submitted electronically, via Grants. gov unless waiver is granted 37
Grants. gov Information • Helpful information on website • Click on “Applicants” to find – Applicant Tools and Tips – Applicant FAQs – User Guides, Organization Registration Guide, and educational videos 38
Register Your Organization • Obtain a DUNS Number • Register with the SAM • Register in Grants. gov with user name and password • Grant approval to submit • Check status 39
Step 1 – DUNS Number • • Most applicants have already Use the # for the entity applying Carefully type the # when registering If no number get one at: – http: //www. dnb. com/get-a-dunsnumber. html? serv=UP-HP-07082014 -new 3 40
Step 2 – Register with SAM • All who get funds must register and renew every year • To register go to: – https: //www. sam. gov/portal/SAM/#1 • Designate an E-Biz POC who can authorize submission of applications 41
Step 3 – User Name and PW • Create a profile in G. gov • Input email address that G. gov should use • Choose secret Qs and As • EBiz POC is then notified 42
Step 4 – Approval to Submit • EBiz POC must log in and designate AOR • See checklist on G. gov webpage • Sometimes Ebiz POC and AOR can be same person • Ebiz POC can see SAM expiration date 43
Step 5 – Check AOR Status • Should get email of AOR status • Can check status anytime under “Quick Links” • Remind Ebiz POC to designate AOR if not done 44
Download Application • Go to www. grants. gov • Browse by agency or • Search by CFDA number (14. 862) or Funding Opportunity Number (FR 5900 -N-02) 45
Electronic Submission Adobe Reader • Check if your Adobe Reader is compatible with Grants. gov • Adobe Reader is free and available at http: //get. adobe. com/reader/otherversions. c om 46
TA - Electronic Applications • Grants. gov Customer Support: http: //www. grants. gov/contactus. jsp • Technical Problems: support@grants. gov or 800 -518 -4726 47
TA Electronic Applications • Always call Grants. gov helpdesk first • Then Roberta in headquarters if all else fails 48
Submission Dates and Times • 11: 59 pm on June 22, 2015 • Confirmation of Submission • Application Submission Validation check • Application Validation & Rejection Notification 49
Submission Grace Period • In 2015, applicants again have a 1 day grace period to resubmit applications • Applies if application submitted before deadline and time and receive a rejection notice. 50
Successful Submission? • Don’t assume all is fine once you hit “send” • Make sure you get and save confirmation emails from grants. gov • Log on to check what was submitted 51
Successful Submission • New in 2015 is ability to see what documents were submitted, not just that application was. • Go to “Check My Application Status” • You can review and download them 52
Reasons for Rejection • • • Invalid DUNS Number Password ID Mixup Not authorized to submit Virus detected SAMS registration not current 53
Electronic Submission Waiver • Waivers only granted for cause • Submit request in writing with explanation • Examples: lack of available Internet access in rural communities 54
Electronic Submission Waiver • Waiver must be submitted 15 days prior to application deadline date • Send waiver request to glenda. n. green@hud. gov and include good cause for waiver 55
What to Submit 56
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 57
Forms and Required Elements • Cost Summary, HUD-4123 - Planning and admin cannot exceed 20% of grant - Only with physical development - Don’t include costs related to project - Indirect costs comply OMB regulations 58
Forms and Required Elements • Tribal resolution on citizen participation for this project • Low- and moderate-income (LMI) benefit 59
Measuring LMI Benefit • 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 60
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 61
Forms and Required Elements • • Code of Conduct SF-LLL on lobbying – certain applicants HUD fax form optional now Evidence of mold MUST be included 62
Rating Factors 1. 2. 3. 4. 5. Capacity of the Applicant Need/Extent of the Problem Soundness of Approach Leveraging Resources Comprehensiveness and Coordination 63
Rating Factors • Have changed slightly from 2014 • Review table in Section V. A. 2 of the NOFA 64
Rating Factors • Applicants must score a minimum of 70 points to be funded • Minimum of 15 points in Factor 1 • Points vary if current or new applicant 65
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 66
SF 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 67
SF 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 68
SF 1. b. - Implementation Plan • 3 points current grantees / 8 points new • Identify specific tasks and timelines for completing project • Full points if project can start within 180 days 69
SF 1. c. - Financial Management • 2 points for current grantees / 7 points for new • Financial management systems must meet 24 CFR 1003 and new 24 CFR 200 • Seriousness/significance of open findings • Current audit if required 70
SF 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 71
Factor 1, SF 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. ) 72
SF 2 - Past Performance – (c) Close-outs (3 pts. ) – (d) Audits (3 pts. ) – (e) Findings (3 pts. ) 73
SF 3 - Unfunded Applicants • Applicants who did not receive either a mold or a regular ICDBG in 2014 = 3 points • Applicants who did not receive a mold grant in 2014 = 2 points 74
Rating Factor 2 - Need/Extent of Problem • Total of 17 points • SF 1 – Evidence of Mold - up to 8 points • SF 2 - Project Benefit - up to 9 points 75
SF 1 – Evidence of Mold • To receive maximum points in scoring applicants must provide third party evidence of mold • Person must be qualified to make determination • Certification is not required 76
SF 1 - Evidence of Mold • May submit photographs that clearly demonstrate mold • No need to test every unit • Residents’ illnesses can be evidence • Maximum of 8 points of 100 in SF 77
SF 1 - Evidence of Mold • 8 points if mold in at least 50% of units in applicant’s inventory • 4 points if mold in at least 30% • 0 points if mold in less than 30% 78
SF 1 – Evidence of Mold • Many resources for evaluation and addressing mold found at: http: //portal. hud. gov/hudportal/HUD? src=/program_o ffices/public_indian_housing/ih/codetalk/aboutonap/ resourcesmrp • Watch webcast of June 27, 2014 presented by ONAP, EPA, IHS, and OHHLHC 79
SF 1 - Evidence of Mold • IHS’ Environmental Health staff may be able to assist you – Find appropriate help to develop evidence of mold – Provide technical assistance and support with portions of the application http: //www. ihs. gov/dehs/ 80
SF 1 – Evidence of Mold • EPA has many resources on its website – Online mold course – Introduction to Mold and Mold Remediation for Environmental and Public Health Professionals www. epa. gov/moldcourse/index. html – Mold Related Webinars – check for announcements on www. epa. gov/iaq 81
SF 2 – Project Benefit Based on 2015 IHBG formula data $0 - $750 $751 - $1, 250 $1, 251 - $3, 999 $4, 000+ 9 pts 7 pts 3 pts 0 pts See Rating Factor 2 Needs Table posted with other forms with NOFA 82
Rating Factor 3 Soundness of Approach • Up to 30 points • Address quality/effectiveness of project to enhance community viability, meet identified needs, and sustain the project 83
Rating Factor 3 1. 2. 3. 4. Soundness of Approach Description & Rationale for Proposed Project (8 pts) Budget & Cost Estimates (8 pts) HUD Policy Priorities (2 pts) Commitment to Sustain Activities (12 points) 84
SF 1 - Description and Rationale • Up to 8 points • Describe your project • Describe how project will address identified need • Describe how project will enhance community’s viability 85
SF 2 - Budget & Cost Estimates • 8 points • Include cost breakdowns by line item (including planning & admin) • Include cost estimates and describe qualifications of person(s) who prepared the estimate(s) 86
SF 3 – HUD Policy Priority • There are two of these • Promote Economic Development and Economic Resilience – 1 point • Increasing Energy Efficiency and the Health and Safety of Homes 87
Policy Priority - Economic Development • How project will create – Jobs – Business opportunities – Create a flow of investment 88
Policy Priority Increasing Energy Efficiency • Must meet one of two standards – Green building standard – Renewable energy standard 89
SF 4 – Commitment to Sustain • Up to 12 points • Identify tribal and/or participant’s maintenance responsibilities • Describe responsibilities and provide written commitment to undertake 90
Rating Factor 4 Leveraging Resources • Up to 10 points • HUD will award points based on % of non-ICDBG funds relative to total project cost 91
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% At least 25% but less than 30% 30 % or more 0 pts 2 pts 4 pts 6 pts 8 pts 10 pts 92
Leveraging Resources Allowable Non-ICDBG Resources Can Include • Tribal trust or other funds • Private & public loans/guarantees • IHBG funds & other grants • Donated goods/services • Direct admin costs 93
Leveraging Resources Disallowed Leverage Includes • Indirect admin costs • Operations & maintenance costs for project 94
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 95
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 96
Factor 5 Comprehensiveness & Coordination • Up to 10 points • How your project planning and implementation reflects a coordinated community based process of identifying needs 97
SF 1 - Coordination • Up to 2 pts • How you coordinated with those not providing funds but who share your goals • Do not include leverage partners 98
SF 2 – Outputs and Outcomes • Up to 8 points • Outputs include – No. of houses rehabilitated – No. of units in which mold is remediated – No. of units in which mold prevention activities conducted – No. of persons assisted – Other 99
SF 2 – Outputs and Outcomes • Outcomes include: – Reduction in families in substandard housing – Reduction in individuals with health-related illnesses – Increased quality of life – Reduction in health related hazards – Other 100
Bonus Points • In 2015, 2 bonus points for working with Promise Zone or Sustainability Community • Must submit Certification of Consistency • See V. A. 1. of General Section 101
What HUD Does 102
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 103
Review & Selection Process • Threshold / requirements compliance • Past Performance evaluated under Factor 1 • Rating • Minimum Points 104
Review & Selection Process • NOFA explains what happens next • How tiebreakers are treated 105
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 106
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 107
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 108
Anticipated Award Date • • Pre-awards must be met Congressional notification Awards announced by 9/30/15 Execute grant agreement – special conditions 109
Post Award Reporting Requirements • Quarterly Federal Financial Reports (SF 425) • Annual Status & Evaluation Report • Minority Business Enterprise Reports • Close-Out Report 110
General Questions • Area ONAP • Electronic Submission – call 800 -518 -4726 or support@grants. gov 111
Area ONAPs • Alaska: (907) 677 -9860 • Eastern Woodlands: 1 -800 -735 -3239 • Northern Plains: 1 -888 -814 -2945 • Northwest: (206) 220 -5270 112
Area ONAPs • Southern Plains: (405) 609 -8532 • Southwest (Phoenix): (602) 379 -7200 • Southwest (Albuquerque): (505) 346 -6923 113
Technical Assistance (TA) • HUD Reform Act (Section 103) • TA only until NOFA publication • TA includes general guidance about NOFA terms and regulations 114
Additional Technical Assistance • The Institute for Tribal Environmental Professionals and Tribal Healthy Homes Network will jointly be offering two webinars on mold remediation 5/8 and 5/15 115
- Slides: 115