ICDBG IMPLEMENTATION TRAINING FY 201920 Grantees September 16

ICDBG IMPLEMENTATION TRAINING FY 2019/20 Grantees September 16, 2020 NORTHWEST OFFICE OF NATIVE AMERICAN PROGRAMS 1

TODAY’S AGENDA Project implementation – getting started! Environmental reviews Line of credit control (locks) access Methods of procurement Financial management HUD monitoring Grant reporting and grant closeout 2

Grant Award - Getting Started Become familiar with ICDBG Requirements & Regulations § Statute - 42 U. S. C. 5301 § ICDBG Regulations - 24 CFR Part 1003 § Environmental Requirements - 24 CFR Part 58 § Uniform Administrative Requirements – 2 CFR Part 200 3

Grant Award - ICDBG Regulations – 24 cfr§ 1003 § Subpart A – General Provisions § Subpart B – Allocation of Funds § Subpart C – Eligible Activities § Subpart D – Application and Selection Process § Subpart E – Imminent Threat Grants § Subpart F – Grant Administration § Subpart G – Other Program Requirements § Subpart H – Program Performance 4

ICDBG CARES § CARES Act (Public Law 116 -136): ICDBG-CARES Grants § ICDBG-CARES Waivers and Alternative Requirements, PIH Notice 2020 -05 § ICDBG-CARES Implementation Notice – PIH Notice 2020 -11 § Must ensure all proposed activities can be tied to one of the following three eligible purposes: • Activities, Projects, or Programs to Prevent COVID-19 • Activities, Projects, or Programs to Prepare for COVID-19 • Activities, Projects, or Programs to Respond to COVID-19 5

Grant Award - Getting Started Become familiar with requirements of matching funds (e. g. , Indian Housing Block Grant (IHBG). Make sure you have site control. Meet with staff responsible for the project to discuss program implementation and requirements. Set up a good filing system for the project, per 2 CFR Part 200. 333 and. 335 (Record Retention). Complete Special Conditions. 6

Grant Award - Special Conditions Common special conditions § Environmental Reviews – 120 days § Executing a Subrecipient Agreement – 120 days § Force account approval – 120 days § Memorandum of Agreements – 6 -months § Funding commitments – 6 -months All grants are conditioned upon completion of environmental obligations and required release of funds by HUD - before any funds are obligated/expended. 7

Subrecipient Agreement Regulations found at 24 CFR Part 1003. 3 & 2 CFR Part 200. 330 Subrecipients § Non-profit or For-Profit Entities receiving ICDBG funds from the grantee to administer part or all of the grant on behalf of the grantee. Subrecipients are not: § Contractors subject to procurement requirements Grantee Responsibility - 24 CFR Part 1003. 500(b) Subrecipient Agreement 8

Force Account Approval 120 days to clear Force Account Condition. 24 CFR § 1003. 509 – Use of Tribal work forces for construction or renovation Documentation required regarding: Capacity, Supervision, Payroll, Insurance Contracting and procurement standards apply to materials, equipment and supplies 9

Force Account Approval Assign Grant Administration responsibilities Adhere to the project schedule and budget Establish materials and equipment inventory Written progress reports / work inspections Housing Construction – Carried out by CBDO 10

Memorandum of Agreement (MOA) aka Memorandum of Understanding (MOU) A Memorandum of Agreement (MOA) is a written document describing a cooperative relationship between two parties wishing to work together on a project or to meet an agreed upon objective. A MOA usually precedes a more detailed contract or agreement between the parties. This MOA may be used to cooperatively work together on an agreed upon purpose or meet an agreed objective and outline the discussed terms of a new relationship. The purpose of a MOA is to have a written understanding of the agreement between the parties. This MOA provides a simple but effective format to enter into a general agreement prior to finalizing a more detailed contract or agreement with a party. 11

Funding Commitment 6 -months to clear the Funding Commitment Condition – NO Extensions ICDBG NOFA Requirement - “A letter of commitment from a partner by which an applicant or an applicant's partner agrees to perform an activity specified in the application and demonstrates the financial capacity and conditional agreement to deliver the resources necessary to carry out the activity, either in cash or through in-kind contributions if HUD awards ICDBG funds. If a tribe is committing resources to the project the amount of such commitment should be included in the tribal resolution. If a tribal organization is the applicant, it should submit evidence of such commitment in the equivalent of a tribal resolution. ” If not obtainable by the deadline and other funding sources are not available, funding may be recaptured. 12

Environmental Review The funding assistance authorized hereunder shall not be obligated or utilized: for any activities requiring a release of funds by HUD under the environmental review requirements at 24 CFR Part 58, until such release is issued in writing by SWONAP, or for construction or rehabilitation activities not requiring a Part 58 release, until documentation of environmental compliance is submitted to and accepted by SWONAP. 13

HUD Environmental Review Requirements 24 CFR Part 58

Limits on Activities Prior to Clearance Regulations at 24 CFR Part 58. 22 Grantee may not commit or expend HUD or other project funds prior to HUD approving a release of funds (ROF) for activities that require a ROF (environmental assessment, categorically excluded not converted to exempt status). For activities that do not require a ROF, the grantee may not obligate or expend for that activity until the Tribe has documented its determination that the project does not require a ROF (exempt, Categorically Excluded Not Subject To (CENST) to 58. 5, Categorically Excluded Subject To (CEST) 58. 5 converted to exempt status) and the environmental review special condition is cleared by HUD. 15

Environmental Reviews Part 58 - Key Terms Responsible Entity (RE) Recipient Certifying Officer ONAP Point of Contact Environmental Review Record 16

Responsible Entity Tribal governments assume the responsibility for environmental review, decision-making and action that would otherwise apply to HUD (24 CFR Part 58. 4). Tribe assumes these responsibilities with the execution of the grant agreement and/or HUD form 7015. 15, Request for Release of Funds (RROF). 17

Certifying Officer of the Responsible Entity Regulations at 24 CFR Parts 58. 2(a)(2) and 58. 13 The Tribe’s chief executive officer authorized to execute the Request for Release of Funds (RROF) and certification. Has the legal capacity to represent the Tribe and be subject to the jurisdiction of the Federal Courts for environmental matters. Has authority to obligate the tribe to satisfy any judgement stemming from legal action related to the tribe’s performance of environmental responsibilities. 18

Certifying Officer of the Responsible Entity Program Guidance 2017 -03 Must be the Tribal Leader (President, Chairperson, Governor, Spokesperson of the Tribe) or another Tribal official can be designated. Delegation can not go to an employee of the Tribally Designated Housing Entity (TDHE) because a TDHE is not a department of the Tribe. Delegation must be a written delegation from Tribal Leader or a tribal resolution. A copy of official action must be included in the environmental file. 19

Environmental Review Steps: Step 1 Establish the environmental review record, including aggregated, complete & finite scope(s) of work: Definition: A well organized written record of the environmental review process, consultation, mitigation measures, ongoing consultation, alternatives, and resulting determinations. It is based on current and best available information. Must be maintained and available for HUD review for each grant/project. Could be subpoenaed in the event of any legal action that might occur. 20

Environmental Review Steps: Step 2 Determine the level of environmental review for the planned activity: § § § Exempt (58. 34) Categorically Excluded Not Subject to Federal Laws and Authorities (CENST) (58. 35(b)) Categorically Excluded Subject to Federal Laws and Authorities (CEST) 58. 35(a)) Environmental Assessment (58. 36) or Environmental Impact Statement (58. 37) 21

LEVEL OF ENVIRONMENTAL REVIEW 58. 34 58. 35(b) 58. 35(a) 58. 36 Exempt Categorically Excluded NOT subject to 58. 5 Categorically Excluded AND subject to 58. 5 and other federal laws. NEPA Environmental Assessment TYPE OF ACTIVITIES Environmental and other studies Resource Identification Development of plans and strategies Information and financial services Administrative and Management Activities Public services, i. e. , employment, crime prevention, child-care, health, drug abuse, education, counseling, energy conservation, welfare, recreational needs Inspections and testing Purchase insurance and tools Engineering or design costs Technical assistance and training Temporary or permanent improvements that do not alter environmental conditions and are limited to activities to protect, repair or arrest the effects of disasters, imminent threats, or physical deterioration Payments of principal and interest on loans or obligations guaranteed by HUD Tenant-based rental assistance Supportive services such as health care, housing services, permanent housing placement, day care, nutritional services, shortterm payments for rent, mortgage, or utilities, assistance in gaining access to government benefits. Operating costs including maintenance, furnishings, security, equipment, operation, supplies, utilities, staff training and recruitment Economic development activities including equipment purchase, inventory financing, interest subsidy, operating costs, and other expenses not associated with construction or expansion Activities to assist homeownership of existing or new dwelling units not assisted w/Federal funds, including closing costs and down payment assistance to homebuyers, interest buy downs or other actions resulting in transfer of title. Affordable housing pre-development costs: legal consulting, developer and other site-option costs, project financing, administrative costs for loan commitments, zoning approvals, and other activities which don’t have a physical impact. Approval of supplemental assistance (including insurance or guarantee) to a project previously approved under Part 58, if: approval is by same the RE, and re-evaluation is not required, per 58. 47 Acquisition, repair, improvement, reconstruction, or rehabilitation of public facilities and improvements (other than buildings) when the facilities and improvements are already in place and will be retained in the same use without change in size or capacity of more than 20% Replacement of water or sewer lines Reconstruction of curbs & sidewalks Repaving of streets Special projects directed toward the removal of material and architectural barriers that restrict the mobility of and accessibility to the elderly and handicapped. Single Family Housing Rehab • Unit density is not increased beyond 4 units, • Project doesn’t involve change in land use from residential to non-residential • The footprint of the building in not increased in a floodplain or a wetland. Multifamily Housing Rehab Unit density change is not more than 20% Project doesn’t involve change in land use from residential to non-residential Cost of rehabilitation is less than 75% of the estimated cost of replacement after rehab Non-Residential Structures Facilities and improvements were in place and will not be changed in size or capacity by more than 20% Activity does not involve change in land use from non-residential to residential, commercial to industrial, or one industrial use to another Individual action (e. g. , disposition, new construction, demolition, acquisition) on a 1 to 4 family dwelling; or individual action on five or more units scattered on sites more than 2000 feet apart and no more than 4 units per site. Acquisition (including leasing) or disposition of, or equity loans on an existing structure or acquisition (including leasing) of vacant land provided that the structure or land acquired or disposed of will be retained for the same use. Activities not exempt or categorically excluded. Generally, new construction of 5 or more homes, and conversion from one type of land use to another. Combinations of the above activities 22 22

Environmental Review Steps: Step 3 Conduct and document the required level of environmental review. HUD has developed recommended formats for each type of review https: //www. hudexchange. info/programs/environmental-review/. Describe all activities that are part of the project in the review. Document compliance with applicable authorities, i. e. 58. 5 and 58. 6 and section 102 of NEPA and the related provisions in 40 CFR parts 1500 through 1508. 23

Environmental Review Statutory Worksheet: Categorically Excluded Activities 24

Environmental Review Steps: Step 4 If applicable, publish/disseminate public notice(s) (24 CFR Parts 58. 43 & 58. 44) § Notice of intent to Request a Release of Funds (NOI/RROF) – 7 days if published or 10 days if posted (CEST/not converted to exempt). § Finding of no significant impact (FONSI) and/or Combined FONSI & NOI/RROF – 15 days if published or 18 days if posted (EA). § § Comment period days are full 24 -hour periods for the public to comment to the tribe on the proposed action. Evaluate any comments received. 25

Environmental Review Steps: Step 5 Complete and submit signed HUD-7015. 15, Request for Release of Funds and Certification (58. 71) § § Signature cannot be dated prior to expiration of Tribal comment period. Include clear description, total project cost, dollar amount of HUD funds to be released, any comments received. To start the 15 -day comment period with HUD: email signed HUD-7015. 15, copy of public notice(s), affidavit of publication/posting. Must retain form HUD-7015. 15 with original signatures in the project file. (No need to send to HUD-ONAP). 26

Environmental Review Steps: Step 6 HUD issues release of funds (ROF) and clears the special condition to the grant: § § § Public has 15 days from HUD’s receipt of tribe’s RROF to comment to HUD on proposed action. If no adverse comments received during the 15 -day comment period, HUD issues ROF (conditioned on required mitigation). HUD provides form HUD 7015. 16 Authority to Use Grant Funds to the Tribe, clears the special condition and provides notification the project may proceed if no other special conditions to the grant remain open. 27

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Environmental Resources HUD Exchange Website: https: //www. hudexchange. info/programs/environmental-review/ HUD Web-Based Instructional System for Environmental Reviews (WISER) https: //www. hudexchange. info/trainings/wiser/ Environmental Regulations at 24 CFR Part 58 https: //www. hudexchange. info/resource/167/environmental-reviewprocedures-24 -cfr-58/ NOTE: HUD HEROS (HUD Environmental Review Online System) is not mandatory yet for completion of environmental work for Tribal grantees (ICDBG). 29

Implementation Schedule + Cost Summary

Implementation Schedule and Cost Summary Notify and submit the following documents to Nw. ONAP if there are changes: Implementation Schedule, HUD form SF-4125 - Establishes project timelines. Cost Summary, HUD form SF-4123 – Establishes budget / sources of funds. 31

Revise Implementation Schedule 60 -90 days for Environmental Review Hire Project Manager Design Time Procurement, Bids, Preparation and Award Delays – Weather, Fishing Allow time for coordination: § § § With the city for utilities With other Federal Agencies With State Agencies 32

electronic Line of Credit Control System (e. LOCCS)

electronic Line of Credit Control System (e. LOCCS) The Line of Credit Control System (LOCCS) is the U. S. Department of Housing and Urban Development’s (HUD) primary grant and subsidy disbursement system that handles disbursement and cash management for the majority of HUD grant programs. Organizations and individuals have access to these grants through an internet version of LOCCS called e. LOCCS, where Business Partners with appropriate authorization can access, manage, and drawdown against their HUD grant portfolios. e. LOCCS Reference Guide: https: //www. hud. gov/program_offices/cfo/loccs_guidelines 34

electronic Line of Credit Control System (e. LOCCS) e. LOCCS is accessed through the HUD internet portal called Secure Systems. Component 1 – Secure Systems Business Partner Registration Component 2 – Secure Systems “Coordinator” (Approving Official) Registration Component 3 – Secure Systems “User” Registration Component 4 – HUD-27054 LOCCS Access Authorization Form 35

electronic Line of Credit Control System (e. LOCCS) Secure Systems is the bank building e. LOCCS is the vault inside of the building That is why currently you have 2 different user ID’s and passwords 36

electronic Line of Credit Control System (e. LOCCS) When registration in Secure Systems is complete you will then have access to e. LOCCS via logging into Secure Systems 37

electronic Line of Credit Control System (e. LOCCS) Logging into Secure Systems Then select Line of Credit Control System e. LOCCS 38

electronic Line of Credit Control System (e. LOCCS) Finally log into the e. LOCCS system 39

electronic Line of Credit Control System (e. LOCCS) Finally log into the e. LOCCS system 40

HUD 27054 – LOCCS Access Authorization Form Remember to send the completed form to the area ONAP office for signature – they will forward the form to the finance office once it has been reviewed and signed 41

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SF 1199 a – Direct Deposit Sign-Up Form 43

HUD 27053 – Request Voucher for Grant Payment 44

HUD 27053 – Request Voucher for Grant Payment Northwest Tribe/TDHE 92 -0000 Signature 45

Procurement

Procurement ALL EXPENDITURES MUST BE: Necessary Directly related to project Reasonable 47

Procurement Regulations Review your procurement policy to insure compliance with: § 2 CFR Part 200 – Administrative Requirements § 2 CFR Part 200. 317 -326 - Procurement § 24 CFR Part 1003. 510 – Indian Preference 48

Procurement Policies Procedures Practices 49

Procurement Policy § Policy must also include: § Code of Conduct (that was submitted or updated). § Terms and conditions that must be in all contracts and subcontracts- 2 CFR § 200. 326 (Appendix II). § A record system to keep track of purchases. § Bid and Indian Preference protest procedures for complaint resolution. § Section 3 Contracting. 50

Procurement Policies Each procurement must comply with one of the adopted Procurement Procedures. Set up Procurement Files. Keep all records of all procurements: § Requests for quotes successful and unsuccessful quotes and bids. 51

Procurement Policy Purchases must be made using full and open competitions per 2 CFR § 200. 319 § Cannot place unreasonable restrictions on companies. § Cannot require unnecessary experience. § Cannot require excessive bonds. 52

Procurement Policy Must include procurement methods for: §Micro-purchases §Small purchases §Sealed bids §Competitive proposals §Non-competitive proposals 53

Micro-Purchase Small Purchase Sealed Bids Competitive Proposals • Where the aggregate dollar does not exceed $10, 000 • Includes purchases of property or services that do not exceed $250, 000 • Includes purchases over $150, 000; common for construction projects • Includes purchases over $150, 000; used when sealed bids are not appropriate • Distribute equitably among qualified suppliers • Informal purchasing procedures are acceptable • Formal solicitation is required, fixed-price or costreimbursement contracts. • No competitive quotes required if determined that price is reasonable. • Price or quotes are required from adequate number of sources • Fixed price (lump sum or unit price) is awarded to the responsible, responsive bidder & lowest in price • Awarded based on most advantageous to the program, with price being a factor. 54 54

Micro-purchases Regulations at 2 CFR Part 200. 320(a) & 200. 67 Acquisition of supplies or services - the aggregate dollar amount of which does not exceed $10, 000 To extent practicable, distribute micro-purchases equitably among qualified suppliers May be awarded without soliciting competitive quotations if the price is reasonable 55

Small Purchase Procedures Regulations at 2 CFR Part 200. 320(b). Procurements under $250, 000. Prepare a Request for Quote (RFQ). Estimate the cost. Give all vendors the same information. Get at least three phone or written quotes. Buy from the lowest responsive bidder. Keep a record of all price quotes. Use Indian Preference to the greatest extent feasible, as described in Procurement Policy. 56

Sealed Bids Regulations at 2 CFR Part 200. 320(c) Contracts over $150, 000. Generally associated with construction contracts. Develop specifications. Estimate the cost. Include bonding or alternative bonding requirements. Decide method of Indian Preference to use. Prepare invitation for bid (IFB) documents. Publish the bid, usually in the newspaper. 57

Sealed Bids Send bid packages to interested vendors. Keep bids unopened in a secure place until time and place stated in IFB. Open bids and publicly announce bid amounts at the date, time and place stated in the IFB. Resist making any further comments at bid opening until such time as bid documents are reviewed, including analysis of the lowest responsible, responsive and qualified bidder. Award the bid to the lowest responsible, responsive and qualified bidder and notify all bidders of decision. 58

Competitive Proposals Regulations 2 CFR Part 200. 320(d) Contracts over $150, 000. Develop scope of work. Estimate the cost. Develop criteria for proposal evaluation. Decide method of Indian Preference to use. Prepare Request for Proposals (RFP) documents. Publish the proposal, usually in the newspaper. Do not open the proposals in public. 59

Competitive Proposals Regulations at 2 CFR Part 200. 320(d). Seat a panel, generally of three qualified staff. Have a written plan for evaluating cost and technical proposals; evaluation review process must be established before the RFP is issued. Evaluations should be impartial, consistent and fair. Objectivity must be apparent upon review. Use rating sheets for each offeror to document ratings and narrative justifications to support the rating. Evaluate each proposal according to the criteria listed in the RFP. Sign contract with party providing the best offer. 60

Noncompetitive Proposal Regulations at 2 CFR Part 200. 320(f) Solicitation of a proposal from only one source, or after solicitation of a number of sources, “competition determined inadequate”. May be used only when award by other methods are infeasible and one of the following circumstances apply: § Availability from a single source only. § A public exigency or emergency will not permit a delay resulting from solicitation. § HUD authorizes noncompetitive method. § After solicitation from a number of sources, competition determined inadequate (by grantee). 61

Documentation for Noncompetitive Proposals Cost analysis, including an evaluation of the specific elements of costs and profits, is required which verifies the basis of the price and a determination that “price is reasonable”. Description of the efforts made to find competitive sources (e. g. , advertisements, phone calls, etc. ) Statement as to efforts that will be undertaken in the future to promote competition. Signed approval by the Contracting Officer or other designated official. 62

Debarment No awards, sub-grants or contracts to debarred or suspended parties (2 CFR § 200. 212 ) Check the HUD Departmental Enforcement Center website for listing of debarred and suspended parties: www. sam. gov Additional information at: http: //www. hud. gov/offices/enforce/index. cfm KEEP ALL RECORDS 63

“Full and Open” Competition Full and Open means all responsible sources are permitted to compete. Cannot award contract that is not “responsible” and “responsive”. Cannot place unreasonable requirements – such as: § unnecessary experience or excessive bonding Cannot hire a consultant (i. e. attorney, auditor, etc. ) on retainer without competition. Cannot list a brand name without an “Or Equal Clause”. 64

“Full and Open” Competition In order to ensure objective contractor performance and eliminate unfair competition advantage, contractors that develop or draft specifications, requirements, statements of work, or invitations for bid or requests for proposals MUST BE EXCLUDED from competing for such procurements. (2 CFR Part 200. 319(a)) 65

Bonding Requirements For construction contracts over $150, 000 § A bid guarantee of 5 percent of the bid price. § A performance bond for 100 percent of the contract price. § A payment bond for 100 percent of the contract price. [see 24 CFR § 1003. 501(a)(13) and 2 CFR § 200. 325 – Bonding Requirements] 66

Bonding Alternatives For performance and payment bonds, at your discretion you may: § Require a deposit of cash in an escrow account in the amount of not less than 20% of the total contract price, subject to reduction during the warranty period and commensurate with potential risk, or § Require a letter of credit for 25% of the total contract price, unconditionally payable to you by the contractor upon demand, subject to reduction during the warranty period and commensurate with potential risk. 67

Required Contract Provisions ALL CONTRACTS AND SUB-CONTRACTS MUST INCLUDE PROVISIONS FOR: Energy efficiency standards. Contract and Subcontract Activity Report– 2 CFR § 200. 321. OTHER PROVISION REQUIREMENTS Agency’s requirements pertaining to reporting. Compliance with Copeland Anti-kickback. Contract Work Hours and Safety Act. . Retention of records – 2 CFR § 200. 333. Remedies for Breach of Contract. Access to records by awarding agency, auditors – 2 CFR § 200. 336. Clean Air Act / Clean Water Act. Indian Preference – 24 CFR § 1003. 510. Termination for cause or convenience. 68

Other Requirements The Following Requirements Do Not Apply to ICDBG Projects and Contracts: The Equal Employment Opportunity requirements of 2 CFR § 200. 326 Appendix II Davis Bacon Act - 2 CFR § 200. 326 Appendix II 69

Financial Management WHAT YOU NEED: ● 24 CFR § 1003. 501: Applicability of Uniform Administrative Requirements & Cost Principles ● 2 CFR § 200, Subpart D: Administrative Requirements for Grants and Cooperative Agreements – Post Federal Award ● 2 CFR § 200, Subpart E: Cost Principles ● 2 CFR § 200, Subpart F: Audit Requirements 70

Financial Management Review the financial management system in place; determine if it meets the requirements. Update and adopt a financial management system that complies with the regulations. 71

Financial Management Recordkeeping Show all purchases are allowable and eligible WHAT YOU NEED: § 2 CFR § 200 Subpart E, Cost Principles – Establishes principles and standards for allowable and un-allowable costs. § ICDBG REGULATIONS – 24 CFR § 1003 Subpart C – Identifies eligible activities / ineligible activities. § Original ICDBG application – considered to be an integral part of the grant agreement. 72

Financial Management Eligible Costs: A&P Cost Limits Admin and Planning (A&P) COSTS – Limited to not more than 20% of the ICDBG Award May include: (24 CFR 1003 § 206 -206) § § § Reasonable costs to plan and execute the project. General management, oversight and coordination. Budget and project schedule preparations. Accounting services and audit services. Utilities, office supplies and insurance. Travel costs associated with the project. 73

Financial Management Eligible Costs: Public Service Cost Limits Public Service Costs Are Limited To 15 % Of The Grant – Only if included in application See 24 CFR 1003. 201(e) – Basic Eligible Activities May include: § § Providing services related to daycare, crime prevention, fair housing counseling, health services, drug abuse. Labor, Supplies, Materials and Furnishings for public services and facilities. 74

Financial Management Source Documentation This is the most common reason for costs being disallowed. See 24 CFR § 1003. 207 for Ineligible Costs under ICDBG 75

Financial Management EXPENSES MUST BE DOCUMENTED Source documentation can include: §Purchase orders and trip authorizations. §Procurement records. §Bills, invoices, timesheets, payroll records, travel vouchers, and receipts. §Check register, cancelled checks, check stubs, and bank statements 76

Financial Management Cash Management WHAT YOU NEED: § Cash receipts and disbursement journal § Recipient should expend funds from LOCCS within 3 days of funds being electronically transferred to the recipient’s financial institution § Excess funds must be returned to LOCCS if not expended within 3 days of draw — Return funds via www. pay. gov. 77

Financial Management Internal Controls – Over Property WHAT YOU NEED to REVIEW: Equipment and Supplies Regulations – § § § 2 CFR § 200. 313 (Equipment) – over $5, 000 2 CFR § 200. 314 (Supplies) – under $5, 000 24 CFR § 1003. 501(a) 9 & 10 Real Property Regulations – § § 2 CFR § 200. 311 (Real Property) 24 CFR § 1003. 504 (Use of Real Property) 78

Financial Management Internal Controls – Over Property Inventory property as it is received and then also every two years at a minimum Establish a system to assure property is not lost, damaged or stolen – things to consider: § § § Where property is kept. Who is responsible for it. Who can use the property. How to keep the property in good condition. Who investigates loss, theft or damage. 79

Financial Management Budget Control § The recipient is responsible for completing the project within budget. § Project must be completed as described in the Cost Summary, HUD-4123, submitted with the ICDBG application. 80

Financial Management Sub-recipient Compliance The recipient is responsible for overseeing subrecipient compliance Sub-recipient must comply with all regulations: § 24 CFR § 1003. 501(a) or (b). § 24 CFR § 1003. 502 (Sub-recipient Agreement). § 2 CFR 200 Subpart E Cost Principles. § 2 CFR 200 Subparts B-D (Administrative Requirements). 81

Financial Management Audits Dollar Thresholds for Audit Requirement: § Recipients that expend $750, 000 or more in a year in Federal Funds - have an audit conducted in accordance with 2 CFR 200 Subpart F (2 CFR § 200. 500 -520). § If under $750, 000 a year expended, records must be available for review by the Federal Agency. 82

HUD Monitoring

HUD Monitoring Purpose of HUD Monitoring Review 1. Compliance with Regulations / Grant Agreement. 2. Carried out activities as described in application. 3. Made substantial progress. 4. Continuing capacity to complete activities timely. 5. Capacity to undertake specific planned activities. 6. Monitoring findings, audits, corrective actions. 7. Enforcement actions, complaints, correspondence. 84

HUD Monitoring HUD Areas of Review 1. Procurement and Contract Administration 2. Relocation – if applicable 3. Lead Based Paint – if applicable 4. Sub-recipient Agreements 5. Environmental Review 6. Compliance with approved grant application activities 7. Financial Systems Expenditure Report 85

HUD Monitoring HUD Areas of Review 8. Force Account compliance 9. Citizen Participation review 10. Housing Rehabilitation Requirements – Cost limits, adopted policies, standards, expenditures review compared to cost summary 11. Land Acquisition – Financial Commitment for future project (within two years) 12. New Housing – CBDO Implementation, adopted construction standards 86

HUD Monitoring HUD Areas of Review 13. Public Facilities / Improvement – Was an M&O Plan adopted, adhered to, in compliance with NOFA 14. Program Progress – Implementation Schedule 15. MBE Report-HUD 2516, by October 10 SUMMARY: § § § Compliance with requirements Violations of applicable statutes, regulations, or local laws and authorities Corrective Actions – if needed 87

HUD Monitoring If You Are Scheduled For A HUD Monitoring Visit: For Program Progress – Have The Following Information Available: Implementation schedule Approved original application Project implementation plans 88

HUD Monitoring Be Prepared To Explain: Any delays in the project Any cost overruns Changes from approved application 89

HUD Monitoring For Program Benefit – Have The Following Information Available: Beneficiaries as stated in approved application – this is the benchmark Records showing who is actually benefiting from the project 90

HUD Monitoring Citizen Participation Information To Have On Hand: Minutes of meeting Announcements of meetings Verification that community statement was posted Citizen comments for complaints Responses to comments for complaints 91

HUD Monitoring Accountability - Procurement Records Closely Reviewed Written and oral price quotes Bid announcements Bid evaluations Contracts 92

HUD Monitoring Allowable Costs: § § § § Receipts Invoices Cancelled checks Bank statements Check register Tax records Payroll records 93

HUD Monitoring Of Contractors And Subrecipients Documents that show the grantee has monitored contractors and subrecipients on ongoing basis Personal Property Management Property records Inventory of tools and equipment Disposition records 94

HUD Monitoring Financial & Overall Management System Property control system Procurement policy and procedures Cash receipts and disbursement journal 95

Grant Reporting Requirements Resources: § 2 CFR Part 200. 327 – Financial Reporting § 24 CFR § 1003. 506 – Regulatory Reporting Requirements 96

Grant Reporting Requirements Forms: § § Form SF-425: Federal Financial Report Form HUD-2516: MBE Report (Contract and Subcontract Activity Report) Reports: § § § Annual Status & Evaluation Report (ASER) Section 3 - Summary Report Additional CARES Act Reporting: Section 15011 of the CARES Act requires that recipients of $150, 000 or more of CARES Act funding submit a detailed report outlining activity and expenditures. Awaiting more guidance 97

Grant Reporting Federal Financial Reports (SF 425) Quarterly Report Periods SF-425 Due Dates 01/01 – 03/31 04/30 04/01 – 06/30 07/01 – 09/30 10/01 – 12/31 1/30 98

Grant Reporting Federal Financial Reports (SF 425) 99

Grant Reporting Annual Status and Evaluation Report (ASER) Complete narrative report What has been accomplished? — Be specific – address progress on Outputs and Outcomes specified in Rating Factor 5 from your application What remains to be done? Are you on schedule? — If not, why not? How much have you spent on each activity? How much have you spent from each source? 100

Grant Reporting Minority Business Enterprise Reports Submit the MBE Report (Form HUD-2516) annually, covering the period of 10/1 – 9/30 by October 10 th Any contracts or subcontracts over $10, 000 that the Tribe/TDHE enters into must be reported on the HUD-2516, Contract and Subcontract Activity Report Only include contracts executed during the period of the report 101

Grant Reporting Section 3 Summary Report Submit Section 3 reports covering the period of 10/1 – 9/30 by November 14 th Any projects or activities that exceed $200, 000 or more must submit a completed Section 3 Summary Report at the same time as the ASER § This report must describe employment, training and contracting opportunities provided to low and very low-income persons. Report can be found and electronically submitted at the following address: http: //www. hud. gov/offices/fheo/system/index. cfm 102

Grant Closeout Is the project complete? Have responsibilities been carried out satisfactorily? Have all costs incurred been reconciled? Have grant funds and leverage funds been expensed? Have you drawn down all grant funds from LOCCS? 103

Grant Closeout What do you need to closeout the grant? 24 CFR § 1003. 508 – Closeout Procedures 2 CFR § 200. 333 – Retention Requirements for Records FORM SF-425 – Federal Financial Report (Final) Final Annual Status Evaluation Report (Final ASER) Close Out Agreement (24 CFR § 1003. 508) Photographs of the project site 104

Grant Closeout Final Financial Report Element IDENTIFY all expenditures by line item/source as outlined on the HUD-4123, Cost Summary (FSER) IDENTIFY remaining costs to be paid, (such as audit, administration, etc. ) (FSER) IDENTIFY any unobligated balance to be returned to HUD (FSER) SUBMIT a completed Federal Financial Report SF-425 marked “Final” 105

Grant Closeout Program Performance Subpart H of 24 CFR § 1003. 700 -703 describes: l Final Review of Grantee Performance l Final Corrective and Remedial Actions l Final Reduction or Withdrawal of Grant l Final Other remedies for non-compliance 106

Any final questions? 107

QUESTIONS AND CONTACTS Nw. ONAP Grants Management: Tom Carney (206) 220 -6204 Administrator Tom. Carney@hud. gov David Boyd (206) 220 -6161 Director, Grants Management David. P. Boyd@hud. gov Sandel Ferguson (206) 220 -6673 Lead Grants Management Specialist Sandel. Ferguson@hud. gov Amma Cain (206) 220 -6160 Grants Management Specialist Amma. S. Cain@hud. gov Megan Garland (206) 220 -6646 Grants Management Specialist Megan. L. Garland@hud. gov Lisa Stewart (206) 220 -6166 Grants Management Specialist Lisa. Stewart@hud. gov Derreck Wheeler (206) 220 -5378 Grants Management Specialist Derreck. Wheeler@hud. gov Katherine Wilson (206) 220 -6219 Grants Management Specialist Katherine. T. Wilson@hud. gov Niki Paganucci (206) 220 -6372 Program Assistant (e. LOOCS) Niki. A. Paganucci@hud. gov 108