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City of New Bedford
Office of Housing & Community Development
CDBG | CDBG-CVSUBRECIPIENT TA WORKSHOP
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A copy of this presentation is now available on our website athttps://www.newbedford-ma.gov/housing-community-development/.
Please feel free to contact our office at [email protected] if you require translation assistance with the PowerPoint. Questions may be asked either through the chat box available through this Zoom meeting,
or through email at [email protected]. All comments and questions are welcome. Responses to frequently asked questions will be posted online in three languages.
Welcome!
Una copia de esta presentación ya está disponible en nuestro sitio web en https://www.newbedford-ma.gov/housing-community-development/.
No dude en ponerse en contacto con nuestra oficina en [email protected] si necesita asistencia de traducción con PowerPoint. Las preguntas pueden hacerse a través del cuadro de chat disponible a través de esta reunión de Zoom,
por correo electrónico a [email protected]. Todos los comentarios y preguntas son bienvenidos. Las respuestas a las preguntas frecuentes se publicarán en línea en tres idiomas.
Uma cópia desta apresentação está agora disponível em nosso site em https://www.newbedford-ma.gov/housing-community-development/.
Não hesite em entrar em contato com nosso escritório em [email protected] se precisar de ajuda na tradução do PowerPoint. As perguntas podem ser feitas através da caixa de bate-papo disponível nesta reunião do Zoom, ou através do e-mail
[email protected]. Todos os comentários e perguntas são bem-vindos. As respostas às perguntas frequentes serão publicadas on-line em três idiomas.
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AGENDA
▪ CDBG Refresher
▪ The Subrecipient Agreement
▪ Procurement
▪ Income Certification
▪ Reporting
▪ Monitoring
▪ Program Reminders
▪ Next Steps
▪ Contacts
▪ CDBG-CV Grants
▪ Remember…
CDBG | CDBG-CV
SUBRECIPIENT
TA WORKSHOP
City of New Bedford
Office of Housing
& Community
Development
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CDBG Refresher
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CDBG Eligible Activities
✓ Must meet a national objective
• Benefit low to moderate income persons
• Prevent slum or blight
• Address urgent community needs
✓ Not less than 70% of spending must benefit low to
moderate income persons
CDBG Refresher
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Eligible CDBG program components:
✓ Infrastructure Improvements (streets and sidewalk restoration in eligible census tracts)
✓ Public Facilities
(rehab of buildings, handicapped accessibility)
✓ Public Services
(recreation, health, counseling, case management, youth, seniors, etc. for LMI)
✓ Park Improvements
(playground equipment, landscaping, lighting, etc.—in eligible census tracts)
✓ Housing and Rehab
(assistance to senior citizens, housing accessibility improvements, etc.)
✓ Economic Development (job creation activities, storefront façade improvements, micro enterprise
development, etc.)
20%
max
CDBG Refresher
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The Subrecipient
Agreement
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Why a Subrecipient Agreement ?
✓ The city is the recipient of federal CDBG
funding.
✓ As an agency awarded funding under this
program, your agency must enter a
contractual relationship with the city.
✓ The contract—or “subrecipient
agreement”—follows the fiscal year.
✓ Your FY2020 agreement covers
July 1, 2020 - June 30, 2021.
The Subrecipient Agreement
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Key Sections of the Agreement:
✓ Signature Page
✓ Scope of Services
✓ Performance and Outcome Measurements
✓ Reimbursement Process / Form
✓ Budget Summary
✓ Reimbursement Basics
✓ Budget Amendment Process / Form
✓ Procurement Policy
The Subrecipient Agreement
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Executing the Agreement:
✓ The subrecipient agreement is not a legally
executed contract until it is properly signed by each
of the signatories for both the city and your
agency.
✓ It is required that your agency sign the document
first; once that is done the city will then sign it.
✓ Only an authorized signatory for your agency can
sign this agreement.
The Subrecipient Agreement
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Scope of Services:
✓ Based on the final description of the awarded
activity and intended to describe the CDBG
funded activity.
✓ Each scope of service has the following:
Total estimated # of person to be served
Total estimated # of LMI persons to served
Anticipated % of LMI persons to be served
✓See Appendix A of the agreement.
The Subrecipient Agreement
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Performance and Outcome Measurements:
✓ System designed to assess the effectiveness of a
program
✓ In the subrecipient agreement, the performance-
based measurements section includes:
Needs statement
Project goals
Proposed activity
Expected outputs and outcomes
✓ See Appendix A of the agreement.
The Subrecipient Agreement
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Performance and Outcome Measurements:
✓ Your program will be expected to perform to the
standards stipulated in the Subrecipient Agreement.
✓ All outputs and outcomes must be reported each
quarter.
✓ As a CDBG Subrecipient you will want to
consistently understand your project’s performance
measures throughout the program year, ensuring
consistency with the targets you’ve established.
The Subrecipient Agreement
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Performance and Outcome Measurements:
✓ Be sure to contact the OHCD if you anticipate or
are experiencing challenges that will preclude the
project from achieving its targeted performance
measures.
✓ Do not wait until reporting to advise of a problem;
the earlier you contact the OHCD the better.
✓ We want your project to succeed!
The Subrecipient Agreement
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Reimbursements
✓ You can invoice by submitting a “Request for
Reimbursement” either monthly or quarterly:• Monthly requests should reflect the previous month. (ex. Reimbursement
for eligible program activities in July must be submitted by August 10th.)
• Quarterly requests should reflect the quarter previous to the
reimbursement submission. (ex: Second quarter reimbursement request must be
submitted by January 10th.)
✓ All Requests for Reimbursement must always include all
invoices, receipts, cancelled checks and other
documentation justifying the claimed reimbursement costs.
✓ See Appendix B of the Subrecipient Agreement.
How do we get
our money?
The Subrecipient Agreement
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Reimbursements
✓ You need to pay attention to timing!
• Expenses for Fiscal Year 2020 must fall between July 1,
2020 through June 30, 2021.
• Costs incurred prior to July 1, 2020 are ineligible.
• Final invoices for Fiscal Year 2020 must be submitted no
later than July 9, 2021.
What gets
paid?
The Subrecipient Agreement
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Reimbursements
✓ Use the Reimbursement Form!If you want to request reimbursement for your CDBG eligible
expenses, you must submit a completed reimbursement form
and supporting documentation.
✓ Reimbursement Form must contain:• Date of Request
• Authorized Signature
• Period Covered by this request
• Amount of Request Now
• Current Expenditures
✓ See Appendix C in the Subrecipient
Agreement
The Subrecipient Agreement
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Reimbursements
✓ Other important sections!
• Budget Adjustment (If required)
• Current Expenditures
• Cumulative Expenditures
• Balance after this reimbursement
✓ The reimbursement form is an excel document that
has formulas in each cell.
✓ Once you plug-in an amount in a cell, the form will
auto calculate the total.
The Subrecipient Agreement
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Reimbursements will only happen IF your invoice…
…Is accompanied with supporting documentation.
…Shows how items being reimbursed conform to your scope of
services.
…Includes documentation is not “self explanatory” make a note on
the invoice to explain how items support the project.
And don’t even THINK about…
…State and federal taxes, as well as late fees related to the
payment of taxes, because they are ineligible and won’t be
reimbursed.
…Submitting an invoice after the due dates.
The Subrecipient Agreement
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Reimbursements 101
✓ Check will be issued only
if…
✓ Checks are generally
available…
All documentation is
acceptable.
2 weeks from the date the
OHCD receives
documentation.
The Subrecipient Agreement
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Budget
✓ The Subrecipient Request for Reimbursement
Form provides an itemized breakdown of your
approved CDBG budget that includes the
following:
• Category Breakdown
• CDBG Budget
• Budget Adjustment
• Current Expenditure
• Cumulative Expenditures
• Balance after Reimbursement.
✓ See Appendix C of the Subrecipient
Agreement.
The Subrecipient Agreement
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Budget Amendment Process
✓ Reimbursement requests that are different than what
exists in the subrecipient agreement (or approved
amendment) will be flagged.
✓ If you want to amend the budget, the process includes:
• Submitting a signed cover letter from the agency to
the OHCD formally requesting amendment with
explanation.
• Submitting a completed OHCD budget amendment
form along with the written request.
• Execution of a formal subrecipient agreement
amendment that includes an updated scope and
budget.
The Subrecipient Agreement
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Procurement
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Procurement Policy 101
✓ Contact us first! • Contact the OHCD prior to the procurement of
goods, services, supplies or equipment to obtain
the necessary forms and documents.
✓ Follow the law!• Good and services must be procured according
to MA General Law 30B and this table.
• Procurement Regulations have been updated as
of July 2020 and incorporated into your
Subrecipient Agreements
✓ Read your agreement!• See Appendix D of the agreement.
Procurement
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Income Certification
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✓ HUD requirement • Executing the form…
All participants in CDBG funded programs are
required to complete and sign an income certification
form.
• Annual changes…
On an annual basis, OHCD staff provide
subrecipients with an Income Certification Form that
has the specific income limits for that particular
program year.
• Required of all participants…
In order for a participant to be counted, they must
complete the Income Certification Form.
• Always use current form…
Do not use old income certification forms. Only use
the most current certification for provided by the
OHCD.
Income Certifications
You should
now be using
the FY2020
Forms
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Reporting
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“If it’s not written down, it didn’t happen…”
Reporting
Quarterly Reports
HUD requirement • Reporting is the means by which the productivity and impact of
your program is assessed.
• Quarterly Monitoring Reports are the performance and
outcome vehicle by which this impact is reviewed and
measured.
• The Quarterly Monitoring Report should highlight the number
of clients served in relation to the goals, outcomes and outputs
you agreed to in your subrecipient agreement.
• Quarterly Monitoring Report serves as a tool to identify any
issues with program compliance.
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Quarterly Reports
✓ Due on the 10th of the month following the service period
being reported
SERVICE PERIOD REPORT DUE DATE
7/1/20 thru 9/30/20 10/10/20
10/1/20 thru 12/31/20 1/10/21
1/1/21 thru 4/10/21 4/10/21
4/1/21 thru 6/30/21 7/8/21
7/1/21 thru 9/30/21 10/10/21 (CDBG-CV Only)
10/1/21 thru 12/31/21 1/10/22 (CDBG-CV Only)
Any of these can delay
repayment, can require
revisions and can even lead to
suspension of the
Subrecipient Agreement!
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• Late reports
• Incomplete reports
• Inaccurate reports
Reporting
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Quarterly Reports
✓ OHCD Staff developed a new Quarterly Report format
for FY19 that will also be used now for your FY20
grant.
✓ Quarterly reports have statistical, narrative and
budgetary components:• Cover page
• Client Profile Information
• Performance and Measurements
• Funding Sources
• Published Information
Reporting
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Quarterly Reports
▪ The cover page • Project Specific Information
• Contact Information
• CDBG Budget Amount
• Activity Location
• Contact Information
• Service Period
• Signature
Reporting
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Quarterly Reports
▪ New Clients vs. Total Served
▪ Client Profile Information• Single Race
• Multi Race
• Ethnicity
▪ Persons Benefiting from Activity
• Over Income (80% MFI)
• Moderate Income (51-80% MFI)
• Low Income (31-50% MFI)
• Extremely Low Income (0-30% MFI)
Reporting
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Quarterly Reports
▪ Performance and Measurements
• What was Done (general accomplishments)
• Specific Activities (direct products of your program)
• Direct Results (short and long term benefits)
Reporting
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Quarterly Reports
▪ Financial
• Award Amount
• Quarterly Expense (reported by quarter)
• Balance
• YTD Expense / Balance
• Brief Narrative
Reporting
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Quarterly Reports
▪ Published Information
• News Articles
• Press Releases
• Advertisements
• Public Service Announcements
• Brochures
Reporting
▪ Additional Comments• Anything else we need to know regarding
program performance, etc.
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Monitoring
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When will you get monitored?✓ On an annual basis your program will be evaluated
through a Risk Assessment process to determine if you
will undergo an onsite monitoring visit by OHCD staff.
✓ The City’s OHCD conducts quarterly monitoring also
known as “desktop monitoring” to ensure CDBG
requirements are being met.
✓ The higher the risk, the more likely the program will be
monitored on-site.
✓ At the very least:• Every three years a program will be monitored.
• New programs are automatically monitored
• If a program received a finding from the previous
year will be monitored.
Monitoring
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▪ Quarterly EvaluationsSubrecipients will receive a Quarterly
Evaluation Report template based on your
anticipated performance metrics.
Sections include:
▪ Goals and Objectives Review
▪ Financial Review
Each section will have an opportunity to
comment on any concerns related to
performance.
Monitoring
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Three Focus Areas:
Monitoring
Project
performance
Financial
performance
Regulatory
performance
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Expectations:
▪ Contract Scope of Services
Is it consistent with actual activities?
▪ Levels of Accomplishments
Planned versus actual
▪ Time of Performance
Are there issues with program start-
up?
▪ Budget
Compare actual expenditures versus
planned expenditures
Monitoring
▪ Requests for Payment
Timeliness
▪ Recordkeeping
Comprehensiveness and accuracy of
documentation (activities, costs and
beneficiaries)
▪ Financial Management
Systems in place—accounting,
expenses, income
Regulatory
Performance
Financial
Performance
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Next Steps…
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▪ Review your Program▪ It is strongly recommended that all Subrecipients review their
program—from their Subrecipient Agreement and program
policies and procedures, to their client files and data
collection. Make sure program staff are aware of this as well!
▪ CDBG File Forms ▪ Ensure that all program staff are using correct documents,
correct income certifications, etc. Be sure to carefully review
these materials and develop a familiarity with them.
▪ The Income Certification Forms have already been sent to
all CDBG programs; if you have not received this or have
any questions, please speak with OHCD staff as soon as
possible.
Next Steps…
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▪ Reimbursement▪ Reimbursements may be submitted now.
▪ Quarterly Reports▪ Quarterly Reporting forms will be emailed this month.
▪ New Subrecipients▪ For any new subrecipients, the OHCD will be conducting a
site visit to provide technical assistance in order to ensure
that no startup delays occur.
Next Steps…
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Contacts
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Joseph MaiaGrants Compliance Coordinator
Program Questions
Rob TetraultFinance Manager
Finance Questions
Nicole CurralOffice Manager
General Questions
Patrick J. Sullivan,
PHONE: 508 979-1500
FAX: 508 979-1575
WEBSITE: www.newbedford-ma.gov
Jennifer ClarkeDeputy Director
Overall Program Issues/Questions
Contacts
City of New Bedford
Office of Housing and
Community
Development
CDBG | CDBG-CV
SUBRECIPIENT
TA WORKSHOP
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CDBG-CV Grants
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Coronavirus Aid, Relief, and Economic Security Act
(CARES Act)
• The CARES Act made $5 billion available in supplemental CDBG funding for
grant activities specifically for the purpose of preventing, preparing for and
responding to the Coronavirus (CDBG-CV grants),
• The CARES Act provides flexibilities to make it easier to use CDBG-CV
grants and FY2019 and FY2020 CDBG grants for coronavirus response,
• It also authorizes HUD to grant waivers and alternative requirements,
• …and it requires CDBG-CV grantees to prevent the duplication of benefits,
which means grant funds may not be used to pay costs if another source of
financial assistance is available to pay that cost.
CDBG-CV Funding
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CDBG-CV funding must be used to prevent,
prepare for and respond to coronavirus.
This requirement must be clearly
documented in subrecipient files.
CDBG-CV Funding
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Key Similarities Between Traditional CDBG
Funding and COVID CDBG-CV Funding…
CDBG-CV Funding
Both CDBG and CDBG-CV
• Activities must meet one of three (3) National Objectives:
o Benefit low and moderate income persons
o Aid in the prevention or elimination of slums or blight
o Meet an urgent need
• Activities must serve primarily low and moderate income
individuals and families (no more than 80% percent of the areas
median income adjusted for household size)
• Both funding sources follow the same type of Subrecipient
Agreement, the same income certification requirements as well
as the same reporting and annual monitoring expectations.
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Key Differences Between Traditional CDBG
Funding and COVID CDBG-CV Funding…
CDBG-CV Funding
CDBG
• Program year ends June 30,
2020
• Projects can be used for public
services, economic
development, public
facilities/improvements,
infrastructure improvements,
clearance activities, housing and
rehab activities
• Only 15% of the city’s allocation
of CDBG dollars can be spent
on Public Services
CDBG-CV
• Program year extends to
December 31, 2021
• Projects were limited to public
services and economic
development categories to
expedite funding in the
community
• There is no cap on Public
Services.
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Please Note in the CDBG-CV Subrecipient Agreement…
CDBG-CV Funding
Part II: Appendicies
Appendix CV: CARES Act CDBG-CV Requirements
• Subrecipients must comply with the requirements of the CARES
Act that apply to CDBG-CV grants and must use the funding to
prevent, prepare for and respond to coronavirus.
1.
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CDBG-CV Funding
Part II: Appendicies
Appendix CV: CARES Act CDBG-CV Requirements
• Subrecipients must comply with the requirements of the Housing
and Community Development Act, implementing regulations and
rules, waivers and alternative requirements of Federal Register
Notices.
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Please Note in the CDBG-CV Subrecipient Agreement…
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CDBG-CV Funding
Part II: Appendicies
Appendix CV: CARES Act CDBG-CV Requirements
• Subrecipients agree to establish and maintain adequate procedures
to prevent any duplication of benefits as required by law.
A duplication of benefits occur when a beneficiary receives
assistance from multiple sources (such as the Small Business
Administration, private insurance companies, non-profits, etc.
for a cumulative amount exceeding the total need for a specific
purpose. The duplication amount is the excess assistance
provided above the need.
Subrecipients must ensure that all beneficiaries/businesses assisted
with ESG-CV funding do not receive a duplication of benefits.
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Please Note in the CDBG-CV Subrecipient Agreement…
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A Word About Interim Assistance
CDBG-CV Funding
• CDBG-CV funds may be used to provide emergency grant
payments for subsistence-type expenditures like rent, mortgage,
food or utilities for no more than three consecutive months to
prevent homelessness and/or to prevent utility cutoff.
• Funding cannot be used for arrearages (such as rent
arrearages). Only assistance going forward is eligible. (So if
today is August 6th, that means you can only provide assistance
with CDBG-CV funding for September, October and November
rents—not May or June, etc.
• Agencies must always send payments to the landlord, lender or
vendor, directly; you cannot make any payment to the
beneficiary.
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Remember…
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▪ Review your program—Ensure your staff is “on board”
▪ CDBG-CV file forms
▪ Reimbursements now being accepted
▪ The CDBG-CV program year runs through December 31, 2021
▪ Your first quarterly report (July –Sept) is due Oct 10th
▪ New subrecipients will get a TA site visit from OHCD staff
▪ This powerpoint will be available on the OHCD website at
https://www.newbedford-ma.gov/housing-community-development
▪ OHCD staff can be reached at [email protected] or
through individual email addresses.
Remember…
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City of New Bedford
Office of Housing & Community Development
CDBG | CDBG-CVSUBRECIPIENT TA WORKSHOP
