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CDBG Changes in IDIS

U.S. Department of Housing and Urban Development

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Welcome

Purpose:• Provide background/status of IDIS changes

in Release 11.4• Listen to feedback• Answer questions

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Purpose of System Changes

Enhance the role of IDIS as a tool to strengthen the oversight of CDBG activities.

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IDIS Release 11.4

How we got here…

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Results of OIG AuditOctober 31, 2011

Finding: HUD did not adequately use its system to provide oversight of its Block Grant program• $67million disbursed by over 1,300

activities that grantees cancelled with draws• Nearly $3 billion associated with more than

20,000 activities that grantees failed to complete for up to 11 years

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HUD did not…….

• Have policies and procedures requiring it to routinely use IDIS data to provide oversight of long-standing open activities and activities that were cancelled with draws

• Did not evaluate the adequacy of actions grantees took regarding these activities

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Conclusion

Significant amounts of CDBG funding disbursed nationwide did not…• Benefit low- and moderate-income persons,• Aid in preventing or eliminating slums or

blight , or• Meet community development needs having

a particular urgency

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Result

Puts in jeopardy:

• All the good work you do• CDBG program funding levels• CDBG program

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CDBG Response to Audit

CDBG actions in response to the audit have included: Resolving the nearly 23,000 long-standing open activities

and activities cancelled with draws Issuing activity resolution and reporting guidance Incorporating review of IDIS data into monitoring

procedures in the monitoring handbook Creating “IDIS Resources for the CDBG Program” page on

hud.gov Implementing IDIS system changes to prevent

longstanding open activities, reduce the number of activities that are cancelled with draws, and track revised draws

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Overview of System Changes

The new functionality includes: Flagging and requiring remediation plans for the

following activities:• Activities without draws for 12 months• Activities with no accomplishments reported after three years • Activities that are 80% drawn down no accomplishments

reported Requiring approval for activities that grantees want to

cancel with draws Requiring justifications for draws revised from one

activity to another

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Planned Modifications

Scheduled for IDIS Release 11.5, May 30, 2013

One Remediation Plan per At-Risk Activity, no matter how many “at-risk” conditions it meets

Exempt public facilities and certain economic development activities from the 80 percent drawn and no accomplishments factor

Due dates For Remediation Plans will appear on Review Activities list

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These Changes are about…

OVERSIGHT not COMPLIANCE

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Compared to Recent HOME Changes

Similar:– Flagged activities show up on a banner and require

entry of narrative fields and dates

But different:– CDBG changes do not block grantee access to

activities – No automatic impact on activities

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Working with these Changes

Initially, a large backlog of activities, requiring both grantee and field office action, has been flagged

Deadlines for action by grantees and field offices

Extending deadlines for initial backlog—three months for grantee action and three months for FO action instead of two weeks

Work with your field office

Grantees may need to go into IDIS more frequently

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Remediation Plans

HUD is more likely to approve plans:

–That have specific timelines

–That have everything in place, including developers and legally committed financing

–When agreements ensure that CDBG funds are repaid in case of failure

–When comprehensive underwriting practices were exercised

–When relevant details are provided

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Remediation Plans

Samples of Adequate JustificationsActivity Description Reasons for Delay Action Plan

Construction of a new senior center

This project is on schedule. From beginning to end, the timeline for completing the project has always been 3.5 years.

Construction will be completed by June 2013. Accomplishment data will be gathered and entered into the system by December 2013

Loan to business The business could not provide a reason for the delay in creating jobs even though its expansion occurred two years ago. The State Grant Recipient has asked the business for a timeframe during which the jobs would be created and discussed loan repayment in accordance with the terms of its agreement with the borrower.

If job creation does not occur by June 2013, the borrower will repay the loan in full, according to the terms of its agreement with the State Grant Recipient.

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Remediation Plans

Activity Description Reasons for Delay Remediation PlanEconomic Development Activity: Assistance to Private Business (extension to facility & purchase of equipment)

Warehouse construction was delayed, which in turn delayed the purchase of the new equipment funded by CDBG.

The new warehouse building is on schedule to be completed within 5 months, by August 2013. Once completed and new equipment is installed, the business will begin the hiring process for newly created positions. The job reporting period will be ongoing through December 2013 with the activity to be completed in IDIS by January 2014.

48-56 Treelined Avenue CDBG used for acquisition and HOME funds are being used for rehabilitation of these units. Rehabilitation just completed. Properties have all been sold to eligible home owners

HOME-funded rehabilitation work will be completed in December 2012. The units have already been sold to income-eligible households, who will occupy the units by February 2013. Accomplishments will be reported in March 2013 and the activity will be completed. At that time.

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An Inadequate Remediation Plan

Activity Description Reason for Delay Remediation Plan What’s Wrong?

Economic Activity has not yet Jobs will be reported in There is no clear

Development Activity: created any jobs. IDIS when the activity explanation about

Assistance to Private Business (extension to facility & purchase of equipment)

creates jobs. why the project is stalled, no timeline for getting the project back on track, and no description of the underwriting requirements used to award this grant.

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Status of At-Risk Activities

All CDBG Grantees

Total Flagged Activities 39,542

Number of Activities Flagged as of January 18, 2013

29,551

Number of Activities Completed, Canceled or having Remediation Plans

9,991

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Status of At-Risk Activities

Entitlement Communities

Total Flagged Activities 26,329

Number of Activities Flagged as of January 18, 2013

19,056

Number of Activities Completed, Canceled or having Remediation Plans

7,273

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Great Job!

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Need Help?• Contact your field office to have HUD complete certain activities

for you

• Webinar Converted/older activities that were never funded

IDIS malfunctions/new data requirements

Pre-2000

Other

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Need Help?• Contact your field office to have HUD complete certain activities

for you

• Webinar Converted/older activities that were never funded

IDIS malfunctions/new data requirements

Pre-2000

Other

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Resources

• Grantee Instructions• Webinar• FAQs

On OneCPD website andwww.hud.gov/offices/cpd/systems/idis/cdbg