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YOUR 2010 CDBG Grant Administration, Procurement, & Financial Management

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$?$?$?. YOUR 2010 CDBG Grant Administration, Procurement, & Financial Management. 2010 COMPETITION STATS. App’s received: 159 @ $74,459,378 CDBG’s awarded: 75 @ $35,643,405 47% of applications were funded 54,540 beneficiaries, 50,163 LMI (92%)

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2010 competition stats
2010 COMPETITION STATS
  • App’s received: 159 @ $74,459,378
  • CDBG’s awarded: 75 @ $35,643,405
  • 47% of applications were funded
  • 54,540 beneficiaries, 50,163 LMI (92%)
  • 11 more awards & $3+ million more than in 2009

Congratulations!!!!!!

September 30, 2010

what we will cover
What We Will Cover…
  • Grant Award Package
  • Setting up Your CDBG Bank Account
  • CDBG Compliance with Your Field Rep
  • Start-Up, Citizen’s Participation & Fair Housing
  • Procurement
  • Financial Management
  • Closeout

September 30, 2010

grant award package
GRANT AWARD PACKAGE
  • 1. Statement of CDBG Award
  • 2. Budget Summary
  • 3. General & Special Conditions
  • 4. Statement of Revisions
  • 5. Civil Rights Compliance Certification
  • 6. Authorized Signature Card
  • 7. Authorization Agreement for Automatic Deposits (ACH)

September 30, 2010

1 statement of cdbg award
1. STATEMENT OF CDBG AWARD
  • Your CONTRACTwith DCA
  • Include GRANT #on ALL forms & correspondences to DCA
  • GRANT PERIOD: An Important Timeline to Keep

Sign & Return WHITE COPY to DCA.

KEEP PINK COPY FOR YOUR FILES.

September 30, 2010

award package cont 2 budget summary
Award Package, Cont.2. BUDGET SUMMARY
  • Your Official Budget
  • Use THIS budget (not application’s) to create your ledger, accounting records
  • Local match/leverage is listed at bottom; keep documentation of it – it will be monitored
  • DO NOT SIGN & RETURN this form w/award pckg

September 30, 2010

award package cont 3a general conditions
Award Package, Cont.3a. GENERAL CONDITIONS
  • Included in ALL CDBG awards
  • Includes standard, mandatory CDBG compliance responsibilities (Environmental, Section 3, Conflict of Interest, etc.)
  • Must be signed & returned in award package

September 30, 2010

award package cont 3b special conditions
Award Package, Cont.3b. SPECIAL CONDITIONS
  • Specific to each CDBG Award
  • Elected Official’s Signature = “I agree to clear these conditions ASAP.” Signature ≠ clearance
  • SC is not cleared until you receive a “Grant Adjustment Notice” (no clearance, no $$$)
  • Must be signed & returned in award package

September 30, 2010

award package cont 4 statement of revisions
Your Statement of Award might say, “This award is subject to revisions” →

Changes to proposal were made (usually budget)

Review thoroughly, sign & return with award pckg

Award Package, Cont.4. STATEMENT OF REVISIONS

September 30, 2010

award package cont 5 civil rights compliance
Award Package, Cont.5. CIVIL RIGHTS COMPLIANCE
  • To be completed by employee responsible for personnel
  • Explain any civil rights complaints in space provided
  • Preparer of form plus Chief Elected Official should sign
  • Must be signed & returned in award package

September 30, 2010

award package cont 6a authorized signature card
Award Package, Cont.6a. AUTHORIZED SIGNATURE CARD
  • Nothing to do with Bank Account, Everything to do with Draw-Downs.
  • Local authorization to sign & submit draws
  • Up to 4 people can be authorized; should be readily available to sign when needed
  • Gives option of 1 or 2 signatures on draws
  • At least one local gov signature is required (employee or official)

September 30, 2010

award package cont 6b authorized signature card
DCA requires TWO signatures on draw downs if either…

Elected official authorizes him/herself on draw downs, or

Grant administrator is authorized to sign

Additional Points:

Important to keep a signed copy

Signers go on vacation, get sick, etc. Authorize enough people to fill in when needed.

Award Package, Cont.6b. AUTHORIZED SIGNATURE CARD

September 30, 2010

award package cont 7 automatic deposits ach
Award Package, Cont.7. AUTOMATIC DEPOSITS (ACH)
  • Draw-Downs deposited electronically to your CDBG bank account
  • To complete:
    • Attach voided check
    • Fill in bank & account info, CDBG number, authorized signatures, etc.
  • Will take a couple of weeks to set up E-process
  • Must be signed & returned in award package

September 30, 2010

award package cont important final reminders
Award Package, Cont.IMPORTANT FINAL REMINDERS
  • Keep copies of your entire award package
  • Sign & Return Grant Award Package docs* by November 1st
  • Remember: No Signed Award Pckg = No $$$

September 30, 2010

your cdbg bank account
YOUR CDBG BANK ACCOUNT
  • Separate,non-interest bearing bank acct for each CDBG award
  • Acct is for CDBG $$$ ONLY (no match or any other project funds)

Tips:

    • Check with bank for minimum balance; if local $ is used to open, it can be reimbursed later
    • CDBG will not pay insufficient fund charges
    • Regular $ on hand should be $5K* or less

September 30, 2010

cdbg compliance with your field rep
CDBG Compliance with your Field Rep

Your responsibility is to…

  • Keep project on schedule
  • Stay on top of Quarterly Reports, Draw-Downs, Special Conditions…all can create delays
  • Field Rep will monitor at least once per 6 months
  • Communicate problems/delays on your QR’s andto your Field Rep
  • Violations will result in sanctions (see Ch.1, section 15)

September 30, 2010

your field rep s project review checklists are in appendix 2
These are the forms we use when we visit

Use them as a cheat-sheet to prepare for monitorings

Ask in advance what we will be looking for

Your Field Rep’s Project Review Checklists are in APPENDIX 2…

September 30, 2010

start up site visit

START-UP SITE VISIT

Within 60 Days of Grant Award

Elected Official

City or County Clerk

Grant Administrator

Interested Parties

Low/Mod Surveys

START-UP SITE VISIT

September 30, 2010

start up site visit cont
Start-Up Site Visit, cont.

Your Field Rep will look for…

  • The CDBG Application
  • Citizen Participation plan
  • Financial records - including QR’s, bank statements, invoices, & bank register showing receipts & disbursements in chronological order (i.e., CDBG Check Book)
  • Environmental Review Record
  • Other pertinent information such as engineering plans or floor plans

September 30, 2010

citizen s participation ch 1 sec 8
Citizen’s Participation(Ch. 1, Sec. 8)

Mandatory Public Hearings*

  • Prior to application submission (“pre-award PH”)
  • Within 60 days of Grant Award Date (“post-award PH”)
  • At time of Project Completion (“close-out PH”)
  • Plus a PH only if CDBG program is amended

* See sample PH notices in Appendix 1)

September 30, 2010

citizen s participation cont
Citizen’s Participation, cont.

Public Hearing Protocol

  • A full 5 CALENDAR DAYS must pass from publication date to public hearing date.
  • DO NOT count publication date or public hearing date as part of the 5
  • DO NOT publish in legal section
  • Convenient times, locations
  • Both handicap & foreign language accessible

September 30, 2010

citizen s participation cont1
Citizen’s Participation, cont.

Things to Remember…

  • Post-Award PH Must be held within 60 days of award (by November 30th)
  • Notify your Field Rep at least 1 week in advance
  • A Good Idea: why not schedule your PH’s in tandem with Start-Up & Close-Out Monitorings?

September 30, 2010

fair housing complete at least 2 to affirmatively further fair housing
Resolution supporting State/Federal FH Law

Public Information Campaign on FH

FH Discussion on Public Hearing Agenda*

Other?

Distribute FH brochures at public meeting

Post FH Posters at City/County Buildings*

Provide FH info to relocatees

* Most Common

Fair HousingComplete at Least 2 to “affirmatively further Fair Housing”

September 30, 2010

procurement
“ALL procurement transactions will be conducted in a manner providing full & open competition.” (Ch. 3, Sec. 4[c])Procurement

September 30, 2010

procurement1
Procurement

3 BROAD TYPES:

  • Small Purchases < $100K
  • Professional Services from the Private Sector (grant administrator, engineer, architect)
  • Public Works Construction

For Your Reference:

--Chapter 3, Section 4

--Appendix 2

    • 24 CFR 85.36
    • CONFLICT OF INTEREST REGULATIONS
    • Georgia Local Government Public Works Construction Law

September 30, 2010

procurement cont
Procurement, cont.

AVOID CONFLICTS OF INTEREST WITH OFFICIALS AND STAFF

  • Applies to Procurement of ALL goods & services
  • Officials & Staff should not benefit from CDBG by
    • Having a financial interest
    • Receiving a direct program benefit
    • Having family or business ties to CDBG project
  • NO EXCEPTIONS with a Procurement C.O.I.***
  • Much more detail to come (see Rick Huber Presentation from this Workshop)

September 30, 2010

procurement cont1
Procurement, cont.

Type # 1: Small Purchases < $100K

  • Bargain Shop
  • Get price quotes from several different qualified sources
  • Keep documentation in file
  • This method cannot be used for Professional Services

September 30, 2010

procurement cont2
Procurement, cont.

Type # 2: Professional Services

  • “Competitive Negotiations”
  • Advertise RFP or RFQ (include “evaluation factors”) in newspaper and/or “publication with adequate circulation & exposure”
  • Request proposals via U.S. Mail from “known providers” (at least 7 for grant admin; at least 10 for engineer or architect)
  • Allow minimum of 30 days response time
  • KEEP DOCUMENTATION (ads, mail receipts, etc.)

September 30, 2010

procurement of prof services cont
Procurement of Prof Services, cont.

Prepare written evaluation plan with method for scoring proposals

EXAMPLE:

Evaluation Factor #1

“Grant administrator’s knowledge of CDBG guidelines and regulations”.

Score range 4, 3, 2, 1, 0

4 points = 5 or more years of training

3 points = 3-4 years of training

2 points = 2 years of training

1 point = 1 year of training

0 points = less than 1 year of training

September 30, 2010

procurement of prof services cont1
Procurement of Prof Services, cont.

FINAL NOTES:

  • Include Evaluation Factors in RFP/RFQ
  • Scoring involves Elected Officials & Staff
  • After evaluating/scoring, notify legal council & obtain official approval from Council or Commission
  • If Procurement of Prof Services process was executed for a previously denied application, re-advertising is not necessary to retain same firm (if ≤ 1 CDBG year)
  • KEEP RECORDS of all required actions – it will be monitored (ads, mail-outs, evaluations).

September 30, 2010

procurement of public works construction
Procurement of Public Works Construction
  • Advertise for “Competitive Sealed Bids”
  • Traditional “Design-Bid-Build” model vs. Non-Traditional “Design-Build” or “Construction Management” models
  • If non-traditional, you must first consult with Legal Counsel & DCA
  • Reference Appendix 2
    • Georgia Local Government Public Works Construction Law
    • 24 CFR Part 85 (“Common Rule”)

September 30, 2010

procurement of public works construction cont
Procurement of Public Works Construction, cont.

What’s Included in the Bid Advertisement?

  • Work hand-in-hand with engineer to prepare complete & specific CDBG project description
  • Seek a “firm-fixed price” contract*
  • Selection of winner is “principally based on price”
  • Bid ads must include mandatory bonding requirements, pre-qualifications, & pre-bid conferences
  • All bids must be opened publicly at time & place specified in bid ad

September 30, 2010

procurement of public works construction cont1
Procurement of Public Works Construction, cont.

The Bid Advertisement, cont.

  • Include Alternates to the “Base Bid”
    • “DEDUCTS” (you’d prefer to keep but can do without)
    • “ADD’S” (non-essential but you’d like to have)
  • List them by priority because…
    • When bids come in too close to call, these can make difference in determining lowest bidder
    • It levels playing field for pool of contractors
    • Addresses “change-order” issues in advance

September 30, 2010

procurement of public works construction cont2
Procurement of Public Works Construction, cont.

Bid Advertising Requirements

  • Advertise at least 4 consecutive weeks prior to bid opening
  • Specifications must also be available at local gov office from 1st day of advertising

Advertising Options:

  • “Legal Organ” (newspaper)
    • 1st ad “at least 4 weeks prior to the opening of the sealed bids or proposals”
    • 2nd ad “shall follow no earlier than 2 weeks from the first advertisement”*
  • Internet
    • At least 4 consecutive wks continuously prior to bid opening on local gov website or other site “identified by the governmental entity”

September 30, 2010

procurement cont3
Procurement, cont.

If bids come in really low or too high, formally request DCA approval to:

  • Change Project Scope (increase or decrease)
  • DCA reserves right to approve or reject

If you only get one bid for contract (professional service or construction)

  • It’s called “non-competitive” procurement (Ch. 3, Section 4)
  • You must request DCA’s “sole source approval” by providing:
    • Advertisement documentation, dates
    • Response date
    • List of firms who received solicitation
  • Wait to receive DCA letter before proceeding

September 30, 2010

procurement final
Procurement, final

Contracts paid with CDBG $

  • Administrative Contract Requirements see Ch. 1 Section 18
  • For all contracts paid with CDBG $:
    • Appendix 2 → Project Review Checklists → #4 Procurement Review → “CDBG CONTRACT & CONTRACTOR PROCUREMENT REVIEW CHECKLIST”
  • This matrix is key to required clauses & bonds for your contracts
  • All contracts should include compensation amount (“firm-fixed price”)

September 30, 2010

financial management
FINANCIAL MANAGEMENT

September 30, 2010

financial management1
Financial Management

“…financial records should be established & maintained in such a manner as to facilitate the reporting and monitoring of expenditures and obligations by activity.”

--Ch. 3, Financial Management & Administration

Bottom Line:

  • You need a good ledger and financial filing system for your project – please review Chapter 3 carefully.
  • You will be monitored for Financial Management

September 30, 2010

financial management cont
Financial Management, cont.

Draw-Downs:

  • Separate, non-interest bearing bank account with automatic deposit
  • DCA processes draws on Tuesdays & Thursdays
  • Time your draw-downs accordingly; “funds should be in your bank 6 days from the day DCA processes request”
  • Match signatures to those on Authorized Signature Card
  • Funds should be paid out of your account no later than 3 days after they are deposited

September 30, 2010

financial management cont1
Financial Management, cont.

Note Mailing Address for Draw Down Requests*

Office of Community Development

Georgia DCA

P.O. Box 15523

Atlanta, GA 30333

September 30, 2010

financial management cont2
Financial Management, cont.

You cannot Draw Down funds until you…

  • Complete and submit grant award package to DCA
  • Clear your special conditions through GAN’s
  • Receive DCA environmental clearance for non-exempt activities
  • …are caught up on Quarterly Reports
  • Verify required cash match (for final draw down)

September 30, 2010

financial management cont3
Financial Management, cont.

Required Cash Match

  • Formula: 5% of every $ between $300,001 & $500K; 10%of every $ between $500,001 & up
  • Must be verified by Field Rep to receive final draw
  • CDBG Housing-only awards exempt from Match

Required Local Leverage

  • We gave you bonus points for this
  • Field Rep will monitor by Close-Out

Each of these items are found in the Budget Summary of your Grant Award Package

September 30, 2010

financial management cont4
Financial Management, cont.

“Program Income”

  • Recall “non-interest bearing” checking account
  • If the CDBG generates $, you have to return it to DCA
    • See Ch.3, Section 3 for income examples

Exceptions to that Rule:

  • CDBG Revolving Loan Fund (typical with Econ Dev)
  • Permissible CDBG checking acct balance up to $5K

September 30, 2010

financial management cont5
Financial Management, cont.

Program Amendments, Budget Revisions or Other Adjustments (Ch. 3, Section 9)

  • You must receive formal DCA Approval to…
      • Add a new activity or delete an approved activity
      • Decrease scope of activity by 10% or more
      • Propose activity in area other than approved CDBG Target Area
      • Transfer funds from one activity to other by 10% or more
  • DCA will consider effect on match/leverage
  • If proposed change is substantial, you must hold another public hearing

September 30, 2010

financial management cont6
Financial Management, cont.

Quarterly Reports

  • Due 30 days after end of each Qtr (4/30, 7/30, 10/30, 1/30*)
  • Failure to comply = No $ Draw Down
  • Fill out Narrative Section WELL – makes life easier
  • Check “Final” QR only after all activities & expenditures are complete & beneficiaries recorded

September 30, 2010

financial management cont7
Financial Management, cont.

Audit Requirements (Ch. 3, Section 2)

“Must contract for annual independent audit” and submit to DCA

  • If Recipient spend $500K or more in total Federal funds (CDBG plus other)…
    • Follow OMB Circular A-133
  • If $500K or less in total Federal funds…
    • Recipient is exempt from Federal Audit requirements but not from State Audit Requirements

September 30, 2010

close out
Close-Out

Your field Rep will need to see the following:

  • Final Public Hearing (at least one week advance notice); we will keep copied documentation
  • Final Quarterly Report
  • Final Wage Compliance Report
  • Surveys & Beneficiary Data (very low income, low income, moderate income, above moderate income)

This will result in “Conditional Closeout” Letter

September 30, 2010

closeout cont
Closeout, cont.

After audit requirements satisfied, you will receive “Final Closeout Letter”

Retention of Records (Ch. 1, Section 10)

  • Retain for at least 3 years after Final Closeout Letter
  • For “non-expendable property”, retain records for 3 years after final disposition of property

September 30, 2010

immediate action items
Immediate Action Items:
  • COMPLETE & RETURN grant award package by Nov. 1st!
  • SCHEDULE & HOLD post-award public hearing within 60 days of award (by November 30th, notify field rep).
  • OPEN non-interest bearing checking account.

September 30, 2010

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