2009 Shelter Plus Care Start-up What You Need to Know About LOCCS and Financial Management
NEW GRANT NUMBERS • MN-0000-C-5K-00-08-00/01 • MN = Minnesota • 0000 = PIN number/unique identifier • C = SPC • 5K = Minneapolis HUD Office • 00 through 11 = Continuum Number • 08 = year of the funding/application • 00 = new grant 01 = first tracked renewal
What is LOCCS? • Line of Credit Control System • It is a Voice Response System (VRS) • It’s used to access your grant dollars. Access is through your telephone system. • Information on LOCCS, including authorization forms and direct deposit forms, are mailed to you with the grant agreements prior to execution
Steps to Complete Prior to Making Your First Draw • Complete Environmental Review, if applicable • Execute the Grant Agreement • Complete the Direct Deposit Form • Complete the LOCCS Authorization Form • Activate USERID within 45 Days of Receipt • Refer to the grantee financial instructions mailed with your grant agreement for a sample call • Get VRS number from HUD Representative
Environmental Reviews • Are completed by local units of government when they are the grantee. • Must be completed prior to entering into any contract or otherwise commit any HUD or local funds for acquisition, rehabilitation, conversion, leasing, repair, or construction of property to provide housing under the program. • Lead-based paint regs apply to all projects approved after September 15, 2004 (pre-1978 buildings) . • Contact your CPD Representative if you run into problems regarding this item.
Lead-based Paint Regulations • Are found at 24 CFR Part 35 • Requirements are: provision of pamphlet, visual assessment, paint stabilization, notice to occupants, ongoing lead-based paint maintenance and response to EBL (elevated blood level) child. • Good resource: http://www.epa.gov/lead/
Grant Terms • SPC grants are effective the date the Grant Agreement is signed by HUD. • Therefore, the grant term begins on that date and operates for a term of 1 year, 5 years, or 10 years depending on whether it is a new grant, grant extension, renewal grant, or a SPC grant with a rehab component.
Things to Remember When Completing Direct Deposit Form - 1199A • Section 1 is completed the Grantee • Remember to include Tax ID Number and Grant Number in Section 1, Item C • Section 2 is completed by HUD • Section 3 is completed by the Bank • * Include Void Check or Deposit Slip for Account Verification • Mail completed form to local HUD office for processing
Download Direct Deposit Form - SF 1199A • http://www.fms.treas.gov/eft/1199a.pdf • or Call HUD Office at 612-370-3019 to request a copy of the form
Things to Remember When Completing the LOCCS Authorization Form HUD- 27054 • Be Sure ALL Signatures are Dated • The Notary is Witnessing the Authorizing Official’s Signature - Signature Dates Should Match
Recommendation • We strongly recommend that you have a primary and a backup person approved for making draws (in case the primary person is unavailable to make a draw). • ID’s and passwords are unique to an individual, do not share them • Remember - authorized persons need to keep their passwords active! They do expire.
LOCCS Passwords Expire! • Passwords Automatically Expire Every 21 Days • You Will be Prompted to Change Them Between 21 and 44 Days Following Your Last Access • After 45 Days You Will be Locked Out of the System and Need to Get it Reset
To Get A Password Reset You Must Complete the Authorization Form Again and Fax it to LOCCS Security at 202-708-4350. This can cause delays in accessing your funds!
When the Approving Official Changes • New approving official needs to submit a letter to LOCCS security • Use letterhead of your organization • Include: name, title, social security number, daytime phone number and address of the new approving official • Sign, Date and Notarize the new approving official’s signature, Fax to LOCCS Security at 202-708-4350 • Mail original to Local HUD Office for processing
LOCCS Security Help Desk 1-877-705-7504
You May Download the LOCCS Authorization FormFrom HUD’s website at: • http://www.hudclips.org/subscriber/html/forms.htm • Select: HUD-2 • Select: line 154: HUD-27054 Voice Response System • Select: fillable PDF form
Drawdowns, You Will Need: • The 10-digit VRS Number which is generated in LOCCS and used in place of the grant number • 3-digit program code, SPC is 030. These three digits become the first three digits for the voucher number. The system will give you 6 additional numbers. Write them down! You will need to re-enter all 9 digits to validate the request. • Funds are drawn on a reimbursement basis or if drawn in advance, they must be disbursed within 3 days after the funds are deposited into the bank account • Draws are wired to grantees bank account within 48 hours of approval
Approval Means • When the request has passed all LOCCS edits • OR • If a HUD review is required, it is when the HUD person responsible to review the request has approved the request
What Happens fterYou Have Made a Request for Funds? • The LOCCs System is taken down daily at 9 pm eastern time to create a payment tape which is sent to Treasury the next business day. • Funds will be wired to the bank account designated on the direct deposit form.
Eligible Budget Line Items • Rental Assistance • Administrative Costs - up to 8%, which is requested from the rental assistance • Caution: Be sure you know HUD’s definition of administration costs for the SPC program
Definition of Admin • It is the cost of administering the housing assistance NOT activities related to the general operation of the grant. • Examples: processing rental payments, verifying participant income, rent calculations, costs associated with HQS unit inspections, processing new tenants. • Comes out of the funds set aside for rental assistance using line item #1060.
Rental Assistance Budget Line Item Numbers for Drawing Down • 1000 SRA – Sponsor-based • 2000 TRA – Tenant-based • 3000 PRA – Project-based • 3100 PRA – Project-based w/o Rehab • NOTE: All funds are held in one of the above line items, no funds are held in line 1060 • 1060 Administrative Costs
Conditions on Admin Usage • A recipient must serve at least as many participants as shown in its application. • May be used when the grant amount reserved for rental assistance will exceed the actual amount that will be needed to pay the rental subsidy, (rents lower than FMR or participants paying a portion of the rent) grantees may use the remaining funds for eligible administrative costs, one-month vacancy claim, or to repair damages to the unit
LOCCS Toll-Free Number for Requesting Funds 1-877-705-7505
Timeliness • NEW REQUIREMENT • The 2009 grant agreement requires that a grantee draw funds on at least a quarterly basis.
Additional Resources • HUD’s Website is: WWW.HUD.GOV • General homeless program information can be found at: • http://www.hud.gov/offices/cpd/homeless/ • Shelter Plus Care information • http://www.hud.gov/offices/cpd/homeless/ programs/splusc/index.cfm
OMB Circulars • OMB stands for Office of Management and Budget • The Circulars are regulations that apply across all Federal agencies. • Contain information you on financial management, audits, procurement, allowable costs • Its what you need to know to stay out of trouble with federal regulators • KEY: When in conflict, program regulations supersede the OMB Circulars.
List of Applicable Circularsand Regulations • A-122 *Cost Principles for Non-Profit Organizations • A-133 *Audits of States, Local Governments, and Non-Profit Organizations • 24 CFR Part 84 *Grants and Agreements with Institutions of Higher Education, Hospitals and Other Non-Profit Organizations • 24 CFR Part 85 *Uniform Administrative Requirements for Grants and Cooperative Agreements to State and Local Governments
Financial Systems • Must be detailed enough to identify costs by funding source. • Must provide accurate, current and complete disclosure of financial results of each Federally sponsored project. • Must have written procedures for determining reasonableness, allocability and allowability of costs.
OMB Circulars Can Be Downloaded From • http://www.whitehouse.gov/omb/circulars/index.html • http://www.hudclips.org:80/sub_nonhud/cgi/nph-brs.cgi?d=CF98&l=20&s1=85.$[no]&SECT1=TXTHLB&SECT5=CF98&u=../cgi/legis.cgi&p=1&r=0&f=S
RECORD KEEPING REQUIREMENTS • VOUCHERS - Keep Source Documentation. For Shelter Plus Care this means copies of the rental agreements with the current gross rents and tenant rents, rent calculations, income calculations and how you calculated the amount to be drawn. • You need to keep documentation of determination of rent reasonableness. • MATCH – You must keep documentation of services received by participants and the value of those services. Must match SPC Rental Assistance dollar for dollar. • Records Must Be Kept for 3 Years After Submittal of the Final APR (covered by 24 CFR Part 84)
APRs • Annual Performance Reports • Reports accomplishments of the grant on an annual basis and is used to support SPC needs to Congress/COC • Payment of vouchers will be suspended if not submitted by the due date • Includes a worksheet for tracking information throughout the year • Format/questions will be changing
GRANT EXPIRATIONWHAT NEXT? • Renewals are for a one year period and are funded outside the COC’s prorata share • Extensions may be processed if enough funds remain to allow project to operate at least into the next calendar year and still serve the same number of clients. The extension is for a 5 year term, even if there are only enough funds to pay for 1 or 2 years of rental assistance. The grantee applies for renewal funding in the year prior to running out of funds. • Recapture of Funds - Any remaining balance at the end of the grant term will be recaptured and returned to Treasury
Monitoring • We attempt to visit each grantee at least once every three years • We look at • documentation of homelessness and disability • supporting documentation for LOCCS draws from the grant • evidence of match • written eviction and survivor policies • housing inspection forms and recertification procedures • We visit with participants
REMEMBER • Grantees are ultimately the one held responsible for all of the projects activities, even those carried out by project sponsors. • We will be monitoring you to see if you are doing/did what you said you were going to do in your application to HUD • Reviewing documentation to support that you are serving homeless persons with disabilities.
Shelter Plus Care Website • http://www.hud.gov/offices/cpd/homeless/library/spc/ • For more generic homeless program information you can go to: • http://www.hud.gov/offices/cpd/homeless/library/
Where to Get More Information • CPD Division: 612-370-3019 • Sara Bergen, extension 2103 • Mary Burbank, extension 2102 • Joe Geary, extension 2257 • Tom Koon, extension 2108 • Ben Osborn, extension 2237