Increasing Accountability and Oversight

1. Increasing Accountability and Oversight

2. CDBG Reporting Requirements • What’s new • Coming attractions • Tips

3. What’s New • Code enforcement • Multiple addresses for Housing Activities • Lead-based paint • Housing services matrix code 14J • Neighborhood cleanup (05V) and Food Banks (05W) matrix codes

4. Report on New Data Elements for Code Enforcement Activities

5. WHY? • Important to demonstrate the results of code enforcement activities • Important to verify compliance

6. Multiple Addresses for Housing Rehab Activities • HUD still encourages Grantees to report each housing unit in a separate activity • Important to show where CDBG funds are going • Not required but strongly encouraged for State grantees • Multiple addresses are not required for activities that are limited to installation of security locks or smoke detectors, to tool lending libraries, to painting supply programs, or graffiti removal

7. Tips for Entering Addresses for CDBG Activities • Place of performance • Not the address of the administrative offices • For infrastructure activities, use a street address range • No P.O. Boxes

8. New Data Elements forLead-Based Paint Compliance • For housing rehabilitation activities, except for: • Installation of smoke detectors or safety locks • Tool lending libraries • Painting supply programs • Graffiti removal

9. Applicable Lead Paint Requirement • Housing constructed before 1978 • Exempt: Housing constructed 1978 or later • Otherwise exempt: • 0 bedrooms • Elderly/disabled with no children under 6 • Certified lead-based paint free • Used no more than 100 days per year

10. Lead Hazard Remediation Actions • For acquisition— Visual assessment/paint stabilization • For rehabilitation activities: • Lead safe work practices (Hard costs < 5,000) • Interim controls or standard practices (Hard costs $5,000 - $25,000) • Abatement (Hard costs > $25,000)

11. New Housing Services Matrix Code • 14J: Housing Services • 24 CFR 570.201(k) • 105(a)(20) of the Act • Using CDBG funds for Activity Delivery Costs for HOME activities

12. New Housing Services vs. Housing Rehabilitation Administration • Housing Rehabilitation Administration 14H • Housing Services 14J

13. New Public Service Matrix Codes • Neighborhood Cleanup (05V) • Food Banks (05W)

14. Report Accurate Data for Public Services Activities • Use most specific matrix code to accurately describe use of funds, not 05 • Insert a new program year for multiyear activities • Strive to report unduplicated persons served

15. FY 2010 Public Services Expenditures

16. Report Accurate Data for Public Facilities & Improvements Activities • Use most specific matrix code to accurately describe use of funds, not 03 • Avoid combining different public facilities under one activity • Report performance measures when activity completed/benefit realized • Strive to report unduplicated persons served

17. FY 2010 Public Facilities & Improvements Expenditures

18. Coming Attractions • Tracking of accomplishments and expenditures in response to the OIG audit • Section 108 When? September 30, 2012

19. THANK YOU • You have erased over half of the errant CDBG activities identified by the OIG • You are providing detailed documentation to help resolve remaining issues • Our resolution of the OIG audit findings will be a strong determinant of the future of CDBG

20. Tracking Long-Standing Open Activities IDIS will track activities that: • Have no draws within a year’s time period • Have no accomplishments after 3 years and every year thereafter Grantees and field offices will be notified by email when either of these situations occur

21. Tracking Long-Standing Open Activities Grantees will enter into IDIS: • An explanation of the problem causing the delay • The actions to be taken to resolve the situation, along with dates by which those actions will be completed • Confirmation of completion of action items

22. Cancelling Activities with Draws • Need to minimize the number of activities that are cancelled with draws. • Approval of Field Office required • Do not cancel program administration or planning activities with draws, unless there has been an ineligible use and all funds are being returned to the grantee’s line of credit.

23. Cancelling Activities with Draws For all activities, except planning and program administration, when the cancelled button is pressed, the grantee will select either: • Return of All Funds • Request for Field Office Approval • Provide justification • Emailed to field office • Field office approves or disapproves

24. Revising Draws • A justification will be required on the Revised Voucher Line Item screen • All revised draws with justifications will be sent to your Field Office for review

25. Quick Tips Report accomplishment data that are: • Complete • Accurate • Timely

26. Quick Tips • Report as Frequently as possible • When to Report • As benefits are realized • Quarterly recommended • Annual reporting is required • Understand Data Needs Upfront

27. Quick Tips What to Report • All benefits realized during Program Year • Eligible Activity/National Objective compliance • Accomplishment and beneficiary data • Performance measurements • Leveraging • Report complete information for each activity

28. Quick Tips • Review the progress of your activities at least annually • Ensure agreements with your State grant recipients have strong clauses about providing data at least annually within given timeframes

29. More Quick Tips • Especially for economic development activities, agreements should secure, as much as possible , a strong position for the recovery of CDBG funds, in the event a business fails. • As much as possible, have all other funds for an activity legally committed prior to start up. • Fund only what you can manage.

30. Tips for Correctly Reporting Data for Economic Development Activities • Direct financial assistance to for-profits • Separate activity for each business assisted • Do not aggregate • Report jobs in correct program year • Report only the number of jobs created/retained; do not report LMI population or the total population of a jurisdiction for activities with a LMJ national objective

31. Tip for Reporting Beneficiary Data for Presumed Benefit Activities

32. Enter Leveraging Data • High degree of interest among stakeholders • Demonstrates that CDBG funds generate additional investment in communities • Accurate-Grantees in California, Michigan, and Montana do not receive ARC funds

33. Grantees need to monitor IDIS Data Quality • Poor quality, incomplete data under-report or misrepresent program results • Public, HUD, Congress can see program results via HUD web reports generated from data entered into IDIS • Grantees can use IDIS data to assess their CDBG program performance

34. Helpful Tools • CDBG IDIS Training webcast and • CDBG IDIS Training materials are available at http://www.comcon.org/programs/idis.html • Review IDIS reports: • Performance Profiles PR54 • Expenditure Reports PR50 • Selected Accomplishments PR51 • Performance Measurement Report PR83 • Exception Report PR52