September 2015

CDBG Program Update

Office of Block Grant Assistance

1. Budget Overview 2. OMB Super Circular Update 3. Affirmatively Furthering Fair

Housing (AFFH) 4. Grant-Based Accounting 5. National Disaster Resilience

Competition 6. NSP Update 7. New TA Products

Key Topics

Budget Overview

CDBG Funding in FY15

• CDBG Funds $3.066 billion – $66m for Indian CDBG = $3.0 billion for formula vs. $3.03 billion for FY2014.

• Roughly a 1% decrease • Formula allocations announced 2/10/15

• FY2015 grants computed using 2008-2012 ACS data vs. the 2007-2011 ACS data for FY2014 allocations - every grantee’s data will change slightly every year in comparison to every other grantee’s data

• Median change in CDBG allocations = -0.8%

FY 16 – Administration Budget President’s Budget

• CDBG formula funding $2.8b (-$200m)

• Section 108 loan guarantee authority $300m (-$200m)

• HOME $1.06b [incl. $10m for SHOP. (+ $150m)

• HOPWA $332m (+ $2m)

• Homeless $2.480b (+ $345m): incl. $2.223b for Continuum of Care (CoC)

• $250m for Emergency Solutions Grants (ESG)

• $7m for Homeless Management Information System (HMIS) Technical Assistance

FY 16 – Administration Budget (continued)

House Committee • CDBG $3.0 bil • Section 108 $300 mil • HOME $900 mil; $10 mil for SHOP in another budget

line; zeroes out HTF • HOPWA $332 mil • Homeless $2.185 bil: CoC $1.905 b; $250m ESG; $5m

HMIS TA

FY2016 –Budget Perspective

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• Congress appears unlikely to pass appropriations bills before 9/30/15. A continuing resolution(s) through December appears likely •If FY 2016 is like FY 2015, with enactment of appropriations bills around January 1, 2016 then HUD would announce FY2016 allocation amounts in Feb. 2016 • HUD plans to issue another CPD Notice instructing grantees not to submit FY 2016 Action Plans until final allocations are announced •Potential new Entitlement grantees for FY 16: 9>>>>60

OMB Super-Circular

NEW Financial Management Requirements “OmniCircular”

The “Omni Circular” or Super Circular replaces multiple existing regulations and OMB circulars: A-87, A-110, A-122, A-133, Parts 84 & 85

Also included in this circular are updated requirements that apply consistently to grantees, subrecipients, nonprofit organizations, across all grant programs Federal Agencies directed to have implementing regulations in place by

12/26/14. This means HUD will be issuing regulations that replace Parts 84 & 85 and

incorporate the other Circulars. Changes require conforming regulation changes to other regulations that

cross-reference the various financial management requirements OMB & other sources have webinars, training materials, FAQs, etc. 2-CFR: Currently Circulating for comment – Still waiting to hear back from OMB

State CDBG remains partially exempt because they were never subject to Part 85 – but are subject to the provisions that replace A-87, A-133, etc.

Affirmatively Furthering Fair

Housing (AFFH)

What is AFFH?

• AFFH sets out a framework for meaningful action to: • Overcome historic patterns of segregation • Promote fair housing choice • Foster inclusive communities free from

discrimination • The new rule helps program participants better:

• Understand what they are required to do to meet their AFFH duties

• Assess fair housing issues in their community

AFFH Final Rule AFFH is not a new requirement, but is an existing requirement

rooted in the 1968 Fair Housing Act.

The rule better explains how communities can comply with the law and gives them better tools to do so.

The Affirmatively Furthering Fair Housing Rule is at 24 CFR §

5.150 – 5.180 and includes subsequent conforming amendments to CPD and PIH regulations.

Rule published July 16, 2015

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Assessment of Fair Housing

• Under the AFFH rule, an “Assessment of Fair Housing”(AFH) will replace the current Analysis of Impediments” process

• An AFH Assessment Tool has been designed to help participants identify fair housing issues pertaining to: 1. Patterns of integration and segregation 2. Racially and ethically concentrated areas of poverty 3. Disparities in access to opportunity 4. Disproportionate housing needs

Who Does the Rule Apply To?

Jurisdictions and Insular Areas that are required to submit consolidated plans for the following programs: • CDBG • HOME • HOPWA • ESG

Public Housing Authorities (PHAs) receiving assistance under sections 8 or 9 of the United States Housing Act of 1937 *[see § 5.154(b)]

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Four Parts of the AFH Process

Incorporation into Subsequent planning Processes & Action

HUD Reviews and Responds

Analysis

Provision of Data & AFH Assessment Tool

Submission Process

All program participants would submit an Assessment of Fair Housing (AFH) at least once every 5 years. [see § 5.160(d)]

When is AFH Due? • Due on rolling basis based on Consolidated Plan cycle • The AFH is due 270 days prior to the program year for

which a new consolidated plan is due. • This will start with program years beginning:

• For entitlements receiving over $500,000 in CDBG funds in FY2015: January 1, 2017

• For all other grantees: January 1, 2018

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HUD’s Review of an AFH

The AFH would be deemed accepted 60 calendar days after the date that HUD receives the AFH, unless on or before that date, HUD has provided notification that HUD does not accept the AFH. [see § 5.162(a)]

HUD’s review would determine whether the program participant has met the proposed requirements of the AFH NOT its obligation to AFFH [see § 5.162(a)(2)]

Non-Acceptance: If a program participant does not have an accepted AFH, HUD will

disapprove a consolidated plan (see 24 CFR 91.500) or a PHA Plan (see 24 CFR 903.23).

Disapproval of the Plan may affect funding, however HUD does not want to withhold funds. [see § 5.162(d)]

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For More AFFH Information

HUD Exchange:

https://www.hudexchange.info/programs/affh/

Resources and Training Material Available:

• AFFH Final Rule

• AFFH Final Rule Executive Summary

• AFFH Fact Sheet

• AFFH FAQs

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Grant-Based Accounting

Transition to Grant-Based Accounting

• IDIS has historically operated on first-in-first-out (FIFO) basis. • FIFO accounting committed funds and disbursements against

the oldest grants and funds available • Grant based accounting funding commitments and

disbursements are made against specifically user-defined grant years • Begins with FY 2015 formula allocations • Funds from pre-2015 formula grants will continue to be

commuted and disbursed in IDIS

Transition to Grant Based Accounting

Impacts on IDIS processes: • Activity Funding • Drawdowns • Creating & Revising Vouchers • Returning Funds to local program account • Action Plan • Expiration of funds after 8th year

For more information: • Webinar available on HUD Exchange Training

and Events page (http://www.onecpd.info/training-events)

• www.hudexchange.info/manage-a-program/grant-based-accounting

• Rule publication is imminent

Transition to Grant Based Accounting

National Disaster Resilience Competition

Update

National Disaster Resilience Competition

Announced by the President June 14, 2014

• Qualifying disaster in 2011, 2012, or 2013 • 67 potential applicants

• States, local governments, District of Columbia, and Puerto Rico

• Included local governments that received CDBG-DR funding under PL 113-2

• Applicants tied proposal to qualifying disaster

Designed to help communities recover from their last disaster & prepare for a more resilient future

National Disaster Resiliency Competition

Goals of the NDRC: • Fairly & intelligently allocate remaining CDBG Disaster

Recovery funds from Public Law 113-2

• Create examples of modern disaster recovery that applies science-based & forward-looking risk analysis to address recovery/resiliency/ revitalization needs

• Institutionalize the implementation of thoughtful, sound, and resilient approaches to addressing future risks

• Builds on the successful model set forth by Rebuild by Design

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National Disaster Resiliency Competition Phase I: Risk Assessment and Planning Activities • Selected 40 applicants to advance Phase II: Design and Implementation • Highest-ranking Phase I applicants invited • Award in Phase II of between $100,000 and $250,000,000

• Communities propose a disaster recovery or revitalization project or program to addresses vulnerabilities and community development opportunities identified in Phase I

Timeline • October 27, 2015: Applications due to grants.gov 26

Neighborhood Stabilization Program Current Update

• NSP2 funds expire 9/30/15; waiver granted to certain grantees re Program Income

• HUD expects all NSP grants to be closed out within the next 3 years

• Technical Assistance is available to grantees on closing out grants

Technical Assistance Products

Technical Assistance Products Several new TA products in production, including websites and videos covering the following:

• HUD Exchange Product Landing Page • CDBG 101 – National Objectives and Eligible Activities • Formula Process • Urban County Entitlements • Program Income • CDBG Grant Lifecycle: Planning and Implementation • Project Profile Website Launch Scheduled for late September/early October – keep an eye on the HUD Exchange for more information