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«COMMUNITY DEVELOPMENT BLOCK GRANT COMPLIANCE POLICIES (Adopted September 16, 2014) (Updated November 18, 2014) Department of Library & Community Services T:\Departments\Library\Community ...»

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To be allowable under CDBG (and other federal programs), cost must meet the following

general criteria:

Be necessary and reasonable for proper and efficient performance and administration of the federal award;

Be allocable to the federal award under the provisions of the OMB circulars (see below);

Be authorized or not prohibited under state or local laws or regulations;

Conform to any limitations or exclusions set forth in the OMB circulars, federal laws, terms and conditions of the federal award, or other governing regulations as to types or amounts of cost items;

Be consistent with policies, regulations and procedures that apply uniformly to both federal awards and other activities of the governmental unit;

Be accorded consistent treatment; a cost may not be assigned to the CDBG program as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the program as an indirect cost;

Be determined in accordance with generally accepted accounting principles;

Not be included as a cost or used to meet cost sharing or matching requirements of any other federal award in either the current or a prior period, except as specifically provided by federal law or regulation;

Be the net of applicable credits (that is, any credits such as discounts or price adjustments must be deducted from the total costs charged); and Be adequately documented.

The OMB circulars also contain a “selected” list of costs that are allowable or unallowable.

However, the fact that an item of cost is not included does not mean it’s unallowable. Rather the cost’s allowability is determined by reference to the basic guidelines.

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Costs charged to CDBG must also be allocable to the CDBG program.

A cost is allocable if it is treated consistently with other costs incurred for the same purpose in like circumstances (i.e., states/ units of general local government must treat costs consistently

for all grant programs); and:

Is incurred specifically for the CDBG program;

Benefits both the CDBG program and other work and can be distributed in reasonable proportion to the benefits received; or Is necessary to the overall operation of the organization, although a direct relationship to any particular cost objective cannot be shown.

Any costs allocable to a particular federal award or cost objective (such as CDBG) may not be charged to other federal awards to overcome funding deficiencies, to avoid restrictions imposed by law or the terms of the federal award, or for other reasons.

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OMB Circular A-87 requires that governmental entities support indirect costs with a cost allocation plan or an indirect cost proposal prepared in accordance with the circular. Indirect costs should be allocated in a manner which will result in the grant program bearing its fair share of total indirect costs.

A central service cost allocation plan is required if the local government has indirect costs resulting from centralized services that will be charged to federal awards.

A central service cost allocation plan, for the purposes of local governments, refers to a description of a process whereby services provided on a centralized basis (e.g., motor pools, computer centers, purchasing and accounting services) can be identified and assigned to benefited departments/agencies (e.g., the department/agency administering the CDBG program) on a reasonable and consistent basis.

Refer to Attachment C of OMB Circular A-87 for additional information.

An indirect cost rate proposal is required if the local government has indirect costs resulting from centralized services that will be charged to federal awards and other indirect costs originating in various departments/agencies carrying out federal awards.

An indirect cost rate proposal is the documentation prepared by a governmental entity to substantiate its request for the establishment of an indirect cost rate. This rate, expressed in percentage terms, is applied to direct costs in order to determine the amount of reimbursement a state can obtain for indirect costs.

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Under OMB Circular A-122, there are three methods nonprofits are required to utilize for allocating indirect costs. Each method is applicable to certain specific circumstances.

Simplified allocation method:

Used when a nonprofit organization has only one major function, or where all its major functions benefit from its indirect costs to approximately the same degree.

The indirect cost rate is calculated by separating the organization’s total costs for the base period (e.g., fiscal year) as either direct or indirect, and dividing the total allowable indirect costs by an equitable distribution base (total direct costs, direct salaries or other equitable distribution base).

Multiple allocation base method:

Used when major functions benefit in varying degrees from indirect costs.

Costs are separated into distinct groupings, and each grouping is then allocated to benefiting functions by means of a base which best measures relative benefits. An indirect cost rate must be developed for each grouping.

Direct allocation method:

This method may be used for those nonprofits that treat all costs as direct costs except general administration and general expenses.

These joint costs are prorated individually as direct costs to cost objectives using a base most appropriate to the particular cost being prorated. The base must be established in accordance with reasonable criteria and must be supported by current data.

Indirect cost rates determined through one of the three prescribed methods must be submitted to and approved by the federal agency that provides the largest dollar value of funds to the nonprofit.

A written agreement is executed between the nonprofit and the approving federal agency signifying the approval of the proposed indirect cost rate.

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The City must have financial management systems in place to comply with the following


Provide effective control over and accountability for all funds, property and other assets;

Identify the source and application of funds for federally-sponsored activities, including

records and reports that:

o Verify the “reasonableness, allowability and allocability” of costs; and o Verify that funds have not been used in violation of any of the restrictions or prohibitions that apply to the federal assistance (through the use of budget controls and adequate accounting records).

o Permit the accurate, complete and timely disclosure of financial results in accordance with HUD reporting requirements or, for City, state reporting requirements.

o Minimize the time elapsing between the transfer of funds from the U.S. Treasury and disbursement by the state or City.

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The City is required to have accounting records that sufficiently identify the source and application of CDBG funds provided to them.

To meet this requirement, the City’s accounting system should include at least the

following elements:

Chart of accounts - This is a list of account names and the numbers assigned to each of the account names. The names provide a description of the type of transactions that will be recorded in each account (e.g., an account titled “cash” denotes that only transactions affecting cash should be recorded in that account). The account number is required by most accounting software programs and is assigned to an account name to group similar types of accounts. For example, all asset accounts will begin with a “#1” and all liability accounts will begin with a “#2”. A typical chart of accounts will generally include the following categories: assets, liabilities, net assets/fund balance, revenues and expenses.

Cash receipts journal - A cash receipts journal documents, in chronological order, when funds were received, in what amounts and from what sources.

Cash disbursements journal - A cash disbursements journal documents, in chronological order, when an expense was incurred, for what purpose, how much was paid and to whom it was paid.

Payroll journal - A payroll journal documents payroll and payroll related benefit expenses on salaries and benefits, including distinguishing between categories for regulatory purposes.

General ledger - A general ledger summarizes, in chronological order, the activity and financial status of all the accounts of an organization. Information is transferred to the general ledger after it is entered into the appropriate journal. Entries transferred to the general ledger should be cross-referenced to the applicable journal to permit the tracing of any financial transaction.

All journal entries must be properly approved and supported by source documentation.

Documentation must show that costs charged against CDBG were:

Incurred during the effective period of the agreement with HUD or, for Units of general local government, with the State;

o Actually paid out (or properly accrued);

o Expended on eligible items; and o Approved by the appropriate official(s) within the organization.

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The environmental review procedures must be completed for each CDBG subrecipient and City Program activity, as applicable.

Environmental Review Record The City must prepare and maintain a written record of the environmental review undertaken for each project. This written record or file is called the Environmental Review Record (ERR), and it must be available for public review upon request.

The ERR shall contain all the environmental review documents, public notices (and proof of their publication), and written determinations or environmental findings required by 24 CFR Part 58 as evidence of review, decision making and actions pertaining to a particular project.

The document shall:

Describe the project and each of the activities comprising the project, regardless of individual activity funding source; and Evaluate the effects of the project or the activities on the human environment;

Document compliance with applicable statutes and authorities; and Record the written determinations and other review findings required by 24 CFR Part 58.

The ERR will vary in length and content depending upon the level of review required for the categories of activities.

Public comments, concerns and appropriate resolution by the recipient are extremely important and must be fully documented in the ERR.

The four environmental classifications are:

Exempt Activities, Categorically Excluded Activities, Activities Requiring an Environment Assessment, or Activities Requiring an Environmental Impact Statement.


CITY OF HAYWARD Adopted September 2014 Regardless of the number of activities associated with a project, a single environmental review is required. Aggregating related activities ensures the recipient adequately addresses and analyzes the separate and combined impacts of a proposed project.

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Religious or faith-based organizations are eligible to participate in the CDBG program. Local government representatives and CDBG program administrators shall not discriminate against an organization on the basis of its religious affiliation.

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CDBG entitlement communities must submit the following documents:

1. Action Plan

2. Consolidated Annual Performance and Evaluation Report (CAPER)

3. Consolidated Plan three to five years, as chosen by the entitlement community Creation of these documents must follow HUD requirements for content and citizen participation (see 24 CFR 570.486(a) and the City of Hayward Citizen Participation Plan).

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CDBG funds may be awarded to an activity outside the jurisdiction of the entitlement community only if it can be determined that the activity directly benefits the entitlement community's residents.

Documentation of these benefits must be provided before CDBG funds are awarded for the activity.

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There are two sets of conflict of interest provisions applicable to activities carried out with CDBG funding. The first set, applicable to the procurement of goods and services by subrecipients, is the procurement regulations located at 24 CFR 84.44 and 85.36. (See 24 CFR 570.611(a)(1).) The second set of provisions is located at 24 CFR 570.611(a)(2). These provisions cover situations not covered by parts 84 and 85.

With respect to procurement activities, the subrecipient must maintain written standards of conduct governing the performance of its employees engaged in the award and administration

of contracts. At a minimum, these standards must:

• Require that no employee, officer, or agent may participate in the selection, award, or administration of a contract supported by Federal funds if a real or apparent conflict would be involved.

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• Require that employees, agents, and officers of the subrecipient neither solicit nor accept gratuities, favors, or anything of value from contractors, or parties to subagreements. However, subrecipients may set standards for situations in which the financial interest is not substantial or the gift is an unsolicited item of nominal value.

Provide for disciplinary actions to be applied for any violations of such standards by employees, agents, or officers of the subrecipient.

With respect to all other CDBG-assisted activities, the general standard is that no employee, agent, or officer of the subrecipient, who exercises decision-making responsibility with respect to CDBG funds and activities, is allowed to obtain a financial interest in or benefit from CDBG activities, or have a financial interest in any contract, subcontract, or agreement regarding those

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