«COMMUNITY DEVELOPMENT BLOCK GRANT COMPLIANCE POLICIES (Adopted September 16, 2014) (Updated November 18, 2014) Department of Library & Community Services T:\Departments\Library\Community ...»
Program Income used toward other eligible activities outside of the funding process may not exceed 15 percent in the year program income is committed The amount of CDBG funds obligated for planning/CDBG administration activities in each program year shall be based on HUD guidelines.
Any single award will not be less than $10,000.
HUD requires entitlement communities to provide for efficient and adequate administration of CDBG programming. Administration costs include: salary/fringe, necessary training/travel, supplies and telephone/postage, in addition to fair housing services and audit costs. The necessary amount for fulfilling this requirement will be identified by the Director of Library and Community Services and the Director of Finance.
This amount will be deducted from the estimated amount available for the program year and not included in the estimates of the adjusted award. For additional internal control of program administration, a detailed description of these costs will be presented in the City's Budget.
Other administrative costs are associated with Technology, Professional Services, Cost Allocation and other necessary services. This may include costs of external service providers contracted by the City to perform necessary functions such as online application and data processing services. Examples of external service providers include EveryOne Home Homeless Management Information System (HMIS) and CityData Services.
Services will be procured in accordance with procurement policies in 24 CFR Part 85. City preference is for all subrecipients, including fair housing activities and those seeking funding for technical assistance to businesses (not in connection with other special economic development activities) and capacity building, to meet a national objective and not be funded from the administrative cap.
Special Economic Development Projects (24 CFR 570.203) CDBG funds may be used for special economic development activities in addition to other activities. Selection of economic development activities will follow all guidelines outlined in 24 CFR 570.209.
Special economic development activities include:
Acquisition, construction, reconstruction, rehabilitation or installation of commercial or industrial buildings, structures, and other real property equipment and improvements Assistance to a private for-profit business, including, but not limited to, grants, loans, loan guarantees, interest supplements, technical assistance, and other forms of support, for any activity where the assistance is appropriate to carry out an economic development project Economic development services, including, but not limited to, outreach efforts; screening of applicants; reviewing/underwriting applications; preparation of all necessary agreements;
management of activities; and the screening, referral, and placement of applicants for employment.
Public Benefit Standards for Special Economic Development
The City of Hayward will apply aggregate standards of public benefit to individual special economic development projects. Projects must create or retain at least one full-time equivalent, permanent job per $35,000 of CDBG funds used; or provide access to goods and services to at least one low-moderate income person per $350 of CDBG funds used.
MicroEnterprise The City of Hayward will allow Economic Development funds to be used as grants and/or loans for the development of Microenterprises.
Any program income (as defined under 24 CFR 570.500(a)) gained from any activity of the subrecipient may be retained by the subrecipient or City Program provided the income is treated as additional CDBG funds subject to all applicable requirements governing the use of CDBG funds. Anticipated program income must be documented and described in the subrecipient or City Program proposal/application. Furthermore, any and all program income received must be reported to the Department of Library and Community Services, unless otherwise specified in the subrecipient’s contract.
Overview The City of Hayward is on a reimbursement basis with HUD for the CDBG program.
Similarly, subrecipients and contractors are on a reimbursement basis with the City for expenses incurred in CDBG program activities. As the City or its subrecipients incur expenses, claims for payment are submitted, reviewed and approved for payment by appropriate CDBG program staff who then sends claims for payment to the Finance Department. After checks have been issued for these claims, drawdowns of these expenses are completed in Integrated Disbursement & Information System (IDIS).
1.0 Drawdown Responsibilities
1.1. Analyst I will prepare drawdown spreadsheet titled FY XX-XX Drawdown #Y (e.g., FY 12-13 Drawdown #1). Any other description can be added after the draw number; e.g. timeliness draw. By using this nomenclature for the title, the reviewer will know exactly what this particular drawdown spreadsheet contains.
1.2. Analyst I will email the drawdown packet, with will include the drawdown spreadsheet and all backup documentation for the period that verifies expenditures in this draw. That email will go to the Community Services Manager and the Director of Library and Community Services for approval prior to any draw being initiated. After the first draw is made, the PR07 report will also be included in this email so that the reviewer/approver can see exactly how much has been drawn from IDIS for all periods within the Fiscal Year.
1.3. The Community Services Manager and the Director of Library and Community Services will review and approve the drawdown spreadsheet within two (2) business days of receipt unless there is a problem with the spreadsheet. If there are any questions, problems or issues, the Analyst I will respond and revise the drawdown spreadsheet as appropriate prior to approval.
1.4. Analyst I will input approved drawdown data into IDIS.
1.5. Analyst II will review that data against the drawdown spreadsheet and approve the drawdown in IDIS.
2.1. The Monday following the last Friday of the month, Analyst I will begin to cross reference source documentation with the general ledger. If any discrepancies exist, Analyst I will research that discrepancy and a note will made in the drawdown packet explaining the discrepancy and any required follow up. Source documentation will consist of subrecipient reimbursement spreadsheets maintained in citydataservices.net, and other sources as needed.
2.2. Analyst I will prepare the drawdown spreadsheet. Analyst I will complete the drawdown detail and program income detail worksheets before confirming accuracy or making any changes to the open activity and drawdown spreadsheet worksheets.
The Office of Management and Budget (OMB) Circular A-133 – Audits of States, Local Governments, and Non-Profit Organizations and OMB Circular A-133 Compliance Supplement and the State Single Audit Guidelines require major state programs (awards over $100,000) and federal programs (awards over $500,000) to complete a single audit. The necessary amount for fulfilling these requirements will be identified by the Department of Finance and the City's independent auditors. This amount will be deducted from the estimated amount available for the program year and not included in the estimates of the adjusted award. Cost allocations will be associated with the most current Cost Allocation Schedule adopted by the Hayward City Council. The City will not fund any outside agency audits with CDBG money unless the outside agency receives not less than $500,000 in federal funds.
The City of Hayward must ensure that all subrecipients and City Programs maintain accurate records of their CDBG funds expended. Thus, all subrecipients and City Programs are required to complete an independent fiscal audit prior to submitting an application, unless an alternate arrangement has been made to use a fiscal sponsor. Fiscal sponsors, agencies willing to provide an umbrella for non-audited agencies, shall have a current independent fiscal audit, and may receive up to 10% of the applicant's award.. Audits shall be conducted by qualified personnel in a manner which meets the audit standards of the Comptroller General of the U.S.
Government Accountability Office (GAO). Applications without audits will be deemed ineligible without review. All audits will be reviewed by administrative staff for compliance.
CDBG COMPLIANCE POLICIESCITY OF HAYWARD Adopted September 2014 Unspent Grant Funds Any uncommitted CDBG funds remaining at the end of the program year will be reprogrammed for use in the subsequent program year, unless the reprogramming of said funds would inhibit the City’s ability to meet the timeliness spending test. In order to demonstrate funds are committed, all subrecipients and City Programs must present documentation to demonstrate that funds are indeed contracted for a specific project. If funds are not under contract, but designated for a specific project, a carryover request, including both substantial documentation of plans for expending funds and a timeline for the expenditure, should be submitted to the Director of Library and Community Services for approval three months prior to the end of the Fiscal Year. If the carryover request is approved, monthly progress reports on spend down must be filed with the Department of Library and Community Services, which will present them as information items to the Community Services Commission. Any unspent grant funds not under contract after June 30, will be recouped by the City and reprogrammed for use in the subsequent program year.
If the carry forward of unspent grant funds would inhibit the City’s ability to meet the timeliness spending test, allocations of CDBG funding in total amounts less than $250,000 in a single Program Year may be directed toward eligible City Projects/Programs within the same category of the unspent allocation. The Director of Library and Community Services may propose one-time CDBG-eligible City infrastructure projects to the City Manager for such previously allocated but unspent CDBG funding. Depending on project size and scope, the City Manager may bring such one-time projects directly to the City Council for authorization as deemed necessary and appropriate for the timely expenditure of CDBG funds. This eliminates the need for a public hearing for previously allocated funds less than $250,000 and creates a more efficient process for meeting future timeliness. Reallocations of unspent CDBG funding in total amounts greater than $250,000 in a single Program Year shall be presented to the City Council in a Public Hearing, and if approved by Council, submitted to HUD as a Substantial Amendment. All public hearings are reasonably noticed as required by 24 CFR 570.486(a), with a minimum 14-day Public Hearing Notice.
CDBG COMPLIANCE POLICIESCITY OF HAYWARD Adopted September 2014 Financial Management Systems Subrecipients and City Programs must employ financial management systems that are capable of generating regular financial status reports indicating the dollar amount allocated (including budget revisions), amount obligated, and amount expended for each activity. The system must permit the comparison of actual expenditures and revenues against budgeted amounts. The City must be able to isolate/trace every CDBG dollar received. This system must be compliant with the Federal Guidelines, including but not limited to OMB Circulars A-21, A-87, A-122, and ACFR Parts 570, 84, and 85.
CDBG COMPLIANCE POLICIESCITY OF HAYWARD Adopted September 2014 Payment Requests Subrecipients will submit written requests for payment with attached supporting documentation to the Department of Library and Community Services. Payment requests shall be allowed on a reimbursement basis (i.e. only after expenditures have been incurred and cleared) and shall be reviewed to ensure the expenditures are in conformity with the use of funds as described in the Statement of Work.
If source documentation is deemed inadequate or incorrect by Staff, all payments will be withheld until all required documents have been submitted. Payment requests received and approved will be processed and a check issued in accordance with the Department of Finance payment processes.
All payment requests must contain an original signature. Requests can be submitted online, but must be scanned and uploaded with the original signature. City Programs shall request payment via the departmental approval process. The request subject to approval by the Director of Library and Community Services to ensure that reimbursements reflect the original activity for which funds were awarded. Failure to provide accurate documentation violates the subrecipient agreement.
CDBG COMPLIANCE POLICIESCITY OF HAYWARD Adopted September 2014 Consolidated Plan Submission The City of Hayward has elected to submit a Consolidated Plan to HUD every five years, and is required to submit the Consolidated Plan to HUD a minimum of 45 days before the start of a new plan period. The Citizen Participation Plan provides for and encourages citizens to participate in the development of the Consolidated Plan, which will begin approximately one year before the required submittal date.
Subrecipient - an entity charged with implementation of one or more activities funded with Hayward CDBG dollars City program - an eligible activity or service provided by City of Hayward staff through a non-competitive application process.
Adjusted Award - the amount of CDBG funds available to subrecipients after City Programs, administration, fair housing, and audit allocations are deducted