Increasing Accountability and Oversight

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CDBG Reporting Requirements

• What’s new

• Coming attractions

• Tips

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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

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Report on New Data Elements for Code Enforcement Activities

Code Enforcement

* Housing units receiving violations

Housing units where code violations have been corrected using CDBG funds

Housing units where code violations have been corrected by the owner

Housing units where code violations have been corrected using other funds

*Describe specific public and private improvements or services provided in the code enforcement area

IDIS Activity IDs where code corrections are being tracked

Code Enforcement

* Housing units receiving violations

Housing units where code violations have been corrected using CDBG funds

Housing units where code violations have been corrected by the owner

Housing units where code violations have been corrected using other funds

*Describe specific public and private improvements or services provided in the code enforcement area

IDIS Activity IDs where code corrections are being tracked

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WHY?

• Important to demonstrate the results of code enforcement activities

• Important to verify compliance

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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

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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

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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

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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

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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)

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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

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New Housing Services vs. Housing Rehabilitation Administration

• Housing Rehabilitation Administration 14H• Housing Services 14J

Activity Hard Costs Paid With…

Report Accomplishments in IDIS?

Housing Rehab Admin (14H)

CDBG Generally Reported Under Other Activities

Housing Rehab Admin (14H)

Non-CDBG Yes

Housing Services (14J)

HOME Yes

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New Public Service Matrix Codes

• Neighborhood Cleanup (05V)

• Food Banks (05W)

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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

FY 2010 Public Services Expenditures

Matrix Code Activity Group

FY10 Expenditures

03T Operating Costs of Homeless/Aids Patients Programs $29,842,398.88

05 Public Services (General) $174,878,973.57

05A Senior Services $43,551,461.16

05B Services for The Disabled $10,451,612.94

05C Legal Services $4,101,359.94

05D Youth Services $59,335,049.67

05E Transportation Services $4,237,419.60

05F Substance Abuse Services $2,671,811.03

05G Battered and Abused Spouses $11,331,797.11

05H Employment Training $28,277,187.10

05I Crime Awareness/Prevention $11,373,471.37

05J Fair Housing Activities $5,541,448.89

05K Tenant/Landlord Counseling $3,009,062.79

05L Child Care Services $17,349,664.78

05M Health Services $19,451,731.87

05N Abused and Neglected Children $3,344,505.53

05O Mental Heath Services $2,978,027.39

05P Screening for Lead-Based Paint/Lead Hazards Poisoning $3,337,901.42

05Q Subsistence Payments $5,113,996.33

05R Homeownership Assistance (Not Direct) $3,123,494.24

05S Rental Housing Subsidies (HOME Tenant-Based Rental Assistance) $509,655.72

05T Security Deposits $55,626.84

05U Homebuyer Counseling $10,034,972.99

Subtotal for: Public Services $453,902,631.16

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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

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FY 2010 Public Facilities & Improvements Expenditures

Matrix Code Matrix Code Name FY10

03 Public Facilities and Improvements (General) $175,714,475.46

03A Senior Centers $35,287,937.23

03B Centers for the Disabled/Handicapped $9,244,956.21

03C Homeless Facilities (not operating costs) $15,796,133.59

03D Youth Centers/Facilities $7,651,805.07

03E Neighborhood Facilities $57,461,895.88

03F Parks, Recreational Facilities $87,075,225.01

03G Parking Facilities $5,937,338.72

03H Solid Waste Disposal Facilities $6,393,541.43

03I Flood and Drainage Facilities $27,731,603.36

03J Water/Sewer Improvements $392,566,729.62

03K Street Improvements $213,231,744.61

03L Sidewalks $52,275,079.17

03M Child Care Centers/Facilities for Children $10,610,498.70

03N Tree Planting $1,222,757.41

03O Fire Stations/Equipment $26,674,656.33

03P Health Facilities $13,400,450.12

03Q Abused and Neglected Children Facilities $2,129,146.40

03R Asbestos Removal $412,011.53

03S Facilities for Aids Patients (not operating costs) $465,763.37

06 Interim Assistance $51,752,925.58

10 Removal of Architectural Barriers $26,864.30

11 Privately Owned Utilities $92,859.23

16B Non-Residential Historic Preservation $6,023,590.52

Subtotal for: Public Improvements $1,199,179,988.85

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Coming Attractions

• Tracking of accomplishments and expenditures in response to the OIG audit

• Section 108

When? September 30, 2012

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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

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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

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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

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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.

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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

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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

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Quick Tips

Report accomplishment data that are:

• Complete• Accurate• Timely

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Quick Tips

• Report as Frequently as possible• When to Report– As benefits are realized– Quarterly recommended– Annual reporting is required

• Understand Data Needs Upfront

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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

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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

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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.

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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

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Tip for Reporting Beneficiary Data for Presumed Benefit Activities

Abused Children Extremely Low Income

Battered Spouses Low Income

Severely Disabled Adults Low Income

Homeless Persons Extremely Low Income

Illiterate Adults Low Income

Persons with AIDS Low Income

Migrant Farm Workers Low Income

Elderly Senior center – Mod IncomeNot Center based – Low Income

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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

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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

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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