In this interview, Sue Southon discusses her IEDC presentation designed to help state and local governments operationalize a CDBG-CV program in 45 days.
1. icf.com
A p r i l 2 0 , 2 0 2 0
Getting the Money on the
Street: A 45 Day Plan
Sue Southon
Senior Technical Specialist, Disaster Management Division
2. ICF proprietary and confidential. Do not copy, distribute, or disclose.
Operationalizing a CDBG-CV Program in 45 Days
Identify key stakeholders
Identify opportunities to leverage resources
Identify unmet needs and service gaps that could be filled with CDBG-CV funding
Design a program
Provide opportunity for public input
Implement the program
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3. ICF proprietary and confidential. Do not copy,
distribute, or disclose.
Convene, if not already meeting
Local, state, and regional representatives of federal
agencies (FEMA, HUD, SBA, EDA, HHS)
Emergency management
Public Health – health department, hospital association
Economic development organizations
Local banks – bankers associations, local branch of
Federal Reserve
Nonprofit and foundation leadership
Stakeholders should have knowledge and the ability
to act
Identify Key
Stakeholders
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4. ICF proprietary and confidential. Do not copy, distribute, or disclose.
Use expertise of the stakeholders to identify federal, state, local and nonprofit
resources
Prioritize flexible funding to ensure maximum use of significant appropriated
resources (FEMA, HHS, SBA in particular)
Avoid duplication of benefits (Stafford Act)
Triggered by federal disaster declaration
Requires analysis to ensure assistance from more than one source that is not used for the
need
Most likely to occur with business grant programs where SBA funding is anticipated or
received
Identify opportunities to leverage resources
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5. ICF proprietary and confidential. Do not copy,
distribute, or disclose.
Define program scope (eligible activity, national
objective, beneficiaries, program caps, administering
agency)
Public comment period
Environmental review
Execute subrecipient agreements
Develop policies and procedures
Identify staffing, application, organizational
requirements
Launch program
Design
Program to
Meet
Identified
Need
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6. ICF proprietary and confidential. Do not copy,
distribute, or disclose.
Payment of nonfederal cost
share – FEMA match
Activity must be CDBG eligible
Adoption of FEMA environmental
review possible
Business support program
Assistance with SBA loan
applications
Food bank
Interim mortgage assistance
Currently capped at 3 months
Business grant
Target program to address need
SBA may not meet (under banked
or unbanked businesses)
Consider a program for local
businesses to fund alterations to
support social distancing (or for
technology upgrades)
Target program to address
specific local need
– Mainstreet/BID
– Hospitality
– Nonprofits
– Critical supply chain businesses
– Essential services
– Higher wage businesses
– More FTEs
Must get SBA data for duplication
of benefits analysis (direct feed)
Program
Examples
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7. ICF proprietary and confidential. Do not copy, distribute, or disclose.
Secretary has discretion (exceptions: Fair
Housing, nondiscrimination, Davis Bacon,
environmental review)
Consider waiver request if it can be
justified based on DATA
HUD publishes all waivers granted each
quarter in Federal Register
Waivers under CARES Act
15% public benefit cap lifted – also applies to FY
2019 and 2020 allocations
Public notice period for substantial amendments– 5
days, virtual public hearings are acceptable
FY 2019 and 2020 allocations can be used to
respond to COVID-19 as long as costs comply with
CDBG requirements (pre-agreement and pre-award
cost authority available for eligible activities)
24-month extension of interim mortgage assistance
and tenant based rental assistance (HOPWA)
Examples of prior waivers granted –
mostly for CDBG-DR
Removal of public benefit cap for business grant &
loan programs (DR – general)
Permission for states to fun programs directly or
subgrant to other subrecipients, including, but not
limited to local governments (DR – general)
Emergency support for essential public services
(DR – specific)
Waivers
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8. ICF proprietary and confidential. Do not copy,
distribute, or disclose.
CARES Act permits reimbursement of eligible
expenses even if they occurred prior to the passage of
the Act.
Establish cost center and charge codes for ALL
COVID-19-related activities
FEMA Public Assistance – Category B – Emergency
Protective Measures
Requires 25% local match as of today
Broadly defined as activities to prevent, respond to
COVID-19
Local match can be cash or in-kind
Documentation!
Documentation!
Documentation!
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9. ICF proprietary and confidential. Do not copy, distribute, or disclose.
CDBG-CV Allocation
to State or Locality
(or FY 2019 or 2020
allocation)
Unmet needs
analysis (7 days)
Program identified
(eligible activity,
beneficiaries, program
cap) (5 days)
Public notice & hearing
(7 days)
Subrecipient
agreement executed (3
days)
Environmental review -
CENST (1 day)
Policies and
procedures developed
(7 days)
Staffing identified,
application developed,
project entered into
IDIS (14 days)
Program launch (day
45!)
Business Grant Program (working capital only)
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10. ICF proprietary and confidential. Do not copy, distribute, or disclose.
CDBG-CV Allocation
to State or Locality
(or FY 2019 or 2020
allocation)
Unmet needs
analysis (7 days)
Program identified
(eligible activity,
beneficiaries, cap,
administering agency)
(5 days)
Public notice & hearing
(7 days)
Subrecipient
agreement executed (5
days)
Environmental review -
CENST(1 day)
Policies and
procedures
developed* (6 days)
*Currently limited to 3
months
Staffing identified,
application
developed, project
entered into IDIS (14
days)
Program launch (day
45!)
Interim Mortgage Assistance
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11. ICF proprietary and confidential. Do not copy, distribute, or disclose. 11
Questions?
12. ICF proprietary and confidential. Do not copy, distribute, or disclose. 12
Thank you