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