The Ins and Outs of CDBG Homeowner Reimbursement as presented by Leslie Bean of CDM Smith at the 2015 Hurricane Conference.

1. The Ins and Outs of CDBG
Homeowner Reimbursement
April 2, 2015; 8:30 a.m. – 10 a.m.
Leslie Bean, Housing
Manager

2. • “My father gave me these hints on speech-making: Be
sincere…be brief….be seated.” James Roosevelt

3. Agenda
• Introduction
• Federal Requirements
• Program Implementation
• Best Practices
• Lessons Learned
• Document Guide

4. Introduction
• Federal Register Volume 78, No. 43, March 5, 2013 states “
The provisions of 24 CFR 570.489(b) are applied to permit a
State to reimburse itself for otherwise allowable costs
incurred by itself or its recipients sub-grantees or sub-
recipients on or after the incident date of the covered
disaster.
•

5. Introduction
• CPD-13-05 B. Generally Applicable Terms:
HUD will permit grantees to charge to grant the pre-award and
pre-applications costs of homeowners for eligible costs they
have incurred in response to a Presidentially-declared disaster.
For Rehabilitation and Reconstruction costs, grantees mayonly
charge costs for activities completed within the same footprint
of the damaged structure.
Costs must be adequately documented
A duplication of benefits check must be completed before
providing assistance.

6. Introduction
• “The ultimate measure of a man is not
where he stands in moments of comfort,
but where he stands at times of
challenge and controversy.”
Martin Luther King Jr.

7. Federal Requirements
• National Objectives:
Low and Moderate Income (LMI)
Urgent Need
• Davis-Bacon
Not required but check with local/state building code
departments
• Civil Rights Requirements
504, Americans w Disabilities Act, Fair Housing

8. Federal Requirements
• Environment
 Grantee is responsible for completing the environmental reviews in
accordance to Federal laws including Section 106
 Lead-Based Paint Rule applies to homes built prior to January 1978. A housing
unit can be exempt if:
 The homeowner undertook CDBG-eligible activities that qualify as
emergency actions necessary to safeguard against imminent danger to
human life, health /safety, or to protect the property from further
structural damage. (see 24 CFR 35.115(a)(9).
 The rehab did not disturb any painted surface
 An inspection performed found to property contained no lead-based paint
 Lead paint had been identified, removed and cleared.
 Property is meets the “housing for the elderly definition” or “persons with
disabilities” but no child 6 years or under resides in the home. (see 24
CFR 35.110)

9. Federal Requirements
• Duplication of Benefits (DOB)
Section 312 of the Robert T. Stafford Disaster Assistance and
Emergency Relief Act (42 U.S.C. 5155) prohibits any person,
business concern, or other entity from receiving financial
assistance with respect to any part of a loss resulting from a
major disaster as to which he has received financial assistance
under any other program or from insurance or any other source

10. Program Implementation
• Develop program policies
The policies should reflect the action plan.
Be careful not to include procedures in the policies
Consult with other communities
Ensure the policies are approved by all applicable parties
*Remember-You must have procedures
identifying how you plan to verify and
monitor the policies.

11. Program Implementation
• Develop Procedures
 DOB
Acceptable Documentation
Verification of Sources
Allowable/Unallowable Expenses
 Income
Part 5
1040
Self Certification
 Document Control
MIS
Paper Files
Version Control

12. Program Implementation
• Develop Procedures (cont….)
Due Diligence
Homeowners that apply but never provide appropriate
documentation
Unable to verify documents through a 3rd Party
Appeals
Process, Forms, Letters, Tracking
Quality Control
One level or Two levels?
Beginning, Middle, End?

13. Best Practices
• Develop program policies and procedures before starting
program and accepting applications
• Streamline the process
• Promote program through various avenues
• Develop Tracking Systems
• Develop program policies and procedures before starting
program and accepting applications

14. Lessons Learned
• Do not set up this program to mimic a rehab/reconstruction
program
• Policies should not more stringent that local/state/federal
requirements
• Properly review the receipts the first time
• Hire extra staff to just make copies of receipts

15. Document Guide
(Index)
• CPD-13-05, July 30, 2013
• Disaster Relief Appropriations Act, 2013
• 24 CFR 58.5 and 58.6
• 2 CFR part 225
• FR Vol. 78 No. 43, March 5, 2013
• FR Vol. 76 No. 221, November 16, 2011
• www.hud.gov

16. Questions
• Leslie Bean; beanlj@cdmsmith.com