The document outlines a 45-day plan for operationalizing a CDBG-CV program to address unmet needs and service gaps arising from COVID-19. It details steps such as stakeholder identification, program design, public input, and implementation scheduling, alongside examples of possible funding uses and waivers. Additionally, it emphasizes the importance of documentation and compliance with CDBG requirements throughout the process.

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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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 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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 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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 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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 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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 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