SECTION 3: Action Plan & Implementation

This section includes guidance on developing a CDBG-DR Action Plan in response to the Consolidated Notice, including steps to take when submitting the required pre-award submissions, the Implementation Plan, and the Public Action Plan. This section also moves into the Implementation phase of projects and activities, and includes relevant guidance on resilience planning and best practices when incorporating mitigation into long-term recovery.

Action Plan Development

Pre-Award Evaluation of Management and Oversight of Funds

This section focuses on a grantee’s responsibilities for pre-award submissions that are generally due to HUD prior to a CDBG-DR grantee signing a grant agreement. These requirements include the Financial Management and Grant Compliance Certification Checklist and the Implementation Plan.

Generally, appropriations acts require that the Secretary certify, in advance of signing a grant agreement, that the grantee has in place proficient financial controls and procurement processes and has established adequate procedures to prevent any duplication of benefits as defined by section 312 of the Robert T. Stafford Disaster Relief and Emergency Assistance Act (Stafford Act), 42 U.S.C. 5155, to ensure timely expenditure of funds, to maintain a comprehensive website regarding all disaster recovery activities assisted with these funds, and to detect and prevent waste, fraud, and abuse of funds.

The grantee’s Financial Management and Grant Compliance Certification Requirements (described in Section III.A.1 of the Consolidated Notice) are made up of the following components: 

  1. Proficient financial management controls,

  2. Procurement,

  3. Duplication of benefits,

  4. Timely expenditures,

  5. Comprehensive disaster recovery website, and

  6. Procedures to detect and prevent fraud, waste, and abuse.


A grantee submits this certification within 60 days of the effective date of the Allocation Announcement Notice, or with the grantee’s submission of its action plan, whichever is earlier.

Relying on a Prior Certification:

After that original grant, if a CDBG-DR grantee is awarded a subsequent CDBG-DR grant, HUD will rely on the grantee’s prior submissions provided in response to the Financial Management and Grant Compliance Certification Requirements in the Consolidated Notice.

If a CDBG-DR grantee is awarded a subsequent CDBG-DR grant, and it has been more than three years since the executed grant agreement for the original CDBG-DR grant or a subsequent grant is equal to or greater than ten times the amount of the original CDBG-DR grant, grantees must update and resubmit the documentation required by paragraph III.A.1.a. with the completed Certification Checklist to enable the Secretary to certify that the grantee has in place proficient financial controls and procurement processes, and adequate procedures for proper grant management.

HUD will continue to monitor the grantee’s submissions and updates made to policies and procedures during the normal course of business. The grantee must notify HUD of any substantial changes made to these submissions. The applicable Certification Checklists can be found on Note, there are two different checklists – one for states and one for units of local government.

Instructions for Completing the Certification Checklist:

To complete the applicable Financial Management and Grant Compliance Certification Requirements, a grantee will affirm to the requirements provided in the Certification Checklist and submit the appropriate support documentation (including cross-references). After the instructions in the applicable Certification Checklist there is a section titled, “Required Documentation.” The grantee will check the box for each of the required documents selected to indicate to HUD that all documents are attached. Directly below, the grantee will list each file name or identifier, the title of the document, and the page numbers HUD should review. In this checklist, HUD also included a similar table for optional documents. The grantee can submit optional documentation, as needed, to support its proficiencies. Examples of optional documentation may include certain financial management policies and procedures (e.g., copies of financial policies that describe how the grantee accounts for a HUD program in a separate accounting fund or policies for how a grantee will maintain source documentation to support the financial management system records).

After the documentation section, the grantee will complete Part A through Part F, and the certifying official will sign the Certification Checklist. Then, the grantee will submit the completed checklist to HUD within 60 days of the applicability date of the Allocation Announcement Notice or with the submission of the action plan, whichever is earlier. The grantee will work with its grant manager to arrange submission of the Certification Checklist and the required documentation.

Financial Management and Grant Compliance Certification Training for 2020 CDBG-DR Grantees​

To meet this requirement, a grantee must:
• Submit its most recent single audit and consolidated annual financial report, and
• Complete the required Certification Checklist.

To meet this requirement, a grantee must:
•  Determine and adopt the grantee’s procurement processes and standards as required in the Consolidated Notice, and
•  Uphold the principles of full and open competition. 

For states, the grantee must adopt one of the procurement processes permitted in the notice: 

  1. Adopted 2 CFR 200.318 through 200.327; or

  2. Follows state procurement policies and procedures and establishes requirements for procurement policies and procedures for local governments and subrecipients based on full and open competition pursuant to 24 CFR 570.489(g), and the requirements applicable to the state, its local governments, and subrecipients include evaluation of the cost or price of the product or service; or

  3. Adopted 2 CFR 200.317, meaning that it will follow its own state procurement policies and procedures and evaluate the cost or price of the product or service, but impose 2 CFR 200.318 through 200.327 on its subgrantees and subrecipients.

For local governments, the grantee must adopt 2 CFR 200.318 through 2 CFR 200.327.

Grantees are also reminded that the requirements for professional services at 2 CFR 200.459 apply and costs for contracted professional and consultant services are eligible for grant funding, provided they are reasonable and allowable.

  • Necessary: Is the cost for an eligible activity? Is there a need for the assistance? Is it for a permissible recovery purpose?

  • Reasonable: Would a prudent person consider the cost to be payable by the award?

  • Allowable: Is the cost necessary to the operation? Is the cost eligible?

In determining the allowability of costs, a number of factors are relevant, including the adequacy of the contractual agreement for the services (e.g., description of the service, estimate of time required, rate of compensation, and termination provisions). Invoicing should include details to define the services being provided, such as specific deliverables and documentation of those deliverables, or time and effort records to support the services provided.

Additionally, technical assistance resources for procurement are available to grantees either through HUD staff or through technical assistance providers engaged by HUD or a grantee. HUD hosted a webinar on April 26, 2017 discussing updates and clarifications to procurement requirements. 

Updates and Clarifications to Procurement Requirements Webinar

The webinar can also be viewed on the HUD Exchange.

To meet this requirement, a grantee must have policies and procedures that:

  • Verify all sources of disaster assistance prior to awarding CDBG-DR funds, 

  • Determine unmet needs before committing CDBG-DR funds,

  • Establish repayment agreements for any duplicative assistance for the same purpose,

  • Monitor for compliance and including the following language in all agreements, “Warning: Any person who knowingly makes a false claim or statement to HUD or causes another to do so may be subject to civil or criminal penalties under 18 U.S.C. 2, 287, 1001 and 31 U.S.C. 3729.’’,

  • Use the best, most recent data from relevant sources (i.e., FEMA, SBA, Insurers) to prevent duplication of benefits, and

  • Reflect the retreatment of loans for declined and cancelled loans, when applicable .

To comply with Section 312, a person or entity may receive financial assistance only to the extent that the person or entity has a disaster recovery need that has not been fully met. For example, grantees in jurisdictions in which FEMA has implemented its Permanent or Semi-Permanent Housing program must ensure that CDBG-DR funds are not duplicative of FEMA’s funding.

In developing DOB policies and procedures, grantees are directed to the 2019 DOB Notice (84 FR 28836), as may be amended. HUD hosted two webinars discussing duplication of benefits and updated requirements. 

Duplication of Benefits: Understanding and Applying the Requirements Webinar

Webinar can also be viewed on the HUD Exchange.

Duplication of Benefits Webinar
Overview of the 2019 DOB Notice and the 2019 DOB Implementation Notice

Webinar can also be viewed on the HUD Exchange.

Necessary and Reasonable Test

CDBG-DR grantees must apply the Necessary and Reasonable cost principles and audit requirements for Federal awards in subpart E of 2 CFR 200. Under the Cost Principles, a cost assigned to a grant

‘‘is reasonable if, in its nature and amount, it does not exceed that which would be incurred by a prudent person under the circumstances prevailing at the time the decision was made to incur the cost’’ (2 CFR 200.404).

Grantees must consider factors described at 2 CFR 200.404(a) through (e) when determining which types and amounts of cost items are necessary and reasonable. Based on these factors, HUD generally presumes that if a cost has been paid by another source, charging it to the Federal award violates the necessary and reasonable standard unless grant requirements permit reimbursement.

To meet this requirement, a grantee must indicate how they will:

  • Track and document expenditures (grantee and subrecipients) each month,

  • Account for and manage program income,

  • Reprogram funds in a timely manner when there are delays, and

  • Project all expenditures.

The projections of a grantee’s expenditures enable HUD, the public, and the grantee to track proposed versus actual performance. The action plan should be amended for any subsequent changes, updates, or revision of the projections. To assist CDBG-DR grantees with their projections regarding the expenditure of funds over the life of the award and outcomes associated with planned activities, grantees can use the template on the HUD Exchange.

To meet this requirement, a grantee must:

  • Have a separate website for CDBG-DR activities;

  • Post the require information in an accessible form;

  • Take steps to ensure meaningful access to Limited English Proficiency persons, members of protected classes, vulnerable populations, and individuals in underserved communities; and

  • Indicate the frequency of website updates (minimum of quarterly).

    Information that must be posted to a grantee’s website are:

Information that must be posted to a grantee’s website are:

  • Action Plans

  • Citizen Participation Plan

  • Action Plan Amendments

  • Program Policies and Procedures

  • DRGR Action Plans

  • Procurement Policies and Procedures

  • Quarterly Performance Reports

  • Summary of procured contracts

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To meet this requirement, a grantee must:

  • Verify the accuracy of applicant information,

  • Adopt a procedure to evaluate the capacity of potential subrecipients,

  • Adopt a monitoring plan for subrecipients, contractors and other program participants,

  • Demonstrate that it has or will hire an internal auditor for programmatic and financial oversight,

  • Provide a written standard of conduct and conflict-of-interest policy

  • Establish a procedure for investigating and taking action when fraud occurs within the grantee’s activities and/or programs.

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CDBG-DR grantees must monitor subrecipients, contractors, and other program participants. HUD hosted two webinars to assist grantees in understanding the requirements for managing and monitoring subrecipients, learning record keeping requirements, and gaining effective strategies to avoid common mistakes. 

Managing and Monitoring Subrecipients Webinar

The webinar can also be viewed on the HUD Exchange.

Subrecipient Management & Record Keeping Webinar

The webinar can also be viewed on the HUD Exchange.

The grantee’s Implementation Plan describes the grantee’s capacity to carry out the recovery and how it will address any capacity gaps. The grantee’s Implementation Plan is made up of the following components:

  1. Capacity assessment,

  2. Staffing, and

  3. Internal and interagency coordination

Frequency: An initial CDBG-DR grantee submits its Implementation Plan with its action plan for disaster recovery. After an initial award, a grantee will submit a subsequent Implementation Plan after three years of its initial grant or if the amount of a subsequent grant is equal to or greater than ten times the amount of its original CDBG-DR grant.

For example, a grantee receives a CDBG-DR grant for disasters occurring in 2021, 2022, 2024, and then 2025. The grantee would submit its initial Implementation Plan for the 2021 disaster with its action plan. The grantee would not submit an Implementation Plan for its 2022 or 2024 award but would need to update or resubmit its 2021 submission when it submits its 2025 disaster recovery action plan.

If the 2022 or 2024 award is ten times the amount of the 2021 award, the grantee would need to update or resubmit its 2021 submission when it submits its 2022 disaster recovery action plan.

Steps to Capacity:

  • Assess your capacity;

  • Identify staffing positions, partners, and vendors;

  • Determine your approach to meeting capacity needs; and

  • Execute agreements with partners;

When a grantee is identifying staffing positions, grantees are encouraged to:

  • Indicate which personnel or unit is responsible for tasks, and their contact information when available;

  • Document positions for the purpose of case management for housing, infrastructure, and economic revitalization programs; procurements and contracts; and compliance with section 3, fair housing, the environment, and the elements within the certification submission.

  • Describe how duties and responsibilities have checks and balances in place to separate duties (to the extent practicable) so that no one individual has complete authority over certain tasks. For example, financial transaction duties should be separate. Grantees should submit work-flow diagrams for major program areas (including financial management) and position descriptions that demonstrate the chain of command for each position.

A Guide on How CDBG-DR Grantees Can Meet the Requirements of the Consolidated Notice