SECTION 1: General Overview
This guidance is designed for recipients of Community Development Block Grant Disaster Recovery (CDBG-DR) funds. Learn more about the requirements in the CDBG-DR Consolidated Notice and how to meet the requirements throughout each phase of the grant process—pre-award grantee submissions; grantee steps and timelines; and action plan development, submittal, and implementation.
CDBG-DR Authorities
CDBG-DR funds are subject to Title I of the HCDA, (42 U.S.C. § 5301 et seq.) and the CDBG regulations at 24 CFR Part 570, unless modified by waivers and alternative requirements. CDBG-DR appropriation statutes typically grant the Secretary the authority to impose alternative requirements and waive statutes or regulations administered by the Secretary. Statutory requirements and waivers granted by HUD may vary from one disaster to the next. The Consolidated Notice combines waivers and alternative requirements from previous Federal Register notices and CPD Notices governing past CDBG-DR funds. These waivers and alternative requirements are based on the knowledge of the needs of grantees and previous waivers and alternative requirements that were issued contemporaneously with determinations by the Secretary regarding good cause and consistency with the overall purposes of HCDA.
HUD typically provides certain waivers and alternative requirements for all CDBG-DR grantees receiving funds for a particular disaster; however, HUD also reviews and acts on individual grantees’ requests for other waivers and alternative requirements on a case-by-case basis. Not all grantee requests are approved.
Additionally, The Robert T. Stafford Disaster Relief and Emergency Assistance Act (42 U.S.C. 5121 et seq.) (“Stafford Act”) provides the framework for Federal disaster assistance and sets forth the process by which the President declares a major disaster. Although the Stafford Act is largely devoted to programs administered by FEMA, certain sections apply more generally to all disaster assistance. In particular, CDBG-DR grantees must adhere to section 312 of the Stafford Act, which prohibits duplication of benefits.
Key Roles of HUD and the Grantee
HUD is authorized to allocate and award CDBG-DR grants when Congress makes funds available. HUD’s responsibilities include:
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Establishing requirements for use of the funds, through waiver and alternative requirements (including those requested by individual grantees), published in the Federal Register or on HUD’s website,
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Reviewing CDBG-DR action plans and managing CDBG-DR funds,
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Providing technical assistance on eligible uses of grant funds, and
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Monitoring CDBG-DR grantees’ use of CDBG-DR funds to ensure performance and compliance.
Since CDBG-DR funds are provided as a block grant, the CDBG-DR grantee has the primary responsibility to oversee and administer the use of funds for the disaster-related purposes that the funds were made available.
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Designing and implementing recovery programs to meet unmet recovery needs;
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Overseeing the CDBG-DR grant to ensure that CDBG-DR funds are used in accordance with all program requirements, including establishing internal controls;
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Providing technical assistance to, and oversight of, CDBG-DR subrecipients;
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Tracking CDBG-DR assisted activities and reporting the data in the Disaster Recovery Grant Reporting (DRGR) system; and
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Maintaining paper or electronic records of assisted activities sufficient for HUD to determine compliance in accordance with CDBG-DR recordkeeping requirements.
Knowledge Check
Test your understanding and retention of the key concepts covered in Section 1: General Overview by taking this quiz.
1. The Consolidated Notice Guidebook does not establish new requirements but offers the following:
The Consolidated Notice Guidebook offers guidance to develop the action plan, but there is a better answer.
The Consolidated Notice Guidebook offers technical assistance to implement CDBG-DR funds, but there is a better answer.
The Consolidated Notice Guidebook offers helpful tips and resources to inform the use and implementation of CDBG-DR funds, but there is a better answer.
This is the best answer. The Consolidated Notice Guidebook offers all three choices for current and future recipients of CDBG-DR funds.
2. The major phases of the CDBG-DR grant process are 1) prepare pre-award submission documents; 2) submit the financial management and grant compliance certification checklist; and 3) implement approved public action plan.
Incorrect. The second major phase in the CDBG-DR grant process is developing and submitting the public action plan. Submitting the financial management and grant compliance certification checklist is part of the first phase of preparing pre-award submission documents.
Correct. The phases of the CDBG-DR grant process are 1) prepare pre-award submission documents; 2) develop and submit public action plan; and 3) implement approved public action plan. The first phase includes submitting the financial management and grant compliance certification checklist.
3. The CDBG-DR appropriation acts make funds available for activities that are eligible under Title I of the Housing and Community Development Act of 1974. All of these CDBG-DR activities must be: CDBG-eligible (or eligible through a waiver or alternative requirement), meet a national objective, and meet an unmet recovery need that addresses a direct or indirect impact from an eligible disaster, or a mitigation need that addresses a risk identified in a mitigation needs assessment.
Correct. CDBG-DR appropriations make funds available for necessary expenses related to disaster relief, long-term recovery, restoration of infrastructure and housing, and economic revitalization in the most impacted and distressed areas. All CDBG-DR activities must be CDBG-eligible (or eligible under a waiver or alternative requirement), meet a national objective, and meet an unmet recovery need that addresses a direct or indirect impact from an eligible disaster, or a mitigation need that addresses a risk identified in a mitigation needs assessment.
Incorrect. The statement correctly lists the eligible activities for CDBG-DR funds according to Title I of the Housing and Community Development Act of 1974.
4. Within how many days of the applicability date of the Allocation Announcement Notice must grantees submit their Public Action Plan to HUD?
Incorrect. The grantee must publish its draft Public Action Plan for public comment for no less than 30 calendar days on the grantee’s disaster recovery website.
Incorrect. A grantee has 45 days to address deficiencies and resubmit it to HUD after being notified by HUD that the Public Action Plan was rejected.
Incorrect. Within 60 days of the applicability date of the Allocation Announcement Notice (or when the grantee submits its action plan, whichever is earlier), the grantee must submit documentation for the Financial Management and Grant Compliance Certification Requirements.
Correct. The grantee must submit its Implementation Plan, Public Action Plan (which includes Standard Form 424, or “SF-424”), and projection of expenditures and outcomes to HUD not later than 120 days from the applicability date of the Allocation Announcement Notice.
5. Only funds budgeted for activities established in the DRGR system can be drawn from the grantee’s line of credit.
Correct. The grantee may draw funds from its line of credit only for budgeted activities established in DRGR.
Incorrect. The grantee may not draw funds from its line of credit that are not for budgeted activities established in DRGR.
6. Choose one that is NOT a key responsibility of the CDBG-DR grantee:
Incorrect. This is a key responsibility of the grantee.
Correct. HUD is responsible for reviewing and approving CDBG-DR action plans.
Incorrect. This is a key responsibility of the grantee.
Incorrect. This is a key responsibility of the grantee.
A Guide on How CDBG-DR Grantees Can Meet the Requirements of the Consolidated Notice