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EDI CPF Grant Guide

The FY2024 Economic Development Initiative Community Project Funding Grant Guide outlines the process and requirements for administering $3.29 billion in CPF grants as per the Consolidated Appropriations Acts of 2024. It provides detailed instructions for prospective grantees on how to complete grant applications, manage funds through the DRGR system, and comply with federal regulations. The guide also includes contact information for grant officers and resources for technical assistance throughout the grant lifecycle.

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0% found this document useful (0 votes)
48 views77 pages

EDI CPF Grant Guide

The FY2024 Economic Development Initiative Community Project Funding Grant Guide outlines the process and requirements for administering $3.29 billion in CPF grants as per the Consolidated Appropriations Acts of 2024. It provides detailed instructions for prospective grantees on how to complete grant applications, manage funds through the DRGR system, and comply with federal regulations. The guide also includes contact information for grant officers and resources for technical assistance throughout the grant lifecycle.

Uploaded by

thomashouck308
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as PDF, TXT or read online on Scribd
You are on page 1/ 77

FY2024

ECONOMIC DEVELOPMENT INITIATIVE -


COMMUNITY PROJECT FUNDING

GRANT GUIDE
(In accordance with the
Consolidated Appropriations Act, 2024, P.L. 118-42 and
the Further Consolidated Appropriations Act, 2024, P.L. 118-47)

VERSION 1.0

August 19, 2024

U.S. Department of Housing and Urban Development


Office of Community Planning and Development
Office of the Deputy Assistant Secretary for Economic Development
Office of Economic Development
Congressional Grants Division
Washington, DC 20410
FY2024 Community Project Funding Grant Guide (Version 1.0)

Table of Contents

SECTION 1: BACKGROUND AND PURPOSE .......................................................................................4

SECTION 2: GRANT AWARD PROCESS AND INSTRUCTIONS ..............................................................6


2.1 Grant Award Process ....................................................................................................................... 6
2.2 DRGR Overview ................................................................................................................................ 8
2.2.1 How to Create A DRGR Account .......................................................................................... 9
2.2.1.1 How to Request New User(s) ........................................................................ 9
2.2.1.2 Creating Roles in DRGR ............................................................................... 10
2.2.2 Verify Your UEI & Tax Identification Number (TIN) ........................................................... 11
2.2.3 How to Complete Your Grant Package .............................................................................. 12
2.2.3.1 Project Manager .......................................................................................... 14
2.2.3.2 Additional Point(s) of Contact ..................................................................... 15
2.2.3.3 Responsible Entity’s Contact Information .................................................. 15
2.2.3.4 Congressional District(s).............................................................................. 16
2.2.3.5 Subrecipient(s) ............................................................................................ 17
2.2.3.6 Project Scope............................................................................................... 18
2.2.3.7 Project Narrative ......................................................................................... 18
2.2.3.8 Project Location .......................................................................................... 20
2.2.3.9 Funding Narrative........................................................................................ 21
2.2.3.10 Project Activities.......................................................................................... 22
2.2.3.11 Grantee’s Fiscal Year ................................................................................... 22
2.2.3.12 Project Budget ............................................................................................. 23
2.2.3.13 CPF Budget .................................................................................................. 23
2.2.3.14 Indirect Cost Rate ........................................................................................ 24
2.2.3.15 Disclosures................................................................................................... 26
2.2.3.16 Environmental Review Status ..................................................................... 27
2.2.3.17 Disclosure of Lobbying Activities................................................................. 28
2.2.3.18 Assurances................................................................................................... 30
2.2.3.19 Direct Deposit.............................................................................................. 30
2.2.3.20 Annual Single Audit ..................................................................................... 32
2.2.3.21 Miscellaneous.............................................................................................. 32
2.2.3.22 Validating Grant Package ............................................................................ 32
2.2.3.23 Submitting Grant Package ........................................................................... 33
2.3 Detailed Instructions...................................................................................................................... 37
2.3.1 Grant Award Conditions ....................................................................................................... 37
2.3.2 Requesting Changes to Approved Project Narrative or Budget ........................................... 37
2.3.3 SF-424: Application for Federal Assistance .......................................................................... 38

2
FY2024 Community Project Funding Grant Guide (Version 1.0)

SECTION 3: FEDERAL REQUIREMENTS ............................................................................................ 40


3.1 Requirements Under the Consolidated Appropriations Act, 2024 (P.L. 118-42) and Further
Consolidated Appropriations Act, 2024 (P.L. 118-47) ............................................................................ 40
3.2 Cross Cutting Federal Requirements ................................................................................................ 41
3.3 Detailed Environmental Review Guidance for FY2024 CPF Grants .................................................. 55
3.3.1 Contacts and Project-Specific Assistance ............................................................................. 55
3.3.2 Legal Framework and Policy ................................................................................................. 55
3.3.3 CPF Environmental Review Scenarios .................................................................................. 58
3.3.4 Resources .............................................................................................................................. 62
3.4 Build America, Buy America (BABA) Act Guidance for FY2024 CPF Grants ...................................... 64

SECTION 4: CONTACT INFORMATION FOR GRANT OFFICERS, SYSTEM OFFICERS, AND REGIONAL
ENVIRONMENTAL OFFICERS .......................................................................................................... 65

SECTION 5: ATTACHMENTS........................................................................................................... 66
Attachment 1: Grant Agreement Submission Checklist ........................................................................ 67
Attachment 2: Direct Deposit Sign-Up Form (SF-1199A) ....................................................................... 68
Attachment 3: Change of Address Request (HUD-27056) Form ........................................................... 69
Attachment 4: Ask-A-Question (AAQ): Technical Assistance Guide...................................................... 70
Attachment 5: CPF Frequently Asked Questions (FAQs) ....................................................................... 72
Attachment
ment 6: Sample Narrative Outline and Example…………………………………………………………………Attach
Example…………………………………………………………………….73
Attachment 7: Sample Budget…………………………………………………………….………………………………………..….77

3
FY2024 Community Project Funding Grant Guide (Version 1.0)
SECTION 1: BACKGROUND AND PURPOSE

The Consolidated Appropriations Act, 2024, and the Further Consolidated Appropriations Act, 2024,
(“the FY2024 Acts”) provide $3,289,054,336 in Economic Development Initiative (EDI) funding for the
purpose of making Community Project Funding (CPF)/Congressionally directed grants. These Fiscal
Year 2024 (FY2024) CPF grants will be administered by the Congressional Grants Division (CGD) of the
U.S. Department of Housing and Urban Development (HUD).

This “FY2024 Economic Development Initiative Community Project Funding Grant Guide” (FY2024 CPF
Grant Guide) provides information for Congressionally-designated recipients that have yet to execute
their Grant Agreement with HUD (“prospective grantees") on the requirements that govern these
funds, as provided by the FY2024 Act, and the cross-cutting requirements that generally apply to all
HUD awards as provided by HUD regulations and other applicable Federal regulations and statutes.

This FY2024 CPF Grant Guide also provides instructions on how to complete the requested
information and fill out the required forms to execute your Grant Agreement in HUD’s Disaster
Recovery Grant Reporting (DRGR) financial and reporting system.

DRGR is a web-based system used to automate the management of program requirements and
voucher payments issued by HUD. This system will enable you to process requests for payment of CPF
grant funds and to submit periodic reports on the use of those funds.

This FY2024 CPF Grant Guide applies only to FY2024 CPF grants. FY22 and FY23 grantees should
refer to their respective CPF Grant Guides on the HUD CPF website.

The remainder of this FY2024 Grant Guide includes:

• Section 2 – Grant Award Process and Instructions: Walks you through the FY2024 CPF grant
award process and gives you instructions for executing the Grant Agreement and steps to
request payment(s).
• Section 3 – Federal Requirements: Details the Federal regulations that apply to these grant
funds.
• Section 4 – Contact Information for Grant Officers, System Officers, and Regional
Environmental Officers: Gives contact information for CPF Grant Officers, CPF System
Officers, and the environmental review specialists who support you through the grant life
cycle.
• Section 5 – Attachments: Provides attachments including documents required in the Grant
Award process.

HUD will use the process outlined in this FY2024 CPF Grant Guide to administer FY2024 CPF grants as
directed by Congress in the FY2024 Acts. Subject to the applicable conditions in these or later
appropriations acts, HUD is required to award these grants in accordance with the specific
“recipient,” “project,” and “amount” information provided in the “Community Project
Funding/Congressionally Directed Spending” table on pages S1967 through S2184 of the

Section 1 / Version 1 / August 19, 2024 4


FY2024 Community Project Funding Grant Guide (Version 1.0)
Congressional Record for March 5, 2024
(https://www.congress.gov/118/crec/2024/03/05/170/39/CREC-2024-03-05.pdf). The second of the
two FY2024 Acts made just two changes with respect to this table: (1) it added an addendum to the
table to provide for a FY2024 CPF grant of $850,000 to the Town of Normal for “Town of Normal
Street Upgrades to Increase Safety” (which the addendum identifies as a project requested by
Representative Sorensen of Illinois) and (2) it changed the “project” for which Workforce Housing
Coalition Western Maine Mountains was designated to receive a FY2024 CPF grant from “Kingfield
Multi-Family Housing” to “Multi-Family Housing.” To avoid confusion, this guide will refer to the
table with these two changes as the “Amended CPF Grants Table.”

Section 1 / Version 1 / August 19, 2024 5


FY2024 Community Project Funding Grant Guide (Version 1.0)
SECTION 2: GRANT AWARD PROCESS AND INSTRUCTIONS

2.1 Grant Award Process

At a high level, the grant award process is as follows:

1. HUD creates grantees’ accounts in DRGR.


2. HUD, via DRGR, emails you the Grant Award Package, including the Grant Agreement, Letter
of Invitation (LOI), and this Grant Guide along with instructions to complete the required
materials. Your CPF application consists of the project narrative, project budget, and required
standard forms, and will be completed in DRGR.
3. You submit the required complete package in DRGR by the Authorized Representative who
has legal authority to sign on behalf of your organization.
4. HUD reviews the completed grant package in DRGR to ensure that the project narrative and
budget are aligned with your Congressionally-directed project description.
5. Once your materials are determined to be complete and accurate, HUD will execute and
return your Grant Agreement via DRGR.
6. You should also initiate and complete your environmental review and consult with your HUD
Regional Environmental Officer (REO) and/or Responsible Entity (RE), as necessary.

NOTE: CPF grants, like all awards funded by HUD, are subject to requirements under the National
Environmental Policy Act (NEPA), HUD’s NEPA-implementing regulations are located at 24 CFR Part 50
or 24 CFR Part 58, and all appropriate federal environmental and historic preservation laws,
regulations, and Executive Orders. CPF grantees must have a completed environmental review (and,
where applicable, an approved Request for Release of Funds and Certification (HUD-7015.15), as
explained in Section 3.3 below) before committing or expending Federal or non-Federal funds
towards choice-limiting actions or undertaking choice-limiting actions on the project. Further
explanation of HUD’s NEPA requirements are detailed in Section 3.

Instructions for submitting your FY2024 CPF grant materials and requesting payment are below. A
checklist of the grant award process is provided in Section 5.

If you have questions about the grant award process, please contact your CPF Grant Officer listed in
Section 4 of this guide.

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FY2024 Community Project Funding Grant Guide (Version 1.0)

GRANT AWARD PROCESS


HUD sends Grant FY2024 CPF Grant Award Packet includes:
Award Packet • FY2024 CPF Letter of Invitation (LOI);
• FY2024 CPF Grant Guide;
• FY2024 CPF Grant Agreement; and
• link to Direct Deposit Sign-Up Form (SF-1199A)

Standard Forms generated by DRGR system:


• Assistance Award/Amendment (HUD-1044) (also attached to your LOI)
• Application for Federal Assistance (SF-424)
• Assurances for Non-Construction Projects (SF-424B)
• Assurances for Construction Projects (SF-424D)

Standard Forms not generated by DRGR system:


• Direct Deposit Sign-Up Form (SF-1199A) (Also, see Attachment 2.)
Prospective Grantee You provide the following information in DRGR:
Required Documents 1. Project Narrative
2. Project Budget
3. SF-1199A

The SF-1199A will need to be downloaded, completed (by you and your Financial
Institution) and uploaded into DRGR.

Please note: The information identifying the “Applicant,” “Grantee,” or


“Recipient” on each document transmitted to HUD must correspond to the
“Recipient” specified in the Amended CPF Grants Table.
Registration All entities doing business with the federal government must register in
Required SAM.gov (SAM) and use a Unique Entity ID (UEI) created in SAM.gov. The UEI
replaced the DUNS number, which was phased out in April of 2022. More
information on this requirement is below in the Federal Requirements section in
Section 3.

The UEI needs to be established in SAM before you complete and transmit your
SF-424(s) and the Grant Agreement to HUD, because the UEI must be included
on both those documents.
How to Submit With the exception of the SF-1199A, required CPF application materials must be
Required completed in DRGR.
Information
NOTE: The SF-1199A must be uploaded into DRGR before submitting the entire
grant packet for HUD’s review.
When to Submit HUD strongly recommends that you submit these materials as soon as possible.
Please contact your System Officer (listed in Section 4) for assistance with
accessing DRGR or your Grant Officer (listed in Section 4) for assistance with
completing your materials in DRGR.

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FY2024 Community Project Funding Grant Guide (Version 1.0)
Requesting Payment After the grant agreement has been signed by you and then HUD, HUD will
of Grant Funds return the executed Grant Agreement to you along with the “Grant Award
Instructions.” The instructions will include steps for setting up your Action Plan
in DRGR.

Once your Action Plan is created in DRGR and approved by HUD (including entry
of budget information consistent with the approved budget attached to your
executed Grant Agreement), you may begin requesting payment(s) in
accordance with your approved budget. However, to receive payment(s) for
hard costs, you will also need to have a completed project-specific
environmental review.

Additional information and tutorials on DRGR are available on HUD Exchange


here: https://www.hudexchange.info/programs/drgr/.

As a reminder, payment of soft costs, covered by HUD’s nationwide


environmental review for CPF soft costs, can be made once your Grant
Agreement is executed by HUD; however, payment of hard costs can only be
made after your Grant Agreement is executed by HUD AND a project-specific
environmental review is completed.
Support CPF Grant Officers, listed in Section 4, are assigned by state and territory. Your
Grant Officer can assist you with the completion of the required documents and
answer any questions you may have regarding the materials that you will
submit.

System Officers, listed in Section 4, are also assigned by state and territory. Your
System Officer can assist you with DRGR technical assistance.

REOs provide technical assistance to grantees and local government REs on the
environmental review process and coordinate Part 50 concept meetings to
determine the level of environmental review, consultation needs, and a
timeline. Contact your HUD REO, listed in Section 4, with your technical
assistance request(s) regarding the environmental review process.

2.2 DRGR Overview

This section provides you with instructions on setting up your DRGR profile, requesting payments,
and submitting your semiannual reports.

DRGR was established for special appropriations, such as disaster grants, but has been extended to
include other special-purpose programs and appropriations. The system is primarily used by grantees
to access grant funds and report performance accomplishments for grant-funded activities.

DRGR allows grantees to tell their story to Congress, the public, and other stakeholders on project(s)
progress and related activities. Additionally, if a grantee has turnover, DRGR is a repository of data for
new staff.
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FY2024 Community Project Funding Grant Guide (Version 1.0)

DRGR is used by HUD staff to review grant-funded activities. Once your grant is set up in DRGR, HUD
will review your information and unblock the grant to permit withdrawals after they are approved.
Grantees will draw down funds by creating vouchers that list amounts by specific activity. You will
also submit performance reports semi-annually by using the structure established in DRGR.

2.2.1 How to Create A DRGR Account

HUD staff will request the initial DRGR account creation for the grantee administrator user.

Once the Authorized Representative receives access to DRGR, the Authorized Representative can
request additional users by logging into https://drgr.hud.gov/DRGRWeb, using the ID and password
provided by HUD. The Authorized Representative will submit a new user request via the “Request
New User” link in the Admin Module to give the requisite additional staff access to DRGR.

If the user did not receive an email granting access to the system, please check with the Authorized
Representative. To request a new account, modify an existing account, or request a deactivation,
please contact your designated System Officer and copy the CPF mailbox at CPFgrants@hud.gov.

2.2.1.1 How to Request New User(s)

DRGR does not allow a grantee user to both create/request and approve a voucher. You must assign
and maintain at least two (2) DRGR user accounts – one for creating vouchers for payment and one to
approve vouchers. Additionally, grantee administrators can establish the request user roles along
with roles for action plan submission.

If you have a DRGR or Integrated Disbursement and Information System (IDIS) account, you can reuse
your log-in account credentials to log into DRGR to access your CPF grant.

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FY2024 Community Project Funding Grant Guide (Version 1.0)

Administration: User Certification


As part of the account request
process other HUD or grantee
admin users will “certify” the need
for the user to access the system.
HUD staff certify grantee admin
users and then grantee admin
users certify other grantee users.

Users have to be recertified each


six months. If this does not occur
users will not have access to
DRGR. Grantee administrators can
use this screen to remove staff
access if they no longer work at
the grantee or on the grants.
They can also submit a separate
deactivation request for the
profile, as needed
12

2.2.1.2 Creating Roles in DRGR

Click the ‘Crown icon” and then click the “request new user” icon.

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FY2024 Community Project Funding Grant Guide (Version 1.0)

Administration: User Management

Only one draw role N/A N/A If these are 10


allowed per user required

2.2.2 Verify Your UEI & Tax Identification Number (TIN)

Once you login to DRGR, select the crown icon to open your Administration menu and select
“Manage Grantee.”

Review the information on the “Manage Grantee” page to confirm that your UEI and Tax
Identification Number (TIN) are accurately displayed.

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FY2024 Community Project Funding Grant Guide (Version 1.0)

If the UEI or TIN is inaccurate, please email the needed correction to your System Officer listed in
Section 4.

2.2.3 How to Complete Your Grant Package

When you login into DRGR, select the grant number from the drawdown menu on the Task bar.

Next click “Manage Grant Package” under the Grant Packages section.

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FY2024 Community Project Funding Grant Guide (Version 1.0)

Once you have selected “Manage Grant Package,” you will arrive to the Grant Processing Module
home page. You will complete all the required and applicable sections.

On this screen, please take a moment to review your grant information and status.

• Grant Number: Grant number assigned to your grant award.


• Grantee Name: Grantee’s organization (“Recipient” as assigned by the Amended CPF Grants Table).
• Authorized Contact: Your authorized contact for your grant award.
• Grant Package Status: The current status of your grant package in the review and approval process.
• Project Description: The legal description of your project in the Amended CPF Grants Table.
• Recipient Address: Grantee’s legal address.
• Congressional Requestor(s): The sponsoring Congressional member(s) per the Amended CPF Grants
Table.
• Grant Officer Manager: Your assigned CPF Grant Officer.
• Grant Status: The status of your grant.

If you believe any of the above information needs to be changed, please email your CPF Grant Officer.

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FY2024 Community Project Funding Grant Guide (Version 1.0)

2.2.3.1 Project Manager

To begin, click the “Edit” icon to the far right of “Project Manager.”

Please provide the contact information of the main point of contact serving as the Project Manager
for the grant. Select “Complete” then click “Save.”

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FY2024 Community Project Funding Grant Guide (Version 1.0)

2.2.3.2 Additional Point(s) of Contact

Next you have the option to add up to two (2) additional contacts. The two (2) additional contacts
will be copied on all DRGR notifications sent for the grant. Click the “Edit” icon to the far right of
“Additional Contact (1) and/or (2).” Complete the information for each additional contact, select
“Complete,” and then click “Save.”

2.2.3.3 Responsible Entity’s Contact Information

Next click the “Edit” icon to the far right of “Environmental Review Contact.” Please provide the
contact information of the individual who is completing the environmental review for your grant. If
you have not identified the individual, please enter the Project Manager’s contact information. Once
done, select “Complete” then click “Save.”

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FY2024 Community Project Funding Grant Guide (Version 1.0)

2.2.3.4 Congressional District(s)

Next click the “Edit” icon to the far right of “Congressional Districts.” Please provide the
Congressional District for your grant.

Enter the Congressional District in the format: 2-character State Abbreviation and 3-character District
Number. Examples: CA-005 for California’s 5th district, CA-012 for California’s 12th district. If all
districts in a state are affected, enter “all” for the district number. Example: MD-all for all
congressional districts in Maryland. If nationwide (all districts in all states), enter US-all. If the
program/project is outside the US, enter 00-000.

If you’re unsure of your district number, try the following:


1) Go to https://www.house.gov and enter your organization’s zip code under the “Find Your
Representative” heading in the middle-left of the website.
2) The name of your representative, along with his or her district number, will appear in the results. If
a district is described as “at large”, then the congressional district number should be entered
“001.”
3) In some cases, the results will return two representatives and two congressional districts. This
happens when “the information you provided [your zip code] overlaps multiple congressional
districts”. You will then be asked to provide your street address, city and state, and then to click
“Find Your Rep By Address.” This additional search will return a single name and a single
congressional district.

Once done, select “Complete” then click “Save.”

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FY2024 Community Project Funding Grant Guide (Version 1.0)

2.2.3.5 Subrecipient(s)

Use of subrecipients is subject to the conditions provided in Article III, section H of the Grant
Agreement. If you intend to subaward a portion, or all, of your grant funds to a subrecipient, and
have already identified that subrecipient, then that organization’s name, UEI, and an overview of
their role, responsibilities, and functions to be carried out on this project must be included in the
project narrative. The use of subrecipients does not relieve you of responsibility for your grant. You
are responsible for all coordination with HUD on accessing all CPF grant funds, amendment requests,
reporting, correspondence, grant closeout, and all other grant requirements. You are responsible for
ensuring that the subrecipient(s) complies with all grant requirements. Further, you are required to
ensure that your subrecipient(s) is not debarred, suspended, or otherwise excluded from or ineligible
for participation in Federal programs or activities.

Next click the “Edit” icon to the far right of “Subrecipient Applicability.” Please indicate if you will
use a Subrecipient. Once done, select “Complete” then click “Save.”

Next click the “Edit” icon to the far right of “Subrecipients.” Please provide the name of your
subrecipient, name of the subrecipient’s point of contact, phone number, and email address. Please
repeat this step for each subrecipient you plan to use. There is no limit on the number of
subrecipients that can be added.

Once done, select “Complete” then click “Save.”

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FY2024 Community Project Funding Grant Guide (Version 1.0)

2.2.3.6 Project Scope

Next click the “Edit” icon to the far right of “Project Scope.” Please provide information about the set
boundaries on your project and define exactly what goals, deadlines, and project deliverables you’ll
be working towards. Once done, select “Complete” then click “Save.”

2.2.3.7 Project Narrative

Content: Your Project Narrative must include sufficient scope and information about the ENTIRE
affected project (not limited to the portion funded by your grant) to inform the environmental review
process. Project activities must be grouped together and evaluated as a single project for all
individual activities which are related either on a geographical or functional basis, or both, or are
logical parts of a composite of contemplated actions. More information on HUD’s aggregation
principles can be found at 24 CFR 58.32.

Your Project Narrative must also make clear which portion of the project, or specific project activities,
will be funded using the FY2024 CPF grant funds.

In anticipation of the required semi-annual reporting on activity types and annual reports on “Section
3 Economic Opportunity Part 75” accomplishments, the narrative should provide anticipated project

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FY2024 Community Project Funding Grant Guide (Version 1.0)
goals, outputs, or outcomes, including “Section 3 Economic Opportunity Activity Performance
Measures.”

The Project Narrative should include:


• Project Name: Identify the “project.” This must be consistent with the “project” specified in the
Amended CPF Grants Table.
• Project Purpose: Provide a brief one sentence summary.
• Project Scope:
o What will the CPF grant be used for?
▪ Identify general activity categories and specify what the grant award will be used
for.
o Is the CPF funded project part of a larger project?
▪ If so, please provide a brief description of the broader project.
o Has the project started? If so, please provide a brief overview of the status of the project.
▪ If the project has been started, did you initiate a HUD NEPA environmental review?
• Please review HUD’s environmental review requirements in Section 3.
▪ For basic questions about the environmental review requirements or process,
please reach out to the Environmental Review Ask A Question Help Desk. (See
Section 5 for directions.)
▪ For project specific questions about environmental reviews, reach out to the
Regional Environmental Officers listed in Section 3 below.
o Will you be using a subrecipient to implement any part of the project?
(Please note HUD’s conditions on using subrecipients, which are specified in Article III,
section H of the Grant Agreement) and highlighted below.
• Proposed Subrecipient(s): If you intend to subaward a portion, or all, of your grant funds to a
subrecipient, and have already identified that subrecipient, then include that organization’s
name, UEI, and an overview of their role, responsibilities, and functions to be carried out on this
project.

Next click the “Edit” icon to the far right of “Project Description.” Please provide a comprehensive
project overview in accordance with the instructions above. Once done, select “Complete” then click
“Save.”

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FY2024 Community Project Funding Grant Guide (Version 1.0)
2.2.3.8 Project Location

Next click the “Edit” icon to the far right of “Project Location.” Please provide details about the
area(s) where the Project materials, equipment, and any other efforts, as described in the Scope of
Work, are installed, and the general area(s) where the Work is performed. Once done, select
“Complete” then click “Save.”

Next click the “Edit” icon to the far right of “Project Address.” Please provide the street address of
the project. If the project does not have a physical street at the time of submission, please provide
the address of the organization. Then in the Geographic Location, please provide GPS latitude and
longitude of your project. Once done, select “Complete” then click “Save.”

Next click the “Edit” icon to the far right of “Geographic Location.” This section is optional, if you
already provided an address for the activity in the “Project Address.” However, if your project has
multiple addresses for the activity, please provide the additional addresses in this section.

Also, provide the GPS latitude and longitude of your project if you do not have a physical location.
Once done, select “Complete” then click “Save.”

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FY2024 Community Project Funding Grant Guide (Version 1.0)

Next click the “Edit” icon to the far right of “Project Map – Image 1.” Please provide an image of
your project location. Once done, select “Complete” then click “Save.”

Repeat the same step for Project Map – Image 2 through Image 5, if applicable, to attach additional
images.

2.2.3.9 Funding Narrative

Next click the “Edit” icon to the far right of “CPF Funding Description.” Please provide clear, detailed
information for which portion of the project, or specific project activities, that will be funded using
CPF funds. Once done, select “Complete” then click “Save.”

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FY2024 Community Project Funding Grant Guide (Version 1.0)

2.2.3.10 Project Activities

Next click the “Edit” icon to the far right of “Activities Applicability.” Please select the activity type(s)
that best align to your projects. Once done, select “Complete” then click “Save.”

2.2.3.11 Grantee’s Fiscal Year

Next click the “Edit” icon to the far right of “Reporting Period.” Please select the date range that
aligns with your organization’s fiscal year. Once done, select “Complete” then click “Save.”

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2.2.3.12 Project Budget

HUD needs a line-item budget of your project’s funding source(s).

Next click the “Edit” icon to the far right of “SF-424 Budget.” Please enter the total CPF Award
Amount in Federal Estimated Funding. Complete this section by providing the full project budget
total. If other Federal funds are included the project, place the total “Other Estimated Funding.” In
“Data Section” provide the name of funding source for the project. (i.e. CPF Award, CDBG, Local
Development Fund). Once done, select “Complete” then click “Save.”

2.2.3.13 CPF Budget

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As defined by 2 CFR 200.1, “budget” means the financial plan for the Federal award that the Federal
awarding agency or pass-through entity approves during the Federal award process or in subsequent
amendments to the Federal award.

As such, HUD needs a line-item budget to include costs for the CPF portion(s) of your project. PLEASE
NOTE: The CPF portion of the line-item budget must add up to the full grant amount. The line-item
budget does not have to be explicit in the use of funds under a line item, provided that the Project
Narrative and line-item budget provide enough detail as a whole for HUD to make a reasonable
determination that the grant-funded costs are consistent with the Congressional authorization.

All pertinent budgetary information should be listed and explained, such as:
• the overall amount for predevelopment costs;
• construction, renovation, and rehabilitation costs;
• acquisition, demolition, and site preparation;
• architectural and engineering fees;
• initial set asides for revolving loan funds; and
• administrative costs.

As provided by the FY2024 Acts, eligible expenses under the grant may include administrative,
planning, operations and maintenance, and other costs that are reasonable and necessary to carry
out the “Project” specified in the Amended CPF Grants Table.

Next click the “Edit” icon to the far right of “CPF Cost Budget.” Please provide the detailed budget
for use of the CPF funding. Enter the name and amount for the line item, then click “Add row.”
Repeat steps until the total CPF Budget has been allocated. The total CPF Cost Budget must match
the “Federal Estimated Funding” amount entered on the SF-424. Once done, select “Complete” then
click “Save.”

2.2.3.14 Indirect Cost Rate

Next click the “Edit” icon to the far right of “CPF Cost Indirect Cost Budget.” Please select the
applicable cost rate. If you use a Federal Negotiated Indirect Cost Rate, enter the name of the
cognizant agency for indirect costs, the approved Indirect Cost Rate, the budgeted Indirect Cost, and

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answer the questions. Please ensure the “CPF Cost Budget” Includes a line-item reflecting the
indirect cost rate. Once done, select “Complete” then click “Save.”

Click on the “Documents” tab, then click “Add Document.”

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Next click “Public” then click “Choose File.” Search your PC and select the desired file then click
“Open.”

Next click “Save.”

The file will be saved in the Supporting Documents then click “Details.”

2.2.3.15 Disclosures

Next click the “Edit” icon to the far right of “Financial Disclosures.” Please answer all the applicable
questions that apply to your organization.

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NOTE: these questions are part of the SF-424.

Once done, select “Complete” then click “Save.”

2.2.3.16 Environmental Review Status

Next click the “Edit” icon to the far right of “HUD Environmental Review Information.” Please
answer all the questions related to the status of your HUD review. At a minimum, all questions with
an asterisk (*) are required to be completed. Once done, select “Complete” then click “Save.”

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2.2.3.17 Disclosure of Lobbying Activities

No appropriated Federal funds may be paid by or on behalf of the applicant, to any person for
influencing or attempting to influence an officer or employee of any agency, a member of Congress,
or an employee of a member of Congress, in connection with this “application” for Federal assistance
or any award of funds resulting from the submission of this “application” for Federal assistance or its
extension, renewal, amendment, or modification.

If your organization has paid or will pay funds other than Federal appropriated funds to influence or
attempt to influence the persons listed above, you must complete and submit the SF-LLL, as part of
your “application” submission package. This form is generated using the information you provide in
DRGR.

Exception: Federally recognized Indian tribes and Tribally Designated Housing Entities (TDHE)
established by federally recognized Indian tribes as a result of the exercise of the tribe’s sovereign
power are excluded from coverage of the Byrd Amendment, and do not have to submit these forms.
State-recognized Indian tribes and TDHEs established only under State law must comply with this
requirement.

Next click the “Edit” icon to the far right of “Lobbying Registrant Contact.” If your organization used
a Federal Lobbyist, please provide the name and address of your Reporting Entity. Note: If your

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organization did not use a Federal Lobbyist, enter “Not Applicable” in the required fields. Once done,
select “Complete” then click “Save.”

Next click the “Edit” icon to the far right of “Individual Performing Services Contact.” If your
organization used a Federal Lobbyist, please provide the name and address of Lobbying Registrant.
Note: If your organization did not use a Federal Lobbyist, enter “Not Applicable” in the required
fields. Once done, select “Complete” then click “Save.”

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2.2.3.18 Assurances

Next click the “Edit” icon to the far right of “SF424 – Assurances.” Please select the appropriate
assurance as this will generate your SF-424B (Non-Construction related) and/or SF-424D
(Construction related). For construction projects, grantees will complete both the SF-424B and SF-
424D. Once done, select “Complete” then click “Save.”

2.2.3.19 Direct Deposit

Please download the SF-1199A banking information form


(https://www.gsa.gov/system/files/SF1199A-20.pdf).

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You must complete Sections 1 and 2 of the SF-1199A (see Attachment 2). Your bank or financial
institution must complete Section 3 of this form. Ensure that you include a voided check, deposit slip,
or bank letter with this form and upload it to DRGR in accordance with the instructions in Section
2.2.2.14.

Section 1: (To be completed by you) Section 2: (Completed by you)

A. Enter grantee’s name, address, and telephone Government Agency Name:


number HUD/Office of CPD
B. Enter grantee’s CPF grant number
C. Enter grantee’s EIN/TIN Government Agency Address:
D. Check the type of account you want your funds 451 7th Street, SW, Washington, DC 20410
deposited into (Attach voided check or deposit slip)
E. Enter the account number you want your funds
deposited into Section 3: (To be completed by your financial
F. Check “Other” and specify “CPF-Grant” institution)
G. Leave Blank
H. Sign and date the form

Section 1 of this form must be signed and dated by your Authorized Representative. Section 3 must
be signed and dated by your financial institution.

Review and verify the contents on this form for accuracy prior to uploading into DRGR. DO NOT MAIL
THE COMPLETED FORM TO HUD.

Note: Follow the same steps for attaching documents as provided in Section 2.2.2.14.

Once the form is successfully uploaded, click the “Edit” icon to the far right of “SF-1199A” and answer
the questions. Once done, select “Complete” then click “Save.”

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2.2.3.20 Annual Single Audit

Next click the “Edit” icon to the far right of “Single Audit Threshold.” Please answer the questions
based upon your organization’s last completed fiscal year.

Note: If your organization has completed a Single Audit, please attach a copy in the documents
section of DRGR. Follow the same steps for attaching documents as provided in Section 2.2.2.14.

Once done, select “Complete” then click “Save.”

2.2.3.21 Miscellaneous

Next click the “Edit” icon to the far right of “Miscellaneous.” Please provide any additional pertinent
information about your grant. Once done, select “Complete” then click “Save.”

2.2.3.22 Validating Grant Package

Once all required sections of the Grant Package sections are completed, the next step is to validate
the grant package for errors.

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Click on the “Validate Grant Package.”

Once the validation is completed, a success or error(s) message will display. If there are any errors,
address the errors by fixing the section(s) identified in the error(s) message.

After completing the validation of the Grant Package, the next step is to submit your package to HUD
for review.

2.2.3.23 Submitting Grant Package

Next click on the “Submit Grant Package.”

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Note: Please make sure the grant package is submitted by the Authorized Representative. If the
Authorized Representative’s name as listed on the Grant Package home page needs to be updated,
please email your System Officer, and copy your Grant Officer.

Note:
Next the Authorized Representative will type his/her First Name space Last Name as displaced in the
upper right-hand corner of the DRGR system. Click on “Sign Document.”

The Grant Package has been submitted to HUD for review and approval.

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Once you have completed and submitted the package, DRGR generates all the required
documentation. You can obtain copies of the generated documents by clicking the “Documents” tab.
Additionally, you can monitor the grant processing status by checking the Grant Package Status on
the Manage Grant Package screen.

To print or download a complete copy of your completed Grant Package, click “View Package.”

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Then click the “Print” icon or “Word doc” icon in the upper right-hand corner of the TABLE OF
CONTENTS.

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2.3 Detailed Instructions

2.3.1 Grant Award Conditions

Grantee or Project is If a Grantee or Project is awarded more than one CPF grant, HUD will not combine
Awarded More than the grants into one grant. Each grant must be processed separately.
One CPF Grant
Start or Effective Date The date HUD signs your grant agreement is the start date for your grant’s period
of the Grant of performance and budget period. However, grant funds may be used for costs
incurred before this date, provided that:
(1) The soft costs are covered by HUD’s nationwide environmental review for
CPF soft costs and are incurred on or after March 9, 2024, or hard costs
incurred on or after the later of March 9, 2024, or completion of the
required project-specific environmental review; and
(2) The costs would otherwise meet the allowability criteria in 2 CFR
200.403(a) through (g).
Grant End Date To give you the maximum time feasible to complete your project(s), HUD has
established August 31, 2032, as the end date of the period of performance and
budget period for all FY2024 CPF grants. However, despite what 2 CFR 200.344(b)
provides for liquidating obligations incurred under the award and 2 CFR
200.403(h) provides for administrative closeout costs, HUD will NOT be
responsible for making any grant payments after the date Treasury closes the
account in accordance with 31 U.S.C. § 1552. Because Treasury may close the
account up to one week before the September 30th date specified by 31 U.S.C. §
1552, the grantee is advised to make its final request for payment under the grant
no later than September 15, 2032.
Assistance Listing The Assistance Listing number (formerly called the Catalog of Federal Domestic
Number Assistance (CFDA) number) for EDI-CPF grants is 14.251.

2.3.2 Requesting Changes to Approved Project Narrative or Budget

Once you receive your fully executed grant agreement, any project and budget change will be subject
to the conditions provided by 2 CFR 200.308 and Article III, section C of the Grant Agreement. Any
change to the project scope as originally proposed to your Congressional member(s) must be
consistent with the conditions that apply to your award under the Consolidated Appropriations Act,
2024, as modified by the Further Consolidated Appropriations Act, 2024 or a later act. HUD does not
have the authority to approve changes that depart from these applicable appropriations act
conditions. For example, if a grantee wants to change a project from creating a community center to
creating a housing complex, HUD will not be able to approve the change unless the Consolidated
Appropriations Act, 2024, the Further Consolidated Appropriations Act, 2024, or a later Federal
statute authorizes the grant to be used for development of a housing complex.

2 CFR 200.308 allows some changes to be made without HUD approval.

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To request HUD’s approval of a change to your project narrative or budget (outside of what is
allowed in 2 CFR 200.308) after you receive your fully executed Grant Agreement, you must email a
formal letter to your Grant Officer requesting HUD to consider an amendment to revise your
approved project narrative and/or approved budget. The letter must:
• Be on agency letterhead addressed to the CGD Director;
• Be signed by your Authorized Representative;
• Provide justification for the change; and
• Include:
o the revised project narrative and/or revised line-item budget, as applicable;
o a detailed explanation of how the change(s) keeps with the intent of Congress;
o why the change(s) is needed; and
o the details of the revised narrative or line-item budget.

HUD will email you notifying you whether your amendment was approved or disapproved, with an
explanation.

Before you expend grant funds in accordance with any change(s) approved by HUD or otherwise
allowed by 2 CFR 200.308, you must update your grant information in DRGR to reflect the change(s).

Amendments to a previously approved project narrative and/or budget may also require a revision of
your environmental review for the amended project.

2.3.3 SF-424: Application for Federal Assistance

The SF-424 is the common application form for federal funding. The form provides HUD with basic
information about the applicant, the project, and the project funding source. This form is generated
using the information you provide in DRGR.

Additional Certifications and Assurances: By going through our process and completing the SF-424
in DRGR, the Authorized Representative will be making the following additional certifications and
assurances on behalf of the prospective grantee (“applicant”):

a. The governing body of the applicant’s organization has duly authorized the application for
Federal assistance. In addition, by signing and electronically submitting the application, the
Authorized Representative certifies that the applicant:

(1) has the legal authority to apply for Federal assistance and the institutional,
managerial, and financial capacity (including funds to pay for any non-Federal share of
project costs) to plan, manage, and complete the project as described in the
application (including the attached project narrative);
(2) will provide HUD any additional information it may require; and
(3) will administer the award in compliance with the grant requirements as identified
in the Grant Agreement or as may otherwise be provided by Federal law.

b. Certification Regarding Lobbying. Subject to the exception in item c below, the Authorized
Representative certifies, to the best of his or her knowledge and belief, that:
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(1) No Federal appropriated funds have been paid or will be paid, by or on behalf of
the undersigned, to any person for influencing or attempting to influence an officer or
employee of an agency, a Member of Congress, an officer or employee of Congress, or
an employee of a Member of Congress in connection with the awarding of any Federal
contract, the making of any Federal grant, the making of any Federal loan, the entering
into of any cooperative agreement, and the extension, continuation, renewal,
amendment, or modification of any Federal contract, grant, loan, or cooperative
agreement.
(2) If any funds other than Federal appropriated funds have been paid or will be paid
to any person for influencing or attempting to influence an officer or employee of any
agency, a Member of Congress, an officer or employee of Congress, or an employee of
a Member of Congress in connection with this Federal contract, grant, loan, or
cooperative agreement, the undersigned shall complete and submit Standard Form-
LLL, “Disclosure Form to Report Lobbying,” in accordance with its instructions.
(3) The undersigned shall require that the language of this certification be included in
the award documents for all subawards at all tiers (including subcontracts, subgrants,
and contracts under grants, loans, and cooperative agreements) and that all
subrecipients shall certify and disclose accordingly.
This certification is a material representation of fact upon which reliance was placed
when this transaction was made or entered into. Submission of this certification is a
prerequisite for making or entering into this transaction imposed by section 1352, title
31, U.S. Code. Any person who fails to file the required certification shall be subject to
a civil penalty of not less than $10,000 and not more than $100,000 for each such
failure.

c. Exception to Certification Regarding Lobbying: Federally recognized Indian tribes and


Tribally Designated Housing Entities (TDHEs) established by a federally recognized Indian tribe,
as a result of the exercise of the tribe’s sovereign power, are excluded from coverage by item
b (also known as the Byrd Amendment). However, State-recognized Indian tribes and TDHEs
established under State law are not excluded from the statute’s coverage and therefore agree
to, and must comply with, item b above.

d. By submitting this application, the applicant and Authorized Representative are affirming
that these certifications and assurances are material representations of the facts upon which
HUD will rely when making an award to the applicant. The applicant and Authorized
Representative understand that providing false or misleading information during any part of
the application, award, or performance phase of an award may result in criminal, civil or
administrative sanctions, including but not limited to: fines, restitution, and/or imprisonment
under 18 USC 287, 1001, 1010, 1012; treble damages and civil penalties under the False
Claims Act (31 USC 3729 et seq.); double damages and civil penalties under the Program Fraud
Civil Remedies Act (31 USC 3801 et seq.); civil recovery of award funds; suspension and/or
debarment from all federal procurement and non-procurement transactions under 2 CFR
parts 180 and 2424; and other remedies including termination of the award under 2 CFR
200.339 and 200.340.

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SECTION 3: FEDERAL REQUIREMENTS

The FY2024 CPF Grant Agreement will set forth all applicable regulatory requirements for your grant.

As the grantee, you are responsible for managing the project and ensuring the proper use of the CPF
funds in compliance with all applicable Federal requirements. You are also responsible for ensuring
the completion of the project and its proper closeout.

Subject to the conditions stated in Article III, section H of the FY2024 CPF Grant Agreement, you may
subaward all or a portion of your funds to one or more subrecipients, as identified in your Project
Narrative (which will be incorporated in your FY2024 CPF Grant Agreement) or as may be approved
by HUD in accordance with 2 CFR 200.308. As the grantee, you are responsible for ensuring each
subrecipient’s compliance with federal requirements.

Below are the applicable regulatory requirements of the CPF grant.

• Section 3.1 details the requirements of the FY2024 Acts.


• Section 3.2 details the applicable Federal requirements standard to all HUD grants. HUD refers
to these requirements as “cross-cutting” as they apply across all HUD programs.

It is important to note that if CPF funds are combined in a project budget with other Federal grant
funds or the CPF funds are used on projects that are subject to other Federal grant requirements, you
must comply with both CPF requirements and the other Federal grant requirements.

Because CPF awards are authorized and funded through specific Congressional directives as provided
by the Act, CPF awards are distinct from Community Development Block Grant funding and are not
subject to Title I of the Housing and Community Development Act of 1974 or the Community
Development Block Grant regulations at 24 CFR part 570.

Where statutory restrictions apply, HUD cannot provide waivers or exceptions without statutory
authority to do so. In circumstances where there is a conflict between this CPF guide and other HUD
guidance, HUD will resolve the conflict.

3.1 Requirements Under the Consolidated Appropriations Act, 2024 (P.L. 118-42) and Further
Consolidated Appropriations Act, 2024 (P.L. 118-47)

Summary
The Project, Recipient, and The Project, Recipient, and Amount of each FY2024 CPF award must be
Amount of each FY2024 consistent with the “project,” “recipient,” and “amount” specified by the
CPF award Amended CPF Grants Table.
Eligible Expenses Consistent with the FY2024 Acts’ provisions, eligible expenses of the grant
may include administrative, planning, operations and maintenance, and
other costs that are reasonable and necessary to carry out the “project”
specified in the Amended CPF Grants Table.

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PLEASE NOTE: To be allowable under the grant, the cost not only must be
eligible, but also must meet the cost allowability criteria in 2 CFR 200.403,
unless a statute expressly provides otherwise (such as in the case of pre-
award costs as noted below).
Pre-award costs Consistent with the FY2024 Act’s provisions, FY2024 CPF grant funds may
be used to reimburse costs (including administrative, planning, operations
and maintenance, and other costs) incurred before execution of the grant
agreement, provided that:
(1) The soft costs are covered by HUD’s nationwide environmental
review for CPF soft costs and are incurred on or after March 9,
2024, or hard costs incurred on or after the later of March 9, 2024,
or completion of the required project-specific environmental
review; and
(2) The costs would otherwise meet the allowability criteria in 2
CFR 200.403(a) through (g).
Eminent Domain No Federal funds provided under your award may be used to support any
Federal, state, or local project that seeks to use the power of eminent
domain, unless eminent domain is employed only for a public use. Public
use includes use of funds for mass transit, railroad, airport, seaport, or
highway projects, and utility projects which benefit or serve the general
public (including energy-related, communication-related, water-related,
and waste water-related infrastructure), other structures designated for
use by the general public or with other common-carrier or public-utility
functions that serve the general public and are subject to regulation and
oversight by the government, and projects for the removal of an
immediate threat to public health and safety or brownfields, as defined in
the Small Business Liability Relief and Brownfields Revitalization Act (Pub.
L. 107-118). Public use does not include economic development that
primarily benefits private entities.

Restriction on Use of Funds No Federal funds provided under your award may be used to maintain or
for Computer Networks establish a computer network that does not block the viewing,
downloading, and exchanging of pornography. This requirement does not
limit the use of funds necessary for any Federal, State, tribal, or local law
enforcement agency or any other entity carrying out criminal
investigations, prosecution, or adjudication activities.

3.2 Cross Cutting Federal Requirements

Summary
Uniform Administrative The requirements of 2 CFR Part 200 apply to all CPF awards.
Requirements, Cost
Principles, and Audit You are encouraged to review the provisions of these regulations including
provisions related to:

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Requirements for Federal • Suspension and debarment at 2 CFR 200.214
Awards (2 CFR Part 200) • Prohibition on certain telecommunications and video surveillance
services or equipment at 2 CFR 200.216
• Financial management, internal controls, and Federal payment
requirements at 2 CFR 200.302, 200.303, and 200.305
• Program income requirements at 2 CFR 200.307*
• Revision of budget and program plans at 2 CFR 200.308
• Disposition of property acquired with CPF funds at 2 CFR §200.311
• Procurement requirements at 2 CFR §200.317-327
• Record retention and access requirements at 2 CFR 200.334-200.338
• Reporting requirements at 2 CFR 200.328-200.330, including on the
status of property acquired with CPF funds at 2 CFR §200.330
• Subrecipient monitoring and management at 2 CFR 200.331-200.333
• Remedies for Noncompliance at 2 CFR 200.339-200.343
• Closeout of federal grants at 2 CFR §200.344-346
• Cost Principles at 2 CFR Part 200, subpart E
• Audit requirements at 2 CFR Part 200, subpart F

*For purposes of all CPF awards, program income must be used for the
purposes and under the conditions of your specific CPF award in accordance
with the addition requirements at 2 CFR 200.307. Costs incidental to the
generation of program income may be deducted from gross income to
determine program income for purposes of your CPF grant, provided these
costs have not been charged to the Federal award. Further technical
assistance will be provided to grantees with projects that may generate
program income.
Environmental Review All projects funded by HUD are subject to requirements under the National
Requirements (24 CFR Environmental Policy Act (NEPA) and HUD’s NEPA-implementing regulations
Part 50 or Part 58) at 24 CFR Part 50 or 24 CFR Part 58. Environmental reviews must be
completed, and a Request for Release of Funds and Certification must be
Quick Overview approved by HUD CPD Field Office Director through issuance of the
Authority to Use Grant Funds (HUD-7015.16), as applicable, prior to taking
(More detailed guidance any choice limiting action, to avoid violations under 24 CFR 58.22 which
starts in Section 3.3) prohibits limitations on activities pending clearance, and Section 110(k) of
the National Historic Preservation Act which prohibits anticipatory
demolition or significant harm of historic properties prior to completion of
the historic preservation review process known as Section 106 review.

The environmental review must be completed by a RE as defined at 24 CFR


58.2(a)(7), or HUD under 24 CFR Part 50 if your unit of general local
government is unable to serve as RE to complete the review. An applicant
that is a State, unit of general local government, Indian Tribe, or Alaska
Native Village must serve as the RE for the project. For other applicants, the
RE is the unit of general local government within which the project is
located that exercises land use responsibility, or the Indian Tribe or Alaskan

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Native Village jurisdiction within which the project is located that exercises
land use responsibility. REs can conduct an environmental review on behalf
of other entities in their jurisdiction even if they are not the grantee. In the
event that an RE that is not the grantee declines to assume responsibility
for the environmental review under Part 58, you must advise HUD, and
HUD will complete the environmental review under 24 CFR Part 50 or
designate another RE.

Locate your nearest HUD REO here (also see Section 4 in this document):
https://www.hudexchange.info/programs/environmental-review/hud-
environmental-staff-contacts/#region-i-regional-and-field-environmental-
officers.

Further information on environmental requirements can be found here:


https://www.hudexchange.info/programs/environmental-
review/orientation-to-environmental-reviews/#overview.

You may not commit or spend ANY project funds (HUD or non-HUD funds)
on hard costs or take any choice limiting actions until the project
completes an environmental review. Examples of choice limiting actions
include, but are not limited to, purchasing land, entering into contracts for
property acquisition or construction, or physical work on the project.
Failure to comply with the prohibition on choice limiting actions and
Section 110(k) can result in forfeiture of grant funds. You are encouraged
to commence the environmental review process for your project as soon as
possible. Under Part 58, the environmental review process is complete
when the RE certifies the review and, if applicable, a Request for Release of
Funds and Certification is approved by HUD CPD Field Office Director
through issuance of the HUD-7015.16, as applicable. Under Part 50, the
environmental review process is complete when certified by the HUD
Authorizing Official.

See Section 3.3 below for additional detail on fulfilling environmental


review requirements.
Build America Buy The Build America, Buy America Act (BABA) was enacted as part of the
America (BABA) Infrastructure Investment and Jobs Act (IIJA) on November 15, 2021. BABA
established the Buy America Preference (BAP), which requires that
Federally funded infrastructure projects use domestically produced
materials.

FY2024 CPF grantees are encouraged to review BABA information available


on the BABA HUDExchange page, including CPD’s BABA implementation
notice. See Section 3.4 below for additional details on BABA requirements
and applicability.
Indirect Cost Rate Normal indirect cost rules under 2 CFR Part 200, subpart E apply. The
appropriate grant agreement appendix must be filled out and signed if you

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intend to use an indirect cost rate to calculate and charge indirect costs to
the grant.

Special instructions for state and local governments: If your department


or agency unit has a Federally negotiated indirect cost rate, you must
include that rate and the applicable distribution base in the table provided
and be able to support that rate information with a letter or other
documentation from the cognizant agency showing the approved rate. If
your department or agency unit receives more than $35 million in direct
Federal funding per year, you may not claim indirect costs until you receive
a negotiated rate from your cognizant agency for indirect costs as provided
in Appendix VII to 2 CFR Part 200.

If your department or agency unit receives no more than $35 million in


direct Federal funding per year and your department or agency unit has
developed and maintains an indirect cost rate proposal and supporting
documentation for audit in accordance with 2 CFR Part 200, Appendix VII,
you may include the rate and distribution base specified in that indirect cost
rate proposal.

Alternatively, if your department or agency unit receives no more than $35


million in direct Federal funding per year and does not have a current
negotiated rate (including provisional) rate), you may elect to use the de
minimis rate as allowed under 2 CFR 200.414(f). As described in 2 CFR
200.403, costs must be consistently charged as either indirect or direct
costs and must not be double charged or inconsistently charged as both.
Once elected, the de minimis rate must be used for all Federal awards until
you choose to negotiate for a rate, which you may apply to do at any time.

Special instructions for applicants other than state and local governments:
If you have a Federally negotiated indirect cost rate, you must include that
rate and the applicable distribution base in the table provided and be able
to support that rate information with a letter or other documentation from
the cognizant agency showing the approved rate. If your organization does
not have a current negotiated rate (including provisional rate) and elects to
use the de minimis rate, your application must clearly state you intend to
use the de minimis rate. As described in 2 CFR 200.403, costs must be
consistently charged as either indirect or direct costs and must not be
double charged or inconsistently charged as both. Once elected, the de
minimis rate must be used for all Federal awards until the organization
chooses to negotiate a rate, which the organization may apply to do at any
time.
Economic Opportunities Section 3 of the Housing and Urban Development Act of 1968 (Section 3),
for Low-and Very Low- 12 U.S.C. 1701u (Economic Opportunities for Low- and Very Low-Income
income Persons: Section Persons in Connection with Assisted Projects), and the HUD regulations at
3 Requirements (24 CFR 24 CFR Part 75, ensure, to the greatest extent feasible, that training,

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FY2024 Community Project Funding Grant Guide (Version 1.0)
Part 75) and Indian employment, contracting and other economic opportunities be directed to
Preference low- and very low-income persons, especially recipients of government
assistance for housing, and to businesses that provide economic
opportunities to low-and very low-income persons where a proposed
project is located.

You are encouraged to review the requirements of this regulation to


determine ways to support the mission of increasing economic opportunity
for low- and very-low-income persons and small business owners in your
community. You will submit periodic reports of Section 3 accomplishment
Performance Measures in DRGR. A link to DRGR guidance for reporting
Section 3 accomplishments is provided below.

CPF grants made to Tribes and TDHEs are subject to Indian Preference
requirements in Section 7(b) of the Indian Self-Determination and
Education Assistance Act (25 U.S.C. 5307(b)). As stated in 24 CFR §75.3(c),
grants to Tribes and TDHEs are subject to Indian Preference requirements in
lieu of Section 3.

For all other CPF grant recipients, if $200,000 or more is awarded for
projects involving housing construction, rehabilitation, or other public
construction, the Section 3 requirements in 24 CFR Part 75 apply.

www.hud.gov/localoffices

www.EEOC.gov
http://www.dol.gov/ofccp/

https://files.hudexchange.info/resources/documents/DRGR-Guidance-on-
Reporting-Section-3-Labor-Hours-Fact-Sheet.pdf
Uniform Relocation With certain limited exceptions, HUD-funded programs or projects are
Assistance and Real subject to the Uniform Relocation Assistance and Real Property Acquisition
Property Acquisitions Policies Act of 1970, as amended (URA) (42 U.S.C. §§ 4601 et seq.), and the
Policies Act government-wide regulations issued by the Federal Highway Administration
at 49 CFR Part 24.

The URA applies to acquisitions of real property and relocation occurring as


a direct result of the acquisition, rehabilitation, or demolition of real
property for Federal or Federally funded programs or projects. Real
property acquisition that receives Federal financial assistance for a program
or project, as defined in 49 CFR 24.2, must comply with the acquisition
requirements contained in 49 CFR part 24, subpart B. Unless otherwise
specified in law, the relocation requirements of the URA and its
implementing regulations at 49 CFR part 24, cover any displaced person (as
defined in 49 CFR 24.2) who moves from real property or moves personal

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FY2024 Community Project Funding Grant Guide (Version 1.0)
property from real property as a direct result of acquisition, rehabilitation,
or demolition for a program or project receiving HUD financial assistance.
Generally Applicable You and your subrecipients must comply with the generally applicable HUD
HUD requirements (24 and CPD requirements in 24 CFR Part 5, subpart A, including all applicable
CFR Part 5, subpart A and fair housing and civil rights requirements.
24 CFR 1000.12)
The Grantee must report data on the race, color, religion, sex, national
origin, age, disability, and family characteristics of persons and households
who are applicants for, participants in, or beneficiaries or potential
beneficiaries of the Grantee’s Project, consistent with the instructions and
forms provided by HUD in order to carry out its responsibilities under the
Fair Housing Act, Executive Order 11063, Title VI of the Civil Rights Act of
1964, and Section 562 of the Housing and Community Development Act of
1987 (e.g. HUD-27061).
Equal Participation of CPF grants are subject to HUD’s regulations at 24 CFR §5.109 concerning
Faith Based equal participation of faith-based organizations in HUD programs and
Organizations activities.
SAM registration and UEI The System for Award Management (SAM) and Unique Entity Identifier
(UEI) requirements under 2 CFR Part 25 apply.

Unless an exception under 2 CFR part 25 applies, each applicant for a CPF
award must:
(1) Be registered in SAM.gov before submitting an application or plan;
(2) Include its UEI in each application or plan submitted to HUD; and
(3) maintain an active SAM registration with current information at all
times while the applicant or grantee has an active Federal award
or an application under consideration by a Federal agency. This
includes:
(a) reviewing and updating the information in SAM.gov
annually from the date of initial registration or later
updates to ensure the information is current, accurate and
complete; and
(b) if applicable, identifying the applicant or grantee’s
immediate and highest-level owner and subsidiaries, as
well as providing information on all predecessors that
have received a Federal contract or grant within the last
three years.

To Sign up or Reactivate SAM.gov Account: You must have a SAM.gov


account. If your organization is already registered in SAM.gov, your UEI has
already been assigned and is viewable in SAM.gov. This includes inactive
registrations. Remember, you must be signed into your SAM.gov account to
view entity records. To learn how to view your UEI, go here:
https://www.fsd.gov/gsafsd_sp?id=gsafsd_kb_articles&sys_id=a05adbae1b
59f8982fe5ed7ae54bcbba.

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Direct subrecipients or “first-tier” subrecipients are also required to obtain
a UEI through SAM as provided by 2 CFR part 25. Subrecipients may refer
to the “Guide to Getting a Unique Entity ID” at SAM.gov to get a UEI.

You may contact your Grant Officer for technical assistance. Please refer to
this link to begin registering in SAM.gov and obtain your UEI number
https://sam.gov/content/home.
The Federal Financial Compliance with the Federal Funding Accountability and Transparency Act
Accountability and of 2006 (Pub. L. 109-282) as amended (FFATA). FFATA requires information
Transparency Act of on federal awards be made available to the public via a single, searchable
2006, (Public Law 109- website, which is www.USASpending.gov. Accordingly, your award will be
282), as amended subject to the requirements provided by the Award Term in Appendix A to 2
(FFATA) CFR Part 170, “REPORTING SUBAWARD AND EXECUTIVE COMPENSATION
INFORMATION,” unless the Federal funding for the award (including
funding that may be added through amendments) is not expected to equal
or exceed $30,000. Requirements under this Award Term include filing
subaward information in the Federal Funding Accountability and
Transparency Act (FFATA) Sub-award Reporting System (FSRS.gov) by the
end of the month following the month in which the recipient awards any
sub-grant equal to or greater than $30,000.

Each applicant must have the necessary processes and systems in place to
comply with the Award Term in Appendix A of 24 CFR Part 170 if the
applicant receives an award, unless an exception applies as provided in 2
CFR part 170.
Davis Bacon and Related Compliance with Davis Bacon and Related Acts (DBRA) is not a condition or
Acts (DBRA) requirement for CPF grants but may be required if your project is also
supported by other funds which do require adherence to the DBRA.
Suspension and The governmentwide debarment and suspension regulations in 2 CFR Part
debarment 180 apply as incorporated and supplemented by HUD’s implementing
regulations in 2 CFR Part 2424. These regulations restrict awards,
subawards, and contracts with certain parties that are debarred,
suspended, or otherwise excluded from or ineligible for participation in
Federal assistance programs or activities.

Prohibition Against Section 319 of Public Law 101-121, 31 U.S.C. 1352, (the Byrd Amendment)
Lobbying Activities and 24 CFR Part 87 apply to all CPF grantees except Federally recognized
Indian tribes and TDHEs established by Federally recognized Indian tribes as
a result of the exercise of the tribe’s sovereign power. The Byrd
Amendment and 24 CFR part 87 prohibit recipients of federal awards from
using appropriated funds for lobbying the executive or legislative branches
of the Federal government in connection with a Federal award. You must
submit the certification regarding lobbying and required disclosures as
described in section 2.3.3 of this Grant Guide.

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Drug-Free Workplace The following award term applies to all grantees of CPF awards: You as the
recipient must comply with drug-free workplace requirements in Subpart B
(or Subpart C, if the recipient is an individual) of 2 CFR Part 2429, which
adopts the governmentwide implementation (2 CFR Part 182) of sections
5152-5158 of the Drug-Free Workplace Act of 1988 (Pub. L. 100-690, Title V,
Subtitle D; 41 U.S.C. 701-707).

Trafficking in persons All FY 2024 CPF grants will be subject to the following award term and
condition, as required by 2 CFR part 175:

(a) Provisions applicable to a grantee that is a private entity.

(1) Under this award, the grantee, its employees, subrecipients under this
award, and subrecipient's employees must not engage in:

(i) Severe forms of trafficking in persons;

(ii) The procurement of a commercial sex act during the period of time that
this award or any subaward is in effect;

(iii) The use of forced labor in the performance of this award or any
subaward; or

(iv) Acts that directly support or advance trafficking in persons, including


the following acts:

(A) Destroying, concealing, removing, confiscating, or otherwise denying an


employee access to that employee's identity or immigration documents;

(B) Failing to provide return transportation or pay for return transportation


costs to an employee from a country outside the United States to the
country from which the employee was recruited upon the end of
employment if requested by the employee, unless:

(1) Exempted from the requirement to provide or pay for such return
transportation by the Federal department or agency providing or entering
into the grant or cooperative agreement; or

(2) The employee is a victim of human trafficking seeking victim services or


legal redress in the country of employment or a witness in a human
trafficking enforcement action;

(C) Soliciting a person for the purpose of employment, or offering


employment, by means of materially false or fraudulent pretenses,
representations, or promises regarding that employment;

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(D) Charging recruited employees a placement or recruitment fee; or

(E) Providing or arranging housing that fails to meet the host country's
housing and safety standards.

(2) The Federal agency may unilaterally terminate this award or take any
remedial actions authorized by 22 U.S.C. 7104b(c), without penalty, if any
private entity under this award:

(i) Is determined to have violated a prohibition in paragraph (a)(1) of this


appendix; or

(ii) Has an employee that is determined to have violated a prohibition in


paragraph (a)(1) of this this appendix through conduct that is either:

(A) Associated with the performance under this award; or

(B) Imputed to the grantee or the subrecipient using the standards and due
process for imputing the conduct of an individual to an organization that
are provided in 2 CFR part 180, “OMB Guidelines to Agencies on
Government-wide Debarment and Suspension (Nonprocurement),” as
implemented by HUD at 2 CFR part 2424.

(b) Provision applicable to a grantee other than a private entity.

(1) The Federal agency may unilaterally terminate this award or take any
remedial actions authorized by 22 U.S.C. 7104b(c), without penalty, if a
subrecipient that is a private entity under this award:

(i) Is determined to have violated a prohibition in paragraph (a)(1) of this


appendix; or

(ii) Has an employee that is determined to have violated a prohibition in


paragraph (a)(1) of this appendix through conduct that is either:

(A) Associated with the performance under this award; or

(B) Imputed to the subrecipient using the standards and due process for
imputing the conduct of an individual to an organization that are provided
in 2 CFR part 180, “OMB Guidelines to Agencies on Government-wide
Debarment and Suspension (Nonprocurement),” as implemented by HUD at
2 CFR part 2424.

(c) Provisions applicable to any grantee.

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(1) The grantee must inform the Federal agency and the Inspector General
of the Federal agency immediately of any information you receive from any
source alleging a violation of a prohibition in paragraph (a)(1) of this
appendix.

(2) The Federal agency's right to unilaterally terminate this award as


described in paragraphs (a)(2) or (b)(1) of this appendix:

(i) Implements the requirements of 22 U.S.C. 78, and

(ii) Is in addition to all other remedies for noncompliance that are available
to the Federal agency under this award.

(3) The grantee must include the requirements of paragraph (a)(1) of this
award term in any subaward it makes to a private entity.

(4) If applicable, the grantee must also comply with the compliance plan
and certification requirements in 2 CFR 175.105(b).

(d) Definitions. For purposes of this award term:

“Employee” means either:

(1) An individual employed by the grantee or a subrecipient who is engaged


in the performance of the project or program under this award; or

(2) Another person engaged in the performance of the project or program


under this award and not compensated by the grantee including, but not
limited to, a volunteer or individual whose services are contributed by a
third party as an in-kind contribution toward cost sharing requirements.

“Private Entity” means any entity, including for-profit organizations,


nonprofit organizations, institutions of higher education, and hospitals. The
term does not include foreign public entities, Indian Tribes, local
governments, or states as defined in 2 CFR 200.1.

The terms “severe forms of trafficking in persons,” “commercial sex act,”


“sex trafficking,” “Abuse or threatened abuse of law or legal process,”
“coercion,” “debt bondage,” and “involuntary servitude” have the meanings
given at section 103 of the TVPA, as amended (22 U.S.C. 7102).
i.

Conflicts of Interest i. Conflicts Subject to Procurement Regulations. In the procurement of


property or services by recipients and subrecipients, the conflict-of-
interest rules in 2 CFR 200.317 and 2 CFR 200.318(c) shall apply. In all
cases not governed by 2 CFR 200.317 and 2 CFR 200.318(c), recipients

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and subrecipients must follow the requirements contained in
paragraphs ii-v below.
ii. General prohibition. No person who is an employee, agent, consultant,
officer, or elected or appointed official of the recipient or subrecipient
and who exercises or has exercised any functions or responsibilities with
respect to assisted activities, or who is in a position to participate in a
decision making process or gain inside information with regard to such
activities, may obtain a financial interest or benefit from the activity, or
have a financial interest in any contract, subcontract, or agreement with
respect thereto, or the proceeds thereunder, either for himself or
herself or for those with whom he or she has immediate family or
business ties, during his or her tenure or for one year thereafter.
Immediate family ties include (whether by blood, marriage or adoption)
the spouse, parent (including a stepparent), child (including a stepchild),
brother, sister (including a stepbrother or stepsister), grandparent,
grandchild, and in-laws of a covered person.
iii. Exceptions. HUD may grant an exception to the general prohibition in
paragraph (ii) upon the recipient’s written request and satisfaction of
the threshold requirements in paragraph (iv), if HUD determines the
exception will further the Federal purpose of the award and the
effective and efficient administration of the recipient’s program or
project, taking into account the cumulative effects of the factors in
paragraph (v).
iv. Threshold requirements for exceptions. HUD will consider an exception
only after the recipient has provided the following documentation:
a. A disclosure of the nature of the conflict, accompanied by an
assurance that there has been public disclosure of the conflict
and a description of how the public disclosure was made; and
b. An opinion of the recipient's attorney that the interest for which
the exception is sought would not violate state or local law.
v. Factors to be considered for exceptions. In determining whether to
grant a requested exception after the recipient has satisfactorily met the
threshold requirements in paragraph (iii), HUD will consider the
cumulative effect of the following factors, where applicable:
a. Whether the exception would provide a significant cost benefit
or an essential degree of expertise to the program or project
that would otherwise not be available;
b. Whether an opportunity was provided for open competitive
bidding or negotiation;
c. Whether the person affected is a member of a group or class of
low- or moderate-income persons intended to be the
beneficiaries of the assisted activity, and the exception will
permit such person to receive generally the same interests or
benefits as are being made available or provided to the group or
class;

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d. Whether the affected person has withdrawn from his or her
functions or responsibilities, or the decision-making process with
respect to the specific assisted activity in question;
e. Whether the interest or benefit was present before the affected
person was in a position as described in paragraph (ii);
f. Whether undue hardship will result either to the recipient or the
person affected when weighed against the public interest served
by avoiding the prohibited conflict; and
g. Any other relevant considerations.
vi. Disclosure of potential conflicts of interest. Recipients must disclose in
writing to your CPF Grant Officer any potential conflict of interest.
Award Term and If the total Federal share of your Federal award may include more than
Condition for Recipient $500,000 over the period of performance, your Federal award will include
Integrity and the following terms and conditions as required by 2 CFR 200.211(c)(1)(iii):
Performance Matters
Reporting of Matters Related to Recipient Integrity and Performance (a)
General Reporting Requirement.

(1) If the total value of your active grants, cooperative agreements, and
procurement contracts from all Federal agencies exceeds $10,000,000 for
any period of time during the period of performance of this Federal award,
then you as the grantee must ensure the information available in the
responsibility/qualification records through the System for Award
Management (SAM.gov), about civil, criminal, or administrative proceedings
described in paragraph (b) of this award term is current and complete. This
is a statutory requirement under section 872 of Public Law 110-417, as
amended (41 U.S.C. 2313). As required by section 3010 of Public Law 111-
212, all information posted in responsibility/qualification records in
SAM.gov on or after April 15, 2011 (except past performance reviews
required for Federal procurement contracts) will be publicly available.

(b) Proceedings About Which You Must Report.

(1) You must submit the required information about each proceeding that—

(i) Is in connection with the award or performance of a grant, cooperative


agreement, or procurement contract from the Federal Government;

(ii) Reached its final disposition during the most recent five-year period; and

(iii) Is one of the following—

(A) A criminal proceeding that resulted in a conviction;

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(B) A civil proceeding that resulted in a finding of fault and liability and
payment of a monetary fine, penalty, reimbursement, restitution, or
damages of $5,000 or more;

(C) An administrative proceeding that resulted in a finding of fault and


liability and your payment of either a monetary fine or penalty of $5,000 or
more or reimbursement, restitution, or damages in excess of $100,000; or

(D) Any other criminal, civil, or administrative proceeding if—

(1) It could have led to an outcome described in paragraph (b)(1)(iii)(A)


through (C);

(2) It had a different disposition arrived at by consent or compromise with


an acknowledgment of fault on your part; and

(3) The requirement in this award term to disclose information about the
proceeding does not conflict with applicable laws and regulations.

(c) Reporting Procedures.

Enter the required information in SAM.gov for each proceeding described in


paragraph (b) of this award term. You do not need to submit the
information a second time under grants and cooperative agreements that
you received if you already provided the information in SAM.gov
because you were required to do so under Federal procurement contracts
that you were awarded.

(d) Reporting Frequency.

During any period of time when you are subject to the requirement in
paragraph (a) of this award term, you must report proceedings information
in SAM.gov for the most recent five-year period, either to report new
information about a proceeding that you have not reported previously or
affirm that there is no new information to report. If you have Federal
contract, grant, and cooperative agreement awards with a cumulative total
value greater than $10,000,000, you must disclose semiannually any
information about the criminal, civil, and administrative proceedings.

(e) Definitions.

For purposes of this award term—

Administrative proceeding means a non-judicial process that is adjudicatory


in nature to make a determination of fault or liability (for example,
Securities and Exchange Commission Administrative proceedings, Civilian

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Board of Contract Appeals proceedings, and Armed Services Board of
Contract Appeals proceedings). This includes proceedings at the Federal and
State level but only in connection with the performance of a Federal
contract or grant. It does not include audits, site visits, corrective plans, or
inspection of deliverables.

Conviction means a judgment or conviction of a criminal offense by any


court of competent jurisdiction, whether entered upon a verdict or a plea,
and includes a conviction entered upon a plea of nolo contendere.

Total value of currently active grants, cooperative agreements, and


procurement contracts includes the value of the Federal share already
received plus any anticipated Federal share under those awards (such as
continuation funding).
Lead-Based Paint If grant funds are used for purchase, lease, support services,
Requirements operation, or work that may disturb painted surfaces, of pre-1978
housing, you must comply with the lead-based paint evaluation and
hazard reduction requirements of HUD's lead- based paint rules (Lead
Disclosure; and Lead Safe Housing (24 CFR part 35)), and EPA's lead-
based paint rules (e.g., Repair, Renovation and Painting; Pre-
Renovation Education; and Lead Training and Certification (40 CFR
part 745)).
Fraud, Waste and Abuse Any person who becomes aware of the existence or apparent existence of
fraud, waste or abuse of any HUD award must report such incidents to both
the HUD official responsible for the award and to HUD’s Office of Inspector
General (OIG). HUD OIG is available to receive allegations of fraud, waste,
and abuse related to HUD programs via its hotline number (1-800-347-
3735) and its online hotline form. The Grantee must comply with 41 U.S.C. §
4712, which includes informing employees in writing of their rights and
remedies, in the predominant native language of the workforce. Under 41
U.S.C. § 4712, employees of a governmental contractor, grantee, and
subgrantee—as well as a personal services contractor—who make a
protected disclosure about a Federal grant or contract cannot be
discharged, demoted, or otherwise discriminated against as long as they
reasonably believe the information they disclose is evidence of:
1. Gross mismanagement of a Federal contract or grant;
2. Gross waste of Federal funds;
3. Abuse of authority relating to a Federal contract or grant;
4. Substantial and specific danger to public health and safety; or
5. Violations of law, rule, or regulation related to a Federal contract
(including the competition for or negotiation of a contract) or grant.

Federal Contractor or Grantee Protections | Office of Inspector General, Department of


Housing and Urban Development (hudoig.gov)

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3.3 Detailed Environmental Review Guidance for FY2024 CPF Grants

An environmental review is the process of reviewing a project and its potential environmental
impacts to determine whether it meets federal, state, and local environmental standards. The
environmental review process is required for all HUD-assisted projects to ensure that the proposed
project does not negatively impact the surrounding environment and that the property site itself will
not have an adverse environmental or health effect on end users.

This guidance seeks to clarify the environmental review requirements for the CPF Program for
expenditure of funds for planning, administration, management, operations, and maintenance
activities, as well as for development projects where construction contracts were entered into, or
construction was started prior to the date of legislative enactment (March 9, 2024) and/or
completion of a satisfactory environmental review.

3.3.1 Contacts and Project-Specific Assistance

For questions about the environmental review process, please contact your REO. While your CPF
Grant Officer can assist with programmatic questions, your REO can assist with environmental review
requirements for individual projects.

HUD will be providing trainings on environmental reviews and has an extensive body of existing
environmental review training and resources which can be found here:
https://www.hudexchange.info/programs/environmental-review/. HUD has also created a technical
assistance “Ask A Question” (AAQ) Desk for environmental review to support grantees in navigating
the environmental review requirements.

Included in Section 5 is a short guide for requesting support through the AAQ desk (see Attachment
4).

3.3.2 Legal Framework and Policy

Grant Agreement
The Grant Agreement is the legally binding document that outlines requirements and incorporates
assurances and certifications for your project. The Grant Agreement must be signed by HUD prior to
the grantee drawing down funds for reimbursement.

Environmental Review, Federal Nexus, and Choice-Limiting Actions


HUD or the RE will be required to complete an environmental review of ALL project activities and
work that took place or is proposed to take place following the date of enactment (March 9, 2024)
regardless of funding source. See HUD’s aggregation principles at 24 CFR 58.32 for more information
on project aggregation. A “Federal Nexus” is defined as the event that, by its occurrence, triggers the
requirements for federal environmental review under a host of laws, regulations, and Executive
Orders.

The date of legislative enactment is the Federal Nexus for the FY2024 CPF program. As such, the
date of enactment (Federal Nexus) for FY2024 CPF grants is March 9, 2024.

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After the Federal Nexus, you are prohibited from taking new choice-limiting actions related to hard
costs, including commitment or expenditure of HUD and non-HUD funds, until a satisfactory
environmental review has been completed for the aggregated project. HUD’s aggregation
requirements under 24 CFR 58.32 state that environmental reviews must group together and
evaluate as a single project all individual activities which are related either on a geographical or
functional basis or are logical parts of a composite of contemplated actions. More information on
HUD’s aggregation principles can be found at 24 CFR 58.32. A satisfactory environmental review
must include analysis of the applicable environmental laws and authorities, a determination that the
project activities will not result in environmental harm that cannot be mitigated, consultation with
federal/state agencies in a manner that allows for mitigation measures/conditions to be
implemented by the grantee, and a Request for Release of Funds and Certification (HUD-7015.15) for
the project that has been approved by the HUD CPD Field Office Director, if required. Most soft costs
are covered by HUD’s nationwide environmental review for CPF soft costs and can be incurred any
time after the date of legislative enactment (Federal Nexus) on March 9, 2024, and can be drawn
down for reimbursement after the Grant Agreement for the project has been executed.

A choice limiting action is any activity that a grantee undertakes, including committing or expending
HUD or non-HUD funds, that reduces or eliminates a grantee’s opportunity to choose project
alternatives that would avoid or minimize environmental impacts or enhance the quality of the
human environment.

Examples of choice limiting actions include acquisition, leasing, rehabilitation, demolition, new
construction, and ground disturbance work such as clearing, grading or grubbing. HUD’s prohibition
on choice limiting actions at 24 CFR 58.22 is derived from the regulations of the Council on
Environmental Quality implementing the National Environmental Policy Act of 1969 (NEPA), which
state that (with certain exceptions), “until an agency issues a finding of no significant impact, as
provided in § 1501.6 of this chapter, or record of decision, as provided in § 1505.2 of this chapter, no
action concerning the proposal may be taken that would: (1) Have an adverse environmental impact;
or (2) Limit the choice of reasonable alternatives.” 40 CFR § 1506.1.

In addition, the related environmental laws and authorities with which HUD must comply contain
their own procedural requirements which have the effect of limiting actions that may be taken before
approval of the environmental review. For example, under the National Historic Preservation Act of
1966 regulations (54 U.S.C. 300101, et seq.; 36 CFR Part 800; see 24 CFR § 50.4(a)(1)), in the early
stages of project planning, the agency official must determine whether the proposed federal action is
an undertaking as defined by the regulations. The agency must then determine whether it is a type of
activity that has the potential to cause effects on historic properties, and if so, seek ways to avoid,
minimize or mitigate any adverse effects on the property. Similarly, under Section 7 of the
Endangered Species Act (16 U.S.C. 1536), the agency must ensure that any action it authorizes,
funds, or carries out is not likely to jeopardize the continued existence of a listed species in the wild
or destroy or adversely modify critical habitat.

Taking new choice-limiting actions is prohibited after the date of enactment (March 9, 2024) until
the environmental review process is complete. In addition, HUD will not be able to fund a project
where work that occurred after the date of enactment (March 9, 2024) has resulted in

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environmental harm or where environmental compliance with one or more of the laws and
authorities cannot be achieved.

Programmatic Environmental Review for Planning, Administration, Operations and Maintenance


HUD has completed a nationwide Part 50 nationwide environmental review covering most CPF soft
costs for planning, administration, operations, and maintenance activities under the CPF program.
Grantees can incur covered soft costs any time after the date of enactment (March 9, 2024) and
following execution of the Grant Agreement, grantees may draw down funds for eligible planning,
administration, operations and costs categorized as maintenance activities under CPD Notice 16-02:
Guidance for Categorizing an Activity for Maintenance. See below for a list of soft costs which are
covered and not covered by HUD’s nationwide review for CPF soft costs.

art a on i e or F o osts
o ere o ere
Environmental and other studies, resource Purchase of tools. 50.19(b)(7)
iden ca on, development of plans and strategies. Emergency assistance necessary to control or arrest
50.19(b)(1) the e ects from disasters or imminent threats to
Informa on and nancial advisory services. 50.19(b)(2) public safety. 50.19(b)(10)
Administra ve and management expenses. 50.19(b)(3) Tenant based rental assistance. 50.19(b)(11)
Public services. 50.19(b)(4) Economic development ac vi es. 50.19(b)(14)
Inspec ons and tes ng of proper es for hazards or Homebuyer Assistance. 50.19(b)(15)
defects. 50.19(b)(5) A ordable housing pre development costs
Purchase of insurance 50.19(b)(6) 50.19(b)(16)
Engineering or design costs. 50.19(b)(8) Approval of supplemental assistance 58.35(b)(7)
Technical assistance and training. 50.19(b)(9)
Suppor ve services. 50.19(b)(12)
Opera ng costs including most maintenance
50.19(b)(13)
Purchase of vehicles, but not other equipment.

Work Under Contract


You can proceed with work covered by contracts that predate the date of enactment (identified by
HUD as the Federal Nexus triggering federal environmental and historic preservation laws and
regulations) at your own risk.

If your organization is under a legally binding construction contract prior to the date of enactment
(March 9, 2024), work funded by non-federal funds may proceed to the extent practical and to the
extent permitted in accordance with the previously executed contract. After the date of enactment
(March 9, 2024), grantees may not enter into additional construction contracts or take other new
choice limiting commitments or actions, including making a commitment of HUD or non-HUD funds
to the project, until an satisfactory environmental review by a RE under 24 CFR Part 58 is completed
and a Request for Release of Funds and Certification (HUD-7015.15) is approved by the HUD CPD Field
Office Director via certification of the Authority to Use Grant Funds (HUD-7015.16) in HEROS, if
applicable; or an environmental review by HUD under 24 CFR Part 50 is completed.

Hard Costs
HUD or the RE is required to complete a satisfactory environmental review of ALL work that took
place or is proposed to take place following the date of enactment (March 9, 2024). Grantees can

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undertake project activities covered by contracts that were entered into prior to the date of
enactment and can incur reimbursable hard costs related to construction and ground-breaking
activities occurring any time after the date of enactment (March 9, 2024), but do so at their own risk.
If work that has taken place after the date of enactment (March 9, 2024) causes unmitigable
environmental harm, is prohibited under environmental laws or HUD’s environmental regulations
(e.g., damaging endangered species habitat, impacting a structure eligible for listing on the National
Register of Historic Places, or work within a regulatory floodway), or precludes completion of federal
consultation requirements, those project activities cannot be funded.

If a project is unable to satisfactorily complete an environmental review, HUD can potentially fund
other project activities that do not require aggregation with the work started after the date of
enactment, such as operations and maintenance or program services. Contact your CPF Grant Officer
to discuss additional project activities that may be able to be funded on an as needed basis.

Grant funds can be drawn down for reimbursement of eligible costs covered by a satisfactory
environmental review after execution of the Grant Agreement for the project.

3.3.3 CPF Environmental Review Scenarios

The below scenarios offer consideration of some common scenarios received from grantees to date
about the status of their projects and next steps.

In order for CGD and the Office of Environment and Energy (OEE) to best assist you in determining
your next steps, you should submit your project narrative and budget to your CGD Grant Officer.
This will enable HUD to:

1) initiate the Grant Agreement, and

2) work with grantees to determine the level of environmental review necessary for the
project.

1. Can I use my planning and administration funds prior to completion of my environmental


review?

• Prior to the completion of the aggregated environmental review for the project, grantees
can incur reimbursable soft costs covered by HUD’s nationwide environmental review for
CPF soft costs, any time after the date of enactment (March 9, 2024).
• A list of covered CPF soft costs can be found below and in HUD’s Part 50 Programmatic
Environmental Review for CPF Soft Costs and such costs can be drawn down for
reimbursement after execution of the Grant Agreement.

2. Can I use my planning and administration funds to cover the costs to complete an
environmental review?

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• Yes. The costs to complete an environmental review are eligible under the planning,
administration, management, and maintenance activities covered by HUD’s programmatic
environmental review discussed in Scenario 1 above.
• Grantees may also use CPF grant funds to compensate a local government responsible
entity for the cost of preparing the environmental review for their project.
• Again, grantees may incur covered soft costs any time after the date of enactment (March
9, 2024) but can only request payment for those costs after the Grant Agreement has
been fully executed.

3. Who will conduct the environmental review for my project?

• You must reach out to the Unit of General Local Government (UGLG) in which the project is
located and that has some level of land use responsibility, to request that they serve as the
Responsible Entity (RE) and conduct the ER for your project. This can be the local municipality,
county, or state in which the project is located in. If your local government refuses to serve as
RE and conduct the ER, please reach out to your Regional Environmental Officer for next
steps.

4. Who is responsible for implementing mitigation measures required by the environmental


review?

• Grantees are responsible for tracking and implementing any mitigation measures required by
the environmental review. Please work with your local government responsible entity and
Regional Environmental Officer if you have any questions about your responsibilities
associated with carrying out mitigation requirements.

5. I was awarded a grant that is for a 100% planning activity. Do I have to complete an
environmental review?

• Based on your project narrative, your Grant Officer will confirm that your project is for
planning only activities.
• As mentioned above, HUD has completed a programmatic environmental review for all
planning activities and most other soft costs within the CPF portfolio.
• Thus, if you have a planning only grant, you do not have to conduct a new environmental
review because the review has already been completed by HUD. You must have a fully
executed Grant Agreement to draw down HUD funds for reimbursement of eligible
activities.

6. I completed my project before receiving a signed grant agreement from HUD. Can I be
reimbursed?

• Some activities may be reimbursable depending on their timing and nature.


• Soft costs covered by HUD’s nationwide environmental review for CPF soft costs that were
incurred after the date of enactment (March 9, 2024) can be reimbursed after the
execution of the Grant Agreement.

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• Eligible hard costs incurred after the date of enactment (March 9, 2024) and the
completion of a satisfactory environmental review are reimbursable after the execution of
the Grant Agreement. See Federal Nexus and Choice-Limiting Actions section above for
more information on HUD’s project aggregation principles and what is included in a
satisfactory environmental review process.
• For activities that fall outside of the scope of eligibility for reimbursement, HUD may be
able to fund a related activity associated with the completed project. HUD’s CPF Grant
Officers will work with you to determine if there are other elements of the CPF-referenced
project that can be funded in keeping with the intent of Congress.

7. I have started construction on my project with non-HUD funds, but plan to use HUD funds for a
portion of my project:

a. Do I have to stop work on the project if the work was under contract prior to the date of
enactment (March 9, 2024)?

• HUD is not directing grantees to stop construction work in instances where a


construction contract was entered into prior to the date of enactment (March 9,
2024). In such cases, work funded by non-federal funds may proceed to the extent
practical, and to the extent permitted in accordance with the previously executed
contract. Grantees may not enter into additional construction contracts or make other
choice-limiting commitments or actions, including commitments of HUD or additional
non-HUD funds to the project after the date of enactment (March 9, 2024) without the
completion of a satisfactory environmental review covering the aggregated scope of
the project. An environmental review must be completed before HUD funds and new
commitments of non-HUD funds can be used on a project.
• However, HUD does recommend that grantees stop work after the date of enactment
(March 9, 2024), as a best practice. If any work conducted results in environmental
harm that cannot be mitigated (e.g., damaging endangered species habitat, impacting
a structure eligible for listing on the National Register of Historic Places), or precludes
completion of federal consultation requirements, those project activities may not be
able to be funded. For these reasons, continuing with work has risk of ineligibility for
funding.

b. Do I ha e to stop ork on a project i there isn’t a contract in place?

• If you are using your own workforce to do the work and can stop work – i.e., there is
no preexisting legal obligation with another party to continue the construction
activities – you must pause construction until the environmental review is completed.

c. How is the environmental review conducted when the project is underway under an
existing contract?

• As of the date of enactment on March 9, 2024, federal compliance requirements apply


to the project and HUD funds cannot be expended on work that results in

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environmental harm that cannot be mitigated. A satisfactory environmental review is
necessary to determine the environmental impacts of the project.
• Existing contracts or commitments entered into and completed prior to the date of
enactment (March 9, 2024) cannot be reimbursed and do not need to be included in
the satisfactory environmental review.
• Contracts or commitments that were entered into prior to enactment, but consist of
work that will continue after enactment, may proceed at their own risk, as a
satisfactory environmental review is required for all activities taking place after receipt
of the date of enactment (March 9, 2024).
• Analysis with the environmental laws and authorities must be conducted and
determine that there hasn’t been environmental harm that cannot be mitigated, and
that consultation with federal/state agencies is conducted in a manner that allows for
mitigation measures/conditions to be implemented.

Note: If a satisfactory environmental review cannot be completed for any reason, work with your
Grant Officer and REO to determine next steps.

8. I have a completed HUD environmental review, but I do not have an executed Grant
Agreement. Can I start using HUD funds?

• Soft costs covered by HUD’s nationwide environmental review for CPF soft costs can be
incurred any time after the date of enactment (March 9, 2024) and can be drawn down for
reimbursement after the execution of the Grant Agreement.
• Eligible hard costs can be incurred after the date of enactment (March 9, 2024) and can be
drawn down for reimbursement after the execution of the Grant Agreement and the
completion of a satisfactory environmental review for the aggregated project.

Figure 1: FY2024 CPF Payment Request Process Flow

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3.3.4 Resources

Applicable Appropriations Act:


FY24 Consolidated Appropriations Act
FY24 Further Consolidated Appropriations Act

CPF Resources:
HUD.gov EDI-CPF Landing Page
HUD Exchange CPF Landing Page
CPF Grant Officer Portfolio Assignments

FY2024 CPF Specific Resources:


HUD.gov CPF FY24 Webpage
HUD Exchange CPF FY24 Webpage
CPF FY24 Cost Eligibility Chart

CPF Environmental Review Resources:


HUD Environmental Contacts
Guidance for Documenting the Environmental Review Record for CPF Grants
Request for Release of Funds (RROF) Point-of-Contact for CPF Grants
Ask A Question (AAQ) Help Desk for CPF
Sample MOA between a Responsible Entity and CPF Non-profit Grantee

24 CFR Part 58: Procedures for Entities Assuming HUD Environmental Responsibilities

HEROS - HUD Environmental Review Online System


Environmental Review Training

HUD's Nationwide Part 50 Programmatic Environmental Review for CPF Soft Costs:
FY24 Part 50 CPF-Soft-Costs-Nationwide-Programmatic ERR

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Hard Costs
Soft Costs

Incurred before Incurred after Incurred before Incurred after


March 9, 2024 March 9, 2024 March 9, 2024 March 9, 2024

Incurred after ER Incurred before ER


Not Eligible Eligible Not Eligible
process completed process completed

NOTE: This chart assumes that eligible costs are for activities covered by Contractual
Contract executed
the project scope of a satisfactory environmental review. See FY24 CPF ER obligation in place
Eligible after March 9,
Guidance for more details. before March 9,
2024
2024
Costs are incurred at the point the service is performed (not when the
contract is signed or when the customer is billed).
For a complete list of covered soft costs see FY24 Part 50 CPF-Soft-Costs-
Nationwide-Programmatic ERR
Physical work
Supporting Docs: conducted after Not Eligible
- Date ER Process Completed March 9, 2024
- Executed Work Contract(s)
- Grantee Accounting Records

Eligible
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3.4 Build America, Buy America (BABA) Act Guidance for FY2024 CPF Grants

The Build America, Buy America Act (BABA) was enacted as part of the Infrastructure Investment and
Jobs Act (IIJA) on November 15, 2021. BABA established the Buy America Preference (BAP), which
requires that Federally funded infrastructure projects use domestically produced materials.

The obligation date for all FY 2024 CPF grants is August 13, 2024, which means that the BAP applies to
all iron and steel products used in the construction, alteration, maintenance, or repair of
infrastructure projects funded through FY 2024 CPF grants, unless a HUD general or project waiver
applies. Under HUD’s Phased Implementation Waiver, construction materials and manufactured
products are not subject to the BAP for FY 2024 CPF grants.

For assistance determining material classifications, BAP applicability to specific projects, and how to
maximize waiver flexibility, grantees should review CPD’s BABA implementation notice, which is
available on the BABA HUDExchange page.

In addition to the implementation notice, the following technical assistance resources are available:
• Beyond the Basics: Implementing the BAP Webinar
• CPF BABA Quick Guide
• CPF BABA Webinar
• BABA Frequently Asked Questions

For specific questions that are not answered by the materials provided above, grantees should submit
a question via the HUDExchange Ask A Question feature.

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SECTION 4: CONTACT INFORMATION FOR GRANT OFFICERS, SYSTEM OFFICERS, AND REGIONAL
ENVIRONMENTAL OFFICERS

Below is a link to the CPF Grants: Grant Officer Portfolio Assignments, System Officer Portfolio
Assignments, and REO contact information for your state.

https://www.hud.gov/sites/dfiles/CPD/documents/Community-Project-Funding-Portfolio-
Assignments.pdf

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SECTION 5: ATTACHMENTS

Attachment 1: Grant Agreement Submission Checklist


Attachment 2: Direct Deposit Sign-Up Form (SF-1199A)
Attachment 3: Change of Address Request (HUD-27056) Form
Attachment 4: Ask-A-Question (AAQ): Technical Assistance Guide
Attachment 5: CPF Frequently Asked Questions (FAQs)
Attachment 6: Sample Narrative Outline and Example
Attachment 7: Sample Budget

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Attachment 1: Grant Agreement Submission Checklist

To assist you with completing the required materials, please make sure that you have completed the
following:

 You have an active SAM.gov registration. Expired UEIs and “ID Assigned” are not acceptable.
 The project narrative describes the ENTIRE project and indicates the specific activities that will
be financed with CPF grant funds.
 The project budget is consistent with the requirements of the applicable appropriations act(s)
and cost principles in 2 CFR part 200.
 Indirect Cost Rate

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Attachment 2: Direct Deposit Sign-Up Form (SF-1199A)

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Attachment 3: Change of Address Request (HUD-27056) Form

If your official address changes, please complete this form and email to your Grant Officer for
processing. NOTE: This form is not required for changes in your project address if that address
differs from your official address. However, you must email your Grant Officer if your project address
changes.

https://www.hud.gov/sites/documents/27056.PDF

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Attachment 4: Ask-A-Question (AAQ): Technical Assistance Guide

The Ask-A-Question tool on HUD Exchange has been expanded to provide technical assistance for CPF
grantees. You can access the website by going to https://www.hudexchange.info/program-
support/my-question/ where you can submit a question.

The first step in submitting a question is to fill in the Personal Information fields. All the fields are
required.

Once you have entered your personal information, please select I am a “HUD Grantee.” If your
organization or community is listed, please select the correct grantee name.

If you do not find your entity’s name, select “Other – Please Specify” in the I am a field, and you will
be able to provide the entity name in the “Other” field.

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Once you have identified yourself, select the button for Step 2.

You will be taken to Step 2 of 2 after a prompt to review your personal information. Please select
“CPF: Community Project Funding” in the My question is related to field. Then add a subject line,
enter your question, and upload any applicable documents. Include your grant number, if possible.
Submit your question.

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Attachment 5: CPF Frequently Asked Questions (FAQs)

Below is a link to the CPF FAQs.

https://www.hudexchange.info/resource/6777/cpf-faqs/

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Attachment 6: Sample Narrative Outline and Example
The outline below can be adapted for your project narrative. This is not a required format but may be
useful to consider. Having section headers and subsection headers is useful.

1. Project Description
a. Project Name: It must match the Amended CPF Grants Table
b. Project Address(es) and Location: Include specific the project address(es) Including GPS
coordinates or service area.
c. Project Purpose: Provide a sentence that summarizes what the project will
accomplish.
d. Project Narrative:
i. Provide a summary of the entire project which restates its purpose, identifies
activity categories and specifies uses of the CPF grant as part of or for the entire
project.
ii. If part of a larger project, provide a description of the broader project.
iii. This narrative section should describe all actions that will be undertaken as part of
the project, regardless of funding source. The content typically comprises the bulk
of the written narrative.

2. Project Metrics
a. Goals, Outcomes, Objective: The project must have clearly stated goals, outcomes, and
objectives. State each.
b. Section 3 Performance Measures: Refer to the HUD Exchange Section 3 website pages
for additional information.
c. BABA Metrics: Refer to the “BABA for CPF Quick Guide” on the HUD Exchange CPF
Website.

1. Project Timeline & Project Status


a. Current status: understanding the current project status is critical. Provide a succinct
explanation of where the project is in its lifespan from concept to execution to
completion. Consider these questions in your written statements:
• What is the status of the project?
• Is the project still in the “ideas” phase with no contracts or agreements
executed?
• Has procurement started?
• Is construction or program implementation underway?
• Is the project complete?
b. Proposed Timeline: Provide an estimated start and end date for the project along with
key benchmarks with dates for the project.
c. Environmental Review Status: Consider the following:
• Adhering to the environmental review requirements in the National Environmental
Policy Act (NEPA) is critical.
• Describe what steps have been taken toward environmental clearance and the
current status. This could range from having completed no steps toward

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environmental clearance all the way through completion of an environmental
assessment.

3. Project Scope: See below for ideas for including in your written project scope.

4. Subrecipients:
1. Some grantees will want to use one or more subrecipients to execute their project. If
you plan to use subrecipients, a written justification should be provided for why the
project is best implemented using subrecipients.
1. Describe the role of each of the subrecipients and add the subrecipient’s EIN or UEI
number.
a. Describe the scope of the project that will be handled by each subrecipient and what
tasks/functions will be kept with the CPF grantee.

Example: Public Facility – Emergency Food Network Warehouse

Project Name
Emergency Food Network of Alpha and Beta County (B-24-CP-TX-0394)

Project Purpose
EFN will build a warehouse, including but not limited to, providing the staffing and all
relevant soft costs needed to make the warehouse operational.

Project Scope
The CPF grant will be used to help fund the soft costs associated with building and operating
a new warehouse, including but not limited to, providing the staffing and all relevant soft
costs needed to make the warehouse operational. Specify, all funding awarded from the CPF
grant will be used for soft costs associated with building the warehouse.

These soft costs include:


• Architecture and Engineering
• Owner’s Representation Consultation
• Two FTE’s: 75% of hourly rate, 403b, and insurance expenses for three years
• Deputy Director: 50% of salary, 403b, insurance, and benefits expenses for three years
• Security: 80% of security expense for three years
• Insurance of future warehouse
• Potential NEPA review consultant
• Racking, forklifts, breakroom furnishings, office furniture, window coverings, technology
(computers, printers, etc.), long range walkie talkies, lockers, washer/dryer, industrial
warehouse cleaner, floor buffer, impact donor panel, transportation carts and tools,
portable conveyors

EFN is not engaged in lobbying activities.

Yes, the CPF funded project is part of a larger project.

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EFN is building a new 21,500- square-foot warehouse on our Lakewood campus. It will serve
as our primary storage space for food. Our existing warehouse will then maintain a 30-day
supply of food and serve as a more efficient order-building space for distribution.

Yes, the project has already started. We have completed a feasibility study, established a
relationship with a design firm, and hired a project manager to guide us through the process.
EFN has done extensive outreach to elected officials, foundations, and community members
to gather support for this project. Currently, EFN has raised $7,175,000. Below are
additional updates to the current state of the project:

• SEPA Determination of Non-Significance was issued February 9, 2023. There


were no appeals. This permit application is now finalized.
• Design Review application review to be completed, and issued, March 1,
2023. The planning division has a few steps to complete after a design review
has been issued.

EFN will not be using a subrecipient to implement any part of the project.

Overview of Project and Anticipated Outcomes


EFN has been operating above the capacity of our current space to meet the needs of the
community. To maintain our current operating level of over 1 million pounds of food
distributed each month, we currently use our primary 17,000-square-foot warehouse for
storage and order building, along with our 3,200-square-foot vertical storage space, rented
and owned trailers onsite for storage, and rented offsite storage space. All these measures
made it possible for us to meet the 40% increase in demand that occurred during the first
months of the COVID-19 pandemic. These measures also allow us to continue operating
through increased community need this year, as we saw nearly double the number of clients’
visits this October compared to last.

To be prepared to meet changing community needs in the future, however, we need more
sustainable, efficient, and permanent solutions. The new warehouse space created by the
Building Campaign provides these solutions. The campaign will build an additional 21,500-
square-foot warehouse space on our Lakewood campus, and it will serve as our primary
storage space for food. Our existing warehouse will then maintain a 30-day supply of food
and serve as a more efficient order-building space for distribution. We have already
completed a feasibility study, established a close relationship with a design firm, hired a
project manager to guide us through the process, and identified additional staffing and
security that will be required for the warehouse to be operational. We are currently
reviewing bids from contractors and navigating the permitting process. We plan to break
ground in spring of 2023 on the project; project completion will occur by year’s end.

By centralizing our inventory onto our Lakewood campus, the Building Campaign will
transform our daily operations. Our team’s twice-monthly inventory will become vastly more
efficient and accurate, saving us transportation costs and countless work hours to move and
monitor the product across locations. Increased inventory efficiency and accuracy ultimately

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mean better meeting the needs of our Partner Programs, providing them with the food they
ask for more often. Additionally, if a natural disaster occurred with our current storage
arrangements, we would risk being cut off from our food supply and being less able to feed
our neighbors during a disaster. The 40% increase in storage space will also enable us to have
more food on hand. During our feasibility study, we identified that we would need two FTE’s,
security, and additional leadership on EFN’s Executive Team to manage the 40% increase in
space. All these improvements will allow EFN to continue serving our community effectively,
on a day-to-today basis and in the event of a disaster.

The Building Campaign will not just improve our operations in the short term, but it will
position us for success in a changing food landscape for decades to come. Leaders in the
hunger relief sector predict a shift in the types of foods in the emergency food system,
moving away from nonperishables and towards fresh foods, specially produce. Our new
warehouse is specifically designed with the ability to be retrofitted for additional cooler and
freezer space, so that we will not need another capital project when the food landscape
shifts. In the meantime, the new warehouse will provide additional storage space for
nonperishable food. The pandemic taught us that flexibility is key to successfully navigating
changing food streams, and the Building for the Future campaign will give us the necessary
flexibility in the short- and long-term to feed our neighbors in need.

Attachment 7: Sample Budget

The sample below can be adapted for your project budget. This is not a required format but may be
useful to consider. All CPF grantees are required to submit a line-item budget. As defined by 2 CFR
200.1, “budget” means the financial plan for the Federal award. It is an estimate of the money
required to take a project from initiation to completion. The line-item budget should: show expenses
for the entire project, both those being paid for by the CPF award as well as any other
sources; identify separately those costs that will be paid by the CPF award and those that will be paid
by another source; and be consistent with the Amended CPF Grants Table and the project
narrative. The total CPF amount in the budget must equal the amount of the CPF award.

Sample Budget: Construction Projects

COST CLASSIFICATION CPF Funds Non-CPF Funds Total


1. Administrative and legal expenses
2. Land, structures, rights-of-way, appraisals, etc.
3. Relocation expenses and payments
4. Architectural and engineering fees
5. Other architectural and engineering fees
6. Project inspection fees
7. Site work
8. Demolition and removal
9. Construction
10. Equipment
11. Contingencies
12. SUBTOTAL

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13. Project (Program) Income
14. TOTAL PROJECT COSTS (subtract line 13 from 12)

Sample Budget: Non-Construction Projects

COST CLASSIFICATION CPF Funds Non-CPF Funds Total


1. Personnel
2. Fringe Benefits
3. Travel
4. Equipment
5. Supplies
6. Contractual
7. SUBTOTAL Direct Charges (sum of lines 1-6)
8. Indirect Charges
9. TOTAL PROJECT COSTS (sum of line 7 and 8)
10. Project (program) income
11. TOTAL PROJECT COSTS (subtract #10 from #9)

PAPERWORK REDUCTION ACT

Economic Development, Community Project Funding/Congressionally Directed Spending


U.S. Department of Housing and Urban Development
OMB Approval No 2506-0217

Public Reporting Burden for this collection of information is estimated to average 2 hours per
response, including the time for reviewing instructions, searching existing data sources, gathering,
and maintaining the data needed, and completing and reviewing the collection of
information. Response to this collection of information is mandatory to obtain a benefit. The
information requested does not lend itself to confidentiality. HUD may not conduct or sponsor,
and an applicant is not required to respond to a collection of information unless it displays a
currently valid OMB control number.

Section 5 / Version 1 / August 19, 2024 77

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