CDBG-D Regulations: Ramp Up

1. CDBG-D Regulations: Ramp Up Presented by: Celia Ringle Samantha Spergel

2. CDBG-D Basics This program is designed to allocate a portion of IHCDA’s remaining Community Development Block Grant Disaster (CDBG-D) funds reserved for owner-occupied rehabilitation activities to selected applicants that meet the requirements and goals of the program as defined within the policy. Eligible Applicants: 501(c)3 & 501(c)4’s Projects must meet a national objective and be an eligible activity

3. Eligible County Due to CDBG-D limitations, funds will be available for 82 of 92 counties in Indiana. The following 10 counties are ineligible (non-negotiable): Blackford Clinton Delaware Howard Lagrange Miami Steuben Tipton Warren Wells

4. National Objective The HUD Act requires that CDBG-funded activities meet one of the following three national objectives: • Benefit low and moderate income (LMI) persons = Ramp Up • Aid in the prevention or elimination of slums and blight (SB) • Meet urgent community development needs (UN) that the unit of local government is not able to fund either on its own or through other sources

5. Eligible Activities Every project that receives CDBG funds must meet a National Objective and it must also be an Eligible Activity. Eligible activities: • Public facilities improvements • Public services • Infrastructure improvements • Historic preservation • Handicap accessibility projects = Ramp Up

6. Citizen participation and public hearings requirements

7. Citizen Participation Citizen participation is a critical and required component of all CDBG and CDBG-D funded projects. This is important because it provides local residents – especially LMI citizens of the community where the funds will be used – an opportunity to participate in the planning, implementation, and assessment of the program.

8. Public Hearings Grantees are required to conduct at least two (2) public hearings, each at a different stage of the process, to obtain citizens’ input and questions about the program. The first hearing must be held prior to submission of the application to IHCDA. The second hearing must be held at the end of project completion, prior to closeout.

9. Public Hearing- Legal Notice Grantees must publish a legal notice at least 10 days prior to each hearing. Grantees must publish in a newspaper of general circulation in each county the Grantee intends to use the funds. • Only one hearing is required but must be in a reasonable location where all intended beneficiaries can easily access. • If the Grantee is targeting several counties over a large area, the Grantee may want to have more than one hearing to reach the widest audience possible. A sample notice can be found in Chapter 1 Exhibit C of the HOME and CDBG Program Manual.

10. Public Hearing- Content The public hearing should cover the following information: • Goals and objectives of the Ramp Up program. • Total amount of Ramp Up funds to be requested. • How Ramp Up could benefit the community. • Amount and source of local funds to be expended on the project.

11. Public Hearing-Documentation Original Affidavit of Publication for each legal advertisement or the original tear sheet of the publication • Includes the date of public hearing • Includes the date of notice Copy of the sign-in sheet Copy of the minutes of the public hearing, which must include the date and time of meeting, name and title of the person running the meeting, and all content posed to the public Describe methods used to advertise and solicit participation of LMI persons Provide any comments/complaints received and how they were addressed

12. Environmental review

13. Environmental Review- Phase I Upon turning in an application, the Grantee must provide the Phase I Environmental Review. The Ramp Up program falls under the ER category of Categorically Excluded, Subject to 58.5. Phase I documentation for this category includes Exhibits A, B, E, F, Findings, and Signature Pages. See page 11 of the ER Process found in Chapter 11 Exhibits of the HOME and CDBG Program Manual. • Please note that IHCDA requires a hardcopy of the ER with original signatures upon application.

14. Environmental Review & Release of Funds Upon being awarded, IHCDA will issue the Grantee a “proceed to publish” letter. This authorizes the Grantee to publish the FONSI (Finding of No Significant Impact) notice in the newspapers of the areas the Grantee will be working. • a sample FONSI notice may be found in the Chapter 11 Exhibits: ER Process of the HOME and CDBG Program Manual. In order for a Grantee to receive Release of Funds (ROF), they must provide the publication affidavit and tear sheet of such publication. Only after the Grantee is awarded ROF, can they begin drawing their administrative funds and incurring costs. • This is when the Grantee may begin sending in their ER Phase II: site specific exhibit G forms.

15. Environmental Review- Phase II site specific The Grantee must provide Exhibit G forms for each address. • This review can take up to 30 days, so plan accordingly. Only after IHCDA has issued a Phase II concurrence letter to the Grantee, may work on that specific address begin. • No contracts may be signed until this letter is received. Exhibit G forms may be submitted to the IHCDA RED Coordinator on a rolling basis For questions about the site specific ER, contact Clethig@ihcda.in.gov.

16. Procurement

17. Procurement The goal of the procurement regulation is to ensure open and free competition for federally assisted projects. Two (2) methods of procurement apply to the Ramp Up program: • Competitive Sealed Bid – Construction contracts • Small Purchase – Purchasing supplies and materials under $25,000

18. Competitive Sealed Bid This applies only when the Grantee hires a contractor to build the ramp and intends to pay for the contractor’s services out of the Ramp Up grant funds. Bid process and documentation: • Bid publication and bid packet • Must solicit at least 2 MBE/WBE businesses • Bid opening and contractor selection • Must receive 2 bid responses • Contractor verification The complete Sealed Bid process can be found in Chapter 10 Section G of the HOME and CDBG Program Manual.

19. Small Purchase If the Grantee uses Competitive Sealed Bid, the Grantee will not have to do Small Purchase for materials. If the Grantee uses volunteer labor instead of a contractor, the Grantee will use Small Purchase to procure materials Small Purchase process: • May purchase on the open market or invite quotes • At least 2 quotes must be received • Invoices must be submitted for reimbursement by address.

20. Match

21. Required Match The leverage (match) requirement for the Ramp Up program is ten percent (10%) of the total amount of CDBG-D funds drawn minus administration costs. Types of common leverage: • In-kind donation: • Donated or voluntary unskilled labor (valued at $10 per hour) • Skilled volunteer labor valued at reasonable price of service (documentation needed) • Donated construction materials • Other governmental grants from HUD or USDA Rural Development

22. Insurance

23. Insurance Grantee will be required to provide proof of adequate builder’s risk insurance during construction and property insurance following construction for the assisted property. Required policy period for Ramp Up: Builders risk, contractor liability and/or property insurance that includes coverage for work done by contractors. • The coverage must be for the replacement value of the ramp. • Policy must name IHCDA as loss-payee and an additionally insured. • Please see Chapter 10 of the HOME and CDBG Program Manual, P.95 -96 for more information

24. Income verification

25. Income Verification Each homeowner must be income qualified under the HUD published CDBG income limits in order to meet CDBG National Objective. Federal Program income and rent limits can be found here: • Note that HUD updates these annually (around June) so make sure your application reflects most current published limits Each homeowner’s income must be at or below 80% of area median income (AMI) for the county. Documentation required: • Income questionnaire – complete when application is submitted by homeowner • Tenant Income Certification Form – complete at the time of income verification • 3rd party verification document for all asset and income Verification document is valid for 6 months. If more than 6 months lapse, the household income must be re-verified.

26. Income Verification – Income When calculating homeowner’s income, grantee must project the homeowner’s anticipated income over the next 12 months Include income from all adult members of the household and unearned income from children Types of income to be included: • Wages, Salaries, Compensations • Social Security, Insurance Policies, Retirement Funds, Pensions • Alimony, Child Support Payments • Regular Contributions received Types of income not to be included: • Food Stamps • Section 8 Assistance

27. Income Verification - Asset Include all members of the household regardless of age Types of assets to be included: • Savings, Checkings, etc. • 401K, IRA, etc. • Retirement Accounts • Whole Life Insurance • Real Estate Types of assets not to be included: • Necessary personal property (furniture, vehicles, etc.) • Term Life Insurance • Assets not accessible to the homeowner

28. Thank You! For application questions, contact Real Estate Analyst, Dani Miller at dmiller@ihcda.in.gov or 317-233-3895 For compliance questions, contact Real Estate Compliance Auditor, Celia Ringle at cwangringle@ihcda.in.gov or 317-234-2305