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Learn about the changes in the Indian Community Development Block Grant (ICDBG) program for Fiscal Year 2014, including new funding categories, LMI measurement methods, and points for past spending and shovel-ready projects. Discover how to submit applications and find help for mold remediation projects.
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Fiscal Year 2014Indian Community Development Block Grant (ICDBG) Program NOFA TrainingPart 1
What’s New in 2014 • Two categories of funding • New way to slice the pie • New ways to determine LMI • Points for spending past funds • Points for shovel-ready projects • Points if not funded in the recent years
Today’s Agenda • Part 1 - “Regular” ICDBG grants • Part 2 - New funds for mold remediation and prevention
Today’s Agenda (cont) • Part 1 • Purpose and overview of ICDBG • Eligible applicants, uses, and requirements • How to submit applications • Screening and rating factors
Today’s Agenda (cont) • Part 2 • Criteria in NOFA – definitions, rating factors, scoring • Overview of mold health effects, assessment and remediation • Where to find help
Two Categories • Can apply for and receive both • Can use both categories for same project or different types of projects
Available Funds • Total is $70,000,000 • Single Purpose Grants - $56,219,222 • Imminent Threat - $3,960,000 • Mold Remediation - $10,000,000
Authority • Title I of the Housing & Community Development Act of 1974 (42 U.S.C. 5301 et seq) • ICDBG regulations, 24 CFR part 1003
Program Description To develop viable Indian and Alaska Native communities by creating decent housing, suitable living environments & economic opportunities primarily for LMI persons
Types of Grants • Imminent Threat Grants • Single Purpose Grants (including grants for mold remediation and prevention)
Imminent Threat Grants • No Area Office allocations • Funds used to remove imminent threats to health or safety • Must meet regulatory criteria
Imminent Threat Grants • Criteria for funding • Threat must be independently verified • Must not be recurring • Must impact entire service area • Only granted if other tribal or federal funds not available
Imminent Threat Grants • Application • Area ONAP will issue Letter to Proceed only if no environmental impact and for improvements to control or arrest threat • Reimbursement only if HUD approves application • Applications must include information in NOFA
Imminent Threat Examples • Asbestos removal • Replacement of failed water system • Home repairs from floods • Mold remediation • Uranium in wells
New Definitions • Mold Remediation and Prevention • Mold is visible growth of fungi on surfaces • Remediation includes long term solutions • Prevention means action taken if mold is present in minute amounts to prevent more
New Definitions • Tribally owned or operated housing • Means housing that is currently owned or operated by an Indian tribe or TDHE, or was previously assisted with HUD funding • Applies to Category Two projects for mold remediation
Old but Key Definition • New Applicant • An applicant who has never received an ICDBG or whose grants have been closed for more than 12 months prior to application deadline date
Single Purpose Grants Allocations • HUD allocates funds to six Area ONAP regions • Based on a regulatory formula (24 CFR 1003.101) • Allocate $1M to each region • Allocate the remaining based on each region’s share of tribal population (40%), poverty (40%), and overcrowding (20%)
Changes to Allocation • In FY14, HUD replaced old 2000 Census data with new Census data from the American Community Survey (ACS) • State-recognized tribes are excluded from the calculation (except for few grandfathered tribes)
What Is the ACS? • Evolution of the Decennial Census “long form” survey, which collected demographic, housing and socio-economic information from a sample of all households that were counted in the Decennial Census.
What is the ACS? cont… • Instead of sampling once every 10 years, the Census samples a smaller share of the population each year with the ACS and produces multi-year estimates • In FY 2014, HUD is using ACS estimates from 2007-2011 for allocations and estimates from 2006-2010 for new LMI data
Changes to Allocation • More details: http://www.huduser.org/portal/icdbg/home.html • Data used to determine need also found on this website
Measuring LMI Area Benefit • In FY 2014 there are seven options • Primary Option – old way w/new data (1 option) • Standard ICDBG LMI data from the ACS, all people in tribal areas • Other tribal area options (2 options) • AIAN LMI data from the ACS, all HH alone or in-combo
Measuring LMI Area Benefit cont… • Neighborhood level options (3 options) • Standard CDBG LMI data from the ACS, all people (1 option) • AIAN LMI households from the ACS (2 options) • Applicant generated data per NOFA
Measuring LMI – More Info • Additional training on LMI data on July 2 • Website for data downloads –http://www.huduser.org/portal/icdbg/home.html • HUD User website will be revised to include data in all options
Applicant Data • If applicant believes that neither option truly measures need, or if the HUD-provided options are substantially inaccurate or incomplete, applicant may submit other data that meet the criteria of 1003.208(a)(3) and the NOFA
Applicant Data cont… • Data must meet this criteria • Be collected systematically • Be independently verifiable • Differentiate between reservation and BIA service area population where applicable
3. Applicant Data cont… • Must submit • Explanation of number of people benefitting from project and number of LMI • Sample copy of survey form • Explanation of methods used to collect data • Listing of incomes by household and size
Grant Ceilings • Grant ceilings apply to entire application • One of the screening factors • If exceeded, application not rated
Grant Ceilings • Eastern Woodlands $600,000 • Southern Plains $800,000 • Northwest $500,000 • Alaska $600,000
Grant Ceilings • By Population • Northern Plains = $900,000 - $1.1 million • Southwest = $605,000 - $5.5 million (only one tribe)
Grant Ceilings • If funded under both categories, may not receive more than the combined ceiling of both categories
Housing Rehab Cost Limits Eastern Woodlands $35,000 Southern Plains $35,000 Northern Plains $50,000 Southwest $65,000 Northwest $50,000 Alaska $75,000
Regulations and Requirements • If funded, must comply with regulations, guidelines and requirements of the ICDBG program • Regulations apply to both categories of funding
Eligible Applicants • Indian tribe, band, group, or nation including Alaska Indians, Aleuts and Eskimos and any Alaska Native Village • Tribal organizations submitting on behalf of tribes
Period of Performance • Based on the Implementation Schedule and must be approved by HUD • Required under Rating Factor 1
Cost Sharing or Matching • Not required for ICDBG • Points awarded for leveraging • ICDBG can be used as match for other programs
Threshold Requirements • HUD Thresholds in General Section • Program-Related Thresholds in ICDBG NOFA • Project-Specific Thresholds in ICDBG NOFA
General Section Thresholds • Ineligible Applicants • Resolution of Civil Rights Matters • Economic Opportunities for very low- and low- income (Section 3) • Limited English Profiency and Accessible Technology • Accessible Technology
Nondiscrimination • Compliance with Fair Housing and Civil Rights Laws • Affirmatively furthering fair housing • Special rules apply to tribes and their instrumentalities
Other HUD Requirements • Outstanding Delinquent Federal Debts • Pre-award accounting system survey • No debarments and/or suspensions • No False statements • Do Not Pay Website Review
Other HUD Requirements • Code of Conduct • Prohibition against lobbying • Conflicts of interest
Other HUD Requirements • Ensuring participation of small businesses • Equal access for sexual orientation, gender, marital status • Faith-based requirements • Uniform Relocation Act
National Policy Requirements • Procurement of Recovered Materials • Participation in HUD evaluation • Environmental requirements • OMB Requirements – Some new
National Policy Requirements • Drug-free workplace • Safeguarding client files • Compliance with Transparency Act • Compliance with Duncan Hunter Act
Requirements That May Prohibit Award • Name Check Review • False Statements • Do Not Pay.gov Review
Program-Related Thresholds • Outstanding ICDBG Obligation • Compliance with Fair Housing and Civil Rights Laws
Project-Specific Thresholds • Housing Rehabilitation • New Construction • Economic Development
Housing Rehab Threshold • Rehab standards and policies adopted • Homebuyer’s payments are current for HUD-assisted housing