Attachments: Additional Requirements for End of Program Year Reporting

1. All Grantees Must Submit a Narrative Statement Addressing the Following:

1. Assessment of Three- to Five-Year Goals and Objectives

   All Grantees must demonstrate how activities undertaken during the program year address pertinent Strategic Plan objectives and areas of high priority identified in their three- to five- year Consolidated Plan. Narrative information should be provided that describes how activities address these objectives so that overall performance in meeting Consolidated Plan goals can be assessed. For example, CDBG and ESG program activities that serve the homeless or persons with special needs should be referenced to specific objectives and/or goals in the Strategic Plan. This information should be summary information so that HUD and citizens can easily assess annual progress made toward meeting longer term goals.

2. Affirmatively Furthering Fair Housing

   Actions taken to affirmatively further fair housing, including actions taken regarding completion of an analysis of impediments to fair housing choice, a summary of impediments identified in the analysis, and actions taken to overcome the effects of impediments identified through the analysis. (24 CFR 91.520(a))

3. Affordable housing

   Evaluation of progress in meeting its specific objective of providing affordable housing, including the number of extremely low-income, low-income, and moderate-income renter and owner households assisted during the reporting period and the number of households assisted with housing that meets the Section 215 definition of affordable housing for rental and homeownership¹. This summary of progress should include a comparison of actual accomplishments with proposed goals for the reporting period, efforts to address "worst-case needs," and progress in meeting the needs of persons with disabilities². This will be important in enhancing the public's understanding of the report. (24CFR 91.520(b))

4. Continuum of Care Narrative

   Actions taken to address the needs of homeless persons and the special needs of persons that are not homeless but require supportive housing, (including persons with HIV/AIDS and their families). This narrative should include a summary of actions taken during the program year to develop and implement a Continuum of Care strategy for the homeless, i.e. actions taken to prevent homelessness, to address the emergency shelter and transitional housing needs of homeless individuals and families (including significant subpopulations such as those living on the streets), to help homeless persons make the transition to permanent housing and independent living. (This should include new Federal resources obtained during the year from the Continuum of Care Super NOFA to prevent homelessness, address emergency and transitional housing needs of homeless individuals and families, and to help homeless persons make the transition to permanent housing (24CFR 91.220(e), 91.320(e), and 91.520)

5. Other actions

   Other actions indicated in the strategic and action plans. These would include actions to address obstacles to meeting underserved needs, foster and maintain affordable housing, eliminate barriers to affordable housing, overcome gaps in institutional structures and enhance coordination, improve public housing and resident initiatives, evaluate and reduce lead based paint hazards, ensure compliance with program and comprehensive planning requirements, and reduce the number of persons living below the poverty level. Grantees should review requirements contained in 24 CFR 91.215, 91.220 and 91.230 (for local governments) and 24 CFR 91.315, 91.320 and 91.330 (for States). (24 CFR 91.520)

6. Leveraging Resources

   Describe progress in obtaining "other" public and private resources that address needs identified in the plan. The report should also discuss how Federal resources made available from HUD leveraged "other" public and private resources, including how any matching requirements were satisfied.

7. Citizen comments

   Provide a summary of citizen comments received in regard to the program. (HCDA Section 1049e) and NAHA Section 107( c))

8. Self-Evaluation

   The Consolidated Plan is a concept that is designed to enable officials and citizens to become more aware of the larger picture and the extent to which all related programs are effective in collectively solving neighborhood and community problems. Moving beyond the compilation of program outputs, there must be a focus on results that will allow a community to assess progress in meeting the priority needs and specific objectives identified in the strategic plan and action plan in order to help make the community's vision of the future a reality.

   The overall goal of the community planning and development programs included in the Consolidated Plan is to develop viable communities by providing decent housing and a suitable living environment and expanding economic opportunities principally for low and moderate income persons. An evaluation of accomplishments, as well as plans for the future, should be developed with this overall statutory purpose in mind. A more detailed statement of these three elements of this goal is included in the Consolidated Plan regulations at 24 CFR Section 91.1(a).

   As grantees proceed through this process of self-evaluation, there are certain questions which may be considered. Are the activities and strategies making an impact on identified needs? What indicators would best describe the results? What barriers may have a negative impact on fulfilling the strategies and the overall vision?? What is the status of grant programs? Are any activities or types of activities falling behind schedule? Are grant disbursements timely? Do actual expenditures differ substantially from letter of credit disbursements? Are major goals on target? And, based on the answers to these and other question, what adjustments or improvements to strategies and activities might meet your needs more effectively?

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2. All Grantees Receiving CDBG Entitlement Funds Must Submit a Narrative Statement Addressing the Following Issues:

1. Assess the relationship of the use of CDBG funds to the priorities, needs, goals, and specific objectives identified in the Consolidated Plan, including an analysis of the extent to which CDBG funds were distributed among different categories of housing needs identified in the Consolidated Plan. Special attention should be given to the highest priority activities identified and evaluation of the extent to which CDBG funds were used for activities that benefited low-and moderate-income persons. (HCDA Section 104(e) and 24 CFR 91.520( c))

2. Describe the nature of and reasons for any changes in program objectives and indications as to how the jurisdiction would change its programs as a result of its experiences. (24 CFR 91.520 ( c))

3. Assess grantee efforts in carrying out the planned actions described in its action plan as part of the grantee's certifications that it is following a current HUD-approved Consolidated Plan. This should include a narrative analysis to show that the grantee: (1) pursued all resources that the grantee indicated it would pursue; (2) provided requested certifications of consistency for HUD programs, in a fair and impartial manner, for which the grantee indicated that it would support application by other entities; and (3) did not hinder Consolidated Plan implementation by action or willful inaction. To the extent that these points are covered in other parts of the performance report, appropriate cross-reference will suffice. (24 CFR 91.225(b)(3) and 24 CFR 570.903)

4. If grantee funds are not used exclusively for the three national objectives, or if the grantee did not comply with the overall benefit certification, then narrative explanation must be included to address these issues. The narrative should address how the use of funds did not address national objectives and how future activities might change as a result of the current experience.

5. If any activities specified for the program year involve acquisition, rehabilitation or demolition of occupied real property, a narrative must be submitted that identifies the activities and that describes (1) steps actually taken to minimize the amount of displacement resulting from the CDBG-assisted activities, (2) steps taken to identify households, businesses, farms or nonprofit organizations who occupy the site of a CDBG-assisted project subject to the requirements of the Uniform Relocation Act (URA) or Section 104(d) of the 1974 Community Development Act, as amended, and whether or not they were displaced, and what the nature of their needs and preferences, and (3) a description of the steps taken to ensure the timely issuance of information notices to displaced households, businesses, farms, or nonprofit organizations.

6. If during the program year there were economic development activities undertaken where jobs were made available to low- or moderate-income persons but were not taken by them, then the grantee must provide (1) a narrative actions taken by the grantees and the businesses to ensure first consideration was or will be given to low/mod persons, and (2) a listing by job title of all the permanent jobs created/retained and those that were made available to low/mod person. If any of the jobs claimed as being available to low/mod persons require special skill, work experience, or education, include a description of the steps being taken or that will be taken to provide such skills, experience, or education.

   If the grantee undertook an activities during the program year which serve a limited clientele not falling within one of the categories of presumed limited clientele low and moderate income benefit, then the grantee must provide a narrative description as to how the nature, location, or other information demonstrates the activities benefit a limited clientele at least 51% of whom are low- and moderate-income.

   If activities were undertaken during the program year that generated program income to revolving funds; program income from float funded activities; income from the sale of real property; other loan repayments, prior period adjustments; loans outstanding or written off; parcels of CDBG-acquired property available for sale; or lump sum drawdown payments, then narrative information must be provided in accordance with provisions of CDBG Handbook No. 6510.2 REV-2 pages 3-8 and 3-9, and exhibit 3b.

   For each type of rehabilitation program for which projects/units were reported as completed during the program year, provide a narrative description that identifies the type of program and the number of projects/units completed for each, the total CDBG funds involved in the program, and other public and private funds involved in the project.

   All grantees that have HUD-approved neighborhood revitalization strategies will report progress against benchmarks for the program year. For grantees with Federally-designated EZs or ECs that received HUD approval for a neighborhood revitalization strategy, reports that are required as part of the EZ/EC process shall suffice for purposes of reporting annual progress. (24CFR 91.215(e)(2))

3. All Grantees Receiving HOME Funds Must Submit the Following Narrative Information:

1. An analysis of the extent to which HOME funds were distributed among different categories of housing needs identified in its approved Consolidated Plan.

2. A report on match contributions made using a separate HOME Match Report, HUD-4107-A for the period covered by the Consolidated Plan Program Year and comply with Consolidated Plan provisions to indicate resources from private and non-Federal resources. Although the requirement for matching contributions is based on the Federal Fiscal Year, the reporting is based on the PJ's program year and this report should be modified to indicate the PJ's program year. 91.220(b)(2), 91.320(b)(2), and 91.420(b))

3. HOME PJ's should submit Part III of HUD Form-4107 to report contracts and subcontracts with Minority Business Enterprises (MBEs) and Women's Business Enterprises (WBEs).

4. The results of on-site inspections of affordable rental housing assisted under HOME and as assessment of the HOME jurisdiction's affirmative marketing actions and outreach to minority and women owned businesses. (24CFR 91.520(d))

4. All Grantees Receiving HOPWA Funds Must Submit Narrative Information Addressing the Following:

1. An analysis of the extent to which HOPWA funds were distributed among different categories of housing needs identified in its approved Consolidated Plan.

2. An overview of activities carried out, barriers encountered, actions in response to barriers, and recommendations for program improvement. For example, a grantee could describe difficulties that were encountered in implementing the program based on a review of residents' concerns and the actions taken to address those concerns. Recommendations for program improvements should include ideas for procedural, regulatory, and other changes and describe how such changes would benefit eligible persons and/or improve administrative efficiency. Grantees that select project sponsors also should address how grant management oversight of sponsor activities was undertaken, including how recipients of such assistance were chosen and what services provided. (AHOA, Sec. 862 and 24 CFR 91.520(a) and (e))

3. Information on what other resources that were used in conjunction with HOPWA-funded activities, including cash resources and in-kind contributions, such as the value of services or materials provided by volunteers or by other individuals or organizations. If not already addressed in the general performance report narratives, HOPWA grantees also should indicate how activities were carried out in collaboration with related programs, including consultations or coordination of planning with clients, advocates and entities that administer programs under the Ryan White CARE Act, AIDS Drugs Assistance Programs, Continuum of Care Homeless Assistance Programs, or other efforts that assist person living with HIV/AIDS and their families.

5. Requirements for Grantees Receiving ESG Funds

All grantees receiving ESG funds must submit narrative information addressing the following:

1. A description of the extent to which activities supported directly with ESG funds addressed homeless and homeless prevention goals, objectives, and priorities established in the Consolidated Plan, and if applicable, the Continuum of Care Plan. This description may be discussed in the Continuum of Care section of this report.

2. A description of the sources and amounts of funds used to meet the match requirements of the ESG program.

6. Public Participation Requirements

It is important that the reports provided to citizens, community groups, and local political leaders present a clear and complete statement of what has been accomplished not only to HUD, but also to citizens, community groups, and local political leaders. Therefore, we urge your attention to assembling this information in a manner which relates back to the needs, strategies, and objectives as described and presented in your approved Consolidated Plan and Action Plan.

Before submitting performance reports to the HUD Field Office for review, the jurisdiction must make the report available to the public for examination and comment for a period of at least 15 days. A copy of the performance information made available to HUD, including the summary of public comments received as a result of the public participation process, must be available for examination by the public upon request.

The performance report provided to citizens must identify the Federal funds made available for furthering the objectives of the Consolidated Plan. For each formula grant program, the grantee shall identify the total amount of funds available, (including estimated program income) the total amount of funds committed during the reporting period, the total amount expended during the reporting period, and the geographic distribution and location of expenditures. Jurisdictions are encouraged to include maps in describing the geographic distribution and location of investment (including areas of minority concentration). The geographic distribution and expenditure requirement may also be satisfied by specifying the census tracts where expenditures were concentrated.

The grantee must also provide the public a summary of community accomplishments for each priority need that the community designated in the strategic plan. For public services, this must include the number of persons served during the reporting period. For public facilities and improvements, this must include the number of projects assisted and the number of projects completed during the reporting period. For economic development needs, this must include the actual number of businesses assisted, jobs assisted, and the actual number of extremely low-, low-, and moderate-income persons assisted during the reporting period.

This summary of accomplishments can be met using the standard reports generated from the Integrated Disbursements and Information System (IDIS). Please see the attachment for the types of reports that are available from IDIS.

Footnotes

<1> The Section 215 definition of affordable housing is defined in 24 CFR 92.252 for rental housing and 24 CFR 254 for homeownership.

<2>Worst-case housing needs are defined as low-income renter households who pay more than half their income for rent, live in seriously substandard housing (which includes homeless people) or have been involuntarily displaced. The needs of persons with disabilities does not include beds in nursing homes or other service-centered facilities.