Section F, Important Dates

Information by State  Print version   Shp Deskguide Contents   Introduction   Detailed Table of Contents   A. Program Goals   B. Eligible Participants   C. Program Components   D. Eligible Activities and Match   E. Reserved   F. Important Dates   G. Conditional Approval and Program Cycle   H. Site Control Requirements   I. Grantee Responsibilities   J. Reserved for Project Financing   K. Calculating Resident Rents   L. Reserved   M. Reserved for Financial Management   N. Annual Progress Reports   O. Reserved for Compliance Monitoring   P. Technical Assistance   Q. Project Renewals   R. Grant Amendments   S. Grant Extensions   T - X Reserved   Y. Spending and Recaptures   Z. Reserved for Closeouts

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The award letter   Grant agreement execution   Start of operations   Technical Submission milestones   Timeliness of spending   Term of commitment

This section describes the significance of the dates of:

Award notification

The date of the letter from HUD indicating selection as a conditionally funded recipient starts the clock for the site control requirement. A selectee has one year to demonstrate site control, if applicable (see section H of this guide). If site control is not achieved within one year from the date of this award letter, HUD is mandated by law to cancel the offer of an SHP grant.

Contract effective date

The effective date of the grant agreement is the date on which the local HUD office signs a grant agreement. Once executed, the local HUD office returns a copy of the contract to the grantee. The date on the grant agreement is shown below the signature of the Director of the Community Planning and Development Division.

A project sponsor's effective date is the date that the written agreement between the grantee and the project sponsor is executed; the date cannot precede the effective date of the agreement between HUD and the grantee.

Grantees may not incur project costs prior to the effective date of the grant agreement. In very rare instances, a grantee may incur pre-agreement costs subject to prior written approval from the local HUD office. Without this prior written approval, the grantee cannot be reimbursed for expenditures with SHP funds. An example of an allowable pre-agreement cost is the cost of attending post-award training held by the field office for grantees.

Operating start date

The operating start date indicates when the term of the grant begins. It is the date when participants begin to receive housing and/or services.

This date is significant for two reasons. First, it dictates the beginning and end dates of the grant's funding term, i.e., one, two or three years. Second, the operating start date starts the clock for submission of annual reports.

The grantee enters the operating start date into the LOCCS accounting system, according to one of the following situations:

For projects with acquisition, new construction or rehabilitation -

The operating start date begins after completion of all acquisition, new construction or rehabilitation activities; after sending a copy of the Certificate of Occupancy to the local HUD office; and when the first participant is accepted into the project.

For projects without acquisition, new construction or rehabilitation -

The operating start date begins when the grantee accepts the first participant. For example, a Supportive Service Only component grant providing job training would enter the date it serves the first client. As the project term begins, the grantee makes the first draw down for leasing, supportive services or operating costs under LOCCS.

Milestones

The NOFA and regulations contain timeliness standards for SHP projects. Grantees submit project milestones as part of their Technical Submission, and the Technical Submission is incorporated into the grant agreement.

HUD may de-obligate funds if serious delays occur which are within the control of the grantee. Additional information regarding de-obligation is given in section 583.410(c) of the SHP regulations.

HUD compares a grantee's application milestones with actual progress and with information submitted in the APRs. Significant deficiencies regarding milestones could result in corrective measures or cancellation of the grant.

If a grantee feels that its project is not achieving its milestones, it may contact the local HUD Office for technical assistance. This contact will establish two things: it will enable staff to suggest options or provide technical assistance; and it documents the fact that the grantee is working to correct any deficiency.

Timeliness of spending grant funds

Since SHP funds are intended for immediate use to assist people experiencing homelessness, it is necessary for a project to maintain a progressive schedule. In addition to the development milestones, grantees are expected to make timely draws from their LOCCS project accounts - draws that are neither too early nor too late.

Grantees make draws too early when they draw down SHP funds in advance of needing to pay an invoice, salaries, etc. US Treasury rules require grantees to repay any interest gained on holding grant funds in an interest bearing account. The rule of thumb is that grantees should draw funds from the Treasury no more than three days before needing to pay an invoice, salaries, etc.

Grantees make draws too late when they do not use earmarked SHP funds to pay when bills are due. US Treasury rules do not allow grantees to pay late charges with SHP funds. Also, grantees are discouraged from using some other funds to pay for earmarked SHP activities and reimbursing themselves with SHP funds. This is seen as a poor financial management practice.

Term of commitment for acquisition, rehabilitation and new construction projects

By law, projects which receive SHP funds for acquisition, rehabilitation, or new construction must operate the project in the assisted structure for 20 years. After that time, the "value" of the SHP funds are used up, and the grantee may use the site as it wishes. The 20-year period begins when the project begins serving homeless persons (see operating start date section above), and ends 20 years later.

Please note that during the 20-year period the requirements of the SHP program are in effect. For example, participants living in an assisted structure cannot be required to pay resident rent in excess of 30% of their adjusted income, 10% of their monthly income, or their welfare rent. The SHP regulations apply even when the project is not receiving SHP renewal funds.

The law also prescribes procedures when an assisted structure is not used for 20 years. If the structure is used for less than 10 years, the grantee is required to repay all of the acquisition, rehabilitation, or new construction costs originally paid for with SHP grant funds. For each full year the assisted structure is used beyond the 10 years, the grantee's repayment is reduced by 10 percent.

If the assisted structure is sold or otherwise disposed of within the 20-year period, HUD may prescribe terms or conditions which prevent the grantee from unduly benefiting. However, HUD will not impose any terms or conditions when the sale of disposition results in the subsequent use of the assisted structure for the direct benefit of very low-income persons (below 50% of area median) or all of the proceeds are used to provide supportive housing.

Lead Agencies are reminded that, as the grantee, they are responsible for any repayment of grant funds and may want to include a Term of Commitment clause in all project sponsors' contracts.

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