Section I: Grantee Responsibilities

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

	Jump To...
Types of grantees   Elements of a grant agreement   Documenting address and personnel changes   Communications with HUD   Record keeping   Tracking

Grantee, project sponsor, and lead agency duties

The grantee is a direct recipient of the HUD award. The grantee signs a grant agreement with HUD and receives funds directly. Sometimes the grantee itself carries out the day-to-day implementation, operation, and administration of the project. A grantee may carry out the entire project itself or it may arrange for elements of the project to be carried out by other public or private providers.

In other instances, a grantee may act as a lead agency when it administers one or more projects through project sponsors. The lead agency signs the grant agreement for each project awarded, and it receives funding directly from HUD for distribution to project sponsors. The lead agency has the contractual responsibility for ensuring that the project described in the application and technical submission is successfully carried out. A lead agency's responsibility encompasses oversight for every aspect of the project, including ensuring funds expended are for eligible activities.

A project sponsor carries out the project described in the application and technical submission. Project sponsors receive grant funds to pay project expenses indirectly through their lead agency. They make requests for funds and submit annual reports and requests for any program changes to the lead agency for consideration. HUD recommends that a subrecipient agreement be signed by both parties.

It is the responsibility of the lead agency to process funding requests expeditiously and to contact the local HUD field office on any project changes or issues. Specific goals and activities for each project, as well as record keeping and reporting responsibilities, should be set out clearly in the subrecipient agreement.

Requirements in a grant agreement

A grant agreement is the contract between the grantee and HUD concerning an SHP project. The grant agreement is signed by the local HUD field office and the grantee. It dictates project activities and has these elements:

	Common elements -- Items common to all SHP grants are contained in the first several pages. These pages define the parties entering into the contract, project and grantee identification numbers, amount of the SHP award by activity category, and sanctions which HUD may take for nonperformance.
	Application - The application submitted through the competitive process provides the basic information on what activities will be carried out, how many persons served, etc. HUD may issue comments and/or conditions to an application whenever deficiencies are noted during the competitive review process.
	Certifications - Inside the initial application are several pages of certifications which the Chief Executive Officer of the applicant organization signs. These bind the grantee to compliance with other Federal requirements, such as fair housing and civil rights.
	Technical submission - These exhibits are completed by the selectee following award announcement but prior to grant agreement. They establish the budget lines for SHP-funded grant activities.
	SHP regulations - Attachment 1 of a grant agreement is a copy of the SHP regulations applicable to the project.
	Amendments - Section 583.405 allows necessary changes to the project under certain circumstances. If substantial changes are needed, the grantee must request approval of a grant agreement amendment from HUD in writing prior to initiating the change.

Informing HUD of address and personnel changes

Periodically, a grantee or project sponsor will move, have personnel changes, or an agency name change. These changes should be sent to the local HUD Office using the HUD Form 27056, Change of Address Request for processing. For a copy of this form, please contact your local HUD Office.

Additionally, when significant staff or board of director changes occur, a grantee sends the local HUD Office an update. This ensures that mail is sent to the appropriate individual. If a change involves financial access, a grantee should contact the local HUD Office for the forms required for transferring financial responsibility.

Communications with HUD

All issues requiring a written response should be submitted in writing to the local HUD office. For lead agencies, HUD is your direct contact for correspondence. Project sponsors communicate their requests through the lead agency.

The key to expediting correspondence with HUD is the inclusion of the project grant number as a means of reference. This is especially critical for grantees with multiple project sponsors or projects involving more than one HUD program. A secondary benefit of identifying the grant is the assurance that the letter will be filed correctly for future reference. Please send correspondence requests to the Director of Community Planing and Development (CPD) at the local HUD Office. You may want to add an "Attention" line, indicating the primary CPD contact.
Facsimiles should be addressed in the same manner as regular HUD correspondence. Be sure to include the grant number. Again, you may add an "Attention" line, indicating the primary CPD contact. Electronic messages are handled somewhat differently from regular mail in that they are not normally tracked or assigned a response date. For this reason, if you a requesting a written response to your fax, you should indicate the need for a written response and follow-up the fax with a letter.

Recordkeeping

All grantees need complete, up-to-date project records and written procedures used in carrying out the project itself and paying project expenses. The following offers recommendations in those areas:

Written procedures for -
Duties of key employees

	Organizational chart showing lines of responsibility
	Directions for recording financial transactions, including approval authority
	Maintenance of accounting records
	Record retention and security
	Cash management
	Property controls
	Procurement

Project documentation to demonstrate

	Participant eligibility, income and rent calculations, service provision
	Match for acquisition, rehabilitation, new construction, operating and supportive service grant funds
	Compliance with other Federal requirements, such as lead-based paint or relocation

Financial documentation to demonstrate -

	Eligibility of project expenses
	Adequate internal controls
	Timely use of cash from the SHP grant
	Compliance with procurement standards
	Compliance with audit requirements

Reporting

Grantees must report on their progress each year in the Annual Progress Report. These APRs are submitted to the HUD field office within 90 days of the end of the project's operating year.

Tracking for lead agencies

Since lead agencies are responsible for their project sponsors' grants, it is recommended that they maintain up-to-date and thorough information on the projects. The following offers some suggestions:

	Tracking system - This master file should contain information tracking the status of each project from notice of award through technical submission, grant agreement, development activities, start of operations, amendments, end of operations, and renewal. It should also show dates of submission of APRs, audits, and required monitoring remedies/sanctions. (See more discussion below.)
	Project Grant File - One file is used for each project. Items such as the original application, HUD award notification letter, technical submission, grant agreement (with regulations attached), subrecipient agreement, any amendments, site control documentation, any appraisals, and correspondence are in this file.
	Project Monitoring File - One file is used for each project. This file contains the project's narrative from approved application, organizational chart, monitoring findings and responses, APRs with associated correspondence, and any project-specific policy and procedure information.

Following a monitoring visit, the lead agency needs to track violations or deficiencies in the tracking system and insert documentation in the project's monitoring file. In the tracking system, tracking elements could, at a minimum, include:

	The reviewer's name
	Grantee name and number
	Date of on-site visit
	Areas of compliance selected for review
	Date of final assessment report
	Findings and issues to resolve

A lead agency also needs to track the receipt of APRs and their approvals. Elements could, at a minimum, include:

	Grantee name and number
	Operating start date
	Date of reminder notice
	APR due date
	Date of overdue notice, if applicable
	Date received
	Dates of any interim correspondence regarding requests for additional information, if applicable
	Date of approval letter
	Date APR was submitted to local HUD office

 Back to SHP Program Page