Section R: Grant Amendments

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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Program changes   Criterion for approving an amendment   Requesting an amendment   Guidance on significant changes   Procedures for approving an amendment

Program changes

Significant and minor changes are often necessary during the life of an SHP grant. Whenever it is necessary to make changes, the HUD field office needs to be involved - either to be informed of the change or to approve the change, depending on its seriousness.

Significant change

A change is significant when it substantially affects implementation of the project and is a departure from the initial application. The following are examples of significant changes:

	Change in the grantee
	Change in the project site
	Additions or deletions of eligible SHP activities
	Shift of more than 10 percent of funds from one approved SHP activity to another over the life of the grant
	Change in the category or number of participants to be served

Minor change

Minor changes are departures from the initial application that do not substantially affect implementation of the grant. An example of a minor change is a shift of less than 10 percent of SHP funds from one approved SHP activity to another over the life of the grant.

Minor changes do not require prior HUD approval, and no amendment to the grant agreement is necessary. However, the grantee must fully document any changes to its project. The documentation must be available to the field office during on-site reviews or, for remote monitoring, sent to the Field Office if requested.

Criterion for approving an amendment

Field office CPD directors are authorized to approve significant changes in projects and execute grant agreement amendments. In the SHP regulations, approval for a significant change is contingent upon the application ranking remaining high enough after the approved change to have been competitively selected for funding in the year the application was selected.

If a Field Office determines that a proposed change would reduce or lower the quality of the project on any rating factor, the change must be discussed with and concurred on by the SNAPs office in Headquarters. The need for Snaps concurrence in these cases is based on the regulatory standard described in the previous paragraph and the fact that competitive selections are made in Headquarters.

Procedure for requesting an amendment

When a significant change is contemplated, a grantee should prepare a written request to the field office. The request should indicate what the change is and the circumstances causing the need for change.

The grantee should also attach revised application or technical submission exhibits reflecting the proposed change, because the application and technical submission are the part of the grant agreement which set out the scope of the SHP project. In addition, certain changes require additional items to process the request for a change. The most common are described here:

Guidance on Common Significant Changes

Change in grantee

When the grantee seeks to be released from its obligations under the grant, several documents are needed: a letter from the current grantee indicating its reasons for requesting a change of grantee; a letter from the proposed substitute organization indicating its willingness to become the new grantee and to accept all the responsibilities according to the terms of the current grant; a revised Capacity Exhibit from the application; and private nonprofit documentation where the substitute is a nonprofit organization.

Grantee name change

When the grantee organization changes its name, the grantee must submit a revised SF-424 and legal documentation confirming the name change.

Change in project site

For a change in the project site, the grantee must provide evidence of site control and zoning where appropriate; a revised Project Plan Exhibit from the application specifically addressing the housing component; and a revised Certification of Consistency with the Consolidated Plan, if applicable. An environmental review must also be completed according to current requirements.

Change in population served

When changing the population being served and/or where the homeless population is coming from (e.g., outreach, referral source), the grantee needs a revised Project Plan Exhibit from the application and a revised Targeting Exhibit from the application, if applicable.

Change in number being served

For a change in the number of homeless persons being served, the grantee needs a revised Project Plan Exhibit from the application and a revised chart showing number of beds, bedrooms and participants.

Shift in SHP funds of more than 10 percent

When the grantee wishes to shift, over the life of the grant, more than 10 percent of approved funds from one budget category to another, the grantee must provide a revised Project Plan Exhibit from the application and a revised Budget Exhibit. Note that a change in category can also consist of a shift into a new category and not just a shift between authorized categories.

Field office procedure for approving an amendment

All significant changes require HUD approval and are not to be implemented until HUD executes a grant amendment. Field offices process the approvals, taking the following steps, as appropriate.

1. Upon a grantee's verbal request to make a significant change, advise the grantee to submit a written request containing the relevant documentation. (Depending on the nature of the change, a new certification of consistency with the Consolidated Plan may also be required. See 24 CFR 91.)
   
   
2. Assess the information and compare the revised exhibits with the initial exhibits to determine whether the proposed change would have lowered the quality of the project. The following are examples of changes that are likely to result in a project of lower quality:

   	Housing or services are of lower quality or quantity than initially proposed
   	New housing or service provider is less experienced than the initial provider
   	Innovative features are eliminated
   	Site is moved to an area of less need
   	Resources from other public or private sources are reduced
   	Costs-effectiveness is reduced.

   
   
3. Where these or other changes would lower the original quality, phone or e-mail your SNAPS Contact to discuss the proposed revision of the project, and to determine whether the revision would affect the rating, and, if so, whether the revised rating would still render the project approvable. Document the discussion.
   
   If the application remains competitive for its funding year with the proposed change(s), document that "After a review of the proposed change, the field office and Snaps staff determined that the application ranking would have remained sufficiently high to have been competitively selected in the year the application was selected for an award." The field office will then process the grant amendment.
   
   If the application does not remain competitive for its funding year with the proposed
   change, deny the proposed change and so inform the grantee in writing stating the reasons for the denial.
   
   
4. If the proposed change(s), in the opinion of the field office, results in an equal or higher quality project, the field office has the authority to make the change without contacting the Snaps office. The Field Office will then process a grant agreement amendment.
   

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