CDBG Entitlement FAQ

Is there a Buy American requirement for CDBG-funded construction or public works projects similar to other federally-funded work?

Date Published: May 2015

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There is no "Buy American" requirement for the federal Community Development Block Grant Program (CDBG). CDBG grantees and subrecipients must follow federal procurement rules when purchasing services, supplies, materials, or equipment. The applicable federal regulations are contained in:  

  • State and local governments and Indian tribes – 24 CFR Part 85.
  • Nonprofits, institutions of higher education and hospitals – 2 CFR Part 215.44 (formerly OMB Circular A-110), as implemented through 24 CFR Part 84.

Most state and local governments have laws regarding procurement. Each entity receiving CDBG funds should be aware of state and/or local laws that may affect procurement policies. Grantees should adopt procurement policies that describe how the grantee or subrecipient will procure supplies, materials, services and equipment. The policy should assure that all purchases are handled fairly and in a manner that encourages full and open competition. The American Recovery and Reinvestment Act of 2009 awarded Community Development Block Grant Recovery (CDBG-R) funds to grantees that received CDBG funding in fiscal year 2008. For CDBG-R funded programs, the "Buy American" requirement applies to eligible activities for the construction, alteration, repair and maintenance of public buildings or public works. For these activities, with some exceptions, all of the iron, steel, and manufactured goods used in the project must be produced in the United States. All CDBG-R funds had to be expended by September 30, 2012. This "Buy American" requirement did not apply to the regular CDBG program.

Tags: CDBG Entitlement Program Procurement