Date Published: August 2015
The way UFA grants are setup are different than grants funded under a Collaborative Applicant. Because the UFA renewal grant encompasses all renewal projects, the UFA has unique ability to move funds across all projects, regardless of component type, within the grant. The UFA must work with its local HUD field office to make changes to the projects under the UFA grant. All budget changes will be reflected in eLOCCS via the local HUD field office. However, per 24 CFR 578.105(a), the only budget changes that require a grant amendment are shifts of more than 10 percent of the total grant award amount from one approved eligible activity category to another activity in a single year.
Provisions at 24 CFR 578.105(a)(2), further clarifies that:
“…Approval of shifting funds between activities…is contingent on the change being necessary to better serve eligible persons within the geographic area and ensuring that the priorities established under the NOFA in which the grant was originally awarded, or the most recent NOFA, are met.”
Below are specific scenarios where HUD would allow for the shifting of funds–these shifts only require an amendment if they exceed 10 percent of the total grant award amount per 24 CFR 578.105(a).
If a UFA makes these changes it must also ensure that the projects where funds were reduced continue to meet the scope of work originally committed to in the executed grant agreement. If a budget change results in a significant change to the grant, specifically a reduction in units or a change in subpopulations, the UFA may only make this change through a HUD-approved grant amendment. If a UFA has received permanent housing bonus or Samaritan bonus projects in the past, the UFA must ensure that it continues to meet all requirements of the NOFA under which the project was originally awarded and current regulations. For instance, if a recipient received funding for 10 beds dedicated to chronically homeless persons the recipient must continue to meet that obligation. However, a UFA may choose to move funds between projects and designate a different subrecipient to carry out the responsibilities originally committed to in the executed grant agreement.
Per 24 CFR 578.11(c)(4), prior to making any significant changes requiring a grant agreement amendment or changes that involve eliminating projects, the UFA must obtain approval from the Continuum of Care, and then it may submit such request to HUD for approval.
Because UFAs have the authority to determine the best course of action to fulfill their obligations under the terms of the grant agreement, HUD expects them to meet those terms and obligations. HUD encourages UFAs to use their unique authority to make changes that will make their homeless response system more effective for serving homeless persons.