Can an entitlement that is part of a non-entitlement NSP Consortium transfer program income to its Community Development Block Grant (CDBG) program?

Date Published: July 2016

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It depends on the terms of the consortium funding agreement between the lead applicant and the entitlement consortium member. NSP has maintained since the inception of the program that the members of a consortium are considered to be grantees, not subrecipients. If the consortium funding agreement allows the entitlement consortium member to retain NSP program income and the funds are not needed to ensure that the consortium as a whole meets NSP2 original requirements (such as the 25% set-aside), the entitlement may:

  1. Transfer the NSP funds to CDBG at grant closeout without the permission of the lead applicant; or
  2. Secure the lead applicant’s permission to transfer the NSP program income to CDBG prior to grant closeout.

On the other hand, if the consortium funding agreement requires that program income be returned to the non-entitlement lead applicant, the only way NSP program income may be transferred is if the lead entity amends the agreement to give the program income to the entitlement member. In either case, if the transfer is carried out, the lead entity must ensure that the Disaster Recover Grant Reporting System (DRGR) reporting and program records correctly record the change.

Tags: NSP Financial and Grants Management - Program Income