Can an intermediary/SHFA advance actual costs to its subgrantees (upon receipt of required activity documentation) and then reimburse itself with HUD draw down?
Date Published: March 2019
Yes, intermediaries and State Housing Finance Agencies (SHFAs) may be reimbursed for actual costs incurred when they advance funds to subgrantees for eligible grant expenses. The agencies should consult their grant agreements, the HUD Housing Counseling Handbook 7610.1 REV-5, and the Housing Counseling Program regulations to ensure that they are only covering eligible expenses (i.e., for approved housing counseling services) and are requesting the appropriate supporting documentation (including, but not limited to, timesheets, personnel activity reports, receipts, etc.). Agencies should also outline this arrangement in their subgrantee agreements and reference the aforementioned documents. If the agency seeks reimbursement from HUD for ineligible costs, those costs will not be reimbursed. For more information regarding eligible expenses, please review the October 30, 2018 Preparing a Budget Training or contact your Point of Contact (POC) at the Office of Housing Counseling (OHC).