Date Published: March 2019
Many times, it is impractical, if not downright impossible, to secure income verification from the beneficiaries of certain CDBG activities. This is particularly true of public service activities, like food banks, where donated food is made available for individuals and families, often have little or no ongoing client relationship between the beneficiary and the provider. Grantees must use their best judgment in funding agencies providing these services and should at least ensure that they have a written policy on self-certifications and that a majority of the types of services being provided do not depend on self-certifications. Grantees may also find it useful to explore other ways of meeting a national objective, such as "Low and Moderate Clientele (LMC) nature and location" or "LMC presumed benefit" would offer a more reliable path toward documentation.