Date Published: March 2019
Local discretion is important to implementing a CDBG self-certification program because only the grantee can know all the circumstances and risk factors that must be considered in setting up such a program. The flexibility a grantee exercises regarding the 20% sampling recommendation can be a function of several things. For instance, if the grantee is considering a policy for a non-profit subrecipient or a government agency, how comfortable is it with that entity's management and implementation of this public service activity? Is there a direct financial benefit to the beneficiaries? What is the estimated value of the benefit being provided, whether direct or indirect? How many persons is this activity serving?
The answers to all these questions and others should play into the sample size a CDBG grantee requests for verifiable income documentation. The greater the financial value of the benefit being provided – particularly if it is a direct financial benefit (e.g., day care subsidies, rental security deposits), the greater the sample size in most cases. As part of any policy, it is recommended that grantees alert beneficiaries while they are self-certifying as to income, that a select sample of self-certifications will be tested, and those beneficiaries will be expected to produce verifiable income documentation.