CDBG Entitlement FAQ

What are the types of agreements that the entitlement city in FAQ 3540 would have to enter with other entitlement cities/towns and urban counties?

Date Published: March 2019

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If the city is entering into an agreement with another entitlement to administer its CDBG program, it may enter into a Memorandum of Understanding, subrecipient agreement, or interlocal agreement that details the scope of work, budget, timeframe, etc. While not required by 2 CFR Part 200 regulations, the city could formally procure the services of the other jurisdiction(s). Apple must still have a written agreement and must still oversee the other entity's performance under the contract.

If retaining its entitlement status, the city would enter a joint agreement with the urban county during the county's year of requalification. The county would receive its CDBG grant and the city's CDBG grant and is entitled to 20 percent of the city's grant for administering its program. The county would consult with the city on activities it wants the county to carry out on its behalf.

If relinquishing its entitlement status, the city would enter a cooperation agreement with the urban county. The city must remain with the urban county for the entire three-year qualification period (or the remainder thereof). When the urban county is requalifying, the city may then choose to opt out of the county and reclaim its entitlement status or remain with the county for the next three-year qualification period. Urban counties may have cooperation agreements that are automatically renewed.

Tags: CDBG Entitlement Program Consolidated Plan

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