CDBG Entitlement FAQ

What are some ways a CDBG grantee can avoid timeliness problems?

Date Published: March 2019

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  1. Select activities in the Action Plan that are ready to go and include a list of back-up activities that could be funded in case the originally selected activities encounter delays.

  2. Reprogram funds for a new activity that is ready to go and include the original activity in a later year's Action Plan once it is ready to proceed. Consider if any changes are needed to the citizen participation plan to facilitate fund reprogramming.

  3. Consider making fewer, larger awards to subrecipients. Consider past experience and/or performance when choosing subrecipients to ensure funds are being expended in a timely manner.

  4. Consider breaking large infrastructure/construction projects into phases spread across several years' Action Plans. For example, fund the architectural/engineering work in year one, fund the water and sewer line replacements in year two, and fund the street and sidewalk reconstruction in year three.

  5. Make use of the regulatory authority to incur-pre-award costs (24 CFR 570.200(h)), where appropriate and permitted by state/local law.

  6. Set performance deadlines in subrecipient agreements and contracts and enforce them. If necessary, reprogram funds from a slow-moving activity to a ready-to-go, faster-moving activity so that there is less of a time lag for expenditures.

  7. Develop a schedule for each CDBG-funded activity that includes a timeline for estimated draws.

  8. Don't accumulate bills for months before submitting draw requests in IDIS and draw down funds in IDIS on at least a monthly basis. Grantees should establish a regular schedule for making drawdowns. A grantee that "front-ends" local funds to pay CDBG expenses for long time periods before reimbursing itself from its Line of Credit is costing itself money by earning less interest and risking timeliness concerns.

  9. Ensure multiple staff members have IDIS access to both initiate and approve drawdown requests to address sudden or unexpected employee absences.

  10. Perform a cash flow analysis of Revolving Loan Funds (RLFs) to determine whether the fund is over-capitalized (i.e. current balances plus projected repayments exceed expected demand for funds based on past performance). Where supply exceeds demand, reprogram excess RLF balances to other non-RLF activities.

Tags: CDBG Entitlement Program Timeliness