Recipients and subrecipients must understand the difference between approved and eligible costs. Approved costs are the budget line items (BLIs) specifically approved by HUD in the recipient’s grant agreement. A program can only expend CoC funds on approved costs.
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Within each eligible cost category, the expenditure of staff and direct overhead associated with carrying out those eligible activities is charged to that eligible budget line item (BLI). For instance, the time a supervisor spends with a case manager discussing a program participant’s supportive services package is charged to the supportive services BLI. The time the finance department staff spend cutting checks to a landlord would be billed under that program’s rental assistance or leasing BLI (whichever one HUD has approved).
It is important to note that staff may also carry out eligible activities across different cost categories. To the extent a staff person assumes multiple roles, their costs must be split between the two or more categories that their role covers. The recipient or subrecipient will need to maintain documentation, such as time sheets and activity logs, to show how the costs were assigned to each cost category.
To count as match a recipient or subrecipient must spend cash or in-kind resources on eligible activities. If the activity is not eligible under the CoC Program Interim Rule, then it cannot count as match. See the Match Binder for more information.