New Implementation Guidance for Use of CDBG-DR Funds as Non-Federal Cost Share for FEMA's Public Assistance Program
On October 14, 2020, HUD and the Federal Emergency Management Agency (FEMA) published Notice CPD-20-10: Implementation Guidance for Use of Community Development Block Grant Disaster Recovery (CDBG-DR) Funds as Non-Federal Cost Share for FEMA’s Public Assistance Program.
On January 3, 2020, FEMA and HUD signed a Memorandum of Understanding (MOU) that outlines a series of actions intended to streamline the use of CDBG-DR funds to satisfy the cost-share requirements of the Public Assistance (PA) Program. This included developing a joint Implementation Guidance (Guidance) that outlines a flexible approach to using HUD CDBG-DR funding for the PA local cost-share requirements (flexible match).
The flexible match concept allows CDBG-DR funding to be applied to distinct facilities or sites within a PA project. Applying the flexible match concept reduces the number of sites that must meet both FEMA PA and CDBG-DR requirements. While all the sites and facilities must comply with FEMA PA requirements, only the CDBG-DR assisted portion of the project must comply with CDBG-DR requirements.
The Guidance is directed towards FEMA staff, recipients, and subrecipients and HUD staff, grantees, and subrecipients. The Guidance provides tools to plan for and navigate the multiple compliance considerations of both FEMA PA and CDBG-DR in a streamlined manner. It also includes a discussion of the roles and responsibilities of each federal agency and of those entities receiving and using funds under each grant program.