CDBG-CV Toolkit

Duplication of Benefits

A duplication of benefits (DOB) occurs when a person, household, business, government, or other entity receives financial assistance from multiple sources for the same purpose within the same time period, and the total assistance received for that purpose is more than the total need for assistance. Within the CDBG-CV program, all grantees are bound by Section 312 of the Stafford Act, as amended by the Disaster Recovery Reform Act, and the OMB Cost Principles within 2 CFR part 200 that require all costs to be “necessary and reasonable for the performance of the Federal award.”

To comply with DOB requirements, you are required by the CARES Act to establish and follow policies and procedures to ensure that DOB does not occur. Establishing a process to effectively identify and prevent duplication of benefits is critical for you to manage the multiple active funding streams related to coronavirus response and efficiently target CDBG-CV resources to meet unmet needs within your community.

Note to grantees with experience administering CDBG-DR: Unlike other disaster funds, CDBG-CV grantees do not need to follow a statutory “Order of Assistance” for delivery of different federal and non-federal programs. This means that grantees do not need to validate whether other funding sources are available or will be available before allocating CDBG-CV assistance (as opposed to CDBG-DR, where the grantee generally must check to see whether FEMA assistance was provided before making an award). The grantee is solely responsible for ensuring that an actual duplication of benefits does not occur.