Several eligible public services may be funded with CDBG-CV. For CDBG-CV and FY 2019 and 2020 annual CDBG grants, the 15 percent cap has been lifted for public services that prevent, prepare for, or respond to coronavirus. CDBG-CV funds may only be used for those public service activities that are new or that represent a quantifiable increase above the level of an existing service that has been provided by or on behalf of the unit of general local government (through funds raised by the unit or received by the unit from the state in which it is located) in the 12 calendar months before the submission of the action plan.
Emergency Grant Payments
Emergency grant payments, also known as subsistence payments, are a popular CDBG-CV activity available to grantees, as they can help prevent a family from being evicted and/or losing their home due to nonpayment of their rent or mortgage. These payments may also assist families with other essential costs, such as food, clothing, and utilities. Emergency payments may cover a series of up to six consecutive months of assistance for a household to help with rent, mortgage, utilities, and/or other subsistence support. Payment must be made to the provider (e.g., landlord, lender or utility company) on behalf of an individual or family. Emergency grant payments cannot duplicate other assistance the tenant receives for the same time period and purpose.
The period of eligibility for emergency payments begins when the payment is made, not when the arrearage began. If a household is one or more months behind on their housing-related payments, the grantee may cover some or all of the arrearages within the first month of assistance, and then provide an additional five consecutive months of assistance to exhaust the six-month period of eligibility. The date of the first payment also begins the 100-day grace period before a visual lead-based paint inspection is required.
Grantees should prioritize applicants and must deploy emergency assistance payments based on identified and documented need. As a result, grantees may use emergency subsistence payments to support individuals and families who could become homeless without the assistance. However, grantees should ensure that if housing payments are made on their behalf to bring them current, beneficiaries have the financial means to cover subsequent rent or mortgage payments and are unlikely to become homeless upon termination of the assistance.
- HUD Q & A on Using CDBG-CV Funds for Emergency Payments to a Public Utility
- HUD Q & A on Using Annual Formula CDBG, FY 2019 and 2020 CDBG to prevent, prepare for, and respond to coronavirus, and CDBG-CV Funds for Rent or Mortgage and Arrearages Subsistence-Type Payments
- CARES Act & Other COVID-19 Response Funding Chart
- Using CDBG Emergency Payments for Rental Assistance in Coronavirus Responses
- Housing Models for CARES Act Resources Quick Guide – coming soon
- Program Models: Housing Webinar
- Housing Models for CARES Act Resources Webinar – coming soon
Housing Counseling is an eligible public service activity, defined in 24 CFR 5.100 and carried out in accordance with 24 CFR 5.111. To be eligible for CDBG-CV funds, it must be provided to clients in need of assistance with their housing situation as a result of COVID-19. Housing counseling agencies are working across the country to provide clients with supports amid the pandemic. There are two primary types of housing counseling.
- Rental Housing Counseling. Housing counseling agencies can assist clients with the following topics for tenants, for example: finding and identifying housing, including affordable options; supporting clients through identification of the myriad of rental assistance available in the community; understanding fair housing laws and support with complaints; supporting tenants with tenant/landlord tenant laws and lease terms; and helping with reasonable accommodation and modification requests for persons with disabilities.
- Mortgage Forbearance and Delinquency Housing Counseling. Housing counseling can also assist existing homeowners with resolving or preventing mortgage delinquency or default, for example: foreclosure prevention strategies, loss mitigation, budgeting and credit, restructuring debt, obtaining re-certification for mortgage subsidy, and establishing reinstatement plans.
Funding food banks or pantries is an eligible public service with CDBG-CV funds. Coronavirus-related declines in income have a significant impact on families’ ability to pay for food, toiletries, and other personal care items. Many food banks use the Low-Mod Limited Clientele (LMC) national objective, in which 51 percent of program beneficiaries must be in an eligible LMC category or otherwise LMI. HUD recommends that grantees use a consistent process to document income, and the method must be detailed in your policies and procedures. HUD encourages grantees to seek documentation of income first, and if it is not possible to obtain, then allow self-certification. You may also want to explore other ways of meeting the LMC national objective, such as LMC based on nature and location. In some cases, food pantries may qualify for the Low-Mod Area Benefit (LMA) national objective if they are in and primarily serve a community that in which at least 51 percent of the population is LMI.
Personal Protective Equipment (PPE)
Providing personal protective equipment, or PPE, is an eligible CDBG-CV public service activity. The availability of PPE, such as masks and hand sanitizer, to all members of the community is critical to slowing the spread of coronavirus. Depending upon how you structure delivery of the activity, it could meet the requirements of LMC, LMA, or Urgent Need national objectives. If you use the LMC national objective, PPE recipients must confirm they are in an eligible presumed benefit category or are otherwise low-income and that there is no duplication of benefits. To meet the LMA national objective, you must define a primarily residential service area that is at least 51 percent LMI, and PPE supplies must be available to all residents of the area. For Urgent Need, you should document how the service will alleviate existing conditions that pose an immediate threat to the health or welfare of the community, that the condition is of recent origin (within the last 18 months), you are unable to finance the activity on your own, and other sources of funding are not available. You should also review the extensive discussion and guidance on recordkeeping methods to meet the Urgent Need national objective in the CDBG-CV Notice (see page 51465).