State CDBG-CV Implementation
Unlike the annual State CDBG program, with CDBG-CV, states may use a portion of their funds to act directly through staff, contractors, subrecipients, or local governments, instead of exclusively through nonentitlement local governments. The CDBG-CV notice, however, requires that each state set aside a portion of its grant for use by nonentitlement units of general government, equal to no less than the state’s first CDBG-CV allocation. A state may also use CDBG-CV funds to carry out activities in all geographic areas of its jurisdiction, including entitlement communities and tribal areas.
With regard to the minimum nonentitlement set aside, states cannot count any portion of funds used for their own program administration and technical assistance costs towards the minimum threshold. If a state CDBG-CV grantee used a portion of its CV1 allocation for its own costs, the state must allocate sufficient funds from subsequent amounts received under CV2 and CV3 to nonentitlement local governments to ensure no less than an amount equal to the CV1 allocation is provided for their use.