CDBG-DR grantees are under significant pressure to get recovery funds into the community. A successful response must ramp up quickly while establishing a solid foundation that will support the effort over the longer term. You will need to scale up your operations to manage the influx of funds and stand up programs to rebuild a resilient community. Take the following actions immediately to launch your program.
The Public Law (PL) authorizing the CDBG-DR appropriation and associated Federal Register (FR) Notice detail the rules and regulations that govern the use of funds as well as any waivers to the CDBG rules. Grantees must know these rules. You may want to create a short written summary to brief public officials and staff. You should also look at previous FR Notices to see the waivers that have been granted in the past and consider if you want to request additional waivers for your programs.
The needs following a disaster will likely outstrip your available CDBG-DR funding appropriation. You will have to allocate finite resources based on a thorough analysis of unmet needs and your agency’s strategic priorities. Your CDBG-DR Action Plan will describe your analysis and your plan to allocate available funding to a combination of housing, economic development, infrastructure, and services programs. As with your annual Action Plan, you must make the CDBG-DR Action Plan draft available for public comment and address public feedback. The Action Plan will serve as the blueprint for your CDBG-DR Program and as needs evolve you will draft amendments to the plan. The Disaster Impact and Unmet Needs Assessment Kit provides guidance on how to compile your Action Plan.
Disaster Recovery Programs tend to be significantly larger than typical CDBG Programs and require specialized expertise. As a new CDBG-DR grantee, you will need to assess your business processes, IT systems, staff capabilities, and institutional infrastructure and make appropriate changes to increase capacity. You may need to expand and create new divisions, hire new staff and contractors, partner with subrecipients and establish new systems. This toolkit provides guidance on how to scale up your program operations and program staffing to support expanded operations.
Grantees need data as soon as possible to conduct the unmet needs analysis as well as comply with the prohibition on duplication of benefits. To obtain necessary data about assistance provided to homeowners, businesses, renters, and governments, you should immediately execute Memorandums of Understanding with FEMA, SBA, and insurers. See this sample request for FEMA data and a list of data sources.
Some activities undertaken prior to execution of your grant agreement may be eligible for reimbursement from your CDBG-DR allocation. As you begin your response, establish a system to track staff time spent on CDBG-DR related activities such as developing your Action Plan. You will use this system post-award to document costs for reimbursement. Your timekeeping system must align with HUD’s requirements for the Disaster Recovery Grant Reporting (DRGR) system. See the CDBG Cost Types Summary for guidance.
A lot of work goes into successfully launching, operating, and eventually closing out your CDBG-DR grant. Understanding this life cycle early in the process helps grantees to better plan and implement programs. Below are some of the key tasks that you must accomplish and should consider from the start to ensure you have adequate staff, funding, and systems in place to carry them out. The Operational Function summaries provided in the Operations module of the CDBG-DR Launch toolkit provide more details regarding key functions and their responsibilities for supporting your CDBG-DR Program.
For more on key steps to standing up your CDBG-DR Program, download Key Things to Do When You Receive CDBG-DR Funds.
