Section by Section Summary of the 2013 HOME Final Rule: Subpart K - Program Administration

§92.500 The HOME Investment Trust Fund

Interest Bearing Local HOME Accounts

§92.500(c)(1) creates a new requirement that local HOME accounts be interest bearing.

Suggested Next Steps for PJs

  1. Determine whether or not the local HOME account is interest-bearing. If it is not, create a new local account.

  2. Verify that the PJ’s internal accounting system is set up to track and record in IDIS interest to be earned as program income.

Effective Date

August 23, 2013

Separate Expenditure Deadline for CHDO Set-Aside Funds

To provide an incentive for PJs to proactively manage CHDO set-aside funds by moving them from nonperforming CHDOs to performing CHDOs before they expire, HUD has added a new requirement at §92.500(d)(1)(C) to establish a separate 5-year expenditure deadline for CHDO set-aside funds. HUD will deobligate amounts equal to the shortfall and reallocate them in accordance with the provisions of the National Affordable Housing Act (NAHA, the HOME statute) and implementing regulations.

Suggested Next Steps for PJs

  1. Review existing projects in the development pipeline to flag any projects that might be stalled or at risk of not being completed by the five-year expenditure deadline.

  2. Review and revise policies and procedures for committing and tracking CHDO set-aside projects to ensure that set-aside funds are committed and expended timely. (See §92.2, definition of commitment.) The "Deadline Compliance Status Reports” are available online at https://www.hudexchange.info/programs/home/home-deadline-compliance-status-reports/.

  3. Incorporate a "checkpoint” in the program procedures to ensure that stalled CHDO projects are identified early enough that funds can be reallocated if needed.

Effective Date

HUD will implement the five-year deadline for expenditure of CHDO set-aside funds beginning January 1, 2015. HUD will begin posting "Deadline Compliance Status Reports” significantly in advance of this date, so that PJs have an opportunity to reallocate funds among CHDOs as necessary.

Reducing or Recapturing CHDO Set-Aside Funds

The 2013 Rule revises §92.500(d)(2) to better describe the method of calculation that HUD uses to determine compliance with commitment (including CHDO commitment) and expenditure deadlines.

Suggested Next Steps for PJs

None needed.

Effective Date

August 23, 2013

§92.502 Program Disbursement and Information System    

Program Income

Modifications to §92.502(a) clarify and codify existing HOME policy that PJs must report all program income earned on HOME funds in IDIS.

Suggested Next Steps for PJs  

  1. Review financial policies and procedures related to the deposit and expenditure of program income to be sure that all program income earned is recorded in IDIS.
    1. If it is, no action is needed.
    2. If it is not, establish a system for recording program income in IDIS and a verification procedure to ensure that this step is taken.
  2. See §92.500(c)(1) and ensure that interest is included in the determination of program income, and is also recorded in IDIS.

Effective Date

 August 23, 2013 (PJs must record in IDIS all program income received after this date.)

Access to IDIS

Revisions to §92.502(e) clarify that although other program participants may be permitted to access IDIS, only PJs and State recipients (if permitted by the State) may access IDIS to request disbursement. This provision codifies HUD’s longstanding IDIS administrative guidance.

Suggested Next Steps for PJs

  1. Review the IDIS policies and procedures and review IDIS report PR30, "Security Administrator User Profile List,” to verify that only PJs and State recipients (if approved by State) have access to request disbursement in IDIS.
    1. If this is the case, no action is needed.
    2. If it is not, notify affected program partners of clarification and limit IDIS access immediately.

Effective Date

August 23, 2013

§92.503 Program Income, Repayments, and Recaptured Funds

§92.503 is revised to provide that, when a PJ is required to repay HOME funds, HUD will instruct the PJ whether to repay funds to the HOME Investment Trust Fund Treasury account or the local account. Under the pre-2013 Rule, the PJ was required to repay funds to the account from which they were initially drawn.

Suggested Next Steps for PJs

  1. Revise financial policies and procedures to state that when HOME funds must be repaid, the PJ must contact HUD to determine to which account the funds must be repaid.

  2. Notify affected staff of this change.

Effective Date

August 23, 2013

§92.504 Participating Jurisdiction Responsibilities; Written Agreements; On-Site Inspections

Required Policies and Procedures Related to PJ Responsibilities

The 2013 Rule revises §92.504(a) to:

  • Require PJs to develop and follow written policies, procedures, and systems, including a system for assessing risk of activities and projects, and a system for monitoring entities (e.g., subrecipients, CHDOs and project owners), to ensure that HOME requirements are met.

  • Make explicit that State recipients are included in the entities that must be evaluated annually.

  • Clarify that the evaluation must include a review of each entity’s compliance with HOME program requirements.

Under the pre-2013 Rule, PJs were responsible for ensuring that all program funds were used in compliance with HOME requirements and for reviewing the performance of HOME-funded entities. The changes to this provision impose more specific requirements on PJs to strengthen their performance in this area and improve oversight of program partners.

Suggested Next Steps for PJs

  1. Develop or revise written policies, procedures, and systems for monitoring HOME-funded entities; include a process to assess risk of activities and projects that will guide decisions about which entities to monitor on-site, and the nature of the monitoring visit. The policies and procedures should reflect:

  2. All HOME-funded entities must be monitored at least annually: State recipients, subrecipients, developers, owners, sponsors, and contractors.

  3. PJs can use a combination of site visits and desk reviews to undertake monitoring efforts.

  4. The plan and system should identify the staff responsible for monitoring efforts, when the monitoring will be done, the nature of the monitoring effort (program administration, financial, project monitoring, etc.) and how it will be done (on-site vs. desk review).

  5. Consider the monitoring needs of projects that are in process, and those that are completed and in the affordability period. [For the latter, be sure to incorporate the on-site inspection requirements of §92.504(d).]

  6. Look for additional HUD guidance to be issued in this area and update policies and procedures as needed.

Effective Date

July 24, 2014 (12 months following the publication of the Final Rule)

Written Agreements

A number of additions and revisions have been made to the required written agreement provisions established in §92.504(c). The provisions listed in this section must be included in PJs’ written agreements committing HOME funds to State recipients, subrecipients, owners, developers, sponsors, contractors, and CHDOs. Many of these changes are intended to improve HOME written agreements so that they are more effective tools for program compliance, management, and enforcement. Other changes are made to conform to programmatic changes made by this Rule.

State recipient

The following amendments have been made to the provisions required in the agreement between a PJ and a State recipient:

  • Overview. Under the pre-2013 HOME Rule, a State PJ has the option to impose requirements on State recipients to ensure that they comply with HOME requirements or to allow the State recipient to develop its own requirements to ensure compliance with the program. This option has not changed. However, this section is revised to clarify that the State must specify the following HOME requirements in its agreement: income determinations, underwriting and subsidy layering review, rehabilitation standards, refinancing standards, homebuyer program policies, and affordability.

  • Use of HOME funds.  §92.504(c)(1)(i) is revised to require that written agreements include greater detail about the State recipient’s use of HOME funds, including amounts and uses for specific programs and activities (downpayment assistance, affordable housing development, tenant-based rental assistance, etc.), the number of housing projects to be funded or loans to be made, and any requirements for matching contributions. The State PJ must also include the elements established in the pre-2013 Rule: tasks to be performed, schedule for completion, and budget for each program.

  • Affordability. §92.504(c)(1)(ii) is revised to require that the written agreement specify whether repaid and recaptured HOME funds must be returned to the State PJ or retained by the State recipient and expended on eligible activities.

  • Written agreements. §92.504(c)(1)(xi) requires a State recipient to enter into a written agreement that complies with the provisions of §92.504(c) with any other entity or individual to which it disburses HOME funds. This is not a new requirement. The revision to this section specifies that this agreement must be in place before the HOME funds are provided.

  • Fees.  §92.504(c)(1)(xiii) is a new provision that requires the written agreement to include a provision to implement the prohibition against charging fees in §92.214(b), as revised under this Rule.

Suggested Next Steps for PJs

  1. If the PJ is a State and uses State recipients, review the standard language of the agreement used with State recipients.

  2. Revise the written agreement template to reflect these new requirements.

  3. Notify State recipients of the changes to future written agreements to be sure that the new requirements are clearly understood.

  4. Notify monitoring staff of these changes and be sure that the new requirements are reflected on any monitoring checklists for monitors when they review compliance with written agreements executed after the Effective Date of these requirements.

Effective Date

August 23, 2013 (PJs must use the new written agreement for all projects to which HOME funds are committed after this date.)

Subrecipients

§92.504(c)(2) is revised to require that written agreements with subrecipients contain the same new or revised provisions that are modified in the State recipient agreements, described above. In addition, agreements with subrecipients must include requirements that subrecipients must follow to enable PJs to carry out their environmental review responsibilities before HOME funds are committed to a project. The specific amendments include:

  • Overview. §92.504(c)(2) is revised to specify that the PJ’s written agreement with the subrecipient must set forth requirements applicable to the subrecipient. These must include requirements for: income determinations, underwriting and subsidy layering guidelines, rehabilitation standards, refinancing guidelines, homebuyer program policies, and affordability requirements.

  • Use of HOME funds. §92.504(c)(2)(i) is revised to require that written agreements include greater detail about the subrecipient’s use of HOME funds, including amounts and uses for specific programs and activities (downpayment assistance, affordable housing development, tenant-based rental assistance, etc.), the number of housing projects to be funded or loans to be made, and any requirements for matching contributions. The PJ must also include the elements established in the pre-2013 Rule: tasks to be performed, schedule for completion, and a budget for each program.

  • Other program requirements.§92.504(c)(2)(iv) requires the written agreement to state that the subrecipient must comply with all federal laws and regulations that are described in subpart H of the HOME Rule, with the exception of the environmental review responsibilities, which reside with the PJ. This requirement has not changed. However, this provision is revised to clarify that the agreement must specify the requirements imposed on the subrecipient to enable the PJ to carry out the environmental review before HOME funds are committed.

  • Written agreements. §92.504(c)(2)(x) requires a subrecipient to enter into a written agreement that complies with the provisions of §92.504(c) with any other entity or individual to which it disburses HOME funds. This is not a new requirement. The revision to this section specifies that this agreement must be in place before the HOME funds are provided. The revision also clarifies that the written agreement must specify whether repaid and recaptured HOME funds must be returned to the PJ or retained by the subrecipient and expended for additional eligible activities.

  • Fees.  §92.504(c)(2)(xi) is a new provision that requires the written agreement to include a provision to implement the prohibition §92.504(c)(3)(i)on charging fees in §92.214(b), as revised under this Rule.

Suggested Next Steps for PJs

  1. If the PJ uses subrecipients, review the standard language of the agreement used with subrecipients.

  2. Revise the written agreement template to reflect these new requirements.

  3. Notify subrecipients of the changes to future written agreements to be sure that the new requirements are clearly understood.

  4. Notify monitoring staff of these changes and be sure that the new requirements are reflected on any monitoring checklists for monitors when they review compliance with written agreements executed after the Effective Date of these requirements.

Effective Date

August 23, 2013 (PJs must use the new written agreement for all projects for which HOME funds were committed after this date).

For-profit or nonprofit housing owner, sponsor, or developer (other than single family owner-occupant)

In addition to the inclusion and clarifications of the provisions common to the subrecipient and State recipient agreements, §92.504(c)(3) clarifies that the preliminary award of HOME funds (i.e., early awards of HOME funds before other necessary sources of financing have been secured) does not constitute a "commitment” pursuant to the definition at §92.2 and may not be entered into IDIS until a legally binding written agreement containing all required provisions is executed. The specific amendments include:

  • Use of HOME funds. §92.504(c)(3)(i) provides additional information that is needed to describe the use of HOME funds, including the address or legal description of the project site, use of both HOME funds and other funds in the project, and a complete budget. (Emphasis added reflects the Rule revisions.) The previous elements of this provision still must be included: tasks to be performed and schedule for completion.
     
  • Affordability. This provision, at §92.504(c)(3)(ii), is revised to specify that the written agreement must state that the affordability requirements must be imposed by deed restriction, use restrictions, covenants running with the land or other legal mechanisms approved by HUD under which the PJ has the right to seek specific performance. (Emphasis added to reflect the Rule revision.)
    • For rental projects, the 2013 Rule amends §92.504(c)(3)(ii)(A) to require that the written agreement specify the number and size of HOME-assisted units and the designation of units as "fixed” or "floating.” In addition, the agreement must require the owner, developer, or sponsor to provide the address of each unit to the PJ by the time of project completion. In the pre-2013 Rule, the PJ was required to specify the initial rents and the procedures for rent increases in the written agreement. The written agreement must also specify that the PJ must review rents for compliance and approve/disapprove them each year, in accordance with the new requirement at §92.252(f)(2).
    • For homeownership projects, the existing requirement for the agreement to state the resale or recapture provisions that must be imposed on the housing remains unchanged. The 2013 Rule amends §92.504(c)(3)(ii)(B) to add several new provisions to the agreement. The agreement must clearly state the sales price or, if it is not known, the basis on which the sales price will be established; the required disposition of sales proceeds; and that any funds that are recaptured must be returned to the PJ.
  • Project requirements. In general, this provision at §92.504(c)(3)(iii) remains unchanged and requires compliance with all HOME project requirements at subpart F of the regulation. This provision is amended, however, to state that the written agreement may permit the owner to limit the eligibility or give a preference to a particular segment of the population in accordance with changes made to §92.253(d).
     
  • Records and reports. This provision, at §92.504(c)(3)(vi), is revised to list a number of specific reports that the PJ must require the owner to submit:
    • Annual report on rents and occupancy of HOME-assisted units to verify compliance with affordability requirements
    • If the project has floating HOME units, information on unit substitution and filling vacancies to ensure that the project maintains the required unit mix
    • Reports (including financial reports) that enable the PJ to determine the financial condition and continued financial viability of the rental project.
  • Enforcement of the agreement.  §92.504(c)(3)(vii) is amended to add use restrictions as an eligible enforcement mechanism so that the PJ has the right to demand specific performance. The pre-2013 Rule permitted only deed restrictions and covenants running with the land, and other mechanisms approved by HUD. These options continue to be eligible.
     
  • Community housing development organizations. §92.504(c)(3)(x) is amended to add several specific provisions that must be included in an agreement with a CHDO that develops homeownership housing:
    • Whether the CHDO may retain proceeds from the sale of units
    • Whether the proceeds are to be used for HOME-eligible or other housing activities to benefit low-income families
    • Recaptured funds are subject to §92.503(c)—that is, the funds must be returned to the PJ and used for other HOME-assisted housing activities.

The other CHDO requirements of the pre-2013 Rule have not changed. These require the written agreement to specify the terms of CHDO set-aside funds (§92.300) and project-specific assistance funds (§92.301). The 2013 Rule adds the requirement that the written agreement clearly state the requirements for tenant grievance procedures and a tenant participation plan (§92.303).

  • Fees.  §92.504(c)(3)(xi) is a new provision that requires the written agreement to prohibit owners from charging fees that are not customary. For rental housing, owners can charge: reasonable application fees to prospective tenants; other fees (such as parking fees) only to the extent that they are reasonable and customary for the project area; and fees for services provided to tenants, provided that these services are not mandatory. For homeownership projects, the developer cannot charge servicing, loan origination, processing, inspection, or other fees that represent the cost of providing HOME assistance.

Suggested Next Steps for PJs

  1. Review the standard language of the agreement used with owners, developers, and sponsors of HOME-assisted housing.

  2. Revise the written agreement template to include the new HOME requirements.

  3. Notify owners, developers, and sponsors of the changes to future written agreements to be sure that the new requirements are clearly understood.

  4. Notify monitoring staff of these changes and be sure that the new requirements are reflected on any monitoring checklists for monitors when they review compliance with written agreements executed after the Effective Date of these requirements.

Effective Date

August 23, 2013 (PJs must use the new written agreement for all projects for which HOME funds were committed after this date.)

Contractors

A minor revision is made to §92.504(c)(4) to clarify the applicability of the provision. A written agreement is required with contractors that are administering all or some of the PJ’s HOME program (the pre-2013 regulatory requirement) and for contractors who are undertaking specific services for one or more programs. For instance, a contractor that is hired to underwrite rental projects is not administering part of the HOME program, but is carrying out a specific service for the program. This revision clarifies that these types of contractors are covered by this provision.

Suggested Next Steps for PJs  

  1. Confirm that there is a written agreement with all contractors to whom the PJ will provide HOME funds, including those that provide specific services for one or more programs.

  2. Verify that these written agreements meet the requirements of §92.504(c)(4).

Effective Date

August 23, 2013 (PJs must use the new written agreement for all projects for which HOME funds were committed after this date.)

CHDOs Receiving Assistance for Operating Expenses

A new paragraph §92.504(c)(6) is added that enumerates the required provisions for written agreements when a PJ is providing operating expense funds to CHDOs, pursuant to §92.208. The new paragraph requires that the agreement with the CHDO describes the uses of operating funds. These might include salaries, wages, employee training, rent, and utilities and other operating costs. The agreement must state that the CHDO is expected to received HOME funds for a project that it is to own, develop, or sponsor within 24 months, as required in §92.300(e). The written agreement must also describe the terms and conditions upon which this expectation is based, and the consequences of failure to receive funding for a project. If the CHDO is also receiving CHDO set-aside for a specific project, a separate agreement must be executed.

This is a new provision. Under the pre-2013 Rule, a PJ was required to execute an agreement with a CHDO receiving operating assistance, in accordance with §92.504(a). However, the pre-2013 Rule did not specify what provisions were required in that agreement.

Suggested Next Steps for PJs

  1. If the CHDO provides operating assistance to CHDOs, develop a standard written agreement to use to govern these funds.

  2. Be sure the nonprofit is a qualified CHDO, in accordance with the revised requirements at §92.2, definition of a CHDO.

Effective Date

 August 23, 2013 (PJs must use the new written agreement for all projects for which HOME funds were committed after this date.)

On-Site Inspections

§92.504(d) is revised substantially to provide PJs more flexibility in designing risk-based inspection strategies. The revisions include:

  • Required inspections. The PJ must inspect each HOME project at the time of completion and during the period of affordability to determine compliance with the property standards applicable under §92.251.

  • The inspection schedule. The 2013 Rule specifies the frequency of property inspections.

  • Sample sizes. The 2013 Rule specifies the sample size required for inspection of HOME-assisted units.

These changes align the HOME inspection requirements more closely with the Low-Income Housing Tax Credit requirements, in terms of frequency and sample sizes.

These requirements differ significantly from the requirements of the pre-2013 Rule. Previously, PJs were permitted to determine how many units (sample size) to inspect at each property and the frequency of inspections was based on the number of units in the project.
Each of these requirements is described in more detail below.

Required Inspections

The new §92.504(d)(1) requires PJs to conduct on-site inspections of HOME-assisted properties.

  • Project completion inspections. Upon completion of the project, the PJ must conduct an on-site inspection to confirm that contracted work is completed and the property meets the property standards specified in §92.251.

  • Ongoing property inspections. On an ongoing basis throughout the period of affordability, the PJ must conduct on-site inspections to determine that the property meets the property standards adopted by the PJ pursuant to §92.251(f) and to verify the information submitted by the owners regarding rent, occupancy, and unit mix. The inspections must be done in accordance with the PJ’s inspection procedures required at §92.251.

Inspection Schedule

The 2013 Rule provides the following requirements related to timeframes and schedules for inspections.

  • Frequency of inspections. The first on-site ongoing inspections must occur within 12 months after project completion, and an inspection must be conducted at least once every three years thereafter.

  • Follow up to address deficiencies. If any deficiencies are identified for any inspectable items (as established in the PJ’s inspection procedures), a follow-up on-site inspection is required within 12 months. For non-hazardous deficiencies, the PJ can either conduct an on-site inspection or accept third party documentation (such as a paid invoice for work completed).  

  • Health and safety deficiencies. Health and safety deficiencies identified during inspections must be corrected immediately. The PJ must adopt a more frequent inspection schedule for these properties.

  • Annual certification. Property owners must submit an annual certification to the PJ that each building and all HOME-assisted units in the project are suitable for occupancy.

Sample Sizes

For each inspection visit, the PJ must determine how many HOME-assisted units must be inspected in the project (for inspectable items--site, building exterior, building systems, and common areas) within these parameters:

  • For projects with one to four units, the inspectable items for each building with HOME-assisted units and 100 percent of the HOME units must be inspected.

  • For projects with more than four HOME-assisted units, the inspectable items for each building with HOME-assisted units and at least 20 percent of the HOME-assisted units in each building, but not fewer than four units in each project and one HOME-assisted unit in each building.

HUD plans to issue guidance about appropriate sampling for the purposes of ongoing physical inspections of HOME-assisted units. PJs may contract with third parties to conduct these inspections and, in the future, inspections performed by other funders may be permitted once administrative alignment of inspection standards and guidelines at the federal level has been achieved. PJs may establish inspection schedules that involve more frequent inspections or larger sample sizes.

Annual Inspections for TBRA Units

§92.504(d)(1)(iii) is revised to conform the reference to the applicable property standards at 24 CFR 982.401 (HQS) or any successor requirements imposed by HUD. The requirement for annual on-site inspections of housing occupied by TBRA recipients to determine compliance with property standards has not changed.

Financial Oversight

A new requirement is imposed pertaining to annual financial oversight of HOME-assisted rental properties during the affordability period in §92.504(d)(2). At least annually, the PJ must examine the financial condition of HOME-assisted rental projects with 10 or more HOME-assisted units to determine the continued financial viability of the project.

The purpose of this requirement is to enable PJs to identify HOME-assisted projects that may become financially troubled before problems become severe. If the financial review indicates potential problems, PJs must take actions to correct those problems, to the extent feasible.
HUD will provide guidance and training on how to implement this requirement.

Suggested Next Steps for PJs

  1. Prior to the Effective Date of this requirement (12 months following publication of 2013 Rule), look for HUD guidance in this area.
  2. Review the PJ’s current policies and procedures on monitoring projects that are in the affordability period. [This may be part of the PJ’s monitoring plan or may be stand-alone procedures.]

  3. Begin informal assessment of the current inventory of HOME-assisted housing with 10 or more HOME units, and start to think about which properties should be given priority for a review of financial condition.

  4. Begin to plan for how staff will be trained in the new inspection and financial monitoring functions.

  5. The TBRA inspections procedures should remain the same, with annual inspections to ensure conformance with HQS.

  6. Look for additional guidance from HUD on this issue, and revise and update policies and procedures as needed.

Effective Date

 July 24, 2014 (PJs must conduct physical inspections following the new procedures and evaluate the financial condition of all projects to which funds are committed on or after this date.)

§92.505 Applicability of Uniform Administrative Requirements

§92.505(a) and (b) are revised slightly to add a reference to the regulations that implement OMB Circular No. A-87 (2 CFR part 225) and OMB Circular No. A-122 (2 CFR part 230). This is a technical revision that makes no changes to the applicability of the uniform administrative requirements.

Suggested Next Steps for PJs

  1. In written agreements with State recipients and subrecipients that are subject to these uniform administrative requirements, use the updated regulatory references.

Effective Date

August 23, 2013 (Use the updated regulatory citations in written agreements for all projects for which HOME funds are committed after this date.)

§92.508 Recordkeeping

Revisions to §92.508 require PJs to maintain records that correspond to the new requirements that are established under the 2013 Rule. These are necessary for HUD to monitor compliance with these new requirements. The following revisions have been made to the recordkeeping requirements:

Program Records

  • §92.508(a)(2)(ii) is revised to specify that program records must include HUD’s written approval if the PJ uses a form of assistance that is not listed in the HOME regulation, as required by §92.205(b).

  • §92.508(a)(2)(iii) is revised to specify that the program records must include underwriting guidelines to correspond to changes in §92.250 that require PJs have underwriting and subsidy layering guidelines.

Project Records

  • §92.508(a)(3)(i) is revised to specify that the project records must include the location (address or legal property description) of the HOME-assisted units.

  • §92.508(a)(3)(ii) is revised to specify that project records must include documentation for the eligibility and permissibility of project costs, including documentation of actual HOME-eligible development costs of each HOME-assisted unit (through cost allocation, if applicable) in projects with both HOME-assisted and non-assisted units.

  • §92.508(a)(3)(iii) is revised to specify that the project records must include the underwriting evaluation that is performed in accordance with §92.250(b).

  • §92.508(a)(3)(iv) is revised to specify that project records must include records (copies of inspections reports) that demonstrate that HOME-assisted properties are in compliance with property standards upon project completion. During the period of affordability, records must be retained that document compliance with ongoing property inspections and annual financial reviews.

  • §92.508(a)(3)(vi) is updated to specify that project records must reflect the option in §92.209(c)(2) for PJs to target certain populations for TBRA and to clarify record requirements related to property inspections.

  • §92.508(a)(3)(xiv) is added to specify that project records must include copies of written agreements with funded entities to document compliance with the written agreements requirements of §92.504.

Program Administration Records

  • §92.508(a)(6) has been added to require PJs to document that program administration requirements have been met; records should contain copies of written policies, procedures, and systems, including risk assessment and a system for monitoring entities.

Suggested Next Steps for PJs

  1. Update the following documentation to include the additional records requirements, to ensure that these records are retained to demonstrate compliance with the new HOME requirements:
    1. Policies and procedures related to retaining program, project, and administrative records
    2. Written agreements with program partners, to ensure that partners retain the necessary records to demonstrate compliance with the new requirements
    3. Checklists and tools used by staff to help them ensure they retain the necessary records.  
  2. Notify the monitoring staff of these new requirements and update monitoring checklists to ensure compliance reviews.

Effective Date

August 23, 2013

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