August 2018, Volume 7 Issue 02

HUD-9902s, Final Grant Reporting, and Extensions

HUD-9902 Housing Counseling Agency Activity Reports

All agencies participating in HUD’s Housing Counseling programs, including grantees, must submit HUD Form 9902 (HUD-9902), “Housing Counseling Agency Activity Reports,” quarterly. HUD uses the activity data aggregated from the HUD-9902 quarterly activity reports to demonstrate the impact of the national housing counseling program to Congress, the Office of Management and Budget, and the White House. For this reason and others, HUD-9902 data should be accurate and complete. Agencies seeking help with completing this form should view the new HUD-9902 Toolkit, study the archived HUD-9902 training, and read more about it in the July 2018 issue of The Bridge newsletter.


Grant Quarterly Reports

Grantees have quarterly reporting requirements in addition to the HUD-9902. These requirements are outlined in Article XI of the grant agreement and include documentation supporting the reimbursement request, federal financial forms and LOCCS vouchers, and narratives about grant progress and challenges.

Article XI also contains details of the grant reporting timelines. Typically, grant reporting requirements begin after grant execution and continue quarterly until grant expenditure and closeout. Reports are due 30 days after the end of the quarter, with the final report due 90 days after the end of the grant performance period. If a grantee does not have financial grant activity during the early reporting periods, an abbreviated “No Activity” report may be filed.

Since FY 2018 grant funds have not yet been awarded and will have a two-year grant performance period from October 1, 2017 through September 30, 2019, grantees will want to pay special attention to Article XI Reporting Requirements for the FY 2018 grants.

Housing counseling agency staff that become proficient with both HUD-9902 reporting and grant quarterly reporting can help their agencies remain in compliance with HUD regulations, as well as:

  • Track program goals;
  • Keep performance on par to meet stated goals; and,
  • Adjust work plans as necessary.

March 31st marked the end of the FY 2017 grant performance period. Final grant reports for this performance period were due by June 30, 2018. At this time, agencies should have completed their final grant report narratives or requested an extension if FY 2017 grant funds have not been expended. Below is some pertinent information that will prove to be helpful in navigating through final grant wrap-up activities.


Oversight Agency Grant Reports

All HUD-approved housing counseling agencies that receive a grant award provide a standard set of data in their quarterly grant performance reports, but some agencies are required to report additional data collected from their network of affiliates, branches, or sub-grantees.

  • Parent agencies are responsible for aggregating quarterly grant reporting information for all sub-grantees and may establish their own procedures for obtaining data.
  • The HUD-9902 must be submitted directly to HUD through an approved Client Management System (CMS) by all participating housing counseling agencies/ subgrantees in the network providing counseling services, regardless of agency type or grant status. Housing Counseling System aggregates submitted HUD-9902 data from subgrantees into the oversight agency’s HUD-9902 report.

Final Grant Report and Narrative

The final grant report covers the entire grant’s performance and is due when the grant award is fully expended and no later than 90 days after the end of the grant period. The final grant performance report consists of the same reporting components as the quarterly reports, but includes an in-depth narrative that covers the entire grant period. The final report also includes a final SF-425 and budget. Form HUD-424-CB, or a format of the grantee’s own design can be used for the budget. A proper narrative supports the data provided in the quarterly grant reports and summarizes grant accomplishments and successes, as well as obstacles that resulted in changes from grant projections.

Tip: A final Grant Performance Report may be submitted at any point during the grant period when a housing counseling agency fully expends the awarded grant funds. A grantee does not need to continue reporting throughout the remainder of the grant performance period once funds have been expended, the final report has been submitted, and the grant is ready for closeout.


Delinquent Reports

Reports are considered delinquent if they are not submitted by the due date. However, a housing counseling agency can request an extension from their HUD Point of Contact. HUD currently requires housing counseling agencies to submit select Grant Performance Reports on a quarterly basis. However, reporting periods and due dates for these reports are specified for each Notice of Funding Availability (NOFA). Grantees should confirm reporting periods and report due dates against the applicable Notice of Funding Availability (NOFA) publication, housing counseling agency-HUD grant agreement, or confirm with their HUD POC. The grant agreement may also use the terms “Government Technical Monitor” (GTM) or “Government Technical Representative” (GTR) to refer to the HUD Point of Contact.


Extensions

Grants need to be expended by certain deadlines, and balances should be monitored frequently. If an expenditure deadline approaches and the agency still has a significant amount of money yet to be spent down, the agency should ask for a no-cost grant extension. The extension request should be made in writing and include an acceptable justification for the extension (i.e., unanticipated circumstances encountered); an explanation of how those circumstances affected the grant performance; actions the agency has taken to adjust the grant; and the timeline the grant funds are now anticipated to be expended within. Extensions are considered and granted on a discretionary basis. Unexpended funds after the completion of a grant performance period or HUD-approved extension are subject to recapture.


For more information on grant reporting, visit the Office of Housing Counseling’s Overview of Performance Reporting. There is also detailed information available to learn how to prevent recapture of grant funds, along with a Housing Counseling Webinar on Managing Expenditures and Avoiding Recapture of Housing Counseling Funds.

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