Multifamily Housing Program Financial Management Toolkit

15b. Requirements Related to the Financial Management of HUD Grants and Awards

SCMF program grantees should be operating in compliance with Generally Accepted Accounting Principles and state-mandated accounting guidelines. This Toolkit focuses primarily on Federally mandated guidance. Our goal is to communicate grantee responsibilities clearly and concisely, with links to online documents where source materials and additional guidance may be found and studied.

What Are the Primary Sources of Guidance for Grantees Related to Accounting Practices?

Primarily as result of receiving Federal funds, SCMF grantees and sub-recipients/contractors are required to adhere to a range of accounting principles, practices and standards. From an accounting standpoint, there are four primary sources of guidance for a grantee:

  • Generally Accepted Accounting Principles (GAAP)
  • OMB’s ‘Omnibus Circular’ (2 CFR Part 200)
  • SCMF program guidance and contract documents
  • State and agency-specific accounting guidelines and requirements

Underlying Statues Related to the SCMF Program

SCMF activities are authorized under the following statutes, and thus the finance-related requirements in these laws apply:

  • National Affordable Housing Act, Section 808 (Public Law 101-625),
  • 1992 Housing & Community Development Act (Public Law 102-550), American Homeownership & Economic Opportunity Act of 2000, Section 851 (Public Law 106-569)

What Is the Management Agent Handbook and How Does It Apply to SCMF Grantees?

HUD’s Management Agent Handbook (Number 4381.5) is the primary guide for operating an SCMF Program. Chapter 8 of the Handbook provides the procedures for both requesting Service Coordinator funding and operating a program in HUD assisted housing. It also provides the requirements and recommended course work for statutorily mandated Service Coordinator training and continuing education.

What Are the Primary Areas of Focus in this Section?

Since the overarching accounting guidelines contained in OMB circulars are covered in Parts I and II of this Toolkit, in Section 15 we focus on guidance specific to the Service Coordinator Program. SCMF is a program that has evolved over time. Additional key documents are cited as references in the subsections that follow.
From a financial management perspective, there are four primary areas of concern to HUD related to the Service Coordinator Program:

  • Sources of revenue to cover SCMF operating costs (15c)
  • Allowability and Documentation of expenses (15d)
  • Internal Controls (15e)
  • Timeliness and accuracy of drawdowns and reporting (15f-h)