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Community Development Block Grant Disaster Recovery (CDBG-DR) policies and procedures are critical to program success but can be challenging to develop. Although they can be daunting, as a program administrator it’s important to view them not just as another program requirement, but as a tool for helping your program run smoothly and for accomplishing your recovery goals.

The following tips for program administrators provide a starting point for developing and implementing policies and procedures that ensure CDBG-DR program compliance from day one.

Policies should demonstrate that you have the resources and the understanding to implement your CDBG-DR program.

• Use the certification checklist issued by HUD for your CDBG-DR allocation when developing your policies and procedures to demonstrate that you have the capacity to carry out your program.
  • For a checklist example, see HUD’s certification checklist issued under the Disaster Relief Appropriations Act, 2013 (Public Law 113-2), which allocated funds to communities impacted by Hurricane Sandy.
• The checklist ensures that you can carry out:
  • Financial/audit standards
  • Procurement
  • Duplication of benefits (DOB)
  • Expenditure of funds
  • Fraud/waste
  • CDBG-DR  program website

Update your policies to adhere to federal requirements before a disaster is on the horizon.

• If your existing policies already meet federal requirements, you’ll be accustomed to following them and have fewer updates to make if your community is awarded CDBG-DR funding.
• Review your policies and procedures as soon as you receive a federal disaster grant to account for any updates to federal requirements.

Be prepared to implement new policies and pay extra attention to difficult ones.

• CDBG-DR programs require policies that local governments do not typically have in place, including policies such as:
  • duplication of benefits (DOB), environmental review, compliance and monitoring, financial management & audits, complaints, appeals, and home rehab.
• Duplication of benefits and procurement policies, which must adhere to federal requirements, are common points of mishap for grantees. Review policies from other programs when developing your own, and consider hiring a third-party to review them.
  • See IBTS’s tips on procurement policy basics for additional guidance.
• CDBG-DR policies must adhere to the most stringent regulations, whether those are federal, state, county, or city.

Don’t be afraid to ask HUD for help.

• If you have questions about policies and procedures, ask your HUD representative for assistance — they want to help you succeed.
• Be careful of how you ask questions; HUD can pay special attention to the areas you’ve asked about when they conduct audits.
• You can also use the section on policy and planning in HUD’s CDBG-DR toolkit to help develop your processes, policies, and procedures.

Regulations outlined in the Federal Register notice can be read in different ways, to your advantage or to your disadvantage.

• Much like the law, the Federal Register can be interpreted in more than one way.
• Consultants, like IBTS, can identify those places where interpretation can help you in utilizing CDBG-DR funds.
  • For example, the Federal Register might not define the type of replacement housing that funds can be applied to, giving you some leeway to define it or to ask for a waiver.
  • Or, you may be able to define “urgent need” in a way that allows you to apply funding to more projects.

Stick to the policies and procedure manual you delivered to HUD.

• Grantees are required to upload their manual to their disaster recovery website and have them readily available for HUD monitoring and audits.
• You must document that you followed the processes outlined in the manual, otherwise HUD can find you noncompliant.
• Updating your manual throughout the program is an easy process, but it’s important to keep a version history and notify HUD when you make updates.

Use your policies to help explain the program to citizens.

• CDBG-DR programs can be difficult for citizens to understand; however, clear policies and procedures prevent arbitrary decisions and can be used to justify decisions on applicant appeals and funding distribution.
  • For example, communities can have a hard time grasping that residents with a large home or expensive car may still be eligible for CDBG-DR assistance because the program is based on income, not assets. Show citizens your policy for calculating income to help them understand this.

Be prepared for HUD audits.

• Keep an electronic file and a paper file of policies and procedures, as well as documentation that you adhered to them.
• When HUD performs audits, make sure these documents are easily accessible in the format HUD requires.
  • The better things are outlined for HUD and the more consistent your documentation, the smoother the process will be.

Understand what you’ve written and what you’re trying to accomplish with each policy.

• Policies and procedures are often copied directly from programs administered in other communities. Read through what you’ve written to ensure it meets your locality’s needs and that you have a firm grasp on the policies.
• Maintain a general overview of what it is you’re trying to accomplish with each policy and how it contributes to a well-run, compliant CDBG-DR program.
  • For example, your conflict of interest policy goal is to prevent collusion, stealing, hiring friends and family, etc.
• Hire an attorney specializing in CDBG-DR to review your policies. Ensure they’re well-versed in them so they can handle any issues, should they arise.