From Allocation to Grant Agreement: Accessing CDBG-DR Funds
- Published
- Feb 11, 2025
- By
- Laura Katz
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The U.S. Department of Housing and Urban Development (HUD) allocated $12 billion of Community Development Block Grant-Disaster Recovery (CDBG-DR) funds to 46 grantees on January 16, 2025. These allocated funds address unmet needs from disasters in 2023 and 2024, including Hurricane Helene and the Hawaii Wildfires.
The Universal Notice, published January 8, 2025, outlines the steps grantees must take to execute a grant agreement with HUD and begin accessing funds. The key steps in the process include action planning, financial certification, and the grant agreement.
Phase One: The Action Plan
The Universal Notice brought sweeping changes to the CDBG-DR program, including the Action Plan process. Before, grantees typically had 120 days from the applicability date of the Notice to allocate their funds and submit their Action Plan to HUD, but they now have 90 days. This shorter turnaround time means survivors will receive recovery funds faster, but it also means grantees must execute citizen engagement strategies and design programs early.
The Action Plan is the guiding document for the recovery program. It explains to HUD and the public how recovery funds will be spent, including program eligibility criteria, budgets, award caps, and how programs will address long-term recovery and mitigation. The unmet and mitigation needs assessments are two key Action Plan components that help make this connection. Analyzing disaster effects and sector needs while evaluating current and future climate threats can inform program design decisions and promote maximum fund impact.
To help grantees meet the new submission deadline, HUD is allowing some standard Action Plan sections to be covered by the grantee’s policies and procedures. These sections include expenditure projections and outcomes and information on how the grantee’s programs can affirmatively further fair housing and reduce barriers for protected classes and others.
When drafting the Action Plan, grantees should note that the 90-day timeline must include a 30-day public comment period and time to address all comments before submission. Once the Action Plan is submitted, HUD has 45 days to review and approve it.
Phase Two: Financial Certification and Oversight of Funds
Grantees must complete the Financial Management and Grant Compliance Certification Checklist within 135 days of the applicability date. This checklist confirms that the grantee has adequate financial safeguards, procurement processes, and staffing. Additionally, it shows HUD that they can prevent any duplication of benefits (DOB), maintain a comprehensive website, detect and prevent fraud, waste, and abuse, and have a timely expenditure of funds. Along with the checklist, the grantee must submit all supporting documentation, including:
- The most recent single audit
- Procurement policies
- DOB policies
- Financial management policies
Once submitted, HUD has 45 days to review the information. Certification submissions can be relied on for five years after executing a grant agreement, so if a grantee has previously submitted certifications, they might not need to complete them again.
Grant Agreement
Once the Action Plan and certifications are approved and the grantee has requested and received access to the Disaster Recovery Grant Reporting (DRGR) system, HUD will provide the grant agreement to establish the grantee’s line of credit. Grantees may begin drawing down funds once they enter into DRGR and meet all environmental review requirements.
Navigating the Next Steps
With such a condensed timeline, getting a grant agreement can be challenging, especially for first-time or smaller grantees. EisnerAmper professionals have decades of experience and understand the requirements. We’re here to help you navigate the pre-award process, from program design and community outreach to Action Plan drafting and certification completion. Contact us to learn how we can support your disaster recovery efforts.
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Laura Katz
Laura Katz is a Senior Manager in the firm’s Advisory Services Group and has nearly 15 years of experience. Laura specializes in disaster recovery and CDBG-DR grant management.
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