How to build your HUD CDBG-DR Action Plan for Administrative Funds and Public Action Plan
On October 29, 2021, HUD allocated over $2 billion in CDBG-DR funds appropriated by the Disaster Relief Supplemental Appropriations Act, 2022, to grantees for disasters occurring in 2020. On February 3, 2022, HUD issued an Allocation Announcement Notice and a CDBG-DR Consolidated Notice (87 FR 6364), through which they changed how grantees submit their Public Action Plans—formerly known by many as their paper or website Action Plans.
The Allocation Announcement Notice also allows grantees to submit an Action Plan for Administrative Funds prior to completing their HUD certifications—a new feature that will help grantees hire and secure the support needed to work on their Action Plans and start designing their programs as quickly as they can complete their Administrative Funds plan.
While our Federal Register Notice (FRN) Quick Guide summarizes the major requirements of the Consolidated Notice—and allows you to filter by multiple factors—this article focuses on the Action Plan for Administrative Funds and the new Public Action Plan submission procedures. Read on for practical steps and an outline you can use to complete your Public Action Plan in HUD’s Disaster Recovery Grant Reporting (DRGR) system.
Accessing administrative funds immediately: Action Plan for Administrative Funds
With this Federal Register, HUD has made it easier for grantees to access the federal funds needed to prepare an Action Plan, conduct stakeholder engagement, create the Financial Certifications and Implementation Plan, and carry out other administrative activities needed for grantees to receive an approved Action Plan. They can do this by creating a standalone Action Plan for Administrative Funds as soon as the effective date of the Federal Register allows them to do so.
Step 1: Develop the Action Plan for Administrative Funds
The Action Plan for Administrative Funds is developed outside of Disaster Recovery Grant Reporting system (DRGR).
The Action Plan for Administrative Funds must include all the following:
- All proposed uses of funds for program administrative costs incurred prior to a final Public Action Plan being submitted and approved
- The criteria for eligibility
- The amount to be budgeted for that activity
- How the use of the funds will address long-term recovery
- Calculation of need for administrative funds over the life of the grant and how much is needed in the early stage of the CDBG-DR program life cycle
Step 2: Publish the proposed Action Plan for Administrative Funds for public comment
Post the plan on the grantees’ recovery website and provide a reasonable period (no less than seven days) to solicit public feedback. Grantee should consider and respond to all comments.
Step 3: Submit the Action Plan for Administrative Funds to HUD for approval
HUD will review within 15 days from date of receipt and determine whether to approve or ask for additional information.
New procedures for Public Action Plan submission in the DRGR System
For proposed Public Action Plans, not solely specific to administrative funds, grantees will follow the new guidance that requires them to submit their plan using the DRGR system. HUD created the Public Action Plan in DRGR—a new function that allows grantees to develop and submit their Action Plans for disaster recovery directly in the system. The process is as follows:
- Similar to prior Action Plans, grantees will need to identify the use of all funds, include an unmet needs assessment, include criteria for eligibility, define allocations and award caps, describe how it will make information accessible to persons with disabilities and those with limited English proficiency, describe the method of distribution, etc. All the information will be entered into defined fields in the Public Action Plan.
- Once information is entered into the system, grantees can download the Action Plan into a publicly readable version that can be posted on their website for public review during the comment period. At a minimum, grantees are required to have one public hearing during the public comment period, which should last no less than 30 days.
- Within 120 days of the notice date, the Action Plan and other documents (e.g., SF-424, certifications, expenditure, and outcome projections) must be submitted to HUD for review and approval through DRGR. Documents will be uploaded into the DRGR system.
- After submission, HUD will take up to 60 days to review and approve the Action Plan.
- Once HUD approves the Action Plan and approves certifications, it will then sign a grant agreement obligating allocated funds to the grantee.
- For future amendments, the grantee must amend its Action Plan in the DRGR system. Each amendment must be published on the grantee’s website. Take note:
- The same requirements for a substantial Action Plan amendment still apply, but grantees can define a threshold for reallocation of funds across programs. A substantial Action Plan amendment will require a 30-day public comment period.
- Regarding nonsubstantial amendments, for changes to become effective, the DRGR system will automatically approve the amendment by the fifth day, if not approved by HUD sooner.
Major takeaways, benefits, and things to consider
The DRGR Action Plan, familiar to most grantees, is for creating projects and activities, processing vouchers, and reporting, allowing HUD to monitor grantee projects and activities for compliance and spending. The Public Action Plan differs from this because it intends to capture the narrative on how the grantee plans to use the funds.
- HUD is allowing grantees to submit an Action Plan (outside of the DRGR system) in order to access their administrative funds early.
- The new Public Action Plan feature allows grantees to use a built-in Action Plan template with a table of contents and sections developed in a standard format within the DRGR system – this should streamline the Public Action Plan with the DRGR Action Plan, adding efficiencies to grantee reporting and data management requirements.
- Grantees will likely develop their Public Action Plan outside of DRGR (such as in Word) and will then upload all their tables, graphs, maps, and narratives into DRGR. Grantees should budget a good amount of time to get familiar with the layout and requirements of each of the DRGR fields, as there are many!
- 87 FR 6364—Allocations for the Implementation of the CDBG-DR Consolidated Waivers and Alternative Requirements Notice (2-3-2022)
- 2021 DRGR Grantee Public Action Plan Training—January 28, 2022
- DRGR Manual—Chapter 11: Public Action Plan
a. FR-6303-N-01 CDBG-DR Allocations