Housing and Community Development Services Training
This training program covers topics such as record-keeping, project implementation, regulations, financial management, and procurement. It aims to enhance compliance and performance for sub-recipients involved in Housing and Community Development projects. The training focuses on improving project implementation, financial management, compliance with regulations, and effective procurement practices.
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Presentation Transcript
CDBG SUB-RECIPIENT TRAINING 2018 Housing and Community Development Services
AGENDA Record Keeping Training Objectives Other Requirements Project Implementation MWBE/Section 3/ Davis Bacon Regulations Time is of the essence Financial Management Monitoring (notable issues) Procurement and Contracting ACS Orientation Property Management
TRAINING OBJECTIVES Increase compliance and enhance performance Cover shared responsibilities Identify key sub-recipient issues Use of Playing By the Rules handbook as problem- solving tool
PROJECT IMPLEMENTATION If applicable, begin procurement process as soon as the NTP is received Be prompt in signing and returning the CDBG Contract/ MOU Start as soon as you receive the Notice to Proceed (NTP) If your project includes other funds, spend CDBG first Timeliness is Key
PROJECT IMPLEMENTATION Submit invoices for reimbursement on a regular basis, monthly where possible Submit all required reports on time Spend funds within 12 months, if not sooner Seek technical assistance Work closely with your assigned CDBG Project Manager CDBG 1.5 Expenditure Standard
REGULATIONS Uniform Administrative Requirements 2 CFR Part 200 24 CFR Part 570 (supersedes, consolidates, and streamlines requirements from eight (8) OMB Circulars: A-21, A-87*, A-89, A-102, A- 110*, A-122*, A-133*, and A-50) (CDBG Program Regulations) * Previously used by CDBG sub-recipients Refer to Playing by the Rules Chapter 1
FINANCIAL MANAGEMENT Internal controls (written policies / procedures & checks and balances) Cash management- Reimbursement method Accounting records (reliable, current, complete, and adequate for reporting) Allowable costs (consistent with regulations, scope of work, allowed by grantee) Complete source documentation REFER TO PLAYING BY THE RULES CHAPTER 2
PROCUREMENT & CONTRACTING Applicable Federal regulations concerning procurement and contracting using CDBG funds can be found at 2 CFR Part 200.318 through 200.326. Follow open and free competitive process and document all activities and decisions Maintain significant history records Have written selection/protest procedures/ written code of conduct for administration Require proper bonding and insurance Ensure that supplies, equipment, professional services, and construction activities funded with CDBG are obtained efficiently and economically. If possible, use local, small, minority, and women- owned businesses REFER TO PLAYING BY THE RULES CHAPTER 3
PROCUREMENT & CONTRACTING Pre-qualified lists must follow procurement standards (current, competitive process) Exclude bidders who draft/develop specs Disqualify debarred/suspended bidders (always check SAM.GOV and print out for file!) Observe special rules for purchase types REFER TO PLAYING BY THE RULES CHAPTER 3
PROCUREMENT & CONTRACTING METHODS OF PROCUREMENT MICRO-PURCHASES SMALL PURCHASES [2 CFR 200.320 (a)] [2 CFR 200.320 (b)] of $150,000 or less in the aggregate: Acquisition of supplies or services where the aggregate amount does not exceed $3,000 Must distribute these micro- purchases equitably among qualified suppliers or vendors Can be awarded without soliciting competitive proposals if the price can be considered reasonable. Use purchase orders Competition sought through oral/written quotes Document adequate number of quotes. Record the rate or quote received along with other identifying information (name, address, phone number, website). Refer to Playing by the Rules Chapter 3
PROCUREMENT & CONTRACTING SEALED BIDS [2 CFR 200.320 (c)] Submit bid documents for HCDS review before release Formal ad for Invitation for Bid (IFB) IFB has complete/accurate specs with enough detail for bidders to properly respond Bid opened publicly at stated time/place Must receive at least two bids Award - lowest responsive/responsible bidder
PROCUREMENT & CONTRACTING COMPETITIVE PROCESS [2 CFR 200.320 (d)] RFP clearly & accurately states technical requirements for needed goods/services Evaluate, score, negotiate & award to most responsive & responsible offeror Use only if not appropriate for sealed bids Publicize to the maximum extent possible Solicit from adequate pool
PROCUREMENT & CONTRACTING NON-COMPETITIVE/ SOLE SOURCE [2 CFR 200.320 (F)] Use in very limited circumstances if .. Item/service available from single source; or Public emergency/condition of urgency; or Competition was inadequate after receiving proposals from numerous sources
PROCUREMENT & CONTRACTING PROCUREMENT & CONTRACT MUST STATE: Bonding: If construction > $100,000, a bid guarantee equal to 5% of bid price, a performance bond & payment bond equal to 100% of contract prices Section 3: For new construction/major rehab if sub-recipient receives $200K; and/or if contracts are $100K in CDBG funds Labor Standards: If construction project > $2,000 Davis-Bacon
PROCUREMENT & CONTRACTING FIVE GROUND RULES FOR GRANTEES & SUB-RECIPIENTS: Separation of duties Competencies and training Recordkeeping Fair competition Ethics and conflicts of interest Source: www.hudoig.gov/fraud-prevention/industry-advisories/procurement
PROPERTY MANAGEMENT Must be inventoried/maintained for 5 years following completion of CDBG project Property acquired/improved with CDBG funds in excess of $25,000 Must be used for intended purpose for required period Special rules apply to real property acquired by grantee agency & participating cities REFER TO PLAYING BY THE RULES CHAPTER 4
RECORD-KEEPING Keep complete/accurate/orderly records : Personnel, legal, property management General program files Administrative Records Chart of accounts, accounting procedures Journals and ledgers, bank account records Financial reports, audit files Financial Records Documentation of activities undertaken Project/ Case Files Keep records 5 years after contract expires except for real property for grantees Refer to playing by the rules chapter 5
OTHER REQUIREMENTS Independent (single) audit if $750,000 or more in federal funds expended in a year (Effective 12/26/14) Must comply with other applicable program requirements labor standards, lead-based paint, fair housing, environmental, relocation, conflict of interest, political activity, etc. Refer to playing by the rules chapter 6
RESOURCES HUD Forms: http://portal.hud.gov/hudportal/HUD?src=/program_offices/ad ministration/hudclips/forms Subparts J &K (24 CFR 570.500/513 Grant Administration): http://www.ecfr.gov
MINORITY/ WOMEN BUSINESS Minority / Women s Business Enterprises (MWBE) Annual Report [October 1 September 30] Applies to contract or subcontract > $10,000, or if it s a significant part of total project HUD Form 2516: http://portal.hud.gov/hudportal/HUD?src=/program_ http://portal.hud.gov/hudportal/HUD?src=/program_ offices/administration/hudclips/forms
SECTION 3 Wherever federal funds are used, economic opportunities will be given to Section 3 residents and businesses in that area This applies to recipients of HUD Community Planning and Development funding exceeding $200,000 or contracts exceeding $100,000 For projects involving housing construction, demolition, rehabilitation, or other public construction completed with covered funding Reporting Period: July 1 June 30
SECTION 3 PROJECTS City of Imperial Beach Rose Teeple Park City of Lemon Grove Street Rehab Project City of Poway ADA Improvements DPW Rios Canyon DPW Aviation Road DPR Don Dussault Boys & Girls Club Rehabilitation
RESOURCES A COMPLIANCE GUIDE TO SECTION 3 OF THE HOUSING AND URBAN DEVELOPMENT ACT OF 1968: Economic Opportunities for Low and Very Low Income Persons SECTION 3 WEBSITE: http://www.hud.gov/offices/fheo/section3/section3.cfm
DAVIS-BACON CDBG Projects >$2,000 Wage Rate Determination Federal Labor Standard Provisions HUD-4010 in contracts and bid documents WeeklyCertified Payroll - reviewed, signed, & dated Interviews with Employees at Construction Site (HUD-11) http://portal.hud.gov/hudportal/HUD?src=/program_offices/administration/hudclips/forms http://portal.hud.gov/hudportal/HUD?src=/program_offices/administration/hudclips/form s Documentation in Project Files http://portal.hud.gov/hudportal/HUD?src=/program_offices/administration/hudclips/forms Report semi-annually October- March April-September
DAVIS-BACON Use Certified Payroll Report (CPR) WH-347, including Federal Statement of Compliance Owner cannot self-certify his own CPR. CPR must be signed by sub-recipient If classification is not listed on the Wage Decision, contact your HCDS project manager to request HUD/DOL approval of classification Use Federal wage classification and group number listed on the Wage Decision CPR must be marked with Revised when changes are made to the original CPR previously submitted to HCDS Deductions on the CPR (ex. 401, child support) must be properly identified and authorized by employees
DAVIS-BACON PROJECTS City of Coronado - ADA Improvements City of Imperial Beach - Rose Teeple Park City of Lemon Grove Street Rehab Projects City of Poway ADA Improvements
DAVIS-BACON PROJECTS CONTINUED DPW Rios Canyon DPW Aviation Road DPR Don Dussault Park Boys & Girls Club Rehabilitation
RESOURCES MAKING DAVIS-BACON WORK: A Contractor s Guide to Prevailing Wage Requirement for Federally Assisted Construction Projects: http://www.sandiegocounty.gov/content/dam/sdc/sdhcd/docs/D avis_Bacon_Contractor_Guide_062513.pdf DOL Office of Apprenticeship: http://oa.doleta.gov State License Board: http://www.cslb.ca.gov DIR Website: http://www.dir.ca.gov Excluded Parties Search: http://www.sam.gov CWHSSA (other wage requirements) DOL Compliance Link: http://www.dol.gov/whd/govcontracts/cwhssa.htm
TIME IS OF THE ESSENCE Submit claims regularly with required backup (reimbursements only for expenditures) Requests are signed by recipient s authorized personnel Include project name and HUD Activity number Amount requested for reimbursement Submit on Agency Letterhead Reports Quarterly Year-end (CAPER) Section 3 Davis Bacon MWBE Submit key documents for approval/review Bid Documents Contracts Project scope must conform to: Board approved Annual Plan CDBG Contract
TIME IS OF THE ESSENCE Examples of Supporting Documentation Salaries Employee time cards signed by Supervisor Payroll spreadsheets Evidence of payment (canceled checks/warrants, direct deposit, bank statements, etc.) Contract Employees Copy of detailed contract Proof of payment Construction Contract Certified payrolls General Purchases Invoices Bill of Sale Proof of Payment (copy of check/warrant, electronic payment receipts, bank statement, credit card receipts, evidence of direct deposits, etc.) Non- reimbursable items Late charges Fines Penalties Charges prior to contract term
EXPENDITURE REQUIREMENT April Deadline 1.5 Reporting Accuracy Expenditure Rate Requirement Consequences Enhanced Scrutiny
MONITORING CDBG Staff Monitoring may include reviewing: Individual project files Separate accounting system National Objective documentation Procurement procedures Standards for conflict of interest Financial management Records retention Project compliance Progress reports Management Capacity Common Findings Discussion Required Back up
DISCUSSION ITEMS Modifying Project Scope Confer with HCDS Analyst before and throughout the process National Objective 5-Year Requirement
PROVIDE AS PROJECT PROGRESSES: Copy of bi-annual inventory of CDBG-acquired property (if applicable) Project progress photo Project completion photo Project Expenditure Projection (HCD form -- due prior to project commencement) 1st, 2nd, and 3rd Quarterly Reports (due 30 days after end of each quarter) CAPER Report (due 30 days after end of fiscal year ending June 30) Certification/Notice of Project Completion Cost Allocation Plan (if applicable) Single audits, if applicable, or audited financial statements if available, for periods of time that project was underway Section 3 / MWBE documents Claims every 30 days
PROVIDE AS PROJECT PROGRESSES: Formal Bid Advertisement (with bid open date) Bid and Work Specification Documents (or Request for Proposal) Significant Procurement History Documents Section 3 Certifications, if applicable Executed Contract with Successful Bidder Contract Addendum/Change Orders, if applicable Contractor Eligibility - Excluded Parties List (EPLS) Printout Contractor Bonding Document(s) Federal (Davis Bacon) Wage Decision Number Certified Payroll Reports (Form WH-347) (reviewed and submitted weekly within 7 days of receipt) Statement of Compliance (Form WH-348) Submitted weekly Record of Employee Interviews (Form HUD-11) Permits or verification that no permits are required Permit sign-offs
QUESTIONS CONTACTS: Initial Applications: Marco De La Toba Email: MarcoDelatoba@sdcounty.ca.gov Phone: (858) 694-8724 Freddy Villafan Email: Freddy.Villafan@sdcounty.ca.gov Phone: (858) 694-8747 Contract Management (COR): Myrna Manaloto Email: Myrna.Manaloto@sdcounty.ca.gov Phone: (858) 694-4810 Monitoring: Matt Munski Email: Matt.Munski@sdcounty.ca.gov Phone: (858) 694-4824 Program Oversight: Kelly Salmons Email: Kelly.Salmons@sdcounty.ca.gov Phone: (858) 694-4806
HHSA CONTRACTOR ORIENTATION Agency Contract Support (ACS) Last Updated June 20, 2017
HHSACONTRACTOR ORIENTATION CONTACT US Patty Kay Danon, Director ACS (858) 636-3530 ~ Patty.Danon@sdcounty.ca.gov AmaliaArevalo,ACS ContractAudits Unit Manager (858) 636-3536 ~Amalia.Arevalo@sdcounty.ca.gov Paulina Martinez,ACS Coordination Unit Chief (858) 636-3532 ~ Paulina.Martinez@sdcounty.ca.gov Christy Carlson, Group Program Manager, Compliance (619) 338-2807 ~ Christy.Carlson@sdcounty.ca.gov
