Developing and Implementing a CDBG Workout Plan

Page created by Michele Davis
 
CONTINUE READING
$

$

            $                            Developing and
                                        Implementing a
        $        $
                         $
                                             $
                                     CDBG Workout Plan
                                                                       $
    $                            $
                                                      Guidelines for Putting
$                                        $
                                             Your Community Development
                                     $
    $
                             $                          Block Grant Program
            $        $

                                                                      on the Road
                                                                    to Timeliness

        U.S. Department of Housing and Urban Development
        Mel Martinez, Secretary
        Roy A. Bernardi, Assistant Secretary for Community Planning and Development
$           $                $
Developing and                                                           $                                                $
Implementing a
                                                                     $                                                                $
CDBG Workout Plan
Guidelines for Putting Your                                                $                                                  $
                                                                                                                  $
Community Development                                                                 $           $
Block Grant Program on the
Road to Timeliness

Introduction                                      ❉ Leading you through the process of
                                                    analyzing your program to identify the
    ities and counties that receive entitle-

C   ment funds from the Community Devel-
    opment Block Grant (CDBG) program
are required by statute to use their funds in
                                                    causes for delays, the opportunities for
                                                    spending funds more quickly, and the
                                                    actions you can take to hasten the draw-
                                                    down of CDBG funds.
a timely manner. By running a timely local
program, grantees promote the goals of the        ❉ Focusing your attention on the problem
CDBG program by improving the lives of              areas of your program that have pro-
residents of the community, particularly            duced the excess funds backlog and on
those of low and moderate income.                   what needs to be done to address them.

    Some communities, however, fall behind        ❉ Providing the specific information HUD                    $       $
                                                                                                                              $
in the timely expenditure of their CDBG             will need to conclude that you can suc-               $                           $

funds. If they fail to pass the timely expendi-     ceed in bringing your program into com-           $                                       $

ture test at 24 CFR §570.902, HUD may re-           pliance 60 days prior to the end of your                                              $
                                                                                                          $
quire the community to construct a Workout          next program year.                                            $       $
                                                                                                                                  $

Plan for reducing its funds backlog to within
the regulatory standard. This publication         ❉ Providing you with a baseline for assess-                 $       $
                                                                                                                              $
                                                                                                          $
provides guidelines for preparing a Workout         ing your progress against the Workout                                             $

Plan acceptable to HUD.                             Plan and for reporting such progress to           $                                       $

                                                    HUD.                                                                                  $
                                                                                                          $
                                                                                                                                  $
                                                                                                                  $       $

Purposes of a Workout Plan
     The main purpose of a Workout Plan is
                                                  Working Your Way Out of a CDBG Funds Backlog                $       $
                                                                                                                              $
                                                                                                          $                           $
to help you bring your CDBG program into              Working your way out of a funds backlog
compliance with the CDBG timeliness stan-         takes a real effort on your part. However, if       $                                       $

dard, which requires that you have no more        you follow the steps described below you will           $
                                                                                                                                          $
                                                                                                                                  $

than 1.5 times the amount of your last annu-      have developed a Workout Plan that not                          $       $

al grant in your CDBG line of credit 60 days      only brings you into compliance, but also, in
prior to the end of your current program          the long run, will strengthen your program
year. Preparing a Workout Plan will help          management capabilities.
accomplish this goal by:

                                                                                                                      1
$       $
                        $
                                                                  Developing and Implementing a CDBG Workout Plan
    $                           $

$                                       $
                                            Finding the Causes                                   thereby freeing funds for faster moving
    $
                                    $
                                                 Communities with a serious backlog of           projects?
                            $
            $       $
                                            unspent funds need to find the underlying        ❉ Do you have any other projects already
        $       $
                        $
                                            causes, and do so quickly. The longer it takes     under way that could use freed-up funds
    $                           $           to identify the causes and to choose an alter-     quickly?
$                                       $   native course of action, the less time you
                                    $
                                            have available to implement the Workout          ❉ Do you have backup projects in the
    $
            $       $
                            $
                                            Plan. An honest assessment of your projects,       Consolidated Plan that can use funds
                                            program administration, and management             available for reprogramming?
        $       $
                        $
                                            capacity should be undertaken. If you do not
    $                           $                                                            ❉ What steps do you need to take to rapid-
                                            identify the most likely causes of your prob-
$                                       $                                                      ly identify other projects not in your cur-
                                            lem and realistic remedies, you may not only
                                    $                                                          rent program that could be implemented
    $
                            $               be unsuccessful in eliminating your excess
            $       $                                                                          quickly with freed-up funds? Make sure,
                                            backlog, but you also may be unable to avoid
                                                                                               however, you do not substitute one prob-
                                            becoming untimely again. This assessment
                                                                                               lem for another. Once identified, list the
                                            will entail looking at all of your CDBG-
                                                                                               projects in your Consolidated Plan so
                                            funded activities as well as how you carry
                                                                                               they will be ready to go when funds
                                            them out. Some key issues and questions you
                                                                                               become available.
                                            need to consider in this assessment process
                                            include:                                         ❉ Have you identified all unprogrammed/

                                                                                                                                      $
                                                                                               surplus funds and program income?
                                            1. Identifying and responding to
                                               problematic projects                          ❉ Have you determined whether you need
                                                                                               an amendment to your Consolidated
                                            ❉ Do you have a schedule for each project?
                                                                                               Plan?
                                              If you don’t, that is part of your problem.
                                                                                             2. Identifying and responding to systemic
                                            ❉ Which projects are significantly behind
                                                                                                problems
                                              schedule? Which are contributing the
                                              most to your backlog problem?                  ❉ Does your annual program schedule pro-
                                                                                               vide sufficient time to identify and refine
                                            ❉ What actions can you take to move
                                                                                               prospective projects that can be carried
                                              these projects along faster?
                                                                                               out without risking delays?
                                            ❉ If the delays cannot be overcome quick-
                                                                                             ❉ Are you working closely enough with
                                              ly, can any of the projects be restruc-
                                                                                               other parties running your projects, both
                                              tured to defer some portions to another
                                                                                               within and outside local government, to

                                                                                                                  $
                                              year, freeing up the funds for other uses?
                                                                                               enable quick identification of delays and
                                            ❉ Should one or more projects be termi-            their causes?
                                              nated so that the unspent funds can be
                                                                                             ❉ Are you getting the information you
                                              reprogrammed? Are there any not-yet-
                                                                                               need from implementing entities to keep
                                              started, time-consuming projects that
                                                                                               track of expenditures so that you can
                                              could be moved to a future program year,
                                                                                               draw down on a regular basis throughout
                                                                                               the year?

                2
Developing and Implementing a CDBG Workout Plan                                                         $       $
                                                                                                                        $
                                                                                                    $                           $

❉ Are you regularly reviewing the progress      ❉ Do any of your subgrantees have on            $                                       $

  of each funded project against a project-       hand a large amount of program income             $
                                                                                                                                    $
                                                                                                                            $
  ed schedule? (If you do not already use a       they are unlikely to use quickly that you                 $       $

  project management system for this pur-         could retrieve for other, faster moving                       $
                                                                                                        $               $
  pose, this is a good time to start.)            projects?                                         $                           $

❉ Is your backlog largely caused by the fail-   ❉ Is money sitting idle in revolving loan       $                                       $

  ures of subgrantees? If so, what can you        funds because of an insufficient level of         $
                                                                                                                            $
                                                                                                                                    $

                                                                                                            $       $
  do to strengthen their capacity and your        program activity?
  oversight? HUD is producing a separate                                                                        $
                                                ❉ Is there a substantial gap between when               $               $
  publication titled Ensuring CDBG Subre-                                                           $                           $
                                                  expenditures are made and funds are
  cipient Timeliness. It discusses issues                                                       $                                       $
                                                  drawn from the CDBG line of credit for
  concerning the management of subre-
                                                  reimbursement? If so, what steps can you                                          $

                                                                 $
                                                                                                    $
  cipients for program timeliness purposes.                                                                 $       $
                                                                                                                            $

                                                  take to reduce that gap?
  Ask HUD for a copy to assist in this part

        $                                                                                                   $
  of your assessment.                           ❉ Do you have the number of staff and
                                                  skill levels you need? Are you using ex-
❉ If you frequently miss scheduled mile-
                                                  isting staff in the most effective way?
  stones, do you need to be more realistic
  in setting your schedules and/or provide      ❉ Is your staff adequately trained to do
  more oversight to see that schedules are        the assigned tasks? Are they sufficiently
  maintained?                                     knowledgeable about the CDBG program?
❉ Are you encountering unpredicted de-               You may want to seek help with this as-
  lays that were not factored into the          sessment from your HUD Field Office,
  overall timely implementation of your         which is aware of what other communities
  program?                                      in your area are doing. The Field Office may
                                                also be able to put you in touch with some
❉ Do you require an operating agency to
                                                of your peers for more detailed discussions
  define sufficiently a project and demon-
                                                of how they run their programs and what
  strate a readiness to proceed before you
                                                worked best for them. HUD has also pre-
  fund the project?
                                                pared a separate publication titled Keeping
❉ Do you require site control before you        Your CDBG Funds Moving: Guidelines for
  include a project in the Consolidated         Managing Your Overall Community Develop-
  Plan?                                         ment Block Grant Program in a Timely Man-
                                                ner. It focuses on program management
❉ Can you do a better job of phasing or
                                                issues that affect timeliness. You should re-
  staging large projects so that you commit
                                                quest a copy to use in conjunction with as-
  funds only to the portion that can move
                                                sessing and modifying your program as part
  ahead in the next year or two?
                                                of preparing your Workout Plan.
❉ Are you failing to anticipate the receipt
  of large amounts of program income and,       Reviewing the Options
  therefore, are you unprepared to use it           When faced with the need to take ac-
  quickly when received?                        tion on a project experiencing prolonged

                                                                                                                3
$       $
                        $
                                                                      Developing and Implementing a CDBG Workout Plan
    $                           $

$                                       $   delays, you will want to determine possible      intended backlog reduction, it will not nec-
    $
                                    $       options. Is it feasible to stage the project,    essarily result in failure to meet the standard.
                            $
            $       $
                                            leaving the part of the project that can be

        $       $
                                            completed in place and reprogramming the         Bringing Key Officials Into the Solution
                        $
    $                           $           balance of funds (assuming it will not affect         It is critical that key officials in the local
                                        $
                                            the eligibility or fundability of the complet-   governing body and local politicians under-
$
                                            ed portion)? This can be done more easily        stand your situation. Educate your chief
                                    $
    $
            $       $
                            $               if you inform all interested parties that you    executive and council members or commis-
                                            intend to fund the remaining portion in a        sioners about your excess CDBG backlog
        $       $
                        $                   future year after the delay-producing obsta-     and the consequences of failing to reduce
    $                           $
                                            cle has been overcome. If it appears the         it. To get their attention, you may want the
$                                       $   project will not get under way in the fore-      help of your HUD Field Office. If HUD has
    $
                                    $       seeable future, you will need to terminate it.   not already discussed CDBG program timeli-
                            $
            $       $
                                            Identify which ongoing projects are candi-       ness with key local officials, invite them to
                                            dates for increased funding. If you wish to      visit your community. You will probably get
                                            continue with the same project unmodified,       the help and cooperation you will need from
                                            be sure you have realistically identified what   local government agencies if your chief exec-
                                            steps you must now take to get that project      utive is on your side. Your council members
                                            under way.                                       or commissioners will be more likely to ac-
                                                                                             cept both the changes you may need to make
                                            Determining the Course of Action

                                                                                                                                            $
                                                                                             to projects in their jurisdictions and the
                                                 Develop an action plan to remedy each       pressure you may need to place on some of
                                            deficiency you identify. Make a realistic as-    their constituent agencies if they understand
                                            sessment of how long it will take to make        the urgency and possible consequences of
                                            the changes and how they will result in          your backlog problem.
                                            drawing CDBG funds more quickly. Contin-
                                            ue the process of identifying problems and       Caveats About Certain Alternative Approaches
                                            developing solutions until you can conclude           Even if you accurately identify problems
                                            that the selected changes will be more than      that are producing the backlog in your pro-
                                            sufficient to reduce your CDBG balance to a      gram, it may not be possible to fix the prob-
                                            level that will comply with the timeliness re-   lems quickly. You may be tempted to use
                                            quirements by the next measurement date:         float loans or lump sum drawdowns to reduce
                                            60 days before the end of your program year.     the backlog of funds in your line of credit.
                                            Make a projection of how much program in-        However, you should be aware of some criti-
                                            come will come in during that time period.       cal issues (discussed in the paragraphs below)

                                                                                                                         $
                                            Don’t forget that the program income you         before proceeding to do so.
                                            receive during the workout period must be
                                            used first before you can draw funds from             Float loans: A grantee may try to reduce
                                            your CDBG line of credit. Develop your           its backlog by making one or more float loans.
                                            Workout Plan with the objective of bringing      The term float is used because the source of
                                            the backlog to a level well below the 1.5        funds is money the grantee has in its line of
                                            timeliness standard. In this way, if any part    credit that is programmed for other uses, but
                                            of the Workout Plan does not achieve its         which is not expected to be needed for some

                4
Developing and Implementing a CDBG Workout Plan                                                             $       $
                                                                                                                            $
                                                                                                        $                           $

time. You should review the regulations at        used to determine your 15-percent cap for         $                                       $

24 CFR §570.301(b). If you are considering        public services and 20-percent cap on plan-           $
                                                                                                                                        $
                                                                                                                                $
a float loan, you first need to be sure the       ning and administration. Float loans can                      $       $

loan will be for an activity that meets           make more funds available for those uses.                         $
                                                                                                            $               $
CDBG requirements. Some activities that           However, a one-time spike in the amount               $                           $

need funds quickly could be difficult to assess   the grantee obligates for public services may                                             $
                                                                                                    $
for eligibility and compliance with CDBG          create a high expectation for a level of fund-
                                                                                                                                        $
national objectives. Do not rush to fund          ing that cannot be maintained in subsequent           $
                                                                                                                $       $
                                                                                                                                $

such activities without making this assess-       years and may be difficult to end.
ment. You also need to ensure that any such                                                                 $       $
                                                                                                                            $
                                                       Lump sum drawdown: A grantee may                 $                           $
loan will be repaid in time to fund the activ-
                                                  draw funds in advance to fund the rehabili-
ities for which the funds were originally pro-                                                      $                                       $

                                                  tation of privately owned properties under
grammed. Most often, float loans provide                                                                                                $

                                                                 $
                                                                                                        $
                                                  24 CFR §570.513 of the CDBG regulations.                                      $
construction financing or pay for property or                                                                   $       $

                                                  You should read these regulations carefully.
land acquisition before permanent financing

         $                                                                                                      $
                                                  While a lump sum drawdown might signifi-
comes from another source. Loans for such
                                                  cantly decrease your funds backlog, there are
purposes often require large amounts of funds
                                                  other important factors you should carefully
for a relatively short period of time.
                                                  consider. According to §570.513, the funds
     This short time period highlights a prob-    must be deposited in a financial institution
lem with float loans: using the repaid funds      that will agree to provide certain benefits to
quickly enough to avoid creating yet another      your community in exchange for receiving
backlog problem. You must also take care to       the deposit. These benefits include the insti-
ensure that you carry out the steps set forth     tution’s performing administrative services
in the regulations at 24 CFR §570.301(b)          for your community’s rehabilitation program
when making float loans. These steps are de-      at no cost, or a substantially reduced cost,
signed to make sure citizens are properly no-     and paying interest on the deposit at a rate
tified about, and protected against, the risks    that meets minimum requirements. (The
of not receiving loan repayments in time to       regulations provide more detail on the bene-
support the underlying projects that are to       fits you need to derive from the institution.)
be undertaken by the repaid funds. To ensure      It may take a long time to find a willing
that a float loan will be repaid on time, you     financial institution and to negotiate an
should make sure the project has permanent        agreement that will meet these require-
financing. You may also need to obtain an         ments. Moreover, this regulatory provision
irrevocable letter of credit in case one or       requires that the deposited funds, and inter-
more of the underlying projects needs funds       est paid thereon, be put to use within a short
before they can be repaid by the float loan       time. You must begin making use of the
recipient. Finally, you will need to deal with    funds within 45 days after their deposit. Plus,
the citizen participation requirements for        a substantial amount of the funds must be
funding of a new activity.                        used by 180 days after the account is estab-
                                                  lished, and all funds in the account must be
    You may be enticed to use float loans be-
                                                  put to use by the end of 24 months. Thus,
cause the loan repayments are CDBG pro-
gram income. Hence, they expand the base

                                                                                                                    5
$       $
                        $
                                                                        Developing and Implementing a CDBG Workout Plan
    $                           $

$                                       $   lump-sum drawdowns would make sense for                   back into compliance with program stan-
    $
                                    $       your rehabilitation programs only if:                     dards. In this section of your Workout Plan,
                            $
            $       $
                                                                                                      summarize the nature and results of your as-
                                            ❉ You already have one or more successful
                                                                                                      sessment. Although the immediate task is
        $       $
                        $                     rehabilitation loan programs and have
    $                           $                                                                     to find ways to hasten program spending to
                                              the staff and program criteria already in
                                                                                                      meet timeliness requirements, your program
$                                       $
                                              place.
                                                                                                      may soon relapse if you do not pinpoint the
                                    $
    $
            $       $
                            $
                                            ❉ The amount of unspent funds pro-                        reasons why the excess backlog developed.
                                              grammed for rehabilitation, together
        $       $
                        $                     with any additional funds you expect to                 Identification of Activities To Be Modified or Terminated
    $                           $
                                              program, would make a substantial con-                      You may find you are able simply to
$                                       $
                                              tribution to the reduction of your CDBG                 speed up one or more existing activities by
    $
                            $
                                    $
                                              funds backlog.                                          taking actions to spend the funds faster. If so,
            $       $
                                                                                                      describe in this section of your Workout
                                            ❉ You are able to find a financial institu-
                                                                                                      Plan any such activity, the actions you plan
                                              tion willing to participate and negotiate
                                                                                                      to take, and the results you expect. However,
                                              an agreement that meets the regulatory
                                                                                                      speeding up existing activities will not al-
                                              requirements within a reasonable time
                                                                                                      ways reduce the entire backlog, and you will
                                              period.
                                                                                                      usually need to make substantial changes in
                                            ❉ You are likely to spend the funds that                  some of your funded projects. You may find

                                                                                                                                                           $
                                              will be deposited, along with the interest              it necessary to terminate an activity (in
                                              to be paid on the deposit, for rehabilita-              whole or in part) or to modify it to free up
                                              tion activities by the deadlines required               funds that can be spent faster on another
                                              in the regulations.                                     project. List the specific activities you intend
                                                                                                      to either modify or terminate. Describe all
                                                                                                      such activities, the actions you plan to take,
                                            Preparing a Written Plan for Submittal to HUD             and the amount of freed-up funds you expect
                                                Once you have determined the course of                to result from these actions that will be av-
                                            action for reducing the funds backlog, you                ailable for other uses.
                                            will need to prepare a written Workout Plan
                                            for HUD. The Workout Plan must at least                   Reprogramming Available Funds
                                            contain the following elements for it to be                   Identify the activities for which you plan
                                            approved by HUD.                                          to use the funds you will have available from
                                                                                                      modified or terminated projects. Include also
                                            Identification of the Main Causes of the Excess Backlog   a description of how you will use unpro-

                                                                                                                                 $
                                                HUD will need to conclude from your                   grammed funds from completed projects or
                                            Workout Plan that (1) you have conducted                  from program income. These projects might
                                            a thorough review of your program, projects,              include other, already funded activities that
                                            and activities; (2) you have identified the               can use more funding and use the money
                                            main causes of your problem; and (3) you                  quickly. You may also plan to carry out
                                            have chosen actions that will lead to suffi-              (a) one or more projects previously included
                                            cient improvements to get your program                    in your action plan as backup projects or (b)
                                                                                                      new projects not previously identified in an

                6
Developing and Implementing a CDBG Workout Plan                                                              $       $
                                                                                                                             $
                                                                                                         $                           $

action plan. List these activities, the amount    Milestone Schedule                                 $                                       $

of the freed-up funds you expect to use on             Include or attach a schedule that lists all       $
                                                                                                                                         $
                                                                                                                                 $
each, and the time within which you expect        of the key actions that the community will
                                                                                                                 $       $

those funds to be expended. Don’t forget to       take to pursue backlog reduction, and show                         $
                                                                                                             $               $
include time for citizen participation, when      the dates each action is expected to start             $                           $

necessary, to amend your action plan to add       and finish. This schedule should include the                                               $
                                                                                                     $
a new activity or materially change another.      milestones you have identified for each ac-                                            $
                                                                                                         $
                                                                                                                                 $
                                                  tivity that will use CDBG funds as part of                     $       $

Other Planned Actions                             your Workout Plan. (See the sample format
                                                                                                                     $
     Describe any other steps you plan to         provided at the end of this publication.)              $
                                                                                                             $               $
                                                                                                                                     $
take to reduce the excess backlog within the
                                                                                                     $                                       $
time frame covered by the Workout Plan.           Drawdown Projection
This may include adding or reassigning staff,                                                                                            $

                                                                       $
                                                                                                         $
                                                        The Workout Plan should include a pro-                   $       $
                                                                                                                                 $

providing training or technical assistance to     jection showing the amount of CDBG funds

          $
subgrantees, and securing the aid of your

                                                                                                                 $
                                                  your community expects to draw down from
community’s chief executive officer or leg-       its line of credit during the period covered
islative body. It may also include actions to     by the Plan. The projection should identify
reduce the time that elapses between expen-       the amount of expected draws, by month, for
ditures and drawing of funds from the line of     each activity that was delayed but is being
credit. List all such planned actions, state      retained, as well as those projects you have
when you expect to take them, and explain         modified or added to help resolve your time-
the results you expect to achieve.                liness problem. It should also include expect-
                                                  ed draws for the balance of your program,
Longer Range Plans                                showing the activities that make up that bal-
    If you have identified any program de-        ance either individually or combined. (See
sign weaknesses that you believe need to be       the sample format provided at the end of
corrected to help your community meet the         this booklet.) The projection should also
timeliness standard, describe the corrections     summarize the amount of expected draws
here. This section might include changes          for your entire program on a monthly basis,
in overall management procedures, in your         showing the effect they will have on your
process for developing an action plan, or in      line-of-credit balance. At the bottom of the
the process you use for assessing projects and    projection, show how the backlog reduction
subrecipients for future funding decisions.       will affect your drawdown ratio. Again, in
State specifically the deficiency, your planned   making this projection, don’t forget to take
remedial actions, and how they will improve       into consideration that program income
the likelihood the community will keep its        will need to be used before funds can be
CDBG program timely.                              drawn from your line of credit.

                                                  Progress Reports
                                                      Determine the content and timing of
                                                  the progress reports your community will
                                                  provide to HUD over the period of time

                                                                                                                     7
$       $
                        $
                                                                  Developing and Implementing a CDBG Workout Plan
    $                           $

$                                       $   covered by the Workout Plan. Identify how        gram back within timeliness standards. It is
    $
                                    $       you plan to submit the reports (e.g., by mail,   important to submit the Workout Plan and
                            $
            $       $
                                            fax, e-mail, or other method), the frequency     progress reports in a timely manner. The
                $
                                            of the reports, and the dates on which you       plan should reflect realistic goals to show
        $               $
    $                           $           will submit them. The content of such re-        you are taking your backlog problem serious-
                                        $
                                            ports should include at least:                   ly and will deal with it effectively. You may
$
                                                                                             want to determine if HUD staff will review
                                    $       ❉ A comparison of actual results versus
    $
            $       $
                            $                                                                your plan during its development and com-
                                              planned results in terms of both meeting
                                                                                             ment on any aspect that seems questionable.
                                              your milestones and planned drawdowns
        $       $
                        $                                                                    As part of this collaborative process, consid-
    $                           $             from the line of credit.
                                                                                             er asking HUD for advice or technical assis-
$                                       $
                                            ❉ Other relevant actions taken during the        tance as part of your assessment of causes
    $
                                    $
                                              period since the last report.                  and remedies in the course of developing
                            $
            $       $
                                                                                             your Workout Plan. Do not formally submit
                                            ❉ Your assessment of the progress being          the Workout Plan to HUD until you are
                                              achieved by the community in relation          convinced that there is a high likelihood
                                              to expectations.                               that the Plan will be acceptable to HUD.
                                            ❉ Any special actions you plan to take to
                                              deal with any significant deviations from      Implementing the Plan
                                              the Workout Plan.                                   In addition to its daily CDBG workload,
                                                See the attached sample formats for
                                            how you may show actual accomplishments
                                            against planned milestones and drawdowns.
                                                                                             your community must also make a concerted
                                                                                             effort to implement the commitments made
                                                                                             in the Workout Plan if the Plan is to suc-  $
                                                                                             ceed. Because time is of the essence, it is im-
                                                                                             portant to discover promptly any significant
                                            Commitment                                       departure from the Workout Plan in order to
                                                 The letter transmitting your Workout        allow for corrective action. Therefore, you
                                            Plan to HUD should describe the level of         should require special reports (at least once
                                            commitment your community will make to           a month) to track the actions and results
                                            execute the Workout Plan. The transmittal        committed to in the Plan. You may need to
                                            letter should also describe the projected re-    ask subgrantees to provide additional infor-
                                            sults and how they will reduce the excess        mation on a more frequent basis than their
                                            backlog of CDBG funds. Having the letter         normal reporting regimen. You should com-
                                            signed by your chief executive will indicate     municate regularly with key staff members
                                            that the community commits itself to meet-       involved in your program to measure prog-
                                            ing the objectives reflected in the Workout
                                            Plan.

                                            HUD Approval
                                                                                                                    $
                                                                                             ress against the Workout Plan. The Plan
                                                                                             should be an agenda item at every staff
                                                                                             meeting. Report progress on the Workout
                                                                                             Plan to your chief executive monthly.

                                               HUD will review the Workout Plan you               If, at any time, it appears that progress
                                            submit to determine if it is realistic and if    is seriously lagging, and that the lack of
                                            implementing it will likely bring your pro-      progress is threatening the community’s

                8
Developing and Implementing a CDBG Workout Plan                                                            $       $
                                                                                                                           $
                                                                                                       $                           $

ability to achieve the overall goal of the        staff for monitoring its projects; (b) conduct   $                                       $

Workout Plan, you will be expected to take        program training for its current subrecipi-          $
                                                                                                                                       $
                                                                                                                               $
immediate action to get the community back        ents; and (c) amend its reporting require-                   $       $

on track. In such an event, notify HUD im-        ments to make information on expenditures                        $
                                                                                                           $               $
mediately; don’t wait until the next report       and drawdowns more readily accessible. It            $                           $

deadline (unless that deadline is near). Tell     also realizes that these management actions                                              $
                                                                                                   $
HUD what you expect to do to overcome             alone will not immediately result in im-
                                                                                                                                       $
the problem and discuss whether it merits         proved timeliness and that it must take other        $
                                                                                                               $       $
                                                                                                                               $

amending the Plan.                                actions relating to specific projects. The
                                                  grantee sees its best chance for improving its           $       $
                                                                                                                           $
                                                                                                       $                           $
                                                  drawdown rate within the next year in tak-
Sample Formats                                    ing actions in three areas:                      $                                       $

     Following this section, you will find two                                                                                         $

                                                                $
                                                                                                       $
sample formats, which allow the grantee to        ❉ Expediting two of its capital improve-                     $       $
                                                                                                                               $

use the same form for both the Plan itself          ment projects (rehabilitation of a library

         $                                                                                                     $
and for reporting progress against the Plan.        and construction of a neighborhood
The first format identifies the milestones to       center).
be met for management actions and individ-
                                                  ❉ Expanding and expediting one of its
ual projects. The second details the projec-
                                                    housing rehabilitation projects through
tion of funds to be drawn down monthly
                                                    better outreach efforts and improved
during the reporting period and provides for
                                                    staff efficiencies.
a running calculation of the drawdown ratio.
On both sheets, the shaded area is to be used     ❉ Replacing the subrecipient it had been
for reporting actual results by month. HUD          using for one of its public services with
plans to make these formats available as            a more experienced nonprofit agency.
downloadable forms available on its Web site.
                                                      Anytown expects that these actions will
    In the hypothetical community provided        result in its program funds balance being
here, you can see how Anytown, USA,               well within the 1.5 standard by the end of
found in noncompliance with the timeliness        the 10th month of its current program year
standard 60 days prior to the end of its pro-     (April 30, 2003).
gram year, has analyzed its program and
determined what to do to improve its timeli-           The sample milestone schedule shown
ness. In this example, Anytown’s drawdown         here identifies the key actions and dates that
ratio (ratio of grant-to-balance of funds) at     Anytown believes it needs to meet in order
the start of its new program year July 1,         to undertake these changes, and reports
2002, was 2.61 (includes FY 2002 grant).          progress against these targets. The accom-
Anytown has decided that, for the long run,       plishment data in the shaded areas indicates,
it must revise its overall program schedule to    for example, that, 4 months into the Plan,
allow more time for staff to identify potential   some potentially serious slippages in meeting
problems with individual projects and to          milestones have occurred that could result in
take actions to keep funds moving. Anytown        the grantee failing to achieve its objective
has also decided it needs to: (a) hire more       of having its fund balance meet the 1.5 stan-
                                                  dard. Delays in selecting a contractor for the

                                                                                                                   9
$       $
                        $
                                                                  Developing and Implementing a CDBG Workout Plan
    $                           $

$                                       $   Rialto Library rehabilitation project and on-        Note: These samples are not intended
    $
                                    $       site preparation for the Westside Center are    to indicate the level of detail that a Work-
                            $
            $       $
                                            already resulting in a shortfall in its draw-   out Plan should contain, but rather to
                $
                                            down projections as shown on the Funds          show how the material should be present-
        $               $
    $                           $           Drawn report. Therefore, Anytown must           ed. In actual use, HUD would expect the
                                        $
                                            give careful attention to those areas of its    Plan to contain much more detailed infor-
$
                                            Workout Plan and take aggressive remedial       mation than is shown here for these pur-
                                    $
    $
            $       $
                            $               actions if it is to avoid a growing gap in      poses. In reviewing these samples, you
                                            meeting drawdown projections for the            should also bear in mind that the informa-
        $       $
                        $                   ensuing months.                                 tion contained in these formats will con-
    $                           $
                                                                                            stitute only a small part of a grantee’s
$                                       $                                                   Workout Plan and progress reports. The
    $
                                    $                                                       essence of both the Plan and the monthly
                            $
            $       $
                                                                                            reports needs to be covered in accompany-
                                                                                            ing narratives.

                                                                                                                                    $

                                                                                                                 $
                10
Grantee: Anytown, USA                                                                            CDBG Workout Plan                                                                               Preparation date: Nov. 5, 2002
     Contact person: Janet Jones                                                                                                                                                                      Original plan date: July 1, 2002
     Telephone: (301) 555–1234                                                            Milestone Schedule/Progress Report                                                                          Amended plan date:

     Project     Milestone             July 2002            Aug 2002                Sept 2002             Oct 2002                 Nov 2002           Dec 2002            Jan 2003            Feb 2003              Mar 2003                Apr 2003
     Name                           Proj     Actual      Proj    Actual          Proj     Actual       Proj     Actual          Proj     Actual     Proj    Actual     Proj     Actual     Proj     Actual       Proj     Actual         Proj     Actual

     Program       Amend          Start
     Mgmt         program         by 7/3
                  schedule      Complete    Completed
                                 by 7/15      7/17

                  Hire two      Advertise    Issued                              Review     Review    Select Monitors
                  monitors        7/10      ads 7/10                            applicants completed monitors selected
                                                                                 by 9/30     9/28    by 10/25  10/29

                 Train sub-     Start by     Started                            Complete Training
                 recipients      7/15         7/15                               by 9/15 completed
                                                                                           9/15

                   Amend         Start by    Started                Completed
                   reports         7/3        7/28                     8/7
                                Complete
                                  7/15

     Rehab          Issue       Develop     Developed    Issue         RFP
     Rialto          RFP          RFP       RFP 7/15    RFP by       issued
     Library                     by 7/7                    8/5        8/15

                   Select                                                        Select                          Selected
                 contractor                                                     by 9/25                           10/25

                   Rehab                                                                              Start by                                                       Complete
                   library                                                                             10/13                                                           1/15

                 Install new                                                                                                   Order by           Receive                                Install by
                   shelves                                                                                                      11/2              by 12/31                                  2/6

     Eastside       Train                               Start by     Started    Complete Completed
     Rehab          staff                                8/10         8/10        9/25     9/25
     Project

                  Mail out                                                      Mail by                           Mailed
                 brochures                                                       9/15                              10/1

                  Approve                                                                                                     Begin loan
                   Loans                                                                                                       process
                                                                                                                                11/15
                                                                                                                                                                                                                                                           Developing and Implementing a CDBG Workout Plan

     Meals on    Select new        Select   Selected
     Wheels      subrecipient      by 7/2     7/2

                 Train new                              Start by     Started    Complete Completed
                subrecipient                              8/1          8/3      by 9/15    9/30

                    Begin                                                                              Begin      Began
                   service                                                                             10/5      meals 10/5

     Westside     Site prep                              Start by    Started              Completed
     Center                                                8/4        8/14                  9/6
                                                        Complete
                                                         by 8/25

                  Construct                                                                           Start by    Started                                                                                                            Complete
                   center                                                                              10/15       10/30                                                                                                              by 4/15

11
12
     Grantee: Anytown, USA                                                                            CDBG Workout Plan                                                                                Preparation date: Nov. 5, 2002
     Contact person: Janet Jones                                                                                                                                                                       Original plan date: July 1,2002
     Telephone: (301) 555–1234                                                                     Funds Projected/Funds Drawn                                                                         Amended plan date:

                            Amount       Balance                                                                                                                                                                         Cumulative      Undrawn
                   Amount Drawn as        as of    Drawdown        Drawdown        Drawdown         Drawdown         Drawdown        Drawdown         Drawdown        Drawdown         Drawdown         Drawdown           as of          Balance
     Activity     Budgeted of 6/30/02   7/01/02    July 2002       Aug 2002        Sept 2002        Oct 2002         Nov 2002        Dec 2002         Jan 2003        Feb 2003          Mar 2003        Apr 2003         Prep. Date        as of
     Name/#        $(000)  $(000)        $(000)    Proj   Actual   Proj   Actual   Proj   Actual   Proj    Actual   Proj    Actual   Proj    Actual   Proj    Actual Proj    Actual   Proj    Actual   Proj    Actual   Proj   Actual    Prep. Date

     Rialto         240            10     230        0       0       0        0      0       0      40       15       40              40               40              50                0                0               40     15         215
     Library

     Eastside       655        115        540       20      25      20      18      20      21      30       25       30              40               40              40              40                40               90     89         451
     Rehab

     Meals          200             0     200        0       0      15      14      15      15      15       15       20              20               20              15              15                15               45     44         156
     on Wheels

     Westside       855        125        730        0       0      75      38       0      37      50       10       60              50               50              10              50                40             125      85         645
     Center

     Balance        495        240        255       15      13      20      21      20      20      20       19       25              20               15              10              10                 5               75     73         182
     Public
     Services

     Balance        850        395        455       50      55      50      53      30      29      20       21       30              20               20              20              20                40             150    158          297
     Housing
     Rehab

     Balance        575        110        465        0       0      25      23      35      36        0       0       30              35                 0              0                0                0               60     59         406
     Capital
     Projects

     Balance        560        245        315       25      23      20      21      15      16      10       12       25              10               15               5              25                10               70     72         243
     All Others

     Total         4,430     1,240      3,190      110    116      225     188     135    174      185     117       260       0     235       0      200      0     150       0      160       0      150       0      655    595        2,595

     LOC                                 3,190     3,080 3,074 2,855 2,886 2,720 2,712 2,535 2,595 2,275                             2,040            1,840          1,690            1,530            1,380
     Balance
     Current                             1,222
     Grant
     Ratio of                            2.61      2.52    2.52    2.34 2.36       2.23    2.22     2.07    2.12     1.86            1.67             1.51            1.38            1.25              1.13
     Balance to
     Grant
                                                                                                                                                                                                                                                      Developing and Implementing a CDBG Workout Plan
HUD–2002–13B–CPD   www.hud.gov/offices/cpd/communitydevelopment/library/index.cfm   October 2002
You can also read