AMERICAN RECOVERY AND REINVESTMENT ACT OF 2009 (ARRA)
The Office of Capital Improvements (OCI) has announced the award of $2.985 billion in Capital Fund formula grant funds pursuant to the American Recovery and Reinvestment Act of 2009 (ARRA) – HUD is retaining $15 million for its own internal uses.Each PHA is supposed to have received the email notice from OCI, with appropriate links to specific sites needed. The $1 billion appropriated for competitive CFP grants is not included in this action.
The purpose of this email is to try to provide a simplification of the OCI Notice as presented on February 25, 2009. However you are strongly encouraged to read and comply with the entire OCI Notice, as well as regularly check the Office of Capital Improvements web page for likely additional information.
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ACC AMENDMENTS–
Download the ACCs, sign two copies and submit to your Field Office no later than Monday, March 9, 2009. Board Resolutions will be due at a later date.
ANNUAL STATEMENT – 50075.1–
Annual Statements are due at HUD no later than April 10, 2009.
(Note – HUD has issued new CFP forms. HUD 50075.1 is to be used for the new Annual Statement, and is to be signed by the Executive Director. Please note that the revised 50075.1, Part III – Implementation Schedule, is only to be completed for the Capital Fund Financing Program (CFFP).)
HUD OCI is encouraging PHAs to give priority to:
- Capital projects/work items that could be placed for bid and contract awarded within 120 days of the effective date of the grant.
- Rehabilitation of vacant units.
- CFP projects already underway or included in the 5-year CFP.
When you submit your Annual Statement, it is at this point you will submit your Board Resolution. Be certain to put this on your Agenda for the March Board Meeting.
Once the Annual Statement and Board Resolution are received at HUD, HUD will spread the budget line items in the LOCCS system so PHAs will be able to draw funds as they normally do.
(Funds will be available in LOCCS by March 23, 2009. According to the OCI notice, PHAs [regardless of receipt by HUD of a PHA’s budget and Board Resolution] will be able to draw down funds subject to Field Office review)
LIMITATION ON FUNDS
Although not included in the OCI Notice, the following has been issued from HUD personnel:
Operations -1406
No funds can be charged to operations.
Management Improvements – 1408
HUD is“fast tracking” a notice that will help with Management improvements up to 20% of the grant, but the act prohibits the use for operations and resident assistance. So any Management Improvements that would look like operations is not allowed i.e. staff training.
Administration -1410
Up to 10% can be charged to administration (to the COCC), but only the administrative costs associated with the ARRA grant and complying with the 72 hour treasury rule.
Fees and Costs -1430
As is normally funded under the Capital Fund Grants
OBLIGATION AND EXPENDITURE OF FUNDS:
100% of the PHA’s funds must be obligated within one year of effective date of the grant.
60% of funds must be expended within two years of effective date of the grant.
100% of funds must be expended within three years of effective date of the grant.
Any funds not meeting any of the above three dates will result in recapture of those remaining funds.
HUD cautions that the Department has no flexibility to extend or alter the new obligated/expended dates.
While formula calculation will be completed and provided to PHAs prior to receipt of funds, UNDER NO CIRCUMSTANCES should a PHA begin to incur obligations until such time as they receive written notification of funds availability via a jointly executed ACC from the HUD Office.
PHYSICAL NEEDS ASSESSMENT –
A PNA will need to be completed and submitted to HUD “at some point”. HUD will develop the guidelines for the PNA “at some point”.PLEASE MAKE SURE YOU SAVE MONEY IN YOUR BUDGETING FOR THIS ACTIVITY IF YOU NEED TO REVISE YOUR NEEDS ASSESSMENT.
DUNS NUMBERS–
All recipients of this money are required to have a Data Universal Number System (DUNS) number. If you already have a DUNS number, the OCI Notice advises you to go to the Office of Capital Improvements Recovery web page to confirm that number.
If you do not have a DUNS number, follow this link for the process of obtaining one.
The web site indicates that although the process to request a DUNS number takes only a few minutes, it may take approximately five days to get your number.
It may be advisable you go ahead and initiate this process now. For those PHAs that already have a DUNS number, follow the instructions in the OCI notice to verify that number now in the event it is incorrect or there is some other problem.
RESIDENT ADVISORY BOARD CONSULTATION –
It is strongly recommended that PHAs consult with their RAB during the process of developing the ARRA budgets. For those PHAs currently developing the 7/1/2009 Annual Plans that have already conducted the RAB meeting, we suggest you hold another meeting for their input.
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As indicated earlier, the purpose of this document is to try to provide a simplification of the OCI Notice as presented on February 25, 2009. However you are strongly encouraged to read and comply with the entire OCI Notice, as well as regularly check the Office of Capital Improvements web page for likely additional information.
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