Common Application, Waivers, and Alternative Requirements for Community Development Block Grant Disaster Recovery Grantees: The Universal Notice
Published Date: 1/8/2025
Notice
Summary
Starting January 13, 2025, HUD is rolling out a new Universal Notice to make disaster recovery grants faster and clearer for communities hit by disasters. This update affects local governments and organizations getting Community Development Block Grant Disaster Recovery (CDBG-DR) funds by simplifying rules, speeding up approvals, and cutting red tape. The goal? Help disaster-hit areas get money and start rebuilding sooner!
Analyzed Economic Effects
10 provisions identified: 9 benefits, 0 costs, 1 mixed.
Most Funds Must Serve MID Areas
At least 80 percent of each grantee's CDBG-DR award must benefit HUD-identified Most Impacted and Distressed (MID) areas. If the HUD-identified MID area covers the grantee's entire jurisdiction, 100 percent of the award must benefit that MID area.
Early Access to Admin Funds
Grantees may submit an optional Admin Action Plan to access program administrative funds before submitting the full Action Plan. The Admin Action Plan requires no public comment, must include the SF-424, and HUD will review it within 15 calendar days so grantees can enter administrative activities into DRGR and access admin funds (subject to the usual administrative cap rules).
Action Plan Deadlines and Reviews
Grantees must submit an Action Plan within 90 calendar days of the AAN's applicability date; HUD will review Action Plans within 45 calendar days of receipt. If HUD finds the Action Plan substantially incomplete, the grantee must resubmit within 45 days and HUD will respond within 30 days of that resubmission.
Financial Certification and Drawdown Rules
Grantees must submit financial control and procurement certification documentation within 135 calendar days of the AAN; HUD will review these submissions within 45 calendar days. A grantee may draw funds only for activities in an approved DRGR Action Plan and only after required environmental reviews and an approved Request for Release of Funds (RROF) or adoption of another Federal agency's review.
Drawdown Start and Six-Year Deadline
Grantees should begin drawing down funds no later than 180 calendar days after HUD executes the grant agreement (or after HUD approves the Action Plan and financial certification, whichever is later). All CDBG-DR funds must be expended within six years of the date of obligation.
Program Budgets, Award Caps, Income Limits
Each Action Plan must include a high-level budget showing splits for administration, planning, housing, infrastructure, and economic revitalization, and must state the maximum award (award cap) and maximum beneficiary income (income cap) for direct-benefit programs. Grantees must note exceptions to award caps to accommodate accessibility needs.
Fair Housing Data and AFFH Requirements
Grantees must collect fair housing and civil rights data (including LEP languages, protected classes, tenure, vulnerable populations, underserved communities, indigenous/Tribal communities, and R/ECAPs) and must submit an affirmatively furthering fair housing (AFFH) certification and update policies to comply with AFFH obligations.
Required Cross-Cutting Protections
CDBG-DR grantees must comply with cross-cutting federal requirements, including environmental review under 24 CFR part 58, the Davis-Bacon Act (prevailing wage), civil rights laws, the Lead Safe Housing Rule, and the Uniform Relocation Act (URA), as applicable to funded activities.
Universal Notice Is Conditional
The Universal Notice describes how HUD plans to apply waivers and alternative requirements, but it has no legal effect until Congress appropriates CDBG-DR funds and HUD publishes an Allocation Announcement Notice (AAN) that incorporates the Universal Notice provisions. HUD will make required findings and implement any waivers when each AAN is published.
Waiver Requests and Grantee-Specific Changes
After HUD announces allocations, grantees may request additional waivers or alternative requirements with supporting data. HUD intends to publish grantee-specific waivers at least quarterly in the Federal Register or on HUD's website.
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