Description of Agency Periodic Review of Partners' progress:
(1) Data Collection and Reporting
a. Spend Plan Submissions: These identify each grantee’s plan for the use of funds. For NSP2, the use of funds will be described in detail in the competitive applications. If selected, recipients will submit details on the proposed projects and activities to HUD’s reporting system. HUD field staff must review and approve the plans in the system before any draw vouchers or performance reports may be submitted.
b. Financial Reports: HUD will generate and analyze two financial reports. These include a Summary Financial Report that indicates the amount of funds for each program, and a Funding Notification Report, which shows the amount of funding by program for every jurisdiction, including local governments and states.
c. Quarterly Recipient Reports: The cornerstone of HUD’s monitoring and evaluation system is the project and contract data collected from grantees. The Recovery Act specifically requires data collection fields for grantees and contractors. In addition to these data, HUD will also collect program-specific measures from grantees DRGR collects summary information on program beneficiaries, start and end dates of each activity, national objective, number of housing units, location information including addresses of acquired and rehabilitated properties, dollars budgeted, obligated, and expended.
d. Sample Survey of Outcomes: HUD has allocated a portion of the program funds for research, including an evaluation of NSP, which will capture changes in occupancy, tenure, and property values in NSP neighborhoods.
(2) Ongoing Grantee Management: HUD categorizes grantees by risk, then monitors and allocates interventions, including training, technical assistance and if warranted, disciplinary action, accordingly. High Risk grantees are those who are new to the CDBG program, habitually poor CDBG or HOME performers, have open monitoring or audit findings, significant funding increases, recent critical staff turnover, extremely high Congressional or national media interest. HUD looks for factors, such as (1) timely expenditure of funds, (2) quality expenditure of funds, (3) budget/cost compliance, and (4) legal compliance and prevention of fraud. HUD may impose additional grant conditions such as more frequent reporting or HUD pre-approval of smaller draw requests than normal, and HUD may conduct frequent remote and on-site monitoring pursuant to existing monitoring guidelines and practices for the regular CDBG program (CPD Monitoring Handbook and Risk Analysis), with specific risk and monitoring guidelines under development for NSP. HUD staff and NSP TA contractors will provide a broad range of capacity building, such as on-site consultation and project-specific training, web and classroom training on technical areas such as land banking, financial compliance, environmental reviews and model program designs. The CDBG regulations in the 24 CFR 570.900 series provide for a very broad range of corrective actions and due process designed to stop noncompliance, prevent recurrence of the problem and mitigate the negative effects of the problem. HUD’s choice of corrective actions ranges from sending a warning letter to a grantee, to requiring repayment of the grant funds, to legal action.
(3) Longer Term Evaluation and Research: HUD will perform an evaluation on NSP, which will capture changes in occupancy, tenure, and property values in NSP neighborhoods.