(1) Data Collection and Reporting
a. Spend Plan Submissions: These identify the plan for the use of funds for each grantee. After award, but before gaining access to funds, the grantees must submit a plan on how to use their funds. TCAP grantees must submit a statement of intent to accept TCAP funds, which must include: a statement that indicates whether the grantee intends to accept the entire amount of its TCAP formula allocation; a statement detailing which, if any, other federal grant funds the grantee currently administers; a statement regarding the status of its 2009 LIHTC allocation process; and the name and contact information of the individual designated as the agency contact for TCAP. In addition, each TCAP grantee must submit a written description of all the selection criteria and any weightings assigned that it will use to competitively award its TCAP funds. HUD plans to provide links to the website of each TCAP grantee on www.hud.gov/recovery on which the Qualified Allocation Plans for each can be found. TCAP grantees are required to enter project-level data in HUD’s Integrated Disbursement and Information System (IDIS). HUD will use this data to provide commitment, expenditure, completion, and accomplishment information on www.hud.gov/recovery.
b. Financial Reports: HUD has two financial reports that will be generated and analyzed on a weekly basis. 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 TCAP grantees, including the following project-level data elements: General Information, Objective and Outcome, Special Characteristics, Project Unit Information, Period of Affordability and Project Costs.
(2) Ongoing Grantee Management: HUD categorizes grantees by risk, then monitors and allocates interventions, including training, technical assistance and if warranted, disciplinary action, accordingly. A TCAP grantee may be considered high risk if HUD determines that a grantee (1) has a history of unsatisfactory performance, or (2) is not financially stable, or (3) has a management system which does not meet the management standards set forth in this part, or (4) has not conformed to terms and conditions of previous awards, or (5) is otherwise not responsible. To ensure TCAP funds are expended on eligible activities, HUD will review project-level data in its reporting system on a frequent basis and to ensure budget/cost compliance, HUD’s financial system will not allow TCAP grantees to drawdown more funds than are committed to the TCAP project. HUD will require all TCAP grantees to meet statutory requirements of the Recovery Act and all federal cross cutting requirements as identified in HUD Notice CPD 09-03, Implementation of the Tax Credit Assistance Program (TCAP), May 4, 2009, through its grant agreement with each TCAP grantee. If the grantee does not meet its statutory commitment or expenditure requirements, HUD will deobligate the funds and reallocate the funds to grantees meeting these requirements. HUD will refer all eligibility, cost reasonableness, and compliance issues regarding Section 42 of the IRC to the IRS.