SECTION 3: Action Plan & Implementation

This section includes guidance on developing a CDBG-DR Action Plan in response to the Consolidated Notice, including steps to take when submitting the required pre-award submissions, the Implementation Plan, and the Public Action Plan. This section also moves into the Implementation phase of projects and activities, and includes relevant guidance on resilience planning and best practices when incorporating mitigation into long-term recovery.

Action Plan Development

DRGR Requirements & Submittal of the Public Action Plan

HUD has provided guidance and training to grantees on how to develop the Public Action Plan in DRGR and the corresponding DRGR Action Plan (Projects and Activities).

Grantee Public Action Plan in DRGR Training

Grantees can view HUD’s webinars and related materials on the Public Action Plan in DRGR here: https://www.hud.gov/program_offices/comm_planning/cdbg-dr/grantees/drgr-public-action-plan and
https://www.hudexchange.info/trainings/courses/drgr-public-action-plan-webinar1/4536/

General and appropriation-specific guidance for DRGR reporting requirements can be found on the HUD Exchange.

Each grantee must enter its action plan for disaster recovery, including projected performance measures and financial expenditure timelines, into HUD’s Public Action Plan template in DRGR. Historically, the grantee has had two different action plans – the published action plan that meets the requirements of the notice and the DRGR action plan that describes the projects and activities in greater detail. Moving forward, CDBG-DR grantees will no longer develop action plans outside the system. HUD created the Public Action Plan in DRGR to assist grantees in the development of the action plan and to create consistency for all CDBG-DR action plans in the portfolio. This new process streamlines the development of the action plan (including any amendments) and the review and approval processes. The Public Action Plan contains a series of new functions that guide the grantee through the requirements for the action plan. The Public Action Plan allows grantees to provide narratives, insert data into tables, upload pictures, maps, etc.

The grantee will also establish Grantee Programs based on activity types such as “Housing”, “Infrastructure”, “Public Services”, and “Economic Development” within the Public Action Plan in which later developed activities will be associated via the DRGR Action Plan. This will allow grantees with many projects or activities to report their financial and performance data at a level higher than by DRGR project(s) or activity(ies). The Public Action Plan will be submitted in DRGR, and HUD will review for completeness and approve/reject as necessary. Once the Public Action Plan is approved via DRGR, the grantee will then create its projects and activities within the DRGR Action Plan at a level of detail that is sufficient for grantees to submit acceptable performance reports and permits HUD review of grantee compliance with applicable requirements. The grantee must enter activities into the DRGR Action Plan at a level of detail sufficient to allow HUD to determine grantee compliance.

To enter an activity into the DRGR system, the grantee must know the activity type, national objective, and the organization that will be responsible for completing the activity.

Each activity entered into the DRGR Action Plan must also be categorized under a “project.” Typically, projects are based on groups of activities that accomplish a similar, broad purpose (e.g., housing, infrastructure, or economic revitalization), responsible organization (e.g. subrecipient A) or are based on an area of service (e.g., Community A). For example, if a grantee chooses to describe a Grantee Program within its Public Action Plan as a broad activity type (e.g., single family rehabilitation), that program can be entered as a project in the DRGR Action Plan. Further, the budget of the program would be identified as the project’s budget. Another example is if a state grantee has only identified the Method of Distribution (MOD) upon HUD’s approval of the published Action Plan, the MOD itself typically serves as the projects in the DRGR Action Plan, rather than activity groupings. Activities can be added to MOD projects as subrecipients decide which specific CDBG-DR programs and projects will be funded. 

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Each grantee must enter summary information on monitoring visits and reports, audits, and technical assistance it conducts as part of its oversight of its disaster recovery programs into the DRGR system. The grantee’s Performance Report will include a summary indicating the number of grantee oversight visits and reports (see subparagraph 5 for more information on the Performance Report). HUD will use data entered into the Public Action Plan, DRGR Action Plan, Performance Reports, transactional data from the DRGR system, and other information provided by the grantee, to provide reports to Congress and the public, as well as to: (a) monitor for anomalies or performance problems that suggest fraud, waste and abuse of funds, and duplication of benefits; (b) reconcile budgets, obligations, funding draws, and expenditures; (c) calculate expenditures to determine compliance with administrative planning and public service caps and the overall percentage of funds that benefit low- and moderate-income (LMI) persons; and (d) analyze the risk of grantee programs to determine priorities for the Department’s monitoring. Grantees must omit personally identifiable information (PII) reported in Performance Reports made available to the public.

Grantees will use the DRGR system to draw grant funds for each activity. Grantees must also use the DRGR system to track program income receipts, disbursements, revolving loan funds, and leveraged funds (if applicable). If a state grantee permits local governments or subrecipients to retain program income, the grantee must establish program income accounts in the DRGR system. The DRGR system requires grantees to use program income before drawing additional grant funds and ensures that program income retained by one organization will not affect grant draw requests for other organizations.

Each grantee must submit a Performance Report through the DRGR system no later than 30 days following the end of each calendar quarter. Within 3 days of submission to HUD, each Performance Report must be posted on the grantee’s official disaster website. In the event the Performance Report is rejected by HUD, the grantee must post the revised version, as approved by HUD, within 3 days of HUD approval. The grantee’s first Performance Report is due after the first full calendar year quarter after HUD signs the grant agreement. For example, a grant agreement signed in April requires a Performance Report to be submitted by October 30 for reporting period July-September. Performance Reports must be submitted on a quarterly basis until all funds have been expended and all expenditures and accomplishments have been reported. If a satisfactory report is not submitted in a timely manner, HUD may suspend access to grant funds in DRGR until a satisfactory report is submitted, or may withdraw and reallocate funding if HUD determines, after notice and opportunity for a hearing, that the jurisdiction did not submit a satisfactory report.  

Each Performance Report will include information about the uses of funds in activities identified in the DRGR action plan during the applicable quarter. 

This includes, but is not limited to, the project title, activity description, location description, and national objective; funds budgeted, obligated, drawn down, and expended; the funding source and total amount of any non–CDBG-DR funds to be expended on each activity; projected start and end dates and actual end dates of completed activities; achieved performance measures, such as number of housing units completed or number of low- and moderate-income persons served; and the race and ethnicity of persons assisted under direct-benefit activities. For all housing and economic development activities, the address of each CDBG-DR or CDBG-MIT assisted property must be recorded in the Performance Report. Grantees must not include such addresses in its public Performance Report; when entering addresses in the Performance Report, grantees must select “Not Visible on PDF” to exclude addresses from the report required to be posted on its official disaster website. The DRGR system will automatically display the amount of program income receipted, the amount of program income reported as disbursed, and the amount of grant funds disbursed. Grantees must include a description of actions taken in that quarter to affirmatively further fair housing, within the section titled “Overall Progress Narrative” in the DRGR system.

A Guide on How CDBG-DR Grantees Can Meet the Requirements of the Consolidated Notice