Speakers. ESG Learning Opportunity Overview Focus on different ESG-related topics each month Occurs 1 st Wednesday of each month at

Transcription

1 Emergency Solutions Grants (ESG) Learning Opportunity: Match February 1, 2017 *Slide 45 updated on February 3, 2017 Speakers Naomi Cantu Coordinator for Homelessness Programs and Policy HOME and Homeless Programs Division Kay Fairbanks Senior Performance Specialist HOME and Homeless Programs Division For program assistance, please 2 ESG Learning Opportunity Overview Focus on different ESG-related topics each month Occurs 1 st Wednesday of each month at 10:0000 am ESG Learning Opportunities recorded and posted online 3 1

2 Webinar Objective Provide guidance on what and how to count ESG match Match Basics Match M h Uses Match Sources Match Allocation Match Reporting and Recordkeeping 4 Match Basics 5 Match Purpose and Amount Match must supplement the recipient s ESG Program ESG requires 100% match 24 CFR (a) 6 2

3 Match Waiver Statewide match waiver TDHCA is allowed a $100,000 match waiver which can be granted to qualifying ESG Subrecipients 2017/2018 ESG Application Cycle A match waiver can be requested for up to 100% of the ESG award (up to $600,000) 7 Match Waiver (con t) Applicant match waiver request states: How much match is requested to be waived Why the waiver is being requested The size of the community requesting match Funds currently held by the applicant/partners Losses of essential services from other sources An annual budget is $600,000 or less Applicants that do not receive a waiver and are not able to provide 100% match will be ineligible for an award. 8 Match Incentive Incentives for additional match 2017/2018 ESG Notice of Funding Availability provides additional points for 110% or more of match provided per applicant 9 3

4 Match Time Frame Provided after the date that HUD signs the grant agreement to TDHCA through Contract Term August 18, 2016 August 31, 2017 for 2016 ESG contracts Date HUD signs the grant agreement (to be determined) End of the Contract Term for 2017 ESG contracts Typically HUD signs the grant agreement in July or August of each year, though the timing may change. 10 Match Expenditure Ratios Match is not subject to expenditure limits match does not have to meet the 60% limit on street outreach and emergency shelter match does not have to meet the 3% or 3.5% limit on administration 11 Match Used Once Match sources can be used only once as match Match cannot be used to match any other federal program before used for ESG match Match cannot be used to match any other federal program after used for ESG match Match cannot be used to match two ESG Programs 12 4

5 HUD Guidance What sources of funds can be used as cash match for ESG: hat-sources-of-funds-can-be-used-as-cash- of funds can used as cash match-for-esg/ HUD ESG FAQ: s/emergency-solutions-grants-esg-program/ 13 Match Uses 14 Match Eligible Activities Matching contributions must be spent on eligible ESG activities: Street Outreach, Emergency Shelter, Rapid Rehousing, Homelessness Prevention, Homeless Management Information System (HMIS), Administration ESG Basics:

6 Match Eligible Clients Persons assisted with match must meet: Definitions of homeless Definition of at-risk of homelessness and income qualify Homeless Definitions, i i Homeless Definitions i i Recordkeeping, Income Eligibility Training at 16 Match Activities Mirror Contract Activities Subrecipients may provide match for activities in the ESG Contract: If Subrecipient offers Homelessness Prevention, the Subrecipient can provide Homelessness Prevention match If Subrecipient does not have Homelessness Prevention listed in the ESG contract, the Subrecipient cannot provide Homelessness Prevention as match Applies to each ESG Activity 17 Match Activities Mirror Contract Activities (con t 2) For collaborative applicants, if providing emergency shelter as match Ensure that the ESG application includes emergency shelter Ensure that the lead or partner providing the ESG match submits Attachment G: Local Government Approval of the shelter activity 18 6

7 Match Activities Mirror Contract Activities (con t 3) Example: Agency 1 is the lead and partnering with Agency 2 and Agency 3 Agency 1 is going to submit an ESG app lication with emergency shelter performance targets and a budget for Agency 1 and 2 Agency 3 is going to provide ESG match through emergency shelter Agency 3 must submit an Attachment G even though Agency 3 is not receiving ESG funds for emergency shelter 19 Inpati Match Ineligible Costs ESG ineligible costs include: Acquisition of real property/new construction Legal services for immigration and citizenship matters, and issues relating to mortgages tient detoxificati tion/inpati ent drug treatment Payment of temporary storage fees in arrears Bad debts/late fees Payment or modification of a debt Rehabilitation of structures to the extent that those structures are used for inherently religious activities Mortgage payments 20 Match Sources 21 7

8 Match Sources Federal sources of match are allowed, with exceptions Value of buildings used for ESG, with exceptions Fair rental charges for buildings used for ESG State sources Cash Noncash contributions Program income from TDHCA ESG activities 22 Match Federal sources Match may be provided from federal sources, unless The federal Appropriations Act prohibits the use as match Federal program rules prohibit the use of those funds as match The funds are ESG funds from other fiscal years 23 Match Federal sources (con t 1) Program rules generally prohibit the use of these funds as match: Supplemental Nutrition Assistance Program (SNAP) Housing Choice Vouchers Tenant s portion of the rent HOME Tenant Based Rental Assistance* HUD s Supportive Housing Program* *Rare exceptions to use as match. Contact TDHCA before proceeding with match from these sources. 24 8

9 Match Federal sources (con t 2) Eligible sources of federal match Community Service Block Grants (CSBG) per HUD s FAQ: Projects for Assistance in Transition from Homelessness (PATH) per HUD answer 25 Match Value of Buildings Cannot be used if counted as match for previous ESG Applications. Count the lesser of: The value of the remaining life of the property at the time of the donation, or The current fair market value. 26 Match Building: Life of property Life of property found in: Latest Single Audit If no Single Audit, use the Audited Financial Statements Submit accounting records as part of the ESG Application to show the property's value Show the calculation on how a portion of the value was estimated to be used by ESG 27 9

10 Match Building: Fair Market Value Letter from a licensed real estate salesperson, broker, appraiser Letter must state: Location of the building Habitable/usable square footage Value per square foot Space utilization for ESG Total fair market value for the building Current as of 2017 Submit letter with ESG Application to show the property's value based on cost allocation 28 Match Building: Fair Market Rent If not cash, obtain a letter from a licensed real estate salesperson, broker or appraiser: Location of the building Habitable/usable square footage Value per square foot Total fair market value for the building Space utilization for ESG Total lease or rent value based on 12-month occupancy Current as of 2017 Submit letter with ESG Application to show the property's value based on cost allocation 29 Match State Sources Must meet Match Basics Requirements, such as client eligibility and activity eligibility Examples: Some clients in Homeless Housing and Services Program Some clients in Healthy Communities Collaborative 30 10

11 Match Cash Raised or on hand cash used to support ESG Program 31 Volunteers Match Non-cash Value at rates consistent with paid persons for similar work at the Applicant s organization or labor market Donations Eti Estimated tdvalue for all lld donated td goods 32 Match Program Income Program Income 2 CFR Can include a security or utility deposit returned to the Subrecipient during the contract term Timetable: During contract term, use program income on ESG eligible activities and count as match, or return to TDHCA Up to two years after the end of the contract term program income must be returned to TDHCA More than two years after the end of the contract, returned security or utility deposits are not considered 33 program income 11

12 Match Allocation 34 Cost Allocation Overview Steps 1. Develop a Written Cost Allocation Plan Allocate shared costs to multiple programs and funding sources appropriately 2. Document how each program is charged an equitable portion of the shared costs based on benefit received Citations: 2 CFR Texas Uniform Grant Management Standards (UGMS) (Local Governments Only) 35 Cost Allocation Plan (CAP) CAP describes shared costs and allocation of costs Documentation in CAP: Schedules Spreadsheets Timesheets that document the distribution of shared costs 36 12

13 Definitions Shared Costs - cost that benefits more than one program Direct Costs - cost that is identified specifically with a particular award or project. Indirect Costs - cost that is for common or joint objectives and cannot be identified with a particular objective. 37 Example Let s buy a new copier 3 programs are using the copier 1 program uses the copier for 100 copies per month 1 program uses the copier for 50 copies per month 1 program uses the copier for 250 copies per month Total copies: programs benefitted from the copier How should we share the cost? 38 Example Allocating Costs 1. Divide by three 2. Base it on each program's funding amount (i.e., the program with the most money pays the most) 3. Base it on last year's usage of the old copier 4. Base it on the plan we made a month ago when we decided to buy the copier 5. Base it on proportion of the cost of each program's use (i.e., pro-rata share) 39 13

14 Example Allocating Costs (2) 1. Divide by three Equal Share is allowed if you have an indirect cost rate 2. Base it on each program's funding amount (i.e., the program with the most money pays the most) Size of Program, allowed if you have an indirect cost rate 3. Base it on last years' use of the old copier History not allowable 4. Base it on the plan we made a month ago when we decided to buy the copier Budget not allowable 5. Base it on proportion of the cost of each program's use (i.e., pro-rata share) Benefit Received Best Way! 40 Direct Cost Allocation Example If an organization has one person managing more than one program: The manager's salary could be allocated to each program based on the hours spent on each program (pro-rata share) 41 How to Select an Allocation Method? Allocate costs in proportion to the benefits received Similar costs allocated by same methodology. Examples: Using the percent of square footage utilized by each program to allocate rent, utility bills, and building maintenance costs Using the percentage of full time employees to allocate administrative salaries Using a mileage log to allocate the cost of a van 42 14

15 Budget Percentages Budgeted percentages cannot be used Must use actual activity or an allowable and reasonable cost allocation methodology 43 Direct Allocation of Salary Time sheets for direct program staff must identify: which program an employee is working on the number of hours worked by program If an employee works on multiple programs, an employee s time sheet must show: how much time was spent on each program (i.e. hourly distribution if from multiple sources) 44 Allocating Building and Maintenance Costs Building costs e.g., rent, equipment, depreciation, utilities, insurance and maintenance Use proportion of ff full time employees to allocate building costs if use of space is similar * Space utilization allocation method must be used if use of space varies *Updated from webinar on February 1,

16 Allocating Building and Maintenance Costs Space Utilization Example: XYZ Organization administers 4 different federal programs, one of which is ESG. However, documentation confirms that ESG requires 50% of the building space and the remainder of the space is shared by the other 3 smaller programs. Therefore, 50% of the building rent, utilities, insurance and maintenance costs could be allocated to ESG as match. 46 Allocating Supplies and Other Costs Best method: charge supplies to a particular program It is acceptable to allocate the cost of supplies based on FTEs Copier costs can be allocated with a log or by direct salaries 47 Match Reporting and Recordkeeping 48 16

17 Match Reporting Matching contributions must meet all requirements that apply to the ESG funds including: Reporting in HMIS Reporting of applicable outcomes in TDHCA s monthly Performance Report Reporting of type of match in Monthly Expenditure Report Applicable recordkeeping requirements depending on the type of match 49 Documenting Costs Evidence that costs were: Incurred during the grant period Actually paid (or properly accrued) Expended on allowable activities Expended on allowable items for eligible participants Approved by a responsible official 50 Documenting Costs (con t) A purchase request must: identify which program(s) benefited from an item purchased show the percentage of costs charged to each program If purchase requests are not used, a distribution spreadsheet should support how costs were allocated 51 17

18 Examples of Match Documentation Type Donated Supplies Cash Donations Value of Donated Building Salaries Volunteers Program Income Documentation Source and Value Source and Value Location, Value, and Realtor Letter if not used previously for ESG Timesheets Timesheets Source and Value 52 Questions? 53 Contact Information TEXAS DEPARTMENT OF HOUSING AND COMMUNITY AFFAIRS 221 E. 11th Street, Austin, TX P.O. Box 13941, Austin, TX ESG: Program Assistance: 54 18

19 # Question from Match Webinar Answer 1 2 Can any volunteer be used as match? even if they are not skilled. Can we replace appliances (washers/dryers) used by residents of shelter? Yes, as long as the volunteer is working on ESG eligible activities and/or with ESG eligible clients. For example, a volunteer who files papers in the office may count toward administrative match. However, make sure that the volunteers are participating in activities which match their skills. For example, unskilled volunteers should not conduct case management without proper training. If the shelter owns the Washer/Dryer it would be covered in 24 CFR (a)(3) as a furnishing and it would be an eligible ESG expense. Under that criteria it is a match eligible item, assuming funds that were spent on it were eligible or it was donated by a third-party. The value of the donation will depend on if the washer/dryer is owned or rented. See 2 CFR for additional information. 3 Resource for volunteer hourly rate Information on the value of donated labor may be found in 2 CFR (e): "Volunteer services furnished by third-party professional and technical personnel, consultants, and other skilled and unskilled labor may be counted as cost sharing or matching if the service is an integral and necessary part of an approved project or program. Rates for third-party volunteer services must be consistent with those paid for similar work by the non-federal entity. In those instances in which the required skills are not found in the non-federal entity, rates must be consistent with those paid for similar work in the labor market in which the non-federal entity competes for the kind of services involved. In either case, paid fringe benefits that are reasonable, necessary, allocable, and otherwise allowable may be included in the valuation. 4 5 Can the value of a building be used as match if owned by the recipient? What about the value of renovations on an eligible bldg, or a bldg where the value of the bldg was previously used? A portion of the building owned by the Subrecipient and used for ESG may count as match. For the calculation of how much of the building can be used as match, see slides The eligibility and valuation of match in this circumstance is dependent on a number of factors. Please see TDHCA for more information. 1

20 # Question from Match Webinar Answer 6 In today s presentation on slide 26, Match Value of Buildings, it stated that value of building cannot be used if counted as match in previous ESG applications. I d like to clarify that Match Building: Fair Market Rent is a separate category and that we are able to use the fair market rent of our shelter again in this year s application, given that we provide a letter from a license real estate salesperson, broker, or appraiser. The fair market rent is different that the donation of a building s value for use with ESG. The fair market rent is expended yearly, so it may be eligible to be used yearly as match with the appropriate documentation. However, to qualify as fair market rent the amount must be documented with all of the requirements in 2 CFR regarding Cost Sharing or Matching (except for (b)(4) and (5)). Additionally, if rent is treated by the entity as an indirect cost, per 24 CFR (e)(3) there would have to be a federally approved indirect cost rate and a special rate for allocating the value of those contributions. 7 8 Can we use Comprehensive Emergency Assistance Program (CEAP) as match for those clients receiving services that are 30% AMI? if we receive donations of furniture, household supplies, etc for the homeless that we get into permanent housing can that be used as match For your questions about CEAP, if you will be using CEAP as match, Subrecipients would need to make sure that: (1)The federal Appropriations Act for the year(s) of CEAP funds that the Subrecipient uses as match does not prohibit use as ESG match; (2) CEAP Program Rules do not prohibit the use as ESG match; (3) the clients are below 30% Area Median Income if used for Homelessness Prevention or re-certification for Rapid Re-housing (note that CEAP clients are qualified based on poverty rate and use a different definition of income, so ESG income certification would require different documentation); (4) the clients meet the definition of homeless or at-risk of homelessness; (5) the units meet Habitability Standards. No. Furniture is not an ESG eligible cost for rapid re-housing or homelessness prevention, so it cannot be used as ESG match. 2

21 # Question from Match Webinar Answer 9 10 Does the rule that state you cannot use real property as match if you ve used it for match in previous FY s for ESG go into effect for FY or is that a standard rule? What are the parameters for using HOME tenant-based rental assistance (TBRA) funds as match? We serve many recipients of TBRA that are 30% AMI. Since that is a ESG requirement can we use those client services as match in lieu of using ESG funds. 11 The use of HUD SHP funds as a match. HUD guidance, released in July 2012, states The matching funds have not been and will not be used to match any other Federal program s funds nor any other ESG grant. In TDHCA s ESG NOFAs or Application Guides from , a similar provision is used, such as: Contributions used to match a previous ESG grant may not be used to match a subsequent ESG grant. Therefore, the prohibition for using the donation of a building is not a new requirement for FY ESG. HUD's guidance at states that HOME TBRA may be an allowable source of match in rare instances for ESG. While theoretically allowable, the ESG Subrecipient would need to take on a large responsiblity to ensure that both HOME and ESG regulations would be met. Contact TDHCA before proceeding with using HOME TBRA as match, and TDHCA will make a determination as to allowability on a case-by-case basis. Per HUD's guidance at "SHP funds generally cannot be used as match, because very few activity costs are allowable under both SHP and ESG." More detail of the HUD guidance can be found at the link provided. If a TDHCA ESG Subrecipient wants to use SHP as match, contact TDHCA before proceeding. 3