CITY COUNCIL POLICY ON FUNDING NONPROFIT ORGANIZATIONS

The City Council has adopted guidelines for nonprofit organizations applying to the City for funding. When the total amount of all requests from a nonprofit is $25,000 or more, the organization is required to submit its organizational business plan and certifications regarding the engagement of its Board of Directors as part of its application. All nonprofit organizations are expected to adhere to these guidelines as part of applying for 2023-2024 funding. While non-adherence to the guidelines will not necessarily prohibit an agency from receiving funding, adherence will be one of the key factors in determining the award of funding. (See Library Tab for policy.)

CITY COUNCIL POLICY ON HUD FUNDS

This year’s applications will represent the third full year in the Belmont-Fallon Target Area (BFTA). Applications can address issues city-wide or focus on the target area. On 10 October 2019, the City Council adopted changes to its Policy on HUD funds that had previously been in effect since 2015. Among the most pertinent to this application process are the following:

• • Beginning in 2020, the City selected the Belmont-Fallon Target Area (BFTA). This area encompasses portions of the Belmont and Fallon neighborhoods. (See the Library Tab for the target area.)

• • While applications for funding may be submitted to address any City neighborhood, preference will be given to those programs and projects that focus, in whole or in part, on the Belmont-Fallon Target Area. Applicants are advised to review the entire policy. (See Library Tab to review the revised HUD Policy.)

ADA AND SECTION 504 COMPLIANCE

In accordance with the Americans with Disabilities Act (ADA), Section 504 of the Rehabilitation Act of 1973, as amended (504), and applicable federal, state and local requirements, activities assisted with federal funds are required to be accessible to individuals with disabilities. Reasonable accommodation must be made whenever a qualified individual with disabilities seeks services. (The term “qualified individual with disabilities” means a person with disabilities who meets any eligibility criteria applicable to all persons seeking the respective services.)

• • All agencies applying for HUD funding assistance from the City for the 2023-2024 period thereby agree to:
    
    • Demonstrate progress in taking corrective actions identified in the 504/ADA Self-Evaluation and Assurance of Compliance. (See Library Tab for a copy of the self-evaluation documents.)

• • • Permit, during normal business hours, the City or individuals/groups designated by the City to visit and review the accessibility of their facilities and programs.

SAM.gov Registration

You must include a valid physical address (no PO Box), email address, phone number, and SAM.gov registration.

• • If you do not have a valid SAM.gov registration, please see
    https://sam.gov/content/entity-registration

APPLICATION ELIGIBILITY

• The U.S. Department of Housing and Urban Development (HUD) allocates funds from three federal entitlements to the City of Roanoke. Entitlements include the Community Development Block Grant (CDBG), HOME Investment Partnership Program (HOME), and the Emergency Solutions Grant (ESG). Additionally, the City may have remaining unprogrammed funds from the CARES Act of 2020 that may be applicable to programs that can demonstrate a need for preparation, prevention or recovery to the COVID 19 pandemic.
  
  
• Proposed projects must be eligible under U.S. Department of Housing and Urban Development (HUD) CDBG , HOME and/or ESG regulations and must fulfill at least one National Objective and one of the proposed activity types as outlined in Objectives for Activities for the 2023-2024 HUD Funding (found in Library Tab).
  
  
• The application must also be "fundable" under CDBG, HOME and/or ESG regulations.
  
  
• Private individuals are not eligible to submit project applications directly benefiting themselves. (For example, a homeowner is not eligible to request funds to rehabilitate a property that is used as his or her principal residence.) Projects must benefit a group of people and be administered by an agency or organization (i.e., a legal entity). The administrative capacity and prior experience of an agency or organization are some of the factors considered in the selection of qualified applications. Applications will be reviewed by a committee of city staff and citizens and ranked according to priority as funding allows, and then approved by the Roanoke City Council.
  
  
• Any private non-profit organization which provides or has the capacity to provide the needed services on a non-discriminatory and non-sectarian basis may receive funds to support eligible activities. Programs funded through this project may operate in buildings owned by religious or sectarian organizations; however, no such funds may be used to make physical improvements to buildings owned by religious or sectarian organizations, or to directly or indirectly support religious or sectarian functions.

CDBG and/or HOME ELIGIBILITY 

• CDBG funded activities must either benefit low-and moderate-income (LMI) persons/households (see Library for Income Limits) or eliminate slums and blight on a spot or area basis.
  
  
• All HOME-funded activities must benefit low- and moderate-income (LMI) persons/households. (See Library for Income Limits)
  
  
• Leverage - HUD is looking to see that the Federal Funds are multiplied by leverage being brought to the table. This is reported to HUD each year and is reported to Congress.
  
  
• Belmont/Fallon Neighborhood Revitalization Strategy Area (NRSA) Plan - In 2022 City Council adopted and HUD approved the NRSA Plan.  This plan identifies strategies to revitalize the Belmont-Fallon target area which includes new construction of affordable housing, rehabilitating owner-occupied housing, enhancing neighborhood business opportunities, providing rehabilitation to rental units for low-moderate residents, eradication of slum and blighting conditions, infrastructure improvements, and promoting employment opportunities. In coordination with the Roanoke Neighborhood Revitalization Partnership (RNRP), the City of Roanoke continues to forge a partnership with businesses, community groups, and residents to address community revitalization through a comprehensive strategy. (See Library for Adopted NRSA) 
• Projects Involving Acquisition, Construction, Rehabilitation: 

• • For projects involving acquisition, construction, rehabilitation or related activities to develop housing or public, neighborhood, commercial or industrial facilities:
    
    
    1. Identify the properties involved and indicate whether you have site control or the anticipated date when you will have site control.
       
       
    2. Attach your project proforma, sources by uses budget, or other financial feasibility data and describe how this information supports the feasibility of the project.
       
       
    3. Indicate whether the site and construction plans and designs have been prepared, submitted to and approved by the City; whether the project is expected to receive LEED, Energy Star, Earth Craft or other energy-efficiency certification; or whether it is expected to qualify for the City’s energy-efficiency tax reductions.

• • Indicate the total cost of this project (from start to finish) and whether all financing required, other than the amount applied for in this application, is in place. Indicate whether this project will be completed by 30 June 2024, and, if not, the anticipated completion date.

• • If any of the funding requested for this project will provide direct financial assistance to the buyers or the owners of residential or nonresidential property, indicate the nature of the financial assistance to be offered. (“Direct financial assistance” includes grants, active or deferred loans, as well as the cost of assistance provided on behalf of the buyer or the owner, such as the cost of contracted home repairs). If any of the assistance will be active loans, describe how these will be serviced, including the name and contact information for any servicing institution you have engaged for such purposes. Indicate the anticipated interest rates that will apply to assistance provided as loans. Note that selected projects will be expected to provide a sample file of all the loan documents that may be used and may be required to revise any documents in order to conform to provisions dictated by federal rules associated with the applicable funding source.
    
    
  • Compliance Factors: Substantial rehabilitations of owner-occupied properties and assistance to rental properties must result in the property meeting all applicable building and property codes. Such substantial rehabilitations may require liens to be placed against the property assisted with the applicants becoming party to the rehabilitation contract. All units assisted must comply with lead-based paint, historic review, environmental review, and other applicable federal requirements. Rental units assisted will be subject to affordable rent requirements.

ESG ELIGIBILITY

Proposed projects must be eligible under HUD Emergency Solutions Grant (ESG) regulations.  If you are unsure whether your application would be eligible, contact the Community Resources Division at (540) 853-6879.

• Background

• • Local non-profit organizations may apply for financial support to improve the quality of shelter facilities, to provide homeless prevention activities, provide resources for new initiatives, and to address the vision and goals as identified in the Strategic Planning: An Update on Our Work to End Homelessness in the Blue Ridge Continuum of Care. (Click on hyperlink or see Strategic Plan in Library Tab.)
    
    
  • The ESG program provides funding to:
    
    • Engage homeless individuals and families living on the street;
    • Improve the number and quality of emergency shelters for homeless individuals and families;
    • Help operate these shelters;
    • Provide essential services to shelter residents,
    • Rapidly re-house homeless individuals and families, and
    • Prevent families and individuals from becoming homeless.
      
      
• ESG includes five categories of eligible activities:

• • Street Outreach
    Essential Services related to reaching out to unsheltered homeless individuals and families, connecting them with emergency shelter, housing, or critical services, and providing them with urgent, non-facility-based care. Eligible costs include engagement, case management, emergency health and mental health services, and transportation.
    
    
  •  Emergency Shelter
    Major Rehabilitation, Conversion, or Renovation of a building to serve as a homeless shelter. Site must serve homeless persons for at least 3 or 10 years, depending on the cost. Note: Property acquisition and new construction are ineligible ESG activities.

Essential Services such as case management, childcare, education services, employment assistance and job training, outpatient health services, legal services, life skills training, mental health services, substance abuse treatment services, transportation, and services for special populations.

Shelter Operations, including maintenance, rent, repair, security, fuel, equipment, insurance, utilities, relocation, and furnishings.

• • Homelessness Prevention
    Housing relocation and stabilization services and short- (up to 3 months) and/or medium-term (more than 3 months, but less than 24 months) rental assistance as necessary to prevent the individual or family from becoming homeless if:

• • • Annual income of the individual or family is below 30% of median family income.
    • Assistance is necessary to help program participants regain stability in their current permanent housing or move into other permanent housing and achieve stability in that housing.

Eligible costs include utilities, rental application fees, security deposits, last month's rent, utility deposits and payments, moving costs, housing search and placement, housing stability case management, landlord-tenant mediation, tenant legal services, and credit repair.

• • Rapid Re-Housing
    Housing relocation and stabilization services and short- (up to 3 months) and/or medium-term (more than 3 months, but less than 24 months) rental assistance as necessary to help individuals or families living in shelters or in places not meant for human habitation move as quickly as possible into permanent housing and achieve stability in that housing. Eligible costs also include utilities, rental application fees, security deposits, last month's rent, utility deposits and payments, moving costs, housing search and placement, housing stability case management, landlord-tenant mediation, tenant legal services, and credit repair.

• • Data Collection (HMIS)
    Activities associated with administering of and contributing data to the Homeless Management Information System (HMIS).

• • Match Requirement:
    Applicants are encourage to provide a dollar-for-dollar (cash or in-kind) match will be provided. Applicants selected for funding will need to provide verification of the matching funds and/or sources to the City of Roanoke within thirty (30) days of funds being obligated.

• • Is my agency I an eligible Applicant?
    • Local non-profit organizations may apply for financial support to improve the quality of shelter facilities, to provide homeless prevention activities, provide resources for new initiatives, and to address the vision and goals as identified in the updated Strategic Planning: An Update on Our Work to End Homelessness in the Blue Ridge Continuum of Care.

• • • Any private non-profit organization, which provides or has the capacity to provide the needed services on a non-discriminatory and non-sectarian basis may receive funds to support eligible activities. Programs funded through this project may operate in buildings owned by religious or sectarian organizations; however, no such funds may be used to make physical improvements to buildings owned by religious or sectarian organizations, or to directly or indirectly support religious or sectarian functions.

AGREEMENT AND RELATED REQUIREMENTS:

• A written agreement or Memorandum of Understanding will be required for funds awarded to all successful entities. The agreement must be fully executed (i.e., signed by all parties) before the City can disburse any funds.
  
  
• Direct loans will have promissory notes, contracts, and deeds of trust securing them in addition to the loan agreement itself.
  
  
• In most cases, HUD funds are granted only for the twelve-month period of the program year for which applications are solicited.
  
  
• Extensions of agreements may be considered; however, in some cases, the approval of City Council may be required. Requests for extensions should be submitted to HCR at least 60 calendar days prior to the agreement’s termination date.
  
  
• In addition to the terms and conditions of the agreement with the City, organizations selected for funding are expected to comply with a variety of federal requirements. Organizations considering applying for funds are encouraged to consult the HUD publication "Playing by the Rules: A Handbook for CDBG Subrecipients on Administrative Systems". This free guide is available for review and/or download at: follow this link. (Click on either hyperlink or see Library Tab for the link to the or a PDF of “Playing by the Rules: A Handbook for CDBG Subrecipients on Administrative Systems”).
  
  
• While this guide does not cover the HOME or ESG program, it contains a wealth of information that may help applicants evaluate the costs and other effects of adding a CDBG funded program to their operations. These requirements, and other specific contract management requests and procedures maybe discussed individually or in a group meeting with the organizations selected for funding.

COST CONSIDERATIONS AND PAYMENT METHODS:

• For CDBG and/or HOME funded projects the minimum request to be considered must be at least $25,000. There is no maximum dollar limit on requests.
  
  
• Leveraging of funds is an important factor in the evaluation of your application. The City prefers to invest in activities in which the applicant also invests funds from its own sources and those which are raised from other funding partners. Rating points are awarded according to the amount of funds contributed to the cost of the program or project from sources other than the City. Note that funds provided with respect to HOME match requirements will count toward rating points in this regard. If leveraged funds are promised in your application, the City may choose to award the grant or loan contingent upon those funds being provided. If you are unsure what qualifies as leveraged funds, please contact HCR.
  
  
• Organizations expending $750,000 or more in federal funds in a year, which includes federal funds received from the City and any other source, are required to undergo an independent audit that conforms to the guidelines of federal OMB guidelines as outlined in the Uniform Administrative Requirements, Cost Principles and Audit Requirements in 2 CFR Part 200. (A link to this CFR can be found in the Library Tab.)  Organizations must submit a copy of the audit to HCR within six (6) months of the end of the audited period.  Single Audits are not required under the federal rules for organizations expending less than $750,000 in federal funds in a year. However, an audit is still required to per City Council Policy on Funding Nonprofit Organizations.  Consequently, audit costs for such organizations, including those associated with complying with the City Council Policy on Funding Nonprofit Organizations (see Library Tab), may not be included in the HUD funds requested in your application. Consult HCR if you are uncertain about audit requirements.
  
  
• Applicants selected to receive CDBG, HOME, or ESG funding must carry insurance coverage appropriate for the nature of the activities to be conducted. Coverage required may include Workers’ Compensation, Commercial General Liability, Employer’s Liability, and Automobile Liability, Dishonesty (or Fidelity Bond) and in certain types of programs Professional Liability/Errors and Omissions insurance. A certificate evidencing this coverage must be furnished to the City and must list the City of Roanoke, its officers, agents, employees and volunteers as “additional insureds.” The amount by which an organization's insurance costs increase due to this requirement may be included as part of the budget in your application. Because the types of insurance required vary significantly according to the activities, applicants should contact HCR for advice from the City’s Risk Manager (Insurance Matrix can be found in Library Tab).
  
  
• The purchase of equipment is generally not an eligible expense. Please contact HCR for assistance regarding whether equipment necessary for your project may be purchased with HUD funds.
  
  
• Depending upon the nature of the project(s) proposed, you will be required to obtain and retain documentation of the eligibility of the individuals or families served by or benefiting from your activities. This may be as simple as obtaining data from HCR that 51% of the residents of the area you plan to serve meet low- and moderate-income limits. Others may have to obtain, evaluate, record and retain specific information from each individual or family to document qualifying income and will have to enter all such information in the HUD Income Calculator. Such documentation may be required before any funds can be expended or before individuals or families can be served. Because projects vary widely, no single documentation guideline applies to all. These requirements can, however, affect project designs and costs. Contact HCR regarding requirements that may apply to your specific project.
  
  
• CDBG funds may be requested for organizational capacity or staff development necessary to provide services.
  
  
• Payment will be made on a reimbursement basis only for all projects seeking funding, whether from CDBG, HOME, or ESG. Payment will only be made upon submission of current monthly/quarterly reports as outlined in written agreements or MOUs.
  
  
• Final reimbursements must be requested not later than 30 calendar days after the expiration date of the agreement. Please note that the City is under no obligation to honor requests for payments received after these time limits. Costs incurred prior to the effective date or after the expiration date of your agreement with the City cannot be reimbursed without prior authorization from HCR.

• HOME Match Requirement: Applicants applying for or designated to receive HOME or HOME/CHDO funds are expected to contribute a minimum of 10% in matching funds from one or more of the sources referenced in the HOME regulations at 24 CFR 92.220 and 92.221. In kind labor should be valued at $10.00 per hour per person.

• • • Note: In order to ensure the effective commitment of available funds, the City reserves the right to make awards for selected applications from either CDBG or HOME funds or both, irrespective of the types or proportions of the funds requested, according to the nature of the activities proposed. In cases where HOME funds were not requested but are awarded by the City and accepted by the applicant, the applicant will be expected to contribute HOME Match to the same degree as if HOME funds had been requested.
      
      
  • HOME CHDO Funds: These funds are available only to City-certified Community Housing Development Organizations (CHDOs). In order for the activities to qualify under this category, the CHDO must be the owner, developer or sponsor, as defined in the HOME regulations. Housing assistance must benefit low- and moderate-income households exclusively. For information on the process and requirements to obtain CHDO certification, contact the HUD Community Resources division.
    
    
• Staffing, Direct and Indirect Costs:
  The Uniform Administrative Guidance (2 CFR §200.413) defines direct costs as “those costs that can be identified specifically with a particular final cost objective.” For ESG and CoC programs, most expenses are direct costs and are exclusively used for that program (e.g., case manager salary, rental assistance for clients, purchase of food for shelter meals).  For CDBG and HOME programs, the most expenses will be in direct program/project expenses (e.g., rehab and materials).  Expenses considered to be "project administrative costs" those paid in direct support of the program/project would be considered direct (e.g., the salary and fringe for the employee actively implementing the project). 
  

  In contrast, indirect costs (2 CFR §200.56) are costs “incurred for a common or joint purpose benefiting more than one cost objective, and not readily assignable to the cost objectives specifically benefitted.” These costs are shared by more than one program. Examples of these types of expenses would be rent, utilities, office supplies, phone, administrative support staff salary/wages, etc...  

  • Regarding direct cost reimbursement:
    
    • Any staffing and other administrative direct costs (technically known as “project administrative costs” costs) that are associated with activities that are the subject of a funding application, must be made part of that application and must be reasonable in light of the activities to be conducted and results to be achieved. The City will not accept separate applications for staffing and overhead costs, whether or not related to another application. Priority will be given to projects that limit “project administrative costs” costs to 20% or lower of total project costs for CDBG &/or HOME funded projects and 7.5% for ESG funded projects.
      
      
    • The City expects staffing costs included in this application to be of a “direct charge” nature, supported by time records in 15 minute intervals and other source documents such as invoices, bills and receipts. 
      
      
  • Regarding indirect cost reimbursement:
    
    • If your organization has a Negotiated Indirect Cost Rate Agreement through any federal agency, provide a current approved agreement in the Documents Tab.
       
    • If your organization does not have a Negotiated Indirect Cost Rate Agreement the city will use the De Minimis Cost Rate to calculate the disbursement of funds to cover indirect costs. 
      
      
  • Calculating Indirect Reimbursement Amounts:
    Either the Negotiated Indirect Cost Rate Agreement or the De Minimis will be applied to the Modified Total Direct Costs (MTDC).  Line items included in calculating the MTDC are direct salaries and wages, applicable fringe benefits and any other eligible allowable expenses.  Note either cost rate can only be applied to eligible expense and is not applied to the entire grant allocation.

APPLICATION REVIEW, RATING AND SELECTION PROCESS:

• • The written application must stand alone and will serve as the primary vehicle for applicants to provide information on proposed projects.  Applicants may also be asked to submit additional information and/or to attend an interview with the review committee(s). Inaccurate, incomplete, or unclear applications may be disqualified. If this is a multi-year project, you will be asked to define the performance outcomes to be accomplished by 30 June 2024, and may be asked to submit a separate budget for the overall project. (Note: Awards do not imply a commitment by the City to provide funds in subsequent years of multi-year projects.)
    
    
  • Additional information or clarification may be requested during the application review process or even after the City officially agrees to fund your project. Applicants must respond satisfactorily to requests within the time frames specified. Failure to provide needed information may result in the project not being recommended to City Council.
    
    
  • Your application must convince the review committee(s) that your project is well thought out, adequate staffing capacity/training exists, will be ready to start 1 July 2023 and can be accomplished by 30 June 2024.

CDBG and/or HOME Applications

• • • HCR (HUD Community Resources) staff will review each application for eligibility based on the federal regulations. Applications will then be forwarded to the appropriate citizen review committee. Citizen review committees will rank applications on overall community needs as identified in the 2020-2024 HUD Consolidated Plan and benefits provided and organizational capacity among other factors.  Applicants should be aware that projects may be recommended to City Council with full or partial funding based on availability of funds.
      
      
    • The citizen review committees and HCR will evaluate the eligible applications based on a variety of factors. (See Library Tab for a copy of the Scoring Matrix.)

ESG Applications

• • • The HUD Community Resources Division (HCR) will review each application for eligibility based on the federal regulations. Applications for Emergency Solutions Grant (ESG) funding will then be forwarded to the Blue Ridge Interagency Council on Homelessness (the review committee) for their review and recommendations for funding.
      
      
    • The review committee and the HUD Community Resources (HCR) Division will evaluate the eligible applications based on a variety of factors. The HUD Community Resources Division will provide technical assistance and staff support for the review committees. (See Library Tab for ESG Scoring Matrix)