Program Specific Requirements

Program Specific Requirements

Projects planned with all CDBG funds expected to be available during the year are identified in the Projects Table. The following identifies program income that is available for use that is included in projects to be carried out.

1. 
   A description of other forms of investment being used beyond those identified in Section 92.205 is as follows: N/A The City of Tampa only funds eligible activities as described under 92.205
   

2. 
   A description of the guidelines that will be used for resale or recapture of HOME funds when used for homebuyer activities as required in 92.254, is as follows:
   

3. 
   The City of Tampa uses the recapture option 24 CFR 92.254(a) (5)(ii)(A)(1) to ensure long-term affordability of the assisted property. The entire amount of the direct HOME subsidy becomes due and payable upon transfer of ownership interest during any point of the affordability period. The affordability periods are determined by the subsidy dollar levels and programs. The recapture requirement is subject to the limitations of the mortgage documents in place when the recapture requirement is triggered by a sale (voluntary or involuntary) of the housing unit. The amount recaptured cannot exceed the net proceeds, if any (or the amount of the HOME subsidy). The net proceeds are the sales price minus superior loan repayment (other than HOME funds) and any closing costs. To secure the city’ s investment throughout the affordability period, the City uses a mortgage note attached to each property in the amount of the assistance. HOME funding language is included in all contract documents. The City’s HOME program policy and procedures as well as the mortgage and contract documents are available for public review at the City’s HCD Office.
   

4. 
   A description of the guidelines for resale or recapture that ensures the affordability of units acquired with HOME funds? See 24 CFR 92.254(a)(4) are as follows: The City of Tampa uses the recapture provision 24 CFR 92.254(a)(5)(ii)(A)(1) to ensure long-term affordability of the assisted property. The entire amount of the direct HOME subsidy becomes due and payable upon transfer of ownership interest during any point of the affordability period. To impose and ensure the affordability and recapture provision, the City uses a mortgage note attached to each property in the amount of assistance. The City’s HOME program policy and procedures, as well as the mortgage and contract documents, are available for public review at the City’s HCD Office.
   

5. 
   Plans for using HOME funds to refinance existing debt secured by multifamily housing that is rehabilitated with HOME funds along with a description of the refinancing guidelines required that will be used under 24 CFR 92.206(b), are as follows: The City does not anticipate using any HOME funds to refinance existing debt secured by multi-family housing units that are being rehabilitated with HOME funds. In the event that it becomes necessary to refinance such existing debt, the City will seek HUD’s prior approval as needed on a case by case basis.
   

1. 
   Include written standards for providing ESG assistance (may include as attachment)
   

The City of Tampa issued an RFA for funding consideration under the Emergency Solutions Grant (ESG) grant program. ESG funding was available for emergency shelter and housing services for homeless persons throughout the City of Tampa.

• 
  No more than 5% of Emergency Solutions Grant funds may be utilized for administrative costs.
  
• 
  ESG Project Sponsors must ensure the consistent participation in UNITY the local Homeless Management and Information (HMIS) system administered by the Tampa Hillsborough Homeless Initiative.
  
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  Successful Applicants must utilize the Tampa Hillsborough Homeless Initiative’s Coordinated Intake and Assessment System (CI&A). Further, the successful Applicant will establish a Memorandum of Understanding (MOU) with the community organizations participating in the Coordinated Intake & Assessment (CI&A) process established by the Tampa Hillsborough Homeless Initiative.
  
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  The awarded agencies must also agree to abide by the policies and procedures written and provided by the Tampa Hillsborough Homeless Initiative any subsequent amendments.
  
• 
  ESG grant funds must be matched, dollar for dollar, with locally generated amounts.
  

2. 
   If the Continuum of Care has established centralized or coordinated assessment system that meets HUD requirements, describe that centralized or coordinated assessment system.
   

The City of Tampa is a member of the Hillsborough County Continuum of Care. The Tampa Hillsborough Homeless Initiative (THHI) coordinates delivery of the Continuum of Care programs within the community and is the lead entity for HUD CoC grant programs. THHI has established a Coordinated Intake and Assessment (CI&A) program. All referrals are received through the Coordinated Intake and Assessment service site where triage of the individual or family begins.

3. 
   Identify the process for making sub-awards and describe how the ESG allocation available to private nonprofit organizations (including community and faith-based organizations).
   

The selection process for ESG Project Sponsors will be determined through a Request for Application (RFA) that is coordinated in partnership with the Tampa Hillsborough Homeless Initiative.

4. 
   If the jurisdiction is unable to meet the homeless participation requirement in 24 CFR 576.405(a), the jurisdiction must specify its plan for reaching out to and consulting with homeless or formerly homeless individuals in considering policies and funding decisions regarding facilities and services funded under ESG.
   

The Tampa Hillsborough Homeless Initiative is the lead entity for the Continuum of Care (COC) planning process in Tampa and Hillsborough County. The Initiative is responsible for establishing and maintaining strategic efforts to develop long-term constructive solutions that address the underlying causes of homelessness as well as meet the immediate needs of currently homeless people. The City of Tampa is an active partner in working with the Tampa Hillsborough Homeless Initiative to develop the Continuum of Care needs assessment and strategic plan and recently participated in the homeless count. The City participates in the Initiative’s ongoing and annual efforts to implement the Tampa/Hillsborough's 10-year plan to end chronic homelessness. The City recently participated in planning groups to assist in drafting and updating the community’s plan. CoC members include former and current homeless individuals, veterans, persons with HIV/AIDS, and residents of the community, private business and community foundation representatives, non-profit organizations, advocates, treatment providers and local government representatives.

5. 
   Describe performance standards for evaluating ESG.
   

The City of Tampa adheres to using IDIS as the main reporting tool for the ESG program. In addition the City requires that all providers awarded with City ESG funds use and maintain an active participant role in using the local HMIS known as UNITY. Both IDIS and UNITY capture the federally required reporting fields to assist in evaluating the program goals and objectives.

City of Tampa ESG providers are also asked to submit quarterly reports which mirror the reporting forms in IDIS. As a result, the City is able to review program goals and objectives quarterly to ensure that goals are being met.
Program Monitoring
The goal of program and project monitoring is to ensure that HUD-funded projects and activities are implemented in a timely manner in accordance with Federal and state regulation requirements. As a means to achieve this goal, the City’s project monitoring effort focuses on identifying deficiencies, making corrections, and providing technical assistance in order to improve the performance of the City and all its partners. This process involves effective communication and cooperative problem-solving relationships between the City and its Contractors, subrecipients, and project sponsors.
Project monitoring activities are comprised of desk reviews and on-site visits. The monitoring consists of a review of management procedures, goal establishment and achievement, record keeping, organizational financial status, construction and labor standards (if applicable), procurement procedures, and many other areas. The information that is reviewed is outlined in checklists that have been developed for each type of activity. These checklists were created using HUD’s guidance, HUD’s Monitoring Handbook, and regulations and other statutory requirements for each funding source.
Desk Review

Desk review is an ongoing process, in which the program representative responsible for overseeing the project uses all available information to review the subrecipient’s or project sponsor’s performance in carrying out the approved project or activity. This review process establishes two things. It enables the City to identify problems requiring immediate attention, and preparation for the more in-depth on-site monitoring. Material used for this review includes, but is not limited to, the executed subrecipient/project sponsor agreement, requests for reimbursement, quarterly and annual reports, audits, the certificate of liability insurance, client eligibility information (if applicable), documentation from previous monitoring visits, and the original funding application.

On-site monitoring is a structured review conducted by the program representative at the locations where either project activities are being carried out, or project records are being maintained. In preparation of the on-site monitoring visit, the assigned Community Development Specialist (CD Specialist) contacts the agency to explain the purpose of the visit, schedules a time and date, sends a confirmation letter, and performs a desk review.

Once on-site, the CD Specialist reviews the subrecipient or project sponsor files, including source documentation, to ensure compliance with all regulations governing their administrative, financial, and programmatic operation. The CD Specialist also verifies that their performance objectives are on target and that the activity or project is projected to be completed within budget. This information is utilized to complete the appropriate checklist and provide the subrecipient/project sponsor with tentative conclusions during the exit interview.

Once the on-site visit is concluded, a formal written report describing the results of the visit, as well as any findings or concerns, is provided to the agency. This report also recommends corrective items to address and rectify the problem areas, if necessary. Once the corrective actions have been completed, the City closes out the monitoring review.

The monitoring staff performs an annual desk review and an on-site monitoring visit for each public service activity to ensure that subrecipients are compliant with federal regulations and statutory requirements, as well as the terms of their subrecipient agreement with the City. Additional monitoring takes place with each Request for Payment that is received. Prior to approval, staff verify client eligibility with regard to the criteria outlined in their agreements such as Tampa residency, services provided, whether the rate of reimbursement is appropriate for the services provided, as well as other criteria such as age or disability status, if appropriate. The overall rate of spending is also reviewed at this time. Once it is determined that all activities and clients are eligible, two levels of approvals are obtained and then the payment is processed. This periodic (often monthly) review enables the City to assess progress and ensure the timely expenditure of funds.

The Housing and Community Development Division is responsible for monitoring all other projects and activities that are funded by CDBG, HOME, ESG, and HOPWA. At the beginning of each program year, HCD develops an Annual Monitoring Plan/Schedule for all projects and activities. This plan is derived by conducting a risk assessment analysis on all projects and activities included in the Action Plan. Additionally, the Monitoring Plan takes into consideration HUD’s requirements for post-completion monitoring such as minimum-use period, affordability, income eligibility, and housing quality standards requirements.

A risk assessment is a qualitative analysis of certain risk factors that helps determine the relative compliance and performance risk for a specific project or activity. This indicates who should be monitored, when monitoring should occur, and at what level the monitoring should be conducted. The objective of the risk assessment is to allocate a larger share of monitoring resources to those program functions posing the highest risk. The risk factors considered include program/project complexity; level of funding; subrecipient, public agency or project sponsor capacity; quality of existing reporting documentation; and whether there is a history of compliance issues.

All projects administered by HCD undergo annual desk reviews as well as periodic reviews when reimbursement is requested. When these activities involve construction, HCD staff members perform a physical inspection of the work that has been completed and reviews the Davis Bacon documentation prior to any payment, if applicable. On-site monitoring visits are conducted in accordance with the Annual Monitoring Plan/Schedule.

Once the development phase of a multi-family housing project is complete, an initial rent and occupancy review is conducted. This includes the review of tenant’s income eligibility, lease provisions, a physical inspection of property conditions, and verification of compliance with federal requirements such as fair housing and affirmative marketing.

Ongoing monitoring for these projects is conducted annually to ensure continued compliance with all applicable regulations. Elements of this review include: maintenance of appropriate records, evidence that the property’s written tenant selection policy has been followed, acceptable lease documents, evidence of affirmative marketing and conformance with fair housing policies, review of rent adjustments, review of treatment of rents for tenants who no longer qualify as low-income families, review of corrective procedures dealing with temporary noncompliance caused by increases in the incomes of existing tenants, ensure compliance with the written agreement between the owner and the City, physical inspections for compliance with property standards, and verification of accuracy of information submitted by owners on eligible tenant incomes and HOME rents.

Community Housing Development Organization (CHDO) Qualification and Re-Certification.

Each CHDO is recertified per project; the review for certification includes a review of the entities board of director’s, staff capacity, financial statements, mission statements, and an overview of past and current projects.

The City of Tampa understands the importance of performing a periodic self-evaluation with respect the goals and objectives outlined in the Consolidated Plan as well as the activities included in each Action Plan. The purpose of this review is to ensure long-term compliance with program and comprehensive planning requirements.

The primary means of assessing program performance is through the development of the Consolidated Annual Performance and Evaluation Report (CAPER) at the end of each program year. The information that is provided in this report allows the city and HUD to review the overall program performance. The performance measurement system clearly demonstrates whether the city has met the annual goals and objectives and whether the city is on target to meet the five year goals and objectives.

The second layer of program performance is provided through a periodic review by the city’s Internal Audit Department as well as an annual review by independent external auditors. The information that is obtained from these audits is evaluated and often incorporated as revisions to the city’s policies and procedures.

In response to HUD Community Planning and Development (CPD) Notice: CPD-03-09, Development of State and Local Performance Measurement Systems for Community Planning and Development (CPD) Formula Grant Program, the City of Tampa utilize the Performance Measurement Systems.

Performance measurement is done in two stages, first information is collected to determine how well programs and projects are meeting needs, and then that information is analyzed to determine performance gaps and then available resources are applied to these gaps.

The city utilizes other federal funds such as CDBG, HOME and HOPWA to assist with homelessness issues through non-profit organizations that provide such services. The City also provides operational support on an annual basis to the Tampa Hillsborough Homeless Initiative through its General Fund.