Administering Programs

Part 2: Effective Program Implementation

Once jurisdictions have decided to use HOME and/or CDBG funds to finance a project or program, there are some implementation variables to consider, including:

  • Administering programs;
  • Choosing projects and partners;
  • Setting up adequate financial systems;
  • Developing efficient reporting and record keeping systems; and
  • Reviewing performance and compliance.

Administering Programs

Determining whether staff are available to help plan and implement projects is critical to ensuring that programs are effective and reach their intended goals. Neither the HOME Program nor CDBG dictate the approach that jurisdictions must use to implement their programs. Instead, jurisdictions must make choices about who will administer and implement their HOME and CDBG programs. Programs may be administered by:

  • Jurisdiction staff;
  • Subrecipients;
  • Contractors;
  • Community Housing Development Organizations (CHDOs), under the HOME Program. Note, when administering a program, a CHDO is acting as a subrecipient and this not a set-aside activity; and/or
  • Community Based Development Organizations (CBDOs), under the CDBG Program. Note, a CBDO is not a subrecipient by definition, but may be designated as a subrecipient by the grantee.

Some jurisdictions administer their programs with few staff and a large number of subrecipients while others use jurisdiction staff primarily, and few subrecipient organizations. Factors which tend to affect the degree to which jurisdiction staff are relied upon more heavily for project functions include:

  • Types of projects undertaken;
  • Local politics;
  • Capacity of in-house staff; and
  • Capacity and availability of subrecipient organizations.

Determining the appropriate staffing for HOME and CDBG programs may require:

  • Conducting a skills inventory of staff members;
  • Developing a list of required skills;
  • Assessing where gaps exist between current staff skills and required skills; and
  • Undertaking the appropriate training, capacity building, and staff expansion necessary to administer the projects.

Based on the jurisdiction’s analysis of staffing capacities and upon project needs, the jurisdiction must determine whether and/or to what extent it will work with subrecipients, contractors, CHDOs, or CBDOs.

Choosing Projects and Partners

There are a variety of approaches that jurisdictions may use to select HOME and CDBG projects and partners. Note, however, that contractors must be selected in accordance with the procurement requirements of 24 CFR Part 85 (or 24 CFR Part 84 for subrecipients).

There are four basic models upon which the project or partner selection process can be based; however, different variations of these approaches may be necessary or appropriate to meet community needs. These models are discussed below.

Formal Application Process. The formal application process requires the submission of a formal application or proposal, and is typically undertaken once a year in conjunction with the jurisdiction’s planning and budgeting process. Under the formal application process, applications are evaluated based on explicit selection criteria. This process works best in communities with:

  • Numerous or complex activities;
  • Numerous potential applicants with varying degrees of experience;
  • Size of the community/jurisdiction and of the grant   
  • Limited funding and increasing competition; or amounts;
  • Politics or other community issues requiring standardized, consistent treatment of all requests for funding.

Limited Application Process. The limited application process is similar to the formal application process, but the application is not as detailed and jurisdictions provide more follow-up and hands-on involvement in the process.

  • Jurisdictions may review the applications and narrow the number of applications under consideration before requesting additional detailed information from the applicants.
  • This approach may be useful for jurisdictions interested in encouraging the participation of potential applicants who may not be familiar with the project or the application process, or when the jurisdiction’s program is not complex.

Solicitation of Applications from Qualified Organizations. Jurisdictions may identify potential qualified applicants through an informal process or

through a general request for qualifications (RFQ). From the identified group, jurisdictions identify organizations to carry out specific activities and approach the organization about their interest in doing so.

“Open Door” or Unsolicited Application Process. The “open door” process encourages or allows consideration of requests from applicants at any time during the year, and may or may not include an actual application. If jurisdictions decide to use the “open door” approach as its only means of accepting applications, they must ensure that all applications are treated consistently and that the same types of information are received and reviewed by jurisdictions.

Table 6-1 summarizes the major advantages and disadvantages of the four methods for choosing partners for HOME and CDBG projects.

Table 6-1: Choosing HOME and CDBG Projects

>

Type of Process

Advantages

Disadvantages

Formal Process

(Such as a Notice of Funds Availability or a Request for Proposals)

  • Requires applicants to provide all the information needed regarding the organization’s capacity and experience
  • Helps to ensure consistency throughout the evaluation process
  • Tends to favor more experienced applicants
  • Requires substantial jurisdiction staff time to ensure consistency throughout the process
  • Limits new applicants to one chance per year

Limited Application Process

(Such as an Assisted Request for Proposals)

  • Process is more open
  • May attract new applicants and new ideas to the project
  • Shifts the responsibility for determining capacity and experience to the jurisdiction
  • May require more jurisdiction staff time
  • May not ensure the consistency and fairness that is more evident in the formal process

Solicitation of Applications (Such as a Request for Qualifications)

  • Proactive and more focused on qualified organizations
  • May result in less jurisdiction staff time to administer
  • Much more “closed door”
  • Can result in criticism of the jurisdiction selection process
  • Lesser known, but possibly equally capable organizations may be overlooked

“Open Door” Process

  • May allow opportunities for jurisdictions to more quickly respond to community needs
  • Process is unplanned
  • May require crucial staff time and effort to respond because applications may come in at any time
  • May allow the commitment of funds to projects before qualified applications are received
  • Tends to result in budget changes and project amendments throughout the year


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