HOME Administrative Requirements
HOME Administrative Requirements
Administrative and Planning Costs
Each PJ may use up to 10 percent of each year’s HOME allocation for reasonable administrative and planning costs. In addition, up to 10 percent of program income deposited in a PJ’s local HOME account during a program year may be used for administrative and planning costs. PJs, state recipients and subrecipients may incur administrative and planning costs.
Eligible administrative and planning costs include expenditures for salaries, wages, and related costs of PJ staff persons responsible for HOME Program administration. In addition to staff salaries and related costs, other planning and administrative costs could include:
- Goods and services necessary for administration (for example, utilities, office supplies, etc.);
- Administrative services under third party agreements (for example, legal services);
- Administering a tenant-based rental assistance (TBRA) program;
- Providing public information;
- Fair housing activities;
- Indirect costs under a cost allocation plan prepared in accordance with applicable Office of Management and Budget (OMB) Circular requirements;
- Preparation of the Consolidated Plan; and
- Complying with other Federal requirements.
The HOME Program requires that PJs contribute an amount equal to no less than 25 percent of the total HOME funds drawn down for project costs as a permanent contribution to affordable housing. PJs incur a match obligation only for project funds, not for administrative, operating, or capacity building expenditures. Although the obligation is incurred based on per dollar expended in project, match credit can be invested in any HOME-eligible project, whether the project receives HOME funds or not. Match can be contributed in many different forms, including cash; value of waived taxes or fees; value of donated land or property; donated goods, services, materials or equipment.
Commitment and Expenditure Deadlines
The HOME Program encourages PJs to expend their affordable housing funds expeditiously by imposing two deadlines. HOME funds for a given program year must be committed to a HOME project within two years of signing the HOME Investment Partnerships Agreement. For the CHDO set-aside funds, PJs must reserve funds for use by CHDOs within that 24-month period. In addition, HOME funds must be expended within five years of receipt of funds. The Integrated Disbursement and Information System (IDIS) tracks each PJ’s progress toward meeting these deadlines. Failure to meet these deadlines may result in a return of HOME funds to HUD.
Program income is the income received by a PJ, state recipient, or subrecipient directly generated from the use of HOME funds or matching contributions. Program income must follow all of the HOME rules and must be used before drawing down new HOME funds. Program income includes, but is not limited to:
- Proceeds from the sale or long-term lease of real property acquired, rehabilitated, or constructed with HOME funds or matching contributions;
- Income from the use or rental of real property owned by a PJ, state recipient or subrecipient that was acquired, rehabilitated, or constructed with HOME funds or matching contributions, minus the costs incidental to generating that income;
- Payments of principal and interest on loans made with HOME or matching funds, and proceeds from the sale of loans or obligations secured by loans made with HOME or matching contributions;
- Interest on program income; and
- Any other interest or return on the investment of HOME and matching funds.
All HOME program income must be used in accordance with the HOME Program rules. Where program income is concerned, there is an important distinction between subrecipients/state recipients and CHDOs. Specifically:
- Program income received by subrecipients or state recipients, such as rental income, repayment of loans, interest on loans, fees, and payments for services, is considered program income subject to HOME regulations.
- However, project proceeds received and retained by CHDOs are not considered program income. PJs have the option of permitting project proceeds to be retained by CHDOs or they may require CHDOs to return these proceeds to the PJ. If the project proceeds are returned to the PJ, they are program income. Use of funds must be specified in the CHDO written agreement and limited to either HOME-eligible activities or other housing activities that benefit low-income families.
PJs may incur eligible costs prior to the effective date of their annual HOME Investment Partnerships Agreement, subject to certain conditions. Both administrative and project costs may be incurred. Only costs eligible under the HOME Program rules in effect at the time the costs are incurred are included. Expenditures must meet all regulatory requirements, including environmental review regulations.
Pre-award project costs may not exceed 25 percent of the current HOME grant without written approval from HUD. PJs may authorize subrecipients and state recipients to incur pre-award costs, but authorization must be in writing. Citizen participation and all other applicable HOME requirements must be met.
Consulting Services We Provide
- Review public works preconstruction contracts
- Monitor DIR contractor/subcontractor certified payrolls
- Audit labor classification for each worker employed
- Review DIR pre-DAS 140/142 submissions
- Review CAC training fund contributions form CAC-2
- Review DIR Fringe Benefits Statement PW-26
- Monitor DIR wage determinations
- Audit fringe benefits allowances
- Review DIR holiday payment requirements
- Audit DIR travel & subsistence requirements
- Caltrans Labor Compliance
- County of Sacramento Labor Compliance
- City of Los Angeles Labor Compliance
- Los Angeles Unified School District Labor Compliance
- Federal Davis-Bacon Project Monitoring
- Federal DBE Implementation & Review
- Federal FAA AIP Goal Setting
- DIR & Davis-Bacon Training
- DIR Civil Wage Penalty Review
- Local-Hire Review (e.g., San Francisco)
- Skilled and Trained Workforce
Give us a call to discuss your labor compliance requirements.
This email is intended for general information purposes only and should not be construed as legal advice
or legal opinions on any specific facts or circumstances.