This section provides you, the Grant Recipient, with important information
and guidance to help you properly manage your assistance agreement.
Cradle to grave information is provided from where to begin and
how to end your agreement.
grant regulations are located under Title 24 of the Code of Federal
Regulations (CFR), Parts 84 and 85. Grant recipients must comply
with the requirements in these regulations. HUD will provide guidance,
if needed. Non-profit organizations and institutions of higher education
are governed by 24 CFR Part 84; State and local governments are
governed by 24CFR Part 85.
information provided below is not intended to replace the grant
regulations but to serve as an additional resource for the Grant
Whom do I contact if I need assistance?
2. How do I get paid?
3. What grant regulations apply to my organization?
4. How do I account for costs?
5. How do I account for matching funds?
6. What is program income and what are my responsibilities?
7. What reports will I be required to submit?
8. What records do I need to maintain and for
9. How do I differentiate between sub-awards
and vendor transactions?
10. What must I do to issue sub-awards?
11. How do I avoid conflicts of interest when
procuring goods and services with grant funds?
12. What must I do to procure goods or services
with grant funds?
13. Are there any rules regarding management
of equipment and supplies that were purchased with grant funds?
14. When is a Single Audit Required?
15. What if I need to make changes to my assistance
16. How do I close my grant?
17. What should I expect if my grant is reviewed
1. Whom do I contact if I need assistance?
Department of Housing and Urban Development
Office of Healthy Homes and Lead Hazard Control
451 7th Street, SW, Room 8236
Washington, DC 20410
Government Technical Representative (GTR) is your primary point
of contact. The GTR's name and phone number is listed on the Cover
Page, HUD -1044, Block 9 of your grant agreement.
questions concerning general administrative issues, contact your
Grant Administrator/Grant Officer (GO). The GO's name and phone
number is also listed on the Cover Page, HUD -1044, Block 8, of
your grant agreement.
questions regarding the payment process/the payment system, Line
Control System, contact our Grant Assistant at (202) 402-7576.
How do I get paid?
HUD awards a grant to your organization, you will be instructed
to return 3 signed original grant agreement documents. The most
important step at that time is for your authorized representative
to sign the copies of the agreement, which indicates your acceptance
of the award. The award is a bilateral agreement. After HUD has
received your signed copies of the agreement, the GO will execute
the agreement and return one original agreement to you. Then you
will be able to request payment for grant-related expenses using
the Line of Credit Control System.
of Credit Control System (LOCCS)
is the system HUD uses to disburse and track the payment of grant
funds to Grant recipients (i.e. grantees). Grantees request program
funds through an automated VRS payment system that is maintained
by LOCCS. Grantees use VRS to request funds via a touch-tone telephone.
Synthesized text-to-speech dialogue is used to request payment data
from the caller. Requests for Reimbursement The VRS requires the
caller to enter a LOCCS program Area User ID, password, and a Voice
Response grant number to ensure that the caller has authority to
request grant funds for his/her particular grant.
requested payment amount is checked against the grant's available
balance in LOCCS to ensure that the request does not exceed the
grant's authorized funding limit. LOCCS will only allow one draw
per day on a given grant, unless funds are requested by project
or subgrantee. Once a request/draw is approved, funds are sent from
the U.S. Treasury directly to the grantee's bank account, usually
within 48 hours from the day the request is made.
What grant regulations apply to my organization?
general grant regulations and Office of Management and Budget (OMB)
Circulars listed below apply to all HUD assistance programs (by recipient
type - e.g., State, non-profit). Recipients should familiarize themselves
with these documents to ensure that they are in compliance with the
requirements. Additional regulations for specific HUD programs (listed
below) may also apply; contact your HUD Government Technical Representative
(GTR) for details.
of Federal Regulations (CFR) ? The CFR is organized by
Title, Chapter, and Part. HUD grant regulations are found at:
24 - Department Of Housing And Urban Development;
CFR 84 - Administrative Requirements For Grants And Agreements
With Institutions Of Higher Education, Hospitals, And Other Non-Profit
CFR 85 - Administrative Requirements For Grants And Cooperative
Agreements To State, Local And Federally Recognized Indian Tribal
Circulars ? The following OMB Circulars may apply to the
management of your HUD grant:
Cost Principals for Educational Institutions
Cost Principals for State, Local, and Tribal Governments
Cost Principals for Non-Profit Organizations
Audits of States, Local Governments, and Non-Profits
How do I account for costs?
costs shall be used only for eligible program activities. Refer
to each individual Notice of Funding Availability (NOFA) for eligible
program activities. You are required to adequately track and document
all grant expenses. You should consider the following in order to
establish a system which meets Federal requirements:
accounting system must track costs, including match and leverage
contributions, by grant as well as by expense category (e.g.,
salaries, supplies, equipment, travel). When establishing expense
categories you should refer to the budget categories listed in
your HUD grant agreement.
must ensure that all costs are allowable and acceptable. If you
have any questions as to the allowability of costs, refer to the
applicable OMB Circular for your organization or contact your
HUD GTR prior to incurring those costs.
good records. Make sure that all invoices, payroll expenses, etc.
are filed along with all supporting information (e.g., contracts,
time cards, etc.).
all expense records by expense category. In the case of multiple
grant awards, each grant should have its own master file.
accounting system should enable you to provide financial information,
summarized by expense category i.e., a general ledger report).
This system will also help support your payment requests.
How do I account for matching funds?
of HUD's grant programs require the grantee to contribute a non-federal
cost-share or to match the Federal funds provided for the project.
Consult with the NOFA under which your grant was awarded and refer
to 24 CFR 85 or
24 CFR 84, as applicable.
What is program income and what are my responsibilities?
income is gross income received by the grantee or sub-grantee directly
generated by a grant supported activity or earned only as a result
of the grant agreement during the grant period. Examples of program
income include, but are not limited to:
for services funded by the grant.
generated from the use or rental of property acquired with grant
from the sale of commodities or items fabricated under a grant
from the payment of principal and interest on loans made with
fees for a conference.
to account for program income: All program income should be
deducted from the total grant expenses to determine net allowable
grant expenses. However, when appropriate, HUD may add a condition
to the grant at the time of award or amendment, authorizing one
or more of the following uses of program income:
increase the total funds committed to the project. In this case,
the income must be used to further eligible project activities.
meet the recipient's cost-share or match requirement of the project.
If program income is generated during the project period of the
grant and that income was not anticipated at the time your grant
was awarded, contact your HUD GTR immediately for guidance on
the treatment of the income. Recipients have no obligation to
the Federal Government regarding program income generated after
the end of the project period, unless the terms of the agreement
or regulations provide otherwise.
What reports will I be required to submit?
reports from your organization provide HUD with information regarding
the status of your project. There are two basic types of reports
that you will need to submit: Financial Status Reports and Technical
(quarterly and final).
STATUS REPORTS (FSRs). Supplemental Guidance for FSRs What is
an obligation? An obligation is an indebtedness or liability to
pay for costs such as personnel, travel, equipment, and supplies
and must be incurred during the budget period of the assistance
agreement. Obligation is not to be confused with expenditure or
REPORTS. You will be required to submit periodic reports on
your progress in meeting your work plan commitments. Generally,
your work plan for the project or a condition on your grant award
will specify the frequency and types of reports that are required
and what they should contain, as follows:
DELIVERABLES AND REPORTS. There are two major types of project-related
reports you will be required to submit.
Progress Reports. Quarterly reports will be due no later than
January 30th, April 30th, July 30th, and October 30th, for the
preceding quarter following the initiation of the grant through
project closeout. If a due date falls on a weekend, holiday, or
otherwise-closed Federal workday in Washington, DC, it shall be
extended to the next Federal workday in Washington, DC, without
affecting subsequent due dates. A template to be used in the preparation
of each quarterly report will be provided by HUD after grant award.
Quarterly reports must reflect activities undertaken, obstacles
encountered and solutions achieved, and accomplishments in each
calendar quarter. Contracts, training materials and protocols,
rosters of persons trained, outreach and educational materials
prepared, and other significant products developed to implement,
analyze or control the project or disseminate information are
to be submitted with the quarterly reports as attachments. Login
to the QPRS system.
Report. A final report shall be submitted. Information on
the Final Report is provided in the Closeout
What records do I need to maintain and for how long?
records, technical reports, grant work products, and all other supporting
documents for your grant must be kept for three years from the date
the grant was closed by HUD. Exceptions: " If there is an audit,
claim or litigation regarding the grant which began before the end
of the three year period, the records must be kept until all matters
are resolved. " Real property (e.g., land, buildings) and equipment
records must be kept for three years after the property/equipment
is disposed. " Some HUD programs have special record retention requirements.
Your HUD Project Officer will advise you if additional requirements
apply to your grant. The Federal Government has the right to timely
and unrestricted access to any and all records that pertain to the
How do I differentiate between sub-awards and vendor transactions?
Sub-Awards. Sub-awards are awards of financial assistance made
by the primary grantee to eligible sub-recipients for the purpose
of providing support or stimulation to accomplish a public purpose.
This includes financial assistance when provided by any legal agreement,
whether it is referred to as a contract or a grant. Sub-award agreements
are sometimes referred to as "Pass-Through" funds. A sub-award should
be used if the sub-recipient:
- Will have the responsibility for making decisions regarding
the work to be performed, and
- Will use the funds to perform the project for its own purposes.
Vendor transactions are the purchases
of goods and services, typically acquired through either purchase
orders or contracts. They are not considered to be sub-awards. Grant
recipients must follow the grant procurement requirements when purchasing
goods and services. For additional information, refer to the section
entitled "What must I do to procure goods and services with grant
funds". A vendor transaction should be used when:
goods or services are directly provided to the Grantee organization
for its own use;
Grantee specifies the requirements for the service/goods; and,
Grantee organization has control over the service being performed.
What must I do to issue sub-awards?
should be written agreements and include the following items:
- Information sufficient to identify the Federal Program/Agency
that provided the initial funds, such as:
- Catalog of Domestic Federal Assistance Number
- Federal agency's name
- Federal Grant Number and title of the project
- Federal requirements that apply to the sub-recipient, usually
incorporated by reference.
- Any supplemental requirements from your organization.
- A description of the work to be performed.
- Duration of the project.
- Amount of funds being provided, including matching funds required.
- Access to records and record retention requirements.
All sub-recipient awards must be closely monitored. Your organization
is responsible for ensuring that these awards are used for purposes
in compliance with federal laws, regulations, and grant program requirements.
Your organization is also responsible for ensuring that the performance
goals are achieved and the project is completed. Keeping detailed
records of your monitoring activities is highly recommended!
How do I avoid conflict of interest when procuring goods and services
with grant funds?
employee, officer, or agent of your organization may participate
in the selection, award, or administration of a procurement action
if a conflict of interest would or would appear to be involved.
of interest occur when an employee, officer, or agent, any member
of his/her immediate family, his/her partner, or an organization
which employs or is about to employ any of these individuals, has
a financial or other interest in the firm selected for an award.
organization must have a written standard of conduct, refer to 24
CFR 84/85 - 84.42/85.36, to provide guidance for employees regarding
their conduct in the award and administration of procurement. The
standard should also include disciplinary actions that will be applied
if an employee violates these written standards.
What must I do to procure goods or services with grant funds?
organizations are required to have written procedures which cover
all procurement actions and which comply with Federal requirements.
The procurement regulations at 24 CFR 85 - 85.36, applies to State,
local government, and Tribal recipients; 24 CFR 84 - 84.44, applies
to university and non-profit recipients. These regulations contain
standards which help ensure that materials and services are obtained
in compliance with applicable Federal statutes and Executive Orders.
States should follow the same policies and procedures they use for
procurement with their non-Federal funds. Some of the major points
contained in the procurement regulations include:
- To the extent practical, all transactions shall be conducted
in a manner which provides open and free competition.
- All recipients shall establish written procedures which:
- prevent purchase of unnecessary items o require, where appropriate,
an analysis of lease versus purchase alternatives to determine
which is the most economical and practical
- ensure that solicitations provide:
- a clear description of the technical requirements
- the requirements which bidders must fulfill and the
factors to be used in evaluating bids
- a description, whenever practical, of the technical
requirements in terms of functions to be performed or
performance required, including acceptable standards
- specific features of "brand name or equal" that bidders
are required to meet.
- Recipients shall make positive efforts to utilize small businesses
and minority-owned and women-owned businesses.
- Procurement files must contain, at a minimum:
- the basis for contractor selection
- justification for lack of competition, if applicable
- the basis for award cost or price
When procuring goods or services with HUD grant funds, recipients
are required to use and document a competitive process. How do I compete?
- Write a proposal (Statement of Work) and estimate the costs
- Solicit bids for the proposal, ensuring that Disadvantaged Business
Enterprises are considered.
- Estimated cost > $100K requires formal advertisement in newspapers,
trade magazines, etc. (Your organization may use a lower threshold.)
- Estimated cost < $100K may use formal advertisement or direct
contact of 3 known vendors.
- Perform and document an analysis of all bids received.
- Select the contractor and prepare a written contract.
In certain instances, exceptions to the competitive requirement
may be allowed. The exceptions are:
- The work can be completed by only one source. For example, highly
specialized knowledge or skills are required or no other sources
- Emergency situations
exceptions may require prior HUD approval. Contact your HUD Project
Officer before making binding commitments. Documentation of the
steps and decisions that led to the award of each contract is extremely
Are there any rules regarding management of equipment and supplies
that were purchased with grant funds?
is important that you understand the difference between equipment
and supplies, since the treatment of and accounting for each is
Equipment is non-expendable personal property having a useful
life of more than one year and a cost of $5,000 or more per unit.
What do I do if I purchased equipment under my grant? States may
use, manage, and dispose of equipment purchased in accordance with
State laws and procedures. All other organizations must adhere to
- Equipment must be used in the program or project for which it
was acquired as long as needed, even if the project is no longer
supported by HUD.
- A control system must be developed to ensure adequate safeguards
against loss, damage, or theft, adequate property records must
be maintained, and a physical inventory must be completed at least
once every two years.
- When acquiring replacement equipment, the equipment may be used
as a trade-in or may be sold, with the proceeds used to offset
the cost of the replacement equipment.
How do I dispose of equipment (items which are no longer needed)?
When no longer needed for the original project, the equipment may
be used in other activities currently or previously supported by
a Federal agency. When actually disposing of equipment items which
are no longer needed for the original project or for other Federally
funded activities, the following applies:
- Fair Market Value < $5,000 per unit: May be retained, sold or
otherwise disposed of with no further obligation to the Federal
- Fair Market Value > $5,000 per unit: Contact your GTR for disposition
Supplies are considered to be all tangible, personal property other
is a Single Audit Required?
non-Federal entities that expend $500,000 or more in Federal funds
in one year are required to conduct a single or program-specific
audit for that year. The audits are to be conducted in accordance
with the provisions of OMB Circular A-133. We recommend that you
refer to the Circular for further information.
What if I need to make changes to my assistance agreement?
or Program Revisions. There are certain budget and program changes
that require prior approval by HUD. A detailed discussion of these
requirements may be found in the regulations at OMB Circular A-102
-which was implemented by 24 CFR 85, OMB Circular A-110 - which was
implemented by 24 CFR 84, and OMB Circular A-133 which was implemented
by 24 CFR 84 and 85. Some of the changes requiring prior approval
by the GTR through a grant amendment include:
- Changes in scope or objective
- revisions requiring additional funds
- budget revisions, when the cumulative transfers among direct
cost categories exceed 10% of the current total budget
- inclusion of costs requiring prior approval, as directed by
the OMB Cost Principles
- under non-construction projects: contracting out, sub-granting,
or otherwise obtaining the services of a third party to perform
activities central to the purposes of the award
Your GTR may make the following approvals by letter:
- transfer of funds between direct and indirect cost categories
- transfer of funds allotted for training allowances (direct payment
to trainees) to other expense categories
- unless described in the application and funded in the approved
award, the sub-award, transfer, or contracting out of any work
under the award
Extensions. If you will not be able to complete the project
within the original project period, it is important that you discuss
the situation with your GTR as soon as possible. Grantees may request
an extension by submitting a written request to the GTR at least
10 days before the expiration date for non-profit organizations
and institutions of higher education governed by 24 CFR Part 84;
and no later than 60 days prior to the expiration date for State
and local governments governed by 24 CFR Part 85. Your request should
provide information regarding the reason why the project will not
be completed on time and why it is necessary to continue the project.
The request should also specify the additional length of time needed
What happens when the project is completed?
instructions are provided in the Closeout
Guidance Manual. It is HUD's policy that all assistance agreements
be closed within 180 days of the project end date or completion
of the project. You have 90 calendar days after the project is completed
to submit all the required financial, performance, and any other
reports or deliverables. During this closeout process, any excess
funds paid to you must be returned to HUD. Contact your GTR for
guidance if you need to return money to HUD. Any funds undisbursed
funds will be deobligated with an amendment to your grant. When
all close out requirements have been satisfied, the HUD Grants Office
will issue a final letter to notify you that the grant is officially
What should I expect if my grant is reviewed or audited?
entities that expend $300,000 ($500,000 for fiscal years ending
after December 31, 2003) or more in a year in Federal awards shall
have a single or program-specific audit conducted for that year
in accordance with OMB Circular A-133. Separate from the official
audit, as part of HUD's oversight of your assistance agreement,
your project may be selected for a review and/or an audit. The review
or audit could occur either during the course of the project or
as part of the final close-out phase of the grant. Generally, the
reviews and audits completed by HUD. Part of this responsibility
may include the on-site review of your administrative operations.
The overall purpose of an on-site visit by HUD is to:
- Ensure that your organization has the necessary systems in place
to manage your agreement.
- Ensure that your organization is in compliance with applicable
Federal regulations, policies, etc.
- Assist your organization with the overall management of your
grant and to recommend changes, where needed.
- Make certain that the costs incurred under the grant are generally
the review is complete, a report will be issued to your organization
detailing any concerns and recommendations. Your GTR will work with
you to resolve those concerns.