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CHAPTER 4. PROGRAM IMPLEMENTATION AND OPERATION

4.1 OVERVIEW

This chapter covers the key administrative steps in starting and

operating the CHSP. it includes the following activities:

o designation of the GTR/GTM, if not already identified

o execution of the Grant Assistance Award

o holding a start-up conference

o development of administrative procedures

o establishment of record-keeping systems, including

applicant/participant case files

o semi-annual financial and annual program reporting

4.2 DESIGNATION OF THE GTR/GTM

a\. General

The CHSP Grant Officer may not serve as the GTR or GTM. The

HUD or RHS official who designates the GTRs and GTMs depends

on the program area of the CHSP project:

\(1\) For multifamily projects, the Director of Multifamily

Housing assigns GTRs and GTMS; a GTR should be a current

or former GTM or a Multifamily Asset Servicer for the

project or a Resident Initiatives Specialist;

\(2\) For public housing projects, the Director of Public

Housing assigns GTRs and GTMS; the GTR should be a

current or former GTM or a public housing management

specialist assigned to that project or a Resident

Initiatives Specialist;

\(3\) For Indian housing, the Director, Office of Native

American Programs, assigns GTRs and GTMS; a GTR should

be a current or former GTM or a Public and Indian

Housing Management Specialist assigned to that project;

and

\(4\) For RHS projects, the Chief, Rural Housing in the RHS

state office assigns GTRs and GTMS. A GTR should be a

current or former GTM or a rural housing specialist.

In addition, the Grant Officer will designate a HUD GTR

to coordinate with the RHS state office in

administration of CHSP grants for RHS projects.

A financial analyst or other staff member with strong

financial skills is recommended for the GTM responsibility.

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b\. Notice of Designation

\(1\) The GTR and GTM are designated by memorandum. Appendix

3 provides a sample memorandum format.

\(2\) A GTR may redelegate some of his or her

responsibilities to a GTM. The GTR must redelegate

responsibilities to the GTM in writing.

\(3\) Signed copies of the memoranda designating GTRs/GTMs

must be provided to:

HUD Headquarters Desk Officer, Room 6122

Office of Elderly and Assisted Housing

U.S. Department of HUD

451 7th St., S.W.

Washington, D.C. 20410

The RHS Rural Housing Chief follows the same notice of

designation procedures listed above. In addition, he

or she sends a memorandum to RHS Headquarters at:

Multifamily Housing Processing Division, Room 5343

South Building

14th and Independence Avenue, SW

Washington, DC 20250

4.3 EXECUTION OF THE GRANT ASSISTANCE AWARD

a\. Funds Reservation

When grantees have been selected, the HUD state or area

office will receive a form HUD-185 and a list of the

selected grantees. The form HUD-185 allocates the funds

available to both the HUD and the RHS selected grantees.

Based on the selection list and the HUD-185, the HUD GTR

must prepare the Funds Reservation and Contract Authority,

Form HUD-718 (Appendix 5) for signature by the GTR

Supervisor and the CHSP Grant Officer.

The Grant Officer is responsible for sending the signed Form

HUD-718 to the FAD for approval and recording into the

appropriate accounting system. The FAD must return a copy

of the approved HUD-718 to the HUD GTR, and the HUD GTR must

provide a copy of the HUD-718 to the RHS GTR, where

appropriate.

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b\. Preparation of Grant Agreement

A one-time advance payment for start-up activities may be

approved by the Grant Officer. This advance must be

reasonable and usually is for no more than the first 3 weeks

of grant operations. The amount will be stated in the grant

document.

HUD GTRs negotiate the grant terms and conditions for

selected HUD applicants. RHS Headquarters staff perform

these negotiations for selected RHS applicants and send

finalized documents to the HUD appropriate GTR. The HUD GTR

then:

\(1\) completes Form HUD-1044, Grant Assistance Award

(Appendix 6) except for signatures,

\(2\) completes the Assistance Award Format (Appendix 7),

\(3\) sends the completed HUD-1044 and Assistance Award

Format to the Grant Officer for review, and

\(4\) upon authorization by the Grant Officer, sends three

copies of the Grant Award HUD-1044 and Assistance Award

Format to the grantee, requesting signature and return

of all signed copies.

c\. Execution and Distribution of the Agreement

Following signature and return of the Grant Agreement by the

grantee, the Grant Officer executes three original copies of

the agreement. The executed agreement is distributed as

follows:

Original 1: Grantee

Original 2: Field Accounting Division

Original 3: Grant Officer Master File (See Chapter 4 for

additional information on record keeping),

Copy 1: HUD and/or RHS GTR/GTM files

4.4 START-UP CONFERENCE

a\. Timing

GTRs must hold a start-up conference with appropriate

individuals of each new grantee. The GTR should contact the

grantees and schedule the conference within 30 days of

execution of the grant agreement.

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b\. Attendance

The GTR, the GTM and grantee staff must attend the

conference. If grantees are states, local governments, or

tribes, project owners/managers should also attend.

Attendance is also recommended, but not mandatory, for

project Service Coordinators and fiscal staff. GTRs may

also want to invite other HUD and/or RHS staff as relevant.

c\. Coverage

GTRs convening the meeting should cover the following areas:

\(1\) Roles and responsibilities of GTRs/GTMs, other HUD/RHS

state office staff, and HUD/RHS Headquarters staff, as

they pertain to the administration of the CHSP. (See

Paragraphs 4.7, 5.5, 7.4 and 8.5 for information to be

included in the discussion.)

\(2\) Financial and program record-keeping requirements for

CHSP grantees. This includes the contents of all

files, required forms (the HUD-90198, SF-269 and HUD-90006)

and an explanation of LOCCS operations. (See

Paragraphs 4.6 and Chapter 5 for more information.)

\(3\) The on-site review (HUD-90003). This should be

explained in general terms, stating the requirement and

the related annual program and budget process to which

the review may be connected. (See Chapter 6 for more

information.)

\(4\) Program procedures for states, units of general local

government and Indian tribes that will administer

projects. This includes record-keeping, using LOCCS,

reporting, and on-site monitoring.

\(5\) For units of government or Indian tribes that have more

than one project site, requirements for monitoring the

project sites for conformance with the grant agreement

and handling all financial and other transactions. (HUD

will award an additional one percent of the value of

the grant to the grantee to cover some or all of the

staff costs involved.)

4.5 INITIAL GRANTEE ADMINISTRATIVE PROCEDURES

In order to meet requirements specified in the grant agreement,

grantees must perform several administrative procedures to

implement the CHSP program. These are initiated during the

start-up period, which is generally the 3 to 6 months following

grant execution.

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a\. Organization and Staffing

The CHSP grantee should perform the following organization

and staffing activities:

\(1\) Within 30 days of grant execution, develop a list of

staff positions and write job descriptions.

\(2\) Appoint a Professional Assessment Committee (PAC), as

described in Paragraph 2.8, or secure an agreement with

a community agency. (If a community agency is used, it

must conform to 24 CFR 700.135 or 7 CFR 1944.258 of the

Common Rule.)

\(3\) Hire staff as necessary.

b\. Policies and Procedures

The CHSP grantee should establish the following policies and

procedures:

\(1\) Develop PAC operating procedures, for

application/intake, screening and participatory

agreement forms, including termination of assistance

and the processes for appeals, as described in

Paragraphs 2.9 and 2.10.

\(2\) Establish record keeping system. Within 30 days of

execution of the grant agreement, each grantee must

establish record systems and applicant/participant case

files that document all of the administrative

activities described in this Paragraph. Figure 4-1

describes the contents of both project records and case

files.

\(3\) Recordkeeping for Grantees with multiple sites. In

cases where the CHSP grantee is different from the

project owner or has more than one site, grantee files

must contain all of the basic grantee information and

all of the accounting/timekeeping records.

In all cases, the grantee must maintain both aggregated

and site-specific financial records. Individual

project site files must contain: grant document and any

amendments, copies of all HUD 90198s and SF-269s, all

of the participant information and appropriate payroll

and accounting information.

In the case of a PHA/IHA with multiple sites,

information listed above ma be kept at EITHER the

administrative offices, if a central source provides

all services, or at both the administrative offices and

the individual sites, if the services are run

independently at each site.

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Figure 4-1

GRANTEE RECORD-KEEPING

A. Basic Grantee Information

o Grant application and grant award document and any

amendments

o Copies of HUD Payment Vouchers (HUD-90198) and Financial

Status Reports (SF-269)

o Documentation of all funds obtained and expended

o Correspondence with HUD or RHS offices

o Other materials, e.g, staff hiring procedures, PAC resumes

and operating procedures and applications and certifications

related to meal service

B. Applicant and Participant Information

o Application screening and intake forms

o PAC assessments, service plan, participatory agreements

o Fee scale computation

o Documentation of participant monitoring, and meetings with

client and family

o Documentation of any reports of civil rights or adult abuse

o Date and reason for separation from CHSP/any appeals

C. Accounting/Timekeeping Records

o General financial information

o Personnel information (policies, employee information,

payroll)

o Documentation of all costs (schedule of costs by category,

indirect costs, procurement records)

o Subcontractor information (agreements, invoices)

o Equipment inventory and depreciation policies

o Copies of HUD-1044, HUD-90198 and SF-269s

\(A\) Basic Grantee Information. The grantee must maintain

copies of all HUD forms and reports and other basic

operations information.

\(B\) Applicant and Participant Information. The grantee

must maintain case files for each program participant.

All information related to applicants/participants

should be kept confidential and secured. This

information should be accessible ONLY to the service

coordinator and to grantee program/project management

to the extent necessary.

\(C\) Accounting/Timekeeping Records. The grantee must

maintain all appropriate accounting and staff

timekeeping records.

If a CHSP grantee is also the project owner and has only one site, the

grantee\'s files should contain all of the information in Figure 4-1.

The CHSP Grantee Review Form, HUD-90003 (Appendix 10), contains a

checklist of both participant information and financial records for

CHSP grantees. Also, the grantee should make project records

available to HUD state or area office staff and others, as

appropriate, upon request for the purpose of making audits,

examinations, excerpts, transcripts and copies, according to 24 CFR

Parts 84 and 85.

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c\. Preparation for Meals Programs

Within 30 days of execution of the CHSP grant award, the

grantee should:

\(1\) Apply for approval as a retail food store under Section

O of the Food Stamp Act of 1977, implemented through 7

CFR Part 271.

\(A\) Application forms can be obtained from and must be

returned to State Food and Nutrition Service

offices. (See sample form at Appendix 11.)

\(B\) Evidence of this application shall be placed in

the project files.

\(C\) If approved, eligible owners or grantees shall

accept food stamps for partial or full payment of

the meals provided. Coupons can then be redeemed

at any bank.

Group homes and independent living projects for non-elderly

disabled cannot become retail food centers.

Project staff may be authorized, however, to use food

stamps to purchase food outside the home for the

residents.

\(2\) Request agricultural commodities for use in meal

services from the USDA, under 7 CFR Part 250.

\- Each state has a separate application form that

must be obtained from and returned to the

appropriate state USDA office.

\- Evidence of this request should be placed in the

grantee files.

\- Once approved, the project can obtain food from a

local distribution center. This food may be used

in the meals program, or distributed to residents

as appropriate.

d\. Establish LOCCS Account

Grantees must use the Line of Credit Control System (LOCCS)

to draw down CHSP grant funds. This process is described in

detail in Chapter 5. Grantees complete the necessary forms

and GTRs process the forms to enable the grantees to

establish accounts and access the system.

To be able to use the LOCCS system, each grantee must

complete the necessary forms and submit them to the GTR:

\(1\) SF-1199A, Direct Deposit Sign-up Form (Appendix 8)

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\(2\) Form HUD-27054, LOCCS/Voice Response Access

Authorization Security Form (Appendix 9)

Grantees will be sent both of these forms with the grant

notification letter.

e\. Initiate Services

To initiate supportive services, the grantee should perform

the following steps:

\(1\) Screen applicants and obtain PAC assessments;

\(2\) Develop supportive service plans and establish fees for

participants accepted into the program; negotiate

service plan with proposed participant;

\(3\) At completion of negotiations, require each accepted

participant to sign a participatory agreement regarding

the use of congregate services and the payment of

service fees;

\(4\) Execute subgrants or subcontracts with service

providers, as appropriate;

\(5\) Start in-house services; and

\(6\) Require service coordinator to implement service plans.

4.6 INITIAL HUD/RHS ADMINISTRATIVE PROCEDURES

a\. HUD/RHS Recordkeeping Systems

For the CHSP, the Grant Officer and the HUD or RHS GTR are

required to keep separate files. The Grant Officer\'s file

for a CHSP grant is the official record for legal and

administrative purposes and contains the originals of all

documents. The GTR\'s file is the working file for each

grant and contains copies of the forms in the Grant

Officer\'s files as well as additional project information

and copies of correspondence with the grantee. Figure 4-2

illustrates the contents of the Grant Officer and GTR files.

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Figure 4-2

HUD/RHS RECORDKEEPING

Grant Officer Files \-- originals of:

1\. Executed grant agreement

2\. GTR/GTM designation memoranda

3\. HUD-90198

4\. SF-269, \"Financial Status Report\"

5\. HUD-90006 \"CHSP Annual Reporting Form\"

6\. Grant amendments

7\. Grant extensions

8\. Other documentation

GTR Files:

1\. Grant application and any amendments

2\. Grant document and any amendments

3\. Sequential copies of all HUD-90198s approved for payment and

SF-269s

4\. Project site-specific information (where grantee has

multiple sites)

5\. Correspondence from grantee and communications of area/state

offices with Headquarters.

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b\. LOCCS Access Forms

HUD/RHS GTRs are responsible for review and processing of

forms so that grantees can establish LOCCS accounts and access

the system.

\(1\) The GTR reviews the Direct Deposit Form (SF-1199A)

completed by the grantee for accuracy. The GTR should

especially check for:

\- the presence of the grantee\'s grant and tax

identification numbers (block C) and

\- the name of the authorized payee in Section 1 of

the SF-1199A.

\(2\) Within 48 hours of receipt, the GTR should send the SF-1199A

to HUD Headquarters: U.S. Department of HUD, P.O.

Box 44816, Washington, D.C. 20026.

HUD GTRs must also complete and submit the form that

authorizes HUD staff to access the system. To get a password

and a user ID:

\(1\) The GTR/GTM or other designated LOCCS user in the HUD

state or area office should complete the Form HUD-27054-A,

\"LOCCS Access Authorization Security Form for HUD

Staff\" (Appendix 11). The form must be signed by: the

user (GTR/GTM), the authorizing official (Director of

Housing/Director of Multifamily Housing) and the state or

area office personnel officer.

\(2\) The personal officer should validate the following:

\- SF-85P, Limited Background Investigation

\- SF-87, set of fingerprints

\(3\) The GTR should send the completed forms to:

Office of Information Policies and Systems, Room

3184

U.S. Department of HUD

451 7th St., S.W.

Washington D.C. 20410

ATTN: LOCCS Security Officer

4.7 REQUESTS FOR REIMBURSEMENT (Form HUD-90198)

GTRs should emphasize to grantees that the CHSP is a reimbursement

program, although the grantee may receive a one-time advance

payment for start-up activities as described In Paragraph 4.4

above. The vehicle for disbursement of grant funds to the CHSP

grantee is the LOCCS/VRS CHSP Payment Voucher (form HUD-90198).

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The HUD-90198 must be used by all grantees as an official file

document of requests of payments. The HUD-90198 will indicate

the type and amount of funds requested and the period in which

the funds are wanted. (A copy of this form and instructions for

completing it can be found in Appendix 12. Grantees may

photocopy blank voucher forms as needed, or get originals from

State or area office stock.)

a\. Due Dates and Submission

The time period covered by the reimbursement is quarterly or

monthly and will be stated in the grant agreement. All

requests for reimbursement must be submitted on the HUD-90198

within 30 days of the end of the reporting period.

Grantees request the drawdown of grant funds over the

telephone using the Line of Credit Control System/Voice

Response System (LOCCS/VRS). (Instructions to grantees and

GTRs on the use of LOCCS/VRS are presented in Chapter 5.)

The CHSP grantee must send an original HUD-90198 to the

GTR/GTM within five days after each disbursement request and

keep a copy of the voucher on file.

b\. Responsibilities for Grantees with Multiple Project Sites

If the grantee has more than one project, or the grantee is

not the owner of the project, it is the grantee\'s

responsibility to establish a submission timetable for all

project sites within the grant to assure that the project

owner or manager submits a project-specific HUD-90198 to the

grantee. Once the grantee has received the necessary HUD-90198s

from the project(s), it will have all information for

one aggregated submission to the GTR, which should be made

on a quarterly or monthly schedule. The HUD-90198 submitted

to the GTR must represent sufficient funding for all sites

for the time period covered.

4.8 FINANCIAL STATUS REPORT (SF-269)

The SF-269 is used to account for all disbursements and accrued

bills under the CHSP during the reporting period. It is the

chief tool that the GTR has to ensure that the information

contained on the CHSP Payment Voucher (HUD-90198) is accurate and

reasonable within the terms of the budget and the grant

agreement. The grantee is required to submit the Financial

Status Report, SF-269, on a semi-annual basis (Appendix 13).

a\. Reporting Periods

Grantees must submit the original SF-269 and one copy to the

HUD state or area office no later than 30 days after the end

of each reporting period. The semi-annual reporting periods

under CHSP are: October 1-March 31 and April 1-September 30.

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b\. Responsibilities of Grantees with Multiple Project Sites

Grantees with more than one project site are responsible for

collecting site-specific SF-269 reports from each site and

preparing an aggregated report. Once the grantee has

received the necessary SF-269 from the site(s), it will have

all necessary information for one aggregated submission to

HUD.

The SF-269 submitted to HUD must reflect sufficient funding

for all sites for the time period covered, and must be

signed by the appropriate grantee official. The appropriate

official is the CHSP director, executive director of the

PHA/IHA or the project administrator of other projects.

c HUD/RHS Review

The GTR/GTM must review the SF-269 within 10 workdays after

receipt. Grantees should be notified immediately of any

deficiencies found that require correction or additional

documentation.

The GTR reviews the SF-269, as required by 24 CFR 84,

\"Uniform Administrative Requirements for Grants and

Agreements with Institutions of Higher Education, Hospitals,

and Other Nonprofit Organizations\" and 24 CFR 85

\"Administrative Requirements for Grants and Cooperative

Agreements to States, Local Governments and Federally

Recognized Indian Tribes\".

The GTR makes certain that:

\(1\) The SF-269 is based upon the approved budget and covers

all bills paid and costs accrued during the reporting

period.

\(2\) Match and participant fees are reported in each SF-269.

(If they are not present, the GTR may request

supporting documentation or further explanation if

necessary.)

After completing the review, the GTR distributes copies

within 10 days of receipt, as follows:

o Original to the Grant Officer.

o Copy to the GTR\'s grantee file.

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LOCCS REMINDER: LOCCS/VRS will automatically generate

reminder letters to the grantee 45 days

prior to the appropriate due date of the

semi-annual report.

If a grantee is delinquent in submitting

the SF-269, reimbursement under LOCCS

may be delayed or suspended.

4.9 GRANTEE/OWNER ANNUAL REPORT (Form HUD-90006)

The Grantee/Owner Annual Report, Form HUD-90006, contains a

summary of programmatic and budgetary information for grantee

operations during the preceding 12 months, and it is part of the

annual program and budget review process. It provides

performance information for the just-ended federal fiscal year to

be used in an Annual Report to Congress.

a\. Due Dates and Submission

The annual report is due with the financial report on

October 30 of each year. The information reported must be

for the preceding federal fiscal year, October 1 through

September 30. The grantee submits the original and one copy

to the GTR.

A copy of the HUD-90006 and instructions for completing it

can be found in Appendix 14 of this handbook.

b\. Responsibilities for Grantees with Multiple Project Sites

Grantees with multiple sites must have each owner complete a

form for each project and send it to the grantee, who then

submits the aggregated data to HUD/RHS.

c\. HUD/RHS GTR Review

The GTR reviews the report and obtains corrections from

grantees if necessary. The GTR may discuss any problems

with the Headquarters Desk Officer.

After completing the review, the GTR:

o Maintains reports for the annual program/budget review

process; and

o Sends copies to the Headquarters program office by

November 30 of each year.

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Originals of each annual report submitted must be provided

to the Grant Officer.

LOCCS REMINDER: LOCCS/VRS will automatically generate

reminder letters to the grantee 105 days

prior to the appropriate due date of the

annual report. If the HUD-9006 is not

submitted in a timely manner, the next year\'s

budget amounts cannot be entered into the

system.

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