**CHAPTER 4**

**ORIENTATION, TRAINING, AND TECHNICAL ASSISTANCE**

**CONTENTS**

INTRODUCTION 4-2

> ORIENTATION SESSIONS 4-3
>
> TRAINING SESSIONS 4-6
>
> TRAINING DESIGN CRITERIA 4-8
>
> TECHNICAL ASSISTANCE 4-9
>
> MEASURING SUBRECIPIENT PROGRESS 4-11

**APPENDIX**

-   Sample Training Curriculum on Relocation, Real Property
    Acquisition,\
    and One-for-One Housing Replacement in CDBG Projects 4-15

-   Sample Handout: Summary of Major Differences Between 104(d) and URA\
    Relocation Assistance 4-20

-   Sample List of Written Materials 4-22

**CHAPTER 4**

**ORIENTATION, TRAINING, AND TECHNICAL ASSISTANCE**

*"An ounce of prevention is worth a pound of cure." -* Benjamin Franklin

#### INTRODUCTION

####  As a busy CDBG manager, you are probably confronted every day with recommendations for improving program operations. However, in your struggle to balance limited staff resources with the endless work to be done, these "good ideas" may never seem to get your full attention.

  -----------------------------------------------------------------------
  ***Subrecipient orientation, training and technical assistance provide
  the keys to successful program operations and reduced problems.***

  -----------------------------------------------------------------------

If you are like some CDBG managers, **subrecipient orientation**,
**training**, and **technical assistance** tend to fall into the
"good-idea category." You fully intend to get around to developing a
training program, once you get through *today's* crises.

The problem is that today's crises never completely end. The only way to
gain some control over these problems is to anticipate them and to take
steps to prevent them from occurring in the first place. ***Anticipating
and avoiding otherwise inevitable problems is the key benefit that
subrecipient orientation, training and technical assistance can bring to
your CDBG program.***

**Training as an Investment in the Future of Your Program**

Orientation, training, and technical assistance are part of the ongoing
investment you make in the quality of your programs. The payoff from
that investment is enhanced productivity among your subrecipients,
improved services for your community, and fewer administrative headaches
for you.

This chapter explains how you can use orientation, training, and
technical assistance to build more efficient and effective CDBG programs
among your subrecipients.

**How Orientation, Training, and Technical Assistance Differ**

With their future focus on enhancing performance and reducing problems,
these three teaching approaches have much in common. However, they
differ with respect to emphasis, timing, and target audiences.

-   **Orientation sessions** are traditionally held at the beginning of
    the program year (or whenever subrecipients are selected) and tend
    to address broad program objectives and methods.

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-   **Training sessions** are generally aimed at larger groups in more
    traditional classroom settings and are conducted throughout the year
    to address specific program areas.

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-   **Technical assistance** is usually provided one-on-one or in small
    groups, often on-site, when operations are already underway.

The characteristics and value of each approach are discussed in the
following sections.

  -----------------------------------------------------------------------
  ***The orientation session is a way to re-open the door of
  communications with subrecipients and to resolve old problems and
  tackle new ones.***

  -----------------------------------------------------------------------

The purpose of an orientation session is to educate (or remind)
subrecipients about the **basic** rules under which any CDBG activity
must operate in your community. An orientation session provides an
opportunity for you to establish **clear expectations** for
subrecipients with respect to **performance standards**, and with
respect to the **policies and procedures** that need to be followed. The
latter include both the policies and regulations of the national CDBG
program and your local administrative practices.

**ORIENTATION SESSIONS**

**One-on-One Orientation Sessions**

Many grantees approach orientation sessions with subrecipients on an
***informal, one-on-one basis*** whenever a new subrecipient joins the
local CDBG program. This approach has certain advantages but can also
have some significant drawbacks:

**Pros**: The one-on-one structure

-   allows you to tailor the orientation to the needs of the individual
    subrecipient organization and thereby secure greater involvement of
    subrecipient staff;

-   provides a better opportunity for you to test the subrecipient's
    understanding of essential material periodically throughout the
    session;

-   allows you to avoid an overly bureaucratic style that can intimidate
    new subrecipients; and

-   involves fewer logistics (and less cost) than conducting more formal
    sessions for multiple subrecipients.

**Cons:** The one-on-one style

-   may be inefficient because several sessions must be held;

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-   usually rules out peer group learning and interaction;

-   because of its informality, may understate the importance of
    consistent and complete compliance with the regulations; and

-   may have less impact as a "one-shot deal" due to subrecipient staff
    turnover later on, lack of repetition, and absence of formal
    integration into the monitoring program.

**Group Orientation Sessions**

  -----------------------------------------------------------------------
  ***Monitoring or performance problems are not limited to inexperienced
  subrecipients.***

  -----------------------------------------------------------------------

An alternative, and often preferable, approach is to hold **group
orientation sessions for multiple subrecipients at the beginning of
every program year**. Since problems encountered during monitoring are
not limited to "novice" subrecipients, it is a good idea to encourage
attendance by both new and experienced agencies. This would include **at
least**:

-   new subrecipients

-   new staff of current subrecipients

-   current subrecipients that have problems

-   current subrecipients that are undertaking new activities

You can invite even the most experienced subrecipients to attend, both
to share their experience with their less seasoned counterparts and to
learn about new program guidelines and regulations.

  -----------------------------------------------------------------------
  ***Don't forget the Board of Directors. They are legally responsible
  for everything the subrecipient does, so they should know what's going
  on.***

  -----------------------------------------------------------------------

Frequently, the more seasoned subrecipients are flattered to be asked to
share their expertise as part of the orientation. For enticing more
reluctant agencies to attend, you can use a variety of other
inducements:

-   promise to hand out executed written Agreements (or amended
    Agreements) at the orientation;

-   offer to explain new drawdown arrangements or forms;

-   make attendance by appropriate individuals a consideration for
    future selection; and

-   announce that you will couple orientation sessions with award
    ceremonies that recognize exceptional programs from the previous
    year.

> **Who should represent the subrecipient?**

For group orientation sessions, you can ask subrecipients to have more
than one representative attend. For example, in addition to a
non-profit's executive director, it may make sense to ask the
organization's program specialist, chief fiscal officer, or a
representative of the Board of Directors to attend (especially if the
Board is unfamiliar with the program).

Some of the benefits and drawbacks of the annual, group approach to
orientation sessions include:

**Pros and Cons of Group Orientation Sessions**

+-----------------------------------------------------------------------+
| ***Yes, we hold regular orientation sessions. It's important to get   |
| everyone involved, because we all learn from each other.***           |
|                                                                       |
| ***-New York Area Grantee***                                          |
+-----------------------------------------------------------------------+

**Pros:** Group sessions

-   help to assure that large numbers of subrecipients get the ***same
    message at the same time*** (important for organizations
    experiencing staff turnover, or in need of a general review of CDBG
    program regulations);

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-   support a ***structured agenda*** aimed at major fiscal and program
    reporting responsibilities;

-   encourage subrecipients to have ***several staff*** participate in
    the orientation, thereby increasing familiarity with program
    requirements ***throughout the subrecipient organization***;

-   generate exchange between seasoned and novice subrecipients,
    enabling newcomers to learn the ***"real world" applications*** of
    the regulations directly from the "old hands," while old-timers can
    be challenged by the vigor of the novices; and

-   communicate to subrecipients your ***emphasis on understanding CDBG
    program rules and regulatory compliance***, by making the
    orientation a formal workshop and conducting it on an annual basis.

**Cons:** Formal orientation workshops

-   tend to require ***more effort to prepare***, coordinate, and
    deliver than do one-on-one sessions;

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-   lose some of their benefits ***if subrecipients are unable to send
    more than one*** representative;

-   can make it ***more difficult*** to cover information that is
    ***relevant to every organization*** in attendance;

-   make it ***more difficult*** to assess subrecipients' comprehension
    of the material and to adapt the material ***to differences in
    comprehension***; and

-   make it ***more difficult*** to get certain ***key (higher level)***
    staff to attend.

+-----------------------------------------------------------------------+
| **A Tip for Structuring Orientation Sessions**                        |
|                                                                       |
| USE THE SUBRECIPIENT AGREEMENT AS A TEACHING TOOL FOR SUMMARIZING     |
| CDBG PROGRAM REQUIREMENTS                                             |
|                                                                       |
| Use the Subrecipient Agreement as one of the key training materials   |
| in any orientation session you conduct. As noted in Chapter 3, a      |
| well-written Subrecipient Agreement will summarize all the principal  |
| CDBG program requirements in easily readable language, and can serve  |
| as a "mini" training manual. By structuring your orientation session  |
| to make extensive use of the written Agreement, you emphasize the     |
| importance of this document and teach subrecipients to develop the    |
| habit of referring to the Agreement for guidance on CDBG program      |
| policies and procedures.                                              |
+-----------------------------------------------------------------------+

#### TRAINING SESSIONS

  -----------------------------------------------------------------------
  ***Training sessions can be issue-specific or activity-specific, but in
  either case, you should make your training goals clear to everyone at
  the outset.***

  -----------------------------------------------------------------------

An orientation workshop usually focuses on meeting [general]{.underline}
program requirements and addressing g[eneral]{.underline} topics that
merit particular attention in the coming year.

Training sessions tend to *focus on specific CDBG topics, and examine
topics at a much greater level of technical detail* than an orientation
session does. For example, although the orientation will give
subrecipients an overview of the entire program, many grantees hold
periodic training sessions for groups of subrecipients on specific
aspects of the CDBG program. On-going monitoring should tell you the
topics on which your subrecipients need help.

**Issue-Specific Training Topics**

The topics you cover can be either issue-specific or activity- specific.
Examples of issue-specific training topics include:

-   basic financial underwriting for economic development;

-   financial control systems and procedures (including Independent
    Public Accountant audits);

-   record-keeping and reporting requirements (including documentation
    of eligible expenses and National Objective compliance);

-   procurement methods;

-   recruitment and hiring of staff;

-   anti-discrimination requirements;

-   program income;

-   relocation/anti-displacement;

-   Davis-Bacon Act/prevailing wage requirements;

-   historic preservation;

-   property appraisals;

-   lead-based paint requirements;

-   liens and recapture agreements; and

-   accessibility requirements.

The common feature of the above training topics is that each one is
relevant to **more than one type of CDBG-eligible activity**. For
example, Davis-Bacon wages are applicable to most CDBG-assisted public
facilities, residential, and commercial activities involving
CDBG-financed construction contracts over \$2,000.

  -----------------------------------------------------------------------
  ***Train subrecipient and grantee staff in administrative systems using
  two publications available on the HUD Web site.***

  -----------------------------------------------------------------------

Because of their broad applicability, issue-specific training topics may
be relevant to many (if not all) of your subrecipients. Materials for
any or all of these subjects may be obtained from HUD. **The
publication, [Playing by the Rules*-*A Handbook for CDBG Subrecipients
on Administrative Systems]{.underline}*,* and its companion piece*,*
[Training CDBG Subrecipients in Administrative Systems]{.underline},**
**are available from the CPD library on the HUD Web site at
*www.hud.gov*. Both can serve as the centerpiece for grantee training of
both subrecipient and grantee staff.**

**Activity-Specific Training**

**Topics**

Training sessions can also focus on the requirements associated with
specific activity areas. In these cases, the training will be relevant
only to agencies that carry out the specified activity. For example, you
might want to structure activity-specific training around the following
topics:

-   housing rehabilitation and development (including the use of escrow
    accounts);

-   public and human services;

-   economic development or commercial improvements;

-   public facilities and infrastructure;

-   administration or planning activities;

-   acquisition, demolition, or disposition;

-   special CBDO activities under 24 CFR 570.204; and

-   Section 108 loan guarantees.

**Issue- [and]{.underline} Activity-Specific Training Combined**

A third option is to provide training to a **subgroup of agencies that
carry out specific activities** (e.g., public services, housing,
economic development) but to **focus** on the generic requirements of
the overall CDBG program.

The reason for using this approach is that certain kinds of activities
are more likely than others to cause fiscal or program monitoring
problems.

For example, the large CDBG programs that use many subrecipients to
carry out acquisition, housing, and economic development activities are
more likely to encounter problems with their subrecipients' basic
administrative systems and overall performance than their smaller
counterparts. They are therefore more likely to benefit from training
the subrecipients responsible for these activities in general
administrative requirements.

Many of these administrative problems can result in disallowances,
interruptions in projects, and other serious problems. For this reason,
you're better off avoiding the problem in the first place through
effective training, instead of waiting until HUD finds a problem in your
program.

**Basic Training Objectives**

-   Compliance

-   Performance

-   Capacity

In designing training for subrecipients, keep your objectives in mind.
Obviously, you want to **improve compliance with program rules and
regulations** in order to avoid the monitoring findings, questioned
costs, disallowances, or interruptions in funding.

####  {#section .unnumbered}

#### In addition, you want the training to enhance overall performance and the long-term capacity of subrecipients to provide services to the community both efficiently and effectively. {#in-addition-you-want-the-training-to-enhance-overall-performance-and-the-long-term-capacity-of-subrecipients-to-provide-services-to-the-community-both-efficiently-and-effectively. .unnumbered}

#### TRAINING DESIGN {#training-design .unnumbered}

#### CRITERIA

+-----------------------------------------------------------------------+
| ***We usually hold a "networking" dinner after major annual training  |
| and hold an awards segment for the "best new CDBG project," or "best  |
| CBO" director. It's lots of fun.***                                   |
|                                                                       |
| ***-Enthusiastic Los Angeles Area Subrecipient***                     |
+-----------------------------------------------------------------------+

Design all your training to meet the following three criteria that form
the basis of all learning:

**Relevance (What**)**:** Training must have some direct connection with
the daily experience and concerns of subrecipients in terms of what they
do. For example, you might teach non-profits rehabilitating low-income
housing how to standardize their work write-ups to correspond to their
Agreements and provide a basis for contract specifications.

**Utility (How**)**:** Training must enable participants to acquire new
skills, which they can apply to their activities to help increase
productivity, reduce problems, or both. For example, non-profits can
learn how to use the standardized work write-up on a computer, thereby
saving an enormous amount of time while also reducing errors.

**Motivation (Why**)**:** Training must make participants want to take
action, change behavior, learn new ways of doing things, solve problems,
or improve their performance. The time savings and use of new technology
in the previous example enables the non-profit to streamline its entire
approach to managing the rehabilitation process.

Without these three elements, training cannot be effective.

**Learning by Doing**

It has been said that people remember 10 percent of what they hear and
90 percent of what they do. As much as possible, your training should
involve participants in problem-solving exercises, role-playing,
simulations, small group discussions, and other hands-on activities that
will involve them actively in the training.

If you lecture, give participants written summaries of key points. Use
panels and oral presentations to feature successful examples in order to
reinforce the relevance and the feasibility of your training goals.

**The Appendix to this chapter provides an example of how you might
structure a day-long training session on relocation and
anti-displacement requirements for CDBG projects. The format covers
various topics and methods organized around a single theme.**

**Scheduling and Location**

Clearly, the convenience of the time and place of the training sessions
is important for assuring attendance. It is also crucial to select a
training site that fosters participation. Key features include adequate
space for role playing and small group discussions, lighting,
ventilation, furnishings, restrooms, audio-visual equipment and, if
necessary, photocopying equipment.

Ideally, the training site should be accessible by both public
transportation and private vehicles, provide parking, and accommodate
disabled participants. Translation of written materials into other
languages should be available where it is likely to be needed.

If the training is going to run for more than half a day, there should
be a restaurant nearby or provision for participants to bring their own
food and refreshments.

####   {#section-1 .unnumbered}

#### TECHNICAL ASSISTANCE {#technical-assistance .unnumbered}

####  Typically, technical assistance is designed to correct a specific subrecipient weakness, either in performance of a particular CDBG-funded activity or in general administration. Technical assistance addresses well-defined functional areas. Some examples of technical assistance topics include:

**For general administration**:

-   how to structure a line item budget and an administrative cost
    allocation system.

**For economic development activities:**

-   how to document financial analysis and organize data collection from
    job applicants and employees in connection with economic development
    assistance to a for-profit corporation.

**For housing rehabilitation activities:**

-   how to conduct a home inspection, prepare a work write-up, test for
    lead-based paint, and measure progress toward project goals.

**Broaden the Scope of Technical Assistance**

  -----------------------------------------------------------------------
  ***The first task is to solve the problem; the next is to motivate
  overall improved performance.***

  -----------------------------------------------------------------------

+-----------------------------------------------------------------------+
| ***"Effective monitoring programs require frequent site visits and    |
| field audits. Technical assistance is the same. It helps to be where  |
| the action is."***                                                    |
|                                                                       |
| ***-St. Louis Area Grantee***                                         |
+-----------------------------------------------------------------------+

Technical assistance tends to be reactive, aimed at correcting existing
subrecipient problems. Whenever possible, however, you should broaden
the focus to emphasize the importance of overall program quality and
constant improvement by providing subrecipients with new knowledge and
skills.

Technical assistance is frequently offered "on-site" (that is, at the
location where program operations occur). While on-site, the person(s)
providing the assistance may:

-   demonstrate approved techniques.

-   observe subrecipient staff in their normal activities and then
    recommend ways to improve operations.

While technical assistance is generally conducted on a one-on-one
(grantee-to-subrecipient) basis, you can also assemble several staff
from one subrecipient, or staff from several subrecipients, at a single
location where you can pass out and explain materials or present
demonstrations of materials or techniques. Technical assistance can also
be provided to individual subrecipients by telephone, for instance, when
the subrecipient has a question about filling out a form or implementing
an administrative procedure.

**Standards for Delivering Technical Assistance**

Technical assistance is the most frequent training-related contact
between grantees and subrecipients, and it is often conducted by
grantees in response to a specific request from a subrecipient. In order
to provide the best possible response, make sure you adhere to the
following five guidelines:

-   **Provide a reasonable response time**: Making subrecipients wait
    weeks for help sends a strong message that you don't think their
    request is important.

-   **Be relevant**: Make sure that the technical assistance you provide
    addresses the questions the subrecipient has raised and not merely
    the topics you feel are important. Deal first with the issues on
    their minds, before addressing your concerns or HUD's.

-   **Provide accurate information**: Nothing frustrates a subrecipient
    more than getting incorrect information from a grantee. If your
    staff are not sure of the correct answer to a question, they should
    say so, and then take the time to get the proper answer or
    interpretation before passing it on.

-   **Consider the subrecipient's level of expertise and resources**:
    Technical assistance is supposed to clarify, instruct or correct
    matters for subrecipients, not confuse or place unrealistic demands
    on them. It does little good to recommend high-powered accounting
    software to a subrecipient that does not have access to a computer.
    Similarly, the guidance you offer to satisfy technical or regulatory
    requirements should be consistent with the funds, time, and staffing
    level the subrecipient has available for meeting them.

-   **Assess subrecipient comprehension**: Always test the
    subrecipient's understanding of the information you provide. One way
    of doing this is to ask subrecipient staff to give their opinion of
    how they would apply the new technical information or skills to a
    hypothetical situation.

Keep in mind that ***technical assistance is usually not a one-time
event.*** Allow the subrecipient staff some time to apply the knowledge
or the skills covered by the technical assistance in the work place;
then re-visit them to determine how well they learned the lessons and
how confident they feel about having mastered the new information or
skills after some "real world" testing.

+-----------------------------------------------------------------------+
| **A Tip for Conducting Technical Assistance in Anticipation of        |
| Monitoring a Subrecipient**                                           |
|                                                                       |
| **One objective of technical assistance is to help subrecipients      |
| avoid monitoring "findings."** As a strategy for achieving this, some |
| grantees conduct a **pre-monitoring technical assistance visit** to   |
| subrecipients. During the visit, grantee staff identify all the areas |
| that formal monitoring will cover, and provide an initial, informal   |
| assessment of the adequacy of the subrecipient's systems, procedures, |
| and records. If scheduled several months before the formal monitoring |
| is to occur, these pre-monitoring TA visits give the subrecipient     |
| time to correct possible deficiencies so as to avoid written          |
| findings. It also gives them the opportunity to raise questions with  |
| the grantee outside of the formal monitoring process when the         |
| participants are likely to be more defensive. Subrecipients tend to   |
| feel better about the effort that they have put in to comply with     |
| program regulations. At the same time, the grantee can demonstrate to |
| HUD that the regulations have been satisfied.                         |
+-----------------------------------------------------------------------+

## MEASURING SUBRECIPIENT PROGRESS

##  There are many ways to measure the effectiveness of your orientation, training, and technical assistance efforts. For example, you can examine:

-   the number of new monitoring findings that occur among subrecipients
    after you have provided them with orientation, training, or
    technical assistance; or

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-   changes in subrecipient productivity for activities that you
    addressed in orientation, training, and technical assistance
    sessions.

Another way to assess your orientation training and technical assistance
capacity is to ask subrecipients how valuable and relevant they thought
your training and technical assistance were. Soliciting their opinion in
a formal, serious manner will show them that you care about whether they
benefited from your efforts and that you really want to provide
assistance they can use to make their job easier and more productive.
Showing this concern will help motivate subrecipients to want to
continue learning from you, because they will realize you really do have
something of practical benefit to offer them.

***Above all, let them know how much their success and their opinions
about orientation, training, and technical assistance matter to you.***

**NOTES:**

# CHAPTER 4: APPENDIX {#chapter-4-appendix .unnumbered}

#  {#section-2 .unnumbered}

-   Sample Training Curriculum on Relocation, Real Property

> Acquisition, and One-For-One Housing Replacement in
>
> CDBG Projects (and Related Materials) 4-15

-   Sample Handout: Summary of Major Differences

> Between 104(d) and URA Relocation Assistance 4-20

-   Sample list of Written Materials 4-22

  -----------------------------------------------------------------------
  [NOTE TO GRANTEES:]{.underline} The requirements of the Uniform
  Relocation Assistance and Real Property Acquisition Policies Act of
  1970 (URA) and the Relocation Assistance Plan under section 104(d) of
  the Housing and Community Development Act of 1974 (HCDA of 1974) are
  very complicated and technical. When the grantee executes the required
  certifications, it assures that all statutory and regulatory
  requirements will be met. Regardless of the tasks delegated to a
  subrecipient, the grantee remains liable for any costs arising from
  noncompliance with the law or regulations. For these reasons, HUD
  believes that few subrecipients will have or acquire the expertise to
  carry out all these requirements and that generally it is not in the
  interest of the grantee to delegate completely the tasks required under
  these laws. Before conducting any training for subrecipients on this
  subject, the grantee must decide exactly which functions it will
  perform and those it expects the subrecipient to perform.

  -----------------------------------------------------------------------

#### Sample Training Curriculum on Relocation, Real Property Acquisition, and 

#### One-For-One Housing Replacement in CDBG Projects

9:00 a.m. − 9:15 a.m. **Introduction and welcome**

9:15 a.m. − 10:30 a.m. **Applicable regulatory requirements**

> OVERVIEW: [Presentation on key legislation and
> regulations]{.underline}
>
> a\. **Uniform Relocation Assistance and Real PropertyAcquisition
> Policies Act of 1970 (URA)**

-   The government-wide regulations are found at 49 CFR part 24, as
    referenced in the CDBG regulations at 24 CFR 570.606(b)(1).

-   Changes to the government-wide regulations were effective February
    3, 2005.

-   For questions on real property acquisition and relocation, contact
    your HUD Field Office or the HUD Regional Relocation Specialist
    responsible for your geographic location as identified at
    www.hud.gov/relocation.

> b\. **Section 104(d) Relocation Requirements ("Barney Frank**
>
> **Amendments" to Title I of the Housing and Community**
>
> **Development Act of 1974)**

-   Section 104(d) relocation requirements differ from URA in several
    ways, including eligibility for assistance and extent of assistance
    provided.

> c\. **Other Relocation Requirements**

-   Program regulations at 24 CFR 570.606 and 24 CFR Part 42

> specify additional relocation requirements (e.g., temporary
>
> relocation).
>
> These Federal laws and regulations require that whenever there is a
> need to relocate property occupants on a [permanent or temporary
> basis]{.underline}, all affected occupants must be notified as early
> as possible about their rights to relocation payments and other
> assistance.
>
> Section 104(d) requires the community to certify that it is following
> a Residential Anti-Displacement and Relocation Assistance Plan. The
> Plan requires the grantee to: 1) outline the steps that will be taken
> to minimize displacement; 2) replace, on a one-for-one basis, all
> occupied and vacant occupiable low- and moderate-income housing units
> lost due to demolition or conversion (although replacement is not
> necessary if HUD determines there is an adequate supply of standard
> low- and moderate-income housing in the community); and 3) provide
> relocation assistance for low- and moderate-income occupants. The
> replacement plan must ensure that the replacement housing will be:
> provided within 3 years of commencement of the assisted activity;
> located in the same community; sufficient in size and number to house
> no fewer than the number of occupants who could have been housed in
> the demolished converted units; in standard condition; and designed to
> remain low and moderate income for 10 years.

10:30 a.m. − 10:45 a.m. Break

10:45 a.m. − 12:00 noon **Roles, Procedures, and Types of Assistance**

> [Presentation on grantee and subrecipient roles relative to relocation
> and real property acquisition:]{.underline}
>
> Functions that the grantee should routinely undertake itself are:

-   The issuance of notices of eligibility for relocation assistance.

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-   The provision of advisory services to businesses.

-   Social service referrals for difficult cases.

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-   Review and approval of relocation claims and processing of
    relocation payments.

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-   Processing of appeals.

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-   Maintaining records sufficient to demonstrate compliance with the
    relocation and real property acquisition requirements. (To maintain
    complete records, the grantee will need to be copied on
    correspondence, etc., from subrecipients.)

> Specific functions that subrecipients normally can be expected to
> perform:

-   Identify occupants of the property when consideration of project
    proposal is initiated (e.g., obtain copy of "rent roll").

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-   Identify persons moving into the property after consideration of the
    project is initiated.

-   Survey tenants to gather information on household size, income,
    housing needs and preferences. \[Grantee should explain in detail
    exactly what is expected of subrecipients, e.g., how to survey
    tenants and collect information on household size, income, etc.\]

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```
-   Issue general information notice.

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-   Coordinate with grantee on referrals to suitable and comparable
    replacement housing and provide transportation to inspect the
    housing.

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-   Identify suitable housing for the temporary relocation of persons
    not displaced.

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-   Issue timely Notices of Non-displacement.

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```
-   Coordinate with grantee to permit grantee to issue timely Notices of
    Eligibility for relocation assistance.

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-   Coordinate with grantee to permit timely grantee processing of
    relocation claims.

> \[Grantee should supply information booklets, guideform general
> information notices and guideform Notices of Eligibility and/or
> Non-displacement (if applicable) to the subrecipients and answer
> questions about the materials.\]
>
> [Additional information on forms and amounts of
> assistance]{.underline}:
>
> Discussion of differences in assistance available under 104(d) versus
> URA: Section 104(d) assistance is similar to that under URA, although
> Section 104(d) also allows for relocation payments for security
> deposits and credit checks and provides for replacement housing
> payments for a longer time period (60 months versus 42 months under
> URA). \[See "Sample Handout" in this Appendix.\]
>
> Discussion of formulas to compute residential relocation assistance
> payments: moving and related expenses (fixed moving and dislocation
> allowance or actual moving expenses and related costs); replacement
> housing payments (URA formula versus Section 104(d) formula).
>
> Discussion of available Section 8 assistance and HOME tenant-based
> rental assistance.
>
> Presentation on specific requirements for temporary residential
> relocation: notice of non-displacement; definitions of suitable
> temporary housing; exceptions for owner-occupants.

12:00 noon − 1:00 p.m. **Lunch break**

1:00 p.m. − 1:30 p.m. **Exercise on temporary residential relocation**

> Exercise could involve presenting the participants with several brief
> hypothetical examples of temporary relocation, asking them to comment
> on process, range, and levels of assistance provided.

1:30 p.m. − 2:00 p.m. **Presentation on procedures for residential
displacement**

> Discussion of procedures, including: informing occupants and manner of
> notice; advisory services to persons to be displaced; identification
> and referrals to comparable replacement housing; moving into
> replacement housing; processing claims and making payments; appeal
> procedures; and respective roles of grantee and subrecipient.

2:00 p.m. − 2:45 p.m. **Exercise on residential displacement**

> Participants could be given a scenario involving probable displacement
> of residential property occupants, and asked to describe the process
> that should be followed to ensure adequate replacement housing and the
> respective roles of the grantee and the subrecipient in that process.
> Participants also examine the long- and short-term costs of alternate
> approaches.

2:45 p.m. − 3:00 p.m. Break

3:00 p.m. − 3:30 p.m. **Presentation on requirements and procedures for
business relocation**

> Discussion of differences between residential and business relocation
> assistance under URA; differences between actual and fixed payments;
> business owner options to remain in business or go out of business,
> and the assistance available in each case; and limits to assistance in
> finding suitable replacement business locations.

3:30 p.m. − 4:00 p.m. **Exercise on business relocation**

4:00 p.m. − 4:30 p.m. **Record-keeping requirements for
relocation/displacement assistance**

4:30 p.m. − 5:00 p.m. **Summary of key points, additional questions &
answers, and feedback**

> Grantee should close session by providing name and telephone number of
> grantee staff member(s) who will be responsible for providing
> assistance on relocation, property acquisition, and one-for-one
> housing replacement matters.

**ATTACHMENTS:**

-   Sample Handout Comparing 104(d) and URA Relocation Assistance

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-   Sample List of HUD Written Materials on Relocation

**SAMPLE HANDOUT**

**SUMMARY OF MAJOR DIFFERENCES**

**BETWEEN 104(d) AND URA RELOCATION ASSISTANCE**

**PART I. ELIGIBILITY FOR ASSISTANCE**

+-----------------+----------------------------+-----------------------+
| **Subject**     | **Section 104(d)**         | **URA/HUD Program     |
|                 |                            | Regulations**         |
+-----------------+----------------------------+-----------------------+
| Income          | Only lower-income persons  | Displaced persons of  |
| Requirements    | are assisted.              | all incomes are       |
|                 |                            | eligible.             |
+-----------------+----------------------------+-----------------------+
| Person          | Displaced persons are      | Displaced persons are |
| displaced by    | eligible only if the       | eligible for          |
| rehabilitation  | market rent (including     | assistance regardless |
| activities      | utilities) of the unit     | of pre- and           |
| (including      | before rehab did not       | post-rehabilitation   |
| economic        | exceed the Section 8       | rents. (URA does not  |
| displacement).  | Existing Housing Fair      | cover economic        |
|                 | Market Rent (FMR) and the  | displacement, but HUD |
|                 | market rent after rehab    | program regulations   |
|                 | was above the FMR.         | require assistance    |
|                 |                            | equivalent to URA.)   |
+-----------------+----------------------------+-----------------------+
| Economic        | Displaced person is        | Displaced person is   |
| Displacement    | eligible if not offered a  | eligible if not       |
| Criteria        | suitable unit at or below  | offered an            |
|                 | the greater of:            | appropriate unit at   |
|                 |                            | or below the greater  |
|                 | -   Total Tenant Payment;  | of:                   |
|                 |     or                     |                       |
|                 |                            | -   30% of gross      |
|                 | -   Old rent/utility       |     income; or        |
|                 |     costs.                 |                       |
|                 |                            | -   old rent/utility  |
|                 |                            |     costs             |
|                 |                            |                       |
|                 |                            | NOTE: 30% of gross    |
|                 |                            | income is the general |
|                 |                            | policy; rules vary by |
|                 |                            | program.              |
+-----------------+----------------------------+-----------------------+
| Person          | Displaced person is        | Displaced person is   |
| displaced by    | eligible only if the       | eligible for          |
| [conversi       | market rent (including     | assistance by any     |
| on]{.underline} | utilities) of the          | conversion to a       |
| of unit to a    | displacement unit did not  | nonresidential use.   |
| nonresidential  | exceed the FMR before      |                       |
| use.            | conversion.                |                       |
+-----------------+----------------------------+-----------------------+
| Person          | Displaced person is        | Displaced person is   |
| displaced by    | eligible regardless of     | eligible regardless   |
| [demolitio      | pre-demolition market      | of the pre-demolition |
| n]{.underline}. | rent.                      | market rent.          |
+-----------------+----------------------------+-----------------------+
| Person          | Displaced person is not    | Displaced person is   |
| displaced by    | eligible.                  | eligible.             |
| [acquisiti      |                            |                       |
| on]{.underline} |                            |                       |
| only (no        |                            |                       |
| conversion).    |                            |                       |
+-----------------+----------------------------+-----------------------+

**SAMPLE HANDOUT (Continued)**

**SUMMARY OF MAJOR DIFFERENCES**

**BETWEEN 104(d) AND URA RELOCATION ASSISTANCE**

**PART II. AMOUNT OF ASSISTANCE PROVIDED**

+-----------------+----------------------------+----------------------+
| **Subject**     | **Section 104(d)**         | **URA/HUD Program    |
|                 |                            | Regulations**        |
+-----------------+----------------------------+----------------------+
| Rental          | 60 Months                  | 42 Months            |
| Assistance Term |                            |                      |
+-----------------+----------------------------+----------------------+
| Rental          | Amount needed to reduce    | Amount needed to     |
| Assistance      | new rent/utility costs to  | reduce new           |
| Payment         | Total Tenant Payment,      | rent/utility costs   |
|                 | which is usually greater   | to the lower of:     |
|                 | of:                        |                      |
|                 |                            | -   Old rent/utility |
|                 | -   30% of adjusted        |     costs; or        |
|                 |     monthly income, or     |                      |
|                 |                            | -   30% of gross     |
|                 | -   10% of gross monthly   |     monthly income   |
|                 |     income.                |     (varies by       |
|                 |                            |     program).        |
+-----------------+----------------------------+----------------------+
| Use of Section  | If Section 8 assistance    | Displaced person has |
| 8 Rental        | and suitable referrals are | the right to a cash  |
| Assistance      | offered, displaced person  | replacement housing  |
|                 | cannot insist on cash      | payment but may      |
|                 | replacement housing        | accept Section 8     |
|                 | payment. (But tenant may   | assistance if it is  |
|                 | request cash replacement   | offered.             |
|                 | housing payment under      |                      |
|                 | URA.)                      |                      |
+-----------------+----------------------------+----------------------+
| Other Housing   | Assistance includes        | Assistance does not  |
| Assistance      | security deposit at        | include security     |
|                 | replacement dwelling.      | deposit.             |
+-----------------+----------------------------+----------------------+
| Homeownership   | Limited to purchase of     | Not limited to       |
| Assistance      | cooperative or mutual      | cooperative or       |
|                 | housing and based on       | mutual housing.      |
|                 | present (discounted) value | Payment equals 42x   |
|                 | of 60 monthly rental       | monthly rental       |
|                 | assistance payments.       | assistance payment   |
|                 |                            | (i.e., not           |
|                 |                            | discounted).         |
+-----------------+----------------------------+----------------------+
| Moving and      | Same as URA.               | Person may choose    |
| Rental Expenses |                            | either:              |
|                 |                            |                      |
|                 |                            | -   Payment for      |
|                 |                            |     actual moving    |
|                 |                            |     and related      |
|                 |                            |     expenses; or     |
|                 |                            |                      |
|                 |                            | -   Alternative      |
|                 |                            |     Allowance based  |
|                 |                            |     on DOT schedule. |
+-----------------+----------------------------+----------------------+
| Advisory        | Same as URA.               | Comprehensive        |
| Services        |                            | services provided.   |
+-----------------+----------------------------+----------------------+

**SAMPLE LIST OF WRITTEN MATERIALS**

**RELOCATION AND REAL PROPERTY ACQUISITION IN HUD-ASSISTED PROGRAMS -
GUIDANCE MATERIALS**

The following HUD materials are available to help grantees implement
relocation and real property acquisition requirements in HUD-assisted
programs. The materials were current as of the date this Guidebook was
printed, but may be updated, as appropriate, due to changes to the URA
regulations that were effective February 3, 2005.

1.  **URA INFORMATION BOOKLETS**. Under the URA, grantees are required
    to provide advisory information to persons to be displaced and the
    owners of property to be acquired, explaining their rights and the
    assistance to which they are entitled. The following four
    information booklets meet the generic information requirements.
    These booklets are optional. Grantees may develop and distribute
    their own information booklets, provided they meet applicable
    requirements. These booklets are available on HUD's website at
    www.hud.gov/relocation.

    a.  *When a Public Agency Acquires Your Property* (HUD-1041-CPD)
        (1/03).

> Spanish Title: *Cuando Una Agencia Publica Adquiere Su Propiedad*
> (HUD-1041- CPD-1) (3/03).

b.  *Relocation Assistance to Displaced Homeowners* (HUD-1044-CPD)
    (9/02).

> Spanish Title: *Asistencia Para La Reubicación a Propietarios de
> Vivienda Desplazados* (HUD-1044-CPD-1) (3/03).

c.  *Relocation Assistance to Tenants Displaced From Their* *Homes*
    (HUD-1042-CPD) (9/02).

> Spanish Title: *Asistencia Para La Reubicación a Inquilinos
> Desplazados de Sus Hogares* (HUD-1042-CPD-1) (3/03).

d.  *Relocation Assistance to Displaced Businesses, Non-profit
    Organizations and Farms* (HUD-1043-CPD) (9/02).

> Spanish Title: *Asistencia Para La Reubicación a Negocios,
> Organizaciones No Lucrativas y Granjas Desplazados* (HUD-1043-CPD-1)
> (3/03).

2\. **SECTION 104(d) INFORMATION BOOKLET**. This booklet, *Relocation
Assistance Under Section 104(d) to Persons Displaced From Their Homes*
(HUD-1365-CPD) (3/02), explains a tenant's rights and the assistance
available to the tenant if he/she is displaced by an action subject to
Section 104(d) of the HCDA of 1974, as amended. A Spanish version,
*Asistencia Para La Reubicación a Personas Desplazadas de Sus Viviendas*
(Sección 104 (d)) HUD-1365-CPD-1, is also available.

3\. **RELOCATION CLAIM FORMS**. In order to obtain the relocation
payment(s) for which he or she is eligible, a displaced person must file
a claim. The grantee must provide the person whatever assistance is
necessary to prepare such claims. The following claim forms meet all HUD
requirements. A grantee may utilize these forms or design its own forms.

1.  *Claim for Moving and Related Expenses*  *Families and Individuals*
    (Form HUD- 40054) (10/02).

2.  *Claim for Actual Reasonable Moving and Related Expenses 
    Businesses Non-profit Organizations and Farm Operations* (Form
    HUD-40055) (10/02).

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a.  *Claim for Fixed Payment in Lieu of Payment for Actual Moving and
    Related Expenses---Businesses, Non-profit Organizations and Farm
    Operations* (Form HUD-40056) (10/02).

b.  *Claim for Replacement Housing Payment for 180-Day Homeowner* (Form
    HUD- 40057) (10/02) (URA only).

c.  *Claim for Rental Assistance or Down Payment Assistance* (Form
    HUD-40058) (10/02) (URA only).

d.  *Reclamo Para Asistencia para el Alquiler o Asistencia para el Pago
    (Bi-lingual)* (Form HUD-40058-S).

e.  *Claim for Rental or Purchase Assistance under Section 104(d) of the
    Housing and Community Development Act of 1974, as amended* (Form
    HUD-40072) (2/02).

4\. **FORM HUD-40061 (2/02), SELECTION OF MOST REPRESENTATIVE COMPARABLE
REPLACEMENT DWELLING.** This form assists grantees in selecting the
comparable replacement dwelling to be used to establish the upper limit
of a replacement housing payment.

5\. **SCHEDULE FOR DETERMINING THE FIXED MOVING EXPENSE AND DISLOCATION
ALLOWANCE**. These statewide schedules establish moving expense and
dislocation allowances for persons displaced from a dwelling by a
project subject to the URA and/or Section 104(d) of the HCDA of 1974. A
new schedule is published periodically in the [Federal
Register]{.underline} by the Department of Transportation and can be
found at its web site at www.fhwa.dot.gov/realestate/fixsch96.htm.