**CHAPTER 2**

**PRE-AWARD ASSESSMENT**

**CONTENTS**

> INTRODUCTION 2-2
>
> FACTORS IN A PRE-AWARD ASSESSMENT 2-3
>
> MODELS FOR PERFORMING PRE-AWARD ASSESSMENTS
>
> AND SELECTING SUBRECIPIENTS 2-6
>
> A MIXTURE OF APPROACHES 2-10
>
> DEALING WITH A SCARCITY OF QUALIFIED ORGANIZATIONS 2-11

**APPENDIX**

-   Sample Subrecipient Application Package 2-14

-   Basic Elements of a Subrecipient Application for Funding and

> Applicable Federal Regulations 2-23

-   Subrecipient Selection Checklist 2-24

-   Application Rating System 2-25

-   Risk Analysis Matrix 2-27

**CHAPTER 2**

**PRE-AWARD ASSESSMENT**

*As director of the Community Development Agency in Midtown, William Lee
was looking for an organization to help run the city\'s new housing
rehabilitation program in the South Park neighborhood. William had heard
about a local non-profit agency that was doing 'great things' in
housing, according to several Midtown city councilors. Based on this
endorsement, and with assurances from the non-profit's Director about
the quality of its work and its commitment to the neighborhood, William
didn\'t feel a more formal assessment of the organization\'s capacity
was necessary. He selected the non-profit as a subrecipient without
determining whether the subrecipient had the administrative systems and
procedures necessary to comply with CDBG regulations.*

*Eight months later, the CDA\'s monitoring revealed that the non-profit
had incurred substantial program expenses before the environmental
review process was completed, rendering those expenses unallowable.
Moreover, although the non-profit was doing high quality rehabilitation
work, staff had failed to maintain documentation on household
eligibility, procurement of materials, progress payments, or final
inspection of the work. When William called to find out how this had
happened, the non-profit\'s Executive Director said that he had never
paid much attention to bureaucratic \'red tape,\' and focused on
\'results rather than paperwork.\' The next day, William received calls
from two city councilors wanting to know why he was \'harassing\' such
an outstanding organization.*

**INTRODUCTION**

This chapter focuses on procedures for assessing the capabilities of
prospective subrecipients **prior to** awarding them CDBG funds. Because
many local CDBG programs have been funding the same subrecipients for
several years, you should also apply these procedures in deciding
whether to continue to use your current subrecipients.

There is no regulatory requirement that grantees formally assess
prospective subrecipients. Your authority to "designate" an organization
as a subrecipient is one of the features of this category of service
provider that distinguishes it from a contractor. (You can select
contractors only after a formal procurement process designed to afford
"free and open competition.")

**Importance of Pre-Award Assessments**

A thoughtful pre-award assessment of potential subrecipients can:

-   reduce the risk of major problems later on, and

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-   increase the chances for success.

Whether you are selecting new subrecipients or extending current
Subrecipient Agreements, it is helpful to know ahead of time what to
prepare for and what to fix ***before the Agreement is signed.*** You
may have to live with the problem a long time if you don\'t.

**There are no perfect subrecipients.**

You should not view the pre-award assessment of potential subrecipients,
or the review of the prior performance of current subrecipients, as
attempts to weed out all organizations except those with a perfect track
record. Ideal subrecipients probably do not exist. Instead, you should
treat the assessment process as a way to measure the strengths and
weaknesses of prospective organizations and to identify potential
problem areas in working with them, so that you can develop support
mechanisms to strengthen these organizations in

the future.

+-----------------------------------------------------------------------+
| ***Pre-award assessments are essential for effective:***              |
|                                                                       |
| -   ***Selection***                                                   |
|                                                                       |
| -   ***Subrecipient Training***                                       |
|                                                                       |
| ***Design***                                                          |
|                                                                       |
| -   ***Technical Assistance***                                        |
|                                                                       |
| -   ***Subrecipient Agreements***                                     |
|                                                                       |
| -   ***Performance Monitoring***                                      |
+-----------------------------------------------------------------------+

Pre-award evaluations can help you:

-   decide which of several prospective subrecipients to select for a
    particular activity;

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-   identify early training and technical assistance that you can

provide to potential subrecipients lacking previous CDBG

experience;

-   include special conditions in the written Subrecipient Agreement
    that make initial or continued funding contingent on the agency\'s
    correcting particular deficiencies by a mutually agreed-on date; and

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-   identify special monitoring procedures, such as more frequent
    on-site visits or special audits, to assure the subrecipient
    organization is achieving its goals.

Given this prior knowledge, you can better balance your future
monitoring and technical assistance responsibilities with the
administrative resources that you have available. When the pre-award
evaluation process is complete, you will know exactly which
organizations need what kind of monitoring support.

Even when the selection of a particular subrecipient appears to be
inherently "political" and pre-determined, it is helpful to identify the
particular areas where you are likely to have problems. For existing
subrecipients, pre-award screening closes the previous year\'s
monitoring loop.

####  

**FACTORS IN A**

**PRE-AWARD ASSESSMENT**

Factors used to determine selection of subrecipients should be based on
both the quality of the project and the capacity of the subrecipient to
carry it out. For example, in judging whether to use a specific
organization as a subrecipient, you should examine:

-   the nature of the activity or activities;

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-   whether the proposed plan for carrying out the activity is
    realistic;

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-   the organization\'s capacity to do the work and do it in a timely
    manner; and

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-   the possibility of any potential conflicts of interest.

**Are the activities eligible for funding?**

It is surprising how many grantees continue to fund activities without
determining their eligibility for funding under CDBG guidelines\
(§570.201-207 of the CDBG regulations). **One of your first steps should
be to verify the eligibility of proposed activities.** Certain
activities are excluded automatically. For example, "partisan political
activities" such as voter transportation or candidate forums, no matter
how impartially structured, are [never]{.underline} eligible activities
under CDBG rules. On the other hand, housing construction can be an
eligible activity, but [only]{.underline} under certain circumstances.
CDBG funds generally cannot be used for assistance relative to
"buildings or portions thereof used for the general conduct of
government." However, this prohibition does not apply to the removal of
architectural barriers (see §570.207(a)(1)), or where social services
operate out of such a building. It is very important, therefore, to
check the eligibility of each proposed activity. Sometimes a small
change is all that is required to assure the proposed project conforms
to the CDBG regulations.

**Does the activity meet a National Objective?**

  -----------------------------------------------------------------------
  ***Make sure your subrecipients are aware of the National Objective
  their activity is expected to meet as well as the records to be
  maintained to document compliance*.**

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

You should also evaluate **how the proposed activity addresses the
National Objective of providing benefit to low- and moderate-income
persons, preventing or eliminating slums or blight, or meeting other
urgent community development needs.** For each activity there must be a
logical, documented connection to a National Objective. As noted in the
Appendix to Chapter 1, the standards for meeting and documenting
compliance with a National Objective can vary depending on the
particular activity undertaken. Be particularly careful in assessing
housing and economic development activities.

You should also assess the consistency of the proposed activity with the
community\'s Consolidated Plan and with your CDBG program priorities.

**Is the design of the proposed activity appropriate?**

You should evaluate the adequacy of the proposed program design or
service delivery approach.

-   Does the activity adequately address an established need?

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-   Has the prospective subrecipient identified all the major tasks that
    will be involved in carrying out the activity?

-   Does the organization understand the interrelationship of these
    tasks, and has it developed a realistic schedule for their
    accomplishment? Are there any stumbling blocks to prompt
    implementation?

-   Has the organization made a careful estimate of the resources
    necessary for each component of its proposed program, and has it put
    together a realistic budget that reflects these resources? Are other
    sources of funds, when indicated, committed to this project?

-   Is the budget for the CDBG funded activity separate from other
    activities undertaken by the subrecipient?

**Does the organization have the capacity to complete the**

**activity as proposed?**

  -----------------------------------------------------------------------
  ***See the Application Rating System and the Risk Analysis Matrix in
  the Appendix to this chapter for a sample of techniques you can use to
  select subrecipients for funding.***

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

Finally, you should assess the prospective subrecipient\'s **overall
organizational capacity.**

-   Has the organization ever undertaken the proposed activity before,
    and what was the result?

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-   Does the organization have experience with the Community Development
    Block Grant or other Federal programs?

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-   Do the prospective subrecipient\'s staff appreciate the additional
    requirements associated with Federal funding (for example, when
    staff split their time between CDBG and non-CDBG functions, keeping
    detailed records of time spent on specific activities)?

-   Is the organization familiar with the specific regulatory
    requirements associated with the proposed activity (such as
    Davis-Bacon prevailing wage requirements for new construction or
    rehabilitation projects involving eight units or more)?

-   What is the organization\'s "track record" regarding compliance with
    such requirements?

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-   Does the prospective subrecipient have adequate administrative and
    fiscal structures in place to deal with these guidelines
    (particularly record keeping)?

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-   If not, does it recognize its organizational weaknesses, and has it
    developed a plan for upgrading these aspects of its operations?

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-   Does the organization have qualified staff for all the necessary
    functions associated with the proposed activity, and is there
    adequate staff time available?

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-   If not, how does the organization plan to fill these gaps in
    personnel?

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  ***See Appendix 2 for a sample application package.***

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

The Appendix to this chapter provides a sample subrecipient application
for CDBG funding that was developed with the assistance of Oakland,
California. Part A, Abstract of an Application, lists the basic elements
that should be included in the application and/or as supplemental
information requested by the grantee after it has been determined that
the subrecipient has submitted a priority proposal and has the capacity
to carry it out. The sample application can be modified to fit a variety
of the following approaches to selecting subrecipients.

####  

#### MODELS FOR PERFORMING PRE-AWARD ASSESSMENTS AND SELECTING SUB-RECIPIENTS 

You can use a variety of approaches to selecting subrecipients:

-   **Model 1: formal application or request-for-application (RFA)
    process;**

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-   **Model 2 simplified or limited application, with grantee
    follow-up;**

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-   **Model 3: grantee survey of qualified organizations, with direct
    solicitation;**

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-   **Model 4: response to unsolicited applications; or,**

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-   **Model 5: review of existing subrecipients\' performance, before
    renewing their participation.**

**Model 1: A Formal Application or RFA Process**

Under this model, the prospective subrecipient is required to submit a
formal application to the grantee, generally as part of the grantee\'s
planning process for developing its subsequent year\'s CDBG Action Plan.
In the application, the prospective subrecipient describes its proposed
activity(ies), implementation schedule, budget, and staffing structure,
as well as its related past experience and how the organization intends
to assure compliance with the program regulations that apply to the
proposed activity(ies). The grantee then evaluates each application
according to explicit selection criteria, its CDBG program priorities
and (if the proposed activity is housing-related), the local priorities
as expressed in the Consolidated Plan.

Among the models discussed here, this one most closely resembles the
competitive procurement process used in selecting contractors, although
with subrecipients there is likely to be a variety of activities
proposed, and "lowest price" will not necessarily be a factor in
deciding which organization to select. The formal application process is
recommended when:

(1) activities are numerous and/or complex,

(2) there are many potential applicants with varying degrees of
    expertise and capacity,

(3) the cost and level of risk of program failure are high, thereby
    requiring greater care and more time, and/or

(4) there are limited funds and many competing needs and/or approaches
    for addressing these needs.

**Pros and Cons of a Formal Application or RFA Process**

**Pros:** This approach ***places the full responsibility with the
applicant*** to prepare a thorough, written description of its
expertise, capacity, and program design. This approach also allows you
to compare applicants on a broad range of selection criteria, since each
must submit similar applications. The Request-For-Application format
should provide prospective subrecipients with an overview of the
regulatory issues they must address. Their responses will reveal their
awareness of and capacity to deal with these program requirements. At
the same time, the formality of the process helps to assure the
consistency of the evaluation process. (It should be noted, however,
that the applicant\'s responsibility to describe its capacity and
program design does **not** relieve the grantee of its ultimate
responsibility for ensuring compliance with all applicable
requirements.)

**Cons:** The approach in Model 1 rewards experienced subrecipients or
organizations that can write strong applications (or hire consultants to
write them). Although they may be aware of the weighting criteria used
in evaluating applications, these agencies may not be organizations that
can run good programs. Because the Model 1 approach may require
considerable effort to prepare the application, less experienced
applicants or those with smaller staffs may not apply, thereby depriving
you of well-qualified applicants. In addition, your time involved in
assessing and scoring applications (and reviewing the scores with
unsuccessful applicants) can be substantial. This approach may allow you
to bring in new subrecipients only once a year.

**Model 2: Simplified Application, with Grantee Follow-up**

This model, a toned-down version of Model 1, requires applicants to
provide a more general description of their proposed activity(ies),
organizational experience, and capacity to do the work. Applicants need
not produce detailed written explanations of how they will address the
regulatory requirements of the CDBG program. However, they are required
to demonstrate their organization\'s ability to meet those selection
criteria that you choose to specify. (For example, for a new job
training program you might want to specify how many training slots are
to be filled, what disciplines are to be taught, and what the budgeted
cost is for each trainee over what period of time.)

The grantee reviews prospective agencies' general descriptions to narrow
the number of applications under consideration. The grantee then
requests the most promising organizations to provide more detailed
information regarding their capacity or to answer questions about their
program design.

Model 2 may be useful when there are several inexperienced providers
with limited ability to respond to a formal RFA, the level of program
complexity (and therefore, risk of failure) is moderate or low, and/or
the grantee wants to maintain the largest possible pool of qualified
applicants.

**Pros and Cons of a Simplified Application with Grantee Follow-up**

**Pros:** This approach makes it easier for new or inexperienced
organizations to prepare an application and participate in the
application process, at least through the first round "cut". The open
process tends to encourage a wider group of prospective subrecipients to
apply for consideration by the grantee.

**Cons:** This approach shifts much of the burden for developing a
complete picture of the prospective subrecipients' qualifications from
the applicant to the grantee. Grantees have to devote more time for
pulling this information together. In addition, because the award
criteria used at each stage may be less clear than in Model 1, grantees
may be subject to more criticism or challenge over how they made their
selections.

**Model 3: Grantee Survey of Qualified Organizations, with Direct
Solicitation**

In this approach, the grantee first identifies a ***pool of qualified
organizations.*** This can be done informally, through discussions with
knowledgeable community sources or through the internal information that
the Community Development office has acquired over the years.
Alternatively, the grantee can periodically issue a general request for
qualifications (RFQ) to local organizations in order to maintain
up-to-date information about qualified subrecipients.

From this pool, the grantee can then identify the qualified
organizations to carry out a desired CDBG activity and approach them
directly to determine their interest and suitability for the work. (This
latter step is crucial to avoid the problems described in the vignette
at the beginning of this chapter.) Assuming that this process confirms
an organization's capacity, the grantee has the option either to solicit
an application from the organization for the work to be undertaken or to
move directly to negotiate a written Agreement. (See Chapter 3.)

**Pros and Cons of a Grantee Survey, with Direct Solicitation**

**Pros:** With this approach the grantee can take a more proactive
approach in deciding which is the "best" subrecipient to meet its needs.
Because this approach tends to be more focused and entails deliberations
involving fewer organizations, it can also be less time-consuming for
agency staff.

**Cons:** One of the "pluses" of this approach, that it may be a less
public process, can also be a significant disadvantage.

That is, it is vulnerable to criticism about favoritism on the part of
the grantee, and as a less open process, may be subject to more
political pressure. By focusing on fewer organizations, the grantee also
may unintentionally be overlooking or excluding qualified agencies that
it would like to get involved in its local CDBG effort. Finally, any
tendency on the part of the grantee to be less rigorous in evaluating
the capacity of the organization(s) it approaches can result in
performance problems later on.

**Model 4: Unsolicited Applications**

It is quite likely that prospective sponsors of community development
activities (both public and private) will contact you directly to
request funding for a special project. The activities involved may or
may not conform to your funding plans, and it is your responsibility to
determine the merit and feasibility of the application. Certainly, this
determination includes an assessment of whether the project meets a
National Objective and whether the proposed activity or activities are
eligible under the CDBG regulations.

If your preliminary review determines that the application has merit and
that there is funding available, this model becomes the same as Model 2
or 3. Regardless of the size or complexity of the proposal, you should
require the sponsoring organization to submit a formal application much
like those suggested in Model 2 or 3. This will assure that all
prospective subrecipients are treated the same way, and more
importantly, that you have the same opportunity to review crucial
information about the capacity, experience and reliability of the
prospective sponsor as in other evaluation formats.

**Pros and Cons of**

**Unsolicited Applications**

**Pros:** The advantages of Model 4 are similar to those of Models 2 and
3. However, there are two additional benefits. First, the unsolicited
nature of the application suggests that the applicant is already
motivated and in some way committed to undertaking the work and is not
simply responding to your request. Second, unsolicited applications can
reveal opportunities to address community needs that your agency may
have overlooked or permit a more timely response to emerging needs.

**Cons:** You never know when you might receive an unsolicited
application and whether there are political considerations attached to
it. Following up the application may take time away from other matters.
If politics are involved, your protection is knowing that you and your
agency will observe the same process and criteria in responding to all
applications. Another problem with unsolicited applications is that many
times they are not received at an appropriate time in the funding cycle.
The best applications may be received after the funds have been
committed.

**Model 5: Reviewing the Performance of Current Subrecipients**

Even if you, the grantee, are not seeking to identify new subrecipients
for your programs, and intend to retain your current group of
subrecipients, a pre-award assessment is still appropriate. Some of your
current subrecipients may be marginal performers that need the
accountability and feedback of such a review to motivate them to
improve. Other subrecipients may be well-intentioned and generally
well-run but unaware of specific weaknesses in their operations. Still
others may be exemplary performers that deserve to have their
achievements recognized. Even if the assessment itself is not sufficient
to motivate subrecipients to deal immediately with problems in their
daily operations, it can be used to develop special language for the
written Subrecipient Agreement governing future funding. The assessment
could, for example, require corrective action as a condition for
continued participation in the CDBG program.

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  ***For current subrecipients, the pre-award review should be a part of
  the annual monitoring process.***

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***The pre-award assessment for extending current subrecipient
agreements should be incorporated into your normal monitoring
process.*** To save time and effort, it makes sense to schedule your
monitoring reviews to coincide with decisions about renewing
subrecipients for another program year. Chapter Five of this Guidebook
discusses detailed monitoring procedures.

####  

#### A MIXTURE OF APPROACHES 

You may want to use different approaches with different activities and
organizations, depending on the number of "new" versus "experienced"
subrecipients that you want to consider, the amount of information that
you have available on different organizations, or the demand by local
organizations for CDBG resources.

**Making Your Selection**

**Criteria Explicit**

Regardless of the selection approach used, you are encouraged to **make
your selection criteria explicit and,** as much as possible, **tie these
criteria directly to the CDBG program requirements.** In addition, it
would be appropriate to identify all of the applicable rules, including
environmental reviews, anti-discrimination, and accessibility standards
as part of the Request for Applications. This will serve several
purposes, among them:

-   By presenting the criteria explicitly at the beginning of the
    process, you can reduce the number of questions that may arise over
    the objectivity and fairness of your assessments; and

-   By tying the criteria to Federal program requirements, you can begin
    to educate prospective subrecipients and the community at large
    about the regulatory constraints that limit how you operate the
    local CDBG program.

Finally, if local elected officials who are not part of the agency
responsible for the CDBG program gain a better appreciation of the
Federally imposed regulatory constraints under which the local CDBG
program must function, the political pressure they may exert to select a
particular organization or to assist a particular constituency can be
reduced.

#### DEALING WITH A SCARCITY OF  {#dealing-with-a-scarcity-of .unnumbered}

**QUALIFIED ORGANIZATIONS**

You may want to add new activities to your CDBG program, but find that
there are not enough local organizations with the necessary experience
and administrative systems to function effectively as subrecipients. In
such cases, you can:

-   **carry out the desired CDBG activities yourself;**

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-   **find or develop organizations with the necessary capacity; or**

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-   **not undertake the new activities.**

If the proposed activity is critical for revitalizing a targeted
neighborhood or meeting the needs of a particular population, then
deferring action may not be an option. In addition, if your
administrative capacity is already stretched thin, it may be very
difficult for you to take on new activities yourself.

**Expanding the Pool**

**of Subrecipients**

You may find, therefore, that in order to increase the diversity and
effectiveness of your CDBG effort, your only reasonable course of action
is to create and nurture greater subrecipient capacity. While there will
be an initial cost to this capacity-building effort, you may be able to
view it as an investment with a future return.

If you decide to support one or more start-up organizations as new
subrecipients, you will probably encounter two issues unique to new
organizations: incorporation and start-up financing. Although CDBG funds
can be used for capacity building, in most cases funding for start-up
costs may have to be secured from other sources such as foundations,
other non-profit agencies, or corporations that support local community
development efforts. Most law firms, for example, can provide assistance
with incorporation either for a modest fee or on a *pro* *bono* basis.

Once you have selected an organization to participate in the CDBG
program for a particular program year, you must execute a written
agreement with the designated subrecipient. Drafting useful Subrecipient
Agreements is the subject of Chapter 3.

**NOTES:**

**CHAPTER 2: APPENDIX**

-   Sample Subrecipient Application Package 2-14

-   Basic Elements of a Subrecipient Application for Funding and

> Applicable Federal Regulations 2-23

-   Subrecipient Selection Checklist 2-24

-   Application Rating System 2-25

-   Risk Analysis Matrix 2-27

**SAMPLE SUBRECIPIENT APPLICATION PACKAGE**

Among other features, application packages provided to prospective
subrecipients for use in proposing activities for CDBG funding should
have the following characteristics:

1)  Provide a clear explanation of the CDBG program, so that
    subrecipients understand what they are applying for and what their
    responsibilities will be;

2)  Indicate the grantee's funding priorities;

3)  Be detailed enough to capture all important information regarding
    eligibility, compliance with National Objectives requirements, and
    the schedule for project implementation;

4)  Not be so elaborate or forbidding that subrecipients are discouraged
    from applying; and

5)  Provide enough information about the subrecipient organization to
    permit grantees to make reasonable judgments about the
    subrecipient's qualifications to carry out the proposed activity.

The sample application materials on the following pages provide a good
example of the important features listed above. City Agencies generally
submit a more abbreviated list of documents.

**Previously Funded Subrecipients:** Most grantees that review
applications received from previously funded subrecipients make
allowances for information they already have about the subrecipient in
order to make the application procedure less burdensome. One suggestion
is to include a question in your application that addresses
subrecipients with prior CDBG experience, such as, "Has anything changed
on this item? If so, explain how and why." Alternatively, you might
include a statement indicating which items need not be resubmitted, such
as:

> *"Private agencies that have applied in the past three years or are
> currently funded by the Office of Community Development do not need to
> submit Articles of Incorporation, tax exemption letters, an
> organization chart, and resumes of the program administrator and
> fiscal officer if they are on file in this office and they have not
> been changed since initially submitted."*

**SAMPLE SUBRECIPIENT APPLICATION**

**(Developed with Assistance from the City of Oakland, CA)**

**[Abstract of an Application]{.underline}** (It is recommended that
total narrative be limited to no more than

five pages.)

The application package should include a discussion of eligible and
ineligible activities and National Objectives, such as found in the
Appendix to Chapter 1, followed by the required data to be submitted by
the prospective subrecipient for funding consideration. The application
package should address the following items:

1\. Summary of Eligible and Ineligible Activities (with references to
relevant section of regulations)

---Basic Eligible Activities

---Eligible Rehabilitation and Preservation Activities

---Special Economic Development Activities

---Special Activities by CBDOs

---Eligible Planning, Urban Environmental Design, Policy-Planning, and
Management-

Capacity Building Activities

---Eligible Administrative Costs

---Ineligible Activities

2\. Data Required to be Submitted

(a) Project Summary (Narrative)

> ---Need/Problem to be addressed (consistent with priorities
> established in
>
> Consolidated Plan
>
> ---Population/Area served (including estimated numbers of clients and
> other measurable outputs)
>
> ---Description of work (including who will carry it out and how
> eligibility and National Objective requirements will be met)
>
> ---Proposed Schedule of Work
>
> \(b\) Detailed Budget Information including all funding sources

\(c\) Agency Information

> ---Background/Program Experience
>
> ---Personnel/Staff Capacity
>
> ---Financial Capacity
>
> ---Monitoring
>
> ---Audit Requirements
>
> ---Insurance/Bonding/Worker's Compensation
>
> ---Any other additional information
>
> \(d\) Standard Required Documents/Forms
>
> ---Articles of Incorporation/Bylaws
>
> ---Certificate of Good Standing with the State
>
> ---State and Federal Tax Exemption Determination Letters
>
> ---List of Board Members
>
> ---Authorization to Request Funds
>
> ---Designation of Authorized Official(s)
>
> ---Organizational Chart
>
> ---Resumes of Program Administrator and Fiscal Officer
>
> ---Annual Financial Statements and Audit
>
> ---Conflict of Interest Questionnaire (followed by a discussion of the
> conflict of interest provisions)
>
> ---Documentation of Compliance with National Objectives

**RECOMMENDED APPLICATION DATA**

> **[Project Summary]{.underline}**
>
> Briefly describe the proposed project. The narrative should include
> the need or problem to be addressed in relation to the Consolidated
> Plan or other community development priorities, as well as the
> population to be served or the area to benefit. Describe the work to
> be performed, including the activities to be undertaken or the
> services to be provided, the goals and objectives, method of approach,
> and the implementation schedule.
>
> In your project summary, further:

-   Indicate how you will identify clients. Provide an estimate as the
    number of clients to be served and describe them in terms of age,
    gender, ethnicity, income level, and other defining characteristics.

-   Be very specific about who will carry out the activities, the
    location in which they will be carried out, the period over which
    the activities will be carried out, and the frequency with which the
    activities will be carried out, and the frequency with which
    services will be delivered.

-   For service programs, include how you propose to coordinate your
    services with other community agencies and leverage resources.

-   Describe the site where the program will be implemented. How will
    clients get to the facility? What efforts will your agency and
    partners make to promote your program and reach isolated
    individuals? Describe how the facility complies with Americans with
    Disabilities Act (ADA) requirements regarding accessibility.

**[Project Budget]{.underline}**

> Discuss all funding sources, proposed and confirmed. Complete the line
> item budget, Attachment A or B, as appropriate. All applicants must
> complete Attachment C.
>
> **[Agency Information]{.underline}**
>
> [Background/Program Experience]{.underline}
>
> Include the length of time the agency has been in operation, the date
> of incorporation, the purpose of the agency, and the type of
> corporation. Describe the type of services provided, the agency's
> capabilities, the number and characteristics of clients served, and
> license to operate (if appropriate).
>
> [Personnel/Staff Capacity]{.underline}
>
> Briefly describe the agency's existing staff positions and
> qualifications, its capacity to carry out this activity, and state
> whether the agency has a personnel policy manual with an affirmative
> action plan and grievance procedure.
>
> [Financial Capacity]{.underline}
>
> Describe the agency's current operating budget, itemizing revenues and
> expenses. Identify commitments for ongoing funding. Describe the
> agency's fiscal management, including financial reporting, record
> keeping, accounting systems, payment procedures, and audit
> requirements.
>
> [Monitoring]{.underline}
>
> Briefly describe how you will monitor progress in implementating the
> program. Attach copies of all data collection tools that will be used
> to verify achievement of program goals and objectives. Describe who
> will be responsible for monitoring progress.
>
> [Audit Requirements]{.underline}
>
> In accordance with the Office of Management and Budget Circular A-133,
> the Federal Government requires that organizations expending \$300,000
> or more in Federal financial assistance in a fiscal year must secure
> an audit. Agencies requesting \$300,000 or more must choose one of the
> three ways of meeting this requirement and state which method they
> chose:

1)  If your agency already conducts audits of all its funding sources
    including CDBG, the agency must submit a copy of its most recent
    audit, and may, at its discretion, include the CDBG portion of the
    audit cost in its CDBG project budget.

2)  If your agency already conducts audits of its other funding sources
    but has neither received nor included CDBG in the past, the scope of
    the audit would be modified to incorporate CDBG audit requirements.
    The associated cost of the augmentation could then be included in
    the CDBG project budget, accompanied by the auditor's written cost
    estimate.

3)  If your agency does not have a current audit process in place, your
    agency will be required to include a 10-percent set aside in the
    CDBG project for the provision of an audit.

### Insurance/Bonding/Worker's Compensation

> State whether or not the agency has liability insurance coverage, in
> what amount, and with what insuring agency. State whether or not the
> agency pays all payroll taxes and worker's compensation as required by
> Federal and state laws. State whether or not the agency has fidelity
> bond coverage for principal staff who handle the agency's accounts, in
> what amount, and with what insuring agency.

### Additional Information

> Include any other pertinent information.

####  

#### [Standard Required Documents]{.underline}

[Articles of Incorporation/Bylaws]{.underline}

Articles of incorporation are the documents recognized by the State as
formally establishing a private corporation, business or agency.

[Non-profit Determination]{.underline}

> Non-profit organizations must submit tax-exemption determination
> letters from the Federal Internal Revenue Service and the State
> Franchise Tax Board.
>
> [List of the Board of Directors]{.underline}
>
> A list of the current board of directors or other governing body of
> the agency must be submitted. The list must include the name,
> telephone number, address, occupation or affiliation of each member
> and must identify the principal officers of the governing body.

### Authorization to Request Funds

> Documentation must be submitted of the governing body's authorization
> to submit the funding request. Documentation of this requirement
> consists of a copy of the minutes of the meeting in which the
> governing body's resolution, motion or other official action is
> recorded.

### Designation of Authorized Official

> Documentation must be submitted of the governing body's action
> authorizing the representative of the agency to negotiate for and
> contractually bind the agency. Documentation of this requirement
> consists of a signed letter from the Chairperson of the governing body
> providing the name, title, address and telephone number of each
> authorized individual.
>
> [Organizational Chart]{.underline}
>
> An organizational chart must be provided that describes the agency's
> administrative framework and staff positions, indicates where the
> proposed project will fit into the organizational structure, and
> identifies any staff positions of shared responsibility.

[Resume of the Chief Program Administrator]{.underline}

[Resume of the Chief Fiscal Officer]{.underline}

[Financial Statement and Audit]{.underline}

[Conflict of Interest Questionnaire]{.underline}

[Documentation of Compliance with National Objectives]{.underline}

####  Subrecipient Project Title Project \# {#subrecipient-project-title-project .unnumbered}

######## ATTACHMENT A: Line Item Budget Form -- Service Projects  {#attachment-a-line-item-budget-form-service-projects .unnumbered}

**Guidance: Please use the following format to present your proposed
line item budget. In column A, list the items for which you anticipate
the need for CDBG funds. In Column B, provide the calculation explaining
how you arrived at the estimated cost of the line item. In Column C,
provide the projected request for CDBG funds. On Attachment C, provide
description of other funds and volunteer and donated services/resources
to be used in the project.**

+-----------------------+-------------------------------+-------------+
| **A**                 | ######## B {#b .unnumbered}   | **C**       |
+-----------------------+-------------------------------+-------------+
| **Budget Item**       | **Calculation**               | **CDBG      |
|                       |                               | Request**   |
+-----------------------+-------------------------------+-------------+
| ## PERSONNEL {#p      |                               |             |
| ersonnel .unnumbered} |                               |             |
+-----------------------+-------------------------------+-------------+
| ## Salaried Posit     | Provide rate of pay           |             |
| ions -- Job Titles {# | (hourly/salary) and           |             |
| salaried-positions-jo | percentage of time spent on   |             |
| b-titles .unnumbered} | project (Full-Time            |             |
|                       | Equivalent) or hours per week |             |
+-----------------------+-------------------------------+-------------+
|                       |                               |             |
+-----------------------+-------------------------------+-------------+
|                       |                               |             |
+-----------------------+-------------------------------+-------------+
|                       |                               |             |
+-----------------------+-------------------------------+-------------+
|                       |                               |             |
+-----------------------+-------------------------------+-------------+
|                       |                               |             |
+-----------------------+-------------------------------+-------------+
|                       |                               |             |
+-----------------------+-------------------------------+-------------+
|                       |                               |             |
+-----------------------+-------------------------------+-------------+
| ## Sal                |                               |             |
| aries Total  {#salari |                               |             |
| es-total .unnumbered} |                               |             |
+-----------------------+-------------------------------+-------------+
| **Fringe Benefits**   |                               |             |
+-----------------------+-------------------------------+-------------+
| **PERSONNEL TOTAL**   | Total of Personnel & Fringe   |             |
|                       | Benefits                      |             |
+-----------------------+-------------------------------+-------------+
| **OPERATING COSTS**   | Provide description of how    |             |
|                       | you arrive at total for each  |             |
|                       | line item                     |             |
+-----------------------+-------------------------------+-------------+
| ## Supplies  {#       |                               |             |
| supplies .unnumbered} |                               |             |
+-----------------------+-------------------------------+-------------+
| **Equipment**         |                               |             |
+-----------------------+-------------------------------+-------------+
| **Rent/Lease**        |                               |             |
+-----------------------+-------------------------------+-------------+
| **Insurance**         |                               |             |
+-----------------------+-------------------------------+-------------+
| **Printing**          |                               |             |
+-----------------------+-------------------------------+-------------+
| **Telephone**         |                               |             |
+-----------------------+-------------------------------+-------------+
| **Travel**            |                               |             |
+-----------------------+-------------------------------+-------------+
| **Other**             |                               |             |
+-----------------------+-------------------------------+-------------+
| **TOTAL OPERATING**   |                               |             |
+-----------------------+-------------------------------+-------------+
| **CONTRACT SERVICES** |                               |             |
+-----------------------+-------------------------------+-------------+
|                       |                               |             |
+-----------------------+-------------------------------+-------------+
|                       |                               |             |
+-----------------------+-------------------------------+-------------+
|                       |                               |             |
+-----------------------+-------------------------------+-------------+
|                       |                               |             |
+-----------------------+-------------------------------+-------------+
| **TOTAL CONTRACT      |                               |             |
| SERVICES**            |                               |             |
+-----------------------+-------------------------------+-------------+
|                       |                               |             |
+-----------------------+-------------------------------+-------------+
| **BUDGET TOTAL**      |                               |             |
+-----------------------+-------------------------------+-------------+

####  {#section-4 .unnumbered}

####  Subrecipient Project Title Project \# {#subrecipient-project-title-project-1 .unnumbered}

########  {#section-5 .unnumbered}

######## ATTACHMENT B: Line Item Budget Form -- Construction/Acquisition Projects  {#attachment-b-line-item-budget-form-constructionacquisition-projects .unnumbered}

+---------------------+---------------------------------+-------------+
| **A**               | ######## B {#b-1 .unnumbered}   | **C**       |
+---------------------+---------------------------------+-------------+
| **Budget Item**     | **Calculation**                 | **CDBG      |
|                     |                                 | Request**   |
+---------------------+---------------------------------+-------------+
| #                   |                                 |             |
| # PERSONNEL {#perso |                                 |             |
| nnel-1 .unnumbered} |                                 |             |
+---------------------+---------------------------------+-------------+
| ## Sal              | Provide rate of pay             |             |
| aried Positions --  | (hourly/salary) and percentage  |             |
| Job Titles {#salari | of time spent on project        |             |
| ed-positions-job-ti | (Full-Time Equivalent) or hours |             |
| tles-1 .unnumbered} | per week                        |             |
+---------------------+---------------------------------+-------------+
|                     |                                 |             |
+---------------------+---------------------------------+-------------+
|                     |                                 |             |
+---------------------+---------------------------------+-------------+
|                     |                                 |             |
+---------------------+---------------------------------+-------------+
| ## Salaries         |                                 |             |
| Total  {#salaries-t |                                 |             |
| otal-1 .unnumbered} |                                 |             |
+---------------------+---------------------------------+-------------+
| **Fringe Benefits** |                                 |             |
+---------------------+---------------------------------+-------------+
| **PERSONNEL TOTAL** | Total of Personnel & Fringe     |             |
|                     | Benefits                        |             |
+---------------------+---------------------------------+-------------+
| **DELIVERY COSTS**  | Provide description of how you  |             |
|                     | arrive at total for each line   |             |
|                     | item                            |             |
+---------------------+---------------------------------+-------------+
| ## A                |                                 |             |
| cquisition  {#acqui |                                 |             |
| sition .unnumbered} |                                 |             |
+---------------------+---------------------------------+-------------+
| **Development**     |                                 |             |
+---------------------+---------------------------------+-------------+
| **Rehab Hard        |                                 |             |
| Costs**             |                                 |             |
+---------------------+---------------------------------+-------------+
| **Physical          |                                 |             |
| Inspections**       |                                 |             |
+---------------------+---------------------------------+-------------+
| **Architectural     |                                 |             |
| Engineering**       |                                 |             |
+---------------------+---------------------------------+-------------+
| **Rehab Loan        |                                 |             |
| Costs**             |                                 |             |
+---------------------+---------------------------------+-------------+
| **Permits and       |                                 |             |
| Fees**              |                                 |             |
+---------------------+---------------------------------+-------------+
| **Insurance**       |                                 |             |
+---------------------+---------------------------------+-------------+
| **Legal Fees**      |                                 |             |
+---------------------+---------------------------------+-------------+
| **Financing**       |                                 |             |
+---------------------+---------------------------------+-------------+
| **Appraisal Costs** |                                 |             |
+---------------------+---------------------------------+-------------+
| **Other**           |                                 |             |
+---------------------+---------------------------------+-------------+
| **TOTAL OPERATING** |                                 |             |
+---------------------+---------------------------------+-------------+
| **CONTRACT          |                                 |             |
| SERVICES**          |                                 |             |
+---------------------+---------------------------------+-------------+
|                     |                                 |             |
+---------------------+---------------------------------+-------------+
|                     |                                 |             |
+---------------------+---------------------------------+-------------+
|                     |                                 |             |
+---------------------+---------------------------------+-------------+
| **TOTAL CONTRACT    |                                 |             |
| SERVICES**          |                                 |             |
+---------------------+---------------------------------+-------------+
|                     |                                 |             |
+---------------------+---------------------------------+-------------+
| **BUDGET TOTAL**    |                                 |             |
+---------------------+---------------------------------+-------------+

**Guidance**: Please use the following format to present your proposed
line item budget. In column A, list the items for which you anticipate
the need for CDBG funds. In Column B, provide the calculation explaining
how you arrived at the estimated cost of the line item. In Column C,
provide the projected request for CDBG funds. On Attachment C, provide a
description of other funds and volunteer and donated services/resources
to be used in the project.

#### ATTACHMENT C: Supplemental Budget Form -- Use of Other Resources {#attachment-c-supplemental-budget-form-use-of-other-resources .unnumbered}

I.  Describe your plans to use other funds on this project. In this
    section only describe funds that are secured. Provide the source of
    funds, amounts and how these funds will be used.

II. Describe your plans to seek new funding to supplement CDBG funding.
    Describe the sources to which you will apply, the amounts sought and
    the proposed use of those funds.

III. Describe your use of donated goods and services. Estimate the value
     of these services and describe how you arrive at these amounts.

IV. Please provide an explanation for any unusual budget expenditures
    listed in the line item budget on the previous page.

V.  Explain why you consider your program costs to be reasonable.

#### Basic Elements of a Subrecipient Application for Funding

#### and Applicable Federal Regulations

+---+-------------------+------------------------+----------------------+
|  | **Data**          | **Description**        | **Some Key           |
|   |                   |                        | Applicable           |
|   |                   |                        | Regulations**        |
+===+===================+========================+======================+
|   | 1\. Project       | A brief project        | 24 CFR 570.200(a),   |
|   | Summary           | description including: | 570.201−570. 208,    |
|   |                   |                        | 507.503              |
|   |                   | -   Need or problem    |                      |
|   |                   |                        |                      |
|   |                   | -   Population to be   |                      |
|   |                   |     served             |                      |
|   |                   |                        |                      |
|   |                   | -   Geographic service |                      |
|   |                   |     area               |                      |
|   |                   |                        |                      |
|   |                   | -   Description of     |                      |
|   |                   |     work and how it    |                      |
|   |                   |     addresses the      |                      |
|   |                   |     problem            |                      |
|   |                   |                        |                      |
|   |                   | -   Schedule for       |                      |
|   |                   |     completion         |                      |
|   |                   |                        |                      |
|   |                   | -   Proposed           |                      |
|   |                   |     accomplishments    |                      |
|   |                   |                        |                      |
|   |                   | -                      |                      |
|   |                   |   Eligibility/National |                      |
|   |                   |     Objective          |                      |
|   |                   |                        |                      |
|   |                   | -   Proposed budget    |                      |
|   |                   |                        |                      |
|   |                   | -   Intended staffing  |                      |
|   |                   |                        |                      |
|   |                   | -   Other sources of   |                      |
|   |                   |     funding            |                      |
+---+-------------------+------------------------+----------------------+
|   | 2\. Agency        | -   Years in operation | 24 CFR 570.506,      |
|   | Background        |                        | 570.507, 570.610; 24 |
|   |                   | ```{=html}             | CFR Parts 84 or 85   |
|   |                   | <!-- -->               |                      |
|   |                   | ```                    |                      |
|   |                   | -   Purpose            |                      |
|   |                   |                        |                      |
|   |                   | -   Type of services   |                      |
|   |                   |     provided           |                      |
|   |                   |                        |                      |
|   |                   | -   Agency's           |                      |
|   |                   |     capabilities       |                      |
|   |                   |                        |                      |
|   |                   | -   Experience with    |                      |
|   |                   |     Federal Programs   |                      |
|   |                   |                        |                      |
|   |                   | -                      |                      |
|   |                   | Number/characteristics |                      |
|   |                   |     of clients served  |                      |
|   |                   |                        |                      |
|   |                   | -   License to operate |                      |
+---+-------------------+------------------------+----------------------+
|   | 3\. Personnel     | Describe:              | 24 CFR 570.506,      |
|   |                   |                        | 570.507, 570.601,    |
|   |                   | -   Staff positions    | 570.602, 570.607(b), |
|   |                   |     and qualifications | 570.611              |
|   |                   |                        |                      |
|   |                   | -   Policy/procedures  |                      |
|   |                   |     manual             |                      |
+---+-------------------+------------------------+----------------------+
|   | 4\. Financial     | Describe:              | 24 CFR               |
|   |                   |                        | 570.502−570.504,     |
|   |                   | -   Operating budget   | 570.506, 570.507,    |
|   |                   |                        | 570.610; 24 CFR      |
|   |                   | -   Commitments for    | Parts 84 or 85, and  |
|   |                   |     ongoing funding    | OMB Circulars A-87   |
|   |                   |                        | or A-122; Treasury   |
|   |                   | -   Fiscal management  | Circular 1075        |
|   |                   |     (reporting,        |                      |
|   |                   |     records,           |                      |
|   |                   |     accounting         |                      |
|   |                   |     principles)        |                      |
+---+-------------------+------------------------+----------------------+
|   | 5\. Audit         | Organizations          | OMB Circular A-133   |
|   | Requirements      | receiving \$300,000 or |                      |
|   |                   | more in Federal        |                      |
|   |                   | financial assistance   |                      |
|   |                   | in a fiscal year must  |                      |
|   |                   | secure an audit.       |                      |
+---+-------------------+------------------------+----------------------+
|   | 6\.               | Indicate if agency:    | 24 CFR Parts 84 or   |
|   | Insurance         |                        | 85                   |
|   | /Bonding/Worker's | -   Has liability      |                      |
|   |                   |     insurance          |                      |
|   | > Compensations   |                        |                      |
|   |                   | -   Pays payroll taxes |                      |
|   |                   |     and worker's       |                      |
|   |                   |     compensation       |                      |
|   |                   |                        |                      |
|   |                   | -   Has fidelity bond  |                      |
|   |                   |     coverage           |                      |
+---+-------------------+------------------------+----------------------+
|   | 7\. Additional    | Any other pertinent    |                      |
|   | Information       | information            |                      |
+---+-------------------+------------------------+----------------------+
|   | 8\. Standard      | -   Articles of        | 24 CFR 570.208,      |
|   | Documents for     |                        | 570.500(c), 570.611  |
|   |                   |   Incorporation/Bylaws |                      |
|   | > Submission      |                        | \*Although these     |
|   |                   | -   Non-profit         | regulations do not   |
|   |                   |     determinations     | require formal       |
|   |                   |                        | submission of all    |
|   |                   | -   List of Board of   | these documents at   |
|   |                   |     Directors          | the point of         |
|   |                   |                        | application, the     |
|   |                   | -   Authorization to   | grantee can still    |
|   |                   |     Request Funds      | request this         |
|   |                   |                        | information to       |
|   |                   | -   Authorized         | obtain a better      |
|   |                   |     official           | understanding of the |
|   |                   |     designation        | organization,        |
|   |                   |                        | systems, and         |
|   |                   | -   Organization Chart | personnel of a       |
|   |                   |                        | potential            |
|   |                   | -   Resumes of Chief   | subrecipient.        |
|   |                   |     Program Admin. and |                      |
|   |                   |     Chief Fiscal       |                      |
|   |                   |     Officer            |                      |
|   |                   |                        |                      |
|   |                   | -   Financial          |                      |
|   |                   |     Statement and      |                      |
|   |                   |     Audit              |                      |
|   |                   |                        |                      |
|   |                   | -   Conflict of        |                      |
|   |                   |     Interest           |                      |
|   |                   |     Questionnaire      |                      |
|   |                   |                        |                      |
|   |                   | -   Framework for      |                      |
|   |                   |     Documenting        |                      |
|   |                   |     Compliance with    |                      |
|   |                   |     National           |                      |
|   |                   |     Objectives         |                      |
+---+-------------------+------------------------+----------------------+

#### SUBRECIPIENT SELECTION CHECKLIST

  -----------------------------------------------------------------------
  This checklist provides useful criteria for selecting subrecipients and
  assessing risk. A grantee should use such criteria to determine whether
  a prospective subrecipient has the necessary systems in place for the
  Federal requirements that impact the type of activity being proposed.
  The grantee should "walk through" a hypothetical scenario involving the
  proposed activity to assess how the requirements on the checklist will
  be handled. This will allow the grantee to gauge the completeness of
  the prospective subrecipient's systems and determine whether any
  technical assistance and/or close oversight will be necessary.

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

-   Project is eligible and meets one of the three broad National
    Objectives:

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-   Principally benefits low- and moderate-income persons;

-   Prevents or eliminates slum or blight;

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-   Addresses an urgent need or problem in the community.

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-   Project fits into the community priorities set out by the
    Consolidated Plan.

-   Project can be completed within a reasonable time frame.

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-   Prior experience with CDBG related activities, **and/or**

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-   Prior experience with other grant programs, and proven record
    carrying out similar projects in the community.

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-   Financial capacity as indicated by audited financial statements and
    banking/credit references.

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-   Financial stability (not total dependence on CDBG funds) as
    indicated by other funding sources and amounts, over time.

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-   Adequate staffing (number of staff and qualifications).

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-   Organizational strength, including:

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-   record-keeping methods;

-   filing system;

-   financial systems;

-   existence of a written procedures manual for financial management
    and personnel.

> *The following summary scoring sheet represents the first stage of a
> two-part rating system developed principally by Palm Beach Co, FL, to
> select subrecipients and activities for CDBG funding. An application
> must score at least 50 points to be considered for stage II, which is
> a comparative analysis of each activity by a team of the county's
> Housing and Community Development (HCD) staff.*
>
> **[APPLICATION RATING SYSTEM]{.underline}**

1.  [Benefit to Low- and Moderate-Income Persons]{.underline}: 5 Points

> Five points will be given to activities that benefit at least 51
> percent low- and moderate-income persons.
>
> Zero points will be given to activities that meet either of the other
> two National Objectives.

2.  [Benefit to Target Areas]{.underline}: Maximum of 10 Points

> Activities located within a Target Area containing Areas of Hope, will
> receive the maximum 10 points. Activities located in Target Areas with
> no Areas of Hope will receive 8 points. Activities adjacent to a
> Target Area will receive 5 points. All other activities will be
> awarded 3 points.

3.  [Activity Need and Justification]{.underline}: Maximum of 20
    Combined Points

> a\. [Need]{.underline}: Maximum of 15 Points
>
> The activity will be evaluated in terms of the documentation and
> justification of the need for the activity. Activities with excellent
> documentation and justification will be awarded the maximum of 15
> points: good, 10 points; average, 5 points; and poor, 0 points.
>
> b\. [Consolidated Plan Priority]{.underline}: Maximum of 5 Additional
> Points
>
> Activities addressing high priorities, as identified in the
> Consolidated Plan will be awarded\
> 5 points.

4.  [Cost Reasonableness and Effectiveness]{.underline}: Maximum of 10
    Points

> The activity will be evaluated in terms of: 1) its impact on the
> identified need; and 2) its implementation costs and funding request
> relative to its financial and human resources. Evaluation will include
> the cost incurred per person per unit and the justification for a
> particular level of funding.

5.  [Activity Management and Implementation]{.underline}: Maximum of 20
    Points

> a\. Management: Maximum of 15 Points
>
> Points will be awarded to applicants based on documentation and
> information provided, showing that the resources needed to manage the
> proposed activity are available and ready, and that the commitment for
> operation and maintenance, where applicable, has been certified. In
> addition, for applicants that have received CDBG funds in the past,
> their record of maintenance for the funded activity will be evaluated.
>
> b\. Implementation: Maximum of 15 Points
>
> Points will be awarded to applicants based on documentation and
> information provided, showing that the resources, such as funding,
> site control, etc., needed to implement the proposed activity are
> available and ready. Maximum points will be given to activities that
> are ready to move forward quickly. This criteria take into
> consideration factors that may accelerate or slow down the ability to
> implement the activity in a timely manner.

6.  [Experience and Past Performance]{.underline}: Maximum of 10 Points

> The experience of the applicant, including the length of time in
> business and experience in undertaking projects of similar complexity
> as the one for which funds are being requested, will be evaluated.
>
> In addition, the applicant will be evaluated in terms of its past
> performance in relation to any local, state, or Federal funding
> program. The past performance will refer to attainment of objectives
> in a timely manner and expenditure of funds at a reasonable rate in
> compliance with contract. Compliance with the contract will include
> but not be limited to submission of reports and adherence to the scope
> of services.
>
> For those applicants that have not received CDBG funding from HCD in
> the past, allocation of points up to the maximum of 10 points will be
> awarded, dependent upon thorough documentation of similar past
> performances submitted with the application.

7.  [Matching Contributions]{.underline}: (Matching contributions must
    be eligible.) Maximum of 20 Points

> a\. [Efforts to Secure Other Funding]{.underline}: Maximum of 5 Points
>
> Points will be awarded based on the applicant's efforts to secure
> other funding for the activity.
>
> b\. [Matching]{.underline}: Maximum of 15 Points
>
> Points will be awarded based on the ratio of the amount of eligible
> matching funds to the amount of CDBG funds requested:
>
> 1.1 or more 15 points
>
> .75-1 10 points
>
> .50-1 7 points
>
> .25-1 5 points

less than .25 0 points

8.  [Environmental Justice]{.underline}: Maximum of 5 Points

> Applications will receive 5 points if the activity promotes
> environmental justice. Any activity that has a potential adverse
> impact on the environment or that is adversely affected by the
> surrounding environment will not be considered.

9.  [Application Completeness]{.underline}: Maximum of 5 Points

> Applications will receive up to 5 bonus points, based on completeness.
> Applications that have not been signed will not be considered.
>
> **RISK ANALYSIS MATRIX**
>
> ***The following list identifies factors that grantees may use to rank
> the degree of risk associated with a potential subrecipient or
> application submitted for funding. Grantees may develop ranking and
> rating criteria based on risk analysis as part of the process for
> selection of subrecipients.***
>
> **[Project Complexity]{.underline}**
>
> Size of dollar amount requested
>
> Use of funds:
>
> For construction or rehab
>
> For operation of facility
>
> For program only
>
> **[Type of Organization Requesting Funding]{.underline}**
>
> Non-profit
>
> For-profit (570.201(o))
>
> Governmental Agency
>
> **[Complexity of Housing Project]{.underline}**
>
> New construction
>
> Rehabilitation
>
> Single unit/multi-unit
>
> Number of units
>
> Subrecipient's prior experience with this size and type project
>
> **[Economic Development]{.underline}**
>
> Complexity of project
>
> Number of jobs to be created or retained
>
> Area benefit
>
> Providing direct grants and loans
>
> Providing technical assistance
>
> Subrecipient's prior experience
>
> **[Potential Environmental Concerns]{.underline}**
>
> Degree of complexity
>
> E.I.S. needed
>
> **[Other Type of Project]{.underline}**
>
> Degree of experience carrying out similar type project
>
> **[Funding]{.underline}**
>
> Other sources of funds indicated, but not committed
>
> Other funds committed
>
> CDBG funds only
>
> **[Type of Assistance]{.underline}**
>
> Grant
>
> Loan
>
> **[Float Loan]{.underline}**
>
> Ability to repay within necessary time frame
>
> **[Program Income]{.underline}**
>
> To be retained to continue with the same activity
>
> To be retained for a different activity
>
> To be returned to grantee
>
> **[Subrecipient Organization]{.underline}**
>
> Newly created entity
>
> Well established, but no prior CDBG or Federal experience
>
> Prior experience with CDBG or other Federal programs
>
> No independent source of funding, i.e., general fundraising
>
> **[Subrecipient History, If Previously Funded]{.underline}**
>
> Ability to deliver project within budget and on schedule
>
> Ability to anticipate and overcome past problems
>
> Any past monitoring issues raised
>
> Any special contract conditions needed
>
> **[Staffing]{.underline}**
>
> Staff experienced with this type activity
>
> Have sufficient staff to carry out project or must hire
>
> Entity has significant staff turnover
>
> **[Recent Problems]{.underline}**
>
> Unresolved monitoring findings
>
> Citizen complaints

#  {#section-6 .unnumbered}