OFFICE OF FAIR HOUSING AND EQUAL OPPORTUNITY Fair Housing Initiatives Program
COMPLETE CONTENTS OF THE INFOGRAM
Guidance for FHIP Grantees - June 1995 INTRODUCTION OF THE FHIP INFO-GRAM
This is the premier issue of our FHIP Infogram, which we intend to circulate periodically as questions and issues arise. We envision the Info-Gram as a communication tool for providing guidance to current grantees on program and administrative matters.
INFO ON HUD PERSONNEL CHANGES . . . Roberta Achtenberg announced in April her intention to resign as HUD's Assistant Secretary for FHEO in order to campaign for mayor of San Francisco. Elizabeth Julian, Deputy General Counsel for Civil Rights and Litigation has been asked by Secretary Cisneros to assume the responsibilities of Assistant Secretary for FHEO. Ms. Julian has worked in civil rights law for 20 years and has always been a strong advocate for fair housing. Maxine Cunningham (former Director for HUD's Office of Economic Opportunity) was recently named Director of the Office of Fair Housing Initiatives and Voluntary Programs. She replaces Jacquelyn Shelton, who is now HUD's Los Angeles Area Office Coordinator. Maxine Cunningham is also Acting Director of the Fair Housing Initiatives Program Division, pending selection of a permanent director to replace Barbara Talts, who recently retired from HUD.
While these departures have created some changes in FHEO's organization, we do not expect any interruption in service to our grantees. Roberta, Jackie, and Barbara will all be remembered for their dedication and commitment to carrying out the department's fair housing objectives and we wish them much success in their new endeavors.
FHIP POST-AWARD TRAINING CONFERENCE - SAN DIEGO ... many thanks to all of you who participated in our first ever training focused on post-award administration of FHIP grants held January 11 and 12, 1995 in San Diego. This FHIP update will address outstanding matters from the training.
COMPLETE LISTINGS OF ALL PUBLICATIONS OF THE FAIR HOUSING INFOCLEARINGHOUSE .. The Fair Housing Information Clearinghouse is a repository for information and materials developed under HUD's fair housing programs. Concurrent with submission to the Government Technical Representative (GTR), Grantees are responsible for sending one copy of final product deliverables (including tester training manuals), quarterly reports, and final reports to the Clearinghouse at the following address:
Fair Housing Information Clearinghouse 8201 Greensboro Drive, Suite 600 McLean, VA 22102 1-800-343-3442 (TDD) 1-800-290-1617
Grantees are also advised to contact the Fair Housing Information Clearinghouse to obtain any appropriate manuals, brochures, posters, videos, PSAs, tapes or other materials prior to development of new materials.
COMPLETING THE FINANCIAL STATUS REPORT - SF 269A ... Immediately following this section (pages 2, 3, 4, and 5 of this Infogram=) are instructions for completing the Financial Status Report - SF 269A (blank forms were distributed at the San Diego conference) and a sample form. As discussed at the San Diego conference, there appears to be a need for explaining the form and how it is to be completed in order to achieve greater consistency in submissions from grantees. Please give us your feedback on whether the instructions are clear and the sample is helpful.
SF 269A - FINANCIAL STATUS REPORT INSTRUCTIONS for HUD FHIP GRANTS
Recipients should complete the SF269A as it pertains to the specific grant number entered in Item 2.
Item 1. Enter "Department of HUD" or "'HUD"
Item 2. Enter Grant Number, i.e., FH-OOG9-000-.
Item 3. Enter Recipient organization name, address and zip code as it appears on the grant agreement.
Item 4. Enter Employer Identification Number (BIN) or Tax Identification Number (TIN), as applicable.
Item 5. For recipient use only.
Item 6. Self-explanatory.
Item 7. Put X in appropriate box.
Cash basis means that disbursements or outlays are the total actual cash paid for direct costs for goods and services, indirect expense, in-kind contributions and cash advances and payments made to sub-recipients.
Accrual basis means that disbursements or outlays are the total actual cash paid for direct charges for goods and services, the amount of indirect expense, in-kind contributions and the net increase or decrease in the amounts owed (debt) by the recipient for goods and other property received for services performed by employees, contractors, sub-recipients and other payees, and other amounts becoming owed under programs for which no current services or performances are required, such as annuities, insurance claims, and other benefit programs.
Item 8. Funding Grant Period
From: enter Month/Day/Year, e.g., 10/01/94, of the effective date for grant award.
To: enter Month/Day/Year, e.g., 9/30/95, of the end date for the award. NOTE: The dates shown above are for a 12 month grant awarded on 10/01/94 and ending on 09/30/95.
Item 9. Period Covered by this Report should be indicated by entries of Month/Day/Year in the FROM: and TO: blocks for the quarter covered by this report. For example, the first Quarterly Financial Status Report, SF 269A, for an award dated 10/01/94 would show the following dates - FROM: 10/01/94 TO: 12/31/94.
COLUMNS 1, II, III. For the first Quarterly Report on this form, Columns I and II remain Blank. The purpose of Columns I, II, and III is to show the effect of this reporting period's transactions on cumulative financial status.
Item 10.a. Enter total outlays or expenditures, less any rebates, refunds or other credits. This entry is for those charges made to the project or program under the grant number shown in Item 2 only.
Item l0.b. Enter the recipient's share (in-kind contribution) of charges shown in Item 10.a.
Item 10.c. Enter the federal share (the amount of federal funds used to pay for the total charges shown in Item 10.a).
Item 10.d. Enter the total unliquidated obligations -
For a cash basis, this means the amount of obligations (debt) incurred by the recipient that have not been paid; for an accrual basis, this means the amount of obligations (debt) incurred by the recipient for which an outlay (charge/expenditure) has not been recorded.
Item 10.e. Enter the recipient's share (in-kind contribution) of charges shown in Item 10.d.
Item 10.f. Enter the federal share (the amount of federal funds used to pay for the total charges shown in Item 10.d).
Item 10.g. ADD line lo.c. and lo.f and enter the total in Column III, Cumulative.
Item 10.h. Total Federal funds authorized for the funding period means the total amount of the grant award. For example, if a recipient received a grant award for $100,000 for a 12-month period of performance, the entry for 10.h. would be $100,000 on each Quarterly and Final Report submitted for the specific grant identified in Item 2, unless the grant amount is otherwise increased or decreased through a grant amendment. '
Item 10.I. Unobligated balance of federal funds (a cumulative amount) is determined by subtracting Item 10.g. (total federal share) from the entry in Item 10.h. (total amount of federal money awarded to the grantee). Therefore, the total shown for Item 10.I. is the amount of federal funds authorized by HUD in the award that have not been obligated by the recipient.
Item ii.a. Enter an X in the appropriate box. In most cases, the X will mark "Provisional" for private non-profit organizations.
Item ll.b. Enter the Indirect Rate (overhead) in effect during the reporting period shown in Item 9.
Item ll.c. Enter the amount of the base against which the rate vas applied. In most cases, the base is direct labor or direct labor plus fringe benefits. Recipient should use the base@that vas used in final award negotiations.
Item ll.d. Enter the total amount of indirect costs charged to the specific grant during the report period shown in Item 9.
Item ii.e. Enter the Federal share (the amount of the indirect costs shown in Item ll.d. that will be paid by federal funds provided on the specific grant.
Item 12. Include any Remarks necessary to explain entries for Items I through ii. NOTE: For FY 1993 and FY 1994 multi-year grantees, the basic award amount will be increased by amendment when the second year project is awarded. This increase will require recipients to adjust Item 8 and Item 10.h., at a minimum, for adjustment from previous reports to the multi-year award increase in performance and dollars. Footnote Column I entry on this first report for the second year's effort, and give an explanation in Item 12. Additional plain sheet pages may be used for this Item if needed.
Item 13. Certification requires typed name and title and signature of an authorized certifying official from the recipient's organization. Provide a telephone number and a date on each report.
See attached SAMPLE SP 269A, FINANCIAL STATUS REPORT, for an award made on 10/01/94 for a 12-month period of performance ending on 09/30/95, in the amount of $100,000, with $20,000 In-Kind Contribution. Recipient is providing the Second Quarterly Report for the period 1/31/95 to 3/31/95. The negotiated provisional indirect cost rate vas 10% calculated to an allocation base of $40,000 (for the 12-mouth period) composed of direct labor plus fringe benefits.
The first report submitted recorded $5,000 for total outlays, all of which were paid by federal funds, and no unliquidated obligations or indirect charges were reported.
The SAMPLE second report records an additional $25,000 in total outlays, the recipient's share is $10,000, and the federal share is $15,000; $10,000 is reported for unliquidated obligations, the recipient share is $2,000, the federal share, $8,000; the indirect expense recorded for the second quarter is $10,000, and the federal share is 80% of total indirect expense for the quarter.
NOTE: THIS IS FOR USE AS A SAMPLE ONLY AND IS NOT REPRESENTATIVE OF ANY EXISTING GRANT AWARD.
Grant Amendments .. FHIP staff are frequently asked questions about what constitutes a grant amendment, when they are required, and what the procedures are for executing a grant amendment.
Grant amendments are formal revisions to the basic grant award documents and are executed on form HUD-1044,
Assistance Award/Amendment. They are required whenever there are deviations from program or project plans (i.e., Statement of Work, period of performance) changes in key personnel, increases or decreases to previously budgeted amounts, requests for additional funding, and/or changes of address.
Amendments may be initiated by the government or by the grantee. To request an amendment, the grantee must notify the GTR in writing and request an amendment whenever these types of changes are contemplated. Such requests must be timely and include adequate backup documentation justifying the revisions, so that amendments can be executed accordingly. Program changes will be reviewed by the GTR and budgetary or financial changes will be reviewed by the Grant Administrator prior to the Grant Officer's signature on the amended HUD-1044.
Amendments may be unilateral or bilateral. Unilateral amendments may be issued when there is an administrative action that:
1. Changes the appropriation data;
2. Changes the Grantee's address as requested by the grantee;
3. Changes the Government Technical Representative, Government Technical Monitor, or Grant Administrator; -or-
4. Changes the Project Manager or Key Personnel when requested in writing by the grantee and approved by the Grant Officer.
The Grant Officer has a unilateral right and authority to issue amendments which suspend work performance, or which terminate the grant award.
Bilateral amendments are required when the action is program or budget-related and:
1. Changes the total amount of the award;
2. Changes the Statement of Work;
3. Changes the product deliverables; and/or
4. Changes or extends the period of performance.
Bilateral amendments require signature by the grantee and the Grant Officer to reflect the mutual agreement of the parties. Most often, this type of amendment is the end result of a negotiated material change to the grant instrument and should address all other terms and conditions that are impacted as a result of the change. For example, if the Statement of Work is modified to delete a task, there may be a need to modify the period of performance and to deobligate funds. Bilateral amendments are prepared, reviewed by the Grant Officer, and forwarded to the grantee for signature and return. The grantee should promptly sign and return three copies of the bilateral amendment to the Grant Officer. After signature by the Grant Officer, a fully executed grant amendment, one which shows signatures of the recipient and the grant officer, will be forwarded to the grantee.
Grant recipients should re-ad and understand each grant amendment before signing. If there is any question regarding the text of the amendment, the recipient should contact the Grant Administrator or the GTR and request an explanation.
INVESTMENT INCOME .. Circular A-1 10 requires that FHIP recipients maintain funds in interest bearing accounts, unless (1) the recipient receives less than $120,000 in Federal awards annually, (2) the best available interest bearing account would not be expected to earn interest in excess of $250 per year on Federal cash balances, or (3) the depository would require an average or minimum balance so high it would not be feasible within the expected Federal and non-Federal cash resources.
Interest amounts up to $250 per year may be retained by the recipient for administrative expenses.
For entities not subject to the Cash Management Improvement Act (CMIA) governing State agencies, instrumentalities, and fiscal agents, interest earned on Federal deposits in excess of $250 per year shall be remitted annually to:
Department of Health and Human Services Payment Management System P.O. Box 6021 Rockville, MD 20852 A LIST OF SUBSTANTIALLY EQUIVALENT STATE AND LOCAL AGENCIES.. Below is the most current listing of state and local agencies with fair housing laws substantially equivalent to the Federal Fair Housing Act. Those noted with an asterisk (*) are certified agencies. The remaining agencies have signed Interim Agreements.
King County, Washington*
FUTURE ISSUES ... Reinvention Update ... Financial Management Training ... Fair Housing Planning
If you have suggestions for topics or comments on the Infogram, convey them to your GTR or contact Sherry Fobear at (202) 708-0800.