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COOK COUNTYCommunity DevelopmentBlock Grant (CDBG) ProgramProcedures and OperationsGuide (Draft)Toni Preckwinkle, PresidentCook County Board of CommissionersHerman Brewer, Bureau ChiefPrepared by the Cook County Bureau of Economic DevelopmentJanuary 2012
TABLE OF CONTENTSCHAPTER 1: OVERVIEW1.1-INTRODUCTION . 1-21.2-MISSION STATEMENT .1-31.3-PURPOSE .1-31.4-SCOPE OF DOCUMENT .1-31.5-GENERAL CALENDAR GUIDELINES . 1-5CHAPTER 2: GRANTS MANAGEMENT AND ADMINISTRATION2.1-INTRODUCTION . 2-22.2-NATIONAL OBJECTIVES AND BASIC ELIGIBLE ACTIVITIES .2-22.3-COOK COUNTY CDBG PROGRAM GUIDELINE .2-132.4-PREREQUISITES AND APPLICATION PROCESS . 2-272.5-PUBLIC HEARING PROCESS .2-282.6-APPLICATION PROCESS .2-302.7-PROJECT SELECTION AND REVIEW PROCESS . 2-312.8-PROJECT APPROVAL AND SUBRECIPIENT AGREEMENT PROCESS . 2-332.9-PROJECT SETUP AND NTP PROCESS. 2-352.10-SUBRECIPIENT AND PROJECT MONITORING. 2-362.11-INVOICE/DRAWDOWN PROCESSING .2-392.12-PROJECT CLOSE OUT .2-40APPENDIX 2CDBG PROGRAM PROCESS CHART . 2-42CAPITAL IMPROVEMENT FILE CHECKLIST . 2-43PUBLIC SERVICE CASE FILE CHECKLIST . 2-44CLOSE-OUT FORM . 2-45CHAPTER 3: PROJECT MANAGEMENT3.1-INTRODUCTION . 3-23.2-OVERVIEW OF SUBRECIPIENT PROCEDURES . 3-23.3-PRE-REQUISITES . 3-23.4-CAPITAL IMPROVEMENT PROJECT ACTIVITIES. 3-33.5-PUBLIC SERVICES PROJECT ACTIVITIES .3-63.6-ECONOMIC DEVELOPMENT .3-7Community Development Block Grant ProgramCook County Bureau of Economic DevelopmentiProcedures and Operations GuideJanuary 2012
TABLE OF CONTENTSCHAPTER 4: GENERAL ADMINISTRATIVE REQUIREMENTS4.1-INTRODUCTION. 4-34.2-PROJECT SPECIFIC REQUIREMENTS. 4-34.3-SUBRECIPIENT AGREEMENTS . 4-4ProvisionsNotice to ProceedChange Orders4.4-PROGRAM INCOME . 4-64.5-USE AND MAINTENANCE OF REAL PROPERTY AND EQUIPMENT . 4-74.6-ENVIRONMENTAL REVIEW.4-9Environmental Standards (§570.604)Environmental Review Record ProcedureEnvironmental Review RecordHistoric PreservationNational Flood Insurance Program (§570.605)Floodplain Management4.7-FINANCIAL MANAGEMENT .4-11Provisions-Uniform administrative requirements and cost principles (§570.610)Financial Management RequirementsDrawdown and ExpendituresMonthly Project Status ReportsGuidelines for Preparing Financial StatementsAudit Requirements4.8-PROCUREMENT . 4-15Professional ServicesConstruction and SuppliesContracting with MBE/WBESelection ProceduresCode of ConductStevens Amendment Requirements4.9-GRANT MANAGEMENT AND RECORDKEEPING . 4-21General RequirementsGrant Management and Recordkeeping RequirementsCitizen Participation4.10-CIVIL RIGHTS AND FAIR HOUSING . 4-29Provisions (§570.600)Civil Rights (§570.602)Fair Housing (§570.601)Employment and Contracting opportunities (§570.607)Affirmatively Furthering Fair Housing (§570.601)Handicapped Accessibility (§570.614)Community Development Block Grant ProgramCook County Bureau of Economic DevelopmentiiProcedures and Operations GuideJanuary 2012
TABLE OF CONTENTS4.11-CONSTRUCTION, COMMERCIAL REHABILITATIONS AND DEMOLITION .4-30Documents Required Prior to Preparing Bid PackagesDocuments Required in Bid SpecificationsAdministrative Requirements Prior to Award of ContractAdministrative Requirements After Award of ContractChecklists for DemolitionLabor Standards (§570.603)Section 3 RequirementsCapital Improvement Projects over 100,000.00Relocation Policy and Procedures (§570.606)Appendix 4ENVIRONMENTAL REVIEW CHECKLIST . 4-35FORM 4A-LABOR STANDARDS . 4-37FORM 4C-CHANGE ORDERS . 4-38FORM 4D-BIDS . 4-39FORM 4E- EQUAL EMPLOYMENT OPPORTUNITY . 4-40FORM 4F-EMPLOYEE INTERVIEW FORM . 4-4124 CFR SECTIONS 84.32-84.34; 84.40-84.48; 85.32-85.33 . 4-42CHAPTER 5: FINANACIAL MANAGEMENT5.1-INTRODUCTION . 5-25.2-PROCUREMENT AND CONTRACTING . 5-35.3-FINANCIAL MANAGEMENT SYSTEMS . 5-45.4-COUNTY CDBG PROGRAM FINANCIAL GUIDELINES . 5-45.5-SUB RECIPIENT CDBG PROGRAM FINANCIAL GUIDELINES .5-55.6-INTEGRATED DISBURSEMENT AND INFORMATION SYSTEMS (IDIS). 5-95.7-AMENDMENTS/CHANGE ORDERS . 5-95.8-PROJECT CLOSEOUT .5-105.9-PROGRAM INCOME . 5-115.10-FINANCIAL AUDITS .5-115.11-FINANCIAL RECORDS .5-12APPENDIX 5Request for Payment (FORM 3) . 5-14Subrecipient 29A Certification (FORM 4) . 5-15Drawdown Request and Certification . 5-16Community Development Block Grant ProgramCook County Bureau of Economic DevelopmentiiiProcedures and Operations GuideJanuary 2012
TABLE OF CONTENTSCHAPTER 6: PERFORMANCE REPORTING6.1-INTRODUCTION . 6-26.2-OVERVIEW OF COUNTY REQUIREMENTS .6-26.3-SUBRECIPIENT REQUIREMENTS . 6-3APPENDIX 6Cook County Annual Performance Report Worksheet . 6-6Cook County Quarterly Performance Report Worksheet . 6-18CHAPTER 7: MONITORING7.1-INTRODUCTION . 7-27.2-RISK ANALYSIS. 7-27.3-MONITORING SCHEDULE AND PROCESS . 7-37.4-SITE VISIT MONITORING PROCEDURES.7-47.5-IMPOSING SANCTIONS .7-6APPENDIX 7Sample Monitoring Checklist . 7-8Sample Monitoring Letter . 7-13Sample Risk Analysis . 7-15Community Development Block Grant ProgramCook County Bureau of Economic DevelopmentivProcedures and Operations GuideJanuary 2012
CHAPTER 1: OVERVIEW1.1-INTRODUCTION . 1-21.2-MISSION STATEMENT . 1-31.3-PURPOSE . 1-31.4-SCOPE OF DOCUMENT . 1-31.5-GENERAL CALENDAR GUIDELINES . 1-5Community Development Block Grant ProgramCook County Bureau of Economic Development1-1Procedures and Operations GuideDecember 2012
CHAPTER 1: OVERVIEW1.1-INTRODUCTIONThe Cook County Bureau of Economic Development administers three federalprograms with funding from the U.S. Department of Housing and Urban Development(HUD). This manual details the policies and operating procedures for one of theseprograms, the Community Development Block Grant (CDBG) Program. The CDBGProgram which began in 1975 has been an effective program in providing funding toaddress the important community and economic development needs of the suburbancommunities in Cook County. In suburban Cook County, more than 309 million inCDBG funds have been used to build senior centers, improve multi-family and singlefamily housing, provide clean drinking water, demolish abandoned buildings, housethe homeless, improve and develop local infrastructure and provide new low costhousing to our neediest senior citizens.The CDBG Program utilizes funds made available by HUD, for which Cook County isthe Grantee, and for which the County has qualified as an "Urban County Entitlement".Accordingly, Cook County is entitled to receive a specified amount of funds basedupon population, poverty and age of housing stock. In turn, the County may subgrantfunds to eligible municipalities and organizations for various community andeconomic development purposes. These funds must be used for eligible activities thatmeet the national objectives of the CDBG Program. The purpose of the CDBG Programis to develop viable urban communities by providing decent housing and a suitableliving environment and expanding economic opportunities, principally for persons oflow and moderate income.Additionally, funding has been used to provide: educational, recreational andoutreach programs for youth, housing counseling, social and support services forwomen and children, domestic violence awareness and prevention programs, alcoholand drug addiction treatment and predatory lending prevention programs.This manual and other documents developed by the Cook County Department ofEconomic Development for the CDBG Program are based on federal statutes andregulations as formulated by HUD and other applicable federal agencies. Theregulations apply to the following:1. all CDBG funds;2. all un-obligated (not under contract) funds from the previous program yearspresently assigned to subrecipients;3. reprogrammed funds and amendments;4. program incomeNot included in the Cook County CDBG program are communities that receive fundsdirectly from HUD and do not participate in the County’s programs, including:Arlington Heights, Berwyn, Chicago, Cicero, Des Plaines, Elgin, Evanston, MountProspect, Oak Lawn, Oak Park, Orland Park, Palatine, Schaumburg and Skokie. CookCommunity Development Block Grant ProgramCook County Bureau of Economic Development1-2Procedures and Operations GuideDecember 2012
CHAPTER 1: OVERVIEWCounty CDBG funds may not be used, directly or indirectly, in areas not included inthis program.1.2-MISSION STATEMENTThe Bureau of Economic Development seeks to foster community and economicdevelopment through strategic leveraging or resources to stimulate: (1) sustainablecommunity investment connecting housing, employment, development, andtransportation; (2) business growth, attraction, and retention; (3) affordable housing;and (4) regional planning focused on the integration of economic, physical, and socialinfrastructure.1.3-PURPOSEThis manual has been designed and written to assist in the implementation of theCDBG grant related programs administered by the Bureau of Economic Development.It is intended to provide information for use by Cook County staff and subrecipients inthe management of their CDBG projects. This edition of the manual has beensimplified and updated to reflect the latest changes in Federal regulations and CookCounty policies. Periodically, the manual will be updated and available when therehave been regulatory or programmatic changes.If a subrecipient is unsure how to proceed after reading this manual, they areencouraged to call their assigned Planner for guidance. More information can befound on the U.S. Department of Housing and Urban Development’s website atwww.hud.gov.1.4-SCOPE OF DOCUMENTThis manual is constructed on the premise that CDBG program regulatory,performance, administrative, financial, compliance and record keeping requirementscan be satisfied through timely preparation, completion and recording or filing ofrequired documentation over the life-cycle of the grant and project. The requireddocuments are specified in grant and project file checklists in various HUD CDBGGuidebooks: County grant files include application, contract, program administration andfinancial management files that should contain documentation and informationthat relate to the overall funding and administration of Cook County’s CDBGprogram. Subrecipient project files should contain specific documentation and informationpertaining to each Subrecipient’s CDBG funded project. The file checklist for atype of project (capital improvement, economic development, or public services)lists the required documents to be prepared, completed or submitted to theCounty, and maintained in the project file over the life of the project.Community Development Block Grant ProgramCook County Bureau of Economic Development1-3Procedures and Operations GuideDecember 2012
CHAPTER 1: OVERVIEW The key document in both the grant and project files is the SubrecipientAgreement. In the Agreement, the County specifies its policy and procedures and details the pertinentregulations and certifications that the Subrecipient must comply with incarrying out project activities in accordance with the approved projectschedule, statement of work and deliverables and budget. the Subrecipient is provided the performance measures and guidance forthe documentation of all project activities from the notice to proceed toproject closeout including documents and reports to be submitted to theCounty.The objective of this manual is to identify and organize the grant and projectdocuments that the County and Subrecipient staff prepare, complete and file over aproject’s life-cycle. Chapter 2 - Identifies Cook County’s CDBG funded programs, eligibleactivities, stages of the annual CDBG formula grant and related grantsmanagement and administrative processes including the County’s notice offunding availability (NOFA); public hearings; application submission, reviewand project selection; project approval and grant award; monitoring; andreporting activities. These processes are presented in a step by step processfor the benefit of county staff that administer and monitor CDBG programactivities, as well as subrecipients. Chapter 3 - Provides guidance to subrecipients on the processes andactivities traditionally carried out by the subrecipient in accordance withCDBG program guidelines, regulations and procedures in the administrationof CDBG project activities. Processes are broken down according to basicactivities and are presented in a step by step process. Chapters 4, 5 and 6 provide guidance on the preparation, completion,recording or reporting, and filing of required administrative, financial andperformance related documents. The content of some required documentsmay differ by type of project (capital improvement, economic development,or public service). Chapter 7 provides information regarding the monitoring schedule, riskanalysis and the County’s procedures for conducting at least one on-sitemonitoring visit per subrecipient per year.Community Development Block Grant ProgramCook County Bureau of Economic Development1-4Procedures and Operations GuideDecember 2012
CHAPTER 1: OVERVIEW1.5- GENERAL CALENDAR GUIDELINESCOOK COUNTY ANNUAL ACTION PLAN TIMETABLENote: The following dates represented are estimated timeframes and are subject tochange.Early-DecemberAdvisory Council Public Hearing Purpose: Performance Presentations bynot-for-profit organizations for previousyear activitiesMid-DecemberCDBG Application Posted OnlineEarly-JanuaryCDBG Application WorkshopMid-January1st Quarterly Report DueJanuary (3 Scheduled Dates)Three Regional Public Hearings –Purpose: InformationalSouth & Southwest Region Hearing: SixthDistrict Courthouse16501 South Kedzie Parkway, Markham,IL 60426North and Northwest Region Hearing:Third District Courthouse2121 Euclid Ave. Rolling Meadows, IL60008West Region Hearing:Fourth District Courthouse1500 South Maybrook Drive, Maywood,IL 60426Mid-FebruaryApplications funds due by 4:00p.m at 69West Washington Street, 29th Floor,Chicago, Illinois.Mid-MarchAdvisory Council Public Hearing Purpose: Project Proposal Presentationsby not-for-profit organizationsrequesting funding.Mid-April2nd Quarterly Report DueCommunity Development Block Grant ProgramCook County Bureau of Economic Development1-5Procedures and Operations GuideDecember 2012
CHAPTER 1: OVERVIEWLate-AprilFair Housing Workshop (Subrecipients)Early-JuneAnnual Action Plan Preparation BeginsMid-JuneCook County Board Hearing to ApproveCDBG ProjectsEarly-JulyAnnual Action Plan (Draft) Public CommentPeriod BeginsMid-JulyLate-July3rd Quarterly Report DueAnnual Action Plan Scheduled forCompletionMid-AugustAnnual Action Plan due to HUDEarly-SeptemberCAPER Report Preparation BeginsMid-SeptemberSubrecipient Agreement WorkshopSend Letters to Surecipients requesting:Final Quarterly Performance Reports,Section 3 Reports and NotifyingMunicipalities that it is time to conducttheir Performance Hearing and submitdocuments as evidence (publication,minutes and sign-in sheets)September 30End of Program YearOctober 1Start of Program YearEarly-NovemberCAPER (Draft) Public Comment PeriodDecember 31Comprehensive Annual Performanceand Evaluations Report (CAPER) due toHUD*Additional meetings and workshops will be scheduled as applicable*Community Development Block Grant ProgramCook County Bureau of Economic Development1-6Procedures and Operations GuideDecember 2012
CHAPTER 2: GRANTS MANAGEMENTAND ADMINISTRATION2.1-INTRODUCTION . 2-22.2-NATIONAL OBJECTIVES AND BASIC ELIGIBLE ACTIVITIES . 2-22.3-COOK COUNTY CDBG PROGRAM GUIDELINE . 2-132.4-PREREQUISITES AND APPLICATION PROCESS . 2-272.5-PUBLIC HEARING PROCESS. 2-282.6-APPLICATION PROCESS . 2-302.7-PROJECT SELECTION AND REVIEW PROCESS . 2-312.8-PROJECT APPROVAL AND SUBRECIPIENT AGREEMENT PROCESS . 2-332.9-PROJECT SETUP AND NTP PROCESS . 2-352.10-SUBRECIPIENT AND PROJECT MONITORING . 2-362.11-INVOICE/DRAWDOWN PROCESSING . 2-392.12-PROJECT CLOSE OUT . 2-40APPENDIX 2CDBG Program Process Chart .2-42Capital Improvement File Checklist . 2-43Public Service Case File Checklist . .2-44Close-Out Form . .2-45Community Development Block Grant ProgramCook County Bureau of Economic Development2-1Procedures and Operations GuideJanuary 2012
CHAPTER 2: GRANTS MANAGEMENTAND ADMINISTRATION2.1-INTRODUCTIONCook County is responsible for establishing the necessary operating principles andadministrative policy and procedures to ensure implementation of its HUD-approvedConsolidated Community Development Plan (ConPlan). The operating procedures set forthherein ensure consistent and uniformly applicable programs to all subrecipientsparticipating in the Cook County CDBG program.This chapter describes Cook County CDBG funded programs, eligible activities, stages of theannual CDBG formula grant and related grants management and administrative processesincluding the County’s notice of funding availability (NOFA); public hearings; applicationsubmission, review and project selection; project approval and grant award; monitoring; andreporting activities. These processes are presented in a step by step process for the benefit ofcounty staff that administer and monitor CDBG program activities, as well as subrecipients.CDBG grant funds are awarded to municipalities and subrecipients to carry out capitalimprovement, public services, public facilities, and economic development projects. Countyplanners are assigned to coordinate capital improvement projects with municipalities or tocoordinate public services, economic development, or public facilities projects with nonprofit agencies serving the region or neighborhoods.Please refer to Chapter 4: General Administrative Requirements for a complete description ofapplicable federal requirements for program administration.2.2-NATIONAL OBJECTIVES AND BASIC ELIGIBLE ACTIVITIESNational ObjectivesThis section summarizes the National Objectives of the CDBG Program contained in the Codeof Federal Regulations, Title 24, Part 570, Sections 570.200 (a)(2) and (3), 570.208(a)-(d),and 570.506.Each Activity, except planning and administrative activities, must meet one of the CDBGprogram’s three broad National Objectives:1. Benefit low-moderate-income persons,2. Aid in the prevention or elimination of slums or blight, or3. Meet community development needs having a particular urgency.At least 70 percent of the grantee’s overall expenditures during a one-, two- or three-yearperiod (specified by the grantee) must be used for activities that benefit low- and moderateincome persons. To ensure that this statute is met; all new applications are reviewed byCook County CDBG Staff to ensure eligibility of proposed projects and compliance with lowto-moderate income areas. (Area benefit shall not exceed 49.2% for capital improvementCommunity Development Block Grant ProgramCook County Bureau of Economic Development2-2Procedures and Operations GuideJanuary 2012
CHAPTER 2: GRANTS MANAGEMENTAND ADMINISTRATIONprojects and 51% for water/sewer and projects requiring flood control). The followingprocedure is applied: HUD provides Cook County (Grantees) with updated website link information,http://www.hud.gov/offices/cpd/ systems/census/lowmod/, regarding eligibleCensus Tract and Block Group data. The census information includes identifyinglow- and moderate income percentages.Cook County staff downloads the updated Census Tract and Block Group datainto Cook County’s Lotus Approach Management System database.All applications are reviewed by Cook County CDBG Staff to ensure eligibility ofproposed projects and compliance with low-to-moderate income areas. (Areabenefit shall not exceed 49.2% for capital improvement projects and 51% forwater/sewer and projects requiring flood control).A checklist is located within the project files and upon completion of applicationreviews, of which require proof of eligibility and compliance, CDBG staff insertsthe results into the project files and check the appropriate section on thechecklist.1. Activities Benefiting low- and moderate- income personsa) Area benefit activitiesArea benefit activities include an activity that benefits all the residents in a particulararea, where at least 49.2 percent of the residents are low- and moderate-incomepersons. The service area must be primarily residential or serve a residentialcommunity, and it must meet the identified needs of low- and moderate-incomepersons. Examples include: street improvements, water and sewer lines,neighborhood facilities, and façade improvements in neighborhood commercialdistricts. Such an activity must meet one of the following qualifying criteria.(i) Fifty-one percent of the persons residing in the service area are low andmoderate income, supported by the most recently available decennial censusinformation, together with the Section 8 income limits that would haveapplied at the time the income information was collected by the CensusBureau. (HUD provides grantees with information by census tract and blockgroup that may be used to determine this percentage); or(ii) Fifty-one percent of the persons residing in the service area are low- andmoderate-income residents supported by a current survey of the residents ofthe service area if the applicant believes that the census data do not reflectcurrent relative income levels in an area, or where census boundaries do notcoincide sufficiently well with the service area of an activity. The surveyCommunity Development Block Grant ProgramCook County Bureau of Economic Development2-3Procedures and Operations GuideJanuary 2012
CHAPTER 2: GRANTS MANAGEMENTAND ADMINISTRATIONresults must meet statistical reliability standards and be approved by HUD;or(iii) Under the Exception Criteria, a service area that contains less than 51percent low- and moderate-income residents will be considered to meet theNational Objective if the proportion of low- and moderate-income persons inthe area is within the highest quartile of all areas in the recipient’sjurisdiction in terms of the degree of concentration of such persons. HUD willdetermine the lowest proportion a recipient may use to qualify an area forthis purpose.Cook County has determined that
CHAPTER 1: OVERVIEW _ Community Development Block Grant Program Procedures and Operations Guide Cook County Bureau of Economic Development December 2012 1-3 . County CDBG funds may not be used, directly or indirectly, in areas not included in this program. 1.2-MISSION STATEMENT. The . Bureau of Economic Development
