The Subrecipient Agreement (SRA) is the basis for the contractual obligations between PRDOH and the Subrecipient. Although the main agreement contains the general responsibilities of the Subrecipient and PRDOH, Subrecipients should refer to the Exhibits of the SRA for specific requirements, timelines, goals, budget breakdown, personnel, and special conditions. SEE MORE+
To access agreements executed as part of the CDBG-DR Program, follow this link below.
Includes all timelines and performance goals that the Subrecipient will report on a monthly basis.
It is recommended that these milestones and goals be incorporated into subcontracts. This is what is reported on the Grant Compliance Portal.
The terms and conditions included herein apply to any contracts for which any portion of the funding is derived from a grant made by HUD.
Special conditions the Subrecipient must complete within the dates provided. These vary from subrecipient to subrecipient and are the result of a capacity assessment conducted prior to the SRA execution.
GRANT COMPLIANCE PORTAL
PRDOH, through oversight and monitoring efforts, ensures Subrecipients are properly carrying out activities, as agreed to in the Grant Compliance Portal.
The Grant Compliance Portal is the tool created for Subrecipients to comply with reporting requirements. In the Grant Compliance Portal, information regarding Key Activities and Deliverables, schedule changes, equipment, procurements, and other transactions involving grant funds will be overseen for compliance.
Subrecipients must identify a Contract Manager POC. This will be the staff member assigned to report on the Subrecipients projects or activities funded under a CDBG-DR Program SRA.
The Subrecipient Contract Manager POC will receive their login information (username and password) upon their Grant Compliance Portal Training completion.
New reports are available on the 25th of the reporting month and are due on the 5th of the following month.
There are various tools to aid and guide the Subrecipient in the reporting process. These tools include a user manual, instructional videos, and PRDOH offers live webinars on the 3rd week of every month.
Reporting Module for the Grant Compliance Portal
Compliance Portal Procurements and contracts
Special conditions stated in the corresponding exhibit of the SRA may include implementation of policies and procedures, organizational structure, and capacity building efforts. Information and instructions on the main topics are offered below.
Contact your program’s POC and/or Subrecipient Management team for any additional information here.
POLICIES AND PROCEDURES
Subrecipients are required to develop, update, and implement policies and procedures in compliance with PRDOH CDBG-DR policies and federal and state regulations.
To aid the compliance of this requirement, the Subrecipient shall complete the Policies Requirements Checklist and Self-Certification available on their My Profile Section in GCP. This section contains the policies, in a checklist type way, that guide the Subrecipient certify their compliance with required policies. Download instructional pager.
You can download a model template to compile the information, prior to the completion in GCP. Download Self-Certification.
STAFFING / ORGANIZATIONAL CHART
Subrecipient shall submit an updated organizational chart for offices and divisions in the organization participating in the implementation and management of the CDBG-DR awarded funds, that clearly demonstrate an appropriate segregation of duties in compliance with the Standards for Internal Control in the Federal Government established by the GAO, and in compliance with 2 C.F.R. § 200.303. Furthermore, the organizational chart shall also include the position, title, and employee’s name, clearly establishing the segregation of duties, including the finance division.
Your entity can upload the required documents in the GCP. Go to My Profile Module and click My Documents section. Download instructions on how to perform this action here.
CAPACITY BUILDING / TECHNICAL ASSISTANCE
The PRDOH is committed to supporting Subrecipients in increasing the CDBG Program’s capacity by implementing different initiatives such as orientations, basic and advanced training sessions, and technical support.
As part of their contractual requirements, every Subrecipient must complete the basic Core Curriculum utilizing the Learning Management System (LMS). Currently, the LMS used by the PRDOH contains over 50 courses available to subrecipients.
The CDBG-DR/MIT Curriculum can be accessed through the Talent LMS Learning Portal. Your entity will need to identify three to four (3-4) employees to complete the assigned modules in the learning portal. Once registered, the identified staff will receive an automated welcome email asking them to provide a password to access their account. Once they enter their username and password, they will have access to all assigned modules.
Please note that all modules are self-guided and can be completed at the users’ own pace (within the timeframe provided by PRDOH, as outlined in the Subrecipient Agreement). The identified staff will be able to select the language of preference for navigating the platform and completing the courses. All courses are available in English and Spanish. It is recommended that at least one (1) person from the Finance and/or Procurement Area register in the learning portal, as some courses include information related to finance and procurement processes.
You can register your entity’s identified personnel HERE.
Subrecipients can also register for recurring webinars. PRDOH Training Area has developed and is implementing a holistic program of recurring webinars to educate entities on the responsibilities and duties outlined in the contract and/or Subrecipient Agreement.
PRDOH publishes a list of available webinars each month on the CDBG resources page. You can access the calendar by clicking HERE.
Upon the subrecipient’s completion of requisite online or introductory courses, PRDOH makes available additional capacity-building opportunities to subrecipients. This could manifest in administering a phased curriculum or in offering ad hoc training initiatives as needed.
Technical assistance and workshops serve as follow up capacity-building initiatives with area or program-specific details that respond to identified needs. These initiatives are designed to correct specific weaknesses, provide more focused guidance, or answer program or issue-specific questions.
FEDERAL COMPLIANCE AND LABOR STANDARDS
The SRA between PRDOH and the Subrecipient requires the Subrecipient to follow all applicable Federal regulations in the use of CDBG-DR/MIT funds.
All activities funded with CDBG-DR funds must meet one of the CDBG-DR Program’s national objectives, as defined in 24 C.F.R. § 570.208:
• benefit low-and moderate-income persons (LMI);
• aid in the prevention or elimination of slums or blight (SB), and/or
• meet community development needs having a particular urgency (UN).
The Subrecipient shall ensure that the services meet the applicable CDBG-DR national objective(s) and that Subrecipient’s contractors complete the applicable forms to document the national objective(s). The following documents aid Subrecipients with National Objectives compliance:
Failure to complete/ demonstrate completion of National Objectives could result in recapture of disbursed funds by PRDOH.
The environmental review process is required for all HUD-assisted projects to ensure that the proposed project does not negatively impact the surrounding environment and that the property site itself will not have an adverse environmental or health effect on end users. Not every project is subject to a full environmental review, but every project must be in compliance with the National Environmental Policy Act (NEPA), and other related Federal and state environmental laws.
For more information and to access environmental assessments that have been carried out under the CDBG-DR Program, press the following link:
DAVIS-BACON AND RELATED ACTS
The CDBG-DR Program and its subrecipients, contractors, subcontractors, and subrecipient’s contractors are subject to the requirements of the Davis-Bacon and related Acts (DBRA) as applicable which guarantee fair wages, benefits, and overtime to employees while working on government-funded construction, alternation, or repair projects in excess of $2,000.
For additional information, please follow this link to the DBRA section of the CDBG-DR Program.
PRDOH CDBG-DR Program and its subrecipients, regulations contractors, subcontractors, and subrecipient’s contractors are subject to the requirements of Section 3 of the Housing and Urban Development Act of 1968, as amended, to provide training, employment, and contracting opportunities to low- and very-low income persons and businesses, particularly those who are recipients of government assistance for housing or residents of the community in which the Federal assistance is spent, to the greatest extent feasible.
For additional information, please follow this link to the Section 3 section of the CDBG-DR Program.
As a recipient of HUD financial assistance, set forth in 2 C.F.R. § 200.321 require that PRDOH take necessary steps to ensure that all Subrecipients, contractors, subcontractors, and/or developers funded in whole or in part with CDBG-DR funds ensure that, when possible, contracts and other economic opportunities are directed to small and minority firms, women-owned business enterprises and labor surplus area firms.
For additional information, please follow this link to the M/WBE section of the CDBG-DR Program.