Recordkeeping and Data Management

DED will collect data through two primary methods:

• Data and information sharing with State partners; and
• Direct data collection from Successful Applicants and Subrecipients. Data will be maintained in AmpliFund, which is the CDBG-DR program’s primary system of record.

Subrecipients and Successful Applicants should establish and maintain at least five major categories of records. Questions and points of clarification regarding these recordkeeping systems should be directed to DED.

• Administrative;
• Financial;
• Project;
• Reports; and
• Close-Out.

For each CDBG-DR-funded activity, records must contain reliable and up-to-date information. At a minimum, the records must include:

• Copy of the associated SRAs between DED and the Subrecipient or funding agreement between DED and the Successful Applicant;
• Full description of activities undertaken assisted with CDBG-DR funds;
• Documentation that all activities undertaken meet at least one of the criteria for National Objectives, as set forth in 24 CFR § 570.208;
• Documentation of determination of eligibility of all activities;
• Documentation of compliance with citizen participation requirements, where applicable;
• Documentation of acquisition, improvement, use, or disposition of real property acquired or improved with CDBG-DR assistance;
• Documentation of compliance with all applicable HUD cross-cutting requirements (such as Environmental Review, Davis-Bacon, Section 3);
• Financial records as required by 2 CFR Part 200, 24 CFR § 570.502, and State requirements, which include:
  • Current authorizations and obligations of CDBG-DR funds;
  • Unobligated balances (funds remaining available for distribution);
  • Assets and liabilities;
  • Program income, if any;
  • Actual outlays or expenditures, with a breakdown of the grant program the funds were derived from;
  • Clear evidence indicating the use of program funds belongs to the eligible activity; and
  • Evidence each expenditure is necessary, reasonable, and directly related to the project.

Furthermore, for each CDBG-DR funding award, each organization must have the accounting records:

• Chart of accounts, which includes general assets, liabilities, expenses and revenues;
• Cash receipts and disbursement journal;
• Payroll journal;
• General ledger; and
• Original contracts and procurements.

In addition to the above requirements, construction project files must also contain the following information:

• Full description of the project;
• Project budget;
• Evidence of obligated and committed funding (all sources);
• Work specifications;
• Bid documents, including the RFP, cost estimate, evidence of contractor solicitation, scoring, evidence of non-debarment, and selection;
• Davis-Bacon prevailing wage determination;
• State prevailing wage determination;
• Weekly payroll certifications and back up documentation;
• Payroll deduction authorizations;
• Employee field interviews;
• Progress and final inspections, including documentation of the Subrecipient’s or Successful Applicant’s periodic on-site inspections and final inspection;
• Change orders, including evidence of necessity and approval prior to work being completed;
• All correspondence related to construction; and
• Progress and final disbursements records. Files must contain documentation that payments were paid only for completed work, and data in the project file must agree with the project financial records.

Each project or case file should include documentation of the National Objective being met, the characteristics and location of beneficiaries, the eligibility of the activity, the compliance with special program requirements, the allowability of the costs, and the status of the case/project.

Although the specific documentation maintained may vary depending on the type of project or activity (e.g., infrastructure, housing), Subrecipients and Successful Applicants must maintain comprehensive, up-to-date project files. The files should cover all aspects of the project, beginning with application, eligibility, and cost allowability and ending with program closure. Subrecipients and Successful Applicants must keep files that contain PII and sensitive PII, such as social security numbers, in a secure place.

Subrecipients and Successful Applicants are specifically required to maintain, at a minimum, the following files:

• Executed SRAs / funding agreements (as applicable);
• Documentation of compliance with cross-cutting requirements in project files (e.g., Davis-Bacon, Uniform Relocation Act, and Lead-Based Paint), as described in the CDBG-DR Manual; and
• DED monitoring correspondence.

AmpliFund

Subrecipients and Successful Applicants will have an account in DED’s grants, management system, AmpliFund. This account will be used throughout the lifecycle of their application or award.

On-Site

In order to meet federal and state requirements, Successful Applicants and Subrecipients are required to maintain a full and current set of all program-related documents at their primary office location and available upon request. This includes maintaining compliance with the following:

• Successful Applicants and Subrecipients are responsible for maintaining all CDBG-DR files on-site at the Subrecipient’s or Successful Applicant’s customary place of business, available for review upon request by DED or other entities. Successful Applicants and Subrecipients must be familiar with and adhere to all regulations of FOIA, as appropriate; and

Successful Applicants and Subrecipients must designate a person responsible for records management. If the Subrecipient or Successful Applicant relies on an electronic recordkeeping system, contingency plans for data recovery and access must be part of their policies and procedures.

For each CDBG-DR-funded activity, records must contain reliable and up-to-date information. At a minimum, the records must include:

• Copy of the associated SRAs between DED and the Subrecipient or funding agreement between DED and the Successful Applicant;
• Full description of activities undertaken assisted with CDBG-DR funds;
• Documentation that all activities undertaken meet at least one of the criteria for National Objectives, as set forth in 24 CFR § 570.208;
• Documentation of determination of eligibility of all activities;
• Documentation of compliance with citizen participation requirements, where applicable;
• Documentation of acquisition, improvement, use, or disposition of real property acquired or improved with CDBG-DR assistance;
• Documentation of compliance with all applicable HUD cross-cutting requirements (such as Environmental Review, Davis-Bacon, Section 3);
• Financial records as required by 2 CFR Part 200, 24 CFR § 570.502, and State requirements, which include:
  • Current authorizations and obligations of CDBG-DR funds;
  • Unobligated balances (funds remaining available for distribution);
  • Assets and liabilities;
  • Program income, if any;
  • Actual outlays or expenditures, with a breakdown of the grant program the funds were derived from;
  • Clear evidence indicating the use of program funds belongs to the eligible activity; and
  • Evidence each expenditure is necessary, reasonable, and directly related to the project.

Furthermore, for each CDBG-DR funding award, each organization must have the accounting records:

• Chart of accounts, which includes general assets, liabilities, expenses and revenues;
• Cash receipts and disbursement journal;
• Payroll journal;
• General ledger; and
• Original contracts and procurements.

In addition to the above requirements, construction project files must also contain the following information:

• Full description of the project;
• Project budget;
• Evidence of obligated and committed funding (all sources);
• Work specifications;
• Bid documents, including the RFP, cost estimate, evidence of contractor solicitation, scoring, evidence of non-debarment, and selection;
• Davis-Bacon prevailing wage determination where applicable;
• State prevailing wage determination;
• Weekly payroll certifications and back up documentation;
• Payroll deduction authorizations;
• Employee field interviews;
• Progress and final inspections, including documentation of the Subrecipient’s or Successful Applicant’s periodic on-site inspections and final inspection;
• Change orders, including evidence of necessity and approval prior to work being completed;
• All correspondence related to construction; and
• Progress and final disbursements records. Files must contain documentation that payments were paid only for completed work, and data in the project file must agree with the project financial records.

Each project or case file should include documentation of the National Objective being met, the characteristics and location of beneficiaries, the eligibility of the activity, the compliance with special program requirements, the allowability of the costs, and the status of the case/project.

For each CDBG-DR-funded activity, records must contain reliable and up-to-date information. At a minimum, the records must include:  

• Copy of the associated SRAs between DED and the Subrecipient or funding agreement between DED and the Successful Applicant; 

• Full description of activities undertaken assisted with CDBG-DR funds; 

• Documentation that all activities undertaken meet at least one of the criteria for National Objectives, as set forth in 24 CFR § 570.208; 

• Documentation of determination of eligibility of all activities; 

• Documentation of compliance with of citizen participation requirements, where applicable; 

• Documentation of acquisition, improvement, use, or disposition of real property acquired or improved with CDBG-DR assistance; 

• Documentation of compliance with all applicable HUD cross-cutting requirements (such as Environmental Review, Davis-Bacon, Section 3); 

• Financial records as required by 2 CFR Part 200, 24 CFR § 570.502, and State requirements, which include:  

• • Current authorizations and obligations of CDBG-DR funds; 

  • Unobligated balances (funds remaining available for distribution); 

  • Assets and liabilities; 

  • Program income, if any; 

• • Actual outlays or expenditures, with a breakdown of the grant program the funds were derived from; 

  • Clear evidence indicating the use of program funds belongs to the eligible activity; and 

  • Evidence each expenditure is necessary, reasonable, and directly related to the project. 

Furthermore, for each CDBG-DR funding award, each organization must have the accounting  records:  

• Chart of accounts, which includes general assets, liabilities, expenses and revenues; 

• Cash receipts and disbursement journal; 

• Payroll journal; 

• General ledger; and 

• Original contracts and procurements. 

In addition to the above requirements, construction project files must also contain the following information:  

• Full description of the project; 

• Project budget; 

• Evidence of obligated and committed funding (all sources); 

• Work specifications; 

• Bid documents, including the RFP, cost estimate, evidence of contractor solicitation, scoring, evidence of non-debarment, and selection; 

• Davis-Bacon prevailing wage determination where applicable; 

• State prevailing wage determination; 

• Weekly payroll certifications and back up documentation; 

• Payroll deduction authorizations; 

• Employee field interviews; 

• Progress and final inspections, including documentation of the Subrecipient’s or Successful Applicant’s periodic on-site inspections and final inspection; 

• Change orders, including evidence of necessity and approval prior to work being completed; 

• All correspondence related to construction; and 

• Progress and final disbursements records. Files must contain documentation that payments were paid only for completed work, and data in the project file must agree with the project financial records. 

Each project or case file should include documentation of the National Objective being met, the characteristics and location of beneficiaries, the eligibility of the activity, the compliance with special program requirements, the allowability of the costs, and the status of the case/project.

DED expects direct data and information sharing to be used as a component of all programs, and particularly the Infrastructure Match Program, Affordable Housing Construction Program, and Risk Awareness Planning Program.

Quarterly Performance Reports

HUD requires submission of performance reports that are due on a quarterly basis, which are predominantly managed through Quarterly Performance Reports (QPRs) to capture the progress of CDBG-DR grant activities. As Grantee, DED reports on activities it directly administers and uses data collected and submitted by Subrecipients and Successful Applicants to submit QPRs through the DRGR system on a set, quarterly schedule. Much of the data in a QPR is automatically generated by AmpliFund, but each report requires the DED Program Manager to write one or two sentences for the Activity Progress Narrative.

The QPR must relate back to the activities expressed in the CDBG-DR approved application. The QPR must accomplish the following: 

• Update Subrecipient/Successful Applicant race/ethnicity and income data, if applicable;

• Report baselines (one time only) and update values per the frequency outlined in the Action Plan (Outcome Value Activities  only);

• Update performance measures as accomplishments are made;

• Report CDBG-DR expenditures;

• Report direct leverage expenditures;

• Report supporting leverage expenditures;

• Enter progress narrative; and

• Enter the actual completion date (when the activity is completed).

DED, implementation and partners, Subrecipients, and Successful Applicants shall take reasonable steps to ensure that all data collected through the CDBG-DR program is managed in compliance with the Privacy Act of 1974, as amended, and other federal privacy-related laws, guidance, and best practices.

DED will collect CDBG-DR data through its grant management system, AmpliFund. The GMS is designed to provide government-level security of all data, including PII. The Subrecipient Agreement SRAs or funding agreement Template details that Subrecipients and Successful Applicants are required to secure any PII they collect. 

If the Subrecipient and Successful Applicant relies on an electronic recordkeeping system, contingency plans for data recovery and access must be part of their policies and procedures.

Retention is a crucial piece of the overall information management strategy. Files must be complete, accurate, and orderly and should portray the program’s life, from its inception to its completion. DED maintains all records CDBG-DR Successful Applicants and Subrecipients do not manage. Successful Applicants and Subrecipients maintain project-related documentation, including financial records, supporting documents, and statistical records associated with grant funds as established in this P&P, for three years after DED closes the contract with HUD. The record retention period for Subrecipients and/or Successful Applicant does not begin when the SRA funding agreement between the Subrecipient and/or Successful Applicant and State is closed.

For each CDBG-DR funding award, each organization must have the following:

• Chart of accounts, which includes general assets, liabilities, expenses and revenues;
• Cash receipts and disbursement journal;
• Payroll journal;
• General ledger; and
• Original contracts and procurements.

To ensure DED retains a complete record of information related to the CDBG-DR Program, DED will orchestrate file transfers from the Subrecipient and Successful Applicant to DED. DED will articulate the standard processes for file transfer within the SRA or funding agreement, as well as within the Closeout Checklist. File transfer will be conducted throughout program implementation, as Subrecipients and Successful Applicants will be required to provide supporting documentation and related contracts in order to complete draw requests. Ongoing file transfer will also be reviewed during the QPR process and associated monitoring process, which captures aspects of programmatic implementation and compliance. While file transfer is ongoing throughout program implementation, Successful Applicants and Subrecipients are responsible for record retention during the agreement or contract period.

Further, their obligations do not end until all closeout requirements are completed. Important aspects of agreement/contract closeout activities include:

• Determining how files are transferred from the Subrecipient and/or Successful Applicant to DED at the end of the agreement/contract period;
• Providing guidance outlining closeout requirements, six months prior to the agreement/contract closeout; and
• Turning over programmatic records, reports, documents, or any other material resulting from CDBG-DR funded programs, projects, or activities to DED at the conclusion or termination of the contract, or earlier, at DED’s discretion.