Financial policies

9. CDBG reprogramming policies

Sixty days prior to end of a program year, HUD requires the City to have a CDBG line of credit balance no more than 1.5 times its current program year CDBG budget allocation. Reprogramming of CDBG project funds may be necessary to meet this requirement. Reprogramming is required in cases of a project being found ineligible for CDBG.

There are four sources for reprogramming funds:

1. Unspent annual administrative appropriations,
2. Unspent and not legally obligated public service funds over two years old,
3. Cancelled, ineligible or unspent capital funds over four years old,
4. Program income.

9.1 Administrative allocations

The intent of the reprogramming policy is to limit administrative fund expenditures to the amount that was appropriated for that calendar year, regardless of the amount that is available from the grant balances. The limitation applies to the City Department’s non-contractual, internal costs. Funds that are allocated to grant recipients for administrative purposes are exempt from this provision (e.g.: Legal Aid, Public Housing Citizen Participation). These projects are legal obligations and do not become part of the administrative reprogramming calculation unless the projects were finalized without fully expending the funds.

9.2 Public service allocations

The amounts that are awarded from and appropriated for public service activities expire two years from the original award date for that CDBG program year that starts on June 1. The Department may roll over appropriations from the prior year, as needed to carry out these activities. After two years, any unspent amounts and those that are not legally obligated are available for reprogramming and will be referred to the reprogramming process.

9.3 Program income

Program income not obligated by existing contracts is available for reprogramming. Projects with a twelve-month period of inactivity shall be cancelled if the project has been authorized for more than three years.