Reduce the Burden on Limited Administrative Dollars 2017 NCDA Conference 48th Annual Training Conference June 2017

Are Administrative Costs Wearing You Down? Here are some suggestions to help with that!

Direct Charge Costs to Specific Projects When Possible For example, ensure that staff working on project-related environmental reviews are able to charge their time as a project cost and not charge general administration. Allocate staff costs to activity delivery and project implementation e.g. procuring architects, bidding construction contracts, managing contractors, labor compliance monitoring. Offset some of the costs of managing subrecipients by creating and charging to technical assistance/capacity building projects.

570. 201(p) Technical assistance 570.201(p) Technical assistance. Provision of technical assistance to public or nonprofit entities to increase the capacity of such entities to carry out eligible neighborhood revitalization or economic development activities. (The recipient must determine, prior to the provision of the assistance, that the activity for which it is attempting to build capacity would be eligible for assistance under this subpart C, and that the national objective claimed by the grantee for this assistance can reasonably be expected to be met once the entity has received the technical assistance and undertakes the activity.) Capacity building for private or public entities (including grantees) for other purposes may be eligible under §570.205. This provision makes eligible the use of CDBG funds to increase the capacity of public or nonprofit entities to carry out eligible neighborhood revitalization or economic development activities. Note: While building capacity of an entity under this authority provides an alternative to using the authority under the category of Planning and Administration (and thus can help avoid a problem with exceeding the 20% cap), the program does not provide a presumption concerning national objective compliance - important that this be considered before charging costs under this category. Prior to providing the assistance, the eligibility of the activity for which capacity is to be built and that there is a reasonable expectation that a national objective can be met once the entity has received the technical assistance and undertakes the activity.

Factors to consider to meet the national objective: Nature of the organization receiving the assistance Type and eligibility of the activity to be carried out Location of the activity Entity’s expected (or traditional) clientele Based on a review of these factors, the grantee should have a reasonable expectation that the activity to be undertaken by the entity would comply with a national objective before funding capacity building.

Sample Technical Assistance Project Structure Project No. Description CBLMA0 Capacity building for projects serving low-mod  areas CBLMC0 Capacity building for projects serving low-mod  clientele CBLMH0 Capacity building for projects serving low-mod  housing CBLMJ0 Capacity building for projects providing jobs in low-mod  areas CBSBA0 Capacity building for projects serving slum/blight areas

These costs are not subject to the 20% cap. 570.202(a)(9) Rehabilitation services, such as rehabilitation counseling, energy auditing, preparation of work specifications, loan processing, inspections, and other services related to assisting owners, tenants, contractors, and other entities, participating or seeking to participate in rehabilitation activities authorized under this section, under section 312 of the Housing Act of 1964, as amended, under section 810 of the Act, or under section 17 of the United States Housing Act of 1937. Costs of performing the assessment and related public notices as required under 24 CFR part 58 are considered to be “activity delivery costs.” Alternately, it should be noted, that the regulations allow charging these costs under §570.205. Generally not desirable for a grantee if it is at or near its 20% cap to elect this alternative. Thus part of the costs of carrying out the activity under the same basic eligibility category applicable to that activity. Costs charged as “project delivery” must be reasonable relative to project cost/accomplishments – 20% These costs are not subject to the 20% cap.

Factors to consider for residential rehabilitation: Where environmental assessment costs incurred with respect to an activity would create a problem for that activity, it may be preferable to charge that cost to the category of Planning and Admin. A grantee may prefer to charge all of its environmental assessment costs to §570.205 for administrative convenience, so as to avoid the need to share the costs of one or more staff persons performing the assessments.

How About Some Tools To Help With those Admin Costs!

Tool No. 1

Tool No. 2

Some other ideas…. Always look for ways to improve efficiency in operations and process…an admin dollar saved is an admin dollar earned Eliminate redundancy and overlapping functions Automate processes from paper to electronic e.g. contracting, correspondence, payment processing. Where staff are working on non-federal projects, make sure costs are properly allocated to those projects as well. Assess core functions and eliminate mission creep and non-essential activities. Trade the Cadillac for the VW budget…focus on minimum needs for meeting mandates.

QUESTIONS Scott Stevenson Director County of Los Angeles Community Development Commission – Community Development Division