1. Tips for Reporting Timely and Accurate CDBG Data in IDIS
NCDA Winter Conference
February 17, 2017

2. HUD Requires CDBG Data that are
• Complete
• Accurate
• Timely
Thanks for inviting me to talk about my favorite subject, complete and accurate reporting in IDIS. This subject is not only for data enter staff but is just as important for directors and managers and program staff at the state and local level. Program staff must be just as knowledge about the data requirements for the CDBG activities they are carrying out so that they can ensure that complete and accurate data are collected for each of their activities.

3. Why IDIS Data Are Important
Demonstrate Compliance
Provide Transparency and Accountability
Incorporate in government-wide and department-wide reports. Respond to frequent requests from
the White House,
OMB,
Congress,
GAO,
OIG,
HUD Secretary  
and other stakeholders
Demonstrate the contributions each of our grantees are making toward meeting the needs of LMI citizens
IDIS data are very important for a number of reasons. IDIS is the only place where we can justify the existence of the CDBG program. With idis data we can demonstrate compliance with program requirements and prvide transparency and accountability on how we are using taxpayers money. These data are featured in reports and websites and are used to respond to frequent requests from our many stakeholders. Most importantly idis data demonstrate the contributions each of our grantees are making toward meeting the needs of its low and moderate income residents. You all do wonderful work in helping those who are less fortunate than others in our country. IDIS is the only place that where you can tell your story.

4. Tip #1: Report as Frequently as Possible
When to Report
As benefits are realized
Quarterly recommended
Annual reporting is required
Understand Data Needs Upfront
Since we are generally asked by our stakeholders for up to the minute data on the CDBG program, it is always good from our point of view for grantees to frequently update their data. Thus, providing us with constantly increasing accomplishment numbers. However, we realize it is not always possible to provide us with accomplishment,beneficiary, and performance measurement data as they are achieved. We do recommend quarterly reporting and annual reporting is required. It is important to understand the data needs upfront for each activity you are carrying out with cdbg funds, so that your data will not only be timely but also complete. Data requirements and their due dates should be included in all agreements with subrecipients and by grantee staff directly carrying out activities.
when grantees put off reporting: it gets overlooked/forgotten as one gets pulled into other urgent issues, and eventually the activity gets flagged in IDIS, or more time goes by, staff turn over, old files get thrown out/lost…and then it gets questioned in an OIG audit as not meeting a national objective and the grantee has no way to prove that it did.  So it has to be paid back.

5. Tip # 2: What to Report All benefits realized during Program Year
Eligible Activity/National Objective compliance
Accomplishment and beneficiary data
Performance measurements
Leveraging
Report complete information for each activity

6. Tip # 3: Enter the Place of Performance for the Activity Address
Not the address of the administrative offices
For infrastructure activities, use a street address range
Housing activities with multiple sites
No P.O. Boxes
Do not enter the address of the department or organization carrying out the activity. Report the address where that activity is actually being carried out.

7. Tip # 4: Set up Housing Activity
Include physical address
Single unit structure: can be aggregated in one activity
HUD encourages separate IDIS Online activity for each address
Multi-unit structure: one activity per structure
For privacy, do not use individual family names in Activity Name
Report accomplishments each year
For multi-units housing, one activity needs to be set up for each building, unless the buildings are located on the same or contiguous properties and under common ownership and management.

8. Tip # 5: Report Accomplishments for Some Housing Admin & Services Activities
Housing Rehabilitation Administration 14H
Housing Services 14J
Activity
Actual Rehab Costs Paid With…
Report Accomplishments in IDIS?
Housing Rehab Admin (14H)
CDBG
Generally Reported Under Other Activities
Non-CDBG
Yes
Housing Services (14J)
HOME
We think this is where we lose a lot of our housing data. When the CDBG program is funding the activity delivery costs for rehab or other housing activities and where the actual work is funded by other sources, then accomplishments must be reported in the CDBG rehab admin or housing services activity, otherwise the CDBG program will not get credit for its part in funding the rehabilitation.

9. Tip # 6: Correctly Report Certified Energy Star Units
High Priority Performance Goal
Gut rehabilitation or new construction; not replacement windows, insulation, appliances
Must be certified by an Energy Star inspector
Energy Star Performance Standards for Buildings at

10. Tip # 7: Report Accurate Data for Public Facilities & Improvements Activities
Use most specific “03” matrix code to accurately describe use of funds
Avoid combining different public facilities under one activity
Report performance measures when activity completed/benefit realized
Strive to report unduplicated persons served

11. Tip # 8: Report Accurate Data for Public Services Activities
Use most specific matrix code to accurately describe use of funds
Insert a new program year for multiyear activities
Strive to report unduplicated persons served

12. Tip #9: Report Accurate Income Level Data for Direct Benefit Activities
CDBG Statute requires that moderate-income persons are not benefited to the exclusion of low-income persons
Do not report all beneficiaries as moderate income

13. Report Beneficiary Data for Presumed Benefit Activities
Abused Children
Extremely Low Income
Battered Spouses
Low Income
Severely Disabled Adults
Homeless Persons
Illiterate Adults
Persons with AIDS
Migrant Farm Workers
Elderly
Senior center – Mod Income
Not Center based – Low Income

14. Tip # 10: Correctly Report Data for Economic Development Activities
Direct financial assistance to for-profits
Separate activity for each business assisted
Do not aggregate
Report Jobs in correct program year
Report jobs only once each program year

15. Tip # 10: Enter Leveraging Data
High degree of interest among stakeholders
Demonstrates that CDBG funds generate additional investment in communities
Accurate-Grantees in California, Michigan, and Montana do not receive ARC funds

16. Tip #11: Report Program Income
Creating Receipts
Identify IDIS activity ID that generated the program income
Do not associate CDBG receipts with Activity 2
Create receipt when program income is received
How often do I need to receipt income into the system? General rule, you create receipt when program income is received. You need to remember HUD’s rule: use program income before drawing additional funds. Given this, you need to incorporate the receipts process into the drawdown process. Before doing a drawdown, you must create a receipt for any program income you have on hand.

17. Grantees need to monitor IDIS Data Quality
Poor quality, incomplete data under-report or misrepresent program results
Public, HUD, Congress can see program results via HUD web reports generated from data entered into IDIS
Grantees can use IDIS data to assess their CDBG program performance
when data is missing or inaccurate:  Audit findings, monitoring findings, citizen complaints about misuse of funds or even claims of discrimination.  In short, Negative Attention!  Which then requires damage control.

18. Helpful Tools
IDIS resources for the CDBG program:
Review IDIS reports:
Performance Profiles PR54
Expenditure Reports PR50
Selected Accomplishments PR51
Performance Measurement Report PR83
Training materials include guidance that recaps most of the tips in my presentation.

19. Section 108 Loan Guarantee Reporting

20. Activities Using 108 Guarantee Funds
Setup of activities using 108 Guarantee very similar to other CDBG activities
Will this activity use Section108 loan?
If yes, only 108-eligible matrix codes listed
Loan must be loaded/added into IDIS to fund
New Fund Type: Section 108 Loan (SL) and Section 108 Loan Income (SI)
Draw Vouchers approved by HUD
HUD added three Section 108 specific matric codes into IDIS, 24A –payment of interest on the section 108 loan, 24B payment of costs of section 108 financing, and 24C Debt services. In addition to these three matrix codes, grantees will use any matrix codes relevant to the activities being carried out with Section 108 loan proceeds.
AT the beginning of FY2014, HUD uploaded information into IDIS for section 108 loans that have not been fully paid. HUD HQ will add any new loans that have been approved.
108 loan recipients submit drawdown requests via IDIS to track loan advances. However, unlike the regular CDBG funds, the Section 108 funds are not provided through the Line of Credit Control System (LOCCS), but rather are advanced by the Section 108 Program’s Fiscal Agent. The Section 108 recipients will also need to submit advance request to the Financial Management Division (FMD) directly. The fiscal Agent then advances funds to a recipient’ designated bank account.

21. Activities using 108 Guarantee Funds (cont’d)
Accomplishments and performance outcomes are required
Set up repayment activity for the term of loan if EN or SI funds are used.
Repayment activities should be updated to “Completed” after each program year
Grantees are required to report accomplishment and performance outcomes for the activities that funded with Section 108 funds. Grantees will follow the CDBG rules to report accomplishments and performance outcomes for the section 108 activities. When all the advances have taken place, a national objective has been met, and all accomplishments have been reported, the grantee should update activity status to “Completed” in IDIS.

22. Section 108 Guarantee Receipts
New Fund Type: Section 108 income (SI)
SI funds can only be used for financing and repayment activities:
19F Planned Repayment of Principal
19G Unplanned Repayment of Principal
24A Payment of interest on Section 108 loans
24B Payment of costs of Section 108 financing
24C Debt service reserve
Receipt is tied to IDIS activity that generated the income.

23. Sample IDIS Structure of 108 Loan Guarantee info
Section 108 Project
Activity #201
ED Loan: Medical Business Park
18A
Activity #202
Debt Service
Reserve
24C
Activity #203
108 Unplanned Repayment
19G
Activity #204
108 Planned Repayment
19F/24A
Fund Type: SL
Fund Type: SL
Fund Type: EN
Fund Type: SI
Drawn as needed; HUD approval
Drawn as needed; HUD approval
Drawn as needed; NO HUD approval
Drawn as needed; HUD approval

24. “-OLD Loans” Loans Advance Prior to October 1, 2013
Set up an activity under the Section 108 project(s)
“Complete” activity if a national objective has been met
Only need to fund an activity, IDIS will generate a voucher to match funded amount
Report cumulative accomplishments for the program year when the activity was completed
Loan number with suffix “OLD” were added for the loan loans that were advance prior to October 1, 2013 and the grantee is still receiving section 108 program income (SI) or is still repaying the “OLD” loan.