Sneak Preview: HUD, FEMA Issue Guidance on New Flexible Match Concept

(The following was excerpted from a recent Thompson Grants 360 article.) The Department of Housing and Urban Development (HUD) and the Federal Emergency Management Agency (FEMA) recently issued joint guidance discussing a new “flexible match” concept for applicants and recipients receiving funding under both HUD’s Community Development Block Grant disaster recovery (CDBG-DR) program and FEMA’s Public Assistance (PA) program.

The PA program requires that the costs of any PA-funded project be shared by the federal government in partnership with states, tribes and local governments or certain eligible nonprofit organizations. Typically, the federal share of such a project is no less than 75% of the total project costs, while the PA applicant, either a recipient or subrecipient, must pay a 25% nonfederal (i.e., local) match.

HUD’s Community Development Block Grant (CDBG) program, as well as the CDBG-DR program, authorizes the use of these program funds to meet the local match requirements of other federal programs. “In recognition of the changing scale, nature and frequency of disasters that can place an increasingly heavy burden on PA applicants,” entities may use CDBG funds made available for disaster recovery purposes to pay the local match requirement for PA-funded projects, the guidance explains.

The guidance discusses how the flexible match can be used to satisfy the local match. Typically, a PA-funded project will encompass multiple facilities or sites (e.g., all of the elementary schools within a community or multiple road segments across a locality). Under the traditional match concept, CDBG-DR funds are applied as local match to the entire PA project plan, and all work within the project is subject to both PA and CDBG-DR eligibility and compliance requirements.

However, when opting for a flexible match, a PA applicant can choose to apply its CDBG-DR funding to distinct facilities or sites within a PA project (e.g., one specific school). While all of the sites and facilities under the award still must comply with FEMA PA requirements, only the CDBG-DR-assisted portion of the project must comply with CDBG-DR requirements. “In this way, applying the flexible match concept can reduce the number of facilities or sites within the subaward that must comply with both federal grant program requirements,” according to the guidance.

(The full version of this story has now been made available to all for a limited time here.)

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