POST-AWARD COMPLIANCE CHECKLIST

HUD Lead Hazard Control and Healthy Homes Grant: Compliance Requirements

What you must do after you win this award — administered by US Department of Housing and Urban Development · Federal Program.

7
Total requirements
4
Clawback-risk items
7
Deadline-bound

⚠ Common Disallowed-Cost Pitfalls

  • Procurement & Vendor Rules: Work performed by uncertified contractors is ineligible and costs will be disallowed
  • Recordkeeping: Inability to produce records during audit triggers questioned costs and potential disallowance
  • Financial & Cost Eligibility: Administrative costs exceeding 10% are unallowable and subject to clawback
  • Financial & Cost Eligibility: Non-compliant costs are unallowable per 2 CFR 200 Subpart E
  • Reporting: Failure to report may trigger suspension of funds or award termination
  • Labor & Wage: Non-compliance may result in corrective action requirements and potential cost disallowance

Reporting

  • HighQuarterly

    Submit progress reports using HUD Form 96006 (electronic equivalent) documenting grantee program progress and unit production data.

    Deadline: As specified in grant agreement

    Source: Federal Register OMB 2539-0008, September 7, 2022

Financial & Cost Eligibility

  • Clawback riskOngoing

    Limit program administrative costs to no more than 10% of total HUD grant funding amount.

    Deadline: Throughout grant performance period

    Source: Green & Healthy Homes Initiative OLHCHH program guidance

  • Clawback riskQuarterly

    Submit Federal Financial Reports (FFR) and comply with 2 CFR Part 200 Uniform Guidance cost principles for all expenditures.

    Deadline: Quarterly and annual as specified in grant agreement

    Source: 2 CFR 200.328, 200.329; HUD Grants Management Handbook

Procurement & Vendor Rules

  • Clawback riskOngoing

    Use only EPA-certified lead-based paint contractors, inspectors, and risk assessors trained through an EPA authorized program for all lead hazard control work.

    Deadline: All project work must use certified contractors

    Source: 40 CFR 745; Federal Grants Wire program description

  • MediumOngoing

    Follow 2 CFR 200.321 affirmative procurement steps to ensure small and minority businesses, women's business enterprises, and labor surplus area firms are used when possible.

    Deadline: All procurement actions during award period

    Source: 2 CFR 200.321; HUD Grants Management Handbook 2210.17

Labor & Wage

  • HighOngoing

    Comply with Section 3 economic opportunities requirements if LHCHH funding exceeds $100,000, ensuring targeted hiring and contracting for low-income residents.

    Deadline: Throughout project performance period

    Source: HUD Exchange Section 3 Guidebook for OLHCHH programs

Recordkeeping

  • Clawback riskOngoing

    Retain all financial records, supporting documents, statistical records, and award-related records for a minimum of three years from the date of submission of the final expenditure report.

    Deadline: 3 years from final expenditure report submission

    Source: 2 CFR 200; HUD Grants Management Handbook 2210.17 Chapter 4

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This checklist is compiled from official program sources and general grant-management rules for informational purposes. Final compliance obligations are governed by your specific grant agreement and the administering agency — always verify with US Department of Housing and Urban Development.