Michigan Community Development Block Grant: Compliance Requirements

Grantee must submit a Consolidated Annual Performance and Evaluation Report (CAPER) to HUD reporting all project activities, expenditures, beneficiaries served, and compliance results for the program year.

Deadline: CAPER must be submitted to HUD annually within timeframe specified by HUD (typically 90 days after fiscal year end)

Source: 24 CFR 570.507; MEDC CDBG GAM; HUD Playing by the Rules Chapter 5

Grantee must maintain a financial accounting system documenting compliance with federal statutes, regulations, and grant terms to permit preparation of required reports and tracing of funds to expenditure levels adequate to establish proper use of funds.

Deadline: System must be maintained continuously throughout grant period and during closeout

Source: MEDC CDBG GAM Chapter 8 (Financial Management); 24 CFR 570.503; 2 CFR 200.302

Grantee expending $750,000 or more in federal awards in a fiscal year must obtain a single audit performed in accordance with 2 CFR Part 200 Subpart F and submit audit to Federal Audit Clearinghouse within nine months of fiscal year end.

Deadline: Single audit must be performed and submitted to Federal Audit Clearinghouse no later than 9 months after fiscal year end

Source: 2 CFR 200 Subpart F (Audit Requirements); MEDC GAM; MSHDA Policy Manual

Grantee must complete and submit monthly or quarterly progress reports tracking project accomplishments, obligations, expenditures, and beneficiaries served against approved budget and project schedule.

Deadline: Progress reports due to grantee/state on regular schedule (typically monthly or quarterly) as specified in grant agreement and subrecipient agreement

Source: HUD Playing by the Rules Chapter 5; MEDC CDBG GAM reporting requirements; 24 CFR 570.507

Grantee must obtain MSHDA approval of procurement method and documents before executing any procurement process; all procurements must comply with competitive bidding standards in 2 CFR 200.319 and maintain documented procurement records.

Deadline: Approval from MSHDA must be obtained before procurement execution; condition of fund disbursement

Source: MSHDA CDBG Policy Manual Chapter 11 (Procurement); 2 CFR 200.318-200.320; MEDC GAM Chapter 4

For construction projects, grantee must include Davis-Bacon prevailing wage provisions in all construction contracts, require certified weekly payrolls from contractors, and conduct compliance monitoring of wage payments.

Deadline: Wage clauses required in all construction contracts; certified payrolls collected weekly during construction; reviewed upon project completion

Source: Davis-Bacon Act; 24 CFR 570.603; HUD Playing by the Rules Chapter 4; CLA guidance on common CDBG audit findings

Grantee must complete environmental review and receive written approval before incurring project costs or acquiring rights-of-way; project cannot proceed without grant agreement signed and environmental clearance documented.

Deadline: Environmental review must be completed and approved before any project costs incurred or procurement executed

Source: 24 CFR 570.601; MEDC CDBG GAM Chapter 4; environmental review requirements

Grantee must retain all CDBG program records for minimum of three years beyond grant closeout, including contracts, financial records, compliance documentation, and rehabilitation project files.

Deadline: Records must be accessible and retained for 3 years after grant close-out; longer periods recommended for protection against OIG audits

Source: 24 CFR 570.502; 2 CFR 200.334; HUD Playing by the Rules Chapter 5

Grantee receiving federal subawards of $30,000 or more must file a FFATA (Federal Funding Accountability and Transparency Act) subrecipient award report within 30 days of making the subaward.

Deadline: Report must be filed within 30 days of the end of the month in which subaward of $30,000+ is made

Source: 2 CFR 170; HUD guidance on FFATA reporting; CLA guidance on common CDBG findings

Grantee must conduct pre-rehabilitation and post-rehabilitation inspections on all CDBG-assisted rehabilitation projects to verify deficiencies were identified and properly corrected before project closeout.

Deadline: Pre-inspection before rehabilitation begins; post-inspection upon completion; documentation must be retained

Source: HUD Playing by the Rules Chapter 5; CLA guidance on common CDBG audit findings (December 2024)