POST-AWARD COMPLIANCE CHECKLIST

MSHDA Rental Rehabilitation Program: Compliance Requirements

What you must do after you win this award — administered by Michigan State Housing Development Authority · Michigan.

8
Total requirements
5
Clawback-risk items
8
Deadline-bound

⚠ Common Disallowed-Cost Pitfalls

  • Financial & Cost Eligibility: Failure to expend advanced funds within 180 days results in suspension from NDD programs for six months or until all grants are closed in compliance
  • Procurement & Vendor Rules: Use of debarred contractors results in disallowed costs for all payments made to ineligible parties
  • Financial & Cost Eligibility: Costs incurred without pre-approval will be denied and not reimbursed
  • Ongoing Eligibility: Violation triggers grant clawback and potential repayment of full assistance amount
  • Environmental: Failure to comply may result in work stoppage, disallowed costs for non-compliant work, and regulatory penalties
  • Financial & Cost Eligibility: 10% of award withheld until all compliance documentation submitted
  • Recordkeeping: Failure to maintain records may trigger audit findings and potential recapture if costs cannot be substantiated
  • Reporting: Funds will not be disbursed without proper FSR approval and documentation

Reporting

  • HighEvent Driven

    Financial Status Reports (FSRs) are required for all draw requests on a reimbursement basis; work must be completed, invoiced, and both grantee and property owner sign-off secured before reimbursement.

    Deadline: With each draw request; activity must be fully completed in IGX before FSR can be approved

    Source: MI Neighborhood Policy and Compliance Handbook §6-12, 6-16

Financial & Cost Eligibility

  • Clawback riskOngoing

    Grant expenditure must be completed within 24 months from the grant start date with no time extensions allowed; funds must be expended within 180 days if advanced.

    Deadline: 24 months from grant start date for full expenditure; 180 days for advanced funds

    Source: MI Neighborhood 3.0 Policy and Compliance Handbook §10-2, 10-29

  • Clawback riskOngoing

    Funds may not be used to finance rehabilitation items not included within program guidelines, budget, or pre-approved by MSHDA; failure to secure written pre-approvals results in non-compliance and funding denial.

    Deadline: Prior written approval required before incurring non-budgeted costs

    Source: MI Neighborhood Policy and Compliance Handbook §6-1, 23-9

  • HighOne Time

    Ten percent (10%) of total award amount will be withheld and not reimbursed until final FSR submission and all completion/reporting documentation is provided.

    Deadline: At project closeout upon submission of final Financial Status Report

    Source: MI Neighborhood Program Overview §28-4

Procurement & Vendor Rules

  • Clawback riskOngoing

    All contractors and subcontractors must be validated as not debarred on sam.gov; main organization must be registered in sam.gov with valid UEI numbers.

    Deadline: Prior to contractor engagement and maintained throughout project

    Source: MI Neighborhood Policy and Compliance Handbook §6-3

Environmental

  • Clawback riskEvent Driven

    Asbestos-containing materials disturbed during rehabilitation must be subject to testing and abatement protocol per OSHA regulations 29 CFR 1910.1001 and 1926.1101 for worker and occupant safety.

    Deadline: Prior to disturbing materials during construction

    Source: MI Neighborhood Policy and Compliance Handbook §10-10, 23-16

Recordkeeping

  • HighOngoing

    All grant-related documents including agreements, payment requests, progress reports, and monitoring reports must be retained for three years following issuance of closeout letter.

    Deadline: Three years post-closeout

    Source: MSHDA Neighborhood Enhancement Program Guidelines §26-3

Ongoing Eligibility

  • Clawback riskOngoing

    Property owners or immediate family members cannot live in NDD-assisted rental units for five years after the MSHDA regulatory agreement date.

    Deadline: Five years from regulatory agreement date

    Source: Mixed-Use Building Program Guidelines §12-5

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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 Michigan State Housing Development Authority.