POST-AWARD COMPLIANCE CHECKLIST

Ohio Community Development Block Grant: Compliance Requirements

What you must do after you win this award — administered by Ohio Department of Development · Ohio.

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

⚠ Common Disallowed-Cost Pitfalls

  • Recordkeeping: Missing or incomplete case files result in inability to demonstrate compliance with national objectives and cost eligibility, triggering disallowed costs and potential clawback
  • Financial & Cost Eligibility: Costs for ineligible activities or activities not meeting national objective are disallowed and subject to clawback; 70% of funds must benefit LMI over 3-year period
  • Financial & Cost Eligibility: Use of funds for ineligible general government expenses results in disallowed costs and mandatory repayment
  • Environmental: Costs incurred without environmental clearance are ineligible and subject to disallowance
  • Recordkeeping: Failure to comply with property use restrictions or relocation procedures results in disallowed costs; change of use violations trigger recovery
  • Reporting: Failure to report can result in suspension of funds, ineligibility for future drawdowns, or recovery of improperly documented costs
  • Procurement & Vendor Rules: Non-competitive or undocumented procurement results in disallowed costs for affected contracts
  • Labor & Wage: Failure to meet Section 3 employment/contracting targets can result in cost disallowance and compliance penalties

Reporting

  • HighMonthly

    Submit regular progress reports (monthly or quarterly basis as specified in grant agreement) documenting actual accomplishments, obligations, and spending patterns to the state grantee.

    Deadline: Within 30 days of each reporting period end (specific frequency set in subrecipient agreement)

    Source: 24 CFR 570.506; HUD Playing by the Rules Chapter 5; HUD Subrecipient Agreement Template

Financial & Cost Eligibility

  • Clawback riskOngoing

    Use CDBG funds only for eligible activities meeting one of three national objectives: benefit low- and moderate-income persons, aid elimination of slums/blight, or address urgent community development needs.

    Deadline: Applicable to every expenditure and activity throughout grant period

    Source: 24 CFR 570.208; 24 CFR 570.201

  • Clawback riskOngoing

    Establish fiscal controls ensuring funds are used only for reasonable and necessary costs in compliance with all statutory and regulatory provisions, and not for general government operating expenses.

    Deadline: Throughout entire grant performance period

    Source: 24 CFR 570.489(d)

Procurement & Vendor Rules

  • HighEvent Driven

    Conduct competitive procurement and maintain documentation of contractor solicitation and selection process in compliance with 2 CFR 200 Subpart D (Uniform Guidance) and applicable state procurement laws.

    Deadline: Required for all contracts; documentation must be maintained throughout grant period

    Source: 2 CFR 200.317-326; HUD Playing by the Rules Chapter 5

Labor & Wage

  • HighEvent Driven

    Comply with HUD Section 3 requirements (24 CFR 135) by providing employment and training opportunities to low-income persons and contracting opportunities to Section 3 businesses to the greatest extent feasible.

    Deadline: Applicable to all projects subject to Section 3; must be documented throughout project execution

    Source: 24 CFR 135; HUD Section 3 regulations

Environmental

  • Clawback riskOne Time

    Complete environmental review in accordance with 24 CFR Part 58 and obtain Release of Funds/Environmental Clearance before project commencement.

    Deadline: Must be completed and approved before project starts; failure to clear delays grant drawdown

    Source: 24 CFR Part 58; CDBG-DR Guidelines

Recordkeeping

  • Clawback riskOngoing

    Maintain case files for each activity with documentation sufficient to establish the national objective being met, income eligibility, contractor selection, and contract/payment records per 24 CFR 570.208-570.490.

    Deadline: Maintain throughout grant period and retain for greater of 3 years from closeout or as required by other applicable laws

    Source: 24 CFR 570.490(a)(1); HUD Playing by the Rules Handbook Chapter 5

  • Clawback riskOngoing

    Maintain records documenting compliance with property acquisition, displacement, relocation, and re-use restrictions per 24 CFR 570.503(b)(7) for any real property acquired or improved with CDBG funds.

    Deadline: Maintain throughout period of ownership/use and per standard record retention (3 years post-closeout)

    Source: 24 CFR 570.503(b)(7); Uniform Relocation Assistance and Real Property Acquisition Policies Act of 1970

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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 Ohio Department of Development.