POST-AWARD COMPLIANCE CHECKLIST

Ohio Housing Development Assistance Program: Compliance Requirements

What you must do after you win this award — administered by Ohio Housing Finance Agency · Ohio.

10
Total requirements
5
Clawback-risk items
10
Deadline-bound

⚠ Common Disallowed-Cost Pitfalls

  • Reporting: Failure to submit prevents project closeout and may trigger fund clawback or prevent future awards
  • Labor & Wage: Failure to demonstrate prevailing wage compliance triggers federal Davis-Bacon penalties and cost disallowance
  • Labor & Wage: Underpayment of prevailing wages triggers federal/state wage and hour penalties and construction cost disallowance
  • Financial & Cost Eligibility: Misalignment with approved budget or drawing for incomplete work triggers cost disallowance and potential repayment
  • Environmental: Work commenced without environmental clearance triggers fund recapture and project suspension
  • Reporting: Outstanding submissions may impact project's ability to receive future award funding and be reimbursed on timely basis
  • Labor & Wage: Failure to comply with Section 3 employment targets may result in cost disallowance and federal sanctions
  • Financial & Cost Eligibility: Incomplete draw requests delay fund disbursement; failure to submit required construction docs may result in cost disallowance
  • Recordkeeping: Missing or inadequate construction documentation results in draw denial and cost disallowance
  • Other Obligations: Failure to disclose partner/ownership changes may result in compliance violations and potential sanctions

Reporting

  • Clawback riskOne Time

    All HDAP recipients must complete and submit a Final Performance Report documenting project completion and compliance with funding agreement terms.

    Deadline: Deadline noted in funding agreement; for tax credit projects, submit with 8609 request if completed early

    Source: OHFA Project Administration page; HDGF Guidelines; QAP pages

  • HighQuarterly

    Submit OHFA Quarterly Construction Monitoring Form on a quarterly basis beginning the first reporting period following OHFA Board approval through 100% construction completion.

    Deadline: Due January 1, April 1, July 1, and October 1 of each year until project placed in service

    Source: OHFA Project Administration page; 2026 HDGF Guidelines

Financial & Cost Eligibility

  • Clawback riskEvent Driven

    Maintain detailed project budget per Funding Agreement and ensure all HDAP funds requested match activities listed in Funding Agreement Attachment A (HDAP Program Budget). Draws must be for completed, paid work.

    Deadline: Budget reconciliation required with each draw request and Final Performance Report

    Source: Guide to Requesting HDAP Funds; Project Administration

  • HighEvent Driven

    All HDAP fund draw requests must be submitted using OHFA Request for Payment form with appropriate supporting documentation including executed AIA construction certificates, notarized AIA G702/703 forms, and most recent Mortgagee's Title Insurance Endorsement.

    Deadline: OHFA processes complete claims within five business days of receipt; delays trigger reimbursement delays

    Source: Guide to Requesting HDAP Funds (OHFA); Project Administration page

Labor & Wage

  • Clawback riskSemi Annual

    Projects funded with HOME or NHTF dollars must submit Notice of Contract Award (NOCA) and Semi-Annual Labor Standards Enforcement Report (SALSER) to document prevailing wage compliance.

    Deadline: NOCA must be submitted with first draw request; SALSER completed annually

    Source: OHFA Project Administration page (HOME/NHTF Labor Requirements); HDGF page

  • Clawback riskOngoing

    For HOME-assisted units (12 or more units), comply with federal Davis-Bacon wage rates and document prevailing wage compliance. For OHTF/NHTF funding, comply with applicable Ohio prevailing wage law.

    Deadline: Prevailing wage rates must be paid on all covered work throughout construction; documented in contractor payroll records

    Source: Project Administration page; Ohio Revised Code Chapters 176.05 and 4115

  • HighMonthly

    Starting with 2021 HOME and NHTF awards, document and report Section 3 compliance, including total hours, Section 3 hours, targeted hours for all contractor employees, contractor Section 3 business status, and efforts to meet benchmark goals.

    Deadline: Monthly documentation required during construction; submissions attached to Quarterly Construction Monitoring Form

    Source: Project Administration page (Section 3 Requirements); HDGF page

Environmental

  • Clawback riskOne Time

    Projects receiving HOME or federal funds must comply with environmental review requirements, including preparation of Finding of No Significant Impact (FONSI) or Environmental Assessment (EA) with public notice and comment period.

    Deadline: Environmental review must be completed and funds released before construction begins

    Source: OHFA Public Forums/Environmental Review page; 24 CFR Part 58

Recordkeeping

  • HighOngoing

    Maintain detailed construction records including AIA G702/703 Certificates of Payment, Schedule of Values, notarized contractor documentation, and lien waivers. Construction progress must be evidenced by completed AIA forms with notary.

    Deadline: Records must be current and available for each draw request submission

    Source: Guide to Requesting HDAP Funds; Project Administration monitoring policy

Other Obligations

  • MediumEvent Driven

    Notify OHFA of any changes to owners, management companies, or general partners within established timeframes. Annual partner recertification and e-signature authorization renewal required if using electronic signatures.

    Deadline: Notification required within 30 days of change; annual recertification if using e-signatures

    Source: QAP Requirements page; Compliance Policies page

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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 Housing Finance Agency.