HOMEfires - Vol. 6 No. 1, August, 2005

Q: What are the rules and expectations for entering HOME project completion information and beneficiary data into the Integrated Disbursement and Information System (IDIS)?

 
A. The introduction of an Outcome Performance Measurement System for Community Planning and Development's four formula programs, and the pending modernization of IDIS has brought renewed attention to the quality and timeliness of IDIS data input by participating jurisdictions and other grantees, which has been less than satisfactory. For example, approximately 10 percent of all completed HOME-assisted units appear as "vacant" in IDIS with no beneficiary data having been provided. In addition, it is common to find projects left open or in final draw status for many years.

PJs must report HOME project completion and beneficiary data for initial occupants timely by entering it in IDIS on a regular basis, and periodically review the status of all projects in the system to identify those that need to be cancelled. The HOME final rule at 24 CFR 92.502(d)(1) requires PJs to enter project completion information into IDIS within 120 days of making a final draw for a project. Failure to do so is a violation of this provision and of 24 CFR 92.504(a), which states that PJs are responsible for managing day-to-day operations of its program. The final rule states that HUD may suspend further project set-ups or take other corrective actions, if satisfactory project completion data is not provided.

Many PJs are not entering completion data timely or at all and, consequently, are in violation of the HOME regulations. Further, failure to enter project completion data negatively affects a PJ's score on several HOME Performance SNAPSHOTs indicators, understating actual accomplishments and reducing the PJ's statewide and national overall rankings. The widespread failure of PJs to timely enter completion and beneficiary data results nationally in underreporting of actual HOME Program accomplishments to Congress and the Office of Management and Budget (OMB) and may negatively impact future funding for the program. Furthermore, the current effort to develop an Outcome Performance Measurement System for the four formula programs covered by the Consolidated Plan, including HOME, will be of no value if grantees fail to establish an effective system to collect and report project completion information in an accurate and timely manner.

PJs should have quality control systems in place to ensure that required project completion information and beneficiary data are complete, accurate and entered into IDIS at least monthly. Project completion information, including beneficiary data for any occupied units, should be entered into IDIS as soon as it is available. Beneficiary data for units that are vacant at the time of project completion should be entered as they are obtained. For homeowner rehabilitation projects, project completion data, including beneficiary data, should be entered as soon as the rehabilitation and final inspections are completed. For homebuyer projects (particularly those involving downpayment assistance with no construction activity), project completion and beneficiary data can often be entered at the time that a final draw is made, as total costs, other financing sources, and occupant information are known at that time. If this is not possible, project completion information should be entered immediately after the closing. Completing a project requires changing the status code in IDIS. Instructions for completing projects can be found in Chapter 4 of the IDIS Reference Manual available online.

In instances where the PJ has failed to collect and enter information on initial tenants of HOME rental housing units and those tenants have already moved, the PJ may instead enter the current tenant's beneficiary data in order to correct the non-compliance in reporting. For homeowner rehabilitation and homebuyer assistance units, only data for the household that was the original beneficiary of the assistance is acceptable.

Failure to report beneficiary data for rental housing may result in a PJ not complying with the "program rule" established at 24 CFR 92.216(a). This provision requires, that for each fiscal year's HOME allocation, not less than 90% of rental housing units receiving assistance be occupied by and tenant-based rental assistance funds be provided to families with incomes not exceeding 60% of area median income. Failure to meet this targeting requirement is a violation of the HOME statute and regulations and will result in HUD requiring deeper targeting in the PJ's future HOME units or TBRA, or the imposition of more serious corrective actions.

It is vital that PJs improve their performance reporting both to comply with HOME regulations and ensure accurate individual and national reporting on HOME accomplishments. HUD Field Offices should review their PJs' compliance with performance reporting requirements at least quarterly. HUD should communicate deficiencies to PJs and provide a reasonable opportunity for them to enter or correct completion data. If PJs fail to fully comply with reporting requirements after this notice is provided, Field Offices must make findings of noncompliance with §92.502(d)(1) and §92.504(a) and identify appropriate corrective actions. Field Offices may wish to consult with the Office of Affordable Housing Programs (OAHP) regarding corrective actions before imposing them.

To assist PJs and HUD Field Offices in identifying projects that may need to be cancelled or projects that remain in "open" status despite their having been completed, OAHP will be posting a new report, the HOME PJs Open Activities Report, on its website each month. This report will provide information on all HOME projects entered in IDIS that have not been completed. While the report has many potential management uses, its primary purpose is to enable PJs and Field Offices to regularly review and identify open projects that should be completed in IDIS or cancelled. The reports will be posted as Excel files, which can be downloaded and manipulated to make it easier to identify reporting deficiencies.

OAHP will issue a separate HOMEfires addressing the widespread problem of old, open projects with no draws.