Fiscal Year 2023/Program Year 2022 End-of-Year Review for the Community Development Block Grant Consolidated Annual Performance and Evaluation Report (CAPER)City of Dubuque
City Council Meeting
Consent Items # 017.
Copyrighted
December 4, 2023
ITEM TITLE: Fiscal Year 2023/P rog ram Year2022 End -of -Year Review for the
Community Development Block Grant Consolidated Annual
Performance and Evaluation Report (CAPER)
SUMMARY: City Manager sharing information on an End -of -Year Review the City of
Dubuque received from the U.S. Department of Housing and Urban
Development (HUD) regarding the Community Development Block Grant
(CDBG) funds for FY23/PY22.
SUGGESTED Suggested Disposition: Receive and File
DISPOSITION:
ATTACHMENTS:
Description Type
MVM Memo City Manager Memo
FY23/PY22 End -of -Year Review CAPER- Memo Staff Memo
FY23/PY22 End -of -Year Performance Letter Supporting Documentation
THE CITY OF
Dubuque
DUB TEE1.
All -America City
Masterpiece on the Mississippi
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TO: The Honorable Mayor and City Council Members
FROM: Michael C. Van Milligen, City Manager
SUBJECT: FY23/PY22 End -of -Year Review for the Community Development Block
Grant Consolidated Annual Performance and Evaluation Report (CAPER)
DATE: November 29, 2023
Housing and Community Development Director Alexis Steger is sharing information on
an End -of -Year Review the City of Dubuque received from the U.S. Department of
Housing and Urban Development (HUD) regarding the Community Development Block
Grant (CDBG) funds for FY23/PY22. The End -of -Year Review is a comprehensive
performance review of the City's overall progress. To demonstrate our progress, the
City submits a CDBG Consolidated Annual Performance and Evaluation Report
(CAPER) for activities from the period of July 1, 2022 through June 30, 2023. The End -
of -Year Review is based off the City's CAPER submission.
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Mic ael C. Van Milligen
MCVM:sv
Attachment
cc: Crenna Brumwell, City Attorney
Cori Burbach, Assistant City Manager
Alexis Steger, Housing & Community Development Director
Mary Bridget Corken-Deutsch, Community Development Specialist
Dubuque
THE CITYF
DUijB- E
AII•Ameriea City
, ,.
Masterpiece on the Mississippi
2017*2019
TO: Michael C. Van Milligen, City Manager
FROM: Alexis M. Steger, Housing and Community Development Director
SUBJECT: FY23/PY22 End -of -Year Review for the Community Development Block
Grant Consolidated Annual Performance and Evaluation Report (CAPER)
DATE: November 27, 2023
Introduction
The purpose of this memorandum is to summarize an End -of -Year Review the City of
Dubuque received from the U.S. Department of Housing and Urban Development
(HUD) regarding the Community Development Block Grant (CDBG) funds for
FY23/PY22. The End -of -Year Review is a comprehensive performance review of the
City's overall progress. To demonstrate our progress, the City submits a CDBG
Consolidated Annual Performance and Evaluation Report (CAPER) for activities from
the period of July 1, 2022 through June 30, 2023. The End -of -Year Review is based off
the City's CAPER submission.
Discussion
HUD's Office of Community Planning and Development partners with state and local
governments to ensure that our joint efforts result in housing and community
development programs and policies that benefit and serve low- and moderate -income
persons. In order to meet these requirements, HUD reviews the City's CDBG program
to ensure it's following the consolidated plan, managing CDBG funds under compliance
and regulatory requirements, providing accurate performance reports, and evaluates the
City is meeting our objectives.
The End -of -Year Review congratulated the City of Dubuque on our many
accomplishments during FY23/PY22 including:
Expended over $289,000 of CDBG funds were expended within the City's
Housing program to complete led based paint reduction and energy saving
activities for affordable properties.
Expended $50,000 in CDBG funds to assist 10 low- and moderate- income
families in becoming first time homebuyers through our downpayment assistance
program.
• Rehabbed 29 rental units to maintain affordable rental housing.
Expended over $96,000 of CDBG funds to public service activities including
assisting low income neighborhoods with recreation programs.
Although the City certified it would provide an overall benefit to low- and
moderate- income persons of at least 70%, in FY23/PY22, 100% of the City's
eligible CDBG funds were used to benefit low- and moderate- income persons.
These successes are made possible through collaboration between Housing and
Community Development staff, City of Dubuque Recreation staff, and community
partners.
The End -of -Year Review states an area of concern continues to be our CDBG
regulatory standard of timeliness which requires no more than 1.5 years of funds remain
unexpended 60 days prior to the end of the program year. City staff have created a
timeliness plan to ensure our FY24/PY23 activities are carried out in a timely manner
and ultimately, in compliance. Another area of improvement is to ensure our Citizen
Participation Plan includes our outreach efforts and services provided are inclusive for
all protected classes. This work is an ongoing priority for Housing and Community
Development staff.
Requested Action
I respectfully submit this memo as informational only.
Prepared by: Mary Bridget Corken-Deutsch, Community Development Specialist
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Ms. Alexis Steger, CPA
Housing and Community Development Director
City of Dubuque
350 West 6th Street, Suite 312
Dubuque, IA 52001
Dear Ms. Steger:
U.S. Department of Housing and Urban Development
Omaha Field Office
Edward Zorinsky Federal Building
1616 Capitol Avenue, Suite 329
Omaha, Nebraska 68102-4908
November 8, 2023
Subject: Consolidated End -of -Year Review, Program Year 2022
HUD's Office of Community Planning and Development has sought to establish
partnerships with state and local governments. The focus of our partnership has been to work with
communities to ensure that our joint efforts result in housing and community development
programs and policies that benefit and serve low- and moderate -income (LMI) persons. These
efforts occur within the framework of the statutes we administer and the regulations and emerging
policies that are designed to improve program performance.
The provisions of the Housing and Community Development Act of 1974, as amended,
and the National Affordable Housing Act of 1990, require the annual submission of performance
reports by grant recipients receiving federal assistance through programs covered under these Acts.
Additionally, these Acts require that a determination be made by the Secretary that the grant
recipient is in compliance with the statutes and has the continuing capacity to implement and
administer the programs for which assistance is received.
In order to meet these requirements, the Department will be making a comprehensive
performance review of your overall progress at least annually, as required by Section 91.525 of
the regulations. The review consists of analyzing your consolidated planning process; reviewing
management of funds; determining the compliance of funded activities with statutory and
regulatory requirements; determining the accuracy of required performance reports; as well as
evaluating your accomplishments in meeting key Departmental objectives.
This assessment not only meets the mandates of the statutes, but also provides a basis for
working together in collaboration to help you achieve your housing and community development
goals. One critical outcome of this collaboration should be the development of a more
comprehensive, effective, and concise Consolidated Plan and improved performance in achieving
specific goals that correspond to the activities outlined in your forthcoming Action Plan.
2
We congratulate the City of Dubuque on their many accomplishments during fiscal year
2022 and on achieving housing and community development objectives. Some examples are as
follows:
• Over $289,000 CDBG resources were expended within the City's housing program in order
to complete lead based paint reduction and energy saving activities for affordable
properties throughout Dubuque.
• The City utilized $50,000 in CDBG funds to assist 10 low to moderate income families in
becoming first time homebuyers through its downpayment assistance program.
• The City rehabilitated 29 rental units in order to maintain affordable rental housing
throughout the community.
• For 2022, the City utilized over $96,000 in CDBG resources for public service activities.
These activities included assisting low income neighborhoods with their recreation
programs which benefited low to moderate income persons throughout the community.
• The City certified that it would provide an overall benefit to LMI persons annually of at
least 70 percent. In 2022, 100% of the City's eligible CDBG funds were used for the benefit
of LMI persons.
One area of concern is related to the CDBG regulatory standard for timeliness at 24 CFR
570.902 which requires that no more than 1.5 years of funds remain unexpended 60 days prior to
the end of the program year. Based on expenditure information in IDIS, the City had an adjusted
draw ratio of 2.29 on May 2, 2023. The ratio calculation included the letter of credit balance
adjusted for program income on the date of the timeliness test. It is important that your CDBG
program is carried out in a timely manner and continued noncompliance may result in sanctions,
including the loss of funds and other corrective actions. Please review CDBG timeliness resources
on the HUD Exchange website and continue to evaluate the broad range of eligible activities in
order to best utilize CDBG resources for your community. In addition, continue to reach out to
our Field Office staff for additional assistance as needed in order to help meet your regulatory
obligations.
In addition, the Office of Fair Housing and Equal Opportunity (FHEO) received a copy of
the City's FY 2022 CAPER. Based on FHEO's review, the following recommendations are
provided related to subsequent CAPER submittals that include:
• Reviewing the City's Citizen Participation Plan to ensure it includes information on
outreach efforts for all protected classes;
• Providing additional details and information in the CAPER related to the City's planned
activities to further fair housing. Additional details should include activities, timetables,
outcomes, and funding for all actions taken to ameliorate the identified barriers to fair
housing; and
• Exploring ways to ensure the City's service beneficiaries are inclusive of all protected
classes.
In conclusion, as a result of our analysis, we have determined that your overall progress in
2022 was satisfactory. This determination is based upon the information available to this office
and does not reflect a comprehensive evaluation of specific activities.
Should you or your staff have any questions, please contact Mr. Brian Gaskill, Community
Planning and Development Representative, by email at brian.o. ag skill(ahud.gov.
Sincerely,
TOUT
ANDERSON Dig CN= ANDERSON STOUEgned by: ANDERSON SemailE
ANDERSON.STOUTE@HUD.GOV C =AD O =
STOUTE HUD GU=GPD
Date: 2023.11.08 10:18.18-06'00'
Anderson Stoute
Director
Office of Community
Planning and Development
cc: Mary Bridget Corken Deutsch