FY24/PY23 End-of-Year Review for the Community Development Block Grant Consolidated Annual Performance and Evaluation Report (CAPER)Copyrighted
December 16, 2024
City of Dubuque CONSENT ITEMS # 10.
City Council
ITEM TITLE: FY24/PY23 End -of -Year Review for the Community
Development Block Grant Consolidated Annual Performance
and Evaluation Report (CAPER)
SUMMARY: City Manager providing information 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 FY24/PY23.
SUGGUESTED Receive and File
DISPOSITION:
ATTACHMENTS:
1. MVM Memo
2. Staff Memo
3. Dubuque 2023 Year End Performance Letter
Page 200 of 1050
Dubuque
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TO: The Honorable Mayor and City Council Members
FROM: Michael C. Van Milligen, City Manager
SUBJECT: FY24/PY23 End -of -Year Review for the Community Development Block
Grant Consolidated Annual Performance and Evaluation Report (CAPER)
DATE: December 10, 2024
Housing & Community Development Director Alexis Steger is providing information 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 FY24/PY23. 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, 2023, through June 30, 2024.
The End -of -Year Review is based off the City's CAPER submission.
The End -of -Year Review congratulated the City of Dubuque on our many
accomplishments during FY24/PY23 including:
• Over $110,000 CDBG resources were expended within the city's housing
program to complete lead -based paint reduction for affordable properties
throughout Dubuque.
• The city utilized $20,000 in CDBG funds to assist four low to moderate income
families in becoming first time homebuyers through its downpayment assistance
program.
• The city rehabilitated 15 single-family residential units in order to maintain
affordable housing throughout the community and provided over $690,000 in
resources for multi -unit residential rehabilitation.
• For 2023, the city utilized over $235,000 in CDBG resources for public service
activities. These activities included youth services and employment training
which benefited low to moderate income persons throughout the community.
• The city certified that it would provide an overall benefit to low to moderate
income (LMI) persons annually of at least 70 percent. In 2023, 100% of the city's
eligible CDBG funds were used for the benefit of LMI persons.
• The CDBG regulatory standard for timeliness at 24 CFR 570.902 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 1.45 on May 2, 2024. The ratio calculation included the letter of
Page 201 of 1050
credit balance adjusted for program income on the date of the timeliness test.
The city was in compliance with this standard.
These successes are made possible through collaboration between Housing and
Community Development staff and community partners.
In addition to the city's accomplishments, Office of Fair Housing and Equal Opportunity
(FHEO) provided recommendations including:
• ensure all notices utilized throughout the citizen participation process are
attached to the CAPER
• ensure that the city's lack of citizen comments on the CAPER are not tied to a
civil rights related barrier
• encourage the city to continue addressing the identified barriers and further fair
housing.
Housing and Community Development staff is confident we are following these
recommendations and will continue to make this work a priority. For example, all notices
utilized throughout the citizen participation process were attached to the
CAPER. Additionally, staff review all citizen comments to make sure they are not tied to
a civil rights related barrier and, if they were, ensure the proper steps are taken to follow
our processes regarding civil rights. Lastly, the city continually addresses identified
barriers and furthers fair housing. The most recent example is the city's work with the
Analysis of Impediments to Fair Housing document that will outline Goals and Actions to
city to implement for the next five years
/ � A�
Michael 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
2
Page 202 of 1050
Dubuque
THE CITY OF
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TO: Michael C. Van Milligen, City Manager
FROM: Alexis M. Steger, Housing and Community Development Director
SUBJECT: FY24/PY23 End -of -Year Review for the Community Development Block
Grant Consolidated Annual Performance and Evaluation Report (CAPER)
DATE- December 12, 2024
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
FY24/PY23. 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
July 1, 2023 through June 30, 2024. 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. 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 evaluating
the city is meeting our objectives.
The End -of -Year Review congratulated the City of Dubuque on our many
accomplishments during FY24/PY23 including:
• Over $110,000 CDBG resources were expended within the city's housing
program to complete lead -based paint reduction for affordable properties
throughout Dubuque.
• The city utilized $20,000 in CDBG funds to assist four low to moderate income
families in becoming first time homebuyers through its downpayment assistance
program.
Page 203 of 1050
• The city rehabilitated 15 single-family residential units in order to maintain
affordable housing throughout the community and provided over $690,000 in
resources for multi -unit residential rehabilitation.
• For 2023, the city utilized over $235,000 in CDBG resources for public service
activities. These activities included youth services and employment training
which benefited low to moderate income persons throughout the community.
• The city certified that it would provide an overall benefit to low to moderate
income (LMI) persons annually of at least 70 percent. In 2023, 100% of the city's
eligible CDBG funds were used for the benefit of LMI persons.
• The CDBG regulatory standard for timeliness at 24 CFR 570.902 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 1.45 on May 2, 2024. The ratio calculation included the letter of
credit balance adjusted for program income on the date of the timeliness test.
The city was in compliance with this standard.
These successes are made possible through collaboration between Housing and
Community Development staff and community partners.
In addition to the city's accomplishments, Office of Fair Housing and Equal Opportunity
(FHEO) provided recommendations including:
• ensure all notices utilized throughout the citizen participation process are
attached to the CAPER
• ensure that the city's lack of citizen comments on the CAPER are not tied to a
civil rights related barrier
• encourage the city to continue addressing the identified barriers and further fair
housing.
Housing and Community Development staff is confident we are following these
recommendations and will continue to make this work a priority. For example, all notices
utilized throughout the citizen participation process were attached to the CAPER.
Additionally, staff review all citizen comments to make sure they are not tied to a civil
rights related barrier and, if they were, ensure the proper steps are taken to follow our
processes regarding civil rights. Lastly, the city continually addresses identified barriers
and furthers fair housing. The most recent example is the city's work with the Analysis
of Impediments to Fair Housing document that will outline Goals and Actions to city to
implement for the next five years.
Requested Action
I respectfully submit this memo as informational only.
Prepared by: Mary Bridget Corken-Deutsch, Community Development Specialist
Page 204 of 1050
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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
December 3, 2024
Subject: Consolidated End -of -Year Review, Program Year 2023
EIM'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.
We congratulate the City of Dubuque on their many accomplishments during fiscal year 2023 and
on achieving housing and community development objectives. Some examples are as follows:
• Over $110,000 CDBG resources were expended within the City's housing program in order to
complete lead based paint reduction for affordable properties throughout Dubuque.
Page 205 of 1050
• The City utilized $20,000 in CDBG funds to assist four low to moderate income families in
becoming first time homebuyers through its downpayment assistance program.
• The City rehabilitated 15 single-family residential units in order to maintain affordable housing
throughout the community and provided over $690,000 in resources for multi -unit residential
rehabilitation.
• For 2023, the City utilized over $235,000 in CDBG resources for public service activities. These
activities included youth services and employment training which benefited low to moderate
income persons throughout the community.
• The City certified that it would provide an overall benefit to low to moderate income (LMI) persons
annually of at least 70 percent. In 2023, 100% of the City's eligible CDBG funds were used for the
benefit of LMI persons.
• The CDBG regulatory standard for timeliness at 24 CFR 570.902 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 1.45 on May 2, 2024. The
ratio calculation included the letter of credit balance adjusted for program income on the date of
the timeliness test. The City was in compliance with this standard.
In addition, the Office of Fair Housing and Equal Opportunity (FHEO) received a copy of the City's
FY 2023 CAPER. Based on FHEO's review, the following recommendations are provided related to
subsequent CAPER submittals that include:
• Ensure all notices utilized throughout the citizen participation process are attached to the CAPER;
• Ensure that the City's lack of citizen comments on the CAPER are not tied to a civil rights related
barrier; and
• Encourage the City to continue addressing the identified barriers and further fair housing.
In conclusion, as a result of our analysis, we have determined that your overall progress in 2023
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, Senior Community
Planning and Development Representative, by email at brian.o. ag skill&hud.gov.
Sincerely,
ANDERSON STOUTE =NDER
"AND :ANDER3DN STOUTE
Orv: CNA. N STOUTE email=ANDERSON.
STOUTE@HU C=ADO=HUDOU=CPD
dare: mm.,—De... .
Anderson Stoute
Director
Office of Community
Planning and Development
cc: Mary Bridget Corken Deutsch
Page 206 of 1050