2021-03-02 HCHA Approved Minutes

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HCHA meeting March 2, 2021 Le: Yeah, you've actually highlighted a really important point in terms on how these programs and funding operates. So for any grantee, HUD requires that we define what constitutes a substantial amendment and what's called a non - substantial amendment, they have some baseline rules but then they leave it to us to be clear that it's there. In the current approved action plan from October 2020, there is a section that defines what is a substantial amendment and what we've defined is in clear line in what HUD requires which is any movement of program funds, 10 percent or more of the total of the grant amount, so in our case if we were to move 8.3 million dollars or more that would require a substantial amendment, if we moved less than that it would not require a substantial amendment. Another, the second of the three is whether we change any criteria in terms program eligibility, that triggers a substantial amendment and then lastly, if we add or move any projects that also triggers a substantial amendment and so that kind of covers the substantial amendment territory, in terms of the non-essential amendment, it's everything not that but essentially HUD also is very incredibly keen on what constitutes an amendment so when we say that we have an approved action plan, if I feel like I gotta and change one adjective to another adjective or put a semicolon instead of a colon, that triggers an amendment, right, and so it gets down to that level, but within kind of the operation of the funding, non -substantial amendments as long as they don't fall under those three triggers, we, any grantee can pursue those amendment to the action plan. Kanealii-Kleinfelder: Okay, so up to, sorry, 8.3 million dollars less than, we can do that without any public comment. Le: Right, 10 percent of the grant. I think, well and really that's kind of the cut off, right, it doesn't mean that we don't take opportunities in terms of what is important and critical, folks understand and know even if it is moving less than ten percent of the total grant. For example, the housing relocation services currently budgeted for 1.6 million dollars, really important program, right, one of the two major projects we're lifting up, but clearly well under the threshold of the ten percent of the grant, right, and so if we were to change anything there, you now, I think it would behoove us to at least help people understand why did, even if HUD does not require us to enter into a specific 30 day public comment period. Kanealii-Kleinfelder: Okay, and then most importantly, reporting, this says, reporting, we don't have to, looks like we're required to do a quarterly and that goes directly to HUD but posted on our website as well? Le: That's correct. So HUD relies on their national on-line system for us to report our financial management information into it but then narrative reporting in terms of program activities and program outcomes are also part of that and so Page 15 of 19