CDBG CARES
Through the Coronavirus Aid, Relief, and Economic Security (CARES) Act, the State of Montana, Department of Commerce was awarded Community Development Block Grant funds (CDBG CARES) to support communities as they respond to the impacts of the COVID-19 pandemic.
If applicants have questions about the eligibility of potential projects, please contact Montana Housing at 406.841.2840 or contact us by email. Program Specialists are available to provide guidance on the nuances of CDBG CARES.
Currently, CDBG CARES funds are allocated. Application guidelines and associated appendices are linked below. Eligible applicants may submit multiple applications so long as they prioritize their proposals and demonstrate both need and reasonability.
Application Guidelines
Appendix A – Project Budget
Appendix B – Project Implementation Schedule
Appendix C – Public Hearing and Public Notice
Appendix D – Environmental Checklist
Appendix E – Certification for Application
Appendix F – Resolution to Authorize Submission of a CDBG-CV Application
Montana’s allocation of CDBG CARES funds is $10,174,175 (CDBG-CV1, CDBG-CV2, and CDBG-CV3).
Administrative costs are eligible for funding so long as they are necessary and reasonable and do not exceed 10% of a project's total CDBG CARES award.
CDBG CARES applications were reviewed using the following Ranking Rubric and Ranking Sheet.
Eligible Applicants
Eligible applicants include towns, cities, and counties. Billings, Great Falls, and Missoula – known as entitlement areas – are eligible applicants for CDBG CARES, but CDBG CARES regulations limit the amount of CDBG CARES the State of Montana can award to these entitlement areas. Other entities such as tribes, non-profits, public housing authorities, etc., although not eligible directly, may apply in partnership with an eligible applicant.
Eligible Activities
Activities funded through CDBG CARES must:
- Prevent, prepare for, and respond to the COVID-19 pandemic
- Primarily benefit Montanans whose incomes are low or moderate
- Avoid duplication of benefits from other local, state, or federal sources of funds
Montana will use CDBG CARES to fund activities that:
- Improve and Sustain Public Facilities
- Provide Vital Public Services
- Preserve and Construct Affordable Housing / Reduce Homelessness
Examples of eligible activities:
- Public Facilities: Improvements to HVAC for ventilation; expansion to allow for social distancing; acquisition, rehabilitation, or construction of a public facility, such as a park, that allows for outdoor recreation and social distancing
- Public Services: Support, including equipment, for senior centers, head start centers, shelters, health clinics, daycares, food banks
- Housing/Homelessness: Acquire, develop, and/or rehabilitate shelters; acquire or convert property to affordable housing to prevent overcrowding
Expenses incurred for eligible activities can be reimbursed back to January 21, 2020.
Resources for Applicants
CDBG CARES Start-Up Workshop Video
HUD has numerous resources to help applicants understand CDBG CARES and eligible activities:
- CDBG-CV PPR Tieback Flexibilities Quick Guide
- CDBG-CV Public Facilities Quick Guide
- CDBG-CV Rural Coronavirus Response Quick Guide
LMI Categories
CDBG CARES activities must primarily benefit low- to moderate-income (LMI) Montanans, i.e., those earning less than 80% of the area median income. Activities may target LMI residents and provide direct benefits, provide an area-wide benefit to an entire community whose population is at least 51% LMI, or serve a “limited clientele” that is presumed primarily LMI.
Site Specific (LMS)
Site specific activities provide direct assistance to income-eligible households, such as rehabilitation of housing for occupancy by an LMI family. To qualify under the site specific LMI category, applicants must indicate how their activity will serve income-eligible households. The following tools can be used to determine income limits for the county in which the activity will occur and to document household eligibility.
HUD Exchange CDBG Income Limits
https://www.hudexchange.info/resource/5334/cdbg-income-limits/
HUD Exchange Self Certification of Income that May Be Adapted for CDBG CARES Activities (Note: Part II and the portion of Part III dealing with cash value of assets and imputed calculation do not apply.)
https://www.hudexchange.info/resource/6069/home-sample-self-certification-of-annual-income-form/
Area Benefit (LMA)
Area benefit activities address needs in a specified geographic area where at least 51% of the population is LMI. Activities benefit all residents of the area equally, regardless of income. To qualify under the area benefit LMI category, applicants must demonstrate that their area of service meets the 51% LMI threshold. The following tools can be used to demonstrate area benefit LMI eligibility.
HUD Low- and Moderate-Income Mapping Application:
https://hud.maps.arcgis.com/home/item.html?id=ffd0597e8af24f88b501b7e7f326bedd
Limited Clientele (LMC)
Limited clientele activities are presumed to provide 51% benefit to LMI persons. To qualify under the limited clientele LMI category, applicants must show that their activity meets one of the following four tests.
- Test 1: Benefits a demographic group consisting of principally LMI persons, as follows:
- abused children
- elderly persons (age 62 or older)
- victims of domestic violence
- persons experiencing homelessness
- severely disabled adults or children
- adults with limited literacy
- persons living with AIDS
- migrant farm workers
- Test 2: Is of such nature that it may be reasonably concluded that the activity’s clientele will primarily be LMI persons. For example: a day care center that is designed to serve residents of a public housing complex.
- Test 3: Applicant has income eligibility requirements that limit their services to LMI persons. For example: a Head Start Center since federal requirements mandate that at least 90% of the children served come from lower income families.
- Test 4: Conduct a household income survey that meets the requirements of the CDBG handbook “Documenting Benefit to Low- and Moderate-Income Persons.”
How many applications can a town, city, or county submit for CDBG CARES funds?
Local governments may submit more than one application for CDBG CARES funds; however, local governments must prioritize their applications. Local governments with an open CDBG grant are eligible to apply for CDBG CARES funds.
How much in CDBG CARES funds can an applicant apply for?
There is no minimum or maximum award amount for CDBG CARES funds. However, applicants must clearly document need and reasonability, and outline their proposed budget. CDBG CARES funds do not require a match from the applicant. CDBG CARES funds cannot duplicate benefits that were or will be provided from other sources of funds.
Do applicants have to complete an environmental review for CDBG CARES funds?
Yes, applicants must complete an environmental review. Appendix D – Environmental Checklist must be submitted with each application. Once awarded, grantees will be notified by Commerce staff of the steps necessary to comply with environmental review requirements.
Do applicants need to hold a public hearing for CDBG CARES funds?
Yes, applicants must hold a public hearing. This public hearing can be done virtually to adhere to public health standards related to the COVID-19 pandemic. The notice for the public hearing must be published in a newspaper at least two days prior to the public hearing. One public hearing can be held for multiple projects apply for CDBG CARES funding.
