SECTION 8: Grant Administration & Other Requirements

8.1 Subrecipient Recordkeeping and Reporting Requirements

ESG Subrecipients must maintain records on the following for both ESG AND Match activities, with the expectation that they may be reviewed by DHS on a two-year monitoring cycle (Your agency will be notified within 30 days of monitoring date):

Type Requirement
  • Written Policies/Standards on Service Delivery (see Section 2.8 for more details on what to include)
  • Staff/Personnel Manual (Explains Roles, Subrecipient Policies, instructions, conflict of interest policies, Participant Confidentiality, etc.)
  • Contractual Agreement(s) with DHS and ESG any vendors/subs
  • Grant Applications, Reports, and records submitted to DHS
  • Resumes and other Personnel Information for ESG funded Staff (including applicable licenses, etc.)
  • Habitability Inspection of Facility (Shelter Only)
  • Documentation of Non-Profit Status and Relevant Board Minutes/Charters (If not a unit of Local Government)
  • Documents showing compliance with the faith-based activities requirements under 576.406 (if applicable)
  • Documents showing compliance with the other Federal Requirements in 576.407
Participant / Service Records
  • Participant and Service Documentation (detailing who was served, eligibility backup, and what services they were provided)
  • Participant Income Documentation ONLY for Homelessness Prevention (at intake and re-certification) and Rapid Rehousing (at re-certification)
  • Documentation on the Units assisted with Financial Assistance (RR and HP ONLY, includes inspections, leases, etc.)
  • HMIS or Comparable Database Documentation (releases, etc.)
  • Records showing Participants were made aware of their rights and grievance policies
  • Participant Grievances and Complaints (including resolutions)
  • Financial Policies and Procedures, Including Internal Controls, Procurement Standards, and Conflict of Interest Policies.
  • Backup for all Expenditures (invoices, canceled checks, timesheets, payrolls, etc.)
  • Documentation of Procurement for ESG Purchases (showing purchase made in line with ESG rules, cost estimates/bids when necessary, etc.)
  • Bank Statements and Reconciliations
  • General Ledgers and other accounting records (with ESG expenses with its cost center or code)
  • Match Funds (including sources and receipts, etc.)
  • Cost Allocation Plans (Either Direct or Indirect, as applicable)
  • Audits
  • Documentation of all Applicable Insurance Policies

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8.2 Period of Record Retention 24 CFR §576.500(y)(1)

All records pertaining to each fiscal year of ESG funds must be retained for the greater of 5* years after DHS's closeout with HUD (not the Subrecipient's closeout with DHS) or the period specified below:

  • Where ESG funds are used for the renovation of an emergency shelter involves costs charged to the ESG grant that exceed 75% of the value of the building before renovation, records must be retained until 10 years after the date that ESG funds are first obligated for the renovation; and
  • Where ESG funds are used to convert a building into an emergency shelter and the costs charged to the ESG grant for the conversion exceed 75% of the value of the building after conversion, records must be retained until 10 years after the date that ESG funds are first obligated for the conversion.

Copies made by microfilming, photocopying, or similar method may be substituted for the original records. Many things may delay DHS's closeout with HUD including open audits, OIG investigations, and slow spending subrecipients. Subrecipients shall contact DHS before destroying any ESG records to ensure they are no longer within the record retention period.

NOTE: It's not uncommon for DHS's closeout with HUD to take 3-5 years, so subrecipients should minimally plan to maintain records for at least 10 years.

8.3 Access to Records

The confidentiality procedures established under this section, HUD, the HUD Office of the Inspector General, and the Comptroller General of the United States, or any of their authorized representatives, and DHS, must have the right of access to all books, documents, papers, or other records of examination, excerpts and transcripts. These rights of access are not limited to the required retention period but last as long as the records are retained.

  • Subrecipients must make available program participant records, along with any financial and program records, for review by DHS during periodic monitoring visits.
  • Monitoring of subrecipients may be conducted by DHS, local HUD Office of Community Planning and Development, HUD's Office of Special Needs Assistance Programs, HUD's Office of Inspector General, HUD's Office of Fair Housing and Equal Opportunity, a contractor hired on behalf of the DHS for the purposes of auditing programs funded through the State, or other authorized state or federal subrecipient, to determine compliance with the requirements of each program.
  • In lieu of a site visit DHS may request either copies of supporting documentation in order to conduct a Desk Audit review of a subrecipient or access to HMIS for review of documentation uploaded to the system.

DHS must provide citizens, public subrecipients, and other interested parties with reasonable access (consistent with state and local laws regarding privacy and obligations of confidentiality, and the confidentiality requirements in this part) to records regarding any uses of ESG funds DHS received during the preceding 5 years. DHS must collect and report data on its use of ESG funds in HUD's Integrated Disbursement and Information System (IDIS) and other reporting systems, as specified by HUD. DHS must also comply with the reporting requirements in 24 CFR parts 85 and 91 and the reporting requirements under the Federal Funding Accountability and Transparency Act of 2006, which are set forth in Appendix A to 2 CFR part 170.

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8.4 Conflict of Interest

A Conflict of Interest is a real or seeming incompatibility between a person's private interests and his or her public or fiduciary duties. For the purposes of ESG, the rule is that no persons:

Who are an:

  • Employee, Agent, Consultant, Officer, Elected official, and/or Appointed official

Of the:

  • State of Illinois
  • Subrecipient of ESG funds (applies to your subrecipient and other ESG subrecipients) and/or
  • Federal Government


  • Exercise or have exercised any functions or responsibilities with respect to ESG activities, and/or
  • Are in a position to participate in a decision-making process or gain inside information with regard to such activities,

Shall not:

  • Obtain a financial interest or benefit from an ESG-assisted activity,
  • Have a financial interest in any contract, subcontract, or agreement with respect to an ESG-assisted activity, or with respect to the proceeds of the ESG-assisted activity,

Either for themselves or those with whom they have business or immediate family ties, during their tenure or for one year thereafter.


Upon the written request of the recipient, HUD may grant an exception to the provisions of this section on a case-by-case basis when it has satisfactorily met the threshold requirements below:

HUD will consider an exception only after the recipient has provided the following documentation:

  1. A disclosure of the nature of the conflict, accompanied by an assurance that there has been public disclosure of the conflict and a description of how the public disclosure was made. Typically, notification is provided through a Website Posting and Legal Notices in local newspaper. AND
  2. An opinion of the Subrecipients & DHS attorneys that the interest for which the exception is sought would not violate State or local law.

IMPORTANT: Mere submission of a request for an exception does not authorize a recipient to engage in any activity or enter into any contract that constitutes a conflict. An exception is not granted until the subrecipient receives such determination in writing from the local HUD office.

In determining whether to grant a requested exception after the recipient has satisfactorily met the requirements, HUD shall conclude that such an exception will serve to further the purposes of the McKinney-Vento Act and the effective and efficient administration of the recipient's program or project, considering the cumulative effect of the following factors, as applicable:

  • Significant cost benefit or essential expertise to project.
  • Opportunity for open competitive bidding or negotiation.
  • Person affected has withdrawn from his or her functions or responsibilities, or the decision-making process with respect to the assisted activity.
  • Interest or benefit was present before affected person was in the "conflicting" position.
  • Undue hardship to subrecipient or person affected when weighed against public interest served by avoiding the prohibited conflict.
  • Any other relevant considerations.

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8.5 Affirmative Outreach

The DHS or subrecipient must make known that use of the facilities, assistance, and services are available to all on a nondiscriminatory basis. If it is unlikely that the procedures that the DHS or subrecipient intends to use to make known the availability of facilities, assistance, and services will reach persons of any particular race, color, religion, sex, age, national origin, familial status, or disability who may qualify for those facilities and services, the DHS or subrecipient must establish additional procedures that ensure that those persons are made aware of the facilities, assistance, and services. The DHS and its subrecipients must take appropriate steps to ensure effective communication with persons with disabilities including, but not limited to, adopting procedures that will make available to interested persons information concerning the location of assistance, services, and facilities that are accessible to persons with disabilities. Consistent with Title VI (The Civil Rights Act of 1964) and Executive Order 13166 [Improving Access to Services for Persons with Limited English Proficiency (LEP)], the DHS and subrecipients are also required to take reasonable steps to ensure meaningful access to programs and activities for limited English proficiency (LEP) persons.

8.6 Uniform Administrative Requirements

The requirements of 24 CFR part 85 and 2 CFR 200 apply to the DHS and subrecipients that are units of general purpose local government, except that 24 CFR 85.24 and 85.42 do not apply, and program income is to be used as match under 24 CFR 85.25(g). The requirement of 24 CFR part 84 apply to subrecipients that are private nonprofits organizations, except that 24 CFR 84.23 and 84.53 do not apply, and program income is to be used as the federal share under 24 CFR 84.24(b). These regulations include allowable costs and non-Federal audit requirements.

8.7 Environmental Review Responsibilities

Activities under this part are subject to environmental reviews by HUD under 24 CFR part 50. Each subrecipient shall supply all available, relevant information necessary for the DHS to perform for each property any environmental review required by 24 CFR part 50. The Division, its subrecipient if applicable, also shall carry out mitigating measures required or select alternate eligible property. HUD may eliminate from consideration any application that would require an Environmental Impact Statement (EIS).

The DHS or subrecipient, or any contractor of the DHS or subrecipient, may not acquire, rehabilitate, convert, lease, repair, dispose of, demolish, or construct property for a project under this part, or commit or expend HUD or local funds for eligible activities under this part, until the DHS has performed an environmental review under 24 CFR part 50 and the DHS has received HUD approval of the property.

8.8 Davis Bacon Act

The provisions of the Davis Bacon Act do not apply.

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8.9 Procurement of Recovered Materials

The DHS and its contractors must comply with Section 6002 of the Solid Waste Disposal Act, as amended by the Resource Conservation and Recovery Act. The requirements of Section 6002 include procuring only items designated in guidelines of the Environmental Protection Subrecipient (EPA) at 40 CFR part 247 that contain the highest percentage of recovered materials practicable, consistent with maintaining a satisfactory level of competition, where the purchase price of the items exceeds $10,000 or the value of the quantity acquired by the preceding fiscal year exceeded $10,000; procuring solid waste management services in a manner that maximizes emergency and resource recovery; and establishing an affirmative procurement program for procurement of recovered materials identified in the EPA guidelines.

8.10 Displacement, Relocation, and Acquisition

Minimizing displacement: Consistent with other goals and objectives of ESG, the DHS and its subrecipients must assure that they have taken all reasonable steps to minimize the displacement of persons (families, individuals, businesses, nonprofit organizations, and farms) as a result of a project assisted under ESG.

Temporary relocation not permitted: No tenant-occupant of housing (a dwelling unit) that is converted into an emergency shelter may be required to relocate temporarily for a project assisted with ESG funds, or be required to move to another unit in the same building/complex. When a tenant moves for a project assisted with ESG funds under conditions that trigger the Uniform Relocation Assistance and Real Property Acquisition Polices Act of 1970 (URA), the tenant should be treated as permanently displaced and offered relocation assistance and payments consistent with URA.

Relocation assistance for displaced persons: In general, a displaced person must be provided relocation assistance at the levels described in, and in accordance with, the URA and 49 CFR part 24. A displaced person must be advised of his or her rights under the Fair Housing Act. Whenever possible, minority persons shall be given reasonable opportunities to relocate to comparable and suitable decent, safe, and sanitary replacement dwellings, not located in an area of minority concentration, that are within their financial means. This policy, however, does not require providing a person a larger payment than is necessary to enable a person to relocate to a comparable replacement dwelling. As required by Section 504 of the Rehabilitation Act and 49 CFR part 24, replacement dwellings must also contain the accessibility features needed by displaced person with disabilities.

Displaced person: The term "displaced person" means any person, family, individual, business, nonprofit organization, or farm, including any corporation, partnership, or association, that moves from real property, or moves personal property from real property, permanently, as a direct result of acquisition, rehabilitation, or demolition for a project assisted under the ESG program.

This includes any permanent, involuntary move for an assisted project, including any permanent move from the real property that is made:

  • After the owner (or person in control of the site) issues a notice to move permanently from the property or refuses to renew an expiring lease, if the move occurs on or after:
  • The date of the submission by the DHS or subrecipient, as applicable, of an application for assistance to HUD (or the Division, as applicable) that is later approved and funded if the DHS or sub-recipient has site control as evidenced by a deed, sales contract or option contract to acquire the property; or
  • The date on which the DHS or sub-recipient selects the applicable site. If the DHS or subrecipient does not have site control at the time of application, provided that the DHS or subrecipient eventually obtains control over the site.
    • Before the date described in this section, if the DHS or HUD determines that the displacement resulted directly from acquisition, rehabilitation, or demolition for the project; or
  • By a tenant-occupant of a dwelling unit and the tenant moves after execution of the agreement covering the acquisition, rehabilitation, or demolition of the property for the project.

A person does not qualify as a displaced person if:

  • The person has been evicted for cause based upon a serious or repeated violation of the terms and conditions of the lease or occupancy agreement; violation of applicable Federal, state and local law, or other good cause; and the DHS determines that the eviction was not undertaken for the purpose of evading the obligation to provide assistance.
  • The person moved into the property after the submission of the application but, before signing a lease and commencing occupancy, was provided written notice of the project, its possible impact on the person, and the fact that the person would not qualify as a "displaced person" as a result of the project;
  • The person is ineligible under 49 CFR 24.2(a)(ii); or
  • HUD determines that the person was not displaced as a direct result of acquisition, rehabilitation, or demolition of the project.

The DHS or subrecipient may, at any time, request that HUD determine whether a displacement is or would be covered by this rule. Refer to other requirements of 24 CFR 576.408 as applicable.

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8.11 Section 504 of the Rehabilitation Act of 1973

Subrecipients must comply with Section 504 of the Rehabilitation Act of 1973 (The Act). Pursuant to the requirement of The Act, subrecipients must ensure that no otherwise qualified disabled person shall, solely by reason of their disability be excluded from the participation in, be denied the benefits of, or be subject to discrimination, including discrimination in employment, in any program or activity that receives or benefits from Federal financial assistance. The subrecipient must also ensure that requirements of The Act shall be included in the agreements with and be binding on all of its subrecipients, contractors, subcontractors, assignees or successors.

8.12 Non-Discrimination and Equal Opportunity

Subrecipients are required to ensure that ESG-funded services are made available to all on a nondiscriminatory basis, and to publicize this fact. This availability must reach persons of any particular handicap, race, color, religion, sex, age, familial status or national origin within the subrecipient's service area.

8.13 Faith-Based Organizations

Federal subrecipients are required to treat all organizations fairly and without regard to religion in federal programs. It is HUD policy that, within the framework of constitutional church-state guidelines, faith-based organizations should be able to compete on an equal footing with other organizations for federal funding. Accordingly, organizations that are faith-based are eligible, on the same basis as any other organization, to participate in HUD's programs and activities. Neither the federal government nor a state or local government receiving funds under a HUD program or activity shall discriminate against an organization on the basis of the organization's religious character or affiliation. HUD supports the participation of faith-based organizations in its programs.

Faith-based activities are eligible to receive ESG funds per 24 CFR 576.406 under the following conditions:

  1. Organizations that are religious or faith-based are eligible, on the same basis as any other organization, to receive ESG funds. Neither the Federal Government nor a State or local government receiving funds under ESG shall discriminate against an organization on the basis of the organization's religious character or affiliation.
  2. Organizations that are directly funded under the ESG program may not engage in inherently religious activities, such as worship, religious instruction, or proselytization as part of the programs or services funded under ESG. If an organization conducts these activities, the activities must be offered separately, in time or location, from the programs or services funded under ESG, and participation must be voluntary for program participants.
  3. Any religious organization that receives ESG funds retains its independence from Federal, State, and local governments, and may continue to carry out its mission, including the definition, practice, and expression of its religious beliefs, provided that the religious organization does not use direct ESG funds to support any inherently religious activities, such as worship, religious instruction, or proselytization. Among other things, faith-based organizations may use space in their facilities to provide ESG- funded services, without removing religious art, icons, scriptures, or other religious symbols. In addition, an ESG-funded religious organization retains its authority over its internal governance, and the organization may retain religious terms in its organization's name, select its board members on a religious basis, and include religious references in its organization's mission statements and other governing documents.
  4. An organization that receives ESG funds shall not, in providing ESG assistance, discriminate against a program participant or prospective program participant on the basis of religion or religious beliefs.
  5. ESG funds may not be used for the rehabilitation of structures to the extent that those structures are used for inherently religious activities. ESG funds may be used for the rehabilitation of structures only to the extent that those structures are used for conducting eligible activities under the ESG program. Where a structure is used for both eligible and inherently religious activities, ESG funds may not exceed the cost of those portions of the rehabilitation that are attributable to eligible activities in accordance with the cost accounting requirements applicable to ESG funds. Sanctuaries, chapels, or other rooms that an ESG-funded religious congregation uses as its principal place of worship, however, are ineligible for funded improvements under the program.
  6. Disposition of real property after the term of the grant, or any change in use of the property during the term of the grant, is subject to government-wide regulations governing real property disposition (see 24 CFR parts 84 and 85).
  7. If the subrecipient that is a local government voluntarily contributes its own funds to supplement federally funded activities, the subrecipient has the option to segregate the Federal funds or commingle them. However, if the funds are commingled, this section applies to all of the commingled funds.

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8.14 Lobbying Requirements

Subrecipients must include Lobbying Policies in program policies and procedures that summarize the community or subrecipient's policy on employees contacting or communicating with a federal subrecipient, member of congress, or congressional staff member as an advocate for funding of any program.

8.15 Financial Management and Procurement Requirements

Subrecipients must comply with applicable requirements outlined in 2 CFR 200 and 24 CFR Part 84/85.

8.16 Other Federal Requirements

Subrecipients must comply with applicable Federal requirements as reflected in 24 CFR 576.404, 576.406, 576.407 and 576.408.

8.17 Other State Requirements

Subrecipients must comply with applicable State requirements as reflected in the Grant Accountability and Transparency Act - 30 ILCS 708/1 et seq.

8.18 Terminating Assistance Policy

If a program participant violates program requirements, the subrecipient may terminate the assistance in accordance with a formal process established by the subrecipient that recognizes the rights of individuals affected. Per 24 CFR 576.402, the recipient or subrecipient must exercise judgment and examine in detail all extenuating circumstances when determining if a recipient's violation warrants termination. The subrecipient should review each circumstance case by case to ensure that a program participant's assistance is terminated only in the most severe cases.

Program participants receiving rental assistance or housing relocation and stabilization services must complete the following process prior to termination of participant's assistance:

  • Written notice to the program participant containing a clear statement of the reasons for termination.
  • A review of the decision, in which the program participant is given the opportunity to present written or oral objections before a person other than the person who made or approved the termination decision.
  • Prompt written notice of the final decision to the program participant.
  • When the Termination Policy is applied to a family or individual, assistance stops, but does not permanently terminate the recipient or subrecipient from providing assistance. In the future, assistance can be given to the same family or individual, after the re-evaluation process is met, as established under 24 CFR 576.402.

8.19 Confidentiality

The recipient and its subrecipients must develop and implement written procedures to ensure:

  • All records containing personally identifying information will be kept secure and confidential.
  • Victims of domestic violence, sexual assault, dating violence, or stalking shelter project, assisted by ESG will not have address or location disclosed to the public, except with written authorization of the person responsible for the operation of the shelter.
  • The address or location of a housing program participant will not be made public, except as provided under a preexisting privacy policy of the recipient or subrecipient and consistent with state and local laws regarding privacy and obligations of confidentiality.
    • Procedures of confidentiality for the recipient and its subrecipients must be in writing and maintained for all records pertaining to each fiscal year of ESG funds for 5 years.
  • Documentation of recipient's records may include microfilming and photocopying of the original recipient's records. Participant's qualification documentation, as a family or individual at risk of homeless, must be retained for 5 years after the expenditure of all funds from the grant which the participant was served. Any Documentation which is pertinent to the ESG grant for purposes of audits, examinations, excerpts, and transcripts are not limited to the required retention period, but expand the needed retainment for proper review, under Federal Government rights.
  • The public has the right to reasonably request access to documentation of ESG funds which have served recipients, during the preceding 5 years. All public access requests must be consistent with state and local laws regarding privacy and obligations of confidentiality, in accordance to 24 CFR 576.500.


  1. Habitability Inspection Doc (pdf) for Shelter and RR/HP
  2. Monitoring Tool (Pending)
  3. Link to FAQ Doc

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