Download:
pdf |
pdfU.S. Department of Housing and Urban Development
Housing
FY19 NOFA Housing Counseling Training Grant
FR-6300-N-30
Application Due Date: 05/30/2019
FY19 NOFA Housing Counseling Training Grant
FR-6300-N-30
TABLE OF CONTENTS
I. Funding Opportunity Description.
II. Award Information.
III. Eligibility Information.
A. Eligible Applicants.
B. Cost Sharing or Matching.
C. Threshold Requirements.
D. Statutory and Regulatory Requirements Affecting
Eligibility.
E. Program Specific Requirements.
F. Criteria for Beneficiaries.
IV. Application and Submission Information.
A. Obtaining an Application Package.
B. Content and Form of Application Submission.
C. System for Award Management (SAM) and Dun and
Bradstreet
Universal Numbering System (DUNS) Number.
D. Application Submission Dates and Times.
E. Intergovernmental Review.
F. Funding Restrictions.
G. Other Submission Requirements.
V. Application Review Information.
A. Review Criteria.
B. Review and Selection Process.
C. Anticipated Announcement and Award Dates.
VI. Award Administration Information.
A. Award Notices.
B. Administrative, National and Department Policy
Requirements
for HUD recipients.
C. Reporting.
D. Debriefing.
VII. Agency Contacts.
VIII. Other Information.
IX. Appendix.
U.S. Department of Housing and Urban Development
Program Office:
Funding Opportunity Title:
Announcement Type:
Funding Opportunity Number:
Primary CFDA Number:
Due Date for Applications:
Housing
FY19 NOFA Housing Counseling
Training Grant
Initial
FR-6300-N-30
14.316
05/30/2019
Overview
For Further Information Regarding this NOFA: Please direct questions regarding the
specific program requirements of this Program Notice of Funding Availability (NOFA) to the
agency contact identified in Section VII.
OMB Approval Number(s):
2502-0567
I. Funding Opportunity Description.
A. Program Description.
1. Purpose
The purpose of this assistance is to continue investing in the creation and maintenance of a
professional and effective housing counseling industry that is able to meaningfully assist
consumers by providing them with the information they need to make informed housing choices
and maximizes the impact of Federal funding appropriated for HUD’s Housing Counseling
Program.
HUD acknowledges the need for more housing counselors trained in HECM default
counseling. According to HUD’s Annual Report to Congress on the FHA Mutual Mortgage
Insurance (MMI) Fund for FY2017, the HECM portfolio has been a substantial economic drain
on the MMI Fund. The Annual Report to Congress for FY2018 noted the Capital Ratio for the
HECM portfolio is negative 18.83 percent, a further decline from the restated negative 18.30
percent for FY 2017. HUD recognizes the important role housing counselors can provide in
helping to mitigate HECM defaults and foreclosures and decrease losses to
the MMI Fund. This assistance will expand the number of agencies and counselors who can
provide default counseling for Home Equity Conversion Mortgage (HECM) borrowers.
HUD recognizes six (6) Core Topics in which housing counselors need to be competent. These
are:
1. Financial Management;
2. Property Maintenance;
3. Homeownership and Tenancy;
4. Fair Housing and other Civil Rights Laws and Requirements
5. Housing Affordability;
6. Avoidance of, and responses to, rental and mortgage delinquency and avoidance of
eviction and mortgage default.
In addition to the six core topics, HUD will recognize courses that provide training in the area
of disaster preparation and recovery.
HUD recognizes that counselors may specialize in specific housing counseling topics, and that
counselors will need more than general housing counseling training in order to provide high
quality services that include general and specialized housing counseling topics.
This NOFA provides notice of a grant program that supports the provision of both basic housing
1 of 43
counseling training and specialized topics of training including HECM default counseling
to help meet these perceived needs. This financial support will assist housing counseling
agencies to increase the use of partnerships with local and state-wide organizations to provide
additional place-based training on state and local issues. In addition, this support should result in
an increased number of training scholarships.
Statutory requirements enacted in 2010 state that individual housing counselors participating in
HUD’s Housing Counseling Program shall demonstrate, by written examination, that they are
competent in providing counseling in each of the core topics. HUD published the Final Rule for
Housing Counseling Certification December 14, 2016. This rule implements statutory
requirements that housing counseling required under or provided in connection with all HUD
programs must be provided by HUD certified agencies and HUD certified housing counselors.
2. Changes from Previous NOFA.
Two-Year NOFA: One Competition Distributes Subsequent Year Funding if Available.
HUD will use the grant applications received for FY 2019 and the corresponding scores and
funding methodology to make awards for FY 2020, subject to the availability of
appropriations. HUD will contact eligible FY 2019 grantees to determine their interest in FY
2020 funds if available.
Funding:
Funding for this fiscal year will be $3,500,000. $1,000,000 from this funding will be
awarded specifically for providing training to housing counselors on HECM default
counseling.
Reporting:
Grantees will be required to submit a monthly report on counselors trained and courses offered
with all funding. Quarterly reports will include only counselors trained and courses offered
with HUD Training Grant Funds.
Application Charts:
Added Public Reporting Information and Privacy Statement.
Added HUD number, HUD-92910.
Clarified definition and updated instructions on scholarships, columns N, O, and P in Charts A
and B.
Changes to Rating Factors:
Rating Factor 1: Requirement to provide number of counselors since inception changed to
number of counselors trained in the last three grant years, June 1, 2015 to June 30, 2018
Rating Factor 3: Include narrative on actual expenditures in Rating Factor 3, Chart C –
Applicants must explain expenses in excess of 10% of the overall budget that did not result in
the direct provision of training services and were not supported by an approved Negotiated
Indirect Cost Rate Agreement (NICRA) or an indirect cost rate.
Proposed Funding Methodology:
Out of the $3,500,000, the first three tiers of funding will distribute $2,500,000 for all training
activities except HECM default training. Applications that earn a score of 75 points or more will
receive a base amount, as determined by HUD. The second tier of funding will be based on the
total number of scholarships awarded in FY2017 Grant Period of July 1, 2017 to June 30, 2018.
The third tier of funding will be based on the total number of classes provided during FY2017
Grant Period of July 1, 2017 to June 30, 2018.
The fourth tier of funding will distribute the $1,000,000 HECM default training funds to those
applicants that scored at least 75 points and will also provide HECM default training. Funding for
HECM default training will be based on the overall score of the applicant.
3. Definitions.
a. Standard Definitions
Authorized Organization Representative (AOR) is the person authorized to submit applications
on behalf of the organization via Grants.gov. The AOR is authorized by the E-Biz point of
contact in the System for Award Management. The AOR is listed in item 21 on the SF-424.
3 of 43
Award, as used in this NOFA means a federal, grant, cooperative agreement, loan, or loan
guarantee.
Catalog of Federal Domestic Assistance (CFDA) is a directory of the various Federal listings,
projects, services and activities offering financial and non-financial assistance and benefits to
the American public. CFDA Number is the unique number assigned to each program, project,
service or activity listed in the Catalog of Federal Domestic Assistance (CFDA).
Consolidated Plan is a document developed by states and local jurisdictions. This plan is
completed by engaging in a participatory process to assess their affordable housing and
community development needs and market conditions, and to make data-driven, place-based
investment decisions with funding from formula grant programs. (See 24 CFR part 91 for more
information about the Consolidated Plan and related Annual Action Plan).
Contract means a legal instrument by which a non-Federal entity purchases property or
services needed to carry out the project or program under a Federal award. The term as used
in this NOFA does not include a legal instrument, even if the non-Federal entity considers it
a contract, when the substance of the transaction meets the definition of a Federal award or
subaward (See 2 CFR 200.22.)
Contractor means an entity receiving a contract.
Deficiency is information missing or omitted within a submitted application. Deficiencies
typically involve missing documents, information on a form, or some other type of unsatisfied
information requirement (e.g., an unsigned form, unchecked box, etc.). Depending on specific
criteria, deficiencies may be either curable or non-curable.
Curable Deficiency – Applicants may correct a curable deficiency with timely action.
To be curable the deficiency must:
Not be a threshold requirement, except for documentation of applicant eligibility;
Not influence how an applicant is ranked or scored versus other applicants; and
Be able to be remedied within the time frame specified in the notice of deficiency.
Non-Curable Deficiency – An applicant cannot correct a non-curable deficiency after the
submission deadline.
Non-curable deficiencies are deficiencies if corrected would change an applicant’s score or rank
versus other applicants.
Non-curable deficiencies may result in an application being marked ineligible, or otherwise
adversely affect an application’s score and final determination.
DUNS Number is the nine-digit identification number assigned to a business or organization by
Dun & Bradstreet and provides a means of identifying business entities on a location-specific
basis. Requests for a DUNS number can be made by visiting the Online DUNS Request Portal.
Eligibility requirements are mandatory requirements for an application to be eligible for
funding. Deficiencies in meeting an eligibility requirement may be categorized as either curable
or non-curable.
Federal Awardee Performance and Integrity Information System (FAPIIS) is a database that has
been established to track contractor misconduct and performance.
Grants.gov is the website serving as the Federal government’s central portal for searching and
4 of 43
applying for federal financial assistance throughout the Federal government. Registration in
Grants.gov is required for submission of applications to prospective agencies.
NOTE: Passwords expire every 60 days. Accounts inactive for 1 year or more result in
removal of all account roles. For more account management information, review the
Applicant FAQs contained on the grants.gov web page.
Non-Federal Entity means a state, local government, Indian tribe, institution of higher
education (IHE), or non-profit organization carrying out a Federal award as a recipient or
subrecipient. Point of Contact (POC) is the person who may be contacted with questions about
the application submitted by the AOR. The point of contact is listed in item 8F on the SF424.
Promise Zones are federally-designated, high-poverty urban, rural and tribal communities
where the Federal government will partner with and invest in communities to accomplish these
goals: create jobs, leverage private investment, increase economic activity, expand educational
opportunities, and reduce violent crime.
Promotores/Promotoras are Spanish-speaking Community Health Workers who work in
their communities to reduce barriers to health services and make health care systems more
responsive.
Recipient means a non-Federal entity receiving an award directly from HUD to carry out an
activity under a HUD program.
Section 3 Business Concern means a business concern (1) 51 percent or more owned by
Section 3 residents; or (2) of which at least 30 percent of permanent, full-time employees are
currently Section 3 residents, or were Section 3 residents within three years of the date of first
employment with the business concern; or (3) provides evidence of a commitment to
subcontract over 25 percent of the dollar award of all subcontracts to be awarded to business
concerns meeting the qualifications in this definition.
Section 3 Residents means: 1) Public housing residents; or 2) Low and very-low income
persons, as defined in 24 CFR 135.5, who live in the metropolitan area or non-metropolitan
county where Section 3 covered assistance is expended.
Standard Form 424 (SF424) Application for Federal Assistance Programs, required
by discretionary grant programs.
Subaward means an award provided by a recipient to a subrecipient for the subrecipient to
carry out part of a Federal award received by the recipient. It does not include payments to a
contractor or payments to an individual’s beneficiary of a Federal program. A subaward may
be provided through any form of legal agreement, including an agreement that the recipient
considers a contract.
Subrecipient means a non-Federal entity receiving a subaward from a recipient to carry out
part of a HUD program; but does not include an individual’s beneficiary of such program.
A subrecipient may also receive other Federal awards directly from a Federal awarding agency
(including HUD).
System for Award Management (SAM), is an official website of the U.S. government. You can
access the website at Sam.gov There is no cost to use SAM. SAM is the official U.S.
Government system that consolidated the capabilities of Central Contractor Registry (CCR),
Excluded Parties List System (EPLS) and the Online Representations and Certifications
Application (ORCA). Registration with Sam.gov is required for submission of applications via
Grants.gov.
Threshold Requirement – Threshold requirements are a type of eligibility requirement.
Threshold requirements must be met for an application to be reviewed. Threshold requirements
5 of 43
are not curable, except for documentation of applicant eligibility. Threshold requirements are
listed in Section III.C. of this NOFA.
Applicants must ensure their application package addresses threshold requirements. Please
check your application carefully!
4. Program Definitions
HUD-Approved Housing Counseling Agencies. HUD-approved housing counseling agencies
are private and public nonprofit organizations that are exempt from taxation under section
501(a) pursuant to section 501(c) of the Internal Revenue Code of 1996, 26 U.S.C. 501(a) and
501(c), and approved by HUD, in accordance with HUD Handbook 7610.1 REV-5 and 24
CFR Part 214, to provide housing counseling services to clients directly, or through their
affiliates or branches, and which meet the requirements set forth in this part.
Eligible Training Recipients. Recipients of training offered by Grantees under the award that are
employed by housing counseling agencies participating in HUD's Housing Counseling Program.
5. Web Resources
The resources indicated provide details for the application process
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
Affirmatively Furthering Fair Housing
Code of Conduct list
Do Not Pay
Dun & Bradstreet
Request a DUNS Number
Equal Participation of Faith-Based Organizations
Federal Awardee Performance and Integrity Information System
Federal Subaward Reporting System) FSRS
Grants.gov
Grants.gov support
Healthy Homes Strategic Plan
Healthy Housing Reference Manual
HUD Funds available
HUD’s Strategic Plan
HUD Grants
NOFA webcasts
Procurement of recovered materials
Promise Zones
Section 3 Business Registry
State Point of Contact List
System for Award Management (SAM))
Real Property Acquisition and Relocation
6 of 43
USASpending
B. Authority.
HUD's Housing Counseling Program is authorized by Section 106 of the Housing and Urban
Development Act of 1968 (12 U.S.C. 1701x) and Section 4 of the Department of Housing and
Urban Development Act (42 U.S.C. 3533) as amended by Subtitle D – Office of Housing
Counseling of Dodd-Frank Wall Street Reform and Consumer Protection Act. The Housing
Counseling implementing regulations are found at 24 CFR part 214. Additional guidance is
provided in the HUD Handbook 7610.1, REV-5. Funding for this NOFA is provided by the
Consolidated Appropriations Act, 2018 (Public Law 115-141, approved March 23, 2018).
II. Award Information.
A. Available Funds
Funding for this fiscal year will be $3,500,000. $1,000,000 from this funding will awarded
specifically for providing training to housing counselors on HECM default counseling.
.
Additional funds may become available for award under this NOFA as a result of HUD's efforts
to recapture unused funds, use carryover funds, or because of the availability of additional
appropriated funds. Use of these funds is subject to statutory constraints. All awards are subject
to the applicable funding restrictions contained in this NOFA.
Awards are available to provide, under cooperative agreements with HUD, training activities
designed to improve and standardize the quality of counseling provided by housing counselors
employed by “Participating Agencies.” Participating Agencies are all housing counseling and
Intermediaries participating in HUD’s Housing Counseling Program, including HUD-approved
counseling agencies, Affiliates and Branches of HUD-approved Intermediaries, HUD-approved
Multi-State Organizations (MSO), and State Housing Finance Agencies (SHFA).
B. Number of Awards.
HUD expects to make approximately four (4) awards from the funds available under this
NOFA. The number of awards under this NOFA will depend on the number of eligible
applicants and other factors. For information on the methodology used to make award
determinations under this NOFA, please see Section V.B. Review and Selection Process
below.
C. Minimum/Maximum Award Information
7 of 43
The minimum award amount for this project is $1, with a maximum award request of $3,500,000
which includes $1,000,000 specifically for providing training to housing counselors on HECM
default counseling.
Estimated Total Funding:
Minimum Award Amount:
Maximum Award Amount:
$3,500,000
$1 Per Project Period
Per Project Period To Be Determined
D. Period of Performance
The period of performance for this project begins on October 1, 2019 and ends on September
30, 2020.
Estimated Project Start Date:
Estimated Project End Date:
Length of Project Periods:
Length of Project Periods Explanation of Other:
10/01/2019
09/30/2020
Other
The initial period of performance for
grants awarded under this program will be
for a period of 12 months. For planning
purposes, Applicants should assume that
the period of performance is October 1,
2019 through September 30, 2020.
HUD expects to make approximately 4
awards from the funds available under
this NOFA.
HUD may at its discretion, fund a single
organization to deliver the full spectrum
of activities eligible for funding, or make
multiple awards under this NOFA. HUD
also reserves the right to not make any
awards.
E. Type of Funding Instrument.
Funding Instrument Type:
Cooperative Agreement
HUD expects to use a cooperative agreement but reserves the right to use the award instrument
it determines to be most appropriate. All awards will be made on a cost reimbursement basis in
accordance with, and subject to, the requirements in 2 CFR Part 200. If an Applicant receives an
award, it must comply with and must ensure that sub-recipients also comply with the above
requirements.
Awards made as cooperative agreements may entail significant HUD involvement including,
but not limited to, the following items:
• Review and approval of marketing of courses assistance.
• Work plan changes, including but not limited to increasing the availability of remote
training;
• Review and approval of proposed courses, including course materials;
• HUD may provide grantees with counseling content standards.
• Review and approval of training locations, technology and logistics. HUD reserves the
right to review and approve or reject training locations, technology and logistics as well
as the type of training and courses offered; including review to ensure appropriate
access is provided for persons with disabilities and persons with limited English
proficiency (LEP);
• Review and approval of evaluation instruments and methodology for determining value
8 of 43
of courses and impact;
• Identifying functional needs of persons with disabilities or other population groups and
outreach techniques; or
• Course audit by HUD staff.
If funds are provided subject to a Cooperative Agreement, HUD will also exercise the right to
have substantial involvement by conducting monitoring reviews, requesting quarterly reports,
approval of all proposed deliverables documented in the Applicant’s Work Plan or Statement of
Work (SOW), and determining whether the agency meets all certification and assurance
requirements.
III. Eligibility Information.
A. Eligible Applicants.
Nonprofits having a 501(c)(3) status with the IRS, other than institutions of higher education
State governments
County governments
City or township governments
Non-profits having a 501(c)(3) status with the IRS, other than institutions of higher education
Applicants must be a public or private non-profit organization and must submit evidence of
“tax exempt” status under section 501(a) pursuant to section 501(c)(3) of the Internal Revenue
Code (26 USC 501(a) and (c)(3)). Applicants may also be SHFAs and other units of local,
county or state government. Applicants must have at least two years of experience providing
housing counseling training services nationwide to housing counselors employed by housing
counseling agencies participating in HUD’s Housing Counseling Program. Applicants are not
required to be HUD Approved Housing Counseling Agencies.
Applicants may utilize in-house staff, sub-grant recipients, Training Partners, qualified thirdparty trainers, and consultants, with requisite experience and capacity. HUD strongly
encourages the partnering by Grantees with SHFAs and other Training Partners. However, one
organization must be designated as the primary applicant. This NOFA is structured to
encourage agencies to sub-allocate funding to sub-grantees and/or Training Partners. Subgrantees and Training Partners may include SHFAs; units of local, county or state government;
and local or state housing coalitions/networks that are public or private non-profit
organizations. sub-grantees and/or Training Partners must have “tax exempt” status under
section 501(a) pursuant to section 501(c)(3) of the Internal Revenue Code [26 USC 501(a) and
(c)(3)] or be an established SHFA. The funding methodology of this NOFA will incentivize
such Training Partnerships.
As required in the Code of Federal Regulations (CFR) at 2 CFR 25.200 and 24 CFR Part 5 Subpart K, all applicants for financial assistance must have an active Data Universal Numbering
System (DUNS) number (http://fedgov.dnb.com/webform) and have an active registration in the
9 of 43
System for Award Management (SAM) (www.sam.gov) before submitting an application.
Getting a DUNS number and completing SAM registration can take up to four weeks; therefore,
applicants should start this process or check their status early.
See also Section IV.B for necessary form and content information.
All Applicants and Sub-grantees must disclose to HUD the status of active HUD Office of
Inspector General (OIG) audits or investigations at the time of the NOFA application
submission date. At the time of application submission or thereafter, HUD may determine that
applicants are not eligible for grant funding based on its review of HUD OIG audits and
investigations.
B. Cost Sharing
This Program does not require cost sharing, matching or leveraging.
.
C. Threshold Requirements.
Applicants who fail to meet any of the following threshold eligibility requirements will be
deemed ineligible. Applications from ineligible applicants will not be evaluated.
1. Timely Submission of Applications – Applications submitted after the deadline stated
within this NOFA that do not meet the requirements of the grace period policy will be marked
late. Late applications are ineligible and will not be considered for funding. See also Section IV
Application and Submission Information, part D. Application Submission Dates and Times
.
D. Statutory and Regulatory Requirements Affecting Eligibility
Eligibility Requirements for Applicants of HUD’s Grants Programs
The following requirements affect applicant eligibility. Detailed information on each
requirement is posted on HUD’s Funding Opportunities Page (click here).
Outstanding Delinquent Federal Debts
Debarments and/or Suspensions
Pre-selection Review of Performance
Sufficiency of Financial Management System
False Statements
Mandatory Disclosure Requirement
Prohibition Against Lobbying Activities
Equal Participation of Faith-Based Organizations in HUD Programs and Activities
E. Program Specific Requirements.
Geographic Coverage. Applicants must propose to provide the housing counseling trainings
10 of 43
nationwide. The proposed training program must be national in scope. In addition, the proposed
training program offered by or in conjunction with Training Partners will focus on state and
local housing issues.
Required activities:
1. Eligible Training Recipients. Recipients of training offered by Grantees under the
award must be housing counselors employed by housing counseling agencies
participating in HUD’s Housing Counseling Program.
2. Trainers. Trainings must be delivered by experienced trainers who have been trained in
adult education and have practical experience and/or subject matter expertise in the
specific field they are presenting. Multiple trainers can be used for a single course to
fulfill these requirements.
3. Open Enrollment. Training enrollment and assistance provision must be open. For
example, enrollment, eligibility and scholarships may not be restricted to affiliates
or branches of a specific intermediary or participating housing counseling agency or
conducted in a way that favors affiliates or branches of a particular organization.
4. Housing Counseling Training must not be limited to in-person, but must be offered via
a variety of models, to increase ease of access and meet the preference(s) of counselors
– including webinars and other internet-based training models. Live, internet-based, and
other training modes of delivery must be accessible to persons with disabilities.
Applicants may offer courses through additional modes of delivery.
5. Learning Checks. Regardless of format, training must have learning checks including a
final examination that confirm a counselor’s participation and measure understanding of
course material and learning objectives.
6. Core Topics. The Final Rule for Housing Counseling Certification, enacted on
December 14, 2016, states that individual housing counselors participating in HUD’s
Housing Counseling Program shall demonstrate, by written examination, that they are
competent in providing counseling in each of the following core topics: 1) financial
management; 2) property maintenance; 3) responsibilities of homeownership and
tenancy; 4) fair housing laws and requirements; 5) housing affordability, and ; 6)
avoidance of, and responses to, rental and mortgage delinquency and avoidance of
eviction and mortgage default. The proposed work plan must describe how the six
Core Topics required will be incorporated in the applicant’s proposed courses.
7. Scholarships. The proposal must include a scholarship element, including assistance
with travel, hotel, and/or tuition expenses for eligible housing counselors.
8. Underserved /Underrepresented Populations. All training programs must include a
strong emphasis on effectively serving limited English proficient, rural, lower income,
persons with disabilities and other underserved/underrepresented of housing consumer
populations. Affirmative efforts must be made to ensure that existing housing counseling
capacity in underserved and underrepresented housing consumer populations is
preserved and expanded. To support the delivery of services in communities where
English is not the primary language, the training and testing must be culturally sensitive.
Eligible Activities.
Applicants may propose to develop and implement a comprehensive and ongoing training
program for housing counselors working for agencies participating in HUD’s Housing
11 of 43
Counseling Program. The training program may contain both basic and must include
advanced courses. Eligible activities may also include ongoing efforts to evaluate training
quality and impact and assess the need for additional training.
An applicant may propose to provide training on one or more of the training topics listed below.
The proposed training curriculum must include the Core Topics identified under Section I.A.,
Program Purpose. Complete Chart B- Proposed Performance to identify those classes which
include the Core Topics. Training specific to HECM default counseling must also be
offered as part of the proposed training curriculum.
1. General Housing Counseling. Teach counselors the principles and applications of
housing counseling from the lender’s and the counselor’s point of view. Review the
skills and tools needed to be an effective housing counselor. Provide overviews of
the industry from a national perspective, as well as information about pre- and postpurchase counseling for homeowners, delinquency, and default counseling.
2. Pre-Purchase Counseling. Train counselors in conducting results-oriented individual
counseling sessions for prospective homebuyers, including financial literacy, budget
analysis, developing corrective action plans and timelines for success, and facilitating
progress as customers overcome obstacles and move toward mortgage-readiness. Train
counselors regarding state-of-the-art software designed specifically for credit rebuilding,
debt reduction, automated budgeting, and down payment savings accumulation. Use
sample customer cases to identify obstacles and simulate counseling sessions. Teach
counselors to give consumers more information about the true cost of living by
incorporating both housing and transportation costs into measures of affordability. Teach
counselors to conduct educational seminars and advise clients regarding how to avoid
predatory lenders and common lending pitfalls. Provide counselors the knowledge and
tools to help borrowers avoid inflated appraisals, unreasonably high interest rates,
unaffordable repayment terms, and other conditions that can result in a loss of equity,
increased debt, default, and eventually foreclosure. Train counselors to counsel potential
homebuyers to get an independent home inspection before the home sale closing, and
train counselors in any HUD required home inspection materials, if applicable. Train
counselors on the HUD/EPA Lead Disclosure Rule (24 CFR part 35, sub-part A) and the
Lead Safe Housing Rule (24 CFR part 35, sub-parts B, K and R). See the lead-safety
information and guidance at: https://www.hud.gov/program_offices/healthy_homes
Train counselors to counsel potential homebuyers on radon and related issues. See
EPA’s radon guidance at www.epa.gov/radon/pubs/index.html and HUD’s at
https://www.hud.gov /healthyhomes, clicking on “About Radon” (including the Radon
fact sheet linked from that page). Train counselors to help clients manage debt, avoid
predatory lenders, or discriminatory loan limits and avoid mortgage default. Teach
counselors how to read the warning signs of debt problems and how to recognize
predatory lenders, as well as identify available resources to help keep homeowners out
of financial trouble. Inform counselors about HUD’s Equal Access rule and the
provision of housing without regard to sexual orientation, gender identification, or
marital status. Assist counselors with obtaining a thorough understanding of state and
federal regulations, including the Real Estate Settlement Procedures Act of 1974 (12
U.S.C. 2601 et seq.) (RESPA) and the Truth in Lending Act (15 U.S.C. 1601 et seq.) so
they are fully versed in State and local requirements in the counseling service area.
12 of 43
3. Training Counselors on Lending Practices and Financial Analysis. Train counselors
in lending practices, analysis of financials, risk elements, and general concepts affecting
conventional and government-insured mortgage loan decisions. Provide counselors with
effective procedures and techniques to teach clients about financing options and how to
choose appropriate loan products and features. Review case studies to illustrate the
functional areas of the underwriting process, from the application to the loan sale.
4. Homebuyer Education Programs. Teach counselors how to: deliver a
comprehensive homebuyer education program; to use the best materials and methods
to train homebuyers with regard to increasing homebuyer financial literacy; create
informed consumers when shopping for a home and mortgage loan; improve one’s
budget and credit profiles; train counselors to counsel potential homebuyers to get an
independent home inspection before home sale closing, and train counselors regarding
any HUD required home inspection materials, if applicable; make homebuyers
knowledgeable about the Lead Disclosure Rule for pre-1978 homes, EPA’s
Rehabilitation, Repair, and Paint Rule and the testing available for lead hazards, toxic
mold, radon, and other conditions that affect the living environment and can add
substantial costs to home owners having to address these issues after settlement; and
maintaining one’s home and finances after purchase.
5. Foreclosure Prevention. Train counselors on the protocol for counseling homeowners
in financial distress. Address all aspects of delinquency and default, including reasons
for default, ways to maximize income and reduce expenses, calculating delinquencies,
understanding the players in the mortgage marketplace, loss-mitigation options for
FHA-insured and other loans, information about foreclosure laws and timelines, tips on
effectively intervening with lenders and servicers, managing multiple mortgages or
liens, and the pros and cons of refinancing. This training should include information on
Federal and other foreclosure prevention programs, such as the Flex Modification
Program, as well as how to identify and report loan scams.
6. Reverse Mortgages. Train counselors about reverse mortgages for elderly homeowners,
including FHA-insured Home Equity Conversion Mortgages (HECM). Teach them to
understand products and programs, analyze plans, compare their costs and benefits, and
identify alternatives. Also, review relevant counseling skills and ethics.
7. HECM Default Counseling. Train housing counselors to work with HECM
borrowers who are delinquent and/or at risk of defaulting due to unpaid property taxes,
insurance, homeowner association dues, or other fees and assessments. Counselors do
not need to be HECM roster counselors to perform HECM default counseling.
8. Reverse Mortgage- HUD Roster Examination Preparation. Provide counselors
in-class in preparation for the HUD HECM Counseling roster examination.
9. Reverse Mortgage Continuing Education. Provide counselors a continuing
education course that offers advanced topics on reverse mortgage counseling.
10. Non-Delinquency Post Purchase. Train counselors in how to advise individuals and
conduct workshops aimed at ensuring the long-term success of new homebuyers,
including home maintenance and repair, lead safety for pre-1978 homes (including
EPA’s Rehabilitation, Repair, and Paint Rule), financial literacy and management,
insurance, and record keeping.
11. Counseling Individuals and Families that are Homeless or at Risk of Becoming
Homeless. Train counselors about the various social services available to which they
should be referring homeless and potentially homeless families and individuals. Provide
13 of 43
12.
13.
14.
15.
16.
17.
information on federal, state, and local homeless programs, including the Continuum of
Care (CoC) Program and how clients can access these programs. Share strategies on how
to partner with local public service providers to ensure that clients receive attention and
assistance quickly and efficiently. Review the unique characteristics of the homeless
population to help counselors understand the types of financial literacy, physical, and
social problems facing the families and individuals who seek their assistance.
Counseling on Emergency Preparedness and Recovery. Train counselors how to
prepare agency and personal Emergency Preparedness Plans. Train counselors
about unique circumstances faced by victims of disasters and other emergencies.
Discuss Federal Emergency Management Agency (FEMA), FHA and Small
Business Administration programs that assist with recovery.
HUD’s Housing Counseling Program Requirements. Train counselors about the
requirements of HUD’s Housing Counseling Program, including the reporting and
delivery of homeownership counseling and education for Local Housing
Counseling Agencies, National and Regional Intermediaries and SHFAs.
Housing Counseling Program Management. Train managers and future managers
about opportunities to diversify funding sources; recruiting, managing, and retaining
counseling staff; performing contract reviews and programmatic assessments;
marketing to a variety of target audiences; complying with fair housing and other civil
rights requirements for recipients of federal financial assistance; maintaining focus on
quality assurance and higher proficiency; increasing capacity; and efficiently managing
case files utilizing a variety of time management techniques.
Rental Housing. Train counselors in how to educate individuals on how to secure and
maintain residence in rental housing, tenant/landlord responsibilities, Lead Disclosure
Rule requirements and lead safety awareness, fair housing and other civil rights
requirements, state and local laws, the eviction process, budgeting, and how to access
rental assistance programs. Teach counselors to give consumers more information
about the true cost of living by incorporating both housing and transportation costs into
measures of affordability. Train counselors regarding mobility counseling, for
example: promoting strategies which result in moves to low poverty and racially
diverse communities, closer to jobs, quality education, health care and other services;
outreach and recruitment of landlords, owners and developers in diverse communities
of opportunity; and outreach to community organizations that can provide support to
families to solicit their involvement, identify available housing, and link families to
services and other support in diverse communities of opportunity.
Federal Housing Administration (FHA). Train housing counselors about FHA-insured
financing, including minimum requirements of FHA loans, loan limits, advantages of
financing through FHA, HUD Real Estate Owned (REO), FHA appraisal requirements,
sections 203k, 203b, and 203h mortgage insurance programs and HECM.
Fair Housing/Lending and Civil Rights. Train housing counselors how to provide
households with information, counseling and/or education on discriminatory housing,
lending and insurance, practices and the rights and remedies available under federal, state
and local fair housing laws. Train housing counselors how to provide households with the
name and contact information for local fair housing groups or government agencies that
enforce fair housing laws. Train housing counselors to make persons aware of federal,
state and local physical accessibility requirements, as well as innovative
14 of 43
housing design or construction to increase access for persons with disabilities. Train
housing counselors on requirements to provide effective communication to persons with
limited English proficiency and persons with disabilities. Train housing counselors on
HUD requirements for equal access to housing on the basis of sexual orientation, gender
identity, and marital status, as well as protections against discrimination on the bases
under state or local law. Train housing counselors on how their clients may file a
housing discrimination complaint. The contact information for the HUD Office of Fair
Housing and Equal Opportunity is: 1-800-669-9777 (Toll free) 1-800-927-9275 (TTY)
www.hud.gov/fairhousing. ;
18. Fair Lending and Mortgage Fraud Counseling. Train housing counselors about how
to identify and counsel regarding fair lending violations and mortgage fraud, including
loan documentation review. Familiarize counselors with the requirements of the Fair
Housing Act, truth in lending laws, predatory lending laws, HUD’s Equal Access rule,
and their companion statutes and regulations as they apply to housing providers,
mortgage lenders, realtors, homebuilders, public agencies, and non-profit organizations.
Train counselors to recognize lender and/or real estate practice that create disparate
impact on clients who are members of Fair Housing Act protected classes or other
prohibited bases. Train housing counselors in how to provide guidance and assistance to
the client regarding identifying fair lending violations, loan scams, and mortgage fraud,
filing a formal complaint and pursuing a formal investigation with the appropriate
authorities under these laws, for example with the Loan Modification Scam Prevention
Network: http://www.preventloanscams.org and the HUD Office of Inspector General
(OIG) Hotline Toll-free at: 800-347-3735 Fax: 202-708-4829 Email: hotline@hudoig.gov
19. Affirmatively Furthering Fair Housing. Train counselors to provide households with
information, counseling and/or education on discriminatory housing, lending, and
insurance practices and the rights and remedies available under federal, state, and local
fair housing laws. Train counselors to provide households with names and contact
information for local fair housing groups or government agencies that enforce fair
housing laws. Train counselors to make persons aware of federal, state and local
accessibility requirements, as well as innovative housing design or construction to
increase access for persons with disabilities; Train counselors to develop a system to
share information about possible discrimination and, when there is information that
suggests that individual or systemic violations of fair housing laws have occurred or are
occurring, training housing counselors to provide this information to HUD or local Fair
Housing Assistance Program (FHAP) agencies. Examples of information that suggest
systemic discrimination include knowing of multiple clients of the same protected class
who are unable to obtain housing from the same housing provider or knowing of
multiple clients who allege discrimination or harassment involving the same housing
provider; train counselors to affirmatively market counseling and education services to
those least likely to apply; Train counselors to become familiar with affirmative fair
housing marketing requirements to inform clients of housing opportunities that provide
greater housing choice or mobility. Train counselors to become familiar with
accessibility requirements; serve clients with disabilities who live in segregated or
institutional settings, and their representatives; educate clients with disabilities on
effective housing search strategies; Inform clients of skilled providers of housing search
15 of 43
assistance; inform clients of housing builders, management companies, real estate, and
brokers that are skilled in providing housing opportunities in the most integrated
setting appropriate to the needs of persons with disabilities; and /or Train counselors to
create, maintain, and market a database of accessible housing for persons with
disabilities; Train counselors to ensure housing counseling training activities are
accessible to persons with disabilities, including making reasonable accommodations,
as necessary. Train counselors on how to take reasonable steps to provide meaningful
access to persons with limited English proficiency (LEP).
20. Making Housing Counseling "culturally sensitive". Prepare counselors to be more
culturally sensitive to the needs of the community they are serving.
21. Basic Math Instruction. Add as a component of the certification examination
preparation, to include basic math calculations and using an on-line calculator.
22. How to Start a Housing Counseling Program. HUD published the Final Rule for
Housing Counseling Certification December 14, 2016. This rule implements statutory
requirements that housing counseling required under or provided in connection with all
HUD programs must be provided by HUD certified agencies and HUD certified housing
counselors. This course is designed for agencies covered by HUD’s Final Rule for
Housing Counseling Certification, but not currently participating in HUD’s
Housing Counseling Program. Course should provide information on how to start a
HUD Housing Counseling Program. Suggested topics include how to identify the needs
of target population, identify counseling services, develop a work plan, create intake,
disclosure, and privacy forms, identify resources, identify a client management system,
collect data for services provided, and an overview on how to apply for HUD approval
to participate in HUD’s Housing Counseling Program. A list of Other HUD Programs
covered by this final rule can be found at https://www.hudexchange.info/resource/5192
/other-hud-programs-covered-under-huds-final-rule-for-housing-counselingcertification /
23. Disaster Preparation. More detailed suggestions for
class topics:
a)
Counseling in the Disaster Recovery Period: Recovery counseling will
focus on relocation, re-housing, rebuilding, helping clients navigate FEMA, insurance,
local aid and grant programs, credit counseling, and foreclosures. In addition to traditional
housing counseling activities, the agencies and their counselors will provide community
support activities. Counselors need to understand disaster recovery programs from various
agencies such as HUD (Section 8, FHA loans- 203(h) & 203(k), foreclosure policies),
FEMA, SBA, USDA, GSEs, and others. They also need to understand homeowners and
flood insurance. Counselors need to be prepared to work with highly stressed clients and
staff who may be affected by Post Traumatic Stress Disorder.
) Emergency Preparedness Plans and Continuity of Operations Plans (agency): train
agency managers how to develop agency Emergency Preparedness Plans and Continuity of
Operations Plans (COOP) and how to implement the Plans. Provide resources, templates, etc.
from HUD, FEMA, Red Cross and other agencies. Discuss how to work with local communities
and other agencies for services and funding and how to formalize the relationships. Business
continuity planning must account for both man-made and natural disasters. Agencies should plan
to manage any emergency. Be prepared to assess the situation, use common sense and
16 of 43
available resources to take care of agency staff, clients, and community. A COOP will help keep
an agency operating as it responds and recovers from the effects of a disaster or emergency
situation.
c) Family Emergency Preparedness Plans: Training counselors to assist clients in
preparing a Family Emergency Preparedness Plan. Provide resources, templates, etc. from
HUD, FEMA, Red Cross and other
agencies.
Additional Requirements. Agencies selected as grantees must comply with the following
requirements:
1. Salary Limitation for Consultants. FY2019 Grant funds may not be used to pay or
to provide reimbursement for payment of the salary of a consultant/trainer, whether
retained by the federal government or the Grantee, at a rate more than the equivalent
of General Schedule 15, Step 10 base pay rate for which the annual rate for FY2019 is
$136,659. The hourly rate is $65.48.
2. Accessibility. In the conduct of training and educational courses, successful applicants
must give priority to methods that provide physical access to individuals with
disabilities, i.e., holding the live, in-person training or any other type of meeting in an
accessible location, in accordance with the regulations implementing Section 504 of the
Rehabilitation Act of 1973 and Titles II and III of the Americans with Disabilities Act
of 1990, as applicable. All programs or activities must be held in accessible locations or
use accessible technology unless the recipient can demonstrate that doing so would
result in a fundamental alteration of the program or an undue financial and
administrative burden, in which case the recipients must take any action that would not
result in such an alteration or such burden but would nevertheless ensure that
individuals with disabilities receive the benefits and services of the program or activity,
e.g., training at an alternate accessible site, in-home training. Individuals with
disabilities must receive services in the most integrated setting appropriate to their
needs. Accessibility arrangements auxiliary aids and services, and reasonable
accommodations may include, but are not limited to: materials provided in different
formats, including large print or Braille; interpreter services – including such service
accompanying web-based training; recording and archiving live, in-person training; and
use of closed captioning. Arrangements for registration, testing, and evaluation must be
accessible to persons with disabilities. Information on how to request available assistive
services and reasonable accommodations must be available, as well as available in
different formats. Regarding accessible technology, HUD requires its funding recipients
to adopt the goals and objectives of Section 508 of the Rehabilitation Act of 1973 by
ensuring, whenever electronic and information technology (EIT) is used, procured, or
developed, that persons with disabilities have access to and use of the information and
data made available through the EIT on a comparable basis as is made available to and
used by persons without disabilities.
3. Effective Communications and Meaningful Access. Successful applicants must
ensure that all training notifications as well as communication during training sessions
are provided in a manner that is effective for persons with hearing, visual, and other
communications-related disabilities consistent with Section 504 of the Rehabilitation
Act of 1973 (24 CFR 8.6), and as applicable, the Americans with Disabilities Act. This
17 of 43
4.
5.
6.
7.
includes ensuring that training materials are in appropriate alternative formats as
needed, g., Braille, audio, large type, sign language interpreters, and assistive listening
devices, etc. All products and tools for capacity building must be accessible in
accordance with Section 504 of the Rehabilitation Act of 1973 (see, for example, 24
CFR 8.6, on effective communications). Applicants obtaining federal financial
assistance from the Department shall take reasonable steps to ensure meaningful access
to their programs and activities for Limited English Proficient Persons (LEP). For more
information on LEP, please visit
https://www.hud.gov/program_offices/fair_housing_equal_opp/promo tingfh/lep-faq
Reports. All grant recipients will be required to report to HUD on a monthly and
quarterly basis, as specified in the cooperative agreement.
Code of Conduct. Applicants that are subject to 2 CFR Part 200 (including most
nonprofit organizations and state, local, and tribal governments or government agencies
or instrumentalities that receive federal awards of financial assistance) are required to
develop and maintain a written code of conduct See 24 CFR 84.42 and 85.36(b)(3). The
code of conduct must prohibit real and apparent conflicts of interest that may arise
among employees, officers, or agents; prohibit the solicitation and acceptance of gifts or
gratuities by an organization’s officers, employees and agents for their personal benefit
in excess of minimal value; and outline administrative and disciplinary actions available
to remedy violations of such standards. Self-recusal will not eliminate a potential or
apparent conflict of interest. Prior to entering into an agreement with HUD, the applicant
will be required to submit a copy of its code of conduct and describe the methods it will
use to ensure that all officers, employees, and agents of the organization are aware of the
code of conduct.
Financial Management Systems. Applicants selected for funding must provide
documentation demonstrating that the applicant’s financial management systems satisfy
the requirements in the applicable regulations at 2 CFR Part 200. Consistent with the
requirements of the Single Audit Act Amendments of 1996 (31 U.S.C. 7501-07), if the
applicant expended $750,000 or more in federal awards in its most recent fiscal year,
such documentation must include a certification from, or a copy of, the most recent audit
by the applicant’s independent public accountant attesting to the fact that the applicant
maintains internal controls over federal awards, complies with applicable laws,
regulations, and contract or grant provisions, and prepares appropriate financial
statements. The applicant will have at least 30 calendar days to respond to this
requirement. If an applicant does not respond within the prescribed time or responds
with insufficient documentation, then HUD may determine that the applicant has not met
this requirement and may withdraw the award offer. If an applicant has not expended
$750,000 or more in federal awards in its most recent fiscal year, HUD, or its assignee
may conduct an audit of the applicant’s financial system. HUD will work with the
applicant to meet federal financial management system standards prior to HUD releasing
funds.
Indirect Cost Rate.
Consistent with 2 CFR 200.414, applicants may use their negotiated rate or the de
minimis rate of 10 percent of modified total direct costs (MTDC). See Section IV.F of
this NOFA for indirect cost rules information.
Indirect costs are, by nature, administrative and represent the expenses of doing business
18 of 43
that are not readily identified, exclusively with a specific grant, contract, project
function or activity but are necessary for the general operation of the organization and the
conduct of activities it performs. 2 CFR 200, subpart E – Cost Principles, establishes the
federal requirements for the determination of allowable and unallowable direct and
indirect facilities and administrative (F&A) costs and is available at: https://www.ecfr
.gov/cgi-bin/text-idx?node=2:1.1.2.2.1.5&;;rgn =div6 . Grantees are required to properly
document their cost methodologies to demonstrate that indirect costs meet these criteria.
8. Participation in HUD-Sponsored Program Evaluation. See Section VI, B below.
9. Ensuring the Participation of Small Businesses, Small Disadvantaged
Businesses, and Women-Owned Businesses. See Section VI, B below.
10. Executive Order 13166, Improving Access to Services for Persons with Limited
English Proficiency (LEP). Housing counseling training organizations shall take
reasonable steps to ensure meaningful access to their services to individuals with
Limited English Proficiency. Applicants are to comply with Executive Order 13166,
“Improving Access to Services for Persons with limited English Proficiency”, and
may refer to the Department’s January 22, 2007 Final Guidance to Federal Financial
Assistance Recipients Regarding Title VI Prohibition Against National Origin
Discrimination Affecting Limited English Proficient Persons (72 FR 2732).
11. Executive Order 13279, Equal Protection of the Laws for Faith-Based and Community
Organizations. HUD is committed to full implementation of Executive Order 13279 in
the operation of its programs.
12. The Americans with Disabilities Act of 1990 (42 U.S.C. 12101 et seq.), the Age
Discrimination Act of 1975 (42 U.S.C. 6101 et seq.), and Title IX of the Education
Amendments Act of 1972 (20 U.S.C. 1681 et seq.).
13. Affirmatively Furthering Fair Housing. Under Section 808(e) (5) of the Fair Housing
Act, HUD has a statutory duty to affirmatively further fair housing. HUD requires the
same of its funding recipients. To meet this requirement, in the narrative responses to the
Rating Factor 3 (B) (1) (f), applicants must describe the organization's training, outreach
and other activities that affirmatively market fair housing information, including:
• Training counselors to provide households with information, counseling and/or
education on discriminatory housing, lending, and insurance practices and the rights
and remedies available under federal, state, and local fair housing and other civil rights
laws;
• Training counselors to provide households with names and contact information for
local fair housing groups or government agencies that enforce fair housing and other
civic rights laws;
• Training counselors to make persons aware of federal, state and local accessibility
requirements, as well as innovative housing design or construction to increase access
for persons with disabilities;
• Training counselors to develop a system to share information about possible
discrimination and, when there is information that suggests that individual or systemic
19 of 43
•
violations of fair housing laws have occurred or are occurring, training housing
counselors to provide this information to HUD or local Fair Housing Assistance
Program (FHAP) agencies. Examples of information that suggest systemic
discrimination include knowing of multiple clients of the same protected class
who are unable to obtain housing from the same housing provider or knowing
of multiple clients who allege discrimination or harassment involving the same
housing provider; training counselors to affirmatively market counseling and
education services to those least likely to apply; Train counselors to provide
households with information on housing options in a range of neighborhoods,
including those of higher opportunity, allowing households to identify
neighborhoods that best fit their needs;
• Train counselors to become familiar with affirmative fair housing
marketing requirements to inform clients of new or rehabilitated sources of
information for housing opportunities that provide greater housing choice or
mobility, as well as affirmative fair housing requirements for housing
counseling agencies, such as displaying the fair housing symbol;
•
Training counselors on methods for affirmatively marketing housing counseling
services, such as advertising in publications in non-English languages or
oriented to certain population groups and co-marketing with settlement or
advocacy organizations;
•
Training counselors to become familiar with accessibility
requirements; serve clients with disabilities who live in segregated or
institutional settings, and their representatives; educate clients with disabilities
on effective housing search strategies; Inform clients of skilled providers of
housing search assistance; inform clients of housing builders, management
companies, real estate, and brokers that are skilled in providing housing
opportunities in the most integrated setting appropriate to the needs of persons
with disabilities; and /or Training counselors to create, maintain, and market a
database of accessible housing for persons with disabilities;
Training counselors must ensure housing counseling training activities are
accessible to persons with disabilities, including making reasonable
accommodations, as necessary. Training counselors must also describe how they
will take reasonable steps to provide meaningful access to persons with Limited
English Proficiency (LEP) including but not limited to translating materials into
non-English language. For more information about how this requirement may be
met for this grant, see Rating Factors 2 and 3 in Section V below.
•
F. Criteria for Beneficiaries.
Criteria are also listed under Additional Requirements in Section E above.
IV. Application and Submission Information.
A. Obtaining an Application Package.
Instructions for Applicants.
You must download both the Application Instruction and the Application Package from
Grants.gov. To ensure you are using the correct Application Package and Application
Instructions, you must verify the CFDA Number and CFDA Description on the first page of the
Application Package, and the Opportunity Title and the Funding Opportunity Number match the
Program and NOFA to which you are applying.
The Application Package contains the Adobe forms created by Grants.gov. The Instruction
Download contains official copies of the NOFA, and forms necessary for a complete
application. The Instruction Download may include Microsoft Word, Microsoft Excel and
additional documents.
An applicant demonstrating good cause may request a waiver from the requirement for
electronic submission. For example, a lack of available Internet access in the geographic area
in which your business offices are located. Lack of SAM registration or valid DUNS is not
deemed good cause. If you cannot submit your application electronically, you must ask in
writing for a waiver of the electronic grant submission requirements. HUD will not grant a
waiver if HUD does not receive your written request at least 15 days before the application
deadline or if you do not demonstrate good cause. An email request sent 15 days before the
application will also be considered. If HUD waives the requirement, HUD must receive your
paper application or email request before the deadline of this NOFA. To request a waiver and
receive a paper copy of the application materials, you must contact:
Judy Ayers Britton
Email: judith.a.ayersbritton@hud.gov
U.S. Department of Housing and Urban Development
21 of 43
Brickell Plaza Federal Building
909 SE 1st Avenue, Room 500
Miami, FL 33176
Inquiries regarding this NOFA should be submitted to housing.counseling@hud.gov and
indicate 'FY19 Training NOFA' in the subject line.
B. Content and Form of Application Submission.
You must verify boxes 11, 12, and 13 on the SF424 match the NOFA for which you are
applying. If they do not match, you have downloaded the wrong Application Instruction and
Application Package.
Submission of an application that is otherwise sufficient, under the wrong CFDA and Funding
Opportunity Number is a curable deficiency.
1. Content.
Forms for your package include the forms outlined below:
Forms / Assurances Submission Requirement
/ Certifications
Notes / Description
HUD Applicant
HUD will provide instructions HUD will provide instructions to
Recipient
to grantees on how the form is grantees on how the form is to be
Disclosure Report
to be submitted.
submitted.
(HUD) 2880
Applicant/Recipient
Disclosure/Update
Report
Additionally, your complete application must include the following narratives and non-form
attachments.
SF424 Application for Federal Assistance In block 8.d of the form, applicant must include a
9-digit number for the applicant’s zip code. Please be sure to check your DUNS number and
ensure that it is listed on SAM.gov with an active registration, and that the person submitting
the application has an ID and password for the Grants.gov system and has been authorized to
submit the application on behalf of the applicant organization named in block 8a of the SF424
by the eBiz Point of Contact listed in the SAM.gov registration for the applicant organization.
Since applicants are not required to request a specific grant amount, all applicants should enter
$1 in block 18a.
1. Organization Description. Applicants must provide a brief description, no more
than 225 words, as they would like it to appear in the press release issued by HUD
in the event that the applicant is funded through this NOFA. Each description
should contain: name of organization; organizational history; purpose and
mission; years of service; affordable housing services provided; number of clients
served to date; and agency web address for additional information.
22 of 43
2. Non-profit Status. Each applicant is required to submit, for itself and for any
organization with which it is partnering for the purpose of this NOFA, a legible
copy of the document that supports the applicant’s claim to be a tax exempt nonprofit organization (for example, a 501(c)(3) determination letter issued by the
IRS). The documentation must contain the official name, address, and telephone
number of the legal authority that granted the tax exemption.
3. Narrative Statements. Applicants must provide narrative statements responding
to specific questions in this NOFA, including the data requested in the Housing
Counseling Training Charts. The narratives along with the completed excel
charts and exhibits will constitute the basis for evaluating the application.
4. Charts. Applicants must provide completed Housing Counseling Training
Charts in Excel format as a required part of their application submission. The
charts must be completed in their entirety in order for Applicants to receive full
points. The completed charts and exhibits along with the narratives will
constitute the basis for evaluating the application.
2. Format and Form.
Narratives and other attachments to your application must follow the following format
guidelines.
Size Limitations and Format for Narrative Statements. Applicants must be as specific and
direct as possible. Applicants are limited to a total of 50 double-spaced, 12-point font, singlesided pages for the narrative portion. Course descriptions including summaries, learning
objectives, learning measures/ test questions, and handouts or other student aids are excluded
from the page limitation. Pages in excess of the size limit will not be read. Number the pages of
the narrative statements and include a header that includes the applicant’s name and the Rating
Factor number and title. Within each narrative, clearly identify each sub-factor immediately
above the response for that sub-factor. Valid file names may only include the following UTF-8
characters: A-Z, a-z, 0-9, underscore, hyphen, space, period.
If applicants use any other characters when naming their attachment files their
applications will be rejected.
C. System for Award Management (SAM) and Dun and Bradstreet Universal Numbering
System (DUNS) Number.
1. SAM Registration Requirement
Applicants must be registered with SAM before submitting their application. In addition,
applicants must maintain an active SAM registration with current information while they have
an active Federal award or an application or plan under consideration by HUD.
2. DUNS Number Requirement.
Applicants must provide a valid DUNS number, registered and active at SAM, in the
application. DUNS numbers may be obtained for free from Dun & Bradstreet.
23 of 43
3. Requirement to Register with Grants.gov.
Anyone planning to submit applications on behalf of an organization must register at
Grants.gov and be approved by the EBiz Point of Contact in SAM to submit applications for
the organization.
Registration for SAM and Grants.gov is a multi-step process and can take four (4) weeks or
longer to complete if data issues arise. Applicants without a valid registration cannot submit an
application through Grants.gov. Complete registration instructions and guidance are provided at
Grants.gov. See also Section IV.B for necessary form and content information.
D. Application Submission Dates and Times.
The application deadline is 11:59:59 p.m. Eastern time on 05/30/2019. Applications must be
received no later than the deadline.
Submit your application to Grants.gov unless a waiver has been issued allowing you to submit
your application in paper form. Instructions for submitting your paper application will be
contained in the waiver of electronic submission.
“Received by Grants.gov” means the applicant received a confirmation of receipt and an
application tracking number from Grants.gov. Then Grants.gov assigns an application tracking
number and date-and time-stamps each application upon successful receipt by the Grants.gov
system. A submission attempt not resulting in confirmation of receipt and an application
tracking number is not considered received by Grants.gov.
Applications received by Grants.gov must be validated by Grants.gov to be received by HUD.
“Validated by Grants.gov” means the application has been accepted and was not rejected with
errors. You can track the status of your application by logging into Grants.gov, selecting
“Applicants” from the top navigation, and selecting “Track my application” from the dropdown
list. If the application status is “rejected with errors,” you must correct the error(s) and
resubmit the application before the 24-hour grace period ends. Applications in “rejected with
errors” status after the 24-hour grace period expires will not be received by HUD. Visit
Grants.gov for a complete description of processing steps after submitting an application.
HUD strongly recommends applications be submitted at least 48 hours before the
deadline and during regular business hours to allow enough time to correct errors or overcome
other problems.
You can verify the contents of your submitted application to confirm Grants.gov received
everything you intended to submit. To verify the contents of your submitted application:
• Log in to Grants.gov.
• Click the Check Application Status link, which appears under the Grant
Applications heading in the Applicant Center page. This will take you to the Check
Application Status page.
• Enter search criteria and a date range to narrow your search results.
24 of 43
• Click the Search button. To review your search results in Microsoft Excel, click
the Export Data button.
• Review the Status column.
• To view more detailed submission information, click the Details link in the
Actions column.
• To download the submitted application, click the Download link in the Actions column.
Please make note of the Grants.gov tracking number as it will be needed by the Grants.gov Help
Desk if you seek their assistance.
HUD may extend the application deadline for any program if Grants.gov is offline or not
available to applicants for at least 24 hours immediately prior to the deadline date, or the system
is down for 24 hours or longer and impacts the ability of applicants to cure a submission
deficiency within the grace period.
HUD may also extend the application deadline upon request if there is a presidentially-declared
disaster in the applicant’s area.
If these events occur, HUD will post a notice on its website establishing the new, extended
deadline for the affected applicants. HUD will also include the fact of the extension in the
program’s Notice of Funding Awards required to be published in the Federal Register.
In determining whether to grant a request for an extension based on a presidentially-declared
disaster, HUD will consider the totality of the circumstances including the date of an applicant’s
extension request (how closely it followed the basis for the extension), whether other applicants
in the geographic area are similarly affected by the disaster, and how quickly power or services
are restored to enable the applicant to submit its application.
PLEASE NOTE: Busy servers, slow processing, or large file sizes, improper registration or
password issues are not valid circumstances to extend the deadline dates or the grace period.
1. Amending or Resubmitting an Application.
Before the submission deadline, you may amend a validated application through Grants.gov by
resubmitting a revised application containing the new or changed material. The resubmitted
application must be received and validated by Grants.gov by the applicable deadline.
If HUD receives an original and a revised application for a single proposal, HUD will evaluate
only the last submission received by Grants.gov before the deadline.
2. Grace Period for Grants.gov Submissions.
If your application is received by Grants.gov before the deadline, but is rejected with errors, you
have a grace period of 24 hours after the application deadline to submit a corrected, received,
and validated application through Grants.gov. The date and time stamp on the
Grants.gov system determines the application receipt time. Any application submitted during
the grace period not received and validated by Grants.gov will not be considered for funding.
There is no grace period for paper applications.
25 of 43
3. Late Applications.
An application received after the NOFA deadline date that does not meet the Grace Period
requirements will be marked late and will not be received by HUD for funding consideration.
Improper or expired registration and password issues are not causes that allow HUD to accept
applications after the deadline.
4. Corrections to Deficient Applications.
HUD will not consider information from applicants after the application deadline. HUD may
contact the applicant to clarify other items in its application. HUD will uniformly notify
applicants of each curable deficiency. A curable deficiency is an error or oversight that if
corrected it would not alter, in a positive or negative fashion, the review and rating of the
application. See curable deficiency in definitions section. Examples of curable (correctable)
deficiencies include inconsistencies in the funding request and failure to submit required
certifications. These examples are non-exhaustive.
When HUD identifies a curable deficiency, HUD will notify the authorized representative. The
email is the official notification of a curable deficiency. Each applicant must provide accurate
email addresses for receipt of these notifications and must monitor their email accounts to
determine whether a deficiency notification has been received. The applicant must carefully
review the request for cure of deficiency and must provide the response in accordance with the
instructions contained in the deficiency notification.
Applicants must email corrections of curable deficiencies
to applicationsupport@hud.gov within the time limits specified in the notification. The time
allowed to correct deficiencies will not exceed 14 calendar days or be less than 48 hours from the
date of the email notification. The start of the cure period will be the date stamp on the email sent
from HUD. If the deficiency cure deadline date falls on a Saturday, Sunday, Federal holiday, or
on a day when HUD’s Headquarters are closed, then the applicant’s correction must be received
on the next business day HUD Headquarters offices in Washington, DC are open.
The subject line of the email sent to applicationsupport@hud.gov must state: Technical Cure
and include the Grants.gov application tracking number (e.g., Subject: Technical Cure GRANT123456). If this information is not included, HUD cannot match the response with the
application under review and the application may be rejected due to the deficiency. This only
applies to certain programs and responses should be sent to the NOFA specific program.
Corrections to a paper application must be sent in accordance with and to the address indicated
in the notification of deficiency. HUD will treat a paper application submitted in accordance
with a waiver of electronic application containing the wrong DUNS number as having a curable
deficiency. Failure to correct the deficiency and meet the requirement to have a DUNS number
and active registration in SAM will render the application ineligible for funding.
5. Authoritative Versions of HUD NOFAs. The version of these NOFAs as posted on
Grants.gov are the official documents HUD uses to solicit applications.
26 of 43
E. Intergovernmental Review.
This program is not subject to Executive Order 12372, Intergovernmental Review of Federal
Programs.
F.Funding Restrictions.
Financial Management Systems. Applicants selected for funding must provide documentation
demonstrating that the applicant’s financial management systems satisfy the requirements in the
applicable regulations at 2 CFR Part 200. Consistent with the requirements of the Single Audit
Act Amendments of 1996 (31 U.S.C. 7501-07), if the applicant expended $750,000 or more in
federal awards in its most recent fiscal year, such documentation must include a certification
from, or a copy of, the most recent audit by the applicant’s independent public accountant
attesting to the fact that the applicant maintains internal controls over federal awards, complies
with applicable laws, regulations, and contract or grant provisions, and prepares appropriate
financial statements. The applicant will have at least 30 calendar days to respond to this
requirement. If an applicant does not respond within the prescribed time or responds with
insufficient documentation, then HUD may determine that the applicant has not met this
requirement and may withdraw the award offer. If an applicant has not expended $750,000 or
more in federal awards in its most recent fiscal year, HUD, or its assignee may conduct an audit
of the applicant’s financial system. HUD will work with the applicant to meet federal financial
management system standards prior to HUD releasing funds.
Indirect Cost Rate.
Normal indirect cost rules apply. If you intend to charge indirect costs to your award, your
application must clearly state the rate and distribution base you intend to use. If you have a
Federally negotiated indirect cost rate, your application must also include a letter or other
documentation from the cognizant agency showing the approved rate.
Nongovernmental organizations and Indian tribal governments. If you have a Federally
negotiated indirect cost rate, your application must clearly state the approved rate and
distribution base and must include a letter or other documentation from the cognizant agency
showing the approved rate. If you have never received a Federally negotiated indirect cost rate
and elect to use the de minimis rate, your application must clearly state you intend to use the de
minimis rate of 10% of Modified Total Direct Costs (MTDC). As described in 2 CFR 200.403,
costs must be consistently charged as either indirect or direct costs but may not be double
charged or inconsistently charged as both. Once an organization elects to use the de minimis
rate, the organization must apply this methodology consistently for all Federal awards until the
organization chooses to negotiate for a rate, which the organization may apply to do at any time.
Documentation of the decision to use the de minimis rate must be retained on file for audit.
State and local governments. If your department or agency unit has a Federally negotiated
indirect cost rate, your application must include that rate, the applicable distribution base, and a
letter or other documentation from the cognizant agency showing the negotiated rate. If your
department or agency unit receives more than $35 million in federal funding, you may not claim
indirect costs until you receive a negotiated rate from your cognizant agency for indirect costs as
provided in Appendix VII to 2 CFR part 200.
27 of 43
If your department or agency unit receives no more than $35 million in federal funding and your
department or agency unit has prepared and maintains documentation supporting an indirect rate
proposal in accordance with 2 CFR part 200, appendix VII, you may use the rate and distribution
base specified in your indirect cost rate proposal. Alternatively, if your department or agency
unit receives no more than $35 million in federal funding and has never received a Federally
negotiated indirect cost rate, you may elect to use the de minimis rate of 10% of MTDC. As
described in 2 CFR 200.403, costs must be consistently charged as either indirect or direct costs
but may not be double charged or inconsistently charged as both. Once elected, the de minimis
rate must be applied consistently for all Federal awards until you choose to
negotiate for a rate, which you may apply to do at any time. Documentation of the decision to
use the de minimis rate must be retained on file for audit.
G. Other Submission Requirements.
1. Application Certifications and Assurances
By signing the SF424 either through electronic submission or in paper copy submission (for
those granted a waiver), applicant affirms certifications and assurances associated with the
application are material representations of the facts upon which HUD will rely when making an
award to the applicant. If it is later determined the signatory to the application submission
knowingly made a false certification or assurance or did not have the authority to make a legally
binding commitment for the applicant, the applicant may be subject to criminal prosecution, and
HUD may terminate the award to the applicant organization or pursue other available remedies.
Each applicant is responsible for including the correct certifications and assurances with its
application submission, including those applicable to all applicants, those applicable only to
federally-recognized Indian tribes, and those applicable to applicants other than federallyrecognized Indian tribes. All program-specific certifications and assurances are included in the
program Instructions Download on Grants.gov.
2. Lead Based Paint Requirements
When providing education or counseling on buying or renting housing that may include pre1978 housing, when required by regulation or policy, inform clients of their rights under the
Lead Disclosure Rule (24 CFR part 35, subpart A), and, if the focus of the education or
counseling is on rental or purchase of HUD-assisted pre-1978 housing, the Lead Safe Housing
Rule (subparts B, R, and, as applicable, F - M).
4. Application Checklist. The Application Checklist indicates forms, information,
certifications and assurances that apply to this NOFA.
V. Application Review Information.
A. Review Criteria.
1. Rating Factors.
Criteria. Applications will be evaluated competitively according to the Rating Factors for
28 of 43
Award described below and ranked against all other applicants. See table below for a summary
of the Rating Factors and Sub Factors, their point values and information on whether to use the
charts or provide separate narratives.
RATING FACTOR
POIN
TS
RF1
Capacity of the Applicant 35
RF1(1)
Capacity/Experience of
Organization
RF1(2)
Performance/Grant
Requirements
14
10
CHART
NARRATIVE
Chart A, Past
Performance
Narrative on Training
Experience
N/A
Only if applicant has
not received a HUD
HC Training grant
for HUD FY 16
Sub factor 2.1 (goals)
RF1(3)
Measuring Student
Satisfaction
6
Chart A. Past
Performance
Narrative on Student
Satisfaction
RF1(4)
Scholarships
5
Chart A, Past
N/A
Performance, Columns
L,
,
N, O
RF2
Need/NOFA Priorities
10
RF2(1)
Needs Data
8
N/A
Narrative on Needs
RF2(2)
NOFA Priorities
2
N/A
Priorities 1 and 2
RF3
Soundness of Approach/
Scope of Housing
Counseling Training
Services
40
RF3(1)
Past Performance -Impact
5
(1) Chart C, Actual
Expenditures
(0) Scholarships.
(1) Include narrative on
actual expenditures
(2) Chart A, Column P
RF3(2)
Work Plan
19
Chart B, Proposed
Performance.
columns C, D, E
(1)(a) Course outline
for each class
(1) (b)
29 of 43
(1) (c)
(2), (3), (4), (%)
RF3(3)
Scholarships and Fees
RF3 (4)
Training Partners
RF3(5)
10
N/A
Narrative on
scholarships and fees
3
Chart E
(d) (1) and (2)
Management Activities
3
N/A
Narrative
RF4
Leveraging Resources
7
RF4(A)
Itemize Leveraging
5
Chart D
N/A
RF4(B)
Fees
2
Chart E
N/A
RF5
Achieving Results and
Program Evaluation
8
RF5(a)
Evaluation Plan
6
N/A
Narrative on
Information Collection,
Data Analysis and
Work Plan Adjustments
RF5(b)
Grant Expenditure History
2
N/A
Only if applicant has
not received a HUD HC
Training grant for HUD
FY 16
Rating Factors for Award Used to Rate and Rank Applications. The Rating Factors for
award, and maximum points for each factor, are outlined below. These Rating Factors will be
used to evaluate applications. The maximum score is 100 for all applicants. HUD may rely on
other information, such as performance reports, financial status information, monitoring reports,
audit reports and other information available to HUD in making score determinations under any
Rating Factor.
Rating Factor 1: Capacity of the Applicant
Maximum Points: 35
HUD uses responses to this Rating Factor to evaluate the applicant’s readiness to begin and
ability to implement the proposed work plan detailed in Rating Factor 3.
1. Capacity/Experience of Organization (14 points)
Using Chart A, Past Performance, all applicants must provide the requested information for all
housing counseling courses including those required for certifications such as foreclosure and
advanced foreclosure certification that the applicant and any applicant partners provided during
the FY 2017 Grant Period of July 1, 2017 and June 30, 2018. See instructions for completion in
30 of 43
Chart A, Past Performance tab. Also indicate in the narrative response:
• Total years of experience providing housing counseling training and total number of
housing counselors that have participated in your training program in the last three grant
years, June 1, 2015 to June 30, 2018.
• Total years of experience providing web-based (interactive or non-interactive), or other
forms of remote training;
• Average years of housing counseling trainer experience for proposed trainers;
• Relevant experience providing training in a manner that is effective for persons with
disabilities and persons with limited English proficiency, including in-person, webbased, and other forms of remote training.
2. Performance/Grant Requirements (10 Points)
Applicants that did not receive a HUD Housing Counseling grant or HUD Housing Counseling
Training grant during the FY 2017 Grant Period of July 1, 2017, to June 30, 2018, must provide
a response to this sub-factor. Previous HUD grantees may respond to this sub factor, but aren’t
required to do so, as HUD may utilize its own records to score regarding these compliance
issues.
In scoring this section, HUD will evaluate performance relative to goals and how well the
applicant has satisfied the requirements, including reporting, on HUD or other grants
received. If an applicant has not received a HUD Housing Counseling Training grant for the
period July 1, 2017 to June 30, 2018, the applicant should base its response on activities and
requirements under HUD’s Housing Counseling Program, other HUD grants, or other sources
of funding, such as other federal, state, local, or other awards. For non-HUD training grants,
provide contact information of funders.
• Goals and Accomplishments. Describe performance relative to quarterly and annual
reports submitted for FY 2017 training grant awards or other goals set during the FY
2017 Grant Period of July 1, 2017 to June 30, 2018, and approved extensions. Indicate
whether funds were fully spent, goals were met, and explain why they were not, if
applicable. If an extension was required, explain reason for not expending funds
within the grant period.
• HUD Oversight / Audits / Financial & Administrative Reviews. Significant findings on
oversight, Financial & Administrative Reviews and audits conducted by HUD staff,
HUD contractors and/or HUD’s Inspector General will be taken into consideration when
scoring this section. Significant findings may be findings that suggest an applicant has
operated its agency in a manner inconsistent with the Housing Counseling Program or
other HUD program requirements, including waste, fraud and abuse of grant funds and
fair housing or other civil rights requirements. HUD will develop and apply a scoring
scale based on the number of significant findings documented during a review(s) and/or
audit(s), and incidence of repeat findings, complaints, etc. HUD will also factor in the
applicant’s responsiveness to findings and implementation of corrective action, as well
as substantiated complaints received about the organization. HUD may also factor in
frequency and responsiveness to complaints, the Applicant’s responsiveness to findings
and implementation of corrective action, grantee performance/reporting, and counseling
activity reporting. For agencies not receiving a HUD grant, provide information and
documentation pertaining to oversight / audits of governing entities.
31 of 43
3. Measuring Student Feedback (6 points)
Scoring in this section will reward applicants that measure student feedback and make course
and/or test adjustments as a result of student feedback. In addition to completing Chart A,
applicants must attach a separate narrative that:
a. Describes the process to collect student feedback data;
b. Summarizes data collected during the FY 2017 Grant Period of July 1, 2017, to June 30,
2018;
c. Attach a copy of the data collection instruments utilized, if applicable;
d. Describes the course and/or test adjustments made as a result of student feedback during
the FY 2017 Grant Period of July 1, 2017, to June 30, 2018.
4. Scholarships – (5 points) Chart A, Past Performance, Columns N, O, & P - List the
number of scholarships provided for each scholarship type during the FY 2017 Grant Period of
July 1, 2017, to June 30, 2018.
Rating Factor 2: Need/NOFA Priorities
Maximum Points: 10
This Rating Factor addresses the applicant’s assessment of the need for training services for
housing counselors and the extent to which the proposed activities described in response to
Rating Factor 3 address these needs, in addition to certain NOFA Priorities.
1. Needs Data (8 Points) Answer the following:
Estimate the total number of counselors that may require general housing counseling training in
FY2019. Explain how the applicant estimated this number.
Describe and document the overall need and demand for each of the following training delivery
methods based on delivery during the prior two fiscal years: place-based, online-interactive, and
on-line non-interactive.
a. Under-served and Under Represented Populations. Indicate how the Applicant and
Training Partners propose to train counselors who serve communities with limited English
proficient, rural, lower income, persons with disabilities and other under-served and
underrepresented housing consumer populations. Rural Areas are defined by the U.S.
Department of Agriculture at 7 CFR 3550.10. Applicants must also describe how its housing
counseling training activities will provide access to persons with disabilities, including making
reasonable accommodations as necessary and how they will take steps to provide access to
persons with Limited English Proficiency (LEP).
b. HECM default counseling training. Applicants interested in offering HECM default
counseling training must indicate how the Applicant and Training Partners propose to train
counselors on HECM default counseling. Also, the Applicant must identify states and/or regions
that have the highest HECM originations for fiscal year 2018. HUD HECM origination data can
be found here.
(https://www.hud.gov/program_offices/housing/rmra/oe/rpts/hecmsfsnap/hecmsfsnap)
c. Incorporating Needs into Training Plan. Explain how applicant will incorporate the
training needs described above for determining delivery method, locations to offer classroom
training if applicable, and awarding scholarships. Applicants should apply this methodology in
detail when responding to Rating Factor 3 C. (1), Scholarships.
2. NOFA Priorities (2 Points)
The total number of points an applicant can receive under this sub-factor is two (2). Each
priority addressed below has a point value of one (1) point. An applicant may address as few or
as many of the priorities as they wish. It is up to the applicant to determine which combination
of the priorities is addressed. Regardless of the combination selected, a maximum of two (2)
32 of 43
points is available. Applicants must limit responses to 500 words per NOFA priority.
The following priorities apply to the Housing Counseling Training funding for the purpose of
this NOFA. Indicate if, and describe how, the applicant’s training work plan substantively
addresses the NOFA priority. Applicants may receive one point for demonstrating any one of
the following, with a maximum of 2 points awarded for these priorities overall.
Priority 1: Affirmatively Furthering Fair Housing.
a. Staff Training (1 point): Applicants must demonstrate that they will train their staff on
fair housing and civil rights laws, that they have a method of providing their clients with
information about their fair housing rights, and that they have established a mechanism for
referring potential fair housing violations to HUD, state or local fair housing agencies, or
private fair housing groups. For example, an applicant demonstrates that it has entered into a
memorandum of understanding with a fair housing enforcement agency that will provide fair
housing training and informational materials and accept referrals of potential fair housing
complaints; and,
b. Mobility Counseling (1 point): Applicants must describe how they will train housing
counselors to provide clients with mobility counseling and what information applicants will
train counselors to furnish to clients that will enhance their housing choices outside of areas of
minority and poverty concentration.
Priority 2: Lead-Based Paint. (1 point) Applicants may earn one (1) point by describing how
they will train housing counselors to inform clients about lead-based paint. Housing counselors
that provide education or counseling regarding Pre-Purchase/Home Buying, or Locating,
Securing, or Maintaining Residence in Rental Housing, are to be encouraged to inform clients
about their rights and responsibilities under the HUD Lead-Based Paint Disclosure Rule (24
CFR part 35, Subpart A), and, if the rental or purchase may be HUD-assisted, requirements of
24 CFR part 35, subparts B, K, and R.
Rating Factor 3: Soundness of Approach/Scope of Housing
Counseling Training Services
Maximum Points: 40
This Rating Factor addresses past performance and the quality and effectiveness of the proposed
work plan. In rating this factor, HUD will evaluate the extent to which the applicant presents a
detailed and sound approach for providing the proposed services. HUD will also evaluate the
extent to which the applicant demonstrates the cost-effectiveness of its activities, and
convincingly explains how the proposed activities will yield long-term results.
1. Past Performance - Impact (5 points) - To score this factor, HUD will analyze the Actual
Expenditures and Cost per Student during the FY 2017 Grant Period of July 1, 2017, to June 30,
2018.
Actual Expenditures – Chart C Actual Expenditures- HUD will evaluate the
applicant’s submitted detailed, comprehensive report of actual expenditures from all
funding sources during the FY 2017 Grant Period of July 1, 2017, to June 30, 2018. At
a minimum, the report must include salaries, fringe and other benefits, consultant/trainer
expenses, travel (staff, trainers), scholarships, rent (office and training venues), phone,
33 of 43
•
postage, supplies, technology/equipment, and indirect costs for administration of the
applicant’s FY2017 training program. Use Chart C to submit this information and
provide a narrative on actual expenditures. Applicants must explain expenses in excess
of 10% of the overall budget that did not result in the direct provision of training
services and were not supported by an approved Negotiated Indirect Cost Rate
Agreement (NICRA) or an indirect cost rate. Narrative must be provided to receive full
points. If the Applicant did not receive a HUD Housing Counseling Program Training
Grant during this time period, provide this information based on the Applicant’s entire
training budget for the same period. If applicable, the report should also include subgrants or allocations to Training Partners. Applicants must explain expenses in excess
of 10% of the overall budget that did not result in the direct provision of training
services and were not supported by an approved Negotiated Indirect Cost Rate
Agreement (NICRA) or an indirect cost rate.
• Cost per Student – Chart A Past Performance - Calculate the cost per student by
dividing the Total Expenditures (All Sources) on Chart C by the total number of
students shown in Column E, Chart A Past Performance. Enter this number in Column
Q. Explain any factors that may have impacted the cost per student such as number and
type of scholarships, locations, or other training expenses.
• Scholarships - Describe in a narrative the number of scholarships and percentage of the
HUD Housing Counseling Program Training grant was spent on travel, lodging, and
tuition during the FY 2017 Grant Period of July 1, 2017, to June 30, 2018. If the
applicant did not expend a HUD Housing Counseling Program Training grant during
this time period, provide this information based on the applicant’s entire training budget
for the same period. If applicable, explain any adjustments made to allocation of
scholarships based on changed needs. For example, an agency may add scholarships for
disaster related courses in response to the occurrence of natural disasters.
2. Work Plan (19 points).
The Work Plan must describe in detail how the applicant plans to develop and administer the
proposed training services, including administrative tasks, marketing, scholarships, and
compliance with Affirmatively Furthering Fair Housing and Federal Electronic and Information
Technology Accessibility and Compliance Act, Section 508.
1) Housing Counseling Training. The applicant must describe each course it plans to offer
and indicate which of the housing counseling Eligible Activities listed in section III. D. 3. the
applicant proposes to address in each course. Applicants must denote any national standards
that may have been incorporated into the development of the curriculum. Applicants offering
HECM default counseling training will be eligible for the additional $1,000,000 in funding under this
NOFA. HUD will award higher points to those applicants that include courses that support
Disaster Preparation and Recovery, Housing Counseling for Renters, Financial Stability, and
Sustainable Homeownership. Applicants must include information on HECM default
counseling training to be eligible for HECM default counseling funding as stated in Section IIC of this NOFA
a. Proposed Curriculum – Chart B. Proposed Performance For each course listed in Column
B answer the following:
1)Insert a brief course description in Column S including instructional goals for each course
2)In a narrative, provide a course outline (no more than 2 pages per course) describing the
following:
1. Course title.
2. Course length for classroom and web-based sessions.
3. All topics to be covered during course learning objectives for each course. Learning
objectives must encompass comprehension, application, analysis, and synthesis
34 of 43
cognitive levels of learning.
4. Understanding and comprehension explaining how learning checks are incorporated into
classroom and web-based courses.
5. If applicable, how the course supports one or more of the FY2019 Strategic
Objectives outlined in Paragraph 1) above.
6. Privacy and security policies in place to ensure counselors taking remote training
courses are protected, and how the remote training will be conducted in a way that
verifies the identity of the student and eliminates the opportunity for fraud, cheating,
and any other circumstances that would result in questioning the veracity, impact, and
applicability of the training.
7. Identify what criteria, including a course examination, will be established for
successful completion of the course.
8. If applicable, indicate the type of counselor certification this course will be used for.
9. Describe the process through which curriculum is developed. Describe research
conducted and indicate experts consulted for curriculum or test content development.
b. Administrative Staff and Trainers.
1. Number of administrative staff devoted to training program management for
training activities under the application.
2. Number of trainers to be utilized for the proposed courses.
3. Describe how trainers are selected and the specific selection criteria employed.
4. Describe how the applicant will monitor trainers including student feedback.
c. Delivery Methods. As outlined in Chart B- Proposed Performance, Column C, Indicate the
delivery method to be used for each course to be offered, (i.e. “web-based’ or ‘in-person’).
1. Indicate the number of proposed web-based courses to be offered (Column D) and the
number of counselors to be trained (Column E).
2. Indicate the number of proposed (in-person) trainings to be held (Column D) and
the number of housing counselors to be trained at each class (Column E). Applicants
offering HECM default counseling training will receive higher points if training is offered
in-person.
3. Also, applicants must describe how the proposed delivery method(s) will be
accessible to persons with disabilities.
d. Marketing / Enrollment. Applicants must describe plans to market the trainings and register
counselors. Describe policies and plans to ensure training enrollment and assistance provision is
open and fair. For example, how will you ensure that enrollment, eligibility and scholarships
may not be restricted to affiliates or branches of a specific intermediary or conducted in a way
that favors affiliates or branches of a particular organization? Describe how affirmative
marketing efforts contribute to ensure that existing housing counseling capacity in rural, underserved and underrepresented populations is preserved and expanded. (1) Describe how
marketing, enrollment, registration, and requests for assistance services or reasonable
accommodation will be accessible to persons with disabilities and affect persons with Limited
English Proficiency; (2) Describe plans to take reasonable steps to provide meaningful access to
persons with limited English Proficiency (LEP), pursuant to Title VI of the Civil Rights Act of
1964, for example, providing materials that are available in languages other than English.
Applicants may refer to the Department’s January 22, 2007 Final Guidance to Federal Financial
35 of 43
Assistance Recipients Regarding Title VI Prohibition Against National Origin
Discrimination Affecting Limited English Proficient Persons (72 FR 2732).
e. Limited English Proficiency. (1) Describe how, in curriculum development and
implementation, a strong emphasis is placed on academic content to effectively serve persons
with limited English proficiency, under-served and under-represented populations. (2)
Describe plans to take reasonable steps to provide meaningful access to persons with limited
English proficiency (LEP), pursuant to Title VI of the Civil Rights Act of 1964, for example,
providing materials that are available in languages other than English. Applicants may refer to
the Department’s January 22, 2007 Final Guidance to Federal Financial Assistance Recipients
Regarding Title VI Prohibition Against National Origin Discrimination Affecting Limited
English Proficient Persons (72 FR 2732).
f. Affirmatively Further Fair Housing. Under Section 808(e) (5) of the Fair Housing Act,
HUD has a statutory duty to affirmatively further fair housing. HUD requires the same of its
funding recipients. See 2018 General Administrative Requirements and Terms for HUD
Financial Assistance Awards 1.b for the actions you must take to address this requirement. In
the narrative responses to the Rating Factor 3 (B) (1) (f), applicants must describe the
organization's training, outreach and other activities that affirmatively market fair housing
information. Applicants must describe one activity they will do that affirmatively furthers fair
housing. Applicants should show what training will be provided to counselors to conduct the
targeted outreach and to provide housing counseling services to under-served and
underrepresented housing consumer populations.
g. Federal Electronic and Information Technology Accessibility and Compliance Act,
Section 508. Applicants offering training on-line must describe how they comply with Section
508 requirements. Please visit www.section508.gov for more details.
3. Scholarships and Fees. (10 Points). Applicants must describe scholarships and fees for
each proposed activity.
a.
Scholarships. The proposal must include a scholarship element, detailing the full
or partial costs to be covered, including travel (lodging, transportation and per diem), and
tuition to be awarded to housing counselors. Indicate if scholarships will be made available to
other HUD stakeholders covered by HUD’s Final Rule for Housing Counseling Certification
for an introductory class only as described under Eligible Activities (site eligible activity
Section). Describe the types of scholarships that will be offered to students both through this
NOFA as well as through leveraged non-federal resources, and the methodology applied for
issuing scholarship awards. Discuss plans to maximize the number of scholarships awarded.
Estimate what percentage of the proposed budget will be earmarked for scholarships, with a
breakdown for tuition and travel (lodging, transportation and per diem). Applicants must also
describe plans for determining how the various types of scholarship assistance will be
distributed based on the needs identified in Rating Factor 2 including assistance for counselors
in rural areas, under-served and underrepresented populations, areas nationwide and reduce
travel costs for local participants or areas with limited housing counseling resources, limited
English proficiency housing counselors, and training on HECM default counseling. Information
on the methodology used to determine types of scholarships should be made available to
scholarship applicants at the beginning of the application process. For Applicants providing
HECM default counseling training, include the anticipated number and type (lodging, tuition
only, tuition & travel) of HECM default counseling scholarships that will be made available
during the grant period of performance October 1, 2019 through September 30, 2020.
(a)
(b) Fees. If applicable, indicate the fee the applicant plans to charge for each proposed activity
36 of 43
for those students that do not receive a scholarship for tuition.
4. Training Partners. (3 points) (see definition of Training Partners in the instructions for
Chart E) List in Chart E, Column B, the name of the identified sub-grantees and/or Training
Partners that will enable the applicant to successfully implement the proposed work plan and
explain in a narrative the role each partner will play in logistical support, marketing and
outreach for the proposed activities and the impact on cost-effectiveness. Applicants may utilize
in-house staff, sub-grant recipients, consultants, and Training Partners with requisite experience
and capacity. Indicate the partner’s name, type of entity, contact person and phone number of
partner, number of events, if the partner is past and/or proposed and the amount of funding the
Training Partner contributed or will contribute to that training. This section will be scored on the
number of Training Partners identified for past and proposed. The contributions for proposed
will be included as leveraged funding for RF4.
1. Past Training Partners - Provide information on the number of partnerships
created during the period of July 1, 2017, to June 30, 2018 that assisted in providing
more training opportunities for counselors and/or reduced the cost and/or burden to
the grantee as indicated in Chart E.
2. Proposed Training Partners - Identify Training Partners proposed for FY 2019 that
will assist in providing more training opportunities for counselors and/or reduce the cost
and/or burden to the grantee as indicated in Chart E. Those applicants that have
established Training Partners will score higher on this sub factor.
5. Management Activities (3 points). Applicants must describe management activities that will
be performed as part of the projected work plan, including monitoring and oversight of agency
staff and if applicable, sub-grantees and/or Training Partners. Also describe what process will be
used to select proposed sub-grantees and/or Training Partners and to determine sub-funding
levels.
Rating Factor 4: Leveraging Resources
Maximum Points: 7
Although HUD funding through this NOFA may fully fund an organization's proposed program,
applicants are encouraged to secure the use of other resources to supplement the HUD award.
Points for this Rating Factor will be awarded based on the amount of leveraged funding that
meets the criteria in this section. Applicants that can demonstrate leveraged resources from
Training Partners described in Rating Factor 3-D, will receive higher scores in this factor.
Applicants who have no other resources available will receive no points for this Rating Factor.
Do not include the same leveraged resources that were submitted for the 2019 Housing
Counseling Program Comprehensive Grant application. Resources identified for the 2019
Housing Counseling Program Comprehensive Grant application cannot be claimed again as a
leveraged resource for the 2019 Housing Counseling Training Grant Program application.
Applicants will be evaluated based on their ability to show that they have obtained additional
non-federal resources for their housing counseling training activities, for the period, including:
direct financial assistance (grants); fees; and in-kind contributions such as services, equipment,
office space, labor; etc. Resources may be provided by non-federal government sources, public
or private non-profit organizations, for-profit private organizations, or other entities committed
37 of 43
to providing assistance. Grantees will be required to maintain evidence that leveraged funds
cited in this application were actually provided to the agency. Funding files and/or leveraging
files will be reviewed by HUD staff as a part of the performance reviews and on-site monitoring
visits.
Do NOT include funding from federal sources such as, but not limited to the, Community
Development Block Grants (CDBG), Emergency Homeowner Loan Program (EHLP), Fair
Housing Initiatives program (FHIP), and Home Investment Partnerships program (HOME).
Attorneys General Mortgage Settlement funds are not considered Federal and therefore can
count toward leveraging.
A. Itemize Leveraging (7 Points) Utilize Chart D – Leveraging Resources and Chart E Funds from Training Partners to provide the following information:
• Chart D – Leveraging Resources (5 points)
• Chart E - Funds from Training Partners (2 points)
All applicants must itemize the list of leveraged resources for the applicant itself, and for each
proposed sub-grantee and identified Training Partner. All applicants must provide a list of all
proposed sub-grantees they propose to fund, and itemize for each the names of the
organizations providing all leveraged funds and in-kind contributions. Include the total amount
and the source of funds. Applicants must list all identified Training Partners with the funds
earmarked by the Training Partners to support the training. Applicants that fail to provide this
information may not receive any points for this factor. All leveraged resources claimed by an
applicant, including cash and third party in-kind, must meet all of the criteria set forth in 2 CFR
Part 200. Responses should be consistent with the leveraged funds amount shown on the SF424,
and the documentation for this Rating Factor.
Resources provided by the applicant may count as leveraged resources. These amounts must
include only funds that will directly result in the provision of housing counseling training.
These funds must also be reflected in the SF424.
B. Fees. While agencies are strongly encouraged to aggressively leverage funds from other
private and public sources, fee income can be counted as leveraged resources. Applicants
claiming fee income must project the total income anticipated from fees. Fee income should be
identified as program income on line “18. Estimated Funding, f. Program Income” of SF-424
“Application for Federal Assistance”.
Rating Factor 5: Achieving Results and Program Evaluation
Maximum Points: 8
This Rating Factor emphasizes HUD's determination to ensure that Applicants meet the
commitments made in their applications and cooperative agreements and assess their
performance in achieving agreed upon performance goals. This factor reflects HUD's Strategic
Goal to embrace high standards of ethics, management and accountability. In scoring this
section, HUD will consider Applicant methodologies used to evaluate overall program
performance and whether the Applicant submitted their organization’s transition or succession
38 of 43
plan. Applicants that utilize a variety of methods and techniques to evaluate performance,
including those methods and techniques identified in this Rating factor, will be awarded a
higher score.
a. Evaluation Plan. (6 points) In responding to this factor, applicants must indicate how they
evaluate the impact of the training program. The applicant must describe an evaluation plan that
explains what will be measured, how an applicant is going to measure it, and the steps in place
to make adjustments to its work plan if performance targets are not met within established time
frames.
Specifically, the plan must identify:
(1) Information Collection. Describe the applicant’s procedures for measuring the impact of
the training program. The applicant must describe how student feedback, learning checks,
testing results, and any other data will be collected or measured to evaluate the success of the
proposed training program. The applicant must also explain how results of marketing and
outreach efforts, especially outreach to counselors in and serving rural areas will be measured.
For this NOFA, HUD will give particular weight to an applicant’s ability to measure change
in housing counselors’ knowledge and skills as a result of the training offered.
(2) Data Analysis and Work Plan Adjustments. Indicate how the information collected
will be evaluated, and the steps the applicant has in place to make adjustments to the work plan
if performance targets are not met within established time frames or student feedback indicates
need to revise teaching methodology.
b. Grant Expenditure History (2 points) In scoring this section, HUD will evaluate Applicant
compliance with programmatic requirements and expenditure results, during the FY 2017 grant
period of July 1, 2017, to June 30, 2018 and any approved extension period.. If an extension
was required, applicant must submit a narrative to explain reason for not expending funds
within the grant period.
If the Applicant did not receive a HUD Housing Counseling Program Training Grant during this
time period, provide this information based on the Applicant’s compliance with the
funders' requirements.
FY18 NOFA Housing Counseling Training Grant
Maximum Points: 100
2. Preference Points.
Preference points are not available for this program.
B. Review and Selection Process.
1. Past Performance
In evaluating applications for funding, HUD will take into account an applicant’s past
performance in managing funds. Items HUD may consider include, but are not limited to:
a. The ability to account for funds appropriately;
b. Timely use of funds received from HUD;
39 of 43
c. Timely submission and quality of reports submitted to HUD;
d. Meeting program requirements;
e. Meeting performance targets as established in the grant agreement;
f. The applicant’s organizational capacity, including staffing structures and capabilities;
g. Time-lines for completion of activities and receipt of promised matching or leveraged funds;
and
h. The number of persons to be served or targeted for assistance.
HUD may reduce scores as specified under V.A. Review Criteria. Each NOFA will specify
how past performance will be rated or otherwise used in the determination of award amounts.
Whenever possible, HUD will obtain past performance information from staff with the greatest
knowledge and understanding of each applicant’s performance. If this evaluation results in an
adverse finding related to integrity or performance, HUD reserves the right to take any of the
remedies provided in Section III.D 1. Pre-selection Review of Performance, above.
2. Assessing Applicant Risk
HUD may impose special conditions on an award as provided under 2 CFR 200.207:
1. Based on HUD's review of the applicant's risk under 2 CFR 200.205;
2. When the applicant or recipient has a history of failure to comply with the general or
specific terms and conditions of a Federal Award;
3. When the applicant or recipient fails to meet expected performance goals; and
4. When the applicant or recipient is not otherwise responsible.
a. Integrity
HUD evaluates the integrity of the applicant as reflected in government-wide websites,
information in HUD’s files, the federal Do Not Pay portal, public information and information
received during HUD’s Name Check Review process. If this integrity evaluation results in an
adverse finding, HUD reserves the right to take any of the remedies provided in Section
III.C.4.a.5, Do Not Pay website Review.
b.Technical Review. First, each application will be reviewed for technical sufficiency to
determine whether the application meets the threshold requirements set out in this NOFA and
whether all required forms have been submitted. Applications that do not meet the threshold
requirements will not be rated and ranked.
c. General Review. The second review considers the responses to the Rating Factors outlined
above and other relevant information. Applications will be evaluated competitively and ranked
against all other applicants that applied in the same funding category.
d. Funding Methodology.
1. Out of the $3,500,000, the first three tiers of funding will distribute $2,500,000 for all training
activities except HECM default training. Applications that earn a score of 75 points or more will
receive a base amount, as determined by HUD. The second tier of funding will be based on the
total number of scholarships awarded in FY2017 Grant Period of July 1, 2017 to June 30, 2018.
The third tier of funding will be based on the total number of classes provided during FY2017
Grant Period of July 1, 2017 to June 30, 2018. The fourth tier of funding will distribute the
$1,000,000 HECM default training funds to those applicants that scored at least 75 points and
will also provide HECM default training. Funding for HECM default training will be based on
the overall score of the applicant.
2. HUD may award the entire amount available under this NOFA to the highest scoring
application. However, to provide the highest quality, comprehensive, and nationwide
40 of 43
training program, HUD reserves the right to make multiple awards.
3. In the event of multiple awards, awardees will be funded based on a formula determined
by HUD.
4. If an applicant turns down an award offer, HUD may make an offer to the next
highest-ranking application.
5. In the event HUD commits a funding error, that when corrected would result in
selection of an applicant during the funding round of a Program NOFA, HUD may
select that applicant for funding, subject to the availability of funds.
e. Award Adjustments. HUD reserves the right to adjust funding levels for each applicant as
indicated in Section II.D. of this NOFA.
C. Anticipated Announcement and Award Dates.
Information about announcement and award dates is unavailable at this time.
VI. Award Administration Information.
A. Award Notices.
Following the evaluation process, HUD will notify successful applicants of their selection for
funding. HUD will also notify other applicants, whose applications were received by the
deadline, but have not been chosen for award. Notifications will be sent by email to the
person listed as the AOR in item 21 of the SF-424.
B. Administrative, National and Department Policy Requirements for HUD recipients
For this NOFA, the following General Administrative Requirements and Terms
for HUD Financial Assistance Awards apply. Please [click here] to read the detailed
description of each applicable requirement.
1.Compliance with Non-discrimination and Other Requirements.
Unless otherwise specified, these non-discrimination and equal opportunity authorities and
other requirements apply to all NOFAs. Please read the following requirements carefully as the
requirements are different among HUD’s programs.
2. Ensuring the Participation of Small Disadvantaged Business, and Women-Owned Business.
3. Equal Participation of Faith-Based Organizations in HUD Programs and Activities.
4. Participation in HUD-Sponsored Program Evaluation.
5. OMB Administrative Requirements, Cost Principles, and Audit Requirements for Federal
Awards.
C. Reporting.
HUD requires recipients to submit performance and financial reports under OMB guidance and
41 of 43
program instructions.
1. Reporting Requirements and Frequency of Reporting. Applicants should be aware that if
the total Federal share of your Federal award includes more than $ 500,000 over the period of
performance, you may be subject to post award reporting requirements reflected in Appendix
XII to Part 200-Award Term and Condition for Recipient Integrity and Performance Matters.
2. Race, Ethnicity and Other Data Reporting. HUD requires recipients that provide HUDfunded program benefits to individuals or families to report data on the race, color, religion,
sex, national origin, age, disability, and family characteristics of persons and households who
are applicants for, participants in, or beneficiaries or potential beneficiaries of HUD programs
in order to carry out the Department’s responsibilities under the Fair Housing Act, Executive
Order 11063, Title VI of the Civil Rights Act of 1964, and Section 562 of the Housing and
Community Development Act of 1987. NOFAs may specify the data collection and reporting
requirements. Many programs use the Race and Ethnic Data U.S. Department of
Housing OMB Approval No. 2535-0113 Reporting Form HUD-27061.
Award recipients will be required to submit quarterly progress reports, comparing actual
accomplishments with the goals and objectives established for the period, explaining why
established goals were not met, and highlighting any problems, delays, or adverse conditions
that materially impaired the ability to meet the objectives of the awards. Each recipient is
also required to report accomplishments against proposed outputs and outcomes as part of
their quarterly reporting requirement to HUD. Recipients shall use quantifiable data to
measure performance against goals and objectives outlined in their application, or as
subsequently revised.
3. Performance Reporting. All HUD funded programs, including this program, require
recipients to submit, not less than annually, a report documenting achievement of
outcomes under the purpose of the program and the work plan in the award agreement.
D. Debriefing.
For a period of at least 120 days, beginning 30 days after the public announcement of awards
under this NOFA, HUD will provide a debriefing related to their application to requesting
applicants. A request for debriefing must be made in writing or by email by the authorized
official whose signature appears on the SF424 or by his or her successor in office and be
submitted to the point of contact in Section VII Agency Contact(s), below. Information
provided during a debriefing may include the final score the applicant received for each
rating factor, final evaluator comments for each rating factor, and the final assessment
indicating the basis upon which funding was approved or denied.
VII. Agency Contacts.
HUD staff will be available to provide clarification on the content of this NOFA.
Questions regarding specific program requirements for this NOFA should be directed to
the point of contact listed below.
42 of 43
Judy Ayers Britton
305-992-5761
Judith.a.ayersbritton@hud.gov
Persons with hearing or speech impairments may access this number via TTY by calling the
toll-free Federal Relay Service at 800-877-8339. Please note that HUD staff cannot assist
applicants in preparing their applications.
VIII. Other Information.
1. National Environmental Policy Act.
This NOFA does not direct, provide for assistance or loan and mortgage insurance for, or
otherwise govern or regulate, real property acquisition, disposition, leasing, rehabilitation,
alteration, demolition, or new construction, or establish, revise or provide for standards for
construction or construction materials, manufactured housing, or occupancy. Accordingly,
under 24 CFR 50.19(c) (1), this NOFA is categorically excluded from environmental review
under the National Environmental Policy Act of 1969 (42 U.S.C. 4321).
Broadcast. HUD may hold an informational broadcast for potential applicants to learn more
about the Program and the application. The Program Office will notify all eligible applicants
regarding the timing of this broadcast and provide viewing information.
43 of 43
File Type | application/pdf |
File Title | Microsoft Word - FY19 TNOFA Final Clean Version rev2 032819.docx |
Author | H02670 |
File Modified | 2019-04-17 |
File Created | 2019-04-17 |