Explanation
BACKGROUND: The Department of Finance and Management, Grants Management Section receives annual grants from the U.S. Department of Housing and Urban Development (HUD) through the Community Development Block Grant (CDBG) Entitlement Program. It is the goal of the CDBG program to develop viable urban communities by providing decent housing and a suitable living environment and expanding economic opportunities, principally for low- to moderate-income people.
Habitat for Humanity of Ohio, Inc. (Habitat for Humanity) is a non-profit housing and human services provider in Central Ohio that has been performing roof repair and replacement for income-qualify homeowners using Community Development Block Grant funds since 2023.
Ordinance 0239-2026 authorized the Director of the Department of Finance and Management to enter into a subrecipient agreement with Habitat for Humanity to complete additional roof repair and replacement projects that could not be completed under the City’s expired 2025 subrecipient agreement with the non-profit. A small number of roof repair projects had been started but due to inclement weather could not be completed prior to the expiration of the agreement on December 31, 2025. Out of necessity to protect the homes under repair, those projects were completed and additional construction costs incurred by Habitat for Humanity before the execution of the new agreement on February 27, 2026.
An additional $139,150 is needed to cover those costs incurred during the lapsed period between agreements, as well as to complete additional roof repair and replacement projects for properties on the waitlist. Additional HUD environmental review requirements requiring radon testing and mitigation have also added costs.
An additional procurement process was not needed for these activities, as the City follows HUD regulations for awarding grant funds to subrecipients, and awards new funds as they become available from HUD. The amount of funding was determined through an assessment of the homes on Habitat for Humanity’s waiting list and estimated construction and radon mitigation costs.
Ordinance 1571-2026 appropriates additional funding for subrecipient agreements that must be executed to allow the City to meet its CDBG expenditure deadlines from HUD. This ordinance is needed to authorize the Director of the Department of Finance and Management to modify the current subrecipient agreement to add these additional funds. This ordinance will also authorize reimbursement of eligible construction expenditures incurred between January 1, 2026 and the execution of the current agreement on February 27, 2026.
Federal regulations (24 CFR 570.902) require each CDBG grantee to have a balance no greater than 1.5 times its annual grant remaining in the line of credit 60 days prior to the end of the Program Year. This is commonly referred to as the CDBG timeliness test. Based on the City’s program year of January 1st to December 31st, the timeliness test is conducted annually on November 2nd. In order to meet the 2026 timeliness test, the City must authorize additional spending of CDBG funds and expedite their expenditure. Failure to comply with HUD’s CDBG timeliness test could result in the reduction of the City’s annual CDBG allocation.
FISCAL IMPACT: This ordinance is contingent on the approval of ordinance 1571-2026, and authorizes the expenditure of up to $139,150 from funding awarded to the City by HUD from Fund 2248. There is no impact to the General Fund as a result of this legislation.
EMERGENCY DESIGNATION: An emergency exists in the usual daily operation of the Department of Finance and Management in that it is immediately necessary to authorize the Director of the Department of Finance and Management to enter into new subrecipient agreements, in order for the project to comply with HUD’s timeliness test requirement all for the immediate preservation of the public health, peace, property, safety and welfare.
Title
To authorize the expenditure of $139,150 from the Community Development Block Grant Fund; to authorize the Director of the Department of Finance and Management to modify the CDBG subrecipient agreement with Habitat for Humanity of Ohio, Inc. to add $139,150 and to allow for reimbursement of expenditures incurred between January 1 and February 27, 2026; and to declare an emergency. ($139,150.00)
Body
WHEREAS, the City of Columbus is an entitlement community and a Participating Jurisdiction of the U.S. Department of Housing and Urban Development (HUD), and the City is a current recipient of Community Development Block Grant (CDBG) funds from HUD; and
WHEREAS, as approved by Ordinance 0239-2026, the City currently has a subrecipient agreement with Habitat for Humanity of Ohio, Inc. to deliver eligible CDBG programs in service of Columbus residents, and to advance HUD’s National Objectives, the City’s Consolidated Plan goals, and the City’s Opportunity Rising aspirations; and
WHEREAS, this ordinance is contingent upon the approval of Ordinance 1571-2026, through which the City is appropriating $704,150 in the Community Development Block Grant Fund 2248 for the purpose of expending these grant dollars prior to HUD’s timeliness test; and
WHEREAS, the City wishes to add additional funds to the existing agreement in order to ensure that enough CDBG grant funds are expended prior to the November 2, 2026 timeliness test to prevent future reductions in the City’s grant amounts; and
WHEREAS, it is necessary to authorize the Director of Finance and Management to modify the existing subrecipient agreement, including a modification to the agreement’s budget to add funding and allow for expenses covering the costs of radon testing and mitigation; and
WHEREAS, it is necessary to authorize the expenditure of up to $139,150 from Fund 2248; and
WHEREAS, an emergency exists in the usual daily operation of the Department of Finance and Management in that it is immediately necessary to authorize the Director of the Department of Finance and Management to modify an existing subrecipient agreement, in order for the project to comply with HUD’s timeliness test requirement all for the immediate preservation of the public health, peace, property, safety and welfare; and NOW THEREFORE.
BE IT ORDAINED BY THE COUNCIL OF THE CITY OF COLUMBUS:
SECTION 1. That the expenditure of up to $139,150 is hereby authorized in Fund 2248, per the accounting codes in the attachment to this ordinance.
SECTION 2. That the Director of the Department of Finance and Management is hereby authorized to modify the subrecipient agreement with Habitat for Humanity of Ohio, Inc.
SECTION 3. That the Director of the Department of Finance and Management may be required to transfer funding from one subfund to another within the Fund 2248, Community Development Block Grant Fund due to the availability of funding based on federal requirements of grants based accounting and account coding will be provided to the City Auditor.
SECTION 4. That the funds necessary to carry out the purpose of this ordinance are hereby deemed appropriated and authorized for expenditure, and the City Auditor shall establish such accounting codes as necessary.
SECTION 5. That the City Auditor is authorized to make any accounting changes to revise the funding source for all contracts or contract modification associated with this ordinance.
SECTION 6. That Council authorizes the reimbursement of expenses incurred prior to the issuance of a Purchase Order from and including January 1, 2026, for reimbursement requests for eligible expenditures incurred from the subrecipient.
SECTION 7. That for the reasons stated in the preamble hereto, which is hereby made a part hereof, this ordinance is hereby declared to be an emergency measure and shall take effect and be in force from and after its passage and approval by the Mayor, or ten days after passage if the Mayor neither approves nor vetoes the same.