Explanation
BACKGROUND: The Department of Finance and Management, Grants Management Section has received funds 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.
When the City uses these funds to provide loans to businesses or other income-generating activities, the income received by the City is considered Program Income (PI) according to HUD, as defined in 24 CFR 570.500. When income is generated by the use of CDBG in a Revolving Loan Fund (RLF), the specific type of PI received is referred to in HUD's financial systems as RLF. Federal regulations (24 CFR 570.902) require each CDBG grantee to have a combined grant and PI 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.
The City is allocating funds to projects that are prepared to immediately begin expending these grant dollars, in order to meet the 2026 timeliness test. Four organizations which have successfully implemented CDBG-funded programs in recent years and which have pending CDBG applications for future grant funding were selected to receive these allocations. Because these organizations have previously administered CDBG-funded programs, and because they have continued to operate these programs using other funding sources, the City is authorizing reimbursement of eligible expenditures prior to the issuance of these new agreements.
Through this ordinance, the City will transfer $249,193.67 of CDBG RLF from fund 2249 to fund 2248, appropriate $704,150.00 in federal grant funds, and will authorize $565,000.00 for expenditure across five new subrecipient agreements. The following agreements will be authorized, allowing expenditures up to the maximum amount listed for each:
Columbus Early Learning Centers (CELC), Turf Installation at Reeb Avenue Center - $150,000.00
Legal Aid of Southeast and Central Ohio (LASCO), Fair Housing Program - $150,000.00
Legal Aid of Southeast and Central Ohio (LASCO), Housing Conditions Program - $90,000.00
Ohio Domestic Violence Network (ODVN), Hotel and Relocation Assistance Program - $100,000.00
Helping Hands Health & Wellness Center, Free Care Program - $75,000.00
FISCAL IMPACT: This ordinance authorizes the appropriation of $704,150.00 and expenditure of up to $565,000.00 from funding awarded to the City by HUD from Fund 2248.
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 Director of the Department of Finance and Management to enter into subrecipient agreements with community-based partners to carry out CDBG-eligible projects in the total amount of $565,000.00; to authorize the appropriation and transfer of $249,193.67, the appropriation of $704,150.00, and the expenditure of $565,000.00; and to declare an emergency. ($704,150.00)
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, under 24 CFR §570.500(c), the City of Columbus may select organizations as subrecipients or contractors to undertake eligible Community Development Block Grant activities; and
WHEREAS, the City wishes to use these funds to support local community-based organizations whose work advances HUD’s National Objectives, the City’s Consolidated Plan goals, and the City’s Opportunity Rising aspirations; and
WHEREAS, it is necessary to authorize the Director of Finance and Management to enter into new subrecipient agreements;
WHEREAS, it is necessary to transfer $249,193.67 from Fund 2249 to 2248, appropriate $704,150.00, and authorize the expenditure of up to $565,000.00 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 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; and NOW, THEREFORE
BE IT ORDAINED BY THE COUNCIL OF THE CITY OF COLUMBUS:
SECTION 1. That from the unappropriated monies and from all monies estimated to come into said fund from any and all sources and unappropriated for any other purpose during the fiscal year ending December 31, 2026, the sum of $704,150 is appropriated in Fund 2248 Community Development Block Grant Fund per the account codes in the attachment to this ordinance.
SECTION 2. That the appropriation of $249,193.67 in Fund 2249 and transfer of $249,193.67 from Fund 2249 to Fund 2248 is hereby authorized.
SECTION 3. That the expenditure of up to $565,000.00 is hereby authorized in Fund 2248, per the accounting codes in the attachment to this ordinance.
SECTION 4. That the Director of the Department of Finance and Management is hereby authorized to enter into subrecipient agreements with the organizations listed below, to carry out CDBG eligible projects:
Columbus Early Learning Centers (CELC), Turf Installation at Reeb Avenue Center
Legal Aid of Southeast and Central Ohio (LASCO), Fair Housing Program
Legal Aid of Southeast and Central Ohio (LASCO), Housing Conditions Program
Ohio Domestic Violence Network (ODVN), Hotel and Relocation Assistance Program
Helping Hands Health & Wellness Center, Free Care Program
SECTION 5. 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 6. 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 7. 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 8. 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 from subrecipient LASCO.
SECTION 9. That Council authorizes the reimbursement of expenses incurred prior to the issuance of a Purchase Order from and including May 1, 2026, for reimbursement requests from subrecipients ODVN, CELC, and Helping Hands.
SECTION 10. 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.