Community Development Block Grant Program, Entitlement Communities
CDBG entitlement funding is formula-based: HUD does not score applications, but it reviews each grantee's Consolidated Plan and Annual Action Plan for completeness and consistency with 24 CFR Part 91 before releasing funds. Every activity must be eligible and meet a national objective, with at least 70% of funds benefiting low- and moderate-income persons over a one- to three-year certification period. For nonprofits, the real competition is the city or county's local subrecipient application, which mirrors the Action Plan's structure.
Program facts
- Agency
- Office of Community Planning and Development (CPD), U.S. Department of Housing and Urban Development
- Assistance Listing
- 14.218
- Statutory authority
- Title I of the Housing and Community Development Act of 1974, as amended (42 U.S.C. 5301 et seq.); regulations at 24 CFR Part 570 and Consolidated Plan rules at 24 CFR Part 91
- Award ceiling
- Formula allocation set annually by HUD; entitlement grants range from roughly $100,000 for small cities to well over $100 million for the largest cities
- Awards
- HUD makes annual CDBG formula grants to roughly 1,200 local governments and states; entitlement grantees are metropolitan cities, principal cities and urban counties
- Period of performance
- Annual program year under a 3- to 5-year Consolidated Plan; grantees must pass HUD's timeliness test (no more than 1.5 times the annual grant undisbursed 60 days before program year end)
- Cost share
- None required
- Cycle
- Not a competitive NOFO. HUD announces formula allocations after appropriations are enacted; the Annual Action Plan is due at least 45 days before the program year starts and no later than August 16, and most grantees run local subrecipient applications in the winter before
Program goals
- Provide decent housing for low- and moderate-income households
- Provide a suitable living environment through public facilities, infrastructure and public services
- Expand economic opportunities, principally for low- and moderate-income persons
- Aid in the prevention or elimination of slums or blight and meet urgent community needs
Scoring rubric
Citizen participation and consultation15
A citizen participation plan followed in practice: at least a 30-day comment period on the draft plan, public hearings, consultation with housing, homeless and service agencies, and a summary of comments received and responses.
Expected resources and leverage10
The year's allocation, program income and prior-year resources, plus other federal, state and local funds leveraged by CDBG activities.
Annual goals and objectives15
Goals tied to the Consolidated Plan's strategic plan with quantified outcome indicators (households, persons or facilities) for the program year.
Projects: eligibility and national objective25
Each project and activity mapped to an eligible activity under 24 CFR 570.201-206 and a national objective under 570.208, with public services kept at or below 15% and planning and administration at or below 20%.
Geographic distribution10
Target areas, low- and moderate-income area benefit data and the rationale for allocating investments geographically.
Affordable housing, homeless and other actions10
One-year affordable housing goals, homeless and special needs activities, public housing actions, and actions on barriers to affordable housing, lead-based paint and poverty reduction.
Program-specific requirements10
Program income, Section 108 and float-funded activities, urgent need activities, and the selected period for the 70% low- and moderate-income benefit certification.
SF-424 forms and certifications5
SF-424, SF-424D and the signed local government certifications, including anti-displacement, drug-free workplace and fair housing.
CDBG entitlement grants are formula awards and HUD does not score them. These points are ELIXIR CONSUMERS' readiness weighting of the Annual Action Plan components in 24 CFR 91.220 and the citizen participation rules in 24 CFR 91.105, used to check completeness before submission in HUD's eCon Planning Suite. Local subrecipient applications use each grantee's own criteria.
Eligibility
- Principal cities of Metropolitan Statistical Areas
- Other metropolitan cities with populations of at least 50,000
- Qualified urban counties with populations of at least 200,000, excluding entitlement cities
- Nonprofits, CDCs and other subrecipients access funds through the grantee's local application process, not directly from HUD
- Smaller communities apply through the State CDBG program (ALN 14.228) or HUD-administered nonentitlement programs
Required attachments
- Annual Action Plan entered in the eCon Planning Suite in IDIS
- Consolidated Plan (3 to 5 years) in the first year of the plan period
- SF-424 and SF-424D
- Signed certifications for entitlement grantees
- Citizen participation comments and the grantee's responses
- Analysis or assessment supporting fair housing certification, as currently required by HUD
Formatting rules
- Action Plan content is entered into fixed eCon Planning Suite screens (AP-05 through AP-90); there is no free-form page limit
- Draft plan must be published for at least 30 days of public comment before submission
- Grantees typically attach a PDF of the full plan as adopted by the governing body
Why applications lose points
- Missing the August 16 submission deadline, after which the grantee risks losing that year's allocation
- Activities with no documented national objective or misclassified area-benefit activities
- Public service spending above the 15% cap or administration above 20%
- Failing the timeliness test because funded projects are not ready to spend
- Thin citizen participation records with no summary of comments received
- Subrecipient applications that cannot document low- and moderate-income beneficiaries
How ELIXIR CONSUMERS helps with HUD CDBG
- 1.For grantees: drafts Action Plan narratives screen by screen from the Consolidated Plan and prior CAPER results stored in the vault
- 2.Runs a cap check on public services and administration and flags activities without a national objective
- 3.For nonprofit subrecipients: drafts local CDBG applications with beneficiary income documentation drawn from your intake data
- 4.Tracks the comment period, hearing dates and governing body adoption so the citizen participation record is complete
Questions, answered
Can a nonprofit apply to HUD for CDBG?
Not for entitlement funds. Nonprofits apply to their city or county as subrecipients, usually through an annual local request for proposals that feeds the Action Plan.
When is the Action Plan due?
At least 45 days before the grantee's program year begins and no later than August 16 of the federal fiscal year of the grant.
What counts toward the 70% benefit test?
Activities that meet the low- and moderate-income national objective, measured over a one-, two- or three-year period the grantee selects in its certification.
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