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HomeMy WebLinkAboutA001 - Council Action Form dated June 24, 2025ITEM #:48 DATE:06-24-25 DEPT:P&H SUBJECT:HEARING ON SUBMITTAL OF PROPOSED APPLICATION TO IOWA ECONOMIC DEVELOPMENT AUTHORITY (IEDA) FOR CDBG-CV GRANT FUNDING COUNCIL ACTION FORM BACKGROUND: On April 14, 2025, the Iowa Economic Development Authority (IEDA) notified City staff that due to some returned funds from previously allocated awards, IEDA has $2,000,000 of unobligated CDBG-CV funds that must be expended within the next year. IEDA informed staff that it was pursuing an idea to support homeless shelters around the state that experienced increased operating costs as they work to prevent, prepare for, and/or respond to the effects of the pandemic. IEDA has asked if the City of Ames would have an interest in being a recipient of CDBG-CV funds for this purpose, which would then pass down to IEDA/IFA- identified shelter(s) in the Ames jurisdiction via a subrecipient agreement. Although these funds would not be awarded through a competitive application process, an application would need to be created and submitted to IEDA. The funding allocation amount would be dependent upon the number of cities interested in applying and the number of beds in shelters in their area, as determined by IEDA/IFA. A list of shelters was identified ahead of time due to the limited grant resources available to allocate and the limited time frame in which to expend those funds. The list includes shelters that are already familiar with working with the City, are in good standing with regards to any previous IFA awards, and serve the general population experiencing homelessness (i.e., no specific subpopulations such as domestic violence shelters). IEDA outlined that the City of Ames can apply for $75,000 for Shelter Housing Corporation (D/B/A The Bridge Home). IEDA would also be able to award the City an additional $1,500 for activity delivery/admin purposes. The award would be to the City for the benefit of The Bridge Home. The City would have to administer the grant and verify eligible expenses of The Bridge Home for reimbursement through the grant program. The City of Ames would be responsible for the proper expenditure of funds in accordance with state requirements. The initial application submittal deadline was June 1, 2025, however, the City was granted an extension until June 30, 2025. After meeting with IEDA staff and later with The Bridge Home interim administrative staff, the City staff is proposing to apply for these funds to assist The Bridge Home with a variety of potential shelter expenses that include, but are not limited to: utility assistance, insurance costs, maintenance, shelter furniture upgrades, appliances, technology, transportation, etc. in order to provide and prepare safer environments for socially distancing services for families, individuals, and the elderly to have access to shelter and other services as needed. 1 At this time, the staff is requesting approval to submit the attached application. The acceptance of funding from IEDA will be subject to the City verifying an acceptable financial audit and other administrative conditions that the City deems necessary from The Bridge Home. ALTERNATIVES: 1. Approve submittal of a CDBG-CV grant application to the IEDA on behalf of The Bridge Home with conditions for verification of financial and administrative capacity prior to the acceptance of a grant agreement. 2. Approve the submittal of a CDBG-CV grant application to the IEDA on behalf of The Bridge Home with modifications . 3. Decline to seek this grant opportunity. CITY MANAGER'S RECOMMENDED ACTION: Although this a special allocation of funds identified by the state for The Bridge Home that can be utilized to address some of the needs for serving this vulnerable population in our community, it is grant that must be administered by the City on its behalf. There are ongoing concerns about the status of the administrative and financial condition of The Bridge Home as a non-profit organization and the physical condition of the two properties where these funds would be utilized located along Kellogg that would warrant conditions of City participation in this process. Due to the short turn around for submitting an application to the State, staff is still verifying the financial and administrative capacity of The Bridge Home that is currently in a temporary administrative contract with Central Iowa Shelter & Services (CISS) in Des Moines. Staff recommends that until these concerns are addressed, a final grant agreement with IEDA should not be approved. Therefore, it is the recommendation of the City Manager that the City Council approve Alternative 1, as described above. ATTACHMENT(S): CDBG-CV Homelesness Operations Application 2025-w attachments.pdf 2 PROPOSED/DRAFT 2025 CDBG-CV ENTITLEMENT FUNDING APPLICATION TO THE IOWA ECONOMIC DEVELOPMENT AUTHORITY (IEDA) JUNE 24, 2025 3 1 Homelessness Operations CDBG-CV Application Name of City: City of Ames, Iowa Allocation Amount: $75,000 General Considerations: 1. 100% of funds must be for Low-to-Moderate Income Activities. 24 CFR 570.208(a)(2)(i)(A) includes homeless persons in the definition of presumed to be principally low and moderate-income persons. 2. Activity costs must be for shelter operations expenses; no construction, rehab, etc., work is allowed. CDBG matrix code 03T “Homeless/AIDS Patients Programs” (e.g., staff costs, utilities, maintenance, insurance). 3. Estimate the amount of funds allocated to activity delivery cost per activity/homeless program. Activity delivery cost would be the source of administration dollars for entitlement cities to administer these funds, and non-entitlement communities would allocate those admin dollars to a grant administrator as per regular CDBG program awards. HUD put out a CPD Notice about activity delivery costs vs. general administration costs: https://files.hudexchange.info/resources/documents/Notice-CPD-13-07-Allocating-Staff-Costs-Program- Administration-Delivery-Costs-CDBG.pdf. 4. This is a non-competitive application. IEDA is seeking information on how you will expend your allocation (referenced above) of IEDA’s remaining CDBG-CV allocation. 5. 100% of funds must be expended post-award after the IEDA environmental/historic review and approval date and before the contract end date of 5/31/26. All costs must be incurred post-award and before 5/31/26. 6. This is a reimbursement grant. Requests for reimbursement of shelter operations expenses and any city activity delivery expenses should be submitted in IowaGrants ideally monthly but at a minimum on a quarterly basis. 7. Unless waived or modified by the Federal Register Notice, all state CDBG regulations will govern these funds. This includes but is not limited to: going through IEDA for the environmental/historic review process, using IowaGrants for all form submissions, using the IEDA Procurement Policy for any purchases made with grant funds, and complying with IEDA records retention, monitoring, and other requirements. Submit with the Application: 1. Cover Page: The application must be accompanied by a letter on City letterhead signed by the Chief Elected Official authorizing IEDA to consider the application 2. Applicant Disclosure Report: https://www.hud.gov/sites/dfiles/OCHCO/documents/2880.pdf 3. Federal Assurances Signature Page: Included on page seven (7) of this document. 4. Public Hearing minutes and the notification of the public hearing. Instructions for the public hearing can be found on page two (2). 5. The completed Program pages that follow in this document, on pages 3-6. Complete one page per shelter that would receive funding. 6. Duplication of Benefits (DOB) documentation: a) the IEDA CDBG DOB Policy to be adopted by the City, and b) documentation demonstrating that this award would not constitute a duplication of benefits for either the City as recipient or shelter subrecipient(s). 7. Email all materials to Sarah Plowman (sarah.plowman@iowaeda.com) by June 1, 2025. Origin of Funds: In 2020, HUD made three allocations of CDBG-CV funds to states. States are allowed to fund either entitlement or non-entitlement communities with these funds. For the Federal Register notice, see here: https://www.hud.gov/sites/dfiles/CPD/documents/CDBG-CV_Notice_Federal_Register_Publication_2002-08.pdf For memos regarding the methodology of the second and third allocations of funds, see these links respectively: https://www.hud.gov/sites/dfiles/CPD/documents/Revised_CDBG-CV2_Methodology.pdf and https://www.hud.gov/sites/dfiles/CPD/documents/Methodology-for-CDBG-CARES-Act-Final-Allocation-CV-3- Part-A-9-11-2020.pdf 4 2 Next Steps: Applications due by 6/1/25. After your community submits the entitlement application, it will be reviewed by IEDA staff who will notify you if any other application materials will be needed for clarification. If the application is complete and meets the CDBG-CV regulations, upon Director approval IEDA would then send you an award letter and contract. Award funds are contingent upon the successful return and execution of the contract. Overall Budget (fill as many lines as you need): 1. The Bridge Home $75,000 $1,500 LMC Total amount $75,000 $1,500 LMC Public Hearing Instructions: The purpose of the hearing is to make the public aware of the application to IEDA to spend the CDBG-CV funds allocated to the City. Publication: The public hearing notice must be published no more than 20 days and no less than 4 days from the date of the public hearing. The notification should follow the City’s normal protocols for publication but should at a minimum be published in a newspaper of general circulation. Public Hearing: The City should follow their normal public hearing protocols. These can be virtual or in-person. The public hearing must include: 1. Need for the CDBG project 2. Description of the CDBG funded project & activities 3. The amount of CDBG funds for the project 4. Estimated amount of CDBG assistance that will benefit low-and moderate-income persons 5. The location of project activities 6. Any relocation that will have to take place because of the CDBG project, plans to minimize any displacement of persons as a result of the funded activity, and plans to assist persons actually displaced if that were to occur 7. City/ County contact information for residents to contact with concerns or complaints regarding the project 8. Community Development and Housing Needs of low to moderate-income persons in the City and any planned or potential activities to address these needs. The City should ask for public input on this item and include public comments in the minutes. 9. Other Community Development and Housing needs and any planned or potential activities to address these needs. The City should ask for public input on this item and include public comments in the minutes. Minutes: The public hearing minutes from the hearing must include the information provided at the hearing on the 9 points listed above. 5 3 Program Descriptions (fill as many as would be funded): Shelter 1 Name: The Bridge Home (THB) 1. Amount of funds to be allocated to the shelter: $75,000 2. Description (pre- and post-pandemic) of the shelter and its operations: • Pre-Pandemic: Founded in 1985 to address the growing need of individuals and families requiring shelter, a trend that continues today, THB is the only organization in the Two Rivers Region serving single men, women, families with children, elderly and disable individuals in hopes to end the cycle of homelessness among single men, women, and families. In the last year alone, they served 150 adults nightly, three meals daily, showers, laundry, case management, and life skills programs. • Post-Pandemic: Enhanced cleaning, PPE, social distancing, when necessary, Health screenings, and symptom checks at entry, low-barrier beds for single women and men would remain available. 3. Estimate of the number of individuals to be assisted with this funding over the contract period: • It is estimated that approximately 750 individuals assisted over the contract period 4. Describe how the planned activity will prevent, prepare for, and/or respond to the effects of the COVID-19 pandemic in this shelter specifically and the community as a whole: • Cleaning supplies, PPE, extra janitorial services, and staff training for health screening and case tracking; Intake flow changes to reduce close contact; Continued housing, job, and benefit assistance to reduce crowding; Maintain staff-to-client ratio to support continued health, safety, and reduction of client crowding. 5. Describe any additional ways that the planned activity will address public health, coronavirus, and/or housing and economic disruption needs: • Additional ways could include, but are not limited to: - Hygiene education and basic care access - Job training and employment services - Rapid housing placement to reduce long-term homelessness - Support for mental health and substance use recovery 6. Describe how the full allotment of funds will be expended on operations expenses by 5/31/26: • Funds will be allocated to support essential shelter expenses/operations that includes but not limited to: utility assistance, insurance costs, cleaning supplies, enhanced cleaning services; shelter furniture upgrades, appliances, storage, technology, etc. in order to provide and prepare safer environments for socially distancing services for families, and individuals to have access to shelter and other services as needed. No staff salaries or benefits or increases in staff will be covered by these funds. 7. Describe how this funding will not constitute a duplication of benefits (DOB) for either the City as recipient or the shelter as subrecipient. Attach supporting documentation. • The City’s current Duplication of Benefit Policy (DOBP) will be expanded to include the services provided by The Bridge Home (THB) for these grant funds. • In addition to the city’s DOBP, The Bridge Home is currently not receiving funding from the City, County, United Way, or Iowa State University through their ASSET Funders Program that would create a 6 4 duplication of benefits. We will also use the following methods to support efforts to reduce any duplication of benefits: -Use HMIS to prevent service duplication across programs -Require individuals utilizing shelter services to verify receipt of any additional funds from other sources. - The City will be the administrator of the grant funds. 7 5 FEDERAL ASSURANCES SIGNATURE PAGE I, Pa Goldbeck, (applicant official) hereby certify that in carrying out the activities funded under the CDBG Program, the City/County of Ames/Story County: A. will minimize displacement of persons as a result of such activities; B. will conduct and administer the program in conformity with Public Law 88-352 (Title VI of the Civil Rights Act of 1964), and Public Law 90-284 (Title VIII of the Civil Rights Act of 1968) and will affirmatively further fair housing); C. will provide for opportunities for citizen participation, hearings, and access to information with respect to our community development program comparable to the requirements found under sections 104(a)(2) and 104(a)(3) of Title I of the Housing and Community Development Act of 1975 as amended through 1987; and D. will not attempt to recover any capital costs of public improvements assisted in whole or part under the CDBG Program by assessing any amount against properties owned and occupied by persons of low and moderate income, including any fee charged or assessment made as a condition of obtaining access to such public improvements, unless (i) funds received under the CDBG Program are used to pay the proportion of such fee or assessment that relates to the capital costs of such public improvements that are financed from revenue sources other than under Public Law 93-383, as amended, or (ii) for purposes of assessing any amount against properties owned and occupied by persons of low and moderate income who are not of very low income, the city/county has certified to the State that it lacks sufficient funds received under the CDBG Program to comply with the requirements of clause (i) above. I also certify that to the best of my knowledge and belief, data in the application is true and correct, including commitment of local resources; the document has been duly authorized by the governing body of the applicant; and the applicant will comply with all applicable federal and state requirements, including the following, if assistance is approved: A. Civil Rights Acts; B. Housing and Community Development Acts of 1974, as amended; C. Age Discrimination Act of 1975; D. Section 504 of the Rehabilitation Act of 1973; E. Davis-Bacon Act, as amended, where applicable under Section 110 of the Housing and Community Development Act of 1974, as amended; Contract Work Hours and Safety Standards Act; the Copeland Anti-kickback Act; the Department of Defense Reauthorization Act of 1986, and the Fair Labor Standards Act. F. National Environmental Policy Act of 1969 and 24 CFR 58 (Environmental Review). G. Uniform Relocation Assistance and Real Property Acquisition Policies Act of 1970, as amended; H. State of Iowa Citizen Participation Plan; I. Lead-based Paint Poisoning Prevention Act; J. Residential Anti-displacement and Relocation Assistance Plan; K. Government-wide Restriction on Lobbying and the Hatch Act; and L. Prohibition on the Use of Excessive Force. Pa Goldbeck _________________________________ ________________ Typed Name of Applicant Official Signature Date _Vanessa Baker-Latimer_________ ___________________________________ ________________ Typed Name of Person Attesting Signature Date 8 Form HUD-2880 (1/27/2023) Applicant/Recipient Disclosure/Update Report U.S. Department of Housing and Urban Development OMB Number: 2501-0044 Expiration Date: 2/28/2027 Public Reporting Burden Statement: This collection of information is estimated to average 2 hours per response, including the time for reviewing instructions, searching existing data sources, gathering, and maintaining the data needed, and completing and reviewing the c ollection of the requested information. Comments regarding the accuracy of this burden estimate and any suggestions for reducing this burden can be sent to: U.S. Department of Housing and Urban Development, Office of the Chief Data Officer, R, 451 7th St SW, Room 8210, Washington, DC 20410-5000. Do not send completed HUD-2880 forms to this address. This agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless the collection displays a valid OMB control number. This agency is authorized to collect this information under Section 102 of the Department of Housing and Urban Development Reform Act of 1989. The information you provide will enable HUD to carry out its responsibilities under this Act and ensure greater accountability and integrity in the provision of certain types of assistance administered by HUD. This information is required to obtain the benefit sought in the grant program. Failure to provide any required information may delay the processing of your application a nd may result in sanctions and penalties including of the administrative and civil money penalties specified under 24 CFR §4.38. This information will not b e held confidential and may be made available to the public in accordance with the Freedom of Information Act (5 U.S.C. §552). The information contained on the form is not retrieved by a personal identifier, therefore it does not meet the threshold for a Privacy Act Statement. Applicant/Recipient Information *UEI Number:*Report Type: INITIAL 1.Applicant/Recipient Name, Address, and Phone (include area code) * Applicant Name: * Street 1: Street 2: City: State Abbreviation: * Zip Code: County: * Country: * Phone: 2.Employer ID Number (do not include individual social security numbers): 3.HUD Program Name: 4.Amount of HUD Assistance Requested/Received: $ 5.State the name and location (street address, City and State) of the project or activity Project Name: * Street 1: Street 2: City: State Abbreviation: * Zip Code: County: * Country: USA: UNITED STATES Part I Threshold Determinations 1.Are you applying for assistance for a specific project or activity? These terms do not include formula grants, such as public housing operating subsidy or CDBG block grants. For further information see 24 CFR Sec. §4.3. Yes No 2.Have you received or do you expect to receive assistance within the jurisdiction of the Department (HUD), involving the project or activity in this application, in excess of $200,000 during this fiscal year (Oct. 1-Sep. 30)? For further information, see 24 CFR §4.9. Yes No If you answered “No” to either question 1 or 2, Stop! You do not need to complete the remainder of this form. However, you must sign the certification at the end of the report. 9 Form HUD-2880 (1/27/2023) Part II Other Government Assistance Provided or Requested/Expected Sources and Use of Funds. Such assistance includes, but is not limited to, any grant, loan, subsidy, guarantee, insurance, payment, credit, or tax benefit. Department/State/Local Agency Name Department/State/Local Agency Name * Government Agency Name: * Government Agency Name: Government Agency Address: Government Agency Address: * Street 1: * Street 1: Street 2: Street 2: City: State Abbreviation: * Zip Code: City: State Abbreviation: * Zip Code: County: County: Country: Country: * Type of Assistance: * Type of Assistance: * Amount Requested/Provided: $ * Amount Requested/Provided: $ * Expected Uses of the Funds: * Expected Uses of the Funds: Note: For Part 1, use additional pages if necessary. Add Attachment: Part III Interested Parties. You must disclose: 1. All developers, contractors, or consultants involved in the application for assistance or in the planning, development, or implementation of the project or activity. * Alphabetical list of all persons with a reportable financial interest in the project or activity (for individuals, give the last name first) * Unique Entity ID * Type of Participation in Project/Activity * Financial Interest in Project/Activity ($ and %) $ % $ % $ % 2. Any other person who has a financial interest in the project or activity for which the assistance is sought that exceeds $50,000 or 10 percent of the assistance (whichever is lower). * Alphabetical list of all persons with a reportable financial interest in the project or activity (for individuals, give the last name first) * City of Residence * Type of Participation in Project/Activity * Financial Interest in Project/Activity ($ and %) $ % $ % $ % Note: For Part 2, use additional pages if necessary. Add Attachment: Certification: I/We, the undersigned, certify under penalty of perjury that the information provided above is true , accurate, and correct. Warning: Anyone who knowingly submits a false claim or makes a false statement is subject to criminal and/or civil penalties, including confineme nt for up to 5 years, fines, and civil and administrative penalties. (18 U.S.C. §§ 287, 1001, 1010, 1012, 1014; 31 U.S.C. §3729, 3802; 24 CFR §28.10(b)(1)(iii)). * Signature: * Date: (mm/dd/yyyy): 10 Form HUD-2880 (1/27/2023) Instructions Overview. A. Coverage. You must complete this report if: (1) You are applying for assistance from HUD for a specific project or activity and you have received, or expect to receive, assistance from HUD in excess of $200,000 during the during the fiscal year; (2) You are updating a prior report as discussed below; or (3) You are submitting an application for assistance to an entity other than HUD, a State or local government if the application is required by statute or regulation to be submitted to HUD for approval or for any other purpose. B. Update reports (filed by “Recipients” of HUD Assistance): General. All recipients of covered assistance must submit update reports to the Department to reflect substantial changes to the initial applicant disclosure reports. Line-by-Line Instructions. Applicant/Recipient Information. All applicants for HUD competitive assistance, must complete the information required in blocks 1-5 of form HUD-2880: 1. Enter the full name, address, city, State, zip code, and telephone number (including area code) of the applicant/recipient. Where the applicant/recipient is an individual, the last name, first name, and middle initial must be entered. 2. Entry of the applicant/recipient's EIN, as appropriate, is optional. Individuals must not include social security numbers on this form. 3. Applicants enter the HUD program name under which the assistance is being requested. 4. Applicants enter the amount of HUD assistance that is being requested. Recipients enter the amount of HUD assistance that has been provided and to which the update report relates. The amounts are those stated in the application or award documentation. NOTE: In the case of assistance that is provided pursuant to contract over a period of time (such as project-based assistance under section 8 of the United States Housing Act of 1937), the amount of assistance to be reported includes all amounts that are to be provided over the term of the contract, irrespective of when they are to be received. 5. Applicants enter the name and full address of the project or activity for which the HUD assistance is sought. Recipients enter the name and full address of the HUD-assisted project or activity to which the update report relates. The most appropriate government identifying number must be used (e.g., RFP No.; IFB No.; grant announcement No.; or contract, grant, or loan No.) Include prefixes. Part I. Threshold Determinations - Applicants Only Part I contains information to help the applicant determine whether the remainder of the form must be completed. Recipients filing Update Reports should not complete this Part. If the answer to either questions 1 or 2 is No, the applicant need not complete Parts II and III of the report, but must sign the certification at the end of the form. Part II. Other Government Assistance and Expected Sources and Uses of Funds. A. Other Government Assistance. This Part is to be completed by both applicants and recipients for assistance and recipients filing update reports. Applicants and recipients must report any other government assistance involved in the project or activity for which assistance is sought. Applicants and recipients must report any other government assistance involved in the project or activity. Other government assistance is defined in note 4 on the last page. For purposes of this definition, other government assistance is expected to be made available if, based on an assessment of all the circumstances involved, there are reasonable grounds to anticipate that the assistance will be forthcoming. Both applicant and recipient disclosures must include all other government assistance involved with the HUD assistance, as well as any other government assistance that was made available before the request, but that has continuing vitality at the time of the request. Examples of this latter category include tax credits that provide for a number of years of tax benefits, and grant assistance that continues to benefit the project at the time of the assistance request. The following information must be provided: 1. Enter the name and address, city, State, and zip code of the government agency making the assistance available. 2. State the type of other government assistance (e.g., loan, grant, loan insurance). 3. Enter the dollar amount of the other government assistance that is, or is expected to be, made available with respect to the project or activities for which the HUD assistance is sought (applicants) or has been provided (recipients). 4. Uses of funds. Each reportable use of funds must clearly identify the purpose to which they are to be put. Reasonable aggregations may be used, such as "total structure" to include a number of structural costs, such as roof, elevators, exterior masonry, etc. B. Non-Government Assistance. Note that the applicant and recipient disclosure report must specify all expected sources and uses of funds - both from HUD and any other source - that have been or are to be, made available for the project or activity. Non-government sources of Form HUD-2880 funds typically include (but are not limited to) foundations and private contributors. Part III. Interested Parties. This Part is to be completed by both applicants and recipients filing update reports. Applicants must provide information on: 1. All developers, contractors, or consultants involved in the application for the assistance or in the planning, development, or implementation of the project or activity; and 2. Any other person who has a financial interest in the project or activity for which the assistance is sought that exceeds $50,000 or 10 percent of the assistance (whichever is lower). Note: A financial interest means any financial involvement in the project or activity, including (but not limited to) situations in which an individual or entity has an equity interest in the project or activity, shares in any profit on resale or any distribution of surplus cash or other assets of the project or activity, or receives compensation for any goods or services provided in connection with the project or activity. Residency of an individual in housing for which assistance is being sought is not, by itself, considered a covered financial interest. The information required below must be provided. 1. Enter the full names and addresses. If the person is an entity, the listing must include the full name and address of the entity as well as the CEO. Please list all names alphabetically. 2. Entry of the Unique Entity Identifier (UEI), for non-individuals, or city of residence, for individuals, for each organization and person listed is optional. 3. Enter the type of participation in the project or activity for each person listed: i.e., the person's specific role in the project (e.g., contractor, consultant, planner, investor). 4. Enter the financial interest in the project or activity for each person listed. The interest must be expressed both as a dollar amount and as a percentage of the amount of the HUD assistance involved. Note that if any of the source/use information required by this report has been provided elsewhere in this application package, the applicant need not repeat the information, but need only refer to the form and location to incorporate it into this report. (It is likely that some of the information required by this report has been provided on SF 424A, or on various budget forms accompanying the application.) If this report requires information beyond that provided elsewhere in the application package, the applicant must include in this report all the additional information required. Recipients must submit an update report for any change in previously disclosed sources and uses of funds as provided in Section I.D.5., above. 11 Form HUD-2880 (1/27/2023) Notes: 1. All citations are to 24 CFR Part 4, which was published in the Federal Register. [April 1, 1996, at 63 Fed. Reg. 14448.] 2. Assistance means any contract, grant, loan, cooperative agreement, or other form of assistance, including the insurance or guarantee of a loan or mortgage, that is provided with respect to a specific project or activity under a program administered by the Department. The term does not include contracts, such as procurements contracts, that are subject to the Fed. Acquisition Regulation (FAR) (48 CFR Chapter 1). 3. See 24 CFR §4.9 for detailed guidance on how the threshold is calculated. 4. "Other government assistance" is defined to include any loan, grant, guarantee, insurance, payment, rebate, subsidy, credit, tax benefit, or any other form of direct or indirect assistance from the Federal government (other than that requested from HUD in the application), a State, or a unit of general local government, or any agency or instrumentality thereof, that is, or is expected to be made, available with respect to the project or activities for which the assistance is sought. 5. For the purpose of this form and 24 CFR Part 4, “person” means an individual (including a consultant, lobbyist, or lawyer); corporation; company; association; authority; firm; partnership; society; State, unit of general local government, or other government entity, or agency thereof (including a public housing agency); Indian tribe; and any other organization or group of people. 12