Solving the staffing equation for CDBG-DR and CDBG-MIT programs

State and local officials who deal with disaster management have many tasks to juggle. One important task is determining the right staffing needs to oversee the various grant programs available to states.

States, cities, and counties receive CDBG funding on an annual basis from the U.S. Department of Housing and Urban Development (HUD) to address community development needs. Therefore, they already have a staffing plan in place to manage the regular annual HUD allocation.

What happens, then, when HUD allocates additional funding through CDBG-DR or CDBG-MIT? These are separate programs with a different set of rules and objectives. Grantees receiving these funds must develop and implement completely separate programs. These can include:

• Action plans and amendments.
• Public participation.
• Website development and maintenance.
• Project implementation and reporting.
• Program policies development and updates.
• Operating procedures.
• HUD compliance and monitoring.

Most if not all grantees find that the additional workload can quickly exceed the capacity of the regular CDBG staff. There are two typical avenues for additional staffing: internal hires or external contractors. How do you determine which is the right one for your needs?

Determining the variables

The four primary factors are time, money, oversight, and expertise. Below are challenges to consider when determining the best approach for obtaining additional capacity to recover from and mitigate disasters.

1. Time: It can take several months to create and hire for internal positions.

Grantees can and should immediately begin the effort of determining additional internal positions to add capacity for administering and monitoring the CDBG-DR and CDBG-MIT disaster programs. Grantees generally have the option of making permanent hires or grant-funded hires for a 12- to 24-month period.

Grant-funded positions are renewable if there is ongoing need, contingent on the availability of the grant funds. Both CDBG-DR and CDBG-MIT are eligible to pay for these types of positions. However, any lag time in onboarding new hires can lead to delays in establishing the programs and expending the funds in a timely manner.

2. Money: Contractors generally cost more than internal hires, so use their services wisely.

Grantees can also choose to procure contractor services to augment their internal staff. Rather than spending this money on general program administrative costs, it’s ideal to assign contractors tasks that can be charged as activity delivery. These are tasks related to implementing and carrying out specific CDBG-eligible activities, such as:

• QA/QC for eligibility and duplication of benefits review.
• Creating or reviewing Award calculations.
• Completing environmental reviews.
• Reviewing draws and payment requests for a subcontractor.
• Program-specific policies, procedures, and monitoring.

Spending money on acquiring seasoned CDBG-DR and CDBG-MIT subject matter experts is less of a risk than having insufficient or unqualified staff performing these functions, potentially resulting in HUD disallowing the costs due to non-compliance.

3. Oversight: The more contractors used, the more coordination and management that is required from an administrative perspective.

Because of how long it takes to get internal positions hired, you should consider starting a program/project by bringing on external contractors to begin key steps to getting things off the ground. For example, contractors can begin to develop the policies and procedures for a new program while the grantee starts the process for an internal hire. While grantees are allowed to use contractors to support administrative functions, contractors cannot be the final approvers or decision makers. Therefore, it’s necessary for the grantee to have sufficient internal staff to perform these roles. As internal hires are made and trained, the contracted support can be lessened and rolled off the project over time.

4. Expertise: It can be difficult to find grant-funded employees for subrecipients in certain areas, or to find good candidates with subject matter expertise.

External contractors can provide the expertise not readily available in the local community. Grantees that use this approach must determine areas that their staff do not currently have capacity to handle, and then procure subject matter experts for these roles. Subrecipients can use CDBG-DR and CDBG-MIT funds to procure contractors for specific disaster management services such as environmental reviews, DOB reviews, or project oversight and management. This can add much-needed capacity to have contractors focus on some of the more complex aspects of the program and allow subrecipient staff to focus on overall program management.

Making sure the math adds up

While there is no one-size-fits-all solution, ICF created a staffing guidance tool for the CDBG-DR Toolkit. It can help you document your needs and determine where your current staffing levels fall short. Once you’ve identified the gaps, there's additional guidance on how to augment your capacity and fulfill key functions.

Grantees must factor in the number of staff and the skill sets they need to administer the CDBG-DR and CDBG-MIT programs, both internally and by their subrecipients. New internal hires or external contractors can each provide that much-needed additional capacity for a successful program.

There are pros and cons to each approach. Internal hires can take several months to put into place and even longer to train, but contractors are more expensive. A combination of internal hires and contractors provides the most expedient implementation and long-term recovery approach.