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HomeMy WebLinkAboutC24-188 West Mountain Regional Health AllianceAGREEMENT FOR PROFESSIONAL SERVICES
BETWEEN EAGLE COUNTY, COLORADO
AND
WEST MOUNTAIN REGIONAL HEALTH ALLIANCE
THIS AGREEMENT (“Agreement”) is effective as of January 1, 2024, by and between West
Mountain Regional Health Alliance, a Colorado nonprofit corporation (hereinafter “WMRHA”), and
Eagle County, Colorado, a body corporate and politic (hereinafter “County”).
RECITALS
WHEREAS, WMRHA has received a grant (the “WMHRA Grant”) from the State of Colorado’s
Department of Local Affairs, Division of Housing (“Division of Housing”) under the Round One
Transformational Homelessness Response Grant Program; and
WHEREAS, the WMRHA Grant is identified as CMS # 186579 and governed by the agreement between
WMRHA and the Division of Housing dated December 6, 2023, included herein as Exhibit A which is
attached hereto and incorporated by this reference; and
WHEREAS, the purpose of the WMRHA Grant is to provide funds to the WMRHA to improve the
quality of programs and services for individuals who lack housing or are at risk of homelessness in Eagle,
Pitkin, and Garfield Counties; and
WHEREAS, the Statement of Project within the WMRHA Grant agreement requires WMRHA and
subgrantees to submit and collect information to and from the Homeless Management Information
System (the “HMIS”); and
WHEREAS, County currently utilizes and submits and collects data to and from the HMIS in the
administration of separate grants received by the County under the Transformational Homelessness
Response Grant program; and
WHEREAS, to promote efficient administration of the WMRHA Grant and to avoid duplicative efforts,
WMHRA desires to retain County to collect and enter data for WMRHA clients located in Eagle County
(the “Project”); and
WHEREAS, County is authorized to do business in the State of Colorado and has the time, skill,
expertise, and experience necessary to provide the Services as defined below in paragraph 1 hereof; and
WHEREAS, the Division of Housing has granted permission for WMRHA to enter into this Agreement;
and
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WHEREAS, this Agreement shall govern the relationship between WMRHA and County in connection
with the Services.
AGREEMENT
NOW, THEREFORE, in consideration of the foregoing and the following promises WMRHA and
County agree as follows:
1. Services. County agrees to diligently provide all services, labor, personnel and materials
necessary to perform and complete Street Outreach, Emergency Shelter, Systems Improvement, Data
Collection, Management and Coordination as described in Section 3 and Section 7.4.3 of the
Statement of Work incorporated within the WMRHA Grant/Exhibit A (“Services”) which is attached
hereto and incorporated herein by reference. The Services shall be performed in accordance with the
provisions and conditions of this Agreement and in accordance with the policies and procedures set
forth in Exhibit A and Exhibit B, which is attached hereto and incorporated by reference.
a. County agrees to furnish the Services no later than in accordance with the schedule
established in Exhibit A. If no completion date is specified in Exhibit A, then County agrees to
furnish the Services in a timely and expeditious manner consistent with the applicable standard of
care.
b. In the event of any conflict or inconsistency between the terms and conditions set forth
in Exhibit A and Exhibit B and the terms and conditions set forth in this Agreement, the terms and
conditions set forth in this Agreement shall prevail.
3. Term of the Agreement. This Agreement shall commence upon the date first written above,
and subject to the provisions of paragraph 12 hereof, shall continue in full force and effect through the
30th day of September 2026.
4. Extension or Modification. This Agreement may not be amended or supplemented, nor may
any obligations hereunder be waived, except by agreement signed by both parties. Accordingly, no
course of conduct or dealings between the parties, nor verbal change orders, express or implied
acceptance of alterations or additions to the Services shall be the basis of any increase in the
compensation payable hereunder.
5. Compensation. WMRHA shall compensate County for the performance of the Services in a
sum not to exceed $795,000.00 (Street Outreach: $230,000; Systems Improvement: $260,000;
Emergency Shelter Services: $305,000).
a. Payment will be made for Services satisfactorily performed within thirty (30) days
of receipt of a proper and accurate invoice from County. County may submit invoices for all
Services provided prior to the execution of this agreement dating to September 30, 2026.
b. County shall have no obligations under this Agreement after without an
appropriation therefor by County in accordance with a budget adopted by the Board of County
Commissioners in
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compliance with Article 25, title 30 of the Colorado Revised Statutes, the Local Government Budget Law
(C.R.S. 29-1-101 et. seq.) and the TABOR Amendment (Colorado Constitution, Article X, Sec. 20).
7. Insurance. WMRHA agrees to provide and maintain at its sole cost and expense, the following
insurance coverage with limits of liability not less than those stated below:
a. Types of Insurance.
i. Workers’ Compensation insurance as required by law.
ii. If applicable, auto coverage with limits of liability not less than $1,000,000 each
accident combined bodily injury and property damage liability insurance, including coverage for owned,
hired, and non-owned vehicles.
iii. Commercial General Liability coverage to include premises and operations,
personal/advertising injury, products/completed operations, broad form property damage with limits of
liability not less than $1,000,000 per occurrence and $2,000,000 aggregate limits.
iv. Professional liability insurance with prior acts coverage for all Services required
hereunder, in a form and with an insurer or insurers satisfactory to County, with limits of liability of not
less than $1,000,000 per claim and $2,000,000 in the aggregate. In the event the professional liability
insurance is on a claims-made basis, WMRHA warrants that any retroactive date under the policy shall
precede the effective date of this Agreement. Continuous coverage will be maintained during any
applicable statute of limitations for the Services and Project.
b. Other Requirements.
i. If applicable, the automobile and commercial general liability coverage shall be
endorsed to include Eagle County, its associated or affiliated entities, its successors and assigns, elected
officials, employees, agents and volunteers as additional insureds.
iii. Insurance shall be placed with insurers duly licensed or authorized to do business
in the State of Colorado and with an “A.M. Best” rating of not less than A-VII.
iv. WMRHA’s insurance coverage shall be primary and non-contributory with
respect to all other available sources. WMRHA’s policy shall contain a waiver of subrogation against
Eagle County.
v. All policies must contain an endorsement affording an unqualified thirty (30)
days’ notice of cancellation to County in the event of cancellation of coverage.
vi. All insurers must be licensed or approved to do business within the State of
Colorado and all policies must be written on a per occurrence basis unless otherwise provided herein.
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vii. WMRHA’s certificate of insurance evidencing all required coverage(s) is
attached hereto as Exhibit C. Upon request, WMRHA shall provide a copy of the actual insurance policy
and/or required endorsements required under this Agreement within five (5) business days of a written
request from County.
viii. WMRHA shall advise County in the event the general aggregate or other
aggregate limits are reduced below the required per occurrence limit. WMRHA, at its own expense, will
reinstate the aggregate limits to comply with the minimum limits and shall furnish County a new
certificate of insurance showing such coverage.
ix. If WMRHA fails to secure and maintain the insurance required by this
Agreement and provide satisfactory evidence thereof to County, County shall be entitled to immediately
terminate this Agreement.
x. The insurance provisions of this Agreement shall survive expiration or
termination hereof.
xi. The parties hereto understand and agree that County is relying on, and does
not waive or intend to waive by any provision of this Agreement, the monetary limitations or rights,
immunities and protections provided by the Colorado Governmental Immunity Act, as from time to time
amended, or otherwise available to County, its affiliated entities, successors or assigns, its elected
officials, employees, agents, and volunteers.
8. Indemnification. WMRHA shall indemnify and hold harmless County, and any of its officers,
agents, and employees against any losses, claims, damages, or liabilities for which County may become
subject to insofar as any such losses, claims, damages, or liabilities arise out of, directly or indirectly, this
Agreement. WMRHA shall reimburse County for reasonable attorney fees and costs, legal and other
expenses incurred by County in connection with investigating or defending any such loss, claim, damage,
liability, or action. This paragraph shall survive expiration or termination hereof.
9. Ownership of Documents. All documents prepared by County in connection with the Services
shall become remain property of County. WMRHA shall execute written assignments to County of all
rights (including common law, statutory, and other rights, including copyrights) to the same as County
shall from time-to-time request. For purposes of this paragraph, the term “documents” shall mean and
include all reports, plans, studies, tape or other electronic recordings, drawings, sketches, estimates, data
sheets, maps and work sheets produced, or prepared by or for WMRHA (including any employee or
subconsultant in connection with the performance of the Services and additional services under this
Agreement).
10. Notice. Any notice required by this Agreement shall be deemed properly delivered when (i)
personally delivered, or (ii) when mailed in the United States mail, first class postage prepaid, or (iii)
when delivered by FedEx or other comparable courier service, charges prepaid, to the parties at their
respective addresses listed below, or (iv) when transmitted via e-mail with confirmation of receipt. Either
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party may change its address for purposes of this paragraph by giving five (5) days prior written notice of
such change to the other party.
COUNTY:
Eagle County, Colorado
Attention: Monica Brutout, Homeless Services Manager
500 Broadway
Post Office Box 850
Eagle, CO 81631
Telephone: 970-328-8774
E-Mail: monica.brutout@eaglecounty.us
With a copy to:
Eagle County Attorney
500 Broadway
Post Office Box 850
Eagle, Co 81631
Telephone: 970-328-8685
E-Mail: atty@eaglecounty.us
WMRHA:
Attention: Cristina Gair, Executive Director
Post Office Box 1909
Glenwood Springs, CO 81602
Telephone: 970-618-9723
E-Mail: cgair@westmountainhealthalliance.org
11. Coordination. WMRHA acknowledges that the development and processing of the Services for
the Project may require close coordination between various consultants and contractors. WMRHA shall
coordinate the Services required hereunder with the other consultants and contractors that are identified
by County to WMRHA from time to time.
12. Termination. County may terminate this Agreement, in whole or in part, at any time and for any
reason, with or without cause, and without penalty therefor with seven (7) calendar days’ prior written
notice to WMRHA. Upon termination of this Agreement, WMRHA shall immediately provide County
with all documents as defined in paragraph 9 hereof, in such format as County shall direct and shall return
all County owned materials and documents. WMRHA shall pay County for Services satisfactorily
performed to the date of termination.
13. Venue, Jurisdiction, and Applicable Law. Any and all claims, disputes or controversies related to
this Agreement, or breach thereof, shall be litigated in the District Court for Eagle County, Colorado,
which shall be the sole and exclusive forum for such litigation. This Agreement shall be construed and
interpreted under and shall be governed by the laws of the State of Colorado.
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14. Execution by Counterparts; Electronic Signatures. This Agreement may be executed in two or
more counterparts, each of which shall be deemed an original, but all of which shall constitute one and the
same instrument. The parties approve the use of electronic signatures for execution of this Agreement.
Only the following two forms of electronic signatures shall be permitted to bind the parties to this
Agreement: (i) Electronic or facsimile delivery of a fully executed copy of the signature page; (ii) the
image of the signature of an authorized signer inserted onto PDF format documents. All documents must
be properly notarized, if applicable. All use of electronic signatures shall be governed by the Uniform
Electronic Transactions Act, C.R.S. 24-71.3-101 to 121.
15. Other Contract Requirements.
a. This Agreement constitutes an agreement for performance of the Services by County as
an independent contractor and not as an employee of WMRHA. Nothing contained in this Agreement
shall be deemed to create a relationship of employer-employee, master-servant, partnership, joint venture
or any other relationship between County and WMRHA except that of independent contractor. WMRHA
shall have no authority to bind County.
b. This Agreement contains the entire agreement between the parties with respect to the
subject matter hereof and supersedes all other agreements or understanding between the parties with
respect thereto.
f. WMRHA shall not assign any portion of this Agreement without the prior written
consent of the County. Any attempt to assign this Agreement without such consent shall be void.
g. This Agreement shall be binding upon and shall inure to the benefit of the parties hereto
and their respective permitted assigns and successors in interest. Enforcement of this Agreement and all
rights and obligations hereunder are reserved solely for the parties, and not to any third party.
h. No failure or delay by either party in the exercise of any right hereunder shall constitute a
waiver thereof. No waiver of any breach shall be deemed a waiver of any preceding or succeeding
breach.
i. The invalidity, illegality, or unenforceability of any provision of this Agreement shall not
affect the validity or enforceability of any other provision hereof.
j. WMRHA shall maintain for a minimum of three years, adequate financial and other
records for reporting to County. WMRHA may be subject to financial audit by federal, state or county
auditors or their designees. WMRHA authorizes such audits and inspections of records during normal
business hours, upon 48 hours’ notice to WMRHA. WMRHA shall fully cooperate during such audit or
inspections.
k. The signatories to this Agreement aver to their knowledge, no employee of the County
has any personal or beneficial interest whatsoever in the Services or Property described in this
Agreement. WMRHA has no beneficial interest, direct or indirect, that would conflict in any manner or
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degree with the performance of the Services and WMRHA shall not employ any person having such
known interests.
16. Data Security.
a. Definitions:
i. “County Data” means all data created by or in any way originating with County
and End Users, and all information that is the output of any computer processing, or other electronic
manipulation, of any information that was created by or in any way originating with County and End
Users, in the course of using and configuring the Services provided under this Agreement, and includes
all records relating to County’s use of Contractor Services and Protected Information.
ii. “End User” means the individuals (including, but not limited to employees,
authorized agents, students and volunteers of County; Third Party consultants, auditors and other
independent contractors performing services for County; any governmental, accrediting or regulatory
bodies lawfully requesting or requiring access to any Services; customers of County provided services;
and any external users collaborating with County) authorized by County to access and use the Services
provided by Contractor under this Agreement.
iii. “Protected Information” includes, but is not limited to, personally-identifiable
information, student records, protected health information, criminal justice information or individual
financial information and other data defined under C.R.S. §§ 24-72-101 et seq., and personal information
that is subject to local, state or federal statute, regulatory oversight or industry standard restricting the use
and disclosure of such information. The loss of such Protected Information would constitute a direct
damage to the County.
iv. “Security Incident” means the potentially unauthorized access by non-authorized
persons to personal data or non-public data the WMRHA believes could reasonably result in the use,
disclosure, or theft of County Data within the possession or control of the vendor. A Security Incident
may or may not turn into a data breach.
b. During the course of performance of the Services, the WMRHA may be required to
maintain, store, process or control County Data. WMRHA represents and warrants that:
i. WMRHA will take all reasonable precautions to maintain all County Data in a
secure environment to prevent unauthorized access, use, or disclosure, including industry-accepted
firewalls, up-to-date anti-virus software, and controlled access to the physical location of the hardware
containing County Data;
ii. WMRHA’s collection, access, use, storage, disposal and disclosure of County
Data shall comply with all applicable data protection laws, as well as all other applicable regulations and
directives;
iii. WMRHA will notify County of any Security Incident as soon as practicable, but
no later than 24 hours after Contractor becomes aware of it;
iv. WMRHA will provide information sufficient to satisfy County’s legal and
regulatory notice obligations. Upon notice of a Security Incident, County shall have the authority to
direct WMRHA to provide notice to any potentially impacted individual or entity, at WMRHA’s expense,
and WMRHA shall be liable for any resulting damages to County.
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v. Where WMRHA has been contracted to maintain, store or process personal
information on behalf of the County, it shall be deemed a “Third-Party Service Provider as defined in
C.R.S. § 24-73-103(1)(i), and WMRHA shall maintain security procedures and practices consistent with
C.R.S §§ 24-73-101 et seq.; and
vi. WMRHA will promptly return or destroy any County Data upon request from the
County Representative.
c. WMRHA’s indemnification obligations identified elsewhere in this Contract shall apply
to any breach of the provisions of this Paragraph.
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IN WITNESS WHEREOF, the parties have executed this Agreement the day and year first set forth
above.
COUNTY OF EAGLE, STATE OF COLORADO,
By and Through Its BOARD OF COUNTY
COMMISSIONERS
Attest:
By:
Regina O’Brien, Clerk to the Board
By:
Matt Scherr, Chair
WEST MOUNTAIN REGIONAL HEALTH
ALLIANCE
By:
Cristina Gair, Executive Director
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EXHIBIT A
GRANT AGREEMENT
Activity Expenditures Amount
Street Outreach - Supportive Services
Wage, Fringe, and Personnel $180,000.00
Street Outreach - Operations
Other Operations Costs $50,000.00
Emergency Shelter - Supportive Services
Wage, Fringe, and Personnel $180,000.00
Emergency Shelter - Operations
Other Operations Costs $125,000.00
Systems Improvement-Data Collection, Management, Analysis, and System
Integration
Wage, Fringe, and Personnel $90,000.00
Other Data Costs $30,000.00
Systems Improvement-Coordination
Wage, Fringe, and Personnel $140,000.00
TOTAL $795,000.00
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Grant Agreement Number: H4HRG23176 Page 1 of 29 Version 6.1.2023
CMS #185361
STATE OF COLORADO GRANT AGREEMENT FOR SLFRF
COVER PAGE
State Agency
Department of Local Affairs, for the benefit of the Division of
Housing
Agreement Number
H4HRG23176
CMS # 185361
Grantee
West Mountain Regional Health Alliance
UEI/SAMS Number
QXYFQ3GK87M1
Agreement Performance Beginning Date
The later of the Effective Date or October 1, 2023
Initial Agreement Expiration Date
September 30, 2026
Agreement Maximum Amount
$2,743,690
Fund Expenditure End Date
September 30, 2026
Agreement Authority
Authority for this Agreement arises from §24-32-721, C.R.S., and Colorado House Bill 22-1377 Authority exists in the law
and funds have been budgeted, appropriated and otherwise made available pursuant to Section 3206 of the “American Rescue
Plan Act of 2021” (the “SLFRF Statute”) and a sufficient unencumbered balance thereof remains available for payment and the
required approvals, clearance, and coordination have been accomplished from and with appropriate agencies.
Agreement Purpose
Transformational Homelessness Response (THR) – Street Outreach, Systems Improvement
Exhibits and Order of Precedence
The following Exhibits and attachments are included with this Agreement:
1. Exhibit A, Statement of Work.
2. Exhibit B, Sample Option Letter.
3. Exhibit C, Budget.
4. Exhibit D, Federal Provisions.
5. Exhibit E, Agreement with Subrecipient of Federal Recovery Funds
6. Exhibit F, SLFRF Subrecipient Quarterly Report
7. Exhibit G, Sample SLFRF Reporting Modification Form
8. Exhibit H, Applicable Laws
9. Exhibit I, Reserved
10. Exhibit J, PII Certification
11. Form 1, Reserved
In the event of a conflict or inconsistency between this Agreement and any Exhibit or attachment, such conflict or
inconsistency shall be resolved by reference to the documents in the following order of priority:
1. Exhibit D, Federal Provisions
2. Exhibit E, Agreement with Subrecipient of Federal Recovery Funds
3. Colorado Special Provisions in §17 of the main body of this Agreement.
4. The provisions of the other sections of the main body of this Agreement.
5. Exhibit A, Statement of Work.
6. Exhibit J, PII Certification
7. Exhibit I, Reserved
8. Exhibit Exhibit H, Applicable Laws
9. Exhibit B, Sample Option Letter.
10. Exhibit C, Budget.
11. Exhibit F, SLFRF Subrecipient Quarterly Report
12. Exhibit G, Sample SLFRF Reporting Modification Form
13. Form 1, Reserved
Principal Representatives
For the State: For Grantee:
Alison George, Director Cristina Gair, Executive Director
Division of Housing West Mountain Regional Health Alliance.
Department of Local Affairs PO Box 1909
1313 Sherman Street, Rm.320 Glenwood Springs, CO 81602
Denver, CO 80203 cgair@westmountainhealthalliance.org
alison.george@state.co.us
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CTGG1 2024*2727
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Grant Agreement Number: H4HRG23176 Page 2 of 29 Version 6.1.2023
CMS #185361
FEDERAL AWARD(S) APPLICABLE TO THIS GRANT AWARD
Federal Awarding Office US Department of the Treasury
Grant Program Coronavirus State and Local Fiscal Recovery Funds
Assistance Listing Number 21.027
Federal Award Number SLFRP0126
Federal Award Date * May 18, 2021
Federal Award End Date December 31, 2024
Federal Statutory Authority Title VI of the Social Security Act, Section 602
Total Amount of Federal Award (this is not the
amount of this grant agreement)
$3,828,761,790
* Funds may not be available through the Federal Award End Date subject to the provisions in §2 and §5 below.
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CMS #185361
SIGNATURE PAGE
THE PARTIES HERETO HAVE EXECUTED THIS AGREEMENT
Each person signing this Agreement represents and warrants that the signer is duly authorized to execute this Agreement
and to bind the Party authorizing such signature.
GRANTEE
West Mountain Regional Health Alliance
By: ______________________________________________
Cristina Gair, Executive Director
Date: _________________________
STATE OF COLORADO
Jared S. Polis, Governor
DEPARTMENT OF LOCAL AFFAIRS
Rick M. Garcia, Executive Director
By: ___________________________________________
Rick M. Garcia, Executive Director
Date: _________________________
DIVISION OF HOUSING
Contracting Reviewer
By: ____________________________________________
Kristin Toombs, Director, Office of Homeless Initiatives
Date: _________________________
In accordance with §24-30-202, C.R.S., this Agreement is not valid until signed and dated below by the State Controller or an
authorized delegate.
STATE CONTROLLER
Robert Jaros, CPA, MBA, JD
By: ___________________________________________
Beulah Messick, Controller Delegate
Effective Date:_____________________
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10/16/2023 | 11:09 AM MDT
10/16/2023 | 12:28 PM MDT
10/16/2023 | 1:40 PM MDT
10/18/2023 | 7:00 AM MDT
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Grant Agreement Number: H4HRG23176 Page 4 of 29 Version 6.1.2023
CMS #185361
TABLE OF CONTENTS
COVER PAGE .......................................................................................................................... 1
SIGNATURE PAGE ................................................................................................................. 2
1. PARTIES ................................................................................................................................... 4
2. TERM AND EFFECTIVE DATE ............................................................................................. 4
3. DEFINITIONS .......................................................................................................................... 6
4. STATEMENT OF WORK ........................................................................................................ 9
5. PAYMENTS TO GRANTEE .................................................................................................... 9
6. REPORTING - NOTIFICATION ........................................................................................... 11
7. GRANTEE RECORDS ........................................................................................................... 12
8. CONFIDENTIAL INFORMATION-STATE RECORDS ...................................................... 13
9. CONFLICTS OF INTEREST .................................................................................................. 14
10. INSURANCE .......................................................................................................................... 15
11. BREACH OF AGREEMENT ................................................................................................. 18
12. REMEDIES ............................................................................................................................. 18
13. DISPUTE RESOLUTION ....................................................................................................... 20
14. NOTICES AND REPRESENTATIVES ................................................................................. 21
15. RIGHTS IN WORK PRODUCT AND OTHER INFORMATION ........................................ 21
16. GENERAL PROVISIONS ...................................................................................................... 22
17. COLORADO SPECIAL PROVISIONS (COLORADO FISCAL RULE 3-3) ....................... 26
18. RESTRICTIONS ON PUBLIC BENEFITS ........................................................................... 29
1. PARTIES
This Agreement is entered into by and between Grantee named on the Cover Page for this
Agreement (the “Grantee”), and the STATE OF COLORADO acting by and through the State
agency named on the Cover Page for this Agreement (the “State”). Grantee and the State agree to
the terms and conditions in this Agreement.
2. TERM AND EFFECTIVE DATE
A. Effective Date
This Agreement shall not be valid or enforceable until the Effective Date, and the Grant Funds
shall be expended by the Fund Expenditure End Date shown on the Signature and Cover Page
for this Agreement. The State shall not be bound by any provision of this Agreement before
the Effective Date, and shall have no obligation to pay Grantee for any Work performed or
expense incurred before the Effective Date, except as described in §5.D, or after the Fund
Expenditure End Date. If the Work will be performed in multiple phases, the period of
performance start and end date of each phase is detailed under the Project Schedule in Exhibit
Insert Exhibit Number.
B. Initial Term
The Parties’ respective performances under this Agreement shall commence on the
Agreement Performance Beginning Date shown on the Cover Page for this Agreement and
shall terminate on the Initial Agreement Expiration Date shown on the Cover Page for this
Agreement (the “Initial Term”) unless sooner terminated or further extended in accordance
with the terms of this Agreement.
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Grant Agreement Number: H4HRG23176 Page 5 of 29 Version 6.1.2023
CMS #185361
C. Extension Terms - State’s Option
The State, at its discretion, shall have the option to extend the performance under this
Agreement beyond the Initial Term for a period, or for successive periods, of one year or less
at the same rates and under the same terms specified in this Agreement (each such period an
“Extension Term”). In order to exercise this option, the State shall provide written notice to
Grantee in a form equivalent to Sample Option Letter attached to this Agreement.
D. End of Term Extension
If this Agreement approaches the end of its Initial Term, or any Extension Term then in place,
the State, at its discretion, upon written notice to Grantee as provided in §14, may unilaterally
extend such Initial Term or Extension Term for a period not to exceed two months (an “End
of Term Extension”), regardless of whether additional Extension Terms are available or not.
The provisions of this Agreement in effect when such notice is given shall remain in effect
during the End of Term Extension. The End of Term Extension shall automatically terminate
upon execution of a replacement Agreement or modification extending the total term of this
Agreement.
E. Early Termination in the Public Interest
The State is entering into this Agreement to serve the public interest of the State of Colorado
as determined by its Governor, General Assembly, or Courts. If this Agreement ceases to
further the public interest of the State, the State, in its discretion, may terminate this
Agreement in whole or in part. A determination that this Agreement should be terminated in
the public interest shall not be equivalent to a State right to terminate for convenience. This
subsection shall not apply to a termination of this Agreement by the State for breach by
Grantee, which shall be governed by 12.A.i.
i. Method and Content
The State shall notify Grantee of such termination in accordance with §14. The notice
shall specify the effective date of the termination and whether it affects all or a portion
of this Agreement, and shall include, to the extent practicable, the public interest
justification for the termination.
ii. Obligations and Rights
Upon receipt of a termination notice for termination in the public interest, Grantee shall
be subject to the rights and obligations set forth in §12.A.i.a
iii. Payments
If the State terminates this Agreement in the public interest, the State shall pay Grantee
an amount equal to the percentage of the total reimbursement payable under this
Agreement that corresponds to the percentage of Work satisfactorily completed and
accepted, as determined by the State, less payments previously made. Additionally, if
this Agreement is less than 60% completed, as determined by the State, the State may
reimburse Grantee for a portion of allowable actual out-of-pocket expenses, not
otherwise reimbursed under this Agreement, incurred by Grantee which are directly
attributable to the uncompleted portion of Grantee’s obligations, provided that the sum
of any and all reimbursement shall not exceed the maximum amount payable to Grantee
hereunder.
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F. Grantee’s Termination Under Federal Requirements
Grantee may request termination of this Grant by sending notice to the State which includes
the reasons for the termination and the effective date of the termination. If this Grant is
terminated in this manner, then Grantee shall return any advanced payments made for work
that will not be performed prior to the effective date of the termination.
3. DEFINITIONS
The following terms shall be construed and interpreted as follows:
A. “Agreement” means this agreement, including all attached Exhibits, all documents
incorporated by reference, all referenced statutes, rules and cited authorities, and any future
modifications thereto.
B. “Agreement Funds” means the funds that have been appropriated, designated, encumbered,
or otherwise made available for payment by the State under this Agreement.
C. “Award” means an award by a Recipient to a Subrecipient funded in whole or in part by a
Federal Award. The terms and conditions of the Federal Award flow down to the Award
unless the terms and conditions of the Federal Award specifically indicate otherwise.
D. “Breach of Agreement” means the failure of a Party to perform any of its obligations in
accordance with this Agreement, in whole or in part or in a timely or satisfactory manner.
The institution of proceedings under any bankruptcy, insolvency, reorganization or similar
law, by or against Grantee, or the appointment of a receiver or similar officer for Grantee or
any of its property, which is not vacated or fully stayed within 30 days after the institution of
such proceeding, shall also constitute a breach. If Grantee is debarred or suspended under
§24-109-105, C.R.S. at any time during the term of this Agreement, then such debarment or
suspension shall constitute a breach.
E. “Budget” means the budget for the Work described in Exhibit C.
F. “Business Day” means any day in which the State is open and conducting business, but shall
not include Saturday, Sunday or any day on which the State observes one of the holidays
listed in §24-11-101(1), C.R.S.
G. “Chief Procurement Officer” means the individual to whom the Executive Director has
delegated his or her authority pursuant to §24-102-202 to procure or supervise the
procurement of all supplies and services needed by the State.
H. “CJI” means criminal justice information collected by criminal justice agencies needed for
the performance of their authorized functions, including, without limitation, all information
defined as criminal justice information by the U.S. Department of Justice, Federal Bureau of
Investigation, Criminal Justice Information Services Security Policy, as amended and all
Criminal Justice Records as defined under §24-72-302, C.R.S.
I. “CORA” means the Colorado Open Records Act, §§24-72-200.1, et seq., C.R.S.
J. “Effective Date” means the date on which this Agreement is approved and signed by the
Colorado State Controller or designee, as shown on the Signature for this Agreement.
K. “End of Term Extension” means the time period defined in §2.D2.D.
L. “Exhibits” means the exhibits and attachments included with this Agreement as shown on
the Cover Page for this Agreement.
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M. “Extension Term” means the time period defined in §2.C.
N. “Federal Award” means an award of Federal financial assistance or a cost-reimbursement
Agreement, under the Federal Acquisition Regulations or by a formula or block grant, by a
Federal Awarding Agency to the Recipient. “Federal Award” also means an agreement
setting forth the terms and conditions of the Federal Award. The term does not include
payments to an Agreement or payments to an individual that is a beneficiary of a Federal
program.
O. “Federal Awarding Agency” means a Federal agency providing a Federal Award to a
Recipient. The US Department of the Treasury is the Federal Awarding Agency for the
Federal Award, which is the subject of this Agreement.
P. “Goods” means any movable material acquired, produced, or delivered by Grantee as set
forth in this Agreement and shall include any movable material acquired, produced, or
delivered by Grantee in connection with the Services.
Q. “Grant Funds” means the funds that have been appropriated, designated, encumbered, or
otherwise made available for payment by the State under this Agreement.
R. “Incident” means any accidental or deliberate event that results in or constitutes an imminent
threat of the unauthorized access, loss, disclosure, modification, disruption, or destruction of
any communications or information resources of the State, which are included as part of the
Work, as described in §§24-37.5-401, et seq. C.R.S. Incidents include, without limitation, (i)
successful attempts to gain unauthorized access to a State system or State Records regardless
of where such information is located; (ii) unwanted disruption or denial of service; (iii) the
unauthorized use of a State system for the processing or storage of data; or (iv) changes to
State system hardware, firmware, or software characteristics without the State’s knowledge,
instruction, or consent.
S. “Initial Term” means the time period defined in §2.B.
T. “Matching Funds” means the funds provided Grantee as a match required to receive the
Grant Funds.
U. “Party” means the State or Grantee, and “Parties” means both the State and Grantee.
V. “PCI” means payment card information including any data related to credit card holders’
names, credit card numbers, or other credit card information as may be protected by state or
federal law.
W. “PII” means personally identifiable information including, without limitation, any
information maintained by the State about an individual that can be used to distinguish or
trace an individual’s identity, such as name, social security number, date and place of birth,
mother’s maiden name, or biometric records; and any other information that is linked or
linkable to an individual, such as medical, educational, financial, and employment
information. PII includes, but is not limited to, all information defined as personally
identifiable information in §§24-72-501 and 24-73-101, C.R.S.
X. “PHI” means any protected health information, including, without limitation any information
whether oral or recorded in any form or medium: (i) that relates to the past, present, or future
physical or mental condition of an individual; the provision of health care to an individual;
or the past, present, or future payment for the provision of health care to an individual; and
(ii) that identifies the individual or with respect to which there is a reasonable basis to believe
the information can be used to identify the individual. PHI includes, but is not limited to, any
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information defined as Individually Identifiable Health Information by the federal Health
Insurance Portability and Accountability Act.
Y. “Project” means the overall project described in Exhibit A including, without limitation, the
Work and the Services.
Z. “Recipient” means the State agency shown on the Signature and Cover Page of this
Agreement, for the purposes of this Federal Award.
AA. “Services” means the services to be performed by Grantee as set forth in this Agreement, and
shall include any services to be rendered by Grantee in connection with the Goods.
BB. “State Confidential Information” means any and all State Records not subject to disclosure
under CORA. State Confidential Information shall include, but is not limited to, PII, PHI,
PCI, Tax Information, CJI, and State personnel records not subject to disclosure under
CORA. State Confidential Information shall not include information or data concerning
individuals that is not deemed confidential but nevertheless belongs to the State, which has
been communicated, furnished, or disclosed by the State to Grantee which (i) is subject to
disclosure pursuant to CORA; (ii) is already known to Grantee without restrictions at the time
of its disclosure to Grantee; (iii) is or subsequently becomes publicly available without breach
of any obligation owed by Grantee to the State; (iv) is disclosed to Grantee, without
confidentiality obligations, by a third party who has the right to disclose such information; or
(v) was independently developed without reliance on any State Confidential Information.
CC. “State Fiscal Rules” means the fiscal rules promulgated by the Colorado State Controller
pursuant to §24-30-202(13)(a), C.R.S.
DD. “State Fiscal Year” means a 12-month period beginning on July 1 of each calendar year and
ending on June 30 of the following calendar year. If a single calendar year follows the term,
then it means the State Fiscal Year ending in that calendar year.
EE. “State Records” means any and all State data, information, and records, regardless of
physical form, including, but not limited to, information subject to disclosure under CORA.
FF. “Subcontractor” means third parties, if any, engaged by Grantee to aid in performance of
the Work. “Subcontractor” also includes sub-grantees of grant funds.
GG. “Subject Property” means real property that Grant Funds are used to acquire; or to which
Grant Funds are used to make on-site improvements; or on which Grant Funds are used to
construct, rehabilitate, clear, or demolish improvements.
HH. “Subrecipient” means a non-Federal entity that receives a sub-award from a Recipient to
carry out part of a Federal program, but does not include an individual that is a beneficiary
of such program. A Subrecipient may also be a recipient of other Federal Awards directly
from a Federal Awarding Agency. For the purposes of this Agreement, Grantee is a
Subrecipient.
II. “Tax Information” means federal and State of Colorado tax information including, without
limitation, federal and State tax returns, return information, and such other tax-related
information as may be protected by federal and State law and regulation. Tax Information
includes, but is not limited to all information defined as federal tax information in Internal
Revenue Service Publication 1075.
JJ. “Uniform Guidance” means the Office of Management and Budget Uniform Administrative
Requirements, Cost Principles, and Audit Requirements for Federal Awards.
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KK. “Work” means the Goods delivered and Services performed pursuant to this Agreement.
LL. “Work Product” means the tangible and intangible results of the Work, whether finished or
unfinished, including drafts. Work Product includes, but is not limited to, documents, text,
software (including source code), research, reports, proposals, specifications, plans, notes,
studies, data, images, photographs, negatives, pictures, drawings, designs, models, surveys,
maps, materials, ideas, concepts, know-how, information, and any other results of the Work.
“Work Product” does not include any material that was developed prior to the Effective Date
that is used, without modification, in the performance of the Work.
Any other term used in this Agreement that is defined in an Exhibit shall be construed and
interpreted as defined in that Exhibit.
4. STATEMENT OF WORK
Grantee shall complete the Work as described in this Agreement and in accordance with the
provisions of Exhibit A. The State shall have no liability to compensate Grantee for the delivery
of any goods or the performance of any services that are not specifically set forth in this Agreement.
5. PAYMENTS TO GRANTEE
A. Maximum Amount
Payments to Grantee are limited to the unpaid, obligated balance of the Grant Funds. The
State shall not pay Grantee any amount under this Agreement that exceeds the Agreement
Maximum for each State Fiscal Year shown on the Cover Page of this Agreement.
B. Payment Procedures
i. Invoices and Payment
a. The State shall pay Grantee in the amounts and in accordance with the schedule
and other conditions set forth in Exhibit A.
b. Grantee shall initiate payment requests by invoice to the State, in a form and
manner approved by the State.
c. The State shall pay each invoice within 45 days following the State’s receipt of
that invoice, so long as the amount invoiced correctly represents Work completed
by Grantee and previously accepted by the State during the term that the invoice
covers. If the State determines that the amount of any invoice is not correct, then
Grantee shall make all changes necessary to correct that invoice.
d. The acceptance of an invoice shall not constitute acceptance of any Work
performed or deliverables provided under this Agreement.
ii. Interest
Amounts not paid by the State within 45 days of the State’s acceptance of the invoice
shall bear interest on the unpaid balance beginning on the 45th day at the rate of 1% per
month, as required by §24-30-202(24)(a), C.R.S., until paid in full; provided, however,
that interest shall not accrue on unpaid amounts that the State disputes in writing.
Grantee shall invoice the State separately for accrued interest on delinquent amounts,
and the invoice shall reference the delinquent payment, the number of day’s interest to
be paid and the interest rate.
iii. Payment Disputes
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If Grantee disputes any calculation, determination or amount of any payment, Grantee
shall notify the State in writing of its dispute within 30 days following the earlier to
occur of Grantee’s receipt of the payment or notification of the determination or
calculation of the payment by the State. The State will review the information presented
by Grantee and may make changes to its determination based on this review. The
calculation, determination or payment amount that results from the State’s review shall
not be subject to additional dispute under this subsection. No payment subject to a
dispute under this subsection shall be due until after the State has concluded its review,
and the State shall not pay any interest on any amount during the period it is subject to
dispute under this subsection.
iv. Available Funds-Contingency-Termination
The State is prohibited by law from making commitments beyond the term of the
current State Fiscal Year. Payment to Grantee beyond the current State Fiscal Year is
contingent on the appropriation and continuing availability of Grant Funds in any
subsequent year (as provided in the Colorado Special Provisions). If federal funds or
funds from any other non-State funds constitute all or some of the Grant Funds, the
State’s obligation to pay Grantee shall be contingent upon such non-State funding
continuing to be made available for payment. Payments to be made pursuant to this
Agreement shall be made only from Grant Funds, and the State’s liability for such
payments shall be limited to the amount remaining of such Grant Funds. If State, federal
or other funds are not appropriated, or otherwise become unavailable to fund this
Agreement, the State may, upon written notice, terminate this Agreement, in whole or
in part, without incurring further liability. The State shall, however, remain obligated
to pay for Services and Goods that are delivered and accepted prior to the effective date
of notice of termination, and this termination shall otherwise be treated as if this
Agreement were terminated in the public interest as described in §2.E.
v. Federal Recovery
The closeout of a Federal Award does not affect the right of the Federal Awarding
Agency or the State to disallow costs and recover funds on the basis of a later audit or
other review. Any cost disallowance recovery is to be made within the Record
Retention Period, as defined below.
C. Matching Funds
Grantee shall provide Matching Funds as provided in §5.A and Exhibit A. Grantee shall have
raised the full amount of Matching Funds prior to the Effective Date and shall report to the
State regarding the status of such funds upon request. Grantee’s obligation to pay all or any
part of any matching funds, whether direct or contingent, only extend to funds duly and
lawfully appropriated for the purposes of this Agreement by the authorized representatives
of Grantee and paid into Grantee’s treasury or bank account. Grantee represents to the State
that the amount designated “Grantee’s Matching Funds” in Exhibit A has been legally
appropriated for the purposes of this Agreement by its authorized representatives and paid
into its treasury or bank account. Grantee does not by this Agreement irrevocably pledge
present cash reserves for payments in future fiscal years, and this Agreement is not intended
to create a multiple-fiscal year debt of Grantee. Grantee shall not pay or be liable for any
claimed interest, late charges, fees, taxes or penalties of any nature, except as required by
Grantee’s laws or policies.
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D. Reimbursement of Grantee Costs
The State shall reimburse Grantee’s allowable costs, not exceeding the maximum total
amount described in Exhibit A and §5.A for all allowable costs described in this Grant and
shown in the Budget, except that Grantee may adjust the amounts between each line item of
the Budget without formal modification to this Agreement with written approval from the
State. The change shall not modify the total maximum amount of this Agreement, the
maximum amount for any State fiscal year, or modify any requirements of the Work. The
State shall reimburse Grantee for the federal share of properly documented allowable costs
related to the Work after review and approval thereof, subject to the provisions of this
Agreement and Exhibit A. However, any costs incurred by Grantee prior to the Effective
Date shall not be reimbursed absent specific allowance of pre-award costs and indication that
the Federal Award funding is retroactive. Grantee’s costs for Work performed after the Fund
Expenditure End Date shown on the Signature and Cover Page for this Agreement, or after
any phase performance period end date for a respective phase of the Work, shall not be
reimbursable. The State shall only reimburse allowable costs described in this Agreement
and shown in the Budget if those costs are:
i. Reasonable and necessary to accomplish the Work and for the Goods and Services
provided; and
ii. Equal to the actual net cost to Grantee (i.e. the price paid minus any items of value
received by Grantee that reduce the cost actually incurred).
E. Close-Out
Grantee shall close out this Award within 45 days after the Fund Expenditure End Date shown
on the Signature and Cover Page for this Agreement. To complete closeout, Grantee shall
submit to the State all deliverables (including documentation) as defined in this Agreement
and Grantee’s final reimbursement request or invoice. The State will withhold 5% of
allowable costs until all final documentation has been submitted and accepted by the State as
substantially complete. If the Federal Awarding Agency has not closed this Federal Award
within one year and 90 days after the Fund Expenditure End Date shown on the Signature
and Cover Page for this Agreement due to Grantee’s failure to submit required
documentation, then Grantee may be prohibited from applying for new Federal Awards
through the State until such documentation is submitted and accepted
6. REPORTING – NOTIFICATION
A. Periodic Reports
In addition to any reports required pursuant to §§6, 7 & 16 of this Agreement, Grantee shall
comply with all reporting requirements of Exhibit A.
B. Litigation Reporting
If Grantee is served with a pleading or other document in connection with an action before a
court or other administrative decision making body, and such pleading or document relates
to this Agreement or may affect Grantee’s ability to perform its obligations under this
Agreement, Grantee shall, within ten days after being served, notify the State of such action
and deliver copies of such pleading or document to the State’s Principal Representative
identified on the Cover Page for this Agreement.
C. Performance and Final Status
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Grantee shall submit all financial, performance and other reports to the State no later than 45
calendar days after the end of the Initial Term if no Extension Terms are exercised, or the
final Extension Term exercised by the State, containing an evaluation and review of Grantee’s
performance and the final status of Grantee’s obligations hereunder.
D. Violations Reporting
Grantee shall disclose, in a timely manner, in writing to the State and the Federal Awarding
Agency, all violations of federal or State criminal law involving fraud, bribery, or gratuity
violations potentially affecting the Federal Award. The State or the Federal Awarding
Agency may impose any penalties for noncompliance allowed under 2 CFR Part 180 and 31
U.S.C. 3321, which may include, without limitation, suspension or debarment.
7. GRANTEE RECORDS
A. Maintenance
Grantee shall make, keep, maintain, and allow inspection and monitoring by the State of a
complete file of all records, documents, communications, notes and other written materials,
electronic media files, and communications, pertaining in any manner to the Work or the
delivery of Services (including, but not limited to the operation of programs) or Goods
hereunder. Grantee shall maintain such records for a period (the “Record Retention Period”)
of five years following the date of submission to the State of the final expenditure report, or
if this Award is renewed quarterly or annually, from the date of the submission of each
quarterly or annual report, respectively. If any litigation, claim, or audit related to this Award
starts before expiration of the Record Retention Period, the Record Retention Period shall
extend until all litigation, claims, or audit findings have been resolved and final action taken
by the State or Federal Awarding Agency. The Federal Awarding Agency, a cognizant
agency for audit, oversight or indirect costs, and the State, may notify Grantee in writing that
the Record Retention Period shall be extended. For records for real property and equipment,
the Record Retention Period shall extend three years following final disposition of such
property.
B. Inspection
Grantee shall permit the State, the federal government, and any other duly authorized agent
of a governmental agency to audit, inspect, examine, excerpt, copy and transcribe Grantee
Records during the Record Retention Period. Grantee shall make Grantee Records available
during normal business hours at Grantee’s office or place of business, or at other mutually
agreed upon times or locations, upon no fewer than two Business Days’ notice from the State,
unless the State determines that a shorter period of notice, or no notice, is necessary to protect
the interests of the State.
C. Monitoring
The State will monitor Grantee’s performance of its obligations under this Agreement using
procedures as determined by the State. The federal government and any other duly authorized
agent of a governmental agency, in its discretion, may monitor Grantee’s performance of its
obligations under this Agreement using procedures as determined by that governmental
entity. Grantee shall allow the State to perform all monitoring required by the Uniform
Guidance, based on the State’s risk analysis of Grantee and this Agreement. The State shall
have the right, in its sole discretion, to change its monitoring procedures and requirements at
any time during the term of this Agreement. The State shall monitor Grantee’s performance
in a manner that does not unduly interfere with Grantee’s performance of the Work.
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D. Final Audit Report
Grantee shall promptly submit to the State a copy of any final audit report of an audit
performed on Grantee’s records that relates to or affects this Agreement or the Work, whether
the audit is conducted by Grantee or a third party. Additionally, if Grantee is required to
perform a single audit under 2 CFR 200.501, et seq., then Grantee shall submit a copy of the
results of that audit to the State within the same timelines as the submission to the federal
government.
8. CONFIDENTIAL INFORMATION-STATE RECORDS
A. Confidentiality
Grantee shall keep confidential, and cause all Subcontractors to keep confidential, all State
Records, unless those State Records are publicly available. Grantee shall not, without prior
written approval of the State, use, publish, copy, disclose to any third party, or permit the use
by any third party of any State Records, except as otherwise stated in this Agreement,
permitted by law or approved in writing by the State. Grantee shall provide for the security
of all State Confidential Information in accordance with all policies promulgated by the
Colorado Office of Information Security and all applicable laws, rules, policies, publications,
and guidelines. If Grantee or any of its Subcontractors will or may receive the following types
of data, Grantee or its Subcontractors shall provide for the security of such data according to
the following: (i) the most recently promulgated IRS Publication 1075 for all Tax Information
and in accordance with the Safeguarding Requirements for Federal Tax Information attached
to this Agreement as an Exhibit, if applicable; (ii) the most recently updated PCI Data
Security Standard from the PCI Security Standards Council for all PCI; (iii) the most recently
issued version of the U.S. Department of Justice, Federal Bureau of Investigation, Criminal
Justice Information Services Security Policy for all CJI; and (iv) the federal Health Insurance
Portability and Accountability Act for all PHI and the HIPAA Business Associate Agreement
attached to this Agreement, if applicable. Grantee shall immediately forward any request or
demand for State Records to the State’s Principal Representative.
B. Other Entity Access and Nondisclosure Agreements
Grantee may provide State Records to its agents, employees, assigns and Subcontractors as
necessary to perform the Work, but shall restrict access to State Confidential Information to
those agents, employees, assigns and Subcontractors who require access to perform their
obligations under this Agreement. Grantee shall ensure all such agents, employees, assigns,
and Subcontractors sign agreements containing nondisclosure provisions at least as protective
as those in this Agreement, and that the nondisclosure provisions are in force at all times the
agent, employee, assign or Subcontractor has access to any State Confidential Information.
Grantee shall provide copies of those signed nondisclosure provisions to the State upon
execution of the nondisclosure provisions.
C. Use, Security, and Retention
Grantee shall use, hold and maintain State Confidential Information in compliance with any
and all applicable laws and regulations in facilities located within the United States, and shall
maintain a secure environment that ensures confidentiality of all State Confidential
Information wherever located. Grantee shall provide the State with access, subject to
Grantee’s reasonable security requirements, for purposes of inspecting and monitoring access
and use of State Confidential Information and evaluating security control effectiveness. Upon
the expiration or termination of this Agreement, Grantee shall return State Records provided
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to Grantee or destroy such State Records and certify to the State that it has done so, as directed
by the State. If Grantee is prevented by law or regulation from returning or destroying State
Confidential Information, Grantee warrants it will guarantee the confidentiality of, and cease
to use, such State Confidential Information.
D. Incident Notice and Remediation
If Grantee becomes aware of any Incident, it shall notify the State immediately and cooperate
with the State regarding recovery, remediation, and the necessity to involve law enforcement,
as determined by the State. Unless Grantee can establish that none of Grantee or any of its
agents, employees, assigns or Subcontractors are the cause or source of the Incident, Grantee
shall be responsible for the cost of notifying each person who may have been impacted by
the Incident. After an Incident, Grantee shall take steps to reduce the risk of incurring a
similar type of Incident in the future as directed by the State, which may include, but is not
limited to, developing and implementing a remediation plan that is approved by the State at
no additional cost to the State. The State may adjust or direct modifications to this plan, in its
sole discretion and Grantee shall make all modifications as directed by the State. If Grantee
cannot produce its analysis and plan within the allotted time, the State, in its sole discretion,
may perform such analysis and produce a remediation plan, and Grantee shall reimburse the
State for the reasonable costs thereof.
E. Safeguarding PII
If Grantee or any of its Subcontractors will or may receive PII under this Agreement, Grantee
shall provide for the security of such PII, in a manner and form acceptable to the State,
including, without limitation, State non-disclosure requirements, use of appropriate
technology, security practices, computer access security, data access security, data storage
encryption, data transmission encryption, security inspections, and audits. Grantee shall be a
“Third-Party Service Provider” as defined in §24-73-103(1)(i), C.R.S. and shall maintain
security procedures and practices consistent with §§24-73-101 et seq., C.R.S.
9. CONFLICTS OF INTEREST
A. Actual Conflicts of Interest
Grantee shall not engage in any business or activities, or maintain any relationships that
conflict in any way with the full performance of the obligations of Grantee under this
Agreement. Such a conflict of interest would arise when a Grantee or Subcontractor’s
employee, officer or agent were to offer or provide any tangible personal benefit to an
employee of the State, or any member of his or her immediate family or his or her partner,
related to the award of, entry into or management or oversight of this Agreement.
B. Apparent Conflicts of Interest
Grantee acknowledges that, with respect to this Agreement, even the appearance of a conflict
of interest shall be harmful to the State’s interests. Absent the State’s prior written approval,
Grantee shall refrain from any practices, activities or relationships that reasonably appear to
be in conflict with the full performance of Grantee’s obligations under this Agreement.
C. Disclosure to the State
If a conflict or the appearance of a conflict arises, or if Grantee is uncertain whether a conflict
or the appearance of a conflict has arisen, Grantee shall submit to the State a disclosure
statement setting forth the relevant details for the State’s consideration. Failure to promptly
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submit a disclosure statement or to follow the State’s direction in regard to the actual or
apparent conflict constitutes a breach of this Agreement.
10. INSURANCE
Grantee shall obtain and maintain, and ensure that each Subcontractor shall obtain and maintain,
insurance as specified in this section at all times during the term of this Agreement. All insurance
policies required by this Agreement that are not provided through self-insurance shall be issued by
insurance companies as approved by the State.
A. Workers’ Compensation
Workers’ compensation insurance as required by state statute, and employers’ liability
insurance covering all Grantee or Subcontractor employees acting within the course and
scope of their employment.
B. General Liability
Commercial general liability insurance covering premises operations, fire damage,
independent contractors, products and completed operations, blanket contractual liability,
personal injury, and advertising liability with minimum limits as follows:
i. $1,000,000 each occurrence;
ii. $1,000,000 general aggregate;
iii. $1,000,000 products and completed operations aggregate; and
iv. $50,000 any one fire.
C. Automobile Liability
Automobile liability insurance covering any auto (including owned, hired and non-owned
autos) with a minimum limit of $1,000,000 each accident combined single limit.
D. Cyber/Network Security and Privacy Liability
This section ☒ shall | ☐ shall not apply to this Agreement.
Liability insurance covering civil, regulatory, and statutory damages, contractual damages,
data breach management exposure, and any loss of income or extra expense as a result of
actual or alleged breach, violation, or infringement of right to privacy, consumer data
protection law, confidentiality or other legal protection for personal information, as well as
State Confidential Information with minimum limits as follows:
i. $1,000,000 each occurrence; and
ii. $2,000,000 general aggregate.
E. Professional Liability Insurance
This section ☒ shall | ☐ shall not apply to this A greem ent.
Professional liability insurance covering any damages caused by an error, omission or any
negligent act with minimum limits as follows:
i. $1,000,000 each occurrence; and
ii. $1,000,000 general aggregate.
F. Crime Insurance
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Crime insurance including employee dishonesty coverage with minimum limits as follows:
i. $1,000,000 each occurrence; and
ii. $1,000,000 general aggregate.
G. Umbrella Liability Insurance
For construction projects exceeding $10,000,000, Grantee and Subcontractors shall maintain
umbrella/excess liability insurance on an occurrence basis in excess of the underlying
insurance described in §10.A through §10.E above. Coverage shall follow the terms of the
underlying insurance, included the additional insured and waiver of subrogation provisions.
The amounts of insurance required in subsections above may be satisfied by the Grantee and
Subcontractor purchasing coverage for the limits specified or by any combination of
underlying and umbrella limits, so long as the total amount of insurance is not less than the
limits specified in each section previously mentioned. The insurance shall have a minimum
amount of $5,000,000 per occurrence and $5,000,000 in the aggregate.
H. Property Insurance
If Grant Funds are provided for the acquisition, construction, or rehabilitation of real
property, insurance on the buildings and other improvements now existing or hereafter
erected on the premises and on the fixtures and personal property included in the Subject
Property against loss by fire, other hazards covered by the so called “all risk” form of policy
and such other perils as State shall from time to time require with respect to properties of the
nature and in the geographical area of the Subject Properties, and to be in an amount at least
equal to the replacement cost value of the Subject Property. Grantee will at its sole cost and
expense, from time to time and at any time, at the request of State provide State with evidence
satisfactory to State of the replacement cost of the Subject Property.
I. Flood Insurance
If the Subject Property or any part thereof is at any time located in a designated official flood
hazard area, flood insurance insuring the buildings and improvements now existing or
hereafter erected on the Subject Property and the personal property used in the operation
thereof in an amount equal to the lesser of the amount required for property insurance
identified in §10.H above, or the maximum limit of coverage made available with respect to
such buildings and improvements and personal property under applicable federal laws and
the regulations issued thereunder.
J. Builder’s Risk Insurance
This section ☐ shall | ☒ shall not apply to this A greem ent.
Grantee and/or Subcontractor shall purchase and maintain property insurance written on a
builder’s risk “all-risk” or equivalent policy form in the amount of the initial
construction/rehabilitation costs, plus value of subsequent modifications and cost of materials
supplied or installed by others, comprising total value for the entire Project at the site on a
replacement cost basis without optional deductibles. Such property insurance shall be
maintained, unless otherwise agreed in writing by all persons and entities who are
beneficiaries of such insurance, until final payment has been made or until no person or entity
other than the property owner has an insurable interest in the property.
i. The insurance shall include interests of the property owner, Grantee, and
Subcontractors in the Project as named insureds.
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ii. All associated deductibles shall be the responsibility of the Grantee, and Subcontractor.
Such policy may have a deductible clause but not to exceed $10,000.
iii. Property insurance shall be on an “all risk” or equivalent policy form and shall include,
without limitation, insurance against the perils of fire (with extended coverage) and
physical loss or damage including, without duplication of coverage, theft, vandalism,
malicious mischief, collapse, earthquake, flood, windstorm, falsework, testing and
startup, temporary buildings and debris removal including demolition occasioned by
enforcement of any applicable legal requirements, and shall cover reasonable
compensation for Grantee’s and Subcontractor’s services and expenses required as a
result of such insured loss.
iv. Builders Risk coverage shall include partial use by Grantee and/or property owner.
v. The amount of such insurance shall be increased to include the cost of any additional
work to be done on the Project, or materials or equipment to be incorporated in the
Project, under other independent contracts let or to be let. In such event, Subcontractor
shall be reimbursed for this cost as his or her share of the insurance in the same ratio as
the ratio of the insurance represented by such independent contracts let or to be let to
the total insurance carried.
K. Pollution Liability Insurance
If Grantee and/or its Subcontractor is providing directly or indirectly work with
pollution/environmental hazards, they must provide or cause those conducting the work to
provide Pollution Liability Insurance coverage. The Pollution Liability policy must include
contractual liability coverage. The policy limits shall be in the amount of $1,000,000 with
maximum deductible of $25,000 to be paid by the Grantee’s Subcontractor.
L. Additional Insured
The State shall be named as additional insured on all commercial general liability policies
(leases and construction Agreements require additional insured coverage for completed
operations) required of Grantee and Subcontractors.
M. Primacy of Coverage
Coverage required of Grantee and each Subcontractor shall be primary and noncontributory
over any insurance or self-insurance program carried by Grantee or the State.
N. Cancellation
All commercial insurance policies shall include provisions preventing cancellation or non-
renewal, except for cancellation based on non-payment of premiums, without at least 30 days
prior notice to Grantee and Grantee shall forward such notice to the State in accordance with
§14 within seven days of Grantee’s receipt of such notice.
O. Subrogation Waiver
All commercial insurance policies secured or maintained by Grantee or its Subcontractors in
relation to this Agreement shall include clauses stating that each carrier shall waive all rights
of recovery under subrogation or otherwise against Grantee or the State, its agencies,
institutions, organizations, officers, agents, employees, and volunteers.
P. Public Entities
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If Grantee is a “public entity” within the meaning of the Colorado Governmental Immunity
Act, §§24-10-101, et seq., C.R.S. (the “GIA”), Grantee shall maintain, in lieu of the liability
insurance requirements stated above, at all times during the term of this Agreement such
liability insurance, by commercial policy or self-insurance, as is necessary to meet its
liabilities under the GIA. If a Subcontractor is a public entity within the meaning of the GIA,
Grantee shall ensure that the Subcontractor maintain at all times during the terms of this
Grantee, in lieu of the liability insurance requirements stated above, such liability insurance,
by commercial policy or self-insurance, as is necessary to meet the Subcontractor’s
obligations under the GIA.
Q. Certificates
For each commercial insurance plan provided by Grantee under this Agreement, Grantee
shall provide to the State certificates evidencing Grantee’s insurance coverage required in
this Agreement within seven Business Days following the Effective Date. Grantee shall
provide to the State certificates evidencing Subcontractor insurance coverage required under
this Agreement within seven Business Days following the Effective Date, except that, if
Grantee’s Subcontractor is not in effect as of the Effective Date, Grantee shall provide to the
State certificates showing Subcontractor insurance coverage required under this Agreement
within seven Business Days following Grantee’s execution of the Subcontractor. No later
than 15 days before the expiration date of Grantee’s or any Subcontractor’s coverage, Grantee
shall deliver to the State certificates of insurance evidencing renewals of coverage. At any
other time during the term of this Agreement, upon request by the State, Grantee shall, within
seven Business Days following the request by the State, supply to the State evidence
satisfactory to the State of compliance with the provisions of this section.
11. BREACH OF AGREEMENT
In the event of a Breach of Agreement, the aggrieved Party shall give written notice of Breach of
Agreement to the other Party. If the notified Party does not cure the breach, at its sole expense,
within 30 days after the delivery of written notice, the Party may exercise any of the remedies as
described in §12 for that Party. Notwithstanding any provision of this Agreement to the contrary,
the State, in its discretion, need not provide notice or a cure period and may immediately terminate
this Agreement in whole or in part or institute any other remedy in this Agreement in order to
protect the public interest of the State; or if Grantee is debarred or suspended under §24-109-105,
C.R.S., the State, in its discretion, need not provide notice or cure period and may terminate this
Agreement in whole or in part or institute any other remedy in this Agreement as of the date that
the debarment or suspension takes effect.
12. REMEDIES
A. State’s Remedies
If Grantee is in breach under any provision of this Agreement and fails to cure such breach,
the State, following the notice and cure period set forth in §11, shall have all of the remedies
listed in this section in addition to all other remedies set forth in this Agreement or at law.
The State may exercise any or all of the remedies available to it, in its discretion, concurrently
or consecutively.
i. Termination for Breach
In the event of Grantee’s uncured breach, the State may terminate this entire Agreement
or any part of this Agreement. Additionally, if Grantee fails to comply with any terms
of the Federal Award, then the State may, in its discretion or at the direction of a Federal
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Awarding Agency, terminate this entire Agreement or any part of this Agreement.
Grantee shall continue performance of this Agreement to the extent not terminated, if
any.
a. Obligations and Rights
To the extent specified in any termination notice, Grantee shall not incur further
obligations or render further performance past the effective date of such notice,
and shall terminate outstanding orders and Subcontractors with third parties.
However, Grantee shall complete and deliver to the State all Work not cancelled
by the termination notice, and may incur obligations as necessary to do so within
this Agreement’s terms. At the request of the State, Grantee shall assign to the
State all of Grantee’s rights, title, and interest in and to such terminated orders or
Subcontractors. Upon termination, Grantee shall take timely, reasonable and
necessary action to protect and preserve property in the possession of Grantee but
in which the State has an interest. At the State’s request, Grantee shall return
materials owned by the State in Grantee’s possession at the time of any
termination. Grantee shall deliver all completed Work Product and all Work
Product that was in the process of completion to the State at the State’s request.
b. Payments
Notwithstanding anything to the contrary, the State shall only pay Grantee for
accepted Work received as of the date of termination. If, after termination by the
State, the State agrees that Grantee was not in breach or that Grantee’s action or
inaction was excusable, such termination shall be treated as a termination in the
public interest, and the rights and obligations of the Parties shall be as if this
Agreement had been terminated in the public interest under §2.E.
c. Damages and Withholding
Notwithstanding any other remedial action by the State, Grantee shall remain
liable to the State for any damages sustained by the State in connection with any
breach by Grantee, and the State may withhold payment to Grantee for the purpose
of mitigating the State’s damages until such time as the exact amount of damages
due to the State from Grantee is determined. The State may withhold any amount
that may be due Grantee as the State deems necessary to protect the State against
loss including, without limitation, loss as a result of outstanding liens and excess
costs incurred by the State in procuring from third parties replacement Work as
cover.
ii. Remedies Not Involving Termination
The State, in its discretion, may exercise one or more of the following additional
remedies:
a. Suspend Performance
Suspend Grantee’s performance with respect to all or any portion of the Work
pending corrective action as specified by the State without entitling Grantee to an
adjustment in price or cost or an adjustment in the performance schedule. Grantee
shall promptly cease performing Work and incurring costs in accordance with the
State’s directive, and the State shall not be liable for costs incurred by Grantee
after the suspension of performance.
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b. Withhold Payment
Withhold payment to Grantee until Grantee corrects its Work.
c. Deny Payment
Deny payment for Work not performed, or that due to Grantee’s actions or
inactions, cannot be performed or if they were performed are reasonably of no
value to the state; provided, that any denial of payment shall be equal to the value
of the obligations not performed.
d. Removal
Demand immediate removal of any of Grantee’s employees, agents, or
Subcontractors from the Work whom the State deems incompetent, careless,
insubordinate, unsuitable, or otherwise unacceptable or whose continued relation
to this Agreement is deemed by the State to be contrary to the public interest or
the State’s best interest.
e. Intellectual Property
If any Work infringes, or if the State in its sole discretion determines that any
Work is likely to infringe, a patent, copyright, trademark, trade secret or other
intellectual property right, Grantee shall, as approved by the State (i) secure that
right to use such Work for the State and Grantee; (ii) replace the Work with
noninfringing Work or modify the Work so that it becomes noninfringing; or, (iii)
remove any infringing Work and refund the amount paid for such Work to the
State.
B. Grantee’s Remedies
If the State is in breach of any provision of this Agreement and does not cure such breach,
Grantee, following the notice and cure period in §11 and the dispute resolution process in
§13 shall have all remedies available at law and equity.
13. DISPUTE RESOLUTION
A. Initial Resolution
Except as herein specifically provided otherwise, disputes concerning the performance of this
Agreement, which cannot be resolved by the designated Agreement representatives shall be
referred in writing to a senior departmental management staff member designated by the State
and a senior manager designated by Grantee for resolution.
B. Resolution of Controversies
If the initial resolution described in §13.A13.A fails to resolve the dispute within ten Business
Days, Grantee shall submit any alleged breach of this Agreement by the State to the
Procurement Official of the State Agency named on the Cover Page of this Agreement as
described in §24-101-301(30), C.R.S. for resolution following the same resolution of
controversies process as described in §§24-106-109, and 24-109-101.1 through 24-109-505,
C.R.S. (the “Resolution Statutes”), except that if Grantee wishes to challenge any decision
rendered by the Procurement Official, Grantee’s challenge shall be an appeal to the executive
director of the Department of Personnel and Administration, or their delegate, in the same
manner as described in the Resolution Statutes before Grantee pursues any further action.
Except as otherwise stated in this Section, all requirements of the Resolution Statutes shall
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apply including, without limitation, time limitations regardless of whether the Colorado
Procurement Code applies to this Agreement.
14. NOTICES AND REPRESENTATIVES
Each individual identified as a Principal Representative on the Cover Page for this Agreement shall
be the principal representative of the designating Party. All notices required or permitted to be
given under this Agreement shall be in writing, and shall be delivered (A) by hand with receipt
required, (B) by certified or registered mail to such Party’s principal representative at the address
set forth below or (C) as an email with read receipt requested to the principal representative at the
email address, if any, set forth on the Cover Page for this Agreement. If a Party delivers a notice
to another through email and the email is undeliverable, then, unless the Party has been provided
with an alternate email contact, the Party delivering the notice shall deliver the notice by hand with
receipt required or by certified or registered mail to such Party’s principal representative at the
address set forth on the Cover Page for this Agreement. Either Party may change its principal
representative or principal representative contact information, or may designate specific other
individuals to receive certain types of notices in addition to or in lieu of a principal representative,
by notice submitted in accordance with this section without a formal amendment to this Agreement.
Unless otherwise provided in this Agreement, notices shall be effective upon delivery of the written
notice.
15. RIGHTS IN WORK PRODUCT AND OTHER INFORMATION
A. Work Product
i. Copyrights
To the extent that the Work Product (or any portion of the Work Product) would not be
considered works made for hire under applicable law, Grantee hereby assigns to the
State, the entire right, title, and interest in and to copyrights in all Work Product and all
works based upon, derived from, or incorporating the Work Product; all copyright
applications, registrations, extensions, or renewals relating to all Work Product and all
works based upon, derived from, or incorporating the Work Product; and all moral
rights or similar rights with respect to the Work Product throughout the world. To the
extent that Grantee cannot make any of the assignments required by this section,
Grantee hereby grants to the State a perpetual, irrevocable, royalty-free license to use,
modify, copy, publish, display, perform, transfer, distribute, sell, and create derivative
works of the Work Product and all works based upon, derived from, or incorporating
the Work Product by all means and methods and in any format now known or invented
in the future. The State may assign and license its rights under this license.
ii. Patents
In addition, Grantee grants to the State (and to recipients of Work Product distributed
by or on behalf of the State) a perpetual, worldwide, no-charge, royalty-free,
irrevocable patent license to make, have made, use, distribute, sell, offer for sale,
import, transfer, and otherwise utilize, operate, modify and propagate the contents of
the Work Product. Such license applies only to those patent claims licensable by
Grantee that are necessarily infringed by the Work Product alone, or by the combination
of the Work Product with anything else used by the State.
iii. Assignments and Assistance
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Whether or not Grantee is under Agreement with the State at the time, Grantee shall
execute applications, assignments, and other documents, and shall render all other
reasonable assistance requested by the State, to enable the State to secure patents,
copyrights, licenses and other intellectual property rights related to the Work Product.
The Parties intend the Work Product to be works made for hire. Grantee assigns to the
State and its successors and assigns, the entire right, title, and interest in and to all
causes of action, either in law or in equity, for past, present, or future infringement of
intellectual property rights related to the Work Product and all works based on, derived
from, or incorporating the Work Product.
B. Exclusive Property of the State
Except to the extent specifically provided elsewhere in this Agreement, any pre-existing State
Records, State software, research, reports, studies, photographs, negatives or other
documents, drawings, models, materials, data and information shall be the exclusive property
of the State (collectively, “State Materials”). Grantee shall not use, willingly allow, cause or
permit Work Product or State Materials to be used for any purpose other than the performance
of Grantee’s obligations in this Agreement without the prior written consent of the State.
Upon termination of this Agreement for any reason, Grantee shall provide all Work Product
and State Materials to the State in a form and manner as directed by the State.
C. Exclusive Property of Grantee
Grantee retains the exclusive rights, title, and ownership to any and all pre-existing materials
owned or licensed to Grantee including, but not limited to, all pre-existing software, licensed
products, associated source code, machine code, text images, audio and/or video, and third-
party materials, delivered by Grantee under this Agreement, whether incorporated in a
Deliverable or necessary to use a Deliverable (collectively, “Grantee Property”). Grantee
Property shall be licensed to the State as set forth in this Agreement or a State approved
license agreement: (i) entered into as exhibits to this Agreement, (ii) obtained by the State
from the applicable third-party vendor, or (iii) in the case of open source software, the license
terms set forth in the applicable open source license agreement.
16. GENERAL PROVISIONS
A. Assignment
Grantee’s rights and obligations under this Agreement are personal and may not be
transferred or assigned without the prior, written consent of the State. Any attempt at
assignment or transfer without such consent shall be void. Any assignment or transfer of
Grantee’s rights and obligations approved by the State shall be subject to the provisions of
this Agreement.
B. Subcontractors
Grantee shall not enter into any subgrant or Subcontract in connection with its obligations
under this Agreement without the prior, written approval of the State. Grantee shall submit
to the State a copy of each such subgrant or Subcontract upon request by the State. All
subgrants and Subcontracts entered into by Grantee in connection with this Agreement shall
comply with all applicable federal and state laws and regulations, shall provide that they are
governed by the laws of the State of Colorado, and shall be subject to all provisions of this
Agreement. If the entity with whom Grantee enters into a Subcontract or subgrant would also
be considered a Subrecipient, then the Subcontract or subgrant entered into by Grantee shall
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also contain provisions permitting both Grantee and the State to perform all monitoring of
that Subcontract in accordance with the Uniform Guidance.
C. Binding Effect
Except as otherwise provided in §17.A, all provisions of this Agreement, including the
benefits and burdens, shall extend to and be binding upon the Parties’ respective successors
and assigns.
D. Authority
Each Party represents and warrants to the other that the execution and delivery of this
Agreement and the performance of such Party’s obligations have been duly authorized.
E. Captions and References
The captions and headings in this Agreement are for convenience of reference only, and shall
not be used to interpret, define, or limit its provisions. All references in this Agreement to
sections (whether spelled out or using the § symbol), subsections, exhibits or other
attachments, are references to sections, subsections, exhibits or other attachments contained
herein or incorporated as a part hereof, unless otherwise noted.
F. Counterparts
This Agreement may be executed in multiple, identical, original counterparts, each of which
shall be deemed to be an original, but all of which, taken together, shall constitute one and
the same agreement.
G. Entire Understanding
This Agreement represents the complete integration of all understandings between the Parties
related to the Work, and all prior representations and understandings related to the Work, oral
or written, are merged into this Agreement. Prior or contemporaneous additions, deletions,
or other changes to this Agreement shall not have any force or effect whatsoever, unless
embodied herein.
H. Digital Signatures
If any signatory signs this agreement using a digital signature in accordance with the
Colorado State Controller Agreement, Grant and Purchase Order Policies regarding the use
of digital signatures issued under the State Fiscal Rules, then any agreement or consent to use
digital signatures within the electronic system through which that signatory signed shall be
incorporated into this Agreement by reference.
I. Modification
Except as otherwise provided in this Agreement, any modification to this Agreement shall
only be effective if agreed to in a formal amendment to this Agreement, properly executed
and approved in accordance with applicable Colorado State law and State Fiscal Rules.
Modifications permitted under this Agreement, other than Agreement amendments, shall
conform to the policies issued by the Colorado State Controller.
i. By the Parties
The State, at its discretion, shall have the option to unilaterally extend the Initial Agreement Expiration
Date, change the Agreement Maximum Amount, and in the Statement of Work
(Exhibit A), adjust the Project Budget, modify the Service Area, the Milestones, the
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Responsible Administrator, the Payment Schedule, and the Remittance Address
through an Option Letter in a form substantially similar to Exhibit B, properly executed
and approved in accordance with applicable State laws, regulations, and policies.
Modifications other than by Option Letter shall not take effect unless agreed to in
writing by both parties in an amendment to this Agreement properly executed and
approved in accordance with State laws, regulations, and policies.
ii. By Operation of Law
This Agreement is subject to such modifications as may be required by changes in Federal or Colorado
State law, or their implementing regulations. Any such required modification
automatically shall be incorporated into and be part of this Agreement on the effective
date of such change, as if fully set forth herein.
iii. Items not Requiring Modification - Consents
Where the terms of this Agreement require the Grantee to obtain the consent of the Division of Housing,
the Division Director or their delegate shall be authorized to provide such consent.
J. Jurisdiction and Venue [Reserved].
K. Statutes, Regulations, Fiscal Rules, and Other Authority
Any reference in this Agreement to a statute, regulation, State Fiscal Rule, fiscal policy or
other authority shall be interpreted to refer to such authority then current, as may have been
changed or amended since the Effective Date of this Agreement.
L. External Terms and Conditions
Notwithstanding anything to the contrary herein, the State shall not be subject to any
provision included in any terms, conditions, or agreements appearing on Grantee’s or a
Subcontractor’s website or any provision incorporated into any click-through or online
agreements related to the Work unless that provision is specifically referenced in this
Agreement.
M. Severability
The invalidity or unenforceability of any provision of this Agreement shall not affect the
validity or enforceability of any other provision of this Agreement, which shall remain in full
force and effect, provided that the Parties can continue to perform their obligations under this
Agreement in accordance with the intent of this Agreement.
N. Survival of Certain Agreement Terms
Any provision of this Agreement that imposes an obligation on a Party after termination or
expiration of this Agreement shall survive the termination or expiration of this Agreement
and shall be enforceable by the other Party.
O. Taxes
The State is exempt from federal excise taxes under I.R.C. Chapter 32 (26 U.S.C., Subtitle
D, Ch. 32) (Federal Excise Tax Exemption Certificate of Registry No. 84-730123K) and from
State and local government sales and use taxes under §§39-26-704(1), et seq., C.R.S.
(Colorado Sales Tax Exemption Identification Number 98-02565). The State shall not be
liable for the payment of any excise, sales, or use taxes, regardless of whether any political
subdivision of the state imposes such taxes on Grantee. Grantee shall be solely responsible
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for any exemptions from the collection of excise, sales or use taxes that Grantee may wish to
have in place in connection with this Agreement.
P. Third Party Beneficiaries
Except for the Parties’ respective successors and assigns described in § 17.A, this Agreement
does not and is not intended to confer any rights or remedies upon any person or entity other
than the Parties. Enforcement of this Agreement and all rights and obligations hereunder are
reserved solely to the Parties. Any services or benefits which third parties receive as a result
of this Agreement are incidental to this Agreement, and do not create any rights for such third
parties.
Q. Waiver
A Party’s failure or delay in exercising any right, power, or privilege under this Agreement,
whether explicit or by lack of enforcement, shall not operate as a waiver, nor shall any single
or partial exercise of any right, power, or privilege preclude any other or further exercise of
such right, power, or privilege.
R. CORA Disclosure
To the extent not prohibited by federal law, this Agreement and the performance measures
and standards required under §24-106-107, C.R.S., if any, are subject to public release
through the CORA.
S. Standard and Manner of Performance
Grantee shall perform its obligations under this Agreement in accordance with the highest
standards of care, skill and diligence in Grantee’s industry, trade, or profession.
T. Licenses, Permits, and Other Authorizations
Grantee shall secure, prior to the Effective Date, and maintain at all times during the term of
this Agreement, at its sole expense, all licenses, certifications, permits, and other
authorizations required to perform its obligations under this Agreement, and shall ensure that
all employees, agents and Subcontractors secure and maintain at all times during the term of
their employment, agency or Subcontractor, all license, certifications, permits and other
authorizations required to perform their obligations in relation to this Agreement.
U. Indemnification
i. General Indemnification
Grantee shall indemnify, save, and hold harmless the State, its employees, agents and
assignees (the “Indemnified Parties”), against any and all costs, expenses, claims,
damages, liabilities, court awards and other amounts (including attorneys’ fees and
related costs) incurred by any of the Indemnified Parties in relation to any act or
omission by Grantee, or its employees, agents, Subcontractors, or assignees in
connection with this Agreement.
ii. Confidential Information Indemnification
Disclosure or use of State Confidential Information by Grantee in violation of §8 may
be cause for legal action by third parties against Grantee, the State, or their respective
agents. Grantee shall indemnify, save, and hold harmless the Indemnified Parties,
against any and all claims, damages, liabilities, losses, costs, expenses (including
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attorneys’ fees and costs) incurred by the State in relation to any act or omission by
Grantee, or its employees, agents, assigns, or Subcontractors in violation of §8.
iii. Intellectual Property Indemnification
Grantee shall indemnify, save, and hold harmless the Indemnified Parties, against any
and all costs, expenses, claims, damages, liabilities, and other amounts (including
attorneys’ fees and costs) incurred by the Indemnified Parties in relation to any claim
that any Work infringes a patent, copyright, trademark, trade secret, or any other
intellectual property right.
V. Compliance with State and Federal Law, Regulations, and Executive Orders
Grantee shall comply with all State and Federal law, regulations, executive orders, State and
Federal Awarding Agency policies, procedures, directives, and reporting requirements at all
times during the term of this Grant.
W. Accessibility
i. Grantee shall comply with and the Work Product provided under this Agreement shall
be in compliance with all applicable provisions of §§24-85-101, et seq., C.R.S., and
the Accessibility Standards for Individuals with a Disability, as established by the
Governor’s Office of Information Technology (OIT), pursuant to Section §24-85-103
(2.5), C.R.S. Grantee shall also comply with all State of Colorado technology standards
related to technology accessibility and with Level AA of the most current version of the
Web Content Accessibility Guidelines (WCAG), incorporated in the State of Colorado
technology standards.
ii. Grantee shall indemnify, save, and hold harmless the Indemnified Parties against any
and all costs, expenses, claims, damages, liabilities, court awards and other amounts
(including attorneys’ fees and related costs) incurred by any of the Indemnified Parties
in relation to Grantee’s failure to comply with §§24-85-101, et seq., C.R.S., or
the Accessibility Standards for Individuals with a Disability as established by OIT
pursuant to Section §24-85-103 (2.5), C.R.S.
iii. The State may require Grantee’s compliance to the State’s Accessibility Standards to
be determined by a third party selected by the State to attest to Grantee’s Work Product
and software is in compliance with §§24-85-101, et seq., C.R.S., and the Accessibility
Standards for Individuals with a Disability as established by OIT pursuant to Section
§24-85-103 (2.5), C.R.S.
17. COLORADO SPECIAL PROVISIONS (COLORADO FISCAL RULE 3-3)
These Special Provisions apply to all agreements except where noted in italics.
A. STATUTORY APPROVAL. §24-30-202(1), C.R.S.
This Agreement shall not be valid until it has been approved by the Colorado State Controller
or designee. If this Agreement is for a Major Information Technology Project, as defined in
§24-37.5-102(2.6), C.R.S., then this Agreement shall not be valid until it has been approved
by the State’s Chief Information Officer or designee.
B. FUND AVAILABILITY. §24-30-202(5.5), C.R.S.
Financial obligations of the State payable after the current State Fiscal Year are contingent
upon funds for that purpose being appropriated, budgeted, and otherwise made available.
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C. GOVERNMENTAL IMMUNITY.
Liability for claims for injuries to persons or property arising from the negligence of the State,
its departments, boards, commissions committees, bureaus, offices, employees and officials
shall be controlled and limited by the provisions of the Colorado Governmental Immunity
Act, §24-10-101, et seq., C.R.S.; the Federal Tort Claims Act, 28 U.S.C. Pt. VI, Ch. 171 and
28 U.S.C. 1346(b), and the State’s risk management statutes, §§24-30-1501, et seq. C.R.S.
No term or condition of this Agreement shall be construed or interpreted as a waiver, express
or implied, of any of the immunities, rights, benefits, protections, or other provisions,
contained in these statutes.
D. INDEPENDENT CONTRACTOR.
Grantee shall perform its duties hereunder as an independent contractor, and not as an
employee. Neither Grantee nor any agent or employee of Grantee shall be deemed to be an
agent or employee of the State. Grantee shall not have authorization, express or implied, to
bind the State to any agreement, liability or understanding, except as expressly set forth
herein. Grantee and its employees and agents are not entitled to unemployment
insurance or workers compensation benefits through the State and the State shall not
pay for or otherwise provide such coverage for Grantee or any of its agents or
employees. Grantee shall pay when due all applicable employment taxes and income
taxes and local head taxes incurred pursuant to this Agreement. Grantee shall (i)
provide and keep in force workers' compensation and unemployment compensation
insurance in the amounts required by law, (ii) provide proof thereof when requested by
the State, and (iii) be solely responsible for its acts and those of its employees and agents.
E. COMPLIANCE WITH LAW.
Grantee shall comply with all applicable federal and State laws, rules, and regulations in
effect or hereafter established, including, without limitation, laws applicable to
discrimination and unfair employment practices.
F. CHOICE OF LAW
Colorado law, and rules and regulations issued pursuant thereto, shall be applied in the
interpretation, execution, and enforcement of this Agreement. Any provision included or
incorporated herein by reference which conflicts with said laws, rules, and regulations shall
be null and void. Any provision incorporated herein by reference which purports to negate
this or any other Special Provision in whole or in part shall not be valid or enforceable or
available in any action at law, whether by way of complaint, defense, or otherwise. Any
provision rendered null and void by the operation of this provision shall not invalidate the
remainder of this Agreement, to the extent capable of execution.
CHOICE OF LAW, JURISDICTION, AND VENUE.
Colorado law, and rules and regulations issued pursuant thereto, shall be applied in the
interpretation, execution, and enforcement of this Agreement. Any provision included or
incorporated herein by reference which conflicts with said laws, rules, and regulations shall
be null and void. All suits or actions related to this Agreement shall be filed and proceedings
held in the State of Colorado and exclusive venue shall be in the City and County of Denver.
G. PROHIBITED TERMS.
Any term included in this Agreement that requires the State to indemnify or hold Grantee
harmless; requires the State to agree to binding arbitration; limits Grantee’s liability for
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damages resulting from death, bodily injury, or damage to tangible property; or that conflicts
with this provision in any way shall be void ab initio. Nothing in this Agreement shall be
construed as a waiver of any provision of §24-106-109 C.R.S.
H. SOFTWARE PIRACY PROHIBITION.
State or other public funds payable under this Agreement shall not be used for the acquisition,
operation, or maintenance of computer software in violation of federal copyright laws or
applicable licensing restrictions. Grantee hereby certifies and warrants that, during the term
of this Agreement and any extensions, Grantee has and shall maintain in place appropriate
systems and controls to prevent such improper use of public funds. If the State determines
that Grantee is in violation of this provision, the State may exercise any remedy available at
law or in equity or under this Agreement, including, without limitation, immediate
termination of this Agreement and any remedy consistent with federal copyright laws or
applicable licensing restrictions.
I. EMPLOYEE FINANCIAL INTEREST/CONFLICT OF INTEREST. §§24-18-201 and
24-50-507, C.R.S.
The signatories aver that to their knowledge, no employee of the State has any personal or
beneficial interest whatsoever in the service or property described in this Agreement. Grantee
has no interest and shall not acquire any interest, direct or indirect, that would conflict in any
manner or degree with the performance of Grantee’s services and Grantee shall not employ
any person having such known interests.
J. VENDOR OFFSET AND ERRONEOUS PAYMENTS. §§24-30-202(1) and 24-30-
202.4, C.R.S.
[Not applicable to intergovernmental agreements] Subject to §24-30-202.4(3.5), C.R.S., the
State Controller may withhold payment under the State’s vendor offset intercept system for
debts owed to State agencies for: (i) unpaid child support debts or child support arrearages;
(ii) unpaid balances of tax, accrued interest, or other charges specified in §§39-21-101, et
seq., C.R.S.; (iii) unpaid loans due to the Student Loan Division of the Department of Higher
Education; (iv) amounts required to be paid to the Unemployment Compensation Fund; and
(v) other unpaid debts owing to the State as a result of final agency determination or judicial
action. The State may also recover, at the State’s discretion, payments made to Grantee in
error for any reason, including, but not limited to, overpayments or improper payments, and
unexpended or excess funds received by Grantee by deduction from subsequent payments
under this Agreement, deduction from any payment due under any other Agreements, grants
or agreements between the State and Grantee, or by any other appropriate method for
collecting debts owed to the State.
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18. RESTRICTIONS ON PUBLIC BENEFITS
This section ☐ shall | ☒ shall not apply to this A greem ent.
Grantee shall confirm that any individual natural person is lawfully present in the United States pursuant
to 8 U.S.C. §§1601 et seq. when such individual applies for public benefits provided under this
Agreement by requiring the applicant to:
B. Produce a verification document in accordance with 62 Fed. Reg. 221 (November 17, 1997),
pp. 61,363 - 61,371; and,
C. Execute a Residency Declaration, attached as Form 1, or a substantially similar form as
determined by the State. [Reserved]
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H4HRG23176
EXHIBIT A
STATEMENT OF WORK
TRANSFORMATIONAL HOMELESSNESS RESPONSE
1. GENERAL REQUIREMENTS
1.1. Program Description. The Transformational Homelessness Response (THR) grant program
(the “Program”) aims to quickly connect people experiencing homelessness with services,
treatment, and temporary and permanent housing to put them on a path to economic self-
sufficiency. The Program provides funding for program models and activities including
outreach support, emergency shelters, transitional housing, recovery care and related
residential programs, training and employment service programs, and permanent housing
with wraparound supportive services. The Program also provides funding for systems
improvement activities including data collection, management, analysis, system integration,
coordination, and resource utilization acceleration. The goal of the Program is to
fundamentally shift the landscape of homelessness in communities across Colorado by
transforming systems, programs, and outcomes. Grant awards must go beyond maintaining
current operations for projects that currently exist while being responsive to the one-time
nature of the funding provided. Grant funds may only be used for Eligible Activities as
defined in §5.2.3 (Descriptions of Uses) and listed in §5.2.2 (Project Budget) of this
Exhibit A. Grantee is responsible for completion of the Project and submission of all
required reporting and other documentation in the manner and timeframes set forth herein.
1.2. Preference. The individuals prioritized by the grant opportunity are those that but for this
project will most likely not resolve their homelessness on their own. In particular, this
includes individuals with long lengths of homelessness with complex needs and who are not
currently connected to other homeless shelters or programs.
1.3. Service Area. Grantee’s performance of services shall occur in: Eagle, Garfield, and Pitkin
Counties, State of Colorado. Grantee may also serve individuals referred to them including
through their regional Coordinated Entry Systems, even if that individual or household
currently lives outside this service area.
1.4. Grantee’s Obligations.
1.4.1. Grantee shall implement the Project, administer this Agreement, and provide required
documentation to the State as specified herein.
1.4.2. Grantee shall enter into written agreement(s), the content of which meet DOH’s
requirements, with the following individuals or entities prior to disbursing any funds:
1.4.2.1. Any Subcontractor engaged by Grantee to aid in performance of the Work.
1.4.3. Assignment. Grantee’s rights and obligations under this Exhibit A are personal and
may not be transferred or assigned without the prior, written consent of DOH. Any
attempt at assignment or transfer without such consent shall be void. Any assignment
or transfer of Grantee’s rights and obligations approved by the State shall be subject to
the provisions of this Agreement.
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1.4.4. Time of Performance. Grantee shall commence performance of its obligations on the
Performance Beginning Date and complete its obligations on or before the Initial
Agreement Expiration Date, both of which are listed on the Cover Page of the Grant
Agreement. Time of Performance may be extended in accordance with §2C of the
main body of this Agreement. To initiate the extension process, Grantee shall submit a
written request to DOH Key Personnel at least 60 days prior to the Initial Agreement
Expiration Date, and shall include a full justification for the extension request.
1.4.5. Services Standards. For grantees awarded funds to provide services, grantee shall
provide services in a manner consistent with the following standards:
1.4.5.1. Grantee shall have a staff-to-participant ratio of no less than one case manager
to every 15 households for any component of the project that includes housing,
such as transitional or supportive housing, as well as no fewer than one case
manager to every 30 households in shelter or community-based programming,
with preference for a 1:15 case management to participant ratio for all program
components.
1.4.5.2. Staff should have relevant professional accreditations, education, and
experience to implement both holistic and housing-focused services. Staff
should be community-based and multi-disciplinary when possible.
1.4.5.3. Services should be implemented using best practice models, including Housing
First, Harm Reduction, Motivational Interviewing, and Trauma-Informed Care
(see Definitions). Other services and treatment models may be coordinated with
or incorporated into the services programming based on the individuals served.
The delivery of all services should be guided by the principles of cultural
competence, recovery, and resiliency, with an emphasis on building
individuals’ strengths and resources in the community, with family, and with
peer/social networks.
1.4.5.4. Services and delivery of the supports should be adjusted appropriately based on
the intended population(s) the project will serve.
1.4.6. Habitability Standards. Temporary housing units or shelter facilities must meet
HUD's habitability standards defined in 24 CFR part 576.403(c). Documentation of
meeting minimum standards must be maintained in households' files. Grantees may use
ESG Habitability Standards Checklist found at:
https://www.hudexchange.info/resource/3766/esg-minimum-habitability-standards-
for-emergency-shelters-and-permanent-housing/ or an equivalent checklist.
1.4.7. Housing Quality Standards (HQS) are required both at initial occupancy and during
the duration of housing assistance for Supportive Housing, Rapid Re-Housing, or
Prevention programs.
1.4.8. Collaboration. Grantees shall work collaboratively with community-based partners
and referral sources as necessary to ensure that all Households served acquire and
maintain housing as efficiently as possible. For example, the grantee may attend and
participate in case conferencing meetings to identify eligible Households for the Project
and assist in process improvements as necessary, or the grantee may work in
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conjunction with the project voucher administrator and property management as
necessary to ensure the intentions and outcomes of this Agreement.
1.4.9. Homeless Management Information System: Grantee shall utilize the local
Continuum of Care (CoC) Homeless Management Information System (HMIS) for
intake, program enrollment, move-in (if applicable), service provision (if applicable),
annual assessments, and exit data collection. If Grantee does not have access to CoC
HMIS, Grantee shall seek approval from DOH to partner with an agency that has
access. Grantee agrees to fully comply with all HMIS rules and regulations including,
without limitation, the following:
1.4.9.1. Grantee shall perform data entry within five (5) days of intake, program
enrollment, move-in (if applicable), service provision (if applicable), and
discontinuance of participation by a Household.
1.4.9.2. Grantee shall run regular data quality checks to ensure data is accurate.
1.4.9.3. Grantee shall sign all required CoC HMIS agreements and adhere to all CoC
HMIS policies and procedures. (These agreements are available from the CoC
HMIS administrator for each CoC.)
1.4.9.4. Grantee shall submit and update data in the HMIS Database as
requested/necessary to complete performance reports (per §7.3 of this Exhibit
A), as well as any other reports required by the CoC.
1.4.9.5. Grantee shall provide other information as requested by DOH for reporting and
program evaluation purposes including, without limitation, the number of
Households, the status of each Household, the location of units, the progress of
the Households, and any other information deemed relevant by DOH.
1.4.9.6. Grantee shall ensure there is a current HMIS Client Consent Form on file for
each Household.
2. DEFINITIONS The following terms pertain to the Statement of Work, and shall be construed
and interpreted as follows:
2.1. Area Median Income. The Department of Housing and Urban Development (HUD) sets
income limits that determine eligibility for assisted housing programs including the Public
Housing, Section 8 project-based, Section 8 Housing Choice Voucher, Section 202 housing
for the elderly, and Section 811 housing for persons with disabilities programs. HUD
develops income limits based on Median Family Income estimates and Fair Market Rent area
definitions for each metropolitan area, parts of some metropolitan areas, and each non-
metropolitan county. DOH sets voucher payment standards annually using HUD income
limits.
2.2. Behavioral Health. “Behavioral Health” is the scientific study of the emotions, behaviors
and biology relating to a person’s mental well-being, their ability to function in everyday life
and their concept of self. Behavioral health conditions include: substance use disorders;
alcohol and drug addiction; and serious psychological distress, including suicide ideation and
mental disorders.
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2.3. Beneficiaries. “Beneficiaries” shall mean the persons and/or households who are the end
users that benefit from the Project.
2.4. Comparable Database. “Comparable Database” is a database that meets all Homeless
Management Information System (HMIS) Data Standards and does so in a method that
protects the safety and privacy of the survivor. Comparable databases are used by “Victim
Service Providers” (i.e., non-profit organizations whose primary mission is to provide
services to survivors of domestic violence, dating violence, sexual assault, or stalking).
2.5. Continuums of Care. “Continuums of Care” are regional planning bodies which organize
and deliver housing and services within their communities. There are four CoCs in
Colorado: the Metro Denver Homeless Initiative (Denver, Boulder, Arapahoe, Douglas,
Jefferson, and Adams counties), Pikes Peak CoC (El Paso County), Northern Colorado
CoC (Larimer and Weld counties), and the Balance of State CoC (the 54 remaining
counties grouped into 10 regional coalitions).
2.6. Coordinated Entry. “Coordinated Entry” is a system operated by each CoC in which the
goal is to create and maintain a by-name list of every assessed individual or family
experiencing homelessness in that CoC’s region so that they can be prioritized and matched
with the most appropriate and available housing resource.
2.7. DOH. “DOH” means the Colorado Department of Local Affairs, Division of Housing.
2.8. Harm Reduction. “Harm Reduction” means a set of practical approaches aimed to reduce
the harm associated with substance use rather than on the prevention of substance use itself.
Harm reduction approaches recognize that individuals can be at different stages of recovery
and that effective interventions should be individually tailored to each individual’s stage.
Such strategies have been effective in reducing morbidity and mortality for such
individuals by incorporating strategies from safer use, to managed use, to abstinence.
Individuals are allowed to make choices about use and treatment, and regardless of the
choices, are not treated adversely, housing status is not threatened, and help continues to be
available.
2.9. Homeless or Experiencing Homelessness. “Homeless” or “Experiencing Homelessness”
refers to a household that is living unsheltered, in a place not meant for human habitation or
in a homeless shelter, or is at risk of losing their housing within 14 days. Homelessness is
defined as living in a place not meant for human habitation, in emergency shelter, in
temporary housing (e.g. - safe haven, transitional housing, bridge housing, or rapid
rehousing), or exiting an institution where the person temporarily resided.
2.10. Homeless Management Information System (HMIS). “Homeless Management
Information System” is a local information technology system used to collect client-level
data and data on the provision of housing and services to homeless individuals and families
and persons at risk of homelessness. Each Continuum of Care is responsible for selecting
an HMIS software solution that complies with HUD's data collection, management, and
reporting standards.
2.11. Housing First. “Housing First” is a proven approach that prioritizes non-time limited
housing to people experiencing homelessness, thus ending their homelessness. Housing
First recognizes that housing is a platform from which individuals can pursue personal
goals and improve quality of life. This approach is guided by the belief that people need
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basic necessities, such as food and housing, before attending to other goals, such as
employment, budgeting, or substance use treatment. Unlike “Housing Ready” or “Housing
Next” or “Treatment First” models, Housing First positions housing as an immediate
priority for people experiencing homelessness. Numerous models complement Housing
First, such as Harm Reduction, low barrier programming, trauma-informed approaches, and
individual choice.
2.12. HUD. “HUD” is the United States Department of Housing and Urban Development.
2.13. Inclusion, diversity, equity, and accessibility (IDEA). “Inclusion, diversity, equity, and
accessibility (IDEA)” are terms used to define efforts to outreach to and include diverse
communities, organizations, and individuals who identify with diverse backgrounds,
including but not limited to ethnicity, race, language, national origin, sexual orientation,
gender identity and expression, and ability.
2.14. Indirect Costs. “Indirect Costs” means those costs that have been incurred for shared or
joint objectives and cannot be readily identified with any particular activity. After direct
costs have been determined and assigned directly to the grant award, or other work as
appropriate, indirect costs are those that remain to be allocated. Examples include: office
rent, utility, insurance, maintenance, and other expenditures related to shared space;
administrative and executive team functions that support multiple program areas; and
purchases, transportation, and staff expenses that benefit multiple program areas. Further
guidance on indirect costs is provided in 2 CFR Part 200, Subpart E.
2.15. Motivational Interviewing. “Motivational Interviewing (MI)” is a collaborative, person-
centered form of guiding to elicit and strengthen motivation for change by exploring and
resolving ambivalence. MI is considered to be an evidence-based practice that has proven
to be successful.
2.16. Other Funds. “Other Funds” means funding provided or to be provided by other federal,
state, local, or private sources for the Project. Other Funds are good faith estimates and do
not include Grant Funds.
2.17. Project Close-Out Date. “Project Close-Out Date” shall mean the date DOLA determines
the Project is complete as identified in writing to the Grantee.
2.18. Recovery Care. “Recovery Care” are services provided for individuals with Substance Use
Disorders (SUDs). These services focus on improving health outcomes and self-sufficiency
that allow individuals to reach their full potential.
2.19. Recovery Care Residential Programs “Recovery Care Residential Programs” provide
residential services and/or treatment for individuals experiencing homelessness so that they
can receive recovery care services, as defined above.
2.20. Rental Assistance. “Rental Assistance” means Housing Assistance Payments (HAP) paid
on behalf of households by a Public Housing Authority (PHA) directly to property
owners/landlords. Rental Assistance is non-time limited and units must meet HQS
standards before rental assistance payments can be made. Rental Assistance must follow
the PHA’s Voucher Administrative Plan policies, procedures and regulations.
2.21. Substantial Completion. “Substantial Completion” means that Grantee has achieved the
milestones and targets identified in §3 (Deliverables) of this Exhibit A through the
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delivery of approved services as identified in §5.2.3 (Descriptions of Uses) of this Exhibit
A to Households identified in §1.2 of this Exhibit A.
2.22. Supportive Housing. “Supportive Housing,” also known as Permanent Supportive
Housing (PSH), means decent, safe, affordable, community-based housing that provides
tenants with the rights of tenancy, Tenancy Support Services, and links to other intensive
supportive services using best practices, particularly the Housing First model, as well as
Harm Reduction and Trauma-informed approaches. Supportive Housing is designed to
allow tenants to live as independently as possible.
2.23. Trauma-Informed Care. “Trauma-Informed Care” is an approach to the delivery of
behavioral health services that includes an understanding of trauma and an awareness of the
impact it can have across settings, services, and populations. It involves viewing trauma
through a cultural lens and recognizes that context plays a significant role in how
individuals perceive and process traumatic events. A trauma-informed approach realizes
the widespread impact of trauma; understands potential paths for healing; integrates
knowledge of trauma into policies and practices; and seeks to actively prevent re-
traumatization.
3. DELIVERABLES
3.1. Outcome. Full implementation of the Project and achievement of all Performance Measures.
3.2. Performance Milestones. Grantee shall achieve each of the following Milestones by the
Date shown.
Milestone Date
Provide certificate of insurance, and all other compliance
documentation requested by DOH within one month of receiving an
executed agreement
11/01/2023
Provide certification of matching funds commitments and sources to
DOH
On-going
Provide DOH access to Grantee’s HMIS web portal to review real time
client data
On-going
Submit request for reimbursements to DOH at least quarterly On-going
Track and record grant outcomes through DOH approved Performance
Measures
On-going
Submit quarterly reports as determined by DOH On-going
Submit annual progress reports as determined by DOH within 30
calendar days after the first twelve months of the grant period and
annually thereafter
On-going
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Submit Project Completion Report to DOH within 30 calendar days
after the completion of the Project
11/13/2026
4. KEY PERSONNEL
4.1. Responsible Administrator. Grantee’s performance hereunder shall be under the direct
supervision of the individual identified below, an employee or agent of Grantee, who is
hereby designated as a key person and the Responsible Administrator of this project:
Cristina Gair, Executive Director
West Mountain Regional Health Alliance
PO Box 1909 Glenwood Springs, CO 81602
cgair@westmountainhealthalliance.org
4.2. DOH Key Personnel. Libby Colón, Transformational Homelessness Response Manager,
libby.colon@state.co.us
4.3. Replacement Personnel. If any Grantee Key Personnel cease to serve, Grantee shall
immediately notify DOH of such event in writing. Replacement of Grantee Key Personnel
shall be subject to DOH approval. Requests to replace Grantee Key Personnel shall be made
in writing and shall include, without limitation, the name of the person, their qualifications,
and the effective date of the proposed change. Notices sent pursuant to this subsection shall
be sent in accordance with §14 of the main body of the Agreement, with a copy to DOH Key
Personnel. Anytime Grantee Key Personnel cease to serve, the State, at its sole discretion,
may direct Grantee to suspend work on the Project until such time as the Grantee proposes a
replacement and such replacement is approved by DOH.
5. FUNDING
The Agreement Maximum Amount to be provided by the State is set forth on the Cover Page
of the Grant Agreement and is shown for convenience in §5.2.1 as “Grant Funds (DOLA)”.
5.1. Other Funds. Grantee shall provide all funds necessary to complete the Project. All Sources,
other than the DOLA Grant Funds and Matching Funds (if any), are good faith estimates.
5.2. Project Budget.
5.2.1. Sources.
Source Amount
Grant Funds (DOLA) $2,743,690
Matching Funds
-In-Kind
-Public Housing Authority
-Medicaid
-County Funding
-Foundation Grants
-Emergency Services Grant $766,442.00
Total $3,510,132.00
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Exhibit A
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CMS #185361
5.2.2. Grant Funds (DOLA). Costs eligible for payment with DOLA Grant Funds are limited
to the items and amounts listed in the table below (subject to any line item adjustments
made pursuant to §5.4.1). A detailed description of uses is provided in §5.2.3.
Use Amount
Street Outreach $573,666
Emergency Shelter $1,093,688
Systems Improvement $1,076,336
Total $2,743,690
5.2.2.1. Pre-Agreement Costs. Reserved.
5.2.3. Descriptions of Uses. Following are descriptions of the Uses listed in §5.2.2.
5.2.3.1. Street Outreach. “Street Outreach” is non-facility based and is the act of
engaging people experiencing unsheltered homelessness where they are. “Street
Outreach” includes the following eligible activities:
5.2.3.1.1. Engagement and case management. Efforts to provide
essential services to individuals experiencing unsheltered homelessness
who are unwilling or unable to access emergency shelter, housing, or
other services or programs. This includes: (i) making an initial assessment
of services need and eligibility; (ii) assessing housing and service needs
and arranging, coordinating, and monitoring the delivery of
individualized services; (iii) coordinating with emergency shelter
providers for immediate access to shelter options, including hotel/motel
vouchers; (iv) providing crisis counseling; (v) addressing urgent physical
needs, such as providing meals, blankets, clothes, or toiletries; (vi)
actively connecting individuals to programs and services, including
transportation to needed services; and (vii) other reasonable and necessary
efforts to connect individuals to immediate support, intervention,
connections with housing, homelessness assistance programs, and/or
mainstream social services and housing programs.
5.2.3.1.2. Services for behavioral health, mental health, substance
use disorders, and medical care. Includes a continuum of behavioral
health services, treatment, and crisis intervention that is provided in non-
facility settings. Also includes coordination for access to healthcare-
related services including primary care, substance use treatment, mental
health care, vision and dental care, and emergency, crisis, and inpatient
services. Emergency behavioral, mental, or physical health services
funded under this activity may include direct outpatient treatment by
licensed professionals operating in non-facility-based settings.
5.2.3.1.3. Educational, vocational, and work-based learning
opportunities. Efforts to connect individuals encountered through
outreach with educational, vocational, and work-based learning
opportunities that resolve a household’s homelessness as quickly as
possible. A best practice is for outreach programs to create or connect to
peer mentoring programs and hire peer mentors with lived expertise
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Exhibit A
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CMS #185361
regarding homelessness to conduct outreach, as well as contribute to
program design and improvement.
5.2.3.1.4. Recovery care and related residential programs. Efforts
to connect individuals to community resources that offer recovery care
and related residential programs, including the cost of transportation to
such services and treatment.
5.2.3.1.5. Operations. Efforts related to locating and delivering
services to individuals experiencing unsheltered homelessness where they
are living and building rapport with them. This may include (i) physically
locating individuals residing in unsheltered situations; (ii) getting staff to
those locations; (iii) ongoing communication (including cell phones for
outreach workers during the performance of these activities); and (iv) and
other reasonable and necessary efforts required to locate and build trust
with those in unsheltered situations. Additionally, this can include
mapping the location of unsheltered encampments as well as upgrading,
enhancing, or customizing a database that can track real-time, geographic
data about homelessness outreach efforts.
5.2.3.1.6. Grant Activities. Efforts focused on administering a
specific grant or funding source may improve effective operations, as well
as effective program implementation. Such efforts include planning and
executing program activities, such as (i) general program or grant
management, oversight, coordination, monitoring, and evaluation; (ii)
salaries, wages, and related costs related to preparing program budgets;
developing systems for ensuring compliance with grant requirements;
developing interagency agreements; and preparing reports and other
required documents or activities; (iii) accounting or other services; and
(iv) other reasonable and necessary goods and services required to
implement the grant program, such as evaluating program results against
stated objectives, occupancy costs, and training on program requirements.
5.2.3.1.7. Indirect Costs. Pursuant to 2 CFR § 200.414, Grant Funds
may be used to pay for indirect costs in accordance with 2 CFR Part 200,
Subpart E. Prior to requesting reimbursement for indirect costs, Grantee
must discuss the indirect cost rate with DOH Key Personnel and submit
corresponding documentation to DOH Key Personnel as requested.
5.2.3.2. Emergency Shelter. “Emergency Shelter” includes facilities for which the
primary purpose is to provide temporary shelter to people experiencing
homelessness and which do not require guests to sign leases or occupancy
agreements and do not charge rent. “Emergency Shelter” includes the following
eligible activities:
5.2.3.2.1. Essential services. Efforts to provide supportive services to
those who are in an Emergency Shelter. These services include finding
housing options that resolve guests’ homelessness as quickly as possible.
Efforts include (i) housing search and placement and navigation, such as
activities to assist guests to locate and obtain housing; (ii) housing
stability case management, such as assessing, coordinating, and
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Exhibit A
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CMS #185361
delivering individualized services to obtain housing, developing case
management plans, and support groups; (iii) legal services necessary to
resolve a legal problem that prohibits the guest participant from obtaining
permanent housing; (iv) services for physical health care, mental health
care, behavioral health care, and other medical care; (v) implementing and
maintaining diversion programming; and (vi) other reasonable and
necessary costs that help resolve a household’s homelessness, including
but not limited to child care and transportation.
5.2.3.2.2. Educational, vocational, and work-based learning
opportunities. Efforts to connect individuals and families with
educational, vocational, and work-based learning opportunities that
resolve the individual’s homelessness as quickly as possible. Shelters may
consider creating or connecting to peer mentoring programs and hiring
peer mentors with lived expertise of homelessness to work in the shelter
and contribute to program design or improvement.
5.2.3.2.3. Recovery care and related residential programs. Efforts
to connect program participants to community resources that offer
recovery care and related residential programs, including transportation
to those services.
5.2.3.2.4. Operations. Efforts related to maintenance (including
minor or routine repairs), rent, security, fuel, equipment, insurance,
utilities, food, furnishings, and supplies necessary for the operation of the
Emergency Shelter.
5.2.3.2.5. Grant Activities. Efforts focused on administering a
specific grant or funding source may improve effective operations, as well
as effective program implementation. Such efforts include planning and
executing program activities, such as (i) general program or grant
management, oversight, coordination, monitoring, and evaluation; (ii)
salaries, wages, and related costs related to preparing program budgets;
developing systems for ensuring compliance with grant requirements;
developing interagency agreements; and preparing reports and other
required documents or activities; (iii) accounting or other services; and
(iv) other reasonable and necessary goods and services required to
implement the grant program, such as evaluating program results against
stated objectives, occupancy costs, and training on program requirements.
5.2.3.3. Systems Improvement. Systems improvement activities generally refer to
collaborative and strategic processes that identify complex problems, develop
community-driven solutions, and implement improvements. “Systems
Improvement” includes the following eligible activities:
5.2.3.3.1. Data Collection, Management, Analysis, And System
Integration includes efforts related to collecting, managing, and
analyzing data and/or integrating data systems to advance communities’
homelessness efforts. Proposals may be related to the Homeless
Management Information System (HMIS), an HMIS comparable
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Exhibit A
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CMS #185361
database, and/or other coordinated activities that use data to strengthen
communities’ understanding of and response to homelessness.
5.2.3.3.2. Coordination includes coordination across communities,
regions, and/or the state at-large, including but not limited to case
conferencing, coordinated entry systems, capacity-building and
infrastructure, cross-sector partnerships, and other strategic activities to
advance a community’s/region’s homelessness efforts.
5.2.3.3.3. Resource Utilization Acceleration relates to enhancing the
utilization of currently available resources, increasing the speed of
connection to resources for eligible households, or otherwise ensuring that
homelessness response systems connect households to resources as
efficiently and effectively as possible.
5.3. Matching Funds. Grantee shall provide the funds identified as “Matching Funds” in
§5.2.1, above, unless otherwise approved in writing by DOH. Matching Funds may only be
used for the eligible costs described in §5.2.3 of this Exhibit A.
5.4. Project Budget Line Item Adjustment.
5.4.1. If the table in §5.2.2 contains more than one budget line item, Grantee shall have
authority to adjust individual budget line item amounts, without approval of the State,
up to an aggregate of 10% of such line item from which the funds are moved. Such
authority shall not include administrative line items (such as project delivery or
administrative costs). Grantee shall send written notification of allowed adjustments to
the State within 30 days of such adjustment.
5.4.2. Changes to individual budget lines amounts in §5.2.2 in excess of 10% shall require
written approval of the DOLA Controller. Grantee shall submit a written request for
changes pursuant to this Section to the State. Such request shall include the amount of
such request, the reason for the request and any necessary documentation. If the State
approves such request, the State shall unilaterally execute an Option Letter accepting
such request pursuant to §16.I.i of the main Agreement.
6. PAYMENTS TO GRANTEE
Payments to Grantee shall be made in accordance with the provisions of §5 of the main body
of the Agreement, and §6 of this Exhibit A.
6.1. Payment Schedule. Grantee shall submit all payment requests in a timely manner to DOH.
Unless otherwise agreed to by DOH, Grantee shall submit payment requests once per month,
on or before the 20th of each month. DOH may request the Grantee to submit payment
requests for the months of May and June earlier than the 20th (to the extent possible) in order
to complete closeout of the state fiscal year in a timely manner. Eligible expenses incurred
by Grantee during any calendar month shall be included in the following month’s pay
request. DOH shall review the pay request and, if approved, shall submit the pay request to
DOLA accounting for its review, approval and payment. Payments may be withheld, at
DOH’s reasonable discretion, pending submission by Grantee and approval by DOH of any
reports or completion by Grantee of any administrative requirements set forth in the main
Grant Agreement or this Exhibit A.
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Exhibit A
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CMS #185361
Payment Amount
All
payments
100% of
Payment
Request
Paid upon DOLA’s receipt of actual expense
documentation and written requests from the
Grantee for reimbursement of eligible approved
Project costs.
Total $2,743,690
6.2. Any excess Grant Funds shall be returned to DOLA via deobligation letter from Grantee
within 60 days prior to the expiration of the Grant Agreement.
6.3. Pay Request Process. Payment requests shall be submitted to DOH Key Personnel via
instructed processes. Each request shall include all required/appropriate information and
documentation necessary, per guidance provided by DOH, in order for DOH to verify
eligibility of expenses.
6.4. Remittance Address. If mailed, payments shall be remitted to the following address unless
changed in accordance with §14 of the main body of the Agreement:
West Mountain Regional Health Alliance
PO Box 1909. Glenwood Springs, CO 81602
6.5. Interest. If advance payments are authorized, Grantee or Subgrantee may keep interest
earned from Grant Funds up to $500 per year for administrative expenses. All interest earned
in excess of $500 shall be remitted to DOLA.
7. ADMINISTRATIVE REQUIREMENTS – STATE
Grantee shall administer Grant Funds in accordance with the requirements of this Agreement,
Division of Housing (DOH) Guidelines, and this Exhibit A.
7.1. Accounting. Grantee shall maintain segregated accounts of Grant Funds and Other Funds
associated with the Project and make those records available to the State upon request. All
receipts and expenditures associated with the Project shall be documented in a detailed and
specific manner, in accordance with the Project Budget in §5.2 of this Exhibit A above.
7.2. Audit Report. If an audit is performed on Grantee’s records for any fiscal year covering a
portion of the term of this Agreement or any other grants/contracts with DOLA, Grantee
shall submit a copy of the final audit report, including a report in accordance with the Single
Audit Act and 2 CFR 200.500 et seq., to:
Department of Local Affairs
Accounting & Financial Services
1313 Sherman Street, Room 323
Denver, CO 80203
Or email to: dola.audit@state.co.us and
libby.colon@state.co.us
7.3. Reporting. In addition to any reporting required pursuant to the terms of the main
Agreement, Grantee shall submit to DOLA the reports listed below in a format acceptable to
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Exhibit A
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CMS #185361
the State. If such reports are not submitted in a timely manner, the State may withhold
payments to Grantee pursuant to §6.1 of this Exhibit A.
7.3.1. Quarterly Performance Reports. Within 20 calendar days after the end of each
quarter, Grantee shall submit a quarterly performance report. The quarterly
performance report shall include reporting on the expected project deliverables as
approved by DOH.
7.3.2. Annual Report. Within 30 calendar days after the first twelve months of the grant
period and annually thereafter, Grantee shall submit an annual report. In the event that
the grant term is shorter or longer than twelve months, Grantee shall use the reporting
deadlines provided by the DOH Key Personnel. The annual report shall be completed
using the reporting template which DOH shall provide and shall include reporting on
the expected deliverables as described in §3 and §1.4.9 (Homeless Management
Information System) of this Exhibit A. DOH may make changes to the reporting
template at any time during the grant period; if such changes are made, DOH shall
communicate these changes to Grantee in a timely manner.
7.4. Monitoring. The State shall monitor this Agreement in accordance with its Risk-Based
Monitoring Policy and §7B and §C of the main body of the Agreement. Final evaluation of
the Project will be accomplished when DOLA approves the Project Completion Report.
7.4.1. DOH at its discretion may monitor files, policies, or other program documentation
either on site or through a request of documents.
THE REST OF THIS PAGE INTENTIONALLY LEFT BLANK
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Exhibit B Page 1 of 3 Version 6.01.2023
EXHIBIT B, SAMPLE OPTION LETTER
SAMPLE OPTION LETTER
State Agency Department of Local Affairs,
for the benefit of the Division of Housing
Grantee
[Grantee’s full legal name.]
Encumbrance Number
H4HRG00000
Option Letter Number
(1, 2, 3, etc.)
(Current) Agreement Maximum Amount
$000,000.00
(New) Agreement Maximum Amount
$000,000.00
(Current) Initial Agreement Expiration Date
Month, Day, Year
(New) Initial Agreement Expiration
Date
[Month, Day, Year]
Existing CMS Number(s)
000000, 000000, 000000
(New) CMS Number (This Option Letter)
000000
Effective Date
The date this Option Letter is signed by the State Controller.
1. OPTIONS: (Select all that are applicable.) In accordance with §18K of the Original Agreement
referenced above, as amended, the State hereby exercises its option to modify the following:
☐ A. Initial Agreement Expiration Date.
☐ B. Agreement Maximum Amount.
☐ C. Project Budget.
☐ D. Payment Schedule.
☐ E. Milestones.
☐ F. Service Area.
☐ G. Responsible Administrator.
☐ H. Remittance Address.
2. REQUIRED PROVISIONS:
1. For use with Option 1(A): The Initial Agreement Expiration Date, shown on the Cover Page
of the Agreement, as amended, is hereby deleted and replaced with the (New) Initial Agreement
Expiration Date shown in the table above.
2. For use with Options 1(B): The Agreement Maximum Amount shown on the Cover Page of the
Agreement referenced above, as amended, is hereby deleted and replaced with the (New)
Agreement Maximum Amount shown in the table above.
3. For use with Option 1(C): The Project Budget in §5.2 of the Statement of Work (Exhibit A),
as amended, is deleted and replaced with the following:
5.2. Project Budget.
5.2.1. Sources
Source Amount
[Source] $x.xx
Total $x.xx
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Exhibit B Page 2 of 3 Version 6.01.2023
5.2.2. Uses/Project Activities
Use/Project Activity Amount
[Use] $x.xx
Total $x.xx
5.2.3. Eligible Uses of DOLA Grant Funds
Eligible Activity Amount
[Eligible Use] $x.xx
Total $x.xx
5.2.4 Pre-Agreement Costs. [Reserved].
4. For use with Option 1(D): The Payment Schedule in §6.1 of the Statement of Work (Exhibit
A), as amended, is deleted and replaced with the following:
6.1 Payment Schedule. Grantee shall disburse Grant Funds received from the State within
fifteen days of receipt. Excess funds shall be returned to DOLA.
Payment Amoun
t
Interim
Payment(s
)
$x.xx Paid upon DOLA’s receipt and approval of a written request for
payment and expense documentation of eligible costs.
Final
Payment
$x.xx Paid upon DOLA’s receipt and approval of a written request for
payment, expense documentation of eligible costs, Beneficiary
data, and all required reports.
Total $x.xx
5. For use with Option 1(E): The Milestones in §3.3 of Exhibit A, as amended, is deleted and
replaced with the following:
3.3. Performance Measures. Grantee shall comply with the following Milestones
and Target Dates:
Milestone: Target Date
[Milestone] [Date]
[Milestone] [Date]
[Milestone] [Date]
6. For use with Option 1(F): The Service Area in §3.2 of Exhibit A, as amended, is deleted and
replaced with the following:
3.2. Service Area. The performance of Services for this Agreement shall be located
in [Area], State of Colorado.
7. For use with Option 1(G): The Responsible Administrator in §4.1 of Exhibit A, as amended,
is deleted and replaced with the following:
4.1. Responsible Administrator. Grantee’s performance hereunder shall be under the
direct supervision of the individual identified below, an employee or agent of Grantee, who
is hereby designated as a key person and the Responsible Administrator of this Project:
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Exhibit B Page 3 of 3 Version 6.01.2023
[Name, Title]
[Entity Name]
[Address]
[City, State, Zip Code]
[e-mail address]
8. For use with Option 1(H): the Remittance Address in §6.2 of Exhibit A, as amended, is deleted
and replaced with the following:
6.2 Remittance Address. If mailed, payments shall be remitted to the following address
unless changed in accordance with §14 of the Agreement:
[Grantee Name]
[Street Address]
[City, State Zip
Code]
In accordance with §24-30-202, C.R.S., this Option is not valid until signed and dated below by the
State Controller or an authorized delegate.
STATE OF COLORADO
Jared S. Polis, Governor
Department of Local Affairs
Rick M. Garcia, Executive Director
By:
Rick M. Garcia, Executive Director
Date:
STATE CONTROLLER
Robert Jaros, CPA, MBA, JD
By:
DOLA Controller Delegate
Option Effective Date:
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Exhibit C Page 1 of 1 Version 6.01.2023
EXHIBIT C, BUDGET
1. BUDGET BY US TREASURY EXPENDITURE CATEGORY
1.1 Expenditure Categories identified in Exhibit C will determine what is reported on as outlined in
Exhibits D-G.
Project
Number
Project Title
US Treasury Expenditure Category
Number and Name
Budget
H4HRG23176 WMRHA_Valley
Alliance to End
Homelessness
EC 2.16, Long-Term Housing Security:
Services for Unhoused Persons
$2,743,690
Total
2. BUDGET BY FUNCTION
3. EXPENDITURE CATEGORY MODIFICATIONS
1.1 Increases or decreases in any Expenditure Category must be requested and approved by the State
Agency by using the SLFRF Expenditure Modification Form. This form can be found at:
https://osc.colorado.gov/american-rescue-plan-act (see SLFRF Grant Agreement Templates tab).
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Exhibit D Page 1 of 14 Version 6.01.2023
Exhibit D, Federal Provisions
1. APPLICABILITY OF PROVISIONS.
1.1. The Grant to which these Federal Provisions are attached has been funded, in whole or in part,
with an Award of Federal funds. In the event of a conflict between the provisions of these Federal
Provisions, the Special Provisions, the body of the Grant, or any attachments or exhibits
incorporated into and made a part of the Grant, the provisions of these Federal Provisions shall
control.
1.2. The State of Colorado is accountable to Treasury for oversight of their subrecipients, including
ensuring their subrecipients comply with the SLFRF statute, SLFRF Award Terms and
Conditions, Treasury’s Final Rule, and reporting requirements, as applicable.
1.3. Additionally, any subrecipient that issues a subaward to another entity (2nd tier subrecipient),
must hold the 2nd tier subrecipient accountable to these provisions and adhere to reporting
requirements.
1.4. These Federal Provisions are subject to the Award as defined in §2 of these Federal Provisions,
as may be revised pursuant to ongoing guidance from the relevant Federal or State of Colorado
agency or institutions of higher education.
2. DEFINITIONS.
2.1. For the purposes of these Federal Provisions, the following terms shall have the meanings
ascribed to them below.
2.1.1. “Award” means an award of Federal financial assistance, and the Grant setting forth the
terms and conditions of that financial assistance, that a non-Federal Entity receives or
administers.
2.1.2. “Entity” means:
2.1.2.1. a Non-Federal Entity;
2.1.2.2. a foreign public entity;
2.1.2.3. a foreign organization;
2.1.2.4. a non-profit organization;
2.1.2.5. a domestic for-profit organization (for 2 CFR parts 25 and 170 only);
2.1.2.6. a foreign non-profit organization (only for 2 CFR part 170) only);
2.1.2.7. a Federal agency, but only as a Subrecipient under an Award or Subaward to a
non-Federal entity (or 2 CFR 200.1); or
2.1.2.8. a foreign for-profit organization (for 2 CFR part 170 only).
2.1.3. “Executive” means an officer, managing partner or any other employee in a management
position.
2.1.4. “Expenditure Category (EC)” means the category of eligible uses as defined by the US
Department of Treasury in “Appendix 1 of the Compliance and Reporting Guidance,
State and Local Fiscal Recovery Funds” report available at www.treasury.gov.
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2.1.5. “Federal Awarding Agency” means a Federal agency providing a Federal Award to a
Recipient as described in 2 CFR 200.1
2.1.6. “Grant” means the Grant to which these Federal Provisions are attached.
2.1.7. “Grantee” means the party or parties identified as such in the Grant to which these Federal
Provisions are attached.
2.1.8. “Non-Federal Entity means a State, local government, Indian tribe, institution of higher
education, or nonprofit organization that carries out a Federal Award as a Recipient or a
Subrecipient.
2.1.9. “Nonprofit Organization” means any corporation, trust, association, cooperative, or other
organization, not including IHEs, that:
2.1.9.1. Is operated primarily for scientific, educational, service, charitable, or similar
purposes in the public interest;
2.1.9.2. Is not organized primarily for profit; and
2.1.9.3. Uses net proceeds to maintain, improve, or expand the operations of the
organization.
2.1.10. “OMB” means the Executive Office of the President, Office of Management and Budget.
2.1.11. “Pass-through Entity” means a non-Federal Entity that provides a Subaward to a
Subrecipient to carry out part of a Federal program.
2.1.12. “Prime Recipient” means the Colorado State agency or institution of higher education
identified as the Grantor in the Grant to which these Federal Provisions are attached.
2.1.13. “Subaward” means an award by a Prime Recipient to a Subrecipient funded in whole or
in part by a Federal Award. The terms and conditions of the Federal Award flow down
to the Subaward unless the terms and conditions of the Federal Award specifically
indicate otherwise in accordance with 2 CFR 200.101. The term does not include
payments to a Contractor or payments to an individual that is a beneficiary of a Federal
program.
2.1.14. “Subrecipient” or “Subgrantee” means a non-Federal Entity (or a Federal agency under
an Award or Subaward to a non-Federal Entity) receiving Federal funds through a Prime
Recipient to support the performance of the Federal project or program for which the
Federal funds were awarded. A Subrecipient is subject to the terms and conditions of the
Federal Award to the Prime Recipient, including program compliance requirements. The
term does not include an individual who is a beneficiary of a federal program.
2.1.15. “System for Award Management (SAM)” means the Federal repository into which an
Entity must enter the information required under the Transparency Act, which may be
found at http://www.sam.gov. “Total Compensation” means the cash and noncash dollar
value earned by an Executive during the Prime Recipient’s or Subrecipient’s preceding
fiscal year (see 48 CFR 52.204-10, as prescribed in 48 CFR 4.1403(a)) and includes the
following:
2.1.15.1. Salary and bonus;
2.1.15.2. Awards of stock, stock options, and stock appreciation rights, using the dollar
amount recognized for financial statement reporting purposes with respect to the
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fiscal year in accordance with the Statement of Financial Accounting Standards
No. 123 (Revised 2005) (FAS 123R), Shared Based Payments;
2.1.15.3. Earnings for services under non-equity incentive plans, not including group life,
health, hospitalization or medical reimbursement plans that do not discriminate in
favor of Executives and are available generally to all salaried employees;
2.1.15.4. Change in present value of defined benefit and actuarial pension plans;
2.1.15.5. Above-market earnings on deferred compensation which is not tax-qualified;
2.1.15.6. Other compensation, if the aggregate value of all such other compensation (e.g.,
severance, termination payments, value of life insurance paid on behalf of the
employee, perquisites or property) for the Executive exceeds $10,000.
2.1.16. “Transparency Act” means the Federal Funding Accountability and Transparency Act of
2006 (Public Law 109-282), as amended by §6202 of Public Law 110-252.
2.1.17. “Uniform Guidance” means the Office of Management and Budget Uniform
Administrative Requirements, Cost Principles, and Audit Requirements for Federal
Awards. The terms and conditions of the Uniform Guidance flow down to Awards to
Subrecipients unless the Uniform Guidance or the terms and conditions of the Federal
Award specifically indicate otherwise.
2.1.18. “Unique Entity ID Number” means the twelve-character alphanumeric ID assigned to an
entity by SAM.gov to uniquely identify a business entity. Information on UEIs can be
found at: sam.gov/content/duns-uei
3. COMPLIANCE.
3.1. Grantee shall comply with all applicable provisions of the Transparency Act and the
regulations issued pursuant thereto, all provisions of the Uniform Guidance, and all
applicable Federal Laws and regulations required by this Federal Award. Any revisions to
such provisions or regulations shall automatically become a part of these Federal Provisions,
without the necessity of either party executing any further instrument. The State of Colorado,
at its discretion, may provide written notification to Grantee of such revisions, but such notice
shall not be a condition precedent to the effectiveness of such revisions.
3.2. Per US Treasury Final Award requirements, grantee programs or services must not include
terms or conditions that undermine efforts to stop COVID-19 or discourage compliance with
recommendations and CDC guidelines.
4. SYSTEM FOR AWARD MANAGEMENT (SAM) AND UNIQUE ENTITY IDENTIFIER (UEI)
REQUIREMENTS.
4.1. SAM. Grantee shall maintain the currency of its information in SAM until the Grantee
submits the final financial report required under the Award or receives final payment,
whichever is later. Grantee shall review and update SAM information at least annually.
4.2. UEI. Grantee shall provide its UEI number to its Prime Recipient, and shall update Grantee’s
information in SAM at least annually.
5. TOTAL COMPENSATION.
5.1. Grantee shall include Total Compensation in SAM for each of its five most highly
compensated Executives for the preceding fiscal year if:
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5.1.1. The total Federal funding authorized to date under the Award is $30,000 or more; and
5.1.2. In the preceding fiscal year, Grantee received:
5.1.2.1. 80% or more of its annual gross revenues from Federal procurement Agreements
and Subcontractors and/or Federal financial assistance Awards or Subawards
subject to the Transparency Act; and
5.1.2.2. $30,000,000 or more in annual gross revenues from Federal procurement
Agreements and Subcontractors and/or Federal financial assistance Awards or
Subawards subject to the Transparency Act; and
5.1.2.3. 5.1.2.3 The public does not have access to information about the compensation of
such Executives through periodic reports filed under section 13(a) or 15(d) of the
Securities Exchange Act of 1934 (15 U.S.C. 78m(a), 78o(d) or § 6104 of the
Internal Revenue Code of 1986.
6. REPORTING.
6.1. If Grantee is a Subrecipient of the Award pursuant to the Transparency Act, Grantee shall
report data elements to SAM and to the Prime Recipient as required in this Exhibit. No direct
payment shall be made to Grantee for providing any reports required under these Federal
Provisions and the cost of producing such reports shall be included in the Grant price. The
reporting requirements in this Exhibit are based on guidance from the OMB, and as such are
subject to change at any time by OMB. Any such changes shall be automatically incorporated
into this Grant and shall become part of Grantee’s obligations under this Grant.
7. EFFECTIVE DATE AND DOLLAR THRESHOLD FOR FEDERAL REPORTING.
7.1. Reporting requirements in §8 below apply to new Awards as of October 1, 2010, if the initial
award is $30,000 or more. If the initial Award is below $30,000 but subsequent Award
modifications result in a total Award of $30,000 or more, the Award is subject to the reporting
requirements as of the date the Award exceeds $30,000. If the initial Award is $30,000 or
more, but funding is subsequently de-obligated such that the total award amount falls below
$30,000, the Award shall continue to be subject to the reporting requirements. If the total
award is below $30,000 no reporting required; if more than $30,000 and less than $50,000
then FFATA reporting is required; and, $50,000 and above SLFRF reporting is required.
7.2. The procurement standards in §9 below are applicable to new Awards made by Prime
Recipient as of December 26, 2015. The standards set forth in §11 below are applicable to
audits of fiscal years beginning on or after December 26, 2014.
8. SUBRECIPIENT REPORTING REQUIREMENTS.
8.1. Grantee shall report as set forth below.
8.1.1. Grantee shall use the SLFRF Subrecipient Quarterly Report Workbook as referenced in
Exhibit F to report to the State Agency within ten (10) days following each quarter ended
September, December, March and June. Additional information on specific requirements are
detailed in the SLFRF Subrecipient Quarterly Report Workbooks and "Compliance and
Reporting Guidance, State and Local Fiscal Recovery Funds" report available at
www.treasury.gov.
EC 1 – Public Health
All Public Health Projects
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a) Description of structure and objectives
b) Description of relation to COVID-19
c) Identification of impacted and/or disproportionately impacted communities
d) Capital Expenditures
i. Presence of capital expenditure in project
ii. Total projected capital expenditure
iii. Type of capital expenditure
iv. Written justification
v. Labor reporting
COVID-19 Interventions and Mental Health (1.4, 1.11, 1.12, 1.13)
a) Amount of total project used for evidence-based programs
b) Evaluation plan description
COVID-19 Small Business Economic Assistance (1.8)
a) Number of small businesses served
COVID-19 Assistance to Non-Profits (1.9)
a) Number of non-profits served
COVID-19 Aid to Travel, Tourism, and Hospitality or Other Impacted Industries (1.10)
a) Sector of employer
b) Purpose of funds
EC 2 – Negative Economic Impacts
All Negative Economic Impacts Projects
a) Description of project structure and objectives
b) Description of project’s response to COVID-19
c) Identification of impacted and/or disproportionately impacted communities
d) Amount of total project used for evidence-based programs and description of evaluation
plan (not required for 2.5, 2.8, 2.21-2.24, 2.27-2.29, 2.31, 2.34-2.36)
e) Number of workers enrolled in sectoral job training programs
f) Number of workers completing sectoral job training programs
g) Number of people participating in summer youth employment programs
h) Capital Expenditures
i. Presence of capital expenditure in project
ii. Total projected capital expenditure
iii. Type of capital expenditure
iv. Written justification
v. Labor reporting
Household Assistance (2.1-2.8)
a) Number of households served
b) Number of people or households receiving eviction prevention services (2.2 & 2.5 only)
(Federal guidance may change this requirement in July 2022)
c) Number of affordable housing units preserved or developed (2.2 & 2.5 only) (Federal
guidance may change this requirement in July 2022)
Healthy Childhood Environments (2.11-2.13)
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a) Number of children served by childcare and early learning (Federal guidance may change this
requirement in July 2022)
b) Number of families served by home visiting (Federal guidance may change this requirement in
July 2022)
Education Assistance (2.14, 2.24-2.27)
a) National Center for Education Statistics (“NCES”) School ID or NCES District ID
b) Number of students participating in evidence-based programs (Federal guidance may change
this requirement in July 2022)
Housing Support (2.15, 2.16, 2.18)
a) Number of people or households receiving eviction prevention services (Federal guidance
may change this requirement in July 2022)
b) Number of affordable housing units preserved or developed (Federal guidance may change this
requirement in July 2022)
Small Business Economic Assistance (2.29-2.33)
a) Number of small businesses served
Assistance to Non-Profits (2.34)
a) Number of non-profits served
Aid to Travel, Tourism, and Hospitality or Other Impacted Industries (2.35-2.36)
a) Sector of employer
b) Purpose of funds
c) If other than travel, tourism and hospitality (2.36) – description of hardship
EC 3 – Public Health – Negative Economic Impact: Public Sector Capacity
Payroll for Public Health and Safety Employees (EC 3.1)
a) Number of government FTEs responding to COVID-19
Rehiring Public Sector Staff (EC 3.2)
a) Number of FTEs rehired by governments
EC 4 – Premium Pay
All Premium Pay Projects
a) List of sectors designated as critical by the chief executive of the jurisdiction, if beyond
those listed in the final rule
b) Numbers of workers served
c) Employer sector for all subawards to third-party employers
d) Written narrative justification of how premium pay is responsive to essential work during
the public health emergency for non-exempt workers or those making over 150 percent of
the state/county’s average annual wage
e) Number of workers to be served with premium pay in K-12 schools
EC 5 – Infrastructure Projects
All Infrastructure Projects
a) Projected/actual construction start date (month/year)
b) Projected/actual initiation of operations date (month/year)
c) Location (for broadband, geospatial data of locations to be served)
d) Projects over $10 million
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i. Prevailing wage certification or detailed project employment and local impact
report
ii. Project labor agreement certification or project workforce continuity plan
iii. Prioritization of local hires
iv. Community benefit agreement description, if applicable
Water and sewer projects (EC 5.1-5.18)
a) National Pollutant Discharge Elimination System (NPDES) Permit Number (if
applicable; for projects aligned with the Clean Water State Revolving Fund)
b) Public Water System (PWS) ID number (if applicable; for projects aligned with the
Drinking Water State Revolving Fund)
c) Median Household Income of service area
d) Lowest Quintile Income of the service area
Broadband projects (EC 5.19-5.21)
a) Confirm that the project is designed to, upon completion, reliably meet or exceed
symmetrical 100 Mbps download and upload speeds.
i. If the project is not designed to reliably meet or exceed symmetrical 100 Mbps
download and upload speeds, explain why not, and
ii. Confirm that the project is designed to, upon completion, meet or exceed 100
Mbps download speed and between at least 20 Mbps and 100 Mbps upload
speed, and be scalable to a minimum of 100 Mbps download speed and 100
Mbps upload speed.
b) Additional programmatic data will be required for broadband projects and will be
defined in a subsequent version of the US Treasury Reporting Guidance, including, but
not limited to (Federal guidance may change this requirement in July 2022):
i. Number of households (broken out by households on Tribal lands and those
not on Tribal lands) that have gained increased access to broadband meeting
the minimum speed standards in areas that previously lacked access to service
of at least 25 Mbps download and 3 Mbps upload, with the number of
households with access to minimum speed standard of reliable 100 Mbps
symmetrical upload and download and number of households with access to
minimum speed standard of reliable 100 Mbps download and 20 Mbps upload
ii. Number of institutions and businesses (broken out by institutions on Tribal
lands and those not on Tribal lands) that have projected increased access to
broadband meeting the minimum speed standards in areas that previously
lacked access to service of at least 25 Mbps download and 3 Mbps upload, in
each of the following categories: business, small business, elementary school,
secondary school, higher education institution, library, healthcare facility, and
public safety organization, with the number of each type of institution with
access to the minimum speed standard of reliable 100 Mbps symmetrical
upload and download; and number of each type of institution with access to
the minimum speed standard of reliable 100 Mbps download and 20 Mbps
upload.
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iii. Narrative identifying speeds/pricing tiers to be offered, including the
speed/pricing of its affordability offering, technology to be deployed, miles of
fiber, cost per mile, cost per passing, number of households (broken out by
households on Tribal lands and those not on Tribal lands) projected to have
increased access to broadband meeting the minimum speed standards in areas
that previously lacked access to service of at least 25 Mbps download and 3
Mbps upload, number of households with access to minimum speed standard
of reliable 100 Mbps symmetrical upload and download, number of
households with access to minimum speed standard of reliable 100 Mbps
download and 20 Mbps upload, and number of institutions and businesses
(broken out by institutions on Tribal lands and those not on Tribal lands)
projected to have increased access to broadband meeting the minimum speed
standards in areas that previously lacked access to service of at least 25 Mbps
download and 3 Mbps upload, in each of the following categories: business,
small business, elementary school, secondary school, higher education
institution, library, healthcare facility, and public safety organization. Specify
the number of each type of institution with access to the minimum speed
standard of reliable 100 Mbps symmetrical upload and download; and the
number of each type of institution with access to the minimum speed standard
of reliable 100 Mbps download and 20 Mbps upload.
All Expenditure Categories
a) Program income earned and expended to cover eligible project costs
8.1.2. A Subrecipient shall report the following data elements to Prime Recipient no later than
five days after the end of the month following the month in which the Subaward was made.
8.1.2.1. Subrecipient UEI Number;
8.1.2.2. Subrecipient UEI Number if more than one electronic funds transfer (EFT)
account;
8.1.2.3. Subrecipient parent’s organization UEI Number;
8.1.2.4. Subrecipient’s address, including: Street Address, City, State, Country, Zip + 4,
and Congressional District;
8.1.2.5. Subrecipient’s top 5 most highly compensated Executives if the criteria in §4
above are met; and
8.1.2.6. Subrecipient’s Total Compensation of top 5 most highly compensated Executives
if the criteria in §4 above met.
8.1.3. To Prime Recipient. A Subrecipient shall report to its Prime Recipient, the following
data elements:
8.1.3.1. Subrecipient’s UEI Number as registered in SAM.
8.1.3.2. Primary Place of Performance Information, including: Street Address, City, State,
Country, Zip code + 4, and Congressional District.
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8.1.3.3. Narrative identifying methodology for serving disadvantaged communities. See
the "Project Demographic Distribution" section in the "Compliance and Reporting
Guidance, State and Local Fiscal Recovery Funds" report available at
www.treasury.gov. This requirement is applicable to all projects in Expenditure
Categories 1 and 2.
8.1.3.4. Narrative identifying funds allocated towards evidenced-based interventions and
the evidence base. See the “Use of Evidence” section in the “Compliance and
Reporting Guidance, State and Local Fiscal Recovery Funds” report available at
www.treasury.gov. See section 8.1.1 for relevant Expenditure Categories.
8.1.3.5. Narrative describing the structure and objectives of the assistance program and in
what manner the aid responds to the public health and negative economic impacts
of COVID-19. This requirement is applicable to Expenditure Categories 1 and 2.
For aid to travel, tourism, and hospitality or other impacted industries (EC 2.11-
2.12), also provide the sector of employer, purpose of funds, and if not travel,
tourism and hospitality a description of the pandemic impact on the industry.
8.1.3.6. Narrative identifying the sector served and designated as critical to the health and
well-being of residents by the chief executive of the jurisdiction and the number
of workers expected to be served. For groups of workers (e.g., an operating unit,
a classification of worker, etc.) or, to the extent applicable, individual workers,
other than those where the eligible worker receiving premium pay is earning (with
the premium pay included) below 150 percent of their residing state or county’s
average annual wage for all occupations, as defined by the Bureau of Labor
Statistics Occupational Employement and Wage Statistics, whichever is higher,
OR the eligible worker reciving premium pay is not exempt from the Fair Labor
Standards Act overtime provisions, include justification of how the premium pay
or grant is responsive to workers performing essential work during the public
health emergency. This could include a description of the essential workers'
duties, health or financial risks faced due to COVID-19 but should not include
personally identifiable information. This requirement applies to EC 4.1, and 4.2.
8.1.3.7. For infrastructure projects (EC 5) or capital expenditures in any expenditure
category, narrative identifying the projected construction start date (month/year),
projected initiation of operations date (month/year), and location (for broadband,
geospatial location data).
8.1.3.7.1. For projects over $10 million:
8.1.3.7.1.1. Certification that all laborers and mechanics employed by
Contractors and Subcontractors in the performance of such project
are paid wages at rates not less than those prevailing, as determined
by the U.S. Secretary of Labor in accordance with subchapter IV of
chapter 31 of title 40, United States Code (commonly known as the
"Davis-Bacon Act"), for the corresponding classes of laborers and
mechanics employed on projects of a character similar to the
Agreement work in the civil subdivision of the State (or the District
of Columbia) in which the work is to be performed, or by the
appropriate State entity pursuant to a corollary State prevailing-
wage-in-construction law (commonly known as "baby Davis-Bacon
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Acts"). If such certification is not provided, a recipient must provide
a project employment and local impact report detailing (1) the
number of employees of Contractors and sub-contractors working
on the project; (2) the number of employees on the project hired
directly and hired through a third party; (3) the wages and benefits
of workers on the project by classification; and (4) whether those
wages are at rates less than those prevailing. Recipients must
maintain sufficient records to substantiate this information upon
request.
8.1.3.7.1.2. A Subrecipient may provide a certification that a project includes a
project labor agreement, meaning a pre-hire collective bargaining
agreement consistent with section 8(f) of the National Labor
Relations Act (29 U.S.C. 158(f)). If the recipient does not provide
such certification, the recipient must provide a project workforce
continuity plan, detailing: (1) how the Subrecipient will ensure the
project has ready access to a sufficient supply of appropriately
skilled and unskilled labor to ensure high-quality construction
throughout the life of the project; (2) how the Subrecipient will
minimize risks of labor disputes and disruptions that would
jeopardize timeliness and cost-effectiveness of the project; and (3)
how the Subrecipient will provide a safe and healthy workplace that
avoids delays and costs associated with workplace illnesses,
injuries, and fatalities; (4) whether workers on the project will
receive wages and benefits that will secure an appropriately skilled
workforce in the context of the local or regional labor market; and
(5) whether the project has completed a project labor agreement.
8.1.3.7.1.3. Whether the project prioritizes local hires.
8.1.3.7.1.4. Whether the project has a Community Benefit Agreement, with a
description of any such agreement.
8.1.4. Subrecipient also agrees to comply with any reporting requirements established by the US
Treasury, Governor’s Office and Office of the State Controller. The State of Colorado may
need additional reporting requirements after this agreement is executed. If there are additional
reporting requirements, the State will provide notice of such additional reporting requirements
via Exhibit G – SLFRF Reporting Modification Form.
9. PROCUREMENT STANDARDS.
9.1. Procurement Procedures. A Subrecipient shall use its own documented procurement
procedures which reflect applicable State, local, and Tribal laws and applicable regulations,
provided that the procurements conform to applicable Federal law and the standards
identified in the Uniform Guidance, including without limitation, 2 CFR 200.318 through
200.327 thereof.
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9.2. Domestic preference for procurements (2 CFR 200.322). As appropriate and to the extent
consistent with law, the non-Federal entity should, to the greatest extent practicable under a
Federal award, provide a preference for the purchase, acquisition, or use of goods, products,
or materials produced in the United States (including but not limited to iron, aluminum, steel,
cement, and other manufactured products). The requirements of this section must be included
in all subawards including all Agreements and purchase orders for work or products under
this award.
9.3. Procurement of Recovered Materials. If a Subrecipient is a State Agency or an agency of a
political subdivision of the State, its Contractors must comply with section 6002 of the Solid
Waste Disposal Act, as amended by the Resource Conservation and Recovery Act. The
requirements of Section 6002 include procuring only items designated in guidelines of the
Environmental Protection Agency (EPA) at 40 CFR part 247, that contain the highest
percentage of recovered materials practicable, consistent with maintaining a satisfactory level
of competition, where the purchase price of the item exceeds $10,000 or the value of the
quantity acquired during the preceding fiscal year exceeded $10,000; procuring solid waste
management services in a manner that maximizes energy and resource recovery; and
establishing an affirmative procurement program for procurement of recovered materials
identified in the EPA guidelines.
10. ACCESS TO RECORDS.
10.1. A Subrecipient shall permit Prime Recipient and its auditors to have access to Subrecipient’s
records and financial statements as necessary for Recipient to meet the requirements of 2
CFR 200.332 (Requirements for pass-through entities), 2 CFR 200.300 (Statutory and
national policy requirements) through 2 CFR 200.309 (Period of performance), and Subpart
F-Audit Requirements of the Uniform Guidance.
11. SINGLE AUDIT REQUIREMENTS.
11.1. If a Subrecipient expends $750,000 or more in Federal Awards during the Subrecipient’s
fiscal year, the Subrecipient shall procure or arrange for a single or program-specific audit
conducted for that year in accordance with the provisions of Subpart F-Audit Requirements
of the Uniform Guidance, issued pursuant to the Single Audit Act Amendments of 1996, (31
U.S.C. 7501-7507). 2 CFR 200.501.
11.1.1. Election. A Subrecipient shall have a single audit conducted in accordance with Uniform
Guidance 2 CFR 200.514 (Scope of audit), except when it elects to have a program-
specific audit conducted in accordance with 2 CFR 200.507 (Program-specific audits).
The Subrecipient may elect to have a program-specific audit if Subrecipient expends
Federal Awards under only one Federal program (excluding research and development)
and the Federal program’s statutes, regulations, or the terms and conditions of the Federal
award do not require a financial statement audit of Prime Recipient. A program-specific
audit may not be elected for research and development unless all of the Federal Awards
expended were received from Recipient and Recipient approves in advance a program-
specific audit.
11.1.2. Exemption. If a Subrecipient expends less than $750,000 in Federal Awards during its
fiscal year, the Subrecipient shall be exempt from Federal audit requirements for that
year, except as noted in 2 CFR 200.503 (Relation to other audit requirements), but records
shall be available for review or audit by appropriate officials of the Federal agency, the
State, and the Government Accountability Office.
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11.1.3. Subrecipient Compliance Responsibility. A Subrecipient shall procure or otherwise
arrange for the audit required by Subpart F of the Uniform Guidance and ensure it is
properly performed and submitted when due in accordance with the Uniform Guidance.
Subrecipient shall prepare appropriate financial statements, including the schedule of
expenditures of Federal awards in accordance with 2 CFR 200.510 (Financial statements)
and provide the auditor with access to personnel, accounts, books, records, supporting
documentation, and other information as needed for the auditor to perform the audit
required by Uniform Guidance Subpart F-Audit Requirements.
12. GRANT PROVISIONS FOR SUBRECIPIENT AGREEMENTS.
12.1. In addition to other provisions required by the Federal Awarding Agency or the Prime
Recipient, Grantees that are Subrecipients shall comply with the following provisions.
Subrecipients shall include all of the following applicable provisions in all Subcontractors
entered into by it pursuant to this Grant.
12.1.1. [Applicable to federally assisted construction Agreements.] Equal Employment
Opportunity. Except as otherwise provided under 41 CFR Part 60, all Agreements that
meet the definition of “federally assisted construction Agreement” in 41 CFR Part 60-1.3
shall include the equal opportunity clause provided under 41 CFR 60-1.4(b), in
accordance with Executive Order 11246, “Equal Employment Opportunity” (30 FR
12319, 12935, 3 CFR Part, 1964-1965 Comp., p. 339), as amended by Executive Order
11375, “Amending Executive Order 11246 Relating to Equal Employment Opportunity,”
and implementing regulations at 41 CFR part 60, Office of Federal Agreement
Compliance Programs, Equal Employment Opportunity, Department of Labor.
12.1.2. [Applicable to on-site employees working on government-funded construction, alteration
and repair projects.] Davis-Bacon Act. Davis-Bacon Act, as amended (40 U.S.C. 3141-
3148).
12.1.3. Rights to Inventions Made Under a grant or agreement. If the Federal Award meets the
definition of “funding agreement” under 37 CFR 401.2 (a) and the Prime Recipient or
Subrecipient wishes to enter into an Agreement with a small business firm or nonprofit
organization regarding the substitution of parties, assignment or performance of
experimental, developmental, or research work under that “funding agreement,” the
Prime Recipient or Subrecipient must comply with the requirements of 37 CFR Part 401,
“Rights to Inventions Made by Nonprofit Organizations and Small Business Firms Under
Government Grants, Agreements and Cooperative Agreements,” and any implementing
regulations issued by the Federal Awarding Agency.
12.1.4. Clean Air Act (42 U.S.C. 7401-7671q.) and the Federal Water Pollution Control Act (33
U.S.C. 1251-1387), as amended. Agreements and subgrants of amounts in excess of
$150,000 must contain a provision that requires the non-Federal awardees to agree to
comply with all applicable standards, orders or regulations issued pursuant to the Clean
Air Act (42 U.S.C. 7401-7671q) and the Federal Water Pollution Control Act as amended
(33 U.S.C. 1251-1387). Violations must be reported to the Federal Awarding Agency and
the Regional Office of the Environmental Protection Agency (EPA).
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12.1.5. Debarment and Suspension (Executive Orders 12549 and 12689). A Agreement award
(see 2 CFR 180.220) must not be made to parties listed on the government wide
exclusions in SAM, in accordance with the OMB guidelines at 2 CFR 180 that implement
Executive Orders 12549 (3 CFR part 1986 Comp., p. 189) and 12689 (3 CFR part 1989
Comp., p. 235), “Debarment and Suspension.” SAM Exclusions contains the names of
parties debarred, suspended, or otherwise excluded by agencies, as well as parties
declared ineligible under statutory or regulatory authority other than Executive Order
12549.
12.1.6. Byrd Anti-Lobbying Amendment (31 U.S.C. 1352). Contractors that apply or bid for an
award exceeding $100,000 must file the required certification. Each tier certifies to the
tier above that it will not and has not used Federal appropriated funds to pay any person
or organization for influencing or attempting to influence an officer or employee of any
agency, a member of Congress, officer or employee of Congress, or an employee of a
member of Congress in connection with obtaining any Federal Agreement, grant or any
other award covered by 31 U.S.C. 1352. Each tier must also disclose any lobbying with
non-Federal funds that takes place in connection with obtaining any Federal award. Such
disclosures are forwarded from tier to tier up to the non-Federal award.
12.1.7. Never Agreement with the enemy (2 CFR 200.215). Federal awarding agencies and
recipients are subject to the regulations implementing “Never Agreement with the
enemy” in 2 CFR part 183. The regulations in 2 CFR part 183 affect covered Agreements,
grants and cooperative agreements that are expected to exceed $50,000 within the period
of performance, are performed outside the United States and its territories, and are in
support of a contingency operation in which members of the Armed Forces are actively
engaged in hostilities.
12.1.8. Prohibition on certain telecommunications and video surveillance services or equipment
(2 CFR 200.216). Grantee is prohibited from obligating or expending loan or grant funds
on certain telecommunications and video surveillance services or equipment pursuant to
2 CFR 200.216.
12.1.9. Title VI of the Civil Rights Act. The Subgrantee, Contractor, Subcontractor, transferee,
and assignee shall comply with Title VI of the Civil Rights Act of 1964, which prohibits
recipients of federal financial assistance from excluding from a program or activity,
denying benefits of, or otherwise discriminating against a person on the basis of race,
color, or national origin (42 U.S.C. § 2000d et seq.), as implemented by the Department
of Treasury’s Title VI regulations, 31 CFR Part 22, which are herein incorporated by
reference and made a part of this Agreement (or agreement). Title VI also includes
protection to persons with “Limited English Proficiency” in any program or activity
receiving federal financial assistance, 42 U.S. C. § 2000d et seq., as implemented by the
Department of the Treasury’s Title VI regulations, 31 CRF Part 22, and herein
incorporated by reference and made part of this Agreement or agreement.
13. CERTIFICATIONS.
13.1. Subrecipient Certification. Subrecipient shall sign a “State of Colorado Agreement with
Recipient of Federal Recovery Funds” Certification Form in Exhibit E and submit to State
Agency with signed grant agreement.
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13.2. Unless prohibited by Federal statutes or regulations, Prime Recipient may require
Subrecipient to submit certifications and representations required by Federal statutes or
regulations on an annual basis. 2 CFR 200.208. Submission may be required more frequently
if Subrecipient fails to meet a requirement of the Federal award. Subrecipient shall certify in
writing to the State at the end of the Award that the project or activity was completed or the
level of effort was expended. 2 CFR 200.201(3). If the required level of activity or effort
was not carried out, the amount of the Award must be adjusted.
14. EXEMPTIONS.
14.1. These Federal Provisions do not apply to an individual who receives an Award as a natural
person, unrelated to any business or non-profit organization he or she may own or operate in
his or her name.
14.2. A Grantee with gross income from all sources of less than $300,000 in the previous tax year
is exempt from the requirements to report Subawards and the Total Compensation of its most
highly compensated Executives.
EVENT OF DEFAULT AND TERMINATION.
14.3. Failure to comply with these Federal Provisions shall constitute an event of default under the
Grant and the State of Colorado may terminate the Grant upon 30 days prior written notice if
the default remains uncured five calendar days following the termination of the 30-day notice
period. This remedy will be in addition to any other remedy available to the State of Colorado
under the Grant, at law or in equity.
14.4. Termination (2 CFR 200.340). The Federal Award may be terminated in whole or in part as
follows:
14.4.1. By the Federal Awarding Agency or Pass-through Entity, if a Non-Federal Entity fails to
comply with the terms and conditions of a Federal Award;
14.4.2. By the Federal awarding agency or Pass-through Entity, to the greatest extent authorized
by law, if an award no longer effectuates the program goals or agency priorities;
14.4.3. By the Federal awarding agency or Pass-through Entity with the consent of the Non-
Federal Entity, in which case the two parties must agree upon the termination conditions,
including the effective date and, in the case of partial termination, the portion to be
terminated;
14.4.4. By the Non-Federal Entity upon sending to the Federal Awarding Agency or Pass-
through Entity written notification setting forth the reasons for such termination, the
effective date, and, in the case of partial termination, the portion to be terminated.
However, if the Federal Awarding Agency or Pass-through Entity determines in the case
of partial termination that the reduced or modified portion of the Federal Award or
Subaward will not accomplish the purposes for which the Federal Award was made, the
Federal Awarding Agency or Pass-through Entity may terminate the Federal Award in its
entirety; or
14.4.5. By the Federal Awarding Agency or Pass-through Entity pursuant to termination
provisions included in the Federal Award.
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Exhibit E, AGREEMENT WITH SUBRECIPIENT OF FEDERAL RECOVERY
FUNDS
Section 602(b) of the Social Security Act (the Act), as added by section 9901 of the American
Rescue Plan Act (ARPA), Pub. L. No. 117-2 (March 11, 2021), authorizes the Department of
the Treasury (Treasury) to make payments to certain Subrecipients from the Coronavirus State
Fiscal Recovery Fund. The State of Colorado has signed and certified a separate agreement with
Treasury as a condition of receiving such payments from the Treasury. This agreement is
between your organization and the State and your organization is signing and certifying the
same terms and conditions included in the State’s separate agreement with Treasury. Your
organization is referred to as a Subrecipient.
As a condition of your organization receiving federal recovery funds from the State, the
authorized representative below hereby (i) certifies that your organization will carry out the
activities listed in section 602(c) of the Act and (ii) agrees to the terms attached hereto. Your
organization also agrees to use the federal recovery funds as specified in bills passed by the
General Assembly and signed by the Governor.
Under penalty of perjury, the undersigned official certifies that the authorized representative
has read and understood the organization’s obligations in the Assurances of Compliance and
Civil Rights Requirements, that any information submitted in conjunction with this assurances
document is accurate and complete, and that the organization is in compliance with the
nondiscrimination requirements.
Subrecipient Name __________________________________
Authorized Representative: _______________________________
Title: __________________________________
Signature: ___________________________
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Cristina Gair
West Mountain Regional Health Alliance
Executive Director
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AGREEMENT WITH SUBRECIPIENT OF FEDERAL RECOVERY FUNDS
TERMS AND CONDITIONS
Use of Funds.
a. Subrecipient understands and agrees that the funds disbursed under this award may only
be used in compliance with section 602(c) of the Social Security Act (the Act) and
Treasury’s regulations implementing that section and guidance.
b. Subrecipient will determine prior to engaging in any project using this assistance that
it has the institutional, managerial, and financial capability to ensure proper planning,
management, and completion of such project.
2. Period of Performance. The period of performance for this subaward is shown on page one of
this Agreement. Subrecipient may use funds to cover eligible costs incurred, as set forth in
Treasury’s implementing regulations, during this period of performance.
Reporting. Subrecipient agrees to comply with any reporting obligations established by
Treasury as they relate to this award. Subrecipient also agrees to comply with any reporting
requirements established by the Governor’s Office and Office of the State Controller. The State
will provide notice of such additional reporting requirements via Exhibit G – Reporting
Modification Form.
Maintenance of and Access to Records
a. Subrecipient shall maintain records and financial documents sufficient to evidence
compliance with section 602(c), Treasury’s regulations implementing that section,
and guidance issued by Treasury regarding the foregoing.
b. The Treasury Office of Inspector General and the Government Accountability Office,
or their authorized representatives, shall have the right of access to records (electronic
and otherwise) of Subrecipient in order to conduct audits or other investigations.
c. Records shall be maintained by Subrecipient for a period of five (5) years after all funds
have been expended or returned to Treasury, whichever is later.
Pre-award Costs. Pre-award costs, as defined in 2 C.F.R. § 200.458, may not be paid with
funding from this award.
Administrative Costs. Subrecipient may use funds provided under this award to cover both
direct and indirect costs. Subrecipient shall follow guidance on administrative costs issued
by the Governor’s Office and Office of the State Controller.
Cost Sharing. Cost sharing or matching funds are not required to be provided by Subrecipient.
Conflicts of Interest. The State of Colorado understands and agrees it must maintain a conflict
of interest policy consistent with 2 C.F.R. § 200.318(c) and that such conflict of interest policy
is applicable to each activity funded under this award. Subrecipient and Contractors must
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disclose in writing to the Office of the State Controller or the pass-through entity, as appropriate,
any potential conflict of interest affecting the awarded funds in accordance with 2 C.F.R. §
200.112. The Office of the State Controller shall disclose such conflict to Treasury.
Compliance with Applicable Law and Regulations.
a. Subrecipient agrees to comply with the requirements of section 602 of the Act,
regulations adopted by Treasury pursuant to section 602(f) of the Act, and guidance
issued by Treasury regarding the foregoing. Subrecipient also agrees to comply with all
other applicable federal statutes, regulations, and executive orders, and Subrecipient
shall provide for such compliance by other parties in any agreements it enters into with
other parties relating to this award.
b. Federal regulations applicable to this award include, without limitation, the following:
i. Uniform Administrative Requirements, Cost Principles, and Audit
Requirements for Federal Awards, 2 C.F.R. Part 200, other than such provisions
as Treasury may determine are inapplicable to this Award and subject to such
exceptions as may be otherwise provided by Treasury. Subpart F – Audit
Requirements of the Uniform Guidance, implementing the Single Audit Act,
shall apply to this award.
ii. Universal Identifier and System for Award Management (SAM), 2 C.F.R. Part
25, pursuant to which the award term set forth in Appendix A to 2 C.F.R. Part
25 is hereby incorporated by reference.
iii. Reporting Subaward and Executive Compensation Information, 2 C.F.R. Part
170, pursuant to which the award term set forth in Appendix A to 2 C.F.R. Part
170 is hereby incorporated by reference.
iv. OMB Guidelines to Agencies on Government wide Debarment and Suspension
(Nonprocurement), 2 C.F.R. Part 180, including the requirement to include a
term or condition in all lower tier covered transactions (Agreements and
Subcontractors described in 2 C.F.R. Part 180, subpart B) that the award is
subject to 2 C.F.R. Part 180 and Treasury’s implementing regulation at 31
C.F.R. Part 19.
v. Subrecipient Integrity and Performance Matters, pursuant to which the award
term set forth in 2 C.F.R. Part 200, Appendix XII to Part 200 is hereby
incorporated by reference.
vi. Government wide Requirements for Drug-Free Workplace, 31 C.F.R. Part 20.
vii. New Restrictions on Lobbying, 31 C.F.R. Part 21.
viii. Uniform Relocation Assistance and Real Property Acquisitions Act of 1970 (42
U.S.C. §§ 4601-4655) and implementing regulations.
ix. Generally applicable federal environmental laws and regulations.
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c. Statutes and regulations prohibiting discrimination applicable to this award include,
without limitation, the following:
i. Title VI of the Civil Rights Act of 1964 (42 U.S.C. §§ 2000d et seq.) and
Treasury’s implementing regulations at 31 C.F.R. Part 22, which prohibit
discrimination on the basis of race, color, or national origin under programs or
activities receiving federal financial assistance;
ii. The Fair Housing Act, Title VIII of the Civil Rights Act of 1968 (42 U.S.C.
§§ 3601 et seq.), which prohibits discrimination in housing on the basis of
race, color, religion, national origin, sex, familial status, or disability;
iii. Section 504 of the Rehabilitation Act of 1973, as amended (29 U.S.C. § 794),
which prohibits discrimination on the basis of disability under any program or
activity receiving federal financial assistance;
iv. The Age Discrimination Act of 1975, as amended (42 U.S.C. §§ 6101 et seq.),
and Treasury’s implementing regulations at 31 C.F.R. Part 23, which prohibit
discrimination on the basis of age in programs or activities receiving federal
financial assistance; and
v. Title II of the Americans with Disabilities Act of 1990, as amended (42 U.S.C.
§§ 12101 et seq.), which prohibits discrimination on the basis of disability
under programs, activities, and services provided or made available by state
and local governments or instrumentalities or agencies thereto.
Remedial Actions. In the event of Subrecipient’s noncompliance with section 602 of the
Act, other applicable laws, Treasury’s implementing regulations, guidance, or any
reporting or other program requirements, Treasury may impose additional conditions on
the receipt of a subsequent tranche of future award funds, if any, or take other available
remedies as set forth in 2 C.F.R. § 200.339. In the case of a violation of section 602(c) of
the Act regarding the use of funds, previous payments shall be subject to recoupment as
provided in section 602(e) of the Act and any additional payments may be subject to
withholding as provided in sections 602(b)(6)(A)(ii)(III) of the Act, as applicable.
Hatch Act. Subrecipient agrees to comply, as applicable, with requirements of the Hatch Act
(5 U.S.C.§§ 1501-1508 and 7324-7328), which limit certain political activities of State or local
government employees whose principal employment is in connection with an activity financed
in whole or in part by this federal assistance.
False Statements. Subrecipient understands that making false statements or claims in
connection with this award is a violation of federal law and may result in criminal, civil, or
administrative sanctions, including fines, imprisonment, civil damages and penalties,
debarment from participating in federal awards or Agreements, and/or any other remedy
available by law.
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Publications. Any publications produced with funds from this award must display the
following language: “This project [is being] [was] supported, in whole or in part, by
federal award number SLFRF0126 awarded to the State of Colorado by the U.S.
Department of the Treasury.”
Debts Owed the Federal Government.
a. Any funds paid to the Subrecipient (1) in excess of the amount to which the
Subrecipient is finally determined to be authorized to retain under the terms of this
award; (2) that are determined by the Treasury Office of Inspector General to have
been misused; or (3) that are determined by Treasury to be subject to a repayment
obligation pursuant to sections 602(e) and 603(b)(2)(D) of the Act and have not
been repaid by the Subrecipient shall constitute a debt to the federal government.
b. Any debts determined to be owed to the federal government must be paid promptly
by Subrecipient. A debt is delinquent if it has not been paid by the date specified in
Treasury’s initial written demand for payment, unless other satisfactory
arrangements have been made or if the Subrecipient knowingly or improperly
retains funds that are a debt as defined in paragraph 14(a). Treasury will take any
actions available to it to collect such a debt.
Disclaimer.
a. The United States expressly disclaims any and all responsibility or liability to
Subrecipient or third persons for the actions of Subrecipient or third persons
resulting in death, bodily injury, property damages, or any other losses resulting in
any way from the performance of this award or any other losses resulting in any
way from the performance of this award or any Agreement, or Subcontractor under
this award.
b. The acceptance of this award by Subrecipient does not in any way establish an
agency relationship between the United States and Subrecipient.
Protections for Whistleblowers.
a. In accordance with 41 U.S.C. § 4712, Subrecipient may not discharge, demote, or
otherwise discriminate against an employee in reprisal for disclosing to any of the list
of persons or entities provided below, information that the employee reasonably
believes is evidence of gross mismanagement of a federal Agreement or grant, a gross
waste of federal funds, an abuse of authority relating to a federal Agreement or grant,
a substantial and specific danger to public health or safety, or a violation of law, rule,
or regulation related to a federal Agreement (including the competition for or
negotiation of an Agreement) or grant.
b. The list of persons and entities referenced in the paragraph above includes the following:
i. A member of Congress or a representative of a committee of Congress;
ii. An Inspector General;
iii. The Government Accountability Office;
iv. A Treasury employee responsible for Agreement or grant oversight or
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management;
v. An authorized official of the Department of Justice or other law enforcement
agency;
vi. A court or grand jury; or
vii. A management official or other employee of Subrecipient, Contractor, or
Subcontractor who has the responsibility to investigate, discover, or
address misconduct.
c. Subrecipient shall inform its employees in writing of the rights and remedies provided
under this section, in the predominant native language of the workforce.
Increasing Seat Belt Use in the United States. Pursuant to Executive Order 13043, 62 FR
19217 (Apr. 18, 1997), Subrecipient should encourage its Contractors to adopt and enforce
on-the-job seat belt policies and programs for their employees when operating company-
owned, rented or personally owned vehicles.
10. Reducing Text Messaging While Driving. Pursuant to Executive Order 13513, 74 FR 51225
(Oct. 6, 2009), Subrecipient should encourage its employees, Subrecipients, and Contractors
to adopt and enforce policies that ban text messaging while driving, and Subrecipient should
establish workplace safety policies to decrease accidents caused by distracted drivers.
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ASSURANCES OF COMPLIANCE WITH CIVIL RIGHTS
REQUIREMENTS
ASSURANCES OF COMPLIANCE WITH TITLE VI
OF THE CIVIL RIGHTS ACT OF 1964
As a condition of receipt of federal financial assistance from the Department of the
Treasury, the Subrecipient provides the assurances stated herein. The federal financial assistance
may include federal grants, loans and Agreements to provide assistance to the Subrecipient’s
beneficiaries, the use or rent of Federal land or property at below market value, Federal training, a
loan of Federal personnel, subsidies, and other arrangements with the intention of providing
assistance. Federal financial assistance does not encompass Agreements of guarantee or insurance,
regulated programs, licenses, procurement Agreements by the Federal government at market value,
or programs that provide direct benefits.
The assurances apply to all federal financial assistance from or funds made available
through the Department of the Treasury, including any assistance that the Subrecipient may request
in the future.
The Civil Rights Restoration Act of 1987 provides that the provisions of the assurances
apply to all of the operations of the Subrecipient’s program(s) and activity(ies), so long as any
portion of the Subrecipient’s program(s) or activity(ies) is federally assisted in the manner
prescribed above.
1. Subrecipient ensures its current and future compliance with Title VI of the Civil Rights Act of
1964, as amended, which prohibits exclusion from participation, denial of the benefits of, or
subjection to discrimination under programs and activities receiving federal financial assistance,
of any person in the United States on the ground of race, color, or national origin (42 U.S.C. §
2000d et seq.), as implemented by the Department of the Treasury Title VI regulations at 31 CFR
Part 22 and other pertinent executive orders such as Executive Order 13166, directives, circulars,
policies, memoranda, and/or guidance documents.
2. Subrecipient acknowledges that Executive Order 13166, “Improving Access to Services for
Persons with Limited English Proficiency,” seeks to improve access to federally assisted
programs and activities for individuals who, because of national origin, have Limited English
proficiency (LEP). Subrecipient understands that denying a person access to its programs,
services, and activities because of LEP is a form of national origin discrimination prohibited
under Title VI of the Civil Rights Act of 1964 and the Department of the Treasury’s
implementing regulations. Accordingly, Subrecipient shall initiate reasonable steps, or comply
with the Department of the Treasury’s directives, to ensure that LEP persons have meaningful
access to its programs, services, and activities. Subrecipient understands and agrees that
meaningful access may entail providing language assistance services, including oral
interpretation and written translation where necessary, to ensure effective communication in the
Subrecipient’s programs, services, and activities.
3. Subrecipient agrees to consider the need for language services for LEP persons when
Subrecipient develops applicable budgets and conducts programs, services, and activities. As a
resource, the Department of the Treasury has published its LEP guidance at 70 FR 6067. For
more information on taking reasonable steps to provide meaningful access for LEP persons,
please visit http://www.lep.gov.
4. Subrecipient acknowledges and agrees that compliance with the assurances constitutes a condition
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of continued receipt of federal financial assistance and is binding upon Subrecipient and
Subrecipient’s successors, transferees, and assignees for the period in which such assistance is
provided.
5. Subrecipient acknowledges and agrees that it must require any sub-grantees, contractors,
subcontractors, successors, transferees, and assignees to comply with assurances 1-4 above,
and agrees to incorporate the following language in every Agreement or agreement subject to
Title VI and its regulations between the Subrecipient and the Subrecipient’s sub-grantees,
Contractors, Subcontractors, successors, transferees, and assignees:
The sub-grantee, Contractor, Subcontractor, successor, transferee, and assignee shall comply
with Title VI of the Civil Rights Act of 1964, which prohibits Subrecipients of federal financial
assistance from excluding from a program or activity, denying benefits of, or otherwise
discriminating against a person on the basis of race, color, or national origin (42 U.S.C. §
2000d et seq.), as implemented by the Department of the Treasury’s Title VI regulations, 31
CFR Part 22, which are herein incorporated by reference and made a part of this Agreement
(or agreement). Title VI also includes protection to persons with “Limited English
Proficiency” in any program or activity receiving federal financial assistance, 42
U.S.C. § 2000d et seq., as implemented by the Department of the Treasury’s Title VI
regulations, 31 CFR Part 22, and herein incorporated by reference and made a part of this
Agreement or agreement.
6. Subrecipient understands and agrees that if any real property or structure is provided or improved
with the aid of federal financial assistance by the Department of the Treasury, this assurance
obligates the Subrecipient, or in the case of a subsequent transfer, the transferee, for the period
during which the real property or structure is used for a purpose for which the federal financial
assistance is extended or for another purpose involving the provision of similar services or benefits.
If any personal property is provided, this assurance obligates the Subrecipient for the period during
which it retains ownership or possession of the property.
7. Subrecipient shall cooperate in any enforcement or compliance review activities by the
Department of the Treasury of the aforementioned obligations. Enforcement may include
investigation, arbitration, mediation, litigation, and monitoring of any settlement agreements that
may result from these actions. The Subrecipient shall comply with information requests, on-site
compliance reviews and reporting requirements.
8. Subrecipient shall maintain a complaint log and inform the Department of the Treasury of any
complaints of discrimination on the grounds of race, color, or national origin, and limited English
proficiency covered by Title VI of the Civil Rights Act of 1964 and implementing regulations and
provide, upon request, a list of all such reviews or proceedings based on the complaint, pending or
completed, including outcome. Subrecipient also must inform the Department of the Treasury if
Subrecipient has received no complaints under Title VI.
9. Subrecipient must provide documentation of an administrative agency’s or court’s findings
of non-compliance of Title VI and efforts to address the non-compliance, including any
voluntary compliance or other agreements between the Subrecipient and the administrative
agency that made the finding. If the Subrecipient settles a case or matter alleging such
discrimination, the Subrecipient must provide documentation of the settlement. If
Subrecipient has not been the subject of any court or administrative agency finding of
discrimination, please so state.
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10. If the Subrecipient makes sub-awards to other agencies or other entities, the Subrecipient is
responsible for ensuring that sub-Subrecipients also comply with Title VI and other applicable
authorities covered in this document State agencies that make sub-awards must have in place
standard grant assurances and review procedures to demonstrate that that they are effectively
monitoring the civil rights compliance of sub- Subrecipients.
The United States of America has the right to seek judicial enforcement of the terms of this assurances
document and nothing in this document alters or limits the federal enforcement measures that the
United States may take in order to address violations of this document or applicable federal law.
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EXHIBIT F, SLFRF SUBRECIPIENT QUARTERLY REPORT
1. SLFRF SUBRECIPIENT QUARTERLY REPORT WORKBOOK
1.1 The SLFRF Subrecipient Quarterly Report Workbook must be submitted to the State Agency
within ten (10) days following each quarter ended September, December, March and June.
The SLFRF Subrecipient Quarterly Report Workbook can be found at:
https://osc.colorado.gov/american-rescue-plan-act (see SLFRF Grant Agreement Templates
tab).
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Exhibit G – SAMPLE SLFRF REPORTING MODIFICATION FORM
Grantee: Grant Agreement No:
Project Title: Project No:
Project Duration: To: From:
State Agency:
This form serves as notification that there has been a change to the reporting requirements set forth in
the original SLFRF Grant Agreement.
The following reporting requirements have been (add/ remove additional rows as necessary):
Updated Reporting
Requirement
(Add/Delete/Modify)
Project Number Reporting Requirement
By signing this form, the Grantee agrees to and acknowledges the changes to the reporting
requirements set forth in the original SLFRF Grant Agreement. All other terms and conditions
of the original SLFRF Grant Agreement, with any approved modifications, remain in full force
and effect. Grantee shall submit this form to the State Agency within 10 business days of the
date sent by that Agency.
____________________________________ _______________________________
Grantee Date
____________________________________ _______________________________
State Agency Grant Manager Date
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EXHIBIT H – APPLICABLE LAWS
Laws, regulations, and authoritative guidance incorporated into this Grant include, without limitation:
1. Housing and Community Development Act of 1974, Pub L, No. 93-383, as amended.
2. Cranston-Gonzales National Affordable Housing Act of 1990, as amended
3. 24 CFR Part 92, HOME Investment Partnerships Program Final Rule
4. State of Colorado Community Development Block Grant (CDBG) Guidebook, available on
DOLA’s website.
5. 24 CFR Parts 0-91 Housing and Urban Development.
6. 24 CFR Subtitle B, Chapter I – XXV, HUD.
7. 24 CFR Part 58, Environmental Review Procedures for Entities Assuming HUD Environmental
Responsibilities.
8. 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit
Requirements for Federal Awards
9. 2 CFR Part 230, Cost Principles for Non-Profit Organizations.
10. 2 CFR Part 200 Section 500, et seq., Audit Requirements.
11. §29-1-601, et seq., C.R.S., Local Government Audit Law.
12. §24-32-106 C.R.S., Powers of the director provision.
13. §24-32-705(1)(i) C.R.S., DOH ability to accept and receive grants
14. 16 USC §469, et seq., Historic Preservation
15. 2 USC Chapter 26, Disclosure of Lobbying Activities.
16. 5 USC §552a, Public Information; agency rules, opinions, order, records and proceedings
(Privacy Act 1974).
17. 8 USC §1101-1646, Immigration and Nationality.
18. 12 USC §§1701- 1701z-15, National Housing Act.
19. 15 USC Chapter 49, Fire Prevention and Control.
20. 16 USC Chapters 1-92, Conservation.
21. 16 USC §469, et seq., Historic Preservation
22. 16 USC §1531, et seq., Endangered Species
23. 16 USC §1271, et seq., Wild and Scenic Rivers
24. 20 USC Chapter 38, Discrimination Based on Sex or Blindness (Title IX, as amended,
Education Amendment of 1972).
25. 29 USC Chapter 8, §§201, 206, et seq., as amended, Labor.
26. 29 USC Chapter 14 Age Discrimination in Employment.
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27. 29 USC Chapter 16, §§793-794, et seq., as amended, Vocational Rehabilitation and Other
Rehabilitation Services.
28. 31 USC Subtitles I – VI, Money and Finance.
29. 40 USC Subtitle I, Federal Property and Administrative Services.
30. 40 USC Subtitle II, Public Buildings and Works.
31. 40 USC §§ 3141 – 3148, Wage Rate Requirements (Davis Bacon).
32. 40 USC §§ 3701 – 3708, Contract Work Hours and Safety Standards Act.
33. 40 CFR Parts 1500-1508, Council on Environmental Quality (Regulations Implementing
NEPA).
34. 41 CFR Chapter 60, Office of Federal Contract Compliance Programs, Equal Employment
Opportunity, Department of Labor.
35. 41 USC § 6502, et seq., Walsh-Healey Public Contracts Act.
36. 41 USC Chapter 81, Drug Free Workplace.
37. 42 USC Chapter 6A, Public Health Service.
38. 42 USC Chapter 21, Civil Rights.
39. 42 USC Chapter 45 Fair Housing.
40. 42 USC Chapter 50, National Flood Insurance.
41. 42 USC Chapter 55, National Environmental Policy.
42. 42 USC Chapter 63, Lead-Based Paint Poisoning Prevention.
43. 42 USC Chapter 69, Community Development.
44. 42 USC Chapter 76, Age Discrimination in Federally Assisted Programs.
45. 42 USC Chapter 85, Air Pollution Prevention and Control.
46. 42 USC Chapter 89, Congregate Housing Services.
47. 42 USC Chapter 126, Equal Opportunity for Individuals with Disabilities.
48. 42 USC Chapter 130, National Affordable Housing.
49. 42 USC §§300f – 300j-26, Safe Drinking Water
50. 49 CFR Part 24, as amended, Uniform Relocation Assistance and Real Property for Federal and
Federally Assisted Programs.
51. §24-34-301, et seq., C.R.S., Colorado Civil Rights Division.
52. §24-34-501, et seq., C.R.S., Housing Practices.
53. §24-75-601, et seq., C.R.S., Legal Investment of Public Funds.
54. Executive Order 11063, HUD Equal Opportunity in Housing, as amended by Executive Order
12259, Leadership and Coordination of Fair Housing in Federal Programs.
55. Executive Order 11593, Protection and Enhancement of the Cultural Environment.
56. Executive Order 11988, Floodplain Management.
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57. Executive Order 11990, Protection of Wetlands
58. Public Law 110-289, Housing and Economic Recovery Act of 2008.
59. Public Law 111-203, Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010.
60. Compliance with all applicable standards, orders, or requirements issued pursuant to section
508 of the Clean Water Act (33 USC §1368), Executive Order 11738, and Environmental
Protection Agency regulations (40 CFR Part 15). (Applicable to contracts, subcontracts, and
subgrants of amounts in excess of $100,000).
61. Mandatory standards and policies relating to energy efficiency which are contained in the state
energy conservation plan issued in compliance with the Energy Policy and Conservation Act
(Pub. L. 94–163, 89 Stat. 871). [53 FR 8068, March 11, 1988, as amended at 60 FR 19639,
Apr. 19, 1995]
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EXHIBIT I - RENT AND INCOME LIMITS
[Reserved]
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Exhibit J Page 1 of 2 Version 6.01.2023
EXHIBIT J-PII CERTIFICATION
STATE OF COLORADO
THIRD PARTY INDIVIDUAL CERTIFICATION FOR ACCESS TO PII THROUGH A
DATABASE OR AUTOMATED NETWORK
Pursuant to § 24-74-105, C.R.S., I hereby certify under the penalty of perjury that I have not and will
not use or disclose any Personal Identifying Information, as defined by § 24-74-102(1), C.R.S., for the
purpose of investigating for, participating in, cooperating with, or assisting Federal Immigration
Enforcement, including the enforcement of civil immigration laws, and the Illegal Immigration and
Immigrant Responsibility Act, which is codified at 8 U.S.C. §§ 1325 and 1326, unless required to do so
to comply with Federal or State law, or to comply with a court-issued subpoena, warrant or order.
Signature: __________________________
Printed Name: __________________________
Date: ___________
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EXHIBIT J-PII CERTIFICATION
STATE OF COLORADO
THIRD PARTY ENTITY / ORGANIZATION CERTIFICATION FOR ACCESS TO PII
THROUGH A DATABASE OR AUTOMATED NETWORK
Pursuant to § 24-74-105, C.R.S., I, _________________, on behalf of __________________________
(legal name of entity / organization) (the “Organization”), hereby certify under the penalty of perjury
that the Organization has not and will not use or disclose any Personal Identifying Information, as
defined by § 24-74-102(1), C.R.S., for the purpose of investigating for, participating in, cooperating
with, or assisting Federal Immigration Enforcement, including the enforcement of civil immigration
laws, and the Illegal Immigration and Immigrant Responsibility Act, which is codified at 8 U.S.C. §§
1325 and 1326, unless required to do so to comply with Federal or State law, or to comply with a court-
issued subpoena, warrant or order.
I hereby represent and certify that I have full legal authority to execute this certification on behalf of the
Organization.
Signature: __________________________
Printed Name: __________________________
Title: __________________________
Date: ___________
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Executive Director
10/16/2023 | 11:09 AM MDT
Cristina Gair
West Mountain Reg. Health AllianceCristina Gair
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FORM 1 -
RESIDENCY DECLARATION
[Reserved]
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EXHIBIT B
TRANSFORMATIONAL HOMELESSNESS RESPONSE GRANT PROGRAM POLICIES AND
PROCEDURES
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Department of Local Affairs (DOLA),
Div ision of Housing (DOH),
Office of Homeless Initiatives (OHI)
Transformational Homelessness Response (THR)
Grant Program
Policies &Procedures
Updated 2/23/2024
These policies and procedures apply to all Subrecipients of the Transformational Homelessness
Response (THR)grant program.
DOH may add to this document as additional areas for clarification are identified.Please see
the Revisions section for a list of additions made from previous editions.
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Table of Contents -Click the desired topic to jump to that section
REVISIONS 5
Introduction 6
Overview of Funding 6
Recipient and Subrecipients 7
Recipient and Subrecipient Responsibilities 7
Governing Documents 7
Subrecipient Specific Policies and Procedures 8
Cost Principles &Allowable Costs 9
Allowable costs 9
Unallowable Costs 10
DOH Discretion &Determination of Unallowable Costs for THR 10
Use of Funds for Law Enforcement Personnel and Expenses 10
Construction,Acquisition,or Renovation 10
Supplantion &Supplementing 11
Supplantation 11
Supplementing 11
Best Practices To Prevent Supplanting 11
Duplication of Benefits 12
Conducting the Duplication of Benefits Analysis 12
Program Assistance Analysis 12
Individual Assistance Analysis 12
Direct and Indirect Costs 13
Indirect Cost Rates 13
Modified Total Direct Costs 14
Cost Allocation Plans 15
Salaries and Expenses 15
Time and Activity Documentation 16
Pass Through Entities 17
Pass Through Entity Responsibilities 17
Subaward Classification 18
Subrecipient 18
Subcontractor 18
Subaward Approval Process 19
THR Subcontractor Expectations Guidance 19
Procurement Standards 19
Financial Management 20
Internal Controls 20
Fraud,Waste,&Abuse 21
Program Income 22
Accounting for Program Income 22
Match or Cost Sharing 23
General Considerations 23
Types of Allowable Match 23
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Unallowable Match 24
Rules to Follow 24
Grant Reimbursement 24
Federal Funds Advances 24
Advances Fund Approval Process 25
Interest on Advances 25
Supporting Documentation 25
Pay Request Supporting Documentation 25
Examples Of Pay Request Supporting Documentation 26
Income Limits for THR Activities 27
Expectations on the Equitable Distribution of Resources 28
THR Referral Plan 28
Beneficiary Documentation or Client Files 29
Examples of Beneficiary Documentation by Program Activity 29
Personal Identifying Information (PII)34
Record Retention 36
Pay Requests 37
Reporting 38
HMIS Setup 38
HMIS Project Setup Guidelines 39
HMIS Reporting 39
Reporting Dates 39
Monitoring 40
Risk-Based Monitoring 41
Types of Monitoring 41
Outcomes of Monitoring 41
Audit Requirements 42
Eligible Activities and Program Components 42
General Best Practices 43
Street Outreach 44
Emergency Shelter 45
Transitional Housing 46
Bridge Housing 47
Eviction &Homelessness Prevention 48
Rapid Re-housing 50
Permanent Supportive Housing 53
Systems Improvement 55
Additional Resources 55
Appendix A 56
Pay Request Policies &Procedures 56
Overview of Pay Requests 56
Completing Your THR Cover Sheet 57
Compiling &Organizing Your Backup Documentation Packet 58
Using Access Gov 59
Frequently Asked Questions 61
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REVISIONS
Since the first edition of the THR Policies &Procedures published in September 2023,the
following updates have been made:
Edition Date Section &Hyperlink Revision
November 2023 Unallowable Costs Gift cards were added to the list of
unallowable costs.
Income Limits for THR
Activities
Details added on the maximum income
limits for households to be eligible for THR
funded services
Expectations on the Equitable
Distribution of Resources
Additional policy clarity added surrounding
the intended audience of THR grants,and
prioritization requirements for grantees.
THR Referral Plan Additional policy and procedure for referral
plans for THR grants.
Beneficiary Documentation or
Client Files
Additional details added on the required
backup documentation by funded activity.
HMIS Project Setup Additional details added on the required
grant reporting,including reporting
schedule &important distinctions.
Linking the HMIS Program Setup Guide
Spreadsheet for grantees.
Eligible Activities &Program
Components Best Practices
Details on best practices from the Playbook
on eligible activities &program
components.
December 2023 Beneficiary Documentation or
Client Files
Residency Declaration requirements
specified for all adults in households.
February 2024 Third Party Entity Access to PII Clarity on language included in grant
agreement surrounding disclosure of PII
THR Subcontractor
Expectations Guidance
Additional guidance of subaward approval
expectations for subcontractors
Pay Request Procedure The separate THR Pay Request Procedure
document was updated and added to
Appendix A.
Pay Request Backup
Documentation Submission
Requirements
Clarity that DOH may waive the
requirement to submit full backup each
month after 3 months of accurate requests.
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Introduction
Overv iew of Funding
Created by Colorado House Bill 2022 1304 (HB22-1304)and Colorado House Bill 2022 1377
(HB22-1377)the Transformational Homelessness Response (THR)grant program seeks to
ensure everyone has a safe and stable place to live and thrive.
The Colorado Department of Local Affairs (DOLA),through its Division of Housing (DOH)Office
and Office of Homeless Initiatives (OHI),administers the Transformational Homelessness
Response (THR)grant program.
The aim of the THR grant program is to create a future where homelessness is rare and brief
when it occurs,and no one gets left behind.The program achieves this aim by advancing and
implementing proven solutions and program models that reduce homelessness in a holistic and
sustainable way by targeting many of the key underlying factors necessary for people to
thrive:advance equity,improve overall well-being,connect to benefits and stable housing,
and increase employable skills and experiences that allow individuals to meet their needs,
pursue their goals,and achieve self-sufficiency.In addition to reducing homelessness,this
program aims to reduce public utilization costs,revitalize public spaces,and increase
workforce opportunities.
As the U.S.Department of Housing and Urban Development (HUD)stated after the passing of
the American Rescue Plan Act (ARPA):COVID-19 has exacerbated our nation’s already severe
housing affordability crisis.Today,1 in 5 renters is behind on rent and just over 10 million
homeowners are behind on mortgage payments.People of color face even greater hardship
and are more likely to have deferred or missed payments,putting them at greater risk of
eviction and foreclosure.At the same time,our nation’s homelessness crisis has worsened
during the pandemic,as people experiencing homelessness are highly vulnerable to COVID-19
transmission,illness,and severity due to their use of congregate shelters and their high
prevalence of underlying health conditions.
Colorado is no exception,as COVID-19 has been hitting low-and extremely low-income
individuals and families who were already severely cost-burdened especially hard,increasing
their risk of experiencing homelessness or inability to resolve their homelessness.
The source of funds for these programs are from The Coronavirus State and Local Fiscal
Recovery Funds (SLFRF)program,a part of the American Rescue Plan Act (ARPA).This THR
policies and procedures document covers specific compliance and reporting requirements for
this funding.
As the Recipient of federal funds,DOH is required to comply with all applicable requirements,
and pass the responsibility to comply with all applicable regulations onto any Subrecipients
who are awarded federal funds.
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Recipient and Subrecipients
As it pertains to the THR program:
●Recipient –The State of Colorado is the Recipient entity that receives SLFRF funding.
In the context of this policies and procedures document,the Division of Housing (DOH)
is the Recipient.
●Subrecipients –DOH allocated THR funds through a competitive application process.
Entities that receive DOH’s THR funds through this application process and administer
the program components are DOH’s Subrecipients.
○Additional details outlining the roles and responsibilities of THR Subrecipients
that may enter into subawards of their own can be found in the Pass Through
Entities section.
Recipient and Subrecipient Responsibilities
Recipients and Subrecipients of federal funds have responsibilities including:
●Effective administration of federal funds
●Application of sound management practices
●Administration of federal funds in a manner consistent with the program objectives
and terms and conditions
It is not only the Recipient's responsibility but the Pass Through Entity’s responsibility to make
sure that costs are allowable.
Recipients and Subrecipients should document and follow written policies and procedures,it
will be expected that a Recipient or Subrecipient can readily produce this documentation
during an audit.
Pass Through Entities must continue to monitor Subrecipients and review costs charged to the
federal award using the above criteria and completed documentation to support these costs.
Governing Documents
DOH staff must follow the most restrictive guidelines for all funds included in a project.For
example if the Office of the State Controller (OSC)has a more restrictive rule for funds,DOH
staff must follow the OSC rule rather than the Uniform Administrative Requirement.
The most recent version of these governing document applies:
1.Uniform Administrative Requirements (2 CFR 200)
Uniform Administrative Requirements are federal requirements that are used to
administer all federal funding throughout the grant life cycle.These requirements are
applicable to all costs related to Federal awards.
2 CFR 200 contains six subparts and twelve appendices.The subparts of 2 CFR 200 are
aligned with the award lifecycle:
○Subpart A –Acronyms and Definitions (2 CFR 200.0 to 2 CFR 200.99)
○Subpart B –General Provisions (2 CFR 200.100 to 2 CFR 200.113)
○Subpart C –Pre-Federal Award Requirements and Contents of Federal Awards (2
CFR 200.200 to 2 CFR 200.213)
○Subpart D –Post Federal Award Requirements (2 CFR 200.300 to 2 CFR 200.345)
○Subpart E –Cost Principles (2 CFR 200.400 to 2 CFR 200.475)
○Subpart F –Audit Requirements (2 CFR 200.500 to 2 CFR 200.521)
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2.SLFRF 2023 Interim Final Rule
Provides additional provisions relevant to SLFRF funding.
3.Overview of the 2023 Interim Final Rule,provides a summary of major rule provisions
to assist recipients and stakeholders
4.SLFRF Final Rule:Frequently Asked Questions -July 2023
5.Office of the State Controller (OSC)Fiscal Procedures
The requirements outlined in the Uniform Administrative Requirements are mirrored
for state funds in the Office of the State Controller (OSC)Fiscal Procedures.These
procedures govern the State’s fiscal procedures.
6.OSC SLFRF Recovery Funds Reference Guide
Throughout this document are links to desk guidance for applicable guidance that have
been developed by the State of Colorado Office of the State Controller (OSC).These
do not cover every aspect of the 2 CFR 200 requirements,but address the common
grant management requirements of which grant managers should be aware.
7.THR Grant Agreement
THR-funded organizations must review and adhere to their THR Grant Agreement(s).
The executed Grant Agreement for each THR award has specific definitions,
requirements,and provisions governing the award.
Within the Grant Agreement Subrecipients can find critical information including:
●Period of Performance
●Approved Statement of Work
●Performance Milestones
●Reporting Requirements
●Line Item Approved Budget
●Insurance Requirements
●Payment Process
8.THR Policies and Procedures
Subrecipient Specific Policies and Procedures
While many of the Governing Documents above outline DOH's responsibilities with regard to
these funds,Subrecipients should note that all requirements pass through to them as well as
they receive these funds from DOH.
Subrecipients receiving THR grant funds should be familiar with these THR policies and
procedures and,as is noted throughout this document,should have written policies and
procedures for their own organization.Subrecipient may adopt these THR policies and
procedures as their organization’s policies and procedures.
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Cost Principles &Allowable Costs
2 CFR 200 Subpart E (2 CFR 200.400 to 2 CFR 200.475)
Cost principles are standards for federal awards that apply to all direct and indirect costs,
definitions for which can be found in the Direct and Indirect Costs section.
Non-Federal entities (including state &local governments)are required to:
●Submit cost sharing/matching funds plans
●Abide by Generally Acceptable Accounting Principles (GAAP)
●Abide by Federal Audit requirements
Additional resource:
OSC Cost Principles Basic Considerations -2 CFR 200.400 -22.419 -An overview of cost
principles as outlined in 2 CFR 200,Subpart E.
Allowable costs
2 CFR 200.403-406
Allowable costs,able to be charged to a federal award,must meet all of the following
requirements:
●Be necessary and reasonable
○Necessary costs are “generally recognized as ordinary and necessary for the
operation..and efficient performance of the federal award”2 CFR 200.404 (a).
○You should be able to specifically describe how and why costs are necessary.If
you’re unable to,it’s most likely unallowable.
○A cost is reasonable if it does not exceed what would be incurred by a prudent
person under normal circumstances at the time the decision to incur the cost
was made.
○In other words,the necessary requirement is about the need and the
reasonableness requirement is about the cost.
○THR is a housing-focused program that aims to transform homelessness in
Colorado.DOH recognizes that there will be a variety of costs associated with
housing individuals who have historically been unhoused that will be
reasonable.Agencies should be able to provide rationale for how they
determine if a cost is reasonable to address the housing needs of their clients.
●Conform with federal law,program guidelines,and terms of the federal award
●Be allocable to the specific award and its activities
○All costs must be chargeable or assignable to the Subrecipent’s THR grant
agreement before they are paid out
●Be accorded consistent treatment,meaning a cost may not be assigned to a federal
award as a direct cost if any of costs is incurred for the same purpose
●In accordance with the Generally Accepted Accounting Principles (GAAP)
●Not used for cost sharing or matching requirement of any other federally funded
program
●Purchased materials and supplies must be charged at their actual prices or net of
applicable credits -the actual costs after all discounts and promotions are applied
●Consistent with the organization’s policies uniformly applied to all activities
○Costs must be consistently charged as either indirect or direct costs.
Subrecipients may not charge the same administrative costs to both direct and
indirect cost categories,or to other programs.
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●Have adequate backup documentation using sound management techniques
○A cost cannot be considered allowable if there is no documentation to support
it.This includes but is not limited to invoices for services,time and effort
documentation for staff time,and documentation of indirect costs.
●All costs under a federal award must occur during the approved period of
performance.If a cost occurs outside the period of performance then it will be
considered unallowable.
Unallowable Costs
2 CFR 200.400,Subpart E
Costs that are considered unallowable cannot be charged to federal awards,they include:
●Advertising and public relations
●Alcoholic beverages -includes costs of alcohol at hosted events and while traveling for
grant related activities
●Contingencies
●Contributions and donations -federal funds cannot be used to donate to any cause,
including political contributions
●Prosecution and criminal activities
●Entertainment
●Fines
●Penalties
●General government expenses and lobbying costs
●Gift cards
●Duplication of benefits
Additional resource:An additional summary of selected items of cost as outlined in 2 CFR
200.421-475 by the Office of State Controller is provided for your guidance only.Please
consult Uniform Guidance for additional information.
DOH Discretion &Determination of Unallowable Costs for THR
The Colorado legislature endowed the DOH with the discretion to determine restrictions or
conditions of the grant program and the use of awarded grant funds.DOH will continue to
update this THR policies and procedures with additional guidance as necessary.
Use of Funds for Law Enforcement Personnel and Expenses
DOH does not consider law enforcement personnel and expenses to be an eligible cost under
the THR Grant program.Subrecipients may,with written DOH approval,leverage the staff
time of law enforcement as match when directly spent on approved grant program activities,
such as street outreach.
Construction,Acquisition,or Renovation
Under the THR RFA,costs related to development such as acquisition,renovation,and new
construction are not eligible expenses.
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Supplantion &Supplementing
Subrecipients must understand the differences between supplanting and supplementing.This
distinction is important because supplanting is not allowed,while supplementing is allowed.
Supplantation
Supplanting occurs when a grantee replaces existing organizational or program funds currently
used to pay for an activity,because federal funds are available (or are expected to be
available)for that same activity.Federal funds cannot be used to cover expenses that would
otherwise be paid out using other funds.Federal grant funds must instead be used to benefit
the intended purpose of the funds as defined in the grant agreement,such as starting a new
project or building upon an existing project.
For example,an emergency shelter provider has a staff person whose time is covered with an
existing grant.That person’s job will not change if THR is awarded to an agency.Even though
their time could be covered by THR (emergency shelter operations is an eligible activity under
the THR program),that agency cannot reallocate the existing grant to another use in order to
pay for that staff person’s time with THR.The only way the program could cover that staff
person’s time with THR would be if that staff person’s job will change to support the
increased THR project in some capacity.
Supplementing
An entity is supplementing funding when federal grant funds are used in combination with
other funds to enhance a planned expenditure in an existing budget or to administer the
increased work that results from the additional federal award.Supplementing funds is
allowable to the extent that funds are used to meet the programmatic purpose and that no
other provision prohibits its use this way.Entities may blend and braid their federal funding
with other funding through supplementing.For example,an organization that already has a
financial manager that oversees all organizational spending has added THR funds to that staff
person’s portfolio.That staff person is now spending additional time managing THR funds.
Therefore,that organization can request reimbursement for the time and activities required
to manage the THR funds,with appropriate time/activity documentation.
Best Practices To Prevent Supplanting
If supplanting is discovered via monitoring or auditing,it indicates that the Subrecipient did
not identify supplanting upfront and must improve its financial practices and internal
controls.Subrecipients that have supplanted must return that money to the state agency or
directly to the federal agency.This often will result in suspension of future funds for the
particular program and potentially civil or criminal penalties.Below are some best practices
that can help agencies and their Subrecipients avoid supplanting:
●Ensure that all internal staff understand the difference between supplementing and
supplanting
●Ensure funds are tracked separately and not co-mingled.
○Funds should not be lumped into one category labeled “grants”
○Financial system must be able to track funds by funding source
○All expenses and reimbursements must be consistently tracked for accuracy
●Never use federal funds to pay for existing employees,unless the existing position
changes to include different responsibilities that are created due to the new funding
●Never use federal funds to pay for items or costs that you are already committed to
pay with state,local,or tribal funds
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●Maintain supporting documentation:budget sheets,meeting minutes,or other official
documents that may address the reduction of non-federal funds
●Review internal processes and/or create processes to address supplanting
●DOH monitors Subrecipients to ensure sound financial practices are in place
Additional resource:OSC Supplanting Determination Tool
Duplication of Benefits
The American Rescue Plan Act (ARPA)requires that grantees avoid a duplication of benefits.A
duplication of benefits occurs when a person,household,business,government,or other
entity receives financial assistance from multiple sources for the same purpose within the
same time period,and the total assistance received for that purpose is more than the total
need for assistance.
Subrecipients can create a duplication of benefits if they charge two funders for the same
cost (i.e.February’s rent payment for office space,the annual salary of the same staff
person,etc.).Beneficiary duplication of benefits occurs when the amount of the assistance to
a beneficiary exceeds the total allowable assistance to that beneficiary.The total allowable
assistance is based on the eligible activities of a grant program,a required needs assessment,
or another reasonable needs-based metric.Subrecipients must conduct an analysis to
determine whether the beneficiary could receive assistance from other sources and should
pay only for needs not met by other sources.
Conducting the Duplication of Benefits Analysis
Program Assistance Analysis
Subrecipient can complete a duplication of benefits analysis by developing an overall project
budget that demonstrates the funding needed for the activity and the funding reasonably
anticipated.
This analysis can be used for a particular program or geographic area where the sources of
funding can be identified and the need can be reasonably estimated.This has been described
as similar to a “sources and uses”analysis for a housing or economic development project.
The sources of funding for the budget should include all Federal and non-Federal funding,
in-kind or cash donations,and any projected program income.If the budget shows that the
estimated need is greater than the funding sources,there is no duplication of benefits.
Individual Assistance Analysis
An organization can conduct an individual assistance analysis by assessing a beneficiary’s
current level of resources they are receiving toward the need that they are presenting to the
Subreicpient.If the benefits they are receiving exceed the total need,any additional support
would constitute a duplication of benefits.If the benefits are less than the total need,the
agency can provide resources to fill the gap.
The preferred method for assessing beneficiary resources toward a need is through collection
of third party documentation about the resources already being provided.If this is not
feasible,a signed attestation form at the time of intake to certify that the beneficiary is not
receiving duplicative rental assistance from another agency.
Additional resource:OSC Duplication of Benefits Guidance
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Direct and Indirect Costs
There are two ways to charge a grant,through direct costs and indirect costs.Uniform
Guidance provides guidelines whether a cost is direct or indirect.
A direct cost is one “that can be identified specifically with a particular final cost
objective...or that can be directly assigned to such activities relatively easily with a high
degree of accuracy.”(2 CFR 200.413(a)).
Examples of direct costs include salary,materials,and supplies used for the grant.Supply
costs must either be dedicated to the grant 100%,or have a clear and consistent methodology
for tracking the portion of the costs allocated to each grant.
On the other hand,an indirect cost is “incurred for a common or joint purpose benefitting
more than one cost objective and not readily assignable to the cost objectives specifically
benefited,without effort disproportionate to the results achieved.”(2 CFR 200.1)
Said another way,indirect costs are not readily identifiable with a specific project but are
necessary to the general operation of an agency and how activities are conducted.
Indirect costs are often incurred for a common purpose of benefitting more than one cost
objective.Such as maintenance of office equipment or equipment that can be used by
multiple programs and projects.
Common examples of indirect costs are costs of heat,air conditioning,lighting,payroll,and
the accounting system.
Indirect costs charged to a federal grant must be proportionate to the percentage of program
benefit and are expressed as an indirect cost rate.
Subrecipients are permitted to charge both direct and indirect costs to their award as long as
they are accorded consistent treatment per 2 CFR 200.403.
It is important to have written policies and procedures in place that provide the process for
making this decision.These policies and procedures must be applied consistently and
uniformly to both federally funded activities and non-federally funded activities.
Additional resources:
●Allowable Costs and Cost Principles (2 CFR 200,Subpart E)micro training
●OSC ARPA Reference Guide Direct and Indirect Costs
Indirect Cost Rates
2 CFR 200.416 (a)
To recover indirect costs on Federal Awards,you must have either a current Negotiated
Indirect Costs Rate Agreement (NICRA)or utilize the De Minimis Indirect Cost Rate of 10
percent.
If your organization has a current NICRA,then you must use that negotiated rate for your
indirect expenses,and you must provide DOH with documentation of your current NICRA along
with your first reimbursement request.
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If your organization does not have a NICRA,you may elect to use the de minimis rate of 10%
of the modified total direct costs pursuant to 2 CFR 200.414(f).
No documentation is required to elect to utilize the de minimis rate of 10%of the modified
total direct costs.However,if your organization chooses to elect to use the de minimis rate of
10%of the modified total direct costs,then you must consistently do so for all Federal awards
until you elect to negotiate a NICRA,which you may apply to do at any time.
If your organization elects to utilize the de minimis rate of 10%of the modified total direct
costs,then you must provide DOH with documentation of how you identified your modified
total direct costs along with your first reimbursement request.
Modified Total Direct Costs
Recipients and Subrecipients electing the 10 percent de minimis rate must use the Modified
Total Direct Costs (MTDC)as the base for this rate.According to 2 CFR §200.68,the MTDC is
composed of “[a]ll direct salaries and wages,applicable fringe benefits,materials and
supplies,services,travel,sub-awards and subcontracts up to the first $25,000 of each
sub-award or sub-contract (regardless of the period of performances under the award).”
MTDC does not include equipment,capital expenditures,charges for patient care,rental
costs,tuition remission,scholarships and fellowships,and participant support costs.
All costs used to comprise an MTDC base (used for calculating de minimis)must be identified
specifically to a funded program or be directly assigned to such activities easily and
accurately.Costs must also be allowable under program regulations,necessary and reasonable
for the performance of the federal award,and consistent with policies and procedures that
apply uniformly to both federal and non-federal activities of the grantee (2 CFR §200.403).
Once the MTDC base has been determined,the de minimis rate of 10 percent is applied to
that base,deriving total de minimis indirect costs.
In order to include eligible direct activity costs in the MTDC base,Recipients and
Subrecipients must maintain detailed accounting records clearly separating salaries,wages,
fringe benefits,and service and consultant costs.
Furthermore,Recipients and Subrecipients must track costs by element for each eligible
component activity.For example,organizations must maintain detailed accounting records
clearly separating salaries,wages,fringe benefits,and service and consultant costs for each
eligible activity (e.g.,supportive services,operating costs,project administrative costs).If
costs are grouped (totaled)under eligible activities,they cannot be included in the MTDC
base.
When costs are grouped as total costs for eligible activities,there is not adequate information
to identify the allowable and excludable costs for the purpose of determining the MTDC base
and calculating the de minimis rate.Recipients and Subrecipients must maintain adequate
documentation to support the costs included in the MTDC base consistent with the 2 CFR
§200.333 retention requirements.
Additional resource:HUD’s Indirect Cost Toolkit for Continuum of Care (CoC)and Emergency
Solutions Grants (ESG)Programs -A helpful tool for understanding indirect costs and modified
total direct costs pursuant to 2 CFR 200.414(f)
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Cost Allocation Plans
2 CFR.200,Subpart E,400-475
A Subrecipient that receives federal funds shall prepare either an indirect cost rate
proposal/plan (ICRP);Public Assistance Cost Allocation Plan (PACAP);or Cost Allocation Plan
(CAP)in accordance with the OMB’s Uniform Administrative Requirements,Cost Principles and
Audit Requirements for Federal Awards commonly known as ‘Uniform Guidance’.
Cost allocation plans are among the bedrocks for successfully managing an organization,
especially one that spends federal funds.This plan will serve as a roadmap for the
organization and its funders to understand how it spends and manages revenue.It will be the
foundation for the organization to adequately charge its program costs to the federal award.
Each organization will need a cost allocation plan that is tailored to its structure and
activities that explains:
●How it will determine which costs are direct and indirect;
●How it will allocate shared costs among different departments,including
administrative functions and direct programs;and
●How it will charge (recover)all eligible and allowable direct and indirect costs from
the federal government or its awardees and make sure that it does not short-change
itself unnecessarily.
In a cost allocation plan,direct and indirect costs are allocated to each cost objective.There
are three acceptable methods to calculate the indirect cost rate in a cost allocation plan:
●Simplified allocation method
●Multiple rate allocation method
●Direct allocation method
Additional resources:
●Statewide Indirect Cost Allocation Plan (Uniform Guidance,Appendix V)
●State Agency;Indirect Cost Rate Proposal (DCRP)(Uniform Guidance,Appendix IV)
●HUD’s Indirect Cost Toolkit for Continuum of Care (CoC)and Emergency Solutions
Grants (ESG)Programs also contains additional information on cost allocation plans
Salaries and Expenses
2 CFR 200.430 and .413
In general,compensation in the form of salaries and benefits is allowable under SLFRF.This
means that the portion of a person’s salary,costs for insurance,unemployment,and FICA that
is directly related and documented to SLFRF can be charged to a grant,if the grant has
awarded payroll costs as an eligible expense.
Compensation can be direct,for example for the project manager who runs the SLFRF funded
program.Or,compensation can be indirect as part of a calculated indirect cost.
SLFRF also lists retention pay as an enumerated use,and the additional salary and benefits
that relate to retention pay must be documented appropriately.
Administrative/clerical staff are typically indirect costs,unless:
●Salaries are an integral part of the grant or program management (such as a grant
manager’s salary)
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●Individuals can be specifically identified
●These salaries must be explicitly included in the budget or otherwise approved,and
such costs are not otherwise recovered
The SLFRF Interim Final Rule provides additional overview of allowable uses of funds for
wages,salaries,and benefits.
The Uniform Guidance identifies selected items of cost,and will help to determine the proper
use of the funds and whether or not the salaries or expenses should be treated as direct,
indirect,allowable,unallowable,or allocable.
Additional resource:OSC Selected Items of Cost Guidance
Time and Activity Documentation
2 CFR 200.430(i)
Federal funding is often used to pay employee wages.While this is an allowable use of
funding,employee salaries paid partially or completely with federal funds must track their
time and activities contributed toward any and all federal programs that fund their salary.
This process is known as “Time and Activity”tracking.All Recipients and Subrecipients of
SLFRF funding are required to track their “time and activities''.An absence of this
documentation will result in significant audit findings.
Time and activity record-keeping includes two components.First,it should reflect the time
(i.e.number of hours per work day/week)employees spend on each program they administer
(federal and non-federal).Second,it must include the activities they completed/
conducted/administered,etc.during the time they are tracking toward each grant.
Time and activity record-keeping should also be consistent with written agency policy;
applied equally to federal and non-federal activities;and correctly calculated and supported
by documentation.It should be used to support salary distribution across all funding sources
or activities;include an after-the-fact review of actual hours worked,be incorporated into
official records;and be signed by an employee’s supervisor,or by a responsible supervisory
official having firsthand knowledge of the activities performed by the employee.
SLFRF and other federal funds require that the percentage of time allocated to a funding
source should be well documented and accurately reflect the efforts.Time and activity
documents must be submitted with pay requests to DOH in order for employee salaries
charged to SLFRF to be reimbursed.Additionally,Subrecipients who function as pass-through
entities must monitor their Sub-Subrecipients for adherence to time and effort tracking
requirements.
Additional resources:
●OSC SLFRF Time and Effort Guidance -Page 2 contains a list of common mistakes and
how to avoid them,as well as a time and effort checklist
●OSC Sample Time &Effort Timesheet
●Time and Effort (2 CFR 200.430)OSC micro training
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Pass Through Entities
When a Subrecipient of the THR program elects to enter into a subaward with another entity
to carry out part of their THR grant,they are considered a Pass Through Entity.
Subrecipients shall not enter into any subaward in connection with its obligations under
this Agreement without the prior,written approval of DOH.See the Subaward Approval
Process section for more information.
All subawards entered into by a Subrecipient in connection with their THR award shall comply
with all applicable federal and state laws and regulations,shall provide that they are
governed by the laws of the State of Colorado,and shall be subject to all provisions outlined
in their THR Grant Agreement.
Pass Through Entity Responsibilities
Pass Through Entities are responsible for,at minimum:
●Maintaining written policies and procedures that cover all requirements of the THR
program,including those established by 2 CFR Part 200.
●Maintaining written,appropriate documentation in accordance with their policies and
procedures,and producing the appropriate documentation when requested,such as
for DOH monitoring.
●Ensuring that each Subrecipient and/or Subcontractor shall obtain and maintain
insurance as required under this grant at all times during the term of their subaward.
All insurance policies required by the THR grant that are not provided through
self-insurance shall be issued by insurance companies as approved by the State.
●Verifying that all Subrecipients’reimbursement requests meet SLFRF requirements and
DOH written policies and procedures prior to submitting reimbursement requests to
DOH.Unless requested,Pass Through Entities should not submit Subrecipients’back-up
documentation to DOH with their pay requests.When submitting pay requests to DOH,
Pass Through Entities should submit an overview of expenses and documentation
signifying that they as the Fiscal Agent have reviewed all pay request documentation
from Subrecipients and deem all expenses to be documented and eligible.
●Collecting and combining all reports from Subrecipients in order to submit one
consolidated report on the project's THR funds to DOH.As noted above,Pass Through
Entities should not submit the Subrecipients’back-up documentation to DOH unless
requested,but they are responsible for maintaining and producing it when requested.
●Conducting regular monitoring of Subrecipient files and documentation to ensure that
all written standards are being met.Pass Through Entities should not submit that
back-up documentation to DOH,but are responsible for maintaining it in accordance
with written standards,and will be monitored on this documentation during
monitoring.
●Providing technical assistance to Subrecipients about basic THR policies,procedures,
and written standards in accordance with these policies and procedures,as needed.
Pass Through Entities are able to add additional expectations to their Subrecipients,in
so far as those expectations do not conflict with what is written in these policies and
procedures or what is required per 2 CFR Part 200.If a Pass Through Entities intends to
place additional expectations on Subrecipients,it must notify DOH prior to doing so.
●All Pass Through Entities must allow the 10%de minimis rate to their Subrecipients if
the Subrecipient does not have a NICRA with the federal government.
Additional resource:This OSC checklist provides additional information on requirements to
Subrecipients serving as Pass Through Entities.
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Subaward Classification
2 CFR Part 200.1
Pass Through Entities make subawards to Subreceipients or Subcontractors.For additional
information on Subrecipient and Subcontractor determinations,see 2 CFR 200.331.
Subrecipient
A Subrecipient is an entity,usually but not limited to non-Federal entities,that receives a
subaward from a Pass Through Entity to carry out part of a Federal program;but does not
include an individual that is a beneficiary of such award.
If a THR Subrecipient enters into a subward with Subrecipients of their own,they would be
considered “Sub-subrecipients”to DOH.
Characteristics indicative of a procurement relationship with a Subrecipient:
●Is responsible for programmatic decision making
●Will determine who is eligible to receive what federal assistance
●Measures performance based on meeting objectives of federal program
●Is responsible for ensuring federal requirements outlined in the award are followed
●Uses the federal funds to carry out a program of the organization as opposed to
providing goods or services
●Is responsible for reporting
An example of a Pass Through Entity subawarding to a Subrecipient would be a county that
received a THR grant from DOH (a DOH Subrecipient now also a Pass Through Entity)entering
into a subaward with a nonprofit shelter provider (their Subrecipient)to provide shelter
services at the nonprofit’s facility under their THR award.
If the entity with whom the Pass Through Entity enters into a Subaward is determined to be a
Subrecipient,then the written agreement entered into must contain provisions permitting
both the Pass Through Entity and the State to perform all monitoring of that subaward in
accordance with the Uniform Guidance.
Subcontractor
A Subcontractor means an entity that receives a contract as defined by the Uniform Guidance
as a legal instrument by which a Subrecipient purchases property or services needed to carry
out the project or program under a Federal award.
An example of a Subcontractor would be a nonprofit shelter that received a THR grant from
DOH (a DOH Subrecipient now also a Pass Through Entity)entering into a contract with a
mental health provider (their Subcontractor)who will provide care to clients at the shelter
and provide care under their THR award.
Characteristics indicative of a procurement relationship with a Subcontractor:
●Provides the goods and services within normal business operations
●Provides similar goods or services to many different purchasers
●Normally operates in a competitive environment
●Provides goods or services that are ancillary to the operation of the Federal program
●Is not subject to compliance or reporting requirements of the Federal program as a
result of the Agreement
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Subaward Approval Process
If an awarded THR Subrecipient intends to subaward for the service provision outlined within
their approved Scope of Work,the selection and approval of those Subrecipients or
Subcontractors must be done in conjunction with OHI staff.
To request approval of an entity for a subaward,the Subrecipient must email the request to
relevant DOH staff.Criteria reviewed by DOH in making the subaward approval determination
include if the entity is in good standing with the Colorado Secretary of State,has an active
SAM.gov registration with no exclusions,has a history of monitoring findings with other DOH
awards,commits to utilize HMIS for any relevant grant activities,and complies with all the
insurance requirements outlined in the grant agreement.
Working with DOH staff,the Subrecipient must identify if subawards will be Subrecipients or
Contractors before making an award.This OSC determination tool provides definitions,as well
as characteristics of beneficiaries,Subrecipients,and Subcontractors.This document should
be consulted before ARPA funds are awarded.
THR Subcontractor Expectations Guidance
After assessing the criteria outlined in the Uniform Guidance relating to subawards using the
OSC’s Subrecipient,Beneficiary,or Contractor Classification Checklist,if an entity receiving
funds through a THR subrecipient is determined to be a contractor and not a recipient or
beneficiary,then they will be considered a vendor.
In approving the requested subaward for a subcontractor,DOH staff will ensure that:
●The UEI for the vendor is collected
●The entity in good standing with the Colorado Secretary of State
●The entity has an active SAM registration with no exclusions
●The subrecipient has followed the applicable Procurement requirements still apply to
the entity as they would for any purchase
Insurance requirements outlined in the grant agreement are required to be met by all
subrecipients,but not of vendors.
In monitoring,DOH staff will review backup documentation for subawards of the THR grantee,
including a sampling of procurement documentation,contracts/scopes of work,proof of
service/proof of payment,documentation of completion.
Procurement Standards
A Subrecipient shall use its own documented procurement standards when selecting the
entities it will subaward THR funds to prior to making subawards and requesting DOH
reimbursement.
These standards must reflect applicable State,local,and Tribal laws and applicable
regulations,provided that the procurements conform to applicable Federal law and the
standards identified in the Uniform Guidance,including without limitation,2 CFR 200.318
through 200.327 thereof.
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Procuring Subrecipients should occur in an open and competitive fashion,in alignment with
DOH Procurement policies and 2 CFR Part 200.If Subrecipients do not plan to use a
competitive application process to allocate their DOH THR funds,the Subrecipient must
follow DOH’s procurement standards or written standards of their own that follow federal and
state procurement requirements,which will state why the Subrecipient has forgone the
competitive process and include a signature of a procurement officers who can verify that the
decision follow all required expectations.
Financial Management
2 CFR 200.302
Subrecipients are responsible for tracking both income and expenses and must be easily
identified within their accounting system for all federal awards received and expended.At
any time,Subrecipients should be able to produce source documentation which consists of
receipts,contracts,payroll documents,and more that support the request for reimbursement
and that source documentation should exactly match the Subrecipient's accounting records
and the request for reimbursement that they submitted to DOH.
For example,if DOH requests backup documentation from a Subrecipient for quarter one,the
Subrecipient should be able to print their accounting records and provide backup
documentation for all transactions related to the grant.Any requests for costs that cannot be
documented must be reclaimed by the state awarding agency.
Internal Controls
2 CFR 200.1 –Definitions
An internal control is a process,carried out by an entity’s oversight body,management,and
other personnel that provides reasonable assurance regarding the achievement of objectives
in the effectiveness and efficiency of operations,reliability of financial reporting,and
compliance with applicable laws and regulations.
Internal controls are the measures to ensure that the things we want to happen will happen,
and the things we don’t want to happen won’t happen.
Waste or misuse of federal/state/local government assets,inaccurate or incomplete
information,embezzlement,and fraud can result if proper internal controls are not in place.
Characteristics of a good internal control system include:
●Continuous processes built into operations
●Processes that are accomplished by people,not only policies,procedures,and forms
●Processes that are adaptable to the entire agency or department
●Processes that provide reasonable assurance (not absolute assurance)that assets and
resources are safeguarded
●Documented processes that can be provided to auditors
●Tailored processes to the unique operations and degree of complexities for each entity
Internal controls are not only good practice,but are required when using federal funds.Per
Uniform Grant Guidance,Section 200.303-Internal Controls,2 CFR 200.303 --Internal
controls,the Non-Federal Entity must:
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●Establish and maintain effective internal controls
○Provide reasonable assurance that the non-Federal entity is managing the
Federal award in compliance with Federal statutes,regulations,and the terms
and conditions of the Federal award.
●Evaluate and monitor compliance
○Remain compliant with statutes,regulations and the terms and conditions of
the Federal award.
●Take prompt action on audit findings
○Take prompt action when instances of non-compliance are identified,including
non-compliance identified in audit findings
●Safeguard protected personally identifiable information (PII)
○Take reasonable measures to safeguard PII and other information the Federal
awarding agency or Pass Through Entity designates as sensitive consistent with
applicable Federal,state,and local laws regarding privacy and obligations of
confidentiality (this includes Social Security numbers,credit card numbers,
etc.).
DOH Subrecipients must utilize appropriate internal financial controls to track and document
THR expenditures.These controls should align with Generally Accepted Accounting Principles
(GAAP).This requires Subrecipients to have written:
●Separation and segregation of duties,which ensures that no one staff person has the
responsibility for every financial component
●Budget controls for tracking all THR-funded budget expenditures.This includes
strategies to track expenditures over time to ensure the timeliness of grant spend
down,reconciliation for projected budgets and actual expenditures
●Accounting Controls that track THR funds by sources and uses by fund type by program
year.This includes accounting for sources and uses of all funds,including but not
limited to THR funds and activities
●If a Subrecipient uses cash,they must have cash controls in place that align with 2 CFR
Part 200 Cash Control expectations
Internal Control Framework is a standard way to organize,document,and discuss internal
controls.Subrecipients shall use the Green Book,published by the U.S.Government
Accountability Office (GAO),as its framework.The Green Book includes five interrelated
components –control environment,risk assessment,control activities,information and
communication,and monitoring –as well as 17 principles that work together to form an
effective internal control system.
Internal control principles help management achieve a strong internal control system by
supporting the effective design,implementation,and operation of the five interrelated
components.
Fraud,Waste,&Abuse
Both the Division of Housing and its Subrecipients,are responsible for preventing and
detecting fraud,waste,and abuse of the federal funds received.
Additional resource:This resource from the OSC provides helpful information to provide
basic understanding of fraud,waste,and abuse,as well as steps to take if detected.It
includes specifics about SLFRF funds.
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Program Income
2 CFR 200.307
The intent of the THR grant awards is that grants do not have program income.Should a
Subrecipient identify that they have program income related to their THR grant,they must
notify DOH immediately.
When a project earns money from services that are supported with federal funds that is called
program income.Program income can be earned in many ways,such as:
●Income from services provided.This is probably the most common form of program
income.
○Example:Mental health agencies whose therapists are paid by grant funds may
offer sliding scale fees for clients.These fees from those grant funded services
are considered program income.
●Income from rental,real property,or personal property procured under federal awards
○Example:If a piece of real property,say a medical facility,was purchased using
federal dollars and a portion of it is rented to a local company,that rental
income would be considered program income.
●Interest earned from loans made with federal award funds
○This would be the repayment interest that is associated when a loan principal is
funded with federal funds.
○Interest earned on advances of federal funds is not program income.
For more information on what constitutes “Program Income”please see 2 CFR 200.1.
Per the SLFRF Final Rule:Frequently Asked Questions,the US Treasury specified that
Recipients may add program income to the federal SLFRF award.Any program income
generated from SLFRF funds must be used for the purposes and under the conditions of the
federal award.
Accounting for Program Income
●Recipients and Subrecipients must carefully account for the program income.
●Program income should be calculated,documented,and recorded within the
accounting system.
●Any project earning program income should have strong internal controls that clearly
define:
○Allocation methods -how program income is allocated
○Accounting standards and principles
○Compliance monitoring for income calculations and records
Additional resource:OSC Microtraining on Program Income
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Match or Cost Sharing
2 CFR 200.306
Match,or cost sharing,is the portion of the total cost associated with a project that the
federal award does not cover.It includes all contributions,including cash and in-kind,that a
Subrecipient makes to an award.
It is important to carefully read the specific requirements associated with match as described
by DOH.
Only acceptable non-federal costs qualify as match or cost sharing and must conform to other
necessary and reasonable provisions to accomplish the program objectives.Match or cost
sharing can be audited and must be allowable under cost principles and verifiable to records.
General Considerations
●Funds must be spent on eligible THR activities per the grant agreement and program
guidance in order to be counted as match
●All amounts designated as match must be verifiable and documented
●To qualify as match,costs must be reasonable and necessary to accomplish the project
●Failure to secure the required match may reduce the amount of the grant award,or
result in compliance findings
●Clear procedures should be established in consultation with accounting staff that
document fair market value,time tracking,and internal controls for cash donations
Types of Allowable Match
There are a few allowable types of match:
●Indirect costs not claimed -If the actual indirect costs are higher than the limit able
to be charged to the grant,the costs exceeding the cap may be considered as match,
with written permission from DOH.For example,a portion of a program director's
salary that is not funded by other federal or state grant funding.
●Cash match
○For cash donations,written documentation is required,such as a receipt,
written documentation from the donor,and/or an acknowledgement letter
from the Recipient.
●Volunteer hours -If the program relies on volunteers for program purposes or if
volunteers are utilized for training,technical assistance,or other professional roles,
those hours may be considered as match
○The value of volunteers for match must be credibly established according to
fair market value
■Independent Sector has useful resources to determine the fair market
value of volunteer service
●In-kind or donated goods -Must determine the fair market value of space,land,
equipment,or supplies as long as those goods directly benefit the program.
○The value of in-kind or donated goods for match must be credibly established
according to fair market value
■The cost of the donated equipment if it were to be purchased,could be
established
○The Donor must establish the value and verification of fair market
reasonableness
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Unallowable Match
●Unless specifically stated as allowable,funds from other grant federal funds cannot be
used as match for a different federal agency
●Unverifiable funds
●Funds not in accordance with Cost Principles
●Any other exclusion noted by the funding entity
Rules to Follow
●Failure to meet minimum match requirements will may reduce the amount of the
grant award,or result in compliance findings
●Match must be verifiable
●Ensure match is not used for any other purposes.Your THR match cannot be included
as match for other federal awards (double dipping)
●Match costs must be necessary and reasonable for accomplishment of the program
objectives
●Match costs must adhere to cost principles allowable under Subpart E -Cost Principles
●Match costs are not funds from another federal award,unless explicitly permitted
●Match costs are detailed in the approved budget submitted to DOH
●Remember,match is required to be reported in the same manner as federal funds
Additional resource:
●OSC Match Micro Training
●OSC SLFRF –Cost Sharing and Match
Grant Reimbursement
THR grants will be processed on a reimbursement basis.That means,the grant funds are
distributed based on actual expenditures (not estimates)and only for costs that have already
been incurred and paid for by sub-recipients.
All costs must be supported by back-up documentation and retained by the Subrecipient until
the end of the documentation retention period,as defined by the grant.
Income from a grant can never exceed the expenses incurred by the Subrecipient.
Grant reimbursement requests must be:
●Based on actual expenditures
●All expenditures must be supported by back-up documentation (i.e.receipts,payroll)
●Subrecipients are reimbursed for costs previously incurred and paid
●State agencies must make payment within 45 calendar days of receipt of the final
reimbursement request.Incorrect reimbursement requests will be returned to the
Subrecripient until they are correct.
Federal Funds Advances
State Fiscal Rules require grants to be paid through a reimbursement process to protect both
Subrecipients and the State.However,in some cases,advance payments may be acceptable if
reimbursement causes undue hardship.If an advance is approved,it must be limited to the
minimum dollar amount and for the minimum time needed to be in accordance with actual,
immediate cash requirements.Advances must be deposited and maintained in insured
accounts.
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Advances Fund Approval Process
Advances are not given as a normal course of action and must be carefully reviewed to
confirm a true business need.This may only happen if the Subrecipient can prove significant
financial burden due to the reimbursement model.
Should a THR Subrecipient feel that an advanced payment is necessary,they must submit this
request to DOH in writing with rationale provided as to the specific circumstance where
payment on a reimbursement basis would cause undue hardship,and what the actual
immediate cash requirements are for the THR program.
DOH will consider this request and,if in agreement,will consult the OSC for approval.
Advance payment must be pre-approved in writing by DOH before this pay request method
can be utilized.
Interest on Advances
If an advance is requested and approved,any interest on advance payments must be tracked
and reported.Additionally,per 2 CFR 200:
●Advanced payments must be deposited into interest-bearing accounts unless:
○Subrecipients receive less than $250,000 in federal awards annually or
○Account would earn less than $500 annually or
○A minimum balance requirement is too high
●Interest up to $500 per year may be retained as an administrative expense
●Any additional interest must be remitted annually
Additional resource:OSC Financial Management Micro Training
Supporting Documentation
2 CFR 200.302 and .403
Subrecipients are required to maintain both financial and programmatic supporting
documentation as described below.Please note that the terms client,beneficiary,individual,
and participant are used interchangeably within the THR Policies &Procedures,unless
otherwise mentioned.
Pay Request Supporting Documentation
Supporting documentation is the foundation used to support accounting and cost records.The
documentation should provide the means to verify proper segregation of spending between
various Federal awards and non-Federal expenditures.Sound documentation is central to
ensuring funds are obligated and spent as they were intended by the Federal award.
The extent of the documentation required is affected by the size and complexity of the
Subrecipient’s organization and funded program,as well as the existing internal control
mechanisms of the Subrecipient organization.The type of the documentation needed depends
on the nature of the goods delivered or services performed.
Pay request supporting documentation submitted to DOH must not include Personal Identifying
Information (PII)about Program Participants.PII can include,but is not limited to,names,
date of birth,social security numbers,etc.The address for Domestic Violence Shelters should
also be redacted from any supporting documentation provided for Domestic Violence Shelter
Providers.Please see the PII section below for additional information.
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For more information on Pay Requests,including important timelines,detailed instructions
and best practices please see our full THR Pay Request Procedure in appendix A.
Examples Of Pay Request Supporting Documentation
●General ledger and subsidiary ledgers used to account for
○Payments made for eligible expenses
○The receipt of federal award payments
●Budget records for the period of performance and evidence as to whether the cost was
budgeted before or after the inception of the federal award.If before,additional
notation describing how the use of that budget item is substantially different than
what was intended as well as how it was allowable
●Subawards entered into relating to the THR award,outlining specific description of
tasks performed by Subcontractors or Subrecipients and how the tasks relates to the
activities prescribed in the award
○Written agreements
○Written approval from DOH to enter into the subaward
○All documents related to such contracts or agreements
●Evidence of risk assessments conducted for all Subrecipients
●All documentation of reports,audits,and other monitoring of Subrecipients and
Subcontractors
●Payroll register including name of person paid,payroll period covered,number of hours
or %of time the employee spent on related duties,pay rate,and total amount paid.
○Documentation (which will probably be separate from the payroll register)
showing the number of hours or %of time the employee spent on related
duties,what those duties were,and justification on how such duties were
related.Typical documentation to support allocation of labor time includes
timesheets,work orders,and approved schedules.
●All documentation supporting THR performance measures and outcomes based on
grant agreements,contracts and subcontracts
●All internal and external email/electronic communications related to payments,
training,and all other relevant activities/discussions related to the THR award
●All investigative files and inquiry reports involving THR funding
●Supporting documentation for all pay requests clearly outlining the costs incurred from
either goods purchased,services rendered,or other eligible expenses that can be paid
for through the THR grant agreement.
○Documentation must include both proof of service/cost incurred and proof of
payment.Examples include:
Examples of Supporting Documentation
Proof of Service/Cost Incurred Proof of Payment
Timesheets must explicitly break out actual
time on each THR funded activity and be signed
by the THR employee and their supervisor.
Corresponding paycheck and payroll summary.
(Note that the wage must be included so that DOH
can clearly determine that the rate of pay and the
hours match up with the request.)
Invoices for eligible services,including rent or
utilities paid for on behalf of the participant.Corresponding bank statement or cleared check.
Itemized receipts showing what was purchased,
the amount,and the date of purchase.
Corresponding cleared check,bank statement,or
receipt showing what payment method was used.
Additional resource:OSC Supporting Documentation
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Income Limits for THR Activ ities
As it pertains to Rapid Rehousing,and Eviction &Homelessness Prevention activities for THR
grants,DOH is holding programs accountable to the area median income (AMI)eligibility
levels outlined in HB22-1304 as follows:
●For a household residing in housing on a
rental basis in urban counties,housing
must be targeted to households with an
annual income that is at or below
eighty percent of the area median
income of households of that size in the
county in which the housing is located.
●For a household residing in housing on a
rental basis in rural counties,housing
must be targeted to households with an
annual income that is at or below one
hundred forty percent of the area
median income of households of that
size in the county in which the housing
is located.
●For a household residing in housing on a rental basis in rural resort counties,housing
must be targeted to households with an annual income that is at or below one
hundred seventy percent of the area median income of households of that size in the
county in which the housing is located.
●For a household residing in housing on a home ownership basis in any area of the
state,housing must be targeted to households with an annual income that is at or
below one hundred forty percent of the area median income of households of that
size in the county in which the housing is located.
For THR activities,AMI threshold is determined by the residence of the individual being
served,not the location of the grantee.For a full list of county designations by Urban,Rural,
and Rural Resort -consult the table provided in the THR NOFA on pages 21-23.
It is important to note that Rapid Re-Housing (RRH)is defined in THR grant agreements as a
short-to medium-term supportive housing intervention that provides financial assistance
and/or housing-focused services for households experiencing homelessness to quickly exit
homelessness by securing permanent housing in the community.OHI will be monitoring that
programs maintain documentation of proof of homelessness in beneficiary files.
Bridge Housing provides a temporary place for those who have been matched with a housing
opportunity to safely reside while waiting to move into the housing (e.g.,while logistics for
utilizing the housing resource are being finalized).“Housing opportunities”may include
tenant-based and project-based vouchers,rapid re-housing opportunities,and other
permanent housing resources supported with local,state,and federal resources.Therefore
the target population for Bridge Housing is limited to individuals who qualify for a housing
resource,which is typically a rental subsidy/voucher.
Expectations on the Equitable Distribution of Resources
DOH recognizes that these AMI eligibility thresholds outlined in HB-1304 are significantly
above the income limits set for similar programs [30-50%for HUD’s Emergency Solutions
Grants (ESG);50%for DOH’s Emergency Rental Assistance Program (ERAP)program].While
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Maximum Area Median Income Limits of Households
Served by THR RRH/EHP Activities
Household Basis Location AMI
Maximum
Rental Basis Urban Counties 80%AMI
Rental Basis Rural Counties 140%AMI
Rental Basis Rural Resort
Counties
170%AMI
Homeownership
Basis
All Colorado
Counties
140%
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these AMI thresholds represent the maximum income limits,THR grantees must implement
prioritization practices that ensure the equitable distribution of resources to resolve or
prevent homelessness.
THR grantees must document their program’s prioritization criteria and practices that ensure
that resources are reaching the intended audience of THR grants,as outlined the Preference
section of the THR Grant Agreement’s Scope of Work:
Preference.The individuals prioritized by the grant opportunity are those that but
for this project will most likely not resolve their homelessness on their own.In
particular,this includes individuals with long lengths of homelessness with complex
needs and who are not currently connected to other homeless shelters or programs.
In compliance monitoring for the THR program,DOH staff will be monitoring for clear
demonstration of programs prioritizing individuals that would most likely not resolve
homelessness on their own for THR resources.This would include documentation on
prioritization criteria and practices within the program’s policies and procedures,evidence of
training of relevant staff to these policies and procedures,staff that when asked can explain
these policies and procedures,and outcomes that reflect the successful implementation of
prioritization.
DOH will be monitoring that resources are not disproportionately being allocated to clients
with higher income levels that would have a lower risk of becoming homeless.In the event
that “creaming,”defined as the process of intentionally admitting individuals expected to
have the best program outcomes as a tactic to improve program outcomes,is detected DOH
will take disciplinary action.
THR Referral Plan
The Department of Local Affairs (DOLA),Division of Housing (DOH),Office of Homeless
Initiatives (OHI)works with local,state,and federal stakeholders to build,promote,and
support collaborative approaches to make homelessness rare,brief,and one-time in
Colorado.
No single individual,agency or organization can solve homelessness alone.A strong
homelessness response system is built on partnerships across agencies,organizations,and
community leaders.
Coordinated Entry is a proven solution in ending homelessness.Coordinated Entry is a process
developed to ensure that all people experiencing a housing crisis have fair and equal access to
resources and are quickly identified,assessed for,referred,and connected to housing and
assistance,based on the person’s needs.
These standardized and coordinated systems of care over a given geographic area help ensure
that homelessness services are provided equitably,efficiently,and effectively.The
collaborative distribution of limited resources prioritized by the needs of the most vulnerable,
is at the core of Coordinated Entry.
The Division of Housing expects that Transformational Homelessness Response (THR)grant
program projects participate with their local Continuum of Care’s (CoC)Coordinated Entry
(CE)process,and utilize referrals through CE as outlined in this referral plan,once approved
by DOH staff,wherever possible.
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However,the Division of Housing also recognizes that there are inequities across the state
that contribute to less developed Coordinated Entry systems and that some program models
by design require alternative referral processes.Each program must,at minimum,outline
how it will prioritize referrals with the highest need for resources.This prioritization must be
based on evidence-based evaluations that use objective assessments rather than subjective
procedures like first come,first served or behavioral obligations like sobriety.Programs may
target specific populations (i.e.families,veterans,etc.).If programs are not using
coordinated entry for referrals,they should ensure that they are connecting clients to local
coordinated entry systems in order to connect people to housing once they exit programs.
Each THR funded project must complete the Referral Plan form provided by DOH staff for
your THR program’s activities.DOH staff will send all THR grantees a form to complete.
Referral plans indicate how programs will identify eligible participants for services,as well
identify the program’s criteria/process for the prioritization of resources.In compliance
monitoring for the THR program,DOH staff will be monitoring for clear demonstration of
programs prioritizing individuals that would most likely not resolve homelessness on their own
for THR resources.This would include documentation on prioritization criteria and practices
within the program’s policies and procedures,evidence of training of relevant staff to these
policies and procedures,staff that when asked can explain these policies and procedures,and
outcomes that reflect the successful implementation of prioritization.
Beneficiary Documentation or Client Files
Subrecipients are required to maintain documentation on beneficiaries in client files.A
beneficiary or client is an individual who is the end user of assistance and receives the
benefit,examples include recipients of housing assistance and services.
Below is a list of examples of beneficiary documentation or supporting documentation that
will be kept in your client files and/or in the HMIS.Please be aware that this is a lengthy list
of all possible forms of documentation.Not every piece will be applicable to every program or
project.We encourage you to meet with your Grant Specialist to work through any specific
needs.
Examples of Beneficiary Documentation by Program Activity
Street Outreach
●INTAKE
○HMIS intake form
○HMIS Release of Information (ROI)
○Documentation of staff (Case Managers)assigned to the individual
●SERVICES
○Services provided
■Referrals or services provided to client
○Case Management notes
●EXIT
○HMIS exit form
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■Includes exit date &destination
Emergency Shelter
●INTAKE
○HMIS intake form
○HMIS Release of Information (ROI)
○Lead based paint notice (if applicable)
○Documentation of staff (Case Managers)assigned to the individual
●SERVICES
○Services provided
■Referrals or services provided to client
○Case Management notes
●EXIT
○HMIS exit form
■Includes exit date &destination
Transitional Housing
●INTAKE
○HMIS intake form
○HMIS Release of Information (ROI)
○Documentation of eligibility for Transitional Housing services under the program
○Referral Information
■Documentation of how this individual was referred for services
○Residency Declaration (if a government)(for all adults in household)
■Self-declaration of residency form
●Photo ID or driver’s license or bill with name and address
●This is not required to be retained,but this record can be very
helpful in the chance that the individual loses their photo ID
○Duplication of benefits attestation
○Lead based paint notice (if applicable)
○Documentation of staff (Case Managers)assigned to the individual
●SERVICES
○Services provided
■Referrals or services provided to client
○Case Management notes
○Regular reassessment
■Updates on income,connection to services,progress toward case
management goals,needed services for stability,continued eligibility
●EXIT
○HMIS exit form
■Includes exit date &destination
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Bridge Housing
●INTAKE
●HMIS intake form
○HMIS Release of Information (ROI)
●Documentation of eligibility for Bridge Housing services under the program
○Must document the permanent housing situation that has been
identified and expected move-in date
●Attestation of no duplication of benefits
●Lead based paint notice (if applicable)
●Referral Information
■Documentation of how this individual was referred for services
○Residency Declaration (if a government)(for all adults in household)
■Self-declaration of residency form
●Photo ID or driver’s license or bill with name and address
●This is not required to be retained,but this record can be very
helpful in the chance that the individual loses their photo ID
○Documentation of staff (Case Managers)assigned to the individual
●SERVICES
○Services provided
■Referrals or services provided to client
○Case Management notes
○Regular reassessment (if applicable)
●EXIT
○HMIS exit form
■Exit resource
●Includes exit date &destination
○Documentation that the client exited to the previously identified resource.If
leaving on a different resource -documentation as to why.
Eviction &Homelessness Prevention
●INTAKE
○HMIS intake form
○HMIS Release of Information (ROI)
○Documentation of eligibility for Eviction &Homelessness Prevention services
under the program
■Must document the risk of homelessness
●Examples:
○Demand for rent or eviction notice
○Landlord’s tenant ledger or account invoice
○Written notice from landlord or property management
○Referral Information
■Documentation of how this individual was referred for services
○Proof of legal lease
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■Proof of utilities in the client's name,if applicable
○Landlord or property manager’s W-9
○Verification that unit is within Fair Market Rent (FMR)or Rent Reasonableness
■Example:HUD Rent Reasonableness Checklist
○Documentation that household meets AMI Limits
■See policy in THR Policy &Procedures Manual
○Housing stability plan for client
■To be used to ensure housing stability will be met with one-time
assistance and homelessness prevented
○Attestation of no duplication of benefits
○Residency Declaration (if a government)(for all adults in household)
■Self-declaration of residency form
●Photo ID or driver’s license or bill with name and address
●This is not required to be retained,but this record can be very
helpful in the chance that the individual loses their photo ID
○Documentation of staff (Case Managers)assigned to the individual
●SERVICES
○Services provided
■Referrals or services provided to client
○Case Management notes
●EXIT
○HMIS exit form
■Includes exit date &destination
Rapid Re-Housing
●INTAKE
○HMIS intake form
○HMIS Release of Information (ROI)
○Documentation of eligibility for Rapid Re-housing services under the program
■Example:A verification of homelessness
○Attestation of no duplication of benefits
○Referral Information
■Documentation of how this individual was referred for services
○Residency Declaration (if a government)(for all adults in household)
■Self-declaration of residency form
●Photo ID or driver’s license or bill with name and address
●This is not required to be retained,but this record can be very
helpful in the chance that the individual loses their photo ID
○Habitability documentation of unit being funded
■Sample habitability checklist:
●HUD Housing Habitability Standards Inspection Checklist
■Lead based paint notice (if applicable)
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○Proof of legal lease
○Landlord or property manager’s W-9
○Verification that unit is within Fair Market Rent (FMR)or Rent Reasonableness
■Example:HUD Rent Reasonableness Checklist
○Documentation that household meets AMI Limits
■See policy in THR Policy &Procedures Manual
○Housing stability plan for client
■To be used to ensure housing stability will be met with one-time
assistance and homelessness prevented
○Documentation of staff (Case Managers)assigned to the individual
●SERVICES
○Services provided
■Referrals or services provided to client
○Case Management notes
○Regular reassessment
■Updates on income,connection to services,progress toward case
management goals,needed services for stability,continued eligibility
●EXIT
○HMIS exit form
■Includes exit date &destination
Permanent Supportive Housing
●INTAKE
○HMIS intake form
○HMIS Release of Information (ROI)
○Documentation of eligibility for Permanent Supportive Housing services under
the program
○Attestation of no duplication of benefits
○Referral Information
■Documentation of how this individual was referred for services
○Residency Declaration (if a government)(for all adults in household)
■Self-declaration of residency form
●Photo ID or driver’s license or bill with name and address
●This is not required to be retained,but this record can be very
helpful in the chance that the individual loses their photo ID
○Habitability documentation
■Sample habitability checklist:
●HUD Housing Habitability Standards Inspection Checklist
●Lead based paint notice (if applicable)
○Proof of legal lease
○Landlord or property manager’s W-9
○Verification that unit is within Fair Market Rent (FMR)or Rent Reasonableness
■Example:HUD Rent Reasonableness Checklist
○Documentation of staff (Case Managers)assigned to the individual
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●SERVICES
○Services provided
■Referrals or services provided to client
○Case Management notes
○Regular reassessment
■Updates on income,connection to services,progress toward case
management goals,needed services for stability,continued eligibility
●EXIT
○HMIS exit form
■Includes exit date &destination
Personal Identifying Information (PII)
Personal identifying information (PII)is information that may be used,alone or in conjunction
with any other information,to identify a specific individual.
PII includes but is not limited to:
●name;
●date of birth;
●place of birth;
●social security number or tax identification number;
●password or pass code;
●official government-issued driver's license or identification card number;
●vehicle registration information;
●license plate number;
●photograph,electronically stored photograph,or digitized image;
●fingerprint;
●record of a physical feature,physical characteristic,or handwriting;
●government passport number;
●health insurance identification number;
●employer,student,or military identification number;
●school or educational institution attended;source of income;
●medical information;
●biometric data;
●financial and tax records;
●home or work addresses or other contact information;
●family or emergency contact information;
●status as a recipient of public assistance or as a crime victim;
●race;
●ethnicity;
●national origin;
●immigration or citizenship status;
●sexual orientation;
●gender identity;
●physical disability;
●intellectual and developmental disability;
●or religion.
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Do not send DOH emails with PII,or upload pay request supporting documentation
containing PII.Doing so puts the personal protected information of staff and clients at risk
and may result in monitoring findings or additional disciplinary actions.
Best Practices for PII
●Subrecipients must maintain strong PII policies and procedures within their
organization and train all employees on the collection,use,and protection of PII
○Include within training discussing PII requests with a supervisor before
responding
●Limit Collection of PII
○Do not ask for PII from individuals or partners that is not required by your
program
○Refuse PII from individuals or partners if it is not required by your program
●Immediately Destroy PII that is not required by DOH
○Immediately shred and secure hard copy PII that was not requested
○Immediately delete emails and files with PII that is not needed using the
two-step process described below
●Protect Hard Copy PII (including paper,thumb drives,CDs,other removable media)
○Do not copy documents with PII onto thumb drives,CDs or other portable media
without explicit permission from your supervisor.
○Label all documents,thumb drives,CDs containing PII will be labeled with “For
Official Use Only”
○Do not leave hard copy files or electronic media unattended.Lock them
secured file cabinets when not in active use and absolutely every night.
●Protect Electronic Files with PII
○Limit storing electronic files with PII.If the material is printed,the electronic
file should be deleted immediately using the two-step process described below.
If the electronic file is maintained,it must be stored on a secured network
drive in a program file that is known to contain PII.Discuss this location within
your organization’s PII policies and procedures
○Do not store PII on local computer desktop or drives
○Immediately delete emails that contain PII in the body or as attachments using
the two-step process described below
●Protect Fax Transmissions of PII
○Do not fax out PII unless absolutely necessary
○If you do fax out PII,coordinate with the recipient so they are available to get
the fax immediately and confirm receipt of the fax with the recipient
●Protect Emailed PII
○Receiving PII Emails
■If PII is in the body of the email that DOH must keep,print or save the
information and delete the email immediately using the two-step
process described below.
■If PII is in an attachment that DOH must keep,print or save the
document and delete the email immediately using the two-step process
described below.
●Sending PII emails
○If PII must be sent by email,encrypt the email by typing ENCRYPT in the
subject line of the email
●Avoid creating other electronic PII
○Do not put PII on shared calendars or intranet or internet sites.
●Protect Mailed PII
○Create and maintain a policy and procedure for mailed PII such as:
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■Mail will be opened by one person on each floor.Mail addressed to you
will be put in your mailbox.Check your mailbox every day.If you
receive mail with PII,follow best practices above for hard copy PII
●Mailing out PII
○Do not to mail out PII unless absolutely necessary
○If you do mail PII,make sure the item is addressed to a specific individual with
a complete mailing address
○Use a delivery service with tracking if possible
●Protect PII Security While Telecommuting
○Do not print any PII at home
○Do not download or save documents with PII to your home computer
●Use Two-Step Process to Permanently Delete Emails
○From your email inbox,select the email and click on the trash can to delete
○Go into your “Trash”folder and again highlight the email and click on “delete
forever”
●Use Two-Step Process to Permanently Delete Electronic Files
○Right click on the file name and select “delete”
○Open the “recycle bin”on your desktop and again select the file,right click,
and permanently delete
Third Party Entity Access to PII
Per State law and as outlined in the grant agreement,THR Subrecipients can not use or
disclose any PII for the purpose of investigating for,participating in,cooperating with,or
assisting Federal Immigration Enforcement*.
This includes:
●The enforcement of civil immigration laws
●The Illegal Immigration and Immigrant Responsibility Act
*Unless required to do so to comply with Federal or State law,or to comply with a
court-issued subpoena,warrant or order.
Record Retention
All federal and state funds have retention timelines for supporting documentation,reports,
beneficiary data,and all other records document how an award was used.
According to US Treasury Terms and Conditions,section 4.c.,SLFRF records must be
maintained for a period of 5 years after all funds have been expended or returned to Treasury.
This means that these records must be maintained for 5 years following the end of the period
of performance.So,if a THR’s period of performance were to end on 12/31/26,records then
must be maintained through 12/31/2031.
Both DOH and the US Treasury must be able to access these records at any point within that
record retention period of 5 years.
For a Subaward the record retention period begins at the date of submission of the final
expenditure report by the Subrecipient to Pass Through Entity.Subrecipients shall comply
with appropriate federal records retention period and local records retention policies.
If litigation or an audit is started before the expiration of the retention period,the records
must be retained until all litigation or audit findings have been resolved.The governing
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documents for this grant program may outline a variety of required periods for record
retention,agencies shall comply with the longest records retention required,which is 5 years
under the US Treasury’s Terms and Conditions for SLFRF funds.
Additional resource:
●OSC SLFRF Grant Records Retention Guidance
●Eligibility (2 CFR 200.203(b)(5))Micro Training
Pay Requests
In general,funds awarded through THR will be paid out with a reimbursement model.This
means that Subrecipients expend THR funds and then submit a request to DOH for
reimbursement.Costs eligible for reimbursement may only include allowable activities
incurred within the timeframe of the THR grant agreement.Costs that are not eligible per the
THR grant agreement or those incurred outside of the THR grant agreement timeframe will
not be reimbursed.
DOH would prefer reimbursements be submitted on a monthly basis.Reimbursement requests
must,at minimum,be submitted to DOH on a quarterly basis.Subrecipients are allowed to
submit reimbursement requests more frequently,if needed.
Pay requests must be submitted to your THR Grant Program Specialists through the designated
system,Access Gov (https://bit.ly/THRpayrequest),and must include the following:
■THR Pay Request Cover Sheet Expense Log which includes identifying the total
requested amount and documented match for each funded activity.This Cover
Sheet also includes a breakdown of the requested amount from each expense/line
item included in that pay period’s request,noting which two pieces of supporting
documentation are connected with that expense and where to find them in the
corresponding supporting documentation packet.
■Supporting documentation for items requested for reimbursement as requested by
DOH (described in more detail in the Supporting Documentation section below)
DOH staff will review the reimbursement request and submitted documentation as requested
to ensure all costs are eligible for reimbursement through THR,and that supporting
documentation matches all costs accrued.If any errors or discrepancies are found,DOH staff
will return the payment to the Subrecipient with specific instructions for any corrective
actions or additional documentation as needed. Reimbursement payments will be made to the
Subrecipient within 45 days of receipt of the final approved payment request.
The THR grant program requires at least three consecutive months of complete and accurate
pay request submissions with full backup documentation to ensure that THR grantees
understand the grant’s financial management requirements,and have built sufficient systems
to meet them.After the Division of Housing has approved three consecutive pay requests on
their first submission (i.e.without the THR Program Specialist returning the pay request for
required edits and resubmission),the Division may elect to no longer require submission of
the full backup documentation for pay requests.Should this occur,the THR Program Specialist
will notify the agency’s pay request point of contact that full backup documentation is no
longer required to be included with submission of subsequent pay requests.The THR pay
request process will then only include the Access Gov submission with the corresponding cover
sheet uploaded.
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The THR grantee is still required to collect and retain the full backup documentation
corresponding to each pay request as outlined in the Supporting Documentation section of the
THR Policies and Procedures -they just are no longer required to submit it for review by the
Division each month.The Division may at any time request the backup documentation be
submitted,and it will be reviewed during program monitoring
For more information on Pay Requests,including important timelines,detailed instructions
and best practices please see our full THR Pay Request Procedure in appendix A.
Reporting
HMIS Setup
DOH THR Subrecipients are required to use the Homeless Management Information System
(HMIS),as noted in the grant agreement.
The HMIS is a locally-administered database that collects,stores,and centralizes real-time
data about people experiencing homelessness and housing opportunities.To maximize HMIS
and effectively capture real-time client-and community-level data,the HMIS data entry
should be timely,consistent,accurate,and complete.
The DOH THR performance reports are based on the HMIS information such as project
enrollments,move-ins,benefits,and project exits.Therefore,it is important that each DOH
THR Subrecipient properly sets up their THR project in the HMIS,enrolls participants in the
HMIS project,and completes ongoing data entry for participants within the HMIS project.
Further details on the HMIS requirements are listed in Exhibit A of the DOH THR grant
agreement and below under Expectations.
If your agency is brand new to the HMIS,please visit the COHMIS website and use the
“Submit a request”button.In your request,complete and submit the Colorado HMIS New
Agency Questionnaire found in Agency Forms.Your request will be directed to the
appropriate HMIS Lead Agency staff within your Continuum of Care (CoC).For more
information on the different CoCs,see the CoC Information page.
If your agency is already in the HMIS and you are familiar with the process for setting up new
projects and/or staff training/access in your CoC,please follow that process by completing
and submitting the Colorado HMIS Program and Inventory Setup Request Form found on the
COHMIS Help Desk.See THR specific Project Setup Guidelines for this form below.If you are
not sure who your CoC HMIS Lead Agency is and/or the process to follow,please visit the
COHMIS website and use the “Submit a request”button.In your request,it’s a good idea to
include your agency name,location,the project type,start date,and funding type.
Once your THR project has been set up in the HMIS,please email your THR specialist
with the HMIS agency name,project name,and reporting contact(s)(i.e.,person(s)with
HMIS Manager Level access who will be running HMIS reports).Please complete a
project set up for each of your funded activ ities:Colorado HMIS Program and
Inventory Setup Request Form Specifics for THR
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HMIS Reporting
THR will gather data from the HMIS and from Subrecipients in a combination of
qualitative and quantitative reporting.Projects should be utilizing the HMIS from the
beginning of the grant period.Subrecipients will be expected to enter all Universal &
Program Specific HMIS Data Elements that are required for the project activity being
operated.Data elements to be entered into HMIS include,but are not limited to:
●All other Universal &Program Specific HMIS Data Elements that are required for
the project type(s)you operate
●Completed quarterly &Annual assessments (these will be necessary for future
custom reporting)
Reporting Dates
➔The reporting period for Annual Reports is 12-months of data (January-December)
(excluding the 2026 Annual Report).
➔The reporting period for Quarterly Reports is the corresponding quarter:
Report Due Performance Period Deadline
2023 Q4 (Round 1 only)10/1/23 -12/31/23 1/31/24
2024 Q1 1/1/24 -3/31/24 4/30/24
2024 Q2 4/1/24 -6/30/24 7/31/24
2024 Q3 7/1/24 -9/30/24 10/31/24
2024 Q4 10/1/24 -12/31/24 1/31/25
2024 Annual Report 1/1/24 -12/31/24 1/31/25
2025 Q1 1/1/25 -3/31/25 4/30/25
2025 Q2 4/1/25 -6/30/25 7/31/25
2025 Q3 7/1/25 -9/30/25 10/31/25
2025 Q4 10/1/25 -12/31/25 1/30/26
2025 Annual Report 1/1/25-12/31/25 1/30/26
2026 Q1 1/1/26 -3/31/26 4/30/26
2026 Q2 4/1/26 -6/30/26 7/31/26
2026 Q3 7/1/26 -9/30/2026*11/13/2026
2026 Annual Report 1/1/26 -9/30/2026 11/13/2026*
*Final spending deadline is 9/30/2026.
**Final reporting deadline is 11/13/2026.
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Important Distinctions
➔Some reporting questions refer to households,some refer to unique individuals.
●Households refers to the group of persons residing under the same roof.This could be
multiple adults and/or children.
●Unique individuals refers to each,separate participant within a household and
enrolled in the HMIS project.
➔Those completing the Annual Report should not simply add up numbers from the
Quarterly Reports.The Quarterly Report asks for cumulative information AND numbers
specific to that stand-alone quarter,so simply adding up Quarterly Report information
could result in counting households multiple times,compiling incorrect information,
and other errors.Please follow the instructions when completing each report.
Monitoring
As a Pass Through Entity,DOH through the Office of Homeless Initiative (OHI)is responsible
for monitoring and providing assurance that all THR Subrecipients are in compliance with
requirements and expectations.
As part of that responsibility,DOH monitors its Subrecipients for compliance with 2 CFR part
576,including the Uniform Administrative Requirements at 2 CFR part 200,and related OHI
standards.As discussed in the Pass Through Entities section,any Subrecipients subwarding
through their THR grant are responsible for monitoring their Subrecipients for compliance.
DOH’s approach to monitoring is two-fold:
●Monitoring is an ongoing process through which DOH and the Subrecipient maintain
ongoing communication around Subrecipient projects and activities,expenses,
documentation,and other THR-related efforts.For example,Grant Program Specialists
process Subrecipients’pay requests while also rigorously assessing use of funds and
back-up documentation.Grant Program Specialists also review quarterly and annual
performance reports submitted by Subrecipients.These reports include HMIS
Consolidated Annual Performance and Evaluation Report (CAPER)as well as qualitative
sections that collect information on program successes and challenges.Addressing
questions,feedback,and/or potential concerns continuously (e.g.,via pay request
review or performance report evaluation)can prevent future compliance issues,
mitigate future inefficiencies,and improve performance and processes.
●Monitoring is also a scheduled formal monitoring session,through which Grant
Program Specialists meet and communicate with their Subrecipients on predetermined
topics,as well as topics that may arise during the session.For the remainder of this
section,“monitoring”refers to this formal monitoring session,rather than the
ongoing process and communication.
Risk-Based Monitoring
DOH monitors THR Subrecipients based these perceived risks (but are not limited to these):
●Being new to managing federally funded grants
●Not being consistent or timely in responding to THR program reporting requirements
●Evidence from payment requests that the agency is not obligating or spending funds in
a timely or allowable manner
●Evidence based on complaints,visual inspection that the Subrecipient is not
performing the funded activities in an appropriate manner
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●Consistent staff turnover,organizational restructuring,or other changes in the THR
program
DOH will complete risk assessment forms for each Subrecipient on an annual basis.DOH
conducts a risk assessment prior to the execution of the grant agreement using a standardized
pre-agreement risk assessment tool,and then annually thereafter utilizing a tool that
captures THR grant performance indicators.Once Grant Program Specialists complete risk
assessment forms for all Subrecipients they will schedule monitoring with agencies as capacity
allows,prioritizing those scored at a higher risk level risk through the assessment.
Types of Monitoring
DOH conducts monitoring in two primary ways,both of which assess the THR Subrecipient’s
grants management and oversight,financial management,services,programming and
eligibility,coordination (e.g.,Coordinated Entry involvement)and data requirements,
facilities,and/or other requirements.Each of these monitoring types requires written
notification and advanced notice from DOH,including a list of items or topics to be reviewed
and other instructions or guidelines on the monitoring process.
●Full Monitoring:On-site review of documentation and other programmatic and
administrative materials to ensure compliance with written standards and DOH and
SLFRF requirements.DOH will conduct Full Monitors virtually,as needed.
●Partial Monitoring:Virtual examination of documents and a self-certification
questionnaire signed by the Subrecipient.
DOH will strive to thoughtfully provide Subrecipients with advanced notice of monitoring.
However,DOH reserves the right to monitor THR Subreceipients at any point should concerns
arise or evidence be presented that lead staff to believe that the Subrecipient may not be in
compliance,operating within the law,or that corrective actions may be necessary.
Outcomes of Monitoring
After a monitoring session and thorough review of materials,DOH notifies THR-funded
organizations with a written monitoring report,which may include findings and/or concerns:
●Findings are based on noncompliance with a statutory,regulatory or program
requirement.Findings are accompanied by and require corrective action.
●Concerns are based on deficiencies or areas of improvement and are not based on a
statutory,regulatory or other program requirement.
Although OHI does not issue corrective actions with concerns,OHI may make note of and offer
guidance,recommendations,or support around the concern.
Performance Improvement Planning
If a Subrecipient’s THR program is found to have programmatic or administrative deficiencies
during any monitoring mentioned above,DOH will develop a Performance Improvement Plan
(PIP)in collaboration with the Subrecipient.The PIPs are designed to provide a formal and
collaborative process for agencies to access technical assistance from DOH,ensure programs
are aligned with all THR requirements,and improve the overall performance of THR-funded
programs.
To create a PIP,DOH staff will schedule one-on-one meetings to discuss outcomes from the
monitoring and create measurable goals with agency staff.PIPs will exist until all identified
goals have been met.Progress will be reported through quarterly reports and will provide an
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opportunity for agencies to discuss with OHI staff what challenges or successes a program has
faced,including an opportunity for agencies to request technical assistance from DOH staff to
assist with meeting goals.
When appropriate,PIP goal forms and quarterly reporting forms may be provided to those
reviewing applications for other DOH funds. This will ensure that program improvements are
included in the review discussions and ensure that DOH funds are used effectively.
Audit Requirements
Audits are rigorous examinations of a program or an entity.Single audits are required for all
entities that receive/expend $750,000 or more in federal funds from grants,awards or other
federal funding in a fiscal year.According to the American Institute of Certified Public
Accountants (AICPA),“entities that receive federal funds including states,local governments,
and not-for-profit organizations (NPOs),are subject to audit requirements commonly referred
to as “single audits”under the Single Audit Act of 1984,as amended in 1996.The Single Audit
Act provides that grantees are subject to one audit of all of their federal programs versus
separate audits of each federal program,hence the term “single audit.”
Single audits contain two main components:financial compliance and programmatic
compliance with the funding requirements.Audits are conducted based upon the OMB
Compliance Requirements for the funding source.There are 12 categories for examination
during an audit.Each federal program has different compliance requirements,although
financial requirements cut across all audit compliance requirements regarding demonstration
of effective internal controls.
If a Subrecipient receives an audit within the timeframe of their THR grant agreement,they
must promptly submit a copy of any final audit report to DOH.Additionally,if the
Subrecipient is required to perform a single audit under 2 CFR 200.501,et seq.,then the
Subrecipient shall submit a copy of the results of that audit to the State within the same
timelines as the submission to the federal government through the Federal Audit
Clearinghouse.
Additional resource:OSC Audits,Special Tests and Provisions Micro Training
Eligible Activ ities and Program Components
The THR policies and procedures align with the OHI Homelessness Program Model Comparisons
document,which are subject to evolution and changes as determined by DOH.
The following sections outline the program components and eligible activities allowable for
the activities for THR grants.
Eligible costs for individual THR grants are limited to the approved activities included within
the THR grant agreement.
General Best Practices
The Department of Local Affairs (DOLA),Division of Housing (DOH),Office of Homeless
Initiatives (OHI)works with local,state,and federal stakeholders to build,promote,and
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support collaborative approaches to make homelessness rare,brief,and one-time in
Colorado.OHI’s vision is to advance a broad continuum of solutions that combines affordable
housing with accessible services so no one languishes in homelessness.This OHI document
describes program models,benchmarks,and outputs &outcomes for responding to and
resolving homelessness.DOH and OHI use this document to guide funding opportunities and
decisions,as applicable based on funding eligibility and availability.The document is a live
document and will be edited periodically.
OHI’s approach to implementing any homelessness program is rooted in evidence-based
philosophies and guidelines,including:
●Utilize Housing-Focused Models.Housing-focused models recognize housing as a
prerequisite to stability and health.The model adheres to Housing First,which
prioritizes housing and voluntary supportive services.The approach is guided by the
understanding that basic needs,such as food and housing,are a platform upon which
individuals can achieve personal goals.Housing First is not just an individual or agency
philosophy.It is also a coordinated,systems-wide approach.Unlike “Housing Ready”,
“Housing Next”,or “Treatment First”,Housing First positions housing as an immediate
priority for individuals experiencing homelessness.Numerous models or strategies
complement Housing First,such as low-barrier programming,trauma-informed
approaches,harm reduction,individual choice,and others.
●Apply Real-Time,Quality Data.Real-time,quality data allows organizations and
communities to understand the scale of homelessness,determine whether strategies
are driving down the number of people experiencing homelessness,and improve
programs,policies,and systems.Additionally,real-time,quality data can capture
information regarding inequities and disparities;improve accountability and
transparency;create a shared understanding of individual housing needs,housing
options,and strategic resource allocation;allow organizations to understand how their
services interact with each other and with other systems (e.g.,inflow into
homelessness and outflow out of homelessness);streamline access to services and
service delivery;prevent inefficiencies,such as retroactive data entry and data user
errors;and be leveraged to build cross-sector partnerships.
●Advance Inclusion,Diversity,Equity,and Accessibility.Inclusion,diversity,equity,and
accessibility (IDEA)are terms related to outreach to and inclusion of diverse
communities,organizations,and individuals who identify with diverse backgrounds,
including but not limited to ethnicity,race,language,national origin,sexual
orientation,gender identity and expression,and ability.In alignment with IDEA
efforts,OHI is committed to undoing inequities that create and perpetuate disparate
outcomes that are evident among homelessness in Colorado.OHI promotes programs
that center lived experiences of homelessness and related systems in leadership and
decision-making,program development,and program implementation.
●Encourage Community-Wide Collaboration.Collaboration is central to making
homelessness rare,brief,and one-time for those who experience it.For that reason,
OHI partners with non-profits,local governments,Continuum of Care entities (CoCs),
and a variety of internal and external stakeholders.OHI encourages collaboration
within communities and across regions,including coordination of services and active
partnerships with CoCs.Additionally,most OHI programs require participation in the
local Coordinated Entry System and the use of the statewide Homeless Management
Information System (HMIS).
Resources:Playbook on Making Homelessness History in Colorado
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Street Outreach
“Street Outreach”is non-facility based and is the act of engaging people experiencing
unsheltered homelessness where they are.“Street Outreach”includes the following eligible
activities:
Engagement and case management:Efforts to provide essential services to
individuals experiencing unsheltered homelessness who are unwilling or unable to
access emergency shelter,housing,or other services or programs.This includes:(i)
making an initial assessment of services need and eligibility;(ii)assessing housing and
service needs and arranging,coordinating,and monitoring the delivery of
individualized services;(iii)coordinating with emergency shelter providers for
immediate access to shelter options,including hotel/motel vouchers;(iv)providing
crisis counseling;(v)addressing urgent physical needs,such as providing meals,
blankets,clothes,or toiletries;(vi)actively connecting individuals to programs and
services,including transportation to needed services;and (vii)other reasonable and
necessary efforts to connect individuals to immediate support,intervention,
connections with housing,homelessness assistance programs,and/or mainstream
social services and housing programs.
Services for behav ioral health,mental health,substance use disorders,and
medical care:Includes a continuum of behavioral health services,treatment,and
crisis intervention that is provided in non-facility settings.Also includes coordination
for access to healthcare-related services including primary care,substance use
treatment,mental health care,vision and dental care,and emergency,crisis,and
inpatient services.Emergency behavioral,mental,or physical health services funded
under this activity may include direct outpatient treatment by licensed professionals
operating in non-facility-based settings.
Educational,vocational,and work-based learning opportunities:Efforts to connect
individuals encountered through outreach with educational,vocational,and
work-based learning opportunities that resolve a household’s homelessness as quickly
as possible.A best practice is for outreach programs to create or connect to peer
mentoring programs and hire peer mentors with lived expertise regarding
homelessness to conduct outreach,as well as contribute to program design and
improvement.
Recovery care and related residential programs:Efforts to connect individuals to
community resources that offer recovery care and related residential programs,
including the cost of transportation to such services and treatment.
Operations:Efforts related to locating and delivering services to individuals
experiencing unsheltered homelessness where they are living and building rapport with
them.This may include (i)physically locating individuals residing in unsheltered
situations;(ii)getting staff to those locations;(iii)ongoing communication (including
cell phones for outreach workers during the performance of these activities);and (iv)
and other reasonable and necessary efforts required to locate and build trust with
those in unsheltered situations.Additionally,this can include mapping the location of
unsheltered encampments as well as upgrading,enhancing,or customizing a database
that can track real-time,geographic data about homelessness outreach efforts.
Grant Activ ities:Efforts focused on administering a specific grant or funding source
may improve effective operations,as well as effective program implementation.Such
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efforts include planning and executing program activities,such as (i)general program
or grant management,oversight,coordination,monitoring,and evaluation;(ii)
salaries,wages,and related costs related to preparing program budgets;developing
systems for ensuring compliance with grant requirements;developing interagency
agreements;and preparing reports and other required documents or activities;(iii)
accounting or other services;and (iv)other reasonable and necessary goods and
services required to implement the grant program,such as evaluating program results
against stated objectives,occupancy costs,and training on program requirements.
Indirect Costs:Pursuant to 2 CFR §200.414,Grant Funds may be used to pay for
indirect costs in accordance with 2 CFR Part 200,Subpart E.Prior to requesting
reimbursement for indirect costs,Grantee must discuss the indirect cost rate with
DOH Key Personnel and submit corresponding documentation to DOH Key Personnel as
requested.
Emergency Shelter
“Emergency Shelter”includes facilities for which the primary purpose is to provide temporary
shelter to people experiencing homelessness and which do not require guests to sign leases or
occupancy agreements and do not charge rent.“Emergency Shelter”includes the following
eligible activities:
Essential services:Efforts to provide supportive services to those who are in an
Emergency Shelter.These services include finding housing options that resolve guests’
homelessness as quickly as possible.Efforts include (i)housing search and placement
and navigation,such as activities to assist guests to locate and obtain housing;(ii)
housing stability case management,such as assessing,coordinating,and delivering
individualized services to obtain housing,developing case management plans,and
support groups;(iii)legal services necessary to resolve a legal problem that prohibits
the guest participant from obtaining permanent housing;(iv)services for physical
health care,mental health care,behavioral health care,and other medical care;(v)
implementing and maintaining diversion programming;and (vi)other reasonable and
necessary costs that help resolve a household’s homelessness,including but not limited
to child care and transportation.
Educational,vocational,and work-based learning opportunities:Efforts to connect
individuals and families with educational,vocational,and work-based learning
opportunities that resolve the individual’s homelessness as quickly as possible.Shelters
may consider creating or connecting to peer mentoring programs and hiring peer
mentors with lived expertise of homelessness to work in the shelter and contribute to
program design or improvement.
Recovery care and related residential programs:Efforts to connect program
participants to community resources that offer recovery care and related residential
programs,including transportation to those services.
Operations:Efforts related to maintenance (including minor or routine repairs),rent,
security,fuel,equipment,insurance,utilities,food,furnishings,and supplies
necessary for the operation of the Emergency Shelter.
Grant Activ ities:Efforts focused on administering a specific grant or funding source
may improve effective operations,as well as effective program implementation.Such
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efforts include planning and executing program activities,such as (i)general program
or grant management,oversight,coordination,monitoring,and evaluation;(ii)
salaries,wages,and related costs related to preparing program budgets;developing
systems for ensuring compliance with grant requirements;developing interagency
agreements;and preparing reports and other required documents or activities;(iii)
accounting or other services;and (iv)other reasonable and necessary goods and
services required to implement the grant program,such as evaluating program results
against stated objectives,occupancy costs,and training on program requirements.
Transitional Housing
“Transitional Housing”is an intermediate step between emergency crisis shelter and
permanent housing.It is more long-term,service-intensive,and private than emergency
shelters,yet remains time-limited to stays of 3 months to 3 years.“Transitional Housing”
includes the following eligible activities:
Essential services:Efforts for supportive services targeted at alleviating identified
barriers for residents who chose to focus on these structured programs.Services may
include (i)housing search and placement and navigation,such as activities to assist
guests to locate and obtain housing;(ii)housing stability case management,such as
assessing,coordinating,and delivering individualized services to obtain housing,
developing case management plans,and support groups;(iii)legal services necessary
to resolve a legal problem that prohibits the participant from obtaining permanent
housing;(iv)services for physical health care,mental health care,behavioral health
care,and other medical care;and (v)other reasonable and necessary costs that help
resolve a household’s homelessness and achieve personal goals,including but not
limited to child care,transportation,parenting education and interventions,home
management and life skills training,and others.
Operations:Efforts related to maintenance (including minor or routine repairs),rent,
security,fuel,equipment,insurance,utilities,food,furnishings,and supplies
necessary for the operation of the facility.
Grant Activ ities:Efforts focused on administering a specific grant or funding source
may improve effective operations,as well as effective program implementation.Such
efforts include planning and executing program activities,such as (i)general program
or grant management,oversight,coordination,monitoring,and evaluation;(ii)
salaries,wages,and related costs related to preparing program budgets;developing
systems for ensuring compliance with grant requirements;developing interagency
agreements;and preparing reports and other required documents or activities;(iii)
accounting or other services;and (iv)other reasonable and necessary goods and
services required to implement the grant program,such as evaluating program results
against stated objectives,occupancy costs,and training on program requirements.
Educational,Vocational,and Work-Based Learning Opportunities:Efforts to deliver
educational,vocational,and work-based learning opportunities within Transitional
Housing that resolve the household’s homelessness as quickly as possible.A best
practice is for Transitional Housing programs to use funds to create or connect to peer
mentoring programs and hire peer mentors with lived expertise of homelessness to
work in the facility and contribute to program design or improvement that are not able
to be funded by other sources.
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Recovery Care and Related Residential Programs:Efforts to provide recovery care
and residential programs within the Transitional Housing,including (i)treatment and
support services;(ii)primary prevention;(iii)recovery support services and
facilitation;(iv)outreach,engagement,pre-treatment,screening,and assessment;(v)
detoxification;(vi)substance use education,treatment,and relapse prevention;(vii)
medical,dental,and other health care services;(viii)specialized assessment,
monitoring,and referrals for education,peer support,therapeutic interventions and
physical safety;(ix)mental health care that includes a trauma-informed system of
assessments and interventions;(x)mental health promotion and assessment;(xi)
education,testing,counseling,and treatment;(xii)the cost of transportation to those
services,if needed;and (xiii)other reasonable and necessary costs related to carrying
out the recovery care and/or residential program.
Bridge Housing
“Bridge Housing”is temporary housing for those who have been matched with a permanent
housing resource to safely reside while waiting to move into housing.“Bridge Housing”
includes the following eligible activities:
Essential services:Efforts to provide supportive services to those who are in Bridge
Housing that are needed to bridge them into permanent housing placements.Activities
include (i)housing search and placement and navigation,such as activities to assist
guests to locate and obtain housing;(ii)housing stability case management,such as
assessing,coordinating,and delivering individualized services to obtain housing,
developing case management plans,and support groups;(iii)legal services necessary
to resolve a legal problem that prohibits the guest participant from obtaining
permanent housing;(iv)services for physical health care,mental health care,
behavioral health care,and other medical care;and (v)other reasonable and
necessary costs that help bridge the gap between securing the housing option and the
housing becoming available,including but not limited to logistics planning,child care,
and transportation.
Educational,Vocational,and Work-Based Learning Opportunities:Efforts to connect
Bridge Housing residents with educational,vocational,and work-based learning
opportunities that will stabilize the household once they transition to permanent
housing.Bridge Housing providers may consider creating or connecting to peer
mentoring programs and hiring peer mentors with lived expertise of homelessness to
work in the Bridge Housing program.
Recovery Care and Related Residential Programs:Efforts to connect residents to
community resources that offer recovery care and related residential programs,
including the cost of transportation to those services,if needed.
Operations:Efforts include maintenance (including minor or routine repairs),rent,
security,fuel,equipment,insurance,utilities,food,furnishings,and supplies
necessary for the operation of the facility.
Grant Activ ities:Efforts focused on administering a specific grant or funding source
may improve effective operations,as well as effective program implementation.Such
efforts include planning and executing program activities,such as (i)general program
or grant management,oversight,coordination,monitoring,and evaluation;(ii)
salaries,wages,and related costs related to preparing program budgets;developing
systems for ensuring compliance with grant requirements;developing interagency
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agreements;and preparing reports and other required documents or activities;(iii)
accounting or other services;and (iv)other reasonable and necessary goods and
services required to implement the grant program,such as evaluating program results
against stated objectives,occupancy costs,and training on program requirements.
Ev iction &Homelessness Prevention
“Eviction &Homelessness Prevention”provides financial assistance and/or supportive and
legal services to prevent households from being evicted and entering emergency shelters
and/or experiencing homelessness.“Eviction &Homelessness Prevention”includes the
following eligible activities:
Housing Search and Placement:Services or activities necessary to assist program
participants in locating,obtaining,and retaining suitable permanent housing,including
(i)assessment of housing barriers,needs,and preferences;(ii)development of an
action plan for locating or maintaining housing;(iii)housing search;(iv)outreach to
and negotiation with owners;(v)assistance with submitting rental applications and
and other lease-up assistance,such as understanding leases;(vi)assessment of housing
for compliance with unit requirements,such as habitability;(vii)assistance with
obtaining utilities and moving arrangements and assistance;and (viii)tenant
counseling.
Housing Nav igation and Landlord Mediation:Assists program participants in obtaining
housing by helping them navigate housing applications,screening criteria,and
relationships with landlords that aim to increase exits to permanent housing with
ongoing support.This staff capacity may provide services to landlords to de-escalate
any challenges that arise with program participants,with the goal of avoiding evictions
or exits to homelessness.This can also include providing services and life skills for
program participants to equip them with understanding tenant responsibilities and
other skills that may be needed to achieve long-term housing stability.
Housing Stability Case Management and Tenancy Support Services:Efforts to assess,
arrange,coordinate,and monitor the delivery of individualized services to facilitate
housing stability for a participant who resides in permanent housing or to assist a
participant in overcoming or mitigating immediate barriers to obtaining housing,
including tenant screening barriers.This may include (i)using the centralized or
coordinated assessment system to evaluate individuals and families applying for or
receiving homelessness prevention or rapid re-housing assistance;(ii)conducting the
initial evaluation,including verifying and documenting eligibility,as well as conducting
the ongoing re-assessments for ensuring program participants’continued eligibility and
adjusting assistance;(iii)counseling;(iv)developing,securing,and coordinating
services to enroll eligible individuals and families into economic security programs and
other eligible public benefits;(v)monitoring and evaluating participant progress;(vi)
providing information and referrals to other providers;(vii)developing an
individualized housing and service plan,including planning a path to permanent
housing stability;(viii)linkages to education,job skills training,and employment
support;and (ix)conducting re-evaluations.
After move-in,case management best practice is home-based as much as possible and
is focused on stabilizing the participant in housing by identifying supports,
employment or other income,housing retention barriers,and conflict resolution that
may lead to tenancy problems.
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Case management is participant-driven,voluntary,progressive,strengths-based and
focused on housing attainment and retention.
Activities may also include in-reach,outreach,engagement,and other on-going
tenancy support services,including (i)acquiring necessary furnishings and household
goods;(ii)tenancy rights and responsibilities education and support;(iii)eviction
prevention supports;(iv)transportation assistance related to housing stability;(v)
independent living skills coaching;(vi)de-escalation support;(vii)support groups;
(viii)end-of-life planning;and (ix)re-engagement and relocation support.
Mediation:Mediation between the participant and the owner or person(s)with whom
the participant is living,provided that the mediation is necessary to prevent the
participant from losing permanent housing in which the program participant currently
resides.
Legal Serv ices:Legal services necessary to resolve a legal problem that prohibits the
participant from obtaining permanent housing or will likely result in the participant
losing the permanent housing in which the program participant currently resides.This
may include strategies that prevent evictions from reaching courts and formal legal
proceedings and other alternatives to formal eviction hearings.
Credit Repair:Credit counseling and other services necessary to assist program
participants with critical skills related to household budgeting,managing money,
accessing a free personal credit report,and resolving personal credit problems.
Services for Behavioral Health,Mental Health,Substance Use Disorders,and
Medical Care:Includes a continuum of behavioral health services and treatment,as
well as coordination of access to healthcare-related services including primary care,
substance use treatment,mental health care,vision and dental care,and emergency,
crisis,and inpatient services.
Other supportive serv ices:Includes but is not limited to other supportive services
such as:
Childcare:Efforts to establish and operate childcare or provide childcare vouchers for
children from families experiencing homelessness,and provide meals,snacks,and
comprehensive and coordinated developmental activities.
Education Serv ices:Efforts to improve knowledge and basic educational skills.
Services include instruction or training in consumer education,health education,
substance use prevention,literacy,English as a Second Language,General Educational
Development (GED),and others,such as the provision of books,supplies,and
instructional material.
Food:Efforts to provide meals or groceries to program participants.
Educational,Vocational,And Work-Based Learning Opportunities:Efforts to connect
program participants to educational,vocational,and work-based learning
opportunities that resolve the household’s homelessness as quickly as possible and/or
stabilize permanent housing.
Recovery Care And Related Residential Programs:Efforts to connect program
participants to community resources that offer recovery care and related residential
programs,including the cost of transportation to those services.
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Grant Activ ities:Efforts focused on administering a specific grant or funding source
may improve effective operations,as well as effective program implementation.Such
efforts include planning and executing program activities,such as (i)general program
or grant management,oversight,coordination,monitoring,and evaluation;(ii)
salaries,wages,and related costs related to preparing program budgets;developing
systems for ensuring compliance with grant requirements;developing interagency
agreements;and preparing reports and other required documents or activities;(iii)
accounting or other services;and (iv)other reasonable and necessary goods and
services required to implement the grant program,such as evaluating program results
against stated objectives,occupancy costs,and training on program requirements.
Short-Term And Medium-Term Rental Assistance:Up to 24 months of rental
assistance during any 3-year period.This assistance may be short-term rental
assistance,medium-term rental assistance,payment of rental arrears,or any
combination of this assistance.This may include:short-term rental assistance is
assistance for up to three months of rent;medium-term rental assistance is assistance
for more than three months but not more than 24 months of rent;payment of rental
arrears consists of a one-time payment for up to six months of rent in arrears,
including any late fees on those arrears;rental assistance may be tenant-based or
project-based.
Financial Assistance:Efforts to obtain or maintain permanent housing,such as rental
application fees,security deposits,last month's rent,utility deposits,utility payments,
and moving costs.
Rapid Re-housing
“Rapid Re-housing”provides financial assistance and/or services for households to quickly exit
homelessness by securing permanent housing.“Rapid Re-housing”includes the following
eligible activities:
Housing Search and Placement:Services or activities necessary to assist program
participants in locating,obtaining,and retaining suitable permanent housing,including
(i)assessment of housing barriers,needs,and preferences;(ii)development of an
action plan for locating or maintaining housing;(iii)housing search;(iv)outreach to
and negotiation with owners;(v)assistance with submitting rental applications and
and other lease-up assistance,such as understanding leases;(vi)assessment of housing
for compliance with unit requirements,such as habitability;(vii)assistance with
obtaining utilities and moving arrangements and assistance;and (viii)tenant
counseling.
Housing Nav igation and Landlord Mediation:Assists program participants in obtaining
housing by helping them navigate housing applications,screening criteria,and
relationships with landlords that aim to increase exits to permanent housing with
ongoing support.This staff capacity may provide services to landlords to de-escalate
any challenges that arise with program participants,with the goal of avoiding evictions
or exits to homelessness.This can also include providing services and life skills for
program participants to equip them with understanding tenant responsibilities and
other skills that may be needed to achieve long-term housing stability.
Housing Stability Case Management and Tenancy Support Services:Efforts to assess,
arrange,coordinate,and monitor the delivery of individualized services to facilitate
housing stability for a participant who resides in permanent housing or to assist a
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participant in overcoming or mitigating immediate barriers to obtaining housing,
including tenant screening barriers.This may include (i)using the centralized or
coordinated assessment system to evaluate individuals and families applying for or
receiving homelessness prevention or rapid re-housing assistance;(ii)conducting the
initial evaluation,including verifying and documenting eligibility,as well as conducting
the ongoing re-assessments for ensuring program participants’continued eligibility and
adjusting assistance;(iii)counseling;(iv)developing,securing,and coordinating
services to enroll eligible individuals and families into economic security programs and
other eligible public benefits;(v)monitoring and evaluating participant progress;(vi)
providing information and referrals to other providers;(vii)developing an
individualized housing and service plan,including planning a path to permanent
housing stability;(viii)linkages to education,job skills training,and employment
support;and (ix)conducting re-evaluations.After move-in,case management best
practice is home-based as much as possible and is focused on stabilizing the
participant in housing by identifying supports,employment or other income,housing
retention barriers,and conflict resolution that may lead to tenancy problems.Case
management is participant-driven,voluntary,progressive,strengths-based and focused
on housing attainment and retention.Activities may also include in-reach,outreach,
engagement,and other on-going tenancy support services,including (i)acquiring
necessary furnishings and household goods;(ii)tenancy rights and responsibilities
education and support;(iii)eviction prevention supports;(iv)transportation assistance
related to housing stability;(v)independent living skills coaching;(vi)de-escalation
support;(vii)support groups;(viii)end-of-life planning;and (ix)re-engagement and
relocation support.
Mediation:Mediation between the participant and the owner or person(s)with whom
the participant is living,provided that the mediation is necessary to prevent the
participant from losing permanent housing in which the program participant currently
resides.
Legal Serv ices:Legal services necessary to resolve a legal problem that prohibits the
participant from obtaining permanent housing or will likely result in the participant
losing the permanent housing in which the program participant currently resides.This
may include strategies that prevent evictions from reaching courts and formal legal
proceedings and other alternatives to formal eviction hearings.
Credit Repair:Credit counseling and other services necessary to assist program
participants with critical skills related to household budgeting,managing money,
accessing a free personal credit report,and resolving personal credit problems.
Services for Behavioral Health,Mental Health,Substance Use Disorders,and
Medical Care:Includes a continuum of behavioral health services and treatment,as
well as coordination of access to healthcare-related services including primary care,
substance use treatment,mental health care,vision and dental care,and emergency,
crisis,and inpatient services.
Other supportive serv ices:Includes but is not limited to other supportive services
such as:
Childcare:Efforts to establish and operate childcare or provide childcare vouchers for
children from families experiencing homelessness,and provide meals,snacks,and
comprehensive and coordinated developmental activities.
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Education Serv ices:Efforts to improve knowledge and basic educational skills.
Services include instruction or training in consumer education,health education,
substance use prevention,literacy,English as a Second Language,General Educational
Development (GED),and others,such as the provision of books,supplies,and
instructional material.
Food:Efforts to provide meals or groceries to program participants.
Educational,Vocational,And Work-Based Learning Opportunities:Efforts to connect
program participants to educational,vocational,and work-based learning
opportunities that resolve the household’s homelessness as quickly as possible and/or
stabilize permanent housing.
Recovery Care And Related Residential Programs:Efforts to connect program
participants to community resources that offer recovery care and related residential
programs,including the cost of transportation to those services.
Grant Activ ities:Efforts focused on administering a specific grant or funding source
may improve effective operations,as well as effective program implementation.Such
efforts include planning and executing program activities,such as (i)general program
or grant management,oversight,coordination,monitoring,and evaluation;(ii)
salaries,wages,and related costs related to preparing program budgets;developing
systems for ensuring compliance with grant requirements;developing interagency
agreements;and preparing reports and other required documents or activities;(iii)
accounting or other services;and (iv)other reasonable and necessary goods and
services required to implement the grant program,such as evaluating program results
against stated objectives,occupancy costs,and training on program requirements.
Short-Term And Medium-Term Rental Assistance:Up to 24 months of rental
assistance during any 3-year period.This assistance may be short-term rental
assistance,medium-term rental assistance,payment of rental arrears,or any
combination of this assistance.This may include:short-term rental assistance is
assistance for up to three months of rent;medium-term rental assistance is assistance
for more than three months but not more than 24 months of rent;payment of rental
arrears consists of a one-time payment for up to six months of rent in arrears,
including any late fees on those arrears;rental assistance may be tenant-based or
project-based.
Financial Assistance:Efforts to obtain or maintain permanent housing,such as rental
application fees,security deposits,last month's rent,utility deposits,utility payments,
and moving costs.
Permanent Supportive Housing
“Permanent Supportive Housing”is a housing model that provides households non-time
limited rental assistance,the rights of tenancy,voluntary tenancy support services,and links
to other supportive resources.“Permanent Supportive Housing”includes the following eligible
activities:
Housing Search and Placement:Services or activities necessary to assist program
participants in locating,obtaining,and retaining suitable permanent housing,including
(i)assessment of housing barriers,needs,and preferences;(ii)development of an
action plan for locating or maintaining housing;(iii)housing search;(iv)outreach to
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and negotiation with owners;(v)assistance with submitting rental applications and
and other lease-up assistance,such as understanding leases;(vi)assessment of housing
for compliance with unit requirements,such as habitability;(vii)assistance with
obtaining utilities and moving arrangements and assistance;and (viii)tenant
counseling.
Housing Nav igation And Landlord Mediation:Assists program participants in obtaining
housing by helping them navigate housing applications,screening criteria,and
relationships with landlords that aim to increase exits to permanent housing with
ongoing support.This staff capacity may provide services to landlords to de-escalate
any challenges that arise with program participants,with the goal of avoiding evictions
or exits to homelessness.This can also include providing services and life skills for
program participants to equip them with understanding tenant responsibilities and any
other skills that may be needed to achieve long-term housing stability.
Housing Stability Case Management And Tenancy Support Services:Efforts to assess,
arrange,coordinate,and monitor the delivery of individualized services to facilitate
housing stability for a participant who resides in permanent housing or to assist a
participant in overcoming or mitigating immediate barriers to obtaining housing,
including tenant screening barriers.This may include (i)using the centralized or
coordinated assessment system to evaluate individuals and families applying for or
receiving homelessness prevention or rapid re-housing assistance;(ii)conducting the
initial evaluation,including verifying and documenting eligibility,as well as conducting
the ongoing re-assessments for ensuring program participants’continued eligibility and
adjusting assistance;(iii)counseling;(iv)developing,securing,and coordinating
services to enroll eligible individuals and families into economic security programs and
other eligible public benefits;(v)monitoring and evaluating program participant
progress;(vi)providing information and referrals to other providers;(vii)developing
an individualized housing and service plan,including planning a path to permanent
housing stability;(viii)linkages to education,job skills training,and employment
support;and (ix)conducting re-evaluations.After move-in,case management best
practice is home-based as much as possible and is focused on stabilizing the
participant in housing by identifying supports,employment or other income,housing
retention barriers,and conflict resolution that may lead to tenancy problems.Case
management best practice is participant-driven,voluntary,progressive,
strengths-based and focused on housing attainment and retention.Activities may also
include in-reach,outreach,engagement,and other on-going tenancy support services,
including (i)acquiring necessary furnishings and household goods;(ii)tenancy rights
and responsibilities education and support;(iii)eviction prevention supports;(iv)
transportation assistance related to housing stability;(v)independent living skills
coaching;(vi)de-escalation support;(vii)support groups;(viii)end-of-life planning;
and (ix)re-engagement and relocation support.
Mediation:Mediation between the participant and the owner or person(s)with whom
the participant is living,provided that the mediation is necessary to prevent the
program participant from losing permanent housing in which the program participant
currently resides.
Legal Serv ices:Legal services necessary to resolve a legal problem that prohibits the
participant from obtaining permanent housing or will likely result in the participant
losing the permanent housing in which the program participant currently resides.
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Credit Repair:Credit counseling and other services necessary to assist program
participants with critical skills related to household budgeting,managing money,
accessing a free personal credit report,and resolving personal credit problems.
Services For Behavioral Health,Mental Health,Substance Use Disorders,And
Medical Care:Includes a continuum of behavioral health services and treatment,as
well as coordination of access to healthcare-related services including primary care,
substance use treatment,mental health care,vision and dental care,and emergency,
crisis,and inpatient services.
Other Supportive Services:Includes but is not limited to other supportive services
such as:
Childcare:Efforts to establish and operate childcare or provide childcare vouchers for
children from families experiencing homelessness,and provide meals,snacks,and
comprehensive and coordinated developmental activities.
Education Serv ices:Efforts to improve knowledge and basic educational skills.
Services include instruction or training in consumer education,health education,
substance use prevention,literacy,English as a Second Language,General Educational
Development (GED),and others,such as the provision of books,supplies,and
instructional material.
Food:Efforts to provide meals or groceries to program participants.
Educational,Vocational,And Work-Based Learning Opportunities:Efforts to connect
program participants to educational,vocational,and work-based learning
opportunities that resolve the household’s homelessness as quickly as possible and/or
stabilize permanent housing.
Recovery Care And Related Residential Programs:Efforts to connect program
participants to community resources that offer recovery care and related residential
programs.
Operations:Efforts to provide building maintenance (including minor or routine
repairs)specific to the development serving the target population,security,fuel,
equipment,insurance,furnishings,and supplies necessary for the operation of
Supportive housing programming.
Grant Activ ities:Efforts focused on administering a specific grant or funding source
may improve effective operations,as well as effective program implementation.Such
efforts include planning and executing program activities,such as (i)general program
or grant management,oversight,coordination,monitoring,and evaluation;(ii)
salaries,wages,and related costs related to preparing program budgets;developing
systems for ensuring compliance with grant requirements;developing interagency
agreements;and preparing reports and other required documents or activities;(iii)
accounting or other services;and (iv)other reasonable and necessary goods and
services required to implement the grant program,such as evaluating program results
against stated objectives,occupancy costs,and training on program requirements.
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Systems Improvement
“Systems improvement”activities generally refer to collaborative and strategic processes
that identify complex problems,develop community-driven solutions,and implement
improvements.“Systems Improvement”includes the following eligible activities:
Data Collection,Management,Analysis,And System Integration:Efforts related to
collecting,managing,and analyzing data and/or integrating data systems to advance
communities’homelessness efforts.Proposals may be related to the Homeless
Management Information System (HMIS),an HMIS comparable database,and/or other
coordinated activities that use data to strengthen communities’understanding of and
response to homelessness.
Coordination:Coordination across communities,regions,and/or the state at-large,
including but not limited to case conferencing,coordinated entry systems,
capacity-building and infrastructure,cross-sector partnerships,and other strategic
activities to advance a community’s/region’s homelessness efforts.
Resource Utilization Acceleration:Enhancing the utilization of currently available
resources,increasing the speed of connection to resources for eligible households,or
otherwise ensuring that homelessness response systems connect households to
resources as efficiently and effectively as possible.
Additional Resources
●Uniform Guidance:2 CFR Part 200
●Office of the State Controller Micro Training Series on 2 CFR 200
○2 CFR 200 Overview
○Eligibility
○Period of Performance
○Financial Management
○Match
○Cost Principles and Allowable Costs
○Terms and Conditions
○Audits Special Test Provisions
○Program Income
○Equipment and Real Property
○Reporting
○Subrecipient Monitoring
○Procurement Suspension and Debarment
○Full OSC Micro Training Series
●OSC ARPA Reference Guide
●Office Of The State Controller Guide For Monitoring Subrecipients
●OSC SLFRF State Agency Desk Guide
○2 CFR 200 Subpart E-Cost Principles Basic Considerations
○2 CFR 200 Subpart E-Cost Principles Selected Items of Cost
○SLFRF and Internal Controls
○Duplication of Benefits
○Match or Cost Sharing
○Subrecipient,Beneficiary or Contractor Classification Checklist
○Pass-Through Entity Responsibilities Checklist
○SLFRF Subrecipient Award Checklist
○Risk Assessment
○Supplanting Guidance
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○SLFRF Fraud,Waste and Abuse Guide
○Supporting Documentation
Appendix A
Pay Request Policies &Procedures
Overview of Pay Requests
General Information
●DOH THR grantees are paid on a reimbursement basis.
●In order to receive reimbursement,THR grantees must submit payment requests
according to the requirements listed in their DOH THR grant agreement.
●Pay requests should only include eligible expenses for the THR program.See the THR
Policies and Procedures and your Exhibit A for more information.
●THR grantees must submit pay requests once per month,on or before the 20th of the
month,for the expenses incurred in the previous month (e.g.,a pay request for
expenses incurred in July would be due August 20th).In the event that the 20th falls
on a weekend,the pay request will be due the following business day.
●THR uses the grant management platform Access Gov for grantees to submit pay
requests.
●Once DOH receives the pay request,DOH has 45 days to disburse payment,so long as
the pay request is complete and accurate.
●Pay requests should be clear and understandable to any outside third party,without
additional context or agency knowledge being necessary to understand the expenses
included.
●Reviewing pay requests is a method for ongoing monitoring by DOH staff and may
involve follow-up discussion.
●Each expense incurred must be sufficiently documented via two required forms of
backup documentation:(1)Proof of Cost/Service,and (2)Proof of Payment.Proof of
cost/service may include an invoice,bill,itemized receipt,timesheet,etc.Proof of
payment may include a check,bank statement,payroll summary,paystub,etc.
●Expenses must be incurred within the grant period.
●Pay request submissions should adhere to the guidelines outlined below.
●Each pay request is comprised of the following key components listed below and discussed
in the following subsections:
○A completed THR Cover Sheet
○A backup documentation packet that matches your THR Cover Sheet
○An Access Gov draw request submission that includes your uploaded THR Cover
Sheet and backup documentation packet
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Completing Your THR Cover Sheet
The purpose of the THR Cover Sheet is to (a)quickly orient the DOH reviewer to the request,
which expedites the review and payment process,(b)ensures pay request submissions are
clear to understand and only include eligible and allocable costs,and (c)ensures that the
grantee is maintaining sufficient financial records.The THR Cover Sheet should clearly explain
what is included in the backup documentation and list all direct expenses in the pay request.
The THR Cover Sheet is always required,unless otherwise discussed with and approved by the
DOH grant manager.
●Fill out your THR Cover Sheet and save it as a new file.
●Enter the Expense Period Start Date and Expense Period End Date at the top left of the
THR Cover Sheet.
●List each direct expense in the appropriate section of the THR Cover Sheet by activity.
●For each expense,be sure to complete all columns:Expense Category,Expense
Incurred Date(s),Date Paid,Vendor/Payee,Use/Description,Proof of Service/Cost,
Proof of Payment,Page #’s in Attached Documentation,Included in Modified Total
Direct Cost (MTDC)base?(if applicable),and Expense Amount.
○For the Expense Category column,there is a dropdown menu including the
different THR Expense Categories.Select the category that best describes the
expense you are listing.
●If you choose to bill indirect costs:
○Ensure that the indirect rate included in the Cover Sheet Template is accurate
for your organization.
○Complete the corresponding Modified Direct Total Costs (MTDC)Calculator or
NICRA Base Cost Calculator to identify the expenses eligible to be included in
calculating the indirect amount.
○Keep in mind that not all THR grantees choose to bill Indirect Costs.If you do
not have Indirect Costs,this section should be left blank.For more information
on Indirect Costs,see THR Policies and Procedures.
●Make sure the total below each section adds up each expense in that section correctly
(we’ve added the SUM function in the appropriate sections to do this for you but it’s a
good ideal to double check).This should exactly match the amount requested in
Access Gov for that funded activity.
●Enter in the amount of match funds expended during this pay period,and note the
sources of match.Backup documentation is not required to be submitted for match
funds with the pay request,however backup documentation must be maintained and
retained for match expenses.
●Ensure the “TOTAL REQUESTED”at the bottom of the THR Cover Sheet adds up the
total of each section correctly.
●Once your THR Cover Sheet for that pay period is complete,save and rename the file
and upload to the corresponding draw request in Access Gov (see the Submitting Pay
Requests in Access Gov section below for more information).
○Upload the THR Cover Sheet as a separate Excel sheet,not as a PDF (the pay
request will have to be returned if not submitted as an Excel sheet).
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Compiling &Organizing Your Backup Documentation Packet
Below are the key things to keep in mind as you compile and organize backup documentation
for proof of cost/service and proof of payment for each expense for which you are requested
reimbursement.There are no specific step-by-step instructions for this section as each agency
uses different procedures for documenting/tracking,maintaining,and compiling backup
documentation.The following guidance pertains to backup documentation:
●Each expense incurred must be sufficiently documented via two required forms of
backup documentation:(1)Proof of Cost/Service,and (2)Proof of Payment.Proof of
cost/service may include an invoice,bill,itemized receipt,timesheet,etc.Proof of
payment may include a check,bank statement,payroll summary,paystub,etc.
●Include proof of cost/service incurred for every expense,including staff
compensation.Proof of cost/service should clearly show the cost incurred (i.e.,
expense)and when it was incurred (i.e.,expense date must be visible/legible).For
personnel costs,this includes showing the pay period /days worked.
●Include corresponding proof of payment for every expense,including staff
compensation.
●Compile the backup documentation PDF so that proof of cost/service and
corresponding proof of payment can easily be cross-checked by the reviewer (e.g.,
place the expense’s proof of cost/service incurred and proof of payment immediately
next to one another).
●Organize backup documentation in the same order as listed in the THR Cover Sheet.
●Upload backup documentation in one PDF attachment.
●Ensure that the request amount for each expense listed in the THR Cover Sheet
matches the amount shown in the backup documentation.If there are multiple
numbers in the backup documentation,please clearly indicate (e.g.,highlight,circle,
provide additional documentation)which numbers add up to the expense amount
listed in the THR Cover Sheet and should clearly demonstrate that these numbers do
add up.The reviewer should not need to manually calculate the amounts.Show your
work.
○To add highlights,draw circles,and/or write notes into your backup
documentation PDF,simply login to your Adobe Acrobat account or open PDF in
Microsoft Edge browser (click here for a short tutorial on how to do this).
●Remove program participants’personal identifiable information from the backup
documentation.
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Using Access Gov
Creating your account in Access Gov
You will first need to set up your account in Access Gov.To do this follow the below instructions.
1.Navigate to this web page:
https://bit.ly/THRpayrequest
2.Click “Log in”
3.Select “Sign up now”
4.Enter your email address,then select “Send verification code”.
Keep this web page open.
5.You will be immediately emailed a unique verification code
6.Copy and paste that verification code into the open
Access Gov web page,then click “Verify code.”After
your email has been verified,create your password.
Finally,enter your first and last name,then click
“Create.”You’re done!You now have an active
account with Access Gov.
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Submitting Your Pay Requests in Access Gov
1.Log into Access Gov:
https://bit.ly/THRpayrequest
2.Click on “Start Form”or “Draw
request”to open the submission
form.
3.Fill out the Draw Request form
completely
a.Enter your project number
in the follow format:
XX-XXX
b.Select all funded activities relevant to your award and that month’s pay request
c.Enter the expense period start date and end date in the following format:
XX/XX/XXXX -XX/XX/XXXX.These dates should exactly match the expense period
start and end dates listed in your corresponding THR Cover Sheet
d.Enter Requester Name (this is the form filler’s name,not the agency’s name)
e.Enter the total amount being requested for each activity (This should exactly
match the amount(s)listed in your corresponding THR Cover Sheet)
f.Enter the total match calculated for each activity (This should exactly match the
amount(s)listed in your corresponding THR Cover Sheet)
g.Under your Cover Sheet and corresponding supporting documentation
i.Upload your completed THR Cover Sheet as an Excel file
ii.Upload all backup documentation (i.e.,proof of cost/service and proof of
payment for each expense listed in the THR Cover Sheet,in the same
order)in as a single PDF
h.Enter any relevant comments/notes you’d like your THR Program Specialist to be
aware of relative to this request.
i.Click on the Submit button.
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Frequently Asked Questions
What are some common reasons for a THR pay request to be returned?
1.Insufficient Supporting Documentation for Personnel Costs
The Division of Housing (DOH)requires two forms of documentation for each accrued
cost:
1.Proof of Service,such as a timesheet that includes the required information
described below
2.Proof of Payment,such as a paystub
Proof of service or “Time and Activity”is a standard compliance requirement for
federal grants,and is required for THR funding.Your time and activity reports
(timesheets)must include these three components:
1.An accurate #of hours/day each employee spends on each THR funded activity
2.A brief description of the activities conducted during the time tracked toward
each funded activity (We're being pretty open with what this looks like -even
just indicating 2 hrs THR Systems Improvement would suffice)
3.Staff signature reflecting actual hours worked as well as supervisor signature
approving hours
a.Timesheets must show written or electronic approval from employee’s
and supervisor’s verifying actual THR hours worked.If the current
payroll system does not show approval timestamps,please reach out to
your THR specialist to discuss other possible options to meet this
requirement.
Any cost without the appropriate corresponding supporting documentation is
considered unallowable and therefore not eligible for reimbursement.Your THR
Program Specialist will ask you to resubmit if they discover personnel costs without
sufficient backup documentation.
2.Lack of clarity with personnel costs allocated to multiple funding sources
Your THR Program Specialist needs to be able to clearly connect the expense amounts
listed on your THR cover sheet for each personnel cost to the corresponding
documentation included with your pay requests submission.Therefore,if you have
employees whose time is funded by multiple sources,their “THR hours”should be
clearly represented in their timesheet and totaled into a “THR percentage”which is
then clearly applied to their paystub.Meaning,SHOW YOUR MATH.Reminder:this
math needs to be clear enough that a 3rd party auditor can decipher it.
If your allocation math lacks clarity,your THR program specialist will ask for an
alignment meeting and before asking you to resubmit your pay request with the
requested edits.
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3.Failing to Report Match Each Month:
No back up documentation for match is required on your monthly pay requests.
However,we do ask for the total amount of match you tracked that month.You will
record this information in Access Gov and on your THR Cover Sheet.You'll notice your
match is totaled by funded activity (1st image below)and then totaled for the pay
period at the bottom of your cover sheet's 1st page (2nd image below).
That said,we will ask for your back up documentation on how your match was
calculated during formal monitoring sessions (which have not been scheduled yet).
Personnel costs,receipts for services or purchased goods,as well as clear internal
accounting policies that describe how you track every penny of your match
requirement are all good forms of match backup documentation when that time
comes.
4.Unredacted Personally Identifying Information (PII):
Please do not send DOH emails with PII,or upload pay requests with supporting
documentation containing PII.Doing so puts the personal protected information of
staff and clients at risk and may result in monitoring findings or additional disciplinary
actions.Be sure to black out PII in supporting documentation in all places it appears.
This could include redacting employees’addresses from their pay stubs that you are
submitting as proof of payment.
Note:Your THR Program Specialist will ask you to resubmit a redacted pay request
packet if they discover PII when reviewing your backup documentation.
5.Incorrect information entered into Access Gov
Take a moment to double check that you have filled out all of the required fields in
your Access Gov Draw Request form completely and accurately.Specifically,be sure to
enter your project number in the follow format:XX-XXX
What are some general guidelines for avoiding mistakes on my Pay Request
submissions?
Pay Request Do’s
✔Include a completed THR Cover Sheet that lists every direct expense in the pay
request.Your assigned THR Program Specialist will provide you with a customized THR
Cover Sheet,which includes your funded activities,selected indirect rate,and
Modified Direct Total Cost calculator (if applicable).
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✔Include proof of cost/service incurred for every expense,including staff
compensation.Proof of cost/service should clearly show the cost incurred (i.e.,
expense)and when it was incurred (i.e.,expense date must be visible/legible).For
personnel costs,this includes showing the pay period /hours worked.
✔Include corresponding proof of payment for every expense,including staff
compensation.
✔Compile the backup documentation PDF so that proof of cost/service and
corresponding proof of payment can easily be cross-checked by the reviewer (e.g.,
place the expense’s proof of cost/service incurred and proof of payment immediately
next to one another).
✔Organize backup documentation in the same order as the corresponding expenses are
listed in the THR Cover Sheet.
✔Upload backup documentation in a single PDF attachment.
○You can drag and drop multiple PDF files here.Then simply reorder each file as
needed to reflect your cover sheet page numbers and merge them all into one
PDF document to be submitted.
✔When uploading backup documentation to the pay/draw request in Access Gov,upload
your corresponding THR Cover Sheet as a separate Excel file.
✔Ensure that the request amount for each expense listed in the THR Cover Sheet
matches the amount shown in the backup documentation.If there are multiple
numbers in the backup documentation,the grantee should (a)clearly indicate (e.g.,
highlight,circle,provide additional documentation)which numbers add up to the
expense amount listed in the THR Cover Sheet,and (b)clearly demonstrate that these
numbers do add up (e.g.,write out the math,provide a table adding up the numbers).
The reviewer should not need to manually calculate the amounts.Show your work.
Pay Request Don’ts
✘Submit pay requests without backup documentation (i.e.,proof of cost/service
incurred and proof of payment).
✘Submit pay requests without a completed THR Cover Sheet.
✘Convert the THR Cover Sheet to a PDF.
✘Combine multiple expenses (including pay periods /pay dates)in the THR Cover Sheet
instead of listing each expense individually.
✘Upload a separate backup documentation file for each expense.
✘Include program participants’personal identifiable information.
✘Submit multiple pay requests per month (unless otherwise discussed THR Program
team).
How do I determine eligible expenses?
See the Eligible Activities and Program Components and/or your Exhibit A for a full list of
eligible expenses by funded activity type.
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When will I be paid?
Per the DOH THR grant agreement,the State shall pay each invoice within 45 days following
the State’s receipt of that invoice,as long as the amount invoiced is considered complete and
accurate.Should corrections be needed,it may take longer to approve and disburse payment,
as the 45 days is from the date of submission of the final complete invoice.
How will I know if my pay request has been approved or not?
If the pay/draw request is approved,you will receive an automated email from Access Gov
notifying you of the approval.
If the DOH reviewer has any questions/concerns (e.g.,backup documentation is missing,pay
request is difficult to follow,an expense is ineligible),the DOH reviewer will return the
pay/draw request to the grantee with the rationale and items to address.You will receive an
automated email from Access Gov notifying you of the return.Check your email inbox for
additional questions,requests,or instructions from DOH grant managers regarding your pay
request.
You can also look at the Dashboard in Access Gov to see the status of your request.
What counts as proof of service/cost and proof of payment for personnel costs?
Proof of service/cost:The most straightforward proof of service/cost for personnel costs is a
timesheet showing the below items.If a timesheet is not used,another form of
documentation (e.g.,paystub)clearly showing the below items may be acceptable.
●Employee name
●Hours worked /pay period /Funded Activity (make sure the dates worked fall within
the grant period)
●A brief description of what the employee performed grant-related activities (e.g.,
activity name/code,job title,job description)
Proof of payment:The most common proof of payment is a paystub showing the following:
●Employee name
●Amount paid
●Evidence that the employee was paid (e.g.,pay/check date)
Other forms of documentation for proof of payment that have been provided in the past
include an earnings statement,labor distribution report,payroll register,employee earnings
record,and other payroll system reports.
When the personnel costs amount listed in the THR Cover Sheet does not exactly and clearly
match the amount on the backup documentation,additional information/documentation is
required to clearly show how the grantee arrived at the amount listed in the THR Cover
Sheet.For example:
●Highlighting or circling the amount(s)on a QuickBooks ledger that align with the
personnel costs listed in your Cover Sheet.
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●Including a table or other documentation showing (a)the amounts that appear on the
backup documentation,and (b)the percentage of those amounts that were billed to
the THR grant and therefore are listed on the THR Cover Sheet.
○To add highlights,draw circles,and/or write notes into your backup
documentation PDF,simply login to your Adobe Acrobat account or open the
PDF in Microsoft Edge browser (click here for a short tutorial on how to do
this).
Can ledgers be used as proof of service/cost incurred or proof of payment?
A ledger cannot be used as proof of service/cost incurred.For proof of payment,the only
scenario in which a ledger can be used is if (1)the ledger is exported from a formal
accounting system and is part of the organization’s official records and (2)the ledger includes
details on the cleared payment,including the check or card number.
What backup documentation is needed if I subcontract to another agency?
The Division of Housing (DOH)must approve all subawards in writing before your agency may
enter into any agreement regarding your Transformational Homelessness Response (THR)
award,and allow a vendor to begin incurring expenses towards the THR award.
Subawards is an umbrella term referring to sub-recipients and sub-contractors -which
includes consultants.Determination of the type of subaward is based on the OSC’s
Subrecipient Beneficiary or Contractor Classification Checklist.
DOH written approval should be requested after the selection of the subaward through your
agency’s procurement process but before your agency enters into an agreement with the
selected entity.If you have selected any subrecipients or subcontractors to work on your
THR award -please complete the THR Subaward Approval Form and submit it to your THR
Program Specialist as soon as possible to begin the approval process.co
Reimbursement requests received for expenses related to subawards that have not been
previously approved by THR staff,are ineligible for reimbursement.If you are concerned that
your grant may be incurring such expenses -please contact your THR specialist immediately.
THR Subrecipients acting as pass-through-entities must collect and monitor their own
subawards’(subcontractors/subrecipients)backup documentation.Pass-through-entities do
not need to provide DOH with each subaward’s two forms of backup documentation (proof of
cost/service and proof of payment)per expense with each month’s THR Pay Request
submission.Including the proof of cost/service and proof of payment for the subaward is
sufficient for the monthly pay request.Once approved,DOH will make the payment to the
THR grantee,i.e.,the agency that holds the DOH THR grant agreement.DOH will request
subaward backup documentation during monitoring,and this information must be retained for
the record retention period.
Please see the Pass Through Entity section of this document for more information.
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How do I bill indirect costs?
If your organization is eligible for and using the De Minimus Indirect Rate of 10%,you will
need to provide documentation showing how your Modified Total Direct Cost (MTDC)base
amount,the indirect cost rate,and the indirect costs charge were calculated.To do this use
the MTDC calculator tabs provided in your customized THR Cover Sheet for each funded
activity.Fill in the requested information in the blue cells within the MTDC calculator that
corresponds with expenses listed on the Cover Sheet.Once complete,these totals will
auto-populate into the indirect total fields on your cover sheet tab.
If your organization has a current Negotiated Indirect Costs Rate Agreement (NICRA),you
must use that rate for your indirect expenses,&provide DOH with documentation of your
current NICRA.This agreement will provide information on any exclusions applying to your
direct base total and your approved indirect cost rate.After reviewing your NICRA,your THR
Program Specialist will create a THR Cost Base Calculator for each of your funded activities as
supplementary tabs in your customized THR Cover Sheet.Along with each pay request,use
the base rate calculator tabs provided in your customized THR Cover Sheet for each funded
activity.Fill in the requested information in the blue cells within the base rate calculator that
corresponds with expenses listed on the Cover Sheet.Once complete,these totals will
auto-populate into the indirect total fields on your cover sheet tab.
For more information on indirect costs,please see the Indirect Cost section of this document
for more information.
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EXHIBIT C
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