With 40+ years of experience supporting the administration and implementation of over $25 billion in federal grants, Civix has helped in the recoveries from some of the largest disasters in recent history and serves as a trusted technical assistance provider for the U.S. Dept. of Housing and Urban Development (HUD). Our team is actively helping clients with Action Plan submissions via HUD’s Disaster Recovery Grant Reporting (DRGR) system. Based on that work, this Navigation Guide shares lessons learned, best practices, and helpful tips that grantees should consider when submitting Action Plans according to HUD’s new requirements.
What is DRGR?
DRGR is the system HUD uses to review grant-funded activities, prepare reports to Congress and other interested parties, monitor program compliance, and make data available to the public.
For grantees, it is used for accessing funds and reporting performance activities.
HUD recently began requiring grantees to submit Public Action Plans through the DRGR. To standardize the Public Action Plans and ensure they align with the federal register, the new submission process is organized by discrete, sequential modules that grantees must complete.
Since previously there was not a standard format, grantees should re-examine how they go about developing Action Plans to meet the new requirements of the DRGR system.
How to Navigate the DRGR System for Action Plan Submission
Even seasoned grantees will need to rethink how they submit their Action Plans considering the new method required by HUD. After multiple successful submissions, Civix has developed best practices that grantees should consider as they approach the DRGR.
- Start with Roles and Responsibilities – Before starting, it is important for grantees to identify personnel and assign roles and responsibilities. Ensuring the appropriate parties have access to the DRGR could take several weeks, so it is best to make these decisions as early in the process as possible.
- Begin with a Complete View of the Modules – Grantees should begin by understanding the flow of the modules, what is required by each, and how they interact – to inform the structure of workflows and timelines.
It may be best to work on the modules out of order. For example, while the first module is an Executive Summary, Civix recommends grantees start by reviewing the data requirements modules. Those will drive the development of their recovery programs.
Additionally, grantees need to understand how the various modules interact so they can synchronize activities accordingly. For example, HUD now requires certain public engagement during the Action Plan development process, rather than at the end during public comment, so these activities must be conducted and incorporated at the appropriate points in time.
- Divide and Conquer – A deep understanding of the modules and guides referenced in #2 is especially important for making plans to distribute work, collect information, and organize that information. Civix recommends assigning teams for development of unmet needs, program design, and public engagement. Then, each of the team leaders can identify the modules for which they are responsible, pull the questions, and formulate responses.
- Cushion the Timeline for Submission – Grantees have 120 days from the applicability date of the federal register notice to submit their Action Plans. Within that short period, grantees must account for 30 days of public comment, responses to public comment, quality control, and much more. These aspects further reduce the time grantees can work on developing their Action Plans to around just a couple months.
Furthermore, given some of the new DRGR limitations (for now, you’re not able to cut/paste large sections into the modules), grantees should factor in extra time for manually entering content into the system.
In developing a workplan for the Action Plan, grantees should allocate sufficient time to (1) download the Action Plan from DRGR, (2) review and format it, (3) translate it, and (4) post it to their website for public comment. For most grantees, adding two weeks to their typical submission timeline will suffice.
- Maintain Master Files Outside of DRGR – To be safe, grantees should copy the modules from DRGR and build their Action Plans outside of the system (especially data tables). Even though they will have to
- Be Extra Thoughtful on Program Design – Previously, grantees would provide a framework for program design in their Action Plans. This allowed for a degree of flexibility and for many of the details to be developed when creating policies and procedures after the Action Plan was submitted. Now, HUD is requiring a higher degree of program design detail in Action Plans, and adjustments after submission could be considered a “substantial change,” requiring a substantial Action Plan Amendment. This new policy means that grantees must be extra thoughtful about program design throughout the development of their Action Plans or be prepared for a time-consuming substantial amendment process (inclusive of an additional public comment period).
Promoting Public Engagement and Equity in Recovery
The goals of the new DRGR system are laudable. They’re aimed at ensuring Action Plans align with federal register notices, provide ample opportunity for public input and transparency, reflect the desires of communities, and advance equity in recoveries. While the new method of submitting Action Plans requires grantees to adjust their usual workflows, ultimately, it will help drive more impactful, equitable programs.
How to Choose a Disaster Recovery Grant Partner
Floods, hurricanes, tornadoes, wildfires… Large-scale disasters strike at the heart of communities: the homes of the people who make them up. Getting survivors back into homes quickly is essential to not only a successful recovery but also a more resilient future.
When choosing a DR grant management partner, grantees should look for a proven record of success and a team that shares their passion and values.
Civix has over 40 years of DR grant management experience and is committed to providing our public and non-profit sector clients with exceptional technical assistance and the tools they need to succeed. Our work experience is grounded in funding that serves low income and disadvantaged communities, and we are committed to building the capacity of the communities we serve.
Our team includes subject matter experts skilled in grant administration, program design and implementation, regulatory compliance, fair housing, demographic analysis, needs assessment, and sustainable development to create equitable and catalytic change.
Our work includes leading and supporting HUD-funded efforts in Louisiana, New York, New Jersey, Tennessee, Massachusetts, California, Virginia, Puerto Rico, Florida, and other locations across the U.S. We have worked as integral members of state and local governments responsible for the full lifecycle of grant processes, authored fully compliant Action Plans, developed and implemented comprehensive grant administration manuals, successfully navigated HUD monitoring visits and HUD-OIG audits, and conducted exhaustive trainings on key administrative requirements. Most recently, our teams have helped California and Michigan successfully submit their DRGR Action Plans.