TLDR
HUD Community Planning & Development grants - CDBG (24 CFR 570), HOME (24 CFR 92), ESG (24 CFR 576), and CoC (24 CFR 578) - share a reporting backbone in IDIS (Integrated Disbursement and Information System) but diverge sharply on eligibility, income verification, match, and affordability period rules. Affordable housing nonprofits operating across two or more CPD programs are running parallel compliance systems on the same properties and people, and the OIG findings that appear most often are the places where the two systems were treated as one.
Affordable housing nonprofits that operate across CDBG, HOME, ESG, and CoC are running four different federal compliance systems simultaneously, often on overlapping populations and sometimes on the same properties. The programs share HUD as the federal funder and IDIS as the reporting backbone, but they diverge on almost every operational rule: eligibility determination, match, affordability period, environmental review sequencing, labor standards applicability, and data collection.
This guide maps the CPD programs, what each requires, and where the compliance breaks happen.
The Four CPD Programs at a Glance
| Program | CFR | Core use | Match | Key reporting |
|---|---|---|---|---|
| CDBG | 24 CFR 570 | LMI community development | None federally | IDIS, Consolidated Plan, CAPER |
| HOME | 24 CFR 92 | Affordable housing production and preservation | 25% | IDIS, CAPER |
| ESG | 24 CFR 576 | Homelessness prevention and rapid re-housing | 100% | IDIS, CAPER, HMIS |
| CoC | 24 CFR 578 | Permanent supportive housing, rapid re-housing | 25% cash match on SH activities | IDIS, APR via Sage/HMIS |
CDBG and HOME are administered by states and entitlement jurisdictions. ESG flows to states and entitlement jurisdictions. CoC is competitive and flows directly to the CoC lead agency (collaborative applicant or designated collaborative applicant) and its subrecipients.
CDBG: The National Objective and LMI Documentation
Every CDBG-funded activity must meet a national objective under 24 CFR 570.208:
- LMI benefit - area benefit, limited clientele, housing, or jobs
- Prevention or elimination of slums and blight - area basis or spot basis
- Urgent need - rare, narrowly defined
LMI benefit is the most common for nonprofit subrecipients, and it requires documented income data. The three LMI benefit subcategories:
Area benefit: the activity serves a geographic area where at least 51 percent of residents are LMI. Documented through Census data or HUD-provided LMI data layers.
Limited clientele: the activity serves a specific population group where at least 51 percent are LMI. Four documentation paths:
- Income verification on each beneficiary
- Beneficiary group is categorically low-income (abused children, elderly persons, homeless persons, adults with severe disabilities, illiterate adults, migrant farm workers, battered spouses)
- The activity serves an area where the limited clientele exclusively resides
- The activity’s nature provides sufficient evidence of LMI benefit
Housing: the housing assisted must be occupied by LMI households. For rental, at least 51 percent of units must be LMI-occupied. For single-unit ownership assistance, the assisted household must be LMI.
Documentation for LMI benefit is the most common CDBG finding. An activity claimed under limited clientele without documented income verification or without evidence the beneficiary group is categorically LMI is a finding that can void the expenditure.
HOME: Affordability Periods and Recapture
HOME is structured around the affordability period. Investment triggers a recorded covenant or deed restriction that runs with the property for the regulated period.
Rental affordability period (24 CFR 92.252(e)):
- Under $15,000 per unit: 5 years
- $15,000 to $40,000 per unit: 10 years
- Over $40,000 per unit: 15 years
- New construction of rental housing: 20 years
Homebuyer affordability (24 CFR 92.254(a)(4)) uses the same per-unit investment tiers and drives either a resale restriction or a recapture mechanism recorded against the property.
Breaking affordability - charging rent above the HOME rent limit, failing to rent to an income-eligible household on turnover, ownership transfer without recapture or resale enforcement - triggers HOME repayment. The nonprofit subrecipient or project owner is typically on the hook for the repayment.
Match: HOME requires 25 percent non-federal match on expenditures on affordable housing activities (24 CFR 92.218). Match sources include cash contributions, foregone taxes or fees, value of donated real property or materials at fair market value, volunteer hours, and proceeds from bond financing. Match must be permanent and documented at the project level. CHDO operating assistance and administrative funds do not require match.
ESG: Four Components and 100 Percent Match
Emergency Solutions Grants fund:
- Street outreach - engagement and case management for persons living unsheltered
- Emergency shelter - operations, essential services, and renovation costs for emergency shelters
- Rapid re-housing - rental assistance, housing relocation and stabilization services for persons experiencing homelessness
- Homelessness prevention - rental assistance, housing relocation and stabilization services for persons at risk of homelessness
Plus HMIS costs and administrative costs (up to 7.5 percent cap).
Match: 100 percent of ESG expenditures (excluding HMIS and administration) per 24 CFR 576.201. Match can be cash, in-kind goods or services, or volunteer hours. Donated shelter space is valued at fair market rental. Match is documented at the activity level and must occur within the program year.
Eligibility: ESG rapid re-housing requires the participant to meet HUD’s definition of homeless under 24 CFR 576.2. Homelessness prevention requires the participant to be at risk of homelessness per 24 CFR 576.2 and have income at or below 30 percent of area median income.
HMIS data: ESG participant data must be entered into HMIS per the HUD HMIS Data Standards. Domestic violence provider exception applies - comparable database use, not HMIS.
CoC: The Competitive Program and the APR
Continuum of Care funds permanent supportive housing (PSH), rapid re-housing (RRH), transitional housing, supportive services only (SSO), and HMIS. Awarded through the annual CoC Program Competition.
APR: the Annual Performance Report is the grantee-level performance report, generated from HMIS and submitted through Sage (HUD’s reporting portal) at the end of each operating year. APR data elements track participants served, housing outcomes, income at entry and exit, and utilization.
Chronic homelessness documentation is heavily tested. A person qualifies as chronically homeless per 24 CFR 578.3 if they have a qualifying disability and are either currently homeless and have been homeless for 12 continuous months or for 12 months cumulatively over 4 occasions in the past 3 years. Documentation must be in the participant file at the time of program entry.
Match: 25 percent cash or in-kind match on most CoC grant activities, per 24 CFR 578.73. Leasing activities are exempt.
Environmental Review: 24 CFR Part 58
Environmental review under 24 CFR Part 58 applies to all CPD programs. The Responsible Entity (usually the jurisdiction) must complete the review before funds are committed.
The sequence that gets subrecipients in trouble: signing a construction contract, releasing rehab funds, closing on a property acquisition, or obligating funds for a rental assistance contract before the Responsible Entity’s Request for Release of Funds (RROF) is approved by HUD.
A choice-limiting action taken before environmental review clearance voids the expenditure. The subrecipient can be required to repay HUD funds and cannot retroactively bring the action into compliance.
Exempt activities under 24 CFR 58.34 (administrative costs, public services not involving physical work, engineering studies) do not require individual environmental review but do require documentation that the activity qualifies as exempt.
Davis-Bacon and Labor Standards
Construction activities using HOME or CDBG funds trigger Davis-Bacon prevailing wage requirements when the activity meets the applicable thresholds:
- HOME: Davis-Bacon on projects with 12 or more HOME-assisted units under 24 CFR 92.354
- CDBG: Davis-Bacon on construction contracts over $2,000 for CDBG-funded work per 24 CFR 570.603
Documentation: certified payroll reports from every contractor and subcontractor, wage determination posted at the job site, and apprentice ratio compliance. Wage restitution findings on HOME and CDBG projects are common and reach six figures on larger projects.
IDIS, CAPER, and the Reporting Cadence
Entitlement jurisdictions and states submit to HUD:
- Consolidated Plan - 3- to 5-year strategic plan covering CDBG, HOME, ESG, and HOPWA
- Annual Action Plan - yearly update identifying activities and funding
- CAPER - Consolidated Annual Performance and Evaluation Report, submitted 90 days after the program year end
Subrecipient nonprofits feed the CAPER with accomplishment data - units rehabilitated, beneficiaries served with income categories, persons housed, outcomes achieved. The CAPER is generated from IDIS data, so subrecipient reporting to the jurisdiction must reconcile to what appears in IDIS.
CoC recipients submit the APR through Sage, using HMIS-generated data. APR submission timing is set by the grant start and end dates in the agreement.
Single Audit and HUD Monitoring
CPD subrecipients that expend over $1,000,000 in federal (raised from $750,000 for fiscal years ending September 30, 2025 or later) awards trigger single audit under 2 CFR 200.501. HUD CPD major program testing covers:
- Activities allowed / unallowed (by national objective, eligible activity, eligible cost)
- Allowable costs and cost principles
- Cash management
- Eligibility (income, program entry criteria)
- Matching, level of effort, earmarking
- Period of performance
- Procurement, suspension, debarment
- Reporting
- Subrecipient monitoring
- Special tests and provisions per program (environmental review, labor standards, affordability)
HUD also conducts its own on-site monitoring of grantees, which often extends to subrecipients. Monitoring findings that appear most frequently across HUD OIG reports are: environmental review sequencing errors, income eligibility documentation gaps, Davis-Bacon certified payroll deficiencies, HMIS data quality failures, and subrecipient monitoring gaps at the jurisdiction level that cascade to the nonprofit.
Start a GrantPipe trial
GrantPipe tracks restricted funds with program-specific cost categories, grant reporting calendars keyed to CAPER and APR deadlines, and activity logs that keep documentation tied to transactions. Start a trial at grantpipe.com/signup to evaluate whether the workflow holds up across multi-CPD program operations.
Free resource
Get the Nonprofit Grant Compliance Checklist
A practical checklist for post-award grant compliance: restricted funds, reporting cadence, audit prep, and common failure points. Delivered by email.
Source: HUD HOME Program Budget
- CDBG
- Community Development Block Grant - HUD CPD formula grant under 24 CFR Part 570. Flexible funding for community development activities meeting one of three national objectives: benefit to low- and moderate-income persons, prevention or elimination of slums and blight, or urgent need.
DEFINITION
- HOME
- HOME Investment Partnerships Program - HUD CPD formula grant under 24 CFR Part 92, funding affordable housing acquisition, rehabilitation, new construction, tenant-based rental assistance, and homebuyer assistance. Requires 25 percent non-federal match on most activities.
DEFINITION
- ESG
- Emergency Solutions Grants - HUD CPD formula grant under 24 CFR Part 576 funding street outreach, emergency shelter, rapid re-housing, homelessness prevention, HMIS, and administration. Requires 100 percent match.
DEFINITION
- CoC
- Continuum of Care Program - HUD competitive grant under 24 CFR Part 578 for permanent supportive housing, rapid re-housing, transitional housing, supportive services only, and HMIS. Awarded through the annual CoC Program Competition.
DEFINITION
- IDIS
- Integrated Disbursement and Information System - HUD's financial management system for CPD grantees. Used to set up activities, commit funds, draw funds, and report accomplishments.
DEFINITION
Q&A
Does a nonprofit subrecipient have its own IDIS account?
Usually not. The grantee jurisdiction operates IDIS; the subrecipient provides source records the jurisdiction uses to execute IDIS transactions. Some states delegate IDIS access to subrecipients for specific activities; check the subrecipient agreement.
Q&A
Can ESG and CoC funds serve the same person?
Yes, in sequenced or complementary ways, but the same cost cannot be paid twice. Rapid re-housing funded by ESG for the first 6 months transitioning to CoC-funded permanent supportive housing is common; the cost allocation must keep the two funding sources separate at the transaction level.
Q&A
What is the CDBG national objective?
Every CDBG activity must meet one of three national objectives: benefit to low- and moderate-income persons (LMI benefit), prevention or elimination of slums and blight, or urgent need. LMI benefit is the most common and requires documented income data on the beneficiary population.
Q&A
What match documentation does HOME require?
24 CFR 92.218-92.222 require 25 percent non-federal match on HOME funds expended on affordable housing activities (not administration or CHDO operating). Match sources must be permanent contributions, documented at the project level, and retained for the affordability period.
Q&A
What are ESG match requirements?
24 CFR 576.201 requires a 100 percent match on ESG expenditures (excluding HMIS and administrative costs up to the cap). Match can be cash, in-kind contributions of goods or services, or volunteer hours valued per 2 CFR 200.306. Donated building space is valued at fair market rental value.
Frequently asked