Roofing Replacement Program FAQ

• A: Project Delivery
• A2: Tier II Review after being awarded are also PD.

No, according to Iowa Code chapter 28E, not required if performed by a COG.

Yes

This is dependent upon the program applied for. Section 106 and some ERR processes can always start prior to the Application, and this can result in higher scores for readiness. Upper Story and other rehabilitation programs require a 2-tier ERR and have a different process to follow:

• “Responsible Entity” (the Applicant UGLG) completes an initial environmental review at a broad or programmatic level, followed by site ‑specific environmental clearance at a later stage:
• The first tier (draft ERR – unsigned, unpublished) evaluates the proposed project (typically a rehabilitation program of some kind) and the types of activities to be undertaken and identifies applicable environmental laws and authorities that can be addressed without knowing the specific project sites.
• The second tier is completed once individual properties are identified and addresses site specific environmental conditions—such as historic preservation, floodplain status, contamination, and other property specific environmental conditions— ‑specific environmental conditions—such as historic preservation, floodplain status, contamination, and other property‑level factors—before any rehabilitation work or choice limiting‑limiting actions occur.

If you attended the Third Thursdays prior to September 1, 2025, you will not be required to take the Basic Training Course. However, if you started attending on or any time after September 1st, you will be required to. Notifications and instructions will be sent out soon to start that process.   

Q: I have current projects who we are moving forward and am doing my contractor clearance checks on possible contractors and subs. I know that a SAM.gov registration isn’t required and a UEI is. What if I can’t find an active UEI account on SAM.gov? I typically do an entity search prior to the exclusion search. Some will note that they don’t have a full SAM.gov registration however they do have an active UEI#. If it does not show that they have an active UEI, however the engineer is able to provide the UEI #, would that work?

A: This is a common problem, but NO - If an entity does not appear in SAM.gov with an active UEI record, simply providing a UEI number is not sufficient for contractor clearance. IEDA’s Contractor Clearance Policy requires two separate checks for all vendors:

• 1) Verification of a valid Unique Entity Identifier (UEI)
• 2) Confirmation that the entity is not debarred, suspended, or otherwise excluded, as documented in SAM.gov:
  • SAM.gov entity search (business entity name) and
    • SAM.gov exclusion search (both biz entity level & Owner)

A UEI must be verifiable in SAM.gov for IEDA to complete the required exclusion / debarment review. Even entities that are not fully registered must still have a basic SAM.gov entity record to be issued a UEI and be searchable in SAM for exclusion (debarment) purposes. If a vendor provides a UEI number, but does not appear in SAM.gov under an entity search or exclusion search, then one of the following is likely true:

• The entity has not completed the SAM entity registration process,
• The record is inactive, incomplete, or incorrectly entered, or
• The UEI provided is invalid or associated with a different legal entity name

In these situations, IEDA cannot accept the UEI number alone. The vendor must create or update their SAM.gov entity record, at least to the level needed to obtain a UEI, and be searchable in SAM.gov. Also, the vendor must ensure the legal business name and address match what is being used for the contract. Once the entity appears in SAM.gov, or is able to provide proof of registration confirmation and the UEI can be verified, IEDA can complete the required exclusion check.

The roof is considered “failing” or “posing a threat to the stability of the home’s structure” when observable conditions indicate that the roof is no longer performing its basic protective function and, if left unaddressed, is likely to result in structural damage, unsafe living conditions, or loss of habitability. This determination may be made by a qualified local official, such as a planner, housing inspector, or code enforcement officer, based on visual inspection and documented conditions, without requiring a formal engineering or architectural analysis.

Examples of qualifying conditions include, but are not limited to:

• Active roof leaks evidenced by interior water intrusion, staining, mold, or rot
  • Widespread missing, cracked, curled, or deteriorated shingles or roofing materials
    • Roof decking, rafters, or trusses showing visible signs of rot, sagging, or water damage
    • Repeated or chronic roof failure documented through prior repairs or complaints
    • Roof conditions cited as violations of local housing, property maintenance, or building codes
    • Roof failure that threatens the structural integrity of ceilings, walls, or framing systems

The assessment is based on observable and documented conditions, not on professional design judgment. An architect or engineer is not required unless unusual conditions are present that cannot be reasonably evaluated through standard inspection practices.

The Applicant is not required to have a specified Target Area or use an LMI census tract. All the homeowners must be determined to be LMI to be eligible.

Q: Eligible Activities: Are these funds available for the activities listed in the chart on page 5 of the Program Guide or are only owner-occupied? Would a rental house be eligible if the tenant is LMI, and the owner agrees to a 5-year forgivable lien?

A. This program is only available to owner-occupied single-family homes.

This program must have the homeowners sign a five-year receding forgivable loan only.

Yes

Q: Will a letter of resolution from a city serve as acceptable documentation? How does match affect project scoring? Are there different levels of scoring for different match contributions?

A:  Per the Program Guide:

Any one of the following are acceptable examples of Match documentation:

• Applicant/UGLC Resolution of Match, clearly indicating the source of the funds and the availability of their contribution
• Fully executed grant or loan agreements by other funding entities
• Formal, signed grant or loan approval letters documenting committed funds”

A2: Match is not scored; it is a threshold item.

Q: Housing Program Specific Documents: Does the GA need to procure for project delivery and technical services if they are to be performing those services? If so, would that happen after the Release of Funds?

A: Technical Services must be procured no matter who performs it.

A2: Other forms of services that are quantified as Project Delivery, if conducted by the local COG do not need to be procured; however, there should either be a separate contract between Grant Administration and Project Delivery or if covered by one contract, each scope of work should be separately defined. See the details provide in revisions to the Program Guide. 

No, you must perform the sealed bid process for the contractor who will be conducting the work on these projects. These definitions were generalized and to alleviate confusion, we have removed this from the Program Guide. 

Q: A COG can provide Technical Services AND administration, correct? It just needs to be spelled out in the contract as being different scopes of work?

A: Yes, a COG can do both; however, Technical Services must be procured for, and there must be two separate contracts. 

Q: Project Team Identification: Project Manager: Wouldn’t these tasks fall under the technical services? How is this category different from technical services. If the GA is to be performing these services, do we need to procure post-award?

A: The definitions are broad across all programs. In this instance, it could be the GA performing Technical Services under a distinct contract to do these services, logged and claimed as Project Delivery.

A2: Regarding procurement, see the question above about a COG providing technical services and administration. 

Q: Budget: Does the Project Delivery activity count towards the $24,999 or only the actual rehabilitation costs? Will you include an admin activity update? Does the Technical Services amount listed include project delivery costs?

A: The breakout amounts have been adjusted to the following:

Admin cannot exceed 10% of the total CDBG funds. These will be on top of the $30,000 per unit costs. All costs can be matched as long as the Hard Costs do not exceed $24,999 from all sources.

A2: Yes, the Technical Services does include and is considered Project Delivery, distinct from the 10% cap but must also be of reasonable cost.

Q: Forms of Assistance: States the 5-year forgivable is receding, but later stated the entire amount is due if the owner does not retain the home for the full 5 years. Also, states the city has discretion to determine if the forgivable loan would be paid back. Please clarify.

A: The forgivable loan is on a receding basis, and the wording has been corrected.

A2: The city in their “Project Management Plan” (previously titled “Administrative Plan”) states under what circumstances they would consider forgiving the amount due. This has always been the case. The plan template provided by IEDA has those allowable instances listed. 

Yes, radon testing is required because $1 federal funds will be spent on these projects, and someone will be using or residing in the home for more than 4 hours per day. If the test results in the level exceeding the 4.0 picocuries per liter (pCi/L) level, then mitigation will be required. This will need to be paid out of the project’s hard costs. 

This program will be a two-year period of performance.

Unfortunately, this is a nuanced response; projects will need to complete the Section 106 form in IowaGrants. Because radon testing is required, if the level is found to be under the required mitigation level, then you can complete the Programmatic Agreement as “Exempt”. If the radon results exceed the level and mitigation is required, the project would not be “Exempt”. Historical properties will be handled on a case-by-case basis. 

Yes, noise is a part of the environmental review for these projects.

Yes, as long as all parties sign the lien.

Q: Prequalification of homeowners up-front – Based on the funding available, it appears IEDA will only be able to award 4-5 grants across the whole state of Iowa (18 COG regions). Although we understand the desire for shovel-ready projects, it is a lot of paperwork for low-income citizens to submit as part of the application for a grant that the city has a relatively small chance of receiving. We did this under the old housing rehab program, but the funding level was higher. It is emotionally taxing for the residents to go through this process only to be told the city didn’t receive the funds. There should be no issue getting 6 households determined to be eligible, and work conducted with a three-year grant.

A: Since these projects are basically a pilot-project, we will remove this requirement for this round and see how it goes. Please note, this could be subject to change in future rounds if we find applicants not getting any projects completed in the first year because of the length of time it takes to find eligible homeowners.

A2: We do also want to point out that these awards are for a two-year contract, but there should still be no issue in getting 6 roofs completed in that timeframe.

Q: I understand the rationale for including the regulatory citations (p. 5 –6) under which the program is eligible. However, including the broad regulatory language that includes every possible eligible activity under the regulations may confuse city stakeholders who are trying to interpret what is eligible under this specific program. If IEDA plans to include the full regulatory citation, it might be helpful to put in footnotes or annotations that indicate which activities specifically are applicable for IEDA’s program.

A: Annotations have been added to enhance some clarity, but any reader that seeks to perform federally funded projects should be cognizant of intentionality of  CFRs that allow the method of distribution to be broad by necessity to address eligibility, etc. at a high level across many potential program types; to that end, IEDA is not going to alter the codified reference text. 

Q: There is a lot of information regarding Davis Bacon, Section 3, and BABA, which would not be applicable for these projects. It might be a good idea to designate those as not applicable to this program so that those who are unfamiliar will not be overwhelmed with requirements that will not need to be fulfilled.

A: Many program guides contain boiler plate data that is generally applicable to all programs, as instances can occur in which cross-cutting requirements can be required to be followed. To that end, IEDA is careful to include these references for the Applicants benefit AND see the CDBG Management Guide for full details. 

Yes, we have added this to the list of eligible activities.

No, all assisted households must be LMI to meet the project’s national objective.

Correct. It is generally true that federal funds cannot be used as a match for other federal funds and holds true for this program.

This principle exists to ensure:

• Federal programs do not supplant each other
  • Congress’s intent for non‑federal leveraging is preserved
  • The same federal dollar is not counted twice

This is the baseline assumption across federal programs, including HUD, DOT, EPA, and others.

Q: For budget, it would be $30,000 per unit up to 6 units, plus 10% for admin? So, a potential $198,000 per project/community maximum?

A: Yes

Q: Do policies need to be adopted with this project, or if the city already has adopted policies from a previous project, can they be used.

A: If they are no older than 5 years from the application date or a revised policy hasn't been instituted, you can use the old policies.

No

Q: There seems to be a lot of names for admin. It seems to me that General, Activity delivery, and Project Delivery are all talking about the same thing. If not, there needs to be clarification to the definitions.

A: Definitions have been included in the program guide, as well as a plain-language detail of the examples of what constitutes grant administration vs project delivery. In addition, there was a session in the Application Workshop that provided dialogue on this topic. 

Yes, however, you may not score as many points on impact compared to a community that does want to do 6 houses.