Public Services Fund 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• The first tier (draft ERR – unsigned, unpublished) evaluates the proposed project (typically a rehabilitation program of some kind) and the types of activities to be undertaken and identifies applicable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.

All Applicants must be a Unit of Local Government (i.e. a City or County) and will sponsor / partner with the nonprofit entity performing the public services. In addition, the entity performing the public services cannot also perform the role of the CGA. 

A UGLG may implement the program similarly to a nonprofit entity, provided they also acquire a separate CGA to provide grant admin / project delivery services according to the CGA Policy. 

Q: Some local foundations have funds that are intended specifically as a match to leverage other grant funding, so they will make awards contingent upon receipt of the other grant that is being pursued – how do they present acceptable forms of Match?

Q2: If a foundation has issued an award letter stating that they will provide up to $500,000 for a project, contingent upon the city/organization matching that fund (so if they can put in $400,000, the foundation will provide $400,000) this CANNOT be considered match?

A: Per the revised program guide:

• “Applicants must demonstrate that they have a minimum $5,000 Match of cash or in-kind services. Shelter Assistance Funds (SAF) are not eligible for use as Match. For the Public Services program, the Match must be available at the time of Application.

Match funds must be:

• Committed (not speculative)
• Available within the project timeframe
• Legally authorized
• Not double counted
• Allowable under both funding sources

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

• UGLG Applicant resolution of local match, identifying the source of funds and availability
• Fully executed grant or loan agreements by other funding entities
• Formal, signed grant or loan approval letters documenting committed funds”

Q: If a subsidiary of the COG is the nonprofit (Subrecipient Partner) who is the coordinated entry point of contact for a specific region, can they apply for homeless services money and the COG administer the grant?

A: This is permissible, provided the COG can demonstrate a clear delineation between those individuals performing grant administration activities and then those performing the role of the nonprofit element implementing the homelessness services. 

The UGLG Applicant team must be either a County or the City that the subrecipient Partner is located in; the sponsorship of the UGLG cannot occur to another jurisdictional locality. Additionally, the Applicant must be able to demonstrate that a majority of the low-to-moderate income (LMI) / low-to-moderate limited clientele (LMC) beneficiaries (i.e., over 51%) are from outside the Entitlement City, as Entitlements receive their own funding from HUD.