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HUD Office of Lead Hazard Control and Healthy Homes Grant Programs

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Description

The U.S. Department of Housing and Urban Development’s (HUD) Office of Lead Hazard Control and Healthy Homes (OLHCHH) oversees the United States’ primary federal funding dedicated to the remediation of lead-based paint hazards in residential housing. Historically, HUD’s OLHCHH makes lead and healthy homes grant funds available to jurisdictions1 through two programs dedicated to addressing lead-based paint hazards in private, residential properties – the Lead-Based Paint Hazard Control (LBPHC) and the Lead Hazard Reduction Demonstration (LHRD) Grant Programs. LBPHC is the larger program in terms of dollar amount and number of grants, while the LHRD is targeted to larger and/or urban jurisdictions with at least 3,500 pre-1940 occupied rental housing units. Jurisdictions may apply as a consortium of cities and counties for LHRD funding in order to meet this specific pre-1940 occupied rental unit threshold requirement. The HUD OLHCHH lead grants are typically awarded for a period of thirty-six months, and the average funding amounts available are $2.5-3 million for the LHC program and $3-4 million for the LHRD program. In addition, the OLHCHH’s budget has designated Healthy Homes Supplemental Funds, which must be utilized in LHC and LHRD grant program recipient properties to address additional home-based environmental health and safety hazards in housing which receives lead hazard control2 Jurisdictions must select through their grant application whether they are applying for LBPHC or LHRD and can also apply to receive the Healthy Homes Supplemental Funds (HHS) as part of their application. The HHS awards have averaged from $200,000-$600,000 per lead grant. In 2018, HUD’s OLHCHH combined the funding into one, consolidated Lead Hazard Reduction Grant Program which is described further below.

The chart describes the differences between these two traditional OLHCHH lead grant funding sources:

  Lead-Based Paint Hazard Control (LBPHC)  Lead Hazard Reduction Demonstration (LHRD) 
Average Grant Amount Available  $2.5-3.0 Million $3.0-4.5 Million
Length of Funding  36 months 36 months
Match Requirement  10% 25%
Healthy Homes Supplemental Funds  $200,000-$600,000 $200,000-$600,000
Direct Lead Hazard Costs Requirement  65% 80%
Other Requirements  —- 3,500 pre-1940 occupied rental units

 

HUD Lead Hazard Control and Lead Hazard Control Demonstration Fund grants can be used for the following categories of activities:

  • Direct Lead Hazard Control Cost activities (minimum of 65-80% or more of total funding amount required to be spent on these activities)3
    • Allowable remediation of lead-based paint hazards in income eligible (pre-1978, child under age 6 or pregnant woman occupied, household income at or below 80% Area Median Income (AMI)) private, residential properties.
    • Activities directly related to lead-based paint inspection/lead risk assessment, resident temporary relocation, lead clearance inspections, client application processing and other unit production activities.
    • Note: HUD issued guidance that lead grant funds (LBPHC, LHRD, LHR) may be used to test for lead in drinking water as part of Direct Lead Hazard Control Costs, and that Healthy Homes Supplemental Funds may be used to replace leaded plumbing fixtures and pipes in properties receiving lead remediation through HUD LHC-funded programs.
  • Other allowable program activities (Non-Direct Lead Hazard Control) such as outreach and education, blood lead testing of applicant children under age 6 in the household, and lead training.
  • Program administrative costs (no more than 10% of total HUD funding amount)
    • Activities directly related to program staff and sub-grantee supervision, fiscal and programmatic grant reporting, contracting, etc.
    • Administrative costs include indirect costs

New Funding Levels in FY 2019

In fiscal years (FY) 2017, 2018 and 2019 HUD’s OLHCHH received substantial increases in funds from Congress, to bring the Office’s total budget to $145 million (FY2017), $230 million (FY2018), and $279 million (FY 2019) 45The Senate’s Continuing Budget Resolution increased HUD OLHCHH to $279 million, including $45 million to address hazards in public housing, $139 million for Lead Hazard Control, and $95 million for high need communities (which includes a set aside $64 million for 7 high needs jurisdictions to be awarded over three years). In June 2018, HUD unveiled a modified funding application process which involves a single, consolidated NOFA for Lead-Based Paint Hazard Reduction (LHR) Grant Program funding.

The new LHR NOFA requires 10% lead grant matching funds and placed an emphasis on larger, higher need jurisdictions. For those considering applying for the first time, note that the OLHCHH often reserves a portion of the lead grant funding for new applicant jurisdictions that have never received HUD OLHCHH lead grant funding previously.

  2018 Lead-Based Paint Hazard Reduction Grant Program (LHR) 
Total Lead and Healthy Homes Funding
Lead Grant Amount Available 
$212 million
$2.0-3.5 million per grantee
$1M minimum; $3.5M maximum
Length of Grant Funding  42 months
Match Requirement  10% of HUD lead grant funds
Healthy Homes Supplemental Funds  $600,000 per applicant
Direct Lead Hazard Cost Requirement  65%
Other Requirements  3,500 occupied, pre-1940 rental units in the grant’s target jurisdiction

 

Strategic Implementation

HUD historically releases an annual Notice of Funding Availability (NOFA) in the spring for funds to been awarded by the end of September. In more recent years the release date has been impacted regularly by federal budget negotiation timelines. The grant application includes a Rating Factors narrative, program abstract, budget, budget narrative and several mandatory forms that are submitted to HUD via the grants.gov federal grant portal. The timeline for responses to HUD OLHCHH lead grant NOFAs is typically 45 days, which can be a brief timeframe for applicants to put in place the partnerships, program design and match resources needed for a successful grant application. Successful applicants begin to put in place partnerships to support match funding and program design, implementation and evaluation in the months leading up to anticipated release of the NOFA’s. These partners may include:

  • A primary applicant with experience in housing repair and construction project management, for example a housing department with a current weatherization or housing rehabilitation program is ideal to ensure that the unit production goals set forth in the application can be met and the HUD grant reviewer has confidence in the organization and project management team.
    • A unit production plan should include a plan to engage a pool of certified lead hazard reduction inspectors and contractors, expedite the bidding or job assignment process, standardize pricing, conduct resident temporary relocation processes and project manage time frames for lead hazard control repair projects in order to meet quarterly benchmarks.
  • Match funding (lead-related) and leveraged resource partners, and a plan to leverage HUD investment with other sources of home repair dollars (weatherization, housing rehabilitation) from private and federal, state and local government contributions. Except for HUD’s Community Development Block Grants (more information can be found in the CDBG section of the toolkit), which are designated as local funds by federal statute, only non-federal, local and private funds can be used to meet the statutory lead grant match requirement. Leveraged funds can provide resources to holistically address housing needs beyond lead hazard control as well as increase the total resources available for lead hazard remediation in jurisdictions where the cost of the lead hazard reduction job exceeds the grant program budget, or in states where the required lead abatement standard exceeds HUD’s allowable lead hazard control measures.
  • Evaluation partners that include academic institutions, state or local government departments and others who can track health, education and housing metrics over time, and establish a plan to track program impact through health outcomes (elevated blood lead levels (EBLL) prevalence), educational outcomes (special education costs) and other socio-economic indicators by engaging in data and evaluation partnerships. Data partners include state and local departments of health who engage in EBLL surveillance and case management activities. Similar pre and post health outcome indicators are necessary for also tracking the impact of the Healthy Homes Supplemental funded interventions.
  • The U.S. Centers for Disease Control and Prevention has provided joint verbal guidance with HUD to partners and grantees in a number of contexts that EBL data should be shared between CDC-funded lead surveillance programs and local HUD-funded housing programs, both to target lead remediation resources to the most at-risk homes with EBL children, and to evaluate the impact of lead poisoning prevention or housing remediation programs. This data can be shared under HIPPA regulations by putting Business Associate Agreements or Memoranda of Understandings in place between agencies at the local or state level that allows data sharing.

Developing a strong work plan is key to successfully implementing a HUD-funded lead grant program. The work plan, while not required to be submitted as part of the most recent version of the LHR NOFA in 2018, should be initiated prior to applying for funding, as it will inform the proposal and ensure success in setting program implementation in motion when the funds are awarded. A HUD lead grant program work plan describes and sequences tasks over the life of the grant, and typically includes the following elements:

  • Project staff roles and project management plan, including who will handle key roles and project administration such as programmatic and fiscal benchmark tracking and reporting.
  • Project partners and sub-grantees roles and deliverables
  • Plan for match and leverage funding
  • Unit Production and Fiscal Benchmarks and Timeline
  • Unit Production Process
    • Community outreach and marketing
    • Client application processing and unit selection
    • Lead-based paint inspection/lead risk assessment and healthy homes environmental assessment (if applicable)
    • Scope of Work creation
    • Contractor bidding or assignment
    • Resident temporary relocation
    • Lead hazard control remediation process, including lead-based paint hazards, drinking water hazards, soil hazards and other sources of lead exposure as allowed using HUD lead, Healthy Homes Supplemental or leveraged funds
    • Healthy homes interventions (where applicable)
    • Unit clearance inspection
  • Fund Dispersal
  • Reporting
  • Evaluation

Strategic planning and continuous process improvement can ensure that HUD lead grant programs are successfully implemented. HUD also provides a Government Technical Representative (GTR) to every grantee who provides guidance as well as tracks and rates grantee performance on a quarterly basis. Transparent and consistent communications with a grantee’s GTR is often helpful in solving for challenges as they arise and keeping an LHC project on track to achieve planned benchmarks.

HUD lead grants are an important source of funds for interventions to address residential lead-based paint hazards as part of any local lead poisoning prevention strategy. While these lead grant resources can be awarded every three years where program performance is strong, in order to effectively address residential lead hazards on a broader scale, communities need to supplement and leverage these funds with additional resources from public, private and philanthropic sources.

Example

GHHI Rhode Island partners align and braid HUD LHRD funds with Community Development Block Grant funding, Weatherization Assistance Program and local utility funds, housing rehabilitation and other housing, health and energy efficiency resources, to offer a holistic set of services to meet the housing needs of families of children with EBLs and to preventively address potential lead exposures in other properties. For homes that require extensive lead hazard reduction or have other structural defects that need to be addressed prior to lead remediation, the partnering agencies braid together multiple lead, housing rehabilitation and other gap funding to prevent the property from being deferred from the LHRD grant programs. The comprehensive services include reducing exposure to lead-based paint hazard and other health and safety hazards as well as reducing energy costs in order to help families improve financial and housing stability, so they can remain in the home that has been made safes. GHHI Rhode Island works closely with the HUD funded LHRD Programs, Rhode Island Housing’s LeadSafe Homes and the City of Providence’s Lead Safe Program, as well as the Community Action Program’s energy efficiency services throughout the state. Together, partners have developed a work plan model that leverages strong state and local health and housing code enforcement and tracks the health and educational impact of HUD’s lead poisoning prevention funding through partnerships with academic institutions. GHHI Rhode Island also leverages their HUD LHRD lead grant investment with innovative sources of support including Attorney General settlement funds (additional information available in the Attorney General Settlement Funds section of the Lead Toolkit). Recently, the GHHI Rhode Island partners completed a statewide lead poisoning prevention policy analysis and produced a brief for state lawmakers that has become the agenda for updates to the state’s lead poisoning laws and regulations in the current legislative cycle.

Toolkit Information

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