Title
title
Resolutions Approving the Grant Agreements in Lieu of Using CDBG Funds and Authorizing their Execution
..end
Introduction
overview
Staff are seeking approval to enter into grant agreements with three CDBG Public Services grantees to use General Funds rather than CDBG funds due to changing program requirements.
end
body
Recommended Action
Approve the resolution.
Prior Board Action
The Board has taken the following prior action(s):
• RES 25-234: A Resolution Approving The Final 2025 - 2029 Consolidated Plan And The Program Year (PY) 2025 Action Plan For Federal Community Development Block Grant Funds And Submitting This Plan To The U.S. Department Of Housing And Urban Development
• RES 25-192: A Resolution Approving the Release of the Draft Program Year (PY) 2025 Funding Recommendations, PY 2025 - 2029 Consolidated Plan, and PY 2025 Action Plan for Public Comment
Background
The Village received approximately $1.57 million annually in CDBG funding. Of that, no more than 15% can be used on “public service” projects (appx. $235,500 annually). Each year, the Village fully uses all of its public service funds, giving grants to an array of community partners. For PY25, grants have been provided to the following organizations.
• Beyond Hunger
• Housing Forward
• NAMI Metro Suburban
• North West Housing Partnership
• UCP Seguin of Greater Chicago
• Way Back Inn
• Infant Welfare Society Children’s Clinic
• Hephzibah
• YEMBA
The Village’s PY25 CDBG agreement with HUD included the following provisions in Addendum 1:
• The Recipient must administer its grant in accordance with all applicable immigration restrictions and requirements, including the eligibility and verification requirements that apply under title IV of the Personal Responsibility and Work Opportunity Reconciliation Act of 1996, as amended (8 U.S.C. 1601-1646) (PRWORA) and any applicable requirements that HUD, the Attorney General, or the U.S. Citizenship and Immigration Services may establish from time to time to comply with PRWORA, Executive Order 14218, or other Executive Orders or immigration laws.
• The Recipient must use SAVE, or an equivalent verification system approved by the Federal government, to prevent any Federal public benefit from being provided to an ineligible alien who entered the United States illegally or is otherwise unlawfully present in the United States.
These sections require the Village to verify that any low/moderate income households benefiting from the Village’s PY25 CDBG funds are eligible under the Personal Responsibility and Work Opportunity Reconciliation Act (PRWORA) via the SAVE system. Staff are already adding this to the Village’s process of verifying eligibility for Village CDBG-funded rehabilitation programs.
Since the Village’s Public Service subrecipients run programs that benefit LMI households, the Village also must pass the verification requirement on to them. After review by Law and Neighborhood Services staff, Village PY25 agreements with subrecipients were changed to include provisions so that they needed to collect this information as well.
Review of these provisions also included a review against the requirements of Village’s Welcoming Ordinance (13-7). The Welcoming Ordinance includes section 13-7-4 that prohibits the Village from conditioning the access to benefits on citizenship or immigration status “unless required to do so by statute, federal regulation, or an order of a court of competent jurisdiction.” In this case, federal enforcement of a federal regulation is requiring the Village to document the conditioning of benefits under PRWORA via the SAVE system.
Staff held a session with Public Service grantees to go over this new provision on January 15 and asked that they follow up with any questions/concerns prior to signing their PY25 grant agreement. Three grantees have chosen not to sign their PY25 grant agreement due to these new provisions.
• YEMBA ($20,000)
• Hephzibah ($30,000)
• Infant Welfare Society Children’s Clinic ($20,161)
Timing Considerations
Neither the grantees nor Village staff were aware of these changing requirements at the time that the applicants applied for these funds (February 2025). As a result, these entities will be forced to adjust programs or cut services to address the unexpected lack of access to these CDBG funds for PY25 operations.
Financial Impact
Staff recommend that the Village allocate $70,161 from the fund balance to 1001.46215.101.530667.0000 to allow the Village to enter into grant agreements with these entities to support operations during PY25 from the General Fund.
Staff anticipate that this request is a one-time occurrence as grantees will be aware of these requirements prior to application for PY26 funds. Staff are delaying the launch of the PY26 application until April to allow more time for identification of other changes.
Operations Impact
There is no operating impact associated with this item. The item aligns with the department’s core service delivery.
DEI Impact
The Community Development Block Grant (CDBG) program requires that each activity funded, except for administration, meet one of three national objectives. The three national objectives include: 1) benefit to low-and moderate-income (LMI) persons; 2) aid in the prevention or elimination of slums or blight; and 3) meet a need having a particular urgency. An activity that does not meet a national objective is not compliant with CDBG requirements.
The provision of General Funds to support these three grants for PY25 would benefit LMI persons as identified in the original CDBG scope.
Community Input
There has been no community input given in relation to this item.
Staff Recommendation
Staff recommend that the Village allocated allocate $70,161 from the fund balance to 1001.46215.101.530667.0000 to allow the Village to enter into grant agreements with these entities to support operations during PY25 from the General Fund.
Advantages:
• Allows service providers to maintain their level of operations for PY25, avoiding unforeseen service disruptions.
Disadvantages:
• There are no identified disadvantages to this action.
Alternatives
Alternative 1:
The Board can ask staff to research this approach further.
Advantages:
• This action allows more time for the consideration of concerns raised by the Board.
Disadvantages:
• This action can delay funds needed for service provision by these providers.
Anticipated Future Actions
Staff will submit a budget amendment request for Q1 2026 to allocate $70,161 from the fund balance to 1001.46215.101.530667.0000. Staff will also proceed with executing the needed grant agreements with the three grantees.
Prepared By: Jonathan Burch, AVM/ Neighborhood Services Director
Reviewed By: Jack Malec, Assistant to the Village Manager
Approved By: Kevin J. Jackson, Village Manager
Attachment(s):
1. Resolution for YEMBA
2. Resolution for Hephzibah
3. Resolution for Infant Welfare Society
4. Draft agreement with YEMBA
5. Draft agreement with Hephzibah
6. Draft Agreement with Infant Welfare Society