Grant Administration: Section 7.2 Overall Procurement Requirements

Environmental Review and Bidding
As stated in Chapter 6: Environmental Review, it is HUD policy as of April 2011 that the environmental review process be completed prior to bidding to allow for an unprejudiced decision about the action and to allow for any modifications or project cancellation based upon the environmental review.

Excluded Parties
Grantees must not award any contract to any organization that is debarred or suspended or is otherwise excluded from or ineligible for participation in federally assisted programs. This applies to any CDBG-assisted contract at any tier in the process. Documentation proving verification of contractor eligibility will be checked at monitoring.

  • Prior to contract execution, the grantee must check the organizations name against the federal System for Award Management (SAM).  System for Award Management (SAM)
  • The grantee must document that the organization (including all contractors and subcontractors) are not on this list with screenshots or other proof the organization is not debarred.

Minority Business Enterprises/Women Business Enterprises (MBE/WBE)
The regulations at 2 CFR Part 200.318 requires grantees to take affirmative action to contract with small and minority-owned firms and women business enterprises. CDFA does not require set asides or participation quotas, but grantees are expected to make special efforts to award contracts to MBE and WBE firms. 2 CFR 200.321

The grantee must make good faith efforts to see that Minority Businesses and Women Business Enterprises are provided opportunities as a result of Small Cities funding. A separate file should be established and maintained with efforts clearly documented. In addition, grantees are required to notify the Department of Transportation (DOT) and several construction services firms of all procurements utilizing CDBG funds. Grantees must upload the MBE/WBE Services Form prior to submission of construction claims in GMS.  Attachment 7-1: MBE/WBE Services Form  and Department of Transportation Disadvantaged Business Program

Suggested Outreach
It is the grantee’s job to ensure the MBE/WBE firms are notified of any contracts ready for bid. Other specific measures a grantee may take to meet M/WBE goals include:

  • Assuring that small businesses and MBE/WBEs are solicited whenever they are potential sources.
  • Including MBE and WBE firms on solicitation lists and sending them an Invitation to Bid.
  • When economically feasible, dividing total requirements into smaller tasks or quantities so as to permit maximum participation by small businesses and MBE/WBEs.
  • Where the requirements permit, establishing delivery schedules which will encourage participation by small businesses and MBE/WBEs.
  • If any subcontracts are to be let, requiring the prime contractor to take the above affirmative steps.
  • Setting aside a percentage of CDBG funds to be awarded to MBE/WBEs.
  • Including MBE/WBE criteria with additional points in selection criteria for professional services procurement.
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