"Updates to Duplication of Benefits Requirements Under the Stafford Act for Community Development Block Grant (CDBG) Disaster Recovery Grantees. Housing and Urban Development Department (6-20-2019) DOB information

If you find yourself still not fully recovered from the major to severe disaster you experienced you'll most likely be looking to HUD for their Community Development Block Grant funds for Disaster Recovery (CDBG-DR). 

Most states that provide assistance from HUD count your FEMA IHP Grants as a duplication of benefits. The state will say you made repairs with the grant fund which is the same task you would complete with the CDBG-DR grant funds. Your state will deduct the amount of FEMA grants you received from the estimated total unmet needs or total repairs or replacement of your dwelling. It typically works out that you have to provide proof that the FEMA grants were used to complete repairs. 

But if you used the FEMA IHP grant funds to complete temporary repairs because you could not or would not take housing assistance elsewhere or in a different form such has rental assistance, FEMA trailer, FEMA MHU, hotel/motel or staying with friends or family. When you had no option but to make repairs to allow your disaster home to also be your temporary shelter while you were making repairs your FEMA IHP grant could be used in this case and not be counted as a duplication of benefits from other disaster grant programs you my be eligible for at a later date. 

Homeowners penalized with FEMA IHP Grants that made temporary repairs to your home so not to relocate or to take temporary housing assistance may be able to have the FEMA IHP Grant that currently is a DOB removed from the DOB calculation.

I know we have this and will be working on a pathway to have the FEMA IHP removed from the DOB calculation according to HUD policy. I would like to find homeowners that had to repay the FEMA IHP and have proof you used the IHP grants to make your home livable until you were offered a Grant. Then at that point you removed all your temporary repairs and made final repairs.

Resource: 2019-13147 p-88: Assistance provided for the purpose of housing rehabilitation, including assistance provided for temporary or minor rehabilitation, is for the same purpose as CDBG-DR rehabilitation assistance. However, the grantee can exclude assistance used for different costs of the rehabilitation, which are a different allowable use (rehabilitation costs not assisted with CDBG-DR). For example, if the other assistance is used for minor or temporary rehabilitation which enabled the applicant family to live in their home instead of moving to temporary housing until rehabilitation can be completed, the grantee can undertake remaining work necessary to complete rehabilitation. The grantee's assessment of total need at the time of application may include the costs of replacing temporary materials with permanent construction and of completing mold remediation by removing drywall installed with other assistance. These types of costs to modify partially completed rehabilitation that the grantee determines are necessary to comply with the requirements of CDBG-DR assistance do not duplicate other assistance used for the partial rehabilitation.

( https://www.federalregister.gov/d/2019-13147/p-88 )

Most states will not exclude temporary repairs from their DOB calculations. This is why when you use IHP funds you should know ahead of time if you can complete all repairs with the amount of FEMA IHP grant funding you received. If not, place the funds in a new bank account and when you are reviewed for other possible grants you can then apply the FEMA IHP grants according to the policy rules of the secondary program which would be the HUD CDBG-DR Grant program. 

If you repaired one room in your home for shelter you will need to make sure you follow specific guidelines of your states HUD CDGB-DR program to be able to use the same materials again in the program. Louisiana actually ordered homeowners to remove new showers, toilets, smoke detectors, sinks, kitchen appliances that were new and replace them using the new grants. This was a waste of federal tax payer dollars but the state of Louisiana felt that it was a duplication of benefits if use purchased a toilet with FEMA IHP funds then wanted a grant that included the costs of a new toilet. Confusing if you are a logical thinker. Let's take a smoke detector that was purchased with FEMA IHP funds. One inspector from the state made the homeowner remove the smoke detector purchased one year before and replace it with the same type of smoke detector purchased that week. They claimed that you could not keep any temporary repairs that you made.