IV.E. Reassess Unmet Need When Necessary. June 20, 2019 HUD Guidance for Disaster Recovery CDBG-DR programs.

HUDGuidance / 2-23-2021 / File # 445

The applicant's CDBG-DR award may increase if a reassessment shows that the applicant has additional unmet need, as discussed in section IV.E. of this notice.

IV.E. Reassess Unmet Need When Necessary.
Although long-term recovery is a process, disaster recovery needs are calculated at points in time. As a result, a subsequent change in an applicant's circumstances can affect that applicant's remaining unmet need, meaning the need that was not met by CDBG-DR and other sources of assistance. Oftentimes, unmet need does not become apparent until after CDBG-DR assistance has been provided. Examples may include: A subsequent disaster that causes further damage to a partially rehabilitated home or business an increase in the cost of construction materials vandalism contractor fraud or theft of materials. Unmet need may also change if other resources become available to pay for costs of the activity (such as FEMA or Army Corps), and reduce the need for CDBG-DR.


To the extent that an original disaster recovery need was not fully met or was exacerbated by factors beyond the control of the applicant, the grantee may provide additional CDBG-DR funds to meet the increased unmet need.

Grantees must be able to identify and document additional unmet need, for example, by completing a professional inspection to verify the revised estimate of costs to rehabilitate or reconstruct damaged property.

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