Understanding HUD’s Universal Notice: What’s New

On January 8, 2025, the U.S. Department of Housing and Urban Development (HUD) published the Universal Notice, a standalone notice outlining the requirements for Community Development Block Grant Disaster Recovery (CDBG-DR) funding moving forward. The Universal Notice establishes three phases of the grant award process: 

• Phase One: The Action Plan
• Phase Two: Financial Certification and Oversight of Funds
• Phase Three: Implementation of Universal Notice Requirements

To develop the Universal Notice, HUD solicited stakeholder feedback and incorporated past CDBG-DR requirements.  

Updated Universal Notice Overview 

The Universal Notice differs from previous HUD notices because it does not apply to grantees until it is made applicable through a separate Allocation Announcement Notice (AAN). Until then, it should serve as a roadmap to understand CDBG-DR expectations and requirements. Past grantees can use it to help justify waiver requests to align a previous disaster’s requirements with those in the Universal Notice.  

HUD Objectives: Phase 3 Initiatives  

In this notice, HUD introduced sweeping changes geared toward streamlining the CDBG-DR implementation process for grantees and emphasizing equitable recovery for disaster survivors. Below, we highlight some of the most significant changes in Phase 3 that improve the recovery process.  

Adoption of Another Agency’s Environmental Review 

To better align with agencies like FEMA and streamline requirements, grantees may adopt an environmental review, approval, or permit performed by another federal agency when using CDBG-DR funds to supplement other federal funds, provided the actions covered by the funds are substantially similar. 

Changes to Rental Assistance

To alleviate the administrative burden for grantees and increase access to funds for survivors, grantees are permitted to make lump-sum relocation rental assistance payments to displaced residential tenants. Grantees can also provide rental assistance and utility payments for up to 24 months without a waiver when made under the development of affordable rental housing or other housing assistance. Additionally, rental assistance is now excluded from the 15% cap on public services. 

Changes to Eligible Activities 

Recognizing disaster survivors' difficulty paying for necessities throughout the recovery phase, HUD extended the period for grantees to make disaster relief payments on behalf of individuals and families from three to six months. This expanded disaster relief assistance is available to low- and moderate-income (LMI) individuals for food, clothing, housing, utilities, or medical care related to the qualifying disaster. To improve survivors’ access to shelters at critical times, HUD eliminated the prohibition on assisting privately owned facilities, so grantees can aid qualified privately owned facilities used as shelters. 

LMI Calculation for Infrastructure Activities 

In the past, grantees may have chosen not to pursue large, innovative infrastructure projects because they could not meet the national objective criteria for low- and moderate-income. Typically, to meet this national objective, 51% of the residents in the area benefitting from the project must be LMI. Instead, to encourage grantees to pursue projects that benefit underserved communities, grantees can meet the area benefit criteria by multiplying the total cost of the infrastructure activity by the percentage of LMI persons in the service area. 

Next Steps 

Navigating HUD’s Universal Notice for CDBG-DR funding can be complex, especially with the updated requirements and new opportunities for grantees. The EisnerAmper team can help you interpret and implement this guidance across all phases, from action planning to financial oversight and compliance. Whether you need assistance with waiver requests, streamlining environmental reviews, managing rental assistance programs, or aligning infrastructure projects with LMI criteria, we have years of experience to help you meet your disaster recovery goals efficiently and equitably. Contact us below to learn how we can support your disaster recovery efforts.