The Community Development Block Grant-Disaster Recovery (CDBG-DR) program, administered by the United States (US) Department of Housing and Urban Development (HUD), is a cornerstone of federal disaster recovery efforts. However, as a program that relies on Congress to appropriate funds for groups of disasters, CDBG-DR operations are governed by Federal Register Notices rather than permanent legislation. On January 8, 2025, HUD took a significant step to improve the program by issuing its Universal Notice (Notice), aiming to expedite the use of CDBG-DR funds while also bringing greater consistency and efficiency to grantee implementation efforts.
CDBG-DR Funding and the Universal Notice
HUD’s CDBG-DR program received $12 billion in funding to address major disasters from 2023 to 2024 as part of a broader relief package enacted on December 21, 2024. These funds, allocated to 47 states, local governments, and Insular Areas, are now governed by the Notice, which is based upon feedback from stakeholders and aims to improve outcomes for disaster-impacted communities in the following ways:
- Standardizing Waivers and Requirements: Establish a uniform framework for future appropriations to reduce confusion and administrative delays.
- Encouraging Early Collaboration: Promote proactive and inclusive coordination among all recovery stakeholders.
- Advancing Equity: Ensure recovery actions consider protected classes, vulnerable populations, and disadvantaged communities.
- Fostering Resilience: Strengthen long-term community resilience to future disasters.
Key Changes in the Recent Notice
HUD’s goal is to simplify access to recovery funds by revising and simplifying many front-end requirements. These actions are in response to long-standing criticisms of the program that it takes too long to access the funds, thereby delaying household and community recovery. The Notice breaks down the CDBG-DR program into three straightforward phases:
- Developing and Submitting an Action Plan: Grantees need to work closely with stakeholders to develop their Action Plans, which are now due within 90 days of HUD’s Allocation Announcement Notice (AAN). These plans require 30 days of public comment, and larger allocations will also require public hearings. HUD has also eased the opportunity for grantees to quickly access funds for front-end administrative purposes.
- Financial Certification and Oversight: To help grantees focus on preparing their Action Plans, HUD will now provide up to 135 days to submit financial certification materials as opposed to the former 60-day window. HUD is also reducing regulatory burdens by accepting grantee certifications that were approved in the past five years. Clear documentation requirements ensure grantees meet financial controls and anti-fraud standards.
- Implementing Universal Notice Requirements: HUD has removed the need for upfront production of programmatic policies and procedures, thereby enabling grantees to access funds more quickly. Housing program P&Ps must be available for review within one year of the AAN, while program P&Ps must be available within 18 months.
Enhanced Policy Guidance
HUD’s updates also include significant policy changes. Recovery initiatives will now prioritize underserved communities, ensuring equity in economic development. Infrastructure projects in non-low-and moderate-income (LMI) areas are now eligible for partial credit and environmental review processes aligned to the FAST-41 permitting system for greater efficiency and transparency. HUD has modernized flood risk management by adopting its own Federal Flood Risk Management Standard (FFRMS), replacing FEMA’s floodplain framework. Additionally, Appendix C in the Notice overhauls duplication of benefit policies, making the rules clearer and easier to follow for grantees.
HUD has supported the Notice with the parallel issuance of various templates to guide the preparation of Action Plans and webinars to highlight the features and opportunities presented within the Notice. Materials and other information can be found on HUD’s Universal Notice webpage.
Implications for Recovery Stakeholders
The Notice signals HUD’s commitment to making CDBG-DR a more responsive, effective, and equitable program. For disaster-impacted communities, the changes mean faster access to recovery funds and clearer guidelines for action. Grantees will benefit from reduced administrative bottlenecks, enabling them to focus on rebuilding resilient and inclusive communities.
Key stakeholders—from state and local governments to non-profit organizations—should take immediate steps to familiarize themselves with the Notice’s provisions, especially the revised timelines and consultation requirements. Early and intentional coordination will be critical to maximizing the impact of these funds.
Hagerty Can Help
Whether you are a grantee, recovery partner, or community advocate, the Notice offers a pivotal opportunity to strengthen recovery efforts. Review it thoroughly, engage in early and inclusive planning, and align actions with HUD’s enhanced expectations for equitable and resilient recovery. We can work alongside recipients to make every dollar count and help communities rebuild stronger than ever before.
Stan Gimont, Senior Advisor for Community Recovery and former senior executive at the United States (US) Department of Housing and Urban Development (HUD).