- Build funding priorities on unmet needs assessments, GIS mapping, and demographic data.
- Develop a transparent approach for allocating limited CDBG-DR funding across housing, infrastructure, public services, and mitigation needs.
- Use community input alongside data analysis to inform program design and guide recovery investments.
These Key Takeaways were generated by AI and reviewed by a BDO professional.
When a community receives a CDBG-DR allocation, one challenge becomes clear almost immediately: funding will not cover every recovery need.
Housing, infrastructure, economic recovery, public services, and mitigation projects all compete for limited resources. The CDBG-DR Action Plan is the HUD-required document that establishes how those resources will be allocated, which needs will be addressed first, and how programs will be delivered. And because grantees typically have 90 days to submit their Action Plan to HUD, those decisions have to be made quickly.
The strongest Action Plans follow a deliberate process for making those decisions.
1. Build your allocation strategy on data
The most important question during Action Plan development is: Where should funding go first? The answer starts with data.
Communities should combine information from multiple sources to understand the full picture of disaster impacts and remaining unmet need. FEMA Individual Assistance data, FEMA Public Assistance data, SBA loan data, insurance information, housing assessments, utility assessments, economic impact studies, local damage inspections, and property records all contribute to that picture.
GIS mapping is particularly valuable because it helps communities identify patterns that are difficult to see in spreadsheets alone. Mapping can show where housing losses are concentrated, where infrastructure failures had the largest impacts, where displaced residents are located, and where recovery gaps remain. It also helps show how investments align with HUD-identified most impacted and distressed (MID) areas, where at least 80 percent of the CDBG-DR allocation must benefit.
Data should also help communities understand who was affected. Because CDBG-DR grants must meet an overall (70 percent) benefit requirement for low- and moderate-income (LMI) persons, demographic and income analysis is critical. Communities often use census data, HUD LMI data, social vulnerability indices, housing affordability data, and local demographic information to identify:
- Neighborhoods with large concentrations of LMI households.
- Areas where residents face the greatest barriers to recovery.
- Locations where housing affordability challenges existed before the disaster.
- Communities that may require targeted outreach and assistance.
Understanding unmet need without considering where and how programs can serve eligible populations can create challenges later in the process.
Strong Action Plans use data to answer five questions:
- Where did damage occur?
- Who was affected?
- What assistance has already been provided?
- What needs remain?
- Which populations should recovery programs prioritize?
Those answers become the foundation for every funding decision that follows.
2. Decide what funding should cover
Every Action Plan faces the same reality: unmet needs exceed available funding.
Housing assessments may identify substantial recovery needs. Infrastructure projects may have significant public safety implications. Economic recovery investments may support businesses and jobs. Public service providers may be dealing with increased demand for healthcare, childcare, housing counseling, transportation assistance, or mental health needs.
Most communities cannot fund every project, assist every household, or address every recovery challenge through a single allocation. As a result, one of the most important Action Plan decisions is determining what funding should cover first. Many communities establish funding priorities using factors such as:
- Severity of unmet need
- Number of residents served
- Impact on LMI households
- Public health and safety benefits
- Long-term community value
- Readiness to launch
- Ability to leverage other funding sources
- Long-term operating and maintenance requirements
- Capacity to implement, including staff and partner organizations
The goal is not to determine whether housing, infrastructure, or economic recovery is more important. The goal is to determine which recovery needs should receive funding first and how limited resources can deliver the greatest community impact.
Documenting priorities also helps leaders communicate funding decisions to residents, elected officials, federal partners, and stakeholders. Those priorities then shape the award caps and eligibility criteria that the Action Plan must include for each program.
3. Use community input to refine priorities
Data provide an important starting point, but residents and local organizations often identify recovery challenges that are not visible in federal datasets or damage assessments.
Leaders can gather this information through public meetings, surveys, stakeholder interviews, workshops, focus groups, and consultations with local organizations.
Community input can help recovery leaders understand:
- Why residents have not returned home
- Which infrastructure issues have the greatest day-to-day impact
- Where housing shortages are affecting recovery
- Which services communities need most
- What investments residents view as most important
Communities should gather input before programs are finalized. Waiting until after funding decisions are made limits the ability to incorporate community priorities into the Action Plan. Early outreach also helps communities gather input from organizations that play an important role in recovery, including neighboring jurisdictions, Continuum of Care agencies, and public housing agencies.
HUD requires substantial citizen participation before an Action Plan is submitted, including at least one public hearing for grantees receiving $20 million or more in CDBG-DR funding. The draft Action Plan must also be made available for public comment for at least 30 days before submission.
Resident feedback can help decision-makers test assumptions, identify gaps in available data, and better understand where funding can have the greatest impact.
4. Connect every funding decision to a documented need
A strong Action Plan creates a clear connection between identified unmet recovery or mitigation needs and proposed investments.
Housing programs should be supported by housing data. Infrastructure projects should be supported by infrastructure assessments. Economic recovery efforts should be supported by business and workforce data. Public service investments should be connected to documented service gaps.
The Action Plan should clearly answer: Why is funding being allocated this way?
HUD expects allocations to be reasonably proportionate to the needs identified in the plan's assessments or supported by a justification when they are not. When each allocation is tied directly to a documented need, communities can clearly explain funding decisions, communicate priorities, and maintain public trust, especially when difficult tradeoffs are required.
5. Identify opportunities to reduce future risk
Action Plan development gives leaders an opportunity to identify projects that address current recovery needs and also strengthen a community's ability to withstand future disasters. Every Action Plan must include a mitigation needs assessment informed by current FEMA-approved hazard mitigation plans, and mitigation measures must be built into construction activities.
As priorities are determined, communities should consider investments that address identified hazards, such as:
- Water and wastewater system improvements
- Utility hardening projects
- Evacuation route improvements
- Transportation network enhancements
- Flood mitigation projects
- Wildfire mitigation measures
- Housing resilience investments
- Strategic buyout programs in high-risk areas
These projects compete for the same finite funding as other recovery activities, along with any activities to be funded from the grantee’s mitigation set-aside. That is why mitigation planning should occur alongside funding allocation discussions, not after they have been completed.
Moving from unmet need to funding decisions
The Action Plan process ultimately comes down to a series of allocation decisions. The quality of those decisions can influence recovery efforts for many years after funding is awarded.
Communities that invest time in data analysis, GIS mapping, income and demographic analysis, community engagement, funding prioritization, and mitigation planning are often better positioned to direct resources where they can have the greatest impact. And because recovery needs change over time, a well-documented Action Plan makes future amendments easier to justify and carry out.
How BDO Government Services Can Help
BDO Government Services supports communities throughout the recovery lifecycle, from Action Plan development through program implementation and closeout. Our teams help clients:
- Conduct unmet needs assessments and data analysis.
- Develop GIS mapping and recovery dashboards.
- Facilitate public meetings, surveys, and stakeholder outreach.
- Establish funding priorities and allocation strategies.
- Design recovery, mitigation, and resiliency programs.
- Launch and manage CDBG-DR programs.
- Support compliance, reporting, monitoring, and grant management.
Whether a community is developing an Action Plan, launching programs, or managing long-term recovery efforts, BDO Government Services provides the technical, operational, and program management support needed to move recovery forward.