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AYBR Program Administration

Lesson 9: Costs, estimating and procurement

Module 4, The project · 14 practice questions

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Money is where many program mistakes begin, and it is also where they are easiest to prevent. This lesson shows how the grant is split, how to price a job, and how to buy the work in a way the Department will accept. Lesson 8 ended with an approved work write-up. Everything here happens after that and before any contractor starts work.

The money in one picture

Each household can receive a one-time grant of up to $22,500 in combined Hard and Soft Costs. The 2026 AYBR NOFA sets that limit, and the Program Manual repeats it. The rule leaves the number to the NOFA, so the NOFA is where you check it each year.

The administrative fee is separate. Under 10 TAC 26.21 and the Program Manual, the fee is 10 percent of the Project Costs (Hard plus Soft) and it is paid "in addition to the grant amount." The most the fee can be on a full $22,500 project is $2,250. The fee is figured on what you actually draw, not on what you reserved. GCHS charges applicants no fees of any kind (GCHS procedure).

How a $22,500 reservation splits A bar showing the $22,500 maximum grant split into Hard Costs of $20,455 and Soft Costs of $2,045, which is about one eleventh of the total. A second bar below shows the administrative fee of up to $2,250, which is 10 percent of Hard plus Soft Costs drawn and is paid on top of the grant. Most that can be reserved: $22,500 in Project Costs Hard Costs $20,455 construction costs: labor, materials, permits Soft Costs $2,045 (at most 10% of Hard Costs) On top of the grant $2,250 Administrative fee: 10% of the Hard plus Soft Costs actually drawn One reimbursement from the Department covers the project draw and the administrative draw.
A full reservation splits into about 91 percent Hard Costs and about 9 percent Soft Costs, and the administrative fee is paid in addition.

Hard Costs and Soft Costs

The rule defines Hard Costs as site-specific costs incurred during construction, including permits, a jobsite toilet, a dumpster, demolition, materials and labor. Soft Costs are costs related to a specific unit that are other than construction costs. The Program Manual gives examples, and the table below sorts the common ones.

CostCategoryNote
Permits, jobsite toilet, dumpsterHardNamed in the rule's definition
Demolition, materials, laborHardPart of the construction contract
Administrator staff or consultant time with the householdSoftDocument it in the Activity File
Administrator staff mileageSoftClaimed on the Soft Cost invoice
Consultant mileageNot a Soft CostThe manual excludes it
Septic inspection, lead testingSoftManual examples
Contracting out the inspection or the work write-upSoftManual, page 23

Soft Costs are optional. If you use them, they cannot exceed 10 percent of Hard Costs. The quick way to find the ceiling on a reservation is to divide the total by 11. At the maximum that gives Hard Costs of $20,455 and Soft Costs of $2,045 (the manual shows the exact Soft figure as $2,045.45). Soft Costs are claimed on the Activity Soft Cost Invoice and supported by documents in the Activity File.

When a final draw is smaller than the reservation, the test follows the draw: the Soft Costs you request must not exceed 10 percent of the Hard Costs you request. Check the numbers yourself before you submit.

Why this matters

The Department enters the administrative fee when the reservation is set up, but it pays only on what you actually draw. Reserving $22,500 for a $17,000 job does not create a $2,250 fee. Staff who assume it does will promise a number the final draw cannot deliver.

Worked example: the Delgado household

Ms. Delgado (a made-up household) lives in a 1962 owner-occupied house in Montgomery County. Her inspection calls for a roll-in shower, grab bars and a wider bathroom door. GCHS reserved the full $22,500: Hard $20,455 and Soft $2,045.

  1. The selected line-item bid totals $17,600. That is the Hard Costs request.
  2. GCHS claims $1,100 of staff time and $300 for lead testing, so Soft Costs are $1,400. The ceiling is 10 percent of $17,600, which is $1,760, so the request passes.
  3. The total project draw is $17,600 plus $1,400, or $19,000.
  4. The administrative draw is 10 percent of $19,000, which is $1,900.
  5. The Department reimburses $20,900 in all, not $24,750.

The Hard Costs figure also drives the hazard caps from Lesson 8. The sources do not say whether the caps use the reserved Hard Costs or a smaller final contract, so the cautious practice is to use the lower figure. Twenty-five percent of $17,600 is $4,400, and the 40 percent combined ceiling is $7,040. Sizing the caps on the reserved $20,455 instead would allow $5,113.75 and $8,182, which could overspend on hazards without anyone noticing.

Your written procurement policy comes first

The Program Manual says all Administrators must establish written procurement policies, and Lesson 5 listed it among the policies to adopt before taking applications. The policy must follow the Chapter 1 cost principles (10 TAC 1.402 requires TxGMS or UGMS). The manual also points to Local Government Code 262.003(a) for counties, 252.021(a) for cities, Government Code Chapter 2254 for professional services, and TxGMS. Its rule of thumb is that Administrators must meet the most stringent procurement requirement that applies to them.

The procurement steps

The manual lays out the sequence. The Administrator, not the household or the contractor, runs it.

  1. Define the goods or services. For AYBR that is the Department-approved work write-up.
  2. Research an independent cost estimate.
  3. Solicit multiple contractors.
  4. Compare each quote or bid to the independent estimate.
  5. Select the winner and draft a contract that states each party's responsibility.
  6. Document every step as it is completed (GCHS keeps the record in the Activity File).

Notice what is missing: a number of bids. No rule, manual page or NOFA sets one. The manual says "multiple." Follow your written policy and any stricter law that applies to you, and write the number you use into the policy so you can show it later.

You solicit bids only after the Department has reviewed the work write-up and cost estimate (10 TAC 26.27(e)). Soliciting early means pricing a scope that may change.

Line-item bids only

10 TAC 26.27(f) says "Lump sum bids will not be accepted." The manual adds that lump-sum quotes and bids will be rejected and that zero-line items are not acceptable. The reasons are practical. Line items give the Department something to review, give you a price basis for change orders, and give future estimators real unit costs. Give contractors a bid form built from the approved write-up so every bidder prices the same lines.

Comparing bids: back to the Delgado job

Suppose GCHS's policy calls for three line-item bids on the Delgado bathroom (the AYBR documents set no number, so this is the policy talking). The independent cost estimate comes in at $17,900. The bids arrive as follows.

  • Contractor A bids $17,600 on every line of the bid form.
  • Contractor B bids $19,100, also complete.
  • Contractor C bids $15,900, but shows $0 for debris removal.

Contractor C is out before price is discussed, because a zero-line item is not acceptable. Contractor B is complete but above the estimate. Contractor A is complete and a little under the estimate, so A is the natural selection. The point is not the arithmetic. The point is the file: it should show the three bids, the estimate, the comparison and the reason for the choice. That comparison is how you show the price is reasonable. The documents give no percentage that makes a bid "too high," so if you want a trigger for re-soliciting, state it in your policy. For anything else, check the current Program Manual.

Choosing and vetting contractors

The manual offers a pre-qualification checklist as an example, not a rule: years of residential rehabilitation experience, registration with the Secretary of State and Comptroller, general liability and workers' compensation certificates, EPA lead (RRP) certification, financial strength to carry the job without prepayment, and references. Pre-bid site visits are an optional best practice.

On debarment, the NOFA and the manual both tell Applicants to familiarize themselves with the Department's certification and debarment policies, and 10 TAC 20.6(b)(2) says an Applicant debarred by HUD or the Department may be ineligible. The sources do not give a step-by-step contractor check, so build one into your policy and keep a dated record of it in the file. That is good practice, not a TDHCA requirement.

Independence matters as much as price. GCHS provides inspection, estimating and construction management, not hands-on repair labor. GCHS staff who inspect or estimate a job never bid on it, and the contractors are independent firms (GCHS procedure). The manual goes further for outside help: an inspector, and any specialist who helps, must be excluded from consideration as a contractor on that activity.

The Department reviews the selected bid

Stage 3 is the procurement review. You upload the selected line-item quote or bid, signed by the Head of Household and the Contractor, with the construction contract and its checklist. The Department aims to review within 14 calendar days, and an administrative deficiency has the usual 14-day cure period. Do not let the contractor begin until the Department tells you to proceed. Lesson 10 covers that step. Treat the 14 days as a planning figure, not a promise: the manual says the Department "will attempt" to meet it, and the rule sets no review time at all.

When the bids come in too high

Suppose the lowest line-item bid exceeds the money reserved and the scope includes hazard repairs. You cannot trim the hazard work to fit. The manual says hazard work may not be deleted because of budget limitations or lack of applicant consent. You must commit supplemental funding or risk cancellation, and sometimes the right answer is the walk-away policy you adopted in Lesson 5, with a written notice to the household.

A quick illustration: the lowest complete bid on another job is $21,300 against $20,455 of reserved Hard Costs, a gap of $845, and the scope includes an unsafe electrical panel. The panel stays in. GCHS either commits $845 of its own supplemental funding or follows its walk-away policy and tells the household in writing. Quietly trimming the panel from the scope is not an option, and GCHS charges applicants no fees, so the gap does not go to the household (GCHS procedure).

Where the paperwork lives

Keep the written procurement policy in the Program File, in the section for procurement and eligibility policies, and keep each household's bids, estimate comparison and signed Stage 3 documents in that household's Activity File. At GCHS, program forms and policies sit in the shared AYBR Working-Files folder. Anything holding a Social Security number, income detail or citizenship document stays in the GCHS Restricted SharePoint library and never goes into the shared folder (GCHS procedure).

What goes wrong

These are teaching examples drawn from the requirements, not TDHCA findings data.

  • Accepting a lump-sum bid because the total looked good.
  • Soliciting bids before Stage 2 approval.
  • Figuring the administrative fee on the reserved amount.
  • Claiming Soft Costs above 10 percent of the Hard Costs requested.
  • Skipping the independent cost estimate, or not documenting the comparison.
  • Letting someone who wrote the scope bid on the job.

Practice questions

1. Under the 2026 NOFA, what is the most that can be spent on one household's Project Costs, and where does the administrative fee fall?

  1. $22,500 in total, with the administrative fee taken out of it, leaving $20,250 for the work
  2. $20,455 in Hard Costs only, with Soft Costs and the administrative fee both paid from a separate pool of funds
  3. $22,500 in combined Hard and Soft Costs, with the administrative fee paid in addition to that amount
  4. $24,750 in Project Costs, because the administrative fee is counted as part of Project Costs

2. A household is reserved at the $22,500 maximum. What are the default Hard and Soft Cost amounts?

  1. Hard $20,455 and Soft $2,045, found by dividing the total by 11
  2. Hard $20,250 and Soft $2,250, found by taking 10% of the total as Soft Costs
  3. Hard $19,500 and Soft $3,000, because Soft Costs may be up to 15% of Hard Costs
  4. Hard $22,500 and Soft $0, because Soft Costs are never allowed at the maximum

3. Which of these is a Soft Cost under the Program Manual?

  1. A consultant's mileage for driving to the household's home to meet the family
  2. The contractor's jobsite toilet and dumpster rental for the length of construction
  3. Demolition of a damaged bathroom floor before the new shower is installed
  4. A septic system inspection ordered before the work write-up

4. GCHS reserved $22,500, but the final draw is Hard Costs of $17,000 and Soft Costs of $1,500. What is the administrative fee?

  1. $2,250, which is 10% of the $22,500 reserved
  2. $1,850, which is 10% of the $18,500 actually drawn
  3. $1,700, which is 10% of the Hard Costs alone
  4. $2,045, which is the default Soft Cost amount at the maximum

5. A final draw requests Hard Costs of $16,400. What is the most Soft Costs that can be requested with it?

  1. $2,045, because the default Soft Cost amount from the reservation stays the ceiling whatever the draw is
  2. $1,640, because Soft Costs requested may not exceed 10% of Hard Costs requested
  3. $1,491, which is the $16,400 of Hard Costs divided by 11
  4. $2,250, which is 10% of the maximum grant

6. A contractor's bid gives one lump-sum price for a bathroom modification plus a line showing $0 for debris haul-off. What should GCHS do?

  1. Accept it if the lump sum is below the independent cost estimate
  2. Accept the lump sum but ask the contractor to replace the $0 line with a nominal price
  3. Send it to the Department as it is, because only the Department has authority to reject a bid for pricing
  4. Reject it and require line-item pricing, because lump-sum bids and zero-line items are not accepted

7. When may GCHS solicit bids for a household's work?

  1. After the Department has reviewed the work write-up and cost estimate at Stage 2
  2. As soon as the HAC is fully executed, so bids are ready when Stage 2 is submitted
  3. After the Department approves the selected bid at Stage 3
  4. Once the household signs the intake application

8. How many bids must GCHS collect for each job?

  1. At least three, as the Program Manual requires
  2. At least two, as 10 TAC 26.27 requires
  3. No number is set in the rule, manual or NOFA, so follow the written procurement policy and any stricter law that applies
  4. One, as long as it is within the independent cost estimate

9. Which statement about the written procurement policy is correct?

  1. It is optional for nonprofit Administrators
  2. It may be adopted after the first bid is solicited, as long as it is in place before the final draw is submitted to the Department
  3. It replaces the Department's review of the selected bid
  4. It must exist in writing, follow the Chapter 1 cost principles, and meet the most stringent requirement that applies

10. An outside specialist who helped the inspector evaluate a problem and recommend a fix on the Alvarez household's job asks to bid as the contractor on that same job. What is the answer?

  1. No, because the inspector and any specialist who helps must be excluded from consideration as a contractor on that activity
  2. Yes, if the specialist discloses the relationship in the Activity File and the other bidders are told about it in writing before bids are opened
  3. Yes, if the specialist's bid is the lowest received
  4. Yes, but only for the Soft Cost items

11. What do the AYBR documents say about checking contractors for debarment?

  1. They require a written debarment certification signed by each contractor on a Program form
  2. They require a debarment check only for contracts above a dollar amount set in the NOFA
  3. They tell Applicants to learn the Department's debarment policies but give no contractor check procedure, so GCHS builds one into its policy
  4. They say debarment matters only for the Administrator and never for a contractor

12. What does the Department review at Stage 3, procurement review?

  1. Every bid received, ranked by price, with the lowest bidder approved automatically unless the household objects to it in writing
  2. The selected line-item quote or bid signed by the Head of Household and the Contractor, with the construction contract
  3. Only the contractor's insurance certificates and registrations
  4. The final inspection and the After photos

13. A household's Hard Costs budget is $18,000. Before alarm-type exceptions or a Department-approved different ratio, what is the most that may go to life-threatening hazard and unsafe-condition repairs?

  1. $4,500, which is 25% of the Hard Costs budget
  2. $7,200, which is 40% of the Hard Costs budget
  3. $5,625, which is 25% of the $22,500 maximum grant
  4. $1,800, which is 10% of the Hard Costs budget

14. The approved estimate is higher than the money reserved, and the scope includes hazard repairs. What does the Program Manual say about those repairs?

  1. Drop them and note the budget limit in the Activity File
  2. Move them into Soft Costs so the Hard Costs cap does not apply
  3. Ask the household to pay the difference at the final inspection
  4. They may not be deleted for budget reasons, so GCHS must commit supplemental funding or risk cancellation

Glossary

Hard Costs
Site-specific costs during construction, such as permits, jobsite toilet, dumpster, demolition, materials and labor (10 TAC 26.21).
Soft Costs
Optional costs for a specific unit other than construction, such as Administrator staff time and septic inspection; capped at 10 percent of Hard Costs.
Project Costs
Hard plus Soft Costs, the program funds that directly assist a household; up to $22,500 per household.
Administrative fee
Ten percent of the Hard plus Soft Costs actually drawn, paid to the Administrator in addition to the grant.
Independent cost estimate
An estimate researched separately from the bids and used to compare them.
Line-item bid
A bid priced line by line against the approved work write-up; lump-sum and zero-line bids are rejected.
Procurement policy
The Administrator's written rules for buying construction services, consistent with Chapter 1 cost principles.
Debarment
A formal bar from program participation; Applicants should know the Department's debarment policies.
Activity Soft Cost Invoice
The document used to claim a household's Soft Costs, supported by records in the Activity File.