CDBG 100%

CDBG Administration

Lesson 1: CDBG, entitlement vs State, and the Texas path through TDA

Texas Government Code 487.351 · TxCDBG Project Implementation Manual · 14 practice questions

Content current as of September 22, 2026, per the 2026 TxCDBG Project Implementation Manual (effective September 1, 2026) and the current eCFR.

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Reading

Community Development Block Grant money reaches Texas communities by two completely different roads, and knowing which road a given community is on changes almost everything else in this course, including which manual governs a project and which agency you actually answer to.

Two paths CDBG money takes from HUD to a Texas community HUD funds entitlement cities and counties directly every year. For everyone else, HUD allocates a block of funds to the State of Texas, and the Texas Department of Agriculture runs the TxCDBG program for non-entitlement cities under 50,000 population and non-entitlement counties with a non-metropolitan population under 200,000. HUD Entitlement Cities & Counties Funded directly, every year State of Texas TDA runs TxCDBG Non-entitlement cities & counties Direct, annual Via 487.351(a) Runs own Con Plan, Action Plan, CAPER Cities under 50,000 · counties under 200,000 non-metro population
CDBG reaches Texas two ways: entitlement cities and counties get funds directly from HUD every year, while everyone else is reached through the state, where the Texas Department of Agriculture runs TxCDBG under Texas Government Code 487.351(a).

What CDBG is for

The program's stated purpose is to develop viable communities by providing decent housing and a suitable living environment, and by expanding economic opportunities, principally for persons of low and moderate income. This course groups the work into four broad areas under that purpose: improving public facilities, improving housing, expanding economic opportunities through job creation and retention, and eliminating hazardous or emergency conditions. That grouping is a teaching device, not a list written into the statute, which (at 42 USC 5301(c)) states the primary objective and then lists more detailed goals. Every lesson in this course about eligible activities and national objectives traces back to one of those four areas.

Entitlement communities

Larger cities and urban counties receive CDBG funds directly from HUD every year, without going through a state agency. These are entitlement communities. Houston and Harris County are the entitlement grantees closest to GCHS's own service area, and they run their own Consolidated Plan, Action Plan, and CAPER process, covered in an earlier lesson, entirely in-house.

Non-entitlement communities and the Texas path

Everywhere smaller does not receive CDBG directly from HUD. Instead, HUD allocates a block of CDBG funds to each state, and the state runs its own competitive or formula program for the non-entitlement cities and counties within it. In Texas, the agency that runs this program is the Texas Department of Agriculture, not TDHCA, administering what is known as the Texas Community Development Block Grant program, TxCDBG, under the authority of Texas Government Code, Section 487.351(a), which directs the department to administer the state's CDBG nonentitlement allocation under 24 CFR Part 570, Subpart I.

Eligibility for TxCDBG is defined by population, not by any other characteristic of the community:

  • Non-entitlement cities under 50,000 in population.
  • Non-entitlement counties with a non-metropolitan population under 200,000.

A city or county that is not eligible for direct CDBG funding from HUD, and that falls under these population figures, is exactly who TxCDBG exists for. This is the majority of the geography GCHS actually works in. Most of the 13 Gulf Coast counties GCHS serves are TxCDBG territory, not entitlement territory, which means the TxCDBG Project Implementation Manual, not HUD's general CDBG regulations alone, is the operating rulebook for most GCHS- adjacent projects, even though the federal regulations covered earlier in this course remain the floor underneath everything TDA does.

Why the distinction matters beyond terminology

An entitlement grantee and a TxCDBG grantee both operate under the same federal statute and the same core CFR requirements: the national objectives, the eligible and ineligible activities, environmental review, labor standards, and so on. What differs is who administers the program day to day, what manual and forms actually govern the paperwork, and in some cases, specific numeric limits that TDA sets on top of the federal floor. This course has already flagged one example: the federal timeliness test at 24 CFR 570.902 is written in terms of an entitlement grant, and does not directly apply, in that specific form, to a TxCDBG grantee. TDA sets its own expenditure timing and administrative thresholds, and those live in the Implementation Manual, not in the CFR section written for entitlement communities.

The federal rules for the State program also sit in their own subpart. 24 CFR 570.480 says the other subparts of Part 570 do not apply to the State CDBG program unless expressly provided. So when a later lesson cites an entitlement section such as 570.208 (national objectives) or 570.200(a)(3) (the 70 percent test), TDA's counterparts are 570.483 and 570.484 in Subpart I, which parallel them closely but not word for word.

TDA's manual structure

The TxCDBG Project Implementation Manual is organized into numbered chapters covering administration and reporting, financial management, environmental review, contract special conditions, procurement procedures, acquisition, Davis-Bacon labor standards, force account labor, civil rights requirements, grant agreement amendments, grant agreement closeout, monitor review, and audit requirements, plus lettered sections covering the community development program overview, planning projects, housing rehabilitation, and self-help centers (the manual currently lists its Texas Capital Fund section as reserved). A grantee administering a TxCDBG contract works out of this manual day to day, using the federal regulations as the underlying authority the manual itself has to comply with.

What this means in practice for GCHS

Before assuming a federal rule from an earlier lesson applies unchanged to a specific GCHS-adjacent project, check whether the jurisdiction involved is an entitlement community or a TxCDBG community, because that answer decides which manual, which forms, and in some cases which numeric threshold actually governs. For the large majority of GCHS's Gulf Coast service area, the answer will be TxCDBG, which means the Implementation Manual is the document to have open, and TDA, not a HUD field office, is the agency a grantee is actually reporting to and being monitored by day to day.

Practice questions

1. What are the four broad areas of CDBG work that this lesson groups under the program's purpose?

  1. Improving public facilities, improving housing, expanding economic opportunities through job creation and retention, and eliminating hazardous or emergency conditions
  2. Building new government offices, funding political campaigns, purchasing equipment, and paying general operating expenses
  3. Funding only single-family new construction, multifamily new construction, commercial construction, and public parks
  4. Meeting the 70 percent primary objective, the national objectives, the two spending caps, and the timeliness test

2. What distinguishes an entitlement community from a non-entitlement community under CDBG?

  1. Entitlement communities are always small rural places funded by formula, while non-entitlement communities are always large urban centers that apply directly to HUD each year
  2. Non-entitlement communities always receive larger annual awards than entitlement communities, because the state adds its own revenue
  3. An entitlement community receives CDBG funds directly from HUD every year, while a non-entitlement community does not and instead accesses CDBG funds through its state
  4. There is no meaningful difference, because the state program simply passes every award back through HUD unchanged to the city

3. Which state agency administers the TxCDBG program for non-entitlement Texas communities?

  1. The Texas Department of Housing and Community Affairs, TDHCA
  2. The Texas Department of Agriculture, TDA
  3. The Texas General Land Office
  4. HUD's Fort Worth field office directly

4. What is the population threshold for a non-entitlement city to be eligible for TxCDBG?

  1. Under 200,000
  2. Under 10,000
  3. Under 100,000
  4. Under 50,000

5. What is the population threshold for a non-entitlement county to be eligible for TxCDBG, and what specific population figure does it apply to?

  1. A non-metropolitan population under 200,000
  2. A total county population under 50,000, counting all residents
  3. A non-metropolitan population under 500,000
  4. Counties are never eligible for TxCDBG, only cities

6. Under what legal authority does TDA administer the TxCDBG program?

  1. 24 CFR 570.902, the entitlement timeliness rule
  2. Texas Government Code, Section 487.351(a)
  3. 24 CFR Part 58, the environmental review regulations
  4. 2 CFR 200.320, the federal procurement methods section

7. The federal timeliness test at 24 CFR 570.902 is written in terms of an entitlement grant. What does this lesson say about applying that test directly to a TxCDBG grantee?

  1. It applies identically, since all CDBG grantees use the same entitlement grant formula and the same 1.5 ratio in every state and in every program year
  2. It never applies to any Texas grantee under any circumstance, including entitlement cities such as Houston
  3. It does not directly apply in that form to a TxCDBG grantee, since TDA sets its own expenditure timing rules in the Implementation Manual
  4. It applies only to counties, never to cities, regardless of entitlement status or the size of the grant

8. Do entitlement grantees and TxCDBG grantees operate under different federal statutes and different core CFR national objective requirements?

  1. Yes, entirely different federal statutes apply to each
  2. No, both operate under the same federal statute and the same core CFR requirements; what differs is administration, forms, and some TDA-specific numeric thresholds layered on top
  3. Yes, only entitlement grantees are subject to national objective requirements
  4. No, but only because TDA has formally adopted HUD's regulations word for word with no additions

9. Which document governs the day-to-day paperwork and administrative process for a TxCDBG grantee?

  1. HUD's Consolidated Plan regulations at 24 CFR Part 91 exclusively
  2. The Uniform Relocation Assistance Act handbook
  3. Whatever internal policy the grantee itself chooses to write, with no state document involved
  4. The TxCDBG Project Implementation Manual

10. For most of the 13 Gulf Coast counties GCHS serves, which path is more likely to govern a CDBG-funded project: entitlement or TxCDBG?

  1. TxCDBG, since most of GCHS's service area falls under the non-entitlement population thresholds
  2. Entitlement, since Houston and Harris County together represent all 13 counties of GCHS's service area
  3. Neither; GCHS's service area receives its CDBG funds through a separate federal program run by HUD field offices
  4. It cannot be determined without first measuring each county's total land area and highway mileage

11. What underlying authority does the TxCDBG Project Implementation Manual itself have to comply with, according to this lesson?

  1. Texas Government Code 487.351(a) alone, since a state statute replaces the federal regulations for any grant TDA administers
  2. TDHCA's own program regulations, which TDA adopts word for word for its community development awards
  3. The federal CDBG regulations covered earlier in this course, which remain the floor underneath everything TDA does
  4. HUD's Consolidated Plan and Action Plan process exclusively, which TDA runs for each grantee

12. Besides its numbered chapters on administration, financial management, and environmental review, what do the TxCDBG Project Implementation Manual's lettered sections cover?

  1. Fair housing complaint procedures and the grantee's annual fair housing certification forms
  2. Section 3 hiring preferences and the summary report forms that go with them
  3. URA replacement housing payments and relocation claim forms for displaced tenants
  4. The program overview, planning projects, housing rehabilitation, and self-help centers

13. Which entitlement grantees does this lesson identify as closest to GCHS's own service area?

  1. Houston and Harris County
  2. Harris County and Galveston County
  3. The City of Beaumont and Jefferson County
  4. TDHCA and the General Land Office

14. What is the CDBG program's stated overall purpose, as distinct from the four broad areas of work that sit under it?

  1. To maximize the number of activities completed within the timeliness test
  2. To develop viable communities by providing decent housing and a suitable living environment, and by expanding economic opportunities, principally for persons of low and moderate income
  3. To fund entitlement communities exclusively, with TxCDBG as a secondary program
  4. To ensure every dollar spent individually meets a 51 percent low and moderate income benefit

Glossary

Entitlement community
A city or urban county that receives CDBG funds directly from HUD every year, without going through a state agency.
Non-entitlement community
A city or county not eligible for direct CDBG funding from HUD; it accesses CDBG funds through its state's program instead.
TxCDBG
The Texas Community Development Block Grant program, administered by TDA for non-entitlement Texas cities and counties under Texas Government Code 487.351(a).
Texas Department of Agriculture (TDA)
The state agency that administers TxCDBG for non-entitlement communities; not TDHCA.
TxCDBG Project Implementation Manual
TDA's governing document for day-to-day TxCDBG administration, built on top of the underlying federal CDBG regulations.
Consolidated Plan, Action Plan, CAPER
The planning and reporting cycle an entitlement grantee runs in-house; not required of TxCDBG grantees in the same form.
Timeliness test
The federal expenditure-pace requirement at 24 CFR 570.902, written for entitlement grants; TDA sets its own expenditure timing for TxCDBG grantees instead.
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