REFUGEE INDIVIDUAL DEVELOPMENT ACCOUNTS PROGRAM OVERVIEW
Purpose and Objectives
The Refugee IDA Program represents an anti-poverty strategy built on asset accumulation for low-income refugee individuals and families with the goal of promoting refugee economic independence.
IDAs are leveraged or matched savings accounts established in qualified financial institutions. In the Refugee IDA Program, IDAs are matched with federal funds that have been allocated as "match funds" from at least 65 percent of the annual federal grant award. The funds are intended for the Asset Goals specified in this announcement. Although the refugee participant maintains control of all funds that the participant deposits in the IDA, including all interest that may accrue on the funds, the participant must sign a Savings Plan Agreement that specifies the funds in the account will be used only for the participant's qualified Asset Goal(s) or for an emergency withdrawal.
The objectives of the Refugee IDA Program are to help participants:
- Establish IDAs;
- Maintain regular saving habits;
- Participate in the financial institutions of this country;
- Acquire assets to build individual, family, and community resources;
- Increase their knowledge of financial and monetary topics, including developing a household budget;
- Advancing the education;
- Buy homes;
- Gain access to capital; and
- Increase the socio-economic development of their communities.
These new projects will accomplish these objectives by establishing programs that combine the provision of matched savings accounts with financial training and counseling.
To be eligible to participate in the Refugee IDA Program, individuals must have the following statuses (see 45 CFR § 400.43(a) (1)-(6)) or statutory provisions cited below:
- Individuals paroled as refugees or asylees under § 212(d)(5) of the Immigration and Nationality Act (INA).
- Refugees admitted under § 207 of the INA.
- Asylees whose status was granted under § 208 of the INA.
- Cuban and Haitian entrants, in accordance with the requirements in 45 CFR § 401.2
a. Any individual granted parole status as a Cuban/Haitian Entrant (Status Pending) or granted any other special status subsequently established under the immigration laws for nationals of Cuba or Haiti, regardless of the status of the individual at the time assistance or services are provided;
b. A national of Cuba or Haiti who was paroled into the United States and has not acquired any other status under the INA and with respect to whom a final, non-appealable, and legally enforceable order of removal, deportation, or exclusion has not been entered;
c. A national of Cuba or Haiti who is the subject of removal, deportation, or exclusion proceedings under the INA and with respect to whom a final, non-appealable, and legally enforceable order of removal, deportation, or exclusion has not been entered;
d. A national of Cuba or Haiti who has an application for asylum pending with the Department of Homeland Security/United States Citizenship and Immigration Services or Department of Justice/Executive Office for Immigration Review and with respect to whom a final, non-appealable, and legally enforceable order of removal, deportation or exclusion has not been entered
- Lawful permanent residents provided the individuals previously held one of the statuses identified above. (Note that this does not refer to Amerasians who are admitted as lawful permanent residents. See #6 below.)
- Certain Amerasians from Vietnam who are admitted to the United States as immigrants pursuant to § 584 of the Foreign Operations, Export Financing, and Related Programs Appropriations Act, 1988 (as contained in § 101(e) of Pub. L. 100-202), as amended (8 U.S.C. § 1101 note).
- Iraqi and Afghan Special Immigrants per section 1244(g) of Div. A of Pub. L. 110-181, as amended (8 U.S.C. § 1157 note) and section 602(b) (8) of Div. F of Pub. L. 118-8, as amended (8 U.S.C. § 1101 note).
- Victims of a severe form of trafficking in persons per the Victims of Trafficking and Violence Protection Act of 2000, Pub. L. 106-386, as amended, 22 U.S.C. § 7105(b) (1) (A) and (C).
Detailed information on eligibility of ORR-funded projects is available at 45 § CFR 400.43 and ORR Policy Letter 16-01, which can be found on the ORR website at: www.acf.hhs.gov/programs/orr/resource/policy-letter-16-01.
ORR assistance and services must be provided to refugees without regard to race, religion, nationality, sex, or political opinion.
A Form I-94 showing admission into the United States as a refugee, or an Asylum Grant Letter are acceptable documents to prove eligibility status. A United States Permanent Resident Card (USCIS Form I-551) also known as a green card, or an Employment Authorization Document are also acceptable documents to prove eligibility only if they contain codes that show the applicant is in one of the eligible statuses.
Intake information must include the client's name, status under which client arrived in the U.S, date of eligibility, date of enrollment, date of projected Program service termination, documentation of eligibility for Refugee IDA Program services, alien number, birth date, and current address.
Among eligible clients, enrollment in the Refugee IDA Program is limited to eligible individuals:
- Who are not yet citizens and who have been in the U.S. for not more than 5 years at the time of enrollment;
- Who have earned income;
- Whose gross household earned income at the time of enrollment does not exceed 200 percent of the federal poverty level if enrolling for the purpose of purchasing Education and Vocational Training goals, Microenterprise Capitalization goals, and/or Vehicle goals;
- Whose gross household earned income at the time of enrollment does not exceed 200 percent of the HHS federal poverty level, or does not exceed 80 percent of the Housing and Urban Development's Area Family Median Income (HAMFI) only if enrolling for the purpose of a Home Purchase;
- Whose assets at the time of enrollment do not exceed $10,000, excluding the value of a primary residence and one vehicle; and
- Who have not already received IDA match funds from an ORR-funded IDA program.
Clients who are enrolled into the Refugee IDA Program with a household income that exceeds 200 percent of the HHS poverty level but does not exceed 80 percent of the HAMFI are only eligible for the purpose of a Home Purchase. If the client fails to complete the program and purchase a home, they may not switch to any other Asset Goals and must exit the program without receiving any Match Funds. Federal funds obligated for matching the IDAs of clients who meet this description should be re-allocated for matching other IDAs immediately.
IDAs are established for refugee participants at a qualified financial institution. Refugee participants will systematically contribute to the IDAs out of earned income to purchase specified Asset Goals. The primary focus of the Asset Goals in their Refugee IDA Program is limited to the following areas:
- Primary Residence Home Purchase;
- Vocational Training, Professional Recertification, and Education (limited to postsecondary education costs, college entrance exam fees, and TOEFL and GED preparation and test fees) as required for employment, certification, or education purposes;
- Microenterprise Capitalization, including home-based child care services; and
- Vehicle Purchase.
Please see Definition and Explanation of Terms in this section for further detail. In cases of documented necessity, the purchase of an automobile is allowable for the purposes of employment or education. The purpose of an automobile purchase must be thoroughly justified and well documented. Justification can include, but is not limited to, lack or high cost of public transportation, or long distances to work, school, or business.
Savings Plan Agreement and Documentation
A Savings Plan Agreement must be established with each refugee participant. The Savings Plan Agreement must include:
(1) A proposed schedule of savings deposits by the participant;
(2) The rate at which the participant's savings will be matched by federal funds allocated as "match funds";
(3) The Asset Goal(s) for which the account is maintained;
(4) Any training or counseling that the participant agrees to attend;
(5) An agreement that the participant will not withdraw funds except for the specified Asset Goal or for an emergency and only after notification and approval;
(6) A statement by the participant that they have not received the maximum allowable match from any other ORR-funded IDA program;
(7) A procedure for amending the Agreement;
(8) A date by which assets must be purchased or the date on which the program will end;
(9) A designation of beneficiary;
(10) An individualized statement by the organization on which partners will be engaged during the clients' enrollment and how the partners will contribute; and
(11) If saving for a vehicle, a statement by the participant that the vehicle will be used for the purposes of maintaining or upgrading employment or for the purpose of transportation for education, vocational training, recertification, or small business use.
Appropriate documentation for the usage of an automobile could include a calculation of long distances from the participant's home to their place of employment or educational institution, public transportation schedules showing unreasonable time tables and connections, the anticipation of increased wages due to more time on the job or access to better wages or employment due to reduced commuting time, and school transcripts showing current enrollment.
Additional provisions may be proposed to be included in the Savings Plan Agreement. In addition to the Savings Plan Agreement, confirmation of the client's eligibility must be documented, which may include household budget, assets and liabilities, and earned income (this can be in the form of pay stubs, tax returns, etc.). Furthermore, each participant is required to provide an overall household budget plan describing how their IDA savings will derive from their discretionary income.
Programs must ensure compliance with 45 CFR §75.202 (e) to take reasonable measures to safe-guard protected personally identifiable information. If the Refugee IDA Program is using an electronic case file system, then safeguards such as limiting access to the data and encryption must be in place to protect participant information. Paper files must be kept confidential--ideally in a file cabinet that is kept locked and can be accessed only by authorized staff.
Training and Technical Assistance
All refugee participants must complete at least two forms of trainings in order to complete an asset purchase: Financial Literacy training and Asset-Specific training. Trainings must be provided in-house, or through a partnership with organizations that have demonstrated expertise in the area of training to be provided. Refer to Section I. Program Description, Definition and Explanation of Terms, Partnering with Organizations With Areas of Expertise.
Trainings must be provided in-house, or through a partnership with organizations that have a demonstrated expertise in the area of training to be provided. Please see Section I. Program Description, Definition and Explanation of Terms, Partnering with Organizations With Areas of Expertise.
Asset-specific training must be provided for refugee participants for each Asset Goal that is available through the program. These trainings may be provided directly by the grantee if they have a relevant area of expertise, or through other providers who specialize in the asset goals (e.g., HUD Housing Counselors, bank partners that provide car loans, SBA Program for Investment in Microentrepreneurs partners, etc.), or a combination of both approaches.
Financial literacy training must include, but is not limited to, the following topics: budgeting, cash management, savings, investment, and credit counseling. Due to the diverse nature of the refugee population, training must be culturally and linguistically appropriate.
At minimum, the client(s) listed on the Savings Plan Agreement must attend all required trainings; however, the entire household should be encouraged to participate. While ORR recognizes that the industry standards for financial literacy and asset-specific trainings usually span 6 to 8 hours, sufficient trainings must be provided for the client in a manner which best meets their needs. Clients are ineligible to make asset purchases until all training requirements are met.
Technical assistance must be provided for refugee participants for each Asset Goal provided through the program. Technical assistance can include, but is not limited to, setting up IDAs at participating banks, developing business plans, and assisting with the home purchase closing process.
Coordination with Refugee Resettlement Community
Coordination with the local refugee resettlement community is critical to the success of the Refugee IDA Program. Programs must include regular coordination with resettlement agencies, State Refugee Coordinators or Replacement Designees, and other relevant community services providers to extend the effort of the outreach, awareness, and coordination with the refugee resettlement community. Attendance at quarterly consultations with resettlement agencies, regular meetings with State Refugee Coordinators, and participation in other relevant forums are examples of activities with strategic partnerships to facilitate resource mapping. ORR is requiring a letter of support support from the State Refugee Coordinator, or the individual responsible for the statewide or regional coordination of the refugee resettlement program, as applicable, of the state where the proposed project will be implemented. Contact information for State Refugee Coordinators or individuals responsible for statewide or regional coordionation of the refugee resettlement program can be found on ORR's website at: https://www.acf.hhs.gov/orr/resource/orr-funded-programs-key-contacts.
No more than 35 percent of ORR funds may be used for administrative purposes. At least 65 percent of ORR funds must be used to match IDA savings made by refugees participating in the Refugee IDA Program. ORR defines Administrative Funds as any federal funds that are not used directly for IDA match. Examples of costs that are considered administrative include, but are not limited to, salary, rent, supplies, benefits, travel, program material, interpretation services, costs associated with providing financial literacy and asset-specific training, and federally approved indirect costs. 45 CFR Part 75 requires that non-federal entities be compensated for all allowable Indirect Costs claimed under a grant, in accordance with the non-federal entity’s fully negotiated and approved Indirect Cost rate. As such, the 35 percent limitation for administrative costs can be exceeded only in cases where the payment of Indirect Costs causes the non-federal entity to exceed that percentage based on their Indirect Cost rate effective at the time of award. For more information on the funding restrictions specific to this FOA, please see Section IV.6 Funding Restrictions.
State-Specific Asset Limits
ORR recognizes that some clients who are eligible for the Refugee IDA Program may also be eligible for other state and federally sponsored benefits program with asset limits (e.g., Supplemental Nutrition Assistance Program (SNAP), Temporary Assistance for Needy Families (TANF), etc.). Grantees must be aware of state-specific asset limits, if any, and provide information to clients about potential impacts to public benefits.
ORR does not require grantees to provide any non-federal funds to match federal funds awarded to grantees for the Refugee IDA Program. The "match," "matching funds," or "match funds" mentioned in this announcement do not refer to the applicant finding additional funds to match funds being provided by the federal government; they are the portion of federal funds to be allocated and used for matching clients' IDA savings. ORR funds may be used at a matching rate no greater than one-to-one for each dollar deposited in the IDA by the refugee participant. Over the course of the 4-year project period, not more than $2,000 in ORR grant funds may be provided through matching contributions to any one refugee individual and not more than $4,000 may be provided to any one refugee household (see Definition and Explanation of Terms in this section for the definition of "household"). When the refugee purchases the Asset Goal, the grantee must provide payment of the participant's IDA matching funds directly to the asset vendor. Match Funds may not be used to pay towards existing loans or debts.
Accounts and Drawdown of Funds
The IDA contains only the refugee participant's deposits and interest earned on those deposits. Grantees may establish non-interest bearing IDAs for participants only with ORR approval. The grantee will create one Parallel Account, separate from the participants' IDAs, at a qualified financial institution, in which all matching ORR grant funds will be deposited and maintained on behalf of the refugee participants. Drawdown of the ORR grant funds and deposit of those funds into the Parallel Account will be permitted no earlier than the time of the refugee's deposit to the IDA. Grantees must drawdown ORR funds for matching IDA deposits within 3 months of the date that the refugee participant makes the deposit, and must continue to drawdown at least on a quarterly basis thereafter as participants make deposits.
The interest that accrues on the ORR matching funds deposited in the Parallel Account must be used to enroll additional refugee participants or to match interest earned on the refugee participant's deposits. The interest on the match funds in the Parallel Account may not be retained by the grantee for any purpose, including program administration, participant support services, or program data collection. (See 45 CFR § 75.307 (e)(2)).
Proof of Purchase
Proofs of purchases must be provided for all assets purchased through the Refugee IDA Program and can include, but is not limited to, cash register receipts, completed vehicle title transfers, Seller's Signed Disclosure, and emailed receipts. Proofs of Purchases ensure that only eligible assets were purchased for the benefit of the Refugee IDA clients or the benefactors listed in his/her household.
Closeout and Client Withdrawals
Account activities must be scheduled so that all IDA accounts reach their maximum Savings Goal and refugee participants have purchased their Asset Goals within the 4-year project period. If educational tuition or fees are paid in installments to an institution, a plan must be established to return funds to the government if all of the federal match money is not used by the student within the project period. If the participant stops contributing towards his/her IDA for a period of 3 months without grantee approval, or fails to meet his/her Savings Goal, the grantee may use those funds to enroll another participant.
All remaining funds and any subsequent interest generated in the Parallel Account that are a result of participants not being able to reach their Savings Goal and purchase their Asset Goals within the 4-year project period, must be returned to HHS Payment Management Services in accordance with 45 CFR § 75.381(d).
Program Performance Evaluation
As required by the Paperwork Reduction Act (PRA), ORR has obtained approval from the Office of Management and Budget (OMB) for the Refugee IDA Program Data Indicators for post-award reporting. Data points will include:
Recruitment and Enrollment
- Number of Individual and Household Savings Plan Agreements signed
- Number of Individual Household IDAs opened
- Number of IDAs opened for each eligible asset goal
- Total Match Funds obligated for each eligible asset goal
- Total Number of IDAs for all assets
- Total Match Funds obligated for all assets
Training & Technical Assistance
- Number of clients completing financial literacy training
- Number of hours of financial literacy training completed
- Number of clients completing asset-specific training
- Number of hours of asset-specific training completed
- Number of hours of technical assistance provided
- Number of assets purchased in each category of eligible asset goals (i.e., vehicles, education/vocational training/professional recertification, microenterprise, and homes)
- Total Savings and Match Funds used to purchase assets in each category of eligible asset goals
- Total value of purchased assets in each category of eligible asset goals
- Number of all assets purchased
- Total value of all assets purchased
- Total Match Funds obligated for asset purchases
- Total Match Funds Liquidated for asset purchases
- Total match Funds currently in the Parallel Account
- Total Match Funds Obligated but Unliquidated
- Total Match Funds Unobligated
- Number of Refugee IDA clients assessed based on a scaled provided by ORR
- Mean self-sufficiency score of all clients assessed
Logic Model Progress
- Progress towards each Output identified in the Logic Model
- Progress towards each Outcome identified in the Logic Model
Paperwork Reduction Act Disclaimer
As required by the PRA of 1995, 44 U.S.C. §§ 3501-3521, the public reporting burden for the Refugee IDA Program Data Indicators is estimated to average four burden hours per response, including the time for reviewing instructions, gathering and maintaining the data needed, and reviewing the collection information. The Refugee IDA Program Data Indicators information collection is approved under OMB control number 0970-0490, expiration date is 01/31/2020. An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB control number.
If ACF identifies additional resources to fund a federal study of the funded Refugee IDA activities, then the grantee will be required to participate. The study would utilize an outside non-grantee evaluation team and would focus on the processes, implementation, progress indicators, and quality improvement of funded activities.
Participation in ORR-Sponsored Workshops
The IDA grantees will meet quarterly by phone, to discuss the performance indicators, methods for collecting and reporting those indicators, and other variables or benchmarks that might be appropriate for highlighting progress on the funded activities.
Refugee IDA Programs will be expected to participate in ORR sponsored webinars, trainings and peer sharing events throughout the program period. An annual workshop is planned for each program year. Attendance is required for one key staff member to participate in an annual 2-day workshop at ORR's office in Washington, DC each year.
For more information on application requirements specific to this FOA, please refer to Section IV.2, The Project Description and Project Budget and Budget Justification.
DEFINITION AND EXPLANATION OF TERMS
The following definitions apply for purposes of this announcement:
Asset Goals - the purchases/investments for which the matching funds are intended for when used in conjunction with the savings from the IDAs of refugee participants. The Asset Goal specified by a participant in the Savings Plan Agreement may be for the benefit of the refugee participant or of a dependent refugee (children under 21 years of age who are dependent of an adult for their livelihood) of the refugee participant. Purchase of any Asset Goal must not create an excessive debt burden for the refugee participant. Allowable Asset Goals are defined as follows:
- Home Ownership - costs of a principal residence, including the down payment and closing costs when purchasing a home. The purchaser must be a first-time home buyer. Prior to approval for a client to save for this asset, the grantee must assess the likelihood that the client can obtain appropriate financing prior to the end of the project period. Grantee must also assess client's abilities to maintain a mortgage and the upkeep of a home.
- Post-Secondary Education, Vocational Training, and Professional Recertification - cost of tuition or fees, professional recertification fees, books, supplies and equipment, including one computer per student if required or recommended by the institution for enrollment or attendance of a refugee student at a post-secondary educational institution. Mobile phones and other electronic devices that are not explicitly required or recommended by the institution where the client is enrolled are not considered eligible assets for the purpose of Post-Secondary Education, Vocational Training, and Professional Recertification. Funds may be used for a dependent refugee if that child begins post-secondary education or vocational training within the project period. Proof of enrollment and requirement of electronic devises, if applicable, must be documented in the client's file.
- Purchase of an Automobile - a vehicle that is a documented necessity for the purpose of maintaining or upgrading employment or for the purpose of transportation for post-secondary education, vocational training, or professional recertification. Funds can be used for the actual cost of the vehicle as well as one-time fees and taxes associated with the purchase of the vehicle. Vehicles may not be purchased through auctions.
- Microenterprise Capitalization - costs for a microbusiness described in a qualified business plan, such as marketing, equipment, working capital, and inventory expenses. The business plan must be approved by a financial institution, a microenterprise development organization, a non-profit loan fund, or a partner which has a microenterprise expertise. The plan must also describe services or goods to be sold and include a marketing plan and projected financial statements. Costs for microenterprise capitalization cannot include any of the following:
- Paying existing loans;
- Gambling or speculation including buying and selling equity or debt instruments;
- Any not-for-profit undertaking;
- Paying legal fees;
- Any illegal activity or production, or service or distribution of illegal products;
- Purposes not related to microenterprise development (e.g., for the purpose of buying a vehicle for personal use);
- Any other activity that ORR determines, in consultation with the grantee, to be inappropriate for the Refugee IDA Program and Federal funding, or prohibited under applicable appropriation laws (i.e., General Provisions For Selected Items of Cost, 45 CFR §75.420).
Please reference Section IV.6 Funding Restrictions for more information.
Emergency Withdrawal - a withdrawal of funds, or a portion of funds, deposited by the refugee participant in his/her IDA. The withdrawal may also include any of the interest that may have accrued to the participant's savings in the account but does not include any matching funds. The participant must notify the project grantee of the withdrawal prior to the withdrawal. Causes for emergency withdrawals include, but are not limited to, medical expenses, payments to prevent eviction or foreclosure, or payments for necessary living expenses. An IDA client's failure to notify the project grantee and receive approval prior to an Emergency Withdrawal may result in an immediate removal from the Refugee IDA Program. If funds withdrawn for emergency purposes are not repaid within 12 months, the refugee participant forfeits the match on those funds. Emergency withdrawals may never be authorized from the Parallel Account(s).
Household - an eligible client and all other persons living as an individual economic unit at one address that submits a single federal tax return.
Housing and Urban Development Area Median Family Income (HAMFI) - issued each year. This is the median family income calculated by the Department of Housing and Urban Development (HUD) for each jurisdiction, in order to determine Fair Market Rents and income limits for HUD programs. Within HUD, the terms "HAMFI," "area median income" (AMI) or "median family income" (FMI) are used interchangeably. HAMFI can be located at www.huduser.gov/portal/datasets/il.html.
Parallel Account - insured account opened by the grantee in a qualified financial institution for the purpose of depositing the matching funds for the savings deposited by refugee participants in their individual IDAs. Interest earned on the matching funds must remain in the Parallel Account and be used to enroll additional refugee participants or to match the interest earned on the refugee participant's deposits. The matching funds must be made available to the refugee participant at the time that the participant purchases the Asset Goal. The matching funds are not available to the refugee participant except for the purchase of the Asset Goals defined in this announcement.
Partnering with Organizations with Areas of Expertise - Partnering with other organizations is not a requirement of the Refugee IDA Program if the grantee has demonstrated an in-house expertise in all the required components of the program. However, in order to ensure a high quality of service to refugee participants, ORR values the importance of the development of strategic partnerships with community organizations that offer expertise in the required areas of the Refugee IDA Program where the grantee does not have a demonstrated, in-house expertise. Examples of areas of expertise could include, but are not limited to: home buying process, post-secondary education, small business development, financial literacy training, refugee culture, and operating IDA programs. Examples of new partners could include, but are not limited to, the following: Volunteer Income Tax Assistance (VITA) sites, Housing and Urban Development (HUD) approved housing counseling agencies, Small Business Administration (SBA) Microloan offices, Assets for Independence (AFI) grantees, Community Development Financial Institutions, ethnic community based organizations, financial empowerment centers, as well as other private and public institutions.
Refer to Section VIII. Other Information for links to federal agencies.
Poverty Guidelines - issued each year in the Federal Register by the Department of Health and Human Services (HHS). The guidelines are a simplification of the poverty thresholds for use for administrative purposes - for instance, determining financial eligibility for certain federal programs may be found at www.aspe.hhs.gov/poverty/index.cfm.
Qualified Financial Institution - a federally insured bank or credit union, or a state-insured bank or credit union if no federally insured bank or credit union is available.
Savings Goal - the amount, in dollars, that the client and grantee has indicated in the Savings Plan Agreement to be saved by the client and matched with federal funds by the grantee. The Savings Goal and match will be used to purchase the Asset Goal.