As part of the agency-wide Shared Standards Initiative (SSI), Commerce is creating consistency in how all divisions contract, while still tailoring requirements to each program’s needs. The SSI is intended to reduce the risks related to public funds and grantee recapture, creating a more stable funding environment. After receiving feedback on the SSI’s move toward consistent invoicing for work performed by subcontractors and subgrantees, Commerce is working with its authorizing bodies to formalize a payment policy that will pilot permitting flexibility on invoicing in certain circumstances, while balancing the risks related to public funds and grantee recapture. This policy would formalize a contracting practice that permits invoice-only payments under certain circumstances. Commerce anticipates this new payment policy will apply to most state-funded grant agreements (also called passthrough agreements) that have subgrantees and subcontractors for the next fiscal year starting on July 1, 2026.
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In anticipation of the publication of Commerce’s updated policy, the Multifamily Housing Unit (MHU) will process fund drawdown requests based on costs incurred (invoice received) but not yet paid under the following conditions:
- You must follow all existing fund drawdown request procedures, including third-party verification by the construction review services provider (Washington Community Reinvestment Association).
- You must provide proof of payment of every cost for which drawdown funds are authorized based on invoice received, but not yet paid, within 30 days of receipt of the drawn-down funds. If a given cost has already been paid, include proof of payment with your drawdown request.
- Commerce will not approve any subsequent drawdown requests for a contract with outstanding (unfulfilled) proof-of-payment documentation requirements until you provide the outstanding documentation.
Please work directly with your assigned project manager to ensure compliance with these requirements.
For questions or other feedback regarding MHU’s implementation of these requirements, contact John Demboski, MHU managing director, at John.Demboski@commerce.wa.gov. For questions or other feedback about Commerce’s Shared Standards Initiative in general, contact Sarah Champion, director of the Contracts and Compliance Division, at Sarah.Champion@commerce.wa.gov. Thank you for your work to provide affordable housing opportunities for all Washingtonians and for your patience as Commerce works to ensure flexibility in service delivery while protecting the integrity of public funds.
