5-Year PHA Plan (for All PHAs) - Waco Public Housing Authority
Transcription
5-Year PHA Plan (for All PHAs) - Waco Public Housing Authority
5-Year PHA Plan (for All PHAs) U.S. Department of Housing and Urban Development Office of Public and Indian Housing OMB No. 2577-0226 Expires: XX/XX/XXXX Applicability. Form HUD-50075-5Y is to be completed once every 5 PHA fiscal years by all PHAs. A. PHA Information. A.1 PHA Name: Waco Housing Authority & Affiliates PHA Code: TX010 PHA Plan for Fiscal Year Beginning: (MM/YYYY): 10/2015 PHA Plan Submission Type: 5-Year Plan Submission Revised 5-Year Plan Submission Availability of Information. In addition to the items listed in this form, PHAs must have the elements listed below readily available to the public. A PHA must identify the specific location(s) where the proposed PHA Plan, PHA Plan Elements, and all information relevant to the public hearing and proposed PHA Plan are available for inspection by the public. Additionally, the PHA must provide information on how the public may reasonably obtain additional information on the PHA policies contained in the standard Annual Plan, but excluded from their streamlined submissions. At a minimum, PHAs must post PHA Plans, including updates, at each Asset Management Project (AMP) and main office or central office of the PHA. PHAs are strongly encouraged to post complete PHA Plans on their official websites. PHAs are also encouraged to provide each resident council a copy of their PHA Plans. The Waco Housing Authority & Affiliates Five Year Annual Plan will be available for review at all three development office.s Estellay Maxey – 1809 J J Flewellen, Waco TX 76704 Kate Ross – 937 S. 11th St., Waco, TX 76706 South Terrace – 100 Kennedy Circle, Waco, TX 76706 It will also be avavilable at our Central Office at 4400 Cobbs Dr., Waco, TX 76710 On the website at www.wacopha.org A copy will also be provided to each Resident Council. PHA Consortia: (Check box if submitting a Joint PHA Plan and complete table below) Participating PHAs PHA Code Program(s) in the Consortia Program(s) not in the Consortia No. of Units in Each Program PH HCV Lead PHA: Page 1 of 4 form HUD-50075-5Y (12/2011) B. 5-Year Plan. Required for all PHAs completing this form. B.1 Mission. State the PHA’s mission for serving the needs of low- income, very low- income, and extremely low- income families in the PHA’s jurisdiction for the next five years. The PHA’s mission continues to be: Making homes happen for families and to be the main source of providing affordable housing choices for the City of Waco. We continue to do this by providing housing to over 3000 families and we continue to be the largest housing provider in the City of Waco. B.2 Goals and Objectives. Identify the PHA’s quantifiable goals and objectives that will enable the PHA to serve the needs of low- income, very lowincome, and extremely low- income families for the next five years. Goal One: To lease as many vouchers and public housing units possible in order to help meet the housing needs of our area Goal Two: To provide programs and work with our community partners to help our clients gain self sufficiency B.3 Progress Report. Include a report on the progress the PHA has made in meeting the goals and objectives described in the previous 5-Year Plan. The goals and objectives adopted by the Housing Authority of the City of Waco for the previous year were: Goal One: Increase the affordable housing stock available to low-income persons in Waco and to increase the landlord participation in Waco, Hill County and Somervell Counties. Goal One Update: 1. We continue to increase the number of landlords participating in Section 8. 2. We continue to work with organizations involved in revitalizing neighborhoods in Waco. These include Habitat for Humanity and NeighborWorks Waco both for credit repair, homeownership training and down payment assistance. 3. Our Section 8 Homeownership Program in Waco continues to offer clients the opportunity for homeownership. 4. We continue to maintain existing public housing stock to a high quality standard by making all needed upgrades Goal Two: Increase the applicant waiting lists of Waco, Hill County and Somervell County Housing Authority’s housing programs to include citizens from all sectors of our community. Goal Two Update: Marketing was done for our Public Housing program to try and fill vacancies. We advertised in the Thrifty Nickel, and Tiempo papers in Waco. We posted flyers at government agencies and colleges in both Spanish and English to effectively let people know about our programs. We have a webpage with all information needed by our clients. We have initiated an online application process which has increased waiting lists for all of our programs. B.4 Violence Against Women Act (VAWA) Goals. Provide a statement of the PHA’s goals, activities objectives, policies, or programs that will enable the PHA to serve the needs of child and adult victims of domestic violence, dating violence, sexual assault, or stalking. Waco Housing Authority & Affiliates uses its choice to have a domestic preference available in both Public Housing and HCV programs to assist victims in having a safe place to live with their children as they begin their new lives. Waco Housing Authority & Affiliates will use its community partnerships with the Family Abuse Center, the Advocacy Center and CASA to help tenants with additional services. B.5 Public and Resident Advisory Board (RAB) Comments. (a) Did the public or RAB(s) provide comments to the 5-Year PHA Plan? Y N (b) If yes, comments must be submitted by the PHA as an attachment to the 5-Year PHA Plan. PHAs must also include a narrative describing their analysis of the RAB recommendations and the decisions made on these recommendations. B.6 Certification by State or Local Officials. Form HUD 50077-SL, Certification by State or Local Officials of PHA Plans Consistency with the Consolidated Plan, must be submitted by the PHA as an electronic attachment to the PHA Plan. Page 2 of 4 form HUD-50075-5Y (12/2011) Instructions for Preparation of Form HUD-50075-5Y 5-Year PHA Plan for All PHAs A. PHA Information 24 CFR §903.23(4)(e) A.1 Include the full PHA Name, PHA Code, , PHA Fiscal Year Beginning (MM/YYYY), PHA Plan Submission Type, and the Availability of Information, specific location(s) of all information relevant to the hearing and proposed PHA Plan. PHA Consortia: Check box if submitting a Joint PHA Plan and complete the table. B. 5-Year Plan. B.1 Mission. State the PHA’s mission for serving the needs of low- income, very low- income, and extremely low- income families in the PHA’s jurisdiction for the next five years. (24 CFR §903.6(a)(1)) B.2 Goals and Objectives. Identify the PHA’s quantifiable goals and objectives that will enable the PHA to serve the needs of lowincome, very low- income, and extremely low- income families for the next five years. (24 CFR §903.6(b)(1)) B.3 Progress Report. Include a report on the progress the PHA has made in meeting the goals and objectives described in the previous 5Year Plan. (24 CFR §903.6(b)(2)) B.4 Violence Against Women Act (VAWA) Goals. Provide a statement of the PHA’s goals, activities objectives, policies, or programs that will enable the PHA to serve the needs of child and adult victims of domestic violence, dating violence, sexual assault, or stalking. (24 CFR §903.6(a)(3)) B.5 Public and Resident Advisory Board (RAB) comments. (a) Did the public or RAB provide comments? (b) If yes, submit comments as an attachment to the Plan and describe the analysis of the comments and the PHA’s decision made on these recommendations. (24 CFR §903.17(a), 24 CFR §903.19) This information collection is authorized by Section 511 of the Quality Housing and Work Responsibility Act, which added a new section 5A to the U.S. Housing Act of 1937, as amended, which introduced the 5-Year PHA Plan. The 5-Year PHA Plan provides the PHA’s mission, goals and objectives for serving the needs of low- income, very low- income, and extremely lowincome families and the progress made in meeting the goals and objectives described in the previous 5-Year Plan. Public reporting burden for this information collection is estimated to average .76 hours per response, including the time for reviewing instructions, searching existing data sources, gathering and maintaining the data needed, and completing and reviewing the collection of information. HUD may not collect this information, and respondents are not required to complete this form, unless it displays a currently valid OMB Control Number. Privacy Act Notice. The United States Department of Housing and Urban Development is authorized to solicit the information requested in this form by virtue of Title 12, U.S. Code, Section 1701 et seq., and regulations promulgated thereunder at Title 12, Code of Federal Regulations. Responses to the collection of information are required to obtain a benefit or to retain a benefit. The information requested does not lend itself to confidentiality. Page 3 of 4 form HUD-50075-5Y (12/2011) Page 4 of 4 form HUD-50075-5Y (12/2011) Waco Housing Authority - TX010 Annual Plan for the Year 2016 Statement of Financial Resources SOURCES AMOUNT Public Housing Operating Fund $3,193,300 Public Housing Capital Fund: CFP 2014 - amount remaining CFP 2015 $295,100 $1,087,600 Annual Contributions for Section 8 Tenant-Based Assistance $14,782,900 Resident Opportunity and Self-Sufficiency Grants $97,900 Public Housing Dwelling Rental Income $1,981,800 Investment Interest $18,800 Other Income $206,700 Other Non-Tenant Income $9,100 Cable TV Commissions $21,200 Excess Utility Receipts $204,200 . 1001 Washington Rental Income Totals 65,500 21,964,100 Annual Statement/Performance and Evaluation Report Capital Fund Program, Capital Fund Program Replacement Housing Factor and Capital Fund Financing Program Part II: Supporting Pages PHA Name: Waco Housing Authority & Affiliates Development Number Name/PHA-Wide Activities General Description of Major Work Categories U.S. Department of Housing and Urban Development Office of Public and Indian Housing OMB No. 2577-0226 Expires 04/30/2011 Grant Type and Number Capital Fund Program Grant No: TX-21-P-010-501/15 CFFP (Yes/No): Replacement Housing Factor Grant No: Federal FFY of Grant: 2015 Development Account No. Total Actual Cost Quantity Total Estimated Cost Original PHA WIDE Operations Administration 1406 1410 108,763.00 108,763.00 Mod Salaries & Benefits 1430 130,500.00 Non-Dwelling Equipment - Expendable 1475 1,000.00 Total 349,026.00 Revised Funds Obligated 1 - Status of Work Funds Expended 2 - 2 - To be completed for the Performance and Evaluation Report or a Revised Annual Statement. 2 To be completed for the Performance and Evaluation Report. 1 Page 2 form HUD-50075.1 (4/2008) Annual Statement/Performance and Evaluation Report Capital Fund Program, Capital Fund Program Replacement Housing Factor and Capital Fund Financing Program Part II: Supporting Pages PHA Name: Waco Housing Authority & Affiliates Development Number Name/PHA-Wide Activities General Description of Major Work Categories U.S. Department of Housing and Urban Development Office of Public and Indian Housing OMB No. 2577-0226 Expires 04/30/2011 Grant Type and Number Capital Fund Program Grant No: TX-21-P-010-501/15 CFFP (Yes/No): Replacement Housing Factor Grant No: Federal FFY of Grant: 2015 Development Account No. Total Actual Cost Quantity Total Estimated Cost Original Revised Funds Obligated 1 Status of Work Funds Expended 2 2 TX010-01 KATE ROSS Page Total - - - - 1 To be completed for the Performance and Evaluation Report or a Revised Annual Statement. 2 To be completed for the Performance and Evaluation Report. Page 3 form HUD-50075.1 (4/2008) Annual Statement/Performance and Evaluation Report Capital Fund Program, Capital Fund Program Replacement Housing Factor and Capital Fund Financing Program Part II: Supporting Pages PHA Name: Waco Housing Authority & Affiliates Development Number Name/PHA-Wide Activities General Description of Major Work Categories U.S. Department of Housing and Urban Development Office of Public and Indian Housing OMB No. 2577-0226 Expires 04/30/2011 Grant Type and Number Capital Fund Program Grant No: TX-21-P-010-501/15 CFFP (Yes/No): Replacement Housing Factor Grant No: Federal FFY of Grant: 2015 Development Account No. Total Actual Cost Quantity Total Estimated Cost Original Revised Funds Obligated 1 Status of Work Funds Expended 2 2 TX010-02 ESTELLA MAXEY Page Total - - - - 1 To be completed for the Performance and Evaluation Report or a Revised Annual Statement. 2 To be completed for the Performance and Evaluation Report. Page 4 form HUD-50075.1 (4/2008) Annual Statement/Performance and Evaluation Report Capital Fund Program, Capital Fund Program Replacement Housing Factor and Capital Fund Financing Program Part II: Supporting Pages PHA Name: Waco Housing Authority & Affiliates Development Number Name/PHA-Wide Activities General Description of Major Work Categories U.S. Department of Housing and Urban Development Office of Public and Indian Housing OMB No. 2577-0226 Expires 04/30/2011 Grant Type and Number Capital Fund Program Grant No: TX-21-P-010-501/15 CFFP (Yes/No): Replacement Housing Factor Grant No: Federal FFY of Grant: 2015 Development Account No. Total Actual Cost Quantity Total Estimated Cost Original TX010-03 SOUTH TERRACE Electrical Upgrades Total 1460 Revised Funds Obligated 1 Status of Work Funds Expended 2 2 738,604.00 - - - 738,604.00 - - - 1 To be completed for the Performance and Evaluation Report or a Revised Annual Statement. 2 To be completed for the Performance and Evaluation Report. Page 5 form HUD-50075.1 (4/2008) Annual Statement/Performance and Evaluation Report Capital Fund Program, Capital Fund Program Replacement Housing Factor and Capital Fund Financing Program U.S. Department of Housing and Urban Development Office of Public and Indian Housing OMB No. 2577-0226 Expires 04/30/2011 Part III: Implementation Schedule for Capital Fund Financing Program Federal FFY of Grant: 2015 PHA Name: Waco Housing Authority & Affiliates Development Number Name/PHA-Wide Activities PHA WIDE TX010-001 KATE ROSS TX010-002 ESTELLA MAXEY TX010-003 SOUTH TERRACE All Fund Obligated (Quarter Ending Date) Original Obligation End Date 05/12/2017 Actual Obligation End Date All Funds Expended (Quarter Ending Date) Original Expenditure End Date Reasons for Revised Target Dates 1 Actual Expenditure End Date 04/12/2019 05/12/2017 04/12/2019 05/12/2017 04/12/2019 05/12/2017 04/12/2019 1 Obligation and expenditure end dates can only be revised with HUD approval pursuant to Section 9j of the U.S. Housing Act of 1937, as amended. Page 6 form HUD-50075.1 (4/2008) Annual Statement/Performance and Evaluation Report Capital Fund Program, Capital Fund Program Replacement Housing Factor and Capital Fund Financing Program Part II: Supporting Pages PHA Name: Waco Housing Authority and Affiliates 4400 Cobbs Drive, P.O. Box 978 Waco, Texas 76703-0978 Development Number Name/PHA-Wide Activities General Description of Major Work Categories U.S. Department of Housing and Urban Development Office of Public and Indian Housing OMB No. 2577-0226 Expires 04/30/2011 Grant Type and Number Capital Fund Program Grant No: TX-21-P-010-501/14 CFFP (Yes/No): Replacement Housing Factor Grant No: Federal FFY of Grant: 2014 Development Account No. Total Actual Cost Quantity Total Estimated Cost Original PHA WIDE Operations Administration Audit Mod Salaries & Benefits Mod Training A&E Services 1406 1410 1410 1411 1430 1430 1430 Non-Dwelling Office Space Workstation Upgrades Non-Dwelling Equipment - Expendable Demolition Relocation 1470 1475 147509 1485 1495 Revised 1 Funds Obligated Status of Work Funds Expended 2 2 103,832.00 103,832.00 103,832.00 103,832.00 103,832.00 103,832.00 51,916.02 25,958.01 765.00 126,376.00 1,000.00 105,000.00 765.00 126,376.00 1,000.00 113,282.70 126,376.00 36,032.70 36,438.60 32,710.70 2,000.00 1,500.00 35,000.00 1,000.00 100.00 2,000.00 1,500.00 35,000.00 1,000.00 100.00 - - 480,405.00 488,687.70 370,072.70 147,023.33 Ongoing Ongoing Ongoing Ongoing To be completed for the Performance and Evaluation Report or a Revised Annual Statement. 2 To be completed for the Performance and Evaluation Report. 1 Page 2 form HUD-50075.1 (4/2008) Annual Statement/Performance and Evaluation Report Capital Fund Program, Capital Fund Program Replacement Housing Factor and Capital Fund Financing Program Part II: Supporting Pages PHA Name: Waco Housing Authority and Affiliates 4400 Cobbs Drive, P.O. Box 978 Waco, Texas 76703-0978 Development Number Name/PHA-Wide Activities General Description of Major Work Categories U.S. Department of Housing and Urban Development Office of Public and Indian Housing OMB No. 2577-0226 Expires 04/30/2011 Grant Type and Number Capital Fund Program Grant No: TX-21-P-010-501/14 CFFP (Yes/No): Replacement Housing Factor Grant No: Federal FFY of Grant: 2014 Development Account No. Total Actual Cost Quantity Total Estimated Cost Original TX010-01 KATE ROSS Revised 1 Funds Obligated Status of Work Funds Expended 2 2 Erosion, Drainage & Landscaping Fence Repair Grounds Improvement 1450 1450 1450 2,500.00 7,500.00 750.00 2,500.00 7,500.00 750.00 - - Site Security Lighting Replacement of Cast Iron pipes Flooring Replacement Foundation Repairs (pier & beam, dirt replacement, vent covers) HVAC Plumbing Repair/Replacement Repair Outside of Building 1450 1460 1460 500.00 13,132.00 9,238.00 500.00 13,132.00 9,238.00 - - 1460 1460 1460 1460 5,000.00 30,000.00 750.00 2,123.00 5,000.00 30,000.00 750.00 2,123.00 - - 1470 16,000.00 16,000.00 - - 87,493.00 87,493.00 - - Community & Management Facility Buildings Improvements (HVAC upgrades) 1 To be completed for the Performance and Evaluation Report or a Revised Annual Statement. 2 To be completed for the Performance and Evaluation Report. Page 3 form HUD-50075.1 (4/2008) Annual Statement/Performance and Evaluation Report Capital Fund Program, Capital Fund Program Replacement Housing Factor and Capital Fund Financing Program Part II: Supporting Pages PHA Name: Waco Housing Authority and Affiliates 4400 Cobbs Drive, P.O. Box 978 Waco, Texas 76703-0978 Development Number Name/PHA-Wide Activities General Description of Major Work Categories U.S. Department of Housing and Urban Development Office of Public and Indian Housing OMB No. 2577-0226 Expires 04/30/2011 Grant Type and Number Capital Fund Program Grant No: TX-21-P-010-501/14 CFFP (Yes/No): Replacement Housing Factor Grant No: Federal FFY of Grant: 2014 Development Account No. Total Actual Cost Quantity Total Estimated Cost Original TX010-02 ESTELLA MAXEY Revised Funds Obligated 1 Status of Work Funds Expended 2 2 Erosion, Drainage & Landscaping Fence Repair Grounds Improvement 1450 1450 1450 2,500.00 1,000.00 750.00 2,500.00 1,000.00 750.00 - - Site Security Lighting Exterior Repairs & Painting Flooring Replacement 1450 1460 1460 3,000.00 7,500.00 15,550.00 3,000.00 - - - 20,500.00 - - - 25,000.00 750.00 50,000.00 750.00 - - - 28,000.00 28,000.00 - - 154,550.00 36,000.00 - - Foundation Repairs (pier & beam, dirt replacement, vent covers) Repair Outside of Buildings Plumbing Repair/Replacement HVAC System, Duct Work & Grates Community & Management Facility Buildings Improvements (HVAC upgrades) 1460 1460 1460 1460 1470 1 To be completed for the Performance and Evaluation Report or a Revised Annual Statement. 2 To be completed for the Performance and Evaluation Report. Page 4 form HUD-50075.1 (4/2008) Move to ST Termite Move to ST Roofs Move to ST Roofs Move to ST Roofs Annual Statement/Performance and Evaluation Report Capital Fund Program, Capital Fund Program Replacement Housing Factor and Capital Fund Financing Program Part II: Supporting Pages PHA Name: Waco Housing Authority and Affiliates 4400 Cobbs Drive, P.O. Box 978 Waco, Texas 76703-0978 Development Number Name/PHA-Wide Activities General Description of Major Work Categories U.S. Department of Housing and Urban Development Office of Public and Indian Housing OMB No. 2577-0226 Expires 04/30/2011 Grant Type and Number Capital Fund Program Grant No: TX-21-P-010-501/14 CFFP (Yes/No): Replacement Housing Factor Grant No: Federal FFY of Grant: 2014 Development Account No. Total Actual Cost Quantity Total Estimated Cost Original TX010-03 SOUTH TERRACE Revised 1 Funds Obligated Status of Work Funds Expended 2 Erosion, Drainage & Landscaping Fence Repair Grounds Improvement 1450 1450 1450 2,500.00 1,000.00 750.00 2,500.00 1,000.00 750.00 - Site Security Lighting Exterior Repairs & Painting Flooring Replacement Upgrade of Main Electrical Supply HVAC Ceiling Repair Roof Repair Repair of Outside of Building Termite Repairs Community & Management Facility Buildings Improvements (HVAC upgrades) 1450 1460 1460 1460 1460 1460 1460 1460 1460 15.000.00 7.500.00 15,000.00 75.000.00 16,250.00 7,625.00 42,500.00 54,750.00 50,000.00 15.000.00 1,097.65 9,555.00 311,824.72 88,888.93 9,555.00 311,824.72 45,000.00 1470 28,000.00 28,000.00 - 315,875.00 458,616.30 366,379.72 2 9,555.00 311,824.72 Completed Completed Ongoing 321,379.72 1 To be completed for the Performance and Evaluation Report or a Revised Annual Statement. 2 To be completed for the Performance and Evaluation Report. Page 5 form HUD-50075.1 (4/2008) Annual Statement/Performance and Evaluation Report Capital Fund Program, Capital Fund Program Replacement Housing Factor and Capital Fund Financing Program U.S. Department of Housing and Urban Development Office of Public and Indian Housing OMB No. 2577-0226 Expires 04/30/2011 Part III: Implementation Schedule for Capital Fund Financing Program Federal FFY of Grant: 2014 PHA Name: Waco Housing Authority and Affiliates Development Number Name/PHA-Wide Activities All Fund Obligated (Quarter Ending Date) Original Obligation End Date PHA WIDE TX010-001 KATE ROSS TX010-002 ESTELLA MAXEY TX010-003 SOUTH TERRACE Actual Obligation End Date All Funds Expended (Quarter Ending Date) Original Expenditure End Date 05/12/2016 05/12/2018 05/12/2016 05/12/2018 05/12/2016 05/12/2018 Reasons for Revised Target Dates 1 Actual Expenditure End Date 1 Obligation and expenditure end dates can only be revised with HUD approval pursuant to Section 9j of the U.S. Housing Act of 1937, as amended. Page 6 form HUD-50075.1 (4/2008) Changes to the Public Housing Admissions and Continued Occupancy Policy (ACOP) 1.0 FAIR HOUSING (AMENDS TITLE VIII OF CIVIL RIGHTS ACT OF 1968) 24CFR 100.5 It is the policy of the Housing Authority of the City of Waco to fully comply with all Federal, State and local nondiscrimination laws, the Americans with Disabilities Act, and the U.S. Department of Housing and Urban Development regulations governing Fair Housing and Equal Opportunity. No person shall, on the grounds of race, color, sex, religion, national or ethnic origin, familial status, or disability or actual or perceived sexual orientation,or gender identiy be excluded from participation in, be denied the benefits of, or be otherwise subjected to discrimination under the Housing Authority of the City of Waco’s programs. 3.0 ACCOMMODATIONS FOR LIMITED ENGLISH PROFICIENCY ASSISTANCE SERVICES FOR NON-ENGLISH SPEAKING APPLICANTS AND RESIDENTS In order to better serve those applicants with Limited English Proficiency, WHA will do the following: - Post signs in the lobby to request assistance with the application - Have this printed request on the application Online applications will be provided in the two most common languages for our area - Have bilingual staff available by appointment and phone - Allow assistance to the participant from a family member or friend for translation purposes. - Train staff on use of computer internet programs available for translation, ie www.Freetranslator.com - Provide translated materials as provided by HUD - WHA will, when needed, provide professional translation services at no cost to the participant. The Authority retains the right to select the most efficient or economic choice. 7.0 APPLICATION PROCESS (A) Families wishing to apply for the public housing program will be required to complete an application for housing assistance. Applications will be accepted by applying online at wacopha.orgduring regular business hours at: 4400 Cobbs Drive Monday - Thursday 8:30 a.m.-6:00 p.m. (Except Holidays) (B) Applications are taken to compile a waiting list. Due to the demand for housing in the Housing Authority of the City of Waco’s jurisdiction, the Housing Authority of the City of Waco may take applications on an open enrollment basis, depending on the length of the waiting list. (C) Completed applications will be accepted for all applicants and the Housing Authority of the City of Waco will verify the information. (D) Applications will be mailed to interested families upon request. (E) The completed application will be dated and time stamped upon its return to the Housing Authority of the City of Waco. 8.1 INTRODUCTION There are five (5) eligibility requirements for admission to public housing: qualifies as a family, has an income within the income limits, meets citizenship/eligible immigrant criteria, provides documentation of Social Security 1 numbers, and signs consent authorization documents. In addition to the eligibility criteria, a family must also meet the Housing Authority of the City of Waco screening criteria in order to be admitted to public housing. Families include but is not limited to the following regardless of actual perceived sexual orientation , gender or marital status 8.4 INFORMAL REVIEW/HEARING A. 10.1 If the Housing Authority of the City of Waco determines that an applicant does not meet the criteria for receiving public housing assistance, the Housing Authority of the City of Waco will promptly provide the applicant with written notice of the determination. The notice must contain a brief statement of the reason(s) for the decision and that the applicant may request, in writing, an informal review of the decision within ten (10) calendar days of the date of the denial correspondence. If the reason for denial is money owed to the WHA or another housing agency applicant will be notified of denial and given fourteen (14) days to repay the debt or be removed from the waiting list. Prior to Waco Housing Authority denying admission due to criminal record applicants will be provided with an opportunity to dispute the accuracy and relevance of the record before denial of admission. PREFERENCES The Housing Authority of the City of Waco will select families based on the following preferences within each bedroom size category: The local preference(s) applies only to the head of household. Local preference(s) must ber verified by written documentation at the time of orientation and/or eligibility appointment. The applicant must be able to provide written documentation for all preferences claimed on the local preference claim form. If Aa Preference has been selected, it may be changed at the time of eligibility (if the applicant’s circumstances have changed) because the selection criteria is not based upon the type of preference. However, it must match one or more of the local preferences established by Waco Housing Authority & Affiliates. Families include but is not limited to the following regardless of actual perceived sexual orientation , gender or marital status 10.4 OFFER OF A UNIT When the Housing Authority of the City of Waco determines that a unit will become available, it will contact the first family on the waiting list who has the highest priority for the type of unit. Families include but is not limited to the following regardless of actual perceived sexual orientation , gender or marital status 13.4 THE FLAT RENT The Housing Authority of the City of Waco has set a flat rent for each public housing unit. In doing so, in accordance with the Department of Housing and Urban Development Act of 2014 (2014 Appropriations Act) Section 210 requires PHAs to comply with the new requirements effective June 1. The 2014 Appropriations Act requires PHAs to establish flat rents at no less than 80 percent of the fair market rent (FMR). PHAs are required to revise its flat rent schedule to at least 80 percent of FMR by June 1, 2014.. The amount of the flat rent will be re-evaluated annually and adjustments applied. Affected families will be given a 30-day notice of any rent change. Adjustments are applied on the anniversary date for each affected family. The Housing Authority of the City of Waco will post the flat rents at each of its developments, and at the central office. Flat rents are incorporated into this policy upon approval by the Board of Commissioners. pounds. 19.9 INOCULATIONS AND LICENSES Each dog and cat must be certified to have had required inoculations, having been spayed or neutered, and being currently licensed prior to keeping the pet. Certifications must be placed in the pet owner’s resident file upon 2 registering the pet, and must be updated annually. All pets must be chipped in accordance to City of Waco ordinance. . 19.7(B) INOCULATIONS AND LICENSES Each dog and cat must be certified to have had required inoculations, having been spayed or neutered, and being currently licensed prior to keeping the pet. Certifications must be placed in the pet owner’s resident file upon registering the pet, and must be updated annually. All pets must be chipped in accordance to City of Waco ordinance. 3 Changes to the Section 8 Administrative Plan 3.0 Eligibility for Admission 3.1 INTRODUCTION There are five eligibility requirements for admission to Section 8 -- qualifies as a family, has an income within the income limits, meets citizenship/eligible immigrant criteria, provides documentation of Social Security Numbers, and signs consent authorization documents. In addition to the eligibility criteria, families must also meet Waco Housing Authority & Affiliates’ screening criteria in order to be admitted to the Section 8 Program. 3.2 ELIGIBILITY CRITERIA A. 4.2 Family Status 1. A family with or without children. Such a family is defined as a group of people related by blood, marriage, adoption or affinity that lives together in a stable family relationship. a. Children temporarily absent from the home due to placement in foster care are considered family members. b. Unborn children and children in the process of being adopted are considered family members for purposes of determining bedroom size, but are not considered family members for determining income limit. c. Gender identity and sexual orientation TAKING APPLICATIONS Families wishing to apply for the Section 8 Program will be required to complete an application for housing assistance. Applications will be accepted Monday – Thursday 8:30 a.m. to 6:00 p.m. at: 4400 Cobbs Dr., Waco, Texas 76710 Applications are taken to compile a waiting list. Due to the demand for Section 8 assistance in Waco Housing Authority & Affiliates’ jurisdiction, Waco Housing Authority & Affiliates may take applications on an open enrollment basis, depending on the length of the waiting list. When the waiting list is open, completed applications will be accepted from all applicants. Waco Housing Authority & Affiliates will later verify the information in the applications relevant to the applicant’s eligibility, admission, and level of benefit. Applications may be made in person at 4400 Cobbs Dr., Waco, Texas on Monday – Friday 8:30 a.m. to 600 p.m. Applications will be mailed to interested families upon request. The completed application will be dated and time stamped upon its return to Waco Housing Authority & Affiliates. Applications will be accepted online at wacopha.org. Reasonable accommodations will be made for persons with disabilities Access by calling 254-752-0324 ext. 215. 4.9 INFORMAL REVIEW If Waco Housing Authority & Affiliates determines that an applicant does not meet the criteria for receiving Section 8 assistance, Waco Housing Authority & Affiliates will promptly provide the applicant with written notice of the determination. The notice must contain a brief statement of the reason(s) for the decision, and state that the applicant may request an informal review of the decision within eightten (810) business days of the denial. Waco Housing Authority & Affiliates will describe how to obtain the informal review. The informal review process is described in Section 16.2 of this Plan. Formatted: Left, Indent: Left: 0" 5.2 PREFERENCES The local preference(s) applies only to the head of household. Local preference(s) must be verified by written documentation at the time of the briefing and/or eligibility appointment. The applicant must be able to provide written documentation for all preferences claimed on the LOCAL PREFERNCE CLAIM FORM. If a preference has been selected, it may be changed at the time of eligibility (if the applicant’s circumstances have changed) because the selection criteria is not based upon the type of preference. However, it must match one or more of the local preferences established by Waco Housing Authority & Affiliates. Consistent with Waco Housing Authority & Affiliates Agency Plan, Waco Housing Authority & Affiliates will select families based on the following preferences. VETERAN’S PREFERENCE: The head of household and/or spouse is currently a member of the Armed Forces, or the head of the household and/or spouse has an honorable discharge from the Armed Forces. In the case of a divorce or legal separation, the head of the household or former spouse must provide Waco Housing Authority & Affiliates with documentation that the head or spouse has rights to benefits; there is no right to the veteran’s preference. EMPLOYMENT PREFERENCE: Families whose head of household or spouse is employed. Families whose head of household or spouse has been given a bona fide offer of employment. This preference does not require a minimum of income, but the family’s annual income cannot exceed current very low income guidelines by HUD. Must have a minimum of 20 working hours a week for Section 8 and 24 hours a week for Public Housing No minimum length of time is required for the head or spouse to be employed. employment must continue for twelve months or longer. After move-in the ELDERLY: Head of Household or Spouse is 62 years of age or older. DISABLED AND HANDICAPPED HEAD OF HOUSEHOLD: This preference only applies to the Head of Household. JOB TRAINING / SCHOOL PREFERENCE: The head of household or spouse is currently enrolled and participating in a job-training program that prepares them for entering or re-entering the job market. Families where the head of household or spouse is a graduate of a job-training program that prepared them for entering or re-entering the job market. Head of Household is currently enrolled in educational programs working toward a degree. Must be a fulltime student (twelve hours or more) or give verifiable justification for carrying a lesser number of hours. DISPLACEMENT: The household has been displaced due to a nationally declared disaster area. DOMESTIC VIOLENCE PREFERENCE: (Must meet student rule) Household annual income cannot exceed current income guidelines by HUD Must be certified by the Family Abuse Center that provides shelter or counseling to victims of domestic violence. The Housing Authority shall determine that the domestic violence occurred recently (within 1 year) or is of a continuing nature. The applicant shall certify that the person who engaged in such violence will not reside with the family unless Housing Authority has advance written approval. The Housing Authority may deny or terminate assistance to the family for breach of certification. Extended Homelessness/Substandard Housing. This preference must be certified in writing by a caseworker within the HOT Homeless Coalition or the assigned McLennan County school district liasion for the Homeless as being homeless. The caseworker will certify that they meet the HUD or MckinneyVento definition of homeless, are a minimum of 18 years of age and have been homeless for at least thirty (30) days at time of application. They will be required to pass all other WHA 2 screening criteria before being eligible for assistance. We will verify with the caseworker that they are working with the client/s until such time they are no longer deemed as homeless. 6.2 PACKET During the briefing, the Housing Authority will give the family a packet covering at least the following subjects: A. The term of the voucher and the Housing Authority’s policy on extensions and suspensions of the term. The packet will include information on how to request an extension and forms for requesting extensions; B. How the Housing Authority determines the housing assistance payment and total tenant payment for the family; C. Information on the payment standard, exception payment standard rent areas, and the utility allowance schedule; D. How the Housing Authority determines the maximum rent for an assisted unit; E. Where the family may lease a unit. For families qualified to lease outside the Housing Authority’s jurisdiction, the packet includes an explanation of how portability works; F. The HUD-required tenancy addendum that provides the language that must be included in any assisted lease, and a sample contract; G. The request for approval of the tenancy form and an explanation of how to request Housing Authority approval of a unit; H. A statement of the Housing Authority's policy on providing information to prospective owners. This policy requires applicants to sign disclosure statements allowing the Housing Authority to provide prospective owners with the family’s current and prior addresses, and the names and addresses of the landlords for those addresses. Upon request, the Housing Authority will also supply any factual information or third party verification relating to the applicant’s history as a tenant, or their ability to comply with material standard lease terms, or any history of drug trafficking, drug-related criminal activity, or any violent criminal activity; I. The Housing Authority’s subsidy standards, including when the Housing Authority will consider granting exceptions to the standards; J. The HUD brochure on how to select a unit (“A Good Place to Live”); K. The HUD required lead-based paint brochure; L. Information on Federal, State, and local equal opportunity laws; the brochure “Fair Housing: It’s Your Right;" and a copy of the housing discrimination complaint form; M. A list of landlords or other parties known to Waco Housing Authority & Affiliates who may be willing to lease a unit to the family, or help the family find a unit; Wacohousingsearch.org (McLennan) . 11.5 Formatted: Indent: First line: 0" ASSISTANCE AND RENT FORMULAS A. Total Tenant Payment The total tenant payment is equal to the highest of: 1. 10% of monthly income 2. 30% of adjusted monthly income 3. Minimum rent 4. The welfare rent 5. The housing authority shall pay a monthly housing assistance payment on behalf of the family that is equal to the lower of (1) the payment standard minus 30% of the adjusted monthly income or (2) gross rent minus 30% of the adjusted monthly income Example: 1200 x12 14,400 gross monthly income months annual income 3 Formatted: Underline 14,400 - 480 - 480 13.440 - - 13,440 / 12 1,120 dependent allowance dependent allowance Formatted: Underline months adjusted monthly income 1,120 x 30% 336 TTP (Total Tenant Payment) 615 three bedroom payment standard -336 TTP 279 Maximum Subsidy Example: Family – single mom, with 2 dependent daughters Eligible: 2 BR 2 BR payment standard 462 Rent 400 Total Tenant Payment (TTP) 200 Utility Allowance 60 Maximum Subsidy 262 Gross Rent 460 Total Tenant Payment (TTP) 200 Maximum Subsidy 260 Housing Authority will pay the $260 because it’s the lesser of the Gross Rent minus the TTP or the Payment Standard minus the TTP 14.3.2 RELOCATING TENANT A relocating tenant will be responsible for repayment to a vacated landlord for those damages left in a rental property, which Waco Housing Authority & Affiliates finds customary and fair. Tenants will be mailed a letter by the vacated landlord listing these expenses within seven (7) days of moving. Waco Housing Authority & Affiliates reserves the right to review and consider the damage claim for what is customary and fair. Waco Housing Authority & Affiliates will hold the relocating tenant accountable for repayment of those charges found to be customary and fair. The repayment agreement will be determined by Waco Housing Authority & Affiliates on a case by case basis. Should the tenant fail to pay as required in the repayment agreement established, their 4 Formatted: List Paragraph, Indent: Left: 2", First line: 0", Bulleted + Level: 1 + Aligned at: 2.5" + Indent at: 2.75" Formatted: Underline Formatted: Underline Formatted: Underline Formatted: List Paragraph, Indent: Left: 1.5", Bulleted + Level: 1 + Aligned at: 2.5" + Indent at: 2.75" Formatted: Underline Formatted: Underline Formatted: List Paragraph, Indent: Left: 2", First line: 0", Bulleted + Level: 1 + Aligned at: 2.5" + Indent at: 2.75" Formatted: Font: 10 pt, Underline, Font color: Background 2 Section 8 housing assistance will be terminated when the lease ends with their current landlord. 1. 2. 16.2 1. Relocating Tenant will be required to attend a Mover’s Briefing Relocating Tenant will be required to do a walk thru with Landlord/Agent INFORMAL REVIEW FOR THE APPLICANT A. D. Informal Review for the Applicant Waco Housing Authority & Affiliates will give an applicant for participation in the Section 8 Existing Program prompt notice of a decision denying assistance to the applicant. The notice will contain a brief statement of the reasons for Waco Housing Authority & Affiliates’ decision. The notice will state that the applicant may request an informal review within eightten (810) business days of the denial and will describe how to obtain the informal review. Hearing Procedures Waco Housing Authority & Affiliates and participants will adhere to the following procedures: 1. Discovery a. The family will be given the opportunity to examine before the hearing any Waco Housing Authority & Affiliates documents that are directly relevant to the hearing. The family will be allowed to copy any such document at the family’s expense. If Waco Housing Authority & Affiliates does not make the document(s) available for examination on request of the family, Waco Housing Authority & Affiliates may not rely on the document at the hearing. b. Waco Housing Authority & Affiliates will be given the opportunity to examine, at the Waco Housing Authority & Affiliates’ offices before the hearing, any family documents that are directly relevant to the hearing. Waco Housing Authority & Affiliates will be allowed to copy any such document at Waco Housing Authority & Affiliates’ expense. If the family does not make the document(s) available for examination on request of the Waco Housing Authority & Affiliates, the family may not rely on the document(s) at the hearing. Note: The term document includes records and regulations. 2. Counsel of the Family At its own expense, the family may becounseled by an attorney or other representative. Attorney representation requires referral to WHA Attorney on a case by case basis per WHA guidelines. 3. Hearing Officer a. The hearing will be conducted by any person or persons designated by Waco Housing Authority & Affiliates, other than a person who made or approved the decision under review or a subordinate of this person. b. The person who conducts the hearing will regulate the conduct of the hearing in accordance with Waco Housing Authority & Affiliates’ hearing procedures. 4. Evidence Waco Housing Authority & Affiliates and the family must have the opportunity to present evidence and may question any witnesses. Evidence may be considered without regard to admissibility under the rules of evidence applicable to judicial proceedings. 5. Issuance of Decision 5 Formatted: Font color: Background 2 Formatted: List Paragraph, Numbered + Level: 1 + Numbering Style: 1, 2, 3, … + Start at: 1 + Alignment: Left + Aligned at: 2" + Indent at: 2.25" Formatted: List Paragraph, Numbered + Level: 1 + Numbering Style: 1, 2, 3, … + Start at: 1 + Alignment: Left + Aligned at: 1" + Tab after: 1.5" + Indent at: 1.5" Formatted: Font color: Background 2 The person who conducts the hearing must issue a written decision within 14 calendar days from the date of the hearing, stating briefly the reasons for the decision. Factual determinations relating to the individual circumstances of the family shall be based on a preponderance of the evidence presented at the hearing. If the decision to terminate assistance is unheld participant has the right to appeal further. Request must be made in writing within 8 business days. After the second appeal, if the decision to terminate assistance is upheld, participant has the right for a third and final appeal to the Sr. Vice President/COO within 8 business days, provided a written request is made . 21.0 Section 8 Homeownership Voucher Option Program Procedures A. B. C. D. Eligibility for Admission The eligibility for admission to the Homeownership Voucher Program will be the same verification and income requirements as the tenant-based voucher rental assistance program. However, there will be additional eligibility requirements for this program as follows: 1. Family must be a first time homebuyer (or no family member can have had current interest in a residence in the past three years). 2. Family must meet income requirement of the minimum wage x 2000 hours. 3. Family must meet the employment requirement of working on a full time job for at least one year prior to receiving assistance under this program (Full time employment is defined as working at least 30 hours per week on a job). 4. Family must not have defaulted on a mortgage securing debt to purchase a home under the homeownership voucher program. 5. Although all income is included when determining eligibility under the Section 8 rental assistance or public housing rental assistance programs, welfare assistance income must be excluded when determining for homeownership voucher assistance for all applicants with the exception of elderly or handicapped applicants. Application Waiting List The Section 8 Homeownership Voucher Program’s initial implementation date will be December 2000 or January 2001. The waiting list for this program will not be separate and apart from the tenant based rental assistance waiting list. Selection from the Waiting List Selection from the waiting list will be based on date and time of application. Homeownership Counseling Family will be required to attend homeownership counseling administered by Neighborhood Housing Services (NHS) NeighborWorks Waco or another qualified agency that conducts Homeownership training prior to the final approval of homeownership voucher assistance approval. This homeownership counseling shall be scheduled upon the issuance of the search and purchase authorization. 6 CAPITALIZATION POLICY Waco Housing Authority & Affiliates adopts the following capitalization policy for the purpose of determining, distinguishing and recording materials and non-expendable equipment and personal property purchased or acquired in connection with the development, management, and maintenance of public housing developments owned or operated by this Authority. A. If the initial cost of a piece of equipment and/or other personal property is Five ThousandHundred Dollars ($5,000.00) or more and the anticipated life or useful value of said equipment or property is more than one (1) year, the same shall be capitalized. In addition, recorded as non-expendable equipment and charged as a capital expenditure. B. If the initial cost of the piece of equipment and /or personal property is less than Five ThousandHundred Dollars ($5,000.00) or its useful life is less than one (1) year regardless of cost, the C. same shall be treated and recorded as materials or inventory and charged to Maintenance, Administration, or Tenant Services expense. The Executive DirectorPresident/CEO, or the Executive Director’s President/CEO’s designee, is authorized and directed to determine whether each piece of equipment or other personal property that is acquired by the Housing Authority in connection with the development, management and maintenance of the properties owned or operated by the Housing Authority, shall be classified as material or non-expendable, as defined in the preceding sections. The Executive Director President/CEO is further directed to ensure that the determination is documented in the appropriate records of the Housing Authority and retained for the information and guidance of its personnel and for audit purposes. Changes to the Charges for Repairs or Damages for Public Housing CHARGES FOR REPAIRS OR DAMGES 03/25/2015 Waco Housing Authority (Public Housing Units) REFRIGERATOR REPAIRS Door Racks Door Clips (brackets) Shelf Racks Vegetable Trays Glass Vegetable Tray Cleaning, Deforesting & deodorizing Plastic Door Molding, Complete Ice Trays $20.00 - $40.00 $10.00 - $15.00 $20.00 - $45.00 $25.00 - $50.00 $25.00 - $75.00 $25.00 - $75.00 $75.00 - $120.00 $3.00 ea Range Repair Grates (gas) Control Knob for Oven Burner Control Knob Range Burner Oven Racks Cleaning of Range Oven Control Gas Oven Control Electric Electric Range Drip Pan 6” Electric Range Drip Pan 8” $15.00 $5.00 $6.00ea $20.00 - $40.00 $15.00 - $40.00 $25.00 - $75.00 $67.95 $50.00 - $75.00 $5.00 $6.50 Stopped Up Drains Lavatory Sink Kitchen Sink Commode stop up Washer Drain $12.50, $17.50 & $25.00 $12.50, $17.50 & $25.00 $12.50, $17.50 & $25.00 $12.50, $17.50 & $25.00 Window Shades Small 26” – 30” Medium 31” – 40” Large 41 ½” - 66” $10.00 $15.00 $20.00 Screen Door Repair / Replacement (Mart) Screen Door Top Panel Bottom Panel Door Closure Screen Door Handle/Lock $135.00 $30.00 $35.00 $18.50 $12.50 Window Screens New Screen and Frame Top Panel Bottom Panel Bathroom Screen (each panel) Kitchen Screen (each panel) $50.00 - $85.00 $40.00 $40.00 $25.00 $25.00 Window Panes Small 8x12 (Mart) Medium (Mart) Large (Mart) Double Pane (Waco) $15.00 $20.00 $25.00 $84.50 - $100.00 & up Door Locks Set of Locks (Deadbolts) Set of Locks (Deadbolt)TX 10-1&3 Bathroom Lock Passage Lock Deadbolt Plunger Passage Lock Plunger Replacement Keys Us Can Door Plunger Schilage Door Plunger Keyless Door Lock $50.00 $35.00 (delete) $12.00 $12.00 $15.00 $7.50 $3.00ea $16.00 $10.00 $13.00 Floor Tile Square 12x12 Removal of personal floor tile $2.50 $25.00 - $50.00 per room plus cost of new tile ($43.07 per box) Bathroom Items Tub Stopper Lavatory Stopper Tub Stopper Plunger Type Towel Rack Tissue Roller Tissue Holder Towel Rack bar Commode Seat Commode Bowel Commode Tank Medicine Cabinet $3.50 $2.50 $16.00 $12.00 - $20.00 $2.00 $8.00 $8.00 $15.70 $47.50 $35.00 $30.00 ($33.99 new price) Kitchen Items Basket Strainers Kitchen Faucet Handles Fire Extinguisher Fire Extinguisher Refill $2.50ea $7.00ea $25.00 $25.00 Electrical Items Cover Plates Glass Light Fixtures Bathroom Fixture Glass Thermostat Light Switch Wall Plug Light Fixture Replacement Smoke Alarm 120v Replacement Smoke Alarm 9v Remove Ceiling Fan and Install new light Fixture Light Fixture Cover Fluorescent 9v Battery Light Bulb (regular 60w) Fluorescent Light Bulb $3.00 $12.00 - $15.00 $7.00 - $10.50 $27.50 $7.50 $7.50 $15.00 $17.50 $12.00 $40.00 $22.00 & up $2.50 $1.00 $3.00 Doors Cabinet Doors Cabinet Drawers Door Stopper Bedroom Door Replacement Bathroom Door Replacement Front & Back Entrance Doors Front & Back Entrance Doors Casings Return Air Grills $15.00 $20.00 $3.00 $35.00 - $45.00 $25.00 $180.00 - $500.00 $25.00 - $50.00 $7.50 up to $25.00 (depends on size) Trash Hauling Washers Dyers Freezers Refrigerator (personal) Furniture $25.00 $25.00 $75.00 $75.00 $25.00 & up Wall Repair Small Holes Medium Holes Large Holes Excessive Nail Holes – over 10 on any one wall Removal of Wall Boarders Repaint walls to cover (pictures, flowers, writing or other marking on walls) $15.00 $25.00 $30.00 $0.25 each hole $25.00 - $50.00 $25.00 - $50.00 After Hour Charges Commode Stop up Lock Out (5:00pm – 12:00am) Lock Out (12:01am – 8:00am) Kitchen Sink Stop up Lavatory Sink Stop up $25.50 $50.00 $65.00 $25.00 $25.00 Note: Labor charges $17.50 per hour. (Added to each item repaired) delete CHANGES TO THE WACO HOUSING AUTHROTIY & AFFILIATES CHECK SIGNING AUTHORIZATION POLICY CHECK SIGNING AUTHORIZATION POLICY Waco Housing Authority & Affiliates hereby establishes a policy that identifies those people who are authorized to sign and issue checks on its behalf. The purpose of this policy is to update instructions to depositories so that there is a clear understanding regarding this important matter. It also is necessary to implement appropriate internal controls over our financial matters. A. The following policy for issuing and signing checks of Waco Housing Authority & Affiliates shall be established: 1. The persons authorized to sign checks in behalf of Waco Housing Authority & Affiliates, which includes the Waco Housing Opportunities Corporation, the Waco Public Facility Corporation and Rising Images, Inc. are: Any Board Member (Board Chair or Vice Chair will be contacted first for signature) President/CEO Sr. Vice President/COO Vice President of Financial Services 2. All checks to be signed for purchases not exceeding $1,000.00 require one signature of the authorized persons listed under (1.) of this section. 3. All checks to be signed for purchases exceeding $ 1,000.00 but not exceeding $5,000.00 require any two signatures of the authorized persons listed under (1.) of this section. 4. All checks to be signed for purchases exceeding $5,000.00 requires the signatures of a board member and any of the authorized persons listed under (1.) of this section. B. The supporting data for each check shall be available for the signer to review at the time of signing. C. Section 8 Housing Assistance Payments (HAP) to landlords is an exception to the policy listed above. Due to the volume of checks distributed on the first day of each month to landlords, all checks are computer generated in bulk form with two automated signatures regardless of amount. D. The copy of this policy shall be forward to all designated depositories of the Authority. E. Waco Housing Authority & Affiliates may establish procedures for automated signatures. 1 Summary $ 1.00 - $1,000.00 $ 1,000.01 - $5,000.00 $ 5,000.01 and above any 1 signature any 2 signatures 2 signatures Board Member Plus any other authorized signer 2 1 WACO HOUSING AUTHORITY & AFFILIATES Community Services Department Family Self Sufficiency Action Plan RevisedMarch2015 4400 Cobbs Drive • PO Box 978 Waco, Texas 76703-0978 Phone 254-752-0324 • Fax 254.756-2072 2 Family Self Sufficiency (FSS) Program The Program established by a Public Housing Authority in accordance with 24 CFR 984 to promote self-sufficiency of assisted families, including the coordination of supportive services (42 U.S.C. 1437u). Table of Contents Introduction .............................................................................................. 3 Summary of Program ............................................................................... 3 Timetable for Program Implementation................................................... 3 Family Demographics .............................................................................. 3 Program Size ............................................................................................ 3 Family Selection ..................................................................................... 4 Assurance of Non Interference ................................................................ 4 Outreach Efforts ....................................................................................... 4 Program Coordinating Committee ........................................................... 5 Program Orientation................................................................................. 5 Incentives to Encourage Participation ..................................................... 5 FSS Escrow Account ............................................................................... 6 Escrow Account Interim Disbursement ................................................... 6 Porting Escrow Account .......................................................................... 7 Escrow Account Final Disbursement....................................................... 7 Escrow Account Forfeiture ...................................................................... 7 Contract Completion ................................................................................ 7 Contract Extension ................................................................................... 8 Contract Termination ............................................................................... 8 Activities & Supportive Services and Certification of Coordination ...... 9 Method for Identification of Family Support Need ............................... 10 Grievance Procedure .............................................................................. 11 Appendix A: Current Networking Agencies and Supportive Services .. 12 Appendix B: Definition of Terms .......................................................... 13 Three Attachments: WHA FSS Program (Current Statisics) 3 Introduction The Family Self-Sufficiency (FSS) Program is a federal program funded by the Department of Housing & Urban Development (HUD). It was created with the purpose of connecting participants on HUD housing assistance with existing public and private resources in their communities to support increased economic self-sufficiency. The Waco Housing Authority (WHA) was established in 1938 by a group of citizens concerned with the housing needs of moderate and low-income families. WHA’s mission is to provide safe decent and sanitary housing opportunities for individuals and families while promoting selfsufficiency, empowerment and neighborhood revitalization. WHA began its FSS program in 1993. WHA currently runs its FSS Program for both Public Housing (PH) and Housing Choice Voucher (HCV) participants. The FSS program is operated through WHA’s Community Services Department. This FSS Action Plan contains the policies and procedures of WHA’s FSS Program. Summary of Program The FSS Program is a voluntary five year Program that offers services free of charge to qualified tenants. Once enrolled, FSS Participants receive individualized case management by an FSS Coordinator. Services provided support the participants in reaching a variety of individualized goals that contribute to improving their quality of life. Many participants establish goals that result in advancing their education, increasing household income, improving credit score, purchasing a home and reducing dependency on welfare and other government assistance. Timetable for Program Implementation WHA FSS Program is no longer mandatory because all FSS slots have been filled with eligible families. Coordinators now administer a voluntary program in compliance with HUD guidelines. Family Demographics The FSS Program serves a diverse population and continues to target various demographics and people groups to participate in the Program. These groups include the elderly, disabled, veterans, families, individuals, and single parents. Needs of the population served include but are not limited to: seeking and maintaining employment, furthering education, obtaining financial counseling and management, legal aid referrals, reducing food insecurity, home ownership preparation, utility assistance, and other forms of monetary aid for individuals and families. Coordinators attend trainings and network with other agencies to stay abreast of local resources available in the community, as well as relevant available in order to better engage and assist our clients with their specific goals and needs. (See Attachments for current composition of FSS Participants served) Program Size and Estimate of Participating Families The FSS Program size currently consists of a minimum total of 35 participants, PH and/or HCV participants per FSS Coordinator. WHA currently has two FSS Coordinators, who administer at or above its voluntary Program size, in this case a minimum of 70 participants are served. Based 4 upon available resources and reasonable limitations of the two FSS Coordinators, no more than 85 families will be served, this includes any eligible families porting in from other Housing Authorities that are already on the FSS Program. However, as needed, Coordinators will maintain a waiting list where tenants will be in line to join the Program as participants graduate or are terminated from the Program. (See Attachments for current composition of FSS Participants served) Family Selection Procedures WHA will select families to participate in the FSS program in accordance with HUD Guidelines and Policies. Families are invited to attend an FSS Orientation. Those who choose to join are enrolled or placed upon the Wait List, depending upon current enrollment. As slots become available, those families on the Wait List will be invited to join the Program. The FSS Program Coordinators have the primary responsibility to ensure that participants are not discriminated against in the selection process. WHA’s Policy complies with all Federal, State, and Local nondiscrimination laws, the Americans with Disabilities Act and the U.S. Department of Housing and Urban Development Regulations governing Fair Housing and Equal Opportunity. No person shall be excluded from participation in, be denied the benefits of, or otherwise be subjected to discrimination under the FSS Program on the grounds of race, color, sex, religion, national or ethnic origin, familial status, source of income, or disability. In addition, WHA’s FSS Coordinators will, upon request, provide reasonable accommodation to persons with disabilities to ensure they are able to take advantage of the services provided by the FSS Program. If a tenant desires to join the FSS Program and they have a Fraud Repayment Agreement due to owing money to WHA, then they will be allowed to join as long as they are complying with the agreement. If they are not in compliance then admission to the program can be postponed or denied. If an FSS Participant has been previously terminated for the FSS Program and has not received escrow monies (interim disbursements), they will be considered for readmission to the program on an individual basis and can be placed on a temporary probation period to assure compliance. If a tenant owes QHWRA Community Service hours which are more than a reasonable amount, admission to the FSS Program can be delayed or denied. Assurance of Non-Interference with the Rights of Non-Participating Families WHA FSS Program assures that if a family chooses not to participate in the FSS Program, it will not affect the family’s participation in HCV or PH housing assistance programs. Outreach Efforts FSS Program Coordinators’ recruiting efforts include but are not limited to: providing information at PH and HCV Orientations, introductory letters with Program brochures are mailed out to all new WHA tenants, FSS brochures are provided to all PH Admission Specialists, HCV Counselors and Inspectors, who make them available to all tenants who visit their office. Additionally, Program information is made available on the WHA website and presentations are 5 periodically conducted at Public Housing Resident Council Meetings. Outreach materials are available in English, Spanish and any other language as requested, assuming translating services for the language requested are available. Interpreters will be utilized as needed for all aspects of the FSS Program and clients may contact FSS Coordinators via our TTD telephone line, fax, email, telephone or in-person. Efforts are targeted equally to minority and non-minority families to ensure that non-English and limited English speaking families receive information and have the opportunity to participate in the FSS Program. Upon request, the WHA FSS Coordinators provide reasonable accommodation for people with disabilities. Program Coordinating Committee According to Federal HUD Regulations, which guide the administration of the FSS Program, a Program Coordinating Committee (PCC) must be created and maintained to assist in “securing commitments from public and private resources to operate the FSS program.” The WHA FSS Program PCC members serve both the PH and HCV FSS participants by networking with us to provide input and guidance as Coordinators develop, maintain and update the FSS Action Plan. They also provide resources specific to their agencies, which contribute to Program implementation. Members of the PCC include a PHA representative, a PH participant and a HCV participant. In addition, we have a variety of community partners who volunteer to participate in the PCC. Representatives from local job training programs, local government, employment agencies, public child welfare agencies, child care providers, public/private education and/or training institutions, non-profit agencies, private businesses, and other service organizations and community members. This collaboration helps assure better coordination of community resources with the hope of continuous improvement in the services provided. It also minimizes the duplication of services and activities. The PCC meets quarterly and may conduct business on an as-needed basis via telephone conferences, email, and/or in person. Program Orientation Coordinators host FSS group or individual orientations throughout the year, which applicants must attend before enrolling in the Program. The tenant then makes a decision to join or not, or they can choose a later enrollment date. If the maximum number of participants has been reached, then potential participants may be placed on a FSS Wait List. The Orientation includes an overview of Program services offered to participants. Information includes the voluntary nature of the Program, the FSS Contract, the Individual Training Services Plan (ITSP), the responsibilities of the participant, goal setting and documentation requirements, escrow account eligibility, interim and final disbursements, and the requirements to complete the FSS Contract and graduate from the Program. The Head of Household is the only family member required to have an ITSP while on the FSS program, however, other adult household members can choose to create an ITSP. This secondary ITSP does not have the same employment requirements; however, all goals must be completed within the designated timeframes. Incentives to Encourage Participation As part of the FSS program, WHA offers incentives to encourage participation and enhance the participant’s ability to achieve self-sufficiency. Some of these incentives are described below. 6 WHA will establish an FSS Escrow Account for each eligible participating family in accordance with HUD guidelines as a financial incentive. Please see the Escrow Account section for more detailed information Referrals for education, job training and employment support Financial management classes Credit counseling and credit reports GED/HS Diploma preparation services through community partners Provide speakers on various topics pertinent to the participants’ needs and goals at regular FSS Meetings Recognition Award banquet to acknowledge participants’ accomplishments and graduates Provide a support system for participants who experience hardships Letters, emails and phone calls to motivate, encourage and celebrate progress Dependent upon donations from the community, provide bus passes, gas cards, gift cards, clothing, furniture, household items, and door prizes For those pursuing homeownership, access to a wide network of services is made available Note: Many of these incentives are contingent upon available funding and resources and are therefore, subject to change. FSS Escrow Account When a participant becomes eligible for an FSS Escrow deposit, according to HUD Guidelines, the deposit is calculated based upon an increase in earned income and rent from the initial earned income and rent they were earning at the time of enrollment. Escrow credit calculations are completed whenever an interim or annual re-examination occurs. This may or may not result in an escrow deposit. WHA credits eligible escrow accounts monthly; these credits will be effective on the first day of the month. WHA calculates and credits interest monthly. Annually, WHA provides all current FSS participants with an escrow account a statement reflecting the current balance, deposits, withdrawals, and interest accrued for the year. Escrow Account Interim Disbursements The WHA FSS Program allows clients to receive interim disbursements from their escrow accounts in accordance with the following guidelines: Participants in the FSS program with an escrow account are allowed to request money from their escrow accounts prior to the completion of their Contract of Participation. Requests for interim disbursements must be related to one or more goals listed in the participant’s ITSP. The participant must demonstrate progress toward goals before being approved for an interim disbursement. Acceptable progress towards the goal(s) will be determined by the FSS Coordinator. The FSS program reserves the right to request that a participant complete a budget and/or provides additional documentation prior to making a decision on the participant’s interim disbursement request. Final approval is made by both a PCC member and the Coordinator. Interim disbursement checks are made out to vendor/agency or directly to the FSS Participant. The participant must submit documentation (i.e. receipts) to verify the funds were spent as 7 intended. An FSS Program participant will not be eligible to receive future interim disbursements from their escrow account if proper documentation is not received. Porting the Escrow Account The WHA FSS program, in accordance with HUD guidelines, allows HCV FSS clients who port their FSS Contract of Participation to port their FSS escrow accounts as well. The escrow account will be ported when the receiving housing authority absorbs the voucher of the participant. Note: In some cases, the receiving housing authority may not absorb the voucher and WHA continues to administer that voucher. In this situation, the WHA FSS Program would continue to oversee the escrow account under the policy’s defined in this Action Plan for the remainder of the FSS Contract or until the absorption of the voucher, whichever comes first. Escrow Account Final Disbursement The final disbursement funds will be made to the FSS Head of Household (HOH) when the participant completes the Contract of Participation and verifies that no one living in the household is receiving welfare, as defined by FSS guidelines in accordance with HUD’s definition (see Contract Completion section below for more information). There are no requirements or stipulations on the participant’s use of the final disbursement funds. Escrow Account Forfeiture If the participant fails to complete for any reason the Contract of Participation, any escrow funds accumulated are forfeited in accordance with the FSS Program and HUD guidelines. If it is reported that the family has underreported income or assets thus committing fraud, money in the escrow account directly related to this fraud will immediately be forfeited. If they are evicted or their voucher is terminated the entire escrow account is forfeited in accordance with the FSS Program and HUD Guidelines. Contract Completion After completion of the FSS Contract of Participation, in order to receive the balance of the FSS Escrow Account, the participant must meet one of the following sets of criteria: a) The Head of Household must seek and maintain suitable employment and must verify that no one in their household has received welfare assistance for the previous 12 months. (see Definitions, Appendix B) The Head of Household and any additional adult family members who created an ITSP must complete all goals listed on the ITSP within the designated timeframes. b) Thirty percent (30%) of the family’s monthly adjusted income equals or is greater that the FAIR Market Rent amount for the unit size for which the family qualifies. Additionally, when a FSS Participant moves off subsidized housing or into homeownership and are no longer receiving PH or HCV housing assistance, a thorough review of their contract and file is conducted to determine eligibility for completion of the contract. 8 In all situations, the participant must assure that the FSS Coordinator has all necessary documentation required to verify completion of goals on file before final approval and disbursement of escrow account balances can take place. The Community Service Director must approve and sign for the final disbursement. It is possible to complete the Contract of Participation and not be eligible for a final escrow disbursement if a member in their household is still receiving welfare assistance (see Definitions, Appendix B). If a participant experiences a temporary hardship that prevents them from pursuing goals for a short period of time, Coordinators may postpone their participation until a later date when they may resume pursuit of goals. The postponed period of time will not be counted against the term of their 5 year contract. If escrow monies have accumulated they will not be added during this time but the account will continue to earn interest. If a client does not reenter the program within a reasonable amount of time escrow monies will be forfeited. Contract Extensions The term of the Contract of Participation is five (5) years, but in extenuating circumstances the contract may be extended for up to two (2) additional years. Requests for an extension of the contract will be evaluated on a case by case basis to see if “good cause” exists for granting an extension. In general “good cause” means a circumstance beyond the family’s control and that directly interferes with the participant’s ability to meet the obligations of the contract. “Good cause” includes: • Serious illness or injury in the immediate family • Involuntary loss of employment An extension may also be granted to allow the family to meet the interim goal of remaining off welfare (as defined above) for the final 12 months of the Contract. Extensions will not be granted for loss of employment due to inappropriate behavior and/or resulting from a lack of performance on the part of the FSS participant and/or due to voluntary resignation. A written request for contract extension must be submitted by qualified individuals prior to expiration of the Contract of Participation. If a request for extension is denied and the participant disagrees with the decision they may request an informal hearing (see WHA Grievance Procedures). Contract Termination A participant’s Contract of Participation with the WHA FSS Program may be terminated under the following circumstances: If the family withdraws from the FSS Program Mutual consent of both parties (WHA FSS program & the Head of Household on the Contract) 9 The failure of the FSS family to meet its obligations under the Contract of Participation without “good cause.” This will be determined on a case by case basis by the FSS Coordinator to determine if there is “good cause” for not meeting the contract obligations. If an act occurs that is inconsistent with the purpose of the FSS program WHA is permitted to terminate the contract in accordance with HUD requirement If a participant fails to report progress to the Coordinator at least semi-annually. Appropriate documentation of progress is made in the Communication Log. In the event the participant cannot be contacted for a report on progress, the Coordinator mails the participants actions required to avoid termination. If the participant does not comply with the actions outlined in the letter, a notification letter is sent that the contract of participation will be terminated. When a participant’s housing assistance is terminated If the family moves outside of WHA’s jurisdiction under portability procedures and enters the FSS Program of another housing authority. Note: All escrow money held on the family’s behalf will be forfeited in accordance with HUD regulations. The participant will receive a written notice stating the reason for their termination from the FSS Program. The WHA FSS Program uses termination of the COP as the only corrective action for the failure to comply with family obligations defined in the Contract of Participation. Termination of housing assistance will not occur solely because a participant is terminated from the WHA FSS Program. Termination does not preclude a client from future participation in WHA’s FSS program. Reentry into the FSS Program will be determined on an individual basis. Activities and Supportive Services and Certification of Coordination FSS Program participants have access to an extensive network of activities and services to assist them in becoming more self sufficient. Some are provided directly by the FSS Coordinators, and/or Program partners, and/or the PCC, and/or through referrals to other community agencies. Services provided by FSS Coordinators include assisting the participant in developing their Individual Training and Services Plan (ITSP), providing ongoing guidance as they pursue goals, providing supervision of the participant’s progress, and advocating for families to help empower them toward self-sufficiency. Government, non-profit, and private resources provide services that include: Counseling to help further education Job skills and job retention activities Encouragement to obtain and maintain employment Access to affordable childcare and transportation 10 Financial Literacy and Management and Tax Preparation assistance and referrals Credit Report reviews and information on how to improve credit scores Individual Development Accounts (IDA) in preparation for homeownership Life skills and parenting skills Access to Food Pantries, free school supplies and school uniform assistance Donations of clothing and household items See Appendix A for a list of current networking agencies and service providers. WHA FSS Program coordinates with all networking agencies on an ongoing basis to assure avoidance of duplication of services being provided to participants. Method for Identification of Family Support Needs Participants in the FSS program work closely with the FSS Coordinators to identify family needs in a holistic manner and to develop an Individual Training and Services Plan (ITSP), which is an attachment to the Contract of Participation. The ITSP identifies the final goals the participant will complete while enrolled in the program and the interim goals and activities that will be included in reaching those goals. During the first meeting with a new FSS participant, the Coordinator reviews the Intake and Assessment data with the client. This information assists the Coordinator and the participant as they begin the goal setting process. The Coordinator assists the participant in setting specific, measurable, attainable, realistic and timely (SMART) goals. The Head of Household is required to complete and sign the Contract of Participation (COP), the Individual Training and Services Plan (ITSP), and any related documentation. While on the FSS Program, a client must work with their FSS Coordinator to report progress towards their ITSP goals within the timeframes indicated. The Coordinator aids the client in locating and securing resources in the community to assist them with attaining their goals. The Coordinator also helps navigate barriers to completing the goals whenever possible and documents this progress. Communication with the participant and documentation serves as a means to identify new/ existing needs and address them as they relate to their goals of selfsufficiency. The WHA FSS Program understands that throughout the course of the contract, a participant’s priorities and goals may change. Therefore, the program allows changes to be made to the ITSP. All proposed changes to a participant’s ITSP will be evaluated on a case by case basis and the WHA FSS Program will have the final authority in the approval or denial of a change to an ITSP goal. Revisions to a goal, including entirely cancelling a goal, must be signed by both the client and the FSS Coordinator before they will be considered valid. The FSS Coordinator, on an ongoing basis, will always seek to identify relevant needs of the population through contact with clients, office visits, FSS Meetings, and contact through phone and email. Coordinators engage with participants to better understand their current situations and provide relevant service recommendations and knowledge needed. In addition, surveys are conducted which help reveal additional needs of participants. 11 Grievance and Hearing Procedures The WHA FSS Program will make efforts to resolve any and all grievances of FSS participants in accordance with the policies and procedures outlined the FSS Action Plan and in the current WHA Grievance Procedure guidelines. In the unlikely event that a grievance is not resolved, an FSS program participant can request a hearing in accordance with the grievance procedures. 12 Appendix A Current Networking Agencies and Service Providers Note: These agencies and providers may change adapting to new situations and funding resource availability Local Churches (monetary, food, etc) Employment AmeriCorps Acts Church Baylor University Antioch Community Church Chamber of Commerce Brazos Meadows Baptist Church Christian Women’s Job Corp Carver Park Baptist DARS Columbus Avenue Baptist Church Goodwill Learning Center (Job Boot Camp) Crossties Ministries Temp agencies-JOAT, Express, etc First Presbyterian Church Texas Workforce Solutions Highland Baptist Church Waco Housing Authority Lake Shore Baptist Church Praise Temple Education Baylor University Children and Youth Needs FAFSA Baylor Autism Research Clinic GED sites, Adult Basic Education, Literacy classes Boys & Girls Club McLennan Community College Campfire TX State Technical College Child Care Services (CCS) TX WIA Program Children’s Protective Services Children’s Special Needs Network Food and Healthcare Needs Care Net Pregnancy Center of Central Texas Communities in Schools Caritas Equal Opp Advancement Corps (HeadStart) Family Health Center Baylor S & W Hillcrest Car Seat Program Baylor Scott & White Hillcrest Medical Center HOT Autism Network Indigent Health Office Medicaid Reference Desk & TX Health Steps Manna Ministries Methodist Home MCC Support & Empowerment Program Road to Damascus Medicaid & TX Health Steps V.O.I.C.E. Mission Waco Waco Independent School District Providence Hospital WIC Shepherd’s Heart TX AgriLife Financial Needs, Scholarships, & Legal Aid TX Hunger Initiative Annualcreditreport.com Waco McLennan Co. Health District Extraco Bank Women’s Health Insurance Lone Star Legal Aid MCC Foundation Office Crisis Management & Mental Health Service Advocacy Center Money Management International Cenikor NAHRO Family Abuse Center US Dept. of Veterans Affairs Family & Children Counseling Services Waco Housing Authority & Affiliates Jennifer L. Phillips, Med, LPC Wells Fargo Bank H.O.T. MHMR 13 National Alliance on Mental Illness (NAMI) Salvation Army STARRY Counseling Income Tax Preparation AARP Free Tax Prep at UHS General Assistance Services & Referrals Act Locally 211 call center Kate Ross Computer Lab (CCLC) Lone Star Legal Aid www.freedomdisabilities.com Housing Programs and Assistance Carbajal Realty City of Waco Housing & Community Development Services Habitat for Humanity Individual Development Account NeighborWorks S8 Homeownership Program Waco CD www.wacohousingsearch.org Appendix B Definitions of Terms Seek: The WHA FSS Program defines “seek” as making progress towards activities, interim goals and final employment goal as listed in the participant’s ITSP. The participant must demonstrate this progress at least annually by communicating with the FSS Coordinator. Suitable: The WHA FSS Program defines “suitable” employment as a legitimate activity that falls into at least one of the following categories: • Employment which is verifiable. Employment must be with one (or more) established, legitimate business (-es). • Self-employment which is verifiable and reflects net earnings (after business expense deductions). • Contracted or commission employment may be considered if it is verifiable, and is being declared for tax purposes. Individual participant’s situations will be reviewed on an individual basis for approval. • Reasonable Accommodation for Disabled Individuals: The FSS program will consider the number of hours specified by Social Security or the medical provider when determining the hours required for the disabled client to be “suitably” employed. Documentation may be requested. In addition to the above listed criteria, “suitable” employment will be determined by the Coordinator, after consulting with the Head of Household, and will be determined based on the skills, education, and job training of the participant and available job opportunities in the area. Welfare: HUD defines welfare specifically for the FSS program in their guiding documents. It is defined as income assistance from Federal or State welfare programs, and includes only cash maintenance payments (TANF) designed to meet a family’s ongoing basic needs. It does not include food stamps, housing assistance, Social Security payments, Medicaid, or similar benefits. CHANGES TO THE WACO HOUSING AUTHORITY & AFFILIATES INVESTMENT POLICY INVESTMENT POLICY 10.0 DIVERSIFICATION: Waco Housing Authority & Affiliates will diversify its investments by security type and institution. With the exception of U.S. Treasury securities and authorized investment pools, no more than 50% of the Waco Housing Authority total investment portfolio will be invested in a single security type or with single financial institution or broker/dealer. 11.0 MAXIMUM MATURITIES: To the extent possible Waco Housing Authority & Affiliates will attempt to match its investments with anticipated cash flow requirements. Unless matched to a specific cash flow, the Authority will not directly invest in securities maturing more than three years (3) from the date of purchase. This maximum maturity policy applies to all Housing Authority funds. The maximum dollar weighted average maturity (WAM) is 365 days. 12.0 INTERNAL CONTROL: The Vice President of Financial Services shall establish an annual process of independent review as part of the annual audit. This review will provide internal control by assuring compliance with policies and procedures. 13.0 PERFORMANCE STANDARDS AND REPORTING: The Vice President of Financial Services or designee will prepare a monthly quarterly investments report for the Housing Authority Board of Commissioners. The report shall contain the name of the Financial institution or broker/dealer holding the investment, the cost of the investment, the fair market value of the investment, the purchase and maturity dates of the investment. The performance will be measured by standards set by the U.S. Department of Housing and Urban Development. 3. Securities of Government Sponsored Agencies: a. b. c. Farm Credit Consolidated System Wide Discount Notes Federal Farm Credit Banks Consolidated System Wide Bonds Federal Home Loan Banks Consolidated Obligations 1 d. FHLMC Mortgage Participation Certificates (PC) (Guaranteed) e. FHLMC Collateral and Mortgage Obligations (CMOs)Federal National Mortgage Association (FNMA) Debentures f. Federal National Mortgage Association (FNMA) Debentures g. FNMA Notes h. FNMA Short Term Discount Notes i. FNMA Capital Debentures j. Student Loan Marketing Associations (SLMA) Obligations ATTACHMENT B BOARD APPROVED INVESTMENTS INSTITUTIONS Bank Name Address 1. Alliance Bank 4721 Bosque Blvd; Waco, TX 76710 2. American Bank 200 W State Highway 6; Waco, TX 76712 3. Bank of America 1100 N Valley Mills Dr; Waco, TX 76710 4. BBVA Compass 900 Washington Ave; Waco, TX 76701 5. Central National Bank 5400 Bosque Blvd; Waco, TX 76710 6. Chase Bank 320 N New Rd; Waco, TX 76710 7. Community Bank & Trust 1409 Wooded Acres; Waco, TX 76710 8. Extraco Banks 1700 N Valley Mills Dr; Waco, TX 76710 9. Fidelity Bank of Texas 1901 W Lake Shore Drive; Waco, TX 76708 10. First Community Bank 1300 N Valley Mills Dr; Waco, TX 76710 11. First National Bank of Central Texas 1835 N Valley Mills Dr; Waco, TX 76710 12. Incommons Bank 5400 Crosslake Pkwy Ste 100; Waco, TX 76712 13. Independent Bank 5401 Bosque Blvd; Waco, TX 76710 14. Pointwest Bank 420 N Hewitt Dr; Hewitt, TX 76643 15. Synergy Bank 510 N Valley Mills Dr, Ste 100; Waco, TX 76710 16. Texas First State Bank 4800 Sanger Ave; Waco, TX 76710 17. The National Banks of Central Texas 5500 Bagby; Waco, TX 76711 18. Wells Fargo Bank 300 Franklin Ave; Waco, TX 76701 2 CHANGES TO THE PUBLIC HOUSING MAINTENANCE POLICY MAINTENANCE POLICY 1.3 DEVELOP PERFORMANCE STANDARDS AND GOALS The Director of Housing Operations will establish measures that will allow the effectiveness of maintenance systems and activities to be evaluated. In establishing these standards the Housing Authority will take into consideration certain factors: Formatted: Tab stops: 0.5", Left + 1", Left + 1.5", Left + 2", Left + 4.58", Left A. Local housing codes; B. HUD Housing Quality Standards; C. Public Housing Assessment System (PHAS) standards; D. Waco Housing Authority & Affiliates Collective bargaining agreements; and E. Waco Housing Authority & Affiliates job descriptions. Nothing in the documents listed above will prevent the Housing Authority from setting a standard that is higher than that contained in the documents. These standards and goals will be used to evaluate current operations and performance and to develop strategies to improve performance and meet the standards that have been set. 1.6 LONG-RANGE PLANNING The Waco Housing Authority & Affiliates will put in place a long-range maintenance planning capability in order to ensure the most cost-effective use of Authority resources and the maximum useful life of Authority properties. The Director of Housing OperationsHousing Operations or designeewill develop a property-specific long-range planning process that includes the following components: The Director of Housing Operations or designee is responsible for the development of this plan which shall contain components for minimal routine service as well as servicing for seasonal use. Serviceable components for each 1 vehicle or piece of motorized equipment will be listed in the plan along with the type and frequency of service required. The Director of Housing Operations or designee shall also maintain a system to ensure that any employee that operates a vehicle or piece of motorized equipment has the required license or certification. 12.C. Life Safety Systems The Waco Housing Authority & Affiliates shall have a comprehensive program for maintenance of life safety systems to ensure that they will be fully functional in the case of an emergency. The Director of Housing Operations or designee shall be responsible for the development and implementation of a schedule that includes the inspection, servicing and testing of this equipment. The equipment to be included in the plan includes the following: A. Pest Control/Extermination The Waco Housing Authority & Affiliates will make all efforts to provide a healthy and pest-free environment for its residents. The Authority will determine which, if any, pests infest its properties and will then provide the best possible treatment for the eradication of those pests. The Director of Housing Operations will determine the most cost-effective way of delivering the treatments -- whether by contractor or licensed Authority personnel. The extermination plan will begin with an analysis of the current condition at each property. The Director of Housing Operations shall make sure that an adequate schedule for treatment is developed to address any existing infestation. Special attention shall be paid to cockroaches. The schedule will include frequency and locations of treatment. Different schedules may be required for each property. Resident cooperation with the extermination plan is essential. All apartments in a building must be treated for the plan to be effective. Residents will be given information about the extermination program at the time of move-in. All residents will be informed at least one week and again seventy twotwenty-four hours in advance before treatment. The notification will be in writing and will include instructions that describe how to prepare the unit for treatment. If necessary, the instructions shall be bi-lingual to properly notify the resident population. B. Landscaping and Grounds 2 Formatted: Indent: Left: 0.5", Numbered + Level: 1 + Numbering Style: A, B, C, … + Start at: 3 + Alignment: Left + Aligned at: 1" + Tab after: 1.5" + Indent at: 1.5", Tab stops: 1", List tab + Not at 1.5" The Waco Housing Authority & Affiliates will prepare a routine maintenance schedule for the maintenance of the landscaping and grounds of its properties that will ensure their continuing attractiveness and marketability. Routine grounds maintenance includes numerous activities: Formatted: Indent: Left: 1", Hanging: 0.5", Numbered + Level: 1 + Numbering Style: 1, 2, 3, … + Start at: 1 + Alignment: Left + Aligned at: 0" + Tab after: 0.25" + Indent at: 0.25", Tab stops: 1.5", List tab + Not at 0.25" 1. Litter control 2. Lawn care 3. Maintenance of driveways, sidewalks and parking lots 4. Care of flower and shrubbery beds and trees 5. Maintenance of playgrounds, benches and fences Formatted: Indent: Left: 1", Hanging: 0.5", Numbered + Level: 1 + Numbering Style: 1, 2, 3, … + Start at: 1 + Alignment: Left + Aligned at: 0" + Tab after: 0.25" + Indent at: 0.25", Tab stops: 1.5", List tab + Not at 0.25" Formatted: Indent: Left: 1", Hanging: 0.5", Numbered + Level: 1 + Numbering Style: 1, 2, 3, … + Start at: 1 + Alignment: Left + Aligned at: 0" + Tab after: 0.25" + Indent at: 0.25", Tab stops: 1.5", List tab + Not at 0.25" Formatted: Indent: Left: 1", Hanging: 0.5", Numbered + Level: 1 + Numbering Style: 1, 2, 3, … + Start at: 1 + Alignment: Left + Aligned at: 0" + Tab after: 0.25" + Indent at: 0.25", Tab stops: 1.5", List tab + Not at 0.25" Formatted: Indent: Left: 1", Hanging: 0.5", Numbered + Level: 1 + Numbering Style: 1, 2, 3, … + Start at: 1 + Alignment: Left + Aligned at: 0" + Tab after: 0.25" + Indent at: 0.25", Tab stops: 1.5", List tab + Not at 0.25" 3 Changes to the WHA & Affiliates Personnel Policy (Changes are in RED) 5. Termination of Employment The following are policies concerning the various ways in which employment with the Authority may be terminated. A. Dismissals As at will employees, an employee's employment with the Authority may be terminated at any time, with or without notice and with or without cause. B. Resignations An employee who desires to resign from his/her employment should give a two weeks notice in writing to their immediate supervisor. If the individual so desires he/she may set forth his/her reasons for resigning. Employees shall not be entitled to any pay increases pending, or not yet approved by the Board of Commissioners, or by HUD. The employee has to be employed with the Authority for six (6) months or more to receive vacation pay. An employee resigning without the two weeks notice shall be ineligible for rehire. C. Termination Pay An employee who is permanently separated shall be paid in a lump sum for any accumulated vacation less any debts owed to the Authority as long as the employee has been employed with the Authority for six (6) months or more. The employee has to be employed with the Authority for six (6) months or more to receive vacation pay. D. Reduction in Force 1. If it is necessary to reduce personnel, the selection of employees to be retained shall be based primarily on their relative efficiency and the continuing need for the position. Other things being equal, length of service shall be given consideration. 2. Whenever possible, at least a two-week notice prior to dismissal shall be given an employee except for temporary employees or persons employed for a specific period or job, and other employees dismissed for cause. E. Letter of Recommendation Any letters of recommendation for former Authority employees shall be approved and signed by the President/CEO or his delegated representative. F. Retirement Employees may be retired from regular employment with the Authority upon reaching their 70th birthday. Personnel may be retained, however, on a year-to-year basis with the approval of the Board of Commissioners. D. Absence from Work 1. Notice of Absences From time to time, it may be necessary for an employee to be absent from work. Permission to be absent must be obtained from your immediate supervisor or President/CEO in advance. Such permission is necessary whether or not the employee will be gone the whole day or simply absent from work for a period of time, such as for a doctor's appointment. In cases of emergency, you must 1 telephone your supervisor or the central office prior to normal starting time, but no later than 8:00 a.m. You must personally telephone your supervisor prior to normal starting time if you are going to be absent or late. A call from your spouse, mother, or child is not acceptable unless you are physically unable to call. Your failure to report to work without notice is a serious matter, and will not be tolerated. If you are absent from work for one or consecutive full shifts without proper notification, you will be considered to have voluntarily resigned your position and your employment may be terminated at the discretion of the President/CEO. 4. Vacation (Annual ) Leave The Authority will grant annual vacation with pay to all regular full-time and part-time employees. Vacation leave shall be administered according to the following provisions: a. Leave shall be credited at the end of the month for which accrued b. Employees shall receive vacation leave on the basis of eighty (80 ten (10) working hoursdays per year until employee reaches 5 years of consecutive service. Any debts owed by employee to the Authority may be deducted from the employees vacation pay at any time. c. Any holiday falling into an employee's vacation will not be counted as a day of vacation. d. Vacation leave may not be taken by new employees prior to the successful completion of the probationary period except in cases of emergency with written approval of President/CEO. In such cases, the probationary period may be extended commensurably. e. Vacation plans should be submitted in writing to the supervisor for approval at least one week in advance. Seniority shall be the basis to determine priority should vacation plans be in conflict within the department. Should circumstances compel change in an employee's vacation plans, the employee's supervisor may approve or disapprove the change depending on the Authority's needs. No annual leave shall be scheduled during days of the month or time of heavier workloads requiring the services of certain key personnel or those of a specific trade. Short periods of annual leave, including an employee's birthday, shall also require prior approval of the supervisor or department head. Employees on annual leave may be recalled to duty if conditions warrant their service. f. An employee may not receive vacation pay in lieu of time off, except in case of termination. g. A maximum of forty- (40) hours annual leave may be carried over to the next Calendar year. Calendar year is defined as January 1st thru December 31st. Regular employees shall be encouraged to use their full annual or vacation allowance before the end of each calendar year. h. After five years of consecutive Authority service, an employee receives one hundred and twenty fifteen (15) working hours days of vacation each year. Vacation leave is not advanced to employees, and each employee is urged to take his full vacation each yea i. Part-time employees shall earn annual leave in proportion to the hours worked and years of service. Temporary employees shall not earn annual leave benefits. j. Employee hired on or before the 15th day of the month or separated on or after the 16th day of the month shall receive full annual leave credit for the month. Those employees hired after the 15th day of the month receive no annual leave credit for the month. k. Upon separation from employment with the Authority, employees shall be paid for any accrued vacation time less any debts owed to the Authority. However, no vacation pay shall be paid to employees who have worked for less than six months. 2 l. o. In the event an employee resigns or is terminated during the first month of service, that employee will have the cost of hiring deducted from their final pay. Cost associated with hiring will include, but not be limited to, the pre employment medical exam, drug screen, Motor Vehicle Record check, and immediate training cost. m. If an employee gets sick during the time they are on scheduled annual (vacation) leave they must submit a doctor’s excuse in order to utilize sick leave for the time the employee is sick. If the employee cannot provide a doctor’s excuse the employee will be charged for annual (vacation) leave time. n. If the agency closes early the day before a holiday or for snow/ice days, an employee who is on annual (vacation) leave may not have any annual (vacation) hours credited to their records. The employee must use their annual (vacation) hours. Vacation leave must be taken in increments of no less than one (1) hours at a time. 5. Sick Leave The Authority will grant sick leave with pay to eligible full-time and eligible parttime regular employees for the purpose of a bona fide illness or accident of employees. Sick leave begins accruing from the date of initial employment. Sick leave cannot be taken until after one month of full time employment. a. Sick leave for regular full-time employees will be earned at the rate of 8 hours per month of active employment and may be accumulated. b. Temporary employees and part-time regular employees working less than twenty hours per week are not eligible for sick leave. Part-time employees working over 20 hours per week shall receive sick leave in proportion to the hours worked. c. Sick leave shall be administered as follows: 1. Sick leave shall be credited at the end of the month for which accrued and may be taken at any time, thereafter, for illness, injury, or routine medical or dental appointments which cannot reasonably be scheduled outside of working hours. Illness arising from pregnancy or complications thereof shall be regarded the same as other types of illness. 2. Sick leave credits are not transferable between employees. 3. An employee taking sick leave shall notify his immediate supervisor prior to normal starting time. or before 8:00 a.m. on the day of his or her absence. Sick leave cannot be granted unless such prescribed notification has occurred. 4. Any sick leave taken in excess of three (3) consecutive working days may require a signed physician's statement certifying your reason for absence and expected return. Unless waived by the President/CEO, any employee absent for more than three (3) consecutive working days must provide a return to work authorization signed by their physician. 5. High rates of sick leave (7 occurrences per year or 70 hours), may result in a poor performance review and limit annual merit raise to a single step. Higher rates of sick leave usage will be cause for disciplinary action and/or possible termination. Sick leave slips must be submitted immediately upon your return to work. Failure to submit leave slips will result in Absent With Out Leave and loss of wages. You are responsible for seeing that your slips are turned into the office. The President/CEO will consider extenuating circumstances on a case-by-case basis. 6. Sick leave shall not be used for absences due to on-the-job injuries, which are covered by workers' 3 Formatted: Normal, Indent: Left: 0", First line: 0" Formatted: Font: 12 pt Formatted: Indent: Left: 0" compensation. Sick leave shall not be granted to an employee on vacation unless the President/CEO approves such action (see #8 below). 8. If an employee gets sick during the time they are on scheduled annual (vacation) leave they must submit a doctor’s excuse in order to utilize sick leave for the time the employee is sick. If the employee cannot provide a doctor’s excuse the employee will be charged for annual (vacation) leave time. Sick Leave must be taken in increments of no less than one (1) hour at a time. 6. Emergency Leave Emergency leave of 40 hours shall be granted on January 1 for all regular fulltime employees. New employees hired from January 2 through March 31 will be credited with 30 hours of emergency leave, those hired from April 1 through June 30 will be credited with 20 hours and those hired between July 1 and September 30 will be credited with 10 hours. This leave shall be non-cumulative and if not used prior to December 31, it will be lost. Part time employees working 32 to 39 hours per week will be credited with 4/5’s of the emergency sick leave time granted a regular full time employee. Employees serving their probationary period shall not be eligible to use emergency leave except with approval of President/CEO. Emergency leave will be applicable to sudden or unexpected illness or injury due to accident or scheduled medical or dental appointments for members of the employee’s immediate family. The "immediate family" is defined as the employee's husband, wife, significant other, children, brother, sister, parents, mother/father-in-law, or grandparents. Emergency leave is designed to be used when the affected employee is the only person reasonably available to care for the ill or injured family member. 7. 9. C. TRAVEL ADVANCES: 1. 2. 3. It shall be the policy of the Authority to provide for the reasonable and necessary expenses of those authorized to travel. That provision shall take the forms of payment under "advances" for estimated travel expenses and "reimbursements" for actual expenses. An "advance" will be made based upon the following: The cost of meals will be based upon the Internal Revenue per diem rates. The rates may be changed to reflect adjustments by the Internal Revenue Service. When advances for estimated travel expenses (lodging and meals) are made as set forth above, then within five (5) working days of completion of travel, adequate evidence (i.e. receipts) must be submitted to the Authority. In the event reasonable and necessary actual allowable expenses described herein are less than advanced, the traveler must reimburse the Authority within ten (10) days after the return trip. Meal costs are based on daily per diem rate as described above in Section 8, Paragraph C.2. Receipts for meals are not required. Although receipts will not be required for meal per diems, the daily meal per diems are allocated based on the following percentages: Breakfast = 25% of per diem Lunch = 25% of per diem Dinner = 50% of per diem Therefore, if a full meal is included for particular days of a conference, your daily per diem will be decreased by the particular percentage of that particular meal. 4 Formatted: Normal, Indent: Left: -0.5", Hanging: 0.5", Tab stops: Not at 3" Formatted: Font: 12 pt 4. 5. 6. 7. 8. 9. 10. 10. For one-day travel out of town one third of per diem rates of the city in which the training is being held will be allowed. The choice of method of transportation shall be left to the discretion of the authorized traveler. The traveler must be able to travel to and from training within the same timeframe as traveler’s using commercial airlines. The Authority will pay for the use of a personal vehicle at the mileage rate recognized by the Internal Revenue Service not to exceed what airfare would have cost. Commercial airline (only "Coach" fares shall be authorized). A local air carrier shall be utilized whenever possible. Airport limousines, taxis or public transportation shall be used whenever feasible. The President/CEO approves car rentals. If warranted, however, the traveler must use the most economical rental plan available. (Receipt required) When parking a vehicle (such as at an airport or at the hotel), the cost of parking will be advanced based on an estimate, or actual if known. The authority will pay for the use of a personal vehicle for training at the rate recognized by the Internal Revenue Service not to exceed coach airfare. If traveler uses his/her personal vehicle, the Authority beyond the time it would take for someone to travel shall pay no food or lodging by air to and from the destination. Use of a personal vehicle must be approved by the President/CEO. Tips, other than meals, will be reimbursed for actual expenditure. Any tip made in connection with a meal is part of the cost of the said meal and covered by the per diem for meals. Telephone calls will be reimbursed for actual expense for Authority business. A $10.00 allowance will be given to each traveler for personal telephone calls. Cost of taxi, shuttle, etc. will be reimbursed for actual expense. Receipts must be submitted for reimbursement. Other Matters C. Employee Benefit Programs 1. 2. Retirement Plan & Life Insurance In order that employees may earn some security for themselves and their families, IRA or HUD qualified retirement plan is in operation. Retirement plan requirements and benefits will be provided to all employees at time of employment. Employees become eligible for the current retirement plan on the st 1 of the month following the completion of 90 consecutive days of employment and participation in the retirement program is mandatory. The amount to be contributed by an employee is 4.5% on a pre-tax basis of his/her salary. An additional 1% is a mandatory contribution by employee to purchase life insurance for 1.5 times his/her salary on an after-tax basis. Waco Housing Authority & Affiliates also offers a 457 Deferred Comp. Plan that is a voluntary tax deferred plan (pre-tax). All employees shall participate in the Social Security Act. Medical & Dental Insurance Regular full-time employees are covered under a group comprehensive medical program. For single employee medical coverage, Waco Housing Authority & Affiliates pays 85% of the premium and the employee pays 15%. For family medical coverage, Waco Housing Authority & Affiliates pays 70% of the premium and the employee pays 30%. For single dental coverage, Waco Housing Authority & Affiliates pays 100% of the premium. For family dental coverage, the employee pays a small monthly fee, and the remaining premium is paid by Waco st Housing Authority & Affiliates. Coverage commences on the 1 of the month following 60 consecutive days of employment. Payroll deductions for such coverage will begin thirty (30) days in advance of effectiveness of coverage. See Human Resources for more details for the following: 5 Wavier of Insurance for regular full time employees Open Enrollment Removal of Family from insurance coverage The President/CEO will waive the health and dental care probationary period for any part-time or temporary employee whom has had continual employment with WHA & Affiliates or temporary employment thru a contract agency for a period of 6090 days or more prior to being made a regular employee. 3. A sworn Declaration and Registration of Informal Marriage certificate from the Courthouse of residence must be submitted to the Human Resource Specialist along with substantiating documentation including a new social security card and new driver’s license before a spouse/child will be added to the employee’s benefit package. Sick Leave Incentive Payment Policy th with the approval of the President/CEO oOnce a year on September 30 , or the last working day prior to that date, employees with sick leave balances in excess of 120 hours may apply, in writing, through their Department Supervisor, to trade sick leave hours at a rate of 2 to 1 and receive a sick leave incentive payment check in addition to their regular paycheck the first pay day in December. All Supervisors must have all requests to the Finance Department by the end of the th day (September 30 or last working day to that date). The maximum hours that an employee can trade is 80 hours, which, at a rate of 2 to 1, will result in a one-week payment at their current pay rate. Any amount of hours traded less than 80 hours must be traded in multiples of 2016 sick leave hours which equates to 10 8 hours of pay (16 hrs, 32 hrs, 48 hrs, 64 hrs, 80 hrs.) The employee’s sick leave balances will be reduced by the number of hours traded after the trade request is processed. Employees must be on the employee roster the first payday in December to take th advantage of this benefit. Termination of employment between September 30 and the first payday in December will also terminate your request for this benefit L. Use of Authority's Vehicles and Equipment Some positions require employees to drive or operate motor driven vehicles or equipment owned or used by the Authority. Any vehicle (including privately owned) operated or used on Authority business shall be utilized only by drivers with valid Texas Class A, B or C licenses. All drivers shall be required to obey all traffic rules and regulations prescribed by law and to use every reasonable safety measure to prevent accidents. The Authority carries liability insurance on all authority vehicles and collision coverage on selected authority vehicles for such activities. All employees who may use their personal vehicle are required to provide the Authority "proof of insurance liability coverage" issued to them in their name by their personal insurance company (unless they do not own a vehicle). In this instance, they are required to sign a statement to that effect. The Authority requires updated insurance cards on all employees. EQUAL EMPLOYMENT OPPORTUNITY AND AFFIRMATIVE ACTION AND SECTION 504 EMPLOYMENT COMPLAINT COMPLIANCE 6 13. EEO AND AFFIRMATIVE ACTION As noted in the Personnel Policy, the Civil Rights Act of 1964 and subsequent legislation and HUD regulations require that Authorities provide equal employment opportunity to all persons regardless of race, creed or color, sex, age, national origin, handicap, familial status or veteran status. This EEO Policy and Program amplifies the information in the Personnel policy and sets out the Waco Housing Authority's basic action policy, affirmative action (AA) program, and outlines management responsibilities and procedures for implementing the Authority's EEO and AA program and compliant system. Basic EEO/AA Action Policy The Waco Housing Authority will provide equal employment opportunity for all persons regardless of race, creed, color, sex, national origin, age, or handicap familial status or veteran status. An affirmative action plan to overcome effects of past discrimination will be implemented. Managers, at all levels of the Housing Authority share responsibility and will be held accountable for achievement of the Authority's affirmative action goals. Equal Employment Opportunity and affirmative action will affect all employment practices including (but not limited to) recruitment, hiring, layoffs, and termination. Therefore, EEO/AA plan cannot be merely a "neutral" document. It will require accountability for goal achievement. A. Affirmative Action Program The Authority will provide adequate staff to implement the AA program, tasks will be designed to achieve maximum benefits, and the results of implementation will be evaluated periodically. 1. B. Staffing The Authority will designate staff throughout the organization (including all subordinate components) sufficient to effectively implement a results-oriented EEO program including a full range of affirmative action activities. Staff assigned to AA work will be provided training and orientation in personnel administration and in EEO matters. The designated staff will be assigned specific responsibilities and provided authority for implementing AA activities. Affirmative Action Activities The following activities will be conducted as needed and are subject to budget limitations: 1. Recruitment a. 2. Monitor Authority recruitment efforts to ensure that they are reaching all sources, including minority groups and women. b. Establish continuing recruitment relationships with schools and other educational institutions having significant numbers of female or minority group students, including contacts with fraternities, sororities, alumni groups, minority groups, etc. c. Make certain that recruiting efforts reach Blacks, Hispanics and other minority groups, students and women. d. Develop work-study cooperative education programs and similar arrangements to prepare students for employment, particularly in shortagecategory occupations. e. Assure that opportunities for part-time employment are made known to employees and applicants. Full Use of Employees a. Conduct surveys of underutilized or non-utilized skills available in the existing workforce. b. Review qualifications requirements used by the Authority to assure they are not unrealistically high in terms of jobs to be done and that they do not 7 3. 1. 2. 6. screen out lower level employees actually capable of performing the real functions of the jobs. c. Restructure jobs and establish entry level and trainee positions to facilitate movement among occupational areas. Upward Mobility a. Provide career counseling and guidance to employees. b. Ensure that selection requirements do not constitute unwarranted barriers to upward mobility. c. Create career development plans for lower grade employees who are underutilized or demonstrate potential for advancement. d. Conduct positive programs of occupational analysis, job redesign, and job restructuring to provide new opportunities for entry employment and opportunities for advancement to higher positions. Training and Incentives for Managers a. Provide specific and practical training to instruct and advise supervisors and managers on carrying out their equal employment opportunity requirements. b. Develop programs to identify and reward supervisors who contribute notably to affirmative action program success. c. Conduct annual ceremony to award prizes or certificates to employees that made significant contributions to the EEO/AA program and publish results in the Authority's newsletter. Participation in Community Efforts to Improve Employability a. Actively support community equal housing efforts. b. Cooperate with community groups in the establishment of child day-care centers needed by employees or applicants. c. Establish continuing, productive relationships with minority and women’s organizations in the community. d. Assist colleges, technical schools, and high schools to improve the quality of education and to develop curricula, which relate to the requirements of the Authority's jobs. Evaluation of EEO/AA Program Results a. The Authority will designate a management level employee to monitor implementation of the EEO/AA plan and evaluate results of such efforts. This designation will be included in the employee’s job description. b. The designated employee will perform the following tasks. 1. Establish a process for monitoring implementation efforts. 2. 3. C. This will require coordination with and cooperation from other personnel responsible for accomplishing EEO/AA activities listed above. Collect, maintain and analyze statistical data on employment of minority groups including women. At year-end, evaluate implementation of the overall EEO/AA program and prepare a summary report of results and problem areas and recommended solutions. EEO/AA Responsibilities This subsection outlines the responsibilities of management staff in implementing the Authority's EEO/AA program. It covers all aspects of employment from design of the Authority's organization structure to career progression of employees. The responsibilities are outlined below by areas and levels of management. D. Organization/Position Management President/CEO 8 Develop long-range plans for the organization structure and composition of the work force based on forecasts of workload, available resources, labor supply, and EEO/AA requirements. Set policy, establish priorities, goals and objectives for organizational design, job redesign and restructuring to provide upward mobility and increased job opportunities for minorities, women and handicapped (i.e., part time, entry level, etc.). Assemble adequate resources (positions, salary dollars, personnel, material, etc.) to administer a comprehensive organizational design and position management program. Provide leadership and set an example by redesigning or restructuring positions within own office to provide upward mobility and increased job opportunities for minorities, women, and handicapped. Middle Managers Translate long-range strategic plans developed by top management into operational plans and procedures, which will provide increased job opportunities for minorities and women. Integrate and coordinate organizational design and position management with the Personnel/EEO Officer, Administration Finance Officer, and administrative staff. Allocate resources for organizational design and position management in line with priorities, goals, and objectives established by top management. Monitor and evaluate agency efforts to redesign or restructure positions to provide increased opportunities for minorities, women, and handicapped. First Line Supervisors Review all vacancies to determine if job restructuring is possible. Redesign and restructure jobs to provide upward mobility and increased promotion opportunities for minorities, women, low skilled, disadvantaged, and handicapped. Restructure positions within the unit to best utilize and develop subordinates' knowledge, skills and abilities, and to improve organizational effectiveness. Personnel Official/EEO Officer Advise managers and supervisors on organizational design, job restructuring, and position management. Provide staff support and assistance to managers and supervisors in organizational design, position management, and job restructuring. Make recommendations to top management on ways to effectively and efficiently use position management and organizational design techniques to achieve EEO/AA objectives. Review agency policy, procedures and practices on job redesign, position management, and organizational structure to identify barriers and impediments to upward mobility toward increased job opportunities for minorities, women, handicapped, low-skilled, and disadvantaged. Coordinate with management staff on upward mobility, position management, and job redesign efforts. Make recommendations to management on needed changes in organizational design and 9 position management policy and procedures to assure that minorities, women, and handicapped have every opportunity to develop and advance to their full potential. E. Recruiting President/CEO Formulate strategy/goals for personnel staffing and EEO/AA requirements based upon agency mission and anticipated workload, availability of resources, and EEO profile. Establish priorities for recruiting minorities, women, and handicapped to achieve a staff which is representative of the work force or labor supply. Provide leadership and set an example by recruiting applicants for top management positions from all segments of the community and assembling a staff which is representative of the work force. Middle Managers Translate long-range EEO/AA staffing requirements into procedures. Allocate position slots and salary dollars in accordance with goals and priorities established by top management. Coordinate recruiting efforts with Personnel/EEO officer. Monitor and evaluate agency staffing efforts to identify barriers and impediments to recruiting minorities, women, and handicapped. First Line Supervisors Consistently recruit applicants from all segments of the community rather than relying on "the good old boy network" or personal referrals. Use alternative methods and nontraditional recruiting sources to locate qualified minorities, women, and handicapped. Consult with the Personnel Official to assure minorities, women, and handicapped are included in the applicant pool from which selections are made and when necessary expand the minimum area of consideration, extend the closing date of the vacancy announcement, contact minority or women's organizations, make special recruiting efforts, etc. Personnel Official/EEO Officer Develop operational plans and activities to achieve goals set by management for recruiting minorities, women, and handicapped. Develop recruiting methods, policies, and procedures which are designed to attract applicants from all segments of the community -- particularly minorities, women and handicapped. Advise managers and supervisors on the most effective and efficient manner to recruit a highly diversified staff which is representative of the labor force. Provide staff support and assistance to managers and supervisors in recruiting minorities, women, and handicapped. Also, periodically review agency recruiting techniques, procedures, and literature to assure they reflect the organizations mandate to recruit candidates from all segments of the community. Identify staffing techniques and procedures which adversely impact on recruiting of minorities, women, and 10 handicapped. Recommend to management and Personnel needed changes or modifications in staffing techniques to improve the recruiting of minorities, women, and handicapped. Coordinate with the Personnel Division on the recruiting of minorities, women, and handicapped. F. Qualification Standards and Applicant Evaluation President/CEO Delegate authority for developing and implementing job-related qualification criteria and applicant evaluation techniques and procedures which will not adversely impact minorities, women, and handicapped. Set an example and provide leadership by using qualification standards and applicant evaluation techniques developed by Personnel to appraise minorities and women for top management positions. Middle Managers Develop plans in line with goals and priorities established by top management for the preparation and utilization of valid job-related qualification standards and applicant evaluation procedures. Allocate resources for developing qualification standards and applicant evaluation procedures which will not adversely impact minorities, women, and handicapped. Coordinate and integrate the development and use of job-related applicant evaluation standards with other stages in the employment process. Monitor the consistent use of job-related qualification standards to evaluate minorities, women, and handicapped for positions in the agency. First Line Supervisors Use job-related qualification criteria to objectively evaluate minorities, women, and handicapped applicants for employment. Identify and eliminate or modify qualification criteria which are not job-related that impact adversely on minorities, women, and handicapped. Provide input and information for the development of job-related qualification criteria; help identify the relevant knowledge, skills, and abilities required for successful performance. Personnel Official/EEO Officer Develop policy and guidance for managers and supervisors on the use of job-related applicant evaluation criteria, techniques, and procedures. Interpret guidelines and regulations issued by OPM and EEOC on the use of valid, job-related applicant evaluation standards which will not adversely impact on minorities, women, and handicapped. Provide staff support and assistance to managers and supervisors on the use and implementation of job-related applicant evaluation criteria to assure that minorities, women, and handicapped receive full consideration. Recommend to management the elimination or modification of applicant evaluation criteria and 11 procedures which impact adversely on minorities, women, and handicapped. Advise management on the support and commitment needed from them to assure minorities, women, and handicapped are not excluded from consideration because of invalid or inconsistent qualification criteria or evaluation procedures. The Qualifications Table below shows elements of job requirements and factors to be considered regarding qualifications of applicants for employment. QUALIFICATIONS ASSESSMENT TECHNIQUES MEASURES EVIDENCES G. JOB REQUIREMENTS PREDICTORS SKILLS KNOWLEDGE ABILITIES PERSONAL TRAITS EXPERIENCE TRAINING EDUCATION STANDING IN CLASS GRADE POINT AVERAGE TRANSCRIPTS PERFORMANCE APPRAISALS AWARDS/HONORS REFERENCES APPLICATION INTERVIEW PUBLICATIONS MEMBERSHIPS LICENSES WRITTEN TEST SCORES WORK SAMPLES PERFORMANCE TESTS Interview of Applicants President/CEO Utilize interview techniques and procedures, which are job-related and afford minorities, women, and handicapped full consideration for employment. Provide leadership and set an example by objectively interviewing minorities, women, and handicapped using job-related interview techniques and procedures. Middle Managers Monitor and evaluate agency efforts to interview minorities, women, and handicapped for employment and consistently ask job-related questions. Allocate sufficient resources to train supervisors and managers on appropriate interview techniques and procedures. First Line Supervisors Interview all applicants for employment in line with policies and procedures developed by the Personnel/EEO officer. 12 Develop a list of job-related questions for use during interviews. Refrain from asking personal questions during interviews. Consult with Personnel/EEO officer on the need for special recruiting or staffing efforts when minorities, women, and handicapped are not referred for interviews. Personnel Official/EEO Officer Develop and implement training programs for managers and supervisors on interviewing techniques. Provide advice and assistance to managers and supervisors on the development and consistent use of interview questions, which are job-related, impersonal, and non-sexist. Provide staff support and assistance to managers and supervisors by interviewing applicants for employment and assuring that minorities, women, and handicapped are given full consideration. Review agency interview techniques and procedures to identify those which adversely impact on minorities, women, and handicapped. Determine if the number of minorities, women, and handicapped being interviewed is consistent with their inclusion in the applicant pool; if not, identify reasons for the disparity and take the necessary steps to correct. Recommend to top management the policy, support, and commitment necessary to assure minorities, women, and handicapped are given full consideration in hiring and promotion interviews. The table below shows the type of questions asked applicants that may be discriminatory or lead to discrimination. MAJOR AREAS OF PREEMPLOYMENT INQUIRIES IT IS NOT DISCRIMINATORY TO ASK.... ADDRESS Applicant's current and previous address and length of residence. AGE IF HIRED, CAN YOU SUBMIT PROOF OF AGE? or statement that selection is subject to proof of age if age is a legal requirement. If applicant is a minor, proof of age in form of work permit, certificate of age or birth certificate. NONE ANCESTRY OR NATIONAL ORIGIN IT MAY BE DISCRIMINATORY TO ASK... Inquires into foreign addresses, which would indicate national origin. Whether applicant owns or rents home. Relationship of persons with whom applicant lives. Requirements for birth or baptismal certificate as proof of age PRIOR to selection. Any inquiry regarding ancestry or national origin of applicant's parents, spouse or associates, or any membership in associations which may indicate ancestry or national origin. 13 ARRESTS BIRTHPLACE CITIZENSHIP NONE NONE ARE YOU A CITIZEN OF THE U.S.? IF NOT, DO YOU HAVE THE LEGAL RIGHT TO REMAIN PERMANENTLY IN THE U.S.? DO YOU INTEND TO REMAIN PERMANENTLY? If hired, proof of citizenship may be required. CONVICTIONS COURT RECORDS Actual conviction which are substantially related to applicant's ability to perform a specific job. CREDIT RATING NONE DEPENDENTS NONE EDUCATION Schools attended. Academic, vocational or professional education, Language, office or other skills if substantially related to ability to perform job duties. Name of person to contact in emergency. EMERGENCY CONTACT EXPERIENCE HANDICAPS Applicants work experience. Other countries visited. DO YOU HAVE ANY PHYSICAL, MENTAL OR SENSORY HANDICAP WHICH MIGHT AFFECT WORK PERFORMANCE OR WHICH SHOULD BE CONSIDERED IN JOB PLACEMENT? Physical examination if required of all applicants LANGUAGE SKILLS If required to perform the job. MARITAL STATUS MRS., MISS., MS. when made in good faith and not for the purpose of discrimination. Whether applicant can meet specific work schedules. Any other commitments which might hinder attendance. Anticipated duration on job or anticipated absences if asked of both males and females. Military experience and education in the armed forces of the United States which MILITARY RECORD Language commonly used by an applicant or how an applicant acquired a proficiency in a foreign language. Any inquiry relating to arrests. OF WHAT COUNTRY ARE YOU A CITIZEN? Date of citizenship. Whether the applicant or parents are naturalized or native born. Requirement that birth certificate, baptismal or naturalization records be submitted as a proof of citizenship prior to selection. To inquire about any conviction or court record which is not substantially related to applicant's ability to perform job duties. Any questions about applicant's economic status or other source of income. Whether applicant owns or rents home. Method of transportation if not related to job requirement. If any children, number of, names and ages, Child care arrangements, Marital status. The nationality or religious affiliations of schools. How language skills were acquired. Requiring the name of a relative to be contacted. DO YOU HAVE ANY HANDICAPS? LIST ALL SERIOUS ILLNESSES FOR THE PAST FIVE YEARS. General inquires concerning handicaps or physical conditions, which do not relate to applicant's fitness to perform job. Inquiries concerning receipt of Worker's Compensation. Physical examination if required only of some applicants prior to or after selection. Requiring a level of language proficiency or the use of a particular language at ALL times if not substantially related in job duties. "Mother tongue" or language commonly used by applicant. How applicant acquired proficiency in a foreign language. SINGLE, MARRIED, DIVORCED, SEPARATED, and WIDOWED... Questions concerning pregnancy, birth control, children, or future childbearing plans. Spouse's name, age, place of employment, or income. Type of date of discharge. Applicant's general military service which is not 14 relates to specific duties. MISCELLANEOUS Notice that misstatements, omissions, and false information on application may result in discharge. NAME HAVE YOU EVER WORKED FOR THIS ORGANIZATION UNDER ANOTHER NAME? IS ADDITIONAL INFORMATION CONCERNING CHANGE OF NAME NECESSARY TO CHECK WORK OR EDUCATION RECORDS? IF YES, EXPLAIN. ORGANIZATIONS Membership and offices held in organizations, which relate to applicant's ability to perform a particular job. PHOTOGRAPH May be required after hiring. PHYSICAL CHARACTERISTICS SUCH AS HEIGHT AND WEIGHT If necessary to perform substantial job duties. NONE RACE REFERENCE RELATIVES RELIGION WHO REFERRED YOU HERE? and names of professional character references Names and addresses of parents/guardians of MINOR Names of relatives already employed with the organization if this affects company policy. NONE SEX MR., MRS. OR MISS, MS. MALE OR FEMALE when made in good faith and not for the purpose of discrimination. A voluntary request only and stated as such. Job advertisement or classification on the basis of sex and an inquiry concerning the sex of the applicant are permissible only if a BONA FIDE OCCUPATIONAL QUALIFICATION (BFOQ) exists. WORK SCHEDULES Whether applicant can meet a specific work schedule substantially related to ability to perform specific job duties. Any non job-related inquiry which is unnecessary to determine an applicant’s eligibility for employment Inquiries about former names which have been changed by court order or otherwise not required to check necessary records. LIST ALL ORGANIZATIONS, CLUBS OR SOCIETIES TO WHICH YOU BELONG. Inquiries about membership in organizations, which would indicate race, color, national origin, ancestry, sex, physical handicap and creed or religion. Suggested or required prior to hiring unless based on a BFOQ general regulation number three. If unrelated to abilities necessary to perform substantial job duties. Direct or indirect inquiries which would indicate an applicants race or color, color of skin, eyes or hair. Race or color is never a Bona Fide Occupational Qualification (BFOQ) Requiring a religious reference. Name or address of a relative of an adult applicant. Any inquiry to indicate or identify religious affiliation denomination, customs, holidays observed or name of minister. Sex of applicant or inquiries, which would indicate sex if not a voluntary request and stated as such to the applicant, BFOQ is interpreted very strictly by the courts. It is extremely difficult for the sex of the applicant to be considered a lawful pre-employment inquiry. Sex is not a BFOQ – because a job requires physical labor unusual work schedules or travel - because of the preferences of customers, employer, employees or others because of stereotypes concerning attitudes of abilities on the basis of sex. REASONABLE ACCOMMODATION is required for an applicant on the basis of religion or creed inquiry made prior to selection should be justified by BUSINESS NECESSITY. The information above is to be used only as a guide to evaluate Pre-Employment inquiries for 15 potentially discriminatory questions. This concerns both written and oral inquires directed to an applicant PRIOR to selection or employment. H. INTERVIEW QUESTIONS WHICH MAY LEAD TO DISCRIMINATION The following is a list of questions commonly found in public and private employment application forms. Each of them inquires into a factor which might be considered in a manner which might violate Title VII of the Civil Rights Act of 1964 or another law aimed at achieving equal employment opportunities for all. An employer should be aware that when he inquires into any of these factors he is running a risk of encouraging unlawful discrimination by his employees, and of providing evidence which may be used by complainants in proving charges of discrimination made against the employer. Even when the employer does not use the information solicited by these questions, the questions may have the unlawful effect of tending to discourage women or minorities from even applying for jobs. It is equally important to remember, however, that this list is concerned only with the potential unlawful use of information. Quite different considerations are involved when the purpose of seeking information is to carry out an affirmative action program. Finally, if some of the information discussed below is needed for post-employment purposes, it can be obtained after the applicant has been selected for employment. 1. 2. 3. 4. AGE? DATE OF BIRTH? The Age Discrimination in Employment Act (29 U.S.C. 621-34) prohibits discrimination on the basis of age against individuals who are between the ages of 40 and 64, inclusive. A majority of states also have laws prohibiting age discrimination. Thus the answer to this question could be used unlawfully. ARRESTS? Consideration of arrest records is almost certainly unlawful. An arrest is no indication whatsoever of guilt and historically minorities have suffered proportionately more arrests than others. See Carter v. Gallagher, 451 F. 2nd 315 (8th Cir. 1971); Gregory v. Litton System, Inc., 316 F. Supp. 401 (C.D. Cal. 1970). The U.S. Department of Labor has also recognized the potential for discrimination in the consideration of arrest records. See 60-2.24(d) (3) of Revised Order No. 4, establishing standards and guidelines for the affirmative action programs required of government contractors. AVAILABLE FOR SATURDAY AND SUNDAY WORK? This question may serve to discourage applications from persons of certain religion, which prohibits their adherents from working on Saturday or Sunday. On the other hand, it may be necessary to know whether an applicant can work on these days. Section 701 (j) of Title VII, as amended in 1972, prohibits discrimination on the basis of religion defines religion to include "all aspects of religious observance and practice, as well as belief. Unless an employer demonstrated that he is unable to reasonably accommodate to an employee's or prospective employee's religious observance or practice without undue hardship on the conduct of the employer's business." If this kind of question were asked, it would be desirable to indicate that a reasonable effort will be made to accommodate to the religious needs of employees. CHILDREN UNDER 18? NUMBER OF CHILDREN? AGE OF CHILDREN? WHAT ARRANGEMENTS WILL YOU MAKE FOR CARE OF MINOR CHILDREN? The purpose of these questions is to explore what the employer believes to be a common source of absenteeism and tardiness. But why explore this area in such an indirect way, and in a 16 5. way, which applies only to women for all practical purposes? There are a number of common causes of absenteeism and tardiness, which affect both men and women and which would be worthy of exploration if this is a matter of substantial concern to the employer. The U.S. Supreme Court has ruled that in the absence of proof of business necessity, Title VII prohibits an employer from having one hiring policy for women and another for men -- each having pre-school age children. Phillips v. Martin Marietta Corps., 400 U.S. 542 (19971). It is also important to note that any selection procedure, which has an adverse effect on persons with dependent children, will affect minorities and Catholics more than others, since they have, on the average more children. CITIZEN OF WHAT COUNTRY? The Commission has adopted Guidelines on Discrimination Because of National Origin which contain the following statement: "Because discrimination on the basis of citizenship has the effect of discriminating on the basis of national origin, a lawfully immigrated alien who is domiciled or residing in this country may not be discriminated against on the basis of his citizenship." Except pursuant to national security requirements required by a Federal statute or executive order. At least one Federal court has expressly agreed with this analysis (Guzman v. Polich and Benedict Construction Co., F. Supp., 2 (CCH) EPD par. 10, 156 (C.D. Calif. 1970), and one has disagreed th (Espinoza v. Farah Mfg. Co., F 2d, 4 (CCH) EPD Par. 7835 (5 Cir. 1972). State and Federal courts have recently declared invalid laws in several states, which exclude non-citizens from public employment. In addition, this question asks what country the applicant is a citizen of, thus permitting discrimination on the basis of particular national origin. CONVICTIONS (OTHER THAN FOR TRAFFIC VIOLATIONS)? To the extent that this question implies an absolute bar to the employment of an applicant who has a conviction record, it is probably unlawful. See Carter v. Gallagher, 451 F 2d 315 (8th Circ. 1971). This is because some minority groups in our society have conviction records substantially in excess of the average, taking into consideration their relative numbers and the extent of their "criminal" activity. On the other hand, an employer probably has the right to exclude persons who have been convicted of certain offenses from consideration for certain kinds of jobs, at least if this is done on a carefully considered basis. To avoid frightening off 17 6. 7. 8. 9. 10. 11. qualified applicants, who have irrelevant criminal records, the best practice would be to obtain conviction information through local police departments rather than from applicants. If this is not possible, the application might indicate that the existence of a criminal record does not constitute an automatic bar employment. In addition, each person who will evaluate information concerning criminal records should be given careful instructions as to its limited usefulness. CREDIT RECORD? (CHARGE ACCOUNTS? OWN YOUR OWN HOME? OWN YOUR OWN FURNITURE? OWN A CAR?) Because minority persons are far poorer on the average than whites, consideration of these factors has an adverse effect on minorities and is probably unlawful unless required by considerations of business necessity. See EEOC Decision 72-0427 (1971), CCH Employment Practices Guide par. 6312. The U.S. Department of Labor has also recognized the potential par. 60-2.25(d) (3) of Revised Order No. 4, establishing standards and guidelines for affirmative action programs required of government contractors. EYES? HAIR? Eye color and hair colors are not related to the performance of any job and may serve to indicate an employee's race or religion. FIDELITY BOND EVER REFUSED TO YOU? This question presumably represents an indirect effort to find flaws which may exist in an individual's past. The difficulty with this means, however, is that a fidelity bond may be denied for totally arbitrary and discriminatory reasons, which the individual does not have an adequate opportunity to know of or challenge. Thus this method of ascertaining an individual's past history should be dropped in favor of some other method which is not so likely to be infected with bias. The Maryland Commission on Human Relations has issued an order prohibiting an employer from asking about bond refusals because of the discriminatory impact this kind of question may have. CCH Employment Practices Guide par. 5047. FRIENDS OR RELATIVES WORKING FOR US? This question may reflect for friends or relatives of present employees. Such a preference would be unlawful if it has the effect of reducing employment opportunities for women or minorities. It would have this unlawful effect if present work force differs significantly in its proportion of women or minorities from the population of the area from which workers are recruited. This question may also reflect a rule that only one partner in a marriage can work for the employer. There is a growing recognition that such a rule hurt women far more often than men and that the rule serves no necessary business purpose. GARNISHMENT RECORD? In Johnson v. Pike Corporation of America, 332F. Supp 490 (C.D. Calif. 1971), the court ruled that an employer violated Title VII by discharging a black employee because his wages had been garnished several times. This district court based its conclusion on the reasoning of the Supreme Court's testing ruling, Griggs v. Duke Power Co., 401 U.S. 424 (1971), and on the district court's findings that minorities suffer wage garnishments substantially more often than do whites, and that wage garnishments do not affect a worker's ability to perform his work effectively. HEIGHT? WEIGHT? Some employers have imposed minimum height or weight requirements for employees, which are not related to the job to be performed and which have the effect of excluding above-average percentages of women and members of certain nationality groups. Unless height or weight is directly related to a job requirement these questions should not be asked. 18 12. 13. 14. 15. 16. 17. 18. 19. 20. LOWEST SALARY WILL ACCEPT. Women generally have been related to poorer paying jobs than men, and have been paid less than men for the same work. As a result of this discrimination, a woman might be willing to work for less pay than a man would find acceptable. It is unlawful, however, to pay a woman less than a man would be paid because of community wage patterns which are based on discrimination. See Hodgson v. City Stores, Inc., 332 F. Supp. 942 (M.D. Ala., 1971). MAIDEN NAME? This is not relevant to a person's ability to perform a job and could be used for a discriminatory purpose. For example, a woman's maiden name might be used as an indication of her religion or national origin. This item also constitutes an inquiry into marital status, which is discussed separately. MARITAL STATUS? Some employers have refused to hire a married woman for certain jobs. Most airlines for example refused for many years to permit a married woman to be a flight attendant, though other employees could be married. This practice was held to violate Title VII of the Civil Rights Act of 1964 in Sprogis v. United Airlines, 444 F. 2d 1194 (7th Cir. 1971), and par. 1604.4 (a) of the Commission's Guidelines on Discrimination Because of Sex expresses the same conclusion. It would also violate Title VII for an employer to refuse to hire a married woman or pay a married woman less than a married man for the same work because woman's pay represents a second income while the man's does not. Finally, an employer could not refuse to hire a married woman for any job or for particular jobs because of the employer's beliefs concerning morality or family responsibility. MR., MISS. OR MRS? This is simply another way of asking the applicant's sex and (for women only) marital status, questions discussed elsewhere. Even asking an applicant's first name normally serves no other pre-employment purpose than to indicate the applicant's sex. PRIOR MARRIED NAME? This question asks, in effect, whether an individual has been divorced. By its nature, however, it asks this question only of women because only a woman changes her name on marriage. Thus, the question is discriminatory unless the employer must have the information as a means of identification for purposes of preemployment investigation. SEX? Title VII prohibits discrimination in employment in the basis of sex except in the few instances in which sex may be a "bona fide occupational qualification reasonably necessary to the normal operation" of the employer's business. There are virtually no jobs, which can be performed by only one sex or the other. For this reason it would be desirable to omit any questions asking the applicant's sex from an application form which is intended for general use. SPOUSE'S NAME? To the extent that this question asks for marital status, the comments on marital status apply. A spouse's name may also be used as an indication of religion or national origin. SPOUSE'S WORK? To the extent that this question asks for marital status, the comments on marital status questions apply. In addition, some employers have been reluctant to hire a woman if that would make her the second breadwinner in the family, whereas there is seldom any objection to hiring a man if that would make him the second breadwinner in the family. Such a policy is unlawful under Title VII and other nondiscrimination law. WIDOWED, DIVORCED OR SEPARATED? Recent statistics show that many more black than white persons are widowed, divorced or separated and that a much larger proportion of women than men in the 19 labor force are widowed, divorced or separated. Thus this question has a potential for adversely affecting women and blacks. SOURCE: EEOC I. Selection of Applicants President/CEO Develop and utilize valid, job-related criteria to select qualified applicants for positions within the organization and eliminate or modify those selection devices which adversely affect women, minorities, and handicapped. Provide leadership by using job-related criteria to select applicants for top management positions and by eliminating or modifying selection criteria which adversely affect minorities, women, and handicapped. Establish priority for the development and utilization of job-related selection criteria and gather the necessary resources. Middle Managers Coordinate the evaluation, review, and development of selection criteria with Personnel/EEO officer. Monitor and evaluate the implementation and utilization of job-related selection criteria throughout the organization. Allocate resources for the development of selection criteria in line with goals and priorities established by top management. First Line Supervisors Provide information and input for the development of job-related selection criteria; help identify relevant knowledge, skills, and abilities required for successful performance. Consistently utilize selection criteria to fill vacancies and select applicants on merit factors. Help identify selection criteria which have an adverse impact on minorities, women, and handicapped so they can be modified or eliminated. Consider the need for a diverse work force when making selection decisions. Use race, sex, or handicap as one of a number of job-related selection factors/issues. Do not base selection decisions on a prohibited factor. Personnel Official/EEO Officer Provide staff support and assistance in the development of job-related selection criteria which do not impact adversely on minorities, women, and handicapped. Advise top management and make recommendations on the need to utilize job-related selection criteria to hire an efficient and competent staff. Develop policy guidance to assist first-line supervisors in preparing selection criteria. Monitor and evaluate the utilization of selection criteria; advise top management of needed improvements and changes to conform to the uniform guidelines on employee selection. 20 J. Probationary Period President/CEO Encourage the preparation and implementation programs designed to improve the retention rate of minorities and women completing probationary periods. Develop long-range strategic plans for the preparation of training programs (OJT and/or formal) and performance evaluation systems to develop the potential of minority and female probationary employees. Assemble the necessary resources to develop programs to improve the retention rate of minority and female probationary employees. Middle Managers Develop procedures to implement long-range goals and objectives of top management for the retention of minority and female probationary employees. Coordinate and integrate the development and implementation of probationary programs among the administrative staff, training committee, supervisors, and managers. Allocate sufficient resources to develop and administer probationary programs, which will improve the retention rate of minorities and women. Monitor and evaluate agency efforts to train, evaluate, develop, and retain minority and female probationary employees. First Line Supervisors Provide training when possible (either OJT and/or formal) to minority and female probationary employees to enable them to develop their potentials. Periodically evaluate the performance of minority and female probationary employees to identify strengths and weaknesses to determine where additional training and development may be necessary. Retain and promote probationary employees whose performance so warrants. Consult with Personnel/EEO officer on those probationary employees whose performance is marginal or unacceptable. Separate minority and female probationary employees for unsatisfactory performance only after they have been counseled, trained, and given an opportunity to improve their performance. Personnel Official/EEO Officer Provide guidance for supervisors and managers on how to train and develop probationary employees, so as to improve retention rate. Advise managers and supervisors on how to effectively utilize probationary employees and develop their potential. Provide staff support and assistance to managers and supervisors on counseling, training, evaluating, developing, promoting, or separating probationary employees. Review agency retention rate of minority and female probationary employees to determine any disparity with the rate for non-minorities and men. 21 Advise management on the support and commitment needed to assure that minority and female employees are given every opportunity to develop and perform satisfactorily during their probationary period so they can be retained. K. Career Progression President/CEO Set Authority-wide commitment to the enhancement of career opportunities for minorities and women who will enable them to develop and advance to their full potential. Encourage Personnel programs which will help manage human resources more efficiently, with specific attention given to the developmental needs of minorities, women, and handicapped. Assemble and gather sufficient resources (time, material, equipment, funds, positions, etc.) to fully administer personnel management programs specifically geared to the needs of minorities, women, and handicapped. Set an example and provide leadership by training, developing, and progressing qualified minorities and women through top management positions and using incentive awards to encourage and motivate excellent performance. Middle Managers Implement top management goals and priorities for the development and career advancement of minorities, women, and handicapped. Allocate sufficient resources to develop and implement career development and merit promotion programs which will enhance the career progression of minorities, women, and handicapped. Monitor and evaluate agency efforts to train, develop, and promote minorities, women, and handicapped. Review and monitor disciplinary and adverse actions taken against minorities, women and handicapped to assure consistency and equity; review incentive awards in a similar manner. First Line Supervisors Objectively evaluate the performance of minorities and women against job-related standards with specific regard to their training and developmental needs. Apply performance standards, promotion criteria, incentive awards, and discipline guidelines to minorities and women in a fair and consistent manner. Provide training and career development opportunities for minorities and women when possible. Encourage minorities and women to compete for and participate in training and self-development activities. Promote minorities and women on the basis of merit and job-related promotion criteria. Analyze the promotion pattern of minorities and women to identify any disparities and take necessary steps to correct. Counsel minorities and women on steps they can take to improve their chances for promotion. Give recognition and awards to minorities and women when their performance merits it. 22 Initiate disciplinary or adverse action against minorities and women only after counseling, an opportunity to correct the behavior or improve the performance or other alternatives, which have proven unsuccessful. Consult with Personnel/EEO officer of the poor performance or inappropriate conduct of minorities and women. Personnel Official/EEO Officer Develop policy guidance, plans, and procedures for evaluating performance, providing training and developmental assignments, merit promotion, discipline, adverse actions, and incentive awards with specific regard for minorities and women. Develop upward mobility programs that provide increased career opportunities for employees who are low skilled, disadvantaged, or in dead-end positions. Advise managers and supervisors on personnel management techniques that will improve the career progression of minorities and women in a fair, equitable, and consistent manner. Provide staff support and assistance to managers and supervisors on evaluating the performance of minorities and women using job-related standards. Provide training and developmental assignments to minorities and women based on needs identified during performance appraisal. Promote minorities and women based on merit and job-related promotion criteria applied in a fair and consistent manner; recognizing and rewarding the excellent performance of minorities and women and taking disciplinary action or adverse action against minorities and women only after counseling and other alternatives have proven unsuccessful. Recommend to top management the policy, support, and commitment necessary to assure minorities and women are given every opportunity for career advancement. EEO Complaint Process Will also serve as the Section 504 Complaint Systems EQUAL OPPORTUNITY/AFFIRMATIVE ACTION POLICY Affirmative action shall be taken to ensure equal employment opportunity in the Authority. Discrimination against any person in recruitment , examination, appointment, training, promotion, discipline, or any other aspect of personnel administration or membership in employee organizations because of race, clor, religion, age, sex, national origin, marital status, or other non-merit factors is prohibited. 14. EEO COMPLAINT PROCESS Will also serve as the Section 504 Complaint System A. This subsection presents the Authority's procedures for processing complaints of discrimination based on race, color, religion, sex, handicap, or national origin. The steps for processing a complaint are outlined below. 1. EMPLOYEE contacts Housing Authority EEO Officer/Counselor within 30 calendar days of alleged discriminatory action. COUNSELOR has 21 days to attempt informal resolution. If final counseling interview is not completed in 21 days, COUNSELOR must on 21st day give written notice of right to file complaint any time up to 15 calendar days after final 23 2. 3. 4. 5. 6. interview. If informal resolution fails, EMPLOYEE may file formal complaint with PRESIDENT/CEO within 15 calendar days of final interview with COUNSELOR. PRESIDENT/CEO assigns INVESTIGATOR from jurisdiction of PHA other than that in which complaint arose. Investigation conducted; COMPLAINANT given copy of investigative file. PRESIDENT/CEO provides opportunity for informal adjustment. If adjustment not made, PRESIDENT/CEO notifies COMPLAINANT in writing (1) proposed disposition, (2) right to hearing and decision by PHA BOARD without a hearing. If COMPLAINANT does not reply within 15 calendar days, the PRESIDENT/CEO may adopt proposed disposition as decision of the PHA, providing he has been delegated this authority. Upon receipt of decision, the EMPLOYEE may appeal the decision or any final decision within 15 days to PHA BOARD or may file a civil action in an appropriate U.S. District Court within 15 days. NOTE: COMPLAINANT has right to file civil action in an appropriate U.S. District Court: a. Within 30 calendar days of his receipt of notice of final agency action on complaint. b. After 180 calendar days from date of filing a complaint with PHA if there has been no decision. Filing of a civil action does not end PHA processing of a complaint. 24 DRUG FREE WORKPLACE A. Testing Procedures for All Employees All tests shall be conducted in accordance with Authority guidelines to insure accuracy and proper concern for applicant and employee's privacy. These guidelines shall generally provide: a. b. b.c. The employee or applicant shall be allowed to provide samples in the privacy of a restroom stall or the equivalent (unless tampering with or substitution of the sample is suspected); All positive tests will be confirmed by a second methodology; and A secure chain of custody will be maintained for all samples. In the case of any employee or applicant whose test reveals the positive and confirmed presence of drugs, the employee/applicant shall be offered the opportunity for a second test to be performed in the same manner as the original test with the original sample provided. The Authority will arrange a second test using the same sample, upon request; however, should the second test reveal the positive presence of drugs, the employee/applicant requesting re-testing shall be responsible for payment of the cost of the second test. The cost of a second test, which does not reveal the presence of drugs, will be borne by the Authority. Any request for a second test must be made within twenty-four hours of an employee/applicant's notification of positive test results; and the second test will be performed as quickly as possible, thereafter. 25 Changes to the Public Housing Lease Revisions Public Housing Lease Revisions (w) Resident will not allow ex-resident of the WHA who have been evicted to occupy the unit for any period of time. (w) Ability to comply with Lease terms if during the term of this Lease, resident by any reason of physical or mental impairment is no longer able to comply with the material provision of the lease, and cannot make arrangements for someone to aid him/her in complying with the lease THEN: The Authority will assist. Resident, or designated member(s) of Resident’s family, to find more suitable housing and move resident from the dwelling unit. * Entry is for: Responding to your request; repairs; estimation repair or refurbishing cost; pest control; preventive maintenance; filter changes; testing or replacing smoke-detector batteries; retrieving left tools; leaving notices; delivering, installing, reconnecting, or replacing appliances and equipment; removing or re-keying unauthorized locks; inspections or when immediate danger to person or property is reasonably suspected; entry by a law enforcement officer with search or arrest warrant or in hot pursuit; or exigent circumstances; (a) protection of life, (first aid, extracting children who appear in danger, protecting an undercover officer of informer,; or making a protective sweep (b) protection of property (such as extinguishing a fire or stopping a burglary) (c) preventing destruction of evidence and (d) pursuing a fleeing felon (hot pursuit); or showing apartment to government inspectors, fire marshals or insurance agents. 1 Revised April 2014April 2015 Tenant Initial___________ Management Initial________ PROCUREMENT POLICY This Procurement Policy complies with HUD's Annual Contributions Contract (ACC), HUD Handbook 7460.8, "Procurement Handbook for Public Housing Agencies," and the procurement standards of 24 CFR 85.36. MANDATORY CONTRACTS A grantee's and subgrantee's contracts must contain provisions in paragraph as set forth below. Federal agencies are permitted to require changes, remedies, changed conditions, access and records retention, suspension of work, and other clauses approved by the Office of Federal Procurement Policy. A. Administrative, contractual, or legal remedies in instances where contractors violate or breach contract terms, and provide for such sanctions and penalties as may be appropriate. (Contracts more than the simplified acquisition threshold) B. Termination for cause and for convenience by the grantee or subgrantee including the manner by which it will be effected and the basis for settlement. (All contracts in excess of $10,000) C. Compliance with Executive Order 11246 of September 24, 1965, entitled "Equal Employment Opportunity", as amended by Executive Order 11375 of October 13, 1967, and as supplemented in Department of Labor regulations (41 CFR chapter 60). (All construction contracts awarded in excess of $10,000 by grantees and their contractors or subgrantees) D. Compliance with the Copeland "Anti-Kickback" Act (18 U.S.C. 874) as supplemented in Department of Labor regulations (29 CFR part 3). (All contracts and subgrants for construction or repair) E. Compliance with the Davis-Bacon Act (40 U.S.C. 276a to 276a-7) as supplemented by Department of Labor regulations (29 CFR part 5). (Construction contracts in excess of $2000 awarded by grantees and subgrantees when required by Federal grant program legislation) F. Compliance with Sections 103 and 107 of the Contract Work Hours and Safety Standards Act (40 U.S.C. example 327 330) as supplemented by Department of Labor regulations (29 CFR part 5). (Construction contracts awarded by grantees and subgrantees in excess of $2000, and in excess of $2500 for other contracts which involve the employment of mechanics or laborers) 1 1.0 G. Notice of awarding agency requirements and regulations pertaining to reporting. H. Notice of awarding agency requirements and regulations pertaining to patent rights with respect to any discovery or invention which arises or is developed in the course of or under such contract. I. Awarding agency requirements and regulations pertaining to copyrights and rights in data. J. Access by the grantee, the subgrantee, the Federal grantor agency, the Comptroller General of the United States, or any of their duly authorized representatives to any books, documents, papers, and records of the contractor which are directly pertinent to that specific contract for the purpose of making audit, examination, excerpts, and transcriptions. K. Retention of all required records for three years after grantees or subgrantees make final payments and all other pending matters are closed. L. Compliance with all applicable standards, orders, or requirements issued under Executive Order 11738. (Contracts, subcontracts, and subgrants of amounts in excess of $100,000). M. Mandatory standards and policies relating to energy efficiency which are contained in the state energy conservation plan issued in compliance with the Energy Policy and Conservation Act (Pub. L. 94 - 163, 89 Stat. 871). SPECIFICATION STATEMENT/ STATEMENT OF WORK (SOW) Specifications (24 CFR 85.36(c)(1)(i)) A. Definition. A specification is a detailed description of materials, supplies, equipment, pre-cuts, or construction work that is used in the procurement process to tell prospective contractors precisely what the Public Housing Authority (PHA) desires to purchase. (A statement or scope of work is a unique type of specification generally used for the procurement of professional or management services, as discussed in paragraph 1.11.) B. Specification Types. Three general types of specifications are used in preparing contracts for equipment, supplies, or construction – functional or performance specifications, design specifications, and brand name or equal specifications. While these general types are described below, it is rare to find specifications that fit completely into just one of the above categories. Most specifications contain a combination of design and performance requirements and may, include brand name or equal descriptions of components. 2 1. Functional or Performance Specifications. These specifications contain performance characteristics that are desired for the item or that identify how the item functions. The detailed design or exact measurements are not stated. A functional or performance specification is inherently risky. Performance specifications state the overall requirements so that each contractor may furnish its own item to meet the required performance. For example, a new boiler specification can simply call for a gas-fired hot water boiler that will produce 100,000 British Thermal Units (BTU) per hour. It is easy to imagine a gas-fired boiler that can produce 100,000 BTUs per hour but may also require continuous and costly maintenance. 2. Design Specifications. Design specifications contain a description of the item desired as opposed to performance standards. Design specifications may be as detailed as needed. Depending on the nature of the item, the design specifications may contain precise measurements, tolerances, materials, product tests, quality control, and other detailed information, provided competition is not being limited to one product. The information furnished in the specification should be sufficiently detailed to ensure that all items manufactured to the specifications will be virtually the same. A detailed description of kitchen cabinets, giving dimensions, fastening details, materials, and hardware, is one example of this type of specification. 3. Brand Name or Equal Specifications (24 CFR 85.36(c)(1)(vi)). Under this form of specification, clear and accurate product descriptions are developed. These descriptions shall not contain features that unduly restrict competition. It may be necessary to describe technical requirements for materials and equipment by referencing brand name products in order to define performance or other salient requirements. References to brand names shall be followed by the words “or equal” and a description of the item’s essential characteristics so that competition is not restricted. Specific brand names may be used only for establishing design and quality standards and only if there is no other reasonable method of designating the required quality of the item desired. When brand names or catalog numbers are used, inform the offerors that such references establish only design or quality standard; in fact, any other products that clearly and demonstrably meet the standard are also acceptable. C. Standardizing Inventory. Many PHAs, for efficiency, standardize their inventory of equipment and parts. As stated above, PHAs must comply with procurement standards that requires full and open competition and prohibits using specifications that unduly restrict competition. To standardize the PHA’s inventory, specifications or descriptions that use brand names may be used only when accompanied by the term “or equal.” The specific features of the product (design, functional, or performance) that are essential in order to be considered “or equal” shall be clearly stated. In addition to the brand name product specified, any other product that meets the same technical requirements shall be given full and fair consideration. In all cases, the PHA should give all offerors the opportunity to present reasons or data showing that their product can meet the stated requirements. Descriptions or specifications shall not be written so as to specify a particular product or feature of a product particular to one manufacturer unless that feature or product is critical to the intended use. 3 D. Avoiding Manufacturers Specifications. PHAs should avoid incorporating a particular manufacturer’s specification as the project specification. This may give the appearance of restricting competition and suggest that other manufacturers’ products are at a disadvantage and may not be accepted. If the PHA specifies a brand name cabinet, the essential key elements or features of the product should be stated. For example, if specifying kitchen cabinets with the key features of solid wood doors and plywood frames, then many available brands and styles of cabinets will meet the key criteria. Therefore, all of these brands should be acceptable. E. Contractor-Developed Specifications. In order to ensure objective contractor performance and eliminate unfair competitive advantage, contractors funded to develop or draft specifications, requirements, statements of work, invitations for bid, or requests for proposals shall be excluded from competing in the procurement. The only exception to this rule is if, prior to the solicitation, all respondents to solicitations are provided with materials and information made available to the contractor involved in matters pertinent to the solicitation. 2.0 PROCUREMENT METHODS For purchases of items costing $25.00 or less, the Authority authorizes the use of Petty Cash funds. When Petty Cash or charge accounts are used, the person picking up or accepting delivery must obtain a receipt or invoice for goods received, showing full details for the need of the purchase and signed by the recipient. The purchase should also indicate the development or program to be charged, for proper accounting purposes. A. A Petty Cash fund of $200.00 is established at the Authority’s Central Office. The Vice President of Financial Services is responsible for administrating and reconciling the petty cash fund and submitting a voucher to reimburse the fund for receipts. B. 1. Each purchase order and invoice must clearly identify an item name or description Part, item or model number only, will not be accepted. Properly approved and executed purchases orders are to be forwarded to the Finance Office for budgetary approval. Copies shall be maintained in the finance office to accompany invoices packing slips, receiving tickets and other corresponding documentation, for proper payment. 2. All purchases in excess of $25.00 shall be made on the basis of appropriately issued purchase orders as follows: A. For amounts up to $1,000, a purchase order must be signed by the department head. B. For purchases from $1,000 to $1,500, a purchase order must be signed by a Vice President. 4 C For amounts in excess of $1,500 a purchase order by the President/CEO or designee must be signed For purchases greater than $1,500, but less than $5,000, at least three bids and/or quotations shall be informally obtained by the authorized purchaser. (by the authorized purchaser see 2.A above). A list of all vendors solicited and their written quote shall be attached to the purchase order. D. For purchases greater than $5,000.00 but less than $15,000.00 written quotations shall be obtained by the authorized purchaser (see 2C above). A list of all vendors solicited and their written quote shall be attached to the purchase order. E. For purchases in excess of $15, 000, public bidding requirements shall be utilized. Notice shall be published, at least 15 days before the date set for receiving bids (IFB) or request for proposals (RFP), in a newspaper of general circulation in the district. For IFB or RFP, bids shall be opened with at least one witness and a bid sheet shall be used to show all bids received with complete information on the bidder. Original bid information, including bid specifications, tabulations, and name of person(s) opening bids shall be maintained in the Finance Office. The Authority reserves the right to require bidding for purchases of less than $15,000, if it would be to the Authority’s interest. F. For purchases where a quotation came from the State Purchasing and General Services Commission, the requirements for three (3) written quotes shall be waived, however, the authorized purchaser shall certify that the price is fair and reasonable, based upon local practice. G. If three (3) quotations cannot be readily obtained by the Authority from qualified bidders, additional quotations shall be solicited as follows: 1. Written or informal quotes shall be solicited from at least three (3) vendors capable of performing in accordance with Waco Housing Authority & Affiliates specifications. 2. Where no response has been given by a WHA imposed deadline, telephone communication shall be made with the vendors to determine the reason for non-submission of a quote. 5 3. When the purchase order is forwarded for final approval, the reason in any cases where three (3) vendors have not responded shall be attached. H. If the foregoing procedures have been followed and the result is still less than three (3) quotations and/or bids, the Contracting Officer (President/CEO) shall determine whether to proceed with the award to the lowest bidder. Or to re-bid for the purpose of obtaining at least three (3) quotations and/or bids. I. The Authority shall require strict adherence to the procedures outlined above. Any or all of the above requirements may be waived by the President/CEO in the case of bona fide emergencies and in conformance with relevant State statutes. Such waiver and all purchases made pursuant thereto shall be ratified by the Board of Commissioners at their first meeting subsequent to the occurrence of the emergency. J. This section does not apply to purchase of property from public agencies or to contracts for personal or professional services. 2.1 COST AND PRICE ANALYSIS A. General - Some form of cost or price analysis shall be performed for all procurement actions, including contract modifications, using the procedures described in HUD Handbook 2210.18. The method of analysis shall be determined as follows. The degree of analysis shall depend on the facts surrounding each procurement. B. Submission of Cost or Pricing Information - If the procurement is based on noncompetitive proposals, or when only one offer is received, or for other procurements as deemed necessary by the Authority (e.g., when contracting for professional, consulting, or architect/engineer services) the offeror shall be required to submit: C. 1. A cost breakdown showing projected costs and profit; 2. Commercial pricing and sales information, sufficient to enable the Authority to verify the reasonableness of the proposed price as a catalog or market price of a commercial product sold in substantial quantities to the general public; or 3. Documentation showing that the offered price is set by law or regulation. Cost Analysis - Cost analysis shall be performed if an offeror/contractor is required to submit a cost breakdown as part of its proposal. When a cost 6 breakdown is submitted a cost analysis shall be performed of the individual cost elements, the Authority shall have a right to audit the contractor's books and records pertinent to such costs, and profit shall be analyzed separately. Costs shall be allowable only to the extent that they are consistent with applicable Federal cost principles (for commercial firms, Subpart 31.2 of the Federal Acquisition Regulation, 48 CFR Chapter 1). In establishing profit, the Authority shall consider factors such as the complexity and risk of the work involved, the contractor's investment and productivity, the amount of subcontracting, the quality of past performance, and industry profit rates in the area for similar work. D. Price Analysis - For competitive procurements in which cost or pricing information is not required of contractors, the Authority shall perform a comparison of prices received in relation to the independent cost estimate, to ensure that the price being paid is reasonable. E. Bonding requirements. For construction or facility improvement contracts or subcontracts exceeding the simplified acquisition threshold, the Authority may accept the bonding policy and requirements of the contractor or sub contractor provided the Authority has made a determination that the Authority’s interest is adequately protected. If such a determination has not been made, the minimum requirements shall be as follows: (1) A bid guarantee from each bidder equivalent to five percent of the bid price. The bid guarantee shall consist of a firm commitment such as a bid bond, certified check, or other negotiable instrument accompanying a bid as assurance that the bidder will, upon acceptance of his bid, execute such contractual documents as may be required within the time specified. (2) A performance bond on the part of the contractor for 100 percent of the contract price. A performance bond is one executed in connection with a contract to secure fulfillment of all the contractor's obligations under such contract. (3) A payment bond on the part of the contractor for 100 percent of the contract price. A payment bond is one executed in connection with a contract to assure payment as required by law of all persons supplying labor and material in the execution of the work provided for in the contract. 2.2 PROHIBITED CONTRACT TYPES In accordance with 24 CFR 85.36(f)(4), the use of the following types of contracts is prohibited: 7 A.. Cost-plus-percentage-of-cost. This type of contract is prohibited because it obligates the PHA to pay all costs incurred throughout the contract, plus a commission based on the percentage of future costs. In this type of pricing arrangement, the contractor’s profit increases in proportion to its costs incurred in the performance of the contract. The contractor has a clear incentive to increase costs. B. Cost-plus-percentage-of-construction-cost. The cost for individual construction-related services is determined by applying a percentage of actual construction costs as a fee, such as an A/E contract in which the fee is determined based on the total construction cost. Such an arrangement allows the possibility of the contractor designing an overly expensive construction project in order to increase profits. 2.3 CONTRACT ADMINIISTRATION A. The Authority will use their own procurement procedures which reflect applicable State and local laws and regulations, provided that the procurements conform to applicable Federal law and the standards identified in this section. B. The Authority will maintain a contract administration system which ensures that contractors perform in accordance with the terms, conditions, and specifications of their contracts or purchase orders. C. The Authority will maintain a written code of standards of conduct governing the performance of their employees engaged in the award and administration of contracts. No employee, officer or agent of Authority shall participate in selection, or in the award or administration of a contract supported by Federal funds if a conflict of interest, real or apparent, would be involved. Such a conflict would arise when: 1. The employee, officer or agent, 2. Any member of his immediate family, 3. His or her partner, or 4. An organization which employs, or is about to employ, any of the above, has a financial or other interest in the firm selected for award. The Authority officers, employees or agents will neither solicit nor accept gratuities, favors or anything of monetary value from contractors, potential contractors, or parties to subagreements. The Authority may set minimum rules where the financial interest is not substantial or the gift is an unsolicited item of nominal intrinsic value. To the extent permitted by 8 State or local law or regulations, such standards or conduct will provide for penalties, sanctions, or other disciplinary actions for violations of such standards by the Authority’s officers, employees, or agents, or by contractors or their agents. The Authority may in regulation provide additional prohibitions relative to real, apparent, or potential conflicts of interest. D. The authority procedures will provide for a review of proposed procurements to avoid purchase of unnecessary or duplicative items. Consideration should be given to consolidating or breaking out procurements to obtain a more economical purchase. Where appropriate, an analysis will be made of lease versus purchase alternatives, and any other appropriate analysis to determine the most economical approach. E. To foster greater economy and efficiency, the Authority is encouraged to enter into State and local intergovernmental agreements for procurement or use of common goods and services. F. The authority is encouraged to use Federal excess and surplus property in lieu of purchasing new equipment and property whenever such use is feasible and reduces project costs. G. The Authority is encouraged to use value engineering clauses in contracts for construction projects of sufficient size to offer reasonable opportunities for cost reductions. Value engineering is a systematic and creative analysis of each contract item or task to ensure that its essential function is provided at the overall lower cost. H. The Authority will make awards only to responsible contractors possessing the ability to perform successfully under the terms and conditions of a proposed procurement. Consideration will be given to such matters as contractor integrity, compliance with public policy, record of past performance, and financial and technical resources. I. The Authority will maintain records sufficient to detail the significant history of a procurement. These records will include, but are not necessarily limited to the following: rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. J. The Authority will use time and material type contracts only 1. After a determination that no other contract is suitable, and 9 2. If the contract includes a ceiling price that the contractor exceeds at its own risk. K. The Authority alone will be responsible, in accordance with good administrative practice and sound business judgment, for the settlement of all contractual and administrative issues arising out of procurements. These issues include, but are not limited to source evaluation, protests, disputes, and claims. These standards do not relieve the Authority of any contractual responsibilities under its contracts. Federal agencies will not substitute their judgment for that of the Authority unless the matter is primarily a Federal concern. Violations of law will be referred to the local, State, or Federal authority having proper jurisdiction. L. The authority will have protest procedures to handle and resolve disputes relating to their procurements and shall in all instances disclose information regarding the protest to the awarding agency. A protestor must exhaust all administrative remedies with the authority before pursuing a protest with the Federal agency. Reviews of protests by the Federal agency will be limited to: 1. Violations of Federal law or regulations and the standards of this section (violations of State or local law will be under the jurisdiction of State or local authorities) and 2. Violations of the Authority’s protest procedures for failure to review a complaint or protest. Protests received by the Federal agency other than those specified above will be referred to the grantee or subgrantee. 10 Resident Council Advisory Meeting April 8, 2015 2:00 p.m. AGENDA I. Welcome II. Update on Modernization Projects III. Changes to the Admin Plan IV. Changes to ACOP & Lease V. Changes to Maintenance Plan VI. Update on Family Self Sufficiency Action Plan VII. Comments Resident Council Advisory Meeting April 8, 2015 2:00 p.m. Synopsis of the Minutes I. Welcome Vice President/COO Milet Hopping welcomed the group to the meeting. Those in attendance were: Milet Hopping – VP/COO Annie Botsford – VP of Administrative Services Ellona Rodgers – Modernization Coordinator Ninfa Garcia – Section 8 Administration Coordinator Gloria Dancer. – Director of Housing Operations Earnest Ward – Resident Services Coordinator Mary Helen Gonzalez – Kate Ross Stella Hernandez – Section 8 Ruby Bridgewater – South Terrace Michael Mack – Estella Maxey Regina Robbins – Kate Ross Tonia Jackson – Kate Ross Angela Wilson – Section 8 II. Update on Modernization Projects Ellona Rodgers gave the group an update on all the modernization projects that have been completed in the last year and the projects that are being planned for the coming year. Milet Hopping explained to the group about the capital funds that are used to fund these projects and the process WHA goes through to determine which projects will be done. III. Changes to the Admin Plan Ninfa Garcia went over all the proposed changes to the Section 8 Administrative Plan and the reasons for the changes. There were no questions concerning these changes. (Copies of the changes attached) IV. Changes to ACOP & Lease Gloria Dance went over all the proposed changes to the Public Housing ACOP and lease and the reasons for these changes. There were no questions concerning these changes. (Copies of the changes attached) V. Changes to Maintenance Plan Gloria Dancer explained the changes to the Maintenance Plan. There were no questions concerning these changes. (Copies of the changes attached) VI. Update on Family Self Sufficiency Action Plan Milet Hopping explained to the group that since this years Annual Plan is actually a five year action plan, the agency is updating many of the policies and procedures that we use. The Family Self Sufficiency Action Plan had not been updated in a number of years so WHA took the opportunity to update it at this time. There were really no changes made as to how our program operates, we just updated the original action plan. VII. Comments There were no additional comments.