Compliance Services and Evaluations
Section 3 Compliance is a sub-set of the discipline of program evaluation. Where traditional program evaluations ask the question “Did this program accomplish the goals that were established in the original funding of the program?” Section 3 compliance evaluations ask a different question. “Was the program implemented in accordance with HUD’s Section 3 participation requirements?” In the parlance of professional evaluation practice, the assessment of Section 3 compliance is one of process rather than impact on the overall project goals.
Solutient is a leading practitioner of both program evaluations and Section 3 compliance evaluations.
Section 3 Compliance Program Design, for DASNY and the State of NY
In 2013, as a sub-contractor to LiRo on a Long Island engagement, Mr. Robinson’s team provided for DASNY Section 3 programming that included a process map for compliance, management, reporting and budgeting. As a result of this work DASNY issued a second task order.
Manage Xactimate Training
Based on the research product and recommendations submitted by Mr. Robinson and his team, DASNY issued a second task order related to employee training of HUD eligible persons for the position of claims assessor. (2013.)
America Works is a private workface development firm that specializes in matching jobs with persons at risk. Beginning in 2006 American Works established collaboration with HUD and its Section 3 division. As a founding member, Mr. Robinson was instrumental in the development of Section 3 programs in dozens of cities around the United States during the period 2006-2009.
Section 3 and Claims Subject Matter Expert
The Louisiana Community Development Cap Fund was selected by the State of Louisiana in 2009 under a sub-contract with ACS to provide expert Section 3 consultation to ACS in the development of its housing recovery contracts with the State. The ACS contract was canceled in 2010 but the Cap Fund was retained. The resulting Section 3 program was the first statewide application of Section 3 in the United States. Mr. Robinson headed up this effort for the Louisiana Cap Fund.
Louisiana Small Rental Property Program (SRPP)
Mr. Robinson’s team, operating as a unit of the Louisiana Cap Fund, was retained in 2010 by the State of Louisiana under a sub-contract agreement with the Shaw Group, to develop a set of policies consistent with CDBG-DR and FEMA regulations regarding compliance with all federal regulations. Specific emphasis was placed on the implementation of Section 3 regulations and procedures.
The design of Section 3 programs for Kiewit Construction,
In 2012 Kiewit Construction sought out Mr. Robinson to develop Section 3 compliance procedures for its federal government construction projects. Kiewit is the third largest construction firm in the United States.
Collaborative work with HUD to remediate failures in New Jersey’s Section 3 programming,
Mr. Robinson, in conjunction with New Jersey and national organizations in 2013 brought suit against the State of New Jersey in its failure to implement Section 3 programming in its disaster recovery programs stemming from hurricanes Irene and Sandy. Subsequently the State submitted to a consent decree in which it agreed to incorporate Section 3 compliance enforcement.
Solutient designated as a Section 3 firm under category 4, in November 2014
The Buffalo Municipal Housing Authority (BMHA) approved Solutient as a Section 3 firm for the purpose of qualifying to assist the Authority in a broad range of Section 3 planning, compliance enforcement, and management assistance. Dr. Sternhell and Mr’ Robinson collaborated on this project.
The Convergence of CD-DR and FEMA
Solutient has been contracted on multiple occasions by multiple agencies, including DASNY, to review process controls of participating organizations. In other instances Solutient has been requested to provide organizational processes consistent with CDBG-DR, Section 3, and FEMA regulations.
For the State of Louisiana Mr. Robinson and his team were retained to review Katrina/Rita disaster recovery practices pertaining to Section 3 compliance. He and his team were re-hired, after the prime was terminated, to continue the development of these policies and practices. This work required the review of federal regulations and the cross/step comparisons to the practices and internal controls that had been put in place under the Louisiana Recovery Authority (LRA). When the State practices were found to be inadequate to meet federal guidelines he and his team were instructed to recommend comprehensive Section 3 compliance processes. (2009-2012)
A second example of this work was the collaboration with HUD to examine the organizational decision making of the State of New Jersey relative to their implementation of Section 3 compliance procedures and enforcement stemming from HUD disaster recovery funding released after hurricanes Irene and Sandy. The effectiveness of the effort was evidenced by the State coming to agreement with HUD on a consent decree in 2013. The focus of this work was the review of processes and procedures used by the State of New Jersey in their efforts to fulfill the Section 3 compliance responsibilities. In 2014, in large part a result of the consent decree, the State of New Jersey issued an RFP for a contractor to implement a Section 3 compliance program.
Assembling data for the compilation of HUD 60002 reports involves each and all of the record reviews listed above. Solutient Section 3 subject matter experts have performed all of these functions in in the compilation of data included in the delivery of HUD 60002 forms. Since the beginning of its Section 3 practice we have compiled and delivered over a dozen of these reports. In two separate cases, as reported elsewhere in this response, we have provided a methodology and a final report for the analysis of a previous year in which a report had not been compiled. In both cases the reports were accepted by HUD. As important as was the acceptability of a long overdue report, the provision of a methodology to apply to former years proved to be equally valuable.