Neighborhood Stabilization Program

1
Neighborhood Stabilization Program

• Selected Compliance Topics

2
AGENDA

• Environmental Review
• Programmatic Agreement
• Procurement
• Administrators
• Sub Recipients
• Prohibited Conflict of Interest
• Exceptions
• Fraud and Abuse

3
Environmental Review

• Rule 24 CFR Part 58
• Submit RROF to DCA
• Do Not Commit Funds Until DCA sends Release of
  Funds letter

4
Environmental Review

• Tiering (24 CFR Part 58.15)
• Appropriate for Categorical Exclusions Subject to
  58.5 Such as housing rehabilitation
• Other laws still apply
• Complete Statutory Checklist
• As much as possible
• Publish NOIRROF
• Submit RROF to DCA
• Include Categorical Exclusion form
• Statutory Checklist form
• Copy of Public Notice

5
Environmental Review

• As sites are identified Complete Site Specific
  Environmental Screen Form for each home
• Environmental Review Record

6
Programmatic Agreement

• Compliance is a General Condition of each NSP
  Award
• Applicable to rehab of Homes over 50 years old
• The R.E. can cite their compliance with the P.A.
  as evidence of Section 106 compliance on the
  Statutory Checklist as part of the Tiered
  environmental review process

7
Programmatic Agreement

• Document the age of every home in the ERR
• For homes less than 50 year old no further
  compliance is required.

8
Programmatic Agreement

• For home more than 50 years old
• Purchase and Resale only No additional
  compliance is required
• Rehabilitation Determine if work falls within
  scope of exempt rehabilitation activities.

9
Programmatic Agreement

• If work is not exempt Using a Qualified
  Historic Preservation Professional determine the
  effect of the activity.
• If work meets the Historic Preservation
  Rehabilitation Standards contained in the P.A.
  the grantee can make a determination of No
  Adverse Effect document the Site Screening record
  for every home and proceed.
• If the proposed work does not meet these
  standards, as determined in consultation with the
  Qualified Historic Preservation Professional,
  there will be an Adverse Effect and DNR/HP must
  be consulted to agree on mitigation, before the
  activity can proceed.

10
Procurement

• Requirement for Competition
• Competitive Negotiation
• Solicit for a Number of Sources
• Publicize
• State evaluation factors in Solicitation and Ad
• If only one bid is received must receive sole
  source approval from DCA

11
Avoid Conflict of Interest

• Prohibited COI (See page 7 of Manual)
• No covered person may receive a financial or
  other benefit, or be a party to any contract
• Covered persons
• Elected Officials
• Staff with a decision making position or in a
  position to have inside information
• Sub Recipient Board members

12
Conflict of Interest

• DCA can grant an exception, not a waiver
• To Request an Exception
• COI must be Publically Disclosed
• Person Must Abstain
• Written local legal Opinion
• Prior to Action being taken and approved