Monitoring Section 3 Compliance

The Capital Fund Coordinator will monitor the contractor's and subcontractor's outreach and hiring practices and gauge them against Schedule A - Workforce and Hiring Projection; the negotiated resident hiring provisions of the contact; and the finalized Section 3 Opportunities Plan. The Capital Fund Coordinator, in conjunction with the general contractor, will review the subcontracts to determine the dollar value awarded to Section 3 concerns.

All contracts will be evaluated at closing for compliance with the Section 3 program. The contractor's compliance with the program may be used to determine contractor responsibility and bid responsiveness on future contracting opportunities with the Housing Authority of the City of Columbia.

The contractor will provide the following reports to facilitate monitoring Section 3 hiring and contracting activity, compliance with Davis-Bacon Wage Rate requirements and the provision of economic opportunities for women and minorities.

• Report on interview and evaluation of each HSHA resident referred by the HSHA that is not hired, with a written copy to the Section 3 Coordinator when the decision is made and the resident notified.
• A biweekly certified list of all new hires for each contractor and subcontractor will be submitted with payroll. The certified lists will include: name, address, trade, section category, gender and ethnic group or race, date hired, indication of how contact was made (HSHA referral, walk-in, resident council referral, etc.)
• A biweekly certified payroll for each contractor and subcontractor. The certified payroll will indicate: trade and status (i.e., apprentice, journeyman, master, foreman, superintendent, etc.), wage rate and hours worked each day, whether claimed as Section 3 employee, name and address of each employee.
• A copy of each subcontract when executed, with cover sheet indicating dollar value of contract and gender and race or ethnicity of 51% owner and whether or not the business is a certified Section 3 business.

The contractor will submit the above to the Capital Fund Coordinator, who will maintain a checklist of items received. If it is determined that required monthly submissions are not complete, s/he will withhold approval of payment of the monthly draw.

During the duration of a contract, each month the Capital Fund Coordinator will interview a sampling of the residents hired to meet Section 3 goals, including those residents who were referred, but were not hired and those residents who resigned, were terminated or laid off. These interviews, along with the employment interview reports provided by the contractor, will be included in the Section 3 compliance file and in the resident's career file at the corresponding referring office. The interviews will be structured to determine the training needs of the resident, job site problems that could be resolved to make employment more productive for other employees and compliance with basic work place policies.

The Capital Fund Coordinator, working in conjunction with contractor(s) and the various Resident Services programs, will assure that Section 3 employees receive regular evaluations of their work and fair, appropriate disciplinary treatment as follows:

Performance Evaluation: The contractor will conduct an evaluation meeting with HSHA new employees every other month to acknowledge good performance and to discuss areas for improvement. A written evaluation will be provided to the employee and the appropriate HSHA department, signed by the superintendent or project manager and the employee. If an employee is laid off or terminated, an exit interview will be conducted.

Disciplinary Actions: The contractor will notify HSHA in writing of any disciplinary action involving a Section 3 employee.

The Section 3 Opportunity Plan, which is required to be prepared by the contractor and included in its final negotiated form in the contract documents, will have a projected monthly hiring schedule. Compliance with the plan will be determined at the end of the contact prior to substantial completion. At that time, the Capital Fund Coordinator will evaluate resident hiring and retention and Section 3 business subcontracting.

Reporting Requirements

The Capital Fund Coordinator will be responsible for preparing the annual report to HUD on Economic Opportunities for Low-Income Persons in conjunction with Assisted Projects, (Form HUD 60002), by January 10th of each fiscal year.