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HomeMy WebLinkAboutExhibit 16XIV Monitoring Outcome -based Community Development The Community Development Director, Assistant Director and Program Managers oversee the planning process and budgeting process to ensure that projects are developed consistent with grant requirements. This planning process also ensures that each funded project is consistent with the Consolidated Plan and makes progress toward identified community development objectives, forementioned staff members make certain that projects are being completed in a timely manner a at expenditure deadlines for various grants are being met. CDBG- Sub -recipient Contracts For sub -recipient contracts, the Contract Complian the contract analyst engages in contract negotiat needs identified in the Consolidated Plan. This proc HUD guidelines. Then, the plan is reviewed by the pro exercised and that the plan coincides with program direct contract consistent with applicable la .d guiding princip Upon, the Law Department endorsing th program operations. The agency will then Department. The Fiscal Assistants will pro eligibility, compliance,,.,.sonableness been processed by in =Y . i, - partment, it The Contract secure that the work forthcom adm'�'r, be bast out an and reimb outreach is b-recipie ial, ce per yea ency with sign e future. All re ifying the be ent repo • g in 0 e Anal ied ernal con rwar s pa executi 'tu scope o iven to th nalysts approves the scd nsistent ' .'th HUD regulati '11 ens i ompliance with age ho makes stlfe conformity is inally, the City Law Department prepares a on o res for service. As a result, with the priority licable laws and es the agency will commence mbursement to the Fiscal w the information rendered for ice. Once a payment reimbursement has ssistant Director for final approval. also administe p,Iementation of the funded request for proposal, to cordance the guidelines stipulated in the contract. The red at a minimum of once per year for compliance with idelines. The targeted goal for compliance monitoring will t findi on such a monitoring will be typically monitored, on a more frequent ent a: ncies must provide periodic reports which describe the activities carried iciaries for the project. Moreover, the agencies must also submit performance n a monthly basis. These reports help to identify and ensure that minority formity with HUD's program objectives. HOME- Contract Execution Pre -requisite For projects carried out with the use of HOME funds Contract Compliance Analysts are assigned to monitor the progress of each project and submit invoices for payment. All payment requests for HOME construction projects will be cleared and verified by City of Miami Inspectors. The inspectors will assume responsibility for inspecting construction projects prior to authorization of payment. Payments for reimbursement are reviewed and approved by the Fiscal Assistants, whom obtain the final approval from the Finance Assistant Director. This operation protocol preserves a checks and balance system that minimizes overpayment and promotes sound fiscal management practices. In addition, the Contract Analyst assures that all prerequisites have been finalized, as it concerns environmental reviews, Section 3 compliance, and Davis -Bacon monitoring in an attempt to coincide with Federal Regulations. 2006-2007 Action Plan 76 Consequently, all pertinent documentation will be in accordance with Federal Mandates prior to submission for reimbursement and payment. The Department of Community Development will implement and outcome -based Consolidated Plan. The . goal of this initiative is to increase the focus, accountability, impact, and ease of monitoring funded projects. Funds expended through the fiscal years will be tied to performance benchmarks. A forma monitoring strategy will de developed to evaluate the viability, reliability and impact of funded projects. The decision to provide continuing funding for an organization should be shaped, in large part, upon review of their success in meeting established outcomes. • The City understands that all efforts using Federal, State and Local resources must be in accordance with established laws, regulations, and sound management accounting practices. ; programs awarded Federal monies will be monitored and reported according to the program statutoulatory rules of those programs. Affordable housing programs will be monitored on an ongoing s by ct compliance analysts. The Department of Community Development will establish a s *-re. ient mo >+= plan at a minimum establishing the submission of periodic reports and audite ' a statements. A description of the standards and procedures that t furtherance of the plan and will ensure long term i m including minority business outreach. The objectives o monitoring system are: to monitor activitt out in irements of the p s involved, of Communi 1 evelopment's • To minimize the City's liabili _ tifying and corre ajor program deficiencies before resulting in financial pay ing sanctions. To conduct production monitoring part o <' _ 1 proce • To conduct qu. ' ntrol and comp 1' onitor : assessing the quality of the process and produc • CD wi rue to c sly with HUD equirements by preparing the following docu ➢ Five Year Dav This se and Enfor con Prevails rovides a b t Objecti mance and Evaluation Report Wag- overview of Davis -Bacon Streamlining and Labor Standards Administration • Apply i - abor standards properly. Make certain that labor standards, including Davis-Ba prevailing wage rates, are applied where required. Ensure that any exempti.ns or exclusions are identified. • Through education and advice, support contractor compliance with labor standards. Provide basic training and technical support to contractors to ensure that they understand their obligations under prevailing wage and reporting requirements. • Monitor contractor performance. Perform reviews of payroll submissions and other information to help ensure contractor compliance with labor standards provisions and the payment of prevailing wages to workers. ■ Investigate probable violations and complaints of underpayment. Thoroughly explore any evidence of violations, especially allegations of underpayment. 77 2006-2007 Action Plan • Pursue debarment against repeat labor standards violators. HUD will not tolerate contractors who violate the law. The Davis -Bacon Act (DBA). The Davis -Bacon Act requires the payment of prevailing wage rates (which' are determined by the U.S. Department of Labor) to all laborers and mechanics on Federal construction projects in excess of $2,000. Construction includes alteration and/or repair, including painting and decorating, of public buildings or public works. As stated a prevailing wage must be paid to laborers when federal funds are used to pay labor costs for any project over $2,000 or any multi -family project over eight units. The prevailing wage is usually higher than competitive wages, raising the cost of housing production and rehabilitat'on activities. Davis -Bacon requires extensive paperwork that adds to housing costs by requiring . - ntation of the prevailing wages for compliance with labor monitoring requirement. Additio feder:'paperwork requirements are extensive, which increase housing costs. While the objective of -vailing wage requirements is to protect workers from being paid less than their labor is worth - in cost results in higher housing construction expenses. These requirements often restrict participation by sm workers hired for such projects are better paid attr income limited skilled workers who are intend Miami will continue to enforce Davis -Bacon compli Section 3 In compliance with the Code of Federa demonstrated compliance with the "grea set forth for providing training, employme 3 business sectors. Under Section 3 of is give for housi be given to res' ' e employment or contr help give ' ' - s depri Secti ec mic oppo t feasible". Th matic require Enviro The environ Regulations 2 environmental re National Environ commu busin he ener.T of Mt $ rocess for entitlement jurisdictions is outlined in the Code of Federal he procedures outlined in this regulation are used by entities that assume HUD's responsibilities in determining program compliance with the intent of satisfying the ental Policy Act (NEPA). Jurisdictions must assume this responsibility in all applicable federal programs through a system of enforced rules and policies. The Department of Community Development maintains an effective system of communication with HUD to sustain departmental regulatory compliance. The City endows compliance monitoring by adhering to the following categories: nd Urban De evelopment, s in that area. and Urba mino ed to Da he bene ons 24 CFR 1 sible" requi oppo ty contractors. ersely, many of the is -Bacon require . T 's is vital for low aries of this fede . The City of st extent pract • .ble. ipie is and covered contractors must of Section 3 by meeting the goals ities to section 3 residents and section lopment A of 1968, wherever HUD financial assistance the greatest extent feasible, economic opportunities will sistance may be in the form of job training, velopment Act was amended by Congress in 1994 to creased access to employment and job training. The HUD and the contractors they employ to ensure that the the expenditures go to benefit low-income persons "To the greatest continue to enforce Section 3 compliance in all applicable Revi 1 revie • Exempt • Categorically Excluded > Not Subject to 58.5 > Subject to 58.5 2006-2007 Action Plan 78 ■ Environmental Review Assessment The City's Environmental Review Process is explained in detail the subsequent flowchart. 2006-2007 Action Plan 79