1. Aggregate New Hires--30% per Year Goal. HUD requires DCHA as a recipient of PIH funds, and contractors that receive PIH funds through DCHA, to provide training and employment opportunities to public housing residents, Housing Choice Voucher Program participants, and low-income residents “to the greatest extent feasible.” HUD regulations at 24 CFR Section 135.30(b) (1) set a numerical goal of 30% of aggregate new hires over a one year period as a safe harbor for hiring that meets the “greatest extent feasible” statutory requirement.

A DCHA contractor that does not reach the 30% goal must provide a justification of the impediments encountered and what actions or other economic opportunities, such as joint venturing, the contractor attempted in efforts to reach the goal. New hires will be subject to contractor’s standard employment policies. The contractor must complete exit evaluations of Section 3 employees for each job assignment completed.

The contractor can hire an applicant to work on the job site or within the contractor’s office/plant, etc. The work does not have to be directly related to the contract in question. For example, an architectural firm may contract with DCHA to provide drafting services but may hire a resident to work as a clerk-typist on another contract.

Davis-Bacon wages (prevailing wages) only apply if the applicant is working on the specific work funded by the contract with DCHA.

2. Implementing the Training and Employment Commitment. A Section 3 plan may set forth various ways of achieving its 30% new hire goal or, where no new hiring is anticipated by the contractor or subcontractors, alternatives to meeting the training and employment objectives of the DCHA Section 3 Policy. Each option must be exhausted before moving to the next. The following order of progression must be followed:

To hire DCHA residents, HCVP participants, or low and very low income residents from the District of Columbia from the DCHA’s pre-qualified labor pool database.

To provide training to DCHA residents and HCVP participants..

To contribute to the educational/training fund in an amount commensurate with the sliding scale attached. (See Appendix H) The educational fund will be used to assist residents and participants in receiving training in a particular trade, or training that will assist them in becoming economically self-sufficient. The fund will be administered by the Section 3 Coordinator.

3. DCHA Labor Pool Database. DCHA has developed specific requirements that will assist contractors in reaching the 30% goal. The DCHA has created a labor pool database of individuals who are interested in working. Individuals are informed of the Section 3 program by their Resident Council, DC Department of Employment Services, referrals from various employment training programs, postings at unemployment offices, community centers, other government offices, notices in local and community newspapers, and public service announcements on local television and radio. The Section 3 Coordinator will also hold a Section 3 Orientation to discuss the program.

a. Applicant Requirements To Be Part of Labor Pool Database. All applicants will be interviewed and their applications will be filed in the Section 3 Coordinator. The names, addresses, educational backgrounds, training and employment histories of the applicants are contained in this database. A copy of this database will be made available to all prime contractors for use as the main source of new hires for the construction contracts. The Section 3 Coordinator will update the labor pool database continually to indicate the availability of new hires by classification.

All applicants are interviewed to determine their skills and their readiness to work. All Section 3 applicants with limited job histories are required to attend bi-monthly Job Readiness training, e.g., interviewing skills, resume writing, and work ethics.

b. Selection of Section 3 Residents. Section 3 Residents who are selected are able to work on any property where the contractor is starting work, e.g., if a contractor leaves one property and works on another the Section 3 employee(s) are able to work on the second property.

Applicants are selected based on their skill, communication level and their willingness to work. Applicants are chosen by their status in the database not by the property they live on or near. If there is a major redevelopment project, there will be consideration given to residents of that particular the DCHA community. However, preference is given in the following sequence:

i) Public housing residents;
ii) Housing Choice Voucher Program participants; and
ii) Low and very low income residents of the District of Columbia.

4. Compliance Monitoring. The Section 3 Coordinator will monitor the Section 3 employees’ performance weekly by visiting the work site and speaking with the contractor and the employees to discuss any issues that may prohibit any worker from maintaining employment. There are also bi-weekly meetings held with the contractor to discuss the need for additional new hires.

The Section 3 Program Compliance Specialist will review the contractor’s compliance with their contract monthly, including the prevailing wage requirements. Findings from the review will be reported to the Contracting Officer. Upon completion of each job, contractors are requested to conduct a performance evaluation for all new hires. Evaluations will include ratings for quality of work and initiative. Areas of evaluation will include quality of training received and future training needs. This assessment will be conducted at the Section 3 Coordinator or at the work site.

Last modified: 12/22/2014 7:47:21 PM