Civil Rights Font End and Limited Monitoring Review

DRAFT ATTACHMENT A

DRAFT 4

OFFICE OF FAIR HOUSING AND EQUAL OPPORTUNITY (FHEO)

AND

OFFICE OF PUBLIC AND INDIAN HOUSING (PIH)

GUIDANCE FOR THE ON-SITE LIMITED MONITORING REVIEW OF

CIVIL RIGHTS-RELATED PROGRAM REQUIREMENTS (CRRPR)

FOR

LOW-RENT PUBLIC HOUSING (LR) PROGRAM

AND

HOUSING CHOICE VOUCHER (HCV) PROGRAM

1. The Office of Public and Indian Housing (PIH) must complete this review checklist in conjunction with a PIH scheduled on-site comprehensive/consolidated review that is planned based on the PIH risk analysis in accordance with the Management Plan Guidance. PIH should include the language in Attachment C – “Letter Template” – in the PHA notification letter. This checklist and any comments should be completed by PIH and forwarded to FHEO within ten (10) business days of PIH completing its on-site comprehensive/consolidated review. Please highlight those issues, which address or may have an effect on FHEO requirements. FHEO will then take appropriate action, if necessary.

2. PIH, prior to going on-site, should retrieve data from the appropriate HUD/PIH/FHEO data bases, e.g., Public Housing Information Center (PIC) System data on the racial and ethnic characteristics of Housing Choice Voucher holders by census tract, and data on the racial and ethnic composition of the PHA's Low-Rent Public Housing developments, including the location of scattered-site projects by census tract.

3. The PIH reviewer may make additional comments on a separate sheet of paper and attach it to this checklist. These comments should be identified clearly so that the response is associated with the appropriate question.

4. PIH should forward to local FHEO a copy of the completed checklists within ten (10) business days after completing the onsite comprehensive/consolidate review.

ON-SITE LIMITED MONITORING REVIEW OF

CIVIL RIGHTS-RELATED PROGRAM REQUIREMENTS (CRRPR) FOR

LOW-RENT PUBLIC HOUSING (LR)

AND

HOUSING CHOICE VOUCHER (HCV) PROGRAM

The Office of Public and Indian Housing (PIH) must complete this checklist when conducting its on-site comprehensive/consolidated review of a Public Housing Agency (PHA). These questions cover areas that PIH is expected to observe or data that PIH is expected to collect. This checklist is not intended to cover the full range of civil rights and fair housing concerns and PIH will not provide any evaluation or analysis of the data. This checklist alerts PIH and FHEO to certain PHA practices in the Low-Rent Public Housing (LR) and/or Housing Choice Voucher (HCV) Program(s) that may indicate noncompliance with civil rights and fair housing regulations. PIH should forward the completed checklist to local FHEO within ten (10) business days of PIH completing the on-site comprehensive/consolidated review, whether problems are noted or not.

PHA Name: _________________________________________________________

PHA Identification Number: ____________________________________________

Location: ____________________________________________________________

Indicate type PHA program, number of units and vouchers in each, as applicable:

LR Elderly ________ Number of Units _________ Number of Vouchers __________

LR Family ________ Number of Units _________ Number of Vouchers __________

HCV ____________ Number of Units _________ Number of Vouchers __________

Reviewer’s Name: ______________________________________________________

Reviewer’s Title: _______________________________________________________

Reviewer’s Telephone Number and Extension: ________________________________

Date of Review: ________________________________________________________

PART I. POSTING OF DOCUMENT/MATERIAL REQUIREMENTS

Place an “x” in the appropriate column and provide comments whenever an explanation is warranted.

Are the following displayed and readily visible or are they otherwise made available in accordance with the applicable regulations?	YES	NO	COMMENTS (if applicable)
1. Equal Opportunity in Housing Poster (HUD 928.1-English/HUD 928.1A-Spanish) prominently displayed in all public areas. [24 CFR 110.15]
2. Is the Public Housing Agency Plan readily available for public review? [24 CFR 903]
3. Is the Administrative Plan available for public review. [24 CFR 982.54]
4. Notice that the PHA must give the family information on how to fill out and file a housing discrimination complaint. [24 CFR 982.54 (d)(6); 982.304].
5. Are policies, rules, and regulations posted in the project office? [24 CFR 966.5].

PART II. OTHER

	YES	NO	COMMENTS (if applicable)
1. Is there anything else that is related to civil rights or fair housing that should be noted? [For example, fair housing discrimination complaints brought against the PHA by its employees, or media reports of racial/ethnic tensions at the PHA's developments?] If yes, please note.
2. Limited English Proficiency (LEP). Executive Order 13166, titled “Improving Access to Services by Persons with Limited English Proficiency,” requires all agencies and their recipients to ensure that their programs provide meaningful access for LEP persons. (Final Guidance will be published in Federal Register, and is also noted in the Public Housing Occupancy Guidebook, Section 6.2 “Accessibility and Plan Language,” page 68.)
Has the PHA taken the following steps to ensure meaningful access to programs by LEP persons?
Conducted a four-factor analysis. If “yes,” bring a copy to FHEO.
Developed a written Language Assistance Plan? If “yes,” bring a copy to FHEO.
Hired bi-lingual staff.
Contracted with a telephone language line services to provide interpretation for residents and applicants.