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NSP Compliance: Selected Topics & Program Requirements

This agenda covers various compliance topics for the Neighborhood Stabilization Program, including environmental review, programmatic agreement, procurement, conflict of interest, and fraud and abuse.

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NSP Compliance: Selected Topics & Program Requirements

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  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 NSP Compliance

  3. Environmental Review • Rule: 24 CFR Part 58 • Submit RROF to DCA • Do Not Commit Funds Until DCA sends Release of Funds letter NSP Compliance

  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 NSP Compliance

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

  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 NSP Compliance

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

  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. NSP Compliance

  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. NSP Compliance

  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 NSP Compliance

  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 NSP Compliance

  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 NSP Compliance

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