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House by House Reservation Rehabilitation Program Changes
June 29,2015
2 CFR Part 200 aka OMBs
• What is it???• How it affects you…..
– Cost Allocation Plans – Direct vs Indirect Costs– MFA oversight requirements
• …..Which ultimately affects sub-grantees
• Audit Requirements• Coming soon
• Data Act• Changes to Section 3
Audit Requirement Change• Agencies must provide either an Independent Financial Audit or Audited
Financial Statements. Both must contain a report on the financial statements and internal control and compliance. If applicable, a management letter addressing audit findings.
• Single Audit Threshold has changed. Beginning with Fiscal Year ending in 2015, the threshold was increased to $750,000 in one or more sources of Federal funding (was $500,000).
• Only local public bodies (local governments, housing authorities, etc.) are required to conduct annual independent financial audits by a certified auditor that has been approved by the New Mexico State Auditor’s Office and on the State Auditor’s List.
• All entities must at a minimum procure for auditing firm/services every 3 years, through a RFP and provide evidence of the procurement to MFA at the time of re-certification. Entity may still choose the same auditor if their response is more cost effective.
Program Requirements• Subsidy amounts – Maximum amount is $65,000
– Hard construction costs capped at $55,000
– Soft costs capped at $10,000 to offset:• Direct project related salaries for Project/Program Manager, Administrative
Assistant, Construction Manager to prepare:
– Work write-ups, cost estimates
– Bid Documents, bid opening
– Environmental review
– Progress inspections
• Fees:
– Title Search
– Appraisal
– Recording fees for Covenants/Tribal Land Award Agreements
– Admin fee capped at 3%
Program Requirements
• Current Eligible Partners may have up to three (3) projects open at one time.
• New Eligible Partners have to complete one project to start. If funding allows, they may submit for another project upon completion of their initial project.
• All projects must be completed and closed out by MFA within 180 days. Projects not invoiced within the first 90 days may be subject to cancellation by MFA.
• Eligible partners are responsible for guaranteeing that the work is inspected and completed
– Progress reports with pictures are required for all requests for reimbursement for hard construction costs.
– Time for project management must be project specific, dated and signed by personnel and supervisor/manager
Uniform Physical Conditions Standards
• What is UPCS– In the absence of State or Local building code, it is the minimum
standard that must be used when assessing a potential home for the Rehab program
– Replaces Housing Quality Standards (HQS)
– New Checklist and Manual
– Not a Pass/Fail system
– Levels of deficiencies• NOD – no observable deficiency• Levels 1, 2, 3 • N/A• Health and Safety
– Non-life threatening– Life threatenting
Uniform Physical Conditions Standards
• 5 areas of inspection– Building Exterior
• Foundations• Roof• Walls
– Building Systems• Domestic Water• Sanitary
– Unit – all rooms inside the home, interior systems such as electrical and HVAC, HWH
– Health and Safety
– Additional inspection items
Uniform Physical Conditions Standards
• Checklist example:
Inspectable Area: Unit
Level
Inspectable Item Observable Deficiency NOD 1 2 3 NA H&S
Bathroom Pages 10-11 Bathroom Cabinets - Damaged/Missing
Lavatory Sink - Damaged/Missing NLT
Plumbing - Clogged Drains NLT
Plumbing - Leaking Faucet/Pipes NLT
Shower/Tub - Damaged/Missing
NLT
Ventilation/Exhaust System - Inoperable
Water Closet/Toilet - Damaged/Clogged/Missing NLT
Uniform Physical Conditions Standards
• Manual exampleBathroom - A room equipped with a water closet or toilet, tub and/or shower, sink, cabinet(s) and/or closet. This item can have the following deficiencies: Bathroom Cabinets - Damaged/Missing Lavatory Sink - Damaged/Missing Plumbing - Clogged Drains Plumbing - Leaking Faucet/Pipes Shower/Tub - Damaged/Missing Ventilation/Exhaust System - Inoperable Water Closet/Toilet - Damaged/Clogged/Missing
Bathroom Cabinets - Damaged/Missing Deficiency: You see damaged or missing cabinets, vanity tops, drawers, shelves, doors, medicine cabinets, or vanities. Level of Deficiency: Level 1: You see damaged or missing shelves, vanity tops, drawers, or doors that are not functioning as they should for storage or their intended purpose. Level 2: N/A Level 3: N/A Lavatory Sink - Damaged/Missing Deficiency: A basin (sink) is missing or shows signs of deterioration or distress. Level of Deficiency: Level 1: N/A Level 2: N/A Level 3: The sink cannot be used, because the sink or associated hardware is missing or has failed.