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Housing (1)
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1103382
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Housing (1)
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Bradley H. Patterson Files (Ford Administration)
Bradley Patterson's Native American Programs Files
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Indians of North America
Housing
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1976-11-01
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The original documents are located in Box 3, folder "Housing (1)" of the Bradley H.
Patterson Files at the Gerald R. Ford Presidential Library.
Copyright Notice
The copyright law of the United States (Title 17, United States Code) governs the making of
photocopies or other reproductions of copyrighted material. Gerald Ford donated to the United
States of America his copyrights in all of his unpublished writings in National Archives collections.
Works prepared by U.S. Government employees as part of their official duties are in the public
domain. The copyrights to materials written by other individuals or organizations are presumed to
remain with them. If you think any of the information displayed in the PDF is subject to a valid
copyright claim, please contact the Gerald R. Ford Presidential Library.
Digitized from Box 3 of the Bradley H. Patterson Files at the Gerald R. Ford Presidential Library
FORD
MANAGEMENT INITIATIVES FOR INDIAN HOUSING
LIBRARY
It has come to my attention that some unexpected difficulties
may have developed in recent efforts to enhance the effective-
ness of HUD's overall delivery system for low income housing
for Native Americans. The difficulties involve the implementation
of the recently approved Management Initiatives for Indian
Housing (MIFIH) program.
The purpose of the MIFIH program is to improve the management
effectiveness, in both the short and long run, of key employees
of approximately 132 Indian Housing Authorities (IHAs).
Guidelines for the program were recently signed in mid-August
with funding of $3.5 million (including a $500,000 carryover
of TPP monies from FY 76) for a two-year program of management
training and technical assistance. The appropriation requires
that the $3.5 million be obligated by 30 September 1976.
One of the most important issues involved in this legislation
and indeed in all new Federal legislation, is how to best
facilitate the implementation of self-determination by the
Indian peoples and at the same time to maximize the efficient
use of Federal training program funds. The current Assistant
Secretary for Legislation and Consumer Affairs, Dr. Constance
Newman, apparently considers her Office to be legally required
to obligate, through the HUD Regional Offices, the $3.5 million
directly to the individual IHAs by 30 September 1976. The IHAs
are then expected to individually contract (with Regional
Office approval) with various individuals and/or organizations
who appear to have the expertise to provide management training
and technical assistance.
It appears to me that this approach to obligating the MIFIH
monies is likely to lead to the following undesirable results
over the next two years:
(1) arbitrary allocations by formula and, not by true need,
of funds being made to the regional offices and
subsequently to the individual IHAs by 30 September
of this year;
(2) considerable unnecessary duplication of efforts and
inefficient use of Federal resources caused by the
IHAs contracting with a large number of trainers each
of whom would need to develop training materials and
programs of technical assistance;
-1-
(3) minimal development of performance standards across
HUD regions (or even perhaps in a single region) and
thus a lack of clear identification of much needed
role models which are culturally relevant to Native
Americans as they attempt to improve the management
of their own affairs in this very important area of
housing;
(4) setting in motion a highly ineffective and circular
process of providing funds to the IHAs which they are
expected to manage efficiently, when the very reason
for the MIFIH program is to enhance the management
skills of key personnel in the IHAs; and
(5) raising expectations that self-determination will be
enhanced for the Indian peoples when any reasonable
independent evaluation is likely to conclude two
years from now that the IHAs have not effectively
managed the training monies and thus self-determination
is not working so future allocation of monies are not
warranted.
Given the nearness of the 30 September deadline, and the
potential problems outlined above, it appears to me that
immediate reasonable strategy might include the following
elements:
(1) request an interpretation from the HUD General Counsel
regarding the necessity to obligate all monies directly
to the IHAs;
(2) if the interpretation by General Counsel is that all
MIFIH monies are not required to be directly allocated
by the deadline, seriously consider
(a) pre-qualifying one or more training organizations
which could develop some common curriculum
materials and schedule some group training
(based for example on regional, cultural, and
size similarities in IHA tribal units) activities
to effect some economies of scale, and quality
assurance of minimum standards.
(b) set aside some MIFIH funds for the materials in
(a) above with input being provided from IHAs
regarding the materials and the final selection
of trainers from the pre-qualified list of
organizations,
based
ON
A
(c) obligate through the Regional Offices the
remaining MIFIH funds to be used to contract
for their technical assistance and training needs.
THE
WHITE HOUSE
Victor WASHINGTON Revire The
837-4021
SBA Dues
a Region 8
FORD LIBRARY
S.D. Harnin Rojus -
Pre SD-1-10 Pudge somets have Behn
303-837-2152
or
al TheKay
present
to Paped lity This
MEMORANDUM
OF CALL
TO:
Blad
YOU WERE, CALLED BY-
YOU WERE VISITED BY-
Violet LAVEAU
OF (Organization)
PHONE NO.
PLEASE CALL
CODE/EXT.
WILL CALL AGAIN
IS WAITING TO SEE YOU
RETURNED YOUR CALL
WISHES AN APPOINTMENT
MESSAGE
(605)
342-7522
wgeal
RECEIVED BY
DATE
TIME
STANDARD FORM 63
GPO : 1969-c43--18-60341-1 332-889
63-108
REVISED AUGUST 1967
GSA FPMR (41 CFR) 101-11.6
THE WHITE HOUSE
WASHINGTON
Each IHA be allowed
to choose.
IHC new going
for teams, package in Nurda.
Sterling Antitate
Rural Housing allowance Great
FORD LIBRARY & 07
MT to C/V
Mukui
2.5
THE WHITE HOUSE
WASHINGTON
Couni Newwork
HUD
Jae Bursten - HUD 755-7093
Bab Ellistt
Dan Was Donald
Inc. Beaughest
"22 pu puson
SWarea only
for recedultial and
rustrial ->wrable
nationally.
Would add hideon
family rumber
Would have Indian
MBA programs
HUD has THE WASHINGTON vot WHITE HOUSE get
Afrouda list
assouals contractors
of propert
for Reg. Offece
action
Daketa Haveng Autiorities
asked for ok
have for o Rapid City frien
No approval from Denaer
EXECUTIVE OFFICE OF THE PRESIDENT
$
OFFICE OF MANAGEMENT AND BUDGET
DATE: 4/21/76
TO: DR. Marrs
FROM: Howard Borgstrom
Per our conversation
Interesting points are
(1) This includes state
tailes,
(2) No mention of BIA
See page 4, section 6(1),
OMB REV FORM Aug 38 73
H.R. 8650
That this Act may be cited as the "Energy Conservation and
Smith
Weatherization in Buildings Act of 1976".
TITLE I WEATHERIZATION ASSISTANCE FOR LOW-INCOME PERSONS
SHORT TITLE
Sec. 101. This title may be cited as the "Weatherization Assistan
Act of 1976".
FORD
Sec. 102. The Congress finds and declares that
LIBRARY
(1) dwellings owned or occupied by low-income persons frequently
are inadequately insulated, and such persons, particularly elderly
and handicapped low-income persons, can least afford to make the
modifications necessary to reduce their residential energy use;
(2) weatherization of such dwellings would lower utility expenses
for such low-income owners or occupants as well as save thousands
of barrels per day of needed petroleum;
(3) the States should be encouraged through Federal assistance to
develop and support coordinated weatherization programs designed to
ameliorate the adverse effects of high energy costs on such low-income
persons, to supplement other Federal programs serving such persons, and
to conserve energy; and
(4) such State programs should supplement and not supplant, and
be fully coordinated with, the emergency energy conservation program
carried out by community action agencies pursuant to section 222 (a) (12)
of the Economic Opportunity Act of 1964.
PURPOSE
7
Sec. 103. The purpose of this title is to develop and implement
a supplementary weatherization assistance program to assist in achievin
a prescribed level of insulation in the dwellings of low-income persons
particularly elderly and handicapped low-income persons, in order both
to aid those persons least able to afford higher utility costs and to
conserve needed energy.
DEFINITIONS
Sec. 104. As used in this title the term
(1) "Administrator" means the Administrator of the Federal
Energy Administration;
(2) "Director" means the Director of the Community Services
Administration;
(3) "elderly" means persons who are sixty years of age or older;
(4) "Governor" means the chief executive officer of a State
(including the Mayor of the District of Columbia);
(5) "handicapped person" means an individual who meets the
definition of a "handicapped individual as defined in section 7 (6) of
the Rehabilitation Act of 1973, as amended, or who is under a disability
as defined in section 1614 (3) (A) or 223 (d) (1) of the Social Security
Act or in section 102 (7) of the Developmental Disabilities Services
and Facilities Act of 1970, as amended, or who is receiving benefits
under chapter 11 or 15 of title 38, United States Code;
(6) "Indian", "Indian tribe", and "tribal organization" mean
"Indian", "Indian tribe", and "tribal organization" as those terms
are defined in paragraphs (4) (5), and (6) of section 102 of the
Older Americans Act of 1965, as amended; and
(7) "low-income" means that income in relation to familiy size
which (A) is at or below the poverty level determined in accordance wit
criteria established by the Director of the Office of Management and But
or (B) would qualify for cash assistance payments under titles IV and XV
of the Social Security Act or applicable State or local law;
(8) "State" means the several States and the District of Columbia;
(9) "weatherization materials" means items primarily designed to
improve the heating or cooling efficiency of a dwelling, including,
but not limited to, ceiling, wall, floor, and duct insulation, storm
windows and doors, and caulking and weatherstripping, but not
including mechanical equipment valued in excess of $50 per dwelling unit
WEATHERIZATION PROGRAM
Sec. 105. (a) The Administrator is authorized, in accordance
with the provisions of this title and regulations prescribed here-
under, to make grants to (1) States, and (2) in accordance with the
organizations
provisions of subsection (d) of this section, to Indian tribal/to serve
Native Americans, to provide financial assistance 1:0 assist in carryi:
out projects designed to provide for the weatherization of dwellings,
particularly those where elderly and handicapped low-income persons
reside, in which the head of houschold is a low-income person.
(b) (1) The Administrator, after consultation with the Secretary
of Housing and Urban Development, the Secretary of Health, Education,
and Welfare, the Secretary of Labor, the Director of the ACTION Agency,
and the heads of such other Federal departments and agencies as he
deems appropriate, shall develop and publish in the Federal Register
for public comment, not later than forty-five days after the date of
enactment of this title, proposed regulations to carry out the provi-
sions of this title. He shall take into consideration comments sub-
mitted regarding such proposed regulations, and shall publish such
final regulations not later than seventy-five days after the date of
such enactment. The development of regulations under this title shall
be fully coordinated with the Director.
incurrence
leopped
(2) The regulations prescribed pursuant to this section shall
include provisions --
(A) prescribing, in coordination with the Secretary of
Housing and Urban Development, the Secretary of Health, Education,
and Welfare, and the Director of the National Bureau of Standards
in the Department of Commerce, for use in various climatic,
structural, and human need settings, standards for weatherization
materials, energy conservation techniques, and balanced combination
thereof, designed to achieve a balance of a healthful dwelling
environment and maximum energy conservation; and
(B) designed to insure that (i) the benefits of weatherization
assistance in connection with leased dwelling units will accrue
primarily to low-income tenants; (ii) the rents on such dwelling
units will not be raised because of any increase in the value
thereof due solely to weatherization assistance provided under
this title; and (iii) no undue or excessive enhancement will occu
NRS
to the value of such dwelling units.
(c) In the event that a State does not, within ninety days after
the date on which final regulations are published under this section,
submit an application meeting the requirements set forth in section
a unit of general purpose government of sufficient size as determined
by the Administrator, or a community action agency carrying out progra
under title 11 of the Economic Opportunity Act of 1964, as amended,
may, in lieu of such State, submit an application (meeting such requir
ments and subject to all other provisions of this title) for carrying
out projects under this title within the geographical area under the ju
diction of such government, or served by such agency under that Act, as
the case may be. In the event of any such application by a unit of
general purpose government proposing that the allocation requirement
and priority for an applicable community action agency, established
under section 107 (b) (2) (B), be determined to be no longer applicable,
the Administrator, as part of the notice and public hearing procedure
carried out under section 110 with respect to such application, shall
be responsible for making the necessary determination under the provise
in section 107 (b) (2) (B).
Julins
(d) (1) Notwithstanding any other provision of this title, in any
State in which the Administrator determines (after having taken into
account the amount of funds made available to the State to carry out
the purposes of this title) that the low-income members of an Indian
tribe are not receiving benefits under this title that are equivalent
to assistance provided to other low-income persons in such State, and
if he further determines that the members of such tribe would be better
served by means of a grant made directly to provide such assistance,
he shall reserve from sums that would otherwise by allocated to such
State under this title not less than 100 per centum nor more than
150 per centum of an amount which bears the same ratio to the State's
allocation for the fiscal year involved as the population of all low-
income Indians for whom a determination under this subsection has been
made bears to the population of all low-income persons in such State.
(2) The sums reserved by the Administrator on the basis of his
determination under this subsection shall be granted to the tribal
organization serving the individuals for whom such a determination has
been made, or, where there is no tribal organization, to such other
entity as he determines has the capacity to provide services pursuan'
10 this title.
(3) In order for a tribal organization or other entity to be
For a grant for 0 fiscal year under this subsection, it shall subwit
to the Administrator an application meeting the requirements Set
(c) Notwithstanding any other provision of law, the Administrati
is authorized to transfer 10 the Director sums appropriated under thi
title to be utilized in order to carry out programs under section
222 (a) (12) of the Economic Opportunity Act of 1964, as amended, in
furtherance of the purpose of this title.
FINANCIAL ASSISTANCE
Sec. 106. (a) The Administrator shall provide financial
assistance from sums appropriated for any fiscal year under this title
only upon annual application therefor describing the estimated number
and characteristics of the low-income persons and the number of dwelli
to be assisted and containing such other information (including infor-
mation needed for evaluation purposes) and assurances as may be
required (1) in the regulations prescribed pursuant to section 105
and (2) to carry out this section. In providing such financial
assistance, the Administrator shall allocate funds on the basis of
the relative need for weatherization assistance among low-income
persons throughout the States, taking into account the following
factors:
(1) the number of dwellings to be weatherized;
(2) the climatic conditions in the State respecting energy
conservation, which may include consideration of annual degree
days;
(3) the type of weatherization work to be done in the
various settings; and
(4) such other factors as the Administrator may determine nec-
essary in order to carry out the purpose and provisions of this ti:
(b) The Administrator shall not provide financial assistance
under this title unless the applicant has provided reasonable
assurances that it has --
(1) established a policy advisory council which has special
qualifications and sensitivity with respect to solving the prob?
of low-income persons (including the weatherization
and
energy-conservation problems of such persons) and is broadly repr
sentative of organizations and agencies which are providing servi
10 such persons in the State or geographical area in question in
10 advise the responsible official or agency administering the
allocation of financial assistance in such State or area with 110
to the development and implementation of the weathorization
assistance program
(2) established priorities to govern the provision of
weatherization assistance to low-income persons, including
methods to provide priority to
elderly and handicapped low-income persons and the extent to whi
priority will be given to single-family or other high-energy-
consuming dwellings; and
(3) established policies and procedures designed to
assure that financial assistance provided under this title will b
used so as not to supplant State or local funds, but to supplement
and, to the extent practicable, to increase the amounts of such
funds that would in the absence of such Federal funds be made
available for carrying out the purpose of this title, including
plans and procedures (A) for securing, to the maximum extent feasi
the services of volunteers and manpower training participants and
public service employment workers, pursuant to the Comprehensive
Employment and Training Act of 1973, as amended, to work under the
supervision of qualified supervisors and foremen, and (B) for
complying with the limitations set forth in section 107.
LIMITATIONS
Sec. 107. (a) Financial assistance provided under this title
shall, to the maximum extent feasible as determined by the Administrator
be used for the purchase of weatherization materials, except that
not to exceed 10 per centum of any grant under this title may be used
for the administration of weatherization projects under this title.
(b) The Administrator shall insure that financial assistance
provided under this title will
(1) be allocated within the State or area in accordance
with a published State or area plan, determined after notice and
a public hearing, describing the proposed funding distributions
and recipients;
-7-
(2) be allocated, pursuant to such plan, to community acti.
agencies carrying out programs under title I] of the Economic
Opportunity Act., of 1964, as amended, or other appropriate quali:
public or nonprofit entities in the State or area SO that
(A) funds will be allocated on the basis of the
relative need for weatherization assistance among the
low-income persons within the State or area, taking into
account appropriate climatic and energy conservation
factors;
(B) (i) funds to be allocated for carrying out
weatherization projects under this title in the geo-
graphical area served by the emergency energy conservation
program carried out by a community action agency under
section 222 (a) (12) of the Economic Opportunity Act. of
1964, as amended, will be allocated to such agency, and
(ii) priority in the allocation of such funds for carrying
out such projects under this title will be given such a
community action agency in so much of the geographical
area served by it which is not served by the emergency
energy conservation program it is carrying out: Provided,
That such allocation requirement and such priority shall no
longer apply in the event that the Governor of a State
preparing an application for financial assistance under this
title makes a determination, on the basis of the public
hearing required by clause (1) of this subsection, or the
Administrator, as provided in section 105 (c) makes a deter-
mination, that the emergency energy conservation program
carried out by such agency has been ineffective in meeting
the purpose of this title or is clearly not of sufficient
size, and cannot in timely fashion develop the capacity,
to support the scope of the project to be carried out in
such area with funds under this title; and
(C) due consideration will be given to the results
of periodic evaluations of the projects carried out under
this title in the light of information regarding current
and anticipated energy and
weatherization
needs of
low-income persons within the State; and
-8-
(3) be terminated or discontinued during the application
period only in accordance with policies and procedures consistent
with the policies and procedures set forth in section 110.
MONITORING, TECHNICAL ASSISTANCE, AND EVALUATION
Sec. 108. The Administrator, in coordination with the Director
shall monitor and evaluate the operation of projects receiving
financial assistance under this title through reports provided for
in section 109(a) or through onsite inspections, or otherwise, in
order to assure the effective provision of weatherization assistance
for the dwellings of low-income persons, and shall carry out periodic
evaluations of the program authorized by this title and projects
receiving financial assistance hereunder. The Administrator may
provide technical assistance to any such project, directly and through
persons and entities with a demonstrated capacity in developing and
implementing appropriate technology for enhancing the effectiveness
of the provision of weatherization assistance to the dwellings
of low-income persons, utilizing in any fiscal year not to exceed
10 per centum of the sums appropriated for such year under this title.
ADMINISTRATIVE PROVISIONS
Sec. 109. (a) The Administrator, in consultation with the
Director, by general or special orders, may require any recipient
of financial assistance under this title to provide, in such form
as he may prescribe, such reports or answers in writing to specific
questions, surveys, or questionnaires as may be necessary to enable
the Administrator and the Director to carry out their functions under
this title.
(b) Each person responsible for the administration of a
weatherization assistance project receiving financial assistance
under this title shall keep such records as the Administrator may
prescribe in order to assure an effective audit of the disposition
of the funds provided under this title.
(c) The Administrator, the Director (with respect to community
action agencies), and the Comptroller General of the United States,
(1) any of their duly authorized representatives, shall have access
for the purpose of audit and examination to any books, documents
papers, information, and records of any project receiving financial
assistance under this title that are pertinent to the financial
assistance received under this title.
(d) Payments under this title may be made in installments and
in advance or by way of reimbursement, with necessary adjustments on
account of overpayments or underpayments.
APPROVAL OF APPLICATIONS AND ADMINISTRATION OF
STATE PROGRAMS
Sec. 110. (a) The Administrator shall not finally disapprove
any application submitted under this title, or any modification thereof,
without first affording the State
(or general
purpose local government or community action agency under section
(c), as appropriate) in question, as well as other interested parties,
reasonable notice and opportunity for a public hearing. The Administrator
may consolidate into a single hearing the consideration of more than
one such application for a particular fiscal year to carry out projects
within a particular State. Whenever the Administrator, after reasonable
notice and opportunity for a public hearing, finds that in the admini-
stration of the program within the State or geographical area there is
a failure to comply substantially with the provisions of this title and
regulations prescribed hereunder, he shall notify such agency or
institution and other interested parties that the State (or government
or agency, as appropriate) will not be regarded as eligible to parti-
cipate in the program under this title until the Administrator' is
satisfied that there is no longer any such failure to comply.
(b) Reasonable notice under this section shall include a
written notice of intention to act adversely (including a statement
of the reasons therefor) and a reasonable period of time to submit
corrective amendments to the application, or to propose corrective
action.
JUDICIAL REVIEW
Sec. 111. (a) If any applicant is disatisfied with the
Administrator's final action with respect to the approval of its
application submitted under section 106 or with the final action
under section 110, such applicant may, within sixty days after
notice of such action, file with the United States court of
circuit in which the state in question is located
-10-
a petition for review of that action. A copy of the petition shall
be forthwith transmitted by the clerk of the court to the Administrato
The Administrator thereupon shall file in the court the record of the
proceedings on which he based his action, as provided in section 2113 C.
title 28, United States Code.
(b) The findings of fact by the Administrator, if supported by
substantial evidence, shall be conclusive; but the court, for good
cause shown, may remand the case to the Administrator to take further
evidence, and the Administrator may thereupon make new or módified
findings of fact and may modify his previous action, and shall certify
to the court the record of the further proceedings. Such new or
modified findings of fact shall likewise be conclusive if supported
by substantial evidence.
(c) The court shall have jurisdiction to affirm the action
of the Administrator or to set it aside, in whole or in part. The
judgment of the court shall be subject to review by the Supreme
Court of the United States upon certioriari or certification as
provided in section 1254 of title 28, United States Code.
NONDISCRIMINATION
Sec. 112. (a) No person in the United States shall on the
ground of race, color, national origin, or sex, or on the ground
of any other factor specified in any Federal law prohibiting dis-
crimination, be excluded from participation in, be denied the benefits
of, or be subjected to discrimination under any program, project, or
activity supported in whole or in part with financial assistance
under this title.
(b) Whenever the Administrator determines that a recipient
of financial assistance under this title has failed to comply with
subsection (a) or an applicable regulation, he shall notify the recipie
to secure compliance. If within a reasonable period of time the
recipient fails to secure compliance, the Administrator shall (1) refe
the matter 1:0 the Attorney General with a recommendation that an
appropriate civil action be instituted; (2) exercise the power and
functions provided by title VI of the Civil Rights Act of 1961
-11-
U.S.C. 2000d ct scq.) and any other applicable Federal non-
(
;crimination law; or (3) take such other action as may be
provided by law.
REPORT TO CONGRESS
Sec. 113. The Administrator and (with respect to the
ration and effectiveness of activities carried out through
of
CC maunity action agencies) the Director shall each submit, on
before March 31, 1977, and annually thereafter through 1979,
or
eport to the Congress and the President describing the
a
therization
:
assistance program carried out under this
WC
ti
le or any other provision of law, including the results of periodic
Quations and monitoring activities required by section 108.
ev
AUTHORIZATION OF APPROPRIATIONS
Sec. 114. There are authorized to be appropriated to carry
the
weatherization program under this title,
our
$
5
000,000 for each of fiscal years 1976, 1977, 1978, to remain
ilable until expended.
ave
CY PROVIDED
J. MITCHELL
*U.5. GOVERNMENT PRINTING OFFICE: 1975-569-796
D. MC GURK
B. PATTERSON
B. KILBERG
DOM COUNCIL
THE WHITE HOUSE OFFICE
REFERRAL
To:
Department of the Inter ior
Date:
June 10, 1976
ACTION REQUESTED
Draft reply for:
President's signature.
Undersigned's signature.
FORD LIBRARY
NOTE
Memorandum for use as enclosure to
reply.
Prompt action is essential.
X Direct reply.
If more than 72 hours' delay is encountered,
X
please telephone the undersigned immediately,
Furnish information copy.
Code 1450.
Suitable acknowledgment or other
appropriate handling.
Basic correspondence should be returned when draft
Furnish copy of reply, if any.
reply, memorandum, or comment is requested.
For your information.
For comment.
REMARKS:
For direct response, copy to the Undersigned.
Description:
X Letter:
Telegram: Other:
To:
President Gerald Ford
From:
William J. Woods
Date:
5-26-76
Subject:
Indian Reservation Housing Requirements
By direction of the President:
Theodore C. Marrs
Special Assistant to the President
TE - MOAK BANDS OF WESTERN SHOSHONE
Elko, Nevada 89801
ELKO INDIAN COLONY
May 26, 1976
FORD
The Honorable Gerald Ford
President of the United States
LIBRARY
1600 Pennsylvania Avenue
Washington, D.C. 20024
ATTN: Dr. Ted Morris
Dear President Ford,
A very serious problem now exists on the Elko Indian Colony and the other
Indian Reservations and Colonies in the eastern part of the State of Nevada.
We are in dire need of housing. The Department of Housing and Urban
Development recognized this about three years ago in the Elko Colony's case
and authorized the building of 15 new homes. HUD also authorized housing
on other reservations in the area under jurisdiction of the Eastern Nevada
Indian Agency. The initial joy and pride we all felt in having these houses
authorized is slowly slipping away as time passes on and no construction
starts.
We do not have these houses because there is no HOUSING OFFICER sta-
tioned here in the Eastern Nevada Agency in Elko, Nevada, to do the paper-
work and the administration that is necessary to get the houses built and
occupied. It is particulary sad and ironic that we do not have a Housing
Officer here because there is a slot for such an officer in the Eastern Nevada
Indian Agency of the Bureau of Indian Affairs and there has even been a per-
son chosen for the slot, a Patrick E. Flynn now living in the state of Wiscon-
sin. The only thing keeping Mr. Flynn from coming here is the freeze on
filling Civil Service Commission Classification Series 301 positions within
the Department of Interior.
We realize the need for economy in the government, but feel that by not
sending Mr. Flynn here the Department O₂ Interior has shown an insensitive
lack of knowledge or disrespect for near emergency need of housing. Please
see what can be done to get us a Housing Officer in Elko, Nevada, in the
short run, and also see what can be done to get us an additional personnel
policy for the Bureau of Indian Affairs Agency in Elko in the long run. Part
of the Indian-Self Determination Act (P. L. 93-638) was that the Indian people
would be provided adequate B.I.A. service. The E.N.A. agency in order to
provide the minimum services to us, need an additional ten more permanent
employment slots. Approximately half the employees are on temporary
status now. These are local Indian people who are desirous of making a
career in the Federal Service and serving their people. As to the im-
plementation of a more effective personnel policy, we do not believe that
decisions about what personnel are needed in the Nevada Agencies can be
made in Washington, D.C. We strongly believe that the Phoenix Area
Office of the Bureau of Indian Affairs is capable of alloting slots and assign-
ing personnel and could perform these functions more efficiently and with
better results than the Bureau Headquarters in Washington, D.C. because
it deals with Nevada Indians on a day to day basis and is cognizant of
Nevada Indians' problems and needs.
The fact that we do not have a Housing Officer is indicative of a failure of
the Washington, D.C. headquarters of the Bureau to realize our problems.
Another example of the problems that have arisen out of this forced re-
liance on Washington, D.C. to handle our personnel problems is that there
is only one person in the Tribal Operations Section of the Eastern Nevada
Indian Agency in Elko. This one man Mr. Harry Owhi is good and dedicated
but he does not have the time to serve the eight reservations in his area.
The enclosed map will show the great distances he must travel to serve all
these people in their serious and varied problems ranging from the Goshute
Land Claims settlement to constitutional reorganization.
Sincerely,
Chairman, Elko Indian Council
Director, Te-Moak Tribal Gov't Development Program
WJW/cp
Enclosure
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OFFICE OF INDIAN AFFAIRS
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OF
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UTAH
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VINHOATIVO
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475
LasVegas
FOR IMMEDIATE RELEASE
AUGUST 4, 1976
Office of the White House Press Secretary
THE WHITE HOUSE
STATEMENT BY THE PRESIDENT
I have
signed into law S. 3295, the Housing
Authorization Act of 1976.
The need to increase the quantity and quality of
housing in America and to assure adequate housing for all
Americans has been one of my primary concerns. S. 3295
contains provisions which are important in helping us reach
these housing goals, and also contains important fiscal
year 1977 authorizations for the Department of Housing and
Urban Development. Unfortunately, it also contains provisions
which indicate the strong reluctance on the part of this
Congress to seek real solutions to the problems we face in
assuring adequate housing for all lower-income Americans.
Two years ago, the Ninety-third Congress authorized
a new approach to provide rental subsidies for lower...
income families --- the Section 8 Housing Assistance
Payments Program. This program was designed to avoid the
serious, and well-documented, defects in the then-existing
public housing program.
As a result of that new program, for the first time
in our history we have been using effectively the existing
housing in inventory, as well as new housing, to provide
decent shelter for the Nation's poor. This approach is
approximately half as costly as constructing new public
housing, and it prevents the waste of our Nation's housing
stock. Moreover, this program permits lower-income families
to live in modest homes, indistinguishable from those of
their neighbors, instead of institutionalized housing.
In S. 3295, however, the Congress has ignored both our
unfortunate previous experience and the recent success re-
sulting from the Section 8 program. Reversing this record
of progress, it voted to re-initiate a public housing program.
Fortunately. in the 1977 HUD appropriation bill, the Congress
has voted overwhelmingly to cut back the size of that program.
S. 3295 would also extend a number of programs which
should be discontinued and would authorize appropriations
far in excess of my budget proposals. Although the Congress
in acting on HUD's appropriation bill has demonstrated much
greater restraint than was shown in S. 3295, the threat to
future budgets remains because these high authorizations
produce unrealistic expectations.
This bill also calls for short-sighted and illogical
changes in the way interest rates are established under
certain existing Federal programs.
more
2
Despite my strong reservations about these and other
undesirable features I have signed this bill because good
government requires that a number of the authorizations and
program extensions contained in S. 3295 become law as soon
as possible. I have instructed Secretary Hills to use the
resources of the Department of Housing and Urban Development
to implement this measure in a manner which will maximize
its benefits while reducing as much as possible the inevitable
frustration, delays and increased costs it will also bring.
# # #
H.A,
the
TRIBAL OFFICE BLOG.
ROUTE 7. BOX 21
Mississippi BANO OF ChOCTAW iNDiANS
THANK
phiLADELphiA. Miss. 39350
TELEPHONE (601) 656-5251
August 17, 1976
Mrs. Loie Brooks, Executive Director
FORD
National American Indian Housing Council
Post Office Box 215
Stewart, Nevada 89437
GERALD
Dear Loie:
As you know from our telephone conversations, in an effort to quickly grasp
its content, I have been preparing an outline of the new HUD Handbook 7440.2
Management Initiatives for Indian Housing (MIFIH). I have spent most of
tonight finishing that outline. As you suggested, a copy is being sent to
Ron Peake. While reference to the handbook will still be necessary to obtain
exact details on MIFIH, this outline might prove helpful to you and to Ron in
getting an overall view of the program. It might also be helpful to member
Indian housing authorities (IHAs). Use your judgement as to whether or not
it should be distributed.
In a nutshell, HUD will allocate a total of approximately $2.5 million to
IHAs to defray expenses incurred by IHAs in obtaining training and technical
assistance aimed at achieving management capabilities. Each IHA must determine
its own needs and must devise a plan to fill its needs. The expenses to be
incurred in following its plan must be estimated and the HUD Regional Office
must review the plan, approve it and the cost estimate and allocate funds not
later than September 30, 1976. That's about six weeks from today.
Therein lies the problem!
For years we have worked for and waited for the program. And when it gets here,
it has a September 30 deadline. (We understand the reason for the deadline and
do not object to it strongly enough to chance loss of the funds.) While the
handbook directs the Regional offices to allocate their funds by September 30,
even if IHA MIFIH plans have not been approved by that date, such allocations
will be based on HUD Regional estimates of individual IHA needs and the costs
of filling those needs. Those with the greatest needs will likely get the dregs
at the bottom of the barrel. Obviously, the least proficient IHAs won't under-
stand the new handbook - whenever they receive it. If Choctaw is any example,
it is altogether possible that the envelope will not even be opened when the
handbook is received, or else the handbook will never be handed over to the
person needing it.
"chOCTAW SELF-DETERMiNATION"
Mrs. Loie Brooks
August 17, 1976
Page 2
At least two possible courses of action could be followed:
(1) We can impress upon the HUD Regional offices
just how grave some IHA situations can be,
and their needs for special assistance even
in preparing their MIFIH plans; and/or,
(2) We can move quickly to give the needed
special assistance.
The latter seems to have the better chance of actually helping those who
need help. I would venture that most if not all IHAs will need some degree
of help.
Even if we have to personally do everything that needs to be done, let's not
allow this program to be another that is "full of sound and fury, signifying
nothing."
Very truly yours,
Jard Jack Partridge
Enclosure
cc with enclosure:
Mr. G. Ron Peake, Director
Housing Assistance Division
Bureau of Indian Affairs
1951 Constitution Avenue, N. W.
Washington, D. C. 20245
MANAGEMENT INIATIVES FOR INDIAN HOUSING
CHAPTER 1. INTRODUCTION
1. Purpose - to provide management assistance to IHAs
2. Background
a. The fundamental goal is to provide housing. This program is to assist
IHAs in meeting their legal responsibilities as autonomous bodies.
b. The intent of the program is to defray IHA expenses incurred in attaining
the knowledge necessary to effectively fulfill management responsibilities.
C. Management capability is necessary in order to continue production of
Indian housing.
d. IHA accounting is not in auditable çondition.
3. The 124 IHAs who received allocations of FY75 TPP funds are eligible to
participate in MIFIH - others may be added.
4. MIFIH is a 2-year catch-up effort to substantially improve IHAs' management
capability.
a. MIFIH will concentrate on housing operations
(1) Housing management
(2) Development Programs
(3) Community planning and development
b. MIFIH will be devoted to administrative/management capabilities
(1) Training in operational management
(2) Technical assistance in operational management
(3) Training in development functions
C. MIFIH relates to people (software) rather than things (hardware).
d. MIFIH activities are to be monitored to measure effectiveness, control
funds and reveal further needs
(1) By IHAs
(2) By trainers
(3) By HUD
e. MIFIH activities are to be planned by IHAs and reviewed by HUD from the
IHAs' perspectives
5. Responsibilities
a. HUD Central Office
(1) Assistant Secretary for Consumer Affairs and Regulatory Functions
(CARF) and the Director of Indian Policy and Programs (IPP) are
responsible for the implementation, monitoring and evaluation of
MIFIH activities.
(2) Assistant Secretary for Housing and Office of Housing Programs (OHP)
are responsible for assignment, administration and monitoring of
MIFIH funds.
b. HUD Regional Offices
(1) Assistant Regional Administrator for Housing Management (ARA) has
responsibility for administration of MIFIH. (Regions VIII and IX
have ARA's for Indian Programs who will have this responsibility.)
(2) Regional Indian Coordinator or Special Assistants concurrence prior
to Regional Administrator's approval is required at all levels of
development of Regional Strategy and program implementation.
C. HUD Area Offices and Insuring Offices responsibility shall be determined at
Regional level - may cover total program.
-1-
d. Indian Housing Authorities
(1) IHA Executive Director, in consultation with HUD, determines IHA's
needs and develops IHA's plan.
(2) IHA Board of Commissioners reviews and approves plan and adopts
resolution indicating review and approval of plan, assures that
plan will be deligently and effectively carried out, states that
the IHA will comply with all applicable HUD requirements, and
acknowledges HUD's right to terminate funding if IHA fails to carry
out its responsibilities under the plan.
(3) Chairman of IHA Board secures Tribal Council approval of the plan
and verifies Tribal Chairman's participation in the plan.
e. Regional IHA Association may be designated by the IHA Board by resolution
to perform certain MIFIH functions. ARA is to be furnished copy of
IHA resolution.
6. Operation of the MIFIH Program
a. Regional Strategy to be developed by each ARA. Major considerations
include:
LIBRARY is OF
(1) Needs and priorities for particular types of activities within
the broad eligibility limitations of Chapter 2.
(2) HUD resources available for implementation of MIFIH plan activities
and regular program servicing.
(3) Expertise of specific program offices, Regional Training Officers, etc.
(4) IHA's views regarding substance and methods for implementing their
MIFIH program.
(5) Non-HUD resources which might be used for training, technical assistance
and/or supplementary funding:
(a) The IHAs
(b) Other organizations
(c) Educational institutions
(d) Private firms
(e) Individuals
(6) The mix of types and methods of training and technical assistance
activities which will best serve IHAs within the REgion and the degree
to which training is needed and to which technical assistance is needed.
(a) Training methodologies to be used will be determined (formal courses,
workshops, practical exercises, site visits, and on-the-job training)
(b) The extent to which group training sessions should be utilized will
be determined.
(7) Group Training Sessions planned should give consideration to:
(a) IHA input as to participants to be included.
(b) IHA input as to identification of trainers.
(c) Regional office plans to involve potential trainers in training
sessions.
(8) A schedule for program implementation is to be included in the Regional
Strategy with consideration of:
(a) Condition of regular IHA responsibilities and functions within
the Region (budget preparation, development processes, etc.)
(b) The sequence for development and processing MIFIH plans.
(9) Issuances to HUD Personnel and/or IHAs needed to supplement Central HUD
issuances.
b. Each IHA will prepare a plan for its individual activities and group
participation.
(1) Plan provides basis for program funding and implementation.
(2) Organization selected as Trainer will prepare its curriculum for group
training sessions.
(3) Regional Office approval of IHA plans and Trainer curriculum is required.
-2-
C. Funding includes FY75 TPP allocation to 124 IHAs and additional
allocations from FY76 MIFIH funds.
(1) IHA's plan will include its estimate of total funding required.
(2) No distinction between FY75 and FY76 funds shall be made for use
in training and technical assistance.
(3) All obligations of funds to IHAs must be completed by September 30, 1976.
(4) Funds will be disbursed to IHAs as needed to implement their approved
MIFIH plans. All funds must be disbursed directly to IHAs.
(5) All activities to be funded by this program are to be completed
within two years of the start-up of an IHA's approved plan.
d. Public notification, as determined by each Region, must be given of the
opportunity existing to participate as a Trainer.
CHAPTER 2. ELIGIBLE MIFIH ACTIVITIES
7. Each IHA's MIFIH plan shall constitute a coherent package of training and
technical assistance, tailored to the IHA's particular needs. MIFIH funds
shall be used only to finance those training and technical assistance activities
included in the IHA's approved MIFIH plan.
a. Eligible TRAINING related expenditures cover:
(1) Transportation
(2) Per Diem
(3) Registration fees for courses or seminars
(4) Reimbursement for hired Trainers'
(5) Charges for equipment, books and other teaching aids
(6) Other expenses related to specific training which is justified in
the IHA's MIFIH plan.
b. Eligible trainees
(1) IHA personnel
(a) Commissioners
(b) Executive Directors
(c) Key IHA employees
(2) Other personnel to the extent necessary when funds are not otherwise
available.
(a) Tribal Chairmen (or their designees)
(b) Fee Accountants
(c) IHA Lawyers
(d) Mutual Help Contractors
8. Eligible Training Activities
a. The following types of training shall be included, as adapted to the needs
of the particular IHA:
(1) Orientation - for Commissioners and Executive Directors. Key officials
of the Tribal Council and its community development agencies and social
service agencies should be included subject to the availability of funds
from their own budgets - MIFIH funds shall not be used to cover travel
and per diem expenses for such officials. Orientation training should
cover at least the following subjects:
(a) Fundamentals of low-income public housing.
(b) Responsibilities of the IHA.
(c) The relationship between the IHA and HUD.
(d) The roles of the BIA and IHS in development and operation.
(e) The relationship between the Tribal Council and the IHA.
(f) The rights and duties of tenants and homebuyers.
-3-
(2) Technical Training - detailed and highly practical instruction for
Executive Directors and other key IHA employees in subjects pertinent
to everyday tasks and responsibilities for which the IHA has identified
a need. Commissioners, IHA Accountants, lawyers and contractors may
be included for appropriate subjects. The instruction must lead to
the employee's being able to perform the necessary tasks. The following
subjects shall be covered in the depth necessary to address the needs
of the particular IHA:
(a) General management functions.
(b) Occupancy functions.
(c) Financial management.
(d) Maintenance and Utilities functions.
(e) Supply management.
(f) Modernization functions.
(g) IHA/resident relations.
(h) Administration of development programs.
b. Any training method, or combination of methods, may be used provided that
HUD determines the total training program to be genuinely effective, workable,
and reasonably economical.
(1) Group training is strongly recommended where common needs exist.
(2) Other training methods which may be used to supplement group training:
(a) Participation in courses and conferences
(i)
Sponsored by HUD field offices
(ii)
Sponsored by HUD training centers
(iii) Sponsored by educational institutions
(iv)
Sponsored by management organizations
(b) Intra-IHA Courses
(c) On-the-job training
(d) Educational visits to other IHAs
(e) Educational visits to non-Indian Public Housing Agencies
9. Eligible TECHNICAL ASSISTANCE Activities
a. Technical assistance is limited to the areas of administration or management
of housing operations listed below. Only incidental attention may be given
to related aspects of housing development.
(1) First priority in technical assistance shall be given to assistance
in bringing financial accounts and records to an auditable condition
and to training IHA staff to continue such accounting practices without
further outside supervision.
(2) Second priority in technical assistance shall be given to other aspects
of financial management
(a) General financial planning
(b) Preparation and use of operating budgets
(c) Methods for cost control
(d) Collection of rents and homebuyer payments
(e) Other
(3) Third priority for technical assistance shall address needs in other
operational areas
(a) Occupancy
(b) Maintenance and utilities
(c) Supply management
(d) Modernization
(e) IHA/resident relations
b. Types of Technical Assistance
(1) Professional services which the IHA demonstrates will effectively and
economically address a genuine need and will be performed by persons
genuinely qualified to do so.
-4-
(a) Accountants
(b) Management Technicians
(2) Additional staff may be temporarily employed for "catch-up"
for a period not to exceed two years. Specific HUD approval is
required. Such employment shall not include additional maintenance,
security or social service personnel.
10. MIFIH funds shall NOT be used to fund the following types of items:
a. Cost of maintenance, repairs and capital improvements
b. Cost of security programs or social service programs
C. Increases in salaries and benefits to IHA employees
CHAPTER 3. DEVELOPMENT, SUBMISSION, REVIEW AND
APPROVAL OF IHA PLANS AND FY76 FUND
OBLIGATIONS
11. HUD Regional Office Procedures
a. Upon approval of the Regional Strategy by the RA and concurrence by
CARF-IPP, the ARA will authorize each eligible IHA to proceed with
development of its MIFIH plan. This letter of authorization will
include:
(1) Specific instructions for submission of the plan, including timeframe
(2) Statement of the Regional Office's assessment of the IHA's preliminary
needs
(3) A summary of the REgional Strategy as it relates to the IHA, including
recommendations as to the IHA's participation in group training sessions
(4) Resources available for consideration by the IHA in choosing its
training
(5) A statement of the amount of FY75 MIFIH allocation made to the IHA
b. Review of plan submission
(1) Copies of the IHA's plan shall be routed by the ARA for comments and
recommendations to:
(a) Regional Indian Coordinator
(b) Offices of program areas pertinent to any portion of the IHA's
plan
(2) IHA's plan will be reviewed according to specific criteria for
evaluation in accordance with Appendix 2
(3) If APPROVAL of the IHA's plan is indicated, the ARA secures a
prevalidation of funds from Regional Accounting Division and submits
evidence of this prevalidation, the IHA's plan, the ARA's comments
and recommendations and a letter for the RA's signature obligating the
prevalidated funds all to the RA for review.
(4) If the proposed plan DOES NOT MERIT APPROVAL, the ARA shall immediately
advise the IHA and make reasonable effort to obtain an approvalable
resubmission.
(5) If the September 30 deadline for obligation of funds does not allow
sufficient time to obtain an approvable resubmission, the ARA shall
proceed to prevalidate and obligate funds to all IHAs, based on the
best estimates he has of the funds necessary.
c. Final approval of the IHA's plan by the RA may be conditioned on modification,
deletions and/or additions
d. A letter of obligation of TPP/MIFIH funding shall be sent to the IHA by
September 30, 1976, even if some MIFIH plans have not been approved. A separate
letter will be sent to the IHA regarding approval of its plan. NOTE: Two
distinct letters - one obligating funds and another approving the IHA's MIFIH
plan are involved. Training cannot begin until the plan approval letter is
received by the IHA.
-5-
e. ARA will send CARF-IPP, by October 29, 1976, a list of the IHAs involved,
the amounts of FY75 and FY76 TPP funds obligated to each, a list of all
approved trainees, the needs to be addressed at each session and the names
of IHAs included in each training group. Eligible IHAs not participating
in MIFIH shall be listed with the reasons for their non-involvement being
given.
12. IHA Procedures
a. The IHA's individual plan shall follow the points included in the ARA's
letter announcing the Regional Strategy and shall follow the following
format:
(1) Needs of the IHA should be stated realistically and all-inclusively,
even if sufficient MIFIH funding to fill all needs is not anticipated.
(2) Each training and technical assistance activity proposed is to be
listed in order of priority. Participation in group training sessions
shall be noted after consultation with the Regional Office and the
Trainer. Each activity description shall include:
(a) Needs which will be addressed
(b) Individuals to be trained
(c) Methodology/techniques to be utilized
(d) Evaluation criteria
(3) Schedule of beginning and completion dates of each training and
technical assistance activity planned. Completion should be
scheduled within two years from beginning date.
(4) Training resources to be utilized should be identified and their
qualifications should be documented.
(5) A revision of the IHA's current Operating Budget including supporting
data showing the total MIFIH funding requested for each activity and
the total anticipated expenditures in each of the following categories:
(a) Contracts for services
(b) Travel and per diem expense
(c) Salaries and benefits
(d) Procurement of facilities, supplies and equipment
(e) Other identified expenditures
NOTE: This supporting data to the Operating Budget revision becomes
the MIFIH Program budget.
(6) A description of the expertise/skill each participant is expected
to gain from each acivity, as percieved by both the IHA and the Trainer,
and a plan for monitoring and evaluating each activity.
(7) A resolution by the IHA's Board of Commissioners in the form prescribed
in Appendix 1
13. IHA Group Training Sessions
a. In order to obtain stronger training programs, groups of IHAs in various
parts of the country may join together for a common training program.
b. Subject to the Regional Strategy, two or more IHAs who share a common need
may form training groups. The following points are pertinent to such group
formations:
(1) Training sites within the area covered by such IHAs should be conveniently
and economically accessible.
(2) IHAs in a training group should be compatible in terms of training needs,
skill/knowledge levels and other relevant factors.
(3) Inter-regional efforts may be worked out with the approval of both RAs.
C. Overall responsibility for planning and carrying out group training programs
shall be the function of an individual, an agency or an organization (the
Trainer) who is mutually acceptable to the IHAs involved and the ARA. The
following points are pertinent to the selection of a trainer for each
training program:
-6-
(1) A HUD-IHA consensus as to the selection of the trainer shall be
reached by consultations between the ARA and the IHAs involved.
(2) The trainer is to consult with the IHAs involved, the ARA and others
having significant roles in the training program in the preparation
of its proposed training curriculum.
(3) The training program must be genuinely effective and reasonably
economical. Its substance must be sufficient for practical, accurate,
in-depth coverage of all subject matters related to the administrative
and management needs of the IHAs involved. It must be effective in
imparting practical knowledge.
(4) The format of each training program shall contain the following elements:
(a) Detailed description of each training session
(i)
intended training audience
(ii)
the purposes and measurable objectives of each major
block of instruction
(iii)
detailed daily schedules showing each subject to be
covered, methods of instruction and the name of the
person or persons to be used as instructor
(b) An administrative plan including:
(i)
the dates of each training session
(ii)
the places for each training session including arrangements
for meeting facilities, equipment, participants' lodging
and meals
(iii)
the IHA and position of each trainee expected to participate
in each training session
(iv)
the names of the trainer's representative to administer
each training session
(v)
plans for publicizing (selling) the training program and
each training session to assure full IHA participation
and support
(c) A monitoring and evaluation plan
(d) A brief statement of each instructor's qualifications
(e) An administrative budget detailing the trainer's expenses
(f) An estimate of each participating IHA's costs
(g) The trainer's certification regarding performance and HUD's
reservation of the right to terminate funding
(5) Exact arrangements for date, location, facilities and instructors
may be deferred until trainer's plan has been approved.
CHAPTER 4. IMPLEMENTATION OF PLANS
15. Upon receipt of the RA's letter to the IHA approving the priorities and schedule
of activities, the IHA shall proceed with implementation of its plan. Any changes
in the schedule must be reported in writing to the ARA.
16. Monitoring and evaluation by the IHA and trainer shall be performed in accordance
with its approved MIFIH plan. HUD Regional monitoring and evaluation shall be
the responsibility of the ARA.
17. Reports to HUD
a. From IHAs - narrative quarterly reports to ARA
b. From Trainers - evaluation reports on each participant at the conclusion of
each session
c. ARA shall distribute copies of report to:
(1) Regional Indian Coordinator
(2) CARF-IPP
(3) Program offices involved in curriculum development
-7-
18. Notification of changes shall be made by ARA to IHAs when any change in IHAs'
plans are necessary.
19. Final evaluation report of the total effort shall be made by each IHA and
trainer at completion of all funded activities.
20. Financial reporting shall be in accordance with normal HUD financial reporting
requirements.
-8-
PARTMENT OF HOUSING AND URBA EVELOPMENT
(
WASHINGTON, D.C. 20410
OFFICE OF THE ASSISTANT SECRETARY FOR
JUN 29 1976
HOUSING-FEDERAL HOUSING COMMISSIONER
IN REPLY REFER TO:
Mr. Tim Foster
Chairman
National American Indian Housing
Council
Post Office Box 215
Stewart, Nevada 89437
Dear Mr. Foster:
Thank you for your letter of May 18, 1976, regarding the
National American Indian Housing Council's proposed role in
"Management Initiatives for Indian Housing" (MIFIH), the Depart-
ment's new effort to provide training and technical assistance
for Indian Housing Authorities.
I appreciate your kind remarks about my responsiveness to
Indian needs. In my present position, I do indeed continue to
be concerned about Indian needs, and especially the need to improve
the capability of Indian Housing Authorities to manage their
programs in a way which will assure quality housing for low-income
Indian families over the long term. Various members of my staff,
as well as myself, are familiar with the NAIHC, and hold a high
opinion of you and other officials of the NAIHC.
As you may already know, the primary Departmental responsi-
bility for MIFIH has been assigned to the Assistant Secretary for
Consumer Affairs and Regulatory Functions, Mrs. Constance B. Newman.
While we in Housing Management are continuing to take a deep interest
in this program, Mrs. Newman has the lead role in further program
development and implementation. In view of this, I have forwarded
your letter to Mrs. Newman, with the request that she provide you
with a further response.
Sincerely,
for
ABNER D. SILVERMAN
NATIONAL
AMERICAN
INDIAN
HOUSING COUND
James L. Young
Assistant Secretary
JJL 2 1976
ing Assistance
MAY 17 1976
Monorable Constance Newman
Assistant Secretary for Consumer Affairs
Department of Housing and Urban Development
451 Seventh Street, S.W.
Washington, D. C. 20410
Dear Ms. Newman:
It was a pleasure to meet with you the other day and discuss your
responsibilities for Indian housing programs, especially the education
and training of housing authority staff.
We again wish to emphasize the capabilities of several Indian housing
authorities with personnel who have the knowledge and the experience
to carry out their duties properly, efficiently, and ffectively.
Several of these people are working with the National American Indian
Housing Council (NAINC) to develop a training proposal which would
enable those housing authorities that wish to use the knowledge and
expertise of the NAIHC to do so with their Target Project Program (TPP)
funds.
The NAIHC has been working on this training proposal since former
Secretary Crewford advanced the idea at the Reno meetings in June of
1975. As I mentioned, they are fortunate to have on their staff
several people with degrees in education, knowledge and experience
in the programs of HUD and the operations of the local Indian housing
authorities. This combination of abilities gives them # very unique
position in understanding IHA management and administration problems.
We propose to assist the NAINC in expanding their proposal and fund the
necessary coordination, development, and arrangement of the materials for
the training package. Our assistance, of course, would be contingent on
your acceptance of the NAINC as a designated training entity.
We look forward to working with you on the Indian housing program.
Sincerely yours,
(Sad) Harley M. Frankel
Deputy Commissioner of Indian Affairs
CC: Tom Sherman, HUD, Office of Publicly Financed Housing
Dennis Blair, Office of the Secretary, HUD
Loie Brooks, NAIHC
Ron Fromen, NAIHC
PEAKE 5/11/76
KRENZKE 5/12/76
Leg Assistance
MAY 17 1976
Menorable Constance Newman
Assistant Secretary for Consumer Affairs
Department of Housing and Urban Development
451 Seventh Street, S.W.
Washington, D. C. 20410
Dear Ms. Newman:
It was a pleasure to meet with you the other day and discuss your
responsibilities for Indian housing programs, especially the education
and training of housing authority staff.
We again wish to emphasize the capabilities of several Indian housing
authorities with personnel who have the knowledge and the experience
to carry out their duties properly, efficiently, and effectively.
Several of these people are working with the National American Indian
Housing Council (NAINC) to develop 8 training proposal which would
enable those housing authorities that wish to use the knowledge and
expertise of the NAIHC to do so with their Target Project Program (TPP)
funds.
The NAIHC has been working en this training proposal since former
Secretary Crawford advanced the idea at the Reno meetings in June of
1975. As I mentioned, they are fortunate to have on their staff
several people with degrees in education, knowledge and experience
in the programs of HUD and the operations of the local Indian housing
authorities. This combination of abilities gives them a very unique
position in understanding IHA management and administration problems.
We propose to assist the NAIMC in expanding their proposal and fund the
necessary coordination, development, and arrengement of the materials for
the training package. Our assistance, of course, would be contingent on
your acceptance of the NAINC as a designated training entity.
We look forward to working with you on the Indian housing program.
Sincerely yours,
(Sad) Harley M. Frankel
Deputy Commissioner of Indian Affairs
CC: Tom Sherman, HUD, Office of Publicly Financed Housing
Dennis Blair, Office of the Secretary, HUD
Loie Brooks, NAIHC
Ron Froman, NAIHC
30th August 1976.
Dear Mr. Patterson:
Hi! Enclosed is a copy of the comments I drafted for HUD's
concurrence with the inter-Departmental Memorandum of Understanding
which I mentioned to you last week. Unfortunately a copy of
the Memorandum itself was not in either the Division or Offices'
files: I am trying to find one and will send it along to you
when it's discovered.
This morning I met with Reaves Nahwoosky, Director of HUD's Office of
Indian Policy and Programs, in order to complete some information
needed to respond to the annual Indian Reorganization Act report
of planned allowances that will benefit Indian tribes--and I've
just finished the draft of HUD's submission.
A good contact for information about Indian housing &c within
HUD would be Dennis Blair, a Special Assistant to Secretary Hills.
Several times I've seen and/or responded to notes from him
regarding Indians.
Later in the week I'll give you a call. The weather's so great
outside--brisk, clear--that I felt like taking a 2-hour walk-and-run
during lunch. Maybe D.C. isn't so bad as I'd been told.
Yours,
Ray
FORD & LIBRARY 074839
COMMENTS ON INTERAGENCY MEMORANDUM OF UNDERSTANDING ON
CLEARANCES FOR INDIAN HOUSING PROJECTS
The Office of Budget concurs with the proposed Memorandum of
Understanding provided it contains no agreements or understandings
that the Department will have funding responsibility for "recovery,
protection, or preservation of scientific, prehistorical, or
archaeological data," as described in the fourth paragraph of the
memorandum. Our specific concern relates to the source of funding
to support such activity. We are not aware of any source of funds
for these purposes. We are also concerned by the fifth
paragraph which indicates that the Indian Housing Authority may
utilize preliminary loan funds to conduct surveys "to determine if
any part of a project will affect scientific, prehistorical,
historical, or archaeological properties or data." We believe that
this may not be an eligible cost for the use of preliminary loan
funds and we recommend that the Office of General Counsel be consulted.
It is our understanding that the financial and technical
assistance to be provided by HUD, under the terms of the proposed
memorandum, is consistent with existing Departmental procedures and
thus would not require extraordinary efforts and no additional staff
resources are anticipated. It is our further understanding that
no additional costs will be borne by the Department as a result of
the Environmental Impact Statement requirement mentioned in the
memorandum.
The agreement should not be signed until and unless the fourth
paragraph is changed, as indicated above; the legal question resolved;
and both HPMC and CARF agree that there will be no additional staff
or administrative expense resulting from it. In this connection,
we note that there appears to be no CARF involvement in this agreement.
Since CARF now has overall responsibility for Indian matters, they
should be consulted.
co
Co
6/1/76
FORD LIBRARY is 938839
MEMORANDUM
OF CALL
TO:
Mr. Callerson
YOU WERE CALLED BY
YOU WERE VISITED BY-
OF (Organization)
Gay Millard
PHONE NO.
PLEASE CALL
CODE/EXT.
WILL CALL AGAIN
IS WAITING TO SEE YOU
RETURNED YOUR CALL
WISHES AN APPOINTMENT
MESSAGE
755-7287
6/1 medicatory Mino of
RECEIVED BY
DATE
TIME
STANDARD FORM 63
GPO :1969-c48-16-60341-1 : 832-389
63-108
REVISED AUGUST 1967
GSA FPMR (41 CFR) 101-11.6
7/27/76 Dol a
18 a
HEU
MEMORANDUM
OF CALL
TO:
YOU WERE CALLED BY-
YOU WERE VISITED BY-
OF (Organization)
PHONE NO.
PLEASE CALL
CODE/EXT.
WILL CALL AGAIN
IS WAITING TO SEE YOU
RETURNED YOUR CALL
WISHES AN APPOINTMENT
MESSAGE
Constance
newman
755-0950
RECEIVED BY
DATE FORD JBRAB
TIME
STANDARD FORM 63
GPO 1969-c48 16 80341-1 332-280
63-108
REVISED AUGUST 1967
GSA FPMR (41 CFR) 101-11.6
143
MEMORANDUM
OF CALL
TO:
Brad Patterson
YOU WERE CALLED BY-
YOU WERE VISITED BY-
OF (Organization)
PLEASE CALL
PHONE NO.
CODE/EXT.
WILL CALL AGAIN
IS WAITING TO SEE YOU
RETURNED YOUR CALL
WISHES AN APPOINTMENT
MESSAGE
Ronald Peake
not ill town. miss
melen Parkel from
Interear returning callfal
343-4876
mr. Peach
RECEIVED BY
Franne Mclear
DATE
TIME
Dept 15.
10:40
STANDARD FORM 63
REVISED AUGUST 1967
GPO :1969-c48-16-80341-1 332-389
63-108
GSA FPMR (41 CFR) 101-11.6
DEPARTMENT OF THE INTERIOR
Bureau of Indian Affairs
WASHINGTON, D.C. 20242
MEMORANDUM FROM:
DATE 9/16/76
Division of Housing Assistance
TO: Mr. Brad Patterson
As per your request, enclosed are
copies of correspondence on the
NAIHC training proposal. There were
few more papers on this subject,
however, Mr. Peake has them in his
6
brief case and will bring them to you
on Monday.
The Target Project Program (TPP) mentioned
in the Commissioner's letter is now
called "Management Initiatives for Indian
Housing Programs (MIFIH). A copy of
MIFIH Handbook is also enclosed.
With best regards,
Meline
Enclosures
LD P. LLGRARY FORD
Meline P. Parker
Housing Program Specialist
DEPARTMENT OF THE INTERIOR
Bureau of Indian Affairs
Washington, D.C. 20245
202 343-4876
INTERIOR. HASKELL PRESS. 4-69-69-2500
U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
Consumer Affairs and Regulatory Functions
TRANSMITTAL
7440.2
July 30, 1976
FORD
1. This Transmits:
Handbook 7440.2 Management Initiatives for Indian Housing Program
2. Explanation of Material Transmitted:
This handbook prescribes the procedures to be followed in the
development, submission, review, implementation and evaluation of
plans for training and technical assistance, to be utilized
towards improvement of the administrative capabilities of Indian
Housing Authorities in the operation of their low-income housing
program. This handbook also sets forth procedures to be used
by HUD in the development of Regional strategies, which will
serve as preliminary guidelines for the formation of group train-
ing sessions and individual IHA training plans.
Consideration is being given to including in MIFIH training, IHAs
which have no units in management. Therefore, there shall be
included in the Regional strategies (Chapter 1, paragraph 6a) an
itemization of the number of IHAs which have no units in
management, their training needs and the anticipated fund require-
ments. Within this total a further breakdown shall include:
(1) those IHAs having at least one project under ACC; (2) those
IHAs having at least one Program Reservation but no projects under
ACC; and (3) those IHAs having an application submitted but no
Program Reservation. For IHAs in the third category, please
also identify the scheduled date for HUD action and whether a
Program Reservation is anticipated.
3. Filing Instructions:
Insert:
7440.2, dated 7/30/76
MI:DISTRIBUTION: W-1, W-2, W-3-1, R-1, R-2, R-3-1(HM, HPMC.
Indian Specialists), R-5, Indian Housing
Authorities
7/76
UNBRIN AND U. * S. U.S. ANISUOH OF OFFARTMENT
7440.2
MANAGEMENT INITIATIVES
FOR
INDIAN HOUSING PROGRAM
JULY 1976
PROGRAM PARTICIPANTS AND HUD STAFF
A HUD HANDBOOK
U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
WASHINGTON, D.C. 20410
MI: DISTRIBUTION: W-1, W-2, W-3-1, R-1, R-2, R-3-1 (HM, HPMC, INDIAN SPECIALISTS)
R-5, INDIAN HOUSING AUTHORITIES
7440.2
TABLE OF CONTENTS
Paragraph
Page
CHAPTER 1. INTRODUCTION
1.
Purpose
1
2.
Background
1
3.
Eligible IHAs
2
4.
Concept of MIFIH
2
5.
Responsibilities
3
6.
Operation of the MIFIH Program
5
CHAPTER 2. ELIGIBLE MIFIH ACTIVITIES
7.
General
11
8.
Eligible Training Activities
11
9.
Eligible Technical Assistance Activities
16
10.
Ineligible Expenditures
17
CHAPTER 3. DEVELOPMENT, SUBMISSION, REVIEW
AND APPROVAL OF IHA PLANS AND
FY 1976 FUND OBLIGATIONS
11.
Regional Procedures
19
12.
IHA Procedures
21
13.
IHA Group Training Sessions
23
14.
Reserved
27
CHAPTER 4. IMPLEMENTATION OF PLANS
15.
Implementation by IHA
29
16.
Monitoring and Evaluation
29
17.
Reports to HUD
29
18.
Notification of Changes
30
19.
Final Evaluation
30
20.
Financial Reporting Requirements
30
21.
Reserved
30
i
7/76
HUD-Wash., D.C.
7440.2
Paragraph
Page
Appendixes
1.
Sample IHA Board Resolution
2.
Criteria for Evaluation of MIFIH Training Plans
3.
Sample IHA Obligation Letter
4.
Accounting and Financial Reporting Requirements for
TPP/MIFIH Program
4a.
Form HUD 54005, Requisition for Partial Payments
of Operating Subsidy, Target Projects Program (TPP)
5.
Flow Chart for Management Initiatives for Indian Housing
Program
7/76
ii
HUD-Wash., D.C.
MANAGEMENT INITIATIVES
FOR
INDIAN HOUSING PROGRAM
7440.2
CHAPTER 1. INTRODUCTION
1.
PURPOSE. The purpose of this Handbook is to prescribe
requirements and guidelines for the Management Initiatives
for Indian Housing (MIFIH) Program, a short-term (two-year)
program designed to provide management assistance to Indian
Housing Authorities (IHAs). Although the funding is made
through the Target Projects Program (TPP), and its accounting
instructions are to be followed, the regular (non-financial)
administrative reporting procedures of TPP are not applicable.
2.
BACKGROUND.
a.
The fundamental goal of Federal low-income housing programs
is to provide decent, safe, and sanitary housing for low-
income families. The IHA has the key role in this endeavor
because it must evaluate local needs and conditions, coordin-
ate the functions of all involved local and Federal agencies
and carry out the day-to-day tasks which are necessary
to the effective administration of a local housing program.
In signing an Annual Contributions Contract (ACC) with HUD,
the IHA assumes the legal responsibility for the
administration of its housing program. This reflects
the Federal housing policy of maximum local autonomy, and
is reinforced by the policy of Indian Self-Determination
as expressed in P.L. 93-638, the Indian Self-Determination
and Education Assistance Act. (25 U.S.C. 450e(b).
b.
The intent of the program, as expressed in the initial
press release announcing this special TPP set-aside for
IHAs, indicates that the funds will be used to "defray
expenses of those IHA employees participating in management
training approved by HUD The general concept and direction
will focus on detailed technical training in the practical
knowledge that IHA employees must master in order to do
an effective job in their day-to-day management responsi-
bilities."
C. With continuing construction programs in progress and the
recent publication of new regulations for HUD's Indian
Housing Program (24 CFR, Part 805), the need for adequate
IHA administrative capabilities becomes increasingly
Page 1
7/76
HUD-Wash., D.C.
7440.2
important. The regulations refer to this need as
a prerequisite for application approval (Section
805.207), and it is explained more fully in HUD's
Interim Indian Housing Handbook, 7440.1, (paragraphs
2-5(a) (3) and (4) and (c).
d. An additional factor which has been taken into
consideration in the obligation of these funds, is the
realization that, although HUD's Office of the Inspector
General will take over the primary responsibility for
audits of IHA financial records, many IHAs do not have
their records in auditable condition. Thus it becomes
not only a question of improving such an IHA's staff
ability to maintain adequate records, but an urgent
need to provide technical assistance to help the staff
construct their records in order to be ready for audit.
3.
ELIGIBLE IHAs. This program is applicable only to those
124 IHAs which received TPP/MIFIH money in FY 1975, plus
any additional IHAs which will be specifically approved on
the basis of the status of their programs. (See Transmittal
Notice). No other housing authorities are eligible to
receive FY 1976 funding for this program. This Handbook
does not apply to Alaskan IHAs, as that State has been
separately funded and already has a management improvement
program in effect.
4.
CONCEPT OF MIFIH. Currently MIFIH constitutes a special
short-term (two-year) catch-up effort for IHAs to improve
upon their administrative capabilities to the point where they
are substantially better equipped to carry out the operations
and administration of their housing programs at a level
acceptable to HUD. It is anticipated that such improvements
also will contribute to a more satisfactory living environment
for the communities affected. The following points are basic
to the concept of this program.
a. MIFIH will concentrate on housing operations -- i.e.,
housing management but will also include training
to improve IHA capabilities to administer housing
development programs, specifically in relation to the
new Indian Housing Program regulations, and to take
appropriate roles in the local community planning and
development process.
7/76
Page 2
HUD-Wash., D. C.
7440.2
b.
MIFIH will be devoted to administrative or management
capabilities, through training and technical assistance
in basic functional areas of operational management
(e.g., financial management, accounting, rental and
occupancy functions, personnel management and utility
functions, supply management, modernization and
resident-management relations) plus training in
administration of housing development functions.
Chapter 2 sets forth in more detail the eligible
activities for training and technical assistance.
C. MIFIH is a "software" program, directed at improvements
in management systems and procedures; except that some
limited "hardware" features may be included, incidental
to the software aspects. MIFIH will not be used to
fund deferred maintenance or physical improvements, nor
can it fund social services and security, although
some aspects of the program may impact upon these areas.
See Chapter 2 for further detail.
d.
Program performance will be closely monitored by the
IHAs and trainers, as well as by HUD, in order to measure
the effectiveness of MIFIH activies, control disbursements
of MIFIH funds, and enable the IHAs and HUD to take
prompt remedial action when merited. In addition, close
evaluation by HUD Central Office will be necessary in
order to determine, justify and respond to, where possible,
needs for additional training.
e. MIFIH stresses IHA initiatives in identifying local
problems and recommending to HUD the manner in which
they propose to solve those problems. The plans for MIFIH
activities and expenditures are subject to HUD approval,
in accordance with the standards and requirements of this
Handbook, but each IHA's plan shall be viewed from the
perspective of the individual IHA. This approach, then,
will permit individual IHA training and technical
assistance, and/or group training efforts for several
IHAs on either general orientation-type or specific
subjects.
5.
RESPONSIBILITIES.
a.
Central Office.
(1) The Office of the Assistant Secretary for Consumer
Page 3
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HUD-Wash., D. C.
7440.2
Affairs and Regulatory Functions (CARF) has
responsibility for the implementation, monitoring
and evaluation of the MIFIH Program. Communications
and written reports from the field shall be trans-
mitted to this Office, Attn: Director of Indian
Policy and Programs (IPP). Information copies shall
be forwarded by CARF to the Office of Housing.
(2) The Office of the Assistant Secretary for Housing
has responsibility for the assignment, administration
and monitoring of MIFIH funds. Normal HUD budgetary
reporting requirements shall be carried out with
this Office, Attn: Director of Housing Programs (OHP)
unless otherwise so directed. Information copies
shall be forwarded by Office of Housing-OHP to CARF-IPP.
b. Regional Office.
(1) Subject to the normal authority of the Regional
Administrator to delegate, the Assistant Regional
Administrator for Housing Management shall have
primary responsibility for the administration of the
MIFIH program, except in Regions VIII and IX, where
it rests with the Assistant Regional Administrator
for Indian Programs. Such responsible Assistant
Regional Administrator is hereafter referred to simply
as the "ARA".
(2) Regional Office Indian Coordinators or Special
Assistants shall be involved in all levels of
development of regional strategy and program
implementation. The concurrence of the Coordinator
must be secured as a prerequisite to forwarding any
document for RA approval.
C. Area and Insuring Offices. Responsibility at this
level shall be determined by the Regional Office, subject
to normal operating delegations, and may cover the total
program, including funding obligations.
7/76
Page 4
HUD-Wash., D.C.
7440.2
d.
Indian Housing Authorities.
(1) The Executive Director has the primary role in the
development of the IHA's plan. As the day-to-day
coordinator of IHA activity and staff supervisor,
this individual is in the best position to determine
the IHA's needs, in consultation with HUD.
(2) The IHA Board of Commissioners is responsible for
reviewing and approving the plan, including any
group training session which their Chairman will
attend. A resolution shall be passed indicating
that the Board has reviewed and approved the plan,
and stating its assurances that the finally approved
plan will be diligently and effectively carried out
and that the IHA will comply with all applicable
HUD requirements, and also stating that the Board
understands and agrees that HUD reserves the right
to terminate funding for the IHA's program if the IHA
fails to carry out its responsibilities under the
approved plan. (Appendix 1). The Chairman of
the Board has the further responsibility of securing
acceptance of the IHA's plan by the Tribal Council,
including verification of any participation required
of the Tribal Chairman.
e.
Regional IHA Associations. While these organizations
are not specifically responsible for any part of the
program, the Executive Director may, in consultation with
the Board of Commissioners, designate a formal role for their
Association. The ARA shall be so advised by IHA resolution.
6.
OPERATION OF THE MIFIH PROGRAM. Subject to the standards
and requirements prescribed in the further provisions of this
Handbook, the following is a general, introductory description
of how MIFIH will be carried out:
a. Regional Strategy. In recognition of the key responsi-
bilities of Regional Offices and the differences in the
pertinent conditions which prevail in different parts of
the country, this Handbook allows each ARA liberal
discretion in adapting MIFIH to the particular Region.
MIFIH thus creates a unique opportunity for Regional
Offices to use the program as a tool to effect the kinds
of concrete improvements in IHA administrative capabilities
Page 5
7/76
HUD-Wash., D.C.
7440.2
which those offices see as most urgently needed.
Accordingly, a preliminary step in implementing MIFIH
shall be for each Regional Office to develop its own
program strategy to serve as an overall planning and
implementation guide to supplement this Handbook.
Immediately upon publication of this Handbook, each ARA
shall begin development of such a Regional strategy.
When completed, a written plan shall be submitted to
the Regional Administrator for approval, and to CARF-IPP
for concurrence. Among the major considerations which are
pertinent to the development of such a strategy are the
following:
(1) Needs and priorities for particular types of
activities within the Region, within the broad
eligibility limitations of Chapter 2.
(2) HUD resources available to administer MIFIH,
and to provide training and technical assistance
to IHAs, both as resources for implementation of
MIFIH plan activities, and as regular, long-term
program servicing. For example, it may be necessary
or desirable for Regional and/or Area Office personnel
(including Regional Training Officers) (RTOs) to take
part in some MIFIH training activities as resource
persons. Consideration should be given to the need
for assignment of specific responsibilities within
the Region, and the relationships of Regional and
Area Office functions.
(3) The expertise of specific program offices should be
utilized in the development of pertinent training
session curricula, in order to confirm that the sub-
ject matter covered conforms to the HUD office
program expectations and requirements; e.g., Fincancial
Management Specialists and accountants should provide
advice and assistance in the development of a
financial management session, RTOs should provide
input in training design, etc.
(4) IHA's views regarding the substance and methods
for implementing the program. While MIFIH plans
must meet the basic standards prescribed in this
Handbook, plus any Regional Office requirements which
may be prescribed as part of their strategy, there
7/76
Page 6
HUD-Wash., D. C.
7440.2
shall be great latitude for accommodating the
views of the IHAs themselves. Regional Offices
are encouraged to allow the IHAs the greatest
degree of initiative which is consistent with
effective and economical program development and
FORD
performance.
(5) Non-HUD resources which might be used, including
SLD
LIDRARY
the resources and expertise of the IHAs themselves,
other organizations, educational institutions,
private firms and individuals, to provide training
and technical assistance services to contribute
to implementation of MIFIH plans. This assessment
should also include sources for supplementary
funding. Appendix 2 provides criteria for Regional
Office use in approval of trainers.
(6) The mix of particular types and methods for
training and technical assistance activities
which would best serve the needs of the IHAs
within the Region. This should include consideration
of the degree to which training versus technical
assistance is needed. In considering training,
thought must be given to the extent to which
different methodologies (e.g., formal courses
or workshops, practical exercises, site visits, on-the-
job training) would be most effective. Within that
context, consideration must be given to the extent
to which IHA group training sessions should be
utilized. If, for example, the ARA recognizes a need
for financial management training on the part of all
the IHAs in his Region, he may recommend to the
IHAs that they all participate in such a session.
(7) Where IHA group training programs are deemed desirable,
consideration shall be given to the participants of
IHA training groups and the identification of trainers,
subject to input of the IHAs. Consideration must be
given to the method by which the Regional Office plans
to publicize the opportunity for potential trainers
to be involved in group training sessions. A general
orientation for IHA Chairmen of the Boards of
Commissioners, Executive Directors and Tribal
Chairmen of all IHAs on a regional basis is highly
Page 7
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HUD-Wash., D. C.
7440.2
recommended. This session should relate the
roles and responsibilities of these officials to
the development and operation of HUD-assisted
housing projects.
(8) A schedule for program implementation, appropriate
to relevant conditions within the Region, including
those regular responsibilities and functions of the
IHAs, e.g., budget preparation and development
processes. Attention must be given to the sequence
for development and processing of MIFIH plans.
See Chapter 3.
(9) Need for Regional Office issuances to supplement,
where necessary, Central Office issuances to be
provided to HUD personnel and/or IHAs.
b. Written plans for MIFIH activities will provide the
basis for program implementation and funding. Each IHA
will prepare a plan for its individual activities and
group participation. Where group training is contemplated,
the organization selected to act as the trainer will
prepare its curriculum for the group training session.
All plans and curricula shall be subject to Regional
Office approval.
C. Funding.
(1) While the FY 1975 TPP funds were earmarked for
training, no distinction will be made between the
FY 1975 and FY 1976 TPP funds for purposes of
determining how much of the total MIFIH funds will
be used for training versus technical assistance.
The IHA's plan will be based upon, and will include,
its estimate of the total amount of funding needed.
The Regional Office or Area Office, as appropriate,
shall make obligations of the FY 1976 funds to the
to the IHAs based on the priorities expressed
in the Regional strategy and IHA plan estimates.
Funds for FY 1976 have previously been assigned
to the Regional offices on a HUD-185. All obliga-
tions of funds to the IHAs must be completed by
September 30, 1976.
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HUD-Wash., D. C.
7440.2
(2) As the program proceeds, funds will be disbursed
to individual IHAs as needed to implement their
approved MIFIH plans. Since these funds can be
paid by HUD to IHAs only, pursuant to Annual
Contributions Contracts, the cost of group training
programs, including trainers' administrative
expenses, as well as' IHA participants' travel and
per diem expenses, must be covered out of the
participating IHAs' MIFIH funds. No direct HUD
funding to such trainers by way of contract funds,
or otherwise, is involved.
(3) All activities to be funded by this program are to
be completed within two years of the start-up of an
IHA's approved plan, unless the IHA can demonstrate
that it has additional sources of financing longer-
term activities and/or a HUD-approved extension
of time. The expectation is that this two-year
intensive effort will result in a significant
improvement in the administrative capabilities
of the IHA. In this regard, it is anticipated that
one of the long-range benefits to be gained will
be a reduction in the rapid turnover rate of staff.
d. Public Notification of the opportunity to participate
as a trainer is required. It is the responsibility of
the Regions to develop a strategy for such notification.
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MANAGEMENT INITIATIVES
FOR
7440.2
INDIAN HOUSING PROGRAM
CHAPTER 2. ELIGIBLE MIFIH ACTIVITIES
7.
GENERAL. MIFIH funding shall be used by IHAs to finance only
those types of training and technical assistance activities which
are eligible for such funding in accordance with the subsequent
provisions of this chapter. Each IHA's total plan for MIFIH
activities shall constitute a coherent package of training and
technical assistance, tailored to the IHA's particular needs.
a. Eligible training-related expenditures
(1) Transportation
(2) Per Diem
(3) Registration fees for courses or seminars
(4) Reimbursement for hired trainers
(5) Charges for equipment, books and other teaching aids
(6) Other expenses related to specific training, which must
be justified in the IHA's plan.
b. Eligible trainees, limited to IHA Commissioners, Executive
Directors and employees of the IHA, shall be included in the
operating budget amendments. To the extent necessary and when
funds are not otherwise available, participation of Tribal
Chairmen (or their designees), fee accountants, IHA lawyers
and Mutual Help contractors may be funded for appropriate
training. The particular training and technical assistance
which these individuals receive shall vary, not only by each
person's needs, but also by the roles each must fulfill for
the IHA.
8.
ELIGIBLE TRAINING ACTIVITIES.
a. Types of training. Each IHA's training activities shall
include the following types of training, as adapted to the
needs of the particular IHA:
(1) Orientation-type training for Commissioners and
Executive Directors. This should be relatively
general training, designed to acquaint IHA
Commissioners and Executive Directors with the basic
information which is pertinent to their responsibilities.
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7440.2
Key officials of the Tribal Council (or other local
governing body) and its community development and social
services agencies should be included in appropriate
orientation sessions subject to availability of funds
from their own budgets; MIFIH funds shall not be used
to pay the travel and per diem expenses of such officials.
This orientation training should cover at least the
following subjects:
(a) Fundamentals of low-income public housing programs,
including major HUD policies and procedures. This
should include a summary of procedures involved in
both the development and operation of low-income
public housing in Indian areas.
(b) Responsibilities of the IHA, including coverage
of all major functions which must be handled by an
IHA in the development and operation of its low-
income public housing programs. The roles of the
IHA's Board of Commissioners and staff should be
clarified, with particular emphasis on the
respective policy-making and management roles of the
Board and the Executive Director and the need for
developing and retaining staff professionalism and
avoiding undue turn-over of competent Executive
Directors and other staff employees.
(c) The relationship between the IHA and HUD,
including an outline of relevant Regional and Area
Office organization and procedures, and definition
of HUD functions in the development and operation
of low-income public housing in Indian areas.
(d) The roles of the Bureau of Indian Affairs and the
Indian Health Service in the development and
operation of low-income public housing in Indian
areas. The aspect of coordination among the three
Federal agencies and the IHA should be stressed.
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7440.2
(e) The relationship between the Tribal Council
(or other local governing body) and the IHA, with
particular attention to the responsibilities
of the Tribal Council (or other local governing
body) under the Tribal Ordinance (or Cooperation
Agreement).
(f) The rights and duties of tenants and homebuyers,
with particular emphasis on responsibilities for
payment of rent or homebuyer payments and for care
and maintenance of the property.
(2) Technical Training for key IHA employees.
This type of training shall provide detailed,
technical and highly practical instruction for Executive
Directors and other key IHA employees in those subjects,
pertinent to their everyday tasks and responsibilities,
which the IHA has identified as a need. The size of the
IHA's operations and staff will, of course, determine
which employees should be trained, and the depth and
specialization of the training needed for particular
employees. While the. Executive Director will have had
the orientation-type training prescribed in paragraph 8a
(1) above, it is essential that he receive the additional
technical training he needs to perform his everyday
duties. For a large IHA, technical training for the
Executive Director should place more emphasis on broad
managerial skills, and key staff specialists should
receive detailed specialized training in their respective
areas of responsibilities.
For a small IHA, the Executive Director, as well as
staff, may need in-depth instruction in the entire
range of pertinent specialized subjects. If deemed
desirable, Commissioners and agents of the IHA
(e.g., accountants, lawyers, and contractors)
may be included for technical training in appropriate
subjects. The instruction must lead to the employee
being able to perform the necessary tasks; e.g., a
course in bookkeeping must result in a
demonstrated capability to set up a Mutual Help account,
calculate an amortization schedule, calculate a
utilities allowance, etc.
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7440.2
Similarly, after a course on construction inspection
procedures, the student must be able to recognize
adequate framing work, be acquainted with different types
of insulation material, etc. The overall technical
training program shall cover the following subjects in
the depth necessary to address the needs of the
particular IHA:
(a) General management functions, including, but
not limited to, overall managerial planning
and supervision, staffing and personnel
administration, office management, and liaison
with the Tribal Council (or other local
governing body).
(b) Occupancy functions, including establishment of
income limits and tenant/homebuyer selection
policies, taking and processing tenant/
homebuyer applications, procedures in selection of
tenants and homebuyers including interviewing
techniques, examination and re-examination of
family incomes, determination of charges for rents
and homebuyer payments, and the establishment of
lease and grievance procedures.
(c) Financial management, including the financial
structure of each type of low-income public
housing program, financial planning, investment
of funds, budgeting, fiscal controls, accounting,
audits, financial reports, rent collection, and
procedures governing operating subsidies. All
training programs shall place strong emphasis on
how to keep proper (auditable) financial accounts
and records, for both the development and
operation phases of a project.
(d) Maintenance and utilities functions, including
the respective responsibilities of the IHA and
tenants/homebuyers, systems for planning,
organizing and supervising maintenance work,
techniques for correcting particular
maintenance problems, methods for energy
conservation, and procedures for determining
utility allowances.
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7440.2
(e) Supply management, including procurement policies
and procedures, bidding and contracting procedures,
and systems for inventory storage and control.
(f) Modernization functions, including applicable
HUD standards and procedures, and techniques for
determining modernization needs, preparing
modernization programs, and managing and inspecting
modernization work.
(g) IHA/resident relations, including techniques to
improve communication and cooperation between the IHA
and residents, and methods for training and
counseling residents regarding their rights and
responsibilities as tenants or homebuyers.
(h) Administration of development programs, including
applicable HUD procedures and IHA functions in
planning, application, and preparation of development
programs, and contracting, supervising and inspecting
development work.
b. Methods of training. Any training method, or combination of
methods, may be used to carry out an IHA's training activities,
provided that the total training program is determined by HUD
to be genuinely workable, effective, and reasonably economical.
Group training is strongly recommended where a common need
exists but, if mutually acceptable to HUD and the IHA, other
methods may be used to supplement such group training, or in
lieu of such group training. Examples of other training
methods are: participation in courses and conferences sponsored
by HUD Field Offices or Training Centers, educational
institutions, and management organizations, intra-IHA courses
and on-the-job training, and educational visits to other IHAs
or non-Indian Public Housing Agencies.
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7440.2
9.
ELIGIBLE TECHNICAL ASSISTANCE ACTIVITIES.
a. Areas for technical assistance. Eligible technical
assistance activities shall be limited to the following
areas of administration or management of housing operations;
however, incidental attention may be given to related aspects
of housing development:
(1) Financial accounts and records. As the first
priority for technical assistance, each IHA shall
undertake such activities as are required to put
its financial accounts and records in good and
auditable condition, and to establish systems to
maintain that condition. While the immediate goal
is to bring these accounts up to auditable condition,
it is imperative that the IHA staff receive assistance
in this endeavor; that they are at the same time
trained in order to be able to continue such
accounting practices without further outside supervision.
(2) Other aspects of financial management. The second
priority for technical assistance shall be such
activities as are required to address other financial
management needs, including general financial planning,
preparation and use of operating budgets, methods for
cost control, collection of rents and homebuyer payments,
etc.
(3) Other operational areas. The third priority shall
be to address needs for technical assistance in other
operational areas, e.g., occupancy, maintenance and
utilities, supply management, modernization, and IHA/
resident relations.
b. Types of technical assistance
(1) Professional services. The principal type of
technical assistance in the areas specified in
subparagraph 9a above shall be appropriate
services of qualified professionals, e.g.,
accountants and management technicians. In any event,
it must be demonstrated by the IHA that the
specific services proposed will effectively and
economically address a genuine need, and that the
persons to perform such services are genuinely
qualified to do so.
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HUD-Wash., D. C.
7440.2
(2) Additional staff employment. Subject to HUD approval,
technical assistance may include the temporary employ-
ment (not to exceed two years) of additional IHA staff
personnel to provide the "catch-up" capability necessary
to correct problems within the areas specified in
subparagraph 9a above. However, such employment shall
not include additional maintenance, social service or
security personnel.
10. INELIGIBLE EXPENDITURES. MIFIH funds shall not be used to fund
the following types of items:
a. Costs of maintenance, repairs and capital improvements.
b. Costs of social services or security programs.
C.
Increases in salaries and benefits to IHA employees, except
for extending the working hours of part-time employees
pursuant to subparagraph 9b(2) above.
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HUD-Wash., D.C.
MANAGEMENT INITIATIVES
FOR
INDIAN HOUSING PROGRAM
7440.2
CHAPTER 3. DEVELOPMENT, SUBMISSION, REVIEW
AND APPROVAL OF IHA PLANS AND
FY 1976 FUND OBLIGATIONS
11. REGIONAL PROCEDURES.
a. Upon approval of the Regional strategy by the Regional
Administrator and concurrence by CARF-IPP, the Assistant
Regional Administrator shall prepare a letter to each
eligible IHA authorizing it to proceed with development
of its MIFIH plan. The letter shall include the
following points.
(1) Specific instructions to be followed in the
submission of the plan, including the timeframe
for submission. This should include reiterating
use of the format set forth in paragraph 12.
(2) A statement of preliminary needs assessment of the
IHA as perceived by the Regional Office, based upon
its prior knowledge of the IHA's operation.
(3) A summary of the regional strategy as it relates to
the specific IHA, including recommendations as to the
IHA's participation in group training sessions.
(4) Resources available for consideration by the IHA in
choosing its training.
(5) A reminder of how much the IHA received in FY 1975
MIFIH money, if any.
b. Review of plan submission
(1) Upon receipt of IHA plans, the ARA shall route a
copy to the Indian Coordinator and copies to such
other members of the Regional Office staff as he deems
advisable, for comments and recommendations; specific-
ally, those offices whose program areas are pertinent
to any portion of the IHA's plan.
(2) Specific review criteria are listed in Appendix 2.
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7440.2
(3) If, upon completion of the review, the ARA finds
that approval of the proposed plan is merited, he
shall secure prevalidation of the funds by the
Regional Accounting Division. He shall submit the
plan to the RA, with his comments and recommendations,
evidence of prevalidation of the funds and a letter,
prepared for the RA's signature, to the IHA obligating
the funds as prevalidated. The ARA shall bear in
mind the priorities established in the regional
strategy as well as those of each IHA. It is realized
that not all training needs in IHA plans can be
funded through the two-year MIFIH program, but that
other available sources of funding shall be considered.
(4) If the ARA finds that the proposed plan does not merit
approval, he shall immediately so advise the IHA and
make a reasonable effort, including suggestions of
specific changes, to obtain an approvable resubmission.
The ARA's recommendation for approval may specify such
modifications, deletions and/or additions to the plan
as he may deem advisable, with appropriate adjustment
in the funding recommendation.
(5) If the September 30 deadline for obligation of the
funds is approaching without sufficient time to allow
the ARA and IHA to complete a resubmission, the ARA
shall proceed to prevalidate and obligate the funds
to all IHAs, based on the best estimates he has as
to the eventual final plans. The documents shall
be submitted to the RA along with the recommendations
for those plans which are final, as prescribed in
paragraph (3) above.
C. Final approval. After reviewing the ARA's comments and
recommendations, the RA shall indicate to the ARA his
approval or disapproval of the plans and the funding obli-
gations. The RA's approval may be conditioned upon such
modifications, deletions and/or additions as he may deem
advisable.
d. Notification to the IHAs.
(1) A letter of obligation of the TPP/MIFIH funding
shall be sent by the RA or Area Director, as
appropriate, to each IHA immediately after the
obligation amounts have been decided upon. This shall
be done by September 30, 1976, irrespective of
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HUD-Wash., D. C.
7440.2
whether all MIFIH plans have been approved.
A sample letter is included as Appendix 3. A
list of all obligations shall be sent to Office
of Housing-OHP.
(2) The ARA shall communicate with each IHA individually
regarding approval of its plan. The letter shall
indicate what modifications and/or recommendations
the Regional Office has made, and shall remind the
IHA of its responsibility to attend whatever group
training sessions have been agreed upon and scheduled
by the Regional Office and IHAs.
e. Notification to Central Office. By October 29, 1976, the
ARA shall send to CARF-IPP a complete list of the IHAs
involved, indicating the amounts of FY 1975 and FY 1976
TPP funds obligated to each. In addition, the ARA shall
include a list of all approved trainers, the needs to be
addressed at each session, and names of the IHAs included
in each training group. The IHAs who are elibible but who
are not participating in MIFIH shall also be listed, with the
reason(s) for their non-involvement indicated.
12. IHA PROCEDURES.
a. Format of Plan. Each IHA's individual plan shall include
the following elements in such form and breakdown of
details as the Regional Administrator deems necessary to
establish a sufficiently definite description. They shall
follow the points set forth in the letter from the Regional
Administrator, described in paragraph lla.
(1) Needs of the IHA. This should be realistic and all-
inclusive, even though there may not be enough
money under MIFIH to meet all needs.
(2) A clear and complete description of each proposed
training or technical assistance activity. All
activities shall be listed in order of priority.
Participation in group training sessions shall be
noted after consultation with the trainer and the
Regional Office. Each description shall include:
(a) needs which will be addressed
(b) individuals to be trained
(c) methodology/techniques to be utilized
(d) training evaluation, including pre- and post-
tests where appropriate.
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7440.2
(3) A schedule showing estimated (or exact, where known)
dates for the beginning and completion of each
training or technical assistance activity. The
schedule must provide for completion of all activities
within two years from the start of the first activity,
unless specifically exempted by the Regional Office.
Request and justification for such extension must be
included in the plan. An example of an acceptable
extension would be enrollment of a staff person in a
training course, extending beyond the two-year limit.
(4) Identification of training resources to be utilized for
each activity (e.g., organizations, institutions, firms
or individuals), with documentation sufficient to
establish that each such resource is qualified to pro-
vide the type of services comtemplated. Local resources
such as colleges and business schools should be utilized
whenever possible for training when no group session is
planned. Appendix 2 provides suggested criteria for
determining adequacy of qualifications.
(5) A revision of the IHA's current Operating Budget is
necessary to reflect HUD's obligation of the total
MIFIH funds needed to finance the IHA's plan as an
increase in the operating reserve level and a corre-
sponding receivable from HUD set up in the books of
account to be liquidated as the vouchers are paid
by HUD. Training expenditures estimated to be incurred
during the current and subsequent IHA fiscal years
shall be reflected as an operating expense in the
operating budget with a corresponding reduction in the
operating reserve level. The budget revision shall be
supported by such detailed cost breakdowns or other
data as the ARA may require; at the minimum, such
supporting data shall show the total amount of MIFIH
funds to be requested for each activity, and the total
for the following categories of expenditures:
(a) Contracts for services
(b) Travel and per diem expenses
(c) Salaries and benefits
(d) Procurement of facilities, supplies and equipment
(e) Other expenditures (identify).
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7440.2
(6) A monitoring and evaluation plan, sufficient
to establish an effective system of IHA monitoring
and evaluation of its plan activities. It shall
include whatever details for measurement as the ARA
shall prescribe including frequency and contents,
including funding, of reports to the ARA. Ata minimum,
it shall describe what expertise/skill each participant
is expected to gain through each activity, as perceived
by both the IHA and the trainer.
(7) A resolution by the IHA's Board of Commissioners. A
sample is included as Appendix 1.
13. IHA GROUP TRAINING SESSIONS.
a. Concept. It is expected that the basic method for IHA
training under MIFIH will be for groups of IHAs in various
parts of the country to join together for common training
programs. Such group programs will allow IHAs to pool their
training funds and other resources to support stronger
training programs than would be possible on an individual
IHA basis.
b. Formation of training groups. Subject to the Regional
strategy determinations, a training group shall consist of
two or more IHAs which agree to join together for a group
training session, when all share a common need. The follow-
ing points are pertinent to the formation of training groups.
(1) Proximity. The IHAs in a particular training group
should be located in sufficient proximity to permit
convenient and economical access to training sites
within the general area covered by such IHAs.
(2) Compatibility. The IHAs in a particular training
group should be compatible, in terms of training
needs, preferences, skill/knowledge levels, and other
relevant factors.
(3) Inter-regional efforts may be worked out with the
approval of both RAs.
C. Trainers for group sessions. Each IHA group training
session shall be conducted by a trainer who is mutually
acceptable to the ARA and the IHAs involved. A trainer may
be an individual, an agency, or an organization. The
function of the trainer shall be to exercise overall
responsibility for planning and carrying out the training
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HUD-Wash., D.C.
7440.2
program. While the trainer may be strongly encouraged to
obtain needed assistance from other sources, and may even
engage other organizations for co-sponsorship roles, the
trainer must retain overall responsibility for the
execution of the session as approved. The following points
are pertinent to the selection of a trainer for each
training program.
(1) The ARA shall consult with the IHAs involved to reach
a HUD-IHA consensus as to selection of the trainer.
(2) Selection of the trainer will be effective only upon
written approval by the ARA, evidencing his determi-
nation that the individual or organization can be
expected to meet the responsibilities involved,
including compliance with applicable HUD standards and
requirements, including Section 7(b) of the Indian
Self-Determination Act and the applicable provisions
of Sections 805.309 and 805.310 of the Indian Housing
Program regulations.
(3) There shall be an agreement with the trainer as to the
method of compensation, which may be by registration fee
for approved trainers, in a specified amount, or compen-
sation under a HUD-approved contract with the IHA(s)
involved. Where more than one IHA is involved, the
contract shall specify which IHA is responsible for
administration of the contract.
d.
Training Session Curriculum.
(1) General. The trainer shall be responsible for the
preparation and submission of a written curriculum
for its proposed training program, in accordance with
the standards and procedures of this Handbook and any
further instructions of the ARA.
(2) HUD assistance in preparing plans. In preparing its
proposed training curriculum, the trainer shall consult
as necessary with the IHAs involved, the ARA (who shall
involve pertinent program offices and the Indian
Coordinator) and any other organizations or individuals
which are to have significant roles in the training
program.
(3) Basic standards. Trainers shall be allowed great
flexibility as to both the substance and format of
training programs. The substance should be sufficient
for practical, accurate, in-depth coverage of all
pertinent subject matters related to the administrative
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HUD-Wash., D. C.
7440.2
or management needs of the IHAs in the particular
training group. The format should also be tailored
to the needs of the particular group of IHAs, as well
as the capabilities of the particular trainer and any
other resources on which the trainer shall draw. While
traditional lecture-type training has its place, trainers
are encouraged to use other formats which might be more
effective in imparting practical knowledge, e.g., work-
shops, case studies, problem-solving, site visits, group
discussions, on-job training, and panel presentations.
In any event, each training program must clearly meet
the following fundamental standards:
(a) It must be genuinely effective in improving the
IHA's capabilities for administering or managing
both development and operation of low-income
housing.
(b) It must be reasonably economical, in terms of
providing benefits commensurate with the cost
involved, using the most economical methods
available, and keeping travel and per diem costs of
the IHAs to the lowest possible level.
(4) Format. Each training program shall be in writing and
shall contain the following elements:
(a) Detailed descriptions of each training session,
indicating the intended training audience, the
purposes and measurable objectives of each major
block of instruction, and detailed daily schedules
showing each subject to be covered, methods of
instruction, and the name of the person or persons
to be used as instructors in each instance.
(b) An administrative plan, sufficient to demonstrate
that the trainer is prepared to discharge its
responsibilities for overall administration of the
training program, including the following:
1.
The dates for each training session.
2
The places for each training session, and the
arrangements for accommodating the session,
including to the extent pertinent, arrangements
for meeting facilities, equipment,
participants' lodging and meals.
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7440.2
3
The approximate number of trainees expected
to participate in each training session, by
IHA and position.
4
The names of the trainer's representatives
who are to be present at each training session
to exercise the trainer's overall responsi-
bilities for administering the session.
5
Plans for informing IHAs about the training
program in general and each training session
in particular, and such other activities
as may be necessary to assure full IHA
participation and support.
(c) A monitoring and evaluation plan for the trainer to
monitor and evaluate IHA training sessions, to
take such corrective actions as may be necessary,
and to submit such reports as may be prescribed by
the ARA.
(d) Qualifications of instructors, including the name
and organizational affiliation of each individual
who is to act as an instructor or other resource
person, with a brief statement of such individual's
qualifications, sufficient to evidence that he
or she is qualified to perform the particular
function assigned. The ARA and Indian Coordinator
should be consulted for suggestions as to qualified
individuals.
(e) An administrative budget, with a detailed breakdown
of the trainer's expenses (not to include travel
and per diem for trainees) for planning and
carrying out the training program.
(f) An estimate of each participating IHA's costs.
Unless the IHAs contract with the trainer, the only
reimbursement to the trainer for his administrative
expenses will be paid by registration fees. In
either case, the IHA estimate should be agreed upon
by both the trainer and the IHA and communicated
to the IHA in order to be included in the plan it
submits to HUD. (paragraph 12a(5).
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7440.2
(g) The trainer's certification that it will be
diligent and effective in carrying out the
training program in accordance with the proposed
plan, that it will not make any significant
change in the curriculum without prior HUD
approval, and that it understands and agrees that
HUD reserves the right to terminate funding for
the program if the trainer and/or the IHA fail to
carry out their responsibilities under the approved
plan. This may be in the form of a resolution by
the trainer's governing board or a Certificate
signed by its principal Executive Officer.
(5) Deferral of elements of the plan. The Regional
Administrator may approve a trainer's plan which does
not reflect final arrangements for all elements (e.g.,
exact arrangements for dates, locations, facilities
and instructors), provided that he is satisfied that
such final arrangements will be made in a satisfactory
manner, and that the plan presented, plus such final
arrangements, will result in a sound training program.
In such cases, notification of approval shall specify
requirements as to the final arrangements remaining to
be settled before the trainer shall be allowed to
proceed with pertinent portions of the training program.
14. RESERVED.
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MANAGEMENT INITIATIVES
FOR
7440.2
INDIAN HOUSING PROGRAM
CHAPTER 4. IMPLEMENTATION OF PLANS
15. IMPLEMENTATION BY IHA. The IHA shall proceed with the
implementation of its plan in accordance with the approved
priorities and schedule of activities. Any changes in the
schedule must be reported in writing to the ARA.
16. MONITORING AND EVALUATION. Each IHA and trainer shall be
responsible for monitoring and evaluating performance under
its approved MIFIH plan, for the purpose of assuring good
quality as well as adherence to the quantitative provisions of
the plan. The monitoring and evaluation measures to be taken
by the IHA or trainer shall be included in the plan itself.
In addition, the ARA shall be responsible for Regional/Area
Office monitoring and evaluation of IHA/trainer performance,
including the input of the Indian Coordinator and in accordance
with procedures to be determined by the ARA.
17. REPORTS TO HUD.
a. From IHAs. Narrative quarterly reports, indicating the
activities which have been completed and the status of
those in progress, shall be submitted by each IHA to the
ARA. The IHA's evaluation of its activities shall be made
in accordance with the measures included in its plan. The
due dates for each IHA's report may be set at the discretion
of the ARA, taking into account the other responsibilities
of the IHAs and the need for staggering the reporting from
the various IHAs.
b. From trainers. Complete evaluation reports of all
participants shall be written by a trainer at the conclusion
of each group training session for which the trainer is
responsible. Reports should include description of the
degree to which the participants achieved stated objectives.
Such reports shall be sent to the ARA.
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7440.2
C. Distribution of reports by ARA. Upon receipt of IHA
and trainer reports, the ARA shall forward copies to
the following offices, in addition to whomever else he
chooses, in accordance with the procedures referred to
in paragraph 16 above.
(1) Regional Indian Coordinator
(2) CARF-IPP
(3) Those program offices which were involved in
curriculum development
18. NOTIFICATION OF CHANGES. The ARA shall notify the IHA of
any changes to its plan which he feels are necessary to more
adequately address the IHA's needs.
19. FINAL EVALUATION. A final evaluation report of the total
effort shall be submitted by each IHA and trainer at the
completion of all funded activities, or at the end of the
two-year implementation period if all activities have not
been completed. This report shall include an assessment of
those unmet needs which the IHA or trainer feels should still
be addressed in order to correct the IHA's administrative
deficiencies. The distribution of such reports by the ARA
shall be the same as that described in paragraph 17c above.
20. FINANCIAL REPORTING REQUIREMENTS. All reports on funding
and revisions of operating budgets shall be in accordance
with normal HUD financial reporting requirements, unless
otherwise specifically instructed by the Assistant Secretary
for Housing. Detailed accounting instructions for IHAs are set
forth as Appendix 4.
21. RESERVED.
7/76
Page 30
HUD-Wash., D. C.
7440.2
APPROVAL
ustance B. beenmen
7/30/76
Assistant Secretary for Consumer Affairs
and Regulatory Functions
Page 31
7/76
HUD-Wash., D.C.
7440.2
Appendix 1
APPENDIX 1. SAMPLE IHA BOARD RESOLUTION
At the regular (specially called) meeting of the Board of
Commissioners of the (name) Housing Authority of (address),
on (date) , 1976, the Board received, reviewed and adopted the
attached Training Plan to be funded from monies obligated to this
Authority as part of the Management Initiatives for Indian Housing
Program (MIFIH) of the U. S. Department of Housing and Urban
Development (HUD), and forwards that Plan and this resolution to
HUD for approval.
This Board further adopts and approves the portion(s) of the Plan
proposed by (name of trainer) as group training, approves the
estimate of this Authority's costs of participation included in the
Plan, and commits the Authority to full participation in the described
group training.
This Board further assures HUD that it will be diligent and
enthusiastic in carrying out this total Plan, will comply with all
applicable HUD requirements, and understands and agrees that HUD
reserves the right to terminate funding for this program if the
Authority fails, in any way, to carry out its responsibilities as set
out in the Plan, as finally approved by HUD for implementation.
, Chairman
Board of Commissioners
Housing
Authority
Page 1
7/76
HUD-Wash., D.C.
7440.2
Appendix 2
APPENDIX 2. CRITERIA FOR EVALUATION OF
MIFIH TRAINING PLANS
1. INTRODUCTION. There are a number of important factors that
go into a creative and effective training program, and opinions
vary widely as to the priority attached to each. The elements
that must be examined with care are in two parts: 1) the
qualifications of the individual or organization providing the
training (the trainer) and 2) the IHA's training plan and the
trainer's group session plan, which should include implementation,
evaluation and follow-up. These criteria shall be used as a
basis of judgement and evaluation by the Regional Office in
reviewing both types of plans, and shall be provided to those
trainers who may be involved in development of group training
sessions. The following list is not exhaustive, and should be
used by Regional Offices with whatever additions are felt useful
in adapting to the needs of that particular Region.
2. PART 1. TRAINER QUALIFICATIONS. Trainers are frequently
known to selecting/approving officials by previous experience,
by knowledge gained from another agency which has utilized
the Trainer's services, but frequently the only source of
information is the written proposal that is submitted for approval.
In any event, it is of utmost importance that a number of key
questions be included in the evaluation of the Plan/proposal.
The following address fundamental issues to be raised and answered:
a. Does the Trainer demonstrate experience or knowledge
in Federal, and State, and/or local subsidized housing
programs? How? In what ways?
b b. Does the Trainer demonstrate a workable knowledge of
subsidized housing programs in effect in Indian communities?
Page 1
7/76
HUD-Wash., D.C.
7440.2
Appendix 2
C. Does the Trainer demonstrate an understanding of the
particular objectives of the MIFIH Training Program?
d. Has the Trainer a demonstrable capability to develop,
design and implement housing management training programs?
e. Does the Trainer demonstrate a capability (experience) for
dealing with special situations of Native Americans?
f. Has the Trainer a demonstrable awareness of the social
cultural, religious, and political characteristics and
needs of proposed trainees (and residents) of IHAs?
g. What experience has the Trainer in working with such
groups as BIA, IHS, ONAP, National or local Indian groups, etc?
h. Does the Trainer evidence an understanding of the relation-
ships that exist between agencies involved in the production
and administration of subsidized housing in Indian communities?
i. Has the Trainer had experience with training for non-
Indian housing programs?
j. Does the Trainer propose to use Native Americans as trainers?
k. What previous experience have proposed Trainers had (resume)?
1. Has the Trainer made adequate provisions for training and
developing the training staff?
3. PART 2. EVALUATION OF TRAINING PLANS. Some portions of the
following will apply specifically to the plans submitted by
individual IHAs, and some will apply to the group session plans
submitted by a potential trainer. The Regional Office may add
whatever additional criteria it feels are important in order to
evaluate either type of plan.
7/76
Page 2
HUD-Wash., D.C.
7440.2
Appendix 2
a. Need:
(1) How does the Training Plan indicate an understanding
of the total needs of the IHA? And the role the
proposed Training Planis to play in meeting those
needs?
FORD LIBRARY &
(2) How were needs determined? Interview with individua
(Commissioners, Directors, Staff Members, Residents,
etc. Was a written instrument used? Enclose copy.
(3) Show how the plan will most effectively address the
training and technical assistance requirements of the
IHA?
(4) Does the Plan demonstrate an understanding of the
program objectives and tasks to be performed and
the probable effectiveness of the proposed approach?
b. Delivery:
(1) Does the trainer indicate that the most effective
and appropriate methods will be used in carrying
out the program? What are they?
(2) Has the proposed methodology been tested by previous
experience? Where?
(3) Does the trainer propose to use appropriate local
agencies and organizations as resources?
C. Organization in Manpower:
(1) Does the proposed organization of the training
indicate sound management and administrative
practices?
(2) Is an organization chart included?
(3) Position descriptions for key training personnel?
Will Native Americans be used?
Page 3
7/76
HUD-Wash., D.C.
7440.2
Appendix 2
(4) What provisions are made for training and development
of training staff?
(5) Is the proposed manpower adequate to carry out the
proposed methodology?
(6) Staff qualified to perform assigned tasks?
(7) Is there an adequate number of personnel?
d. Schedule of tasks:
(1) Does the trainer identify each major task to be
performed including:
(a) sequence and duration of each task;
(b) allocations of manpower to each task;
(c) an appropriate task chart?
(2) Is the proposed schedule of tasks realistic,
flexible, logical, and adaptable to the needs of
the trainees?
(3) Does the schedule indicate the timing of reports,
evaluations, and meetings with the IHAs?
(4) Does the proposed schedule provide for the
accomplishments of all stated objectives and the
satisfaction of HUD, IHA, and program requirements?
(5) Are scheduled tasks coordinated with IHA schedules,
as set forth in their plans?
e. Equipment/Facilities:
(1) Is proposed equipment appropriate and justifiable
for training objectives?
(2) Does trainer specify how equipment is to be
acquired and used?
(3) Are the proposed training facilities convenient
and accessible?
7/76
Page 4
HUD-Wash., D.C.
7440.2
Appendix 2
(4) Have available and accessible tax-exempt facilities
been utilized?
f. Qualifications/Experience:
See PART 1 of this Appendix for detailed coverage of this area.
g. Cost effectiveness:
(1) Is there a comprehensive breakdown of costs provided,
including:
(a) facility charges
(b) administrative salaries
(c) instructional salaries (are salaries appropriate
(d) for the level of expertise provided)
(e) travel and per diem cost (staff and trainees)
(f) instructional equipment and supplies
(g) overhead costs
(h) management fees (profit) and outside consultant costs.
(2) Are costs realistic and appropriate in terms of the
work proposed?
(3) Are proposed costs within the IHA budget limits for
the program? (Is the amount of the registration fee
appropriate?)
(4) Does the trainer indicate how costs will be allocated
to tasks; and are all elements listed in the technical
approach accounted for?
(5) Does the trainer provide for utilization of on-going
community resources?
h. Evaluation:
(1) Is evaluation structured as an on-going process
during training?
(2) By whom will evaluation be made?
(3) Will a descriptive check be made of the congruence
between plan for the conduct of training and the way
in which the training was actually carried out?
Page 5
7/76
HUD-Wash., D.C.
7440.2
Appendix 2
(4) Will evaluators check to see whether the gains in
knowledge (including skills) which were anticipated
to result from the training actually were achieved?
(5) Will evaluation evidence which portions of the training
were successful? In what ways they were successful?
What contributed most "to the success? Were participants
satisfied with training?
(6) Have any changes occured in the IHA as a result of
MIFIH training? If so, what?
(7) If the training plans were revised or rewritten,
what should be added or deleted?
7/76
Page 6
HUD-Wash., D.C.
7440.2
Appendix 3
APPENDIX 3. SAMPLE IHA OBLIGATION LETTER
Mr. John Doe
Executive Director
Pleasanton Housing Authority
690 Main Street
Pleasanton, Wyoming 13964
Dear Mr. Doe:
The Department hereby commits the amount of $
which, together
with the amount of $
commited on (date)
from FY 1975
funds, constitutes the total funding of $
for your
participation in the Management Initiatives for Indian Housing (MIFIH)
program. This commitment does not carry with it approval of your
training plan, nor are you authorized to implement any of your MIFIH
activities or expend any MIFIH funds at this time. You will be
informed by separate letter concerning approval of your plan by HUD,
and authorization to implement it and requisition your funds.
In order to confirm this obligation, please prepare a revision of
your operating budget showing the increased amount of operating
subsidy on Line 950 and Line 960 equal to the amount obligated
herein. The amount shown on Line 950 should be designated as MIFIH
funding. The provision for operating reserve on Line 980 and Line 09,
Part II, will be increased by the same amount. If the augmentation
of the reserve results in a level which exceeds that authorized in
HM 7475.1, Chapter 2, the provisions of that issuance are hereby
waived with respect to the MIFIH funding.
Sincerely,
Tom Jones
Regional Administrator
Prevalidated
Date:
Page 1
7/76
HUD-Wash., D.C.
7440.2
Appendix 4
APPENDIX 4. ACCOUNTING AND FINANCIAL REPORTING
REQUIREMENTS FOR INDIAN HOUSING AUTHORITIES
PARTICIPATING IN THE TPP/MIFIH PROGRAM
1. Classification of Accounts. The classification of accounts pre-
scribed in Chapters 2 and 3 of the Low-Rent Housing Accounting
Handbook HM 7510.1 shall be used for recording transactions
relating to TPP/MIFIH. No new accounts are prescribed for use in
this program. The IHA's books of account, however, shall be
maintained in such a manner that the operating expenditures
applicable to TPP/MIFIH can be clearly identified.
2. Accounting for TPP Operating Funds. Each IHA participating in the
TPP/MIFIH program has been requested by HUD to submit a revised
Operating Budget requesting an increase in the amount of the
operating subsidy by the total amount of the approved TPP/MIFIH.
The following entry shall be made in the General Ledger upon
approval by HUD of the revised operating budget:
Debit: Account 1125, Accounts Receivable - HUD
Credit: Account 8020, Contributions Earned - Operating
Subsidy-Current Year
(To record the total amount of operating subsidy approved for the
TPP/MIFIH Program)
An Accounts Receivable Register or other record shall be maintained
which shall show the balance of the account receivable applicable
to the TPP/MIFIH.
3. Accounting for Operating Expenditures. The subsidiary accounts
for classifying operating expenditures of TPP/MIFIH shall be the
same as those prescribed in Chapters 2 and 3 of the Accounting
Handbook HM 7510.1. A separate subsidiary ledger or other record
shall be maintained to record TPP/MIFIH expenses and shall provide
for the accumulation of expenditures.
4. Reporting TPP/MIFIH Expenditures on Statement of Operating Receipts
and Expenditures, Form HUD-52599. In preparing the Statement of
Operating Receipts and Expenditures, the TPP/MIFIH expenditures
shall be reported on Line 640 of the Form HUD-52599. For
identification purposes the IHA shall insert the words "TPP/MIFIH
Expense" on Line 640 in the column headed Account Title. Under no
circumstances shall TPP/MIFIH expenditures be included in the
operating expenditures reported on Lines 180 through 620.
Page 1
7/76
HUD-Wash., D.C.
7440.2
Appendix 4
5.
Requisitioning TPP/MIFIH Funds. HUD will make payments of
operating subsidy for the TPP/MIFIH Program on the basis of an
approved requisition. A Form HUD-54005, Requisition for Partial
Payments of Operating Subsidy - Targets Projects Program, shall
be used by the IHAs to obtain partial payments for actual and
proposed expenditures for TPP/MIFIH activities. Instructions
for the preparation, submission, and distribution of the Form
HUD-54005 are printed on the reverse of the form. A specimen
form of the HUD-54005 is shown as Appendix 4a.
6. Payment. Generally, the amount of the approved requisition for
partial payments will be paid by the Regional Accounting Division
in three equal monthly installments. However, if the IHA has
requested payment on the basis other than equal monthly
installments, and such request has been approved by the HUD office,
the Regional Accounting Division will make monthly payments in
the amount requested by the IHA and approved by HUD.
7. Supply of Forms. Forms may be obtained upon request to the
appropriate HUD office.
7/76
Page 2
HUD-Wash., D. C.
7440.2
Appendix 4a
HUD-54005
January 19/5
U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
FOR HUD USE ONLY
LOW-RENT HOUSING PROGRAM
VOUCHER NUMBER
REQUISITION FOR PARTIAL PAYMENTS OF OPERATING SUBSIDY
TARGET PROJECTS PROGRAM (TPP)
NAME AND ADDRESS OF LHA (Including ZIP Code)
DATE OF REQUISITION
'.HA FISCAL YEAR ENDING DATE
QUARTER ENDING
DEPOSITARY SANK (Name, Address and Account No.)
ACC CONTRACT NO.
PROJECT NO.(s)
APPROVED TARGET PROJECTS PROJECT
AMOUNT
1. Total amount approved Target Projects Program
TARGET PROJECTS PROGRAM EXPENSE
2. TPP Expense Incurred prior to beginning of Fiscal Year
3. TPP Expense Incurred to date this Fiscal Year
4. Estimated additional expense to end of requested quarter
5. Total TPP funds required (Lines 2, 3, and 4)
PARTIAL PAYMENTS
6. Total partial payments received prior to beginning of Fiscal Year
7. Total partial payments received for Fiscal Year to date
8. Total partial payments received (Lines 6 and 7)
9. Total TPP funds available (Line 1 minus Line 8)
AMOUNT OF THIS REQUISITION
10. Partial payments requested (Line 5 minus Line 8)
METHOD OF PAYMENT - REQUESTED INSTALLMENT PAYMENTS
1ST INSTALLMENT
2ND INSTALLMENT
3RD INSTALLMENT
TOTAL
I certify that this requisition for annual contribution for operating subsidy has been examined by me and to the best
of my knowledge is true and correct and is in accordance with the provisions of the approved Target Projects Program.
NAME OF LHA
SIGNATURE AND TITLE OF OFFICIAL AUTHORIZED
DATE
TO CERTIFY
HUD FIELD OFFICE APPROVAL
SIGNATURE AND TITLE OF OFFICIAL AUTHORIZED TO APPROVE
DATE
REGIONAL ACCOUNTING
PAYMENT FOR
AMOUNT
DATE CERTIFIED
CERTIFIED BY
DIVISION
MONTH
PAID
FOR PAYMENT
(Initials)
Prevalidated by:
(Signature)
(Date)
Total
Page 1
7/76
HUD-Wash., D. C.
7440.2
Appendix 4a
INSTRUCTIONS FOR PREPARATION OF FORM HUD-54005
REQUISITION FOR PARTIAL PAYMENTS OF OPERATING SUBSIDY
TARGET PROJECTS PROGRAM
1. GENERAL
a. The first requisition (HUD-54005) may be submitted immediately following the approval by HUD of the revised Operating Budget, Form
HUD-52564, which covers the estimated TPP expenditures for the LHA's current fiscal year. The requisition may cover a period from
the date the Part 8 Application - Target Project Program was approved by HUD to the end of the calendar quarter which is not more-than
four months from the date of HUD approval of the Part B Application.
b. The second and succeeding requisitions shall be prepared as of the first day of the month preceding the beginning of the calendar quar-
ter for which a partial payment is being requested, and it should be received by the appropriate HUD Area Office not later than the 10th
day of that month. For example, a requisition for quarter ending June 30th should be prepared as of March 1st and received by the HUD
Area Office not later than March 10th.
C. With the initial requisition, the LHA shall submit as supporting documentation (1) a narrative listing of each TPP Objective, with monthly
estimates and quarterly totals for which funds are being requested, and (2) a copy of each approved Summary of TPP Work Plans, Form
HUD-54002, on which the estimates are based. For the second and subsequent requisitions the LHA shall submit as supporting docu-
mentation a narrative, listing the TPP Objectives with monthly estimates and quarterly totals for which funds are being requested
together with the TPP Monthly Report, Form HUD-54004, for each Objective for the month ending one month prior to the beginning of
the calendar quarter for which funds are being requested. For example, a requisition for quarter ending September 30th, should be
accompanied by a TPP Monthly Report, for the month ending May 31.
d. A separate requisition (HUD-54005) shall be prepared for each Part B Application approved.
2. HEADING. The heading of this requisition shall be completed by inserting in the space provided the following information.
a. Name and address of the LHA, including zip code.
b. Name and address of the bank, including zip code, to which partial payments are to be mailed by HUD, and the LHA's account number.
The bank S0 designated shall be the bank for which the LHA has executed a Form HUD-274, Designation of Depositary for Deposits
of Loan and/or Grant Funds.
C. Date of requisition, that is, the date as of which the requisition is prepared.
d. The Local Authority*s Fiscal Year Ending Date
e. Quarter Ending. Enter the ending date of the calendar quarter for which the requisition is prepared.
f. The Annual Contribution Contract Number.
g. The Project Number(s).
3. APPROVED TARGET PROJECTS PROGRAM. Enter on Line 1 the total amount approved for Target Projects Program as shown
in the Part B Application.
4. TARGET PROJECTS PROGRAM EXPENSES (Lines 2 through 4). Self-explanatory.
5. PARTIAL PAYMENTS (Lines 6 through 9). Self-explanatory. The amount on Line 9 represents the total TPP funds available as of
the date of this requisition.
6. AMOUNT OF THIS REQUISITION (Line 10). Self-explanatory. Line 10 cannot exceed Line 9.
7. SUBMISSION AND DISTRIBUTION OF REQUISITIONS. An original and three copies of the requisition for partial payment
shall be submitted quarterly by the LHA to the appropriate HUD Area Office for approval. Only one copy of the supporting documentation
shall be submitted. After approval by the HUD Area Office, one copy of the approved requisition shall be returned to the LHA; the original
and one copy shall be sent to the Director, Regional Accounting Division for payment; and one copy shall be retained by HUD Area Office
together with the supporting documents.
HUD-54005 (1-75)
7/76
Page 2
HUD-Wash., D. C.
7440.2
Appendix 5
APPENDIX 5 - FLOW CHART FOR MANAGEMENT INITIATIVES FOR
INDIAN HOUSING (MIFIH) PROGRAM
ASSISTANT SECRETARY FOR
CONSUMER AFFAIRS AND
REGULATORY FUNCTIONS
(CARF)
CARF INDIAN POLICY
AND PROGRAMS OFFICE
STRATEGY
REVIEW AND
DOCUMENT
MAKE RECOM-
MENDATIONS
ASSISTANT SECRETARY
FOR HOUSING (H)
H OFFICE OF HOUSING
PROGRAMS
ADMINISTRATION OFFICE
OF FINANCE AND
ACCOUNTING (OFA)
NO
REGIONAL
ADMINISTRATOR
REVIEW
APPROVE?
YES
ASSISTANT REGIONAL
1
ADMINISTRATOR OR
DEVELOP
STRATEGY
STRATEGY
STRATEGY
HOUSING MANAGEMENT
START
REGIONAL
DOCUMENT
DOCUMENT
DOCUMENT
STRATEGY
OR INDIAN PROGRAMS
REGIONAL INDIAN
SPECIALIST
IMPUT
REVIEW
CONCUR
REGIONAL ACCOUNTING
DIVISION
REGIONAL PROGRAM
OFFICES
INPUT
AS
REQUESTED
AREA OFFICE (INVOLVEMENT
SUBJECT TO DELEGATION OF
RESPONSIBILITIES BY
REGIONAL ADMINISTRATOR
INDIAN HOUSING
AUTHORITIES (IHAs)
GROUP TRAINERS
(NON-HUO)
INDIVIDUAL TRAINERS
COLLEGES ETC.
(NON-HUD)
1
FUNDS HAVE PREVIOUSLY BEEN ASSIGNED
TO THE REGIONS BY HUD-185
1
HUD-Wash., D.C.
7440.2
Appendix 5
APPENDIX 5 - FLOW CHART FOR MANAGEMENT INITIATIVES FOR
INDIAN HOUSING (MIFIH) PROGRAM (Cont'd)
NO
ASSISTANT SECRETARY FOR
CONSUMER AFFAIRS AND
YES
REGULATORY FUNCTIONS
APPROVE?
(CARF)
CARF INDIAN POLICY
APPROVAL MEMO
AND PROGRAMS OFFICE
& STRATEGY
DOCUMENT
ASSISTANT SECRETARY
FOR HOUSING (H)
H - OFFICE OF HOUSING
PROGRAMS
ADMINISTRATION OFFICE
OF FINANCE ANO
ACCOUNTING (OFA)
REGIONAL
ADMINISTRATOR
MEMO OF
APPROVAL
ASSISTANT REGIONAL
PREPARE LETTER
PUBLIC NOTICE
NOTICE TO
PREPARE PUBLIC
ADMINISTRATOR FOR
OF STRATEGY&
LETTER
SOLICITING GROUP
REVIEW
PROCEED
NOTIFICATION OF
HOUSING MANAGEMENT
PROCEDURES FOR IHA
TRAINER
PROPOSALS
GROUP TRAINERS
OR INDIAN PROGRAMS
DEVEL OF PLANS
PROPOSALS
REGIONAL INDIAN
SPECIALIST
REGIONAL ACCOUNTING
DIVISION
REGIONAL PROGRAM
OFFICES
AREA OFFICE (INVOLVEMENT
SUBJECT TO DELEGATION OF
RESPONSIBILITIES BY
REGIONAL ADMINISTRATOR
INDIAN HOUSING
AUTHORITIES (IHAs)
LETTER
BEGIN PREPAR-
ATION OF PLANS
GROUP TRAINERS
(NON-HUD)
PUBLIC
DEVELOP
NOTICE
PROPOSALS
PROPOSALS
INDIVIDUAL TRAINERS
- COLLEGES, ETC.
(NON-HUD)
2
HUD-Wash., D.C.
7440.2
Appendix 5
SIGNS
LETTER
YES
CHOOSE
NOTIFY IHAs
WRITTEN
WORK OUT
REQUEST PRE-
PREPARES LETTER
NO
CONSULT
GROUP
AND GROUP
PLAN
REVIEW
COMPROMISE
VALIDATION
OF OBLIGATION COM-
LETTER OF
APPROVES?
TRAINERS
TRAINERS
REVISION
OF FUNDS TO
MITING FUNDS AS PRE-
OBLIGATION
WITH IHA
IHAs
VALIDATED TO IHA
2
INPUT
PREVALIDATES
FUNOS POSTS
ACCOUNTING
RECORDS
COMPL ETE
WRITTEN
WORK OUT
CONSULT
PREPARATION
PLAN
COMPROMISE
OF PLANS
REVISION
WITH ARA
SELECTED GROUP
TRAINERS REFINE
PROPOSED
SESSIONS
2
NEXT ACTION DEPENDS ON TIME AVAILABLE
BEFORE 9/30/76; PROCEED WITH PREVALIOATION
FIRST UNLESS THERE IS SUFFICIENT TIME TO
WORK DUT AN APPROVABLE REVISION.
3
HUD-Wash., D.C.
7440.2
Appendix 5
APPENDIX 5 - FLOW CHART FOR MANAGEMENT INITIATIVES FOR
INDIAN HOUSING (MIFIH) PROGRAM (Cont'd)
ASSISTANT SECRETARY FOR
CONSUMER AFFAIRS AND
REGULATORY FUNCTIONS
(CARF)
CARF INDIAN POLICY
COPY OF
COPIES OF REPORTS
AND PROGRAMS OF FICE
MEMO
FOR EVALUATION
FINANCIAL
REPORTS
OF PROGRAM
ASSISTANT SECRETARY
FOR HOUSING (H)
COPY OF
MEMO
H OFFICE OF HOUSING
COPIES OF REPORTS
PROGRAMS
FINANCIAL
COPY OF
FOR EVALUATION
REPORTS
MEMO
OF PROGRAM
ADMINISTRATION OFFICE
COPY OF
OF FINANCE ANO
FINANCIAL
STOP
ACCOUNTING (OFA)
REPORTS
REGIONAL
ADMINISTRATOR
ASSISTANT REGIONAL
PREPARES NOTIFI-
DRAFT MEMO RE
MEMO
ADMINISTRATOR FOR
CATION LETTERS
NOTIFICATION
PARTICIPATING
SEND BY
REPORTS
HOUSING MANAGEMENT
TO IHAs OF PLAN
LETTER
IHAs. FUNOS COM
10/29/76
APPROVAL
MITTED GROUP
OR INDIAN PROGRAMS
TRAINERS
REGIONAL INDIAN
SPECIALIST
REGIONAL ACCOUNTING
DIVISION
FINANCIAL
REPORTS
REGIONAL PROGRAM
OFFICES
AREA OF FICE (INVOLVEMENT
SUBJECT TO DELEGATION OF
RESPONSIBILITIES BY
REGIONAL ADMINISTRATOR
INDIAN HOUSING
LETTER OF
PREPARES
AUTHORITIES (IHAs)
OBLIGATION
AMENOS
NOTIFICATION
COMMENCE
QUARTERLY
FINANCIAL
RECEIVED BY
OPERATING
LETTER
TRAINING
REPORTS
REPORTS
9/30/76
BUDGET
ACTIVITIES
GRDUP TRAINERS
(NON-HUD)
EVALUATION
INPUT
REPORTS
INDIVIDUAL TRAINERS
- COLLEGES, ETC.
INPUT
(NON-HUD)
4
HUD-Wash., D.C.
5. OF THE INTERIOR
United States Department of the Interior
BUREAU OF INDIAN AFFAIRS
WASHINGTON, D. C. 20245
March
1849
IN REPLY REFER TO:
Housing Assistance
BCCO -5379
SEP 21 1976
Mr. Lawrence Tomah, Jr.
Box 187
Walters, Oklahoma 73572
Dear Mr. Tomah:
President Ford has asked us to respond to your August 7 letter
concerning the operation of the Comanche Housing Authority and
your request for an audit of funds used by the Comanche Housing
Authority from 1970-1976.
As you may already know, the audit of the Comanche Housing Authority's
books and records is not performed by the BIA. Prior to the publica-
tion of the HUD regulations on Indian Housing, the Department of the
Interior Audlt Investigation and Survey Office conducted audits of
Indian housing authorities to the extent their manpower and schedule
permitted. HUD has now assumed this responsibility.
If you feel that the Comanche Housing Authority Is not administering
its housing projects or programs in accordance with HUD regulations
and if there is non-compllance to the established housing authority
criteria, we suggest that you bring these matters to the attention
of the appropriate HUD office (Oklahoma City Office, 301 North Hudson
Street, Oklahoma City, Oklahoma 73102). You may also want to
request HUD approval for an audit. We are also sending copies of
your letter to HUD for their further action.
Sincerely yours,
(SGD) Morris Thompson
Commissioner of Indian Affairs
CC:
Bradley H. Patterson. White House
Area Director, Anadarko, w/copy of incoming.
HUD, Office of Housing Programs, with copy incoming
THE WHITE HOUSE
WASHINGTON
8-27-76
Dear Mr. Tomah:
The President has asked me to thank you for
your letter of August 7 about the Comanche
Housing Authority.
5379
The General Accounting Office is an arm of
Congress; it responds to requests made by
Chairmen of Congressional Committees and
by Members of Congress.
Since, however, the Comanche Housing Authority
presumably received funds from either the Depart-
ment of the Interior or HUD, I would think that
one of these agencies would be interested in your
complaint. I will start with the Department of
the Interior and ask them to respond directly
to your inquiry.
Sincerely yours,
Bradley H. Patterson, Jr.
Mr. Lawrence Tomah, Jr.
Box 187
Walters, Oklahoma 73572
cc: Housing Office, Bureau of Indian Affairs for direct reply
with copy to Bradley Patterson, White House
1
Box 187
Walters, Ok.
73572
August 7, 1976
5379
Gerald Ford
President of the United States
FURD & LIBRARY DERALO
Washington, D. C. 20001
Dear Sir:
This letter is about our Comanche Housing Authority
located at Lawton, Oklahoma.
Many Comanche Indians are not satisfied with its opera-
tion.
Our Comanche Tribal Business Committee will not respond
to tribal members' requests for information.
Therefore I am requesting an audit from the General
Accounting Office in Washington, D.C. of the funds used
by the Comanche Housing Authority from 1970 to the
present July 1976.
fruine Jr. Jamar
To:
Senator Bartlett
Former member of the
Senator Bellmon
Comanche Business Committee
One of the writers of the
Comanche Constitution
Former member of the Okla.
Indian Affairs Commission
under the former Governor
Dewey F. Bartlett
-
Not'l American
Suction Hausing
Comeril
1030 LIBRADA is
Newda
has a BIA contract
helps twith them /
this
FYI
N
National American Indian Housing Council
TELEPHONE (702) 882-1766
P. O. Box 215
STEWART, NEVADA 89437
August 31, 1976
Mrs. Carla A. Hills
EXECUTIVE DIRECTOR
Secretary
BP
Loie Brooks
Department of Housing
CHAIRMAN
and Urban Development
Tim Foster
451 7th Street S.W.
Chairman, Yakima Nation
Washington, D.C. 20410
Housing Authority
Dear Secretary Hills:
VICE-CHAIRMAN
Lloyd LeBeau
Executive Director, Cheyenne
Enclosed are Resolutions No. NAIHC 6/76-1
River Housing Authority
through NAIHC 6/76-6 which were introduced
and adopted by the member Indian Housing
SECRETARY
Authorities during the annual convention
Marvin Abrams
Chairman, Seneca Nation
of the National American Indian Housing
Housing Authority
Council's annual convention June 21-25,1976
R. FORD
at Niagara Falls, New York.
TREASURER
Ronald Froman
Sincerely,
Executive Director, Housing
Authority of the Creek Nation
NATIONAL AMERICAN INDIAN HOUSING COUNCIL
Jase Brooks
Loie Brooks
Executive Director
enc: Resolutions
cc:
President, United States of America
Board of Directors
1b/pm
Circumstance is the Ruler of the Weak
and the Instrument of the Wise
N
National American Indian Housing Council
TELEPHONE (702) 882-1766
P. O. Box 215
STEWART, NEVADA 89437
RESOLUTION
No. NAIHC 6/76-1
FORD
WHEREAS, AN ACUTE SHORTAGE OF DECENT, SAFE AND SANITARY HOUSING
CONTINUES TO EXIST IN INDIAN AREAS; AND
WHEREAS, THE CONGRESS OF THE UNITED STATES, IN THE HOUSING AND
COMMUNITY DEVELOPMENT Act OF 1974, RECOGNIZES THE SHORTAGE OF
HOUSING IN INDIAN AREAS AND MANDATES, THROUGH ITS SET-ASIDE OF
FUNDS FOR INDIAN HOUSING, THAT THE SECRETARY OF THE U.S. DEPARTMENT
OF HOUSING AND URBAN DEVELOPMENT TAKE ACTIONS TO ALLEVIATE
THE DEPLORABLE HOUSING CONDITIONS ENDURED BY INDIAN FAMILIES; AND
WHEREAS, THE DEYELOPMENT OF INDIAN HOUSING THROUGH NEGOTIATED
CONTRACTS WITH INDIAN-OWNED CONSTRUCTION ORGANIZATIONS HAS
PRODUCED HOUSING MEETING VERY HIGH STANDARDS AT A REASONABLE
COST, HAS PROVIDED EMPLOYMENT OPPORTUNITIES AND TRAINING EXPERIENCE
IN CONSTRUCTION SKILLS FOR INDIAN WORKERS AND HAS MADE POSSIBLE
THE ECONOMIC DEVELOPMENT OF TRIBAL RESOURCES, WHICH NEGOTIATED
CONTRACTS HAVE HISTORICALLY BEEN UTILIZED AND WHICH WERE ALLOWED
BY A PROVISION INCLUDED IN THE PROPOSED INDIAN HOUSING REGULATIONS
AS PUBLISHED FOR COMMENT ON SEPTEMBER 19, 1975; AND
WHEREAS, IN DISREGARD OF THE SUPPORT FOR THE PROVISION FOR
NEGOTIATED CONTRACTS FROM INDIAN LEADERS, |RIBAL GOVERNMENTS,
INDIAN HOUSING AUTHORITIES AND OTHERS INTERESTED IN INDIAN HOUSING,
SAID PROVISION WAS ARBITRARILY DELETED FROM THE INDIAN HOUSING
REGULATIONS WHEN SUCH REGULATIONS WERE PUBLISHED FOR IMPLEMENTATION
ON MARCH 9, 1976; AND,
WHEREAS, THE DELETION OF SAID PROVISION FOR NEGOTIATED CONTRACTS
IS ALIEN TO THE POLICY OF INDIAN SELF-DETERMINATION, IS NOW DELAYING
THE DEVELOPMENT OF DECENT, SAFE AND SANITARY HOUSING FOR INDIAN
FAMILIES, IS WITHHOLDING EMPLOYMENT OPPORTUNITIES AND TRAINING
EXPERIENCE FOR INDIAN WORKERS AND IS RESTRICTING THE DEVELOPMENT
OF INDIAN RESOURCES;
NOW THEREFORE, BE IT RESOLVED BY THE MEMBERS OF THE NATIONAL
AMERICAN INDIAN HOUSING COUNCIL, ASSEMBLED AT NIAGARA FALLS, NEW
YORK, AS FOLLOWS:
N
National American Indian Housing Council
TELEPHONE (702) 882-1766
P. O. Box 215
STEWART, NEVADA 89437
PAGE TWO
No. NAIHC 6/76-1
1.
THAT THE MANY INDIAN HOUSING AUTHORITIES HERE ASSEMBLED
DO PETITION THE SECRETARY OF THE U.S. DEPARTMENT OF
HOUSING AND URBAN DEVELOPMENT TO REINSTATE THE PROVISION IN THE
INDIAN HOUSING REGULATIONS TO ALLOW THE NEGOTIATION OF DEVELOPMENT
CONTRACTS BETWEEN INDIAN HOUSING AUTHORITIES WHICH CHOOSE TO DO
so AND INDIAN-OWNED ECONOMIC ENTERPRISES AND OTHER INDIAN ORGAN-
IZATIONS; AND,
2.
THAT THE NEGOTIATION PROVISION BE REINSTATED IN ADDITION
TO ANY PREFERENTIAL TREATMENT AFFORDED INDIAN-OWNED
ECONOMIC ENTERPRISES UNDER THE PROVISIONS OF THE INDIAN SELF-
DETERMINATION AND EDUCATION ASSISTANCE AcT; AND,
3.
THAT THE CHANGE IN THE REGULATIONS REINSTATING THE PROVISION
FOR NEGOTIATED CONTRACTS BE PROMULGATED AND DISTRIBUTED
TO FIELD OFFICES OF THE U.S. DEPARTMENT OF HOUSING AND URBAN
DEVELOPMENT NOT LATER THAN JULY 15, 1976, IN ORDER TO MINIMIZE
THE DELAY IN THE DELIVERY OF INDIAN HOUSING; AND,
4.
THAT THE SECRETARY OF THE NATIONAL AMERICAN INDIAN HOUSING
COUNCIL IS HEREBY AUTHORIZED AND DIRECTED TO IMMEDIATELY
DISPATCH A CERTIFIED COPY OF THIS RESOLUTION TO THE PRESIDENT OF
THE UNITED STATES, TO THE SECRETARY OF THE U.S. DEPARTMENT OF
HOUSING AND URBAN DEVELOPMENT, TO THE APPROPRIATE CONGRESSIONAL
COMMITTEES, TO THE NATIONAL TRIBAL CHAIRMEN'S ASSOCIATION AND TO
THE NATIONAL CONGRESS OF AMERICAN INDIANS.
CERTIFICATION
THE UNDERSIGNED, ACTING AS THE DULY QUALIFIED AND ELECTED SECRETARY
OF THE NATIONAL AMERICAN INDIAN HOUSING COUNCIL, DOES HEREBY CERTIFY
THAT THE FOREGOING RESOLUTION WAS DULY AND PROPERLY INTRODUCED,
CONSIDERED AND ADOPTED BY THE GENERAL MEMBERSHIP OF THE NATIONAL
AMERICAN INDIAN HOUSING COUNCIL AT ITS ANNUAL MEETING ON THE 24TH
DAY OF JUNE, 1976.
ATTEST:
Mawn B. abramo
CHAIRMAN
SECRETARY
N
National American Indian Housing Council
TELEPHONE (702) 882-1766
P. O. BOX 215
STEWART, NEVADA 89437
RESOLUTION
No. NAIHC 6/76-2
WHEREAS, THE NATIONAL AMERICAN INDIAN HOUSING COUNCIL SEEKS
AND IS SUPPORTIVE OF REGIONALIZED TRAINING IN MANAGEMENT
INITIATIVES FOR INDIAN HOUSING AUTHORITIES, FLEXIBILITY IS
NEEDED IN ORDER TO DESIGN AND IMPLEMENT COURSES OF ACTION THAT
WILL EXPEDITE : SERVICE ORIENTATION FOR EACH AREA; AND
WHEREAS, IT IS RECOGNIZED THAT HOUSING AUTHORITY TRAINING ON
A NATIONAL BASIS MAY NOT HAVE ADAPTABILITY NECESSARY FOR ADEQUATE
SERVICE DELIVERY; AND,
THEREFORE, BE IT RESOLVED THAT WHEN TRAINING IN MANAGEMENT
INITIATIVES BE IMPLEMENTED IN EACH HUD REGION, THAT INPUT FROM
THE INDIAN HOUSING AUTHORITIES AFFECTED BE INCLUDED IN THE
APPROVED PROGRAM.
CERTIFICATION
THE UNDERSIGNED, ACTING AS THE DULY QUALIFIED AND ELECTED SECRETARY
OF THE NATIONAL AMERICAN INDIAN HOUSING COUNCIL, DOES HEREBY CERTIFY
THAT THE FOREGOING RESOLUTION WAS DULY AND PROPERLY INTRODUCED,
CONSIDERED AND ADOPTED BY THE GENERAL MEMBERSHIP OF THE NATIONAL
AMERICAN INDIAN HOUSING COUNCIL AT ITS ANNUAL MEETING ON THE 24TH
DAY OF JUNE, 1976,
ATTEST:
That
Mawri B. abram
CHAIRMAN
SECRETARY
N
National American Indian Housing Council
TELEPHONE (702) 882-1766
P. O. Box 215
STEWART, NEVADA 89437
RESOLUTION
No. NAIHC 6/76-3
WHEREAS, THE INDIAN HOUSING AUTHORITIES OF THE DENVER REGION
OBJECTS TO THE PRESENT PERFORMANCE FUNDING SYSTEM BEING USED TO
DETERMINE THE CORRECT AMOUNT OF OPERATING SUBSIDIES FOR THE
FOLLOWING REASON:
1.
THAT THE SYSTEM IS TOO COMPLICATED TO USE EFFECTIVELY
BY THE LOCAL HOUSING AUTHORITIES.
2.
THAT THE FORMULA WORKS AN INJUSTICE TO THE INDIAN
HOUSING AUTHORITIES, BECAUSE AN IMPROPERLY DETERMINED
OPERATING SUBSIDY MAY NOT BE ENOUGH TO MAKE UP THE DIFFERENCE
BETWEEN WHAT RENTALS ARE RECEIVED AND THE TOTAL OPERATING COSTS
ARE,
3.
THAT THE INDIAN HOUSING AUTHORITIES HAYE NOT BEEN EXPOSED
TO ENOUGH TRAINING ON THE PERFORMANCE FUNDING SYSTEM TO
PROPERLY UTILIZE THE SAME.
4.
THAT A MORE SIMPLIFIED SYSTEM BE USED TO ARRIVE AT FAIR
OPERATING SUBSIDIES.
NOW, THEREFORE, BE IT RESOLVED THAT THE FOREGOING RESOLUTION BE
ADOPTED BY THE NATIONAL AMERICAN INDIAN HOUSING COUNCIL IN
SESSION THIS 24TH DAY OF JUNE, 1976, AT NIAGARA FALLS, NEW YORK; AND
BE IT FURTHER RESOLVED THAT THIS RESOLUTION BE BROUGHT TO THE
ATTENTION OF THE DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT FOR
IMMEDIATE CORRECTIVE ACTION TO ALLEVIATE THE SITUATION DISCUSSED
IN THIS RESOLUTION.
CERTIFICATION
THE UNDERSIGNED, ACTING AS THE DULY QUALIFIED AND ELECTED SECRETARY
OF THE NATIONAL AMERICAN INDIAN HOUSING COUNCIL, DOES HEREBY CERTIFY
THAT THE FOREGOING RESOLUTION WAS DULY AND PROPERLY INTRODUCED,
CONSIDERED AND ADOPTED BY THE GENERAL MEMBERSHIP OF THE NATIONAL
AMERICAN INDIAN HOUSING COUNCIL AT ITS ANNUAL MEETING OF THE 24TH
DAY OF JUNE, 1976.
ATTEST:
Marin B. abams
CHAIRMAN
SECRETARY
N
National American Indian Housing Council
TELEPHONE (702) 882-1766
P. O. Box 215
STEWART, NEVADA 89437
RESOLUTION
No. NAIHC 6/76-4
WHEREAS, THE NATIONAL AMERICAN INDIAN HOUSING COUNCIL IN
FORD
CONVENTION ASSEMBLED, IS THE DULY RECOGNIZED SPOKESMEN FOR
INDIAN HOUSING AUTHORITIES ON A NATIONAL BASIS TO SECURE, BY
UNITED EFFORT, ALL THE BENEFITS, RIGHTS, PRIVILEGES AND POWERS
AS PROVIDED FOR AND BY THE LAWS OF THE UNITED STATES NOW
EXISTING OR THAT MAY HEREAFTER BE ENACTED FOR THE BENEFITS OF
ALL CITIZENS OF THE UNITED STATES; AND
WHEREAS, THE NATIONAL AMERICAN INDIAN HOUSING COUNCIL IS ENABLED
TO PROVIDE CONSTANT SURVEILLANCE OF CURRENT HOUSING AND URBAN
DEVELOPMENT POLICIES AND TO RECOMMEND CHANGES IN REGULATIONS
AND RECOMMEND LEGISLATION THAT WOULD INSURE BETTER HOUSING
PROGRAMS; AND,
WHEREAS, THE NEW HUD REGULATIONS, FEDERAL REGISTER VOLUME 41,
No. 47, SECTION #805. 416 REQUIRE MONTHLY PAYMENTS OF 25% OF
THE HOMEBUYER'S INCOME MINUS A UTILITY DEDUCTION WILL RESULT
IN GREAT DISCREPANCIES IN PAYMENTS BETWEEN FAMILIES OF THE
SAME NET FAMILY INCOME DEPENDING UPON WHETHER THEY ARE IN OLD
OR NEW PROJECTS; AND,
WHEREAS, IT HAS TAKEN YEARS TO PARTIALLY CONVINCE OUR FAMILIES
THAT A PAYMENT BASED UPON INCOME IS FAIR, THIS RULE IMPOSES AN
UNFAIR BURDEN UPON LOW INCOME INDIAN FAMILIES BY REQUIRING NOT
LESS THAN 25% OF AN ALREADY INADEQUATE MONTHLY INCOME TO BE
PAID TO THE HOUSING AUTHORITY AT A TIME WHEN OTHER FAMILY EXPENSES
ARE so INFLATED AND WHEN OTHER MORE FORTUNATE FAMILIES NOT
CLASSIFIED LOW INCOME DO NOT HAVE TO COMMIT SUCH A LARGE PORTION
OF THEIR INCOME TO HOUSING; NOW,
THEREFORE, BE IT RESOLVED THAT THE NATIONAL AMERICAN INDIAN
HOUSING COUNCIL REQUESTS THE MODIFICATION OF SECTION #805.416 TO
ACHIEVE A MORE EQUITABLE PAYMENT SCHEDULE AS BETWEEN MUTUAL HELP
PARTICIPANTS, IRRESPECTIVE OF WHEN THEY ENTERED THE PROGRAM, AS
WELL AS RESULT IN A MONTHLY PAYMENT THAT REPRESENTS A PERCENTAGE
OF INCOME THAT WILL NOT UNDULY BURDEN THE MUTUAL HELP PARTICIPANT
TO THE POINT WHERE OTHER FAMILY NECESSITIES CANNOT BE PROVIDED
FOR; AND,
BE IT FURTHER RESOLVED THAT WE HEREBY SUPPORT THE POSITION PAPER
PREPARED REGARDING THE PROBLEM.
N
National American Indian Housing Council
TELEPHONE (702) 882-1766
P. O. Box 215
STEWART, NEVADA B9437
PAGE TWO
No. NAIHC 6/76-4
CERTIFICATION
THE UNDERSIGNED, ACTING AS THE DULY QUALIFIED AND ELECTED SECRETARY
OF THE NATIONAL AMERICAN INDIAN HOUSING COUNCIL, DOES HEREBY CERTIFY
THAT THE FOREGOING RESOLUTION WAS DULY AND PROPERLY INTRODUCED,
CONSIDERED AND ADOPTED BY THE GENERAL MEMBERSHIP OF THE NATIONAL
AMERICAN INDIAN HOUSING COUNCIL AT ITS ANNUAL MEETING ON THE 24TH
DAY OF JUNE, 1976.
ATTEST:
Maron B. abram
CHAIRMAN
SECRETARY
ATTACHED: POSITION PAPER
BY: VIRGINIA TOEWS, NORTHERN CHEYENNE HOUSING AUTHORITY
National American Indian Housing Council
TELEPHONE (702) 882-1766
P. O. BOX 215
STEWART, NEVADA 89437
RESOLUTION
No. NAIHC 6/76-5
WHEREAS, THE NATIONAL AMERICAN INDIAN HOUSING COUNCIL SEEKS TO
ACQUIRE AND IMPROVE INDIAN HOUSING; AND,
WHEREAS, THE DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT INDIAN
HOUSING RULES AND REGULATIONS, TUESDAY, MARCH 9, 1976 DISCRIMINATE
AGAINST INDIANS AND PLACES UNFAIR RESTRAINTS ON THE VALUATION
OF POTENTIAL INDIAN HOUSING SITES.
NOW THEREFORE, BE IT RESOLVED, THAT THE NATIONAL AMERICAN INDIAN
HOUSING COUNCIL HEREBY REQUESTS THE DEPARTMENT OF HOUSING AND
URBAN DEVELOPMENT TO CEASE ITS DISCRIMINATION AGAINST INDIANS
AND TO IMMEDIATELY AMEND THE INDIAN HOUSING RULES AND REGULATIONS
OF TUESDAY, MARCH 9, 1976 AS FOLLOWS:
A. THAT THE EXTRACTED PORTION OF SECTION 805.219 OF
SUBJECT RULES AND REGULATIONS BE DELETED: AN
ACCEPTABLE ESTIMATE OF THE VALUE OF THE LEASEHOLD SHALL IN NO
EVENT EXCEED 2/3 OF THE ESTIMATE OF THE VALUE AS IF ALIENABLE IN
FEE. AND, THAT LEASEHOLD VALUE SHOULD BE ESTABLISHED AT 100% OF
FAIR MARKET VALUE,
B, THAT THE EXTRACTED PORTION OF SECTION 805.404 OF
SUBJECT RULES AND REGULATIONS BE DELETED IN ITS ENTIRETY:
"HOWEVER, IF THE COST OF A PURCHASED HOMESITE EXCEEDS $1,500, THE
AMOUNT OF THE EXCESS SHALL BE COVERED BY EITHER (1) ADDITIONAL MA
CONTRIBUTIONS IN ACCORDANCE WITH SECTION 805.408, (B), IN WHICH
CASE THE COST OF THE HOMESITE MAY NOT EXCEED $2,500, OR (2) FUNDS
FROM A SOURCE OTHER THAN PROJECT FUNDS.
C. THAT OTHER SECTIONS OF SUBJECT RULES AND REGULATIONS
ABETTING THE CURRENT INTENT OF THE ABOVE BE AMENDED TO
CONFORM WITH THE COUNCIL'S RECOMMENDATIONS.
CERTIFICATION
THE UNDERSIGNED, ACTING AS THE DULY QUALIFIED AND ELECTED SECRETARY
OF THE NATIONAL AMERICAN INDIAN HOUSING COUNCIL, DOES HEREBY CERTIFY
THAT THE FOREGOING RESOLUTION WAS DULY AND PROPERLY INTRODUCED,
CONSIDERED AND ADOPTED BY THE GENERAL MEMBERSHIP OF THE NATIONAL
AMERICAN INDIAN HOUSING COUNCIL AT ITS ANNUAL MEETING ON THE 24TH
DAY OF JUNE, 1976.
ATTEST:
Marin B. abram
CHAIRMAN
SECRETARY
N
National American Indian Housing Council
TELEPHONE (702) 882-1766
P. O. Box 215
STEWART, NEVADA 89437
RESOLUTION OF ENDORSEMENT
No. NAIHC 6/76-6
THE GENERAL MEMBERSHIP OF THE NATIONAL AMERICAN INDIAN HOUSING
COUNCIL VOTED TO ENDORSE THE FOLLOWING:
1. THE LETTER FROM THE ONEIDA HOUSING AUTHORITY,
DATED JUNE 17, 1976, WRITTEN AND SENT TO
SECRETARY HILLS OF THE DEPARTMENT OF HOUSING
AND URBAN DEVELOPMENT.
2. RESOLUTIONS MADE PREVIOUSLY BY THE NATIONAL
TRIBAL CHAIRMEN'S ASSOCIATION;
No. NTCA 5/76-1
No. NTCA 5/76-21
CERTIFICATION
THE UNDERSIGNED, ACTING AS THE DULY QUALIFIED AND ELECTED SECRETARY
OF THE NATIONAL AMERICAN INDIAN HOUSING COUNCIL, DOES HEREBY CERTIFY
THAT THE FOREGOING RESOLUTION WAS DULY AND PROPERLY INTRODUCED,
CONSIDERED AND ADOPTED BY THE GENERAL MEMBERSHIP OF THE NATIONAL
AMERICAN INDIAN HOUSING COUNCIL AT ITS ANNUAL MEETING ON THE 24TH
DAY OF JUNE, 1976.
ATTEST:
CHAIRMAN
Maroin B. abrams
SECRETARY
STEWART
U.S.POSTAGE
National American
N
SEP-2'78
E24E !!!
Indian Housing Council
NEV
C219484
IMETER
P. O. Box 215
STEWART, NEVADA 89437
President Gerald Ford
HOUSE SECURITY
THE WHITE HOUSE
WHITE RECEPTION Processed SEP by. 6 1976 2
Washington, D.C. 20500
Washington,
17th September 1976.
Dear Mr. Patterson,
Enclosed is a copy of the draft Memorandum of Understanding
between HUD-HEW-Interion regarding Indian Housing Projects;
I located a copy in the Office of the Secretary here at HUD.
It's my understanding that a final Memorandum has not yet
been agreed to.
Previously I had suggested you could contact Dennis Blair,
a Special Assistant to Secretary Hills and a White House Fellow,
as a knowledgable person about Indians in HUD; Dennis is no
longer with the Department and a new White House Fellow came
two weeks ago (Porter Briggs from Little Rock).
You sounded so busy yesterday when you returned my call! If
the Task Force you are co-ordinating needs (additional) staff,
please consider me...a detail from another Executive Department
should be okay I hope. As an analyst in Office of Budget/Office
of the Secretary at HUD I'm being exposed to a great many facets
of Housing, Indian Housing, and litigation involving the Department.
I hope we can get together soon.
Best,
Ray Ray Millard.
FORD LIBRARY "y 07 &
INTERAGENCY MEMORANDUM OF UNDERSTANDING
GERALE FORD JOHARY
ON CLEARANCES FOR INDIAN HOUSING PROJECTS
1. This Memorandum of Understanding applies to housing
projects undertaken by Indian Housing Authorities (IHAs) of
Federally Recognized Tribes for which financial and technical
assistance is provided by the Department of Housing and Urban
Development (HUD), the Bureau of Indian Affairs, Department of
Interior (BIA) and the Indian Health Service, Department of
Health, Education and Welfare (IHS).
2. HUD is responsible for certifying compliance of the
entire project with the provisions of the National Environmental
Policy Act of 1969 (P.L. 91-190), the Flood Disaster Act of
1973 (P.L. 93-234) and Executive Order 11514. HUD procedures
apply. BIA and IHS furnish to HUD the specifications of their
parts of the project. HUD will not consider its environmental
review complete until notified by BIA that the clearances in
paragraphs 3 and 4 have been conducted.
3. BIA is responsible for compliance of the entire project
with the Act for the Preservation of American Antiquities of
1906 and the National Historic Preservation Act of 1966 (P.L. 89-
665) and Executive Order 11593. BIA procedures apply. HUD
and IHS furnish to BIA the specifications of their parts of
the project.
4. BIA is responsible for compliance of the entire project
with the Archaeological and Historic Data Preservation Act of
1974 (P.L. 93-291). HUD and IHS will furnish to BIA the
specifications of their parts of the project. Should the
recovery, protection or preservation of scientific, pre-
historical, historical or archaeological data prove necessary,
BIA will reach agreement with HUD or IHS regarding funding
responsibility.
5. If preliminary surveys are necessary to determine if
any part of a project will affect scientific, prehistorical,
historical or archaeological properties or data, they will be
funded by the Indian Housing Authority from preliminary loan
funds advanced by HUD.
6. All parties to this agreement will have the opportunity
for review and clearance of documents and reports written by
other parties.
Back ground
1. Original Draft 1/30/76
FORD YOWARK
2. HEW's Comments 3/19/76
3 BIA redraft 1/28/76
BIA /NPS Dratt of
an MOU
4/28/76
INTERAGENCY MEMORANDUM OF UNDERSTANDING
ON CLEARANCES FOR INDIAN HOUSING PROJECTS
I. Principles
A. HUD is the designated lead agency for environmental
clearance. HUD procedures and standards apply. BIA and IHS
furnish to HUD the specifications of their parts of the
project.
B. BIA is responsible for coordinating and insuring
compliance of the entire project with the Act for the
Preservation of American Antiquities of 1906 and the
National Historic Preservation Act of 1966 and Executive
Order 11593, Protection and Enhancement of the Cultural
Environment. The notification from BIA that these clearances
have been completed will be necessary before HUD can consider
its environmental review complete.
C. BIA is responsible for coordinating and insuring
compliance with the Archeological and Historical Preservation
Act of 1974 and mitigation commitments made during the
compliance phase of program or project planning.
D. Responsibilities and Funding
1. If preliminary surveys are necessary to locate or
inventory historical or archeological resources or to determine
if any part of the project will affect historical or archeological
2
resources, then such surveys will be funded by the IHA from
preliminary loan funds. If the results of these surveys and
evaluations indicated any part of the project will have an
effect on archeological or historical resources, then the BIA
will initiate the appropriate procedures of 36 CFR Pt. 800
based on data provided by the surveys funded by the
preliminary loan.
2. If salvage of archeological or historical values
in a project area is required or warranted, then the funding
for the salvage operations will be in accordance with
Section 3(a), 3(b) or 4(a) of the Historic and Archeological
Preservation Act of 1974, as may be appropriate. If the
salvage is within the lot lines or along a roadbed, then
Interior will be responsible for funding; if the salvage is
along a water or sewer line then IHS will be responsible
for funding.
II. Process
It is anticipated that the following process of actions
will take place for a typical Indian housing project.
A. Generally an Indian Housing Authority approaches a
local BIA representative for advice on site selection before
it submits an application to HUD, because the BIA is
3
responsible for the trust, providing for leases and recording
of final site surveys and right away easements. The Indian
Health Service at this time can make an estimate of the areas
in which it would be necessary to run water and sewer lines
for sites under consideration. At this time the BIA repre-
sentative after consulting with the Regional Director of the
appropriate National Park Service Office, the State Historic
Preservation Office, and state archeologists and historians
should make and document a preliminary assessment of the need
for detailed professional surveys of the project site.
B. When HUD approves the IHA's program application for
a particular number of units and advances a preliminary loan,
the IHA will advise BIA of the specific sites under consideration
for the project. The BIA representative, after consulting with
the Indian Health Service, the IHA will contact the National Park
Service or their contract representatives to examine the constructio
area to determine whether archeological clearance can be given
or determine where further professional examination should be
conducted.
C. Based on the professional report, and the recommendations
of the NPS, the BIA will advise the housing authority which parts
of the project will cause substantial damage to important
archeological or historical resources. The BIA will attempt
4
to work out alternative ways to complete a project so as not
to disturb those resources.
D. If it is not feasible to find alternative sites for
the project, then the housing authority will, based on appro-
priate professional advice, formulate a plan to mitigate the
adverse effects of the project. Generally this plan will
involve some degree of salvage or preservation operations.
The BIA will be responsible for compliance with the Advisory
Council on Historic Preservation's regulations contained in
36 CFR Pt. 800.
E. Once a Memorandum of Agreement has been negotiated with
ACHP, HUD will be informed by BIA that historical and archeological
evaluations and compliance actions are completed and, having
completed the other environmental clearances in accordance with
its own procedures, HUD can make a tentative site approval.
F. Salvage will be accomplished prior to the initiation
of actions which will disturb the archeological and historical
values determined to require further study or investigation.
G. A schematic !ow-process diagram illustrates the
procedures envisioned by this agreement.
MEMORANDUM
DEPARTMENT OF HEALTH, EDUCATION, AND WELFARE
OFFICE OF THE SECRETARY
:
Dennis Blair
DATE:
MAR 19 1976
Special Assistant to the
Secretary for the
Department of Housing
and Urban Development
:
Director
Office of Environmental Affairs
UBJECT:
Comments on the Proposed HUD/BIA/HEW Lead Agency Agreement
This Office received subject draft document on February 9,
1976, and after reviewing it, is providing you with comments
and suggestions for consideration in undertaking a revision.
As you requested, I am attaching a copy of the lead agency
agreement format used by HEW.
Overall, the memorandum needs restructuring if you are going
to follow the format of the draft, i.e., a section on
Principles and one on Process or Procedures. The principles
should be succinctly stated and cover all aspects of the
action to which this agreement applies. They should also
indicate the degree of agency responsibility with respect to
each principle. As a minimum this section should include the
following:
1. The kinds of actions that are covered by the
agreement (i.e., all new housing projects, upgrading
existing housing by providing services such as
water, electricity or sewage systems, etc.).
2. The agency responsible for obtaining environmental,
historical, and archaeological clearances.
3. Responsibility of each agency for providing
information and/or data to the agency assigned
clearance responsibility.
4. A statement regarding who will pay for costs associated
with survey, recovery of data, and printing of
EIS's, case reports and other required documents.
5. A statement regarding the opportunity for review
and clearance of documents and reports by all parties
to the agreement.
Page 2
6. A statement that no action shall be taken by any
party to the agreement with respect to approving
all or a part of any proposal, application or
grant for a project covered by this agreement until
such time as all required clearances have been
obtained.
7. Definitions for specific words or terms associated
with clearances which are important to understanding
the principles or process set forth in this
agreement. (See B. under General Comments.)
As presently written the section on process does not address
the procedures that will be followed for obtaining the various
clearances as set forth under Principles. It only addresses those
relating to archaeological clearances. Some of the information
is inaccurate and there are certain provisions with which we
cannot concur. The section should incorporate each of the
principles into the flow of documentation and actions which
occur throughout the various steps of the clearance process.
The entire section needs to be restructured and rewritten
in accordance with the above and the general comments which are
listed below.
General Comments
These comments include concerns of this Department with
respect to elements of the principles as well as suggestions
for improving and clarifying the substantive content of the
Principles and Process sections of the agreement. This
Department does not necessarily care whether or not a process
section is included in the agreement. However, if it is,
it must be consistent with the substantive legal requirements
of the acts covered by the agreement, i.e., in the case of NEPA
this means insuring that no approval of a program application
occurs prior to completing the environmental review process.
A. It is recommended that the following title be
used in referring to P.L. 93-291 on archaeological
preservation: National Archaeological Scientific
Data Preservation Act. By including scientific
data in the title, emphasis is directed at one
Page 3
of the major concerns of this Act as opposed to
that of NHPA; i.e., preservation of scientific
data as opposed to historical objects.
B. Data should be defined as it is in the NASDPA,
i.e., includes scientific, historic, prehistoric,
and archaeological data.
C. The Advisory Council on Historic Preservation does
not administer the National Archaeological
Scientific Data Preservation Act and should not
be consulted with respect to the recovery of
archaeological data. This is the responsibility
of the Department of the Interior (DOI). The NASDPA
implicitly requires that the Secretary of DOI be
informed whenever a Federally assisted project
is undertaken which may result in significant data
being irrevocably lost or destroyed. References to
historic or archaeological sites are confusing
as mentioned in the draft. Any references to the
National Historic Preservation Act (NHPA) should
be distinguished from those of NASDPA.
D. Suggest deleting Funding as a sub-heading under
Principles. Also, as presently written, paragraphs
C. 1, 2, and 3 are a mixture of principles and
process. All that need be said here is who pays for
what.
E. What is the Indian Housing Authority (IHA) and
what is its relationship to BIA? Will IHA be
obtaining and utilizing preliminary loan funds
prior to all clearances being completed (this
is not clear in the draft)? If so, whose funds?
BIA's?
F. We cannot agree to the provision that IHS will
fund the recovery of archaeological data based on
an agreement with the Advisory Council on Historic
Preservation for two reasons. The first is based
on comment C, above. The second concerns the fact
that since BIA procedures would be followed in
obtaining the archaeological clearance, including
determinations with respect to the need for recovery,
then they should also provide the funds for the
recovery operations particularly since DOI is
authorized by NASDPA to receive funds for this
program.
Page 4
G. The statement should be included under
Principles which will clearly indicate that the
Indian Health Service (IHS) will not provide
information beyond the project specification.
Since the procedures being used for clearances
will not be those of this Department, the IHS
should not be required to provide data and
information beyond that which is necessary to
comply with the procedures of this Department.
Charles fould
Charles Custard
Attachment
EPA-IAG-P5-0656
LEAD AGENCY AGREEMENT
RESEARCH TRIANGLE PARK, NORTH CAROLINA
DEPARTMENT OF HEALTH, EDUCATION, AND WELFARE
ENVIRONMENTAL PROTECTION AGENCY
It is hereby agreed that 'the Department of Health, Education,
and Welfare is designated as the lead agency for purposes of
preparing an Environmental Impact Statement on the development
of the U. S. Public Health Service Research Park at Research
Triangle Park, North Carolina. The procedures to be followed
in developing this document shall be those of the Department
of Health, Education, and Welfare.
RESPONSIBILITIES
The following is an assignment of responsibilities and
activities associated with the development of the Environmental
Impact Statement:
1. Development, coordination, and preparation of EIS - HEW.
2. Technical documentation on environmental matters, air
pollution, water pollution, noise, etc. - EPA, HEW.
3. Facility information and requirements associated with
proposed EPA research center - EPA.
4. Facility information and requirements for environmental
health sciences laboratory - HEW.
5. Printing and reproduction costs associated with reports,
impact statement, etc. - shared equally - EPA, HEW.
6. Approval of draft and final impact statements - EPA, HEW.
APPROVED
Immed
I burons hi. husan
Director, Office of Facilities
Deputy Assistant Administrator
Engineering and Property Management,
for Administration, Environ-
Department of Health, Education,
mental Protection Agency
and Welfare
Charles Contant
Sheldon Thildon Miyer Mayer
Director, Office of Environmental
Director, Office of Federal
Affairs, Department of Health,
Activities, Environmental
Education, and Welfare
Protection Agency
DRAFT Blair 1/30/76
Interagency Memorandum of Understanding
on Clearances for Indian Housing Projects
I. Principles
A. HUD designated lead agency for environmental clearance.
HUD procedures and standards apply. BIA and IHS furnish to
HUD specifications of their parts of the project.
B. BIA responsible for insuring compliance of the entire
project with the Act for the Preservation of Historical
Antiquities of 1906, the National Historic Preservation Act of
1966 and the Historic and Archaeological Data Preservation Act
of 1974. The notification from BIA that these clearances have
been completed will be necessary before HUD can consider its
environmental review complete.
C. Funding
1. If BIA determines that preliminary surveys are
necessary to determine if any part of the project site will
cause damage to historical or archaeological sites, then such
surveys will be funded by the IHA from preliminary loan funds.
2. If BIA determines that any part of the project
will cause damage to an archaeological or historical site, then
BIA will approach the Advisory Council on Historic Preservation
with a plan for mitigating the effects and negotiate an agree-
ment with the Council.
3. If a negotiated settlement with the Council includes
salvage of relics in part of a project area, then the funding
for the salvage operations will be in accordance with Section 3
2
of the 1974 Historic and Archaeological Data Preservation Act:
if the salvage is within the lot lines or along a roadbed then
Interior will provide funding; if the salvage is along a water
or sewer line then IHS will fund.
II. Process
It is anticipated that the following process of clearances
will take place for a typical Indian housing project.
A. Generally an Indian Housing Authority approaches a
local BIA representative for advice on site selection before it
submits an application to HUD, since BIA provides legal assistance
in clearing title to the land. The Indian Health Service at
this time can make an estimate of the areas in which it would
be necessary to run water and sewer lines for sites under con-
sideration. At this time the BIA representative after consulting
with the local National Park Service personnel and state
historians should make a preliminary assessment of the need
for detailed archaeological surveys of the project site.
B. When HUD approves the IHA's program application for a
particular number of units and advances a preliminary loan, the
IHA will advise BIA of the specific sites under consideration
for the project. The BIA representative after consulting with
the Indian Health Service will advise the IHA which parts of a
project should be surveyed by an archaeologist and the IHA will
arrange to have the survey conducted.
C. Based on the archaeologist's report, BIA will advise
the housing authority which parts of the project will cause
3
substantial damage to important archaeological evidence. BIA
will attempt to work out alternative ways to complete a project
so as not to disturb those sites.
D. If it is impossible to find alternative sites for the
project, then the housing authority will commission the
archaeologist to formulate a plan to mitigate the damage of
construction. Generally this plan will involve some degree of
salvage or preservation operations. BIA will be responsible
for taking this plan to the Advisory Council on Historic Preser-
vation and negotiating an acceptable agreement with them.
Funding for the salvage operations will be as provided in
Section 3 of the 1974 Historical and Archaeological Data
Preservation Act.
E. Once the agreement has been negotiated, HUD will be
informed by BIA that historical and archaeological clearances
are complete and, having completed the other environmental
clearances in accordance with its own procedures, HUD can make
a tentative site approval.