Residential Contractors

Environmental Review

All federally funded projects must undergo a review process to measure the potential environmental impact of the project and to ensure that it meets federal, state, and local environmental standards. The environmental review process ensures that the project will not negatively impact the surrounding environment or health of end users. This review must be completed by an Environmental Review Officer from HCD. During the environmental review process, environmental mitigation conditions may be identified for the project to meet local, state and federal requirements. These mitigation measures are required to be implemented to comply with HUD Environmental Requirements and will be monitored to ensure appropriate implementation. No funds may be spent on any HUD-related project that may have an adverse environmental impact or will limit the choice of reasonable alternatives.

Effective immediately, the Environmental section of the Real Estate Compliance Division will be assessing a fee for performing the Environmental Review process for agencies not receiving direct Department funding for their project/program. The fee will be based on the number of hours spent by HCDD staff members to complete the review, and it will be invoiced once the review is completed.

For additional information, you may contact the following:

Resources

• 24 CFR Part 58 Environmental Review Procedures for Entities Assuming HUD Environmental Responsibilities
• HUD Environmental Review Resources
• HUD Tiered Environmental Reviews Guidance
• HUD Web-Based Instructional System for Environmental Review
• Texas DSHS Asbestos Remediation Regulations
• HUD Lead Abatement Guidance
• Choice Limiting Actions

Pay or Play Program

The Pay or Play Program policy applies to all contracts that exceed $100,000 and/or all subcontracts that exceed $200,000 throughout the life of the contract.

The POP Program does not apply to:

• Any contract in which the primary purpose (51% or more) is the procurement or purchase of property, leases, goods, supplies, and/or equipment;
• 4.2.2. An intergovernmental contract, interlocal agreement, bulk purchasing or purchasing cooperative.
• 4.2.3. Any contract for which the City of Houston has not expended funds, regardless of funding source

All employees over the age of 18 who work at least 30 hours per week on the contract are covered.

Options

PLAY

Each covered employee must be given health insurance coverage that meets the following standards:

• The employer contributes no less than 75% of the total premium costs per covered employee per month toward the total premium cost; and
• The covered employee contributes, if any amount, no greater than 25% of the total monthly premium costs.

PAY

• The contractor will have to submit workforce audits in B2GNow (https://houston.mwdbe.com/ ) that list all PAY employee total work hours for the firm, and the total hours on the City of Houston contract for each week they work on the contract.
• A fee of $1 will be assessed to the employer for each hour of work on the covered contract that each covered employee working a total 30 hours or more for the contractor completes. A POP invoice will be generated via the B2GNow webite and will be sent to the contractor’s email as listed in their vendor profile. Invoices must be paid within 30 days of receipt via the Chase Payment Portal in B2GNow. Checks or ACH Deposit payment are no longer accepted. For payment instructions or clarity, please contact the HCD Pay or Play Coordinator, Jesse Ortiz, at 832-393-9110 or jesse.ortiz@houstontx.gov.

EXEMPTION

There are several means for an employee to be considered exempt from the POP program, including:

• Under the age of 18
• Has insurance through their spouse.
• Has Medicaid/Medicare
• Refuses Health Insurance from their employer that meets City of Houston Requirements.
• For each exempt employee, a POP-8 form must be filled out and supporting documentation/ acceptable proof of insurance are required. These POP-8 forms should be signed, notarized, and completed by the employee.

A full list of needed documents for the Pay or Play program are available on the Office of Business Opportunity’s website .

Department-Specific Guides:

• Pay or Play Technical Assistance Training Presentation
• Pay or Play Federal Regulations Packet

For more information, please contact the department’s Pay or Play Coordinator, Jesse Ortiz, at 832-393-9110 or jesse.ortiz@houstontx.gov.

Section 3 and MWSBE Hiring

Most projects funded by HCD will also require compliance with Section 3 and Minority- and Women-Owned Small Business Enterprises (MWSBEs).

HCD Policies

Document Name	Use	View
Compliance Forms: Section 3 and MWSBE	Used in all stages of hiring Section 3 and MWSBE residents and business concerns	View
Compliance Forms: Section 3 and MWSBE	Used in all stages of hiring Section 3 and MWSBE worker and business concerns	View

Required Forms

Document Name	Use	View
Compliance Forms: Section 3 and MWSBE	Used in all stages of hiring Section 3 and MWSBE residents and business concerns	View
Federal Regulations Compliance Packet	Used in all stages of hiring Section 3 and MWSBE residents and business concerns	View
Section 3 Worker Directory	Use to find and hire Section 3 Workers with relevant skills	View
Section 3 Business Directory	Use to find and contract with Section 3 Businesses	View
MWSBE Directory	Use to find and contract with MWSBEs	View

Resources

• 24 CFR 125.32 Regulations on Section 3
• HUD Section 3 Website
• HUD Section 3 Business Portal
• HUD Section 3 FAQs