training

1. CDBG-DR
FEDERAL CIVIL RIGHTS COMPLIANCE
LEVEL 3 COMPLETING QUARTERLY REPORTING& DOCUMENTING EFFORTS
SECTION 3 AND M/WBE
2021 V2

2. AGENDA FOR LEVEL 3 SECTION 3 & M/WBE
In this learning module we will cover:
1. What are the forms used for Reporting Efforts &
Reporting Quarterly to PRDOH
2. How to complete documenting Efforts and Quarterly
Reporting.
3. Documenting and Reporting Tips

3. TRAINING CURRICULUM
Level 1 Section 3 and M/WBE Compliance Fundamentals
This module introduces the federal compliance statutes and other federal
guidance on what is Section 3 and M/WBE, its applicability, and what triggers
the need to comply. It frames additional supporting documentation and
overall process for achieving compliance as a part two to the introduction to
federal compliance for Section 3 and M/WBE.
Level 2 Section 3 and M/WBE Completing Documentation & Activities
This module uses the documents discussed in the 101 training to review the
documents themselves in depth and address questions about the document
areas and discuss different examples of how to complete the documentation.
Level 3 Section 3 and M/WBE Completing Efforts and Quarterly Reporting
This module uses the quarterly reporting form and covers in depth how to
complete each of the areas for the quarterly reporting form and addresses
technical questions from the audience.
Level 4 Section 3 and M/WBE Best Practices and Implementation Tips
This module discusses some best practices for how to implement activities and
create workflows around the compliance requirements to ensure
subrecipients or contractors will be successful in completing activities.

4. BENEFITS OF USING THE PRDOH DOCUMENTING EFFORTS TEMPLATE
• The same template for helping document your Section 3
“greatest extent feasible efforts” and “good faith efforts” for
M/WBE.
• Provides already premade drop-down lists of the efforts from the
Section 3 plan template, Section 3 policy guide and M/WBE
policy guide efforts.
• Helps you focus on performing efforts instead of debating how
to document them.
• Will assist you to complete quarterly reporting quickly.
• Provides uniformity to the process of documenting efforts and
reviewing efforts documented.

5. DOCUMENTING YOUR EFFORTS TEMPLATE
Document Structure
• The excel document has two
tabs.
• The first tab is a cover page to
summarize your status to date.
You should complete the cover
page with the relevant
information from your project.
1 2

6. DOCUMENTING YOUR EFFORTS
Documenting Efforts Template
• The second tab provides you with drop down
menus for identifying:
• The type of effort you are performing
• The intended audience
• Dropdown lists of efforts listed for Section 3
• Drop down lists for M/WBE efforts
• You will have to manually put in the date you
complete the effort
• You will have to manually put in additional
information in the comment section.

7. STREAMLINING WHERE AND HOW REPORTING HAPPENS
Working on a federally funded project means that there
will be significant tracking, reporting, documenting and so
forth.
Subrecipients have many compliance reports to complete.
To alleviate the burden of reporting on many separate
documents and trying to track the latest version of that
document, PRDOH made reporting more uniform, practical
and under one document- the Unireport.

8. QUARTERLY REPORTING FORM STRUCTURE
Reporting Form
• PRDOH’s Unireport will capture multiple compliance areas of data all in one
excel form. It captures:
• Section 3 Data
• Targeted Section 3 Workers Labor Hours
• Section 3 Workers Labor Hours
• Total Labor Hours
• Efforts performed
• MWBE Data
• Contracting/Subcontracting MBEs
• Contracting/Subcontracting WBEs
• FHEO Data
• Limited English Proficiency
• Compliance with EEOC
• Workforce Race and Gender Information
• DB Unfound Workers Data

9. QUARTERLY REPORTING FORM STRUCTURE
In the first tab
you will find
detailed
instructions and
reminders on
applicability.

10. QUARTERLY REPORTING FORM STRUCTURE
The next tab will ask you for your entity’s information and the reporting period.

11. SECTION 3 REPORTING
Reporting to HUD Section 3 Report for PRDOH
• HUD requires the Puerto Rico Department of Housing to report annually on
everyone’s activities for Section 3.
• Everyone shares the responsibility to collect and report this information as best
possible. Employers who do not track this information using a formal time and
attendance system, HUD indicates you may provide a good faith assessment of
the labor hours for a full or part time employee.
• Report 1 from the Unireport will collect Section 3 information
• Targeted Section 3 Workers Labor Hours
• Section 3 Workers Labor Hours
• Total Labor Hours
• Greatest Extent Feasible Efforts performed

12. SECTION 3 REPORTING
Report 1 will have a table to capture labor hours and a second table to capture
efforts performed in that period.

13. SECTION 3 REPORTING
To complete the efforts tables, read each option and use the Yes or No drop down
to indicate what actions have been taken during that reporting period.

14. M/WBE REPORTING
Reporting to HUD on the HUD 2516 Form for PRDOH
HUD requires the Puerto Rico Department of Housing to report
annually on:
• Number and type of registered women owned businesses who
were awarded contracting and subcontracting opportunities
• Number and type of registered minority owned businesses who
were awarded contracting and subcontracting opportunities
• Type of Trade Code and Racial/Ethnic Code
• Efforts performed to ensure that all recipients, including PRDOH
took “Good Faith Efforts”

15. M/WBE REPORTING
Report 2 Asks some basic questions to remind you to keep your MWBE utilization
report up to date and in line with what you are reporting

16. M/WBE REPORTING
Report 2 also has a table that requests data on the MBE or WBE businesses you
engaged with during the pay period.

17. M/WBE REPORTING
Report 2 also captures the efforts you performed to engage with MBE and WBE
businesses during that period. Use the yes/no drop-down menu to select response.

18. LEP REPORTING
Report 3 asks to report if you received requests for language assistance or
translations. Use the drop-down menus to choose the best response.

19. EEOC REPORTING
Report 4 covers if your entity has any open or pending cases with the EEOC.
Additionally covers questions about your policies and procedures.

20. WORKFORCE EMPLOYMENT UTILIZATION
Report 5 provides you an option to report the diversity of your organization. If you
have less than 15 employees , you are exempted from reporting. If you have more
than 15 employees, it is optional for you to report.

21. WORKFORCE EMPLOYMENT UTILIZATION
Report 5 If you choose to report on your racial/ ethnic and gender diversity, you
can use this tab to complete the information using the definitions provided in report
5 workforce tab.

22. DAVIS BACON UNFOUND WORKERS
Report 6 HUD requires to report on efforts to locate unfound workers to whom wages
are owed. Construction projects may come across the need for contractors to
document and report this to subrecipients who in turn will need to report this to
PRDOH.

23. FINAL CERTIFICATION
The Final certification asks for your name and select the I certify from the drop-
down menu. Once complete, you will use the form on the PRDOH site to submit your
report.

24. Apr.
5
Jul.
5
Oct.
5
Jan.
5
JAN - MAR APR - JUN JUL - SEP OCT – DEC
QUARTERLY REPORTING
To ensure the continual monitoring and required oversight on reporting, PRDOH
requires quarterly reporting for all subrecipients and contractors to ensure
compliance.

25. SUBMITTING YOUR QUARTERLY REPORT AND EFFORTS
Submit your Quarterly Report and
Documentation of Efforts to PRDOH
Here
Complete the form and attach your
Efforts tracker and your quarterly
report.
You can request a copy of the
submission be sent to you directly.

26. Section 3
FAQ’S
How do I know if Section 3 or M/WBE apply to me?
If you have a Subrecipient Agreement with the Department of Housing for the
use of CDBG-DR funds in excess of $200,000 for a covered project/program ,
you must comply with Section 3 benchmarks ,reporting and efforts.
If you are a Subrecipient receiving over $10,000, you must comply with M/WBE
goals, efforts and reporting.
If you are a Contractor and have a covered contract over $100,000 with at
least $1 of CDBG-DR funding for a covered contract, you must comply with
Section 3 reporting, goals and efforts.
If you are a Contractor and have over $10,000, you must comply with M/WBE
goals, efforts and reporting.

27. Section 3
FAQ’S
Can a business be both Section 3 and M/WBE?
Yes, a business/ subcontractor can be both because those compliance areas
are separate. Section 3 identified level of incomes to determine status. M/WBE
uses race and gender information to qualify businesses.
If I am not planning on subcontracting do I still need to complete documents?
Yes, you should still submit : your M/WBE utilization plan, Section 3 Plan, the
documentation of efforts template, and quarterly reports.
If Section 3 doesn’t apply to my project, do I still have to complete the quarterly
report?
Yes, you may have to complete other compliance reports such as the M/WBE
report and the FHEO report areas.

28. Section 3
FAQ’S
If I am either an MBE or WBE contractor do I fulfill the total goals?
You may have safe harbor for one of the goals for M/WBE participation of 10%
but you will still have an additional 10% goal to show good faith efforts for any
subcontracting or purchasing you perform with the CDBG-DR funding.
What happens if I don’t fulfill the goals before the end of my contract?
All awarded contractors should perform and document efforts. PRDOH has
developed templates discussed in this presentation that help you complete this
exercise. You can submit a waiver only for M/WBE before the end of your
contract for approval. This waiver request should be submitted with the efforts
and justification as appropriate.

29. Section 3
TIPS FOR THE LEVEL 5 Q & A TECHNICAL ASSISTANCE SESSION
We highly encourage you
to try completing the
documents found on the
PRDOH website for Section
3 and MWBE and
download the documents.
The technical session will
work best when you have
attempted to complete the
documents and are
finalizing them and getting
live help from our team.

30. PROGRAM DESCRIPTION
PRDOH reserves the right to update this webinar and any program materials as is needed to ensure Compliance with federal requirements.
Thank you for completing this Level 3 webinar.
Visit the PRDOH Website for Section 3 and M/WBE in English or Spanish.
Please complete our survey and share any suggestions you have for
future webinars and technical assistance sessions.
The next webinar is the Level 4 Best Practices and Implementation Tips.
Be sure to complete all the learning material available.
THANK YOU

31. Section 3
ACCESSIBILITY
The Puerto Rico Department of Housing offers reasonable
accommodation to ensure equal opportunity.
Persons with disabilities or accessibility specifics needs,
can contact:
Telephone
TTY 787-522-5950
Email
infoCDBG@vivienda.pr.gov
Postal Mail
PO Box 21365 San Juan PR 00928-1365

32. PROGRAM DESCRIPTION
Maria del Carmen Figueroa Correa, Esq.
Federal Compliance & Subrecipient Management
Assistant Deputy Secretary for Disaster Recovery
CDBG-DR Program
787.274.2527
Visit us: www.cdbg-dr.pr.gov
Write us: Section3CDBG@vivienda.pr.gov
MWBECDBG@vivienda.pr.gov
CONTACT INFORMATION