Training

1. CDBG-DR
FEDERAL CIVIL RIGHTS COMPLIANCE
LEVEL 4 BEST PRACTICES AND IMPLEMENTATION TIPS
SECTION 3 AND M/WBE
2021 V2

2. Section 3
TIPS FOR THE LEVEL 4 BEST PRACTICES AND IMPLEMENTING TIPS SESSION
Welcome to the Level 4 session. We highly
encourage you to try completing the
documents found on the PRDOH website for
Section 3 and MWBE ,download the
documents and attempt to complete them
before attending this session.
This learning module will work best when you
have attempted to complete the documents
and are finalizing them.

3. BEGIN : 1. Sign
Subrecipient Agreement
and/or Contract with
PRDOH
2. Assign Compliance Staff
to be a Point of Contact for
Compliance documents
and activities
3. Complete Trainings &
Read and Adopt PRDOH
Policies
4. Access Templates
Available on PRDOH
Website and Complete
them.
5. Submit Initial
Documents Section 3 Plan,
MWBE Plan and Customize
Self Certifications for use.
6. Complete Quarterly
Reporting until the end of
your Program / Project
7. Complete ongoing effort
activities to ensure you
Will be in Compliance.
END: 8. Maintain
organized records for
Monitoring or Audits.
Compliance Lifecycle
Section 3 & MWBE

4. 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.

5. 1. Assigning staff who will attend to the day-to-
day activities for Civil Rights compliance
2. Attending Trainings and Workshops
3. Using tools and templates provided by PRDOH
4. Executing Activities and Documentation
needed
5. Participating in PRDOH sponsored technical
assistance
6. Comply and Complete Reporting
Subrecipient & Contractor
ROLES AND RESPONSIBILITIES FOR COMPLIANCE

6. SECTION 3 & MWBE POLICY
Share the policy documents with your
teams and project management team.
• Section 3 Policy available in English
and Spanish
• PRDOH M/WBE Policy available in
English and Spanish

7. SECTION 3 FORMS TIPS
Section 3 Contractor Plan & Section 3 Subecipient Plan
Speak with your project team and discuss together what efforts make
sense to complete to be in compliance with Section 3 benchmarks.
Section 3 Worker/ Targeted Worker Self Certification Forms
Section 3 Business Self Certification Forms
Customize the forms and consider teaching your HR team how to
integrate this form in the recruiting process and how to provide a
preference in hiring.
Documentation of Efforts Form
Keep this document template in an easy to reach location so you will
remember to document your efforts as soon as they happen. Meet with
HR to find out how many new positions were available. Meet with your
project team to see what subcontracting needs exist.

8. M/WBE FORMS TIPS
M/WBE Utilization Plan
Discuss with your project team what contracting or purchasing you
will need for your project. If nothing, document that upfront as part
of your efforts. Reach out to PRDOH for a list of M/WBEs.
MWBE Waiver Form
Keep efforts on file that show you have routinely (once a year, 2x a
year) have evaluated the need for M/WBE participation.
Documentation of Efforts Form
This document template allows contractors or recipients to identify
how they are performing efforts to be in compliance with Section 3
efforts.

9. SECTION 3 BUSINESS EFFORTS TIPS
Visit the HUD website, choose
your metropolitan area and
download the Excel provided
with businesses.
 Section 3 Business Registry
Search for a Business
Direct businesses to check out if
they qualify. You can send blast
emails and document this as
efforts.
 Am I a Section 3 Business Form

10. PROGRAM DESCRIPTION
TIPS ON LOCATING CERTIFIED M/WBE’S
Visit the websites, call the local office or email requesting a listing of
businesses. This will be documentable as efforts.
Direct businesses to seek registration and how that may provide them an
advantage in competing for public projects.
• SBA 8A, WOSB, Preliminary Assessment Tool
• Puerto Rican Minority Supplier Development Council (PRMSDC)
• EPA Office of Small Business Programs (OSDBU)
• DOT Department of Transportation DBE Program
• MBDA Minority Business Development Agency PR
• WBENC Women’s Business Enterprise National Council FL- PR
• PMSDC Puerto Rican Minority Supplier Development Council PRMSDC

11. TIPS FOR LOCATING M/WBE BUSINESSES
You can contact the PR SBA office for a listing of minority
businesses.
Puerto Rico and US Virgin Islands District Office
273 Ponce de León Ave., Plaza 273, Suite 510
San Juan, PR
Phone: 787-766-5572
Fax: 787-766-5309
SBA offers a resource book with contacts and information
The Puerto Rican Minority Supplier Development Council
offers a digital catalog is available.

12. Section 3
TIPS FOR BEING PROACTIVE IN COMPLIANCE
• Save your Section 3 and M/WBE documents in
separate folder that is easy to access for you.
• Ask our team questions when you have
doubts.
• Save the presentations with the links for where
you have to submit documents .
• Use your favorites function in your browser to
save those submission links so that they are
easy to find.

13. Participate in Outreach Events
Attend the PRDOH sponsored
networking events:
• Virtual
• In person
• Set up booths at existing events
You can also create your own small
networking events such as job fairs
or Meet the Prime events.

14. Section 3
TIPS FOR BEING PROACTIVE IN COMPLIANCE
• Add the quarterly reporting dates to your calendar and
provide yourself a reminder at least a week in advance so
that you will have plenty of time to complete the report with
any updates
• Set reminders on your calendar for when you will be
completing activities so that when you document your
efforts, it will be easy to remember.
• Set up regular communication with your HR team and
Procurement team to be in the loop when new procurements
are available to be shared with Section 3 and M/WBE
businesses

15. Apr.
5
Jul.
5
Oct.
5
Jan.
5
JAN - MAR APR - JUN JUL - SEP OCT – DEC
QUARTERLY REPORTING TIPS
 Ask your support staff to set preparation meetings on your calendar each
quarter so that you won't have to rush to update your report.
 Watch the webinar on how to complete the report before completing the
report to help you remember key areas to complete.

16. PREPARING FOR THE LIVE QUESTION AND ANSWER SESSIONS
Outlook Invites
• Section3CDBG@vivienda.pr.gov
• Please be sure to accept the
outlook invite if you would like
direct assistance
• Bring your questions to our live
technical assistance sessions
• Have your documents available
to ask questions

17. CDBG-DR
NEXT STEPS

18. SUBMITTING INITIAL DOCS & QUARTERLY REPORTS
Initial Documentation
• MWBE Utilization Plan
• Section 3 Recipient Plan
https://cdbg-dr.pr.gov/iframes/section3PlanMWBEIFRM.html
Quarterly Report Submission :
January 5 , April 5, July 5 and
October 5 every year.
• Quarterly Report template
• Documentation of Efforts Template
https://cdbg-
dr.pr.gov/iframes/quarterlycomplian
cereportIFRM.html

19. 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 4 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.
You have completed the webinars. The next session will be a live Q and
A session coordinated through your program area upon your request.
THANK YOU

20. 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

21. 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