FY 2022 Fair Housing Initiative Program - Fair Housing Organization Initiative
The Fair Housing Initiatives Program (FHIP) provides funding to fair housing organizations and other non-profits that assist individuals who believe that they have been victims of housing discrimination. Currently FHIP provides funds to eligible organizations through competitive grants under several initiatives to carry out enforcement activities to prevent or eliminate discriminatory housing practices and inform individuals of their rights and responsibilities under the Fair Housing Act. The Initiatives are: the Fair Housing Organizations Initiative (FHOI), Private Enforcement Initiative (PEI) and the Education and Outreach Initiative (EOI). In addition, consistent with FY 2022 HUD appropriations directives, FHEO is publishing a separate NOFO for EOI-Tester Coordinator Training. This FHOI NOFO makes available $1.825 million under the Continued Development Component (CDC) and $1.875 million under the Establishing New Organizations Component (ENOC). The CDC component provides funds to non-profit fair housing organizations to build their capacity and effectiveness to conduct enforcement related activities eligible for funding such as: investigating discrimination allegations based on sexual orientation and gender identity or expanding testing expertise and experience in mortgage lending discrimination or appraisal bias. The ENOC provides funds to Qualified Fair Housing Enforcement Organizations (QFHOs) (“sponsoring organizations”) to establish new, separate organizations (“sponsored organizations”) to engage in fair housing work, particularly in areas of the country which are currently unserved or underserved by fair housing enforcement organizations. Eligible activities under the ENOC are those that establish a single organization to become a viable regional/local fair housing enforcement organization that will conduct testing and other fair housing enforcement-related activities. This NOFO will receive applications for the FHOI NOFO only. Please see the specific PEI and EOI NOFOs for the additional FHIP funding opportunities. · Changes from Previous NOFO. Page 5 of 61 a. This NOFO add a new component, Establishing New Organizations Component with $1.875 million in available funding. B. Departmental Template Change (NOFO Summary). The FY2022 NOFO template adds a summary of HUD’s five core goals under the Strategic Plan for FY2022-2026. C. Section I.A. Program Definitions. This NOFO adds program definitions for the following: 1.) Appraisal - in accordance with Interagency Task Force on Property Appraisal and Valuation Equity (PAVE) initiative; 2.) Government Technical Representative; and 3.) Government Technical Monitor. D. Section III.A. Eligible Applicants. This NOFO adds additional eligible activities that will further enhance the ability of eligible organizations to investigate sexual orientation and gender identity and appraisal claims, especially through the use of testing that can be used as evidence of housing discrimination. Other eligible activities include investigation of source of income discrimination, algorithmic bias, and criminal record policies when such discrimination may violate the Fair Housing Act and/or substantially equivalent state or local fair housing laws. Funding these additional activities will also ensure a high standard of relief to victims of discrimination and communities that are harmed by discrimination. This NOFO additionally includes as an eligible activity under the Continued Development Component (CDC) the expansion of fair housing enforcement services in areas not currently served by an enforcement organization or agency. This NOFO also includes as an eligible activity by a FHIP and FHAP agency. E. Section III.F. Program-Specific Requirements #3. This NOFO adda discrimination on the basis of sexual orientation and gender idenity. This NOFO complies with Executive Order 13988 on Preventing and Combating Discrimination on the Basis of Gender Identity or Sexual Orientation, directing every federal agency to assess all agency actions taken under federal statutes that prohibit sex discrimination and to fully enforce those statutes to combat discrimination based on sexual orientation and gender identity. HUD’s Office of General Counsel has concluded that the Fair Housing Act’s sex discrimination provisions are comparable to those of Title VII and that they likewise prohibit discrimination because of sexual orientation and gender identity. F. Section III.F. Program-Specific requirements #10. HUD reduced the time period that an applicant is ineligible for funding if the applicant received a “poor” on its most recent performance assessment on a prior FHIP grant year. HUD reduced the eligibility period from 2 years to 1 year to benefit grantees who quickly resolve a “poor” performance assessment. G. Section III.F. Certification of Consistency with the Consolidated Plan/Participative Planning and Implementation. This former section which was included in the FY2021 NOFO is removed. a. Section III.G. Criteria for Beneficiaries. This section is revised to remove the criteria, Dun and Bradstreet Numbering System (DUNS), as the Department addresses the New Government Issued Unique Entity Identifier (UEI) created in SAM.gov under Section Page 6 of 61 IV.C.2. The change provides notification to applicants of the new means of entity identification which will become effective April 2022 and is consistent with U.S. General Services Administration guidance at www.gsa.gov/entityid. J. Section III.G. Criteria for Beneficiaries #6. In addition to HUD sponsored or approved training, this section adds training related to lending, appraisal and/or algorithmic bias, sexual orientation and gender identity discrimination, and discrimination resulting from criminal records policies as approved uses of training funds. K. Section IV.B. This new requirement result from the Office of Management and Budget (OMB) requirement to improve the quality of award descriptions and standardize the data collection. L. Section IV.F. Funding Restrictions. Removes former Compensation restriction pursuant to OMB guidance from FY2021 NOFO. M. Section V. Rating Factor Chart. This chart is revised for consistency with the Department’s template updates which include the removal of Opportunity Zones as an available preference and the addition of preference points for Environmental Justice. The current preference points include Promise Zones, Historically Black Colleges and Universities (HBCU), and/or Environmental Justice. The maximum points available under this section has increased from two to four preference points. HUD may award no more than four total points for these preferences. These additions increase the total available NOFO score from 102 to 104. N. Section V. Rating Factor 1, Capacity of Applicant and Relevant Organizational Experience (1)(d). Under the section regarding applicant proposal of complex testing, this section adds testing to uncover possible discrimination in lending, appraisals, source of income, if there is a possible Fair Housing violation and when based on sexual orientation and gender identity. The changes comply with Executive Order 13988 and PAVE. O. Section V. Rating Factor 2(2), Highly Segregated, Rural or Underserved Area Focus. The section “need” is revised as it relates to the expansion of fair housing enforcement services in areas not currently served by an enforcement organization or agency. P. Rating Factor 2(3)(a), Proposed Solution. This NOFO includes a requirement for a plan to address discrimination, sexual orientation and gender identity. This NOFO also includes under the Continued Development Component (CDC) the expansion of fair housing enforcement services in areas not currently served by a FHIP organization. Q. Section V. Rating Factor 3, Soundness of Approach. Removes references to Statement of Work (SOW) COVID-19 limitations since updated COVID guidance is consistent with “in-person” testing and other enforcement related activities. R. Section V. Rating Factor 3, Proposed SOW& Budget. Both sections adjust the number of points that may be reduced if an applicant fails to comply with NOFO criteria for the submission budgets. S. Preference Points. The Department, in accordance with Executive Order 12898, Federal Actions to Address Environmental Justice in Minority Populations and Low-Income Populations, and EO 14008, will award up to two (2) points for applications proposing projects that advance environmental justice in communities that have been historically marginalized and overburdened by pollution and underinvestment in housing, transportation, water and wastewater infrastructure, and health care. In addition, the Department has removed Opportunity Zones as an available preference. The current Page 7 of 61 preference points include Promise Zones, Historically Black Colleges and Universities (HBCU), and Environmental Justice. The maximum points available under this section has changed from a maximum two points to four points. T. Section VI. Program-Specific Reporting Requirements. In compliance with Executive Order 13988 on Preventing and Combating Discrimination on the Basis of Gender Identity or Sexual Orientation, this NOFO confirms that all FHIP-funded projects must address housing discrimination based on sexual orientation and gender identity. All grant recipients under this NOFO will be required to review all records of allegations of discrimination (inquiries, complaints, phone logs, etc.) received since January 20, 2020 to determine any claims of discrimination based on gender identity or sexual orientation may still be timely and jurisdictional. All grant recipients must confirm this review was undertaken and report on findings in the first quarterly report.
Program Office: Fair Housing and Equal Opportunity
Funding Opportunity Title: Fair Housing Initiative Program - Fair Housing Organization Initiative
Funding Opportunity Number: FR-6600-N-21B
Estimated opening date: September 15th, 2022
Estimated closing date: December 6th, 2022
Stephanie W. Thomas Phone: 202-402-6938
Persons with hearing or speech impairments may access this number via TTY by calling the tollfree Federal Relay Service at 800-877-8339. Please note that HUD staff cannot assist applicants in preparing their applications.