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NYCHA Now
Compliance quarterly newsletter
July 2023 

Inspiring a Compliance Culture: Read the Compliance Department’s Summer ’23 Newsletter

Michael Corwin

The Compliance Department: A Vital Part of NYCHA

Staying in Touch

The Compliance Department was created in 2019 as part of the federal Agreement between NYCHA, the U.S. Department of Housing and Urban Development (HUD), and the U.S. Attorney’s Office for the Southern District of New York. NYCHA employees have made a lot of progress helping to build a culture of compliance that will prevent the problems NYCHA faced in the past. 

Keeping an open line of communication and making sure employees have a way to report compliance issues are very important parts of maintaining that culture of compliance. Remember that there are two ways you can file a complaint with the Compliance Department, and it can be done anonymously. Both methods can be used by NYCHA and PACT residents, the general public, and NYCHA contractors alike.   

You can call the Customer Contact Center (CCC) at 718-707-7771 (selecting menu option 7) to get to the Compliance Department hotline, or you can visit NYCHA’s online Self-Service Portal: selfserve.nycha.info/nycha/app/compliance/enu?SWECmd=Start.

Examples of complaints that can be filed include maintenance issues, poor repairs, a lack of repairs, and deceptive practices.  

One Department – Seven Units

  • Compliance Integration Reporting and Evaluation (CIRE); Deputy Director Marlon Forbes. CIRE works with departments to incorporate compliance into everyday work practices through the use of data analysis, monitoring, and change management. The Unit promotes compliance through research and statutory and regulatory review and works with departments to communicate changes to regulations, laws, and procedures.
  • Compliance Inquiry Review and Assessment (CIRA); Deputy Director Sabinah Nimrod. CIRA manages the hotline and portal through which compliance complaints are reported anonymously. CIRA’s team also proactively investigates allegations of suspected noncompliance in key operational areas. CIRA evaluates existing and potential compliance issues and does assessments to determine operational and regulatory risk. 
  • Operations Monitoring (MU); Deputy Director Ka Ng. MU performs monitoring through site visits, interviews, and data analysis and develops reports to recommend improvements. MU also collaborates with departments to identify areas to evaluate for compliance and create corrective action plans. MU leads the On-Site Monitoring (OSM) program, Skilled Trades Monitoring (STM) program, and the drafting of NYCHA’s lead-based paint reporting.
  • Procedures; Deputy Director Shirley Brown. The Procedures Unit works closely with departments across NYCHA to create and write new standard procedures and manuals when the need arises and update existing procedures and manuals to take account of new rules, regulations, and legal obligations or to reflect other changes that have happened since the last review. The Procedures Unit also maintains copies of all published NYCHA standard operating procedures.
  • Records Management; Chief Records Officer Alan Wong. The Records Management Unit ensures that NYCHA remains in compliance with all statutory and regulatory requirements for recordkeeping, collaborating with NYCHA departments to develop and maintain record retention schedules, policies, and procedures. The Unit also approves and processes requests from NYCHA departments to destroy or transfer records for long-term storage and acts as custodian for all NYCHA long-term inactive records. 
  • Transactions Monitoring Unit (TMU); Deputy Director Craig Flamm. TMU plays a crucial role in identifying and addressing potential illegal or improper practices by NYCHA vendors by monitoring vendor compliance with regulations, contracts, and internal standard procedures. TMU monitors capital programs and reporting of court-ordered mold and leak repairs, Community Air Monitoring Plans for controlling dust from contaminated soils stockpiles, and Section 3 compliance.  
  • Violations; Senior Manager Mary Mohan. The Violations Unit tracks and processes violations and summonses issued to NYCHA from a variety of regulating agencies. It meets regularly with NYCHA departments and Property Management staff to discuss repairs and supporting documentation required to resolve outstanding violations. The Violations Unit also works closely with regulatory agencies to resolve violations.   

Compliance Advisory Alerts

During the past quarter, the Compliance Department posted four Advisory Alerts to bring attention to a number of important compliance issues. Please read the alerts in full; here are the key takeaways:

Use of Federal Funds to Purchase Food and Beverages for Employees

Compliance Advisory Alert #42 focused on a recent review which indicated that staff are not always compliant with the guidelines for buying food and beverages with federal funds. 

NYCHA employees are authorized to use a NYCHA Commercial Card for a limited set of business-related needs, but that does not include purchasing food or beverages unless prior authorization is given by the CEO or CFO. 

Exceptions are when NYCHA hosts a public-facing conference and providing food/beverages is necessary and reasonable for the successful performance under the federal award, or as part of necessary travel if the expenses meet certain requirements under federal regulations and NYCHA policy.

NYCHA Handheld Devices

Compliance Advisory Alert #43 addresses the inconsistent use of NYCHA handheld devices, failure to use the devices as intended, and how employees should properly care for devices in their possession.

Devices must be used for purposes that are directly related to the business of NYCHA. Applicable guidelines must always be followed, and the relevant standard procedures that set out the guidelines for their use must be reviewed.

Handheld devices are used to take photographs that automatically attach to work orders. NYCHA handhelds are also an important communication log that staff must use to record each step when performing a maintenance work order.

Adherence to Procurement Guidelines to Avoid Risk Behaviors

Compliance Advisory Alert #44 addresses contractors who may be working at risk without proper authorization through contractual agreement. Failure to follow statutory and regulatory processes for the expenditures of government funds may lead to an unprocured liability.

This may be caused by:

  • Using an expired contract or working outside the scope of a contract
  • Exceeding the contractual limits of the contracted amount
  • Absence of a contract award or purchase order

To avoid this situation, all employees must follow NYCHA’s procurement policies and regulations.  

Janitorial Conditions at Construction Sites

Compliance Advisory Alert #45 addresses how NYCHA is required to ensure development grounds maintain a neat and clean appearance, including when construction is being carried out. Over the course of a number of visits to developments where construction was taking place, it was observed that sites were not meeting the required standards.  Discussions with staff also revealed a degree of uncertainty over who was responsible for conditions around construction sites.

NYCHA Standard Procedure 040:09:2, Administration of Development Grounds, establishes that Property Management is responsible for maintaining satisfactory janitorial conditions outside the perimeter of any construction sites. 

The Capital Projects Division Procedures Manual establishes that Asset and Capital Management staff are responsible for ensuring the contractor maintains satisfactory janitorial conditions inside the construction site.

Conclusion

The Compliance Department will continue working with our colleagues to ensure that NYCHA is a safe and healthy place for residents, staff, and vendors. If you have any concerns or complaints, or are interested in working with one of our business units, you can reach out to our staff directly or you can make a confidential and anonymous report by calling the Customer Contact Center at (718) 707-7771 (select menu option 7) or by visiting the Compliance Department section of NYCHA’s website. Complaints can also be reported to any other federal, state, or local government agency. Remember, the Compliance Department is here to help.

90 Church Street, New York, NY 10007

https://on.nyc.gov/submit-concern