Fair Housing Testing Requests for Proposals Approval Copyright 2014
City of Dubuque Action Items # 5.
ITEM TITLE: Fair Housing Testing Requests for Proposals
SUMMARY: City Manager recommending approval of the selection of
the Fair Housing Center of Nebraska and Iowa to provide
both the originally proposed testing as well as the testing
based on disability, and allow the City Attorney's Office to
negotiate the contact subject to City Manager approval.
SUGGESTED DISPOSITION: Suggested Disposition: Receive and File; Approve
ATTACHMENTS:
Description Type
Award of Contract for Fair Housing Testing Services- City Manager Memo
MVM Memo
Staff Memo Staff Memo
Proposal Supporting Documentation
Proposal Supporting Documentation
THE CITY OF Dubuque
DUB E i"
Masterpiece on the Mississippi 2007.2012.2013
TO: The Honorable Mayor and City Council Members
FROM: Michael C. Van Milligen, City Manager
SUBJECT: Award of Contract for Fair Housing Testing Services
DATE: September 14, 2016
Two proposals were received in response to a Request for Proposals for a vendor to
conduct fair housing testing based on protected classes in furtherance of the objectives
of the Voluntary Compliance Agreement with the U.S. Department of Housing and
Urban Development.
The Fair Housing Center of Nebraska and Iowa submitted a proposal to test local
housing providers on the basis of race, race with the applicant possessing a Housing
Choice Voucher, and rental housing where advertisements indicate "No Section 8" or
"No Housing."
As part of its proposal The Fair Housing Center of Nebraska and Iowa suggested the
addition of 15-20 telephonic matched tests on the basis of disability and the presence of
a companion/therapeutic animal to the scope of the project. "Statistics show that over
50% of the fair housing cases investigated in the United States are for people with
either a physical or mental disability or both." The cost for the additional tests on the
basis of disability and presence of a companion/therapeutic animal is $8,360. Funding
is available.
Assistant City Attorney Crenna Brumwell and the RFP review committee recommend
City Council approval of the selection of The Fair Housing Center of Nebraska and Iowa
to provide both the originally proposed testing as well as the testing based on disability,
and allow Crenna to negotiate the contact subject to City Manager approval.
I concur with the recommendation and respectfully request Mayor and City Council
approval.
Mic ael C. Van Milligen
MCVM:jh
Attachment
cc: Barry Lindahl, City Attorney
Crenna Brumwell, Assistant City Attorney
Cindy Steinhauser, Assistant City Manager
Teri Goodmann, Assistant City Manager
Kelly Larson, Human Rights Director
Alvin Nash, Housing & Community Development Department Director
2
THE CITY OF
DUB E MEMORANDUM
Masterpiece on the Mississippi
CRENNA M . BRUMWELL ,
ASSISTANT CITY ATTORNEY
To: Michael C. Van Milligen
City Manager
DATE: September 14, 2016
RE: Award of Contract for Fair Housing Testing Services
As part of the FY 2017 Budget, an improvement level package was approved by the
City Council for conducting fair housing testing based on protected classes. The
package allows the City Attorney's Office to contract with an outside vendor to conduct
fair housing testing based on protected classes in furtherance of the objectives of the
Voluntary Compliance Agreement (VCA) with the US Department of Housing and Urban
Development.
Human Rights Director Kelly Larson, Assisted Housing Specialist Erica Haugen, and I
worked together as the RFP committee because of our familiarity with the requirements
under the VCA. The RFP was approved by the City Council on July 5, 2016 and
released shortly thereafter for proposals.
Two (2) proposals were received in response to the RFP. The proposals came from:
1) Metropolitan St. Louis Equal Housing & Opportunity Council
2) The Fair Housing Center of Nebraska and Iowa.
It is our recommendation the contract be awarded to The Fair Housing Center of
Nebraska and Iowa to perform the requested fair housing testing in the amount of
$24,000 to test local housing providers on the basis of race, race with the applicant
possessing a Housing Choice Voucher, and rental housing where advertisements
indicate "No Section 8" or "No Housing."
As part of its proposal The Fair Housing Center of Nebraska and Iowa suggested the
addition of 15-20 telephonic matched tests on the basis of disability and the presence of
a companion/therapeutic animal to the scope of the project. "Statistics show that over
50% of the fair housing cases investigated in the United States are for people with
either a physical or mental disability or both." The cost for the additional tests on the
basis of disability and presence of a companion/therapeutic animal is $8,360.
A source of funding has been identified to cover the additional costs; there is $28,763 in
carryover funds in line item 10016200-62753 for Fair Housing Training. Use of $8,360
will leave a balance of$20,403 for fair housing training activities and expenditures.
It is the committee's recommendation to contract with The Fair Housing Center of
Nebraska and Iowa for both the originally proposed testing as well as the testing based
on disability and allow me to negotiate the contract subject to City Manager approval.
Testing based on disability and the presence of a companion/therapeutic animal is
responsive to our population and community needs. Both areas of testing will provide
important data in development of the City's Annual Action Plan under the VCA and 5-
year plan.
Please let me know if you need any further information. Thank you.
FAIR HOUSING CENTER
-Since 1968-
FAMILY HOUSING OF NEBRASKA & IOWA
Advisory Services, Inc. Off: (402) 934-6675 1 Fax: (402) 934-7928
MAIN OFFICE -
2401 Lake Street August 9, 2016
Omaha,Nebraska 681 1 1
402.934.7921/Fax 402.934.7928
Ms. Crenna Brumwell
SOUTH OFFICE
3605 Q Street 300 Main Street
Omaha,Nebraska 68107 Suite 330
402.546.1013/Fax 402.734.8887
Dubuque, [A 52001
COUNCIL BLUFFS OFFICE
1South 4th Street RE: Request for Proposal: Fair Housing Testing Services &Trends in
Council Bluffs,Iowa 51503 q p g g
71 2.322.4436/Fax 712.322.4443 Housing Discrimination
OMAHA 100 Dear Ms. Brumwell,
2401 Lake Street
Omaha,Nebraska 6811 1 Please accept the enclosed proposal for the above referenced project from
402.342.3773/Fax 402.342.3277
the Fair Housing Center of NE-IA (the Center), a program of Family Housing
Advisory Services Inc. (FHAS), a Nebraska not-for-profit Corporation.
METRO loo Included in the proposal you will find the workplan/approach, the firms'
to South 4th Street p p y
Council Bluffs,Iowa 51503 history and prior experience, references, the qualifications of the project
712.256.3035/Fax 7 12.322.4443
team, the ability to perform the required services and the total project
cost.
This project is for twenty matched paired race-based, site visit, rental tests
to be conducted and completed by November 15, 2016.
There will be two full-time Center staff with over 30 years combined
experience who have coordinated over 2,700 matched pair tests assigned
to this project. Our experience includes partnerships in which we have
provided testing services for three (3) Fair Housing Assistance Programs
(FHAPs) throughout the state of Iowa, including the Iowa Civil Rights
Commission (ICRC), the Sioux City Human Rights Commission (SCHRC), and
the Davenport Civil Rights Commission (DCRC).
If you have any questions regarding the proposal, please feel to contact me
at 402-934-6669 or by email ioe@fhasinc.org.
Sincerely,
Joe Garcia, Program Director
Fair Housing Center of NE-IA
Certified by the United States Department
of Housing and Urban Development
(HUD)to Provide Comprehensive
Housing Counseling Service
TTD Access via the Nebraska Relay System
Increasing Affordable Housing Opportunities for All
PFS®P®SAI® FOR TESTING
PROFILE OF THE FIRM:
Family Housing Advisory Services (FHAS), a Nebraska not-for-profit Corporation was
established in 1968. Its mission is to improve the quality of life by eliminating poverty
through housing stability and financial security. FHAS helps people prevent homelessness,
become educated homeowners, learn their foreclosure prevention options, become
financially-wise consumers, access affordable mortgage lending options, address housing
discrimination, and overcome poverty. Our core programs are Tenant Services,
Homeowner Services, Financial Education, the Earned Income Tax Credit (EITC) Coalition,
and the Fair Housing Center of Nebraska and Iowa. We improve quality of life by
stabilizing housing. We eliminate poverty through services that include budgeting, saving,
individual development accounts (IDAs), asset development, credit repair, and access to
tax credits.
While clients benefit from the holistic efforts of FHAS' comprehensive menu of services,
the program submitting this Request for Proposal is the Fair Housing Center of Nebraska
and Iowa (the Center), which provides education to eliminate discriminatory barriers to
housing choice. The Center investigates, advocates, and conducts outreach and education
to resolve issues related to housing. In addition, the Center operates the only HUD-
approved fair housing testing program in Nebraska and Iowa.
The Center assists people to overcome barriers they encounter to access housing in the
rental or purchase of a home or apartment, senior housing, public and subsidized
housing, mobile homes, dormitories, and independent or assisted living facilities. We
empower vulnerable populations by providing information needed to understand their
rights and the laws that protect them from unfair practices and ensure stability in their
housing. We protect people from housing discrimination based on Race, Color, Sex,
Religion, National Origin, Disability, and Familial Status as well as Sexual Orientation and
Gender Identity, which are also protected in Iowa.
FAIR HOUSING CENTER OF NE-IA PAGE 1 OF 9
PROPOSAL FOR TESTING
WORK PLAN/APPROACH AND PROJECT SCHEDULE(20 points),'
1. The Fair Housing Center of NE-IA will provide materials necessary for the training
of fair housing testers, and will utilize the testing methodology currently approved
by the U.S. Department of Housing and Urban Development for use by the Center
in its Private Enforcement Initiatives (PEI) grants as a Qualified Fair Housing
Organization (QFHO).
2. The Fair Housing Center of NE-IA will design and conduct a survey testing project
to include a total of twenty (20) matched pair fair housing site tests of rental
transactions within the city limits of Dubuque, Iowa. The focus of these tests will
be:
• Race
• Race with the applicant possessing a Housing Choice Voucher
• Rental housing where advertisements indicate "No Section 8" or "No
Housing."
3. The time-frame for this project is September 1, 2016 through November 15, 2016.
4. The Fair Housing Center of NE-IA will provide the City of Dubuque with an analysis
of the results of all fair housing testing conducted and any information required
for reporting or investigative purposes.
5. During the term of this agreement, the Center will provide such data and
compilations of data as needed by the City of Dubuque to report on the activities
in a format and timetable acceptable to the City of Dubuque. Products of this
contract including books and records of account shall be retained by the Fair
Housing Center of NE-IA for a period of three years, during which time they shall
be available for inspection by the City of Dubuque or its designated agent. All such
records, including records of testing and testing products, remain the property of
the Fair Housing Center of NE-IA at all times except as otherwise provided herein.
The City of Dubuque and the Fair Housing Center of NE-IA agree there shall be no
distribution of results or press releases without the consent of both of the parties.
6. The parties agree that the Center staff member coordinating the tests and the
testers will be reasonably available for interviews by the Iowa Civil Rights
Commission (ICRC) staff telephonically. In addition, should court action become
necessary in specific test cases, the FHC staff and applicable testers will be
available for depositions and testimony for the standard witness fee and travel
expenses, if any.
FAIR HOUSING CENTER OF NE-IA PAGE 2 OF 9
PROPOSAL FOR TESTING
7. The Center will evaluate conditions, both public and private affecting fair housing
choice, as well as supply conclusions and recommendations for action, including
actions to overcome identified trends, issues or instances of housing
discrimination.
8. The Center will present conclusions and recommendation of actions to the City
Council as well as in a community setting.The time-frame for the two (2)
presentations will be in December 2016 (weather permitting) but may reach into
2017.
FIRM'S HISTORY, PRIOR EXPERIENCE(15 points):
FHAS has documented discrimination through the Fair Housing Center as a significant
barrier to housing choice for 22 years. It has administered numerous projects similar in
scope and complexity to this project since its inception. The Fair Housing Center has
successfully administered 12 Fair Housing Initiatives Program (FHIP) grants from 1991 to
the present, including three three-year Performance Based Funding Component (PFBC)
Grants covering the years from 2005 to the present. Table 1 shows the HUD FHIP grants
received from FY 2005-2015.
TABLE 1: HUD FHIP GRANTS 2005 TO PRESENT
GRANT YEARS AMOUNT OF GRANT STATUS
FHIP-PEI-PBC FY2005-2008 $825,000 Closed
FHIP-PEI-PBC FY2009-2011 $825,000 Closed
FHIP-PEI-PBC FY2011-2014 $975,000 Closed
FHIP-PEI-PBC FY2014-2017 $975,000 Open
*This open grant is scheduled to be completed by November 30, 2017.
In its first year of performance-based funding, the Fair Housing Center was one of only 13
organizations nationally to be awarded such funding. The Center has significant
experience in conducting fair housing assessments of clients' housing concerns and
identifying and investigating fair housing allegations. Over the term of the current
Performance Based Funding Component (PBFC) grant, the Fair Housing Center has
completed 776 investigations of allegations of housing discrimination between 2011 and
2015.
In addition, the Center has a highly effective testing program to assess potential systemic
violations of the Fair Housing Act and to develop possible evidence to assess allegations
of fair housing violations. The Center has conducted testing throughout Nebraska and
FAIR HOUSING CENTER OF NE-IA PAGE 3 OF 9
PROPOSAL FOR TESTING
Iowa as well as communities bordering South Dakota near the Native American
reservations to identify potential systemic violations of the Fair Housing Act.
Between December 1, 2011 and November 30, 2015, the Center conducted 530 matched
pair tests in compliance with its HUD-approved methodology and strictly adhering to FHIP
regulations at 24 CFR 125.107. The testing program requires every tester to identify any
felony convictions or convictions involving fraud or perjury prior to being trained as a
tester, and criminal background checks are conducted on all testers before they are used
in any test conducted. HUD tester requirements are explained as part of the training as
well. Testers receive a standard payment per completed test part without regard to the
outcome of those tests, and the test coordinator verifies that testers selected for a given
test have no conflicts with the entities or persons being tested and are not licensed
competitors.
Of the tests conducted between 2011 and 2015, 30 were real estate sales tests, 30 were
lending tests, and 16 were design and construction tests, the remaining 454 were rental
tests. The tests were conducted in the metropolitan areas of Nebraska and western Iowa,
in smaller communities, and in the rural areas. The majority of tests focused on race,
national origin, and disability. Currently, five (5) Substantially Equivalent Agencies (FHAPs)
work directly with the Center's testing program and contract for testing services and/or
accept tests with evidence to investigate in the name of that agency. The FHAPs include
the City of Omaha's Human Rights and Relations Department, the City of Lincoln's
Commission on Human Rights, the City of Sioux City, IA Human Rights Commission, the
City of Davenport, IA Civil Rights Commission and the State of Iowa Civil Rights
Commission. All five agencies contract with the Center and will review survey tests and
consider filing them in their agency's name.
The qualifications and abilities of the Center staff to accomplish the activities of this
project are clearly demonstrated by their highly successful management of 11 FHIP grants
and the current PEI-PBFC three-year awards. The cumulative experience of FHAS staff
establishes it as a Qualified Fair Housing Organization (QFHO). The Center has met or
exceeded every measurable objective in all of its FHIP grants. The organization's
expertise has been recognized by HUD, receiving a Best Practices Award in 2000 and a
HUD Regional Award in 2008 for its "dedication and extraordinary creativity' in fighting
housing discrimination. It has also received awards from both the City of Omaha (2001,
2011) and the City of Lincoln NE (2002, 2010) for providing outstanding fair housing
services. In addition, the Center received two statewide awards (2000 and 2011) in
Nebraska for its fair housing work with underserved populations.
FAIR HOUSING CENTER OF NE-IA PAGE 4 OF 9
PROPOSAL FOR TESTING
REFERENCES(10 points):
1) Mr. Don Grove, Supervisor
Iowa Civil Rights Commission
Grimes State Office Building
400 E. 14th Street
Des Moines, IA 50319-1004
(515) 281-0338, 1-800-457-4416
2) Ms. Karen Mackey, Executive Director
Sioux City Human Rights Commission
PO Box 447
405 6th Street, Room 410
Sioux City, IA 51102
(712) 279-6985
3) Ms. Rhonda Uher, Compliance and Outreach Manager
Omaha Human Rights and Relations Department
City of Omaha
1819 Farnam Street, Suite 502
Omaha, Nebraska 68183
(402) 444-5067
4) Ms. Kimberly Taylor-Riley, Executive Director
Lincoln Commission on Human Rights
555 South 10th Street, Suite 304
Lincoln, NE 68508
(402) 441-7625
5) Ms. Keirsten Anderson, Housing Analyst
Davenport Civil Rights Commission
226 W. 4th Street
Davenport, IA 52801
(563) 326-7888
FAIR HOUSING CENTER OF NE-IA PAGE 5 OF 9
PROPOSAL FOR TESTING
QUALIFICATIONS OF THE PROJECT TEAM(10 points):
The Fair Housing Center of Nebraska-Iowa has a total of 58 years of staff experience with
a nine (9) year average for its staff members. The staff resources to successfully
implement this project include not just the staff of the Fair Housing Center, but also the
staff of its parent agency, Family Housing Advisory Services Inc. (FHAS). FHAS has five
major programs providing services to the community: homelessness prevention,
homeownership education,tax assistance, financial education and credit repair,
mortgage default counseling, as well as the full range of fair housing services of the Fair
Housing Center of Nebraska and Iowa (the Center). FHAS is a multi-disciplinary HUD-
certified housing counseling agency and the only Qualified Fair Housing Enforcement
Organization (QFHO) in Nebraska and Iowa. The Fair Housing Center was established in
1994 and for 22 years has been working to end housing discrimination though its
comprehensive testing, investigation of allegations, advocacy, education and outreach
and mediation services. It is The Center carries out these activities through seven highly-
trained and qualified staff members:
Program Director: Joe Garcia joined the Center in 2001 and holds an Associates of Arts
degree in Paralegal Studies. He has 15 years direct experience in fair housing
investigation and testing and has served as the Director of the Center for six (6) years.
Prior to becoming the Program Director Mr. Garcia served as the Fair Housing Test
Coordinator for nine (9)years and has coordinated over 2,000 matched pair tests. He has
received specialized training from HUD including National Policy Conferences, the
National Fair Housing Training Academy and National Fair Housing Alliance including
advanced training on conducting real estate testing. Mr. Garcia is bilingual in
Spanish/English and has significantly increased outreach and fair housing services to the
Spanish-speaking immigrant communities in the Center's service area.
Fair Housing Investigator/Assistant Director: Leslie Seymore has eight (8) years of
experience in the Center as a fair housing investigator and more than 26 years'
experience in law enforcement, including investigations and supervision. She investigates
all allegations of fair housing violations; ensuring complaints are jurisdictional and have
the requisite documentation. She serves as a personal representative for complainants as
needed. Ms. Seymore has specialized training from the US Department of Justice,
Duquesne University's School of Leadership and Professional Advancement, the National
Organization for Victim Assistance, HUD, the John Marshall Law School and the National
Fair Housing Alliance. She is also trained in conflict resolution and mediation.
FAIR HOUSING CENTER OF NE-IA PAGE 6 OF 9
PROPOSAL FOR TESTING
Fair Housing Test Coordinator: Carla Cox has 15 years of experience in fair housing
testing and investigation, including seven (7) years as a volunteer tester for the Center.
She coordinates the testing program, including the recruitment and training of testers
and scheduling of tests. Ms. Cox has coordinated over 700 matched pair tests (1,800 test
parts). She has received significant training from HUD, the US Department of Justice, John
Marshall Law School and the National Fair Housing Alliance, including training in real
estate sales testing. In addition, she has 4 years supervisory experience with training in
management skills and customer outreach.
Fair Housing Intake Specialist/Data Manager: Gloria Robles has 18 years of experience
providing bilingual intake services to clients and customers in both for profit and non-
profit settings, including eight (8) years of fair housing experience. She has extensive
experience and training in database entry and management, including Access. She
handles all client intakes and assesses all contacts for possible fair housing issues. Ms.
Robles has received training from the John Marshall Law School and the National Fair
Housing Alliance. Ms. Robles is bilingual/bicultural (Spanish) and uses these skills with
Spanish-speaking telephone and walk-in contacts, as well as providing education and
outreach to the Spanish-speaking communities in the project's geographical area. In
addition, Ms. Robles has been a fair housing tester for eight (8) years.
General Counsel-FHAS: Gary Fischer, JD has a strong background in civil rights litigation,
including 31 years of experience in a legal services/poverty law environment and 19 years
in fair housing law. He has significant direct experience in the mediation and litigation of
fair housing cases and provides overall legal reviews of the Fair Housing Center's
activities, ensuring complaints are jurisdictional and meritorious.
Executive Director-FHAS: Teresa Hunter has over 20 years of experience with FHAS,
including 4 years as the Director of Investigations for the Center. She has a background in
fair housing law and complaint processing. She holds a Juris Doctorate from Creighton
University and a Master's in Public Administration.
Director-Operations: Ronette Steffes oversees all human resource and accounting
functions of the agency. She maintains the agency's financial controls and all records
related to internal and external financial audits.
FAIR HOUSING CENTER OF NE-IA PAGE 7 OF 9
PROPOSAL FOR TESTING
ABILITY TO PERFORM REQUIRED SERVICES (20 Points):
The Center has two (2) qualified staff (Mr. Garcia and Ms. Cox) with over 30 years
combined experience who have coordinated over 2,700 matched pair tests. In addition,
the Center has at its disposal a total of approximately 20 trained fair housing testers, both
male and female of various ethnicities, with a combined number of 96 years' experience,
who have conducted over 1,000 tests for the Center.
TOTAL PROJECT COST(25 points):
The total cost to complete this project in full is twenty-four thousand dollars ($24,000).
This shall be the maximum monetary obligation of the City of Dubuque, IA to the Fair
Housing Center NE-IA. The expenses of the testers, including tester stipends, mileage, per
diem, including hotel, if required, all at the 2016 federal rates, will be paid by the Center.
Please consider this as the cost savings option (and the preferred option by the Center).
The second and more expensive option is $26,000. The difference between the two
options is that the $24,000 option includes the Center using two (2) of its most
experienced local Testers and one (1) Test Coordinator for this project.
The $26,000 option consists of the City of Dubuque recruiting 4 individuals to act as fair
housing testers, insure the Testers are reliable and available when the Center's Test
Coordinator is scheduled to be in-town to train these individuals as well as when the Test
Coordinator schedules the tests to be conducted. In addition, the City of Dubuque would
incur the costs associated for a 2nd Test Coordinator to be present with these
inexperienced, newly-trained Testers.
FAIR HOUSING CENTER OF NE-IA PAGE 8 OF 9
PROPOSAL FOR TESTING
RECOMMENDED SCOPE OF WORK.
As requested in the RFP, the Fair Housing Center of NE-IA would recommend to the city of
Dubuque, IA to consider contracting for testing services to conduct a series of 15-20
telephonic matched tests with the scope of the work (basis) focused on Disability-
companion/therapeutic animal.
In 2015, the Center investigated a total of 262 fair housing complaints. Of that number,
200 (76%) were based on disability. This overwhelming number is just not limited to
Nebraska and Iowa, but it is nation-wide. Statistics show that over 50% of the fair housing
cases investigated in the United States are for people with either a physical or mental
disability or both. It is our experience that no matter wherever (town or city)the Center
conducts these types of tests, housing providers continue to violate fair housing law.
The Center has conducted these tests both as site visits and by telephone. Due to the
distance between our home-based office in Omaha, NE and Dubuque, IA, and all of the
logistics and costs associated with that, the Center would recommend these tests be
done by telephone. It would be a substantial cost savings to the city of Dubuque, and still
get the same high-quality professionally conducted tests. In addition, city officials would
get a good sampling on how people with disabilities are treated by housing providers in
your city.
FAIR HOUSING CENTER OF NE-IA PAGE 9 OF 9
METROPOLITAN ST. LOUIS
EQUAL HOUSING & OPPORTUNITY COUNCIL
1027 South Vandeventer Avenue, Sixth Floor
Saint Louis, Missouri 63110
Telephone: (314)534-5800
Facsimile: (888)636-4412
Toll-Free(800)555-3951
ZACHARY M. SCHMOOK Ext. 7013 KALILA JACKSON Ext. 7007
Managing Attorney and Deputy Director Staff Attorney
zschmook@ehoc-stl.org kjackson@ehoc-stl.org
Direct Dial:(314)246-9381 Licensed in Missouri
Licensed in Missouri and Illinois
Working to ensure equal access to housing and places ofpublic accommodation for all people
August 10, 2016
Kevin Firnstahl, City Clerk
City of Dubuque
50 W. 13th Street
Dubuque, IA 52001
Re: Proposal for Fair Housing Testing Services & Trends in Housing Discrimination
Dear Mr. Firnstahl:
Please find enclosed a proposal by the Metropolitan St. Louis Equal Housing and
Opportunity Council (EHOC) in response to your request for services related to a fair housing
testing and analysis of trends in housing discrimination.
EHOC is a private nonprofit fair housing organization,with experience completing fair
housing discrimination testing projects in towns similar in size to Dubuque, IA. EHOC's key
personnel involved in this project will be our Director of Fair Housing Investigation, Katina
Combs, and our testing coordinators, Valerie Leslie and Niya Foster.
EHOC proposes to conduct a total of 20 matched pair housing discrimination tests within
City limits. This would include at least 8 matched pair racial discrimination tests (comparing
African-American housing seekers to white housing seekers) and 8 tests involving discrimination
against Section 8/Housing Choice Voucher holders (comparing housing seekers with and without
subsidized housing assistance).
Additional information is included in the enclosed proposal, but please feel free to
contact me for any additional information. Thank you for your consideration of EHOC!
S' y,
C
achary hmook
Enclosure
cc: Electronic copy to cbrumwel@cityofdubuque.org
www.ehocstl.org
I
METROPOLITAN ST. LOUIS
EQUAL HOUSING & OPPORTUNITY COUNCIL
Proposal for Provision of Services:
Fair Housing Testing Services & Trends in Housing Discrimination
PROFILE OF FIRM:
The Metropolitan St. Louis Equal Housing Opportunity Council (EHOC) is a private
nonprofit fair housing organization which was founded in 1993. EHOC has received 10
grants from the U. S. Department of Housing&Urban Development (HUD) through the
Fair Housing Initiatives Program, most recently being awarded a 3-year Performance
Based Grant. In 2008, EHOC was recognized by HUD with the Blue Ribbon Award for
being the most outstanding nonprofit fair housing program in the nation. EHOC has also
received the Governor's Human Rights Award from Lt. Gov. Pat Quinn in Illinois; a
Social Justice Award from the Midwest Sociological Society; and FOCUS St. Louis's
"What's Right with the Region Award."
EHOC follows nationally developed testing procedures approved by HUD. EHOC has
provided housing discrimination testing for HUD, the U. S. Department of Justice,
Illinois Department of Human Rights, the Missouri Commission on Human Rights, and
for private litigation. EHOC hasp rovided training in fair housing for architects, builders,
developers, university housing administrators,private landlords and management
companies, real estate agents, local governments, advertisers and for social service
agencies, first time home buyer programs and home seekers. EHOC has been licensed
through the Illinois Office of Banks and Real Estate and the Missouri Division of
Professional Registration to conduct real estate fair housing training.
QUALIFICATIONS: t
Although located in St. Louis, EHOC has experience conducting remote testing, in towns
similar in population to Dubuque, IA. In recent years, EHOC has successfully bid for and
completed housing discrimination testing contracts in Cape Girardeau (population:
38,000) and Kansas City, Missouri (250 miles away). EHOC also has experience
conducting testing for discrimination against Section 8/Housing Choice Voucher holders,
having collaborated with the City of St. Louis to pass a local ordinance prohibiting
discrimination against subsidized housing tenants, and working with the city to educate
landlords and tenants and investigate violations.
EHOC's key personnel involved in this project will be our Director of Fair Housing
Investigation, Katina Combs, and our testing coordinators, Valerie Leslie and Niya
Foster. All three employees have at least five years of experience with EHOC and have
been trained in conducting testing in accordance with HUD standards. Please find
attached resumes for each.
I
Metropolitan St.Louis Equal Housing&Opportunity Council
Proposal for Provision of Services: Fair Housing Testing Services&Trends in Housing Discrimination
SCOPE OF SERVICES AND PROPOSED PROJECT SCHEDULE:
In order assist the City in understanding and working to combat discrimination in
housing, EHOC proposes to work with the City of Dubuque to conduct housing
discrimination testing within City limits, specifically focusing on racial discrimination
and discrimination against Section 8 tenants or voucher holders.
A. Fair Housing Discrimination Testing
EHOC staff would identify the places to be tested, develop tester profiles,recruit and
assign testers, monitor and debrief testers and compare the difference in treatment. EHOC
can either identify its own testing targets by analyzing existing data, or it can respond to
requests from the City to test selected neighborhoods,properties, owners, or management
companies.
EHOC proposes to conduct a total of 20 matched pair housing discrimination tests within
City limits. This would include at least 8 matched pair racial discrimination tests
(comparing African-American housing seekers to white housing seekers) and 8 tests
involving discrimination against Section 8/Housing Choice Voucher holders (comparing
housing seekers with and without subsidized housing assistance). At least four matched-
pair tests will examine intersectional discrimination based on multiple protected classes
(i.e. comparing African-American voucher holders to whites without vouchers). The
remainder of the 20 matched paired tests will either be additional tests on these protected
classes or will test additional protected classes (e.g. familial status, disability, national
origin). EHOC will make this determination based on its analysis of the data and testing
results.
EHOC will use St. Louis-based testers for this testing project. Testers would travel to
Dubuque, complete a series of tests, and return to St. Louis. EHOC anticipates that each
visit to Dubuque would require a tester to stay overnight two nights, and EHOC
anticipates that each tester would complete five tests per visit. EHOC anticipates
completing all testing between August 20 and October 2, 2016, although EHOC may
conduct additional testing throughout October to ensure that it completes at least 20 fully
documented matched pair tests.
B. Enforcement and Reporting
Upon completion of testing,EHOC will report its conclusions and recommendations for
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action to the City Council. This will include a summary of the tests conducted and
results, an analysis of trends identified by testing, and identification of any complaints to
be filed as a result of testing. EHOC will also provide a community presentation
explaining its results and providing a general introduction to fair housing laws.
For any test where EHOC finds evidence of a discriminatory difference in treatment,
EHOC will take action by dual-filing complaints with HUD and the Iowa Civil Rights
Commission. The City may elect to be a joint complainant in any complaint brought
pursuant to this contract. EHOC will take steps to ensure that its staff and testers are
made available for testimony in any action brought pursuant to this contract. EHOC
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Metropolitan St. Louis Equal Housing&Opportunity Council
Proposal for Provision of Services: Fair Housing Testing Services&Trends in Housing Discrimination
testers will meet HUD guidelines regarding age, lack of criminal history, and other
qualifying factors. EHOC will ensure that tester notes meet all requirements of HUD and
the Iowa Civil Rights commission, and will maintain adequate chain of custody of all
tester files and evidence obtained during testing.
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REFERENCES
Dr. Alisa Warren
Executive Director
Missouri Commission on Human Rights
111 N. 7th St., Ste. 903
St. Louis, MO 63101
alisa.warren@labor.mo.gov
Marian Honel
Manager, Fair Housing Division
Illinois Department of Human Rights
100 W. Randolph St., Ste. 10-100
Chicago, IL 60601
Thomas Randolph
Civil Rights Investigator
City of Kansas City, MO
414 E. 12th St.
Kansas City, MO 64106
BUDGET BREAKDOWN
See separately sealed breakdown.
ADDITIONAL ENCLOSURES
EHOC Program Brochure
Resumes
• Katina Combs
• Niya Foster
• Valerie Leslie
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KATINA COMBS
Kcombs@ehoc-stl.org
314-535-5800 ext. 7015
Employment
Metropolitan St Louis Equal Housing Opportunity Council-St. Louis, MO
Director of Testing/Fair Lending Specialist (2002 to present)
Design and construct rental, sales, lending, insurance and accessibility test
Review and analyze mortgage loan documents for possible fair housing, loan fraud and
RESPA violations
Submit fair housing complaints to federal, state and private attorneys and for
supplementary investigation
Counsel and represent Complainants during the investigation process I
Facilitate settlement and conciliation of fair housing discrimination complaints
Conduct research
Conducted fair housing Tester trainings
Conduct fair housing workshops for community organizations
Provided Housing Counseling to Homeowners facing foreclosure
Metropolitan St Louis Equal Housing Opportunity Council-St. Louis,MO
Fair Housing Assistant (20012002)
Completed housing discrimination intakes
Facilitated mediation and alternative resolution disputes relating to various tenant/
Landlord issues
Assisted Fair Housing Specialist with fair housing investigation complaint and audits
Investigated housing discrimination complaints
Conducted fair housing Tester trainings
Designed and constructed housing discrimination test and audits
Sigma Aldrich St Louis, MO
Customer Service Representative (2001)
Answered 50-60 incoming calls per day
Resolved customer service complaints
Assisted customers with company's website
Typed correspondence
Robert Half International, Inc.-St.Louis, MO
Administrative Assistant/Sales' Support (2000-2001)
Performed various administrative tasks for The Creative Group Division
Answered incoming calls
Maintained group daily planner and budget
Scheduled staff meetings
Maintained employees' timesheets
Ordered office supplies
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Robert Half International, Inc-St Louis, MO
Receptionist (1999-2001)
Provided administrative support; performed various customer service responsibilities
Answered incoming calls; update database
Filed, faxed and copied various documents
Submitted Federal and Missouri tax information to Accountant
Education
Forest Park Community College-St Louis, MO Associated Degree in Liberal Arts— 1994
St. Louis College of Health Careers-St., Louis, MO Certified Patient Accountant— 1992
Health Careers High School-St Louis, MO Diploma— 1991
PROFESSIONAL DEVELOPMENT
• National Fair Housing Alliance-Mortgage Lending Training-May 2011
• John Marshall Law School-Investigating and Resolving Fair Housing Cases-April 2011
• National Community Reinvestment Coalition (NCRC)-Certification received 2010
• Facilitator/Presenter for National Fair Housing Alliance National Conference 2006
• Fair Housing Accessibility First- Certification received July 2005
• John Marshall Law School-Enforcing the Fair Housing Act- September 10 - 11, 2004
• National Fair Housing Alliance-Real Estate Sales - Certification received July 30, 2004
• National Fair Housing Alliance-Mortgage Lending Case Investigation and Testing-
Certification received May 7, 2004
• St. Louis Association of Realtors-Culture Diversity Awareness Training - Certification
received April 23, 2004
• John Marshall Law School-Predatory Lending Laws - September 5 - 6, 2003
• National Fair Housing Alliance-Fair Housing Basics - Certification received July 26,
2002
• John Marshall Law School-Testing and Investigation for Fair Housing Violations April
12 - 13, 2002
EHOC Accomplishments
• HUD Blue Ribbon Award for excellence as a FHIP (2008)
• Governor's Award for Human Rights
• What's Right with the Region Award from FOCUS St. Louis
• Investigated and referred Familial Status complaints against Ridge Crest
Apartments to HUD resulting in a 170,000.00 settlement for six families and
others injured by Familial Status discrimination.
• Interviews/articles related to housing discrimination on Fox 2 News, CNN, KWMU and
St. Louis Post-Dispatch, New York Times, Huffington Post
Niya Foster Phone: 314-229-1165
Saint Louis, MO Email: nfosterCcDehoc-stl.org
Professional Experience
Metropolitan St. Louis Equal Housing & Opportunity Council Saint Louis, MO
Testing Coordinator October 2014— Present
• Conduct audit and complaint bases testing throughout the St. Louis Metro area
• Recruitment and training of individuals for fair housing testing program.
• Evaluates new testers in testing program.
• Develop disability status tester pool.
• Cultivate relationships with individuals and organizations for recruitment opportunities for tester
pool.
• Analyze and Summarize results for tests.
• Debriefing of testers
• Update testing data into work and test log.
United Way of Greater St. Louis Saint Louis, MO
Campaign Representative Aug. 2015— Nov. 2015
• Engage United Way funded agencies during campaign season.
• Assist agencies in coordinating fund raising activities
• Regularly update micro-site database
• Drop off and pick up fund raising campaign materials
St. Louis Civil Rights Enforcement Agency Saint Louis, MO
Human Relations Specialist Jul. 2012—Sep. 2014
• Conducts investigations of discrimination as it relates to housing, employment, and public
accommodation.
• Mediation and Conciliation of discrimination complaints.
• Prepares reports and determinations based on findings of investigation.
• Evaluates, updates, and disseminates policies and procedures to ensure compliance with federal,
state, and local civil rights laws.
• Conducts analysis of data and presents at briefing sessions with supervisor and director.
• Performs outreach at various community events.
• Updates and maintains case files and documents in HUD's paperless tracking system
(TEAPOTS).
• Prepares and send cases to HUD for review.
USDA/NASS Olivette, MO
Telephone Interviewer Nov. 2011 — Present
• Performs telephone interviews for a wide variety surveys and censuses.
• Telephones respondents and explains the purpose of survey or census to gain cooperation.
• Obtains and records data on a survey instrument.
• Reviews information for completeness, edits and assist in the clerical processing of the collected
information.
• Trainings in complex computer terminal operation techniques.
Society of St. Vincent DePaul/Criminal Justice Ministry Saint Louis, MO
Recruitment/intake Specialist Mar. 2010 — Mar. 2011
• Recruits/interviews potential candidates for employment/re-entry program.
• Complete intake assessments on participants
• Communicates w/MO and U.S. Probation and Parole corrections leaders on participants'
progress.
• Facilitates informational sessions and group meetings.
• Works with landlords and various social service programs to establish housing for participants.
• Provide case management to participants and make referrals for other social services.
• Provide literacy tutoring to participants.
• Collect urine samples to determine positive/negative drug usage.
• Update participant information in agency databases w/case notes, employment, and probationary
status.
City of Saint Louis Parole & Probation Saint Louis, MO
Parole & Probation Officer Aug. 2007— Mar. 2010
• Serves as liaison for Municipal/State Courts, City Correctional facilities, and various community
mental health agencies.
• Maintains case notes on participant status and progress.
• Recruitment and screening of potential participants for mental health jail diversion program.
• Supervises defendants placed on probation.
• Provide recommendations to judges and prosecutors to determine entrance into specialty court
programs.
• Successful implementation of the mental health jail diversion program with 85% of participants
placed in stable housing, 42% employed, and a 97% reduction in recidivism.
Metropolitan St. Louis Equal Housing & Opportunity Council Saint Louis, MO
Fair Housing Assistant Aug. 2004 -Aug. 2007
• Intake and investigation of Fair Housing, Accessibility, & Landlord Tenant complaints.
• Update and maintain databases for subsidized & accessible housing, volunteers, and mailing list.
• Retrieval, compilation, and analysis of Census Data for Enforcement Department.
• Develops and administers rental and sales tests using various testing techniques.
• Maintains notes and status updates in case testing database.
• Analyze and summarize rental and sales tests with descriptive narratives detailing results.
• Conduct volunteer trainings and informational sessions.
• Conduct mass mailings of newsletters, brochures, and other informational literature.
• Responsible for intake and distribution of incoming mail.
InternshipNolunteer
St. Mary of Victories Church Saint Louis, MO
Volunteer Feb. 2011 - Sept. 2011
• Complete intake assessment for individuals seeking charitable assistance; visit sick and shut in.
• Contact utility companies for payment on delinquent accounts.
• Provide employment search assistance; make referrals to social service agencies.
Department of Housing and Urban Development Saint Louis, MO
Intern/Fair Housing Equal Opportunity Division May 2005 -Aug. 2005
• Collect measurements for Design and Construction compliance review
• Interview residents for housing compliance review.
• Trained as rental and accessibility tester
Education
Harris Stowe State University Saint Louis, MO
Currently Enrolled
• B.S. Biology
Harris Stowe State College Saint Louis, MO
May 2005
• B.S. Interdisciplinary Studies (Criminal Justice, Psychology, Urban Studies), Cum Laude
Trainings
National Fair Housing Training Academy Washington D.C.
• Fair Housing Law and Ethics March 2013
• Effective Fair Housing Intake
• Critical Thinking and Investigation
ProLiteracy America Volunteer Tutor Saint Louis, MO
Certificate of Completion November 2011
Regional Justice Information System (REGIS) Saint Louis, MO
• Full Law Enforcement Inquiry March 2006
National Fair Housing Alliance's Fair Housing School Coral Gables, FL
January 2005
• Fair Housing History
• The Fair Housing Act& Regulations
• Disability Components of Fair Housing Act
• Skills Training: Taking a Complaint Through the HUD Process
Valerie Miller
(3 14) 706-9610 • vIesie@ehoc-stI org
EMPLOYMENT
Saint Louis Board of Education
Parent University Facilitator 2007-2009
• Facilitated parent educational meetings
• Provided parents with information on home/community support
• Identified and assist families with resources to meet their needs
• Collaborated with community centers for resources for families
• Provided assistance to parents in understanding no child left behind-parents right to know
• Worked collaboratively with school staff and parents to implement a parent involvement plan
• Tailored a program that promotes male parental involvement
• Created and implemented incentives to support parental involvement
• Monitored daily attendance
• Collaborated with teachers to implement programs for parents
• Revised school compact/Parent Involvement Plan for parents, staff and students
Metropolitan St. Louis Equal Housing Opportunity Council 2002 - 2006
Fair Housing Assistant(2004-present)
Intake Coordinator(2002-present)
Receptionist(2002-present)
■ Conduct intakes on fair housing complaints and landlord/tenant issues
■ Counsel and educate landlords and tenants on their rights and responsibilities
■ Mediate disputes between landlords and tenants to promote reconciliation, understanding or settlement
■ Recruit housing discrimination testers
■ Maintain intake database, phone log and advertising database
■ Assist with fair housing outreach and educational activities
■ Generate correspondence to complainants,testers and community supporters
■ Home inspections of tenants with issues of landlord
■ Assist coordination of fund raising efforts for organization
■ Provide clerical support and office management
K-Mart, Inc.-St. Louis,MO 2000-2002
Department Manager
■ Supervised specific departments
■ Handled and resolved customer service issues
■ Redeveloped and organized departments
Incarnate Word Hospital—St. Louis, MO
Deaconess Health Systems—St. Louis,MO 1992-2000
Certified Nurse Assistant/Clerk Specialist
■ Provided patient healthcare
■ Assisted Registered Nurse with special projects
■ Updated patient information
■ Provided specific information to doctors regarding patient healthcare
■ Organized,faxed,filed, and copied various documents
■ Delivered medical records
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RELEVANT EDUCATION AND TRAINING
Certificate of Achievement,Fundamentals of Fair Housing Training,National Fair Housing Alliance,2005
Specialized Mediation Training,2005
Specialized Tenant/Landlord Intake and Dispute Resolution Training,Legal Service of Eastern Missouri,2005
Certificate of Completion,Tenant/Landlord Mediation Program,2005
Certificate of Completion,Word 2000-Level I(7-Hour Course),2004
Certificate of Participation,Cultural Diversity Seminar, St. Louis Association of Realtors,2004
YWCA Head Start Program, St, Louis MO, 40 Hour Certificate of Completion for Substitute Teacher,2000
St. Louis Community College at Forest Park, 1993— 1995
University of Phoenix Axia College, Business Administration 2009-2010
Certificate of Achievement,Fundamentals of Fair housing Training, Orlando California, 2011
Metropolitan St. Louis Equal Housing&Opportunity Council
Proposal for Provision of Services:Fair Housing Testing Services&Trends in Housing Discrimination
BUDGET BREAKDOWN
Name of Description of Services Amount Number Total Cost
Item per unit of units
Rental Test Tester stipends for 40 tests $150 40 tests $6,000
Stipends (20 matched pairs)
Tester Travel Mileage for 8 trips (round .54 /mi 8 trips $2,896
trip) to Dubuque; testers will * 670 mi
be expected to complete 5 =$362
rental tests per trip
Tester Hotel / Two-night hotel stay at per $325 8 trips $2,600
Per Diem diem rate of$89/night, plus 3
days per diem for meals and
incidentals at $49/day
Staff Time Time for staff to travel to area $75 450 $33,750
and research housing hours
providers; recruit and assign
testers; develop profiles;
debrief testers; and compare
treatment of testers, legal
analysis,prepare and deliver
post-test conclusions and
recommendations
Staff Hotel / Two-night hotel stay at per $325 1 trip $325
Per Diem diem rate of$89/night, plus 3
(Pre-Test days per diem for meals and
Investigation) incidentals at$49/day
Staff Hotel/ One-night hotel stay at per $187 2 trips $374
Per Diem diem rate of$89/night, plus 2
(Post-Test days per diem for meals and
Presentations) incidentals at$49/day
Staff Travel Mileage for 3 trips (round .54/mi 3 trips $1,086
trip) for pre-test orientation, * 670 mi
conclusions and = $362
recommendations to city, and
community post-test
presentation
Total Cost $47,031
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