Housing & Urban Development Grant Compliance

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Bexar County administers grants issued by the U.S. Department of Housing & Urban Development including the Community Development Block Grant (CDBG), Home Investment Partnership Program (HOME), and the Emergency Solutions Grant (ESG). 

The County's role in these projects is typically as a pass-through entity for municipalities and agencies. However, when a municipality or agency for whatever reason is unable to meet minimum procurement standards, the Bexar County Economic & Community Development Department will work in conjunction with the Bexar County Purchasing Department and the receiving municipality or agency. 

HUD Small Business Policy Statement:

“It is the policy of the Department of Housing and Urban Development to ensure nondiscrimination in federal procurement opportunities for small businesses and especially those small businesses owned by the disadvantaged (SDB), women (WOSB), service disabled veterans (SDVOSB), and those located in historically Underutilized Business Zones (HUBZone), or part of the 8(a) Business Development Program (8(a)). It is HUD policy to take affirmative steps to ensure inclusion of these businesses in HUD contracting. The Department recognizes that these businesses are of vital importance to job growth and economic strength of the country and that they have faced historic exclusion and underutilization in federal procurement. A successful and strong business community is an integral component of the Department's overall mission of job creation, community empowerment, and economic revitalization.”

§ 200.321 Contracting with small and minority businesses, women’s business enterprises, and labor surplus area firms.

a. The non-Federal entity must take all necessary affirmative steps to assure that minority businesses, women’s business enterprises, and labor surplus area firms are used when possible.

b. Affirmative steps must include:

  1. Placing qualified small and minority businesses and women’s business enterprises on solicitation lists;
  2. Assuring that small and minority businesses, and women’s business enterprises are solicited whenever they are potential sources;
  3. Dividing total requirements, when economically feasible, into smaller tasks or quantities to permit maximum participation by small and minority businesses, and women’s business enterprises;
  4. Establishing delivery schedules, where the requirement permits, which encourage participation by small and minority businesses, and women’s business enterprises;
  5. Using the services and assistance, as appropriate, of such organizations as the Small Business Administration and the Minority Business Development Agency of the Department of Commerce; and
  6. Requiring the prime contractor, if subcontracts are to be let, to take the affirmative steps listed in paragraphs (1) through (5) of this section

Contracting with Small & Minority Firms, Women's Business Enterprises, and Labor Surplus Area Firms

(See 2 CFR 200.321 Above)

Does the non-Federal entity take all necessary affirmative steps to assure that minority businesses, women’s business enterprises, and labor surplus area firms are used when possible, including::

Question: Yes No N/A
a. Placing qualified small and minority businesses and women’s business enterprises on solicitation lists? [2 CFR 200.321(a); 2 CFR 200.321(b)(1); CDBG Entitlement: 24 CFR 570.502; HOME: 24 CFR 92.505; ESG: 24 CFR 576.407(c); CoC: 24 CFR 578.99(e)] X    
b. Assuring such businesses are solicited whenever they are potential sources?
[2 CFR 200.321(a); 2 CFR 200.321(b)(2); CDBG Entitlement: 24 CFR 570.502; HOME: 24 CFR 92.505; ESG: 24 CFR 576.407(c); CoC: 24 CFR 578.99(e)]
X    
c. Dividing procurement requirements, when economically feasible, into smaller tasks or quantities to permit maximum participation by such businesses?
[2 CFR 200.321(a); 2 CFR 200.321(b)(3); CDBG Entitlement: 24 CFR 570.502; HOME: 24 CFR 92.505; ESG: 24 CFR 576.407(c); CoC: 24 CFR 578.99(e)]]
    X
d. Establishing delivery schedules, where the requirement permits, which encourage participation by small and minority businesses, and women's business enterprises?
[2 CFR 200.321(a); 2 CFR 200.321(b)(4); CDBG Entitlement: 24 CFR 570.502; HOME: 24 CFR 92.505; ESG: 24 CFR 576.407(c); CoC: 24 CFR 578.99(e)]
    X
e. Using the services and assistance, as appropriate, of such organizations as the Small Business Administration and the Minority Business Development Agency of the Department of Commerce?
[2 CFR 200.321(a); 2 CFR 200.321(b)(5); CDBG Entitlement: 24 CFR 570.502; HOME: 24 CFR 92.505; ESG: 24 CFR 576.407(c); CoC: 24 CFR
X    
f. Requiring prime contractors, when subcontracts are let, to take the affirmative steps listed in 2 CFR 200.321(b)(1) -(5) to select small, minority-owned & women-owned businesses in grant-funded contracts?
[2 CFR 200.321(a); 2 CFR 200.321(b)(6); CDBG Entitlement: 24 CFR 570.502; HOME: 24 CFR 92.505; ESG: 24 CFR 576.407(c); CoC: 24 CFR
X    

Describe Basis for Conclusion:  Review of the four procurement actions performed during this monitoring visit revealed the Grantee took all necessary affirmative steps. It is noted the Grantee has established its own Small and Minority Business and Women’s Enterprise Department which is charged with the responsibility of administrating the Small, Minority and Women Owned Business Enterprise (SMWVBE) Program, Disadvantaged Business Enterprise (DBE) Program and coordination for the grantee’s various funding sources, to include HUD. The Grantee includes contract language promoting SMWVBE participation in all procurements (see attachment A of policy). Grantee works in tandem with the SBA and MBDA offices located in San Antonio to promote the utilization of its programs through yearly procurement outreach events.