HomeMy WebLinkAboutAgenda - 06-06-2017 - 8-h - Adoption of Policies Related to North Carolina Housing Finance Agency (NCHFA) 2017 Urgent Repair Program (URP17) Award 1
ORANGE COUNTY
BOARD OF COMMISSIONERS
ACTION AGENDA ITEM ABSTRACT
Meeting Date: June 6, 2017
Action Agenda
Item No. 8-h
SUBJECT: Adoption of Policies Related to North Carolina Housing Finance Agency
(NCHFA) — 2017 Urgent Repair Program (URP17) Award
DEPARTMENT: Housing, Human Rights and
Community Development
ATTACHMENT(S): INFORMATION CONTACT:
1. Award Letter Annette Moore, Housing, Human Rights
2. Orange County Assistance Policy and Community Development Interim
3. Orange County Procurement and Director/Staff Attorney, (919) 245-
Disbursement Policy 2492
PURPOSE: To adopt the Assistance, Procurement and Disbursement Policies for the NCHFA
2017 Urgent Repair Program (URP17) grant.
BACKGROUND: On April 27, 2017 Orange County received a notice of award for the 2017
Urgent Repair Program (URP17). The award of $100,000 will assist sixteen (16) low-income-
owner-occupied households with urgent repairs. Orange County's grant application included a
$40,000 in local match funds to assist with the rehabilitation of the housing units. Eligible
households are those with one or more fulltime household members with special needs (e.g.,
elderly, disabled, and/or Veteran fulltime household members or a child 6 or under with an
elevated blood-lead level). Household incomes cannot exceed 50% of area median income.
Housing staff will seek potential households to assist with this funding through newspaper
advertisements, information on the County website, notices at senior centers, and other
opportunities that may be identified.
The NCHFA Grant requires that, by August 21, 2017, program participants adopt policies for
Assistance, Procurement and Disbursement for the program. These policies outline the details
of the bid solicitation and payment processes for the program. These policies are different from
the policies for County funded urgent repairs and rehabilitation.
FINANCIAL IMPACT: This $100,000 Urgent Repair (URP17) award represents additional
funding available for emergency home repairs or modifications.
SOCIAL JUSTICE IMPACT: The following Orange County Social Justice Goals are applicable
to this agenda item:
• GOAL: ENSURE ECONOMIC SELF-SUFFICIENCY
The creation and preservation of infrastructure, policies, programs and funding necessary
for residents to provide shelter, food, clothing and medical care for themselves and their
dependents.
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The creation and preservation of affordable housing options helps to meet a basic need and
advances economic self-sufficiency.
• GOAL: CREATE A SAFE COMMUNITY
The reduction of risks from vehicle/traffic accidents, childhood and senior injuries, gang
activity, substance abuse and domestic violence.
Affordable housing options allow individuals to reduce risks associated with being unhoused.
• GOAL: FOSTER A COMMUNITY CULTURE THAT REJECTS OPPRESSION AND
INEQUITY
The fair treatment and meaningful involvement of all people regardless of race or color;
religious or philosophical beliefs; sex, gender or sexual orientation; national origin or
ethnic background; age; military service; disability; and familial, residential or economic
status.
RECOMMENDATION(S): The Manager recommends that the Board adopt the Assistance
Policy, Procurement Policy and Disbursement Policy for the 2017 Urgent Repair (URP17)
Program funded by the North Carolina Housing Finance Agency, authorize the Chair to sign the
Assistance Policy and the County Manager or her authorized designee to sign any additional
documents necessary to carry out the Program.
Attachment 1 3
Nom CAROLINA
HOUSING
Orange County Department of
FINANCE;
AGENCY MAY 032017
Housing,Human Rights and
April 27, 2017 Community Development
A self-supporting Ms Bonnie Hammer sley, County Manager
public agency Orange County
300 W, Iryon Street
Hillsborough,NC 27278
Scott Fanner
F-eeutive 1)uector Dear Ms Hamrner'sley:
Again,congratulations on your 2017 Urgent Repair Program(URP17)award. This is to provide
PO Box 28066 you with information on the necessary steps to be taken so that you may begin your URP 17
Raleigh NC project in a timely manner.
27611-8006
In the envelope,you will find a"Post Approval Documentation"packet. Please read it over and
complete the sections that request specific information or require signatures for certification
Once complete, return it to the Agency along with any other requested documents such as proof
3503 Bush Sweet of honesty and fidelity bonding,and a notarized copy of the conflict of interest policy governing
Raleieth NC
the recipient entity if required
When the completed packet has been returned to the Agency(to the attention of your case
manager), along with all the requested documentation, it will be reviewed by your case manager
'" 919-877-5700 The Completed PAD with all requested documentation must be received at the Agency by
t'8 919-877-5701 August 21,2017. If not received by the deadline,your award will be canceled, Once
`"`wn`fa coin approved,the Funding Agreement will be forwarded to you.It will be the responsibility of the
Recipient's chief administrative official to sign the Funding Agreement and return an executed
electronic copy to the Agency. Once the Agency receives the properly executed Funding
Agreement,the Recipient will be forwarded the first disbursement of Program funds,via direct
deposit,equal to 50%of the project allocation.
Enclosed in your PAD is an e-payment form necessary for direct deposit and a financial contact
record Please complete them and forward them to your case manager with the rest of the PAD
Should you have any questions,please contact your case manager listed in the instructions
section of the enclosed PAD packet We look forward to working with you toward the successful
completion of your URP17 project.
Sincerely
ichael Handley
Manager of Housing Rehabilitation
Encl
cc: Audrey Spencer-Horsley,Director
Attachment 2 4
Orange County
Assistance Policy
For the 2017 Cycle of the
Urgent Repair Program
What is the Urgent Repair Program? Orange County ("the County") has been awarded
$100,000 by the North Carolina Housing Finance Agency ("NCHFA") under the 2017 cycle
of the Urgent Repair Program ("URP17"). This program provides funds to assist very-low
and low- income households with special needs in addressing housing conditions which
pose imminent threats to their life and/or safety or to provide accessibility modifications
and other repairs necessary to prevent displacement of very-low and low- income
homeowners with special needs such as frail elderly and persons with disabilities. A total
of 16 households will be assisted under URP17.
This Assistance Policy describes who is eligible to apply for assistance under URP17, how
applications for assistance will be rated and ranked, what the form of assistance is and
how the repair/modification process will be managed. The County has tried to design this
URP17 project to be fair, open, and consistent with the County's approved application for
funding and with NCHFA's URP Program Guidelines.
The funds provided by NCHFA come from the North Carolina Housing Trust Fund.
Additional funds for construction costs are provided by local organizations in the amount of
$40,000.
Eligibility To be eligible for assistance under URP17 applicants
1) must reside within Orange County and own and occupy the home in need of
repair
2) must have a household income which does not exceed 50% of the County
median income for the household size (see income limits below)
3) must have a special need (i.e. be elderly, > 62 years old, handicapped or
disabled, a single parent with a dependent living at home, a Veteran, a large
family with >5 household members or a household with a child below the age of
six with an elevated blood lead level (between 101.1g/dl and 201.1g/dl)).
4) must have urgent repair needs, which cannot be met through other state
or federally-funded housing assistance programs
URP17 Income Limits* for Orange County
Number in 30% of Median 50%of Median
Household (very-low income) (low income)
1 $14,850 $24,750
2 $17,000 $28,300
3 $19,100 $31,850
4 $21,200 $35,350
5 $22,900 $38,200
6 $24,600 $41,050
7 $26,300 $43,850
8 $28,000 $46,700
*Income limits are subject to change based on annually published HUD HOME Limits.
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Outreach Efforts of the Urgent Repair Program. Orange County will advertise or publish
an article about the Urgent Repair Program in the local newspaper serving Orange County
(The Chapel News), at senior centers throughout the County, and on the County's website.
Selection of applicants. The County has devised the following priority system to rank
eligible applicants, determine which of them will be selected for assistance and in what
order. Under this system applicants will receive points for falling into certain categories of
special need and income. The applications will be ranked according to which receive the
most points.
Priority Ranking System for Orange County URP17
Special Needs (for definitions, see below) Points
Disabled, Elderly or Veteran Head of Household (62 or older) 4
Disabled, Elderly, or Veteran Household Member (not Head of 3
Household)
Single-Parent Household (with one or more children in the home) 3
Large Family (5 or more permanent residents) 2
Emergency (may submit without regard to application deadlines) 2
Elevated Blood Lead Level Child 2
Income (See Income Table above) Points
Less than 30% of County Median Income 10
30% to 50% of County Median Income 5
Under NCHFA Program Guidelines, a minimum of 50% of households assisted must have
incomes which are less than 30% of the area median income for the household size, and
no household with an income exceeding 50% of the area median income will be eligible.
This guideline will be adhered to strictly and will be the primary factor in the selection of
those households to be assisted under URP17.
Recipients of assistance under the URP17 will be chosen by the above criteria without
regard to race, color, religion, national origin, sex, familial status and disability.
The definitions of special needs' populations under URP17 are:
• Elderly: An individual aged 62 or older.
• Emergency: A situation in which a household member has an immediate threat of being
evicted or removed from a home due to health or safety issues within a time frame that
the program can complete a repair to stop eviction or removal. These applications will
be received at any time during the funding cycle and evaluated on the ability of the
program to complete the work in a timely manner that meets the goal of assisting
homeowners to remain in their home.
• Disabled: A person who has a physical, mental or developmental disability that greatly
limits one or more major life activities, has a record of such impairment, or is regarded
as having such an impairment.
• Large Family: A large family household is composed of five or more individuals; at
least four are immediate family members.
• Head of Household: The person or persons who own(s) the house.
• Household Member. Any individual who is an occupant (defined below) of the unit to
be rehabilitated shall be considered a "household member" (the number of household
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members will be used to determine household size and all household members are
subject to income verification).
• Occupant: An occupant is defined as any immediate family member (mother, father,
spouse, son/daughter of the head of the household, regardless of the time of
occupancy); or non-immediate family member who has resided in the dwelling at least
3 months prior to the submission of the family's application.
• Single-Parent Household: A household in which one and only one adult resides with
one or more dependent children.
• Veteran: A person who served in the active military, naval, or air service, and who was
discharged or released therefrom under conditions other than dishonorable.
• Child with elevated blood lead level: a child below the age of six with an elevated blood
lead level between 10 µg/dl and 20 µg/dl.
Client Referral and Support Services Many homeowners assisted through the Urgent
Repair Program may also need other services. When the Urgent Repair Program staff
meets the homeowner during the work write-up process, they will discuss the resources
and programs available in the County and provide pamphlets and a list of the agencies
with contact information. With the homeowner's permission, a case file will be created
and a staff person will follow up with the homeowner concerning the available services in
the referral network.
What is the form of assistance under URP17? The County will provide assistance to
homeowners, whose homes are selected for repair/modification in the form of a loan.
Homeowners will receive an unsecured deferred, interest-free loan, forgiven at a rate of
$1,000 per year, until the principal balance is reduced to zero.
What is the amount of the loan? The amount of the loan will depend on the scope of
work necessary to address the identified imminent threats to life and/or safety, and that will
be determined by the county's rehabilitation specialist. There is no minimum to the
amount of the loan; however the maximum life-time limit according to the guidelines of
URP17 is $8,000.
What kinds of work will be done? Only repairs that address imminent threats to the life
and/or safety of occupants of the dwelling unit or accessibility modifications will be
performed under the county's URP. It should be noted that all deficiencies in a home may
not be rectified with the available funds.
All work that is completed under URP17 must meet or exceed NC Residential Building
Code.
Who will do the work on the homes? The County is obligated under URP17 to ensure
that quality work is done at reasonable prices and that all work is contracted through a fair,
open and competitive process. To meet those very difficult requirements, the County will
invite bids only from contractors who are part of an "approved contractors' registry".
Please request a copy of the County's Procurement and Disbursement Policy for further
information.
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(Homeowners who know of quality rehabilitation contractors that are not on the County's
Approved Contractors Registry are welcome to invite them to apply.)
A minimum of three approved contractors will be invited to bid on each job, and the lowest
responsive and responsible bidder will be selected for the contract. "Responsive and
responsible" is described in the Procurement and Disbursement Policy.
What are the steps in the process, from application to completion? Now that you
have the information about how to qualify for Orange County URP17, what work can be
done, and who will do it, let's go through all the major steps in the process:
1. Completing an Application form: Homeowners who wish to apply for assistance
must do so by November 1, 2017. Apply by contacting Renee D. Holmes, Housing
Programs Coordinator, at (919) 245-2495, David Saconn, Rehabitation Specialist, at
(919) 245-2494 or Jim Hutcherson, Rehabilitation Specialist, at (919) 245-2485. Proof
of ownership and income will be required. Those who have applied for housing
assistance from the County in the past will not automatically be reconsidered. A new
application will need to be submitted.
2. Preliminary inspection: The County's Rehabilitation Specialist will visit the homes of
potential loan recipients to determine the need and feasibility of repairs/modifications.
3. Screening of applicants: Applications will be rated and ranked by the County based
on the priority system outlined on page 2. The households to be assisted will be
selected by December 15, 2017. Household income will be verified for program
purposes only (information will be kept confidential). Ownership of property will be
verified along with other rating factors. From this review, the twelve (12) most qualified
applicants will be chosen according to the priority system described above. There will
also be a list of three (3) alternates. Applicants not receiving notification that they were
chosen by December 30, 2017 may contact Renee D. Holmes, Housing Programs
Coordinator, at (919) 245-2495 to confirm the disposition of the application.
4. Applicant interviews: Approved applicants will be provided detailed information on
assistance, program repair/modification standards and the contracting procedures
associated with their project at this informational interview.
5. Work write-up: The County's Rehabilitation Specialist will visit the home again for a
more thorough inspection. All parts of the home must be made accessible for
inspection, including the attic and crawlspace, if any. The owner should report any
known problems such as electrical short circuits, blinking lights, roof leaks and the like.
The Rehabilitation Specialist will prepare complete and detailed work specifications
(known as the "work write-up". A final cost estimate will also be prepared by the
Rehabilitation Specialist and held in confidence until bidding is completed.
6. Formal agreement: After approval of the work write-up, the homeowner will sign a
formal agreement that will explain and govern the repair/modification process, and an
explanation of the Promissory Note, which is considered a forgivable loan. This
agreement will define the roles of the parties involved throughout the process.
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7. Bidding: The work write-up and bid documents will be mailed to a minimum of three
contractors on the Approved Contractors' Registry who will be given one week in
which to inspect the property and prepare bid proposals. The names of the invited
contractors will be supplied to the homeowner. Each will need access to those areas of
the house, in which work is to be performed, in order to prepare a bid. A bid opening
will be conducted at the Housing, Human Rights and Community Development office at
a specified date and time, with all bidders and the homeowner invited to attend.
8. Contractor selection: Within 24 hours of the bid opening, after review of bid
breakdowns and timing factors, the winning bidder will be selected. All bidders and the
homeowner will be notified of (1) the selection, (2) the amount, (3) the amount of the
County's cost estimate, (4) any support or contingency costs that will be included in the
loan amount, and (5) if other than the lowest bidder is selected, the specific reasons
for the selection.
9. Execution of loan and contract: The loan will be executed as well as the
repair/modification contract prior to work beginning on the project. This contract will be
between the contractor and homeowner, with Orange County signing as an interested
third party. The cost of the actual work and project related support costs up to the
amount of$800 will be included in the loan document.
10.Pre-construction conference: A pre-construction meeting will be held at the home.
At this time, the homeowner, contractor and program representatives will be present
and discuss the details of the work to be done. Starting and ending dates will be
agreed upon, along with any special arrangements such as weekend or evening work
hours and disposition of items to be removed from the home (such as old plumbing,
etc.). If the contract has been executed, the Orange County will issue a "proceed order"
formally instructing the contractor to commence by the agreed-upon date within 24
hours of the pre-construction meeting.
11.Construction: The contractor will be responsible for obtaining any required building
permits for the project before beginning work. The permit must be posted at the house
during the entire period of construction. Program staff will closely monitor the
contractor during the construction period to make sure that the work is being done
according to the work write-up (which is made a part of the rehabilitation contract by
reference) and in a timely fashion. Code Enforcement Officers will inspect new work
for compliance with the State Building Code as required by the guidelines of URP17.
The homeowner will be responsible for working with the contractor toward protecting
personal property by clearing work areas as much as practicable.
12.Change Orders: All changes to the scope of work must be reduced to writing as a
contract amendment ("change order") and approved by all parties to the contract: the
owner, the contractor and two representatives of Orange County. If the changes require
an increase in the loan amount, a loan modification stating these changes in the
contract amount must be completed by the County, and executed by the owner. If the
changes result in a decrease in the loan amount, an estoppel informing the homeowner
of these changes in the contract amount will be completed by the County and conveyed
to the owner.
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13.Payments to contractor: The contractor will be paid following inspection of and
satisfactory completion of all items on the work write-up and change orders, if any, as
outlined in the County' s Procurement and Disbursement Policy..
14. Post-construction meeting: Following construction the contractor and the
Rehabilitation Specialist will sit down with the homeowner one last time. At this
meeting the contractor will hand over all owner's manuals and warranties on
equipment. The contractor and Rehabilitation Specialist will go over operating and
maintenance requirements for any new equipment installed and discuss general
maintenance of the home with the homeowner. The homeowner will have the
opportunity to ask any final questions about the work and the loan.
15.Closeout: Once each item outlined in section 13 has been satisfied and the
homeowner has signed a Certificate of Satisfaction, the job will be closed out (fully
completed).
What are the key dates? If, after reading this document, you feel that you qualify for this
program and wish to apply, please keep the following dates in mind:
• Applications available to the public starting September 1, 2017.
• Applications must be turned in at the Orange County Department of Housing, Human
Rights and Community Development by 5:00 PM on November 1, 2017.
• Loans made to selected households will begin January 3, 2018.
• All rehabilitation work must be under contract by October 15, 2018.
• All rehabilitation work must be completed by December 31, 2018.
How do I request an application? Just contact:
Renee D. Holmes, Housing Programs Coordinator
Orange County
300 W. Tryon Street
Hillsborough, NC 27278
(919) 245-2495
David Saconn, Rehabilitation Specialist
Orange County
300 W. Tryon Street
Hillsborough, NC 27278
(919) 245-2494
Jim Hutcherson, Rehabilitation Specialist
Orange County
Southern Human Services
2501 Homestead Road
Chapel Hill, NC 27278
(919) 245-2485
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Is there a procedure for dealing with complaints, disputes and appeals? Although
the application process and repair/modification guidelines are meant to be as fair as
possible, Orange County realizes that there is still a chance that some applicants or
participants may feel that they are not treated fairly. The following procedures are
designed to provide an avenue for resolution of complaints and appeals.
During the application process:
1. If an applicant feels that his/her application was not fairly reviewed or rated and would
like to appeal the decision made about it, he/she should contact the Housing, Human
Rights and Community Development Director within five days of the initial decision and
voice their concern. If the applicant remains dissatisfied with the decision, the detailed
complaint should be put into writing.
2. A written appeal must be made within 10 business days of the initial decision on an
application.
3. Orange County will respond in writing to any complaints or appeals within 10 business
days of receiving written comments.
During the repair/modification process:
1. If the homeowner feels that repairs or modifications are not being completed according
to the contract, he/she must inform the contractor and the Rehabilitation Specialist.
2. The Rehabilitation Specialist will inspect the work in question. If he finds that the
work is not being completed according to contract, the Rehabilitation Specialist will
review the contract with the contractor and ask the contractor to remedy the problem.
3. If problems persist, a mediation conference between the homeowner and the contractor
may be convened by the Rehabilitation Specialist and facilitated by the County's
Housing, Human Rights and Community Development Director.
4. Should the mediation conference fail to resolve the dispute, the Housing, Human
Rights and Community Development Director will render a written final decision.
5. If the Rehabilitation Specialist finds that the work is being completed according to
contract, the complaint will be noted and the Rehabilitation Specialist and the
homeowner will discuss the concern and the reason for the Rehabilitation Specialist's
decision.
Will the personal information provided remain confidential? Yes. All information in
applicant files will remain confidential. Access to the information will be provided only to
County employees who are directly involved in the program, the North Carolina Housing
Finance Agency and auditors.
What about conflicts of interest? No officer, employee or other public official of the
County, or member of the Board of County Commissioners, or entity contracting with the
county, who exercises any functions or responsibilities with respect to URP17 shall have
any interest, direct or indirect, in any contract or subcontract for work to be performed with
program funding, either for themselves or those with whom they have family or business
ties, during their tenure or for one year thereafter. Relatives of County employees, Board
of County Commissioners Members and others closely identified with the County may be
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approved for rehabilitation assistance only upon public disclosure before the Board of
Commissioners and written permission from NCHFA.
What about favoritism? All activities under URP17, including rating and ranking
applications, inviting bids, selecting contractors and resolving complaints, will be
conducted in a fair, open and non-discriminatory manner, entirely without regard to race,
color, religion, national origin, sex, familial status and disability
Who can I contact about URP17? Any questions regarding any part of this application or
program should be addressed to:
Renee D. Holmes, Housing Programs Coordinator
Orange County
300 W. Tryon Street
Hillsborough, NC 27278
(919) 245-2495
David Saconn, Rehabilitation Specialist
Orange County
300 W. Tryon Street
Hillsborough, NC 27278
(919) 245-2494
Jim Hutcherson, Rehabilitation Specialist
Orange County
Southern Human Services
2501 Homestead Road
Chapel Hill, NC 27278
(919) 245-2485
These contacts will do their utmost to answer questions and inquiries in the most efficient
and correct manner possible.
This Assistance Policy is adopted this day of 20_
Board Chair
Notary Public
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Attachment 3 1 2
Orange County
Procurement and Disbursement Policy
URGENT REPAIR PROGRAM
PROCUREMENT POLICY
1. To the maximum extent practical, Orange County ("the County") promotes a fair, open
and competitive procurement process as required under the North Carolina Housing
Finance Agency's Urgent Repair Program (URP). Bids are invited from Contractors who
are part of the County's approved contractor registry. (To be on the registry, a contractor
must complete an application, have their recent work inspected, reviewed and approved
by the Rehabilitation Specialist and submit proof of insurance.) Any contractor listed with
and approved by the County and in good standing will receive automatic approval status
on the contractor registry.
2. At least three eligible contractors on the County's approved contractor registry shall be
invited to bid on each job and the lowest responsive and responsible bidder shall be
selected for the contract. "Responsive and responsible" means (a) the contractor is
deemed able to complete the work in a timely fashion, (b) the bid is within 15%, in either
direction, of the County's cost estimate, and (c) there is no conflict of interest (real or
apparent).
3. Although bid packages may be bundled for multiple job sites, the bids for multiple job
sites shall be considered separate and apart when awarded and shall be awarded to the
lowest responsive and responsible bidder(s) for each job site.
4. Bid packages shall consist of an invitation to bid, work write up(s) and bid sheet(s) for
each job.
5. Bids must include a cost-per-item breakdown with line item totals equaling the submitted
bid price. Discrepancies must be reconciled prior to a contract being awarded.
6. Any change to the original scope of work must be reduced to writing in the form of a
change order to be agreed upon and signed by all parties to the original contract and two
representatives of the County. The change order must also detail any changes to the
original contract price.
7. No work may begin prior to a contract being awarded and a written order to proceed
provided to the contractor. In addition, a pre-construction conference and "walk thru"
shall be held at the work site prior to commencement of repair work.
8. The County reserves the right to reject any or all bids at any time during the procurement
process.
9. In the event of a true emergency situation, the County reserves the right to waive normal
procurement procedures in favor of more expedient methods, which may include seeking
telephone quotes, faxed bids and the like. Should such methods ever become necessary
the transaction will be fully documented.
10. All sealed bids will be opened publicly at a time and place to be announced in the bid
invitation. All bidders are welcome to attend.
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DISBURSEMENT POLICY
1. All repair work must be inspected by (a) an Orange County Rehabilitation Specialist, and
(b) the homeowner prior to any payments to contractors. If all work is deemed
satisfactory and all other factors and written agreements are in order, payment shall be
issued upon presentation of an original invoice from the contractor. Contractor should
allow 21 business days for processing of the invoice for payment.
2. If any of the work is deemed unsatisfactory, it must be corrected prior to authorization of
payment. If the contractor fails to correct the work to the satisfaction of the County's
Rehabilitation Specialist, payment may be withheld until such time the work is
satisfactory. (Contractors may follow Orange County Urgent Repair Program Assistance
Policy if a dispute occurs; however, contractors shall abide by the final decision as stated
in the policy).
3. The County assures, through this policy, that adequate funds shall be available to pay the
contractor for satisfactory work.
4. All contractors, sub-contractors and suppliers must sign a lien waiver prior to
disbursement of funds.
The Procurement and Disbursement Policies are adopted this the day of
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Orange County
BY:
ATTEST:
CONTRACTORS STATEMENT:
I have read and understand the attached Procurement and Disbursement Policy.
BY:
COMPANY NAME:
WITNESS: