General EIC questions
Is EIC reporting mandatory for all awards?
EIC reporting is mandatory for projects awarded in 2021 or later years. Reporting is optional for awards dated 2020 or earlier.
There are tasks to complete the EIC reports in my WorkCenter, but our award was prior to 2021. Do we have to complete these tasks?
No, you do not have to complete the tasks. The tasks are automatically uploaded to all WorkCenters. If you choose not to report, let your development officer know and they will delete those tasks.
What are the EIC goals for rural and urban regions?
The aspirational goals and regions are:
- Region 1: Metro Oregon, MWESB Goal: 30%
- Regions 2 and 3: Rural Oregon, MWESB Goal: 20%
- Regions 4 and 5: Rural Oregon, MWESB Goal: 20%
Counties within each region are:
- Region 1: Clackamas, Columbia, Multnomah, Washington, and Yamhill counties.
- Regions 2 and 3: Clatsop, Tillamook, Yamhill, Polk, Marion, Lincoln, Benton, Linn, Lane, Coos, Douglas, Curry, Josephine, and Jackson counties.
- Regions 4 and 5: Wasco, Sherman, Gilliam, Jefferson, Wheeler, Crook, Deschutes, Klamath, Lake, Morrow, Umatilla, Union, Wallowa, Grant, Baker, Harney, and Malheur counties.
What happens if we do not meet the goal (20% rural, 30% urban)?
There is no penalty for not reaching your region’s aspirational goal, but you still must turn in the reports with all available information filled out. We only ask that you try your best to hire MWESB/VBE firms.
How does OHCS use the data collected from EIC reports?
We combine all information and report it to the Housing Stability Council. We also report trends in MWESB/VBE use, obstacles to using MWESB/VBE firms, and other general non-project-specific information. We do not report individual project data, but sometimes we may present information about specific projects that experience positive results with MWESB/VBE firms. We will always ask your permission and seek your input if we report project-specific information in any form.
My project is a Tribal project that is subject to Tribal Employment Rights Offices (TERO) requirements. How should we report MWESB/VBE activity?
Fill out the EIC forms with your TERO information. We can count your TERO requirements for EIC purposes. Remember that these are aspirational goals, and there is no penalty if the TERO requirements are less than the EIC goals.
Reportable costs questions
Do we report money spent on project costs that are not eligible for reimbursement with our award?
Yes, report all project costs whether they are reimbursable with your LIFT loan or Development Subsidy Grant funds.
Do I report costs for professional services, such as the appraisal, architectural, or engineering services?
Yes, include these costs in your reporting. Report costs for anyone hired who is part of the project costs.
Since SDCs and permit fees go to the city and land acquisition costs are not paid to a construction or construction-related service firm, should those be excluded from project costs?
Do not include SDCs, permits, and land acquisition costs in total project costs or as an Amount Paid line item. However, if your general contractor includes them as a line item in an invoice they send you and you pay, you may include those costs in the amount you pay the general contractor.
How do we determine the dollar amount to report for volunteer labor or donated materials?
For both volunteers and donated materials or services, estimate what the labor, materials, or services would cost if you were to pay for it at market rates. Use that amount and be sure to add it to both project costs spent during the period and on the appropriate line item in the Amount Paid column.
Reportable firms questions
We use firms who are not certified as MWESB/VBE but are either eligible for certifications or would be eligible except their revenue/assets are too high. Should we include these in the reports?
Yes, include these in your reports since we track both certified and non-certified firms. If you know why a firm is not certified, provide that information, though it is not required, and we encourage you to share the Certification Fact Sheet with these firms.
If a business is women- or minority-led, can it be counted as MWESB/VBE?
The business must have more than 50% ownership of the MWESB/VBE category to be included in the project percentages. It does not matter who leads the organization. You may include information about the business in your narrative answers, but the dollar amount paid to them cannot be included.
We use firms who are certified by agencies other than the Certification Office for Business Inclusion and Diversity (COBID). Should we include these in the reports?
Yes, include these and provide the name of the certifying agency. Non-COBID certified firms that fit into an MWESB/VBE category count toward MWESB/VBE goals.
How should we count volunteers and volunteer labor in projects? For example, if we have a 10-person corporate group that comes out, should we look at demographic info on those volunteers or should we look at demographic info of who owns the company they work for?
For volunteers and donated materials or services, look at who owns the company to determine if they can be reported as part of the percentages. You could also include them in the percentages if they have a specific purpose that includes one of the reportable categories, e.g. LatinoBuilt, or you could include a note in the narrative portion of the report if most of the volunteers fall into one or more categories.
Does any veteran-owned company count toward the EIC goal?
Yes, any veteran-owned company counts toward your goal. Previously, only firms owned by service-disabled veterans counted, but COBID changed their certification criteria.