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U. S. Department of
Housing and Urban Development |
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SEP 2 4 2002 |
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OFFICE OF THE ASSISTANT SECRETARY FOR ADMINISTRATION |
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MEMORANDUM FOR: Carolyn Federoff, President, AFGE National Council |
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Of HUD Locals 222 |
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FRO |
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an Mesewicz, Deputy Director, Labor and Employee |
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Relations Division, ARHRL |
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SUBJECT: Operational Protocols |
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In accordance with Article 5, Section 5.02 of the HUD/AFGE Agreement, attached are the Department's Operational Protocols which are designed to guide implementation of the Delegations of Authority to Regional Directors. To facilitate your review of the Protocols, I direct your attention to page 15 which addresses outstationed personnel. |
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Please submit any proposals the Council may have to the Headquarters Labor and Employee Relations Division within ten (10) calendar days of your receipt of this memorandum. |
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If you have any questions concerning this matter, I can be reached at 202-708 |
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Attachment |
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CC: |
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Eddie Eitches, Headquarters Lisa Lowery, Knoxville Perry Casper, Portland Ann Taylor, Richmond John Noyes, Minneapolis Diana Lewis, Houston |
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OPERATING PROTOCOLS To Guide Implementation of Delegations of Authority to Regional Directors |
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Introduction |
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In an effort to more clearly define lines of authority and to enhance the field's ability to accomplish the Department's management plan goals, the Secretary and Deputy Secretary, through the Assistant Deputy Secretary for Field Policy and Management, have delegated substantial field office management and operational authority to Regional Directors, who in turn may redelegate this authority to the Field Office Directors. This includes the authority to manage the work environment and key operational and administrative functions in field offices; the authority necessary to coordinate program activities and take a leadership role in the establishment of overall field office initiatives and priorities; and the limited reallocation of resources needed to meet Management Plan goals and Secretarial Initiatives, or respond to urgent operational needs or opportunities. |
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The formal Delegation of Authority to Regional Directors, as issued by the Deputy Secretary, is outlined in the Federal Register of March 26, 2002. These duties and responsibilities are further amplified in this document. These protocols, consistent with Departmental policy, spell out how the Regional Directors (RD), Field Office Directors (FOD), and Program Directors (PD), and their staff work together to achieve HUD's mission. |
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All redelegations will be concurred on by the appropriate Regional Counsel and the Assistant Deputy Secretary for Field Policy and Management. All redelegations are effective on date of signature and will be published in the Federal Register. |
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There are some protocols where the role of the Regional
Director and the Field Office Director differ. Where these differences exist,
the specific authority delegated from the Regional Director to the Field
Office Director is outlined. |
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These protocols will be reviewed and updated periodically as necessary. |
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Definitions |
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Several generic terms are used in this document for purposes of brevity and clarity. These terms, explained below, are not intended to enhance or diminish the title or authority of any position, but rather to make the document more readable. |
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Regional Director (RD): The Regional Director is appointed by the Secretary, and leads the HUD team in each multistate jurisdiction. Regional Directors report to the Assistant Deputy Secretary for Field Policy and Management. |
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Field Office Director (FOD): The Field Office Director is the senior management official located in each field office. The Field Office Director reports to the Regional Director. |
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Regional Directors and Field Office Directors, acting as the senior management officials in their respective offices, ensure that limited staff and other resources are used to maximum effect to accomplish Departmental priorities (Management Plan goals and Secretarial Initiatives) and that the component parts of each field office. (including program managers, ONAP Administrators, and outstationed staff) effectively function as a common enterprise to serve HUD's customers well and use resources efficiently. |
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Program Director (PD): For purposes of this document, a Program Director is the ranking program person onsite in a regional or field office. Unless otherwise specified, subordinate onsite supervisors are not covered under Program Director. These protocols do not change existing program delegations. |
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In this document, Program Director includes but is not limited to: CPD Program Directors, Fair Housing and Equal Opportunity Hub and Center Directors and Lead Equal Opportunity Specialists, Multifamily Hub and Program Center Directors, and PIH Hub Directors and Program Center Coordinators. Program Director also includes the senior supervisor onsite in the Offices of General Counsel, and Administration; Homeownership Center Directors and outstationed Single Family supervisors; and all other ranking program officials onsite. |
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Remote Program Delivery: Remote program delivery occurs in field office jurisdictions where there are no onsite program staff to provide direct program delivery. This will occur in any field office jurisdiction where program services are provided from another field office. |
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Remote Program Supervisor: A remote program supervisor is the program supervisor directly responsible for supervising employees located in another office. For example, a remote program supervisor for an outstationed Single Family employee may be located in the Homeownership Center; a remote program supervisor for a Multifamily Hub Director is located in Headquarters (HQ). |
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DELEGATIONS |
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AUTHORITY DELEGATED |
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I. Cross-Program Coordination |
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• Developing and implementing Management Plans |
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• Coordinating cross-program projects and Field Office Quality Management Reviews |
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• Preparing briefing papers and Priority Issues documents |
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• Leading disaster relief efforts |
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• Consulting with program directors on major program decisions |
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II. Personnel
Management
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• Providing input on the performance ratings of managers and supervisors within the region |
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• Approving short-term details across program lines |
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• Approving leave requests for managers and supervisors |
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• Serving as part of the selection process for field program managers and supervisors |
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• Acting as supervisor, or when necessary assigning a supervisor, for outstationed program staff |
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• Managing and conducting labor/management relations |
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III. Administrative
Management
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• Determining official office hours, opening, closing, and emergency procedures |
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IV. Resource
Management
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• Managing the local, non-programmatic administrative budget, e.g., training, equipment, etc. |
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• Approving program travel requests |
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• Redistributing up to 20% of travel funds among program areas |
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V. Representation
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• Serving as the lead point of contact with local officials |
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• Serving as principal point of contact with industry groups |
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• Managing all inquiries and correspondence, including Freedom of Information Act requests, congressional and intergovernmental communications |
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• Responding to all media inquiries in conjunction with Headquarters and the Office of Public Affairs |
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• Coordinating onsite efforts for the local office's Web page |
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• Monitoring and evaluating customer service |
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• Entering into cosponsorship agreements, with the concurrence of the General Counsel and the relevant program Assistant Secretary or equivalent |
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I. Cross-Program Coordination
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FIELD OFFICE MANAGEMENT PLAN |
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Authority: The Regional Director is responsible for developing and implementing the Regional Management Plan. |
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Each field office's Annual Management Plan articulates the strategies, goals, and milestones that the office and its remote program partners will pursue for the year in order to deliver HUD programs in ways that connect the Department's Annual Performance Plan with local community needs and opportunities. The Regional Director approves all Management Plans to ensure they adequately address national program goals and reflect effective strategies to meet local and regional needs. |
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To a significant degree the plan forms a framework within which to exercise operational authorities delegated by the Secretary and Deputy Secretary. |
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Regional Director or Field Office Director: The RD or FOD is responsible for providing leadership in the development and implementation of the Management Plan. This includes the assessment of local needs and issues through updated community profiles, development of the local plan, establishment of appropriate cross-program work planning and development activities, and management of administrative resources inorder to ensure that the plan is carried out in an orderly and comprehensive way. Coordination and administrative oversight of all Management Plan activities, including planning, monitoring, and reporting, remains with the RD or FOD. |
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The RD and FOD will be jointly accountable with individual Program Directors for accomplishment of their national program goals of the Management Plan, as determined by the Assistant Deputy Secretary for Field Policy and Management. |
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The RD or FOD has the authority to set resource priorities to ensure the accomplishment of all Management Plan goals, Secretarial priorities and other initiatives. He/she will take appropriate action to resolve problems and remove barriers to goal accomplishment. |
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Program Directors: Program Directors are responsible for implementing the Management Plan program goals and guidance from Assistant Secretaries or equivalents, and working with the RD or FOD to plan, coordinate, and implement the office-wide Management Plan. It is important that all program areas and support areas be part of the planning and implementation of the Management Plan in each office jurisdiction. |
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Remote Program Delivery: PDs will work with the RD/FOD to identify programs and services relevant to their jurisdiction and coordinate activities which ensure effective program delivery. |
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I. Cross-Program Coordination
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COORDINATING CROSSCUTTING PROJECTS, SECRETARIAL
PRIORITIES, AND LOCAL AND INTERAGENCY INITIATIVES |
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Authority: The Regional Director has responsibility for coordinating cross program projects and Field Office Quality Management Reviews. |
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Regional Director
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1. Quality Management Reviews (QMR). The RD or FOD is the principal point of contact to coordinate field office participation in the Quality Management Review. He/she will communicate and coordinate QMR reviews and visits with Program Directors, in conjunction with Headquarters mandates and requirements. He/she will serve as a coordinating point during the review, participate in the closeout conference, and oversee field office follow-up and reporting after the review. The RD or FOD will review the draft report prior to finalizing by Headquarters. |
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2. a. Crosscutting issues and Secretarial Initiatives. The RD or FOD is responsible for managing a variety of projects and initiatives that cross programmatic lines or affect the entire Department. These issues may include Presidential priorities and Secretarial Initiatives, e.g., the faith-based initiative, or involve periodic local or interagency strategies/plans/actions, such as participation in disaster recovery efforts. |
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2. b. The FODs will keep RDs and PDs informed about crosscutting projects, local work on Secretarial Initiatives, and other priorities. Where nonroutine or extraordinary issues arise, the FOD will ensure the RD is aware of the local issues. Should the RD or FOD and PD agree that additional resources are needed to help resolve a problem, the RD or FOD will coordinate the support of the appropriate staff, taking into consideration ongoing Management Plan goals and other major workload requirements. |
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3. Maintaining relationships. The RD or FOD will take the lead in establishing and maintaining relationships with local representatives of other Federal agencies and local organizations that serve the area to enable coordination of programs and projects as needed. |
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Program Directors: |
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1. Quality Management Reviews. PDs will work with the RD or FOD to coordinate program responses and participation during the QMR. PDs will provide significant input into the response to the QMR report and initiate appropriate corrective action for their program areas. |
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2. Crosscutting issues and Secretarial Initiatives. It is the responsibility of PDs to bring potential and immediate crosscutting local issues to the attention of the FOD in the jurisdiction where the issue is located. Initially, these discussions may be for |
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informational purposes only. If action is needed, the PD will work with the RD or FOD to respond appropriately. |
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3. Maintaining relationships. The RD or FOD will take the lead in establishing and maintaining relationships with local representatives of other Federal agencies, e.g., Federal Executive Agencies (FEA) initiative, and local organizations that serve the area to enable coordination of programs and projects as needed. The PD will assist the RD or FOD, as needed, in working with local organizations on crosscutting programs and projects such as multiagency task forces addressing faith-based initiatives or other initiatives for a locality, state, or region. |
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Remote Program Delivery: Program staff without onsite supervision will be managed by the RD or FOD based on an established performance/work plan developed and approved by the remote program supervisor. In instances where a work plan is not established, the RD or FOD will develop a work plan which will be communicated to the affected employee and the remote supervisor. |
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7 |
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I. Cross-Program Coordination |
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REPORT PREPARATIONS: WEEKLY REPORTS, PRIORITY ISSUES
DOCUMENTS, AND SUMMARIES OF SECRETARIAL ISSUES |
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Authority: The Regional Director is responsible for preparing briefing papers and priority issues documents. |
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Regional Director or Field Office Director : The RD or FOD is responsible for the preparation of office-wide reports and briefing papers on behalf of the regional/field office. He/she will request input from appropriate program staff to complete the reports. RDs or FODs will share copies of these reports with Program Directors. |
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Program Directors : PDs will provide timely input to office reports, priority issues documents, and issues summaries as requested, excluding the provision of confidential information. PDs will share copies of weekly reports on their activities with the RD or FOD as appropriate. PD input will include information on major program issues and actions, funding decisions, and information on potential adverse impacts. |
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Remote Program Delivery: PDs should be sure that the local FODs in all the jurisdictions they serve are aware of issues in the local jurisdiction. |
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I. Cross-Program Coordination |
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DISASTER RELIEF EFFORTS |
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Authority: The Regional Director has the lead in disaster relief efforts. |
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Regional Director or Field Office Director (RD or FOD): The RD or FOD serves as the principal point of contact, and will manage and coordinate HUD's field office response to disaster relief efforts, including staff assignments. He/she will manage office disaster relief efforts, including the Continuation of Operations Plan (COOP). This will include soliciting and receiving significant input and participation from Program Directors in the planning and development of a comprehensive field office disaster relief plan, and in the plan implementation and reporting. |
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The RD or FOD will be responsible for assuring HUD's resources are made available to the declared disaster areas, as well as coordinate with other Federal, state, and local agencies in providing disaster assistance. The RD or FOD will prepare reports on local situations and field office response efforts. |
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Program Directors (PD): PDs will carry out disaster relief efforts and provide RD or FOD support in the planning and implementation of disaster relief efforts. PDs shall be responsible for providing timely information, reports, and resources to ensure an effective overall office response. |
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Remote Program Delivery: The FOD will involve all appropriate management team members in disaster relief efforts. Offsite PDs will work with the affected FOD to ensure a coordinated HUD response to a local disaster. |
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Headquarters: Headquarters personnel, e.g., the Special Actions Office, will communicate national policy and HUD procedures for field disaster efforts and COOP activities to the Regional Director. |
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I. Cross-Program Coordination |
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RESOLUTION OF PROGRAMMATIC QUESTIONS |
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Authority: Regional Directors can trigger Headquarters. review of significant field program decisions. |
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Regional Director or Field Office Director: Even though program decisions remain the responsibility of Program Directors, RDs or FODs have the authority to request a review of significant field program decisions. When the RD or FOD has a question or concern about a program decision, the RD or FOD and the Program Director should make an effort to resolve the issue locally. |
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If a FOD and PD cannot reach a reasonable resolution to questions about a program decision, the FOD may raise concerns in a timely way to the Regional Director. |
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If the RD and the relevant PD disagree regarding a major program decision, the Assistant Deputy Secretary for Field Policy and Management may raise the matter with the relevant Assistant Secretary or equivalent. The relevant Assistant Secretary or equivalent will make the final determination, subject to review by the Deputy Secretary, if necessary. |
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Program Directors: PDs are responsible for sharing information about upcoming or pending local or regional decisions in a timely way with the RD or FOD, to the extent that confidential information is not improperly disclosed. PDs will work with the RD or FOD to resolve issues at the field level. |
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Remote Program Delivery: Same as above. PDs must ensure the local FOD is aware of upcoming or pending decisions in his/her office jurisdiction in a timely manner. |
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II. Personnel Management |
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PERFORMANCE RATINGS OF PROGRAM DIRECTORS LOCATED IN
REGIONAL AND FIELD OFFICES |
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Authority: The Regional Director will provide input on the performance ratings of managers and supervisors within the region. To the extent practicable, 40% weight will be given to the assessment provided by the Regional Director. The performance for the Directors of the Homeownership Centers, Troubled Agency Recovery Centers, Administrative Service Centers, and the Regional Counsels will be evaluated within their respective organizations, with consultation provided by the Assistant Deputy Secretary for Field Policy and Management. |
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A Departmental Working Group will develop
recommendations for a new performance based rating system for managers and
supervisors, to be implemented in FY 2003. |
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The Offices of Field Policy and Management,
Administration, and General Counsel will work with program offices to resolve
technical issues related to implementation of this authority. It is essential
that all HUD management officials recognize the importance of program offices
and the RDIFOD working together to ensure seamless delivery of HUD programs
and services to our customers. Effective program delivery and the success of
each Regional management plan and goal accomplishment is contingent upon
strong cooperation among program offices and the Regional and Field Office
Directors. The performance elements for managers and supervisors will be
standardized in FY 2003 and will include: communications; customer service;
representation; EEO, a subject matter specific element; and a critical
element regarding overall management and supervision. |
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Additional Exceptions: In addition to the organizational exceptions in the Delegation of Authority (as shown above), the following organizational units will continue to be evaluated by their respective organizations, with consultation provided by the Assistant Deputy Secretary for Field Policy and Management: |
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- CFO: Ft. Worth Accounting Center |
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- Administration: Employee Service Center (Chicago) - Housing: Financial Operations Center (Albany) |
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- Housing: National Servicing Center (Oklahoma City) |
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- Public and Indian Housing: Special Applications Center (Chicago) |
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-Public and Indian Housing: Section 8 Financial Management Center (Kansas City) - Public and Indian Housing: ONAP National Program Office Director |
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- Public and Indian Housing: ONAP Administrators |
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II. Personnel Management |
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DETAILING OF STAFF |
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Authority: The Regional Director can approve short-term details across program lines for up to sixty days. |
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There will be occasions that require an immediate response to urgent short-term problems, such as a critical staff shortage caused by extended medical leave, disaster response, or a Secretarial priority. There will also be occasions that present significant opportunities to advance local initiatives or enhance customer service. |
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Regional Directors may approve short-term details across program lines for a maximum of 60 days. Under this authority, Regional Directors may redelegate the authority to approve 30 day details to Field Office Directors. |
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All details beyond 60 days must be approved by the respective Assistant Secretary or his/her designee. Requests of extensions of details beyond 60 days should be submitted from the Regional Director to the Assistant Deputy Secretary for Field Policy and Management. The Office of Field Policy and Management will coordinate the review of these requests with the affected program office(s). |
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Regional Director or Field Office Director: The RD or FOD is responsible for ensuring sufficient resources are properly focused to accomplish the Management Plan and/or Secretarial Initiatives, and for ensuring that short-term problems and customer service issues are effectively addressed. |
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A FOD may detail staff across program lines for a maximum of 30 days. At the request of the FOD, the RD may extend this field office detail for an additional 30 days, for a maximum of 60 days. The FOD and RD will take into account any impact on the affected program areas. |
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Within the Regional Office, the RD may approve a short-term detail across program lines for 30 days, and extend it for a second 30 days. |
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The RD or FOD will discuss personnel details with the appropriate PD prior to approval. |
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Program Directors: A PD may request a detail through the RD or FOD. The RD or FOD will discuss the detail with the affected PDs prior to taking action. |
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Remote Program Delivery: Same as above. The FOD shall discuss the detail of an out stationed employee with the appropriate remote program supervisor prior to taking action. |
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12 |
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II. Personnel
Management |
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LEAVE APPROVAL |
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Authority: The Regional Director will approve leave requests for Program Directors. |
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It is the responsibility of the Regional Director or Field Office Director to ensure his/her office is managed efficiently and effectively. In order to accomplish this, the Regional Director or Field Office Director must be aware of the status of key management officials in the office and may require attendance at certain times or events. Therefore, the Regional Director or onsite Field Office Director will approve leave requests for Program Directors. |
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Regional Director or Field Office Director: The RD or FOD will approve routine leave (up to 3 days) for Program Directors in his/her office. Request for leave forms (OPM-71) will be provided, in advance of the leave, to the RD or FOD. The RD or FOD will act on leave requests in a timely manner. Emergency leave will be handled on a case-by-case basis. |
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For leave beyond 3 days, the advance concurrence of the appropriate program official(s) is required. |
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Program Directors: PDs will provide leave requests in advance to the RD or FOD for their action. PDs will ensure their program leadership is aware of their leave plans and status. |
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Remote Program Delivery: Not applicable. |
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II. Personnel Management |
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SELECTION OF LOCAL MANAGEMENT OFFICIALS |
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Authority: Regional Directors are authorized to serve as part of the recommending and hiring process for managers and supervisors within their respective jurisdictions. The Assistant Secretary, or equivalent, makes the final selection regarding their managers and supervisors. |
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Program Directors are key field office management team members. The Regional Director or Field Office Director will be given advance notification of program management vacancies. The RD or FOD will participate in the interviewing and recommendation process. The program Assistant Secretary or equivalent will be the Selecting Official. |
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For positions that cross Regional jurisdictions, input will be coordinated through the Office of Field Policy and Management. The Selecting Official will contact the Assistant Deputy Secretary for Field Policy and Management to obtain the necessary input. The Assistant Deputy Secretary may designate a Regional Director to participate in the process. |
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For selections of supervisors below the Program Director in any office, the Selecting Official will notify the RD or FOD prior to announcing the selection. |
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Regional Director or Field Office Director: As part of the merit staffing process, the RD or FOD shall participate in the selection of Program Directors in his/her local office by participating in interviews to fill such vacancies. The program Assistant Secretary or designee is the Selecting Official. Prior to the interviews, the Selecting Official or his/her designee will contact the RD or FOD and make the necessary arrangements. The RD or FOD may not delegate his/her participation in the selection process to another member of his/her staff. |
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Selecting Official: Prior to setting up interviews for selection of an office Program Director, the Selecting Official or his/her designee will contact the appropriate RD or FOD to make arrangements for his/her participation in the interview process. The Selecting Official need not use more than one RD or FOD in interviews. |
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II. Personnel Management
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OUTSTATIONED
PERSONNEL |
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Authority: The Regional Director will act as supervisor, or, when necessary, assign a supervisor to outstationed staff. |
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All staff in a field office should have onsite supervision. The Regional Director or Field Office Director has the authority to act as, or assign, an onsite supervisor where employees do not have onsite supervision. |
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Any change in working conditions for outstationed employees, e.g., assignment of an onsite administrative supervisor, must be completed in accordance with appropriate union contract requirements and must comply with Departmental Office of Human Resources guidelines. |
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Regional Director or Field Office Director: Where appropriate program supervision is unavailable onsite, the RD or FOD is responsible for assigning an appropriate supervisor to each outstationed employee. The RD or FOD may ask another Program Director to take on this assignment. If no appropriate supervisor is available, the RD or FOD will provide onsite supervision for an outstationed employee. Non-supervisory personnel cannot assume this function. |
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Where a supervisor has been assigned, the designated supervisor will receive the employee's work plan from, and coordinate leave, time and attendance with, the remote supervisor. |
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Remote Program Supervisor: The remote program supervisor will develop a work plan for an outstationed employee outlining assigned duties, performance requirements, and responsibilities under the Field Office Management Plan. The remote program supervisor will provide a work plan to the employee and the RD, FOD, or designated supervisor, detailing the employee's assigned duties, performance requirements and/or responsibilities. The remote program supervisor will provide ongoing technical direction and support. |
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The RD, FOD, or designee and remote program supervisor will communicate regularly regarding any issues of work performance related to the outstationed employee. Both supervisors should be well informed of performance evaluation concerns, awards, training, travel, and other ongoing work issues. |
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Remote Program Delivery: Same requirements as above. |
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Exceptions: Any exceptions to local supervision must be approved by the Assistant Deputy Secretary for Field Policy and Management. |
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Appeals: All applicable grievance procedures apply. |
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15 |
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II. Personnel Management |
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LABOR/MANAGEMENT RELATIONS |
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Authority: The Regional Director manages and conducts labor/management relations. |
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The existing union contracts outline the requirements when formal actions are to be taken between management and the union. The Regional Director or Field Office Director is responsible for overall labor/management relations in his/her office. The Regional Director will take the lead on regional issues. Issues or specific questions should be directed to the labor relations staff in Human Resources offices of the respective Administrative Service Center. While the Assistant Secretary for Administration or his/her designee is responsible for national contract negotiations, at the local level the RD/FOD will conduct bargaining and communicate information to local union representatives in accordance with applicable union contracts. [See Departmental Delegation of Personnel Management Authorities.] |
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III. Administrative
Management |
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ADMINISTRATIVE
MANAGEMENT |
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Authority: The Regional Director will determine official office hours, opening, closing, and emergency procedures. |
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All employees in each field office should be aware of the official office hours for the office, as well as the procedures for an emergency closing, evacuation, how to handle security issues, customer service, and other office-wide procedures. |
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Regional Director or Field Office Director: The RD or FOD is responsible for and has the authority to manage administrative field office operations, such as space utilization, parking, and other local issues. Relevant authorities also include: |
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• Official office hours of operation |
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• Emergency
office closings, e.g., early dismissal • Evacuation plans |
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• Security |
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• Internal
office communications of a general nature • Other items necessary for efficient office operations and effective customer service |
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The RD or FOD, in cooperation with local Program Directors, will set procedures for general office operation. All procedures will be in compliance with established Departmental guidelines. Any changes to existing procedures will be made in accordance with the current union contract, as appropriate. All procedures will be fully communicated to all local HUD staff for effective and full implementation. The Assistant Deputy Secretary for Field Policy and Management will retain authority for office closings for non-emergencies. |
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Program Directors: PDs will provide input to and cooperate with the RD or FOD to ensure smooth office operations. |
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Remote Program Delivery: The local FOD has administrative authority over all onsite staff to enforce field office operations decisions, e.g., closing the office and sending all onsite staff home in the event of an emergency. |
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IV. Resource Management |
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ADMINISTRATIVE MANAGEMENT – OFFICE ADMINISTRATIVE FUNDS |
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Authority: The Regional Director is responsible for the management of the administrative budget for his/her jurisdiction, e.g. training, equipment, etc. |
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The Regional Director or Field Office Director is responsible for ensuring his/her office is managed efficiently and effectively. |
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Regional Director or Field Office Director: The RD or FOD has the authority to manage and administer the local operational budgets and to set priorities on allocating administrative funds provided to the regional or field offices by the |
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ASCs. The RD or FOD will set office-wide priorities working with Program Directors. The RD or FOD will work with the ASC to ensure maximum effective use of the limited resources for the established local priorities. Funds will be expended in accordance with Departmental guidelines. The RD/FOD will work with the ASC prior to submission of the fiscal year budget p | ||||||||||