ACE Program

Advancing Community Employment (ACE) Program

ACE Program Information for Businesses

What is the Advancing Community Employment Program?

CMHA's Advancing Community Employment Program or “ACE Program” fosters local economic development, neighborhood economic improvements and individual self-sufficiency through HUD's Section 3 framework.

What is Section 3?

Section 3 is a provision of the Housing and Urban Development Act of 1968 (12 U.S.C. §1701u) with implementing regulations at 24 C.F.R. Part 75. Section 3 seeks to provide economic opportunities, to the greatest extent feasible, to low- and very low-income persons (particularly those who receive government assistance for housing) and to businesses that provide economic opportunities to low- and very low-income persons.

I am a CMHA contractor/subcontractor. How does the ACE Program affect my business?

As a contractor for CMHA, you must, to the greatest extent feasible, ensure that at least 25% of all labor hours Labor Hours means the number of paid labor hours worked by persons working on an Applicable Expenditure.

Applicable Expenditure means a contract, cost, or other expenditure by CMHA that is paid for by any amount of Public Housing Financial Assistance.
on the contract are worked by ACE Workers and an additional 5% of all labor hours are worked by Targeted ACE Workers.

What are ACE Workers and Targeted ACE Workers?

An ACE Worker is at least one of the following:

  1. Someone whose individual income for the previous or annualized calendar year is below HUD's low-income or very low-income limits;
  2. Someone who is employed by an ACE Business ACE Business, also known as a Section 3 Business, means a business concern meeting at least one of the following criteria, documented within the last six-month period:
    1. It is at least 51% owned and controlled by low- or very low-income persons;
    2. Over 75% of the labor hours performed for the business over the prior three-month period were performed by ACE Workers; or
    3. It is at least 51% owned and controlled by current public housing residents or residents who currently live in Section 8-Assisted Housing
    ; or
  3. Someone who is a YouthBuild YouthBuild Program means YouthBuild programs receiving assistance under the Workforce Innovation and Opportunity Act (29 U.S.C. § 3226). participant.

A Targeted ACE Worker is a type of ACE Worker. Specifically, an individual is a Targeted ACE Worker if they:

  1. Are employed by an ACE Business;
  2. Are (or when hired), as documented within the past 5 years, a resident of public housing or Section 8-assisted housing;
  3. Are (or when hired), as documented within the past 5 years, a resident of other public housing projects or Section 8-assisted housing managed by CMHA; or
  4. Are a YouthBuild participant.
What Qualifies as an ACE Business?

You are an ACE Business if you meet any one of these criteria:

  1. You are at least 51% owned and controlled by Low– or Very Low-Income Persons;
  2. Over 75% of your business's labor hours in the past three months were performed by ACE Workers; or
  3. You are at least 51% owned and controlled by current residents of public housing or Section 8-assisted residents.

If you are unsure if your business is an ACE Business, please call or email ACE Program Coordinator Lydia Sanders at (216) 271- 3247 or ACE@cmha.net

What does it mean to participate in the ACE Program?

There are two key components to participating in the ACE Program.

First, an ACE Business apply to be in the ACE Business Directory. CMHA and its contractors use the Directory to identify business that might help them meet the 25% and 5% targets.

Second, when an ACE Business in the Directory is selected as a contractor or subcontractor, the business will need to seek formal ACE certification from CMHA. The certification process allows CMHA to confirm the business qualifies as an ACE Business. Once certified, CMHA can begin counting the ACE Business's labor hours towards the ACE targets. The certification is valid for six months. (Unfortunately, HUD regulations require CMHA to re-verify ACE eligibility if more than six months have passed since the last time the ACE Business was certified.)

Why should my ACE Business participate?

ACE Business status provides a significant advantage that helps contractors meet CMHA's ACE minimum targets: all of the hours worked by employees of an ACE Business count as hours worked by Targeted ACE Workers—regardless of the worker's housing status or income. This means that when a contractor looks to subcontract a portion of their work, they will look first to ACE Businesses to help them meet the ACE minimum targets. Likewise, an ACE Business that is a prime contractor does not have to worry about the requirements of the ACE Program: all of its workers' labor hours will automatically exceed ACE minimum targets!

How do I get my ACE Business in the ACE Business Directory?
How can my business become a CMHA-certified ACE Business?

If the business is already in the ACE Business Directory or identified itself as an ACE Business on the ACE Program Acknowledgement form (Form DEI-1) in response to a solicitation, then CMHA will officially certify the business prior to execution of the contract with CMHA. To do so, CMHA will require the business to complete an ACE Business Certification Application (Form DEI-5).

If the business becomes an ACE Business after contract award, it may request official ACE Business certification at any time over the duration of that contract by contacting an ACE Program Coordinator.

Is my CMHA Section 3 Business certification still valid?

No, if CMHA previously certified your business as a Section 3 Business it is no longer a Section 3 Business because of HUD changes to the definition of a Section 3 Business. Effective April 6, 2022, CMHA terminated all active Section 3 certifications.

Who should I contact with questions about the ACE Program?

For questions regarding the ACE Program, please contact ACE Program Coordinator Lydia Sanders at (216) 271-3247 or ACE@cmha.net.

ACE Program Information for Workers

What was the PAR Program and how has it been impacted by the ACE Program?

The Project Area Resident (PAR) program was a CMHA program to encourage hiring of CMHA residents on CMHA-funded projects. The ACE Program now combines the old PAR Program with HUD's Section 3 regulations. But similar to the old PAR Program:

  • ACE will continue providing access to job and training opportunities for such things as construction, office work, OSHA safety training, plumbing, and painting.
  • ACE will also ensure CMHA residents are first in line for work and training opportunities.
What is the difference between the ACE Program and HUD Section 3?

CMHA's ACE Program is very similar to HUD's Section 3 regulations, which seek to provide economic opportunities, to the greatest extent feasible, to low- and very low-income persons (particularly those who receive government assistance for housing). Beyond HUD's Section 3 requirements, the ACE Program will also allow CMHA to directly recruit its own residents for job and training opportunities.

Who can participate in the ACE Program?

Anyone who meets the following definition qualifies as an ACE Worker:

  1. Someone whose individual income for the previous or annualized calendar year is below HUD's low-income or very low-income limits;
  2. Someone who is employed by an ACE Business; or
  3. Someone who is a YouthBuild participant.

If you meet this definition and contribute labor hours towards a CMHA contract subject to ACE Program requirements, then those hours will count towards the ACE minimum targets.

But please note that CMHA is only actively recruiting ACE Workers who are current CMHA residents. CMHA will recruit Housing Choice Voucher participants (traditional Section 8 tenant-based voucher holders) and other low-income individuals in the future.

Why should I participate in the ACE Program?

Participating in the ACE Program is a chance to:

  • Be matched with training and paid work opportunities;
  • Achieve sustained employment and self-sufficiency; and
  • Obtain information (through phone calls and emails) about upcoming work and training opportunities suited for your skills and preferences.
How do I participate in the ACE Program?
How can I learn more about the ACE Program?
Who should I contact if I have questions about the ACE Program?

For questions regarding the ACE Program, please contact ACE Program Coordinator Lydia Sanders at (216) 271-3247 or ACE@cmha.net.

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