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2021

Bar Dues Reimbursement
Union Cease-and-Desist Letter Leads OGC to Comply with CBA for Bar Dues Reimbursement. After Council 222 learned that HUD s Office of General Counsel imposed new requirements for attorneys seeking reimbursement for mandatory bar dues, the Union sent a cease-and-desist letter to OGC to halt its violations of our collective bargaining agreement.

The Union fought for years to have HUD reimburse mandatory bar dues for attorneys, and our 2015 collective bargaining agreement provides for reimbursement of one set of bar dues for both OGC and Office of Chief Financial Officer attorneys.

OGC has been reimbursing mandatory bar dues for attorneys in compliance with our agreement for many years. In 2021, OGC imposed new requirements that supervisors approve the requests and attorneys sign the reimbursement claim form, which has no signature block. Under the provisions of our agreement, supervisors have no authority to deny an attorney’s request for reimbursement. OGC also required attorneys to submit reimbursement requests by August 13 this year, which denied reimbursement to attorneys who paid their bar dues from August 14 through September 30.

In response to the Union’s demand that OGC comply with our agreement, OGC sent out revised instructions to attorneys that eliminated signature requirements and supervisory approval and made provisions for reimbursing bar dues that attorneys pay through the end of the fiscal year. Below are OGC's original bar dues memo, Council 222's cease-and-desist letter, and OGC's revised bar dues instructions.
- - Revised bar dues instructions (07.28.2021)
- - Union Cease and Desist Letter (07.08.21)
- - Original dues memo (06.24.21)

Buddy Program
Allow seasoned employees to welcome new employees in their work unit for the first 30 days of onboarding. This will help the new employee become accustomed to the Agency and their new work.
- - Supplement 31 (09.27.21)

COVID-19 Safe Federal Workplace Guide
- - Supplement 28 negotiated by Antonio Carroway and his team (04/08/21)

Emergency Paid Leave
American Rescue Plan Act's Emergency Paid Leave (EPL)
- - Supplement 29 (06.2021)
- - Union Demand to Bargain (06.14.2021)

FHA Catalyst
FHA Catalyst is a web-based platform and provides information for Mortgagees to prepare and submit case binders for endorsement electronically through FHA's platform.
Chief Negotiator - James Flynn
- - Union Demand To Bargain/Cease and Desist (05/06/2021)
- - Management Notice to Union (04/29/2021)

Reorganization of Office of Exec Sec Correspondence Div in Office of Admin
- - Supplement 27 (03/31/2021)

TRANServe System Implementation
TRANServe System is a system for HUD Transit Subsidy Benefit Program nationwide.
- - Supplement 30 (06.20.2021)

2020

Analyst Dashboard Report (ADR) for DEC Analysts
Sept 30,2020 - The Union solicited comments from affected bargaining unit personnel regarding the proposed ADR tool. Employee concerns related to whether the proposed system would increase work by requiring more data entry of the same information, and whether the tool would be used to track employee performance. Most importantly, employees wanted to be sure that the ADR would accurately reflect where delays occurred and not automatically attribute all delays to the analyst assigned the case.

The Union filed a demand to bargain and a request for information in response to the Department's proposal. In the Department's response to the Union's RFI, the Department provided the following information:
• There is no additional data entry required because of implementing ADR.
• The ADR will eliminate the need to produce weekly/quarterly workload reports which are not real time but point in time reports.
• Analysts can view only their assigned referrals/reports. Satellite Office Directors/Team Leads in that office will be able to view only their office's referrals/reports.

The parties signed Supplement 26 on September 22, 2020. The supplement includes the Department's agreement that "Management shall ensure that all reports generated by the system accurately reflect both the timing of when delays occur and the responsible individuals. Employees shall not be held responsible for case processing delays that are out of their control."

HUD has said that it is aiming for a November 2020 implementation date, "but that may be wishful thinking."

August - HUD proposed implementing a new "tool" or system in the Office of General Counsel (OGC) Departmental Enforcement Center (DEC). On August 18, 2020, HUD notified the Union of its intent to implement an Analyst Dashboard Report (ADR) in November for DEC analysts to use in tracking cases. Management has asserted that analysts currently do not have one place where they can review the progress of their work assignments/referrals. Employees, however, have rejected that statement, stating that the integrated Real Estate Management System (iREMS) keeps analysts up to date on all financial, physical, and non-filer referrals. The employees have also questioned the accuracy of the ADR reports in attributing delays to the proper source, such as prior to assignment to an analyst or to team lead reviews. Additionally, employees have expressed concern about management's claim that ADR will aid DEC employees in prioritizing their workload, as opposed to managers monitoring their work.

Implementation of the proposed tool affects DEC bargaining unit personnel in Headquarters OGC DEC Operations Division and DEC satellite offices in Atlanta, Chicago, Fort Worth, Los Angeles, and New York.

Chief Negotiator - Jerry Gross
- - Supplement 26 (09/22/2020)
- - ADR Response to Union Questions
- - Union Demand to Bargain and Request for Information (09/01/2020)
- - Mgmt Notice (08/18/2020)

Clean Desk Policy, HUD's Misnamed Proposed (Protection of Sensitive Information)
On July 6, 2020, HUD provided Council 222 with Article 49 notice regarding a proposed new policy that it called the "Clean Desk" policy. The policy has nothing to do with clean desks. Instead, it is HUD's effort to ensure that sensitive information such as Personally Identifiable Information (PII) and confidential medical information is protected. The Department drafted this policy to resolve an IG audit finding. It proposes to implement on August 5, 2020.

The Council responded with a demand to bargain containing preliminary proposals on July 10, 2020. These proposals included suggested ways to clarify and improve the proposed policy. The Council provided additional preliminary proposals on July 15. Jerry Gross will serve as the chief negotiator.

- - Supplement 24 (08/04/2020)
- - Final Union Proposals (07/20/2020)
- - Union Demand to Bargain Amended (07/15/2020)
- - Union Demand to Bargain (07/10/2020)
- - Mgmt Clean Desk Policy (draft)

Corona Virus
UPDATE: Council 222 modifies their Sept 14 Demand to Bargain (below)on September 20 after the Safer Federal Workforce Task Force issued new guidance on September 16.
Modified Demand to Bargain (09/20/21)
Email exchange between 222 Chief Negotiator Ricardo Miranda and Dee Dee Hankinson, HUD Deputy Director of Employee and Labor Relations

Council 222 files a Demand to Bargain over Corona Virus vaccination mandate attestation and testing requirements. The Union expects to hear more from the Safer Federal Workforce Task Force which will come out with its guidance based on President Biden's Executive Order of September 9. The workforce is to provide guidance for implementation by September 16.
- - Demand to Bargain (09/14/2021)
- - White House Executive Order on Requiring Vaccination for Federal Employees (09.09.21)

COVID-19 Pandemic, Closing Multifamily Loans and Similar Commercial Loans During (Contingency Plans for
- - Supplement 22 (06/25/2020)
- - Demand To Bargain (03/25/2020)
- - Mgmt Memo to OGC (03/16/2020)

Emergency Paid Sick Leave Act (EPSLA)
On March 18, 2020, President Trump signed into law the Families First Coronavirus Response Act (FFCRA), which also created the Emergency Paid Sick Leave Act (EPSLA) that provides emergency paid sick leave in response to the COVID-19 global pandemic. Effective April 1, 2020 through December 31, 2020, in accordance with the FFCRA/EPSLA, employees are entitled to up to a maximum of 80 hours (prorated for part-time employees) of fully or partially paid emergency sick leave under one or more of the 6 provisions. This temporary, new form of leave is available in addition to any other paid leave entitlements.

It is important to note that this provision is an entitlement – and as such – if an employee requests this leave and has the appropriate documentation, supervisors should approve the request(s).

- - Supplement 23 (06/25/2020)
- - Checklist
- - Calculator
- - Guidance
- - Union Demand to Bargain (06/10/2020)

Return to Normal Operations (Phase 1)
- - Supplement 25 (08/04/2020)

2019

Possible Lapse in Appropriations 2019(Contingency Plan for)
- - Demand To Bargain (09/26/2019)

Reorg Office of Exec Sec Correspondence Div in Office of Admin Supplement 27 (03/31/2021)

2018

Anti-Harrassment Policy
Purpose of this policy is to stop harassing behavior. Nothing in this supplement shall limit the employee from utilizing available protections, recourses, and remedies as provided in statute, policy, or this Agreement.
- - Supplement 18 (not dated)

Cellular Phones Distributed to FHEO Bargaining Unit Nationwide
- - Demand To Bargain (10/02/2018)

Email Policy
- - Supplement 19 (not dated, completed June 2018)
- - Union Demand To Bargain (03/15/2018)

ORCF Portal in Office of General Counsel
Mgmt has announced implementation of required use of ORCF Portal in the Office of General Counsel.
- - Demand To Bargain (10/15/2018)

Personnel Security and Suitability Policy and Procedures Handbook 755.1
06/30 Update! Personnel Security and Suitability Policy and Procedures Handbook 755.1 - Negotiations ended in August 2018 and in May 2019 the Department finalized the handbook and posted it online.

Union negotiators worked with management for over two years regarding HUD's proposal to implement a new Handbook 755.1, Personnel Security and Suitability. For information on earlier negotiations, including the ULPs that Council 222 filed regarding related information requests, please see the 2017 Bargaining Page items below. In addition to reaching an agreement on the handbook's implementation, the Union was able to correct problems and errors in the handbook before implementation, to correct inaccurate employee security designations, and to ensure HUD's conformance with current law, the existing CBA, and retained supplements. In addition, Supplement 20 also requires HUD to issue PIV cards to HUD retirees who are Union officials performing representational duties and to protect employee rights under privacy laws, Title VII, the ADA, and the Rehabilitation Act.
- - Personnel Security and Suitability Policy and Procedures Handbook 755.1
- - Supplement 20 (08/21/2018)
- - Demand To Bargain (08/01/2018)

Personnel Security and Suitability from 2017 Bargaining:
Chief Negotiator - Jerry Gross
Update: The union filed two complaints with the FLRA because HUD did not respond properly to the Union´s request for information related to the proposed handbook. The Union demonstrated to the FLRA why the information and documentation requested was essential. The FLRA required HUD to provide all available information and to distribute the Notice as HUD´s public commitment to respond to Union requests for information in a timely manner in the future. The FLRA required HUD to send out a Notice to All Employees by email and to post it on bulletin boards to settle complaints of an unfair labor practice that the Union filed against HUD. The ULP documents are here and on our ULP page.
- - FLRA Required Posting to Employees By Management to Settle Union Complaint (06/2017)
- - FLRA Settlement Agreement (06/05/2017)
- - FLRA Charge Against Agency
- - ULP (03/16/2017)
- - Request for Information and Demand To Bargain (05/26/2016)
- - Handbook Draft of 755.1