Design, Construction & Regulatory Compliance
IHDA works with owners, architects and contractors to facilitate compliance with all applicable construction, accessibility, sustainability, environmental, wage rate, and contract reporting, codes, acts and standards.
Design Compliance
Architectural planning and construction standards
The 2021 IHDA Standards for Architectural Planning and Construction is a comprehensive reference for owners, developers, architects and contractors in the design and construction of quality affordable housing. IHDA uses the standards to evaluate plans, specifications and other relevant data of the proposed new construction, rehabilitation and adaptive reuse of existing buildings. The following memo is a summary of modifications for the 2019 Standards for Architectural Planning and Construction. Please see the updated document for exact language of the modified sections.
Accessibility review
The Architectural Services department reviews plans for compliance with applicable accessibility codes. A summary of each code can be found in the 2021 IHDA Standards for Architectural Planning and Construction. One or more of the accessibility codes and acts applies to any development funded by IHDA. When there is a conflict in the design requirements of the various acts and codes, the most stringent requirements will prevail. Projects electing points for enhanced accessibility under the LIHTC program will be subject to the additional requirements outlined in the relevant QAP for the project’s allocation year.
- Fair Housing Act
- Illinois Accessibility Code
- Section 504 of the 1973 Rehabilitation Act
- UFAS Accessibility Checklist for PHA
Sustainability review
IHDA is using the Enterprise Green Communities criteria as its green design standards. Please refer to the IHDA Standards for Architectural Planning and Construction for all minimum green design requirements. Projects electing points for green initiatives under the LIHTC program will be subject to the additional requirements outlined in the relevant QAP for the project’s allocation year. Acceptable third-party certifications are included below.
Physical Needs Assessment (PNA) review
If the project consists of any existing structures, a Physical Needs Assessment (PNA) must be submitted at the time of application. The PNA will evaluate the current condition of the asset(s) and include a cost estimate for any critical, immediate and long term repairs. The PNA must be prepared in accordance with the property needs assessment standards below.
Regulatory Compliance
IHDA projects must be built in locations that are healthy for both humans and the environment, and must adhere to all federal regulations related to environmental and human safety. All applicants for IHDA multifamily financing must submit a Phase I review prepared in accordance with the Environmental Requirements for Multifamily Affordable Housing.
In rehabilitation projects, special attention must be given to:
- IHDA Lead-Based Compliance Guide
- Asbestos considerations (HUD, IEPA and EPA 40 CFR 61.145 and Illinois Department of Public Health regulations)
- Mold considerations
- HUD/NEPA Requirements
Construction Compliance
Davis-Bacon
Most projects containing funds from federal sources are subject to Davis-Bacon wage requirements and the recipients must ensure that all applicable Davis-Bacon wage requirements are followed. The IHDA Davis-Bacon Compliance Guide is provided as a user guide for the Davis-Bacon wage requirements and includes the various forms, posters and links.
Illinois Prevailing Wage
All IHDA-funded projects are subject to Illinois prevailing wage, unless the project contains funds from federal sources, in which case the Davis-Bacon wage rate will prevail. The Illinois Department of Labor (IDOL) has oversight responsibilities to assure coordination of administration and consistency of enforcement of the labor standards provisions of the Illinois Prevailing Wage Act. IDOL has issued regulations establishing standards and procedures for the Illinois Prevailing Wage Act.
Contract Reporting – Section 3
IHDA administers a portion of its funds from federal sources for housing development activities. Most projects containing funds from federal sources are subject to Section 3 requirements and the recipients must ensure that all applicable Section 3 requirements are followed. The Section 3 Plan and Compliance Guide is provided as a plan for the Section 3 requirements and includes the various forms that must be submitted for compliance.
Change Order Process
When a modification to the construction contract is requested, an AIA G701 change order form executed/signed by the owner, general contractor and architect must be submitted to IHDA’s construction field representative. IHDA provides guidelines for change order submittals and additional guidance can be found in the 2021 IHDA Standards for Architectural Planning and Construction.
Site Inspections
During the monthly field inspections, the construction field representative reviews and approves monthly payment requests, change orders and permissions for occupancy before forwarding a copy of these documents to the construction field representative supervisor.
If federally funded, the construction field representative supervisor will review payrolls for Davis-Bacon compliance.
Projects electing points for enhanced accessibility and green initiatives under the LIHTC program will be subject to the additional requirements outlined in the QAP applicable to the project’s allocation year.
A representative from IHDA’s Architectural Services department will conduct inspections throughout the project duration to review the project for compliance under these sections of the QAP.
Construction and Architectural Services Close Out
When the project is 100 percent complete, prior to final project close out, several criteria must be met for IHDA to give its approval.
Frequently Asked Questions
Design, Construction & Regulatory Compliance FAQs
This is a partial list of FAQs and is meant to serve as a general guide. This FAQ may be updated from time to time. Please be certain to check back.