FOR YOUR INFORMATION
I consult with owners and managers on the full range of 515 issues:
— appeals related to OIG audits;
— Workout Plans;
— appeals of adverse RHS decisions;
— issues with the Agency; and
— prepayment.
I am working with attorneys regarding matters involving the program,
including debarment as well as OIG audits.
I have the following comments on the program:
DRAFT 3560. I have written comments on the draft 3560 regulation. I
conclude the Agency will be the preeminent threat to the program if the
regulation is not revised. E-mail me for a copy of my comments.
YEAR 2000. The General Accounting Office (GAO) reports that:
“Given the enormous potential risk, USDA has determined that the Year 2000
crisis is its top information technology priority. It has not, however,
translated that sentiment into effective action. . . .”
OWNERS COMMITTEE. CARH is proposing to form an Owners Committee to
follow
issues for owners, as distinct from developers and managers.
MANAGEMENT FEES. I have won appeals of Management Fees where the State
Office had put out an AN in an attempt to set fees. Call me to discuss
doing
the same for you.
PREPAYMENT LEGISLATION. CARH has drafted legislation to make prepayment
workable and further the interests of owners. Contact and join CARH for more
information.
I have worked with and advised owners, developers and managers on 515 program issues and problems since 1988. If you have an issue with RHS or on your projects, or don’t have the expertise on your staff, please contact me.