For PHA’s that use free labor from either a Workforce Agency agreement or local jail labor, do those workers hours get counted toward the benchmarks? (Before you ask, I have to assume the jail labor is permissible in those jurisdictions.) The agencies pay nothing to the workers in either case so there is no relatable expense and, in some cases, no real structured job training either.

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Response From HUD:

No, a labor hour as defined in the regulation means the number of paid hours worked by persons on a Section 3 project or by persons employed with funds that include public housing financial assistance. §75.5


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