Founded in 1949, the International Association of Official Human Rights Agencies (IAOHRA) is a private non-profit corporation headquartered in Washington, D.C.  IAOHRA represents civil and human rights agencies committed to promoting high standards of ethical, efficient and effective enforcement of civil and human rights laws and to supporting the growth, quality and recognition of fair housing enforcement professionals.

• Credentialing raises the status of fair housing enforcement professionals by demonstrating that practitioners take a professional approach to their duties.
• The public gains a higher level of protection because certified fair housing investigators are acknowledged to have met certain standards and have demonstrated their competence in relevant skill-sets.

As promoted by the National Commission on Certifying Agencies, IAOHRA’s certification process is geared to test and validate the application of knowledge required to perform the duties of a fair housing investigator. IAOHRA’s certification process will test more than the theoretical basis or the knowledge of “how” to perform these duties – the certification process is designed to validate the demonstrated ability of the Candidate to perform these duties in a consistent and effective manner.
IAOHRA’s certification process assures that the Candidate has had sufficient opportunity to apply learned skills and knowledge, been exposed to the nuances and challenges of the profession, and learned how to adapt and confront these experiences.
IAOHRA is proud to partner with the Patricia Roberts Harris National Fair Housing Training Academy to offer Candidates the opportunity to attain the Certified Fair Housing Investigator (CFHI) designation.

International Association of Official Human Rights Agencies (IAOHRA)

Certified Fair Housing Investigator (CFHI) Process

Introduction

Founded in 1949, the International Association of Official Human Rights Agencies (IAOHRA) is a private non-profit corporation headquartered in Washington, D.C.
IAOHRA provides opportunities and forums for the exchange of ideas and information among human rights advocates.  Organizations and individuals are invited to participate in IAOHRA sponsored seminars and training conferences with professionals from all disciplines.  IAOHRA also provides advance training opportunities for its members and other concerned groups and organizations.
Objectives:

• To promote equal opportunity and equal treatment.
• To provide assistance in the elimination of unlawful discrimination in employment, housing, education and public accommodations.
• To promote affirmative action in all areas.
• To coordinate member agencies' concerns and interest before all branches of the federal government.
• To educate the public and private sector on human rights and civil rights issues. 

The Patricia Roberts Harris National Fair Housing Training Academy (NFHTA) was established by the U S Department of Housing and Urban Development to provide the highest level of professional training for practitioners in the field of civil rights and equal housing opportunity. Completion of the prescribed five week curriculum through the Academy offers benefits that include:

• A practical means of assessing fair housing skills and experience.
• The satisfaction of measuring oneself against the highest industry standards.
• Membership in a distinctive peer group made up of fellow fair housing professionals.
• Recognition for specialized knowledge in varied civil rights specialty areas.
• The opportunity to test your knowledge in a specific area of the profession by earning a proficiency certificate.
• Help in career advancement and compensation.
• For people new to the civil rights field, an entry point for building their professional careers.

This document establishes within the International Association of Official Human Rights Agencies (IAOHRA), in collaboration with the Academy, and the Graduate School, a Certified Fair Housing Investigator (CFHI) certification.  The CFHI is a competency-based Fair Housing investigator credential developed to recognize fair housing industry professionals who meet the investigator competency standards established by IAOHRA. The CFHI credential is part of the fair housing industry and government-wide initiative to drive and improve enforcement and compliance in accordance with the Federal Fair Housing Act.

Purpose

Certification through IAOHRA ensures the creation of a corps of knowledgeable and proficient fair housing professionals. As the Academy expands to reflect the changing nature of the profession, those who complete the core curriculum are held to the highest standards as civil rights professionals.  Certification ensures the consistent, effective enforcement of civil rights laws.

Applicants who successfully complete the five week core curriculum of the NFHTA Fair Housing Investigator training program are considered to have met the following six standards:

• Knowledge of fair housing law and regulations
• Excellence in report writing
• Mastery of investigative procedures and techniques
• Knowledge of hearing rules and procedures
• Knowledge and adherence to Federal, State, and City fair housing-related laws and ordinances, and relevant court decisions
• General understanding of federal fair housing programs

The Certified Fair Housing Investigator professional designation is designed to establish a professional credential for investigators who successfully complete the NFHTA five week core curriculum training program, meet specific professional requirements, and pass a comprehensive examination.

Fair Housing Investigator Certification Process

Requirements for CFHI Certification
The certification process is designed to ensure that investigators have the necessary knowledge and skills to competently perform these functions. Certification is a three step process

• Successful completion of the 5 week core curriculum offered by the Patricia Roberts Harris National Fair Housing Training Academy (NFHTA).
• Evaluation of investigative skills
• Examination of investigative knowledge

Certified Fair Housing Investigator (CFHI) Eligibility
Candidates wishing to take the CFHI examination must first satisfy the following requirements:

• Completion of the 5 week core curriculum offered by the Patricia Harris Roberts National Fair Housing Academy;
• Two (2) years of experience;
• Satisfactory completion of five (5) fair housing investigations
• A letter of recommendation from the applicant's supervisor listing applicant’s job description and length of service (attach to application).

All IAOHRA programs comply with the Americans with Disabilities Act. All IAOHRA programs are non-discriminatory. Eligibility for CFHI certification and recertification is denied only when an applicant does not meet relevant criteria, when an applicant has violated the CFHI Code of Professional Responsibility, or when an applicant has committed an act that would reflect negatively on IAOHRA and the CFHI® program.

Definition of Terms

• "Investigations" is the logical collection of information through inquiry and examination for the purpose of developing evidence leading to problem resolution.
• "Experience" means that the individual has been personally engaged in fair housing investigations on a full-time basis, or has as his or her primary duty:
• Experience as a fair housing investigator in the public or private sector.
• Experience with government, or other organizations performing duties and responsibilities substantively related to fair housing investigations.
• Experience as a supervisor or director who is responsible for the case management of fair housing investigations.
• "Case Management" is the coordination and direction of an investigation utilizing various disciplines and resources, the findings of which would be assessed to establish the facts/findings of investigations as a whole; the management process of the investigation.

Application Process

• Apply to IAOHRA for Fair Housing Investigator Certification.
• IAOHRA will screen applications and notify applicants of their eligibility to sit for the exam.
• IAOHRA will send approved applicants a Comprehensive Exam Self-study Guide.
• IAOHRA will notify applicants of the date of the exam and approved test sites near their community.  Students within 50 miles of the Academy must take the exam on the Academy campus.

Evaluating the Quality of Investigations

IAOHRA will develop an evaluation methodology to provide objective, on-going feedback about the quality of investigations. This evaluation process serves two basic purposes. First, these standards provide guidance to individual investigators regarding the expectations for the performance of a quality investigation as well as serve as an assessment mechanism which can provide feedback to improve their skills. Secondly, this evaluation process can be used to assist those with responsibility for oversight and quality improvement of the investigative process. It can be used as part of the oversight effort at the highest level in the organization, providing a means by which the investigative system as a whole can be evaluated and the information used to monitor and, where needed, improve the quality of investigations.

The following are the performance standards set forth for evaluating a certified fair housing investigator (See IAOHRA Standards of Practice).

1. Performance Standard #1 (24 CFR § 115.206(e)(1)): The Candidate consistently and accurately conducts  complaint proceedings, completes investigations, issues determinations, and makes final administrative dispositions in a timely manner.
2. Performance Standard #2 (24 CFR § 115.206(e)(2)): Administrative closures are utilized only in limited and appropriate circumstances.
3. Performance Standard #3 (24 CFR § 115.206(e)(3)): During the period beginning with the filing of a complaint and ending with filing a charge or dismissal, the Candidate to the extent feasible, attempts to conciliate complaints.
4. Performance Standard #4 (24 CFR § 115.206(e)(4)): The Candidate conducts compliance reviews for settlements, conciliation agreements, and orders resolving discriminatory housing practices.
5. Performance Standard #5 (24 CFR § 115.206(e)(5)): The Candidate must consistently and affirmatively seek and obtain appropriate relief designed to prevent recurrences of discriminatory practices.
6. Performance Standard #6 (24 CFR § 115.206(e)(6)): The Candidate is expected to consistently and affirmatively seek to eliminate all prohibited practices under fair housing laws.

Examination, Administration and Description

The CFHI examination will be given at least twice annually. From the date of application approval, applicants have a two-year eligibility period to take and pass the examination. The applicant will have two hours to complete the 100 question certification examination. Each question is referenced to the material provided during the 5 week core curriculum offered by NFHTA.
Preparation for the test should include a review of the course materials and materials from the CFHI Study Guide and Preparation Manual.
As part of the application screening, a Certification Board (IAOHRA) certifies that all applicants have successfully met the standards and requirements for certification, including;

• Confirmation that the applicant has received satisfactory job performance evaluations since attending the Academy;
• References to attest to the applicant’s character and ethics;
• Competency of the applicant in the essential functions required of a certified investigator as demonstrated by examination; and,
• Successful completion of a minimum of five (5) fair housing investigations.

Examinations

CFHI Examinations will be administered in January and July of each year with confirmation ceremonies held in April at the Academy and in August/September in conjunction with the IAOHRA conference.  All CFHI Examinations will be proctored for quality assurance.
Applicants within a 50 mile radius of the Academy campus will be expected to take the examination on-site.  Applicants outside the 50 mile radius must take the examination at an approved proctoring site. Standard proctoring sites include testing facilities at other accredited colleges or universities, local schools, public libraries, U.S. military bases, or government training facilities. Applicants are responsible for paying proctor fees.
Applicants will be provided with a list of approved proctoring sites available within a 50 mile radius of their address.  Applicants will be responsible for making all arrangements and appointments to take the exam.  Applicants must get the Proctoring Application and Approval Form completed and returned to the Academy no later than 10 business days before the scheduled examination.
Standard approved proctors include professional librarians; testing center officials, online education administrators, college or university faculty; K-12 teachers, administrators, or counselors; testing control or unit education officers; and U.S. embassy officials. Relatives, clergy, employers, and co-workers are not acceptable proctors.
Following completion of the written examination, applicants, and agency supervisors will be notified by letter whether they passed or failed. The student must score 85% or better on the exam in order to pass. In the event that an applicant fails the examination, the applicant may apply to retake the certification examination. Should the applicant fail the exam a second time, he or she must attend and successfully complete the CFHI Refresher Course before taking the examination again. A proctored examination will be given at the end of the refresher course.  There are no limits to the number of retests an Applicant may attempt during the eligibility period; however the refresher course is a requirement after two successive exam failures.

Award of Certified Fair Housing Investigator Professional (CFHI) Certificate

• Applicants and agency supervisors will receive official notification that the applicant has met the requirements of CFHI certification,
• A credential indicating status as a CFHI will be awarded at the next confirmation ceremony.

Board Certification Meetings

Two (2) board certification meetings will be held annually in February and August of each year. 
CFHI Recertification
Once the CFHI is conferred, recertification requirements must be met every three years to maintain a valid credential. The CFHI designation expires unless recertification requirements are met. CFHI certification shall expire three years from the date of certification or from date of recertification. Notification of approaching expiration will be sent to the agency and individual's home address prior to the recertification date. The individual is responsible for supplying IOAHRA with a current home address.
The purpose of the CFHI Continuing Certification Requirements Program is to:

• Ensure that credentialed individuals maintain skills in investigations, leadership, and professionalism
• Ensure that individuals obtain and maintain knowledge of current industry practices, laws and government regulations.

Each CFHI must satisfy the CFHI recertification requirements in order to maintain the CFHI credential. CFHIs are required to attain no less than 60 classroom hours of training during the three year credential validity period.
The investigator will be required to complete the following criteria in order to renew certification:
A. Complete and submit the Recertification Application
B. Provide documentation of 60 classroom hours of training as a student in fair housing investigation related courses or seminars. (Note: All courses or seminars are subject to pre-approval.  Fair Housing courses and seminars offered by HUD, NFHTA, IAOHRA, NAHRW, John Marshall Law School, NFHA and NCRC are presumptively approved. )
C. Submit a letter from the applicant's supervisor listing applicant’s job description and attesting to the fact that the primary duty of the applicant is fair housing investigation. The supervisor shall verify the number of complaints that the applicant has investigated during the three year period.
In the event an individual does not submit the required documentation for recertification his or her certification status will be revoked. IAOHRA does not grant extensions due to job demands, company budgets, employment status, personal finances, changes in marital status, changes in mailing address, and other personal or professional reasons. Extensions might be granted if there is a severe hardship such as a major medical emergency in the immediate family, a natural disaster, or if on active military duty and deployed into a remote or hazardous area. Severe hardship must be documented and verifiable.
In order to regain certification, an individual must retake the CFHI Refresher Course and successfully pass the CFHI certification examinations.

Fees and Payment Submission

Application fee must accompany the application. Checks will be payable to International Association of Official Human Rights Agencies in U.S. dollars; Applications with payments would be due one month prior to the examination date in order to ensure compliance with all provisions of the certification process.

APPLICATION FEE:

• IAOHRA MEMBERS ---$100
• NON MEMBER ---$150

EXAMINATION FEE:

• IAOHRA MEMBERS ---$300
• NON MEMBER  ---$350

RETEST FEE:

• IAOHRA MEMBERS --- $150
• NON MEMBER  --- $175

NFHTA STUDY GUIDE AND PREPARATION MANUAL:

• IAOHRA MEMBERS ---$35
• NON MEMBER  ---$40

NFHTA CERTIFICATION REFRESHER COURSE (study guide included in fee):

• IAOHRA MEMBERS ---$750
• NON MEMBER ---$1000

Funds payable to: IAOHRA, 444 North Capitol Street, N.W. Suite 536, Washington, D.C. Attn: Lonnie Douglas

STANDARDS OF PRACTICE

FOR CERTIFIED FAIR HOUSING INVESTIGATORS

Performance Standard #1 (24 CFR § 115.206(e)(1)): The Candidate consistently and accurately conducts  complaint proceedings, completes investigations, issues determinations, and makes final administrative dispositions in a timely manner.

1. The Candidate is expected to consistently and accurately begin the processing of fair housing complaints within 30 days of receipt.
2. The Candidate is expected to consistently and accurately receive information regarding alleged discriminatory housing practices, and begin the investigation process by collecting information necessary to determine jurisdiction under the Fair Housing Act and other civil rights laws.
3. The Candidate is expected to consistently and accurately take action to ensure timely and effective complaint processing.
4. The Candidate is expected to consistently and accurately recognize and documents all civil rights laws relevant to the complaint.
5. The Candidate consistently and accurately determines whether the complaint contains sufficient information to convert the allegation or” inquiry” into a complaint.
6. The Candidate is expected to consistently and accurately identify the Fair Housing Act’s protected classes and types of conduct and activities prohibited under the Act.
7. The Candidate is expected to consistently and accurately apply fair housing exemptions.
8. The Candidate is expected to consistently and accurately document the facts and circumstances of a complaint to determine if it affirms or refutes allegations of discrimination.
9. The Candidate is expected to consistently and accurately determine when and how to use reasonable accommodation and modification concepts as defined by the federal Fair Housing Act.
10. The Candidate is expected to consistently and accurately investigate and document “psychological harm” during the course of an investigation.
11. The Candidate is expected to consistently and accurately identify witness testimony and other case information that is competent and admissible.
12. The Candidate is expected to consistently and accurately recognize whether the required elements of a prima facie case are present in a housing discrimination complaint.
13. The Candidate is expected to consistently and accurately determine which complaints are appropriate for testing.
    
14. The Candidate is expected to consistently and accurately complete investigative activities within 100 days from the date of receipt.
15. The Candidate is expected to consistently and accurately issue final administrative dispositions of complaints within one year from the date or receipt.
16. The Candidate is expected to consistently and accurately prepare and complete final investigative reports for all complaints.
17. The Candidate is expected to consistently and accurately prepare final determinations for all complaints.

Performance Standard #2 (24 CFR § 115.206(e)(2)): Administrative closures are utilized only in limited and appropriate circumstances.

1. The Candidate is expected to utilize administrative closures only under appropriate circumstances.
2. The Candidate is expected to use all resources to gather the information needed to complete the investigation.
3. The Candidate is expected to take adequate steps to locate the complainant a complaint may not be closed administratively because a complainant cannot be located unless and until the investigator has exhausted all logical sources to obtain the current address of the complainant.

Performance Standard #3 (24 CFR § 115.206(e)(3)): During the period beginning with the filing of a complaint and ending with filing a charge or dismissal, the Candidate to the extent feasible, attempts to conciliate complaints.

1. The Candidate is expected to attempt conciliation throughout the processing of all complaints (i.e., beginning with the filing of the complaint and ending with the filing of a reasonable cause finding or a charge).
2. The Candidate is expected to consistently and accurately explain to the parties that HUD regulations provide that a conciliation agreement shall not only be satisfactory to the parties, but shall adequately vindicate the public interest.
3. The Candidate is expected to consistently and accurately identify organizational representatives who have the authority to negotiate and execute conciliation agreements on behalf of the respondent(s).
4. The Candidate is expected to understand that a conciliator must never depart, or give the impression of departing from the rule of being a neutral person in the conciliation process.
5. The Candidate is expected to consider when negotiating public interest provisions in a conciliation agreement, the agency's mandate to affirmatively further fair housing by protecting potential aggrieved persons in the general public from injury by reason of the respondent's housing practices.

Performance Standard #4 (24 CFR § 115.206(e)(4)): The Candidate conducts compliance reviews for settlements, conciliation agreements, and orders resolving discriminatory housing practices.

1. The Candidate is expected to  consistently and accurately reviews records and reports pertaining to the investigation to verify details, monitor work activities, and evaluate performance.
2. The Candidate is expected to consistently ensure that the terms and conditions of the conciliation agreements are sufficient and that all parties remain in compliance with the agreements.
3. The Candidate is expected to consistently ensure that the terms and conditions of agency orders are sufficient to protect the public interest and that all parties remain in compliance with the orders.

Performance Standard #5 (24 CFR § 115.206(e)(5)): The Candidate must consistently and affirmatively seek and obtain appropriate relief designed to prevent recurrences of discriminatory practices.

1. The Candidate is expected to consistently and accurately evaluate final investigative reports for conformance with current statutes, ordinances, regulations and case law and recommends appropriate action.
2. The Candidate is expected to consistently provide an assessment of the types of the relief available to the agency with consideration for the inclusion of affirmative provisions designed to protect the public interest and make appropriate recommendations.
3. The Candidate is expected to consistently and appropriately assess the adequacy of the relief sought and obtained in light of the issues raised by the complaints.

Performance Standard #6 (24 CFR § 115.206(e)(6)): The Candidate is expected to consistently and affirmatively seek to eliminate all prohibited practices under fair housing laws.

• The Candidate is expected to be actively engaged in the fair housing education and outreach efforts of the agency.
• The Candidate is expected to have developed appropriate relations with key fair housing players in the jurisdiction, including but not necessarily limited to private fair housing groups, civil rights and disability rights organizations, and housing providers.