Guide to Retrofitting and Federal Interest Regulations

Written By Victoria Jones

Download a printable version of the full user guide here.

Starting up a new partnership MAY require physical changes to indoor and/or outdoor space to accommodate the needs of young children, the staff that work for them, and others who engage with the space on campus. As a reminder, Head Start requires specific, usable space (not hallways or bathrooms) of usable space per child for both indoor and outdoor space.

Estimating retrofitting and/or construction costs is complicated and can’t be summarized on one page; however, there are many things that should be considered when beginning to plan out the conversion, updating, or building of any on-campus space. Relevant staff, such as your college facilities manager and Head Start director, should be involved in reviewing this list and beginning any plans or estimates.

Areas with Potential for Construction

  • Indoor space, including:

    • Classrooms

    • Office and storage space

    • Bathrooms

    • Food preparation area

    • Tooth brushing area

    • Security

  • Outdoor space, including:

    • Fencing

    • Play structure (ideal, but not required)

    • Ground cover (eg. mulch, turf)

  • Other on-campus spaces, including:

    • Parking lots

    • Drop off and pick-up area and traffic flow

If significant construction is going to occur, federal interest regulations come into play. You’ll need to enlist the help of an expert in Head Start’s 1303 processes.

Overly simplified, when federal funding is used to purchase or renovate facilities, the government maintains certain ownership or property rights when it comes to that building. This is not ideal for space on community college campuses and is best if avoided.

The easiest ways to avoid federal interest are to: 

  • Stay below the $250,000 threshold;

  • Use other funding sources, such as state or foundation money; or

  • Have the college pay the costs initially and have Head Start pay it off over time as part of any rent payments. (While mortgage payments do create federal interest, rent payments do not.)

Finally, be sure to review the Davis–Bacon Act of 1931 and any regulations around relevant union workers when it comes to planned construction or renovations.

College Process

The process of retrofitting existing space or building new construction, if needed, can be a complicated endeavor. Each college will have different internal operation and administrative processes but there are some general guidelines that may be helpful.

Where to Start?

A project of this scope that involves a partnership with an external organization should start with senior leadership approval and buy in. How the proposal makes its way to the president can happen either from an internal department such as a program area, workforce development, or student services submission or the president can be directly engaged and spearhead the initiative. The president will inform the board of trustees at some point either to inform or gain approval depending on the scope.

Internal vs External

Depending on the scope of the project, the project could be handled by internal college facilities staff. Some factors that would go into that determination are:

  • Scope of work based on project size

  • Timeframe of the project

  • Capacity of the internal staff

  • If project requires permitting (always external)

  • New building construction (always external)

Most colleges have an “in-house” construction manager associated with the college but as the project develops, there may be a decision made to use an new external construction manager triggering a bidding process. 

Funding

If the project is going to be handled internally, the funds may be already appropriated in the facilities budget. The facilities department is given spending authority each year as part of the budgeting process. An amount is requested based on projects and incorporated into the overall budget request to the county. They can use these funds as they see fit and do not need additional approval as long as they remain under their limit. 

If the project is on the larger scale and will be above the scope of the facilities budget or is being handled externally, there is a separate funding process that occurs. Generally, funding will come from three sources, the state, county, and institution. State funds are typically only available if the project is part of the ‘master plan” of the college. If the project is eligible for state funds, the percentage can vary but is usually around 50%. The other 50% of the project is funded through a combination of county and institutional funds. The county will determine the percentage they will contribute. The college may have to undertake a fundraising campaign to meet its obligation.

Work Process

Once the project is approved to move forward, it will start with what may be called a “program development”. This is where the project manager will meet with the department area, any subject matter experts that can provide information on any requirements for the space or regulations that need to be accounted for. If it is a space that is being retrofitted, an environmental study may be required depending on what the space was used for previously. Once the needs and requirements are determined, architects can be engaged. They will create an approval process and begin the initial schematic design process. They will then review them with the stakeholders for feedback and revisions. The next step will be the creation of the design. During both the schematic and design process, changes can be made without incurring any costs. The last phase from the architect is the construction drawings. Cost estimates are created from these so any changes at this phase will have expense implications. All of these processes will go into the decision for a construction manager. As processes begin, the project is typically managed by a mixture of the college and the construction management firm.

Other Stakeholders

Some other individuals and organizations may need to be engaged depending on the scope and scale. They include:

Trustees

The board of trustees will be engaged at a minimum to inform them of the project but will be more involved if budget approvals are required. Each college has expense thresholds that trigger different levels of approval. 

County Government

The county will be engaged whenever there is permitting or inspections that are required. If the project requires a new building, then planning and zoning are involved. They will conduct what is called a site development plan where they assess things like roads and infrastructure, parking, utilities, and stormwater management. They will also conduct an environmental concept plan to assess any environmental concerns.

Public Safety

Public safety is typically engaged during the “program development” to get their input into the space and their needs.

Project Timing

Depending on the scale of the project, timing may not be a consideration. If it is a large scale and expensive project, then building it into a budget cycle or a capital campaign may be required which will have an impact on start time. If it is small enough to be handled internally, it can be worked into the facilities’ schedule. An out of cycle request can be made for certain priority projects but those will typically come from the president.



Retrofit Consideration Checklist for Community Colleges

Funding

  • Internal budget allocation

    • Obtain approvals needed

  • External capital campaign

    • Eligible for state funds

    • County government contribution

    •  Fundraising campaign

Internal stakeholders

  • Board of trustees

    • Do they need to be informed

    • Do they need to approve project costs

  • Public safety

    • Involved in “program development”

  •  Academic programs

    • Provide subject matter expertise and program requirements

    • Other workforce development opportunities

Timing

  • Internal renovations

    • Timeline developed with facilities

    • If from senior leadership can it be prioritized

    •  Align with campus schedule to minimize impact

  • External renovations

    • Follow capital improvement process

Leadership support for partnership

  • Departmental development

  • Senior leadership development

Scope of project

  • Can it be handled by internal facilities?

    • Met with facilities

    • Staff capacity determination

    • Created “program development”

    • Reviewed cost estimates

    • Create project timeline

  • External contractor

    • Does scope require permitting?

    • “In-house” construction manager vs. bidding

    • Created “program development”

    • Architect approval process

      • Schematic design

      • Design development

      • Construction drawings

External stakeholders

  • County government

    • Any permitting needs

    • Any inspection needs

    • Environmental study for existing building

    • New construction needs

      • Site develop plan

      • Environmental concept plan

Victoria Jones
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