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UNFAITHFUL: The Broken Promises of the

Interfaith HomeWorks Training Program

Photo: Interfaith website.

August 2018

302-654-2880

LEEP:
letsgetours@gmail.com
Executive Summary
Interfaith Community Housing of Delaware (ICHDE) is a non-profit organization based in
Wilmington, DE. Founded in 1968, it serves low and moderate-income families with an array of
home ownership services, including default counseling, financial education, credit management
and credit repair, and it has been an affordable housing developer.

Interfaith has also established a workforce development program, the HomeWorks Construction
Employment and Training Program (HCET), to train ex-offenders for careers in construction.
HomeWorks has been partially funded by the Delaware Department of Labor.

Unfortunately, there are many problems with how the HomeWorks program is administered. We
have found documents that show that one project in the Dunleith neighborhood was mishandled
and resulted in county violations. Furthermore, interviews over the past few months with more
than a dozen workers who enrolled in the program or worked directly with Interfaith staff have
found the following problems:

 Inadequate Classroom Training: Workers report that they received fewer days of
classroom training than they were promised, and the training was very basic, like
“watching videos.” Several said they watched YouTube videos on their own to learn more.
 Unmet Promises: Trainees were led to believe that they would obtain a high level of
construction skills. Instead they often performed low-skilled work with inadequate
training on the job sites.
 Exaggerated Value: Trainees were led to believe that they would receive a widely
recognized certificate that would enable them to find a job, but workers don’t believe it
turned out this way.
 Unpaid Work: Workers report doing many days of work for which they were unpaid. A
standard arrangement was that workers would perform five days of work in a week, but
only be paid for two or three, with the other days called “training.”
 Low Wages: When workers were paid, it was only $10/hour, which is a poverty level wage.
 Worker Misclassification: Workers report being forced to fill out 1099 forms so they
would be paid as independent contractors before being assigned to work with a
contractor.
 Inadequate Supervision: Workers report a lack of supervision on the job sites. In a number
of cases they were given instructions or brief training and then left essentially on their
own.

2 UNFAITHFUL: The Broken Promises of the Interfaith HomeWorks Training Program


 Unsafe Work: Workers report unsafe working conditions on the job site. One example is
workers were handling asbestos without proper training and safety equipment. This
debris was also just discarded in a dumpster.
 Conflict of Interest: The program works with several contractors owned by Interfaith or
associated with Interfaith staff, representing a possible conflict of interest. Additionally,
workers reported that one project involved the remodeling of the Interfaith office.
 No Connection to Apprenticeship: The workers were trained in what the Home Builders
Institute calls a “pre-apprenticeship” program, but weren’t directed afterwards toward a
registered apprenticeship program.
 No Job Placement: Workers were led to believe that they would obtain one year of
construction employment after the program, but none of the workers we interviewed
have received that amount of work after the program ended.
 Deceptive Claims to the Public: One worker reports participating in a phony insulation
demonstration for the Governor and other elected officials where he felt obligated to
exaggerate the skills he had learned. He believes this was done so that Interfaith would
continue to receive more state funding. Furthermore, Interfaith appears to be boosting
their program completion rates to make the program look better.

Broken Promises
Interfaith is running a program that is similar to a “construction readiness” or “pre-
apprenticeship” program. This kind of program is supposed to train participants to be ready for
a real construction apprenticeship program that will further enhance their skills. However,
HomeWorks has no connection to a further apprenticeship program. Moreover, Interfaith
appears to be misrepresenting their program to participants as if it was a full apprenticeship
program that taught advanced level construction skills. Several workers state how Interfaith
made exaggerated claims about how much they would learn. Furthermore, there is a real lack of
transparency in how the program is administered. Many program participants were unclear
about the details of how this program worked.

When you talk to the workers, their disappointment is clear. They were excited about a training
program that could teach them the skills and give them a credential to help them get back into
the workforce with a good paying, family supporting construction career. Instead they were
rushed through inadequate training and then brought all over town to unsafe construction
projects where they performed mostly low-skilled, insufficiently supervised work, which was

3 UNFAITHFUL: The Broken Promises of the Interfaith HomeWorks Training Program


often unpaid. Then afterwards, they were dumped into the low wage, unsafe, non-union
residential construction market.

There is a real need for quality programs to assist formerly incarcerated people back into the
workforce. Unfortunately, it appears that Interfaith misled the program trainees, using them as
cheap and often free labor for their projects around Wilmington, including work on the Interfaith
office itself. Interfaith failed to develop them into construction workers with certified and
recognized skills. Interfaith is using taxpayer funding to take advantage of workers with criminal
backgrounds who have a lack of employment options and are trying to turn their lives around.

Recommendations
 Honesty: Workers should be told what the program will deliver without
exaggerations.
 Full Classroom Training: Workers should get the full amount of classroom training
they are promised.
 Living Wages: Workers should be paid at least $15/hour for all project work.
 Full Wage Payment: Workers should be paid for every hour they work on job sites.
Workers in past classes should be made whole for all the unpaid hours they worked.
 Employee Status: Workers should be classified as employees of the contractors they
are working for, with all standard payroll deductions and workers compensation.
 Transparency: Workers and funding agencies should be provided with regular,
written information on their hours worked, payments made, deductions from their
paycheck, project locations and the contractors who employed them.
 Adequate Supervision: Workers on the job site should have a supervisor present at all
times when they are working.
 Health & Safety: Workers should have a safe work environment and receive all
necessary safety training and personal protective equipment.
 Connections to Apprenticeship: Workers should not be dumped straight into the job
market, but should be directed into an apprenticeship program where they can
further develop their skills towards a sustainable construction career.
 The Delaware Department of Labor should engage in more thorough oversight of
these programs and have better enforcement of all applicable labor laws.

4 UNFAITHFUL: The Broken Promises of the Interfaith HomeWorks Training Program


Introduction
Interfaith Community Housing of Delaware area. Interfaith works with a number of
(ICHDE) is a non-profit organization based in contractors who “provide on-site, on-the-
Wilmington, DE. Founded in 1968, it serves job training, with supervision of an HCET
low and moderate-income families with an Trainer. Successful completion results in
array of home ownership services, including industry-recognized HBI certification(s).”5
default counseling, financial education, The program is run by Danielle M. Brothers,
credit management and credit repair.1 MS, the HomeWorks Program Director, and
Interfaith has also been an affordable Tyron Clemmons, the HomeWorks
housing developer in the Wilmington area.2 Education and Training Specialist.6
Its Executive Director is Gary T. Pollio.3
Formally launched in 2016, the HomeWorks
Interfaith has established a workforce program has received funding from the
development program, the HomeWorks Delaware Department of Labor (DDOL) and
Construction Employment and Training the state’s Criminal Justice Council.7
Program (HCET). Interfaith describes Interfaith received a small, four month,
HomeWorks as a “paid, on-the- $20,000 DDOL Today’s Reinvestment
job, residential construction theory and Around Industry’s Needs (TRAIN) Planning
practice training for reentering ex-offenders Grant in 2016 which helped them develop
who originate from, reside in, or reside the HomeWorks program.8 The DDOL was
within a community in which ICHDE is interested in funding the development of
conducting affordable housing development “Strategic Workforce Training Plans that
and/or community revitalization efforts.”4 meet employers’ workforce needs, advance
the skills of Delaware workers, grow the
HomeWorks uses the Home Builders
state’s economy, and increase sustainable
Institute (HBI) curriculum and combines
employment for working families.”9
classroom training sessions with on-site
Interfaith stated in its application the
construction work in the Wilmington metro
following goals (see Figure 1):10

5 UNFAITHFUL: The Broken Promises of the Interfaith HomeWorks Training Program


Figure 1

Interfaith then received a one year, Apprenticeship Certificate Training (PACT)


$167,260 TRAIN Implementation Grant from curriculum, at 20 hours per week. The
DDOL later in the year, which ran from July participants would then receive 13 weeks of
2016 through June 2017.11 The grant on-the-job training at various construction
agreement stated that the goal was to projects “owned and site-controlled” by
“partially fund the Home Works Interfaith. During those weeks, participants
Construction Service Training Program New would still have classroom training several
Castle County.”12 The grant application also afternoons each week.
mentions that Interfaith received $10,000
from the U.S. Probation Office. A letter from The grant application lists seven
that office included with the application construction contractors who would be a
states that the funds are to pay for some of “training partner and potential employer” of
the wages of the program participants.13 workers in the HomeWorks program. These
contractors would work with two program
In its grant proposal, Interfaith proposed to participants on each construction site.
train three cohorts of 10 ex-offenders in four Participants would receive what Interfaith
month training cycles. Perhaps because it calls a “stipend” of $10/hour. Monthly
received less funding than it requested, the financial reports submitted to the DDOL
program launch announcement in state that the program budgeted $78,000 for
November 2016 stated that it would work “participant wages” and $1,500 for
with 20 participants.14 “participant fringes.”15 This $78,000 figure is
consistent with 20 participants being paid
The grant agreement states that program $10/hour for 30 hours of work for 13 weeks,
participants would receive three weeks of or $3,900 per participant.
construction classroom theory training
based on the Home Builders Institute Pre-

6 UNFAITHFUL: The Broken Promises of the Interfaith HomeWorks Training Program


The contractors listed are: The contact person listed for 3 Guys and a
Hammer is Tyrone Clemmons, Interfaith’s
 Petrucon Construction Company, Inc.
HomeWorks Education & Training Specialist
 CLA Construction, LLC
(listed on the Interfaith website as Tyron
 Integrity Construction
Clemmons). The company is registered with
 TAG Construction, LLC
the Delaware Department of State, Division
 3 Guys and a Hammer, LLC
of Corporations as 3 Guys & a Hammer LLC.
 GO 2 GUYS Remodeling, LLC
The name listed on the registration is Omari
 Santos All Phase Construction, LLC
Faust, Interfaith’s Housing Development
Manager (listed on Interfaith’s website as
All contractors signed a “Memorandum of
Omar Faust).19
Understanding” (MOU) for participation in
the HomeWorks program. Integrity At least one of the contractors, Petrucon
Construction is listed in Interfaith’s 2016 IRS Construction, has a history of health and
990 form as 100% owned by Interfaith.16 safety violations. Since 2000, the company
The company’s contact person listed in the had six OSHA inspections and was cited for
proposal is Darlene Sample, Interfaith’s six violations, including five Serious and one
Chief Financial Officer.17 Moreover, the Repeat violation. The company has been
company is registered with the Delaware fined $12,660.20 An OSHA record for an
Department of State, Division of inspection in 2010 indicated that a worker
Corporations as Integrity Construction, Inc. fell on the construction site. The company
at Interfaith’s address.18 was cited then for two Serious violations,
including for OSHA standard “Duty to have
fall protection”, and fined $5,460.21

An Interfaith Project: Problems in Dunleith


Interfaith has had a number of projects to $300,000 to Interfaith for this work (see
rehabilitate houses in the Wilmington Figure 2).24
suburb of Dunleith.22 This work is in
cooperation with New Castle County as part One of the Interfaith houses was located at
of an effort to redevelop houses along the 409 Morehouse Dr. New Castle County
Route 9 corridor.23 In fiscal year 2018, the records show that Interfaith owns this
New Castle County Department of property.25 In October 2017, we heard about
Community Services has given over neighbors at 407 Morehouse Dr.
complaining about the demolition work.

7 UNFAITHFUL: The Broken Promises of the Interfaith HomeWorks Training Program


Figure 2

Interfaith sent the neighbors a letter a few The neighbor reported that the contractor
months earlier saying demolition was illegally dumped a large pile of debris in
starting at 409. In an interview, they nearby Surratte Park. A FOIA request to New
reported that there was dust everywhere Castle County confirms that a crew removed
and that the contractor was making no dumped debris on 10/13/17.27
efforts to control it. They often were short of
breath. They reported that workers Another problem at the construction site
sometimes worked late at night and on was a large hole near the sidewalk that was
weekends. The demolition also caused not blocked off. Figure 3 shows a photo that
ceiling cracks which they had to repair.26 was taken on 11/12/17. The neighbor placed
the caution tape there. There are children in
Figure 3
the area who played near the site and this
was a hazard for them.

An email from an elected official alerted


New Castle County officials about the unsafe
conditions. FOIA records from the County
confirm that an inspection on 11/13/17
found violations that shut down the project
for about two weeks until it passed
inspection on 11/28/17.28 See Figure 4.

8 UNFAITHFUL: The Broken Promises of the Interfaith HomeWorks Training Program


Figure 4

On 11/13/17, the county placed an UNSAFE Housing of Delaware promised to make a list
sign at the site which stated “Work of home repairs for him but left work
performed poses a risk to the public. Provide uncompleted.”30
temporary safeguards to protect the public
from the work area.”29 See Figure 5. Figure 5

The sloppy way that this project was handled


appears, based on interviews with workers,
to be typical of an Interfaith project. A
recent news report describes another
project in Dunleith where Interfaith
participated in the renovation of a veteran’s
house but didn’t complete the job. The
article says, “Willis Phelps, Jr., an 80-year-old
Delaware Army National Guard veteran, said
Home Depot and Interfaith Community

Worker Interviews
We interviewed 14 workers from the In the last few months, the problems with
Wilmington area, most of whom are the HomeWorks program have been
formerly incarcerated, and either covered in press articles which substantially
participated in the Interfaith training confirm what the workers report here.31
program or worked at contracting Several workers provided testimony at a
companies associated with Interfaith staff. Delaware Senate Labor Committee hearing
The interviews were conducted in person in May, 2018.32 Overall, 10 of the workers
with video and/or on the phone over several we interviewed have agreed to have their
months in 2018. stories included in this report. Eight agreed
to be identified and the others are identified
as Worker A and Worker B.

9 UNFAITHFUL: The Broken Promises of the Interfaith HomeWorks Training Program


Chris Butler
I enrolled in Interfaith’s HomeWorks class
that started in September 2017. However, I
did not finish the program after I got into a
payment dispute with Interfaith.

I worked on the project to remodel the


Interfaith building for a few weeks, which
included working 12 hours on a holiday. They
didn’t pay me for any of those hours. Later
on, a paycheck shorted my hours and the
following week they didn’t have a paycheck
for me at all. I went to the Department of
Labor to complain. As I was filling out the Photo: Jennifer Corbett, The News Journal
paperwork, I was contacted by Interfaith. I
complaining to the DOL by kicking me out of
informed them that I was at the Department
the program. I missed out on at least four
of Labor and they said they would pay me.
more weeks of income.
They paid me for the shorted hours and the
missing paycheck soon after, but they still Months later, after talking to a reporter
owe me money for all of my work. about Interfaith, they contacted me by text
telling me that I could pick up my certificate
However, at that point they stopped
from the office even though I never
communicating with me about projects and
completed the program.
I was effectively out of the program. I believe
that Interfaith retaliated against me for

Kashif Handy33
I was working at the Rose Hill Community in September 2017 which ran to January
Center when I heard about the program. I 2018. I was promised training as part of the
was told that I would be receiving a program. At the orientation, Interfaith
carpentry apprenticeship certificate that is handed out a 16 week training schedule. We
recognized nationwide and I could take the were supposed to be in class for five days a
certificate anywhere in the nation and it week during the first two weeks. Then
would be recognized. I have children to starting in the third week, we would be in
support. I enrolled in the class that started

10 UNFAITHFUL: The Broken Promises of the Interfaith HomeWorks Training Program


filled out any employment forms. I am in a
re-entry process and I need a legitimate job
to show that I am working. My wages were
deducted if I had to leave to meet with my
probation officer on Thursdays and Fridays,
the days we were paid for working. I
complained that if I had to miss a day where
we were paid for working, I wouldn’t be
Photo: Suchat Pederson, The News Journal
paid, even though I worked earlier that week
class for three days and two days working in on other days.
the field.
There was a lack of training and supervision
Interfaith didn’t abide by this schedule. In on the job sites. I worked on a project
the first week, we went to work in the field. putting siding on a house in Jefferson Farms.
We then went back to class for a few days, We were dropped off by Interfaith’s Tyron
but then were sent back out to work on Clemmons and the contractor there showed
remodeling the Interfaith building lobby for us how to put one of the siding pieces on,
three weeks straight. We remodeled the and then we were just put to work. I was on
floor and did painting, cleaning up and the ladder with no safety precautions. He
moving things around. From week three we just put us out there, I can’t really say they
spent most of our time in the field, we rarely taught us or trained us.
went back in the classroom, I say from week
Another project at a house on Walnut St
three to 11, 12, we probably went in the
involved the removal of an oil tank in the
classroom about three, four times.
basement. A lot of oil had spilled and we had
When we started getting paid in week three, to clean it up and remove the tank. There
it was for two field days per week, six hours was no adequate ventilation and I became
each day at $10/hour, for a total of $120. light headed within 10 minutes.
During weeks three to six, we were paid for
I was involved in two demonstrations for the
only two days each week. During weeks
Governor who was visiting Interfaith
seven to 10, we were paid for three days of
projects. The first was a framing
project work, and then afterwards for five
demonstration at the Rose Hill Community
days per week. But this whole time we were
Center. The second was an insulation
working nearly every day.
demonstration at an Interfaith project at 5th
There were no payroll deductions from my and Washington streets. The Governor and
check, just a straight $10/hour of pay. I never other elected representatives were there. I

11 UNFAITHFUL: The Broken Promises of the Interfaith HomeWorks Training Program


was asked what we learned in the program. helped place me in that position, in that job,
I felt obligated to say that I was proficient in to basically use me as an Interfaith success. I
framing, siding, painting and insulation. This do not feel like an Interfaith success since I
was not true as I only really knew painting at left the program early and am not confident
the time. The insulation demonstration was in what I was supposed to learn.
just a demonstration, we didn’t lay any
What was promised to us, we were told that
insulation in there, the appearance was just
we would be so knowledgeable that we
so that the governor and his constituents
could go with a contractor and we wouldn’t
basically could give us more money, could
be supervised. I don’t believe that it turned
fund, lend more funding to Interfaith. It was
out that way.
explained to me that this was a
demonstration so that we could impress the If you’re asking me about the program, what
governor so we could get more funding for I would tell somebody, I would tell them it’s
Interfaith. not real. You’re gonna go into this program
believing that you’re gonna learn certain
I left the program early and found a new job.
things and you will not. For anybody who’s
After a few weeks, Interfaith’s Tyron
interested in the program, dealing with
Clemmons called me to find out where I was
Interfaith, basically do it at your own risk, but
working, explaining that he needed the
know that the legitimacy of the whole
information so he could get me the
program is shaky, it’s definitely not what
certificate for completion, even though I
they say it to be, it’s definitely not what it
didn’t complete the program. In my opinion
appears to be on paper.
I believe they wanted to say that Interfaith

Leonard McGinnis
I enrolled in Interfaith’s first class which work with a contractor. Therefore I wasn’t
started in May 2016. The class started with considered an employee but an independent
12 trainees and ended with four. contractor.

Interfaith promised apprenticeship I did receive 17 weeks of training, but


approval, 17 weeks of training, paid field afterwards I did not get an entire year of
training and job placement. We were work. I was assigned to a contractor, DMV,
promised a year of employment upon but they ran out of work because the house
completion of the training course. I had to was put on hold. I didn’t work for several
fill out 1099 forms in order to be assigned to months. Omar Faust then hired me at his

12 UNFAITHFUL: The Broken Promises of the Interfaith HomeWorks Training Program


company, 3 Guys and a Hammer. But the A typical day was six to eight hours of work.
work was inconsistent and only lasted for a Over the five days of work in a week, on
few weeks. Monday through Wednesday, I did not get
paid. I received $10/hour for the work for
Interfaith claimed I was receiving certified
the next two days. There were no payroll
training, but the curriculum seemed high
deductions taken out of my check.
school based to me. They reviewed ANSI and
OSHA certification, and I am familiar with it, I was often doing demolition work and only
but don’t believe this training qualifies for had a cheap paper mask. Omar Faust told me
those certifications. “If you get hurt, you lose your job.”

When I started working on projects in the I would recommend to people, don’t walk
field I would get what they called three days into Interfaith without understanding or
of field training and then two days of finding out everything about this company
working on a project. The field training because everything isn’t authentic or
involved testing my knowledge, the use of genuine. I received my program certificate
tools and building techniques. I worked on but it has not helped. I was basically trained
projects around the Wilmington area, doing for nothing, and it seems my training didn’t
demolition, framing and hanging drywall, count.
etc.

Eric Mundy34
I became interested in the Interfaith training
program because I had been working in
construction for more than five years but I
wanted to get a recognized credential to
show employers that I knew the craft. I
enrolled in Interfaith’s second class.

I understood that Interfaith’s program was a


“pre-apprenticeship” program. However, I Photo: Jennifer Corbett, The News Journal
was not connected to an apprenticeship
program when the training finished. Me and Interfaith promised that I would be a
the rest of the students were just basically “master carpenter” at the end of the training
told a lie. and “know how to build a house from the
ground up.”

13 UNFAITHFUL: The Broken Promises of the Interfaith HomeWorks Training Program


When you’re in class, you know, you’re There were problems with health and safety
watching videos and then you’re taking a and lack of training. We were using framing
test with the answers on the board. We were guns and power saws which trainees didn’t
told that everyone was going to pass the know how to use properly. Sometimes,
training. people were hurt banging their hands with
hammers. They were always short on
While on the construction site, I was paid
personal protection equipment like gloves or
$10/hour for the work while working for
masks and nobody had any hard hats.
Interfaith’s contractor Integrity
Construction. However, I was forced to sign At a project in Dunleith, we were doing
a 1099 form and there were no deductions demolition work and I believe the house had
for Social Security, Medicare or taxes taken asbestos tiles in it. Interfaith gave us dust
from my check. There were no child support masks, and a few people had Tyvek suits, but
deductions as well, which I am required to there weren’t enough for everyone. There
pay. Basically we were getting paid under was no training for asbestos removal, and
the table. Interfaith did not explain to the debris was just thrown in the dumpster.
anyone what the form was or its effect for
I was unhappy with the program and left
their employment. I was also not paid for
early. I’m supposed to be, you know, living a
every day that I worked.
good life, you know, I know a good craft that
While in the field, I was taken to what I was pays well but I’m not seeing the benefits of
told were contractor “side jobs”, meaning that. Interfaith staff contacted me to
they were not official Interfaith projects. The convince me to come back, even coming to
government paid me to do the contractors’ my house.
job.
Interfaith guaranteed the participants a year
There was often intense pressure to work of work after the program but I don’t think
fast, doing framing, spackling, drywall, and that anyone received that. I believe I was
painting. Since I had more experience than misled about how things would turn out for
other trainees, the contractor sometimes me. I’m upset because of the fact that
left me in charge of others, coming back there’s people out here that’s really leading
hours later. Instructors would come in and people on, you know, we got a lot of people
say “Do this, do that, Eric you got ‘em right? out here just trying to change their life and
Yup.” And they’d leave and then, they all be you got people whose out here just ruining
gone for hours. people’s lives, it’s ridiculous.

14 UNFAITHFUL: The Broken Promises of the Interfaith HomeWorks Training Program


Dale Reed
I enrolled in the Interfaith class but only friend walked off after a few hours of work
lasted about four or five weeks. Interfaith because the situation didn’t look good to
wanted me to sign a 1099 form. I asked them. I stayed for a few days, working five to
questions about it and they told me “If you six hours/day. My brother stayed longer and
want to work, this is what you gotta fill out.” worked there for two to three months.
I wanted my mom to look over the form.
I met other workers on the job who had been
They never called me again and I was out of
through the Interfaith training. I was paid
the program.
$50 for five hours of work in a day, with no
When I did work with the program, I worked payroll deductions.
five days a week but was only paid for two.
I was forced to use a flimsy wooden ladder
Sometimes my checks would bounce and
to get to the roof. When I protested I was
Omar Faust wouldn’t show up to pay us. I
told “if you fall, you’re fired.” At a house in
received checks from both Interfaith and 3
Dunleith, I was doing demolition of a kitchen
Guys and a Hammer. I was even paid in cash.
and noticed something that looked like
After I left the program, Omar called me a asbestos. I notified Omar who did not
few months later to see if I wanted to work. dispute this. Omar asked “Are you gonna get
Again I asked Omar a lot of questions, about the asbestos out or are you gonna go
W-2 forms and the wage level. I didn’t get home?” I only had on a paper mask. I have
the job for several weeks, I believe, because three kids to support and I wanted to keep
I was asking these questions. Eventually he the job and he knew I was in a vulnerable
told me to meet him at a project, and I position.
started working. I didn’t fill out any W-2
I only worked for Faust for two days.
forms. I was asked to bring glasses, gloves
Afterwards I was told by my brother that I
and boots, and was provided with a hard hat.
wasn’t called back because I asked too many
I started the job with three relatives and questions, as far as W-2 and safety
friends. I was asked to meet at the job site at precautions. My brother was told by Omar I
8:00am. On the first day, my cousin and a needed to learn how to keep my mouth shut.

15 UNFAITHFUL: The Broken Promises of the Interfaith HomeWorks Training Program


Stephon Stewart
I have a wife and three kids and enrolled in I worked on a house on Oak Street that I
Interfaith’s second class which started in considered unsafe. I saw the foundation
December 2016. I found out about the falling apart. I was often doing demolition
program from my cousin who was in the first work and only had a cheap paper mask.
class.
Interfaith promised me a year of
I had to fill out 1099 forms in order to be employment after the training. But only
assigned to work with a contractor. some participants got work after the
Therefore I wasn’t considered an employee program and I don’t think anyone got a full
but an independent contractor. My year. I worked for the contractor Advanced
paycheck came from Interfaith. Property Maintenance for about two
months.
I worked at various projects around
Wilmington. On the job site, I would work for Interfaith told me the program certificate
a full week but was only paid for two days. was recognized “worldwide”, but it doesn’t
The other three days were called training carry any weight. I invested over a year in
and we were not paid. And for those two the program, and I did learn some useful
days, I was expecting 16 hours of work but I skills, but I am unsatisfied. I feel that they
only got 12 hours. I estimate that I was paid just bamboozled us.
a total of about $2,000 during the whole
I would not recommend that anyone else do
training.
the program. They won’t get anything out of
it.

Ron Wallace
I did not go through the Interfaith program, I was paid $10/hour, but sometimes the
but worked for the company of Interfaith’s checks were short or I had to wait until the
Omar Faust for about six months. I had a next week to get paid. Checks also bounced,
felony and was glad to get the job. I knew and it seems that every week there was a
about the Interfaith program but was kept problem with someone’s check. I was upset
working separate from the guys in the because if I’m working why can’t they make
program. sure that my pay is there and it’s right?
There were no payroll deductions and I was
considered an independent contractor and

16 UNFAITHFUL: The Broken Promises of the Interfaith HomeWorks Training Program


not an employee. Also I still haven’t been I have been working in construction for
paid for all the work I did and I think he owes years, and the working conditions are always
me about $400. After I finished my last job, bad. You have some people out there that’s
Omar disappeared and I never saw him again going to go the cheaper route and try to use
and didn’t get paid. and abuse their workers.

There was no safety training, and the I was always paid under the table without
workers had to take care of each other. social security deductions, and I have little to
Safety was always an issue but I had good show for my years of work, regarding social
workers around me and we keep each other security. This is my life, I’ve been doing
safe. I was mostly doing demolition work but construction all my life and now I have
I had to buy my own masks and gloves. nothing in the end and that’s a hurtful
feeling.
I felt used by the company and I believe that
I was taken advantage of because of my
criminal record.

Shawn Wilson35
My name is Shawn Wilson and I reside in working in the field. However, soon after we
New Castle County. I am currently in the started, we were taken out of class and sent
hospital because of breathing problems to work.
which I believe are caused by working for
One project was working on the Interfaith
Interfaith and I cannot attend the State
building. I spent about two weeks there
Senate Labor Committee Hearing. I request
working on the floors, and painting and
that my statement be read into the record.
framing. I worked for five days each week
I was enrolled in the Interfaith HomeWorks but was not paid for all those days. I was only
program from September 2017 to January paid for two days during each of those
2018. I completed the whole program, but I weeks. We were angry about that.
have not picked up my completion
I was paid by Interfaith, and it was $10/hour.
certificate yet.
In the early weeks of the program, we would
At the beginning of the program they gave us work for five days a week but only be paid
a schedule which outlined the days we for two days of work, at six hours each day. I
would be in class and the days we would be was paid $120 for 12 hours of work.

17 UNFAITHFUL: The Broken Promises of the Interfaith HomeWorks Training Program


In later weeks, I was paid for 18 hours of started working for a contractor, but that
work over three days, even though I worked only lasted a week. I was paid $400 for about
five days a week. Toward the end of the 60 hours of work. I was paid in cash, in
program, I was paid for 30 hours of work for twenty dollar bills.
five days of work in a week. There were
I don’t know anyone who finished the
never any payroll deductions, I was just paid
program who got full time work afterwards.
with a check. I do not remember signing any
Some of them got work but it didn’t last long.
employment forms.
I finished the Interfaith program in January.
In the last two weeks of the program I did
About a month ago I started developing
demolition work at two houses in Dunleith.
health problems. I felt shortness of breath
We worked for one week at each house. I
and my back was hurting. I went to the
believe that one of the houses was at 149
hospital. They did an ultrasound which found
Bunche Blvd.
fluid in my lungs, and they drained the lungs.
I was given a Tyvek body suit to wear and a They said I had walking pneumonia. I still
mask like a doctor’s mask. During the have the symptoms now.
demolition there was a lot of dust. The mask
The nurse told me that they wrote the word
didn’t keep out the dust. When I took off the
asbestos in my hospital notes. I’m not sure if
mask my face was white underneath. We
that means they suspect I was exposed to
had to double-bag insulation material
asbestos. I didn’t see the notes. Nobody at
separately and put it aside for a special
Interfaith ever mentioned that we were
pickup. I also saw black mold during the
working on asbestos.
demolition.

In the program I never had a hard hat while


Overall, I feel that I was taken advantage of
working. I don’t think I was well trained. We
by Interfaith. I lost my apartment while
were showed how to do something once and
working with Interfaith since I didn’t get paid
then we would have to figure it out. I did
for all the work I did and I couldn’t pay my
drywall and watched YouTube videos to
rent. But I stayed because I thought it could
learn how to do it. That’s also true for other
be useful and I wanted to complete the
things I did.
program.
They promised that I would get employment
after finishing the program. After I finished, I

18 UNFAITHFUL: The Broken Promises of the Interfaith HomeWorks Training Program


Worker A

I was in the second Interfaith HomeWorks They explained there would be no pay for
class which started on November 5, 2016. I the first four weeks. Starting in week five, I
saw information about it on Facebook and was paid $120 each week for several weeks.
heard about it at the Rose Hill Community The pay rate was $10/hour with no payroll
Center. I completed the whole class. About deductions. I think we should have been paid
16 or 17 people started the class, but only more than that because we were working
five or six finished it. every day. Everybody was upset about it
because they thought they were supposed
For the first week we were in the classroom,
to be getting more. Sometimes we were
learning about tools from a handbook. We
waiting for hours after finishing work on
also watched videos about construction.
Friday for our checks.
They took me out of the classroom in the
second week even though they promised us There were weekly timesheets that had my
two weeks of class time. name on it with the total hours worked,
which I signed at the end of the week and
During the second week, we were sent to a
then got paid. But the number of hours on
house on Oak Street which was abandoned,
the sheet was less than what I worked. In
and I was there for two or three weeks. I
later weeks I was paid $180 and then $300,
never went back to the classroom. At this
always working every day. There was one
house I did framing and drywall work. There
project where Interfaith’s Mont Clemmons
was a very brief drywall training, and I had to
took us to what I believe was a music studio
watch videos on my own time to learn more.
that he was involved with. We worked there
I was also doing floor work, laying tiles. The
for a week but I don’t think this was part of
floor was loose and shaky, very unstable. We
the Interfaith program.
never completed the floor, and it was half
done when we left the house. I heard later I worked on the demolition of three houses
that the house had been condemned, and in Dunleith. I was told by Interfaith’s Omar
we never went back in. So we were working Faust that the houses had asbestos in them.
for several weeks in an unsafe condemned I believe the houses were on Bunche,
house. Also, it was winter time and very cold Robinson and Morehouse. I had to bring my
and there was no heat even though they own gloves and mask and did not get a
promised there would be heaters. protective suit. Some workers didn’t even

19 UNFAITHFUL: The Broken Promises of the Interfaith HomeWorks Training Program


have masks. At first Interfaith provided with a personal check at $10/hour. I was not
masks, but they ran out. kept on and then I left construction work.

I never had a hard hat for any of these Interfaith promised me one year of
projects. I finally got one at the graduation employment, but I didn’t get that and don’t
ceremony. I received my certificate but had know anyone who got steady work
to wait several months to get it. afterwards.

They also promised us that we would get The Interfaith staff didn’t seem to take the
transportation to and from all the projects program seriously. Overall I feel that
but there were many times when that didn’t Interfaith broke their promises of full
happen and I had to find a ride or take the employment and the amount of pay. There
bus. was not proper safety gear and I also had to
do work that was not construction-related,
After I finished the program, I was placed such as cutting grass and picking up leaves. I
with a general contractor, and worked there believe I was paid about $1,700 total for the
for three to four weeks. I remember the whole program. I would not refer anyone to
contractor criticized the Interfaith program, the program and feel that they took advantage
saying it was not well run or really of me.
recognized. I was paid by that contractor

Worker B

I enrolled in the first Interfaith HomeWorks wait because so few of the participants had
class in 2016. The class started with 15 graduated from that class.
participants and ended with four.
Interfaith promised me a year of
I was paid $10/hour for project work. I had employment at 40 hours/week after
to fill out a 1099 form and it was explained finishing the program. I had recently got a
to me that this meant I was my own new apartment and needed the steady
contractor. I believe that I was paid for all work. But that didn’t happen. I worked
my work on the projects. afterwards with a contractor, but it was not
consistent work, more like two or three
I finished the class but had to wait to get my
days/week. I left after a few weeks. I don’t
certificate. Interfaith said they needed to
know anyone who got a year of work after
the program.

20 UNFAITHFUL: The Broken Promises of the Interfaith HomeWorks Training Program


Issues and Questions
The worker interviews raise a number of important issues with how the HomeWorks program
and its associated contractors operate.

Classroom Hours

Interfaith stated in their grant that weeks of full time work in the classroom and
participants would receive 60 hours of then three days in the classroom in the
classroom training over the first three weeks following weeks. But he reported that he
and then two afternoons each week didn’t get this number of classroom days.
thereafter. Figure 6 shows what Interfaith Shawn Wilson and Worker A also report
stated in the grant about classroom hours.36 receiving fewer class days than promised. It
seems that after the classroom training
However, most of the workers that we started, many workers were rushed into the
interviewed reported that they received far field to work on projects that needed to be
fewer classroom days than what is described finished, and were only brought back to the
here. Kashif Handy described a promised classroom for a few days after that, if any.
classroom schedule that consisted of two

Figure 6

21 UNFAITHFUL: The Broken Promises of the Interfaith HomeWorks Training Program


Wages

Workers report being paid $10/hour for This statement implies that they would be
work on construction project sites. However, paid for all hours on the job site. Moreover,
they also say they were not paid for some of the proposed budget that Interfaith
the work days. It seems that some days on submitted also implies payment for all
the job site were considered “training” even hours. Figure 8 shows the line from the
though in many cases they were doing the budget regarding wages:38
same work. This is at odds with what
Interfaith proposed in the training grant However, nearly all of the workers we
application, shown in Figure 7.37 interviewed who had been through the
Interfaith program believe they were not
paid for all their work.

Figure 7

Figure 8

Interfaith’s monthly financial reports we interviewed, Leonard McGinnis, Eric


submitted to the DDOL state that $78,000 Mundy, Dale Reed, Stephon Stewart and
was allocated for “Participant Wages.” As Worker A were participants in the first or
stated above, this $78,000 figure is second training which occurred during the
consistent with 20 participants being paid time period of this grant and they reported
$10/hour for 30 hours of work for 13 weeks, not being paid every day they were in the
which is $3,900 each. Indeed, the May 2017 field. Stephon Stewart completed the
report stated that up to that point, Interfaith training and estimates that he was paid a
had paid out $75,815.05 in wages, so by the total of about $2,000 during the whole
end of the grant period in June, Interfaith period. Worker A says he was paid $1,700 for
would likely have paid out the whole the whole program. So why weren’t the
allocated $78,000.39 But five of the workers

22 UNFAITHFUL: The Broken Promises of the Interfaith HomeWorks Training Program


workers paid all their money and where did HomeWorks participants were training —
that money go? not working — when they were laboring,
unpaid, on construction sites during
It appears that Interfaith paid the workers
‘classroom’ hours, and therefore did not
nothing for what they called “training” hours
need to be paid more than the original
and a “stipend” for some of their work on
schedule indicated.” Pollio also pretends to
the job sites. As a comparison, a real
be confused about why the workers would
apprenticeship program would pay a stipend
agree to be paid for fewer days than they
for training time and wages for actual work
worked on a job site. “I can only go by what
on the job site. That Interfaith sometimes
evidence I have,” Pollio said. “I can tell you
uses both the words stipend and wages
that if I was on a training site for five days
makes this more complicated.
and I was asked to complete this time sheet
In a confusing video interview accompanying and I didn’t receive the stipend for five days,
a news article about problems with the I would have said something. Because time
HomeWorks program, Interfaith Executive is money.”
Director Gary Pollio made some interesting
comments.40 In defending the program, he Thus Interfaith’s position appears to be that
stated that the payments were made they could simply define what the workers
according to timesheets signed by the were doing on their projects as “training”,
participants. “We only transmit the stipend and pay a “stipend” according to the
for the number of hours that the trainee has schedule set by Interfaith. And the workers,
already agreed to, they confirmed that they who are in a relatively disempowered
actually participated.” Pollio went on to position in their relationship with Interfaith,
simply define all the work as “training”, even signed off on the timesheets which
if it was the same work for which they were misrepresented the actual hours worked.
sometimes paid. Pollio also insisted that Indeed, Worker A stated that the number of
they would never hire trainees for real hours on his timesheet was less than what
construction work on their projects, which he worked. Interfaith now points to those
contradicts what the workers report. timesheets as evidence of the number of
hours worked.
In the article, Pollio was quoted defining all
the activities as training: “Pollio claimed

23 UNFAITHFUL: The Broken Promises of the Interfaith HomeWorks Training Program


Worker Misclassification

Many workers reported that they had to fill part because it was cheaper. ‘It fit within the
out a 1099 form and be classified as scope of the project that we proposed to the
“independent contractors” before they were Department of Labor and fit within the
assigned to work with any contractors. This confines of the costs that were available to
is a potential “misclassification” which has run the program at the level we proposed,’
serious consequences for workers who will he said. ‘Otherwise they would all have to
be unprotected by workers compensation or become Interfaith employees and we just
unemployment insurance. It impacts the couldn’t do that.’ ”42
public because payroll taxes are not
collected from the paycheck. For the However, the Delaware Workplace Fraud
HomeWorks program, this practice may be a Act states: “An ‘employer-employee’
violation of labor law, as there is a strict test relationship shall be presumed to exist when
that determines when a worker should be work is performed by an individual for
classified as an independent contractor.41 remuneration paid by an employer, unless to
Eric Mundy reported that Interfaith did not the satisfaction of the Department the
explain to anyone what the form was or its employer demonstrates that the individual is
ramifications for their employment. Dale an exempt person or independent
Reed reported that he was told “If you want contractor.”43 The following box shows the
to work, this is what you gotta fill out.” Act’s definition of exempt person and
independent contractor. Overall, this does
Interfaith has defended this practice. “Pollio not appear to describe the workers in the
said Interfaith chose the 1099 designation in HomeWorks program.

24 UNFAITHFUL: The Broken Promises of the Interfaith HomeWorks Training Program


Delaware Workplace Fraud Act

The Act defines Exempt Person as an individual who:

a. Performs services in a personal capacity and who employs no individuals other than
a spouse, child, or immediate family member of the individual;
b. Performs services free from direction and control over the means and manner of
providing the services, subject only to the right of the person or entity for whom
services are provided to specify the desired result;
c. Furnishes the tools and equipment necessary to provide the services; and
d. Operates a business that is considered inseparable from the individual for purposes
of taxes, profits, and liabilities, in which the individual:
1. Owns all of the assets and profits of the business; and
2. Has sole, unlimited, personal liability for all of the debts and liabilities of the
business; or alternatively, if the business is organized as a single-person
corporate entity, to which sole, unlimited personal liability does not apply,
the individual must be the sole member of said single-person corporate
entity; and
3. For which the individual does not pay taxes for the business separately but
reports business income on the individual's personal income tax return; and

e. Exercises complete control over the management and operations of the business.

Furthermore, the Act defines an Independent Contractor as an individual who:


a. Performs the work free from the employer's control and direction over the
performance of the employee's services; and
b. Is customarily engaged in an independently established trade, occupation, profession
or business; and
c. Performs work which is outside of the usual course of business of the employer for
whom the work is performed.

25 UNFAITHFUL: The Broken Promises of the Interfaith HomeWorks Training Program


Health & Safety

Construction can be dangerous work and it’s too. Worker A reports that Omar Faust told
important for workers to have a job site him that the houses they were working on had
environment that is as safe as possible, asbestos in them and that he had to bring his
which includes proper safety training and own gloves and mask and did not get a
equipment. protective suit. Dale Reed reports that he
asked about asbestos on one project and
Interfaith’s MOU with contractors states Faust asked him “Are you gonna get the
that Interfaith will provide “necessary work asbestos out or are you gonna go home?”
‘gear’ to all trainees, including appropriate Shawn Wilson believes he may have been
boots, hard hats, gloves, etc.”44 exposed to asbestos. On one project, he had
on a body suit but only a paper mask. And
Eric Mundy reports that they were always paper masks aren’t good enough for this kind
running out of gloves and masks, and that of work. This of course is in addition to the
nobody had a hard hat. Shawn Wilson and fact that none of these workers were trained
Worker A said they never had a hard hat to handle asbestos.
while working. Furthermore, a number of
workers report that they were working Furthermore, several workers make it clear
around asbestos without proper equipment. that Interfaith had a cavalier attitude toward
Mundy thinks there was asbestos on one of safety. Leonard McGinnis reported that
his projects and other workers had on body Interfaith’s Omar Faust told him “If you get
hurt, you lose your job.” Dale Reed also
suits but there wasn’t one for him, he just
worked for Faust and reported, “I was told if
had a mask. The fact that others had body
you fall, you’re fired.”
suits indicate that he should have had one

Connection to Apprenticeship Programs

Interfaith is using the Home Builders application stated they should work with just
Institute’s Pre-Apprenticeship Certificate such a program:45
Training (PACT) curriculum. However, a pre-
Moreover, the PACT curriculum information
apprenticeship is designed with the
that was included in the grant application
intention that the trainee will be directed to
states: “As its name suggests, PACT training
an apprenticeship program afterwards.
lays the foundation for participation in an
Figure 9 shows that Interfaith’s grant
apprenticeship. An apprenticeship is a
training program that is formally recognized

26 UNFAITHFUL: The Broken Promises of the Interfaith HomeWorks Training Program


and administered based on standards or However, none of the workers we
rules approved by the U.S. Department of interviewed who went through the
Labor’s (DOL) Office of Apprenticeship or by HomeWorks program said that they were
a State Apprenticeship Council.”46 directed to or connected with an
apprenticeship program. Instead they were
expected to just find a job.

Figure 9

Program Completion and Employment

The HomeWorks program grant application left the program early and found a new job
stated the following goals for program and was later contacted by Interfaith’s Tyron
completion, “Proposed Outcomes to be Clemmons to find out where Handy was
Achieved (i.e. 75% of participants will obtain working so that he could get the certificate
a recognized credential/certificate or 80% of for completion, even though he didn’t
participants will obtain unsubsidized complete the program. Similarly Chris Butler
employment after completion of training was essentially kicked out of the program
program.”47 after complaining to the Department of
Labor but was then contacted months later
Now of course, despite best efforts things by Interfaith and told that he could pick up
can go wrong in the real world and proposed his certificate.
objectives may not be achieved. But several
workers report information that suggests The job placement outcomes are
Interfaith may be boosting its numbers to questionable as well. Stephon Stewart, Eric
make the program seem more successful Mundy, Shawn Wilson, Worker A and
than it is. According to Eric Mundy, Worker B report that they don’t think
Interfaith said they were told that everyone anyone got a full year of employment after
was going to pass the training. Kashif Handy the program.

27 UNFAITHFUL: The Broken Promises of the Interfaith HomeWorks Training Program


References

1
Interfaith website: http://www.ichde.org/about-us/
2
Interfaith website: http://www.ichde.org/affordable-housing/
3
Interfaith website: http://www.ichde.org/about-us/meet-our-staff/
4
Interfaith website: http://www.ichde.org/workforce-development/. It appears that Interfaith has taken this page
down. It can be found here from July 9, 2018,
https://web.archive.org/web/20180709223100/http://www.ichde.org/workforce-development/
5
Ibid.
6
Interfaith website: http://www.ichde.org/about-us/meet-our-staff/
7
“Interfaith Launches New Workforce Development Program,” 11/5/16,
http://delawareway.blogspot.com/2016/11/interfaith-community-housing-of.html
8
Agreement between DDOL and Interfaith, Contract 3-104-TRAINPL, February 2016. Received through a FOIA
request in January 2017.
9
From the DDOL TRAIN grant Request for Proposals, included in the Contract 3-104-TRAINPL FOIA response.
10
Agreement between DDOL and Interfaith, Contract 3-104-TRAINPL, February 2016. Received through a FOIA
request in January 2017.
11
Professional Services Agreement between DDOL and Interfaith, Contract 3-104-TRAINIM, July 2016. Received
through a FOIA request in January 2017.
12
Ibid.
13
Ibid.
14
“Interfaith Launches New Workforce Development Program,” 11/5/16,
http://delawareway.blogspot.com/2016/11/interfaith-community-housing-of.html
15
Interfaith’s Monthly Financial Report for 3-104-TRAINIM grant, May 2017.
16
Interfaith, IRS Form 990, Schedule R, Part IV, 2016,
http://990s.foundationcenter.org/990_pdf_archive/510/510298556/510298556_201706_990.pdf
17
Interfaith website: http://www.ichde.org/about-us/meet-our-staff/
18
Delaware Secretary of State, file number: 4987597,
https://icis.corp.delaware.gov/Ecorp/EntitySearch/NameSearch.aspx
19
Delaware Secretary of State, file number: 5519395,
https://icis.corp.delaware.gov/Ecorp/EntitySearch/NameSearch.aspx
20
U.S. Occupational Safety and Health Administration (OSHA) records for Petrucon Construction.
21
Petrucon Construction OSHA record,
https://www.osha.gov/pls/imis/establishment.inspection_detail?id=311810626
22
U.S. Department of Housing and Urban Development, “Homeownership Opportunities in Dunleith,”
https://archives.hud.gov/local/de/goodstories/2015-07-02b.cfm
23
Delaware Business Now, “New Castle County takes aim at vacant properties,” 5/17/17,
http://delawarebusinessnow.com/2017/05/new-castle-county-takes-aim-vacant-properties/
24
New Castle County, Department of Community Services, FY18 CDBG, ESG, HOME Allocations,
http://www.nccde.org/DocumentCenter/Home/View/18303
25
New Castle County, Parcel # 1000530254, http://www3.nccde.org/parcel/Details/Default.aspx?ParcelKey=83238
26
Interview with residents of 407 Morehouse Drive, Dunleith, DE, 10/27/17 and phone interview on 4/20/18.
27
New Castle County, Work Order 195265, General Park Maintenance, received through FOIA request, 11/17/17.
28
New Castle County, Cases and Violations, Case 201709680, Parcel 1000530254, received through FOIA request,
12/21/17.
29
New Castle County, Case Inspection Detail, Inspection 1868021, Parcel 1000530254, received through FOIA
request, 2/15/17.
30
The News Journal, “Veteran says volunteers botched, abandoned home renovation,” 5/21/18,
https://www.delawareonline.com/story/news/local/2018/05/21/veteran-home-makeover-botched-
abandoned/615941002/

28 UNFAITHFUL: The Broken Promises of the Interfaith HomeWorks Training Program


31
The News Journal, “Delaware-funded construction training program exploits ex-offenders, participants say,”
4/27/18, https://www.delawareonline.com/story/news/local/2018/04/26/delaware-construction-training-
nonprofit-exploits-ex-offenders-free-labor/404457002/
32
The News Journal, “At state Senate hearing, job training program called a 'travesty',” 5/7/18,
https://www.delawareonline.com/story/news/2018/05/07/labor-committee-stated-funded-homeworks-program-
travesty/586745002/
33
Kashif Handy, statement submitted to the Delaware Senate Labor Committee hearing, 5/7/18.
34
Eric Mundy, statement submitted to the Delaware Senate Labor Committee hearing, 5/7/18.
35
Shawn Wilson, statement submitted to the Delaware Senate Labor Committee hearing, 5/7/18.
36
Professional Services Agreement between DDOL and Interfaith, Contract 3-104-TRAINIM, July 2016. Received
through a FOIA request in January 2017.
37
Ibid.
38
Ibid.
39
Interfaith’s Monthly Financial Report for 3-104-TRAINIM grant, May 2017.
40
The News Journal, “Delaware-funded construction training program exploits ex-offenders, participants say,”
4/27/18, https://www.delawareonline.com/story/news/local/2018/04/26/delaware-construction-training-
nonprofit-exploits-ex-offenders-free-labor/404457002/
41
National Employment Law Project, “Independent Contractor vs. Employee: Why independent contractor
misclassification matters and what we can do to stop it,” 5/9/16, http://www.nelp.org/publication/independent-
contractor-vs-employee/
42
The News Journal, “Delaware-funded construction training program exploits ex-offenders, participants say,”
4/27/18, https://www.delawareonline.com/story/news/local/2018/04/26/delaware-construction-training-
nonprofit-exploits-ex-offenders-free-labor/404457002/
43
Delaware Workplace Fraud Act, § 3503, http://delcode.delaware.gov/title19/c035/index.shtml
44
Memorandum of Understanding with contractors, included in the Professional Services Agreement between
DDOL and Interfaith, Contract 3-104-TRAINIM, July 2016. Received through a FOIA request in January 2017.
45
Professional Services Agreement between DDOL and Interfaith, Contract 3-104-TRAINIM, July 2016. Received
through a FOIA request in January 2017.
46
PACT Instructor Guide, included in the Professional Services Agreement between DDOL and Interfaith, Contract
3-104-TRAINIM, July 2016. Received through a FOIA request in January 2017.
47
Professional Services Agreement between DDOL and Interfaith, Contract 3-104-TRAINIM, July 2016. Received
through a FOIA request in January 2017.

29 UNFAITHFUL: The Broken Promises of the Interfaith HomeWorks Training Program