TO: Chair and Housing Authority Commissioners
THROUGH: Keith Stahley, Executive Director
FROM: Nicole Utz, Administrator
SUBJECT:
title
Revised Section 8 Housing Choice Voucher Program Administrative Plan
Ward(s): All Wards
Commissioners(s): Commissioners
Neighborhood(s): All Neighborhoods
Result Area(s): Welcome and Livable Neighborhood
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SUMMARY:
summary
Revisions to the Section 8 Administrative Plan. The proposed revisions would be effective October 1, 2024.
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ISSUE:
Shall the Commission adopt Resolution No. 2313 approving the Revised Section 8 Housing Choice Voucher Program Administrative Plan, effective October 1, 2024?
RECOMMENDATION:
recommendation
Adopt Resolution No. 2313 approving the Revised Section 8 Housing Choice Voucher Program Administrative Plan, effective October 1, 2024.
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FACTS AND FINDINGS:
This update to the Section 8 Housing Choice Voucher (HCV) Program implements changes to several HCV elements of oversight and administration in compliance with Housing Opportunities Through Modernization Act (HOTMA), including the following:
1. Chapter 2: additional information regarding complaints relating to Equal Access Final Rule and the Violence Against Women act (VAWA).
2. Chapter 3: denial of admission due to:
a. VAWA coverage now to include human trafficking.
b. Added denial of admission due to failure to sign consent forms and assets exceeding allowable limits.
3. Chapter 5: Updated briefing options to include in-person individual and group briefings, as well as a remote option.
4. Chapter 6:
a. New section regarding anticipated annual income under the Housing Opportunity Through Modernization Act of 2016 (HOTMA).
b. Student Financial Assistance section that indicates what is included and excluded from income.
c. Updated guidelines and requirements for the treatment of assets, determining net asset value, and calculating imputed asset income, per HOTMA.
d. Clarification that monthly opt-out savings deposits will not be counted as income (however, the account will be included as an asset in the determination of net assets for the family).
e. Definition of necessary and non-necessary property for the determination of net asset value, per HOTMA.
f. Phase-in of increase of medical deduction threshold from 3% to 10%.
5. Chapter 7:
a. Implementation of HUD’s Enterprise Income Verification (EIV) and Self-Certification as a valid method of income verification when other methods are not available.
b. Adjustment to verification hierarchy, per HOTMA requirements.
c. Guidelines for self-certification.
d. The addition of PHA policy to allow verification of SSN via other government databases.
6. Chapter 8:
a. Implements NSPIRE (National Standards for the Physical Inspection of Real Estate) standards, replacing HQS (Housing Quality Standards).
b. Establishes updated life-threatening fail items that must be corrected within 24 hours.
c. Updates SHA policy relating to extensions of inspection due dates to allow for a 120-day extension in documented cases of unavailability of contractors or supplies/parts to complete needed repairs.
7. Chapter 11:
a. Establishes updated steps to determining annual income in accordance with HOTMA requirements, including exhibits providing multiple examples of the updated methods for calculating income.
b. Establishes new guidelines for effective dates of interim changes, in accordance with Notice PIH 2023-27, which sets the effective date for a decrease in tenant rent (where the change was reported timely) as “effective on the first of the month after the date of the actual change leading to the interim reexaminations of family income. This means the decrease will be applied retroactively.”
c. Establishes non-interim reexamination transactions, as required under PIH Notice 2023-27.
8. Chapter 14: Identifies a threshold for de minimis errors and outlines how the PHA will credit or repay families for whom assistance was found to be underpaid.
9. Chapter 15:
a. States that the Home Ownership option is offered only if required as a reasonable accommodation.
b. Informs families of the option to rent shared housing, in keeping with HUD best practices.
10. Chapter 17:
a. Added Voyagers Village to list of Project-Based Voucher (PBV) developments.
b. Clarified that PBV Vacancy Loss Calculation is based on 2 months of contract rent (not 60 days).
11. Chapter 18: (new chapter)
a. Outlines PHA requirements and policies relating to FUP (Family Unification Program), FYI (Foster to Youth Independence), Mainstream, NED (Non-Elderly Disabled), and other voucher types.
b. Added language for FYI Vouchers.
This revision includes no other changes or updates.
BACKGROUND:
The Section 8 Housing Choice Voucher Program Administrative Plan establishes by policy the criteria under which families are eligible to receive a Housing Choice Voucher. The plan outlines SHA’s written policies where there is discretion in the regulations to operate the Housing Choice Voucher Program. The plan includes policies relating to waitlist management, issuance and denial of Vouchers, special purpose Vouchers, occupancy, recruitment of property owners, subsidy and payment standards, grievance and hearing processes, recertifications, housing inspections, application of the Fair Market Rents, and others. The Administrative Plan is required by federal regulation to be adopted by the Board and used to guide the operations of the Housing Choice Voucher program.
Nicole Utz
Administrator
Attachments:
1. Resolution No. 2313
2. Draft - Section 8 Housing Choice Voucher Administrative Plan, effective October 1, 2024.