1. FY 2024-2025 Annual PHA Plan — Anaheim City Council, April 2, 2024

Streamlined Annual
PHA Plan
(HCV Only PHAs)
U.S. Department of Housing and Urban Development
Office of Public and Indian Housing
OMB No. 2577-0226
Expires 03/31/2024

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Purpose. The 5-Year and Annual PHA Plans provide a ready source for interested parties to locate basic PHA policies, rules, and requirements concerning the PHA’s operations, programs, and services, including changes to these policies, and informs HUD, families served by the PHA, and members of the public of the PHA’s mission, goals and objectives for serving the needs of low- income, very low- income, and extremely low- income families

Applicability. The Form HUD-50075-HCV is to be completed annually by HCV-Only PHAs. PHAs that meet the definition of a Standard PHA, Troubled PHA, High Performer PHA, Small PHA, or Qualified PHA do not need to submit this form. Where applicable, separate Annual PHA Plan forms are available for each of these types of PHAs.

Definitions.

(1) High-Performer PHA – A PHA that owns or manages more than 550 combined public housing units and housing choice vouchers, and was designated as a high performer on both the most recent Public Housing Assessment System (PHAS) and Section Eight Management Assessment Program (SEMAP) assessments if administering both programs, or PHAS if only administering public housing. (2) Small PHA - A PHA that is not designated as PHAS or SEMAP troubled, that owns or manages less than 250 public housing units and any number of vouchers where the total combined units exceed 550.
(3) Housing Choice Voucher (HCV) Only PHA - A PHA that administers more than 550 HCVs, was not designated as troubled in its most recent SEMAP assessment and does not own or manage public housing.
(4) Standard PHA - A PHA that owns or manages 250 or more public housing units and any number of vouchers where the total combined units exceed 550, and that was designated as a standard performer in the most recent PHAS and SEMAP assessments. (5) Troubled PHA - A PHA that achieves an overall PHAS or SEMAP score of less than 60 percent. (6) Qualified PHA - A PHA with 550 or fewer public housing dwelling units and/or housing choice vouchers combined and is not PHAS or SEMAP troubled.

PHA Information.

A.1

PHA Name: __ Anaheim Housing Authority______________________________ PHA Code: __ CA104__________ PHA Plan for Fiscal Year Beginning: (MM/YYYY): 07/2024______________ PHA Inventory (Based on Annual Contributions Contract (ACC) units at time of FY beginning, above) Number of Housing Choice Vouchers (HCVs) ___6,835____________________________ PHA Plan Submission Type: Annual Submission Revised Annual Submission

Availability of Information. In addition to the items listed in this form, PHAs must have the elements listed below readily available to the public.

A PHA must identify the specific location(s) where the proposed PHA Plan, PHA Plan Elements, and all information relevant to the public hearing and proposed PHA Plan are available for inspection by the public. Additionally, the PHA must provide information on how the public may reasonably obtain additional information of the PHA policies contained in the standard Annual Plan but excluded from their streamlined submissions. At a minimum, PHAs must post PHA Plans, including updates, at the main office or central office of the PHA. PHAs are strongly encouraged to post complete PHA Plans on their official website.

This PHA Plan and all relevant documentation is available at the Anaheim Housing Authority:
• Office: located at Anaheim City Hall – West Tower, 201 S. Anaheim Blvd., 10th Floor Anaheim, CA 92805 – Available Monday-Friday, between the hours of 8:00 a.m. and 5:00 p.m.; and • Website: www.anaheim.net/1947/Public-Documents

PHA Consortia: (Check box if submitting a joint Plan and complete table below) Participating PHAs PHA Code Program(s) in the Consortia Program(s) not in the Consortia No. of Units in Each Program
Lead HA:

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Plan Elements.

B.1

Revision of Existing PHA Plan Elements.

a) Have the following PHA Plan elements been revised by the PHA since its last Annual Plan submission?

Y N
Statement of Housing Needs and Strategy for Addressing Housing Needs.

Deconcentration and Other Policies that Govern Eligibility, Selection, and Admissions.

Financial Resources.

Rent Determination.

Operation and Management.

Informal Review and Hearing Procedures.

Homeownership Programs.

Self Sufficiency Programs and Treatment of Income Changes Resulting from Welfare Program Requirements.

Substantial Deviation.

Significant Amendment/Modification.

(b) If the PHA answered yes for any element, describe the revisions for each element(s):

Please see the following attachments:

Attachment 1 – Summary of Revisions to the Administrative Plan and Significant Amendment/Modification Attachment 2 – Deconcentration and Other Policies that Govern Eligibility, Selection, & Admissions Policies Attachment 3 – Financial Resources Table
Attachment 4 – Rent Determination Policies
Attachment 5 – Operation and Management

B.2

New Activities. – Not Applicable

B.3

Progress Report.

Provide a description of the PHA’s progress in meeting its Mission and Goals described in its 5-Year PHA Plan.

Please see Attachment 6 – Progress Report

B.4

Capital Improvements. – Not Applicable

B.5

Most Recent Fiscal Year Audit.

(a) Were there any findings in the most recent FY Audit?

Y N N/A
The AHA did not have any findings in the FY 21-22 audit. FY 22-23 results pending.

(b) If yes, please describe:

C. Other Document and/or Certification Requirements.

C.1

Resident Advisory Board (RAB) Comments.

(a) Did the RAB(s) have comments to the PHA Plan?

Y N

Please see below

(b) If yes, comments must be submitted by the PHA as an attachment to the PHA Plan. PHAs must also include a narrative describing their analysis of the RAB recommendations and the decisions made on these recommendations.

Attachment 7 of this Plan contains the RAB member comments.

C.2

Certification by State or Local Officials.

Form HUD 50077-SL
, Certification by State or Local Officials of PHA Plans Consistency with the Consolidated Plan, must be submitted by the PHA as an electronic attachment to the PHA Plan.

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C.3

Civil Rights Certification/ Certification Listing Policies and Programs that the PHA has Revised since Submission of its Last Annual Plan.

Form HUD-50077-ST-HCV-HP, PHA Certifications of Compliance with PHA Plan, Civil Rights, and Related Laws and Regulations Including PHA Plan Elements that Have Changed, must be submitted by the PHA as an electronic attachment to the PHA Plan.

C.4
Challenged Elements. If any element of the PHA Plan is challenged, a PHA must include such information as an attachment with a description of any challenges to Plan elements, the source of the challenge, and the PHA’s response to the public. (a) Did the public challenge any elements of the Plan?

Y N

If yes, include Challenged Elements.

This Plan was available for public comment from Thursday, January 25, 2024, through March 10, 2024.

As stated in Attachment 8, no elements of the proposed PHA Plan were challenged or opposed as of March 10, 2024.

The AHA received one public comment that inquired about how existing program participants can add their children to their household if custody is split among two parents. In response, AHA staff explained the process and provided the pertinent policies. The public comment and the response have been included in Attachment 9.

Affirmatively Furthering Fair Housing (AFFH).

D.1

Affirmatively Furthering Fair Housing (AFFH).

Provide a statement of the PHA’s strategies and actions to achieve fair housing goals outlined in an accepted Assessment of Fair Housing (AFH) consistent with 24 CFR § 5.154(d)(5). Use the chart provided below. (PHAs should add as many goals as necessary to overcome fair housing issues and contributing factors.) Until such time as the PHA is required to submit an AFH, the PHA is not obligated to complete this chart. The PHA will fulfill, nevertheless, the requirements at 24 CFR § 903.7(o) enacted prior to August 17, 2015. See Instructions for further detail on completing this item.

On August 6th, 2020, a consortium of more than 20 Orange County, CA cities released the Orange County’s Analysis of Impediments to Fair Housing Choice (AI). The AI is a thorough examination of structural barriers to fair housing choice and access to opportunity for members of historically marginalized groups protected from discrimination by the federal Fair Housing Act (FHA). The AI also outlines fair housing priorities and goals to overcome fair housing issues and lays out meaningful strategies that can be implemented to achieve progress towards the County’s obligation to affirmatively furthering fair housing.

The complete AI may be accessed through the following website:
http://www.anaheim.net/DocumentCenter/View/39608/Regional-AI_Final

Fair Housing Goal: 1. Increase the supply of affordable housing through the following strategies:

Describe fair housing strategies and actions to achieve the goal

The AHA’s housing strategies and actions include:
a. Exploring creative land use and zoning policies that facilitate the development of affordable housing, examples include a housing overlay zone or religious institutions amendment. b. Reviewing Anaheim’s current Density Bonus and Accessory Dwelling Unit (ADU) Ordinances to ensure compliance with state requirements.
c. Supporting legislation that removes CEQA requirements for affordable housing. d. Identifying and exploring allocating city-owned sites that may be well suited for housing for which there are no other development plans.
e. Continuing to support tenant-based rental assistance programs that facilitate additional affordable housing for homeless and low-income individuals

Fair Housing Goal: 2. Preserve the existing stock of affordable rental housing and rent stabilized housing through the following strategies:

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Describe fair housing strategies and actions to achieve the goal

The AHA’s housing strategies and actions include:
a. Strengthening and expand education and outreach of tenants and owner of affordable rental housing at risk of conversion to market rents.
b. Extending affordability restrictions through loan extensions, workouts, and buy-downs of affordability. c. Preserv ing at-risk housing through the issuance of Tax-Exempt Bond financing. d. Exploring the development of a rental rehabilitation loan program.

Fair Housing Goal: 3. Expand the access to fair housing services and other housing services through the following strategies:

Describe fair housing strategies and actions to achieve the goal

The AHA’s housing strategies and actions include:
a. Dedicating eligible entitlement dollars (CDBG, HOME, etc.) and explore local, state and federal resources to expand fair housing services.
b. Continuing to support fair housing testing and investigation to look for evidence of differential treatment and disparate impact, including providing services to low income tenants reporting fair housing violations. c. Continuing to support fair housing presentations, mass media communications, and multi-lingual literature distribution; conducting fair housing presentations at accessible locations and conducting fair housing presentations for housing providers.
d. Exploring alternative formats for fair housing education workshops such as pre-taped videos and/ or recordings. Such formats could serve persons with one or more than one job, families with you children and other who find it difficult to attend meetings in person.

In addition,
• The City has allocated CDBG funds to the Fair Housing Foundation (FHF) to provide fair housing services to Anaheim residents and operators of rental properties. These services include holding tenant and landlord workshops, counseling, and resolving any housing issues and allegations of discrimination . • In June 2018, the City's Planning and Building Department amended its fee schedule and removed the reasonable accommodations application fee
• In June 2018, the City's Planning and Building Department amended its fee schedule and removed the reasonable accommodations application fee

Fair Housing Goal: 4. Continue efforts to build complete communities through the following strategies:

Describe fair housing strategies and actions to achieve the goal

The AHA’s housing strategies and actions include:
a. Maximizing and securing funding from the State of California’s Cap and Trade Program (Greenhouse Gas Reduction Fund) to improve housing opportunities, increase economic investments, and address environmental factors in disadvantaged communities.
b. C ontinuing to work with local transit agencies and other appropriate agencies to facilitate safe and efficient routes of transportation, including public transit, walking, and biking. c. Exploring policy development to encourage developers to provide residents with incentives to use non-auto means of transportation, including locating new developments near public transportation and providing benefits such as bus passes.
d. Prioritiz ing workforce development resources in racially or ethnically concentrated areas of poverty to improve economic mobility

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Instructions for Preparation of Form HUD-50075-HCV
Annual PHA Plan for HCV-Only PHAs
___________________________________________________________________________

A. PHA Information. All PHAs must complete this section. (24 CFR §903.4)

A.1 Include the full PHA Name, PHA Code, PHA Type, PHA Fiscal Year Beginning (MM/YYYY), Number of Housing Choice Vouchers (HCVs), PHA Plan Submission Type, and the Availability of Information, specific location(s) of all information relevant to the public hearing and proposed PHA Plan.

PHA Consortia: Check box if submitting a Joint PHA Plan and complete the table. (24 CFR §943.128(a))

B. Plan Elements. All PHAs must complete this section. (24 CFR §903.11(c)(3) )

B.1 Revision of Existing PHA Plan Elements. PHAs must:

Identify specifically which plan elements listed below that have been revised by the PHA. To specify which elements have been revised, mark the “yes” box. If an element has not been revised, mark “no."

Statement of Housing Needs and Strategy for Addressing Housing Needs. Provide a statement addressing the housing needs of low-income, very low-income and extremely low-income families and a brief description of the PHA’s strategy for addressing the housing needs of families who reside in the jurisdiction served by the PHA and other families who are on the Section 8 tenant-based assistance waiting lists. The statement must identify the housing needs of (i) families with incomes below 30 percent of area median income (extremely low-income); (ii) elderly families (iii) households with individuals with disabilities, and households of various races and ethnic groups residing in the jurisdiction or on the public housing and Section 8 tenant- based assistance waiting lists. The statement of housing needs shall be based on information provided by the applicable Consolidated Plan, information provided by HUD, and generally available data. The identification of housing needs must address issues of affordability, supply, quality, accessibility, size of units, and location. Once the PHA has submitted an Assessment of Fair Housing (AFH), which includes an assessment of disproportionate housing needs in accordance with 24 CFR 5.154(d)(2)(iv), information on households with individuals with disabilities and households of various races and ethnic groups residing in the jurisdiction or on the waiting lists no longer needs to be included in the Statement of Housing Needs and Strategy for Addressing Housing Needs. (24 CFR § 903.7(a)).

The identification of housing needs must address issues of affordability, supply, quality, accessibility, size of units, and location. (24 CFR §903.7(a)(2)(i)) Provide a description of the ways in which the PHA intends, to the maximum extent practicable, to address those housing needs in the upcoming year and the PHA’s reasons for choosing its strategy. (24 CFR §903.7(a)(2)(ii))

Deconcentration and Other Policies that Govern Eligibility, Selection, and Admissions. A statement of the PHA’s policies that govern resident or tenant eligibility, selection and admission including admission preferences for HCV. (24 CFR §903.7(b))

Financial Resources. A statement of financial resources, including a listing by general categories, of the PHA’s anticipated resources, such as PHA HCV funding and other anticipated Federal resources available to the PHA, as well as tenant rents and other income available to support tenant-based assistance. The statement also should include the non-Federal sources of funds supporting each Federal program, and state the planned use for the resources. (24 CFR §903.7(c))

Rent Determination. A statement of the policies of the PHA governing rental contributions of families receiving tenant-based assistance, discretionary minimum tenant rents, and payment standard policies. (24 CFR §903.7(d))

Operation and Management. A statement that includes a description of PHA management organization, and a listing of the programs administered by the PHA. (24 CFR §903.7(e)).

Informal Review and Hearing Procedures. A description of the informal hearing and review procedures that the PHA makes available to its applicants. (24 CFR §903.7(f))

Homeownership Programs. A statement describing any homeownership programs (including project number and unit count) administered by the agency under section 8y of the 1937 Act, or for which the PHA has applied or will apply for approval. (24 CFR §903.7(k))

Self Sufficiency Programs and Treatment of Income Changes Resulting from Welfare Program Requirements. A description of any PHA programs relating to services and amenities coordinated, promoted, or provided by the PHA for assisted families, including those resulting from the PHA’s partnership with other entities, for the enhancement of the economic and social self-sufficiency of assisted families, including programs provided or offered as a result of the PHA’s partnerships with other entities, and activities subject to Section 3 of the Housing and Community Development Act of 1968 (24 CFR Part 135) and under requirements for the Family Self-Sufficiency Program and others. Include the program’s size (including required and actual size of the FSS program) and means of allocating assistance to households. (24 CFR §903.7(l)(i)) Describe how the PHA will comply with the requirements of section 12(c) and (d) of the 1937 Act that relate to treatment of income changes resulting from welfare program requirements. (24 CFR §903.7(l)(iii)).

Substantial Deviation. PHA must provide its criteria for determining a “substantial deviation” to its 5-Year Plan. (24 CFR §903.7(r)(2)(i))

Significant Amendment/Modification. PHA must provide its criteria for determining a “Significant Amendment or Modification” to its 5-Year and Annual Plan.

If any boxes are marked “yes”, describe the revision(s) to those element(s) in the space provided.

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B.2 New Activities. This section refers to new capital activities which is not applicable for HCV-Only PHAs.

B.3 Progress Report. For all Annual Plans following submission of the first Annual Plan, a PHA must include a brief statement of the PHA’s progress in meeting the mission and goals described in the 5-Year PHA Plan. (24 CFR §903.11(c)(3), 24 CFR §903.7(r)(1))

B.4 Capital Improvements. This section refers to PHAs that receive funding from the Capital Fund Program (CFP) which is not applicable for HCV-Only PHAs

B.5 Most Recent Fiscal Year Audit. If the results of the most recent fiscal year audit for the PHA included any findings, mark “yes” and describe those findings in the space provided. (24 CFR §903.7(p)
)

C. Other Document and/or Certification Requirements.

C.1 Resident Advisory Board (RAB) comments. If the RAB had comments on the annual plan, mark “yes,” submit the comments as an attachment to the Plan and describe the analysis of the comments and the PHA’s decision made on these recommendations. (24 CFR §903.13(c), 24 CFR §903.19 )

C.2 Certification by State of Local Officials. Form HUD-50077-SL, Certification by State or Local Officials of PHA Plans Consistency with the Consolidated Plan, must be submitted by the PHA as an electronic attachment to the PHA Plan. (24 CFR §903.15). Note: A PHA may request to change its fiscal year to better coordinate its planning with planning done under the Consolidated Plan process by State or local officials as applicable.

C.3 Civil Rights Certification/ Certification Listing Policies and Programs that the PHA has Revised since Submission of its Last Annual Plan. Provide a certification that the following plan elements have been revised, provided to the RAB for comment before implementation, approved by the PHA board, and made available for review and inspection by the public. This requirement is satisfied by completing and submitting form HUD-50077 ST-HCV-HP, PHA Certifications of Compliance with PHA Plan, Civil Rights, and Related Laws and Regulations Including PHA Plan Elements that Have Changed.

Form HUD-50077-ST-HCV-HP, PHA Certifications of Compliance with PHA Plan, Civil Rights, and Related Laws and Regulations Including PHA Plan Elements that Have Changed must be submitted by the PHA as an electronic attachment to the PHA Plan. This includes all certifications relating to Civil Rights and related regulations. A PHA will be considered in compliance with the certification requirement to affirmatively further fair housing if the PHA fulfills the requirements of §§ 903.7(o)(1) and 903.15(d) and: (i) examines its programs or proposed programs; (ii) identifies any fair housing issues and contributing factors within those programs, in accordance with 24 CFR 5.154; or 24 CFR 5.160(a)(3) as applicable (iii) specifies actions and strategies designed to address contributing factors, related fair housing issues, and goals in the applicable Assessment of Fair Housing consistent with 24 CFR 5.154 in a reasonable manner in view of the resources available; (iv) works with jurisdictions to implement any of the jurisdiction's initiatives to affirmatively further fair housing that require the PHA's involvement; (v) operates programs in a manner consistent with any applicable consolidated plan under 24 CFR part 91, and with any order or agreement, to comply with the authorities specified in paragraph (o)(1) of this section; (vi) complies with any contribution or consultation requirement with respect to any applicable AFH, in accordance with 24 CFR 5.150 through 5.180; (vii) maintains records reflecting these analyses, actions, and the results of these actions; and (viii) takes steps acceptable to HUD to remedy known fair housing or civil rights violations. impediments to fair housing choice within those programs; addresses those impediments in a reasonable fashion in view of the resources available; works with the local jurisdiction to implement any of the jurisdiction’s initiatives to affirmatively further fair housing; and assures that the annual plan is consistent with any applicable Consolidated Plan for its jurisdiction. (24 CFR §903.7(o)).

C.4 Challenged Elements. If any element of the Annual PHA Plan or 5-Year PHA Plan is challenged, a PHA must include such information as an attachment to the Annual PHA Plan or 5-Year PHA Plan with a description of any challenges to Plan elements, the source of the challenge, and the PHA’s response to the public.

D. Affirmatively Furthering Fair Housing (AFFH).

D.1 Affirmatively Furthering Fair Housing. The PHA will use the answer blocks in item D.1 to provide a statement of its strategies and actions to implement each fair housing goal outlined in its accepted Assessment of Fair Housing (AFH) consistent with 24 CFR § 5.154(d)(5) that states, in relevant part: “To implement goals and priorities in an AFH, strategies and actions shall be included in program participants' … PHA Plans (including any plans incorporated therein) …. Strategies and actions must affirmatively further fair housing ….” Use the chart provided to specify each fair housing goal from the PHA’s AFH for which the PHA is the responsible program participant – whether the AFH was prepared solely by the PHA, jointly with one or more other PHAs, or in collaboration with a state or local jurisdiction – and specify the fair housing strategies and actions to be implemented by the PHA during the period covered by this PHA Plan. If there are more than three fair housing goals, add answer blocks as necessary.

Until such time as the PHA is required to submit an AFH, the PHA will not have to complete section D., nevertheless, the PHA will address its obligation to affirmatively further fair housing in part by fulfilling the requirements at 24 CFR 903.7(o)(3) enacted prior to August 17, 2015, which means that it examines its own programs or proposed programs; identifies any impediments to fair housing choice within those programs; addresses those impediments in a reasonable fashion in view of the resources available; works with local jurisdictions to implement any of the jurisdiction’s initiatives to affirmatively further fair housing that require the PHA’s involvement; and maintain records reflecting these analyses and actions. Furthermore, under Section 5A(d)(15) of the U.S. Housing Act of 1937, as amended, a PHA must submit a civil rights certification with its Annual PHA Plan, which is described at 24 CFR 903.7(o)(1) except for qualified PHAs who submit the Form HUD-50077-CR as a standalone document.

This information collection is authorized by Section 511 of the Quality Housing and Work Responsibility Act, which added a new section 5A to the U.S. Housing Act of 1937, as amended, which introduced the Annual PHA Plan. The Annual PHA Plan provides a ready source for interested parties to locate basic PHA policies, rules, and requirements concerning the PHA’s operations, programs, and services, and informs HUD, families served by the PHA, and member s of the public for serving the needs of low- income, very low- income, and extremely low- income families.

Public reporting burden for this information collection is estimated to average 6.02 hour per response, including the time for reviewing instructions, searching existing data sources, gathering and maintaining the data needed, and completing and reviewing the collection of information. HUD may not collect this information, and respondents are not required to complete this form, unless it displays a currently valid OMB Control Number.

Privacy Act Notice. The United States Department of Housing and Urban Development is authorized to solicit the information requested in this form by virtue of Title 12, U.S. Code, Section 1701 et seq., and regulations promulgated thereunder at Title 12, Code of Federal Regu lations. Responses to the collection of information are required to obtain a benefit or to retain a benefit. The information requested does not lend itself to confidentiality ATTACHMENT 1 Page 1 of 50
B.1 Revision of the PHA Plan Elements

Summary of Revisions to the FY 2024-2025 Section 8 Housing Choice Voucher Administrative Plan

The Anaheim Housing Authority (AHA) is required to maintain an Administrative Plan (Plan) that details the policies and procedures governing how its Section 8 Housing Choice Voucher (HCV) program will be administered. Since the last revisions that went into effect in 2022, some sections of the Plan are currently being updated with new or modified policies.

This attachment reflects the revisions made to the Administrative Plan regarding the Section 8 HCV, Project-Based Voucher (PBV), and special purpose voucher programs. Summaries of the changes being made are listed below. For your reference, the revisions are listed under the “PROPOSED PHA ADMIN PLAN LANGUAGE” column.

Significant Amendment/Modification
In the FY 2020-24 Five Year PHA Plan, the AHA defined a significant amendment or modification to the PHA Plan as a change in program policy, including changes to rent, admissions policies, and organization of the waiting list or terminations. Exceptions to this definition will be made for changes that are adopted to reflect changes in U.S. Department of Housing and Urban Development (HUD) regulatory requirements or if such changes are adopted in response to a significant reduction in funding.

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B.1 Revision of the PHA Plan Elements

CHAPTER 2: FAIR HOUSING AND EQUAL OPPORTUNITY
Chapter Section: 2.I.C. DISCRIMINATION COMPLAINTS
Subsection (if any): n/a
Description of Change:

Current Section 2.I.B. of the AHA Administrative Plan addresses how the agency addresses complaints. These policies are designed to formalize AHA's approach, providing structured steps for addressing and resolving complaints. The proposed revision introduces new policies aimed at structuring AHA’s approach to addressing discrimination complaints, complaints under the Equal Access Final Rule, and VAWA-related complaints against AHA. These policies outline the specific steps that AHA will take to address and resolve complaints, ensuring a transparent and efficient process for all involved.

PROPOSED PHA ADMIN PLAN LANGUAGE:

2.I.C. DISCRIMINATION COMPLAINTS

General Housing Discrimination Complaints
If an applicant or participant believes that any family member has been discriminated against by the PHA or an owner, the family should advise the PHA. HUD requires tThe PHA should to make every reasonable attempt to determine whether the applicant’s or participant’s assertions have merit and take any warranted corrective action.

In I
n all cases addition, the PHA will advise the family that they may file a fair housing complaint if the family feels they have been discriminated against under the Fair Housing Actis required to provide the applicant or participant with information about how to file a discrimination complaint [24 CFR 982.304].

PHA Policy

PREVIOUS PHA ADMIN PLAN LANGUAGE:

Discrimination Complaints
If an applicant or participant believes that any family member has been discriminated against by the PHA or an owner, the family should advise the PHA. HUD requires the PHA to make every reasonable attempt to determine whether the applicant’s or participant’s assertions have merit and take any warranted corrective action.

In addition, the PHA is required to provide the applicant or participant with information about how to file a discrimination complaint [24 CFR 982.304].

PHA Policy
Applicants or participants who believe that they have been subject to unlawful discrimination may notify the PHA either orally or in writing.

The PHA will attempt to remedy discrimination complaints made against the PHA.

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B.1 Revision of the PHA Plan Elements

Applicants or participants who believe that they have been subject to unlawful discrimination may notify the PHA either orally or in writing.

If a discrimination complaint is made against a participating owner or landlord, the PHA will refer the family to the City of Anaheim’s Fair Housing partner to receive education, outreach, training, and counseling pertaining to housing discrimination within 10 business days of receiving the complaint.

If a discrimination complaint is made against the PHA, the PHA will investigate and The PHA will attempt to remedy discrimination complaints made against the PHA within 10 business days of receiving the complaint.

The PHA will advise the family of their right to file a fair housing complaint with HUD, provide a copy of a
discrimination complaint form to the complainant, and
provide them with information on how to complete and
submit the form to HUD’s Office of Fair Housing and Equal Opportunity (FHEO).

The fair housing poster, posted in conspicuous and accessible locations in PHA lobbies, will reference how to file a
complaint with FHEO.

The PHA will keep a record of all complaints, investigations, notices, and corrective actions consistent with its current record-keeping obligations [Notice PIH 2014-20] (See
Chapter 16).

The PHA will provide a copy of a discrimination complaint form to the complainant and provide them with information on how to complete and submit the form to HUD’s Office of Fair Housing and Equal Opportunity (FHEO).

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B.1 Revision of the PHA Plan Elements

Complaints under the Equal Access Final Rule [Notice PIH 2014- 20]
On February 3, 2012, HUD published a final rule entitled Equal Access to Housing in HUD Programs Regardless of Sexual
Orientation or Gender Identity (“Equal Access Final Rule”) [77 FR 5662]. The Equal Access Final Rule requires that PHAs provide equal access regardless of marital status, gender identity, or sexual orientation.

Upon receipt of a complaint from an applicant or participant alleging a violation of the Equal Access Final Rule, the PHA must determine if a program violation occurred and implement appropriate corrective action(s). The PHA may seek assistance from its local HUD Field Office of Public Housing in order to make this determination. In addition, the PHA must follow its written policies for responding to complaints. Notice PIH 2014-20 requires an articulated complaint process for allegations of discrimination under the Equal Access Final rule.

The PHA will be informed of these obligations by the HUD Field Office or FHEO when an Equal Access complaint investigation begins.

PHA Policy
Applicants or tenant families who believe that they have been subject to unlawful discrimination based on marital status, gender identity, or sexual orientation under the Equal Access Rule may notify the PHA either orally or in writing.

If a discrimination complaint is made against the PHA, the PHA will provide a written notice to those alleged to have violated the rule within 10 business days of receiving the complaint.

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B.1 Revision of the PHA Plan Elements

The PHA will also send a written notice to the complainant informing them that notice was sent to those alleged to have violated the rule, advise them of their right to file a housing discrimination complaint with HUD, provide a copy of a
housing discrimination complaint form, and provide them with information on how to complete and submit the form to HUD’s Office of Fair Housing and Equal Opportunity
(FHEO) within 10 business days of receiving the complaint.

The PHA will attempt to remedy discrimination complaints made against the PHA and will conduct an investigation into all allegations of discrimination.

Within 10 business days following the conclusion of the PHA’s investigation, the PHA will provide the complainant and those alleged to have violated the rule with findings and either a proposed corrective action plan or an explanation of why corrective action is not warranted.

The PHA will keep a record of all complaints, investigations, notices, and corrective actions consistent with its current record-keeping obligations [Notice PIH 2014-20] (See
Chapter 16).

VAWA Complaint Processing [Notice FHEO 2023-01]
A complainant may, not later than one year after an alleged VAWA violation has occurred or terminated, file a complaint with FHEO alleging such violation. If there is a violation that began prior to a year before the complaint is filed, but it continues into the one-year time period, HUD will accept the complaint. FHEO will investigate the complaint if it is timely and FHEO otherwise has jurisdiction. If a complaint is filed more than one year after the alleged violation occurred or terminated, FHEO may, but is not required to, investigate ATTACHMENT 1 Page 6 of 50
B.1 Revision of the PHA Plan Elements

the allegations under the additional authority and procedures described in FHEO 2023-01.

Complaints do not need to allege a violation of the Fair Housing Act for FHEO to accept and investigate the complaint.

PHA Policy
Applicants or tenant families who wish to file a VAWA
complaint against the PHA may notify the PHA either orally or in writing.

The PHA will advise the family of their right to file a VAWA complaint with HUD, provide the family a copy of a HUD’s complaint form, and provide the family with information on how to complete and submit the form to HUD’s Office of
Fair Housing and Equal Opportunity (FHEO). The PHA will inform the family that not later than one year after an alleged VAWA violation has occurred or terminated, applicants and tenants who believe they have been injured by a VAWA
violation or will be injured by such a violation that is about to occur may file a VAWA complaint using the HUD’s
complaint form.

The PHA will attempt to remedy complaints made against the PHA and will conduct an investigation into all allegations of discrimination.

The PHA will keep a record of all complaints, investigations, notices, and corrective actions consistent with its current record-keeping obligations [Notice PIH 2014-20] (See
Chapter 16).

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CHAPTER 2: FAIR HOUSING AND EQUAL OPPORTUNITY
Chapter Section: 2-II.E. APPROVAL OR DENIAL OF A REQUESTED ACCOMMODATION [JOINT STATEMENT OF THE DEPARTMENTS OF HUD AND JUSTICE: REASONABLE ACCOMMODATIONS UNDER THE FAIR HOUSING ACT, NOTICE 2010-26]
Subsection (if any): n/a
Description of Change:

This revision formalizes AHA's procedure for handling requests to review denials of reasonable accommodations. These policies specify that the Section 504 Coordinator will handle reviews and outline specific steps for addressing appeals, including considerations, and establishing due dates for related actions.

PROPOSED PHA ADMIN PLAN LANGUAGE:

Before making a determination whether to approve the request, the PHA may enter into discussion and negotiation with the family, request more information from the family, or may require the family to sign a consent form so that the PHA may verify the need for the requested accommodation.

PHA Policy
After a request for an accommodation is presented, the PHA will respond, in writing, within 15 business days.

If the PHA denies a request for an accommodation because it is not reasonable (it would impose an undue financial and administrative burden or fundamentally alter the nature of the PHA’s operations), the PHA will discuss with the family whether an alternative accommodation could effectively
address the family’s disability-related needs without a fundamental alteration to the HCV program and without
imposing an undue financial and administrative burden.

If the PHA believes that the family has failed to identify a

PREVIOUS PHA ADMIN PLAN LANGUAGE:

PHA Policy
After a request for an accommodation is presented, the PHA will respond, in writing, within 15 business days.

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reasonable alternative accommodation after interactive
discussion and negotiation, the PHA will notify the family, in writing, of its determination within 15 business days from the date of the most recent discussion or communication with the family.

If the PHA denies a request because there is no relationship, or nexus, found between the disability and the requested accommodation, the PHA will notify the family in writing of its determination within 15 business days.

If the PHA denies a reasonable accommodation request, the notice to the family will contain a brief statement of the reasons for the decision. If the family does not agree with the decision, the family may request a review from the Section 504 Coordinator. Although the PHA will encourage the
family to make its request in writing, the PHA will also accept a request made orally. A request for a review must be submitted to the PHA by the close of the business day, no later than 10 business days from the date of the PHA’s notice that the reasonable accommodation is denied. If sent by mail, it must be postmarked by the same date. The family’s request for a review must include the family’s objection to the decision and all documentation supporting the objection. If the request does not include supporting documentation, the Section 504 Coordinator may choose to uphold the original decision without further review.

The review must be conducted by a Section 504 Coordinator who did not make or approve the decision under review, or a subordinate of this person.

The Section 504 Coordinator conducting the review will
make a recommendation to the PHA, but the PHA is
If the PHA believes that the family has failed to identify a reasonable alternative accommodation after interactive
discussion and negotiation, the PHA will notify the family, in writing, of its determination within 15 business days from the date of the most recent discussion or communication with the family.

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responsible for making the final decision as to whether the decision is upheld or overturned.

In rendering a decision, the Section 504 Coordinator will evaluate the following matters:

Whether the request was made by or on behalf of a
person with a disability;
Whether there is a disability-related need for the
accommodation;
Whether the requested accommodation is reasonable,
meaning it would not impose an undue financial and
administrative burden on the PHA, or fundamentally
alter the nature of the PHA’s HCV operations;
The nature and cost of the requested accommodation;
Whether or not the grounds for denial were stated
factually in the notice;
The validity of grounds for denial of the reasonable
accommodation request; and
If the facts prove the grounds for denial.

The Section 504 Coordinator may request additional and
applicable documentation to render a final decision. If the family does not submit the requested documentation by the established due date, the Section 504 Coordinator may choose to uphold the original decision.

The PHA will notify the family of the final decision,
including a statement explaining the reason(s) for the
decision. The notice will be mailed within 15 business days of the review.

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The PHA will grant only one review for each decision to deny a reasonable accommodation request. If the decision to deny the reasonable accommodation is overturned as a result of the review, the PHA will approve the reasonable
accommodation request. If the decision is upheld, the PHA will not address the decision again unless the family presents new and compelling evidence in their favor or submits a new reasonable accommodation request.

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CHAPTER 3: ELIGIBILITY
Chapter Section: 3-I.C. FAMILY BREAK-UP AND REMAINING MEMBER OF TENANT FAMILY Subsection (if any): Family Break-up
Description of Change:

When a family on the waiting list separates into two otherwise eligible families, only one may retain the original application date. The current Administrative Plan considers various factors for determining which family retains the placement, and this revision adds a significant consideration. AHA will consider the interests of any family member who is a victim of domestic violence, dating violence, sexual assault, stalking, or human trafficking, including those forced to leave an assisted unit due to such abuse.

PROPOSED PHA ADMIN PLAN LANGUAGE:

PHA Policy
When a family on the waiting list breaks up into two otherwise eligible families, only one of the new families may retain the original application date. […]
[…]
In the absence of a judicial decision, or an agreement among the original family members, the PHA will determine which family retains their placement on the waiting list, or will continue to receive assistance. In making its determination, the PHA will take taking into consideration the following factors: (1) the interest of any minor children, including custody arrangements, ; (2) the interest of any ill, elderly, or disabled family members, (3) the interest of any family member who is the victim of domestic violence, dating violence, sexual assault, stalking, or human trafficking, including a family member who was forced to leave an assisted unit as a result of such actual or threatened abuse; (4) any possible risks to family members as a result of domestic violence or criminal activity, and (45) the recommendations of social service professionals.

PREVIOUS PHA ADMIN PLAN LANGUAGE:

PHA Policy
When a family on the waiting list breaks up into two otherwise eligible families, only one of the new families may retain the original application date. […]
[…]
In the absence of a judicial decision, or an agreement among the original family members, the PHA will determine which family retains their placement on the waiting list, or will continue to receive assistance. taking into consideration the following factors: (1) the interest of any minor children, including custody arrangements, (2) the interest of any ill, elderly, or disabled family members, (3) any possible risks to family members as a result of domestic violence or criminal activity, and (4) the recommendations of social service professionals.

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CHAPTER 3: ELIGIBILITY
Chapter Section: 3.III.C. OTHER PERMITTED REASONS FOR DENIAL OF ASSISTANCE PROGRAMS Subsections (if any): Criminal Activity; Previous Behavior in Assisted Housing Description of Change:

Section 3.III.C. of the AHA Administrative Plan discusses conditions under which the AHA may deny assistance from a rental assistance program. HUD permits, but does not require, the AHA to deny assistance if the AHA determines that any household member is currently engaged in, or has engaged in during a reasonable time before the family would receive assistance, certain types of criminal activity. The recommended policy change is intended to make the AHA’s programs most accessible by removing daunting barriers that individuals with a criminal history consistently face in obtaining and maintaining housing. The PHA’s recommendations take into consideration HUD recommendations and guidance.

PROPOSED PHA ADMIN PLAN LANGUAGE:

Criminal Activity [24 CFR 982.553]
[…]
PHA Policy
If any household member has been convicted of any criminal sexual conduct against one or more identified victims, and is currently subject to a registration requirement under a state sex offender registration program, the family will be denied assistance.

If any household member is currently engaged in, or has been convicted of drug-related criminal activity, defined as the illegal manufacture, sale, or distribution of a drug, or the possession of a drug with intent to manufacture, sell, or distribute the drug that resulted in a felony conviction within the past 24 months, or a misdemeanor conviction within the past 12 months, within the past 36 months, the family will be denied assistance.

PREVIOUS PHA ADMIN PLAN LANGUAGE:

If any household member is currently engaged in, or has been convicted of drug-related criminal activity, defined as the illegal manufacture, sale, or distribution of a drug, or the possession of a drug with intent to manufacture, sell, or distribute the drug, within the past 36 months, the family will be denied assistance. If any household member is currently engaged in, or has been convicted of drug-related criminal ATTACHMENT 1 Page 13 of 50
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If any household member is currently engaged in, or has been convicted of drug-related criminal activities for personal use only, within the past 12 months, the family will be denied assistance.

For convictions for drug-related criminal activity for personal use only, within the past 12 months, the PHA will consider whether the culpable household member is participating in or has successfully completed a supervised drug or alcohol rehabilitation program or has otherwise been rehabilitated successfully. The PHA will require the applicant to submit evidence of the household member’s current participation in or successful completion of a supervised drug or alcohol rehabilitation program, or evidence of otherwise having been rehabilitated successfully.

If any household member has been convicted of violent
criminal activity that resulted in a felony conviction within the past 24 monthswithin the past five years or a,
misdemeanor conviction within the past 12 months the family will be denied assistance.. Violent criminal activity, defined by HUD as any criminal activity that has as one of its
elements the use, attempted use, or threatened use of physical force substantial enough to cause, or be reasonably likely to cause, serious bodily injury or property damage [24 CFR

5.100].

If any household member is currently engaged in, or has e
ngaged in any of the following criminal activities, within the past 12 months, the family will be denied assistance.:

Criminal activity that may threaten the health, safety, or right to peaceful enjoyment of the premises by
activities for personal use only, within the past 12 months, the family will be denied assistance.

If any household member has been convicted of violent
criminal activity within the past five years, the family will be denied assistance. Violent criminal activity, defined by HUD as any criminal activity that has as one of its elements the use, attempted use, or threatened use of physical force substantial enough to cause, or be reasonably likely to cause, serious bodily injury or property damage [24 CFR 5.100].

If any household member is currently engaged in, or has engaged in any of the following criminal activities, within the past 12 months, the family will be denied assistance.

Criminal activity that may threaten the health, safety, or right to peaceful enjoyment of the premises by
other residents or persons residing in the immediate
vicinity; or
Criminal activity that may threaten the health or
safety of property owners and management staff, and
persons performing contract administration functions
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other residents or persons residing in the immediate
vicinity; or
Criminal activity that may threaten the health or
safety of property owners and management staff, and
persons performing contract administration functions
or other responsibilities on behalf of the PHA
(including a PHA employee or a PHA contractor,
subcontractor, or agent).

Immediate vicinity means within a three-block radius
of the premises.

Evidence of such criminal activity includes, but is not limited to:

Any conviction for drug-related or violent criminal
activity within the past three years.

Records of arrests for drug-related or violent criminal activity within the past three years, although a record or records of arrest will not be used as the sole basis for the denial or proof that the applicant engaged in
disqualifying criminal activity
In making its decision to deny assistance, the PHA will consider the factors discussed in Section 3-III. F and 3- III.GE. Upon consideration of such factors, the PHA may, on a case-by-case basis, decide not to deny assistance.

Previous Behavior in Assisted Housing [24 CFR 982.552(c)] HUD authorizes the PHA to deny assistance based on the family’s previous behavior in assisted housing.
or other responsibilities on behalf of the PHA
(including a PHA employee or a PHA contractor,
subcontractor, or agent).

Immediate vicinity means within a three-block radius
of the premises.

In making its decision to deny assistance, the PHA will consider the factors discussed in Section 3-III.E. Upon consideration of such factors, the PHA may, on a case-by- case basis, decide not to deny assistance.

Previous Behavior in Assisted Housing [24 CFR 982.552(c)] HUD authorizes the PHA to deny assistance based on the family’s previous behavior in assisted housing:

PHA Policy
The PHA will not deny assistance to an otherwise eligible family because the family previously failed to meet its obligations under the Family Self-Sufficiency (FSS) program.

The PHA will deny assistance to an applicant family if:

Any family member has been evicted from federally-
assisted housing in the last five years.

Any PHA has terminated assistance under the
program for any adult member of the family within
the last five years.

Any family member has committed fraud, bribery, or
any other corrupt or criminal act in connection with
any federal housing program.

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PHAs are not permitted to deny assistance to a family because the family previously failed to meet its obligations under the Family Self-Sufficiency (FSS) program [24 CFR 984.101(d)].:

PHA Policy
The PHA will not deny assistance to an otherwise eligible family because the family previously failed to meet its obligations under the Family Self-Sufficiency (FSS) program.

The PHA will deny assistance to an applicant family if:

Any family member has been evicted from federally-
assisted housing in the last five years24 months.

Any PHA has terminated assistance under the
program for any adult member of the family within
the last five years24 months.

Any family member has committed fraud, bribery, or
any other corrupt or criminal act in connection with
any federal housing program.

The family owes rent or other amounts to any PHA in
connection with the HCV or other public housing
assistance under the 1937 Act, Certificate, Moderate
Rehabilitation or public housing programs, unless the
family repays the full amount of the debt prior to
being selected from the waiting list.

If the family has not reimbursed any PHA for amounts
the PHA paid to an owner under a HAP contract for
rent, damages to the unit, or other amounts owed by
the family under the lease, unless the family repays
the full amount of the debt prior to being selected
from the waiting list.

The family owes rent or other amounts to any PHA in
connection with the HCV, Certificate, Moderate
Rehabilitation or public housing programs, unless the
family repays the full amount of the debt prior to
being selected from the waiting list.

The family has breached the terms of a
repayment agreement entered into with the
PHA, unless the family repays the full amount
of the debt covered in the repayment
agreement prior to being selected from the
waiting list.

A family member has engaged in or threatened violent
or abusive behavior toward PHA personnel.

Abusive or violent behavior towards PHA
personnel includes verbal as well as physical
abuse or violence. Use of racial epithets, or
other language, written or oral, that is
customarily used to intimidate may be
considered abusive or violent behavior.

Threatening refers to oral or written threats or
physical gestures that communicate intent to
abuse or commit violence.

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The family has breached the terms of a repayment
agreement entered into with the PHA, unless the
family repays the full amount of the debt covered in
the repayment agreement prior to being selected from
the waiting list.

When denying admission due to family debts
as shown in HUD’s EIV system, the PHA will
provide the family with a copy of the EIV
Debt Owed to PHA and Termination report.

If the family wishes to dispute the information
in the report, the family must contact the PHA
that entered the information in EIV in writing,
explaining why EIV information is disputed.

The family must also provide a copy of the
letter and all applicable verification to the
PHA to support the family’s claim. The PHA
will consider the information provided by the
family prior to issuing a notice of denial
A family member has engaged in or threatened violent
or abusive behavior toward PHA personnel.

Threatening refers to oral or written threats or
physical gestures that communicate intent to
abuse or commit violence.

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In making its decision to deny assistance, the PHA will consider the factors discussed in Section 3-III.EF and 3- III.G.. Upon consideration of such factors, the PHA may, on a case-by-case basis, decide not to deny assistance.

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CHAPTER 5: BRIEFINGS AND VOUCHER ISSUANCE
Chapter Section: 5-I.B. BRIEFING
Subsection (if any): Several listed below
Description of Change:

This policy revision addresses the increasing prevalence of remote environments. This update establishes clear policies for conducting remote briefings and adopts best practices outlined in HUD Notice PIH 2020-32 to assess and address potential barriers to remote briefings.

The revision outlines the PHA's approach to ensuring accessibility for all participants and specifies situations in which an in-person briefing may be scheduled.

PROPOSED PHA ADMIN PLAN LANGUAGE:

Notification of Briefing
Prior to issuance of a voucher, the PHA must give the family an oral briefing and provide the family with a briefing packet containing written information about the program. Families may be briefed in individual face-to-face meetings, through group briefing sessions, or via remote briefing sessions.

Notification and Attendance
PHA Policy
Families will be notified of their eligibility for assistance at the time they are invited to attend a briefing. The notice will identify who is required to attend the briefing, as well as the date and time of the scheduled briefing. The notice may be sent by first-class mail or by email if the family has provided a valid email address to the PHA.

The notice will advise the family of the type of briefing, who is required to be present at the briefing, and the date and time

PREVIOUS PHA ADMIN PLAN LANGUAGE:

If the notice is returned by the post office, the family will be removed from the waiting list. A notice of denial (see Chapter 3) will not be sent to the family’s address of record as the address on record is will no longer be considered valid.

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of the briefing. The notice will also inform the family of any additional requirements for in-person or remote briefings as addressed in relevant policy elsewhere in this section.

If the notice is returned by the post office, the family will be removed from the waiting list. A notice of denial (see Chapter 3) will not be sent to the family’s address of record, as the address on record is will no longer be considered valid.

In-Person Briefings
At the briefing, the PHA must ensure effective communication in accordance with Section 504 requirements (Section 504 of the Rehabilitation Act of 1973) and ensure that the briefing site is accessible to individuals with disabilities. For a more thorough discussion of accessibility requirements, refer to Chapter 2.

Remote Briefings [Notice PIH 2020-32]
Remote briefings may be conducted over the phone, via video conferencing, or through other virtual platforms.

PHA Policy
The PHA has the sole discretion to require that briefings be conducted remotely. If the PHA schedules a remote briefing, the PHA will conduct a face-to-face briefing upon request of the applicant as a reasonable accommodation for a person with a disability if safety and health concerns can be
reasonably addressed.

In addition, the PHA will conduct a briefing remotely upon request of the applicant as a reasonable accommodation for a person with a disability, if an applicant does not have child care or transportation that would enable them to attend the ATTACHMENT 1 Page 20 of 50
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briefing, or if the applicant believes an in-person briefing would create an undue health risk. The PHA will consider other reasonable requests for a remote briefing on a case-by- case basis.

Accessibility Requirements for Persons with Disabilities and LEP Individuals
As with in-person briefings, the platform for conducting remote briefings must be accessible, and the briefing must be conducted in accordance with Section 504 and accessibility requirements. This includes ensuring any information, websites, emails, digital notifications, and other virtual platforms are accessible for persons with vision, hearing, and other disabilities. Further, providing effective communication in a digital context may require the use of individualized auxiliary aids or services, such as audio description, captioning, sign language and other types of interpreters, keyboard accessibility, accessible documents, screen reader support, and transcripts. Auxiliary aids or services must be provided in accessible formats, in a timely manner, and in such a way as to protect the privacy and independence of the individual.

If no method of conducting a remote briefing is available that appropriately accommodates an individual’s disability, the PHA may not hold against the individual their inability to participate in the remote briefing, and the PHA should consider whether postponing the remote briefing to a later date is appropriate or whether there is a suitable alternative.

Due to the individualized nature of disability, the appropriate auxiliary aid or service necessary, or reasonable accommodation, will depend on the specific circumstances.

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Limited English Proficiency (LEP) requirements also apply to remote briefings, including the use of interpretation services and document translation. See Chapter 2 for a more thorough discussion of accessibility and LEP requirements, all of which apply in the context of remote briefings.

Conducting Remote Briefings
The PHA must ensure that the lack of technology or inability to use technology for remote briefings does not pose a disadvantage to families that may not be apparent to the PHA. The PHA must ensure that the family has appropriate technological access in order to fully participate in the remote briefing.

PHA Policy
The PHA will provide written notice via first class mail and/or email to families attending the briefing, outlining the technological requirements for connection. The written notice will also request that the family notify the PHA of any known technological barriers. The PHA may also contact the family by telephone prior to the briefing to identify potential technological barriers and to determine which technology resources are accessible to the family. The PHA will resolve any barriers using the guidance in Section 6 of Notice PIH 2020-32, including offering the family the opportunity to attend an in-person briefing or have a one-on-one briefing over the phone, as appropriate.

The PHA may conduct remote briefings via a video
conferencing platform when available. If applicants are unable to adequately access the video conferencing platform, the briefing will be conducted by telephone conferencing call-in. If the family is unable to adequately access the ATTACHMENT 1 Page 22 of 50
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telephone conferencing call-in, the remote briefing will be postponed, and an in-person alternative or one-on-one
briefing over the phone will be provided.

The PHA will provide login information and/or conferencing call-in information and an electronic copy of the briefing packet via email at the time they are invited to the briefing.

The PHA will provide a paper copy of the briefing packet upon family request and may reschedule the briefing to allow adequate time for the family to receive the physical briefing packet.

The PHA will ensure that all electronic information stored or transmitted as part of the briefing meets the requirements for accessibility for persons with disabilities and persons with LEP, and is secure, including ensuring personally identifiable information (PII) is protected (Notice PIH 2015-06,).

The PHA will ensure that families who participate in remote briefings have the opportunity to ask questions as part of the briefing.

If families lose connectivity during any remote briefing or otherwise feel they were unable to access information
presented during the briefing, the family may request a one- on-one briefing over the phone or in person with the PHA.

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CHAPTER 5: BRIEFINGS AND VOUCHER ISSUANCE
Chapter Section: 5-II.C. EXCEPTIONS TO SUBSIDY STANDARDS Subsection (if any): n/a
Description of Change:

The AHA currently determines the appropriate number of bedrooms for each family under subsidy standards, which doesn't mandate the size of the unit leased or bedroom arrangements within households. Exceptions for health or disability reasons require a written request with documentation, verified by a professional source. The AHA is recommending a periodic reassessment of the necessity for an additional bedroom granted as a reasonable accommodation, as deemed necessary. This proposed policy adjustment aims to ensure that the right level of assistance is consistently provided to all families.

PROPOSED PHA ADMIN PLAN LANGUAGE:

PHA Policy
The PHA will consider granting an exception for the following reasons specified in the regulation: health and as a reasonable accommodation for a person with a disability.

The family must request any exception to the subsidy standards in writing. The request must explain the need or justification for a larger family unit size, and must include appropriate documentation.

Requests based on health-related reasons must be verified by a knowledgeable professional source (e.g., doctor or health professional), unless the disability and the disability–related request need for accommodation is readily apparent or otherwise known.

Under the sole discretion of the PHA, the family’s continued need for an additional bedroom due to special medical equipment may be re-verified during an annual or interim reexamination or an inspection.

PREVIOUS PHA ADMIN PLAN LANGUAGE:

PHA Policy
The PHA will consider granting an exception for the following reasons specified in the regulation: health and as a reasonable accommodation for a person with a disability.

Requests based on health-related reasons must be verified by a knowledgeable professional source, unless the disability and the disability–related request for accommodation is readily apparent or otherwise known.

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CHAPTER 6: INCOME AND SUBSIDY DETERMINATIONS
Chapter Section: 6-I.E. EARNED INCOME DISALLOWANCE FOR PERSONS WITH DISABILITIES [24 CFR 5.617; STREAMLINING FINAL RULE (SFR) FEDERAL REGISTER 3/8/16; NOTICE PIH 2023 27] Subsection (if any): n/a
Description of Change:

The Earned Income Disallowance (EID) was a provision created by HUD to encourage program participants with disabilities to enter the workforce by not including the total value of increases in earned income for a maximum period of 24 consecutive months. Presently, the Housing Opportunity Through Modernization Act (HOTMA) Final Rule has eliminated new enrollments into EID after December 31, 2023.

As a result, EID will be available only to eligible families already participating in the program before the end date, and no new families may be added. Therefore, this section is being updated to comply with the new HOTMA requirement.

Existing EID families will continue to operate under existing EID policies until their applicable timeframe is over. Families receiving the EID benefit before December 31, 2023, may continue to receive the full benefit until their remaining EID timeframe ends.

PROPOSED PHA ADMIN PLAN LANGUAGE:

HOTMA removed the statutory authority for the earned income disallowance (EID). The EID is available only to families that are eligible for and participating in the program as of December 31, 2023, or before; no new families may be added on or after January 1, 2024. If a family is receiving the EID prior to or on the effective date of December 31, 2023, they are entitled to the full amount of the benefit for a full 24-month period.

The policies below are applicable only to such families. No family will still be receiving the EID after December 31, 2025. The EID will sunset on January 1, 2026, and the PHA policies below will no longer be applicable as of that date or when the last qualifying family exhausts their exclusion period, whichever is sooner.

The earned income disallowance (EID) encourages people with disabilities to enter the work force by not including the full value of increases in earned income for a period of time. The full text of 24

PREVIOUS PHA ADMIN PLAN LANGUAGE:

Eligibility criteria and limitations on the disallowance are summarized below.

Eligibility
This disallowance applies only to individuals in families already participating in the HCV program (not at initial examination). To qualify, the family must experience an increase in annual income that is the result of one of the following events:

Employment of a family member who is a person with disabilities and who was previously unemployed for one or more years prior to employment. Previously unemployed includes a person who annually has earned not more than the minimum wage applicable to the ATTACHMENT 1 Page 25 of 50
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CFR 5.617 is included as Exhibit 6-4 at the end of this chapter.

Eligibility criteria and limitations on the disallowance are summarized below.

Employment of a family member who is a person with disabilities and who was previously unemployed for one or more years prior to employment. Previously unemployed includes a person who annually has earned not more than the minimum wage applicable to the community multiplied by 500 hours. The applicable minimum wage is the federal minimum wage unless there is a higher state or local minimum wage.

Increased earnings by a family member who is a person with disabilities and whose earnings increase during participation in an economic self-sufficiency or job-training program. A self-sufficiency program includes a program designed to encourage, assist, train, or facilitate the economic independence of HUD-assisted families or to provide work to such families [24 CFR 5.603(b)].

New employment or increased earnings by a family member who is a person with disabilities and who has received benefits or services under Temporary Assistance for Needy Families (TANF) or any other state program funded under Part A of Title IV of the Social Security Act within the past six months. If the benefits are received in the form of monthly maintenance, there is no minimum amount. If the benefits or services are received in a form other than monthly maintenance, such as one-time payments, wage subsidies, or community multiplied by 500 hours. The applicable minimum wage is the federal minimum wage unless there is a higher state or local minimum wage.

New employment or increased earnings by a family member who is a person with disabilities and who has received benefits or services under Temporary Assistance for Needy Families (TANF) or any other state program funded under Part A of Title IV of the Social Security Act within the past six months. If the benefits are received in the form of monthly maintenance, there is no minimum amount. If the benefits or services are received in a form other than monthly maintenance, such as one-time payments, wage subsidies, or transportation assistance, the total amount received over the six- month period must be at least $500.

Calculation of the Disallowance
Calculation of the earned income disallowance for an eligible member of a qualified family begins with a comparison of the member’s current income with his or her “prior income.” PHA Policy
The PHA defines prior income, or prequalifying income, as the family member’s last certified income prior to qualifying for the EID.

The family member’s prior, or prequalifying, income remains constant throughout the period that he or she is receiving the EID.

Initial 12-Month Exclusion
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transportation assistance, the total amount received over the six- month period must be at least $500.

B. Calculation of the Disallowance
Calculation of the earned income disallowance for an eligible member of a qualified family begins with a comparison of the member’s current income with his or hertheir “prior baseline income.” The family member’s baseline income is their income immediately prior to qualifying for the EID. The family member’s baseline income remains constant throughout the period that they are participating in the EID.

PHA Policy
The PHA defines prior income, or prequalifying income, as the family member’s last certified income prior to qualifying for the EID.

The family member’s prior, or prequalifying, baseline income remains constant throughout the period that he or she is they are participating in receiving the EID.

Initial 12-Month Exclusion
During the initial exclusion period of 12 consecutive months12- month exclusion period, the full amount (100 percent) of any increase in income attributable to new employment or increased earnings is excluded. The 12 months are cumulative and need not be consecutive [24 CFR 5.617(c)(1)].

PHA Policy
The initial EID exclusion period will begin on the first of the month following the date an eligible member of a qualified family is first employed or first experiences an increase in During the initial 12-month exclusion period, the full amount (100 percent) of any increase in income attributable to new employment or increased earnings is excluded. The 12 months are cumulative and need not be consecutive [24 CFR 5.617(c)(1)].

If employment is not reported in a timely manner, the EID exclusion may still begin on the first of the month following the date in which the eligible event occurred on the premise that the family has benefitted from the exclusion during the period that the income was not fully declared.

Second 12-Month Exclusion and Phase-In
During the second 12-month exclusion period, the exclusion must be reduced to at least half (50 percent) of any increase in income attributable to employment or increased earnings. The 12 months are cumulative and need not be consecutive. [24 CFR 5.617(c)(2)].

PHA Policy
During the second 12-month exclusion period, the PHA will exclude half (50 percent) of any increase in income attributable to employment or increased earnings.

Lifetime Limitation for households that qualified for EID before May 9, 2016
For persons qualifying before May 9, 2016, the two 12-months exclusion periods are cumulative, with a lifetime limit of 48 months for the qualifying member [24 CFR 5.617(c)(4) and FR Notice 3/8/16].. The four-year eligibility period begins at the same time that the initial exclusion period begins and ends 48 months later. The one-time eligibility for the EID applies even if the eligible individual ATTACHMENT 1 Page 27 of 50
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earnings assuming the family reports the employment or
earnings in a timely manner.

Second 12-Month Exclusion and Phase-In
During the second exclusion period of 12 consecutive months12- month exclusion period, the PHA must exclude at least 50 percent of any increase in income attributable to employment or increased earningsthe exclusion must be reduced to at least half (50 percent) of any increase in income attributable to employment or increased earnings. The 12 months are cumulative and need not be consecutive. [24 CFR 5.617(c)(2)].

PHA Policy
During the second 12-month exclusion period, the PHA will exclude half (50 percent) of any increase in income
attributable to employment or increased earnings.

Lifetime Limitation for households that qualified for EID before May 9, 2016
The EID has a two-year (24-month) lifetime maximum. The two- year eligibility period begins at the same time that the initial exclusion period begins and ends 24 months later. During the 24- month period, an individual remains eligible for EID even if they begin to receive assistance from a different housing agency, move between public housing and Section 8 assistance, or have breaks in assistance. The EID will sunset on January 1, 2026. In no begins to receive assistance from another housing agency, if the individual moves between public housing and Section 8 assistance, or if there are breaks in assistance.

PHA Policy
During the 48-month eligibility period, the PHA will schedule and conduct an interim reexamination each time there is a change in the family member’s annual income that affects or is affected by the EID (e.g., when the family member’s income falls to a level at or below his/her prequalifying income, when one of the exclusion periods ends, and at the end of the lifetime maximum eligibility period).

Lifetime Limitation for households that qualified for EID on or after May 9, 2016
For persons qualifying on or after May 9, 2016, the two 12-month exclusionary periods must run consecutively, with a lifetime limit of 24 months for the qualifying member. The two-year eligibility period begins at the same time that the initial exclusion period begins and ends 24 months later. The one-time eligibility for the EID applies even if the eligible individual begins to receive assistance from another housing agency, if the individual moves between public housing and Section 8 assistance, or if there are breaks in assistance.

If the family member discontinues the employment that initially qualified the family for the EID, the 24–calendar month period continues [FR Notice 3/8/16].

PHA Policy
During the 24-month eligibility period, the PHA will schedule and conduct an interim reexamination each time there is a change in the family member’s annual income that affects or is affected by the EID (e.g., when the family member’s income falls to a level at or below his/her prequalifying income, when one of the exclusion periods ends, and at the end of the lifetime maximum eligibility period).

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circumstances will a family member’s exclusion period continue past January 1, 2026.

For persons qualifying before May 9, 2016, the two 12-months exclusion periods are cumulative, with a lifetime limit of 48 months for the qualifying member [24 CFR 5.617(c)(4) and FR Notice 3/8/16].. The four-year eligibility period begins at the same time that the initial exclusion period begins and ends 48 months later. The one-time eligibility for the EID applies even if the eligible individual begins to receive assistance from another housing agency, if the individual moves between public housing and Section 8 assistance, or if there are breaks in assistance.

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If the family member discontinues the employment that initially qualified the family for the EID, the 24–calendar month period continues [FR Notice 3/8/16].

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CHAPTER 12: TERMINATIONS
Chapter Section: 12-I.E. Mandatory Policies and Other Authorized Terminations Subsection (if any): n/a
Description of Change:

Section 12.I.E. of the AHA Administrative Plan discusses conditions under which the AHA may terminate assistance from a rental assistance program. HUD permits, but does not require, the AHA to terminate assistance if the AHA determines that any household member is currently engaged in certain types of criminal activity. The recommended policy changes are intended to align with the proposed changes in Chapter 3 and make the AHA’s programs most accessible by removing daunting barriers that individuals with a criminal history consistently face in obtaining and maintaining housing. The PHA’s recommendations take into consideration HUD recommendations and guidance.

PROPOSED PHA ADMIN PLAN LANGUAGE:
12-I.E. Mandatory Policies and Other Authorized Terminations Mandatory Policies [24 CFR 982.553(b) and 982.551(l)]
HUD requires the PHA to establish policies that permit the PHA to terminate assistance if the PHA determines that: […]
PIH 2012-28]
The PHA is prohibited from admitting individuals subject to a lifetime registration requirement under a State sex offender registration program into its program. If a participant who is subject to such a lifetime registration requirement was erroneously admitted (the household member was subject to a lifetime registration requirement at admission and was admitted after June 25, 2001), the PHA must immediately pursue termination of assistance for the household member.

Use of Illegal Drugs and Alcohol Abuse
PHA Policy

PREVIOUS PHA ADMIN PLAN LANGUAGE:
12-I.E. Mandatory Policies and Other Authorized Terminations Mandatory Policies [24 CFR 982.553(b) and 982.551(l)]
HUD requires the PHA to establish policies that permit the PHA to terminate assistance if the PHA determines that: […]
PIH 2012-28]
The PHA is prohibited from admitting individuals subject to a lifetime registration requirement under a State sex offender registration program into its program. If a participant who is subject to such a lifetime registration requirement was erroneously admitted (the household member was subject to a lifetime registration requirement at admission and was admitted after June 25, 2001), the PHA must immediately pursue termination of assistance for the household member.

Use of Illegal Drugs and Alcohol Abuse
PHA Policy
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[…]
The PHA will consider all credible evidence, including but not limited to, any record of arrests,police records,
convictions, or eviction of household members related to the use of illegal drugs or abuse of alcohol.

A record or records of arrest will not be used as the sole basis for the termination or proof that the participant engaged in disqualifying criminal activity.

In making its decision to terminate assistance, the PHA will consider alternatives as described in Section 12-II.C and other factors described in Sections 12-II.D and 12-II.E. Upon consideration of such alternatives and factors, the PHA may, on a case-by-case basis, choose not to terminate assistance.

Drug-Related and Violent Criminal Activity [24 CFR 5.100] […]
PHA Policy
The PHA will terminate a family’s assistance if any
household member has violated the family’s obligation not to engage in any drug-related or violent criminal activity, including conviction of any criminal sexual conduct and is currently subject to a registration requirement under a state sex offender registration program, during participation in the HCV program.

The PHA will consider all credible evidence, including but not limited to, any police record of arrests and/orrecords, convictions of household members related to drug-related or violent criminal activity, and any eviction or notice to evict based on drug-related or violent criminal activity.
[…]
The PHA will consider all credible evidence, including but not limited to, any police records, convictions, or eviction of household members related to the use of illegal drugs or abuse of alcohol.In making its decision to terminate
assistance, the PHA will consider alternatives as described in Section 12-II.C and other factors described in Sections 12- II.D and 12-II.E. Upon consideration of such alternatives and factors, the PHA may, on a case-by-case basis, choose not to terminate assistance.

The PHA will consider all credible evidence, including but not limited to, any police records, convictions of household members related to drug-related or violent criminal activity, and any eviction or notice to evict based on drug-related or violent criminal activity.

In making its decision to terminate assistance, the PHA will consider alternatives as described in Section 12-II.C and other factors described in Sections 12-II.D and 12-II.E. Upon ATTACHMENT 1 Page 32 of 50
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A record or records of arrest will not be used as the sole basis for the termination or proof that the participant engaged in disqualifying criminal activity.

Other Authorized Reasons for Termination of Assistance
[24 CFR 982.552(c), Pub.L. 109-162]
HUD permits the PHA to terminate assistance under a number of other circumstances. […]
PHA Policy
The PHA will not terminate a family’s assistance because of the family’s failure to meet its obligations under the Family Self-Sufficiency program.

The PHA will terminate a family’s assistance if:

The family has failed to comply with any family
obligations under the program. See Exhibit 12-1 for a
listing of family obligations and related PHA policies.

Any family member has been evicted from federally-
assisted housing in the last five years24 months and
the family failed to disclose the information at
admission to the program.
[…]

consideration of such alternatives and factors, the PHA may, on a case-by-case basis, choose not to terminate assistance.

The PHA will terminate a family’s assistance if:

The family has failed to comply with any family
obligations under the program. See Exhibit 12-1 for a
listing of family obligations and related PHA policies.

Any family member has been evicted from federally-
assisted housing in the last five years and the family
failed to disclose the information at admission to the
program.
[…]

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CHAPTER 16: PROGRAM ADMINISTRATION
Chapter Section: Part X: COVID-19 Related Waivers
Subsection (if any): n/a
Description of Change:

In response to the global pandemic caused by the spread of Coronavirus Disease 2019 (COVID-19), HUD issued Notice PIH 2020-05 on April 10, 2020, granting the Public Housing Authority (PHA) the authority to adopt waivers and alternative requirements for various statutory and regulatory obligations within the HCV program. Subsequent notices, including PIH 2020-13 on July 2, 2020, PIH 2020-33 on November 30, 2020, and PIH 2021-14 on May 4, 2021, provided additional waivers and extensions for previously established ones. All COVID-related waivers had an expiration date. The PHAs adopted COVID-related waivers in 2020, however, all COVID-related waivers have since expired and are no longer applicable to the PHA's programs. Therefore, this section is to be removed.

PROPOSED PHA ADMIN PLAN LANGUAGE:

Entire part to be removed.

PART X: COVID-19 RELATED WAIVERS AND ALTERNATE

REQUIREMENTS

On April 10, 2020, HUD released Notice PIH 2020-05 in response to the global pandemic and current state of emergency caused by the spread of the respiratory disease named Coronavirus Disease 2019 (COVID-19). Notice PIH 2020-05 granted the PHA the authority to adopt a series of waivers and alternative requirements for numerous statutory and regulatory requirements for the HCV program.

Subsequently, HUD released Notice PIH 2020-13 on July 2,

PREVIOUS PHA ADMIN PLAN LANGUAGE:

PART X: COVID-19 RELATED WAIVERS AND ALTERNATE

REQUIREMENTS

Subsequently, HUD released Notice PIH 2020-13 on July 2, 2020,Notice PIH 2020-33 on November 30, 2020, and Notice PIH 2021-14 on May 4, 2021 which provided additional waivers and alternative requirements and extended the periods of availability for ATTACHMENT 1 Page 34 of 50
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2020,Notice PIH 2020-33 on November 30, 2020, and Notice PIH 2021-14 on May 4, 2021 which provided additional waivers and alternative requirements and extended the periods of availability for previously established waivers and alternative requirements. HUD made the waivers and alternative requirements listed in these Notices effective immediately for the housing authorities that elect to adopt them. The period of availability for each waiver and alternative requirement, collectively or individually, may be extended by a PIH notice should HUD determine this to be necessary. The PHA is not required to keep the waiver/ alternative requirements in-place for the full period of availability (including any extension) but may at any time choose to revert to regular program requirements and operations.

The PHA will continue to conduct its due diligence to abide by statutory and regulatory requirements of the HCV program throughout the state of emergency. However, in the case of inability to meet these demands due to the COVID-19 pandemic, the PHA has adopted and implemented the following waivers and alternative requirements as allowed under Notice PIH 2020-05, Notice PIH 2020-13, Notice PIH 2020-33, and Notice PIH 2021-14.

PHA Policy
Delayed Annual Reexaminations - The PHA is required to conduct a reexamination of family income and composition at least annually.

The PHA will continue to use its best efforts to conduct reexaminations on time. In the case that PHA is unable to meet these demands due to the COVID-19 pandemic, the reexamination will be conducted as soon as practicable, but will apply the prevailing payment standard by the original effective date of the reexamination.

If the PHA delays annual reexaminations for HCV families under this authority, it will comply with the alternative requirement previously established waivers and alternative requirements. HUD made the waivers and alternative requirements listed in these Notices effective immediately for the housing authorities that elect to adopt them. The period of availability for each waiver and alternative requirement, collectively or individually, may be extended by a PIH notice should HUD determine this to be necessary. The PHA is not required to keep the waiver/ alternative requirements in-place for the full period of availability (including any extension) but may at any time choose to revert to regular program requirements and operations.

PHA Policy
Delayed Annual Reexaminations - The PHA is required to conduct a reexamination of family income and composition at least annually.

If the PHA delays annual reexaminations for HCV families under this authority, it will comply with the alternative requirement regarding the application of an increase in the payment standard amount during the Housing Assistance Payment (HAP) contract term (see HCV-7 below) if applicable, so as not to delay the application of the increased payment standard amount to the family’s HAP calculation. All delayed annual reexaminations due in calendar year ATTACHMENT 1 Page 35 of 50
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regarding the application of an increase in the payment standard amount during the Housing Assistance Payment (HAP) contract term (see HCV-7 below) if applicable, so as not to delay the application of the increased payment standard amount to the family’s HAP calculation. All delayed annual reexaminations due in calendar year 2020 will be completed by December 31, 2020 (or subsequent extensions provided by HUD). Reexaminations due in calendar year 2021 will be completed by December 31, 2021 (or subsequent extensions provided by HUD) (Notice 2021-14, Waiver: PH and HCV-2, p. 10).

Income Verifications for Annual and Interim Reexaminations - The PHA is required to follow the HUD income verification hierarchy and use the Enterprise Income Verification (EIV) System to verify family income when conducting annual and interim reexaminations.

The PHA will continue to use its best efforts to follow the HUD income verification hierarchy and provide an EIV report for all reexaminations. In the event that the PHA is unable to collect proper verifications due to the impacts of COVID-19, the PHA may forgo HUD verification hierarchy requirements and may accept self- certifications as the highest form of income verification through December 31, 2021 (or subsequent extensions provided by HUD). (For annual reexaminations only, the PHA may use self-certifications if the PHA wishes to conduct the annual recertification rather than delaying the family’s annual recertification as listed above). This may occur over the telephone (but will be documented by PHA staff with a contemporaneous written record), through an email or postal mail with a self-certification form by the tenant, or through other electronic communications. The PHA may also obtain self- certification through email or postal mail, or through other electronic communications. Due to staffing and technology limitations that have stemmed from the COVID-19 pandemic, the PHA may not 2020 will be completed by December 31, 2020 (or subsequent extensions provided by HUD). Reexaminations due in calendar year 2021 will be completed by December 31, 2021 (or subsequent extensions provided by HUD) (Notice 2021-14, Waiver: PH and HCV-2, p. 10).

The PHA will continue to use its best efforts to follow the HUD income verification hierarchy and provide an EIV report for all reexaminations. In the event that the PHA is unable to collect proper verifications due to the impacts of COVID-19, the PHA may forgo HUD verification hierarchy requirements and may accept self- certifications as the highest form of income verification through December 31, 2021 (or subsequent extensions provided by HUD). (For annual reexaminations only, the PHA may use self-certifications if the PHA wishes to conduct the annual recertification rather than delaying the family’s annual recertification as listed above). This may occur over the telephone (but will be documented by PHA staff with a contemporaneous written record), through an email or postal mail with a self-certification form by the tenant, or through other electronic communications. The PHA may also obtain self- certification through email or postal mail, or through other electronic communications. Due to staffing and technology limitations that have stemmed from the COVID-19 pandemic, the PHA may not include an EIV report with annual or interim reexaminations through December 31, 2021 (or subsequent extensions provided by HUD). (Notice 2021-14, Waivers: PH and HCV-3 and PH and HCV-4, pp. 11-13).

Enterprise Income Verification (EIV) Monitoring - The PHA is required to continuously monitor EIV reports. Due to staffing and ATTACHMENT 1 Page 36 of 50
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include an EIV report with annual or interim reexaminations through December 31, 2021 (or subsequent extensions provided by HUD). (Notice 2021-14, Waivers: PH and HCV-3 and PH and HCV-4, pp. 11-13).

Enterprise Income Verification (EIV) Monitoring - The PHA is required to continuously monitor EIV reports. Due to staffing and technology limitations that have stemmed from the COVID-19 pandemic, the PHA may suspend EIV monitoring through December 31, 2021 (or subsequent extensions provided by HUD). (Notice 2020-33, Waiver: PH and HCV-5, p. 13).

Family Self-Sufficiency (FSS) Contract of Participation Extension - The PHA may extend a family’s contract of participation in the FSS program for a period not to exceed two years upon a finding of good cause. The circumstances surrounding COVID-19 pandemic qualify as good cause and the PHA may extend FSS contracts when employment has been impacted by the disease. The period of availability during which the PHA may extend the family’s contract of participation using COVID-19 as good cause ends on December 31, 2021 (or subsequent extensions provided by HUD). (Notice 2021-14, Waiver: PH and HCV-6, p. 14).

Waiting List: Opening and Closing; Public Notice - The PHA is required to give public notice by publication in a local newspaper of general circulation and also by minority media and other suitable means when it opens a waiting list. Recognizing the foreseeable difficulties in complying with this requirement in light of the COVID-19 pandemic, the PHA will adopt an alternative requirement that provides public notice in a voicemail message on its main or general information telephone number and through its website through December 31, 2021 (or subsequent extensions provided by HUD). The PHA will comply with applicable fair housing and other technology limitations that have stemmed from the COVID-19 pandemic, the PHA may suspend EIV monitoring through December 31, 2021 (or subsequent extensions provided by HUD). (Notice 2020-33, Waiver: PH and HCV-5, p. 13).

Waiting List: Opening and Closing; Public Notice - The PHA is required to give public notice by publication in a local newspaper of general circulation and also by minority media and other suitable means when it opens a waiting list. Recognizing the foreseeable difficulties in complying with this requirement in light of the COVID-19 pandemic, the PHA will adopt an alternative requirement that provides public notice in a voicemail message on its main or general information telephone number and through its website through December 31, 2021 (or subsequent extensions provided by HUD). The PHA will comply with applicable fair housing and other civil rights requirements when providing public notice under this alternative requirement, including ensuring effective communication with persons with hearing, visual, and other communication-related disabilities and ensuring meaningful access for persons with limited English proficiency in all notifications and communications (Notice 2021-14, PH and HCV-7, p. 14).

Eligibility Determination: Income Verification - The PHA is required to follow the HUD income verification hierarchy to verify that an ATTACHMENT 1 Page 37 of 50
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civil rights requirements when providing public notice under this alternative requirement, including ensuring effective communication with persons with hearing, visual, and other communication-related disabilities and ensuring meaningful access for persons with limited English proficiency in all notifications and communications (Notice 2021-14, PH and HCV-7, p. 14).

Eligibility Determination: Income Verification - The PHA is required to follow the HUD income verification hierarchy to verify that an applicant is eligible within the 60-day period before the PHA issues a voucher to the applicant. Third-party generated documents under the verification hierarchy are required to be dated within 60 days of the PHA’s request. The PHA will continue to use its best efforts to follow the HUD income verification hierarchy for all applicants at admission. In the event that the PHA is unable to collect proper verifications due to the impacts of COVID-19, the PHA may forgo HUD verification hierarchy requirements and may accept self- certifications as the highest form of income verification through December 31, 2021 (or subsequent extensions provided by HUD).

Applicants must submit an affidavit attesting to reported income, assets, expenses and other factors which would affect an income eligibility determination. Additionally, applicants may provide third- party documentation which represents the applicant’s income within the 60-day period prior to admission or voucher issuance but is not dated within 60 days of the PHA’s request. For each new admission under this waiver, the PHA will comply with reviewing and monitoring the reports by the time frames set forth in this waiver. (Notice 2021-14, Waivers: PH and HCV-8, pp. 15-16).

Eligibility Determination: Social Security Number and Citizenship Verification - At admission, the PHA is required to verify social security numbers (SSN), U.S. citizenship or eligible immigration status for noncitizens, date of birth, and disability status for all applicant is eligible within the 60-day period before the PHA issues a voucher to the applicant. Third-party generated documents under the verification hierarchy are required to be dated within 60 days of the PHA’s request. The PHA will continue to use its best efforts to follow the HUD income verification hierarchy for all applicants at admission. In the event that the PHA is unable to collect proper verifications due to the impacts of COVID-19, the PHA may forgo HUD verification hierarchy requirements and may accept self- certifications as the highest form of income verification through December 31, 2021 (or subsequent extensions provided by HUD).

Eligibility Determination: Social Security Number and Citizenship Verification - At admission, the PHA is required to verify social security numbers (SSN), U.S. citizenship or eligible immigration status for noncitizens, date of birth, and disability status for all applicants to determine their program eligibility. The PHA will continue to use its best efforts to collect proper verifications for all applicants at admission. In the event that the PHA is unable to collect proper verifications due to the impacts of COVID-19, the PHA may admit applicants who are unable to provide the required SSN, citizenship or eligible immigration status, and require that applicant submit the required documentation within 90 days of admission to remain eligible for continued assistance, pending verification.

Additionally, the PHA may accept self-certification of date of birth ATTACHMENT 1 Page 38 of 50
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applicants to determine their program eligibility. The PHA will continue to use its best efforts to collect proper verifications for all applicants at admission. In the event that the PHA is unable to collect proper verifications due to the impacts of COVID-19, the PHA may admit applicants who are unable to provide the required SSN, citizenship or eligible immigration status, and require that applicant submit the required documentation within 90 days of admission to remain eligible for continued assistance, pending verification.

Additionally, the PHA may accept self-certification of date of birth and disability status if a higher level of verification is not immediately available. If self-certification is used, the PHA will obtain a higher level of verification within 90 days of admission or verify the information in EIV to authenticate applicant eligibility.

This waiver is available through December 31, 2021 (or subsequent extensions provided by HUD) (Notice 2021-14, Waivers: PH and HCV-9, pp. 16-17).

Administrative Plan - HUD regulation requires that any revisions of the PHA’s Administrative Plan must be formally adopted by the PHA Board of Commissioners or other authorized PHA officials.

HUD and the PHA have recognized the foreseeable difficulties in complying with this requirement in light of the COVID-19 pandemic. PIH Notice 2021-14 allows the PHA to adopt these waivers on a temporary basis without Board approval through September 30, 2021. The PHA will formally adopt these provisions no later than December 31, 2021 (Notice 2021-14, Waiver: HCV-1, p. 25).

PHA Oral Briefings - The PHA is required through federal regulations to provide an oral briefing to the families that the PHA has selected to participate in either the HCV or PBV program.

Conducting in-person oral briefings during the COVID-19 poses and disability status if a higher level of verification is not immediately available. If self-certification is used, the PHA will obtain a higher level of verification within 90 days of admission or verify the information in EIV to authenticate applicant eligibility.

This waiver is available through December 31, 2021 (or subsequent extensions provided by HUD) (Notice 2021-14, Waivers: PH and HCV-9, pp. 16-17).

Administrative Plan - HUD regulation requires that any revisions of the PHA’s Administrative Plan must be formally adopted by the PHA Board of Commissioners or other authorized PHA officials.

PHA Oral Briefings - The PHA is required through federal regulations to provide an oral briefing to the families that the PHA has selected to participate in either the HCV or PBV program.

Conducting in-person oral briefings during the COVID-19 poses health risks for families and PHA personnel, and may run counter to public health orders, directives, or recommendations such as shelter- in-place or other social distancing practices designed to contain and reduce exposure to the disease. In lieu of in-person oral briefings, the PHA will conduct the briefing by other means such as a telephone call, webcast, video call, or expanded information packet through December 31, 2021 (or subsequent extensions provided by HUD) or after the state of emergency is lifted, whichever is later. Section 504 and the ADA require PHAs to ensure effective communication with applicants, participants and members of the public in all communications and notices. The PHA will ensure that the method ATTACHMENT 1 Page 39 of 50
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health risks for families and PHA personnel, and may run counter to public health orders, directives, or recommendations such as shelter- in-place or other social distancing practices designed to contain and reduce exposure to the disease. In lieu of in-person oral briefings, the PHA will conduct the briefing by other means such as a telephone call, webcast, video call, or expanded information packet through December 31, 2021 (or subsequent extensions provided by HUD) or after the state of emergency is lifted, whichever is later. Section 504 and the ADA require PHAs to ensure effective communication with applicants, participants and members of the public in all communications and notices. The PHA will ensure that the method of communication for the briefing effectively communicates with, and allows for equal participation of, each family member, including those with vision, hearing, and other communication-related disabilities, and ensures meaningful access for persons with limited English proficiency (Notice 2021-14, Waiver: HCV-2, p. 25).

Voucher Extensions - The PHA may grant a family one or more extension of the initial voucher term in accordance with its PHA policy as described in its PHA Administrative Plan. Due to the impacts that the COVID-19 pandemic may have on finding housing, the PHA may issue extensions beyond what is typically allowable under Chapter 5-II.E. of the Administrative Plan through December 31, 2021 (or subsequent extensions provided by HUD) (Notice 2021- 34, Waiver: HCV-3, p. 25-26).

HAP Execution - Typically, the PHA may not make any housing assistance payments to the owner until the HAP contract is executed.

The PHA will continue to use its best efforts to execute the HAP contract no later than 60 days from the beginning of the lease term.

In the case of inability to meet these demands due to the COVID-19 pandemic, the PHA may take up to 120 days from the beginning of the lease term to fully execute the HAP contract and make HAP of communication for the briefing effectively communicates with, and allows for equal participation of, each family member, including those with vision, hearing, and other communication-related disabilities, and ensures meaningful access for persons with limited English proficiency (Notice 2021-14, Waiver: HCV-2, p. 25).

HAP Execution - Typically, the PHA may not make any housing assistance payments to the owner until the HAP contract is executed.

The PHA will continue to use its best efforts to execute the HAP contract no later than 60 days from the beginning of the lease term.

In the case of inability to meet these demands due to the COVID-19 pandemic, the PHA may take up to 120 days from the beginning of the lease term to fully execute the HAP contract and make HAP payments back to the beginning of the lease term through December 31, 2021 (or subsequent extensions provided by HUD) (Notice 2021- 14, Waiver: HCV-4, p. 26).

Absence from Unit - HUD regulations require that a family may not be absent from the unit for a period of more than 180 consecutive calendar days for any reason. The PHA recognizes that families may have to relocate to protect their health and safety due to the COVID- 19 pandemic. The PHA may waive its policies of family absences listed on Chapter 12-I.E. of the Administrative Plan at its discretion, may continue housing assistance payments, and not terminate the HAP contract if the family’s absence is related to a COVID-19 related emergency. The PHA will maintain documentation in the ATTACHMENT 1 Page 40 of 50
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payments back to the beginning of the lease term through December 31, 2021 (or subsequent extensions provided by HUD) (Notice 2021- 14, Waiver: HCV-4, p. 26).

Absence from Unit - HUD regulations require that a family may not be absent from the unit for a period of more than 180 consecutive calendar days for any reason. The PHA recognizes that families may have to relocate to protect their health and safety due to the COVID- 19 pandemic. The PHA may waive its policies of family absences listed on Chapter 12-I.E. of the Administrative Plan at its discretion, may continue housing assistance payments, and not terminate the HAP contract if the family’s absence is related to a COVID-19 related emergency. The PHA will maintain documentation in the tenant file which explains the extenuating circumstances that caused the extended absence. The PHA may waive these policies through December 31, 2021 (or subsequent extensions provided by HUD).

The PHA may not make payments beyond December 31, 2021, and the HAP contract will terminate on that date if the family is still absent from the unit (Notice 2021-14, Waiver: HCV-5 p. 26).

Termination of the HAP Contract/Family Self-Sufficiency - When family’s income increases to the extent that the housing assistance payment is reduced to $0, the PHA is required by regulation to automatically terminate HAP contract 180 days after the last housing assistance payment to the owner. The PHA recognizes that the COVID-19 pandemic is creating economic and employment
instability for many families, as well as situations where families may on a temporary basis be adding members whose additional income may result in a $0 HAP subsidy calculation. Upon written notice to the owner and the family, the PHA may extend the HAP contract beyond 180 days from the date that the family became self- sufficient but may not extend beyond December 31, 2021 (or tenant file which explains the extenuating circumstances that caused the extended absence. The PHA may waive these policies through December 31, 2021 (or subsequent extensions provided by HUD).

The PHA may not make payments beyond December 31, 2021, and the HAP contract will terminate on that date if the family is still absent from the unit (Notice 2021-14, Waiver: HCV-5 p. 26).

Termination of the HAP Contract/Family Self-Sufficiency - When family’s income increases to the extent that the housing assistance payment is reduced to $0, the PHA is required by regulation to automatically terminate HAP contract 180 days after the last housing assistance payment to the owner. The PHA recognizes that the COVID-19 pandemic is creating economic and employment
instability for many families, as well as situations where families may on a temporary basis be adding members whose additional income may result in a $0 HAP subsidy calculation. Upon written notice to the owner and the family, the PHA may extend the HAP contract beyond 180 days from the date that the family became self- sufficient but may not extend beyond December 31, 2021 (or subsequent extensions provided by HUD) (Notice 2021-14, Waiver:

HCV-6, p. 27).

subsequent extensions provided by HUD) (Notice 2021-14, Waiver:

HCV-6, p. 27).

Increase in Payment Standard During HAP Contract Term - HUD regulation requires that if the payment standard amount is increased during the term of the HAP contract, the increased payment standard amount shall be used to calculate the monthly housing assistance payment for the family beginning at the effective date of the family’s first regular reexamination on or after the effective date of the increase in the payment standard amount. Recognizing that the COVID-19 pandemic has creating uncertainty for owners and families, the PHA may apply the increased payment standard at any time (e.g., interim reexamination, owner rent increase) after the effective date of the increase in the payment standard amount, provided the increased payment standard is used to calculate the HAP no later than the effective date of the family’s first regular reexamination following the change. If the PHA has delayed the family’s annual reexamination under the waiver PH and HCV-2 (above), the PHA will use the increased payment standard amount to calculate the family’s HAP beginning the date that the family’s first regular reexamination would have been effective in the absence of the waiver. Alternatively, the PHA may conduct an interim reexamination where the only change is the increased payment standard amount. Regardless of the method used, the participant must receive the increased payment standard no later than the effective date of the family’s first regular reexamination following the increased payment standard. This waiver is available through December 31, 2021 (Notice 2021-14, Waiver: HCV-7, p. 27).

Utility Allowance - The PHA is required to review its utility allowance schedule each year and revise it if there has been a change of 10 percent or more in a utility rate since the last time it was revised. The PHA recognizes that there may be delays in receiving HAP no later than the effective date of the family’s first regular reexamination following the change. If the PHA has delayed the family’s annual reexamination under the waiver PH and HCV-2 (above), the PHA will use the increased payment standard amount to calculate the family’s HAP beginning the date that the family’s first regular reexamination would have been effective in the absence of the waiver. Alternatively, the PHA may conduct an interim reexamination where the only change is the increased payment standard amount. Regardless of the method used, the participant must receive the increased payment standard no later than the effective date of the family’s first regular reexamination following the increased payment standard. This waiver is available through December 31, 2021 (Notice 2021-14, Waiver: HCV-7, p. 27).

Mandatory Removal of Unit from PBV HAP Contract - Under the PBV program, a PHA is required to remove a unit from a PBV HAP contract after 180 days of zero housing assistance payments to the unit owner on behalf of the family residing in the unit. In recognition that the COVID-19 pandemic is creating uncertainty for owners and families, the PHA may use its discretion to keep such units under contract for a period of time that exceeds 180 days but does not extend beyond June 30, 2021 (or subsequent extensions provided by HUD). The PHA may resume housing assistance payments on behalf of a family residing in such a unit should the family’s income change ATTACHMENT 1 Page 42 of 50
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information required for the utility allowance review due to the COVID-19 pandemic. In the event that the PHA experiences delays on receiving information, the PHA may conduct a review of the utility allowances that were due at some point in CY 2020 by December 31, 2021(Notice 2021-14, Waiver: HCV-8, p. 28).

Mandatory Removal of Unit from PBV HAP Contract - Under the PBV program, a PHA is required to remove a unit from a PBV HAP contract after 180 days of zero housing assistance payments to the unit owner on behalf of the family residing in the unit. In recognition that the COVID-19 pandemic is creating uncertainty for owners and families, the PHA may use its discretion to keep such units under contract for a period of time that exceeds 180 days but does not extend beyond June 30, 2021 (or subsequent extensions provided by HUD). The PHA may resume housing assistance payments on behalf of a family residing in such a unit should the family’s income change at any point during the period of time covered by the extension (Notice 2021-14, Waiver: HCV-14, p. 30).

Project-Based Voucher (PBV) and Enhanced Voucher (EV)
Provisions on Under-Occupied Units Statutory Authority: PBV and EV Provisions on Under-Occupied Units – Several HUD regulations and Notices have established regulatory authority that address how families in under-occupied PBV units, Rental Assistance Demonstration (RAD) PBV units, and Enhanced Voucher (EV) units must be appropriately-sized. The PHA recognizes the impact and the difficulty that the COVID-19 pandemic has created in finding stable housing for many families. The PHA may allow a family to initially lease an under-occupied PBV or RAD PBV unit (a unit that has more bedrooms than what the family qualifies for under PHA subsidy standards) under certain circumstances as further described below, and to allow for the continued occupancy of PBV and EV families already under a lease for an under-occupied PBV, RAD PBV, or EV unit. This includes waiver of the statutory provisions concerning single person families, so that the PHA may allow a single person to lease a unit with more than 2 bedrooms under the conditions set forth below.
- The PHA may approve a homeless family on the waiting list (or a homeless family referred as part of the HUD-VASH program, if applicable) to initially lease an under-occupied PBV or RAD PBV unit, provided the PHA has no families on the waiting list, after outreach and marketing, that qualify for the PBV or RAD PBV unit.

unit. This includes waiver of the statutory provisions concerning single person families, so that the PHA may allow a single person to lease a unit with more than 2 bedrooms under the conditions set forth below.
- The PHA may approve a homeless family on the waiting list (or a homeless family referred as part of the HUD-VASH program, if applicable) to initially lease an under-occupied PBV or RAD PBV unit, provided the PHA has no families on the waiting list, after outreach and marketing, that qualify for the PBV or RAD PBV unit.

The family will become subject to § 983.260 no later than the end of the lease term following the expiration of this waiver. - The PHA may allow a family currently occupying an under- occupied PBV unit (or a RAD PBV unit that the family leased after conversion) to remain in the unit until the end of the lease term following the expiration of this waiver, at which time the family will become subject to § 983.260. This also applies to an eligible family whose current under- occupied unit has been subject to a conversion action and placed under a PBV HAP contract, so that the family may continue to lease the same unit under these conditions. - The PHA may allow a family that is currently occupying an under-occupied RAD PBV unit or EV unit, and that was occupying the unit at conversion, to remain in the unit until the end of the lease term following the expiration of this waiver, at which time the family will become subject to the relevant requirement (as described in H 2019-09/PIH 2019-23 and PIH 2016-02, as applicable) to move to an appropriately-sized unit in the project when one becomes available.

This waiver does not affect other requirements for family eligibility or the PBV program. This waiver is available through December 31, 2021. Any PBV, RAD PBV, or EV family residing in an under- occupied unit on this date in accordance with this waiver may remain whose current under- occupied unit has been subject to a conversion action and placed under a PBV HAP contract, so that the family may continue to lease the same unit under these conditions. - The PHA may allow a family that is currently occupying an under-occupied RAD PBV unit or EV unit, and that was occupying the unit at conversion, to remain in the unit until the end of the lease term following the expiration of this waiver, at which time the family will become subject to the relevant requirement (as described in H 2019-09/PIH 2019-23 and PIH 2016-02, as applicable) to move to an appropriately-sized unit in the project when one becomes available.

Mainstream Age Eligibility to Enter HAP Contract - HUD
regulations require that eligible member of a Mainstream household must be non-elderly, defined as at least 18 years of age and under 62 years of age (not yet reached their 62nd birthday) to be eligible to be placed under HAP contract. A Mainstream-eligible individual issued a voucher at 61 years of age may not be able to lease the voucher before their 62nd birthday. The PHA recognizes that the COVID-19 pandemic has impacted PHA operations, unit searches may not have been possible due to shelter-in-place orders, or the movement of people has been significantly restricted. As an alternative requirement, the PHA may expand the definition of an eligible non- elderly family member to include those who were issued a voucher prior to turning 62 and were not yet 63 on the effective date of the ATTACHMENT 1 Page 44 of 50
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in the unit until the end of the family’s lease term following this date, at which time the family will be subject to the relevant requirement for under-occupied units (Notice 2021-14, Waiver: HCV-15, pp. 30- 33).

Mainstream Age Eligibility to Enter HAP Contract - HUD
regulations require that eligible member of a Mainstream household must be non-elderly, defined as at least 18 years of age and under 62 years of age (not yet reached their 62nd birthday) to be eligible to be placed under HAP contract. A Mainstream-eligible individual issued a voucher at 61 years of age may not be able to lease the voucher before their 62nd birthday. The PHA recognizes that the COVID-19 pandemic has impacted PHA operations, unit searches may not have been possible due to shelter-in-place orders, or the movement of people has been significantly restricted. As an alternative requirement, the PHA may expand the definition of an eligible non- elderly family member to include those who were issued a voucher prior to turning 62 and were not yet 63 on the effective date of the HAP Contract through December 31, 2021 (or subsequent extensions provided by HUD). (Notice 2021-14, Waiver: MS-3, p. 52).

Initial HQS Inspections - The PHA is required to conduct an initial inspection of a unit within certain time frames before the beginning of the initial lease term and before any housing assistance payment (HAP) is made to determine whether the unit meets HQS.

Conducting physical inspections of units in communities during the COVID-19 poses health risks for families, participating owners, and PHA personnel, and may run counter to public health orders, directives, or recommendations such as shelter-in-place or other social distancing practices designed to contain and reduce exposure to the disease. The PHA will allow an owner’s self-certification that the owner has no reasonable basis to have knowledge that life- threatening conditions exist in the unit or units in question instead of conducting an initial inspection through December 31, 2021 (or subsequent extensions provided by HUD). At minimum, the PHA will require this owner certification. For any units for which the PHA has accepted a self-certification, the PHA will conduct an initial HQS inspection on the unit as soon as it is reasonably possible and safe to do so but not later than June 30, 2022 (or subsequent extensions provided by HUD). The use of this waiver by the PHA does not relieve owners of their responsibility to maintain the unit in accordance with HQS as required in the HAP contract, nor does it in any way restrict the PHA from taking action to enforce the owner’s obligations (Notice 2021-14, Waiver: HQS-1, p. 19).

conducting an initial inspection through December 31, 2021 (or subsequent extensions provided by HUD). At minimum, the PHA will require this owner certification. For any units for which the PHA has accepted a self-certification, the PHA will conduct an initial HQS inspection on the unit as soon as it is reasonably possible and safe to do so but not later than June 30, 2022 (or subsequent extensions provided by HUD). The use of this waiver by the PHA does not relieve owners of their responsibility to maintain the unit in accordance with HQS as required in the HAP contract, nor does it in any way restrict the PHA from taking action to enforce the owner’s obligations (Notice 2021-14, Waiver: HQS-1, p. 19).

Current regulations allow the PHA to approve an assisted tenancy and execute a HAP contract if a unit failed to meet HQS only as the result of Non-Life-Threatening (NLT) deficiencies. Owners are required to correct the NLT deficiencies within 30 days, otherwise the PHA must withhold HAP payments. Given the circumstances surrounding the COVID-19 pandemic, the PHA may provide an extension of up to an additional 30 days to make the repairs and continue to make payments to the owner during the period of that maximum 30-day extension. However, if repairs are not made within 60 days, (this includes the additional 30 day extension listed above), the PHA will withhold payments until the repairs are made. The PHA may approve this additional extension through December 31, 2021 (or subsequent extensions provided by HUD). The extension to make the NLT repairs may extend beyond December 31, 2021, depending on the date the PHA approved the extension. For example, if the PHA approved the extension on December 15, 2021, the maximum extension provided to the owner would be January 14, 2022 (Notice 2021-14, Waiver: HQS-3, p. 20).

PBV Pre-HAP Contract Inspections - The PHA is required to inspect each PBV contract unit before execution of the HAP contract and the continue to make payments to the owner during the period of that maximum 30-day extension. However, if repairs are not made within 60 days, (this includes the additional 30 day extension listed above), the PHA will withhold payments until the repairs are made. The PHA may approve this additional extension through December 31, 2021 (or subsequent extensions provided by HUD). The extension to make the NLT repairs may extend beyond December 31, 2021, depending on the date the PHA approved the extension. For example, if the PHA approved the extension on December 15, 2021, the maximum extension provided to the owner would be January 14, 2022 (Notice 2021-14, Waiver: HQS-3, p. 20).

PBV Pre-HAP Contract Inspections - The PHA is required to inspect each PBV contract unit before execution of the HAP contract and the HAP contract may not be executed until the units fully comply with HQS. For rehabilitated and newly constructed units, the PHA is required to inspect the units to determine if the housing has been completed in accordance with the Agreement to Enter into the HAP Contract (AHAP), including compliance with the HQS and any additional requirement imposed by the PHA under the Agreement.

HAP contract may not be executed until the units fully comply with HQS. For rehabilitated and newly constructed units, the PHA is required to inspect the units to determine if the housing has been completed in accordance with the Agreement to Enter into the HAP Contract (AHAP), including compliance with the HQS and any additional requirement imposed by the PHA under the Agreement.

Conducting physical inspections of units in communities during the COVID-19 poses health risks for families, participating owners, and PHA personnel, and may run counter to public health orders, directives, or recommendations such as shelter-in-place or other social distancing practices designed to contain and reduce exposure to the disease. The PHA will allow an owner’s self-certification that the owner has no reasonable basis to have knowledge that life- threatening conditions exist in the unit or units in question through December 31, 2022 (or subsequent extensions provided by HUD) or after the state of emergency is lifted, whichever is later. At minimum, the PHA will require this owner certification. If the PHA has imposed an additional requirement under the AHAP for newly constructed or rehabilitated projects, the PHA will allow the owner to certify that the PHA requirement has been met instead of inspecting the housing to make that determination through December 31, 2022 (or subsequent extensions provided by HUD) or after the state of emergency is lifted, whichever is later. For any units for which the PHA accepted an owner’s self-certification, the PHA must conduct an HQS inspection as soon as reasonably possible but no later than June 30, 2022 (or subsequent extensions provided by HUD) (Notice 2021-14, Waiver: HQS-2, p. 19-20).

Biennial HQS Inspections - The PHA is required to inspect units not less than biennially during the term of the HAP contract. Conducting physical inspections of units in communities during the COVID-19 poses health risks for families, participating owners, and PHA certify that the PHA requirement has been met instead of inspecting the housing to make that determination through December 31, 2022 (or subsequent extensions provided by HUD) or after the state of emergency is lifted, whichever is later. For any units for which the PHA accepted an owner’s self-certification, the PHA must conduct an HQS inspection as soon as reasonably possible but no later than June 30, 2022 (or subsequent extensions provided by HUD) (Notice 2021-14, Waiver: HQS-2, p. 19-20).

Biennial HQS Inspections - The PHA is required to inspect units not less than biennially during the term of the HAP contract. Conducting physical inspections of units in communities during the COVID-19 poses health risks for families, participating owners, and PHA personnel, and may run counter to public health orders, directives, or recommendations such as shelter-in-place or other social distancing practices designed to contain and reduce exposure to the disease. The PHA may delay any biennial inspections and instead, the PHA may rely on the owner’s certification that the owner has no reasonable basis to have knowledge that life-threatening conditions exist in the unit or units in question. At minimum, the PHA will require this owner certification. The PHA must resume biennial inspections by December 31, 2021. The PHA must conduct all delayed biennial inspections from CY 2020 as soon as reasonably possible but no later than June 30, 2022 (or subsequent extensions provided by HUD).

The PHA must conduct all delayed biennial inspections from CY 2021 as soon as reasonably possible but no later than December 31, 2022 (or subsequent extensions provided by HUD). The use of this waiver by the PHA does not relieve owners of their responsibility to maintain the unit in accordance with HQS as required in the HAP contract, nor does it in any way restrict the PHA from taking action to enforce the owner’s obligations (Notice 2021-14, Waiver: HQS-5 p. 21-22).

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personnel, and may run counter to public health orders, directives, or recommendations such as shelter-in-place or other social distancing practices designed to contain and reduce exposure to the disease. The PHA may delay any biennial inspections and instead, the PHA may rely on the owner’s certification that the owner has no reasonable basis to have knowledge that life-threatening conditions exist in the unit or units in question. At minimum, the PHA will require this owner certification. The PHA must resume biennial inspections by December 31, 2021. The PHA must conduct all delayed biennial inspections from CY 2020 as soon as reasonably possible but no later than June 30, 2022 (or subsequent extensions provided by HUD).

HQS Interim Inspections - If the PHA is notified that the assisted unit does not comply with the HQS by a family or government official, the PHA is required to inspect an assisted unit within 24 hours of when the PHA received the notification if the condition is life-threatening, or within 15 days is the reported condition is not life-threatening. Conducting physical inspections of units in communities during the COVID-19 poses health risks for families, participating owners, and PHA personnel, and may run counter to public health orders, directives, or recommendations such as shelter- in-place or other social distancing practices designed to contain and reduce exposure to the disease. If the reported deficiency is life- threatening, the PHA will notify the owner of the reported life- HQS Interim Inspections - If the PHA is notified that the assisted unit does not comply with the HQS by a family or government official, the PHA is required to inspect an assisted unit within 24 hours of when the PHA received the notification if the condition is life-threatening, or within 15 days is the reported condition is not life-threatening. Conducting physical inspections of units in communities during the COVID-19 poses health risks for families, participating owners, and PHA personnel, and may run counter to public health orders, directives, or recommendations such as shelter- in-place or other social distancing practices designed to contain and reduce exposure to the disease. If the reported deficiency is life- threatening, the PHA will notify the owner of the reported life- threatening deficiency and the owner must either correct the life- threatening deficiency within 24 hours of the PHA notification or provide documentation (e.g., text or email a photo to the PHA) that the reported deficiency does not exist through December 31, 2022 (or subsequent extensions provided by HUD). In the case of a reported non-life-threatening deficiency, the PHA will notify the owner of the reported deficiency within 30 days and the owner must either make the repair or document that the deficiency does not exist within 30 days of the PHA notification or any approved PHA extension through December 31, 2021 (or subsequent extensions provided by HUD). As is the case under the current HCV program requirements, the PHA is not required to conduct an in-person inspection to verify the repairs have been made but may rely on alternative verification methods (e.g., photos submitted by the owner, tenant certification, etc.). After December 31, 2021 (or subsequent extensions provided by HUD), the PHA must conduct the HQS inspection in accordance with the applicable time periods upon notification by a family or government official that the assisted unit does not comply with the HQS (Notice 2021-14, Waiver: HQS-6 p. 22-23).

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threatening deficiency and the owner must either correct the life- threatening deficiency within 24 hours of the PHA notification or provide documentation (e.g., text or email a photo to the PHA) that the reported deficiency does not exist through December 31, 2022 (or subsequent extensions provided by HUD). In the case of a reported non-life-threatening deficiency, the PHA will notify the owner of the reported deficiency within 30 days and the owner must either make the repair or document that the deficiency does not exist within 30 days of the PHA notification or any approved PHA extension through December 31, 2021 (or subsequent extensions provided by HUD). As is the case under the current HCV program requirements, the PHA is not required to conduct an in-person inspection to verify the repairs have been made but may rely on alternative verification methods (e.g., photos submitted by the owner, tenant certification, etc.). After December 31, 2021 (or subsequent extensions provided by HUD), the PHA must conduct the HQS inspection in accordance with the applicable time periods upon notification by a family or government official that the assisted unit does not comply with the HQS (Notice 2021-14, Waiver: HQS-6 p. 22-23).

PBV Turnover Units - The PHA is required to conduct an inspection before providing assistance to a new family in a PBV contract unit.

Conducting physical inspections of units in communities during the COVID-19 poses health risks for families, participating owners, and PHA personnel, and may run counter to public health orders, directives, or recommendations such as shelter-in-place or other social distancing practices designed to contain and reduce exposure to the disease. The PHA will allow an owner’s self-certification that the owner has no reasonable basis to have knowledge that life- threatening conditions exist in the unit or units in question to allow a new family to occupy the vacated PBV unit until December 31, 2021 (or subsequent extensions provided by HUD) or after the state of emergency is lifted, whichever is later. At minimum, the PHA will require this owner certification. For any units for which the PHA accepted an owner’s self-certification, the PHA must conduct an HQS inspection as soon as reasonably possible but no later than June 30, 2022 (or subsequent extensions provided by HUD) (Notice 2021- 14, Waiver: HQS-7, p. 23).

PBV HAP Contract, HQS Inspections to Add or Substitute Units - The PHA may amend the HAP contract to add additional PBV contract units or to substitute a different unit for a previously covered contract under its own discretion. The PBV requirements include inspecting the proposed substitute or additional unit to determine that the unit meets HQS before it may be added to the HAP contract.

emergency is lifted, whichever is later. At minimum, the PHA will require this owner certification. For any units for which the PHA accepted an owner’s self-certification, the PHA must conduct an HQS inspection as soon as reasonably possible but no later than June 30, 2022 (or subsequent extensions provided by HUD) (Notice 2021- 14, Waiver: HQS-7, p. 23).

Conducting physical inspections of units in communities during the COVID-19 poses health risks for families, participating owners, and PHA personnel, and may run counter to public health orders, directives, or recommendations such as shelter-in-place or other social distancing practices designed to contain and reduce exposure to the disease. The PHA will allow an owner’s self-certification that the owner has no reasonable basis to have knowledge that life- threatening conditions exist in the unit or units in question instead of conducting an initial inspection until December 31, 2021 (or subsequent extensions provided by HUD) or after the state of emergency is lifted, whichever is later. At minimum, the PHA will require this owner certification. For any unit added to a PBV HAP contract based upon an owner’s self-certification, the PHA must conduct an HQS inspection as soon as reasonably possible but no later than June 30, 2022. (Notice 2021-14, Waiver: HQS-8, pp. 23- 24).

HQS Quality Control Inspections - The PHA is required to conduct supervisory quality control inspections of a sampling of units under contracts. Conducting physical inspections of units in communities conducting an initial inspection until December 31, 2021 (or subsequent extensions provided by HUD) or after the state of emergency is lifted, whichever is later. At minimum, the PHA will require this owner certification. For any unit added to a PBV HAP contract based upon an owner’s self-certification, the PHA must conduct an HQS inspection as soon as reasonably possible but no later than June 30, 2022. (Notice 2021-14, Waiver: HQS-8, pp. 23- 24).

HQS Quality Control Inspections - The PHA is required to conduct supervisory quality control inspections of a sampling of units under contracts. Conducting physical inspections of units in communities during the COVID-19 poses health risks for families, participating owners, and PHA personnel, and may run counter to public health orders, directives, or recommendations such as shelter-in-place or other social distancing practices designed to contain and reduce exposure to the disease. The PHA may waive this regulatory requirement and not conduct HQS quality control inspections through December 31, 2021 (or subsequent extensions provided by HUD) or after the state of emergency is lifted, whichever is later (Notice 2021-14, Waiver: HQS-9 p. 24).

HQS Space Standards and Family Additions - The PHA is required to comply with a minimum space standard for both an HCV and PBV assisted family. The PHA recognizes the health and safety precautions that assisted families may take due to the COVID-19 pandemic. The PHA may add a member or members to the assisted household as a result of the COVID-19 pandemic even if the additional family members would result in the unit not meeting the space and security standards. This provision does not apply to an initial or new lease. A participant must not enter into a new lease for a unit that does not comply with the space and security standards.

The PHA will not require the family to move until the end of the current lease term or
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during the COVID-19 poses health risks for families, participating owners, and PHA personnel, and may run counter to public health orders, directives, or recommendations such as shelter-in-place or other social distancing practices designed to contain and reduce exposure to the disease. The PHA may waive this regulatory requirement and not conduct HQS quality control inspections through December 31, 2021 (or subsequent extensions provided by HUD) or after the state of emergency is lifted, whichever is later (Notice 2021-14, Waiver: HQS-9 p. 24).

The PHA will not require the family to move until the end of the current lease term or
May 4, 2022 or whichever is later (or subsequent extensions provided by HUD), (Notice 2021-14, Waiver: HQS-10 p. 24).

May 4, 2022 or whichever is later (or subsequent extensions provided by HUD), (Notice 2021-14, Waiver: HQS-10 p. 24).

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Deconcentration and Other Policies that Govern Eligibility, Selection, and Admissions Policies

The Anaheim Housing Authority (AHA) does not own or manage any public housing units. The AHA only administers Housing Choice Vouchers and Project-Based Vouchers.

Deconcentration Policies
The AHA has existing policies consistent with the goal of deconcentrating poverty and to encourage the participation of landlords in the following sections of the AHA’s Administrative Plan:
- 5-I.B. Briefing [24 CFR 982.301]
- 13-I.A. Owner Recruitment and Retention [HCV GB, pp. 2-4 to 2-6] - 16-II.B. Payment Standards [24 CFR 982.503; HCV GB, Chapter 7] - 17-I.A. Overview [24 CFR 983.5 and FR Notice 01/18/17] - 17-V.B. HAP Contract Requirements
- 17-II.G. Site Selection Standards
Eligibility, Selection, and Admissions Policies
- Chapter 2 of AHA’s Administrative Plan, “Fair Housing and Equal Opportunity,” outlines the policies that the agency abides by in terms of discrimination, providing accessibility, reasonable accommodations, and services in other languages - Chapter 3 of AHA’s Administrative Plan, “Eligibility,” outlines the policies the agency abides by in terms of basic eligibility and denial criteria for the programs - Chapter 4 of AHA’s Administrative Plan, “Applications, Waiting List and Tenant Selection,” outlines policies the agency abides in terms of the application process, managing the wait list, and selection from the waiting list (including preferences) - Chapter 6 of AHA’s Administrative Plan, “Income and Subsidy Standards,” outlines policies the agency abides in terms of the income and assets calculations to determine eligibility for the program
- Chapter 7 of AHA’s Administrative Plan, “Verification,” outlines policies the agency abides in terms of the verifying the applicant and tenant information as required by the program

The FY 23-24 AHA Administrative Plan can be accessed on our website:
https://www.anaheim.net/DocumentCenter/View/52935/FY-23-24-Admin-Plan-- ATTACHMENT 3 Page 1 of 1

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Financial Resources

Program Name Vouchers Allocated CY 2023 Total Funding
Housing Choice Vouchers 6,438 $110,544,804
Mainstream Vouchers 397 $5,834,278
Emergency Housing Vouchers 278 $2,671,623
Family Self-Sufficiency Coordinator N/A $62,855

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Rent Determination Policies

The Anaheim Housing Authority (AHA) does not own or manage any public housing units. The AHA only administers Housing Choice Vouchers and Project-Based Vouchers.

Chapter 6 of AHA’s Administrative Plan, “Income And Subsidy Determinations,” outlines the agency’s policies pertaining to participants’ annual income, adjusted income, and calculating their family share and PHA subsidy amounts to determine their ongoing eligibility for the program. The AHA has existing policies that governing rents charged for HCV dwelling units, including minimum rents, voucher family rent contributions, payment standard, and interim reexamination policies.
- Payment Standards:

AHA Admin Plan Section 6-III.C. “Applying Payment Standards” AHA Admin Plan Section 11-III.B. “Changes In Payment Standards and Utility Allowances”

- Minimum Rent Policies:

AHA Admin Plan 6-III.A. “Overview of Rent and Subsidy Calculations” and 6-III.B. “Financial Hardships Affecting Minimum Rent”
AHA has a $50 minimum rent policy and allows for families to request a financial hardship exemption.

- Voucher family rent contributions:

AHA Admin Plan Chapter 6 “Income And Subsidy Determinations”

- Interim Reexamination Policies:

AHA Admin Plan Chapter 11, Part II “Interim Reexaminations”

The FY 23-24 AHA Administrative Plan can be accessed on our website:
https://www.anaheim.net/DocumentCenter/View/52935/FY-23-24-Admin-Plan--

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Operation and Management
Below is a chart of the Anaheim Housing Authority’s (AHA) management organization:

The AHA Administrative Plan establishes policies for carrying out rental-assistance programs in a manner consistent with HUD requirements and local goals and objectives contained in the PHA’s agency plan.

AHA administers Housing Choice Vouchers and Project-Based Vouchers. The AHA also administers the following types of targeted funding:
- Mainstream for Persons with a Disability- Mainstream vouchers are awarded to disabled families on the HCV waiting list. AHA applies local preferences in determining the order in which Mainstream vouchers are awarded to eligible families.

- Family Unification Program (FUP) – FUP vouchers are awarded to families who are referred to AHA by the Orange County Department of Children Services. AHA applies local preferences in determining the order in which FUP vouchers are awarded to eligible families. As allowed by HUD regulations, when a FUP voucher is vacated, AHA will use the initial FUP voucher to assist families from the regular HCV waiting list.
- Non-Elderly Disabled (NEDs) Vouchers –NEDs vouchers are awarded to non- elderly disabled families on the HCV waiting list. AHA applies local preferences in determining the order in which NEDs vouchers are awarded to eligible families.

ATTACHMENT 5 Page 2 of 2

B.1 Revision of PHA Plan Elements

- Emergency Housing Voucher (EHV) - EHVs are issued to individuals and families who are homeless, at-risk of homelessness, fleeing, or attempting to flee, domestic violence, dating violence, sexual assault, stalking, or human trafficking, or were recently homeless or have a high risk of housing instability. EHVs are administered in accordance with the policies in Chapter 16, Part X of the AHA Administrative Plan.

- HUD-Veteran Affairs Supportive Housing (HUD-VASH) - HUD-VASH vouchers are issued to homeless Veterans or Veteran families and are administered in accordance with the policies in Chapter 16 Part XI of the AHA Administrative Plan.

The FY 23-24 AHA Administrative Plan can be accessed on our website:
https://www.anaheim.net/DocumentCenter/View/52935/FY-23-24-Admin-Plan-- ATTACHMENT 6 Page 1 of 6
B.3 Progress Report

PHA Goal: Expand the supply of assisted housing
During FY 2023-2024, the Anaheim Housing Authority (AHA) was awarded 42 new Stability Vouchers. Stability Vouchers are designed to direct rental assistance to Public Housing Agency’s (PHA’s) partnering with Continuums of Care and Victim Service providers to implement coordinated approaches to reduce the prevalence of homelessness, improve service engagement and promote housing stability while ensuring geographical need of assistance. Specific to Anaheim, the Anaheim Housing Authority (AHA) works with the Orange County Continuums of Care.

Finamore Place Apartment project (Manchester/Orangewood) is 100% affordable 102-unit workforce rental housing project located at 915 E. Orangewood Avenue. The project was successful in receiving a tax credit award in July 2019. Twenty of the 102 units in the project were made available to homeless families and the AHA awarded 20 Project-Based Section 8 Vouchers to assist the project. The project was completed in January 2023.

Studio 6 Permanent Supportive Housing Apartment Community (Studio 6 Motel) is a 100% affordable motel conversion project located at 1245 N. Harbor Boulevard. The Anaheim Housing Authority/City partnered with the Developer to submit an application for State of California Housing and Community Development (HCD) HOMEKEY Program funds and received an allocation in March of 2022. Studio 6 currently provides interim housing for homeless individuals. The Anaheim Housing Authority approved a Developer proposal to convert the interim housing project into an 89-unit Permanent Supportive Housing project for individuals and families who are exiting a chronically homeless condition. The AHA also approved the Developer’s request for 87 Project-Based Section 8 Vouchers to assist the project.

The Developer also received a Tax Credit Allocation from the California Tax Credit Allocation Committee (TCAC) to help finance the project in March 2023. The conversion is expected to commence in February 2024.

In December 2019, the AHA awarded 50 Project-Based Section 8 Vouchers and a $2 million dollar loan to the Salvation Army's Center of Hope Permanent Supportive Housing project. The Salvation Army's Center of Hope project includes a total of 72 units providing long-term housing solutions for individuals who are exiting a chronically homeless condition. Center of Hope includes 70 studio units that are set aside for homeless individuals, with 50% being set aside for homeless individuals with disabilities, plus two one-bedroom Manager’s units. Center of Hope will also include a 325-bed low-barrier shelter as part of a future phase, which will serve as the entry point to exit homelessness and provide a wide array of on-site supportive services. The Salvation Army received a funding award from State HCD through the County of Orange No Place Like Home Program on June 23, 2021, and a Tax Credit award from the California Tax Credit Allocation Committee on August 11, 2021, to assist with the development of the Center of Hope project. Center of Hope was completed in July 2023.

Miraflores Family Apartments (Anaheim/Midway) is a 100% affordable 86-unit workforce rental housing project located at 110 W. Midway Drive. Miraflores Family Apartments was successful ATTACHMENT 6 Page 2 of 6
in receiving a tax credit award in December of 2021. Eight of the 86 units in the project will be made available to homeless families and the AHA awarded eight Project-Based Section 8 Vouchers to assist the project. Miraflores Family Apartments is currently underway and is expected to complete construction in July of 2024.

The AHA continues to actively acquire and assemble property in the City to seek opportunities for the creation of affordable housing. Below is an update for the year 2023-24:

The property located at 212 S. Beach Boulevard, known as the Beach Boulevard (Silvermoon Site), is a Housing Authority-owned parcel of land currently being prepared for development.

The AHA released a Request for Proposals (RFP) for the site for the development of the property with a 100% affordable workforce rental project in July 2023 and received six proposals. The AHA is currently reviewing the proposals and expects to complete the Developer selection process in the Spring of 2024.

The Anaheim Housing Authority acquired the Tampico Motel located at 120 S. State College Boulevard and released an RFP for the conversion of the Tampico Motel to a 100% affordable rental special needs housing project in July 2023. The RFP process and Developer selection were completed in September 2023. The AHA is currently working with the selected Developer to finalize the design and financing plan for the project.

The property known as the Karcher/UEI site is an AHA-owned site recently assembled for the development of a multi-generational affordable housing project. The Karcher/UEI site is located on Harbor Boulevard and West Carl Karcher Way. Staff are currently assessing the development parameters of the site in preparation for an RFP process to seek development proposals. The RFP is expected to be released in the Fall of 2024.

The site known as Lemon/Santa Ana is comprised of several AHA-owned properties assembled for the development of a workforce affordable rental housing and homeownership project. The Lemon/Santa Ana site (comprised of several non-contiguous parcels) is located on Lemon and Santa Ana Streets. Staff are currently assessing the development parameters of the site in preparation for an RFP process to seek development proposals.

PHA Goal: Improve the quality of assisted housing
The City of Anaheim has continued to seek opportunities to revitalize low-income neighborhoods characterized by substandard living conditions and high calls for service, as evidenced in the Avon Dakota and Hermosa Village neighborhoods. Avon Dakota and Hermosa Village consist of multi-phased projects involving the acquisition and rehabilitation of apartment complexes and the conversion of market-rate units to long-term affordable units.

The first phase of the Avon Dakota revitalization project was completed in 2013 and included the acquisition and rehabilitation of 16 units to provide affordable housing for low-income families. The second phase of the project, consisting of 21 units for low-income families, was completed in January of 2019. Since 2014, the City has acquired ten additional properties in the Avon Dakota Neighborhood, totaling 24 units. These properties will be rehabilitated or will be part of a new construction project to provide affordable housing as part of a future phase three project.

ATTACHMENT 6 Page 3 of 6
The Hermosa Village Neighborhood Revitalization project consists of four phases completed between 2002 and 2008. Phase I project consisted of 294 units resyndicated in 2017, which included the rehabilitation of the units to meet current standards, improving on-site resident amenities, and adding four units to the project for a total of 297 units. Phase II project, consisting of 112 units, was also resyndicated in November 2019 to provide the capital to rehabilitate the Project and extend the affordability to 55 years. The Developer was successful in receiving a Tax Credit funding allocation from the California Tax Credit Allocation Committee (TCAC) and Bonds from the California Debt Limit Allocation Committee (CDLAC) in April of 2020. Phase II rehabilitation was completed in February 2022. All four phases in the Hermosa Village project consist of a total of 521 units.

As part of AHA’s efforts to increase the supply of affordable housing, the AHA utilized its own land to develop the following affordable housing projects: Finamore Place (Manchester/Orangewood), Miraflores Family Apartments (Anaheim Midway), Beach Boulevard (Silvermoon Site) and the Tampico Motel affordable housing projects. Finamore Place Apartments (Manchester/Orangewood) was completed in January 2023 and Miraflores Family Apartments is expected to be completed in July 2024. The Tampico Motel and the Beach Boulevard (Silvermoon Site) RFPs were released in July 2023 to seek development proposals for the creation of affordable housing. The AHA selected a Developer for the Tampico Motel in September 2023 and is in the process of reviewing Development proposals for the Beach Boulevard (Silvermoon Site), which is expected to be completed in the Spring of 2024.

The AHA does not own the land for the Studio 6 Permanent Supportive Housing (PSH) project or the Salvation Army’s Center of Hope Permanent Supportive Housing sites but provided funding for both projects to assist in the rehabilitation and conversion of the Studio 6 Motel to 87 PSH units and for the new construction of the 72-unit Center of Hope PSH project. The Studio 6 PSH project obtained a Tax Credit Award in March 2023 and is expected to start the conversion in February 2024. The Center of Hope PSH project was completed in July 2023.

The Center of Hope PSH and Studio 6 PSH projects will create 157 units for homeless individuals and Finamore Place (Manchester/Orangewood) and Miralflores Family Apartments (Anaheim/Midway) will create 186 new affordable housing units for working families and homeless families for a total of 343 new affordable rental units. The Tampico Motel conversion special needs project and the Beach Boulevard (Silvermoon Site) new construction workforce rental project are currently in the development pipeline and will add approximately 131 affordable rental units to the AHA’s affordable housing inventory for a total of 474 affordable units.

PHA Goal: Increase assisted housing choices
The AHA continues its mobility agreement with three other PHA’s in Orange County (the Garden Grove Housing Authority, the Orange County Housing Authority, and the Santa Ana Housing Authority) as an effort to increase housing choices throughout the county. Additionally, AHA maintains its contract with AffordableHousing.com (formerly known as GoSection8.com), a property listing service providing free listing options for landlords that allows program participants to search rental units that accept AHA rental assistance.

PHA Goal: Promote self-sufficiency of assisted households ATTACHMENT 6 Page 4 of 6
During FY 2022-2023, AHA enrolled 14 new participant families into its Family Self- Sufficiency (FSS) program and graduated three households from the program, one of which graduated completely self-sufficient and no longer needed rental assistance. Since the end of FY 2022-2023, the FSS program has continued to actively recruit families who wish to become self- sufficient and has enrolled 31 new participants and graduated four families. Of these four graduating families, three households graduated completely self-sufficient, and no longer relying on rental assistance. The FSS program currently has a grand total of 118 families utilizing this resource, and it continues to grow.

AHA continued to strengthen its relationship with different partners in the FSS program to provide participants with a wide array of resources that can help them achieve their education and career goals. AHA worked closely with multiple local colleges to expand supportive services. Fullerton College’s Extended Opportunity Program & Service (EOP) office helped with books that participants may need during their enrolled semesters. The North Orange County Community College District (NOCCCD) offers many classes to program participants that range from job-seeking skills to specialized job and educational training. They also helped program participants with transportation by offering bus passes. Golden West College (GWC) offers both the CARE and EOPS programs, which offers financial and counseling support to single parents and low-income families who are attending GWC.

AHA also continued to establish and maintain working relationships with employment related service providers. Working Wardrobes offered participants job-seeking and retaining skills.

Participants not only were able to attend job readiness workshops but also were able to receive professional clothing for interviews. AHA has also recently commenced a partnership with Cielo, a nonprofit organization that offers small business consulting services and provides educational workshops on business-related topics. This resource has been helpful to participants whose goal is to start up their own small businesses such as retail and childcare. The Anaheim Housing Authority has also established a strong referral system with the Anaheim Workforce Connection Center that provides employment assistance, training services, career planning, and many other resources for job seekers.

AHA strives to prepare its active participants for self-sufficiency and, hopefully, one day, homeownership. During FY 2022-2023, AHA strengthened its relationship with NeighborWorks Orange County and Orange County Community Housing Corporation, which specializes in realty services. They support participants with educational workshops about credit building and offer housing and budgeting counseling services. These nonprofits also offer a HUD-approved homebuyer education course, which is beneficial to all our participants who wish to become homeowners by the end of their participation in the FSS program.

Although the FSS program focuses on employment, education, and financial literacy, AHA has begun branching out to connections with other nonprofit services that may help participants overcome challenges that may be preventing them from retaining employment. Anaheim Housing continued its partnership with Boys Town to help provide supportive services to individuals who are suffering from abuse, addiction, abandonment, or violence. It is AHA’s goal to continue to grow partnerships in the medical and mental health fields during the FY 2023- 2024. AHA is currently working on a partnership and providing referrals to local nonprofit medical and mental health clinics, such as the Norooz Clinic Foundation and Southland Integrated Services.

ATTACHMENT 6 Page 5 of 6
It is AHA’s goal to continue to expand the Family Self-Sufficiency Program and make the program more accessible and visible to our Section 8 participants. The FSS program plans on streamlining the FSS enrollment process and providing participants with a straightforward method of referring themselves to this program. The FSS program will also continue to strengthen its partnerships within the community to continue to support and address the growing diverse needs of our participants. Sustaining and continuing to expand a strong referral base and ability to provide warm hand-offs will continue to contribute to participants’ progress toward achieving success and self-sufficiency.

PHA Goal: Ensure equal opportunity in housing
Fair housing and reasonable accommodation information is provided in AHA’s briefing packets and notices. Fair housing information is also provided in the lobby. In addition, program participants can utilize services from the Orange County Fair Housing Council, with whom the City has a contract with.

PHA Goal: Expand the Continuum of Care to assist the homeless population in Anaheim.

The AHA operates a homeless set aside program, which contains a preference for homeless families in Anaheim who are referred by local homeless service providers. During FY 2022- 2023, AHA accepted referrals of homeless families for up to 50% of its annual new admissions.

The City of Anaheim is an active participant in the Orange County Continuum of Care, led and coordinated by the Office of Care Coordination run out of the County Executive Office. This partnership helps ensure comprehensive, regional coordination of efforts and resources to reduce the number of people at risk of and experiencing homelessness throughout Orange County. This group serves as the regional convenor of the year-round CoC planning process and as a catalyst for the involvement of the public and private agencies that make-up the regional homeless system of care.

During FY 2022-2023, the City allocated Emergency Shelter Grant funds (which are dedicated to preventing homelessness, reducing the number of people experiencing homelessness on the street and providing services to sheltered and unsheltered households) to two agencies that provided emergency shelter services. The City spent a total of $95K in emergency shelter services. The two agencies provided emergency shelter to 155 homeless adults and children. With ESG Cares Act (ESG-CV) funds, the City funded an additional four emergency shelter programs through the first quarter and expanded the capacity of an emergency shelter program to serve people experiencing homelessness. The additional emergency shelter capacity served 98 homeless individuals in FY 2022-23. Emergency shelter services are also funded in part by State resources and the City's General Fund.

In FY 2022-23, the City allocated $30k in ESG funding towards homelessness prevention programs and funded six additional prevention programs through the first quarter with ESG-CV funds. In that year, all programs assisted 157 individuals with prevention services. The County of Orange assists people discharged from public funded institutions or systems of care (such as health care facilities, foster care or other youth facilities, or correction programs and institutions).

This assistance prevents homelessness resulting from discharge. The City will refer people discharged from public institutions to the County of Orange for additional resources.

ATTACHMENT 6 Page 6 of 6
The City also continued funding the Homeless Assistance Program - Families (HAP-F), which combines ESG and HOME funds to provide case management and rental assistance to program participants. The program focuses on assisting homeless families that have children attending Anaheim schools or ties with the community. During FY 2022-23, the HAP-F program served 34 adults and children. Of the families served, 18 households moved to permanent housing and the rest are still being assisted with case management and housing navigation. The City also invested ESG-CV funding in expanding the HAP-F program, serving an additional 17 households with case management and permanent housing placements.

In addition, the City also continued funding the Chronically Homeless Individuals Program (CHIP), operated by Mercy House Living Centers and the Illumination Foundation. The program provides individuals with case management services and tenant-based rental assistance. During FY 2022-23, the CHIPP program served 16 individual households.

ATTACHMENT 7

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C.1 Resident Advisory Board (RAB) Comments

The Anaheim Housing Authority (AHA) Resident Advisory Board (RAB) meetings that were held in person took place on Tuesday, March 5, and March 7, 2024, at 9 a.m. to discuss the FY 2023-2024 PHA Annual Plan and changes to the Administrative Plan. A virtual RAB meeting took place via Zoom on March 6, 2024, at 1:00 p.m.

An invitation letter was sent to 189 current and prospective RAB members to attend and participate in the RAB meeting. An invitation email was sent to all program participants with an email address on file with AHA.

The meeting began with an introduction of the PHA Plan and the RAB. Next, the RAB discussed the proposed policy changes and reviewed the attachments to the PHA Annual Plan.

Resident Advisory Board Members:

1. Diana Chico

2. Jeanette Brede

3. Bong Thach

4. Nam Thi Tran

5. Frederick Elliott

6. Paul Jordan

7. Mohammad Atiq Sidiqi

8. Keiko Gamez

9. Farangis Akbari, represented
by Kevin Jalalipour

10. Jesus Medina, represented by
Lilian Cruz

11. Doug Hamlin

12. Esther De Leon Hernandez

13. Jessica R Marquez

14. Mary Jones

15. Helen Lopez

16. Lydia Korionoff

17. Consuelo Balen Torres

18. Luu Tran

19. Theresa Campbell

20. Rita Blanco

21. Patricia Johnson

22. Bashir Ahmad

23. Edith Leticia Flores

24. Laura Buonaugurio

25. J.C. Weathersby

26. La Claire Duff

27. Lydia Hales

28. Antwan Frazier

29. Earlean Bailey

30. Chandra Levy

31. Mustapha Traifi

32. Edward Ho

33. Jasmine Atkins

34. Jasmin Crenshaw

35. Rosa Garcia

36. Alfred Lombardelli

37. Jordan Williams

38. David Duran

39. Teresa Posada

40. Kristy Carter

41. Jorge Alvarado

42. Robert Vega

Below are the comments and questions from the RAB at the meeting:

Stance
• While discussing the proposed policy changes, all RAB members expressed support and did not object to any proposed policy changes.

Comments
• While describing the PHA plan and its purpose, a RAB member asked what the difference is between the voucher program and affordable housing.

AHA staff explained that HUD voucher rental assistance programs are federally regulated and subsidize a portion of the rent, with the tenant paying the remainder based on their income. Affordable housing refers to housing units that are owned or managed by private entities, such as developers, that offer at below-market rates because they are typically subsidized through other government programs, such as tax incentives. Because the private entity receives a form of assistance or incentive for the ATTACHMENT 7

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affordable housing development, they, in turn, must offer below-market rates. AHA staff explained that they also have an eligibility process and income limits. AHA explained that the City of Anaheim (City) has an affordable housing interest waiting list and shared it with RAB members:
• While discussing the Section B.5. PHA Annual Plan template, a RAB asked how the external auditing company is selected.

AHA staff explained that the service was available through a Request for Proposals (RFP). Anaheim posted the RFP opportunity and invited vendors to submit their best proposals. Anaheim selected the best winner based on the scoring criteria, and KPMG was selected.

• While discussing policy changes under Section 2-I.C., an RAB commented that they have had problems with discrimination in the past and that their concerns weren’t addressed timely.

AHA staff thanked the RAB member for sharing and explained that this policy change aims to structure the process for reporting and addressing discrimination complaints. Should these policy changes pass, they will provide a more detailed step-by-step guide and hold AHA to a higher standard for providing timely responses and courses of action. AHA staff will contact the RAB member offline to discuss the discriminatory complaint.

• While discussing policy changes under Section 2-II.E., a RAB member asked for clarification on what a reasonable accommodation is, and another member asked where the contact information for the Section 504 Coordinator would be listed.

AHA staff explained that a reasonable accommodation is a change or adjustment to a program rule or policy to make the program accessible to an individual who has a disability. Staff explained that disability must be related and have a nexus to the reasonable request being made and provided several examples of common reasonable accommodation requests. Staff also explained the current process in which requests are reviewed by a board. The contact information of the Section 504 Coordinator would be listed in the letter where a reasonable accommodation is denied so that the family has the direct contact information of whom they can submit a request to review.

• While discussing Section D. of the Proposed PHA Plan, an RAB member asked what entity can assist with Fair Housing-related concerns should they have an issue arise with their landlord.

AHA staff expressed the city of Anaheim’s commitment to furthering fair housing efforts by promoting fair and equal housing opportunities for its residents. Staff shared that the city has engaged the services of the Fair Housing Council of Orange County to provide education, training, and legal services to its residents and provided the contact information to the RAB:

Fair Housing Council of Orange County
2021 E. 4th Street, Ste. 122
Santa Ana, California 92705-3912
Website - www.fairhousingoc.org
Phone - 714-569-0823
Fax - 714-835-0281
Staff also shared the goals that Anaheim set in Orange County’s Analysis of Impediments to Fair Housing Choice (AI) to overcome fair housing issues and achieve progress towards affirmatively furthering fair housing.
• While discussing policy change under 2-II.E., a RAB member asked what a disabled program participant can do if they need assistance with their daily activities.

AHA staff explained that a disabled participant may request a live-in aide through a reasonable accommodation. If approved, the AHA would grant an additional bedroom through a for the live-in ATTACHMENT 7

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aide. Staff explained the reasonable accommodation process and emphasized that there needs to be a nexus between the request and the disability. Staff also explained that a live-in aide refers to someone who permanently lives in the home and is approved to take care of a disabled individual full-time.

• While discussing policy changes under 3-III.C., the RAB supported decreasing the look-back period for certain crimes. Another RAB member asked if AHA considers several factors or actions that a person is doing to rehabilitate.

AHA staff explained that the proposed changes are intended to remove disparate impact, or unintentional, discrimination towards individuals who may be susceptible to committing crime due to homelessness or housing instability. The policy changes are intended to make the AHA’s programs most accessible by removing daunting barriers that individuals with a criminal history consistently face in obtaining and maintaining housing.

The staff also confirmed that, yes, AHA policy does allow individuals to submit any documentation about any and all rehabilitation efforts. AHA staff explained the criminal background process and the opportunities it offers for everyone to turn in the documentation they believe supports why they should be admitted into the program. They also had a one-on-one call for them to provide any explanation they’d like.

• While discussing policy changes under 3-III.C., a RAB member asked if the policy changes would apply to lifetime registered sex offenders.

AHA staff explained that the agency is prohibited from admitting individuals subject to a lifetime registration requirement under a state sex offender registration program into its program (Notice PIH 2012-28).

• While discussing the change under 16.X., a RAB member asked if there would be an impact from the transition away from using the COVID-19 waivers.

AHA staff explained that most of these waivers expired on December 31, 2021, and that AHA has already resumed business as usual following the Administrative Plan. This update will remove the language as it is no longer applicable.

• While discussing Attachment 3 – Financial Resources, a RAB member recommended adding VASH funding to the chart.

AHA staff thanked the RAB members for their recommendation and will research if this information can be added.

• While discussing Attachment 4 – Rent Determination Policies, a suggestion was made by a RAB member to improve the explanation of how income is determined.

AHA staff thanked the RAB members for their recommendation and will review the existing Briefing Packet that is provided to all new program participants and look for ways to improve the way that information is explained.

• While discussing Attachment 5 – Operation and Management, a RAB member said it would be helpful to list the grievance procedures.

AHA staff explained that Section 16 Part II of the Administrative Plan discusses in detail the policies pertaining to informal reviews (for applicants) and informal hearings (for program participants).

Informal reviews and hearings serve as formal reviews that families can request when AHA makes an adverse decision that impacts them.

• RAB members asked why it was the first time they had received an invitation and if they had to apply to be on the RAB Board. Another RAB member requested that having the plan provided to them before the meeting would provide more time to review it.

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AHA staff explained how RAB Board invitations are sent each year. Paper invitations are sent by mail to all prior RAB members, and a random sample of about 100-150 program participants, and an email invitation is sent to all program participants that have registered a valid email with the agency. All invitations contain a link to the Plan being reviewed and instructions on how to request that a paper copy of the Plan be sent directly by mail. AHA staff explained how we could not send a physical letter to everyone due to the high cost. Therefore, AHA sends an email invitation to all. If this is their first time receiving an invitation, then it is possible that this is the first time they were selected in the random sample to receive a physical letter. AHA staff explained that program participants join the RAB Board by attending a meeting such as this one and that no separate application is required. AHA staff explained that everyone attending the meeting at this time is now a RAB member, so they will be receiving a physical invitation each year moving forward.

• A RAB member asked how the PHA publicizes the opening of the public comment period for the PHA Annual Plan and if it could be extended.

AHA staff explained that a draft of the Annual PHA Plan was made available for public comment for the mandated 45-day period commencing on January 25, 2024, and ending on March 10, 2024. Public notices summarizing the purpose and content of the Annual Plan and listing the date of the public hearing were published in issues of the Orange County Register, La Opinion, and Nguoi Viet Daily News and on the AHA website on January 25, 2024. The staff member explained that the closing of the public comment period cannot be extended but clarified that their role is to address all their concerns during this meeting. The staff member also welcomes questions and comments year-round about the AHA and its Administrative Plan.

• A RAB member asked if there are any reasons why seniors may be denied rental assistance.

AHA staff explained that there are no age-specific criteria for AHA’s Section 8 rental assistance program and that admission is based on income and background eligibility. Staff further clarified that the only reason age may be considered a factor is if the family is selected for an age-specific PBV unit.

For example, few developments have a 55+ or 62+ age requirement, but even in this case, seniors would be eligible and not denied based on the age factor.

• A RAB member asked if anything can be done to change the initial 1-year lease requirement. The RAB member commented that this issue is growing and is preventing voucher holders from finding units, and owners are doing this to prevent Section 8 clients from leasing up.

AHA staff explained that the 1-year initial lease requirement is required through federal regulation 24 CFR 982.309. This means that AHA can’t change or deviate from the regulation. AHA staff explained that disabled individuals with a disability-related need or connection to a unit that offers leases for less than a year are welcome to submit a reasonable accommodation request for review. If the disability-related connection is verified, the AHA may provide an exception for a shorter lease. When the RAB member asked what could be done to change this, the staff member recommended writing to the Congressmen who are there to represent their community’s concerns in Congress. The staff member also explained that the AHA participates in several statewide and nationwide boards and organizations and can raise concerns on those platforms. Note: HUD recently removed the 1-year initial lease term for Emergency Housing Vouchers only, which may indicate that they are watching the trends on how difficult it is to lease a voucher. However, no permanent change has been announced for the Section 8 program.

• A RAB member asked when the voucher payment standards would be updated and if they could be notified. Another RAB member said they don’t feel the payment standards align with current market rate rents.

AHA staff explained that the payment standards are updated annually and are typically released in October, and we could plan to announce it in a program participant newsletter. Staff directed RAB ATTACHMENT 7

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members to the Administrative Plan payment standard methodology section, 16-II.B., which explains the elements considered in the annual analysis. Staff explained that in accordance with program rules, new payment standards are applied at the time of each family’s annual recertification. The staff member thanked the RAB member for their input on the payment standard amounts and will consider their comments during the next payment standard update.

• A RAB member asked if the housing authority can replace “PHA” with “AHA” through the Administrative Plan to make it more relatable. Another RAB member recommended changing the acronym of “HOTMA” to “HOPM.”
AHA staff thanked the RAB members for their comments. The staff member explained that the “Anaheim Housing Authority (AHA)” is introduced in the first chapters of the Administrative Plan and introduces the format in which the “PHA” acronym is used. The “PHA acronym is strategically placed so that we can incorporate HUD updates and policy changes more easily, but we will consider their comment in the next update. Regarding “HOTMA,” the staff member explained that this is the federal acronym for granted for the Housing Opportunity Through Modernization Act of 2016, and the AHA cannot change this part.

• A RAB member asked what the “VAWA” acronym stands for.

AHA staff answered that it stands for the “Violence Against Women’s Act” and clarified that the protections granted under this legislation span all, regardless of gender or sexual identity. The staff member explained that this is another acronym established by Congress.

• A RAB member asked where they can search for available units that accept Section 8 vouchers, and another member recommended that we keep an internal list.

AHA staff shared the website AffordableHousing.com and noted that it is entirely managed by landlords themselves, and AHA cannot control the listings. Staff clarified that AHA only refers clients to the website to assist their search for a unit but does not own the website. AHA staff thanked the RAB member for their comment and will review it with the agency.

• A RAB member asked how a PBV voucher can be converted into an HCV voucher.

AHA staff asked that the program participant notify their Housing Specialist so that they can be placed on an existing waiting. This waiting list converts PBV vouchers into HCV vouchers as vouchers, and funding availability allows them to do so.

• A RAB member asked if moves to another state or territory are allowed under the program.

AHA staff explained that moves are allowed under portability, which allows program participants the right to use tenant-based voucher assistance to lease a unit anywhere in the United States, providing that the unit is located within the jurisdiction of a PHA administering a tenant-based voucher program. Chapter 10 of the Administrative Plan details the rules and policies pertaining to moves.

Families that wish to move must notify their housing specialist and specify where they want to move to.

Staff also explained that the initial housing authority might keep you under their program while they live elsewhere, or the receiving housing authority may “absorb” the voucher in which they become a program participant under the receiving housing authority’s program. • There were several questions related to homelessness grouped in this section. RAB members asked what Anaheim is doing to eliminate homelessness and provide support and services to them, how it is funded, and if Anaheim is assisting in building units.

AHA staff provided an overview of the City’s efforts to address homelessness. First, staff discussed upcoming developments that will have PBV units that require homelessness as an eligibility criterion.

Then, staff explained how the Housing and Community Development Department (Department) has the Homeless Service division, which is dedicated to addressing the needs of this vulnerable ATTACHMENT 7

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population by offering shelter, food, medical care, counseling, and resources to help them regain stability in their lives. The team’s efforts include financing shelters in Anaheim and administering an agreement with BeWell OC and the Community Care Response Team (CCRT), which provides boots- on-the-ground assistance for homelessness-related services. The CCRT team works 7 a.m. to 9 p.m., seven days a week, and comprises outreach workers, mental health clinicians, nurse practitioners, and plain-clothes private safety officers. Homelessness programs are funded by the City’s General Fund, federal funds, and state funds such as the Homeless Emergency Aid Program (HEAP) and Homeless Housing, Assistance, and Prevention (HHAP) Funds. The team is also dedicated to applying for new state and federal grants for these programs.

AHA staff also discussed the projects that the Department’s Community Investment division is currently working on. Staff explained that the team is dedicated to developing land that the Housing Authority owns in a way that is most beneficial to the community. Staff also discussed how the team was successful in receiving an award through the state’s HomeKey program, through which they are currently rehabilitating what used to be Studio 6 Motel, into an 89-unit Permanent Supportive Housing project for individuals and families who are exiting a chronically homeless condition. A summary of their efforts is provided in Attachment 6, under the first and second goals. Lastly, the Department’s Affordable Housing division is responsible for planning, implementing, and managing initiatives and programs aimed at increasing the availability of affordable housing in Anaheim.

RAB members asked if any assistance was available for program participants who used to be homeless. If not, they recommended case management services so newly housed families can succeed in new settings and to think of atypical, out-of-the-box solutions.

AHA staff thanked an RAB member for their recommendation to provide supportive services for participating families that are experiencing homelessness. There was a conversation about how the transition from the streets into an apartment can be a difficult one. Staff discussed Anaheim’s new contract with CalOptima to provide referrals for supportive services. This agreement will allow the Authority to refer MediCal recipients to CalOptima’s CalAIM program, where they can receive case management. The ongoing case management can help mitigate tenancy issues and assist individuals in addressing medical and social issues so that they can remain successfully and permanently housed.

The staff took down the recommendation and will research ways the Authority can best support its program participants who have exited homelessness.

An RAB member recommended having a county-wide ombudsman to help keep everyone housed, who knows the internal operations of every agency.

AHA staff thanked an RAB member for their recommendation. AHA staff explained that there are existing homelessness collaboratives, such as the Orange County Coordinated Entry System (CES).

CES is a process designed to match individuals and families experiencing a form of hardship (such as homelessness) with available service providers that can help them. Staff took down the RAB member’s comment and will share it with the agency.
• An RAB member asked why they aren’t notified every time their caseworker changes. They also recommended that these notifications take place so that all program participants know who they should be reaching out to. Another RAB member asked why some caseworkers work out of state and if this correlated with funding shortages.

AHA acknowledged that some program participants have been recently reassigned more often than they were before. The staff member thanked the RAB member for their comment and will bring this recommendation before the agency. AHA staff explained that it's possible that the changes happened so fast that there wasn’t any time to send notifications, but acknowledged how this information is very important for program participants to know at all times.

ATTACHMENT 7

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AHA staff explained that the agency faced a staff shortage like many others during the pandemic and that the decision was made to contract with an agency to conduct case management to ensure all work was completed on time. The decision does not correlate with funding shortages, but rather, it was made to ensure that all work is completed even when a few staff are out of the office for any reason. • A RAB member recommended that briefings be made available to existing program participants and/or for those families who would like a refresher on program rules.

AHA staff thanked the RAB member for their comment and will present this request to the agency. • A RAB member recommended that an emphasis be placed on expanding the program and owner recruitment.

AHA staff thanked the RAB member for their comment and will present this request to the agency.

AHA staff acknowledged that owner recruitment and retainment are important concerns so that housing opportunities remain available for voucher holders. The staff member also explained how AHA is part of the California Housing Authority Association, who often participates in property owner conventions and expos, where they host a booth to recruit new owners into voucher programs. • A RAB member asked if there were any other spaces, other than City Council, where staff recommends that they speak to ask questions and bring up their concerns as they pertain to AHA’s programs.

There are several avenues through which program participants can share their concerns. First, program participants can talk directly with their Housing Specialists or their direct supervisors.

Program participants can also attend the Housing and Community Development Commission (HCDC) Board, which is made up of Anaheim residents who are responsible for making decisions as they pertain to AHA and the Housing and Community Development Department. The HCDC Board meets every 1st and 3rd Wednesday of each month at 5 p.m. at the Anaheim West Tower, 201 S. Anaheim Blvd.10th Floor, Anaheim, CA 92805. The staff member also welcomes questions and comments year- round about the AHA.
• Several RAB members asked if AHA’s waiting lists were opening soon.

AHA staff explained how the Section 8 Housing Choice Voucher waiting list opened for a month last year and created a list of 10,000 applicants. The agency doesn’t anticipate opening its Section 8 waiting list again for the time being. The time frame can vary significantly depending on program funding and voucher availability. The staff member also explained that several of AHA’s Project- Based Voucher (PBV) waiting lists are open and accepting questions. For additional information on PBV waiting lists, please visit: https://www.anaheim.net/761/Project-Based-Voucher-Waiting-Lists • A RAB member asked if they would receive a copy of the PHA Annual Plan.

AHA staff answered yes, all RAB members will receive a copy of the final PHA Annual Plan submitted to HUD. Staff also explained that a link to this document was provided on their invitation for this meeting, and it is also located on our AHA website under “Public Documents.” (https://www.anaheim.net/1947/Public-Documents
). A copy of all the policy changes is also sent to all program participants once they are approved by AHA’s Board of Commissioners through an email newsletter.
• AHA staff indicated that this year presents a unique situation, as an amendment will be necessary to implement the Housing Opportunity Through Modernization Act of 2016 (HOTMA) and National Standards for the Physical Inspection of Real Estate-Voucher (NSPIRE-V) policies. Consequently, the AHA will need to undergo another public comment period, gather additional feedback from the RAB Board, and seek approvals from the board again this year. AHA staff extended an invitation to all current RAB members to participate again and will inform them of the meeting dates accordingly. • A RAB member submitted a comment in writing that has been incorporated into the next page of this attachment.

ATTACHMENT 7

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ATTACHMENT 7

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Attachment 8 Page 1 of 1
C.4 Challenged Elements
If any element of the Annual PHA Plan or 5-Year PHA Plan is challenged, the Anaheim Housing Authority (AHA) must include such information as an attachment to the Annual PHA Plan or 5-Year PHA Plan with a description of any challenges to Plan elements, the source of the challenge, and the PHA’s response to the public.

The FY 24-25 AHA PHA Plan was available for public comment from January 25, 2024, through March 10, 2024. As of March 10, 2024, no elements of the proposed PHA Plan were challenged or opposed.

One public comment was received on March 7, 2024, which is included herein as Attachment 9, but it did not challenge any element proposed in this proposed PHA Plan.

One public comment was received on March 20, 2024 at the public hearing, which is included herein as Attachment 9, but it did not challenge any element proposed in this proposed PHA Plan. 1 Andrea Raez Aristondo
To:

Subject: RE: [EXTERNAL] Re: RAB Meeting Follow-Up
Hello
Thank you so much for submitting your comment and speaking to me on the phone on Friday 03/08/24! This format of comments and questions is acceptable, and there is no need to resubmit. I’ll recap the responses in this email.

The main question at hand is whether a program participant may or may not add their children to their househol d when custody is split. Section 3‐I.F. of the AHA Administrative Plan has a policies about adding dependents (children) when custody is split, and Section 11‐II.B., has policies about how program participants can add a household member. In summary, AHA policies state that a progra
m participant may add their children as part of their household if the participant has at least 50% of custody awarded or if the minor is expected to stay in the unit for more than 30 consecutive days within a 12‐month period.

Further, Section 3‐I.F. specifically states that “Acceptable verification of custody may be documentation from the court or County child welfare agency or verification of government benefits received on behalf of the minor. In the absence of such documentation, the PHA may accept, on a case by case basis, a notarized statement from the absent parent or school records ind
icating the minor has been living with the family at least a year.” Circling back to the question, the answer is: Yes, one may add their children when custody is split and a change isn’t required at the federal level to allow this. Please note, the children may only be added to one household that recei ves federal rental assistance.

Then, we clarified the requirements for receiving the dependent deduction. The dependent deduction is specific to the rental assistance program, and it is separate from the IRS’s deduction for tax purposes. As it pertains to AHA’s rental assistance programs, families only receive the depend
ent deduction for children who are listed as part of the household.

If they are not part of the household, then the parent does not receive the dependent deduction.

We also talked about the potential of moving. Please notify your housing specialist when you seek to initiate the move, and they will be able to help you thro
ugh the portability process.

The last question asks if RAB members can request meetings. Typically, this process only occurs annually when we prepare the Annual Plan for HUD. This year however, we are going to propose an amendment and will host another RAB meet
ing in a few months. You will receive an invitation. With that being said, If you have any policy recommendations at any point during the year, you may send them to me. I compile recommendations year‐round and then the housing authority reviews them when we draft the PHA Plan draft.

It was a ple
asure speaking with you. Please let me know if any other questions about the rental assistance program. I’m happy to help!
Best Regards,
Andrea Raez
From:

Sent: Thursday, March 07, 2024 7:33 PM
To: Andrea Raez Aristondo
Subject: [EXTERNAL] Re: RAB Meeting Follow‐Up
Attachment 9 Page 1 of 7

I You don't often get email from Learn why this is important Warning: This email originated from outside the City of Anaheim. Do not click links or open attachments unless you recognize the sender and are expecting the message.

Andrea,
Good Evening! I am going to apologize in advance if this email is wordy and unflowing. We are on that time constraint so bare with me on any typos/errors.

I have some questions/comments pertaining to what I was reading in this portion the proposed FY 2024-2025 AHA Administrative Plan:
3-1.F. DEPENDENT [24 CFR 5.603] defines a dependant as "a family member who is under 18 years of age or a person of any age who is a person with a disability or a full-time student, except that the following persons can never be dependents: the head of household, spouse, cohead, foster children/adults and live-in aides. Identifying each dependent in the family is important because each dependent qualifies the family for a deduction from annual income as described in Chapter 6.
11 I do not grasp why "there is not a reasonable solution" for the concept of an individual not being allowed to add their children to their voucher because they do not have 51% custody or more. Is this a change that would need to be implemented at the Federal level? It seems clear to me that this clause exists because people were not using the rooms for what they were allocated ... which is why most laws/rules exist. Do we have a means of coming up with a solution to prevent scams from happening so that honest people are still afforded the assistance we need or is this something to take up with Congress?
Not being allocated the space for our dependents is one thing, but in; 3-1.F. DEPENDENT [24 CFR 5.603], it states that "Identifying each dependent in the family is important because each dependent qualifies the family for a deduction from annual income as described in Chapter 6.11 and in "6-I1.B. DEPENDENT DEDUCTION it states that "A deduction of $480 is taken for each dependent [ 24 CFR 5.611(a)(1)1."
I do not believe that I am receiving any dependent deduction because I do not know if I am supposed to put my children on my voucher, but this section reads to me like I should have been adding them to my voucher. I have been speed reading some of these 521 pages of the proposed plan and I want to provide more feedback, but I am trying to focus on the issues of my concern since this is all new to me being my first RAB. I do want to say that most of the concerns of the fellow attendees are similar to mine so I hope that they will tackle that.

If I am incorrect about anything then please provide guidance, but should I be receiving this deduction? I can try to wrap my head around the room issue because that is more difficult to prove. But I provide my children with everything they need in that financial aspect as well from medical, dental, school, extra curricular activities, groceries, etc - everything they need. I have proof and I too can get it in writing from their father.

I was a little confused while reading about dependents because in some of the sections it makes it seem like the whole dependent and custody issue is when both parents have a voucher and want to claim the kids, or both want to claim them on taxes, but in my case it is not that type of situation. He does not have a voucher and we have our own agreements between us with everything else. If this is not the case then please disregard this paragraph.

I wanted to add these questions/comments to the proposed plan. Should I format it better or just email it like this? One more question, as members of the RAB are we allowed to have meetings when we want and make proposals or is it just an annual event?
2 Attachment 9 Page 2 of 7
3 I hope this was not too much and I hope this (and my last email) reaches you we ll because I know your inbox must be
full. Thank you in advance.

Respectfully,
On Wed, Mar 6, 2024 at 4:28 PM wrote:

Good evening,
First, I want to thank you so much for all the information that was provided and for your knowledge/patience throughout the meeting, thumbs up!
I just wanted to touch base with you to set up a time that works to further discuss what I mentioned in the meeting. I am free the rest of the week during the morning through early afternoon; I do have an in‐home appointment from 1000 to 1100 on the 8th (Friday) though. And I currently have similar availability next week from Wednesday through Friday. Once again, thank you and I look forward to hearing from you.

Respectfully,
Attachment 9 Page 3 of 7

Attachment 9 Page 4 of 7
Public Comment Received at the March 20, 2024 Public Hearing A public hearing was conducted on March 20, 2024, to receive the public’s input on this draft.

One public comment was received pertaining to existing subsidy standards. The commenter requested an increase in the number of bedrooms a family qualifies for to account for differences in generations and genders. The example provided was a grandmother and a minor child being awarded a one bedroom voucher. AHA's current policy states that one-bedroom is designated for every two persons. There was a conversation among the commenter, Commissioners, and staff about the impact that it might have to funding if additional bedrooms were awarded. It would consequently lead to AHA assisting less household under its rental assistance programs. The commenter discussed how a rent payment to match the current payment standard would benefit their landlord. There was a conversation about the CA Tenant Protection Act of 2019, limiting rent increase to 5% + local CPI, and how CA housing Authorities have been instructed to follow the legislation by Attorney General Rob Bonta and HUD.

Staff and Commissioners also commented that resources are available to prevent any unjust and illegal notice to move, such as Legal Aid, Fair Housing Council of Orange County, and the protections granted under the Tenant Protection Act of 2019.

The commenter submitted a written comment that has been incorporated into the next pages.

Exceptions to Subsidy Standards
8) In determining family unit size for a particular family, the PHA may grant an exception to its established subsidy standards if the PHA determines that the exception is justified by the age, sex, health, handicap, or relationship of family members or other personal circumstances [24 CFR 982.402(b)(8)]
The above guideline could be interpreted as follows: that a person of a different generation, such as a grandparent, should not be required to share a bedroom with his or her teenage grandchild of the opposite sex.

This type of uncommon family composition should be considered in the policy exceptions, to ensure these families are not brought into conflict with the safety standards of other agencies or non-family court’s, or become the target of a Children’s Services Investigation, which can ultimately lead to removal of the children.

Pursuant to Division 31, MPP Section 31-445, in order to be approved, all Relative & Non-Relative Extended Family Member Homes must meet the following standards, set forth in Title 22, Division 6, Chapter 9.5, Article 3.:
(3) The child does not share a bedroom with an adult unless the child is an infant. (4) No room commonly used for other purposes shall be used as a bedroom . (5) No room commonly used for other purposes or as a public or general passageway to another room is used as a bedroom. (ie: livingroom)
[Checklist of Health and Safety Standards for Approval of Family Caregiver Home §89387] Changes In Payment Standards and Utility Allowances
The family share of the rent and HAP calculations must use the correct payment standard.

Applying Payment Standards
The PHA ’s schedule of payment standards is used to calculate housing assistance payments (HAP) for HCV families.

Increases:
“ If the payment standard is increased during the term of the HAP contract, the increased payment standard will be used to calculate the monthly housing assistance payment for the family beginning on the e
ﬀective date of the family’s ﬁrst regular reexamination on or after the e ﬀective date of the increase in the payment standard” Payment Standards [24 CFR 982.505]
Attachment 9 Page 5 of 7
In this case California Civil Code §1947 prevents the owner from increasing rent more than 10% of the outdated standards. (1 bedroom at $1100, instead of 2024 standards of $2325).

In its application of outdated rent standards (2015), the maximum rent cannot exceed $1575.

This computes to a monthly loss to the owner of $750, and defies the principles of sound business practices
This is neither fair or reasonable. There is no incentive for the owner to extend my tenancy or any other residential landlord who wants to stay ahead of inflation, receive better returns on their investment, or because they have been receiving substantially less rent than Fair Market Value needed to meet expenses and future income to make up for those losses.

The only way the owner can get the Fair Market Value for her property is to terminate my tenancy, and re-rent with the current fair market value NanMcKay&Associates
On November 9, 2023 the San Francisco Housing Authority filed a complaint for damages in San Francisco Superior Court. The complaint alleges that Nan McKay & Associates failed to live up to the terms of its three-year, $32 million contract to manage the Housing Choice Voucher Program, engaged in unfair practices, including failure to effectively train housing agents.

San Francisco Superior Court, Case No: CGC 23-610309
Case Information (sftc.org)
On January 30, 2024, the Marin Housing Authority employee’s, residents and Marin County taxpayers protested and successfully pushed the Marin Board of Commissioners to not renew its contract with Nan McKay.

Marin Housing Authority workers picket over use of subcontractor (marinij.com) In my limited interactions with Nan McKay, they have demonstrated a lack of understanding, experience and training. I question if tenants are being effectively served by some faceless, anonymous person, who doesn’t care what happens when the phone call ends; that has no true knowledge of the laws and regulations nor an appropriate understanding of the consequences of their actions against tenants who rely on them to have a stable home.

On March 7, 2024, I received the Notice of Change, dated February 29, The notice of a rent increase provides a 10-day period in which I can dispute the increase. On March 11, 2024, I requested a copy of the Rent Calculation Worksheet, used to determine tenant share of rent.

Nan McKay responded by asking if I had any questions or concerns, and I again requested a printed copy of the rent calculation of which she knew nothing about. She said “I just type the numbers in and the computer calculates the rent” Nan McKay then told me that the rent increase was based on a wage increase. I requested that she provide that information in writing.

I have attached the written response. I challenge each of you to determine what the correct rent should be based on the numbers provided in Nan McKay’s written response. 2 Attachment 9 Page 6 of 7
Thank you for taking the time to hear my comments. I remain grateful for the help I have received through the housing program and appreciate all the work each of you do in order to ease the current housing crisis.

Kathleen Bias
I
3 Attachment 9 Page 7of 7

Anaheim City CouncilApril 2, 2024

Anaheim City Council
April 2, 2024