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
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.
A.
PHA Information.
A.1
PHA Name: __ Anaheim Housing Authority______________________________ PHA Code: __ CA104__________ PHA Plan for Fiscal Year Beginning: (MM/YYYY): 07/2025______________ PHA Inventory (Based on Annual Contributions Contract (ACC) units at time of FY beginning, above) Number of Housing Choice Vouchers (HCVs) ___7,113____________________________ 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.
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:
B.
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
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 5 – 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
(b) If yes, please describe:
An audit identified that in two out of 40 sampled cases of failed Housing Quality Standards (HQS) inspections, housing assistance payments (HAP) totaling $1,972 were not abated or terminated within the required timeframe.
Federal regulations require that life-threatening HQS deficiencies be corrected within 24 hours of inspection and all other deficiencies within 30 calendar days or an approved extension. If not corrected within these timelines, Public Housing Agencies (PHAs) must abate HAP or terminate the HAP contract. While the majority of inspections complied with federal regulations, the City identified an area for improvement in enforcing HQS timelines.
The findings occurred during a challenging period when the Housing Authority was enforcing new state rent and tenant protection laws while also working to strengthen its landlord base. In an effort to support customer service and maintain a strong landlord base for its programs, staff provided an additional 30-day grace period before initiating abatements, which inadvertently conflicted with AHA’s policy on what circumstances qualified for an extension. Once this was identified, management promptly addressed the issue by reminding staff of HQS enforcement regulations and reinforcing the importance of compliance. Staff also attended an NSPIRE training, to ensure adherence to housing quality standards, reflecting the AHA’s commitment to continuous improvement and regulatory compliance.
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 6 of this Plan addresses RAB 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.
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.
The FY 2025-2026 Annual PHA Plan was available for public comment from January 7, 2025, through February 21, 2025. No elements of the proposed PHA Plan have been challenged or opposed, and no public comments were received.
D.
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.
Please refer to: https://anaheim.net/DocumentCenter/View/63411/AFFH-Response
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.
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 ne w 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 62
B.1 Revision of the PHA Plan Elements
Summary of Revisions to the FY 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 2024, 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 2025-2029 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.
Revisions
The proposed FY 2025-2026 Administrative Plan, including the proposed tracked changes and revisions, is available here:
https://www.anaheim.net/DocumentCenter/View/58522/Admin-Plan-Draft?bidId=
ATTACHMENT 1 Page 2 of 62
B.1 Revision of the PHA Plan Elements
CHAPTER 3: ELIGIBILITY
Chapter Section: 3-I.F. DEPENDENT [24 CFR 5.603]
Subsection (if any): Joint Custody of Dependents
PROPOSED PHA ADMIN PLAN LANGUAGE:
Joint Custody of Dependents
PHA Policy
[…]
When more than one applicant or participant family is claiming the same dependents as family members, the family with whom the minor lived with whose been awarded at least 50% of joint legal and physical primary custody at the time of the initial examination or reexamination will be able to claim the dependents. If there is a dispute about which family should claim them, the PHA will make the determination based on available documents such as court orders, school records, or an IRS return showing which family has claimed the child for income tax purposes.
PREVIOUS PHA ADMIN PLAN LANGUAGE:
Joint Custody of Dependents
PHA Policy
[…]
When more than one applicant or participant family
is claiming the same dependents as family members,
the family with whom the minor lived with at the
time of the initial examination or reexamination will
be able to claim the dependents. If there is a dispute
about which family should claim them, the PHA will
make the determination based on available
documents such as court orders, school records, or an
IRS return showing which family has claimed the
child for income tax purposes.
ATTACHMENT 1 Page 3 of 62
B.1 Revision of the PHA Plan Elements
CHAPTER 3: ELIGIBILITY
Chapter Section: 3.I.M. LIVE-IN AIDE
PROPOSED PHA ADMIN PLAN LANGUAGE:
Live-In Aide
[…]
PHA Policy
A family’s request for a live-in aide must may be made either orally or in writing. The PHA will verify the need for a live-in aide withWritten verification will be required from a reliable, knowledgeable professional, such as a doctor, social worker, or case worker, unless the disability-related need is apparent or known to the PHAthat the live-in aide is essential for the care and well-being of the elderly, near-elderly, or disabled family member.
For continued approval, the family may be required to submit a new, written request-subject to PHA verification.
PREVIOUS PHA ADMIN PLAN LANGUAGE:
Live-In Aide
[…]
PHA Policy
A family’s request for a live-in aide must be made in
writing. Written verification will be required from a
reliable, knowledgeable professional, such as a doctor, social worker, or case worker, that the live-in aide is essential for the care and well-being of the elderly, near- elderly, or disabled family member.
CHAPTER 3: ELIGIBILITY
Chapter Section: 3-II.D. Family Consent to Release of Information [24 CFR 5.230, 24 CFR 5.232, and HCV GB, p. 5-13]
PROPOSED PHA ADMIN PLAN LANGUAGE:
PHA Policy
The revocation of consent to access financial records will result in denial of admission.
PREVIOUS PHA ADMIN PLAN
LANGUAGE:
PHA Policy
No PHA Policy Section
ATTACHMENT 1 Page 4 of 62
B.1 Revision of the PHA Plan Elements
CHAPTER 3: ELIGIBILITY
Chapter Section: 3-III.B. MANDATORY DENIAL OF ASSISTANCE
PROPOSED PHA ADMIN PLAN LANGUAGE:
Mandatory Denial of Assistance
• The PHA determines that any household member is currently engaged in the use of illegal drugs.
PHA Policy
Currently engaged in is defined as any use of illegal drugs during the previous twenty-four months. In making a determination under this policy, the PHA may choose to waive this definition for applicants who have demonstrated progress towards
reintegration and are actively engaged in and fully compliant with a treatment program. The PHA may verify this through third- party documentation.
PREVIOUS PHA ADMIN PLAN LANGUAGE:
Mandatory Denial of Assistance
• The PHA determines that any household member is
currently engaged in the use of illegal drugs.
PHA Policy
Currently engaged in is defined as any use of illegal drugs during the previous twenty-four months.
ATTACHMENT 1 Page 5 of 62
B.1 Revision of the PHA Plan Elements
CHAPTER 4: APPLICATIONS, WAITING LIST AND TENANT SELECTION Chapter Section: 4-I.B. APPLYING FOR ASSISTANCE [HCV GB, PP. 4-11 – 4-16, NOTICE PIH 2009-36]
PROPOSED PHA ADMIN PLAN LANGUAGE:
PHA Policy
Families must apply to the waiting list using an online application available on the City of Anaheim and Anaheim Housing Authority websites. The PHA may also provide a paper application during normal business hours or send a paper application form to the family via first - class mail as a reasonable accommodation.
PREVIOUS PHA ADMIN PLAN LANGUAGE:
PHA Policy
Families must apply to the waiting list using an online application available on the City of Anaheim and Anaheim Housing Authority websites. The PHA may also send a form to the family via first class mail as a reasonable accommodation.
CHAPTER 4: APPLICATIONS, WAITING LIST AND TENANT SELECTION Chapter Section: 4-II.fG. Updating the Waiting List [24 CFR 982.204] Subsection (if any): Purging the Waiting List
PROPOSED PHA ADMIN PLAN LANGUAGE:
PHA Policy
When the PHA is not actively conducting outreach, that is, no notification of housing opportunities have gone out in the last 12 month period, the waiting list will be updated every other yearas needed to ensure that all applicant information is current and timely.
PREVIOUS PHA ADMIN PLAN LANGUAGE:
PHA Policy
When the PHA is not actively conducting outreach, that is, no notification of housing opportunities have gone out in the last 12 month period, the waiting list will be updated every other year to ensure that all applicant information is current and timely.
ATTACHMENT 1 Page 6 of 62
B.1 Revision of the PHA Plan Elements
CHAPTER 5: BRIEFINGS AND VOUCHER ISSUANCE
Chapter Section: 5-I.B. BRIEFING [24 CFR 982.301]
Subsection (if any): Additional Items to Be Included in the Briefing Packet
PROPOSED PHA ADMIN PLAN LANGUAGE:
PHA Policy
The PHA will provide the following additional materials in the briefing packet:
Requirements for notifying the PHA of any changes in income or family composition
The grounds on which the PHA may terminate assistance for a participant family because of family action or failure to act The HUD pamphlet on lead-based paint entitled, “Protect Your Family from Lead in Your Home” [24 CFR 35.88]
Information on how to fill out and file a housing discrimination complaint form
The form HUD-5380 domestic violence certification form and the form HUD-5382 notice of occupancy rights, which contain information on VAWA protections for victims of domestic violence, dating violence, sexual assault, and stalking
“Is Fraud Worth It?” (form HUD-1141-OIG), which explains the types of actions a family must avoid and the penalties for program abuse “What You Should Know about EIV,” a guide to the Enterprise Income Verification (EIV) system published by HUD as an attachment to Notice PIH 2010-192017-12
Information on the FSS program – benefits of the program and how to enroll
PREVIOUS PHA ADMIN PLAN LANGUAGE:
PHA Policy
The PHA will provide the following additional materials in the briefing packet:
Information on how to fill out and file a housing discrimination complaint form
The form HUD-5380 domestic violence certification form and the form HUD-5382 notice of occupancy rights, which contain information on VAWA protections for victims of domestic violence, dating violence, sexual assault, and stalking “Is Fraud Worth It?” (form HUD-1141-OIG), which explains the types of actions a family must avoid and the penalties for program abuse
“What You Should Know about EIV,” a guide to the Enterprise Income Verification (EIV) system published by HUD as an attachment to Notice PIH 2010-19
Information on the FSS program – benefits of the program and how to enroll
ATTACHMENT 1 Page 7 of 62
B.1 Revision of the PHA Plan Elements
CHAPTER 6: INCOME AND SUBSIDY DETERMINATIONS [24 CFR Part 5, Subparts E and F; 24 CFR 982] Chapter Section: 6-I.B. HOUSEHOLD COMPOSITION AND INCOME Subsection (if any): Caretakers for a Child
PROPOSED PHA ADMIN PLAN LANGUAGE:
PHA Policy
The approval of a caretaker is at the owner and PHA’s discretion and subject to the owner and PHA’s screening criteria. If neither a parent nor a designated guardian remains in a household receiving HCV assistance, the PHA will take the following actions.
[…]
PREVIOUS PHA ADMIN PLAN LANGUAGE:
PHA Policy
If neither a parent nor a designated guardian remains in a household receiving HCV assistance, the PHA will take the following actions. […]
ATTACHMENT 1 Page 8 of 62
B.1 Revision of the PHA Plan Elements
CHAPTER 6: INCOME AND SUBSIDY DETERMINATIONS [24 CFR Part 5, Subparts E and F; 24 CFR 982] Chapter Section: 6-I.C. ANTICIPATING ANNUAL INCOME
Subsection (if any): Basis of Annual Income Projection
PROPOSED PHA ADMIN PLAN LANGUAGE:
Basis of Annual Income Projection
[…]
HUD allows PHAs to use pay-stubs to project income once EIV data has been received in such cases where the family does not dispute the EIV employer data and where the PHA does not determine it is necessary to obtain additional third-party data. The PHA may also accept a statement dated within the appropriate benefit year for fixed income sources.
PHA Policy
[…]
When tenant-provided third-party documents are used to
anticipate annual income, they will be dated within the last 60 days of the reexamination interview date. Statements dated within the appropriate benefit year will be accepted for fixed income sources.
EIV quarterly wages will not be used to project annual
income at an annual or interim reexamination.
PREVIOUS PHA ADMIN PLAN LANGUAGE:
Basis of Annual Income Projection
[…]
HUD allows PHAs to use pay-stubs to project income once EIV data has been received in such cases where the family does not dispute the EIV employer data and where the PHA does not determine it is necessary to obtain additional third-party data.
PHA Policy
[…]
When tenant-provided third-party documents are used to
anticipate annual income, they will be dated within the last 60 days of the reexamination interview date.
EIV quarterly wages will not be used to project
annual income at an annual or interim reexamination.
ATTACHMENT 1 Page 9 of 62
B.1 Revision of the PHA Plan Elements
CHAPTER 6: INCOME AND SUBSIDY DETERMINATIONS [24 CFR Part 5, Subparts E and F; 24 CFR 982 Chapter Section: 6-I.D. EARNED INCOME
Subsection (if any): Types of Earned Income Included in Annual Income
PROPOSED PHA ADMIN PLAN LANGUAGE:
Wages and Related Compensation [24 CFR 5.609(a); Notice PIH 2023-27; Notice PIH 2024-38]
The earned income of each member of the family who is 18 years of age or older, or who is the head of household or spouse/cohead regardless of age, is included in annual income. Income received as a day laborer or seasonal worker is also included in annual income, even if the source, date, or amount of the income varies [24 CFR
5.609 (b)(24)].
Earned income means income or earnings from wages, tips, salaries, other employee compensation, and net income from self-
employment. Earned income does not include any pension or annuity, transfer payments (meaning payments made or income received in which no goods or services are being paid for, such as welfare, social security, and governmental subsidies for certain benefits), or any cash or in-kind benefits [24 CFR 5.100].
Unearned income means any annual income, as calculated under 24 CFR § 5.609, that is not earned income.
A day laborer is defined as an individual hired and paid one day at a time without an agreement that the individual will be hired or work again in the future [24 CFR 5.603(b)]. Income earned as a day laborer is not considered nonrecurring income.
A seasonal worker is defined as an individual who is hired into a short-term position ( e.g., for which the customary employment
PREVIOUS PHA ADMIN PLAN LANGUAGE:
Wages and Related Compensation
The full amount, before any payroll deductions, of wages and salaries, overtime pay, commissions, fees, tips and bonuses, and other compensation for personal services is included in annual income [24 CFR 5.609(b)(1)].
PHA Policy
For persons who regularly receive bonuses or commissions, the PHA will verify and then average amounts received for the two years preceding admission or reexamination. If only a one-year history is available, the PHA will use the prior year amounts. In either case the family may provide, and the PHA will consider, a credible justification for not using this history to anticipate future bonuses or commissions. If a new employee has not yet received any bonuses or commissions, the PHA will count only the amount estimated by the employer. The file will be documented appropriately.
ATTACHMENT 1 Page 10 of 62
B.1 Revision of the PHA Plan Elements
period for the position is six months or fewer) and the employment begins about the same time each year (such as summer or winter).
Typically, the individual is hired to address seasonal demands that arise for the particular employer or industry [24 CFR 5.603(b)].
Some examples of seasonal work include employment limited to holidays or agricultural seasons. Seasonal work may include but is not limited to employment as a lifeguard, ballpark vendor, holiday retail worker, or snowplow driver [Notice PIH 2023-27]. Income earned as a seasonal worker is not considered nonrecurring income.
PHA Policy
The PHA will include in annual income the full amount, before any payroll deductions, of wages and salaries, overtime pay, commissions, fees, tips and bonuses, and other compensation, before any payroll deductions for personal services is included in annual income [24 CFR 5.609(b)(1)].
For persons who regularly receive bonuses or commissions, the PHA will verify, and then average amounts received for the two years preceding admission or reexamination. If only a one-year history is available, the PHA will use the prior year amounts. In either case the family may provide, and the PHA will consider, a credible justification for not using this history to anticipate future bonuses or commissions. If a new employee has not yet received any bonuses or commissions, the PHA will count only the amount estimated by the employer. The file will be documented
appropriately.
ATTACHMENT 1 Page 11 of 62
B.1 Revision of the PHA Plan Elements
CHAPTER 6: INCOME AND SUBSIDY DETERMINATIONS [24 CFR Part 5, Subparts E and F; 24 CFR 982 Chapter Section: 6-I.F. BUSINESS INCOME [24 CFR 5.609(B)(2)] Subsection (if any): Business Expenses
PROPOSED PHA ADMIN PLAN LANGUAGE:
PHA Policy
PHA Policy
To determine business expenses that may be deducted from gross income, the PHA will use current applicable Internal Revenue Service (IRS) rules for determining allowable business expenses [see IRS Publication 535], unless a topic is addressed by HUD regulations or guidance as described below.
Business expenses must be directly related in nature to the family member’s business.
PREVIOUS PHA ADMIN PLAN LANGUAGE:
PHA Policy
To determine business expenses that may be deducted from gross income, the PHA will use current applicable Internal Revenue Service (IRS) rules for determining allowable business expenses [see IRS Publication 535], unless a topic is addressed by HUD regulations or guidance as described below.
ATTACHMENT 1 Page 12 of 62
B.1 Revision of the PHA Plan Elements
CHAPTER 6: INCOME AND SUBSIDY DETERMINATIONS [24 CFR Part 5, Subparts E and F; 24 CFR 982 Chapter Section: 6-I.L. NONRECURRING INCOME [24 CFR 5.609(b)(24); Notice PIH 2023-27; AND NOTICE PIH 2024-38] Subsection (if any):
PROPOSED PHA ADMIN PLAN LANGUAGE:
Income amounts excluded under this category may include, but are not limited to:
• Nonrecurring payments made to the family or to a third party on behalf of the family to assist with utilities;
PHA Policy
Nonrecurring payments made to the family or to a third party on behalf of the family to assist with utilities are excluded from the annual income.
However, if a family repeatedly says that a payment is nonrecurring but the PHA can establish a pattern of the payments actually being nonrecurring year after year, the PHA will no longer consider the payments nonrecurring.
PREVIOUS PHA ADMIN PLAN LANGUAGE:
PHA Policy
N/A
ATTACHMENT 1 Page 13 of 62
B.1 Revision of the PHA Plan Elements
CHAPTER 6: INCOME AND SUBSIDY DETERMINATIONS [24 CFR Part 5, Subparts E and F; 24 CFR 982 Chapter Section: 6-II.D. HEALTH AND Medical CARE Expenses Deduction [24 CFR 5.611(a)(3)(i) and 5.603(b); NOTICE PIH 2023-27; AND NOTICE PIH 2024-38]
Subsection (if any): Definition of Medical Expenses
PROPOSED PHA ADMIN PLAN LANGUAGE:
[…]
Although HUD revised the definition of health and medical care expenses to reflect the Internal Revenue Service (IRS) general definition of medical expenses, HUD is not permitting PHAs to specifically align their policies to IRS Publication 502. PHAs must review each expense to determine whether it is eligible in accordance with HUD’s definition.
While PHA policies may not specifically align with IRS Publication 502, HUD recommends PHAs use it as a standard for determining allowable expenses, and the PHA may list examples of allowable expenses in their policy provided they comply with HUD’s definition at 24 CFR 5.603.
The PHA may not define health and medical care expenses more narrowly than the regulation.
PHA Policy
The PHA will use the most current IRS Publication 502, Medical and Dental Expenses, will be used to determine the costs that as a standard for determining if expenses claimed by eligible families qualify as health and medical expenses.
Summary of Allowable Medical Expenses fromcare expenses. However, under no circumstances will the PHA deduct any expenses listed in IRS Publication 502 that do not conform with HUD’s definition of health and medical care expenses.
The most current IRS Publication 502, Medical and Dental Expenses, will be used to determine the costs that qualify as medical expenses.
PREVIOUS PHA ADMIN PLAN
LANGUAGE:
PHA Policy
The most current IRS Publication
502, Medical and Dental Expenses,
will be used to determine the costs
that qualify as medical expenses.
ATTACHMENT 1 Page 14 of 62
B.1 Revision of the PHA Plan Elements
CHAPTER 6: INCOME AND SUBSIDY DETERMINATIONS [24 CFR Part 5, Subparts E and F; 24 CFR 982 Chapter Section: 6-II.D. HEALTH AND Medical CARE Expenses Deduction [24 CFR 5.611(a)(3)(i) and 5.603(b); NOTICE PIH 2023-27; AND NOTICE PIH 2024-38]
Subsection (if any): Families That Qualify for Both Health and Medical and Disability Assistance Expenses
PROPOSED PHA ADMIN PLAN LANGUAGE:
PHA Policy
This policy applies only to families in which the head, spouse, or cohead is 62 or older or is a person with disabilities.
When expenses anticipated by a family could be defined as either a health and medical care or disability assistance expenses, the PHA will consider them health and medical care expenses unless it is clear that the expenses are incurred exclusively to enable a person with disabilities to work.
PREVIOUS PHA ADMIN PLAN LANGUAGE:
PHA Policy
This policy applies only to families in which the head, spouse, or cohead is 62 or older or is a person with disabilities.
When expenses anticipated by a family could be defined as either medical or disability assistance expenses, the PHA will consider them medical expenses unless it is clear that the expenses are incurred exclusively to enable a person with disabilities to work.
ATTACHMENT 1 Page 15 of 62
B.1 Revision of the PHA Plan Elements
CHAPTER 6: INCOME AND SUBSIDY DETERMINATIONS [24 CFR Part 5, Subparts E and F; 24 CFR 982 Chapter Section: 6-III.C. APPLYING PAYMENT STANDARDS [24 CFR 982.505] Subsection (if any): Changes in Payment Standards- Increases [T and Notice PIH 2024-34]
PROPOSED PHA ADMIN PLAN LANGUAGE:
For new HAP contracts, the PHA applies the payment standard in effect at the time of HAP contract execution.
The increased payment standard will be applied no later than the earliest of:
• The effective date of an increase in the gross rent that would result in an increase in the family share; PHA Policy
This would only apply to rent increases, as the PHA will continue to apply utility allowances at the first annual reexamination that is effective after the utility allowance is adopted in accordance with policies in Chapter 6-III.D.
• The family’s first regular or interim reexamination; or • One year following the effective date of the increase in the payment standard amount.
The PHA may adopt a policy to apply a payment standard increase at any time earlier than the date calculated above as long as the policy is included in the administrative plan and applied consistently to all families [24 CFR 982.505(c)(5)].
PHA Policy
The PHA may, at its discretion and subject to available funding, adopt payment standard increases earlier than the date required by the regulations.
PREVIOUS PHA ADMIN
PLAN LANGUAGE:
PHA Policy
N/A
CHAPTER 6: INCOME AND SUBSIDY DETERMINATIONS [24 CFR Part 5, Subparts E and F; 24 CFR 982 Chapter Section: 6-III.C. APPLYING PAYMENT STANDARDS [24 CFR 982.505] Subsection (if any): Changes in Payment Standards- Changes in Family Unit Size (Voucher Size) [24 CFR 982.505(c)(6) and Notice PIH 2024-34]
PROPOSED PHA ADMIN PLAN LANGUAGE:
PREVIOUS PHA ADMIN PLAN
LANGUAGE:
ATTACHMENT 1 Page 16 of 62
B.1 Revision of the PHA Plan Elements
Irrespective of any increase or decrease in the payment standard, if the family unit size increases or decreases during the HAP contract term, the new family unit size must be used to determine the payment standard immediately but no later than the family’s first regular reexamination following the change in family unit sizefor the family beginning at the family’s first regular reexamination following the change in family unit size.
PHA Policy
If the family size (voucher size) changes during the term of a HAP contract, the new family size will be used to determine the payment standard immediately.
PHA Policy
N/A
CHAPTER 6: INCOME AND SUBSIDY DETERMINATIONS [24 CFR Part 5, Subparts E and F; 24 CFR 982 Chapter Section: 6-III.D. APPLYING UTILITY ALLOWANCES [24 CFR 982.517] Subsection (if any): Flat Fees [24 CFR 982.517(b)(2)(iii)]
ATTACHMENT 1 Page 17 of 62
B.1 Revision of the PHA Plan Elements
PROPOSED PHA ADMIN PLAN LANGUAGE:
The PHA may base its utility allowance payments on actual flat fees charged by an owner for utilities that are billed directly by the owner, but only if the flat fee charged by the owner is no greater than the PHA’s applicable utility allowance for the utilities covered by the fee. If the owner charges a flat fee for some but not all utilities, the PHA must pay a separate allowance for any tenant-paid utilities not covered in the flat fee.
PHA Policy
The PHA will not base utility allowance payments on flat fees charged by the owner.
PREVIOUS PHA ADMIN PLAN
LANGUAGE:
PHA Policy
N/A
CHAPTER 7: VERIFICATION [24 CFR 982.516, 24 CFR 982.551, 24 CFR 5.230, Notice PIH 2018-18] Chapter Section: 7-I.A. Family Consent to Release Information [24 CFR 982.516 AND 982.551, 24 CFR 5.230] Subsection (if any): Form HUD-9886-A [24 CFR 5.230(b)(1), b(2), (c)(4), and (c)(5); and Notice PIH 2023-27]
PROPOSED PHA ADMIN PLAN LANGUAGE:
[…]
The PHA has the discretion to establish policies around when family members must sign consent forms when they turn 18.
PHAs must establish these policies stating when family members will be required to sign consent forms at intervals other than at reexamination.
PHA Policy
Family members turning 18 years of age between annual recertifications will be required to sign the required Consent to the Release of Information Form HUD-9886-A at the family’s next annual reexamination, unless the PHA opts to collect the form earlier, at its discretion, following the individual’s 18th birthday.
PREVIOUS PHA
ADMIN PLAN
LANGUAGE:
PHA Policy
N/A
ATTACHMENT 1 Page 18 of 62
B.1 Revision of the PHA Plan Elements
CHAPTER 7: VERIFICATION [24 CFR 982.516, 24 CFR 982.551, 24 CFR 5.230, Notice PIH 2018-18] Chapter Section: 7-I.A. Family Consent to Release Information [24 CFR 982.516 AND 982.551, 24 CFR 5.230] Subsection (if any): Penalties for Failing to Consent [24 CFR 5.232, Notice PIH 2023-27, and Notice PIH 2024-38]
PROPOSED PHA ADMIN PLAN LANGUAGE:
[…]
Revocation of consent or refusal to sign the consent forms prohibits the PHA from requesting and accessing income information and financial records, including pulling EIV reports and using the EIV data to verify income (although the data matches between HUD and other agencies will continue to occur automatically if the family is not terminated from the program). The PHA will not be able to process interim or annual reexaminations of income, including when a family’s income decreases and the family requests an interim reexamination to decrease tenant rent, without the family’s executed consent form(s). The PHA must explain to families the consequences of revoking their consent and notify their local HUD office of a family’s revocation of consent [Notice PIH 2023-27].
PHA Policy
The PHA has established a policy that revocation of consent to access financial records will result in denial of admission or termination of assistance in accordance with PHA policy.
In order for a family to revoke their consent, the family must submit written notice using a form provided by the PHA. The form provided will explain the potential consequences of this action.
The PHA will grant the family 10 business days to return the form. This notice will also offer the family an opportunity to reestablish consent to access financial records before the effective date of the denial or termination, as applicable.
If the family does not return the revocation form by the due date, the PHA will send a denial or proposed termination for not complying with the Family Obligation of supplying information that the PHA determines to be necessary listed in Chapter 5 (in accordance with Chapters 3 or 12, as applicable).
Within 10 business days of the date the family provides written notice, the PHA will send the family a notice of denial or proposed termination (in accordance with Chapters 3 or 12, as applicable). Additionally, the PHA will notify their local HUD office of the revocation.
PREVIOUS PHA ADMIN
PLAN LANGUAGE:
PHA Policy
N/A
ATTACHMENT 1 Page 19 of 62
B.1 Revision of the PHA Plan Elements
CHAPTER 7: VERIFICATION [24 CFR 982.516, 24 CFR 982.551, 24 CFR 5.230, Notice PIH 2018-18] Chapter Section: 7-I.B. Overview of Verification Requirements Subsection (if any): Use of Other Programs’ Income Determinations [24 CFR 5.609(c)(3); Notice PIH 2023-27; HUD Letter 02/23/2024]
PROPOSED PHA ADMIN PLAN LANGUAGE:
[…]
PHA Policy
When available and applicable, the PHA may accept the Safe Harbor determinations of income of the other programs listed above at annual reexamination to determine the family’s total annual income.
The PHA will still require third-party verification of all deductions such as the health and medical care expense or childcare expense deductions. Further, if the family is eligible for and claims the disability assistance expense or childcare expense deductions, where applicable, the PHA will obtain third-party verification of the amount of employment income of the individual(s) enabled to work in order to cap the respective expenses as required.
Prior to using any Safe Harbor determination from another program, the PHA will ask the family if they agree with the income amounts listed. If the family disputes the income amounts on the Safe Harbor determination, the PHA will obtain third-party verification of all sources of income and assets (as applicable).
The PHA will not accept income determinations made under the Earned Income Tax Credit (EITC) program.
The PHA will not accept other programs’ determinations of income for any new admission or interim reexamination
In order to be acceptable, the income determination must:
Be dated within 12 months of the dates listed above;
State the family size
Be for the entire family (i.e., the family members listed in the documentation must match the family’s composition in the assisted unit, except for household members); and
PREVIOUS PHA ADMIN
PLAN LANGUAGE:
PHA Policy
N/A
ATTACHMENT 1 Page 20 of 62
B.1 Revision of the PHA Plan Elements
Must state the amount of the family’s annual income.
The determination need not list each source of income individually. If the PHA does not receive any acceptable income determination documentation or is unable to obtain documentation, then the PHA will revert to third-party verification of income for the family.
When families present multiple verifications from the same or different acceptable Safe Harbor programs, the PHA will use the most recent income determination, unless the family presents acceptable evidence that the PHA should consider an alternative verification from a different Safe Harbor source.
When the PHA uses a Safe Harbor income determination from another program, and the family’s income subsequently changes, the family is required to report the change to the PHA timely.
Depending on when the change occurred, the change may or may not impact the PHA’s calculation of the family’s total annual income. Changes that occur between the time the PHA receives the Safe Harbor documentation, and the effective date of the family’s annual reexamination will not be considered. If the family has a change in income that occurs after the annual reexamination effective date, the PHA will conduct an interim reexamination if the change meets the requirements for performing an interim reexamination as outlined in Chapter 11. In this case, the PHA will use third- party verification to verify the change.
ATTACHMENT 1 Page 21 of 62
B.1 Revision of the PHA Plan Elements
CHAPTER 7: VERIFICATION [24 CFR 982.516, 24 CFR 982.551, 24 CFR 5.230, Notice PIH 2018-18] Chapter Section: 7-I.B. Overview of Verification Requirements Subsection (if any): Requirements for Acceptable Documents [FR Notice 02/14/2023; Notice PIH 2023-27 (J.5.a); HUD Letter 02/23/24; PIH HOTMA FAQs 02/22/24]
PROPOSED PHA ADMIN PLAN LANGUAGE:
Requirements for Acceptable Documents [FR Notice 02/14/2023; Notice PIH 2023-27 (J.5.a); HUD Letter 02/23/24; PIH HOTMA FAQs 02/22/24]
PHA Policy
Any documents used for verification must be the original (not photocopies) and generally must be dated within 60 of receipt by the PHA, or up to 120 days if they are the most current verifications availabledays of the date they are provided to the PHA. Statements dated within the appropriate benefit year are acceptable for fixed sources of income. The documents must not be damaged, altered or in any way illegible.
Print-outs from Web pages are considered original documents.
The PHA staff member who views the original document must make a photocopy, annotate the copy with the name of the person who provided the document and the date the original was viewed, and sign the copy.
Any family self-certification must be made in a format acceptable to the PHA.
PREVIOUS PHA ADMIN
PLAN LANGUAGE:
Requirements for
Acceptable Documents
PHA Policy
Any documents
used for verification
must be the original
(not photocopies)
and generally must
be dated within 60
days of the date they
are provided to the
PHA. The
documents must not
be damaged, altered
or in any way
illegible.
Print-outs from Web
pages are
considered original
documents.
ATTACHMENT 1 Page 22 of 62
B.1 Revision of the PHA Plan Elements
The PHA staff
member who views
the original
document must
make a photocopy,
annotate the copy
with the name of the
person who
provided the
document and the
date the original
was viewed, and
sign the copy.
Any family self-
certification must be made
in a format acceptable to
the PHA.
ATTACHMENT 1 Page 23 of 62
B.1 Revision of the PHA Plan Elements
CHAPTER 7: VERIFICATION [24 CFR 982.516, 24 CFR 982.551, 24 CFR 5.230, Notice PIH 2018-18] Chapter Section: 7-I.C. UP-FRONT INCOME VERIFICATION (UIV) Subsection (if any): EIV Income Reports
PROPOSED PHA ADMIN PLAN LANGUAGE:
PHA Policy
The PHA will obtain income reports for annual reexaminations on a monthly basis. Reports will be generated as part of the regular reexamination process.
[…]
When the PHA determines through income reports and third-party verification that a family has concealed or under-reported income, corrective action will be taken pursuant to the policies in Chapter 14, Program Integrity.
However, the PHA will not use income information in EIV at annual reexamination when Safe Harbor verification is used to determine a family’s income.
PREVIOUS PHA ADMIN PLAN LANGUAGE:
PHA Policy
The PHA will obtain income reports for annual reexaminations on a monthly basis. Reports will be generated as part of the regular reexamination process.
[…]
Income reports will be retained in participant files with the applicable annual or interim reexamination documents.
When the PHA determines through income reports and third-party verification that a family has concealed or under-reported income, corrective action will be taken pursuant to the policies in Chapter 14, Program Integrity.
ATTACHMENT 1 Page 24 of 62
B.1 Revision of the PHA Plan Elements
CHAPTER 7: VERIFICATION [24 CFR 982.516, 24 CFR 982.551, 24 CFR 5.230, Notice PIH 2018-18] Chapter Section: 7-I.C. UP-FRONT INCOME VERIFICATION (UIV) Subsection (if any): EIV Discrepancy Reports
PROPOSED PHA ADMIN PLAN LANGUAGE:
PHA Policy
Policy removed.
PREVIOUS PHA ADMIN PLAN LANGUAGE:
PHA Policy
The PHA will generate the Income Discrepancy Report at least once every 6 months.
When the PHA determines that a participant appearing on the Income Discrepancy Report has not concealed or under-reported income, the participant’s name will be placed on a list of “false positive” reviews. To avoid multiple reviews in this situation, participants appearing on this list will be eliminated from discrepancy processing until a subsequent interim or annual reexamination has been completed.
The PHA will review the EIV discrepancy tab during processing of annual and interim reexaminations.
When it appears that a family may have concealed or under-reported income, the PHA will request written third-party verification of the income in question.
When the PHA determines through file review and third-party verification that a family has concealed or under-reported income, corrective action will be taken pursuant to the policies in Chapter 14, Program Integrity.
ATTACHMENT 1 Page 25 of 62
B.1 Revision of the PHA Plan Elements
CHAPTER 7: VERIFICATION [24 CFR 982.516, 24 CFR 982.551, 24 CFR 5.230, Notice PIH 2018-18] Chapter Section: 7-I.D. Third- Party Written and Oral Verification) Subsection (if any): Written Third-Party Verification [Notice PIH 2010-19 and Notice PIH 2018-18
PROPOSED PHA ADMIN PLAN LANGUAGE:
PHA Policy
The PHA’s first request for written third-party verifications will grant the household 10 business days to respond. If the verifications are not received by the first due date, the PHA will issue a second and final request granting the household 5 business days to respond. If the family is unable to return the requested verifications within the 15 business days for good cause, the PHA will move to the next level of the hierarchy.
Any third-party documents provided by the family must be dated within 60 days of the PHA request date. However, for fixed-income sources, a statement dated within the appropriate benefit year is acceptable documentation.
The PHA may reject documentation provided by the family if the document is not an original, if the document appears to be forged, or if the document is altered, mutilated, or illegible. If the PHA determines that third-party documents provided by the family are not acceptable, the PHA will explain the reason to the family and request additional documentation from the family or may use a lower form of verification such as a written third-party verification form.
When pay stubs are used,As verification of earned income, the PHA will require the family to provide request pay stubs covering the 60-day period prior to the PHA’s request. At its discretion, the PHA may request up to 12 consecutive months of additional pay stubs or payroll records if needed to determine income due to the family's circumstances (e.g., irregular/fluctuating schedule, seasonal employment, inconsistent work hours, etc.) (refer to 7-
I.A.).
PREVIOUS PHA ADMIN PLAN LANGUAGE:
PHA Policy
The PHA’s first request for written third-party
verifications will grant the household 10 business
days to respond. If the verifications are not
received by the first due date, the PHA will issue a
second and final request granting the household 5
business days to respond. If the family is unable to
return the requested verifications within the 15
business days for good cause, the PHA will move
to the next level of the hierarchy.
Any third-party documents provided by the family
must be dated within 60 days of the PHA request
date.
If the PHA determines that third-party documents
provided by the family are not acceptable, the PHA
will explain the reason to the family and request
additional documentation.
As verification of earned income, the PHA will
request pay stubs covering the 60-day period prior
to the PHA’s request.
ATTACHMENT 1 Page 26 of 62
B.1 Revision of the PHA Plan Elements
CHAPTER 7: VERIFICATION [24 CFR 982.516, 24 CFR 982.551, 24 CFR 5.230, Notice PIH 2018-18] Chapter Section: 7-I.E. SELF-CERTIFICATION
PROPOSED PHA ADMIN PLAN LANGUAGE:
PHA Policy
The self-certification must be made in a format acceptable to the PHA and must be signed by the family member whose
information or status is being verified. The self-certification may be provided in the annual reexamination packet or on a form provided by the PHA.
PREVIOUS PHA ADMIN PLAN LANGUAGE:
PHA Policy
The self-certification must be made in a format acceptable to the PHA and must be signed by the family member whose
information or status is being verified.
ATTACHMENT 1 Page 27 of 62
B.1 Revision of the PHA Plan Elements
CHAPTER 7: VERIFICATION [24 CFR 982.516, 24 CFR 982.551, 24 CFR 5.230, Notice PIH 2018-18] Chapter Section: 7-II.A. VERIFICATION OF LEGAL IDENTITY
PROPOSED PHA ADMIN PLAN LANGUAGE:
PHA Policy
The PHA will require families to furnish verification of legal identity for each household member. Generally, the PHA will require a birth Certification for identification purposes. Document submitted by a family must be legible.
In cases where the requested document is not available, the PHA may accept documents listed below.
Verification of Legal Identity for
Adults
Verification of Legal
Identity for Children
Certificate of birth, naturalization
papers
Current, valid driver's license or
Department of Motor Vehicles
identification card
U.S. military discharge (DD 214)
A cCurrent U.S. passport (not
expired)
EmployerCurrent government
employer identification card with
picture
Certificate of birth
Adoption papers
Custody agreement
Health and Human Services
ID
Certified Sschool records
PREVIOUS PHA ADMIN PLAN LANGUAGE:
PHA Policy
The PHA will require families to furnish verification of legal identity for each household member. Generally, the PHA will require a birth Certification for identification purposes. Document submitted by a family must be legible.
In cases where the requested document is not available, the PHA may accept documents listed below.
If a document submitted by a family is illegible or otherwise questionable, more than one of these documents may be required.
If none of these documents can be provided and at the PHA’s discretion, a third party who knows the person may attest to the person’s identity. The certification
ATTACHMENT 1 Page 28 of 62
B.1 Revision of the PHA Plan Elements
Church issued baptismal certificate
(may require additional
documentation or certification if this
is the only documentation available)
If a document submitted by a family is illegible for any reason or otherwise questionable, more than one of these documents may be required.
If none of these documents can be provided and at the PHA’s discretion, a third party who knows the person may attest to the person’s identity. The certification must be provided in a format acceptable to the PHA and be signed in the presence of a PHA representative or PHA notary public.
Legal identity will be verified on an as needed basisfor all applicants at the time of eligibility determination and in cases where the PHA has reason to doubt the identity of a person representing themselves to be a participant.
must be provided in a format acceptable to the PHA and be signed in the presence of a PHA representative or PHA notary public.
Legal identity will be verified on an as needed basis.
ATTACHMENT 1 Page 29 of 62
B.1 Revision of the PHA Plan Elements
CHAPTER 7: VERIFICATION [24 CFR 982.516, 24 CFR 982.551, 24 CFR 5.230, Notice PIH 2018-18] Chapter Section: 7-II.B. Social Security Numbers [24 CFR 5.216 and, Notice PIH 2010-32018-24] Subsection (if any):
PROPOSED PHA ADMIN PLAN LANGUAGE:
[…]
PHA Policy
Once an individual’s status is classified as “verified” in HUD’s EIV system, the PHA will retain the documents in the applicant and participant file as evidence of social security numbers.
PREVIOUS PHA ADMIN PLAN LANGUAGE:
PHA Policy
Once an individual’s status is classified as “verified” in HUD’s EIV system, the PHA will retain the documents in the applicant and participant file.
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CHAPTER 7: VERIFICATION [24 CFR 982.516, 24 CFR 982.551, 24 CFR 5.230, Notice PIH 2018-18] Chapter Section: 7-II.E. Verification of Student Status Subsection (if any): Restrictions on Assistance to Students Enrolled in Institutions of Higher Education
PROPOSED PHA ADMIN PLAN LANGUAGE:
PHA Policy
PHA Policy
In accordance with the verification hierarchy described in Section 7-1.B, the PHA will determine whether the student is exempt from the restrictions in 24 CFR 5.612 by verifying any one of the following exemption criteria of a full time student as defined in Section 3-II.E unless the student satisfies the criteria of a vulnerable youth.:
The student is enrolled at an educational institution that does not meet the definition of institution of higher
education in the Higher Education Act of 1965 (see section Exhibit 3-2).
The student is at least 24 years old.
The student is a veteran, as defined in section 3-II.E.
The student is married.
The student has at least one dependent child, as defined in section 3-II.E.
The student is a person with disabilities, as defined in section 3-II.E, and was receiving assistance prior to
November 30, 2005.
PREVIOUS PHA ADMIN PLAN LANGUAGE:
PHA Policy
PHA Policy
In accordance with the verification hierarchy described in Section 7-1.B, the PHA will determine whether the
student is exempt from the restrictions in 24 CFR 5.612 by verifying any one of the following exemption criteria of a full time student as defined in Section 3-II.E unless the student satisfies the criteria of a vulnerable youth.
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CHAPTER 7: VERIFICATION [24 CFR 982.516, 24 CFR 982.551, 24 CFR 5.230, Notice PIH 2018-18] Chapter Section: 7-II.E. Verification of Student Status Subsection (if any): Independent Student
PROPOSED PHA ADMIN PLAN LANGUAGE:
PHA Policy
The PHA will verify a student’s independence from his/hertheir parents to determine that the student’s parents’ income is not relevant for determining the student’s eligibility by doing all of the following:
Either Rreviewing and verifying previous address information to determine whether the student has established a household separate from his/hertheir parents for at least one year, or reviewing and verifying documentation relevant to determining whether the student meets the U.S. Department of Education’s definition of independent student (see Section 3-II.E)
Reviewing the student’s prior year income tax returns to verify whether a parent has claimed the student as a dependentis independent or verifying the student meets the U.S. Department of Education’s definition of independent student (see Section 3-II.E)
Requesting and obtaining written certification directly from the student’s parents identifying the amount of support they will be providing to the student, even if the amount of support is $0., except in cases in which the PHA determines that the student is a vulnerable youth (see Section 3-II.E)
Verifying documentation relevant to determining whether the student meets the definition of a vulnerable youth (see Section 3-II.E), such a determination is all that is necessary determine that the person is an independent student for the purposes of using only the student's income for determining eligibility for assistance
PREVIOUS PHA ADMIN PLAN LANGUAGE:
PHA Policy
The PHA will verify a student’s independence from his/her parents to determine that the student’s parents’ income is not relevant for determining the student’s eligibility by doing all of the following:
Reviewing and verifying previous address information to determine whether the student has established a household separate from his/her parents for at least one year or reviewing and verifying documentation relevant to determining whether the student meets the U.S. Department of Education’s definition of independent student (see Section 3-II.E)
Reviewing prior year income tax returns to verify whether a parent has claimed the student as a dependent
Requesting and obtaining written certification directly from the student’s parents identifying the amount of support they will be providing to the student, even if the amount of support is $0.
Verifying documentation relevant to determining whether the student meets the definition of a vulnerable youth (see Section 3-II.E), such a determination is all that is necessary determine that the person is an independent student for the purposes of using
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CHAPTER 7: VERIFICATION [24 CFR 982.516, 24 CFR 982.551, 24 CFR 5.230, Notice PIH 2018-18] Chapter Section: 7-II.F. DOCUMENTATION OF DISABILITY
Subsection (if any): Family Members Receiving SSA Disability Benefits
PROPOSED PHA ADMIN PLAN LANGUAGE:
PHA Policy
For family members claiming disability who receive disability benefits from the SSA, the PHA will attempt to obtain information about disability benefits through the HUD Enterprise Income Verification (EIV) system. If documentation from HUD’s EIV System is not available, the PHA will request a current (dated within the last 60 daysappropriate benefit year) SSA benefit verification letter from each family member claiming disability status. If the family is unable to provide the document(s), the PHA will ask the family to request a benefit verification letter by either calling SSA at 1-800-772-1213, or by requesting it from
www.ssa.gov. Once the
applicant or participant receives the benefit verification letter they will be required to provide it to the PHA.
PREVIOUS PHA ADMIN PLAN LANGUAGE:
PHA Policy
For family members claiming disability who receive disability benefits from the SSA, the PHA will attempt to obtain information about disability benefits through the HUD Enterprise Income Verification (EIV) system. If documentation from HUD’s EIV System is not available, the PHA will request a current (dated within the last 60 days) SSA benefit verification letter from each family member claiming disability status. If the family is unable to provide the document(s), the PHA will ask the family to request a benefit verification letter by either calling SSA at 1-800-772-1213, or by requesting it from www.ssa.gov. Once the applicant or participant receives the benefit verification letter they will be required to provide it to the PHA.
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CHAPTER 7: VERIFICATION [24 CFR 982.516, 24 CFR 982.551, 24 CFR 5.230, Notice PIH 2018-18] Chapter Section: PART III: VERIFYING INCOME AND ASSETS
PROPOSED PHA ADMIN PLAN LANGUAGE:
PHA Policy
The following policies do not apply when the PHA uses a Safe Harbor income determination from a means-tested federal assistance program.
PREVIOUS PHA ADMIN PLAN LANGUAGE:
PHA Policy
N/A
CHAPTER 7: VERIFICATION [24 CFR 982.516, 24 CFR 982.551, 24 CFR 5.230, Notice PIH 2018-18] Chapter Section: 7-III.A. Earned Income
Subsection (if any): Wages
PROPOSED PHA ADMIN PLAN LANGUAGE:
PHA Policy
When the PHA requires third-party verification of wages, for wages other than tips, the family must provide original pay stubs covering the consecutive 60-day period prior to the PHA’s request. At its discretion, the PHA may request up to 12 consecutive months of additional pay stubs or payroll records if needed to determine income due to the family's circumstances (e.g., irregular/fluctuating schedule, seasonal employment, inconsistent work hours, etc.) (refer to 7-I.D.).
PREVIOUS PHA ADMIN PLAN
LANGUAGE:
PHA Policy
N/A
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CHAPTER 7: VERIFICATION [24 CFR 982.516, 24 CFR 982.551, 24 CFR 5.230, Notice PIH 2018-18] Chapter Section: 7-III.B. Business and Self Employment Income Subsection (if any):
PROPOSED PHA ADMIN PLAN LANGUAGE:
PHA Policy
Business owners and self-employed persons will be required to provide:
An audited financial statement for the previous fiscal year if an audit was conducted. If an audit was not conducted, a statement of income and expenses must be submitted and the business owner or self- employed person must certify to its accuracy; or
Income tax returns with corresponding official tax forms and schedules attached and including third- party receipt of transmission for income tax return filed (i.e., tax preparer’s transmittal receipt, summary of transmittal from online source, etc.).
All schedules completed for filing federal and local taxes in the preceding year.
If accelerated depreciation was used on the tax return or financial statement, an accountant's calculation of depreciation expense, computed using straight-line depreciation rules.
The PHA will provide a format for any person who is unable to provide such a statement to record income and expenses for the coming year. The business owner/self-employed person will be required to submit the information requested and to certify to its accuracy at all future reexaminations.
If a family member has been self-employed less than three (3) months, the PHA will accept the family member's certified estimate of income and schedule an interim reexamination in three (3) months. If the family member has been self-employed for three (3) to twelve (12) months the PHA will require the family to provide documentation of income and expenses for this period and use that information to project income.
When the family member performs “gig employment” or is employed as an independent contractor consistently throughout the year, the PHA will calculate income based on the last 2 consecutive months of employment. At its discretion, the PHA may calculate income using up to 6 consecutive months of employment.
For self-employed family members, family members performing gig employment, or independent contractors who claim they do not have to file tax returns, the PHA may request a completed copy of IRS Form 4506-T to verify that no return has been filed. At any reexamination, the PHA may request documents that support submitted financial statements such as manifests, appointment books, cash books, or bank statements.
PREVIOUS PHA
ADMIN PLAN
LANGUAGE:
PHA Policy
Business owners and self-
employed persons will be
required to provide:
An audited
financial
statement for the
previous fiscal
year if an audit
was conducted. If
an audit was not
conducted, a
statement of
income and
expenses must be
submitted and the
business owner or
self-employed
person must
certify to its
accuracy.
All schedules
completed for
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filing federal and
local taxes in the
preceding year.
If accelerated
depreciation was
used on the tax
return or financial
statement, an
accountant's
calculation of
depreciation
expense,
computed using
straight-line
depreciation rules.
The PHA will provide a
format for any person
who is unable to provide
such a statement to record
income and expenses for
the coming year. The
business owner/self-
employed person will be
required to submit the
information requested and
to certify to its accuracy
at all future
reexaminations.
If a family member has
been self-employed less
than three (3) months, the
PHA will accept the
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B.1 Revision of the PHA Plan Elements
family member's certified
estimate of income and
schedule an interim
reexamination in three (3)
months. If the family
member has been self-
employed for three (3) to
twelve (12) months the
PHA will require the
family to provide
documentation of income
and expenses for this
period and use that
information to project
income.
At any reexamination, the
PHA may request
documents that support
submitted financial
statements such as
manifests, appointment
books, cash books, or
bank statements.
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CHAPTER 7: VERIFICATION [24 CFR 982.516, 24 CFR 982.551, 24 CFR 5.230, Notice PIH 2018-18] Chapter Section: 7-III.C. Periodic Payments and Payments in Lieu of Earnings Subsection (if any): Social Security/SSI Benefits
PROPOSED PHA ADMIN PLAN LANGUAGE:
NOTE: Removed policy and incorporated as imbedded chapter language.
PHA Policy
To verify the Verification requirements for Social Security (SS/) and Supplemental Security Income (SSI) benefits ofdiffer for applicants, the PHA will request a and participants.
For applicants, since EIV does not contain SS or SSI benefit information, the PHA must ask applicants to provide a copy of their current SS and/or SSI benefit letter (dated within the last 60 days) SSAappropriate benefit verification letter fromyear) for each family member that receives social security SS and/or SSI benefits. If the family is unable to provide the document(s), or documents, the PHA will helpshould help the applicant request a benefit verification letter from SSA’s Web sitewebsite at www.socialsecurity.gov or ask www.ssa.gov or ask the family to request one by calling SSA at 1- 800-772-1213. The PHA must obtain the family to request one by calling SSA at
1-800-772-1213. Once original benefit letter from the applicant has received the benefit verification letter they will be required to provide it, make a photocopy of the document for the file, and return the original to the family.
For participants, the PHA.
To verify the SS/SSI benefits of participants, the PHA will must obtain information about social security/SSI benefits through the HUD EIV System,system and confirm with the
PREVIOUS PHA ADMIN PLAN LANGUAGE:
PHA Policy
To verify the SS/SSI benefits of applicants, the PHA will request a current (dated within the last 60 days) SSA benefit verification letter from each family member that receives social security benefits. If the family is unable to provide the document(s), the PHA will help the applicant request a benefit verification letter from SSA’s Web site at www.socialsecurity.gov or ask the family to request one by calling SSA at 1-800-772-1213. Once the applicant has received the benefit verification letter they will be required to provide it to the PHA.
To verify the SS/SSI benefits of participants, the PHA will obtain information about social security/SSI benefits through the HUD EIV System, and confirm with the participant(s) that the current listed benefit amount is correct. If the participant disputes the EIV-reported benefit amount, or if benefit information is not available in HUD systems, the PHA will request a current SSA benefit verification letter from each family member that receives social security benefits.
If the family is unable to provide the document(s) the PHA will help the participant request a benefit verification letter from SSA’s Web site at www.socialsecurity.gov or ask the family to request one by calling SSA at 1-800-772-1213. Once the participant has received the benefit verification letter they will be required to provide it to the PHA.
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participant(s)participants that the current listed benefit amount is correct.
• If the participant agrees with the amount reported in EIV, the PHA must use the EIV-reported gross benefit amount to calculate annual income from Social Security. PHAs are required to use the EIV-reported SS and SSI benefit amounts when calculating income unless the tenant disputes the EIV-reported amount. For example, an SSA benefit letter may list the monthly benefit amount as $450.80 and EIV displays the amount as $450.00. The PHA must use the EIV-reported amount unless the participant disputes the amount.
• If the participant disputes the EIV-reported benefit amount, or if benefit information is not available in HUD systemsEIV, the PHA willmust request a current SSA benefit verification letter (dated within the appropriate benefit year) from each family member that receives social securitySS and/or SSI benefits. If the family is unable to provide the document(s) or documents, the PHA will helpshould help the participant request a benefit verification letter from SSA’s Web sitewebsite at
www.socialsecurity.govwww.ssa.gov or ask the family to request one by calling SSA at 1-800-772-1213. Once the participant has received the benefit verification letter they will be required to provide it to the PHAThe PHA must obtain the original benefit letter from the participant, make a photocopy of the document for the file, and return the original to the family.
Photocopies of social security checks or bank statements are not acceptable forms of verification for SS/SSI benefits.
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CHAPTER 7: VERIFICATION [24 CFR 982.516, 24 CFR 982.551, 24 CFR 5.230, Notice PIH 2018-18] Chapter Section: 7-III.H. Income from Excluded Sources
PROPOSED PHA ADMIN PLAN LANGUAGE:
The PHA must obtain verification for income exclusions only if, without verification, the PHA would not be able to determine whether the income is to be excluded. For example: If a family’s 16 year old has a job at a fast food restaurant, the PHA will confirm that PHA records verify the child’s age but will not require third-party verification of the amount earned. However, if a family claims the earned income disallowance for a source of income, both the source and the income must be verified.
HUD guidance on verification of excluded income draws a distinction between income which is fully excluded and income which is only partially excluded.
For fully excluded income, the PHA is not required to follow the verification hierarchy, document why third-party verification is not available, or report the income on the 50058. Fully excluded income is defined as income that is entirely excluded from the annual income determination (for example, food stamps, earned income of a minor, or foster care funds) [Notice PIH 2013-04].
PHAs may accept a family’s signed application or reexamination form as self- certification of fully excluded income. They do not have to require additional documentation. However, if there is any doubt that a source of income qualifies for full exclusion, PHAs have the option of requiring additional verification.
For partially excluded income, the PHA is required to follow the verification hierarchy and all applicable regulations, and to report the income on the 50058.
Partially excluded income is defined as income where only a certain portion of what is reported by the family qualifies to be excluded and the remainder is included in annual income (for example, the income of an adult full-time student).
PHA Policy
PREVIOUS PHA ADMIN PLAN LANGUAGE:
The PHA must obtain verification for income exclusions
only if, without verification, the PHA would not be able to determine whether the income is to be excluded. For
example: If a family’s 16 year old has a job at a fast food restaurant, the PHA will confirm that PHA records
verify the child’s age but will not require third-party verification of the amount earned. However, if a family claims the earned income disallowance for a source of
income, both the source and the income must be verified.
PHA Policy
The PHA will reconcile differences in amounts reported
by the third party and the family only when the excluded amount is used to calculate the family share (as is the case with the earned income disallowance). In all other cases, the PHA will report the amount to be excluded as indicated on documents provided by the family.
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The PHA will accept the family’s self-certification as verification of fully excluded income. The PHA may request additional documentation if the PHA deems it necessary to document the income source.
The PHA will verify the source and amount of partially excluded income as described in Part 1 of this chapter.
The PHA will reconcile differences in amounts reported by the third party and the family only when the excluded amount is used to calculate the family share (as is the case with the earned income disallowance). In all other cases, the PHA will report the amount to be excluded as indicated on documents provided by the family.
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CHAPTER 7: VERIFICATION [24 CFR 982.516, 24 CFR 982.551, 24 CFR 5.230, Notice PIH 2018-18] Chapter Section: 7-III.I. ZERO Annual Income Status INCOME FAMILIES [Notice PIH 2023-27]
PROPOSED PHA ADMIN PLAN LANGUAGE:
PHA Policy
The PHA will check UIV sources and/or may request information from third-party sources to verify that certain forms of income such as unemployment benefits, TANF, SSI, SSI, earned income, child support, etc., are not being received by families claiming to have zero annual income.
PREVIOUS PHA ADMIN PLAN
LANGUAGE:
PHA Policy
The PHA will check UIV sources and/or
request information from third-party
sources to verify that certain forms of
income such as unemployment benefits,
TANF, SSI, etc., are not being received by
families claiming to have zero annual
income.
CHAPTER 9: GENERAL LEASING POLICIES
Chapter Section: 9-I.B. Requesting Tenancy Approval [Form HUD-52517] Subsection (if any):
PROPOSED PHA ADMIN PLAN LANGUAGE:
PHA Policy
The RTA must be signed by both the family and the owner.
The owner may submit the RTA on behalf of the family.
Completed RTA (including the proposed dwelling lease) must be submitted as hard copies, in-person, by mail, email, or by fax.
The family may not submit, and the PHA will not process, more than one (1) RTA at a time.
PREVIOUS PHA ADMIN PLAN LANGUAGE:
PHA Policy
The RTA must be signed by both the family and the owner.
The owner may submit the RTA on behalf of the family.
Completed RTA (including the proposed dwelling lease) must be submitted as hard copies, in-person, by mail, or by fax.
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CHAPTER 10: MOVING WITH CONTINUED ASSISTANCE AND PORTABILITY Chapter Section: 10-I.B. FAMILY MOVES DUE TO UNIT DEFICIENCIES Subsection (if any): Units in Abatement [24 CFR 982.404(d)(3)]
PROPOSED PHA ADMIN PLAN LANGUAGE:
Units in Abatement [24 CFR 982.404(d)(3)]
An owner may not terminate the tenancy of a family due to the PHA withholding or abating HAP for housing quality standards deficiencies that are not repaired timely. During the period that assistance is abated, the family may terminate tenancy by notifying the owner and the PHA. If the family chooses to terminate tenancy, the HAP contract will automatically terminate on the effective date of tenancy termination or the date the family vacates the unit, whichever is earlier. The PHA must promptly issue the family its voucher to move.
PHA Policy
Upon receipt of a family’s written notification that it wishes to move, the PHA will issue a voucher within 10 business days of the PHA’s written approval to move. No briefing is required for these families. The PHA will follow the policies set forth in Chapter 5 on voucher term, extension, and expiration.
PREVIOUS PHA ADMIN PLAN
LANGUAGE:
PHA Policy
New section and policy
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CHAPTER 10: MOVING WITH CONTINUED ASSISTANCE AND PORTABILITY Chapter Section: 10-I.B. FAMILY MOVES DUE TO UNIT DEFICIENCIES Subsection (if any): Termination of HAP Contract and Family Moves [24 CFR 982.404(e)]
PROPOSED PHA ADMIN PLAN LANGUAGE:
Termination of HAP Contract and Family Moves [24 CFR 982.404(e)] If an owner fails to make required repairs within 60 days (or a reasonable longer period established by the PHA) of the notice of abatement, the PHA must terminate the HAP contract. In this case, the PHA must issue the family its voucher at least 30 days prior to the termination of the HAP contract.
The family must be provided at least 90 days following the termination of the HAP contract to lease a new unit, although the PHA may provide a longer period as the PHA determines is reasonably necessary.
PHA Policy
The PHA will issue a family whose HAP contract is being terminated due to an owner failing to make required repairs within the required time frame a voucher no later than 30 days prior to the termination of the HAP contract. The initial term of the voucher will be 120 calendar days. No briefing is required for these families.
To continue under the tenant-based HCV program, the family must submit a Request for Tenancy Approval and proposed lease within the 120-day period unless the PHA grants an extension. The PHA will follow the policies set forth in Chapter 5 on voucher extension and expiration.
PREVIOUS PHA ADMIN PLAN
LANGUAGE:
PHA Policy
New section and policy
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CHAPTER 10: MOVING WITH CONTINUED ASSISTANCE AND PORTABILITY Chapter Section: 10-I.DC. Moving Process
Subsection (if any): Voucher Issuance and Briefing
PROPOSED PHA ADMIN PLAN LANGUAGE:
PHA Policy
For families approved to move to a new unit within the PHA’s jurisdiction, the PHA will issue a new voucher within 15 business days of the PHA’s written approval to move. No briefing is required for these families. The PHA will follow the policies set forth in Chapter 5 on voucher term, extension, and expiration. If a family does not locate a new unit within the term of the voucher and any extensions, the family may remain in its current unit with continued voucher assistance if the owner agrees and the PHA approves. Otherwise, the family will lose its assistance.
For families moving into or families approved to move out of the PHA’s jurisdiction under portability, the PHA will follow the policies set forth in Part II of this chapter.
For families moving due an owner failing to make required repairs timely, resulting in the PHA terminating the HAP contract, the PHA will follow the policies set forth earlier in this section and in Chapter 8, Part II.
PREVIOUS PHA ADMIN PLAN LANGUAGE:
PHA Policy
For families approved to move to a new unit within the PHA’s jurisdiction, the PHA will issue a new voucher within 15 business days of the PHA’s written approval to move. No briefing is required for these families. The PHA will follow the policies set forth in Chapter 5 on voucher term, extension, and expiration. If a family does not locate a new unit within the term of the voucher and any extensions, the family may remain in its current unit with continued voucher assistance if the owner agrees and the PHA approves.
Otherwise, the family will lose its assistance.
For families moving into or families approved to move out of the PHA’s jurisdiction under portability, the PHA will follow the policies set forth in Part II of this chapter.
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CHAPTER 10: MOVING WITH CONTINUED ASSISTANCE AND PORTABILITY Chapter Section: 10-II.B. Initial PHA Role
Subsection (if any): Voucher Issuance and Term
PROPOSED PHA ADMIN PLAN LANGUAGE:
PHA Policy
For families approved to move under portability, the PHA will issue a new voucher within 15 business days of the PHA’s written approval to move. The initial term of the voucher will be 60 days.
However, if the move is due to the HAP contract being terminated due to an owner failing to make required repairs within the required time frame, the PHA will issue the family a voucher no later than 30 days prior to the termination of the HAP contract. The initial term of the voucher will be 120 calendar days.
PREVIOUS PHA ADMIN PLAN LANGUAGE:
PHA Policy
For families approved to move under portability, the PHA will issue a new voucher within 15 business days of the PHA’s written approval to move.
The initial term of the voucher will be 60 days.
CHAPTER 11. A.: REEXAMINATIONS
Chapter Section: 11-I.C. Conducting Regular Reexaminations
PROPOSED PHA ADMIN PLAN LANGUAGE:
Additionally, HUD recommends that at annual reexaminations PHAs ask whether the tenant, or any member of the tenant’s household, is subject to a lifetime sex offender registration requirement in any state [Notice PIH 2012-28].
PHA Policy
At the annual reexamination, the PHA will ask whether the tenant, or any member of the tenant’s household, is subject to a lifetime sex offender registration requirement in any state.
PREVIOUS PHA ADMIN
PLAN LANGUAGE:
PHA Policy
N/A
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CHAPTER 11. A.: REEXAMINATIONS
Chapter Section: 11-II.C. CHANGES AFFECTING INCOME OR EXPENSES Subsection (if any): PHA-Initiated Interim Reexaminations
PROPOSED PHA ADMIN PLAN LANGUAGE:
PHA-Initiated Interim Reexaminations
PHA-initiated interim reexaminations are those that are scheduled based on circumstances or criteria defined by the PHA. They are not scheduled because of changes reported by the family.
PHA Policy
The PHA will conduct interim reexaminations in each of
the following instances:
For families receiving the Earned Income
Disallowance (EID), the PHA will conduct an
interim reexamination at the start and conclusion of
the second 12 month exclusion period (50 percent
phase-in period).
If at the time of the annual reexamination, it is not
feasible to anticipate a level of income for the next
12 months (e.g. seasonal or cyclic income), the
PHA will schedule an interim reexamination to
coincide with the end of the period for which it is
feasible to project income.
When a family member obtains new or replacement
income after losing employment. The new income
will be counted towards the family’s rent portion.
The PHA may conduct an interim reexamination at
any time in order to correct an error in a previous
PREVIOUS PHA ADMIN PLAN LANGUAGE:
PHA-Initiated Interim Reexaminations
PHA-initiated interim reexaminations are those that are scheduled based on circumstances or criteria defined by the PHA. They are not scheduled because of changes reported by the family.
PHA Policy
The PHA will conduct interim reexaminations in each of the following instances:
For families receiving the Earned Income Disallowance
(EID), the PHA will conduct an interim reexamination at the start and conclusion of the second 12 month
exclusion period (50 percent phase-in period).
If at the time of the annual reexamination, it is not
feasible to anticipate a level of income for the next 12 months (e.g. seasonal or cyclic income), the PHA will
schedule an interim reexamination to coincide with the
end of the period for which it is feasible to project
income.
When a family member obtains new or replacement
income after losing employment. The new income will
be counted towards the family’s rent portion.
The PHA may conduct an interim reexamination at any
time in order to correct an error in a previous
reexamination, or to investigate a tenant fraud complaint.
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reexamination, or to investigate a tenant fraud
complaint.
Family-Initiated Interim Reexaminations
The PHA must adopt policies prescribing when and under what conditions the family must report changes in family income or expenses [24 CFR 982.516(c)]. In addition, HUD regulations require that the family be permitted to obtain an interim reexamination any time the family has experienced a change in circumstances since the last determination [24 CFR
982.516(b)(2)].
Required Reporting
HUD regulations give the PHA the freedom to determine the circumstances under which families will be required to report changes affecting income.
PHA Policy
The PHA will conduct interim reexaminations for families that qualify for the earned income disallowance (EID), and only when the EID family’s share of rent will change as a result of the increase.
Families are required to report when a family member
obtains new or replacement employment income within ten (10) business days of the change.
Families who report zero income must report a change in income within ten (10) business days of the change. The PHA will conduct an interim re-examination to reflect the addition of income to the household. The increase will be effective on the first of the month following a 30 days’ notice to the family. Please refer to Chapter 5-I.C. for
Family-Initiated Interim Reexaminations
The PHA must adopt policies prescribing when and under what conditions the family must report changes in family income or expenses [24 CFR 982.516(c)]. In addition, HUD regulations require that the family be permitted to obtain an interim reexamination any time the family has experienced a change in circumstances since the last determination [24 CFR 982.516(b)(2)].
Required Reporting
HUD regulations give the PHA the freedom to determine the circumstances under which families will be required to report changes affecting income.
PHA Policy
The PHA will conduct interim reexaminations for families that qualify for the earned income disallowance (EID), and only when the EID family’s share of rent will change as a result of the increase.
Families are required to report when a family member obtains new or replacement employment income within ten (10)
business days of the change.
Families who report zero income must report a change in income within ten (10) business days of the change. The PHA will conduct an interim re-examination to reflect the addition of income to the household. The increase will be effective on the first of the month following a 30 days’ notice to the family.
Please refer to Chapter 5-I.C. for additional policies regarding families that report zero income.
A family member who reported a loss of employment income within the last 12 months must report any new or replacement income obtained by that member.
ATTACHMENT 1 Page 48 of 62
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additional policies regarding families that report zero income.
A family member who reported a loss of employment
income within the last 12 months must report any new or replacement income obtained by that member.
Families are not required to report any other changes in income or expenses that occur throughout the year as long as they have provided complete and accurate information during their regular reexamination.
Optional Reporting
The family may request an interim reexamination any time the family has experienced a change in circumstances since the last determination [24 CFR 982.516(c)(2)]. The PHA must process the request if the family reports a change that will result in a reduced family income [HCV GB, p. 12-9].
If a family reports a decrease in income from the loss of welfare benefits due to fraud or non-compliance with a welfare agency requirement to participate in an economic self-sufficiency program, the family’s share of the rent will not be reduced [24 CFR 5.615]. For more information regarding the requirement to impute welfare income see Chapter 6.
PHA Policy
If a family reports a change that was not required to report and that would result in an increase in the family share of the rent, the PHA will note the information in the tenant file, but will not conduct an interim reexamination.
Families may report changes in income or expenses at any time. The PHA will not process an interim reexamination decreasing rent due to a loss of employment unless the
family provides evidence they have applied for
Families are not required to report any other changes in income or expenses that occur throughout the year as long as they have provided complete and accurate information during their regular reexamination.
Optional Reporting
The family may request an interim reexamination any time the family has experienced a change in circumstances since the last determination [24 CFR 982.516(c)(2)]. The PHA must process the request if the family reports a change that will result in a reduced family income [HCV GB, p. 12-9].
If a family reports a decrease in income from the loss of welfare benefits due to fraud or non-compliance with a welfare agency requirement to participate in an economic self-sufficiency program, the family’s share of the rent will not be reduced [24 CFR 5.615]. For more information regarding the requirement to impute welfare income see Chapter 6.
PHA Policy
If a family reports a change that was not required to report and that would result in an increase in the family share of the rent, the PHA will note the information in the tenant file, but will not conduct an interim reexamination.
Families may report changes in income or expenses at any time.
The PHA will not process an interim reexamination decreasing rent due to a loss of employment unless the family provides evidence they have applied for unemployment, CalWorks, and General Relief benefits, as applicable. Once the family provides this evidence, the PHA will make an interim change, but will require the family to provide verification of the new benefits immediately once they receive it. The PHA will then conduct a new interim reexamination to include the new income. This ATTACHMENT 1 Page 49 of 62
B.1 Revision of the PHA Plan Elements
unemployment, CalWorks, and General Relief benefits, as applicable. Once the family provides this evidence, the PHA will make an interim change, but will require the
family to provide verification of the new benefits
immediately once they receive it. The PHA will then
conduct a new interim reexamination to include the new
income. This policy also applies if the change is reported as part of a regularly scheduled reexamination.
policy also applies if the change is reported as part of a regularly scheduled reexamination.
ATTACHMENT 1 Page 50 of 62
B.1 Revision of the PHA Plan Elements
CHAPTER 12: TERMINATION OF ASSISTANCE AND TENANCY
Chapter Section: 12-I.E. Mandatory Policies and Other Authorized Terminations Subsection (if any): Insufficient Funding [24 CFR 982.454 and Notice PIH 2005-9]
PROPOSED PHA ADMIN PLAN LANGUAGE:
PHA Policy
The PHA will determine whether there is sufficient funding to pay for currently assisted families according to the policies in Part VIII of Chapter 16. If the PHA determines there is a shortage of funding, prior to terminating any HAP contracts, the PHA will determine if any other actions can be taken to reduce program costs.
If after implementing all reasonable cost cutting measures there is not enough funding available to provide continued assistance for current participants, the PHA will terminate HAP contracts as a last resort.
The PHA will terminate the minimum number needed in order to reduce HAP costs to a level within the PHA’s annual budget authority.
If the PHA must terminate HAP contracts due to insufficient funding, the PHA will do so in accordance with the following criteria and instructions:
The PHA will terminate families according to the date of the family’s admission to the program, starting with those who have been receiving assistance the longest and have over $10,000 in assets within each category below (in order of priority below):
o Non-elderly, non-disabled single family members;
o Non-elderly, non-disabled families with no children under the age of 18;
o Elderly and disabled families with adult family members who are non- elderly and non-diasbleddisabled;
o Non-elderly, non-disabled families with children under the age of 18; and
PREVIOUS PHA ADMIN PLAN LANGUAGE:
PHA Policy
The PHA will determine whether there is sufficient
funding to pay for currently assisted families according to the policies in Part VIII of Chapter 16.
[…]
The PHA will terminate families based on their available assets. Families with the highest valued assets will be terminated first.
Only families who have over $10,000 in assets will be
considered under this policy.
If additional families must be terminated to balance the budget, the PHA will then look to terminate assistance to families who reside in buildings that offer other types of assistance such as tax credit buildings. If termination of assistance will result in a rent burden of more than 50% of annual gross income for the family, assistance may
not be terminated. The determination of rent burden will be based on the tax credit rent, or other applicable rent calculation, for the unit not the current HCV rent rate.
The PHA will work with property owners to assist with
the transition and ensure that families are not
substantially impacted.
The PHA will terminate only the number of families
needed to balance the budget.
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o Elderly and disabled families
The PHA will terminate families based on their available assets.
Families with the highest valued assets will be terminated first.
Only families who have over $10,000 in assets will be considered under this policy.
Households in each priority category will be terminated by those with the most assets over $10,000 and then by the longest on the program. The first review of terminations will impact families with the most assets.
If additional families must be terminated to balance the budget, then a second review will impact families that have been on the program the longest, within each category listed above (in order).
If additional families must be terminated to balance the budget, the PHA will then look to terminate assistance to families who reside in buildings that offer other types of assistance such as tax credit buildings. If termination of assistance will result in a rent burden of more than 50% of annual gross income for the family, assistance may not be terminated. The determination of rent burden will be based on the tax credit rent, or other applicable rent calculation, for the unit not the current HCV rent rate. The PHA will work with property owners to assist with the transition and ensure that families are not substantially impacted.
If additional families must be terminated to balance the budget, the PHA will then a second review will impactterminate assistance to those families in priority category order who that have been on the program the longest, within each category listed above (in order).
The PHA will terminate only the number of families needed to balance the budget.
Prior to terminating any HAP contracts, the PHA will
inform the local HUD field office.
ATTACHMENT 1 Page 52 of 62
B.1 Revision of the PHA Plan Elements
CHAPTER 12: TERMINATION OF ASSISTANCE AND TENANCY
Chapter Section: 12-II.E. Terminating the Assistance of Domestic Violence, Dating Violence, or Stalking OR HUMAN TRAFFICKING [24 CFR 5.2005]
Subsection (if any): Limitations on VAWA Protections [24 CFR 5.2005(d) and (e)]
PROPOSED PHA ADMIN PLAN LANGUAGE:
PHA Policy
In determining whether a program participant who is a victim of domestic violence, dating violence, sexual assault or, stalking, or human trafficking is an actual and imminent threat to other tenants or those employed at or providing service to a property, the PHA will consider the following, and any other relevant, factors:
Whether the threat is toward an employee or tenant other than the victim of domestic violence, dating violence, sexual assault or, stalking or human trafficking
Whether the threat is a physical danger beyond a speculative threat Whether the threat is likely to happen within a short period up to 7 days of time
Whether the threat to other tenants or employees can be eliminated in some other way, such as by helping the victim relocate to a confidential location or seeking a legal remedy to prevent the perpetrator from acting on the threat
If the tenantparticipant wishes to contest the PHA’s determination that he or she isthey are an actual and imminent threat to other tenants or employees, the tenantparticipant may do so as part of the informal hearing.
PREVIOUS PHA ADMIN PLAN LANGUAGE:
PHA Policy
In determining whether a participant who is a victim of domestic violence, dating violence, sexual assault or stalking is an actual and imminent threat to other tenants or those employed at or providing service to a property, the PHA will consider the following, and any other relevant, factors:
Whether the threat is toward an employee or tenant other than the victim of domestic violence, dating violence, sexual assault or stalking
Whether the threat is a physical danger beyond a speculative threat Whether the threat is likely to happen within a short period of time Whether the threat to other tenants or employees can be eliminated in some other way, such as by helping the victim relocate to a confidential location
If the tenant wishes to contest the PHA’s determination that he or she is an actual and imminent threat to other tenants or employees, the tenant may do so as part of the informal hearing.
ATTACHMENT 1 Page 53 of 62
B.1 Revision of the PHA Plan Elements
CHAPTER 14: PROGRAM INTEGRITY
Chapter Section: 14-II.D. PHA-Caused Errors or Program Abuse Subsection (if any): De Minimis Errors [24 CFR 5.609(c)(4)]
PROPOSED PHA ADMIN PLAN LANGUAGE:
De Minimis Errors [24 CFR 5.609(c)(4)]
The PHA will not be considered out of compliance when making annual income determinations solely due to de minimis errors in calculating family income. A de minimis error is an error where the PHA determination of family income deviates from the correct income determination by no more than $30 per month in monthly adjusted income ($360 in annual adjusted income) per family.
PHAs must take corrective action to credit or repay a family if the family was overcharged rent, including when PHAs make de minimis errors in the income determination. Families will not be required to repay the PHA in instances where the PHA miscalculated income resulting in a family being undercharged for rent. PHAs state in their policies how they will repay or credit a family the amount they were overcharged as a result of the PHA’s de minimis error in income determination.
PHA Policy
If the family was overcharged rent, the PHA will credit the owner and reduce the rent owed for the following month.
PREVIOUS PHA ADMIN PLAN LANGUAGE:
PHA Policy
New section and policy
ATTACHMENT 1 Page 54 of 62
B.1 Revision of the PHA Plan Elements
CHAPTER 16: PROGRAM ADMINISTRATION
Chapter Section: 16-IV.B. Repayment Policy | Subsection (if any): Late or Missed Payments
PROPOSED PHA ADMIN PLAN LANGUAGE:
PHA Policy
If a payment is not received by the end of the business day on the date due, and prior approval for the missed payment has not been given by the PHA, the PHA will send the family a delinquency notice giving the family 10 business days to make the late payment. If the payment is not received by the due date of the delinquency notice, it will be considered a breach of the agreement and the PHA will terminate assistance in accordance with the policies in Chapter 12.
If a family receives three delinquency notices for unexcused late payments in a throughout the entire term of the repayment agreement, the repayment agreement will be considered in default, and the PHA will terminate assistance in accordance with the policies in Chapter 12.
PREVIOUS PHA ADMIN PLAN
LANGUAGE:
PHA Policy
If a payment is not received by the end of the
business day on the date due, and prior approval
for the missed payment has not been given by the
PHA, it will be considered a breach of the
agreement and the PHA will terminate assistance
in accordance with the policies in Chapter 12.
CHAPTER 16: PROGRAM ADMINISTRATION
Chapter Section: 16-IV.B. Repayment Policy | Subsection (if any): Down Payment Requirement
PROPOSED PHA ADMIN PLAN LANGUAGE:
PHA Policy
Before executing a repayment agreement with a family, the PHA will generally require a down payment of 10 percent of the total amount owed. The family has the option to make a higher down payment if they choose. If the family can provide evidence satisfactory to the PHA that a down payment of 10 percent would impose an undue hardship, the PHA may, in its sole discretion, require a lesser percentage or waive the requirement.
The PHA may require a down payment higher than 10 percent to align with payment threshold policies.
PREVIOUS PHA ADMIN PLAN LANGUAGE:
PHA Policy
Before executing a repayment agreement with a family,
the PHA will generally require a down payment of 10
percent of the total amount owed. If the family can
provide evidence satisfactory to the PHA that a down
payment of 10 percent would impose an undue
hardship, the PHA may, in its sole discretion, require a lesser percentage or waive the requirement.
ATTACHMENT 1 Page 55 of 62
B.1 Revision of the PHA Plan Elements
CHAPTER 19: SPECIAL PURPOSE VOUCHERS
Chapter Section: 19-III.C. HCV PROGRAM ELIGIBILITY [FR Notice 8/13/24] Subsection (if any): Minimum Rent [FR Notice 8/13/24]
PROPOSED PHA ADMIN PLAN LANGUAGE:
PHA Policy
The PHA does not implement a different minimum rent amount for the VASH program. The minimum rent for the VASH program will be the same as it is for HCV program as stated in Section 6-III.A.
PREVIOUS PHA ADMIN PLAN LANGUAGE:
PHA Policy
New section and policy
CHAPTER 19: SPECIAL PURPOSE VOUCHERS
Chapter Section: 19-III.E. LEASING [FR Notice 8/13/24]
Subsection (if any): Voucher Issuance [FR Notice 8/13/24]
PROPOSED PHA ADMIN PLAN LANGUAGE:
Voucher Issuance [FR Notice 8/13/24]
Unlike the standard HCV program which requires an initial voucher term of at least 60 days, VASH vouchers must have a search term of at least 120 days. This applies both to the initial search term and moves. PHA policies on extensions as outlined in Section 5-II.E. will apply.
PHA Policy
All VASH vouchers will have an initial term of 120 calendar days.
The family must submit a Request for Tenancy Approval and proposed lease within the 120-day period unless the PHA grants an extension.
PREVIOUS PHA ADMIN PLAN LANGUAGE:
PHA Policy
New section and policy
ATTACHMENT 1 Page 56 of 62
B.1 Revision of the PHA Plan Elements
CHAPTER 19: SPECIAL PURPOSE VOUCHERS
Chapter Section: 19-III.H. PROJECT-BASING VASH VOUCHERS Subsection (if any): Termination of Assistance
PROPOSED PHA ADMIN PLAN LANGUAGE:
PHA Policy
If the family fails to participate in case management when required by the VA, the PHA will terminate the family’s assistance. The family will have 120 days to vacate the unit. The PHA will terminate assistance to the family at the earlier of (1) the time the family vacates or (2) the expiration of the 120-day period. If the family fails to vacate the unit within the established time, the owner may evict the family. If the owner does not evict the family, the PHA will remove the unit from the HAP contract or amend the HAP contract to substitute a different unit in the project if the project is partially assisted. The PHA may add the removed unit back onto the HAP contract after the ineligible family vacates the property.
PREVIOUS PHA ADMIN PLAN
LANGUAGE:
PHA Policy
New section and policy
CHAPTER 19: SPECIAL PURPOSE VOUCHERS
Chapter Section: 19-III.H. PROJECT-BASING VASH VOUCHERS Subsection (if any): Failure to Participate in Case Management [FR Notice 8/13/24]
PROPOSED PHA ADMIN PLAN LANGUAGE:
Failure to Participate in Case Management [FR Notice 8/13/24] Upon notification by the VAMC or DSP of the family’s failure to participate, without good cause, in case management, the PHA must provide the family a reasonable time period to vacate the unit.
The PHA must terminate assistance to the family at the earlier of either the time the family vacates or the expiration of the reasonable time period given to vacate.
PHA Policy
PREVIOUS PHA ADMIN PLAN
LANGUAGE:
PHA Policy
New section and policy
ATTACHMENT 1 Page 57 of 62
B.1 Revision of the PHA Plan Elements
Upon notification by the VAMC or DSP that a VASH PBV family has failed to participate in case management without good cause, the PHA will provide written notice of termination of assistance to the family and the owner within 10 business days. The family will be given 60 days from the date of the notice to move out of the unit.
The PHA may make exceptions to this 60-day period if needed for reasons beyond the family’s control such as death, serious illness, or other medical emergency of a family member.
CHAPTER 19: SPECIAL PURPOSE VOUCHERS
Chapter Section: 19-IV.C. PARTNERSHIP AND SUPPORTIVE SERVICES [Notice PIH 2020-01]
PROPOSED PHA ADMIN PLAN LANGUAGE:
19-IV.C. PARTNERSHIP AND SUPPORTIVE SERVICES [Notice PIH 2020-01] PHAs are encouraged but not required to establish formal and informal partnerships with a variety of organizations that assist persons with disabilities to help ensure eligible participants find and maintain stable housing.
PHA Policy
The PHA will implement a Mainstream program, in partnership with supportive services agencies that may include, but is not limited to:
Orange County Health Care Agency
Orange County non-profits
PREVIOUS PHA ADMIN PLAN
LANGUAGE:
PHA Policy
New section and policy
ATTACHMENT 1 Page 58 of 62
B.1 Revision of the PHA Plan Elements
CHAPTER 19: SPECIAL PURPOSE VOUCHERS
Chapter Section: 19-IV.D. WAITING LIST ADMINISTRATION [Notice PIH 2024-30]
PROPOSED PHA ADMIN PLAN LANGUAGE:
PHA Policy
The PHA will establish a separate waiting list for the Mainstream program.
All PHA policies on opening, closing, and updating the waiting list in Chapter 4 will also apply to the Mainstream waiting list.
PREVIOUS PHA ADMIN PLAN LANGUAGE:
PHA Policy
New section and policy
CHAPTER 19: SPECIAL PURPOSE VOUCHERS
Chapter Section: 19-IV.E. PREFERENCES [Notice PIH 2024-30]
PROPOSED PHA ADMIN PLAN LANGUAGE:
PHA Policy
The PHA claimed a preference for a targeted group as part of an application for Mainstream vouchers under a NOFO. The PHA will offer the following preference:
From Chapter 4-III.C. - For up to 172 vouchers, preference will be granted to non- elderly disabled persons that are transitioning out of institutional or other segregated settings or are homeless. These vouchers were granted through 2017 Mainstream Voucher Program NOFA and 2020 CARES Act allocations)
The PHA will use the date and time of application technique in selecting families from the Mainstream waiting list among applicants with the same preference status.
PREVIOUS PHA ADMIN PLAN
LANGUAGE:
PHA Policy
New section and policy
ATTACHMENT 1 Page 59 of 62
B.1 Revision of the PHA Plan Elements
CHAPTER 19: SPECIAL PURPOSE VOUCHERS
Chapter Section: 19-IV.F. VOUCHER ISSUANCE | Subsection (if any): Initial Search Term [Notice PIH 2024-30]
PROPOSED PHA ADMIN PLAN LANGUAGE:
PHA Policy
The initial voucher term for all Mainstream vouchers, including those issued when a family wishes to exercise portability, will be 120 days.
PREVIOUS PHA ADMIN PLAN LANGUAGE:
PHA Policy
New section and policy
ATTACHMENT 1 Page 60 of 62
B.1 Revision of the PHA Plan Elements
CHAPTER 19: SPECIAL PURPOSE VOUCHERS
Chapter Section: 19-IV.F. VOUCHER ISSUANCE
Subsection (if any): Voucher Extension [Notice PIH 2024-30]
PROPOSED PHA ADMIN PLAN LANGUAGE:
While HUD is establishing an alternative requirement to 24 CFR 982.303(b)(1), HUD reminds PHAs that 24 CFR 982.303(b)(2) requires PHAs to approve all extensions made as part of a reasonable accommodation and PHAs must provide this information during the family briefing (24 CFR 982.301(a)).
PHA Policy
Families may request an extension, either orally or in writing, at any time prior to the expiration of the family’s voucher. All requests for extensions will automatically be granted without the requirement for the family to provide documentation. The initial extension period will be for 90 days. If the family requires additional extensions beyond 90 days, the family may request one additional extension, either orally or in writing, at any time prior to the expiration of the extended voucher term. The subsequent extension will also be for a period of 90 days and will not require the family to meet certain circumstances or provide documentation.
On at least one occasion after voucher issuance, the PHA will contact the family to remind them of the expiration date of their voucher will prior to the expiration of the initial term of the voucher, the process for requesting an extension, and to inquire if the family needs assistance with their housing search. The PHA will ensure effective communication with persons with disabilities, including those with vision, hearing, speech, intellectual or other developmental disabilities, or any other communication-related disabilities.
Extensions beyond 180 calendar days will only be considered as a reasonable accommodation for a person with disabilities
PREVIOUS PHA ADMIN PLAN
LANGUAGE:
PHA Policy
New section and policy
ATTACHMENT 1 Page 61 of 62
B.1 Revision of the PHA Plan Elements
CHAPTER 19: SPECIAL PURPOSE VOUCHERS
Chapter Section: 19-V.D. LEASE UP [Notice PIH 2013-19] | Subsection (if any): Voucher Term
PROPOSED PHA ADMIN PLAN LANGUAGE:
Voucher Term
While the PHA is not required to establish different policies for the initial term of the voucher for NED vouchers, HUD has encouraged PHAs with NED vouchers to be generous in establishing reasonable initial search terms and subsequent extensions for families with a disabled person.
PHA Policy
The PHA will not implement a different initial voucher term the NED program. The initial voucher term for the NED program will be the same as it is for HCV program as stated in Section 5-II.E.
All other PHA policies on extensions and suspension of vouchers in Section 5-II.E. will also apply.
PREVIOUS PHA ADMIN PLAN
LANGUAGE:
PHA Policy
New section and policy
ATTACHMENT 1 Page 62 of 62
B.1 Revision of the PHA Plan Elements
CHAPTER 19: SPECIAL PURPOSE VOUCHERS
Chapter Section: 19-V.E. PORTABILITY [NED Category 2 FAQs]
PROPOSED PHA ADMIN PLAN LANGUAGE:
19-V.E. PORTABILITY [NED Category 2 FAQs]
NED voucher participants are eligible for portability under standard portability rules and all PHA policies regarding portability in Chapter 10, Part II apply to NED families. However, the PHA may, but is not required to, allow applicant NED families to move under portability, even if the family did not have legal residency in the initial PHA’s jurisdiction when they applied.
PHA Policy
If neither the head of household nor the spouse or cohead of a NED applicant family had a domicile (legal residence) in the PHA’s jurisdiction at the time that the family’s initial application for assistance was submitted, the family must lease a unit within the initial PHA’s jurisdiction for at least 12 months before requesting portability.
The PHA will consider exceptions to this policy for purposes of reasonable accommodation (see Chapter 2) or reasons related to domestic violence, dating violence, sexual assault, stalking, or human trafficking.
PREVIOUS PHA ADMIN PLAN LANGUAGE:
PHA Policy
New section and policy
ATTACHMENT 2 Page 1 of 1
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, Project-Based Vouchers, and Special Purpose 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 its 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, titled “Fair Housing and Equal Opportunity,” details the agency's policies regarding preventing discrimination, ensuring accessibility, providing reasonable accommodations, and offering services in other languages. - Chapter 3 of AHA’s Administrative Plan, “Eligibility,” details the agency's policies regarding program eligibility requirements and denial criteria. - Chapter 4 of AHA’s Administrative Plan, titled “Applications, Waiting List, and Tenant Selection,” details the agency's policies regarding the application process, waitlist management, and tenant selection, including preferences. - Chapter 6 of AHA’s Administrative Plan, titled “Income and Subsidy Standards,” details the agency's policies regarding income and asset calculations to determine program eligibility.
- Chapter 7 of AHA’s Administrative Plan, titled “Verification,” details the agency's policies regarding verifying applicant and tenant information as required by the PHA.
The AHA Administrative Plan can be accessed on our website:
https://www.anaheim.net/1947/Public-Documents
ATTACHMENT 3 Page 1 of 1
B.1 Revision of the PHA Plan Elements
Financial Resources
Program Name Vouchers Allocated CY 2024 Total Funding
Housing Choice Vouchers 6,438 $121,218,517
Mainstream Vouchers 397 $6,688,850
Emergency Housing Vouchers 278 $7,130,665
Family Self-Sufficiency Coordinator N/A $125,710
ATTACHMENT 4 Page 1 of 1
B.1 Revision of PHA Plan Elements
Rent Determination Policies
The Anaheim Housing Authority (AHA) does not own or manage any public housing units. The AHA only administers Housing Choice Vouchers, Project-Based Vouchers, and Special Purpose 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 govern rents charged for HCV dwelling units, including minimum rents, voucher family rent contributions, payment standards, 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 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 AHA Administrative Plan can be accessed on our website:
https://www.anaheim.net/1947/Public-Documents
ATTACHMENT 5 Page 1 of 6
B.3 Progress Report
PHA Goal: Expand the supply of assisted housing
During FY 2024-2025, 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.
The AHA entered into agreements, started construction or completed the following projects in during FY 2024-2025 to expand the supply of affordable housing:
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 selected a developer for the project in March of 2024 and is currently working with the selected developer to finalize development plans and a financing plan in preparation for submittal of a funding application for tax credits in 2025.
Beach-Lincoln Apartment Project (Beach-Lincoln Rental) is a 100% affordable 47-unit Inter- generational apartment rental housing project located at 130 S. Beach Blvd. The project was successful in receiving a tax credit award in September 2024. Nine of the 47 units in the project will be made available to individuals exiting the foster care system. The AHA awarded 46 Project-Based Section 8 Vouchers to assist the project. The project is expected to start construction in April 2025.
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 was completed in September 2023. The selected developer submitted an application for Tax Credits from the California Tax Credit Allocation Committee (TCAC) in August 11, 2024, and is awaiting a decision from TCAC on December 11, 2024. If awarded, the project can commence construction in June 2025.
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 ATTACHMENT 5 Page 2 of 6
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 currently underway and construction is expected to be completed in September 2024. As part of the conversion from interim housing to permanent supportive housing the developer renamed the project Azure Apartments.
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 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 completed construction in November 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 FY 2024-2025:
The Anaheim Housing Authority acquired several motels on Beach Boulevard known as the Covered Wagon, Rainbow Inn and the Anaheim Lodge located at 823, 831and 837 S. Beach Boulevard, respectively. The AHA proposes to assemble the motel properties for the development of a workforce affordable rental housing and homeownership project. Staff is currently conducting the relocation process for existing long term tenants. Once completed, the combined site will be released through an RFP process to seek development proposals.
The Anaheim Housing Authority acquired the Kettle Motel located at 1760 W. Lincoln Avenue.
Staff is currently conducting the relocation process for existing long term tenants. Once completed, staff will assess the development parameters of the site in preparation for an RFP process to affordable housing opportunities.
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 Spring of 2025.
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 ATTACHMENT 5 Page 3 of 6
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.
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. The developer is proposing to resyndicate and conduct improvements for the Phase III and Phase IV projects. The developer is proposing to submit an application for 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 2025.
AHA owned properties assembled for the development of affordable housing:
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: Beach-Lincoln Apartments, Miraflores Family Apartments (Anaheim Midway), Beach Boulevard (Silvermoon Site), and the Tampico Motel affordable housing projects.
Miraflores Family Apartments (Anaheim/Midway) was completed in November 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 and Beach Boulevard (Silvermoon Site) in September 2023 and March 2024, respectively. The Tampico Motel is awaiting a Tax Credit award in December 2024. If awarded, construction can commence in June 2025. AHA is currently working with the selected developer of the Beach Boulevard (Silvermoon Site), on the development and financing plan for the project for a tax credit funding application submittal in 2025.
The AHA does not own the land for the Azure Apartments (Studio 6 Motel) Permanent Supportive Housing (PSH) project site, but provided funding to the project to assist in the rehabilitation and conversion of the site to affordable housing project. The Azure Apartments ATTACHMENT 5 Page 4 of 6
PSH project obtained a Tax Credit Award in March 2023 and is currently under construction with an expected completion date of September 2025.
The Azure Apartments PSH (Studio 6 Motel) project will create 87 units for homeless individuals, Beach-Lincoln Inter-generational Apartments will create 47-units for seniors and transitional aged youth, and Miraflores Family Apartments (Anaheim/Midway) will create 86 new affordable housing units for working families and homeless individuals for a total of 220 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 132 affordable rental units to the AHA’s affordable housing inventory for a total of 352 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 During FY 2023-2024, AHA enrolled 51 new rental assistance participants into its Family Self- Sufficiency (FSS) program for a grand total of 124 participants.
AHA increased its visibility to active rental assistance program participants by revamping our FSS flyer and website, which offers informative material about the FSS program and enrollment inquiries. We also created a streamlined FSS referral system through an online submission form that is available to participants through the new website. AHA has also increased visibility to other PHAs and community agencies by presenting our program design and success at PHA workshops and community collaborative meetings. AHA also increased engagement and visibility among enrolled participants through the implementation of a quarterly newsletter. The quarterly newsletter was created to keep FSS participants informed of new resources or job fair opportunities, events, and any updates on the FSS program policies and procedures. We also have extended our case management services through virtual meetings, making them more accessible and convenient for participants who have unreliable transportation or prefer to meet during small gaps during their work schedules.
AHA has also continued strengthening its relationships with different partners in the community in order to provide participants with a wide array of resources that can help them achieve their educational and career goals. AHA worked closely with multiple local colleges and nonprofit agencies to expand supportive services. AHA has established partnerships with different community colleges that offer the Extended Opportunity Program & Service Program (EOPS).
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EOPS aims to support socioeconomically disadvantaged students through providing textbook assistance, tutoring services and student success workshops. AHA has also helped establish partnerships with career readiness service agencies such as Women Helping Women (WHW), Cielo, Chrysalis, Anaheim Workforce connection. These agencies provide supportive services with job search and preparedness, as well as ongoing case management to ensure job retention.
AHA has also expanded our referral base to include resources and referrals to services that cover basic needs such as food pantries, utility assistance, and low cost medical, dental and mental health services. AHA has connected with agencies such as the Narooz Clinic Foundation, The Friendly Center, and Southland Integrated Services. AHA aims to continue to expand their referral base to include service providers that assist in areas that participants find the most need in. AHA will continue to collect feedback through ongoing case management and graduation interviews to gather data on areas that need further support. In doing so, AHA will be able to collaboratively address and help participants overcome barriers they may be facing towards their educational and career goals.
Lastly, AHA continues to strengthen its relationship with realty agencies such as NeighborWorks Orange County and Orange County Housing Corporation. These agencies offer supportive services through housing counseling and education on consumer credit, financial literacy and homeownership. AHA aspires to help our participants towards self-sufficiency during and after their graduation from our program. AHA has an ongoing collaboration with Orange County Housing Corporation to develop and implement a program specifically tailored for our FSS graduates wishing to continue to receive case management services in managing their escrow disbursement and saving towards homeownership opportunities.
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 2023- 2024, 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 ATTACHMENT 5 Page 6 of 6
system of care.
In FY 2023-2024, the City of Anaheim through a competitive selection process partnered with CalOptima Health, the region’s managed care plan, to launch a street medicine program for individuals living unsheltered in the city. The program provides mobile preventative physician and behavioral health care services alongside enhanced case management and housing navigation for up to 200 qualified individuals. The street medicine team joins the City’s already robust outreach efforts lead by the Community Cares Response Team (CCRT) which operates 14 hours a day, seven days a week. CCRT made 4,539 touches with unsheltered individuals in FY 2023-2024.
During FY 2023-2024, 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 194 households fleeing domestic violence and households with adults and children. Emergency shelter services were also funded in part by State resources and the City's General Fund to provide 325 year round adult shelter beds which on a rotating basis served 488 adults in FY 2023-2023.
In FY 2023-2024, the City allocated $30k in ESG funding towards homelessness prevention programs. In that year, all programs assisted 54 individuals with prevention services. In FY 2023-2024, the City expanded a proof of concept with Orange County Superior Court to divert individuals experiencing homelessness with substance use or mental health conditions to wellness plans in lieu of incarceration. For individuals that opt to receive services, the program named Anaheim Collaborative Court – Evaluating Strategies and Solutions (ACCESS) prevents reoccurring homelessness by supporting individuals through their institutional discharge into interim housing and treatment services while they continue their wellness plan for graduation into permanent housing.-
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 2023-24, the HAP-F program served 34 adults and children. In FY 2023-2024, the City contracted with an additional service provider to expand access to HAP-F. The program now serves families with ties to Anaheim through two service providers that offer up to 24 months of rental assistance.
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 2023-24, the CHIP program served 22 individual households.
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C.1 Resident Advisory Board (RAB) Comments
The Anaheim Housing Authority (AHA) Resident Advisory Board (RAB) hosted a hybrid meeting, in person and virtually via Zoom, on Friday February 7, 2025, at 9 a.m. to discuss the FY 2025-2026 PHA Annual Plan, the Five-Year 2025-2029 PHA Plan, and changes to the Administrative Plan.
An invitation letter was sent to 219 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 first reviewed the Five-Year and Annual PHA Plans. Next, the RAB discussed the attachments to all plans and reviewed proposed policy changes.
Resident Advisory Board Members:
In Person: Virtual:
1. Betty Morales (sp)
2. Jeanette Brede
3. Julie Jones
4. Maftuh Ibrahim
5. Theresa Myles Campbell
6. Hadel Mahammed
7. Rita Blanco
8. Catherine Moore
9. Bashir Ahmed
10. Patricia A. Johnson
11. Fred Elliott Jr.
12. Nanette Arroyo
13. Beverly O’Daniel
14. Shely Youngbauer
15. Christopher Youngbauer
16. Sara Bedolla
17. Rosa Garcia
18. Jordan Williams
19. Dodi Gomez
20. Jo Weathersby
21. Carrie Perry
22. Savina Dramitinos
23. Graciela Alvarez
Below are the comments and questions from the RAB at the meeting:
Overall, all RAB members expressed support for the proposed policies and had no objections. Many of their inquiries focused on gaining a better understanding of the proposed policies and addressing individual concerns, which are being addressed separately.
Comments
• While discussing the Five-Year PHA plan goal: Assist the homeless population in Anaheim, CA, a RAB member asked is it possible for AHA to have inspection for the CHIP Program.
AHA staff explained that there are inspections conducted for the CHIP Program. Currently, the City of Anaheim has subrecipients who operate the CHIP program and perform the inspection for the unit.
They are trained in HUD HQS inspections and are certified to perform the inspection as part of their program implementation.
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• While discussing Section C.2. Five-Year PHA Plan, a RAB member asked about payment standards.
Specifically, when is the analysis done, and why is there no increase in payment standards when there are increases in the rental market?
AHA staff explained that the analysis is conducted annually between July and September, with the results published in October. The payment standards are reviewed and updated each year, and annual reexaminations use the most current payment standards available at that time. Regarding the decision not to increase payment standards this year, AHA staff clarified that the analysis considers market rates and determines an average based on the rental prices of specific bedroom sizes. Additionally, staff directed RAB members to Chapter 16-II.B. of the Administrative Plan for a detailed explanation and confirmed that a staff member would share the payment standard methodology with participants.
• While discussing Section C.2. Five-Year PHA Plan, an RAB member inquired about the measures AHA has in place to protect tenants when a unit repetitively fails an HQS inspection to the extent that it requires the tenant to vacate within 30 days.
AHA staff explained that if a unit continues to fail inspections and does not meet HQS requirements, subsidy payments cannot be made. However, there is a new section in the proposed Administrative Plan (10-I.B.) that discusses this very topic and provides new policies that expedite the processing of a request to move and grant families an initial voucher search time of 120 days (as opposed to 60 days to new voucher holders). AHA staff also explained that AHA can provide extensions, which must be submitted through the assigned Housing Specialist, and try to assist in searching for a unit when possible.
• While discussing Section C.2. Five-Year PHA Plan, a RAB asked whether Housing Choice Vouchers (HCVs) holders could be transferred to Project-Based Voucher (PBV) units.
AHA staff clarified that HCV holders cannot directly transfer to PBV units, as each PBV development maintains its own independent waiting list. Applicants are selected exclusively from the respective waiting list for each development. Additionally, PBV properties may have specific eligibility criteria, such as age restrictions or household size requirements.
• While discussing a policy change in Section B.1. of the Proposed Annual PHA Plan under Chapter
3.I.M Live-in Aide, an RAB member asked whether the income of the live-in aide affects the rental assistance tenant portion.
AHA staff clarified that the income of a live-in aide is not considered household income and does not affect the tenant’s rental assistance calculation.
• While discussing policy change in Section B.1. of the Proposed Annual PHA Plan under Chapter
3.III.B Mandatory Denial of Assistance, which defines current use of illegal drugs to determine eligibility into the program, a RAB member asked for clarification on tenant using substances and the treatment process.
AHA staff explained that this policy emphasizes a holistic approach following previous guidance from HUD, focusing on the individual’s overall situation and the steps they have taken toward rehabilitation. The PHA seeks to evaluate cases on an individual basis, with the goal of removing barriers to housing. The policy allows for flexibility, where the PHA may waive the definition of "currently engaged" for applicants who demonstrate progress in reintegration and are actively participating in and fully compliant with a treatment program. This can be verified through third-party documentation.
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• While discussing policy change in Section B.1. of the Proposed Annual PHA Plan under Chapter 4.II.F Purging the Waiting List, the RAB asked for clarification about the purging of the waiting list.
AHA staff explained that the purpose of purging the waiting list is to ensure that all contact information is current and to confirm that individuals are still interested in remaining on the list. AHA will not remove anyone who responds and is eligible to remain on the waiting list..
• While discussing policy changes in Section B.1. of the Proposed Annual PHA Plan under Chapter
6.II.D Health and Medical Care Expenses Deduction, RAB members asked three questions: first, whether a one-time large medical expense is included; second, whether the expense must be monthly and of the same amount; and third, if counseling qualifies as a medical expense.
AHA staff explained that, in response to the first question, one-time large medical expenses are included in the calculation. For the second question, there is a section on page 3 of the annual reexamination packet that asks if the applicant is disabled and whether their medical expenses exceed the 3% threshold; only if the expenses meet or exceed this threshold do families have to submit verifications and a calculation to determine the deduction will be performed. The expenses can be the same each month but don’t have to be. Regarding the third question, AHA staff clarified that therapy expenses paid out-of-pocket may be eligible for submission. Applicants should answer "yes" to the medical expense question on the annual reexamination form, and the Housing Specialist will conduct a further review. The medical expense deduction is permitted only for families in which the head, spouse, or cohead is at least 62 or is a person with disabilities.
• While discussing policy changes in Section B.1. of the Proposed Annual PHA Plan under Chapter
6.III.D Applying Utility Allowances, a RAB member asked if the Utility Allowance Analysis has changed and if it is up to date.
AHA shared that the Utility Allowance analysis and methodology are found in Chapter 16 of the Administrative Plan and have not changed. The agency has been exploring options to engage a company for a potential updated analysis.
• While discussing policy changes in Section B.1. of the Proposed Annual PHA Plan under Chapter
7.I.C Up Front Income Verification, an RAB member asked if the amount of money in their bank account affects them.
AHA staff explained that the amount of money in a household's bank account can impact eligibility for the Housing Choice Voucher (HCV) program. If the amount in the bank account exceeds a certain threshold, it may affect the household's eligibility or the calculation of their rental assistance. When net family assets are $5,000 or less, the PHA will include in annual income the actual income anticipated to be derived from the assets. When the family has net family assets in excess of $5,000, the PHA will include in annual income the greater of (1) the actual income derived from the assets or (2) the imputed income. Imputed income from assets is calculated by multiplying the total cash value of all family assets by the current HUD-established passbook savings rate. Please refer to Chapter 6-I.G. for detailed policies.
• While discussing policy changes in Section B.1. of the Proposed Annual PHA Plan under Chapter
7.I.C Up Front Income Verification, a RAB Member asked does their FSS benefit count against them.
AHA staff explained that FSS escrow deposit and associated savings do not count as income for the purposes of the HCV program, but any income the participant earns during their participation in FSS is subject to the normal income inclusion rules.
• While discussing policy changes in Section B.1. of the Proposed Annual PHA Plan under Chapter
7.I.C Up Front Income Verification, an RAB Member asked if one-time civil lawsuit settlements are included in asset calculation.
AHA refers to Chapter 6 Section Lump-Sum Receipts for the answer on asset calculation (p. 6-15) ATTACHMENT 6
“Payments that are received in a single lump sum, such as inheritances, capital gains, lottery winnings, insurance settlements, and proceeds from the sale of property, are generally considered assets, not income. However, such lump-sum receipts are counted as assets only if they are retained by a family in a form recognizable as an asset (e.g., deposited in a savings or checking account).”
• While discussing policy changes in Section B.1. of the Proposed Annual PHA Plan under Chapter
7.I.C Up Front Income Verification, a RAB Member asked how AHA calculates income for non- traditional jobs (Uber, Lyft, etc)
AHA staff clarified that this type of income is currently being calculated using self-employment policies found in 7-III.B. and that the Administrative Plan is being updated to include a more specific calculation for “gig employment.”