3. FY 2025-2026 Anaheim Housing Authority Administrative Plan Policy Updates

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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=

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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.

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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

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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.

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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.

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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

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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. […]

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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:

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.

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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.

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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.

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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.

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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

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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

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.

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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:

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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)]

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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

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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

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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-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
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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.

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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-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
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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-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
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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-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.

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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-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
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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-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.

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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.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:

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.

ATTACHMENT 1 Page 30 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.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.

ATTACHMENT 1 Page 31 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.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

ATTACHMENT 1 Page 32 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.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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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: 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

ATTACHMENT 1 Page 34 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-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:

All schedules
completed for
ATTACHMENT 1 Page 35 of 62
B.1 Revision of the PHA Plan Elements

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
ATTACHMENT 1 Page 36 of 62
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.

ATTACHMENT 1 Page 37 of 62
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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.

ATTACHMENT 1 Page 38 of 62
B.1 Revision of the PHA Plan Elements

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.

ATTACHMENT 1 Page 39 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-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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B.1 Revision of the PHA Plan Elements

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

ATTACHMENT 1 Page 43 of 62
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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

ATTACHMENT 1 Page 44 of 62
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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

ATTACHMENT 1 Page 46 of 62
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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 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

Required Reporting
HUD regulations give the PHA the freedom to determine the circumstances under which families will be required to report changes affecting income.

Families are required to report when a family member obtains new or replacement employment income within ten (10)
business days of the change.

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.

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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.

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.

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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
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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.

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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
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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.

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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

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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
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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

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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

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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

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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
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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

Anaheim City CouncilApril 8, 2025

Anaheim City Council
April 8, 2025