Agenda packet, joint meeting — Glendale City Council, April 28, 2026

A G E N D A
JOINT MEETING: GLENDALE CITY COUNCIL AND GLENDALE HOUSING AUTHORITY

COUNCIL CHAMBERS
613 E. Broadway, 2nd Floor
Glendale, CA 91206
APRIL 28, 2026 - 3:00 PM

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PUBLIC COMMENT GUIDELINES
The City Council and Housing Authoirty welcome public input at City Council meetings. Public input during joint meetings is regulated by the City Council’s Rules of Order, Procedure and Decorum for the Conduct of City Council Meetings as set forth in Resolution No. 25-76, which will be summarized below.

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APRIL 28, 2026 - 3:00 PM

ROLL CALL
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3:00 PM
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Report of the City Clerk of the City Council and Housing Authority, re: Posting of Agenda.

The Agenda for the Tuesday, April 28, 2026 joint public meeting of the City Council and Housing Authority was posted on April 24, 2026, on the Bulletin Board outside City Hall.

JOINT PUBLIC MEETING
of the City Council and Housing Authority is hereby called to meet at

3:00 PM
on
Tuesday, April 28, 2026
, in the Council Chamber, 613 E. Broadway,
2nd Floor, Glendale, CA 91206 to consider the following item(s) of business, to wit;

1. Community Development, re:

Report on Emergency Housing Choice Voucher
Transition Plan
a. City Council Motion directing staff on the Section 8 waitlist strategy b. City Council Motion approving the Parkview Selection Plan c. City Council Motion approving the tiered prioritization strategy and approving the deployment of available local and regional resources, HOME, Homeless Services funds, as a temporary subsidy to prevent immediate displacement for the most vulnerable household
s

ADJOURNMENT

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CITY OF GLENDALE, CALIFORNIA
REPORT TO THE JOINT MEETING: GLENDALE CITY COUNCIL AND

GLENDALE HOUSING AUTHORITY

AGENDA ITEM
Report: Report on Emergency Housing Choice Voucher Transition Plan

1. City Council Motion directing staff on the Section 8 waitlist strategy.

2. City Council Motion approving the Parkview Selection Plan.

3. City Council Motion approving the tiered prioritization strategy and approving the deployment of available local and regional resources, HOME, Homeless Services funds, as a temporary subsidy to prevent immediate displacement for the most vulnerable households.

COUNCIL ACTION
Item Type: Action Item
Approved for April 28, 2026 calendar

EXECUTIVE SUMMARY
This report outlines Housing Division staff’s proposed strategy for managing the federal wind-down of the Emergency Housing Voucher (EHV) program, aimed at preventing displacement for 188 vulnerable households. Due to soaring regional rents, federal EHV funding is projected to be exhausted by the end of calendar year 2026. Because Glendale’s regular Section 8 program is already facing a $700,000 shortfall, it cannot currently absorb these households.

At the center of the plan is a four-tier prioritization framework designed to guide the use of limited resources if federal funding ends before other solutions are in place. The framework prioritizes seniors, persons with disabilities, families with children, and households with histories of homelessness or fleeing domestic violence. Conversely, the lower tiers include households with relatively greater ability to transition with reduced subsidy support. This structure is intended to ensure that available resources are directed first at those at greatest risk of displacement.

The Housing Division staff has identified approximately $4.1 million in potential funding sources, including HOME TBRA funds and Homeless Services Local Solutions funding through Measure A, to serve as temporary funding. Longer-term options include Tenant 4 of 66

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Protection Vouchers (TPVs) and affordable housing placements, such as within Parkview Glendale, an affordable housing project.

Because TPVs are the most promising potential federal replacement resource, staff will continue to pursue them as the primary long-term transition strategy. However, given the uncertainty regarding whether TPVs will be awarded, the number of vouchers that may be available, and the timing of their availability, this report outlines a contingency scenario in which local funding would be used to temporarily subsidies EHV applicants.

RECOMMENDATION
The City Council may approve all, none, or any combination of the following recommendations:

1.Direct Staff on Housing Choice Voucher Waitlist Strategy: Select one of three outlined options regarding the placement of EHV households onto the regular Section 8 waitlist as follows:

1.1 Pursue HUD Waiver

1.2 Initiate Targeted Waitlist Opening

1.3 Defer Action

2.Approve Parkview Selection plan: Direct staff to implement either Option A (Income-Weighted), Option B (Age-Weighted), or provide other direction for filling the eleven (11) available HOME ARP senior units.

3.Approval and Prioritization of Home and Homeless Services Funds: Direct staff to establish temporary subsidy using Home and Homeless Services Funds.

ANALYSIS
For 50 years, the Glendale Housing Authority has administered the federal Housing Choice Voucher (HCV) program, commonly known as the Section 8 Program. Funded by the U.S. Department of Housing and Urban Development (HUD), HCV is a core component of Glendale’s housing stability framework. It provides rental subsidies to low-income residents, seniors, and individuals with disabilities, bridging the gap between what they can afford and the contract rent of private-market housing.

The Housing Division staff manage all aspects of the program, including determining eligibility, conducting unit inspections, monitoring compliance, and issuing ongoing housing assistance payments (HAP) directly to landlords. Because vouchers are limited, applicants are selected from a waiting list using a points-based preference system. The waiting list is currently closed with 722 applicants, many of whom have been waiting 25 years. When vouchers do become available, the preference system prioritizes the 5 of 66

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elderly, individuals with disabilities, U.S. Veterans, local residents, and high-need households (such as those experiencing homelessness, victims of hate crimes, or those displaced by government action).

The Housing Authority administers a total of 2,572 vouchers across all programs, supported by an annual HAP budget of $51,794,904 and an administrative fee budget of $3,680,362. A detailed breakdown of the Housing Authority’s current voucher capacity, special purpose programs, waitlist demand, and financial data is provided in Attachment

1. While the HCV program is a vital community resource, it is currently operating in a challenging regional market. Rapidly increasing rents have directly driven up the average subsidy cost per household and made the lease-up process significantly more difficult for participants. More importantly, because per-unit subsidy costs have risen faster than federal renewal funding allocations, the regular HCV program is currently operating under a budget shortfall of approximately $700,000. This deficit directly restricts the staff’s ability to absorb additional households, including EHV participants, into the standard program without new, sustainable federal funding.

Shortfalls occur when projected housing assistance payments exceed the annual HUD renewal funding allocation and available reserves. Shortfalls are common nationally and particularly in high-cost rental markets where per-unit subsidy costs have increased faster than federal funding. Key drivers locally include:
Rapid market rent inflation.
Higher payment standards required to maintain housing stability (last year, for the first time in the agency’s history, payment standards were based on Small Area Fair Market Rents (FMRs) as required by HUD via Notice PIH 2024-34, Attachment 2). Increased overall per-unit subsidy costs.

EMERGENCY HOUSING VOUCHERS (EHVS)
In addition to standard tenant-based vouchers and portability administration, the Housing Division manages several targeted HUD programs, including EHVs. EHV’s are special- purpose subsidies targeted at highly vulnerable populations, including those experiencing or at risk of homelessness, and survivors of domestic violence, sexual assault, stalking, or human trafficking. Through EHVs, HUD provided 70,000 vouchers to local Public Housing Agencies (PHAs) across the United States to assist the qualifying households identified above.

While EHV funds were originally anticipated to last through September 30, 2030, rapidly rising rental costs and higher per-household subsidy levels have accelerated spending 6 of 66

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nationwide. However, HUD’s current estimate is that EHV funding could potentially carry programs into approximately Calendar Year 2026, but this is contingent on national spending trends and subsidy costs, and is not guaranteed to fully cover all households through that period. Consequently, HUD has mandated that all housing authorities stop issuing new EHVs and prepare for an orderly program wind-down.

This accelerated timeline is the direct result of the federal funding environment and not local policy decisions by the City. Between FY 2021 and FY 2026, HUD’s FMR benchmarks for the Los Angeles area surged, increasing nearly 30% for one-bedroom units and 26% for two-bedroom units.

Currently, the City supports 188 households through the EHV program. For each leased EHV household, the Housing Authority must make an ongoing HAP payment to the owner on the household’s behalf in order to keep them housed. Glendale’s local EHV program currently provides the following subsidy:
Monthly EHV HAP obligation: $347,597
Annual EHV HAP obligation: $4,171,164
This challenge is not unique to Glendale. To understand how regional peer agencies are navigating the EHV wind-down, the City surveyed several neighboring housing authorities, including the Orange County Housing Authority (OCHA), the Housing Authority of the City of Los Angeles (HACLA), Burbank, Anaheim, and Los Angeles County Development Authority (LACDA).

Agencies were asked a consistent set of questions regarding their EHV scale, average subsidy costs, populations served, and planned transition strategies. The goal was to identify workable solutions and understand how common constraints are shaping regional responses.

While a comprehensive comparison table is provided in Attachment 3, the key findings below highlight how an agency's regular HCV budget directly dictates its EHV transition capacity.

According to the survey results, Orange County and Anaheim reported that they plan to transition EHV households into their regular HCV programs as funding and capacity allow. Similarly, while Burbank hopes to absorb its full EHV portfolio, it may rely on temporary Measure A funds if full transition is not feasible. In contrast, HACLA reported that it does not currently have an absorption plan due to its HCV funding shortfall.

LACDA indicated that it is still evaluating available options, including prioritizing the most vulnerable households for possible transition to the regular HCV program and pursuing any Tenant Protection Voucher opportunities that may become available through HUD.
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While some agencies reported that they intend to transition EHV households into their regular HCV programs as funding permits, those plans remain conditional and are not guaranteed solutions. In practice, no surveyed agency appears to have a fully certain or permanent path forward currently. Instead, most are operating within a high degree of uncertainty and are largely dependent on evolving federal, state, and local funding developments to determine which transition options will ultimately be feasible.

A common question regarding the EHV wind-down is whether the City can simply transition the 188 EHV households into the regular Section 8 (HCV) program or move them onto the HCV waiting list. Evaluating this option requires a clear understanding of our current financial constraints, the realities of the waitlist, and federal HUD guidelines.

While HUD guidance permits housing authorities to absorb EHV households into the regular HCV program, this option is not currently available to the Glendale Housing Authority due to our program operating in a funding shortfall. Thus, we do not have the ability to absorb the EHV households into the existing HCV program and are prohibited from issuing new vouchers. While the FY26 Transportation, Housing and Urban Development, and Related Agencies (THUD) bill could provide enough funding to address this shortfall and allow for some limited movement on the waiting list, it is not expected to be enough to absorb the entire EHV portfolio of 188 households.

If the agency recovers from this shortfall in the future, the procedural process of moving EHV households into the regular HCV program would require them to be placed on the HCV waiting list first.

Although the City cannot currently absorb these households into the program, the option to move EHV residents onto the waiting list is currently available and can be executed regardless of our shortfall status. Should the City choose this route, it can be accomplished in one of two ways:
HUD Waiver (Automatic Placement): HUD offers a streamlined submission and review process for a regulatory waiver that, if approved, would permit PHAs to place all EHV families on its HCV waiting list with the appropriate preference.

This would automatically transfer all 188 EHV households without requiring individual applications.
Targeted Waitlist Opening: The Housing Authority could formally open the waitlist strictly for EHV participants, allow them to apply, and assign them "preference points" to prioritize their position.

While these pathways exist, it is critical to note that the waiting list is not an immediate housing solution. Placement on a waiting list does not provide a subsidy; it merely ensures a household is "in line" for assistance. Without a federal budget increase, a 8 of 66

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waiting-list-based transition would likely take years to translate into actual assistance.

As a result, placement on the waitlist does not protect EHV households from housing instability when the federal EHV assistance expires. Additionally, prioritizing EHV households would directly impact those on the regular Section 8 waitlist who have been waiting over twenty years. In short, the ability to transition these households to the regular Section 8 program depends entirely on resolving our current budget shortfall.

In fact, HUD issued Notice PIH 2025-19 (Attachment 4) in June 2025, strongly encouraging PHAs to transition EHV families to the HCV program and provided guidance on how to execute this process. However, the guidance emphasizes that the PHA must have available HCV capacity to support EHV families. This means the agency must have federally funded, unused voucher "slots" available. Because the Housing Authority is currently in shortfall, it is unable to issue any additional vouchers at this time. New federal funding is the strict prerequisite to unlocking this transition.

If federal funding were to materialize and vouchers become available, Notice PIH 2025- 19 would allow the Housing Authority to execute the transition with significantly reduced administrative barriers.

Given these conditions, staff is seeking direction from the City Council regarding how to proceed with the HCV waitlist strategy via the following options:

1. Direct Staff to Pursue the HUD Waiver: Council may direct staff to immediately submit a good-cause justification to HUD requesting the regulatory waiver to automatically place all 188 EHV households onto the closed HCV waiting list.

2. Direct Staff to Initiate a Targeted Waitlist Opening: Council may direct staff to begin the formal process of amending the Administrative Plan to open the waitlist exclusively for EHV participants and establish a new preference point ranking system. This will require a formal public comment period and subsequent Board approval.

3. Defer Waitlist Action: Council may choose to take no action regarding the HCV waiting list at this time. Under this option, staff will focus entirely on pursuing TPVs and deploying local funds, if approved by Council.

Should the City Council direct staff to pursue the preceding transition strategy, staff will return at a later date with a detailed implementation plan outlining the necessary administrative steps and policy amendments.

Since managing this wind-down requires adapting to unpredictable external factors, staff continues to monitor pending state and federal funding opportunities, temporary local funding sources currently available, and any other alternative options. 9 of 66

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The timeline and ultimate cost depend heavily on pending federal and state funding decisions. Staff is actively pursuing the following external resources:
Federal Funding and Tenant Protection Vouchers: The FY26 federal budget expanded TPVs to explicitly include EHV households. TPVs are the most promising federal replacement option, but staff does not yet know if the Housing Authority will receive any TPVs, how many will be available, or what application processes and program rules HUD will ultimately require. State Funding: The City is pursuing a direct $3.6 million state budget request to support the local EHV program. Simultaneously, we are tracking a proposed $500 million statewide grant program that could utilize stabilization funds through Continuums of Care (CoCs).

Because this timeline is a race between our expiring EHV funds and the arrival of new money, staff is planning for both a best-case scenario where external funds absorb the EHV portfolio; as well as a contingency scenario requiring strict reliance on limited local resources, as described in this report’s following two sections. However, it is important to note that even in a best-case scenario, any TPV allocation we receive may not be enough to cover all households.

PARKVIEW GLENDALE AFFORDABLE HOUSING PROJECT
Staff has actively explored alternative long-term placement strategies intended to transition eligible households directly into dedicated units within local affordable housing developments and specialized supportive care facilities.

One opportunity for transitioning seniors is associated with the Parkview Glendale development, which includes eleven dedicated units. To qualify for the HOME-ARP units, households must meet one of HUD's designated Qualifying Populations, which include individuals and families who are homeless, at risk of homelessness, fleeing domestic violence, dating violence, sexual assault, stalking, or human trafficking, or at greatest risk of housing instability.

Because Parkview operates with a fixed pro-forma rent of $750 for 1 bedroom and $710 for studio, the City must bridge the gap between the rent and what the senior can afford to pay (calculated at 30% of their income). Housing division staff is exploring funding sources to address this funding gap and has modeled two viable pathways for filling these eleven units, which presents a direct policy trade-off between cost efficiency and protecting the most vulnerable. The two potential pathways for these units are as follows:
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Option A (Income-Weighted): Prioritizes seniors with higher fixed incomes. This requires a lower City subsidy (approximately $1,068 per month or a $221,000 one-time allocation) because the tenants can contribute more toward their rent. Option B (Age-Weighted): Prioritizes the oldest seniors (ages 78–87). Because these residents typically have extremely low incomes, this requires a higher City subsidy (approximately $4,035 per month or a $837,000 one-time allocation).

A complete household-by-household financial breakdown of these two pathways, including the projected cost of providing subsidies over the 15-year affordability covenant period, is provided in Attachment 5.

Additional Options Considered
Another potential temporary option (15 to 24 months) is associated with Hamilton Court, which currently has eight available spaces that can be utilized to directly support women in the EHV program who are fleeing violence and facing housing instability. To allocate these units, the City will inform EHV participants of the opportunity so that those who meet the definition of fleeing violence may submit an application. Because the anticipated need exceeds the available number of spaces, the final residents will be selected through a randomized lottery drawn from that pool of qualified applicants. Staff is continuing to explore this option and is awaiting final confirmation on feasibility and implementation details.

In addition to traditional housing placements, staff also explored the potential of utilizing a Single Room Occupancy (SRO) model for single adults and seniors who would benefit from on-site supportive services. However, after a thorough evaluation of the financial, security, and liability risks associated with this model, it’s been determined that pursuing an SRO facility is not a viable option at this time.

Staff visited the site located in the Pacific–Edison neighborhood on Central Ave. The 30,000 sq ft facility is currently operating as an intermediate care facility for individuals with intellectual or developmental disabilities. There are several concerns regarding this type of assistance, including feasibility, security and liability factors.

The building is a large facility and contains 35 functional rooms with shared bathroom and kitchen facilities. The facility is dated and would need significant improvements, estimated at a minimum of $250,000 in order to bring the units into functional condition.

The owner has requested between $35,000 and $40,000 in monthly rent under a long- term triple net (NNN) lease. In addition to the base rent, the city would be responsible for utilities, insurance, a provider to manage the facility and ongoing maintenance.

These additional obligations increase the estimated monthly total cost to over $60,000. 11 of 66

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Additionally shared bathrooms and kitchens create safety, privacy, and liability concerns. Managing an environment with shared facilities increases the city’s exposure to liability regarding resident health, safety, and overall facility management.

When considering these costs alongside the potential liabilities of property management, staff does not believe this project is feasible. The cost (excluding the $250,000 upfront investment and unpredictable maintenance issues) of operating the facility is estimated to be $1,714 per resident.

The other option would consist of a complete renovation of the building to increase housing capacity. This would be a significantly more expensive endeavor, potentially costing millions of dollars.

Implementation would require a formal policy decision and site approval, with operating costs potentially supported by the HOME or Homeless Services funds identified above.

APPROVAL AND PRIORITIZATION OF HOME AND HOMELESS SERVICS FUNDS As we prepare for the expiration of federal EHV funds, staff has identified a few primary funding options to establish temporary rental subsidy programs. Each resource has specific constraints regarding how it can be used and which populations it can support.

The following temporary funding options may be considered to establish temporary rental subsidy programs:
HOME Funds - Tenant Based Rental Assistance (TBRA) - $3,700,000 oThis is a local resource used to provide time-limited rental assistance where the program structure aligns with EHV household profiles. Funds come from federal HUD block grants allocated to the City to fund affordable housing initiatives. A key constraint is that the use of these funds is subject to federal program rules and requires direct tradeoffs with other HOME-eligible City priorities.
Homeless Services Sources - $434,000
oThese are short-term stabilization resources designed to prevent immediate displacement where rental assistance is a permitted use.

Funds come from State and County allocations, specifically $434,000 from County Measure A (Note: Final allocations are pending). A specific constraint of this funding is that it is not sized to replace a large tenant- based subsidy portfolio for long durations, making it best suited for targeted coverage of a limited tier.

Should the City Council elect to utilize the HOME and Homeless Services funds to establish a temporary rental subsidy program as a strategy to prioritize the 188 EHV 12 of 66

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households, staff has developed a tiered prioritization framework to ensure these limited bridge resources are deployed where they prevent the greatest harm. In developing the following framework, staff conducted a preliminary review of each household based on housing stability indicators. The information presented reflects the most current data available at this time. Prior to implementation, staff will conduct a re-evaluation of each household to verify applicant status and confirm that key factors, including income, health status, and other relevant conditions remain unchanged.

This proposed tiered approach aligns with HUD guidance to prioritize seniors, individuals with disabilities, individuals with long histories of homelessness, and those least likely to stabilize without assistance. Please note that the numbers in parentheses next to each tier indicate the number of EHV households that would be placed under each tier. Because this represents a current snapshot in time, these household counts may shift slightly as staff conducts final verifications of income, age, and health status prior to deploying any temporary bridge funds.
Tier 1 – Highest Risk (24 Households): Reserved for the most vulnerable residents: single seniors (62+) who are disabled, earn less than 15% AMI, and were literally homeless or fleeing violence.
Tier 2 – Moderate Risk (47 Households): Protects disabled adults or families with children who were literally homeless and earn 30% AMI or less. Any Glendale resident 70 years or older is automatically protected in this tier if they did not qualify for Tier 1.
Tier 3 – At-Risk (80 Households): Captures those certified as "At Risk" rather than literally homeless. This serves as a safety net for all seniors (62+), any household with a disability/children, or anyone earning below 30% AMI. Tier 4 – Transition (37 Households): Households with the highest relative capacity to absorb a subsidy reduction, consisting of able-bodied adults under 62 earning above 30% AMI, and any household residing outside of Glendale.

Tiering is a planning tool; it does not change a household’s current assistance while federal funding remains, but provides a transparent framework for deploying resources.

A detailed description of the Tiering approach and priority sorting rule and an alternative option prioritizing senior applicants is also provided in Attachment 6 and the demographics for each tier are provided in Attachment 7.

If the City Council elects to deploy temporary bridge funds, a critical decision remains:
how to distribute them. The funds can be allocated in several ways, ranging from providing short-term support for all 188 households, to utilizing the tier system to provide subsidy strictly for the most vulnerable. To guide the deployment of the $4.1 13 of 66

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million in available resources ($3.7 million HOME TBRA + $434,000 Homeless Services) and help the Council visualize these trade-offs, staff evaluated three primary coverage scenarios. These models are designed to show the Council how many families can be sustained, and for how long, depending on which tiers are funded under each strategic approach. A complete breakdown of the coverage scenarios below and additional scenarios, including specific monthly costs and tier-by-tier expenditure rates, are provided in Attachment 8.

Sample scenarios:
Scenario A (Universal Coverage): Funds all 188 households equally but exhausts all combined bridge resources in approximately one year, returning to the same situation we have today.
Scenario B (Tiered Coverage): Focuses resources solely on the most vulnerable (Tiers 1 and 2) from day one. This significantly extends the funding runway (approximately 2.5 years) but would result in the immediate loss of subsidy for households in Tiers 3 and 4.
Scenario E (Hybrid / Phased Approach): This scenario provides 3 months of universal coverage for all 188 households to allow time for intensive case management and placement planning. After Month 3, bridge assistance ends for Tiers 3 and 4, and the remaining funds are dedicated exclusively to sustaining the 71 highly vulnerable households in Tiers 1 and 2 for approximately an additional 23 months.

Because local bridge resources are finite, households cannot secure long-term, subsidized housing before their short-term coverage expires. If federal or state interventions do not materialize, it will result in the forced termination of cases, resulting in a loss of rental assistance for these households.

If the City Council approves staff’s recommendations as described in this staff report, the following framework outlines the path for implementing and sequencing the strategies and options identified above. If approved, the framework is designed to remain flexible and adaptive, allowing staff to respond in real time to changes in federal timelines and funding availability.

Reevaluate, Communicate and Prioritize
Maintain current EHV households under existing federal funding. While we anticipate support through late 2026, we are monitoring HUD communication daily to adjust if the federal timeline accelerates. Clear communication with participants is ongoing to ensure they understand the federal wind-down. Review in detail all 188 households current status and assign them to Tiers 1–

4. This framework is intended to guide rapid resource deployment to the most 14 of 66

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vulnerable households if federal funding is exhausted earlier than expected.

Monitor State and Federal Funding landscape
Staff will continue to monitor federal and state funding opportunities in order to take advantage of any additional funding that may support EHV’s long-term like the TPV funds.

Establish Temporary Subsidy
Begin work to set up the administrative framework for the temporary rental subsidy program using the $4.1 million in identified bridge funds. Structure the program guidelines and payment mechanics based on the specific coverage scenario approved by City Council, ensuring the system is fully operational and ready to launch if existing federal EHV funding is exhausted and new state or federal replacement funds do not materialize first.

Parkview Placements
Match households to available units at Parkview.
Prepare eleven residents to transition if federal or state funding options do not materialize.

Future Active Monitoring & Crisis Intervention
For households that do not receive a direct voucher replacement or other support, the Housing Division staff will not simply end the relationship. Instead, staff proposes moving these individuals into a long-term monitoring phase.

Should these households face an immediate crisis after their EHV assistance ends, staff will look to secondary options, including Gateways Hospital’s Enhanced Care Management, Rapid Rehousing, or Los Angeles County Affordable Housing Solutions Agency (LACAHSA) funding, to provide short-term stabilization. As participants transition off the federal EHV program, staff maintains a mechanism to intervene if they are at risk of falling back into homelessness.

In conclusion, it is important to acknowledge the stark reality of the current fiscal landscape. Even with full implementation of this proposed strategy, staff cannot guarantee continued assistance for every household currently enrolled in the EHV program.

The wind-down strategy is designed to protect our most vulnerable seniors, disabled individuals, families with children, those fleeing violence and those with a history of homelessness. However, the inevitable trade-off is that households in lower-priority tiers may face a permanent transition off the program if federal resources are not renewed.

Additionally, any new Federal and State funding will be finite and potentially not all eligible participants will likely be served. Some participants will reach the end of their assistance without a direct voucher replacement.
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Furthermore, for some participants, long-term housing stability will require relocation.

Whether transitioning into a partner development with a lower subsidy or seeking more affordable market-rate housing outside of Glendale, maintaining stability may involve a transition to other housing options. To remain housed, participants must be prepared to accept the housing options that are available and feasible within the City's constrained resources.

The Housing Authority’s commitment is to ensure that no household transitions into homelessness. However, the "off-ramps" provided may not mirror the exact level of support or the specific housing units currently enjoyed under the EHV program. This is the difficult reality of navigating the wind-down of a major federal initiative.

STAKEHOLDERS/OUTREACH
Not applicable.

FISCAL IMPACT
The Housing Authority’s current Emergency Housing Voucher (EHV) portfolio supports 188 households and carries an estimated subsidy cost of approximately $347,597 per month (approximately $4,171,164 annually). The proposed options would not have an impact on the General Fund.

If Council approves the proposed transition framework, staff has identified approximately $4.1 million in primary local and regional funding sources potentially impacted as temporary bridge resources as follows:
HOME: approximately $3,700,000
Homeless Services Funding: approximately $434,000
Additionally, if Council elects to assist eleven residents through the Parkview project, an estimated one-time allocation of $221,000 to $837,000 will be required. These funds would be sourced from LACAHSA or other non-General Fund sources. Following Council direction, staff will revise their funding plans with the federal and county funding sources and return to Council at a later date with a request for appropriation.

CAMPAIGN DISCLOSURE
This item is exempt from campaign disclosure requirements. 16 of 66

114
26-89993
6 8
1 1

ALTERNATIVES TO STAFF RECOMMENDATION
Alternative 1: City Council may reject the proposed options and direct staff to explore alternative strategies.

Alternative 2: City Council may elect to consider any other alternative not proposed by staff.

ADMINISTRATIVE ACTION
Submitted by:

Jack Wong, Interim Community Development Director
Prepared by:

Michael Fortney, Deputy Director of Community Development/Housing Sipan Zadoryan, Housing Supervisor
Approved by:

Roubik R. Golanian, P.E., City Manager

EXHIBITS/ATTACHMENTS
Attachment 1 – Program Snapshot
Attachment 2 – PIH 2024-34
Attachment 3 – Peer Agencies
Attachment 4 – PIH_2025-19
Attachment 5 – Parkview Breakdown
Attachment 6 – Tier Breakdown
Attachment 7 – Tier Demographics Update
Attachment 8 – Subsidy Allocation Scenarios
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1. Option 1 – Council directs staff to pursue the HUD Waiver as described in the Report.

2. Option 2 – Council directs staff to initiate a target waitlist opening as described in the Report.

3. Option 3 – Council may defer waitlist action as described in the Report.

Vote as follows:

Ayes:

Noes:

Absent:

Abstain:
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Vote as follows:

Ayes:

Noes:

Absent:

Abstain:
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M O T I O N
Moved by Council Member _________________________, seconded by Council Member ___________________________, that with respect to the Joint Report to the Council and Housing Authority dated April 28, 2026 (“Report”) regarding the Emergency Housing Choice Voucher Transition Plan, the Council approves the tiered prioritization strategy and approves the deployment of available local and regional resources, HOME, Homeless Services funds, as a temporary subsidy to prevent immediate displacement for the most vulnerable households, as described in the Report.

Vote as follows:

Ayes:

Noes:

Absent:

Abstain:
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Attachment 1
Program Snapshot
Program Type Total Active Vouchers
Regular HCV (Section 8) 1411
Port-Ins (Outside PHAs) 950
Special: Emergency Housing (EHV) 188
Special: VASH (Veterans) 13
Special: Mainstream 12
TOTAL VOUCHERS ADMINISTERED 2574
Waiting List
Size 722
Status Closed
Funding
Annual HAP Paid $ 51,794,904
Administrative Fee $ 3,680,362
Average HAP $ 1,628
EHV Funding
Annual EHV HAP $ 4,171,164
Annual EHV Admin $ 366,600
EHV Average HAP $ 1,849
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U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
WASHINGTON, DC 20410-5000

OFFICE OF PUBLIC AND INDIAN HOUSING

SPECIAL ATTENTION OF: NOTICE PIH 2024-34
Office Directors of Public Housing; Issued: September 30, 2024 Regional Directors; Public Housing
Agencies Expires: This notice remains in effect until
amended, superseded or rescinded.

Supersedes: Notice PIH 2018-01 (HA)

Cross References: Notice PIH 2023-32, 88 FR
73352, 81 FR 80567, Notice PIH 2013-18

Subject: Updated and Consolidated Policy Guidance on Housing Choice Voucher (HCV) Program Payment Standards

Table of Contents

1. Purpose ................................................................................................................................ 2

2. Background ......................................................................................................................... 2

3. Fair Market Rents, Small Area Fair Market Rents, and Payment Standards ...................... 2

4. SAFMRs: Mandatory and Opt-in....................................................................................... 8

5. Exception Payment Standards........................................................................................... 11

6. Phase-out of Success Rate Payment Standards ................................................................. 17

7. Deconcentration Payment Standards ................................................................................ 18

8. Payment Standards Lower than the Basic Range ............................................................. 18

9. Applying Increases in the Payment Standard ................................................................... 18

10. Applying Decreases in the Payment Standard .................................................................. 19

11. Reasonable Accommodation Exception Payment Standards ........................................... 20

12. PBVs ................................................................................................................................. 21

13. Administrative Plan Requirements ................................................................................... 22

14. Reevaluation of HUD-published FMRs............................................................................ 23

15. Resources .......................................................................................................................... 23

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2 16. Paperwork Reduction Act ................................................................................................. 24

17. Further Information ........................................................................................................... 24 Appendix A: Summary of Selected Regulatory Changes Effective in 2024 ............................... 25 Appendix B: Examples for Grouping Payment Standards .......................................................... 27

I. Purpose
This Notice provides consolidated and comprehensive guidance to public housing agencies (PHAs) on payment standards that incorporates recent regulatory and policy guidance. While this Notice discusses regulatory changes implemented through the “Housing Opportunity Through Modernization (HOTMA) Act of 2016—Housing Choice Voucher (HCV) and Project- Based Voucher (PBV) Implementation; Additional Streamlining Changes” (FR-6092-F-03), it also covers regulations that were not changed, and other policy guidance previously issued that remains in effect. As a result, this Notice consolidates guidance for PHAs on payment standards.

II. Background
Program regulations at 24 Code of Federal Regulations (CFR) 982.503 and 888.113 describe how PHAs must implement payment standards for their HCV programs. Payment standards are used in the calculation of the housing assistance payment (HAP) that the PHA pays to the owner on behalf of the family leasing the unit. The payment standard amount is the maximum monthly assistance payment that can be paid on behalf of an HCV family.

On October 25, 2023, HUD expanded the required use of SAFMRs to a total of 65 metropolitan areas1, an increase of 41 metropolitan areas, from the original 24 that were established in 2016.2 In addition, on May 7, 2024, HUD updated its payment standard regulations through a final rule, “HOTMA Act of 2016—HCV and PBV Implementation; Additional Streamlining Changes,” hereafter “May 2024 Final Rule.” (FR-6092-F-03). A summary of selected regulatory changes made by the May 2024 Final Rule is provided in Appendix A.

III. Fair Market Rents, Small Area Fair Market Rents, and Payment Standards A. Overview of FMRs and SAFMRs
The HCV program helps low-income families rent eligible units in the private market, by subsidizing a portion of the rent that is paid by the PHA directly to the landlord. Generally, the FMR for an area is the amount that would be needed to pay the gross rent (shelter rent plus utilities) of privately owned, decent, and safe rental housing of a modest (non-luxury) nature

1 Small Area Fair Market Rents in the Housing Choice Voucher Program Metropolitan Areas Subject to Small Area Fair Market Rents, October 25, 2023 (88 FR 73352)
2 Establishing a More Effective Fair Market Rent System; Using Small Area Fair Market Rents in the Housing Choice Voucher Program Instead of the Current 50th Percentile FMRs; Final Rule, November 16, 2016 (81 FR 80567)
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3 with suitable amenities.3 Each year, HUD updates FMRs and publishes them on HUD’s website.4 In the HCV program, the FMR is the basis for determining the “payment standard amount” used to calculate the maximum monthly subsidy for a voucher household.5 The PHA pays a HAP on behalf of an assisted family equal to the difference between the lower of the gross rent of the unit or the payment standard established by the PHA and the family's Total Tenant Payment (TTP), which is generally 30 percent of the household's adjusted monthly income.6 Participants in the voucher program can choose to live in units with gross rents higher than the payment standard but are required to pay the full cost of the difference between the gross rent and the payment standard, in addition to their TTP.7
In the PBV program, the FMRs are used in determining the maximum rent to owner that may be permitted by the PHA for the PBV project. Except for certain tax credit units, the rent to owner must not exceed an amount determined by the PHA, not to exceed 110 percent of the applicable FMR (or any exception payment standard approved by HUD) for the unit bedroom size minus any utility allowance.8 The rent to owner must also not exceed the reasonable rent determined in accordance with 24 CFR 983.303 or the actual rent requested by the owner. In general, SAFMRs do not apply to PBVs regardless of whether HUD designates the metropolitan area or approves the PHA for SAFMRs.9 The exceptions to this general rule are covered in section 12 of this Notice, “PBVs.”
HUD establishes FMRs for different geographic areas and calculates FMRs for all non- metropolitan counties and metropolitan areas.10 FMRs represent the 40th percentile gross rent for typical non-luxury, non-substandard rental units occupied by recent movers in a local housing market.11 Each year, HUD publishes FMRs in the Federal Register (FR) and also makes them available on the HUD website12 with an effective date of October 1.13 HUD initially published FMRs for metropolitan areas and non-metropolitan counties, and more recently also published FMRs for ZIP Codes areas, known as SAFMRs:

3 In addition, all rents subsidized under the HCV program must meet rent reasonableness standards. Rent reasonableness is determined by PHAs with reference to rents for comparable unassisted units. 4 https://www.huduser.gov/portal/datasets/fmr.html
5 24 CFR 982.503(a)(2)
6 24 CFR 5.628
7 Please note that at initial lease up, the family’s share cannot exceed 40 percent of the family’s adjusted monthly income. 24 CFR 982.508
8 24 CFR 983.301(b) and (f)
9 24 CFR 888.113(h)
10 24 CFR 888.113(d)
11 24 CFR 888.111(b) and 888.113(b)
12 FMRs are posted here: https://www.huduser.gov/portal/datasets/fmr.html and SAFMRs are posted here:
https://www.huduser.gov/portal/datasets/fmr/smallarea/index.html 13 24 CFR 888.115(a). HUD will publish a notice announcing the publication of the FMRs in the Federal Register, to be effective October 1 of each year, and provide for a minimum of 30 days of public comments and requested for reevaluation of the FMRs in a jurisdiction. The FMRs will become effective no earlier than 30 days after the date the notice publishes in the Federal Register (e.g., if HUD fails to publish FMRs 30 days before October 1, the effective date will be 30 days after publication), except for areas where HUD receives comments during the minimum 30-day comment period requesting reevaluation of the FMRs in a jurisdiction. After HUD reviews a request for reevaluation, HUD will post on the World Wide Web the final FMRs for the areas that have been reevaluated and publish a notice in the Federal Register announcing the publication and the effective date. 24 of 66

4  Metropolitan area FMRs: HUD uses the metropolitan areas established by the Office of Management and Budget (OMB) and, in some instances, subdivides OMB’s defined metropolitan areas into smaller HUD Metropolitan FMR areas (HMFAs) along historical metropolitan boundaries to preserve continuity of FMR estimates.  Non-metropolitan county FMRs: HUD establishes FMRs for all non-metropolitan counties.
 ZIP Code Areas (SAFMRs): HUD establishes SAFMRs at the ZIP Code level.

Recognizing the variation in rents that occur within large metropolitan areas, SAFMRs are intended to result in payment standards that align more closely with localized rental costs, including higher-cost areas for the express purpose of providing HCV-assisted families with access to areas of high opportunity and lower poverty. In FY 2025, HUD began publishing SAFMRs for non-metropolitan counties in addition to metropolitan areas.

Within each of these FMR areas, the applicable FMR14 for the HCV program is:
 The HUD-published SAFMR;
 The HUD-published metropolitan FMR for any other metropolitan area;15 or  The HUD-published FMR for any other non-metropolitan county.16 Please note that program regulations at 24 CFR 982.503 refer to the “applicable FMR” on numerous occasions. It is important to understand that the “applicable FMR” will be the HUD- published SAFMR for PHAs in mandatory17 SAFMR areas or for those PHAs that have opted-in to using the SAFMR.18
B. Establishing Payment Standard Amounts
The PHA must adopt a payment standard schedule that establishes voucher payment standard amounts for each FMR area in the PHA’s jurisdiction.19 In many cases a single FMR area will cover the PHA’s entire jurisdiction. Some PHAs’ jurisdictions include more than one FMR area.

PHAs administering the HCV program in mandatory SAFMR areas are required to use the SAFMRs when establishing payment standards for those areas (Mandatory SAFMR areas).

For FMR areas that are not mandatory SAFMR areas, the published metropolitan or non- metropolitan county FMRs are used by the PHA to establish the payment standard amounts.

14 24 CFR 982.503(a)(1)(i-iii)
15 The applicable FMR for a PHA that has adopted exception payment standards based on the SAFMR but administers in metropolitan FMR area is the metropolitan FMR. 16 The applicable FMR for a PHA that has adopted exception payment standards based on the SAFMR but administers in non-metropolitan county is the non-metropolitan county FMR. 17 Please note that HUD designates metropolitan areas as Small Area FMR under 24 CFR 888.113(c)(4). PHAs located in those areas are considered “mandatory SAFMR” PHAs. The term “designated” and “mandatory” may be used interchangeably.
18 PHAs administering in a metropolitan or non-metropolitan area that have adopted exception payment standards based on the SAFMR are not considered “opt-in” PHAs. Please see section 5 of this notice for more discussion on “opt-in” PHAs.
19 24 CFR 982.503(a)(2)
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5 However, PHAs may opt-in and use SAFMRs for some or all of those FMR areas (Opt-in SAFMR areas). Alternatively, PHAs may elect to use SAFMRs as the basis for exception payment standards in some or all of those non-mandatory SAFMR areas that cover or are within their jurisdictions (see section 5, “Exception Payment Standards”).

Example 1: Examples of Payment Standards in Multiple FMR Areas The Statewide PHA administers vouchers in the following FMR areas:
 Jefferson City Metropolitan FMR Area
o Payment standards are within the basic range of the published FMR, except where the PHA has chosen to implement exception payment standards based on the SAFMR for ZIP Codes where the SAFMR is higher than the FMR.
 Central City Metropolitan FMR Area
o Payment standards are within the basic range of published FMR.  Lake City Metropolitan FMR Area
o Payment standards are within the basic range of the published SAFMR since Lake City Metropolitan FMR is designated as a mandatory SAFMR area.
 Falls Non-metropolitan County
o Payment standards are within the basic range of published FMR.  River Non-metropolitan County
o Payment standards are within the basic range of the published FMR, except where the PHA has chosen to implement exception payment standards based on the SAFMR for ZIP Codes where the SAFMR is higher than the FMR.
 Brook Metropolitan FMR Area
o Payment standards are within the basic range of the published SAFMR because the PHA has chosen to opt-in to using SAFMRs.

1. Payment Standard Areas
The PHA may designate payment standard areas within each FMR area. For example, these could be census tract areas or groupings of those areas, and the PHA establishes payment standard amounts for such designated areas.20 If the PHA designates payment standard areas, then it must include the criteria used to determine the designated areas and the payment standard amounts for those areas in the Administrative Plan.21 A PHA-designated payment standard area may be no smaller than a census tract block group.22 The PHA’s established payment standards within the payment standard area always must be within the basic range (discussed in detail in

20 24 CFR 982.503(a)(3)
21 24 CFR 982.54(d)(14)
22 24 CFR 982.503(a)(3)(ii)
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6 the next section) of the applicable FMR area, or any HUD-approved exception payment standard.23
For each payment standard area, the PHA must establish a payment standard amount for each unit size, measured by number of bedrooms (zero-bedroom, one-bedroom, and so on).24 These payment standard amounts comprise the PHA’s payment standard schedule.

2. Basic Range
PHAs must set a payment standard within the basic range of at least 90 percent, but no more than 110 percent of the applicable FMR, unless the PHA has received HUD approval for a higher exception payment standard or a payment standard lower than the basic range (see section 5, “Exception Payment Standards,” section 8, “Payment Standards Lower than the Basic Range,” and section 11 “Reasonable Accommodation Exception Payment Standards” of this Notice).25 The PHA’s basic range payment standard amount for each unit size may be based on the same percentage of the published FMR (e.g., all payment standard amounts may be set at 100 percent of the FMR), or the PHA may establish different payment standard amounts for different unit

23 24 CFR 982.503(c) and (d)
24 24 CFR 982.503(b)
25 24 CFR 982.503(c)
Example 2: Census-Tract Based Payment Standard Area

The Reservoir PHA is located in a mandatory SAFMR area and typically sets payment standards based on 100 percent of the published SAFMR for each of the four ZIP Code areas in the jurisdiction.

Recently, a large multifamily rental community opened at one end of the ZIP Code area and rents there are closer to 110 percent of the SAFMR, while the other end of the ZIP Code sees rents closer to 90 percent of the SAFMR. The ZIP Code is comprised of three unique census tracts, with one tract covering the area where the multifamily rental community is located, and the other two covering the rest of the ZIP Code.

The PHA elected to establish a census-tract based payment standard for all three census tracts within the impacted ZIP Code, and to continue to use ZIP Codes areas for the rest of their jurisdiction:

Payment Standard Area Percent of Applicable
FMR
Payment Standard
Amount
ZIP Code 12345 100 percent $1000
ZIP Code 23456 100 percent $1000
ZIP Code 35124 100 percent $1000
Census Tract 00001 90 percent $900
Census Tract 00002 90 percent $900
Census Tract 00003 110 percent $1100
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7 sizes (for example, 90 percent for efficiencies, 100 percent for one-bedroom units, 110 percent for larger units).26
PHAs must revise the payment standard amount no later than three months following the effective date of the published FMR if a change is necessary to stay within the basic range. In other words, the PHA must adjust the payment standard’s actual dollar value where the current payment standard dollar value falls outside of the basic range. For more information on payment standard increases and decreases, see section 9, “Applying Increases in the Payment Standard” and 10, “Applying Decreases in the Payment Standard” of this Notice.

3. Payment Standard Schedule Availability
PHAs are strongly encouraged to post their payment standard schedule on their website for transparency to applicants, participants, landlords and the public. PHAs are reminded that they must27 provide a copy of the payment standard schedule as part of their voucher briefing materials.

26 24 CFR 982.503(c)(2)
27 24 CFR 982.301(b)(2)
Example 3: Changing Payment Standards with Newly Published FMRs The Ocean County PHA (OHA) uses the published metropolitan area FMR to establish payment standards.
1-bedroom 2-bedroom 3-bedroom
2023 FMR $1,000 $1,200 $1,300
Current payment
standard $1,000 $1,320 $1,430
Current percentage
payment standard is
of FMR
100% 110% 110%
2024 FMR $1,300 $1,400 $1,500
Current payment
standard’s
percentage of 2024
FMR
76% 94% 95%
In this example, the published FMR increased between 2023 and 2024. The OHA must assess whether current payment standards are within the basic range of the newly published FMR. In this example, the OHA must adjust the one-bedroom payment standard to be within the basic range of the FMR. Although the two- and three-bedroom payment standards do not need to be adjusted because they remain within the basic range, as a best practice, the OHA will want to consider whether increasing the payment standard is necessary to ensure that a range of rental units are available to families.

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8 IV. SAFMRs: Mandatory and Opt-in
SAFMRs are FMRs calculated at the ZIP Code level, rather than for an entire metropolitan or non-metropolitan county.28 Setting payment standards at a local level helps more assisted households to find and afford rental units in a broader range of neighborhoods, including in lower-poverty areas. Greater access to the rental market is expected to benefit both individual families and areas as a whole. For example, individual families are benefited through greater access to high-performing schools or safer neighborhoods, and areas benefit as a whole through reducing concentrated neighborhood poverty.

Mandatory and opt-in SAFMR PHAs must use the SAFMR for their HCV program, including special housing types (e.g. congregate housing, shared housing, homeownership) 29 with the exception of manufactured home space rental.30 Mandatory and opt-in SAFMR PHAs do not use SAFMRs for their PBV program unless the PHA implements a policy through their administrative plan to apply SAFMRs to all future PBV projects located in the same areas where the SAFMRs are in effect for the PHA’s HCV program.31 Please see section 12 of this Notice, “PBVs” for further information on SAFMRs and PBV applicability.

The vouchers of families that move under portability will be administered according to the policies of the receiving PHA.32 If the receiving PHA is operating under SAFMRs, then the family’s voucher will be administered using SAFMRs (regardless of whether the initial PHA uses SAFMRs). Likewise, if an initial PHA operates in a SAFMR area, and the family moves to a receiving PHA located in a metropolitan FMR area, the family’s voucher is administered using the metropolitan FMR.

A. Mandatory SAFMRs
HUD designates new SAFMR areas as new data becomes available in accordance with program regulations.33 HUD identifies which metropolitan areas are required to use SAFMRs based on significant voucher concentration challenges and market conditions.34 HUD initially designated the first set of metropolitan areas that must use SAFMRs in 2016.35 HUD designated a second set of metropolitan areas in 2023.36 PHAs that operate within those designated metropolitan areas are known as “mandatory SAFMR PHAs.”

28 24 CFR 888.113(d)(2)
29 For more information on calculating payment standards for special housing types, please see the HCV Guidebook chapter:
https://www.hud.gov/sites/dfiles/PIH/documents/Special_Housing_Types_Updated_November%202020.pdf 30 24 CFR 888.113(g)
31 24 CFR 888.113(h) and 983.10(b)(23)
32 These portability policies are applicable to mandatory SAFMRs and exception payment standard SAFMRs. 33 24 CFR 888.113(c)(4)
34 Ibid
35 “Establishing a More Effective Fair Market Rent System; Using Small Area Fair Market Rents in the Housing Choice Voucher Program Instead of the Current 50th Percentile FMRs; Final Rule,” published in the Federal Register on November 16, 2016 (FR-5855-F-03).
36 “Small Area Fair Market Rents in the Housing Choice Voucher Program Metropolitan Areas Subject to Small Area Fair Market Rents,” published in the Federal Register on October 25, 2023 (88 FR 73352) 29 of 66

9 Mandatory SAFMR PHAs must use the SAFMR for any part of their jurisdiction located in the SAFMR area.37 For example, a statewide PHA may operate in a designated SAFMR area, and also in areas subject to the published metropolitan and non-metropolitan county FMR. This PHA is required to use the SAFMR only for the portion of their jurisdiction designated as mandatory SAFMR.

Non-metropolitan counties will not be designated as mandatory SAFMR areas.38

1. Applicability to Moving to Work (MTW) PHAs
An MTW PHA, including both Initial and Expansion MTW agencies, that operates in a mandatory SAFMR area may be exempt from use of SAFMRs. An individual MTW PHA is exempt from the requirement to use SAFMRs if that agency has an alternative payment standards policy in the PHA’s HUD-approved Annual MTW Plan or MTW Supplement to the Annual PHA Plan. An MTW PHA in a mandatory SAFMR area that does not have such policy in the PHA’s HUD-approved Annual MTW Plan or MTW Supplement is required to use SAFMRs.39 MTW PHAs that choose to adopt alternative payment standards are strongly encouraged to ensure that HCV program participants have similar access to a wide range of communities as they would under SAFMRs.

2. Inapplicability of SAFMRs to Other HUD programs
SAFMRs do not apply to any programs other than the HCV program. Other programs that use FMRs (e.g. HOME Investment Partnerships Program) continue to use metropolitan FMRs regardless of whether SAFMRs have been designated for the HCV program within the same metropolitan area. Please follow the requirements of those programs regarding the use of FMRs.

3. Suspension of SAFMRs or Temporary Exemption
In rare cases, HUD may suspend a SAFMR designation from a metropolitan area or may temporarily exempt a PHA in a SAFMR metropolitan area from the use of SAFMRs, when HUD makes a documented determination, through public notice, that such action is warranted.40 The process for reviewing whether a suspension or temporary exemption is warranted may be initiated by HUD or at the request of a PHA. The PHA’s request for suspension or exemption must be emailed to [email protected].

A PHA may request either:
 Suspension of the SAFMR designation for a metropolitan area

37 24 CFR 888.113(c)(3)
38 24 CFR 888.113(c)(3)
39 “Establishing a More Effective Fair Market Rent System; Using Small Area Fair Market Rents in the Housing Choice Voucher Program Instead of the Current 50th Percentile FMRs; Final Rule,” published in the Federal Register on November 16, 2016 (FR-5855-F-03).
40 24 CFR 888.113(c)(4)
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10 o Only PHAs, or a combination of PHAs, that administer more than 50 percent of the vouchers leased in the metropolitan area may make this request.  Temporary exemption from the use of SAFMRs for an individual PHA.

In both cases, the request must be based on a documented finding of an adverse rental housing market condition specific to the area or PHA. Adverse rental housing market conditions may include, but are not limited to:
 Current vacancy rates falling below four percent (insufficient supply)  A sudden and significant influx of families into the metropolitan area (demand shock)  A sudden and significant loss of rental units (supply shock);  A rapid increase in the PHA’s per unit costs (PUC) causing the PHA to experience a funding shortfall (supply or demand shocks).

Adverse rental housing market conditions may apply to the broad rental housing market or may apply to the part of the rental market that is affordable and available to HCV families. For example, declining success rates and increasing rent burdens despite PHA owner outreach efforts may be evidence of adverse rental market conditions for HCV families due to lack of units that are both affordable and owned by owners willing to participate in the HCV program. There are likely to be other circumstances that cause adverse rental market conditions, and HUD will review the documentation of these conditions on a case-by-case basis.

If HUD determines it is necessary to suspend an area’s SAFMR designation or temporarily exempt an individual PHA from use of the SAFMRs, HUD will issue a Notice of Suspension or Exemption with information on the adverse rental market condition that is the reason for the suspension, the duration and timing of the suspension, and other details as HUD determines necessary.

B. Opt-in SAFMR
Upon notification to HUD, a PHA that is not located in a designated SAFMR area, may voluntarily adopt SAFMRs (also known as “opt-in”) for one or more of the FMR areas in which the PHA administers vouchers.41 In other words, a PHA that exercises this option in one metropolitan area or non-metropolitan county is not required to exercise this option in other metropolitan areas or non-metropolitan counties. A PHA that voluntarily uses SAFMRs for the entire jurisdiction, even if that jurisdiction consists of only one ZIP Code, is considered an “Opt- in SAFMR” PHA. PHAs located in metropolitan and non-metropolitan counties may opt-in to using the SAFMR.

Please note, the regulations at 24 CFR 888.113 discuss “voluntary” adoption of the SAFMR, which is also known as “opt-in.” For a PHA that has fully opted-into the SAFMRs, the “applicable FMR” is the SAFMR.42 This is distinct from a PHA that only uses SAFMRs as

41 24 CFR 888.113(c)(3)
42 24 CFR 982.503(a)(1)(i)(B)
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11 exception payment standards, which is discussed further in section 5, “Exception Payment Standards.”43
As a best practice, when considering whether to opt-in to SAFMRs, PHAs should consider a variety of factors such as:
 Whether adoption of SAFMRs is likely to have a positive or adverse effect on the availability of rental housing that is both affordable and available to program participants and applicants
 The effect of SAFMR adoption on family rent burdens, and whether to adopt the hold harmless or gradual reduction in subsidy options (See section 10, “Applying Decreases in the Payment Standard.”)
 Areas where the SAFMR is lower than the published FMR by exactly 10 percent and opt- in will therefore trigger the need for rent reasonableness determinations  Whether to apply SAFMRs to the PBV program, if applicable (See section 12 “PBVs”) An agency that chooses to adopt SAFMRs must submit a written notification to HUD through a DocuSign electronic submission, which can be accessed here. 44 The notification must indicate the PHA’s proposed effective date. Prior to implementing SAFMRs, the opt-in PHA must amend the Administrative Plan, stating that the PHA will establish payment standards based on SAFMRs and also include any policies the PHA has adopted with respect to SAFMRs (e.g., applying SAFMRs to its PBV program and payment standard decrease hold harmless policies).

A PHA that opts in to SAFMRs may subsequently opt out, returning to the use of the published FMR, through revision of the Administrative Plan and notification to HUD through a DocuSign electronic submission which can be accessed here after taking into consideration any potential disruptions to its program, families, and owners.

V. Exception Payment Standards
Although HUD uses the best available data to establish FMRs and SAFMRs, PHAs may find that payment standards within the basic range are not high enough to meet programmatic goals such as high utilization and success rates, landlord participation, and/or reasonable rent burdens for program participants. There are several options available to increase payment standards above the basic range, known as exception payment standards:
 Payment standards based on SAFMRs in ZIP Codes where the SAFMR is higher than the applicable metropolitan or non-metropolitan county FMR45  Payment standards greater than 110 percent up to 120 percent of the applicable FMR46  Payment standards over 120 percent of the applicable FMR

43 24 CFR 982.503(d)(2)
44 24 CFR 888.113(c)(3)
45 Note that SAFMR exception payment standards are different from “opt-in” SAFMRs, which are discussed in the prior section.
46 Note that the applicable FMR is defined as the metropolitan FMR, non-metropolitan FMR, or the SAFMR for PHAs in designated SAFMR metropolitan areas or for PHAs that have “opted in” to the SAFMR 32 of 66

12  Payment standards necessary as a reasonable accommodation (see Section 11 of this notice)
An exception payment standard may be established for a designated part of the FMR area, called an exception area, or for the entire FMR area. 47 The exception area may be no smaller than a census tract block group.48 Please see section 12, “PBVs” for applicability of exception payment standards to the PBV maximum rent.

A. Exception Payment Standards Based on SAFMRs in ZIP Codes Where the SAFMR is Higher Than the Applicable Metropolitan or Non-Metropolitan County FMR PHAs subject to the HUD-published FMR in a metropolitan or non-metropolitan area may choose to establish an exception payment standard using the published SAFMR upon notification to HUD through a DocuSign electronic submission, which can be accessed here. The exception payment standard may be up to 110 percent of the SAFMR. If an exception area crosses one or more FMR boundaries, then the maximum exception payment standard amount that the PHA may adopt for the exception area without HUD approval is 110 percent of the ZIP Code area with the lowest SAFMR to ensure that all areas are within the basic range.49

B. Simplified Process for Exception Payment Standards Greater than 110 percent up to 120 percent of the Applicable FMR

47 24 CFR 982.503(d)(1)
48 24 CFR 982.503(a)(3)(ii)
49 24 CFR 982.503(d)(2)
Example 4: SAFMR Exception Payment Standards
The Mountain Housing Authority administers HCVs in eight ZIP Codes, with three ZIP Codes having a SAFMR greater than the FMR. They notified HUD that they will adopt SAFMR exception payment standards in those three ZIP Codes. The published FMR for a two-bedroom unit is $1,200. The published SAFMR for a two-bedroom unit in ZIP Code 56789 is $1,400, for ZIP Code 09876 is $1,350, and for 44556 is $1,600. The PHA decides to establish exception payment standards for those ZIP Code areas at 110 percent of the applicable SAFMR and payment standards at 110 percent of the FMR for other ZIP codes.

ZIP Code 12345 67891 23456 56789 09876 54321 44556 66778 Payment
Standard (110
percent of

FMR/SAFMR)
$1,320 $1,320 $1,320 $1,540 $1,485 $1,320 $1,760 $1,320

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13 All PHAs that meet at least one of the two specified criteria below may establish an exception payment standard amount greater than 110 percent up to 120 percent of their applicable FMR50 upon notification to HUD:
 Success rate: Fewer than 75 percent of the families to whom the PHA issued tenant- based vouchers during the most recent 12-month period for which there is success rate data available have become participants in the voucher program; and/or  Rent burden: More than 40 percent of families with tenant-based vouchers administered by the agency pay more than 30 percent of adjusted income as the family share.51 PHAs must submit a notification to HUD through a DocuSign electronic submission, which can be accessed here. In the DocuSign notification, PHAs will certify that they meet at least one of the two required criteria.

The duration in which the PHA may use the exception payment standard after proper notification to HUD is:
 Until the effective date of the first newly published FMRs following 12 consecutive months of a sustained tenant-based success rate at 75 percent or higher, if the PHA qualified for the exception payment standard based on the success rate criteria above; or  Until the effective date of the first newly published FMRs following 12 consecutive months of the PHA maintaining a rent burden where fewer than 40 percent of tenant- based voucher families are paying more than 30 percent of adjusted income as the family share, if the PHA qualified for the exception payment standard based on the rent burden criteria above.

The PHA may revert back to the basic range at any time without notification to HUD. PHAs are reminded that if there are changes in the applicable FMR and the PHA’s payment standard exceeds 120 percent of the newly applicable FMR, the PHA would need to reduce its payment standard to be 120 percent or lower than the newly applicable FMR.

The PHA may use the exception payment standard for all units, or for only units of a particular size. The exception payment standard may be established for a designated part of the FMR area (called an “exception area”) or for the entire FMR area52. Exception areas typically are county, city, town, ZIP Code, or census tract. However, so long as the exception area is no smaller than census tract block group, the PHA may select the area for the exception area53.

If the PHA has adopted an exception payment standard greater than 110 and up to 120 percent of the applicable FMR under this section, the amount of rent to owner determined by the PHA for PBV projects in the exception area may not exceed the exception payment standard minus utility

50 As a reminder, the applicable FMR is the metropolitan FMR, non-metropolitan county FMR, or SAFMR for PHAs in designated SAFMR areas or PHAs that have “opted-in” to the SAFMR. 51 Program regulations at 982.503(d)(3)(iii) also provide HUD discretion to establish additional criteria by Notice.

HUD has not opted to establish additional criteria at this time. 52 24 CFR 982.503(d)(1)
53 24 CFR 982.503(a)(3)(ii) and (d)(1)
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14 allowance, rather than the normally applicable 110 percent of FMR minus utility allowance limitation,54 and the rent reasonableness requirements continue to apply.

PHAs may combine exception payment standards based on the SAFMR, and exception payment standards greater than 110 and up to 120 percent55. Prior to doing so, however, HUD encourages (but does not require) PHAs to first assess whether the SAFMR exception payment standard achieves the programmatic goals of the PHA.

C. Other Exception Payment Standards
Most PHAs will find that the simplified exception payment standard process described above for greater than 110 and up to 120 percent of the applicable FMR, or exception payment standards based on the SAFMR, generally helps ensure their payment standards are competitive in the rental market. However, there may be some circumstances where the simplified exception payment standard process does not meet the PHA needs. Examples of these circumstances include:
 Situations where PHAs do not meet the criteria to receive an exception payment standard of up to 120 percent as described in section 5b above and determine the applicable FMR is not in line with local rental market demands or

54 983.301(b)
55 24 CFR 982.503(d)(2) and (3)
Example 5: Exception Payment Standards Greater than 110 and up to 120 percent of FMR The Beach Housing Authority (BHA) administers vouchers in three counties: one in a city, one in a suburban county, and one in an exurban county, and is not in a mandatory SAFMR area. The BHA has determined that the published FMR for the suburban county is not high enough for families to access and afford a significant portion of the available rental units. The BHA has noticed that they have particularly struggled to maintain reasonable rent burdens for families renting units in this area as landlords have raised rents consistently by 10 percent each year. The BHA looked at the data and determined that 45 percent of families with tenant-based assistance are paying more than 30 percent of their adjusted income as their family share. Using the required DocuSign link, BHA notified HUD that the BHA would adopt a payment standard greater than 110 and up to 120 percent for the suburban county within the jurisdiction. BHA’s new payment standards, based on a three-bedroom FMR of $1,500 are as follows:

Geography 3-bedroom Payment Standard Percent of FMR
City $1,500 100%
Suburban County $1,725 115%
Exurban County $1,575 105%

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15  Situations where 120 percent of the applicable FMR is still not high enough to reflect the local rental market demands
PHAs may request approval from HUD to establish an exception payment standard amount that exceeds the basic range of the applicable FMR under 24 CFR 982.503(d)(4). The request must be submitted to [email protected].

The PHA’s request must be for an exception area within the applicable FMR area or for the entire FMR area.56 The information required to be submitted is different for each type of request.

Exception Area Requests
An exception area is a designated part of the applicable FMR area.57 So long as the exception area is smaller than the applicable FMR area but no smaller than a census tract block group, the PHA may determine what the requested exception area is. This is a non-inclusive list of potential exception areas:
 Census tract
 Census tract block group
 County
 City
 Town
 Neighborhood
 ZIP codes (for PHAs not in mandatory SAFMR areas or that have not opted-in to SAFMRs)
To request approval for an exception payment standard that applies to an exception area, the PHA must provide HUD rental market data demonstrating that the requested exception payment standard amount is needed for families to access rental units. The rental market data must include a rent estimate for the applicable FMR area compared with a rent estimate for the proposed exception area (e.g. census tract, census tract block group, county, etc.). As an example, a PHA in a mandatory SAFMR area would submit a rent estimate for the exception area, which must be a smaller geography than the applicable FMR area (ZIP code). Typically for mandatory SAFMR PHAs, the exception area would be a census tract but could be a different geography so long as it is no smaller than a census tract block group. The PHA would also submit a corresponding rent estimate for the applicable FMR area (ZIP code).

For all exception area requests, the rent estimate must consist of a standard metric, such as an average or median rent, measured across a representative portion of the rental market by a reputable source. The rent estimates must include the two years preceding the current FMR year.

For example, in FY 2025, the rent estimates should be for 2023 and 2024.

56 24 CFR 982.503(d)(4)
57 24 CFR 982.503(d)(1)
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16 Entire FMR Area Requests
A PHA may determine that they want to request an exception payment standard for the entire FMR area. For example, a PHA in a mandatory SAFMR area may want to request an exception payment standard for an entire ZIP Code. Or, in another example, a PHA in a non-metropolitan county may want to request an exception payment standard for the entire county.

Example 6: Town-based Exception Payment Standard Over 120 percent Greenville is a suburban town within the Franklin City Metropolitan Statistical Area. The prevailing rents in Greenville are significantly higher than in other parts of the MSA. To better help voucher holders find units within the town, the Greenville PHA requests exception payment standards for addresses within the town of Greenville. According to the Census Bureau’s American Community Survey, the most recent estimate of median gross rent for the town of Greenville is $1,250. The most recent survey also showed that the median gross rent for all of the Franklin City MSA is $1,000. The Greenville PHA is eligible for exception payment standards of 125 percent of the Franklin City MSA FMRs, as $1,250 divided by $1,000 is 1.25.

Example 7: Neighborhood-based (Census Tract) Exception Payment Standard Over 120 percent
The Hill County PHA operates within the Harrison Metropolitan Statistical Area, a mandatory SAFMR area. The PHA has identified University Heights, a popular neighborhood, as an area where HCV families have difficulty in finding units. difficulty for voucher holders in finding units in University Heights, a popular neighborhood. The SAFMR for the area in which the neighborhood is located (01234), although higher than the metropolitan FMR, is still not as high as the prevailing rents in the neighborhood because the ZIP Code also includes other adjacent neighborhoods. University Heights corresponds with Census Tracts 107.01, 107.02, and 107.03. According to the Census Bureau’s American Community Survey, the most recent estimate of median gross rent for these Census Tracts is $1,300, $1,350, and $1,400, respectively. The most recent survey also showed that the median gross rent for all of ZIP Code 01234 is $1,000. The PHA is therefore eligible for payment standards of 130 percent, 135 percent, and 140 percent for Census Tracts 107.01, 107.02, and 107.03 respectively, as these represent the ratios of the median rents for the tracts to the median rent of the ZIP Code.

Should the PHA wish to have a single payment standard for the entire neighborhood of University Heights, it may calculate a rental unit-weighted average of the Census Tract median rents. In this case, the weighted average of tracts 107.01, 107.02, and 107.03 is $1,350, meaning the PHA would be eligible for a payment standard of 135 percent throughout the neighborhood.

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17 PHAs requesting exception payment standards for an FMR area must submit estimates of the typical rent paid in the FMR area. The rent estimate must consist of a standard metric, such as an average or median rent, measured across a representative portion of the rental market by a reputable source. The rent estimates must include the two years preceding the current FMR year.

The PHA must provide data that demonstrates the annual percentage of inflation change for the entire FMR area is greater than the rental inflation adjustment factor in the published FMR. For example, in FY 2025, the rent estimates should be for 2023 and 2024, with the annual percentage of inflation change reflecting the percentage increase from 2023 to 2024. HUD currently publishes the rental inflation factor on the HUD user webpage.58

Once HUD has approved an exception payment standard for a requesting PHA, any other PHA with jurisdiction in the HUD approved exception area, or FMR area, may also use the exception payment standard amount.

Please note that the exception payment standard process for an entire FMR area is different than a reevaluation of HUD’s determination of FMRs. That process is discussed further in section 14, “Reevaluation of HUD-published FMRs/SAFMRs.”
VI. Phase-out of Success Rate Payment Standards
Under the May 2024 Final Rule, HUD will no longer approve success rate payment standards.59 Success rate payment standards allowed qualifying PHAs to adopt a payment standard based on the 50th percentile FMR. PHAs that had an approved success rate payment standard prior to June 6, 2024 (the effective date of the May 2024 Final Rule) may continue to use the approved payment standard amount.60 However, the actual dollar amount of the approved success rate payment standard may never exceed the amount established by the PHA as of June 6, 2024. The approved success rate payment standard may remain in effect until the applicable FMR exceeds

58 For FY 2025, the rental inflation adjustment factors can be found here under the “data” tab for the applicable year: https://www.huduser.gov/portal/datasets/fmr
59 “Housing Opportunity Through Modernization Act of 2016—Housing Choice Voucher (HCV) and Project-Based Voucher Implementation; Additional Streamlining Changes,” hereafter “May 2024 Final Rule.” (FR-6092-F-03).

See discussion on page 38229. See also 24 CFR 982.503(f). 60 Please note that success rate payment standards are not exception payment standards and are never used for determination of rent to owner in the PBV program.

Example 8: Entire FMR Area Exception Payment Standard
The Sunny County PHA operates in the Sunny County FMR area. According to data from MetroEstimators, a reputable rent data service provider, the median asking rent of a typical unit in Sunny County increased 30 percent from 2023 to 2024, or an inflation factor of 1.30.

Theinflation factor from 2023 to 2024 that HUD used in calculating the FY 2025 FMR was 4 percent (1.04). Based on the information provided by the PHA in their request for an exception payment standard, HUD approved an exception payment standard of 125 percent of the FY 2025 FMRs for Sunny County, as 1.30 divided by 1.04 percent is 1.25.

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18 that approved amount. PHAs are encouraged to assess whether they should transition to the applicable FMR should that amount exceed the maximum payment standard the PHA established under their success rate payment standards.

VII. Deconcentration Payment Standards
Prior to 2018, some FMR areas had been set at the 50th percentile rent to provide a broad range of housing opportunities throughout a metropolitan area.61 After 2018, all FMR areas are now set at the 40th percentile rent. PHAs not in a designated SAFMR that were in these areas, could have received a “deconcentration payment standard” based on the 50th percentile rent through HUD Field Office approval of a payment standard amount if the PHA scored the maximum number of points on the deconcentration bonus indicator in 24 CFR 985.3(h) in the prior year, or in two of the last three years. PHAs with an approved deconcentration payment standard may continue to use that payment standard. PHAs are encouraged to assess whether they should transition to the applicable FMR should that amount exceed the maximum payments standard the PHA established under their deconcentration payment standards.

VIII. Payment Standards Lower than the Basic Range
PHAs may request approval to establish a payment standard amount that is lower than the basic range.62 At HUD's sole discretion, HUD may approve PHA establishment of a payment standard lower than the basic range. In determining whether to approve the PHA request, HUD will consider appropriate factors, including rent burden of families assisted under the program.

Unless it is necessary to prevent termination of program participants, HUD will not approve a lower payment standard if the proposed payment standard would cause the family share for more than 40 percent of participants with tenant-based rental assistance to exceed 30 percent of adjusted monthly income, based on analysis of currently available data.

PHAs requesting a payment standard lower than the basic range must submit their request to [email protected].

IX. Applying Increases in the Payment Standard
For new HAP contracts, the PHA applies the payment standard in effect at the time of HAP contract execution.

For existing HAP contracts, when the PHA’s payment standard increases, the PHA must use the increased payment standard amount to calculate the monthly housing assistance payment for each program participant beginning no later than the earliest of:
 Change in Gross Rent/Family Share: The effective date of an increase in the gross rent that would result in an increase in the family share;63

61 24 CFR 888.113(i)(3)
62 24 CFR 982.503(e)
63 24 CFR 982.505(c)(4)(i)
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19  Interim or annual reexamination: The family’s first regular or interim reexamination;64 or
 One year after effective date: One year following the effective date of the increase in the payment standard amount.65
The PHA may apply a payment standard increase at any earlier date, so long as that policy is included in the PHA Administrative Plan, and the policy is applied consistently to all families.66 If the family unit size either increases or decreases during the HAP contract term, the new family unit size may be used to determine the payment standard amount for the family immediately but no later than the family’s first regular reexamination following the change in family unit size.67

X. Applying Decreases in the Payment Standard
For new HAP contracts, the PHA applies the payment standard in effect at the time of HAP contract execution.

When the PHA’s payment standard decreases while the family continues to reside in the unit for which the family is receiving assistance, the PHA has three options:
 Hold harmless: The PHA may choose not to reduce the payment standard amount used to calculate the subsidy for a family for as long as the family continues to reside in the unit for which the family is receiving assistance.68
 Gradual reduction: Upon proper notification (as described below) to the family, the PHA may gradually reduce the payment standard amount used to calculate the family’s

64 24 CFR 982.505(c)(4)(ii)
65 24 CFR 982.505(c)(4)(iii)
66 24 CFR 982.505(c)(5)
67 24 CFR 982.505(c)(6)
68 24 CFR 982.505(c)(3)
Example 9: Applying a Payment Standard Increase
The Plains Housing Authority (PHA) increased their payment standards on November 1, 2025. Ms. Maria Rosa’s annual reexamination is due on July 1, 2026. Her landlord requested a rent increase after the initial lease term, which PHA approved, with an effective date of January 1, 2026. When the PHA processed the rent increase, the PHA also applied the increase of the payment standard.

Prior annual
reexamination
Interim
reexamination
effective January 1

Gross rent $850 Gross rent $950
Payment standard $855 Payment standard $975

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20 subsidy, phasing in the reduction. The initial reduction in payment standard cannot take place earlier than two years following the effective date of the decrease in the payment standard.69
 Two years after effective date: Upon proper notification to the family, the PHA may choose to reduce the payment standard amount used to calculate such a family’s subsidy no earlier than two years following the effective date of the decrease in the payment standard.70
The option the PHA selects must be documented in the PHA Administrative Plan and be applied consistently to all families.71 If the PHA has an established policy to reduce the payment standard, the PHA must provide the family with at least 12 months’ written notice of any reduction in the payment standard amount that will affect the family if the family remains in place. In the written notice, the PHA must state the new payment standard amount, explain that the family’s new payment standard amount will be the greater of the amount listed in the current written notice or the new amount (if any) on the PHA’s payment standard schedule at the end of the 12-month period, and make clear where the family will find the PHA’s payment standard schedule.72

XI. Reasonable Accommodation Exception Payment Standards On a case-by-case basis, PHAs are required to provide reasonable accommodation exception payment standards for a person with a disability in accordance with 24 CFR part 8. For exception payment standards that do not exceed 120 percent of the applicable FMR, the PHA establishes the exception payment standard without prior notification to HUD or HUD approval.73 For exception payment standards greater than 120 percent of the applicable FMR as

69 24 CFR 982.505(c)(3)(i) and (ii)
70 24 CFR 982.505(c)(3)(ii)
71 24 CFR 982.505(c)(3)(iv)
72 24 CFR 982.505(c)(3)(iii)
73 24 CFR 982.503(d)(5)
Example 10: Applying a Payment Standard Decrease
The River Housing Authority (RHA) reduced the payment standard on November 1, 2025.

The three-bedroom payment standard was $1,300 but was reduced to $1,250. Mr. Andrew Chin’s annual reexamination is due on February 1, 2026. The RHA has adopted a “hold harmless” policy in the Administrative Plan. When the RHA processed Mr. Chin’s reexamination, they did not reduce the payment standard.

Prior reexamination New reexamination
effective February 1,
2026

Gross rent $1,200 Gross rent $1,200
Payment standard $1,300 Payment standard $1,300

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21 a reasonable accommodation for a person with a disability in accordance with 24 CFR part 8, the PHA must first request and receive HUD approval.74
Recognizing the importance of providing comprehensive guidance to PHAs on providing reasonable accommodation exception payment standards, HUD provides separate guidance through PIH Notice 2013-18. In response to changes brought about by the HOTMA,75 HUD will publish an update to that notice soon.

XII. PBVs
A. PBVs and SAFMRs
PHAs located in a mandatory SAFMR area, or that have fully opted-in to the SAFMR may elect to, but are not required to, apply the SAFMR to their PBV program. A PHA that chooses to apply SAFMRs to the PBV program must76 adopt such policy in the Administrative Plan.77 If the PHA adopts such a policy, then SAFMRs apply to projects in the following circumstances:
 Where the PHA notice of owner selection under 24 CFR 983.51(d) was made on or before the effective dates of either or both the SAFMR designation/implementation and adoption of the Administrative Plan policy, the PHA and owner may mutually agree to apply the SAFMR. The owner and PHA may not subsequently choose to revert back to the use of the metropolitan area FMRs for the PBV project.  Where the PHA notice of owner selection under 24 CFR 983.51(d) was made after the effective dates of both the SAFMR designation/implementation and adoption of the Administrative Plan policy, the SAFMR shall apply to the PBV project if the Administrative Plan provides that SAFMRs are used for all future PBV projects. An owner and the PHA may not subsequently choose to apply the metropolitan area FMR to the project.

In considering whether to adopt SAFMRs for the PBV program, HUD recommends that PHA compare the HAP contract rents of current PBV-assisted projects within the jurisdiction with what the rents would be under the SAFMRs.

B. PBV Maximum Rent and the Relationship to Exception Payment Standards Under no circumstances can the PHA establish an exception payment standard only for a specific PBV project. Exception payment standards must apply to a specific geographic area as described in section 5, “Exception Payment Standards.”

74 24 CFR 982.503(d)(5) and Notice PIH 2013-18. Please note that HUD anticipates updating Notice PIH 2013-18 soon, and PHAs are encouraged to ensure they are using the latest version of guidance on Reasonable Accommodation Exception Payment Standards.
75 Pub. L. 114-201, 130 Stat. 782
76 24 CFR 888.113(c)(5)
77 24 CFR 983.10(b)(23)
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22 For the PBV program, except for certain tax credit units, the amount of rent to owner must not78 exceed the lowest of:
 An amount determined by the PHA, not to exceed 110 percent of the applicable FMR (or the amount of any HUD approved exception payment standard for the area in which the project is located), minus utility allowance
 The reasonable rent; or
 The owner-requested rent.

As a result, the maximum rent that the PHA may permit for any PBV project located in an area without an approved exception payment standard is 110 percent of the applicable FMR, minus the utility allowance, where this amount is equal to or lower than the reasonable rent and the owner-requested rent.79
For PBV projects that are located in a mandatory SAFMR area or are located in a ZIP code where the PHA has opted in to the SAFMR, any exception payment standard amount approved under 24 CFR 982.503(d)(3)-(4) will apply to the maximum rent limit for the PBV project only if the PHA has adopted a policy applying SAFMRs to its PBV program and met all other requirements in accordance with 24 CFR 888.113(h).80 If the PHA has not applied the SAFMRs to its PBV program, 110 percent of the metropolitan area or non-metropolitan county FMR minus the utility allowance remains the applicable limit on the amount determined by the PHA, regardless of whether any exception payment standard is in effect under 24 CFR 982.503(d)(3)- (4). In either case the rent must also meet the rent reasonableness requirements.

For PBV projects that are not located in a mandatory SAFMR area or are not located in a ZIP code where the PHA has opted in to the SAFMR, any exception payment standard amount approved under 24 CFR 982.503(d)(2)-(4) applies for purposes of establishing the maximum rent for the PBV project.81 HUD will not approve a different payment standard amount for use in the PBV program. The amount of rent to owner determined by the PHA may not exceed the exception payment standard minus utility allowance, rather than the normally applicable 110 percent of FMR minus utility allowance limitation,82 and the rent reasonableness requirements continue to apply.

XIII. Administrative Plan Requirements
The PHA Administrative Plan must83 address:

78 24 CFR 983.301(b). Please also note that the subsidy layering review may cap the rent for a PBV project below the amount determined by these regulations if the project is determined to be over-subsidized based on the subsidy layering review thresholds.
79 For tax credit units that meet the criteria of 24 CFR 983.201(c)(1), the maximum rent is the lowest of (i) An amount determined by the PHA in accordance with the Administrative Plan, not to exceed the tax credit rent minus any utility allowance; (ii) The reasonable rent; or (iii) The rent requested by the owner. 80 24 CFR 983.301(f)(3)(ii)
81 24 CFR 983.301(f)(3)(i)
82 983.301(b)(1)
83 24 CFR 982.54, 983.10(b)(23) and (b)(19)
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23  The process for establishing and revising payment standards, including policies on administering increases and decreases in the payment standard during the HAP contract term.
 Policy to apply payment standard increase at the earliest of a change in gross rent/family share, first regular or interim re-examination, or one year after the effective date.  Policy to apply payment standard decrease using hold harmless, gradual reduction, or two years after the effective date of the decrease.
 Criteria used to determine the designated areas and payment standard amounts for those areas
 Policies concerning application of SAFMRs to project-based voucher units.

XIV. Reevaluation of HUD-published FMRs
PHAs may request a reevaluation of their published applicable FMR following the procedures established in the annual Federal Register notice, which typically is published in August.84 While the procedures are subject to change annually, typically the reevaluation procedures require:
 The area’s PHA, or in multi-jurisdictional areas, PHA(s) representing at least half the voucher tenants in the FMR area must agree that the reevaluation is necessary.  The requester to supply HUD with data more recent than the American Community Survey (ACS) data used in the calculation of the applicable year’s FMRs/SAFMRs.

HUD requires data on gross rents paid in the area for occupied standard quality rental housing units. Occupied recent mover units provide the best data. The data delivered must be sufficient for HUD to calculate a 40th and 50th percentile two-bedroom gross rent. o If this data is not available, requestors may gather this information using the survey guidance at
www.huduser.gov/portal/datasets/fmr/NoteRevisedAreaSurveyProcedures.pdf and www.huduser.gov/portal/datasets/fmr/PrinciplesforPHA- ConductedAreaRentSurveys.pdf
The above information was provided exclusively for informational purposes. PHAs should always follow the instructions in the most recent Federal Register notice.

XV. Resources
There are numerous resources available to assist PHAs with establishing payment standards that meet the local rental market. For further information, please review the following:
 SAFMR Implementation Guidebook
 HCV Landlord Strategies Guidebook: Matching Local Rental Markets  HCV Overview Webinars

84 24 CFR 888.115(a)
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24  Housing Choice Voucher Program Guidebook, Payment Standards Chapter85  Housing Choice Voucher Program Guidebook, Rent Reasonableness Chapter

XVI. Paperwork Reduction Act
The information collection requirements contained in this Notice have been approved by the OMB in accordance with the Paperwork Reduction Act (PRA) of 1995 (44 U.S.C. §§ 3501- 3520) and have been assigned the following OMB control number –2577-0169. An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless the collection displays a valid control number.

XVII. Further Information
Questions concerning this notice should be submitted by email to the following Office of Housing Voucher Programs mailbox: [email protected]. In this email, PHAs should CC their portfolio management specialist in the field office.

Richard J. Monocchio
Principal Deputy Assistant Secretary
Office of Public and Indian Housing

85 At the time of this notice’s publication, the HCV Guidebook Chapter on Payment Standards has not yet been updated to reflect the regulatory changes in the May 2024 Final Rule. PHAs should be aware that the May 2024 Final Rule governs should there be any conflict between current program regulations and the HCV Guidebook chapter.
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25 Appendix A: Summary of Selected Regulatory Changes Effective in 2024

On May 7, 2024, HUD published in the Federal Register a final rule called Housing Opportunity Through Modernization Act (HOTMA) of 2016—Housing Choice Voucher (HCV) and Project- Based Voucher (PBV) Implementation; Additional Streamlining Changes (FR-6092-F-03). This May 2024 Final Rule made changes to payment standard regulations, including at 24 CFR 888 subpart A, 982.503, and 982.505. This Appendix discusses the major change to those program regulations that are reflected in this Notice. For a full discussion of the changes, please review the May 2024 Final Rule publication in the Federal Register which discusses changes at length.

Streamlined Process to Adopt an Exception Payment Standard of up to 120 percent of the

FMR/SAFMR
HUD revised 24 CFR 982.503 to allow PHAs to go up to 120 percent of the applicable FMR upon notification to HUD so long as the PHA meets the required thresholds as set forth in 24 CFR 982.503(d)(3). Under the final rule, PHAs no longer must submit supporting data for exception payment standard requests greater than 110 and up to 120 percent of the FMR if they notify HUD that they meet certain criteria, which had been a longstanding regulatory option. In recent years, HUD has provided a streamlined regulatory waiver process for PHAs to establish payment standards greater than 110 up to 120 percent of the FMR.

Phase-out of Success Rate Payment Standards
HUD revised 24 CFR 982.503 to eliminate the option to establish success rate payment standards. HUD determined that the new flexibility provided in the final rule to set payment standards up to 120 percent of the FMR makes the success rate payment standards option unnecessary. Success rate payment standards were set at the 50th percentile of the FMR. PHAs now have a simplified option to go up to 120 percent of the 40th percentile of the FMR. While these calculations may result in slightly different final payment standards, they would be substantially similar.

Non-metropolitan Counties SAFMR Publication and Voluntary Usage HUD revised 24 CFR 888.113 and 982.503 to increase flexibility for PHAs operating in non- metropolitan areas. The final rule provides PHAs the option in the HCV program to use SAFMRs in a non-metropolitan county with notification to HUD. This provides PHAs operating in non-metropolitan counties the same opportunity to establish payment standards that better align with rents that vary significantly between ZIP Code areas within the non-metropolitan counties. HUD will publish non-metropolitan county SAFMRs for the first time in FY 2025.

Previously, HUD did not publish, nor could PHAs use, non-metropolitan county SAFMRs.

Increase in Payment Standard Application Requirements
HUD revised 24 CFR 982.505 to require PHAs to apply an increase in payment standard no later than the earliest of (1) the effective date of an increase in the gross rent will result in an increase in the family’s share, (2) the family’s first regular or interim reexamination, or (3) one year following the effective date of the increase in the payment standard amount. PHAs can also adopt a policy, at their option, to apply an increase in the payment standard before these events occur. This approach provides participating families the benefit of these increases more consistently and helps ensure that their portion of the rent remains affordable. 46 of 66

26 Changes in Family Unit Size
HUD revised 24 CFR 982.505 to state that irrespective of any increase or decrease in the payment standard amount, if the family unit size either increases or decreases during the HAP contract term, the new family unit size may be used to determine the payment standard amount for the family immediately but no later than the family’s first regular reexamination following the change in family unit size. Previously, the PHA was only allowed to apply the change in unit size at the first regular reexamination and did not have the option to apply it earlier.

Clarifications Regarding SAFMRs and PBVs
HUD revised 24 CFR 888.113, and 983.301 to clarify policies related to the application of SAFMRs in the PBV program. The final rule makes clear that PHAs located in a mandatory SAFMR area, or that have fully opted-in to the SAFMR may elect to, but are not required to, apply the SAFMR to their PBV program.

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27 Appendix B: Examples for Grouping Payment Standards PHAs using the SAFMR, and/or exception payment standards may find themselves with numerous payment standards based on specific geographies. With so many options for establishing payment standards, including at the ZIP Code level and other geographies, PHAs may want to consider grouping payment standards. A grouping strategy enables the PHA to better approximate their payment standard to the private rental market. This option may be especially useful for PHAs with both high- and low-income neighborhoods within their jurisdiction.

Payment standards for a group of ZIP Codes (or other geographies) must remain within the basic range of the applicable FMR for each ZIP Code area (or other geographies) in the group.

However, a PHA does not need to apply the same percentage of the applicable FMR to each ZIP Code area (or other geography) within a payment standard area. In the examples below, which is of a PHA operating in a mandatory SAFMR area, the PHA is considering three options:
 Option A: Six separate payment standards—one for each of the ZIP Code areas  Option B: Three payment standard groups grouping the six ZIP Codes into three separate groups
 Option C: Two payment standard groupings, grouping the six ZIP Codes into two separate groups
While other options potentially exist for the PHA, there could not be fewer than two payment standard groupings since the basic range for the lowest SAFMR does not overlap with the basic range for the highest SAFMR.

Option A: Six separate payment standards—one for each of the ZIP Code areas

Efficiency One-
bedroom
Two-
bedroom

ZIP
Code
SAFMR Payment
Standard
Percentage
of
SAFMR
SAFMR Payment
Standard
Percentage
of
SAFMR
SAFMR Payment
Standard
Percentage
of
SAFMR
Grouping
12345 1,490 1,490 100% 1,600 1,600 100% 1,820 1,820 100% Group 1 23456 1,490 1,490 100% 1,600 1,600 100% 1,820 1,820 100% Group 2 34567 1,480 1,480 100% 1,590 1,590 100% 1,810 1,810 100% Group 3 45678 1,060 1,060 100% 1,140 1,140 100% 1,300 1,300 100% Group 4 56789 1,070 1,070 100% 1,150 1,150 100% 1,310 1,310 100% Group 5 67890 1,040 1,040 100% 1,120 1,120 100% 1,270 1,270 100% Group 6 48 of 66

28 Option B: Three payment standard groups, grouping the six ZIP Codes into three separate groups

Option C: Two payment standard groupings, grouping the six ZIP Codes into two separate groups

Efficiency One-
bedroom
Two-
bedroom

ZIP
Code
SAFMR Payment
Standard
Percentage
of
SAFMR
SAFMR Payment
Standard
Percentage
of
SAFMR
SAFMR Payment
Standard
Percentage
of
SAFMR
Grouping
12345 1,490 1,490 100% 1,600 1,590 99% 1,820 1,820 100% Group 1 23456 1,490 1,490 100% 1,600 1,590 99% 1,820 1,820 100% Group 1 34567 1,480 1,480 100% 1,590 1,580 100% 1,810 1,800 100% Group 2 45678 1,060 1,040 98% 1,140 1,150 101% 1,300 1,310 101% Group 3 56789 1,070 1,040 97% 1,150 1,150 100% 1,310 1,310 100% Group 3 67890 1,040 1,040 100% 1,120 1,150 103% 1,270 1,310 103% Group 3 Efficiency One-
bedroom
Two-
bedroom

ZIP
Code
SAFMR Payment
Standard
Percentage
of
SAFMR
SAFMR Payment
Standard
Percentage
of
SAFMR
SAFMR Payment
Standard
Percentage
of
SAFMR
Grouping
12345 1,490 1,490 100% 1,600 1,590 99% 1,820 1,820 100% Group 1 23456 1,490 1,490 100% 1,600 1,590 99% 1,820 1,820 100% Group 1 34567 1,480 1,490 101% 1,590 1,590 100% 1,810 1,820 101% Group 1 45678 1,060 1,040 98% 1,140 1,150 101% 1,300 1,310 101% Group 2 56789 1,070 1,040 97% 1,150 1,150 100% 1,310 1,310 101% Group 2 67890 1,040 1,040 100% 1,120 1,150 103% 1,270 1,310 103% Group 2 49 of 66

Attachment 3
Peer Agencies
Column1 Question Orange County Housing
Authority (OCHA)
Housing Authority of the City
of Los Angeles (HACLA)
Los Angeles County
Development Authority (LACDA)
Burbank Housing Authority
(BHA)
Anaheim Housing Authority
1 How many EHVs were you
authorized/awarded?
557 3,365 1,972 67 278
2 How many EHVs are currently
leased?
489 Approx. 2,700 1,581 48 from allocation + 5 port-
ins = 53
210
3 What is your current average
monthly HAP for EHV households?
$1,988 Not provided $1,713.74 About $88,000.00 $400k
4 Which household types are you
primarily serving with EHVs
(e.g., homelessness/CES, DV
survivors, trafficking survivors,
etc.)?
Chronically homeless Primarily homeless all EHV families deemed homeless
Homelessness Homeless/CES; initially 10%
DV and 10% rapid rehousing
5 What supportive services, if any,
are tied to your EHV households
(required vs voluntary case
management, provider partners,
etc.)?
Supportive service ties ended
after 12 months; no current
supportive service
connections
None No service requirements in
place
None at this time Providers required to provide
services for 1 year;
participants not required to
take services
6 What is your transition plan for
EHVs as funding is adjusted?
Transition to HCV gradually
over time; movement at end of
each CY until funding is
exhausted
None currently because no
funds in HCV (shortfall)
Exploring options incl.
transitioning most vulnerable
EHV families to HCV and
pursuing avenues such as
Tenant Protection Vouchers
HUD may make available
Plan to transition all EHVs
to HCV should budget suffice
Absorbing into HCV program
7 Are you receiving (or pursuing)
LACAHSA funding, and are there
any plans to address EHVs with
LACAHSA funding? If yes, how do
you plan to use it?
No, not pursuing any
additional funding
Not a recipient of LACAHSA
funds
Not currently receiving
LACAHSA funding; actively
participating in discussions
with LACAHSA and LA County
regarding potential
assistance
Yes; if unable to transition
all EHVs, will utilize
Measure A funds temporarily
until they find other source
of housing
No; not eligible
8 How many non-EHV (regular) HCV
vouchers are you authorized for,
including portables, and how many
are currently leased?
Authorized: 11,435 + 251 MVP
+ 389 EHV (includes OCHA port
out; does not include
portability in). Leased:
10,811 (10,253 HCV + 194 MVP
+ 364 EHV)
ACC is 52,861; only ~85%
voucher utilized due to
insufficient funding
Authorized (incl. PBV):
23,411; Leased: 22,161
Allocation: 1,047 (leased not
provided)
Authorized: 6,438 HCVs (not
including Mainstream).

Leased: ~5,800
9 What other voucher types do you
administer, and approximately how
many of each (e.g., VASH,
Mainstream, FUP, NED, PBV/RAD
PBV, and any other special
purpose/local vouchers)?
VASH, MVP, FUP, FYI, NED, and
PBV
All listed (VASH, Mainstream,
FUP, NED, PBV/RAD PBV, etc.);
refer to HUD HCV dashboard
VASH (Alloc 3,442 / Leased
2,348); Mainstream (203 /
195); FUP (385 / 342); FYI
(191 / 141); NED (100 / 90);
PBV (2,933 / 2,422); SVs (288
/ 129)
VASH (9 in use); PSH (20
allocated/20 used); EHV (67
allocated; 43 used + 5 port-
ins = 53)
VASH, Mainstream, NED, PBV
10 What is your current average
monthly HAP for regular HCV
households?
$1,803 $1,550 $1,605.28 Approximately $1.4 million $10 million 50 of 66

11 For your regular HCV program, do
you prioritize any household
types through preferences or
initiatives (and if so, which)?
Yes. Preference for living and
working in the city
Yes; prioritize homeless
families. Homeless Incentive
Program (HIP) offers monetary
incentives to landlords to
rent to homeless first-time
voucher/certificate holders
prioritized under a homeless
preference
no answer provided Homeless (50% of new
admissions), live/work
residency preference, veteran
priority
12 Is your HCV waitlist open or
closed?
Closed We use lottery process Closed since 2009 Closed Open only for Mainstream and homeless set-aside
preferences13 What is your estimated HCV wait
time (a range is fine)?
Indefinite; no selections
since 9/2023; hope to resume
selection later this year
5–8 years (when the list is
exhausted)
15–19 years 7–10 years 3–5 years
14 About how large is your current
HCV waitlist/applicant pool?
14,000 25,000 names ~4,900 23,000 10k
15 What waitlist preferences/local
preferences do you use (for HCV
and/or EHV, if applicable)?
Applicants who live, work,
have been hired to work in,
or report to an office
located in OCHA’s
jurisdiction. Homeless
individuals and families.

Veterans, Disabled or working
families.

Preference for living and
working in the city
HCV preferences: (1) Pacific
Palisades & Eaton LA
Wildfires displacement; (2)
EHV Super One-Time Limited
Preference; (3) Homeless
Preference; (4) up to 50
trafficking victims via
partner; (5) program
transfers (CoC PSH no longer
needing services; FUP youth
expiring; HOPWA); (6)
live/work in jurisdiction for
declared disasters or
government action
displacement (subject to
approval); (7) VAWA emergency
transfers (subject to
availability); (8) elderly
live/work; (9) jurisdictional
preference live/work admitted
before outside. EHV: no
special preferences; defer to
CES prioritization
Burbank residents; live/work
in Burbank (25 points) +
additional points:
involuntarily displaced by
City/BHA (10); homeless w/
qualified service provider
(10); severely rent burdened
(5); substandard housing (5);
veteran (2.5); disability
(2.5)
Homeless (50% new
admissions), live/work
residency preference, veteran
priority
16 Approximately how many affordable
housing units are in your
agency’s portfolio? Of those
units, approximately how many are
supported by Project-Based
Vouchers (PBVs) (if applicable)?
35 affordable housing
developments that contain PBV
units. ~900 PBV units with
additional units in the
pipeline
Owns/operates ~13,000
affordable units (includes
public housing)
Total affordable units funded
through LACDA NOFA: 25,121
(Completed 20,360; Under
construction 1,475;
Predevelopment 3,286). PBVs
supported: 5,575 (includes
projects under HAP and in
pipeline)
Affordable units count not
provided. PBVs: none
currently; 20 PBVs in
pipeline
~700 PBVs + 77 under AHAP;
over 2,800 affordable units
17 Any additional context, lessons
learned, or considerations you’d
like to share?
Not provided Not provided Clear communication Not provided Not provided Peer Agencies
Column1 Question Orange County Housing
Authority (OCHA)
Housing Authority of the City
of Los Angeles (HACLA)
Los Angeles County
Development Authority (LACDA)
Burbank Housing Authority
(BHA)
Anaheim Housing Authority
51 of 66

U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
WASHINGTON, DC 20410-5000

OFFICE OF PUBLIC AND INDIAN HOUSING

www.hud.gov espanol.hud.gov

______________________________________________________________________________

Special Attention of:

Public Housing Directors;
Regional Public Housing Directors;
Public Housing Agencies

Notice PIH 2025-19

Issued: June 20, 2025

Expires: This notice remains in effect until
amended, superseded, or rescinded.

Cross References: Notice PIH 2025-07;
Notice PIH 2021-15; Notice PIH 2021-20

Subject: Guidance on Transitioning EHV Families into HCV and End of EHV Services Fee Expenditure

1. Purpose

This notice provides guidance to Public Housing Agencies (PHAs) on how to transition Emergency Housing Voucher (EHV) families into its Housing Choice Voucher (HCV) program. PHAs may elect to transition EHV families into the HCV program so that EHV families do not experience a loss or gap in housing assistance and can remain in their assisted units. Further, this notice informs PHAs that they may no longer expend services fees beginning 60 calendar days from the publication of this notice and that they must complete all remaining services fee expenditure reporting in the Voucher Management System (VMS) 120 days from the publication of this notice.

2. Background

EHVs are tenant-based rental assistance under Section 8(o) of the United States Housing Act of 1937 (42 U.S.C. 1437f(o)).1 Eligibility for EHVs is limited to individuals and families who are (1) homeless; (2) at risk of homelessness; (3) fleeing, or attempting to flee, domestic violence, dating violence, sexual assault, stalking, or human trafficking; or (4) recently homeless and for whom providing rental assistance will prevent the family’s homelessness or having high risk of housing instability.

The ARP made EHV funds available for obligation by HUD until September 30, 2030, and those funds will be cancelled as a matter of law effective September 30, 2035.

However, due to historic increases in rental prices resulting in a higher per unit cost

1 Section 3202 of the American Rescue Plan Act of 2021 (P.L. 117-2, hereafter referred to in this notice as “the ARP”) appropriated $5 billion for new incremental EHVs as part of the response to the impact of the COVID-19 pandemic.
52 of 66

2 (PUC) for EHVs, HUD estimates that the Department will only have sufficient funds to cover all EHV families through most of Calendar Year (CY) 2026.

In March 2025, HUD published Notice PIH 2025-07, which directed PHAs to stop issuing any new EHVs after 14 calendar days and reminded PHAs that any incoming EHV ports must be billed to the initial PHA. Additionally, HUD obligated all remaining EHV funding to PHAs. Through this notice, HUD is encouraging PHAs to begin planning for the wind-down of the EHV program as the funding for the program is likely to be expended by the end of CY 2026. PHAs are advised to consider planning a careful transition of families, which may include transitioning families into the PHA’s HCV program, in accordance with this notice. PHAs opting to take this action must follow the procedures described in Section 3 of this notice for adopting a preference for EHV families if the PHA has not already adopted such a preference.

When allocating EHVs to PHAs in 2021, HUD also awarded $245 million in services fees to help facilitate the leasing of EHVs as well as retain and support participating EHV owners. Eligible expenses for services fees, as described in Notice PIH 2023-23, fall into four categories: (1) housing search assistance; (2) security deposit, utility deposit, rental application, and holding fees; (3) owner-related uses; and (4) other eligible uses. HUD expanded the use of services fees in 2023 to provide more opportunities for PHAs to use the fees to support currently housed EHV families. Future guidance on returning unexpended service fees and reallocation is forthcoming.

3. Transitioning EHV Families into the HCV Program

HUD strongly encourages PHAs to transition EHV families to the HCV program so that EHV families do not lose assistance and potentially face homelessness. PHAs that choose this option should provide clear information to EHV families about the process for applying to the HCV waiting list under an EHV preference, the status of EHV funding, and why the PHA is adopting an EHV preference. PHA communication to EHV families should also clearly explain that choosing to apply and be transitioned to the HCV program is optional for the family. Further, communication to families should explain the potential consequences of remaining on EHV assistance, including the risk of termination of assistance due to lack of permanent EHV funding.

In transitioning a family into HCV, a PHA is making assistance payments with funding under its consolidated HCV Annual Contributions Contract (24 CFR 982.4(b)). In order to transition EHV families into its HCV program, the PHA must have HCV unit-months available to use for EHV families. The prohibition on HCV over-leasing as described in Section IV.F.3 of Notice PIH 2025-13 applies. Information on EHV waivers (which do not apply to HCV) and transitioning families to the HCV program follows in subsection c. below.

PHAs are reminded that EHV funding cannot be used for regular HCV Housing Assistance Payment (HAP) costs, even for former EHV families, once the EHV family has been transitioned to the regular HCV program.
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3 PHAs should consider using HUD’s Two-Year Tool (TYT) to help them determine how many EHV families may remain in their program towards the end of CY 2026. Because the amount of remaining EHV funding is known and not subject to annual appropriations, there are fewer unknown variables and PHAs can use PUC trends and attrition rates to estimate the number of families that may need to be transitioned to HCV.

a. Waiting Lists

In order to transition EHV families into the PHA’s regular HCV program, the family must be selected through the PHA’s HCV waiting list as required by 24 CFR 982.204(a).

PHAs that currently have an open waiting list should take the following steps:
 Determine if establishing a waiting list preference constitutes a significant amendment to its PHA Plan (24 CFR 903.21).
 If the PHA determines that establishing a waiting list preference constitutes a significant amendment, complete the process for updating the PHA Plan (24 CFR 903.17). PHAs must provide a public comment period, which is a statutory requirement that cannot be waived by HUD.
 Complete the process for updating the administrative plan (24 CFR 982.54). Per 24 CFR 982.54(a), revisions to the administrative plan must be formally adopted by the PHA’s Board of Commissioners or other authorized PHA officials.

PHAs with a currently closed HCV waiting list who opt to transition EHV families may choose to open their waiting list only for families that qualify for an EHV preference. In this case, the PHA must include the preference in its administrative plan (24 CFR 982.54(d)(1)).

b. Preferences

PHAs may establish a local preference based on local housing needs and priorities as determined by the PHA (24 CFR 982.207(a)(2)), and this may include families participating in EHV. PHAs that want to transition EHV families into the HCV program should structure the preference in a way that provides clarity that only current EHV participants are eligible for the preference. For example, the preference could state that it is for currently assisted EHV families whose assistance is at risk of termination due to lack of program funding.

There are multiple methods that PHAs may use to apply preferences, including lumping, aggregating, and ranking. PHAs have discretion to apply preferences through several methods, provided that the selected methods comply with fair housing and civil rights requirements. In establishing an EHV preference, PHAs will need to consider how the preference method(s) they currently employ will impact the desired goal of moving EHV families to the top of the PHA’s waiting list to expediently transition EHV families.

There are no priority preferences with lumping or aggregating methods, but PHAs can use a ranking method to weigh an EHV preference above all other existing preferences.

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4 Some PHAs may only have available HCVs to transition a portion of their EHV families.

PHAs in this situation may want to consider adopting multiple EHV preferences to first prioritize the most vulnerable households. For example, PHAs could adopt a preference for EHV families with a head of household, spouse, or co-head who is elderly or disabled, and a second preference for all other EHV families. In designing preferences, PHAs are reminded that all preferences must be consistent with fair housing and civil rights laws.

PHAs with Mainstream vouchers available may consider adopting a preference for EHV families that meet Mainstream eligibility requirements. To transition families into Mainstream, families must be Mainstream-eligible, and the family must be properly added to the waiting list consistent with statutory, regulatory, and other requirements.2 This option does not apply to Special Purpose Voucher (SPV) programs other than Mainstream. These SPV programs have statutory eligibility requirements that EHV families cannot meet and/or involve partnerships that require the PHA to receive referrals from certain sources (i.e., the Family Unification Program, Foster Youth to Independence, HUD-Veterans Affairs Supportive Housing, and Stability Vouchers). Per Section IV.E.1 of Notice PIH 2025-13, the same prohibition on over-leasing applies for Mainstream.

Once the PHA has adopted its EHV preference(s), the PHA should ensure effective communication of notice to all EHV families about the new preference and the opportunity to apply for the HCV program under the preference. PHAs should provide a reasonable amount of time to EHV families to apply for the HCV program before selecting any EHV families from their HCV waiting list. As an alternative to only accepting individual applications from EHV families, HUD is providing a streamlined submission and review process for a regulatory waiver that, if approved, would permit PHAs to place all EHV families on its HCV waiting list with the appropriate preference.

To ensure streamlined processing, PHAs must submit their waiver request in DocuSign.

PHAs must provide certain information within the waiver request document, including:
 PHA name, code, and business address
 Name and email for the PHA point of contact
 A PHA-specific justification for the waiver that shows good cause. The good cause justification must include: 1) why the PHA needs the waiver, and 2) the impact on PHA operations and applicants if the waiver is not provided.

Following submission, PIH will reply via email confirming that the request has been received. Once a final determination for approval by the Assistant Secretary has been made, PHAs will receive the signed response to the waiver request via email. No waiver requested may be implemented unless written approval from HUD has been obtained.

2 Notice PIH 2024-30, Statutory and Regulatory Waivers for Mainstream Vouchers, for mandatory and optional waivers and alternative requirements related to waiting lists in the Mainstream program. 55 of 66

5 c. EHV waivers and alternative requirements

PHAs are reminded that the EHV waivers and alternative requirements outlined in Notice PIH 2021-15 do not apply to their HCV program. However, as discussed below, families that were properly admitted to the EHV program and are currently receiving EHV assistance are participants under a section 8(o) tenant-based voucher program. This section discusses the requirements that apply (particularly with respect to criminal screening and income) when a PHA is transitioning a family from EHV to HCV assistance. In addition, this section reviews EHV waivers that PHAs may have opted to use and the existing flexibilities available to PHAs in lieu of those waivers to minimize disruption to EHV families.

Criminal Rescreening. Families that were properly admitted to the EHV program by PHAs in full compliance with the requirements of Notice PIH 2021-15 and are currently receiving EHV assistance are participants under a section 8(o) tenant-based voucher program. Therefore, applicant screening requirements do not apply when the PHA is transitioning a family from EHV to HCV assistance. All HCV requirements with respect to termination of assistance for participants apply to EHV families when they are transitioned to HCV assistance.

Income Eligibility and Targeting. Families that were properly admitted to the EHV program by PHAs in full compliance with the requirements of Notice PIH 2021-15 and are currently receiving EHV assistance are participants under a section 8(o) tenant-based voucher program. Therefore, the income-eligibility and targeting requirements in 24 CFR 982.201, which apply to applicants, do not apply in cases where the PHA is transitioning a family from EHV to HCV assistance. All HCV requirements with respect to participant family income and composition (particularly, 24 CFR 982.516) apply to EHV families when they are transitioned to HCV assistance.

Social Security Number and Citizenship Verification. In Section 9(i) of Notice PIH 2021-15, HUD waived the requirement to obtain and verify documentation of social security number (SSN) and eligible noncitizen status (if applicable) before admitting families to EHV. HUD established an alternative requirement that individuals must provide the required documentation within 180 days of admission to remain eligible for continued assistance, pending verification, unless the PHA provided an extension based on evidence from the family or confirmation from the CoC or other partnering agency that the family has made a good-faith effort to obtain the documentation.

A PHA may not transition a family from the EHV program to the HCV program until it verifies documentation of SSN and eligible noncitizen status. The EHV alternative requirement in this section does not apply to HCV program.

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6 Payment Standards and Rent Reasonableness. To increase housing choice for EHV families, section (9)(p) of Notice PIH 2021-15 waived 24 CFR 982.503(a)(3), allowing PHAs to set separate, higher payment standards for EHV. PHAs were permitted to establish EHV payment standards up to 120 percent of Fair Market Rent (FMR) without HUD approval.

PHAs that chose to set higher payment standards for EHV may want to consider two options to minimize harm to families: (1) If the EHV payment standards are above 110 percent and up to 120 percent of applicable FMR, the PHA could align both programs’ payment standards by using the simplified process described in Section 5B of Notice PIH 2024-34, or (2) the PHA could hold families harmless and choose not to reduce the payment standard amount used to calculate the subsidy for a family as long as they continue to reside in the same unit (see Section 10 of Notice PIH 2024-34).

PHAs should note that the requirement limiting the family share to 40 percent or less of monthly adjusted income at initial occupancy (24 CFR 982.508) does not apply if the family is leasing in place.

d. HAP Contract and Tenancy Addendum

As tenant-based assistance under section 8(o) of the United States Housing Act of 1937, EHV uses the same HAP contract (HUD-52641) and tenancy addendum as the regular HCV program. When transitioning an EHV family to HCV, PHAs are not required to execute a new HAP contract or tenancy addendum for the family provided that the family is remaining in the same unit.

e. PIC Reporting

When admitting an EHV family from the HCV waiting list, the family should be coded on line 2n of the HUD-50058 as “EHCV.” Moving to Work (MTW) PHAs should code the family on line 2p as “EHCV” on the HUD-50058 MTW and leave 2n blank. HUD will use this code to track the number of EHV families admitted to HCV but also to award the $1,000 fee per EHV family that is successfully transitioned to the regular HCV program, as described in Notice PIH 2025-13. PHAs will not receive the fee for transitioning EHV families if they fail to code the family as “EHCV” on line 2n or 2p for MTW PHAs. When a family transitions to HCV and remains in their unit, PHAs should not use action code 6 (“End Participation”) but instead use action code 3 (“Interim Reexamination”). If the family is not leasing in place, PHAs must use action code 7 (“Other change in unit”).

4. Services Fees

PHAs have 60 calendar days from the date of the publication of this notice to use services fees on eligible expenses, and an additional 60 calendar days from the date of the publication of this notice to complete services fees VMS reporting. PHAs should review

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7 Notice PIH 2023-23 that describes the eligible uses of services fees. PHAs will be required to repay any disallowed costs if services fees are used for ineligible expenses.

HUD will describe the process for recapture and reallocation of services fees in a separate, future notice.

5. Information Contact. Inquiries about this notice should be directed to [email protected].

6. Paperwork Reduction Act. The information collection requirements contained in this notice have been approved by the Office of Management and Budget (OMB) under the Paperwork Reduction Act (PRA) of 1995 (44 U.S.C 3520). In accordance with the PRA, HUD may not conduct or sponsor, and a person is not required to respond to a collection of information unless the collection displays a currently valid OMB control number. The active information collections contained in this notice have been approved under the PRA OMB Control Number 2577-0169.

_____________________________
Benjamin Hobbs
Principal Deputy Assistant Secretary
Office of Public and Indian Housing

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Parkview Breakdown
Option A
(Lowest
Subsidy) ID
Option A Tier Option A Age Option A HH
Size
Option A
Annual Income
Option A
Monthly
Subsidy
Applicant 1 Tier 2 65 1 $ 41,331.00 $ -
Applicant 2 Tier 3 65 1 $ 38,293.00 $ -
Applicant 3 Tier 3 75 1 $ 29,262.00 $ 18
Applicant 4 Tier 2 73 2 $ 29,136.00 $ 22
Applicant 5 Tier 2 78 2 $ 24,912.00 $ 127
Applicant 6 Tier 2 72 2 $ 24,780.00 $ 90
Applicant 7 Tier 2 69 2 $ 24,672.00 $ 93
Applicant 8 Tier 3 78 1 $ 22,464.00 $ 148
Applicant 9 Tier 2 62 1 $ 21,283.00 $ 178
Applicant 10 Tier 3 72 1 $ 21,096.00 $ 183
Applicant 11 Tier 2 62 2 $ 20,088.00 $ 208
Total Option 1 Income + Age $ 1,067
Annual Cost $ 12,806.16
Assumption: 2% Increase
Yr 1 Yr 2 Yr 3 Yr 4 Yr 5
Option 1 $ 12,806.16 $ 13,062.28 $ 13,323.53 $ 13,590.00 $ 13,861.80 Option 2 $ 48,428.40 $ 49,396.97 $ 50,384.91 $ 51,392.61 $ 52,420.46 Total Subisidy over 15 years
Option 1 $221,462.26
Option 2 $837,492.51
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Parkview Breakdown
Tenant Rent Total Rent
Option B
(Strictly
Oldest) ID
Option B Tier Option B Age Option B HH
Size
$ 750 $ 750.00 Applicant 1 Tier 2 87 1
$ 750 $ 750.00 Applicant 2 Tier 1 87 1
$ 732 $ 750.00 Applicant 3 Tier 2 86 1
$ 728 $ 750.00 Applicant 4 Tier 2 84 1
$ 623 $ 750.00 Applicant 5 Tier 1 83 1
$ 620 $ 710.00 Applicant 6 Tier 1 82 1
$ 617 $ 710.00 Applicant 7 Tier 1 81 1
$ 562 $ 710.00 Applicant 8 Tier 2 78 1
$ 532 $ 710.00 Applicant 9 Tier 1 78 1
$ 527 $ 710.00 Applicant 10 Tier 2 78 1
$ 502 $ 710.00 Applicant 11 Tier 2 78 1
$ 6,942.82 $ 8,010.00 Option 2 Age Consideration Only
$ 83,313.84 $ 96,120.00
Yr 6 Yr 7 Yr 8 Yr 9 Yr 10 Yr 11
$ 14,139.04 $ 14,421.82 $ 14,710.25 $ 15,004.46 $ 15,304.55 $ 15,610.64 $ 53,468.87 $ 54,538.24 $ 55,629.01 $ 56,741.59 $ 57,876.42 $ 59,033.95 60 of 66

Option 2 Age Consideration Only
Attachment 5
Option B
Annual Income
Option B
Monthly
Subsidy
Option 2
Tenant Rent
Option 2
Total Rent
$ 14,072.00 $ 398 $ 352 $ 750
$ 14,312.00 $ 392 $ 358 $ 750
$ 14,072.00 $ 398 $ 352 $ 750
$ 14,072.00 $ 398 $ 352 $ 750
$ 12,989.00 $ 385 $ 365 $ 750
$ 14,072.00 $ 358 $ 352 $ 710
$ 14,024.00 $ 359 $ 351 $ 710
$ 12,332.00 $ 402 $ 308 $ 710
$ 14,072.00 $ 358 $ 352 $ 710
$ 14,072.00 $ 358 $ 352 $ 710
$ 20,883.00 $ 228 $ 482 $ 710
$4,035.70 $ 3,974 $ 8,010
$ 48,428.40 $ 47,691.60 $ 96,120.00
Yr 12 Yr 13 Yr 14 Yr 15
$ 15,922.85 $ 16,241.31 $ 16,566.13 $ 16,897.46
$ 60,214.63 $ 61,418.92 $ 62,647.30 $ 63,900.25
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Attachment 6
Tier Breakdown
Option 1 - Balanced Approach
Staff developed a multi-factor prioritization process to guide the transition of 188 households from federal Emergency Voucher (EHV) assistance to locally funded bridge support. Rather than using a first-come, first-served approach, the process evaluates households using clinical and financial factors to identify those at greatest risk of returning homelessness. This approach helps ensure that limited local resources are directed to residents with the highest needs and the greatest barriers to maintaining housing stability.

Tier 1: Highest Vulnerability (24 Households)
Reserved strictly for severely low-income, elderly, and disabled individuals. This tier targets those with the highest risk who have the least capacity to navigate the market independently.
Household Size: Limited strictly to single-person households. Age & Disability: Household must be 62 years or older AND have a documented disability.
Income: Gross income must be at or below 15% AMI.
Status: Homeless Certification was strictly "Homeless" or "Recently Homeless" or “Fleeing Domestic Violence”
Must reside in Glendale.

Tier 2: Moderate Vulnerability (47 Households)
The secondary buffer to protect aging seniors, disabled adults, and families with children who have already survived the trauma of literal street/shelter homelessness. Vulnerability: Household is Disabled OR a Family with minor children. Income: Gross income must be at or below 30% AMI (Extremely Low Income) scaled by household size.
Status: Homeless Certification was strictly "Homeless," "Recently Homeless," or “Fleeing Domestic Violence.”
Any household 70 years or older is automatically protected in Tier 2 regardless of income or disability status.
Must reside in Glendale.

Tier 3: At-Risk (80 Households)
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Attachment 6
This tier captures any remaining seniors, as well as ANY household living in extreme poverty, regardless of their age, disability, or family status. Income: Households making 30% AMI or less.
Status: Homeless Certification was strictly "At Risk of Homelessness." Any household 62 years or older is protected in Tier 3, regardless of income. Disability & Family Safety Net: ANY household with a documented disability or minor children is protected in Tier 3, regardless of income. Must reside in Glendale.

Tier 4: Transition (37 Households)
The segment of the EHV population with the highest baseline capacity to transition to independent living, as well as those residing outside Glendale. Income: Includes all households under the age of 62 with a Gross Income exceeding 30% AMI.
Any household residing outside of Glendale.

Option 2: Senior-First Prioritization
Tier 1: Highest Vulnerability
The core safety net reserved strictly for the most fragile seniors who cannot survive a transition to the market.

A household is placed in Tier 1 if they meet ALL of the following criteria:
Age and Disability: Household is 62 years or older; AND has a documented disability;
Income: Gross income must be at or below 15% AMI
Risk: Homeless Certification was strictly "Homeless," "Recently Homeless," or “Fleeing Domestic Violence.”
Must reside in Glendale.

Tier 2: Moderate Vulnerability
A broad safety net designed to pull all remaining seniors out of the lower tiers, regardless of their income or specific homeless history. Vulnerability: ANY household age 62 or older who did not qualify for the specific Tier 1 criteria.
Must reside in Glendale.
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Attachment 6
Tier 3: Vulnerable Families & Non-Seniors
Households with minor children or documented disabilities who are under the age of 62. Vulnerability: Household is Disabled OR a Family with minor children OR an Aging Adult (55 to 61 years old).
Income: Gross income must be at or below 30% AMI.
Risk: Homeless Certification was strictly "Homeless," "Recently Homeless," or “Fleeing Domestic Violence.”
Must reside in Glendale.

Tier 4: Transition
The segment of the population with the highest relative capacity for workforce reentry or independent housing stability.
Able-bodied single adults under 62 without dependents. Families or disabled adults under 62 whose prior status was only "At risk of homelessness."
Income: Any non-senior household (under 62) with an income exceeding 30% AMI.

Priority Sorting Rule
To ensure an equitable distribution of limited funding, households within each of the 4 Tiers are ranked using the following "Vulnerability-First" hierarchy:

1.Age (Primary Sort): Oldest to Youngest.

2.Income (Secondary Sort): Lowest to Highest.

3.Homeless History (Tertiary Sort): Longest to Shortest. 64 of 66

Attachment 7
Option 1: Balanced Approach
Tier Households Avg Age Senior
(62+) Disabled
Families
w/
Children
Below 15%
AMI
Avg
Annual
Income
Avg Gross
Rent
Avg
Tenant
Rent
Avg
Subsidy
(HAP)
Tier 1 24 72.2 100% 100% 0% 100% $ 14,356 $ 2,096 $ 91 $ 1,847 Tier 2 47 60.8 53% 74% 11% 64% $ 17,316 $ 2,420 $ 341 $ 1,921 Tier 3 80 48.3 19% 21% 6% 62% $ 18,475 $ 2,379 $ 224 $ 1,978 Tier 4 37 44.7 16% 27% 0% 38% $ 31,764 $ 2,375 $ 718 $ 1,479 TOTAL PORTFOLIO 188 53.8 37% 46% 5% 63% $ 20,275 $ 2,353 $ 333 $ 1,849 Option 2: Senior-First Prioritization
Tier Households Avg Age Senior
(62+) Disabled
Families
w/
Children
Below 15%
AMI
Avg
Annual
Income
Avg Gross
Rent
Avg
Tenant
Rent
Avg
Subsidy
(HAP)
Tier 1 24 72.2 100% 100% 0% 100% $ 14,356 $ 2,096 $ 91 $ 1,847 Tier 2 40 71.2 100% 60% 0% 52% $ 18,325 $ 2,284 $ 333 $ 1,781 Tier 3 31 48.8 0% 55% 16% 77% $ 14,232 $ 2,517 $ 293 $ 2,063 Tier 4 93 43.2 6% 23% 5% 53% $ 24,655 $ 2,393 $ 409 $ 1,807 TOTAL PORTFOLIO 188 53.8 37% 46% 5% 63% $ 20,275 $ 2,353 $ 333 $ 1,849 65 of 66

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Glendale City CouncilApril 28, 2026

Glendale City Council
April 28, 2026