AR 12 ATTACHMENT A — Pasadena City Council, January 12, 2026 (part 2 of 2)

The CoPHD must execute the HAP Contract if the CoPHD accepts the unit(s) . The effective date of the HAP Contract may not be earlier than the date of the CoPHD inspection and acceptance of the unit(s).

After commencement of the HAP Contract term, the CoPHD must make monthly housing assistance payments for each unit occupied under lease by an eligible family.

At the discretion of the CoPHD and subject to all PBV P requirements, the HAP contract may be amended to substitute a different unit with the same number of bedrooms in the same building for previously covered contract unit. Prior to such substitution, the CoPHD must inspect the proposed substitute unit and must determine the reasonable rent.

The Quality Housing and Work Responsibility Act of 1998 (QHWRA) requires owners to provide not less than one - year written notice to tenants and HUD of expiration or termination of the Contract.

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G. REDUCTION OF UNITS

Owners must lease all assisted units under a HAP Contract to eligible families. Leasing of vacant, assisted units to ineligible tenants is a violation of the HAP Contract and grounds for all available legal remedies, including suspension or debarment from the HUD program and reduction of the number of units under the HAP C ontract. Once the CoPHD determines that a violation exists, the CoPHD must notify the HUD field office of its determination and the suggested remedies. At the direction of the HUD field office, the CoPHD must take the appropriate action.

If at any time beginning 180 calendar days after the effective date of the HAP C ontract, the owner fails to have the assisted units leased to families receiving housing assistance or to families who were eligible when they initially leased the unit , but are no longer receiving housing assistance, the CoPHD may, on at least a 30 calendar days notice, reduce the number of units covered by the HAP C ontract. The CoPHD may reduce the number of units actually leased or available for leasing by eligible families, plus 10 percent (round up).

If the owner has only one unit under a HAP Contract, and if one year has elapsed since the date of the last housing assistance payment, the HAP Contract may be terminated with the consent of the owner.

The CoPHD will agree to an amendment of the HAP C ontract to provide for subsequent restoration of any reduction made pursuant to the above mentioned paragraph of this section, if:

1. The CoPHD determines that the restoration is justified by demand.

2. The owner otherwise has a record of compliance with obligations under the HAP Contract; and

3. Contract authority is available.

H. RESPONSIBILITIES OF THE CoPHD [24 CFR 983.201]

The CoPHD must:

1. Inspect the project before, during, and upon completion of new construction or rehabilitation; and

2. Ensure that the amount of assistance that is attached to units is within the amounts available under the ACC.

I. RESPONSIBILITIES OF THE OWNER [24 CFR 983.208 & 24 CFR 982.452]

The owner is responsible for performing all of the owner responsibilities under the Agreement and the HAP Contract, providing the CoPHD with a copy of any termination of tenancy notification, and offering vacant, accessible units to a family with one or more members with a disability requiring accessibility features of the vacant unit and occupying an assisted unit not having such features.

J. FAMILY PARTICIPATION [24 CFR 983.251]

The CoPHD may select families who are participants in the CoPHD’s tenant -based voucher program. The CoPHD will use the tenant -based assistance waiting list for its PBVP, pursuant to 24 CFR 982.201, 982.202 except paragraph (b)(c), 982.203, 982.204 except paragraph (a)(b), 982.205 except paragraph (a), 982.206 and 982.207.

When the owner notifies the CoPHD of vacancies in the PBVP units, the CoPHD will refer one or more families of the appropriate size from its waiting list. A family that refuses an offer of a PB VP unit will keep its place on the tenant - DRAFT
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based waiting list. The owner must rent all vacant PB VP units to eligible families referred by the CoPHD. The CoPHD will determine eligibility of any family referred for a PBVP unit.

Before the CoPHD selects a specific unit to which assistance is to be attached, the CoPHD must determine whether the unit is occupied, and if so, whether the occupants are eligible for assistance. If the unit is occupied by an eligible family (including a single person) and the CoPHD selects the unit, the family must be given the opportunity to lease that unit or another appropriately sized, project -based unit in the project without requiring that the family be placed on the waiting list. The CoPHD may not enter into an agreement to provide project-based assistance to a unit whose occupants are not eligible to participate in the program.

If the CoPHD does not refer a sufficient number of interested families on the CoPHD’s waiting list to the owner within 30 days of the owner’s notification to the CoPHD of a vacancy, the owner may advertise for or solicit applications from eligible, very low-income families. The owner must refer these families to the CoPHD to determine eligibility.

The CoPHD and/or owner may also partner with other agencies for referrals for project based units.

The owner is responsible for screening and selection of tenants. The owner must adopt written tenant selection procedures that are consistent with the purpose of improving housing opportunities for very low -income households and with a family’s ability to perform the lease obligations. The owner must promptly notify any rejected family in writing of the grounds for that rejection.

In order for a family to be eligible for participation under the PBVP, the family must meet the eligibility criteria outlined in Chapter 2 of this Plan, “Eligibility for Admission” and the family’s annual income may not exceed the applicable income limit as set by HUD.

A family becomes a participant when the family and owner execute a lease for a unit with project-based assistance.

If the HAP Contract for the unit expires or if the CoPHD terminates the HAP Contract for the unit:

1. The CoPHD must issue the assisted family in occupancy of a unit a HCV for assistance under the CoPHD’s voucher program, unless the CoPHD has determined that it does not have sufficient funds for continued assistance for the
family, or unless the CoPHD denies issuance of a HCV in accordance with 24 CFR 982.552.

2. If the unit is not occupied by an assisted family, then the available funds under the ACC that were previously committed for support of this project- based assistance for the unit must be used for the CoPHD’s tenant- based voucher program.

K. BRIEFING SESSIONS FOR PBVP PARTICIPANTS [24 CFR 983.252]

Briefing sessions will be held for families who have been selected to occupy a project -based unit. The briefing session will provide the family with the following:

1. Information regarding the tenant rent and any applicable utility allowance.

2. A copy of the Lead-Based Paint information pamphlet.

3. Family and owner responsibilities under the lease and HAP Contract.

4. Information on Federal, State, and local equal opportunity laws.

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5. The fact that the subsidy is tied to the unit, that the family must occupy a unit under the program, that a family that moves from the unit does not have any right to continued assistance.

6. The likelihood of the family receiving a HCV after the HAP Contract expires.

7. The family’s options under the program if the family is required to move because of a change in family size or composition; and

8. Information on the CoPHD’s procedures for conducting informal hearings for participants, including a description of the circumstances in which the CoPHD is required to provide the opportunity for an informal hearing, in accordance with 24 CFR 98 2.555, and the procedures for requesting a hearing (see Chapter 18 of this Plan).

L. PHYSICAL CONDITION STANDARDS & PHYSICAL INSPECTION

REQUIREMENTS

Housing used in the PBVP must be maintained and inspected in accordance with the requirements in 24 CFR 5, subpart G prior to the HAP Contract execution. In addition to the standards in 24 CFR 5, subpart G, the dwelling unit must have a living room, a kitchen area, and a bathroom. The dwelling unit must have at least one bedroom or living/sleeping room for each two persons.

The Lead-Based Paint Poisoning Prevention Act and implementing regulations at 24 CFR 35, subparts A, B, H, and R of this title apply to units assisted under this part.

The dwelling unit must be inspected and must pass HQS prior to the execution of the Lease.

M. MAINTENANCE, OPERATION AND INSPECTION [24 CFR 983.207]

The following sections do not apply to the PBVP:

1. 24 CFR 982.404 Maintenance: Owner and family responsibility; PHA remedies.

2. 24 CFR 982.405: PHA periodic unit inspections and enforcement of HQS.

The owner must provide all the services, maintenance and utilities as agreed under the HAP C ontract, subject to abatement of housing assistance payments or other applicable remedies if the owner fails to meet these obligations.

In addition to the inspections required prior to execution of the HAP Contract, the CoPHD must inspect or cause to be inspected each dwelling unit under a HAP Contract at least annually, and at such other times as may be necessary to ensure that the owner is meeting the obligations to maintain the unit in decent, safe, and sanitary condition s and to provide the agreed upon utilities and other services. The CoPHD must take into account complaints and any other information coming to its attention in scheduling inspections.

If the CoPHD notifies the owner that the units under HAP C ontracts are not being maintained in decent, safe, and sanitary conditions and the owner fails to take corrective action within the time prescribed in the notice, the CoPHD may exercise any of its rights or remedies under the HAP C ontract, including abatement of housing assistance payments, even if the family continues in occupancy, or t he termination of the HAP Contract and termination of assistance to the family, in accordance with 24 CFR 982.552.

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N. OVERCROWDED, UNDEROCCUPIED, AND ACCESSIBLE UNITS [24 CFR 983.259]

If the CoPHD determines that a family is occupying the wrong sized unit or the unit with accessibility features that the family does not require, and the unit is needed by a family that requires the accessibility features, the CoPHD must promptly notify the family and the owner of this determination, and of the CoPHD offer of continued assistance in another unit. If the CoPHD’s subsidy standards changed after the family moved into the unit and the family has had not a change in family composition, the family will not be considered in the wrong sized unit.

The owner must offer the family a suitable alternative unit if one is available and the family shall be required to move.

If the owner does not have a suitable unit available within the family’s ability to pay the rent, the CoPHD (if it has sufficient funding) may offer tenant-based assistance to the family or otherwise assist the family in locating other standard housing in the CoPHD’s jurisdiction within the family’s ability to pay, and require the family to move to such a unit.

If the CoPHD offers the family the opportunity to receive tenant -based rental assistance under the voucher program, the CoPHD must terminate the housing assistance payments for a wrong -sized or accessible unit at expiration of the term of the family’s voucher (including any extension granted by the PHA).

If the CoPHD offers the family the opportunity for another form of continued housing assistance in accordance with 983.259(b)(2) (not in the tenant-based voucher program), the family does not accept the offer, does not move out of the PBV unit within a reasonable time as determined by the CoPHD, or both, the CoPHD must terminate the housing assistance payments for the wrong- sized or accessible unit, at the expiration of the reasonable period that was determined by the CoPHD

O. ASSISTED TENANCY AND TERMINATION OF TENANCY [24 CFR 983.206]

The term of a lease, including a new lease or a lease amendment, executed by the owner and the family must be for at least one year, or the remaining term of the HAP Con tract if the remaining term of the HAP C ontract is less than one year. The family must notify the CoPHD and the owner before the family moves out of the unit. Term of assisted tenancy, 24 CFR 982.309, and owner termination of tenancy, 24 CFR 982.310(d)(1)(iii)(iv), do not apply to the PBVP.

The family is required to terminate the lease with a 60 -day advance written notice to the owner and a copy of the notice to the CoPHD. The owner may offer the family a new lease for execution by the family for a term beginning at any time after the first year of the term of the lease. The owner must give the family written notice of the offer at least 60 days before the proposed commencement date of the new lease term. The offer may specify a reasonable time for acceptance by the family. Failure by the family to accept the offer of a new lease in accordance with this paragraph shall be “other good cause” for termination of tenancy.

P. RENT AND HOUSING ASSISTANCE PAYMENT [24 CFR 983.302]

In 24 CFR 982 subpart K, rent and housing assistance payment for tenant -based program, the following are the only sections that apply to the PBV P under 24 CFR 982.516 (regular and interim re -examination of the family income and composition) and 24 CFR 982.517 (utility allowance schedule).

Q. LIMITS ON INITIAL RENT TO OWNER [24 CFR 983.301]

The initial rent to owner for a unit may not exceed the reasonable rent as determined by the CoPHD, in accordance with 24 CFR 983.302.

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The tenant rent under the PBVP is limited to 30% of the participant’s adjusted monthly income minus tenant paid utilities.

The initial gross rent for a unit (rent to owner plus utility allowance) may not exceed the payment standard rent limit as determined by the CoPHD, in accordance with 24 CFR 982.503. However, at the time of initial occupancy by the eligible family, the family gross rent must not exceed 40% of the family adjusted monthly income.

The PBVP HAP Contract shall establish gross rents that do not exceed 110% of the established Fair Market Rent (FMR) or any HUD -approved “exception payment standard” for the City of Pasadena. The HAP Contract will also allow for an annual rent adjustment. The initial and adjusted rents to the owner must also be reasonable in relation to rents charged in the private market for comparable unassisted units.

R. ANNUAL ADJUSTMENT OF RENT TO OWNER [24 CFR 983.302]

At each annual anniversary date of the HAP Contract, the CoPHD may re-determine the rent to owner in accordance with the following requirements:

1. The owner must request a rent increase (including a comparability study to determine the amount of such increase) by written notice to the CoPHD, at least 120 days before the HAP Contract anniversary. The request must be submitted in the form and manner required by the CoPHD.

2. The CoPHD may not increase the rent at the annual anniversary unless:

a. The owner requested the increase by the 120-day deadline; and

b. During the year before the HAP Contract anniversary, the owner complied with all requirements of the HAP Contract, including compliance with HQS for all contract units.

3. Rent increases will be implemented at the time of HAP Contract anniversary.

The adjusted rent to owner equals the lesser of:

1. The re-adjustment rent to owner multiplied by the applicable Section 8 A nnual Adjustment Factor published by HUD.

2. The reasonable rent as determined by the CoPHD, in accordance with 24 CFR 983.256; or

3. The rent requested by owner.

The applicable factor is the published annual adjustment factor in effect 60 days before the HAP C ontract anniversary. In making the annual adjustment, the pre -adjustment rent to owner does not include any previously approved special adjustments. The rent to owner may be adjusted up or down, in accordance with 24 CFR 983.301.

S. SPECIAL ADJUSTMENT OF THE RENT TO OWNER [24 CFR 983.301]

At HUD’s sole discretion, HUD may approve a special adjustment of the rent to owner. The CoPHD may only make a special adjustment of the rent to owner if the adjustment has been approved by HUD.

A special adjustment may only be approved to reflect increases in the actual and necessary costs of owning and maintaining the contracted units because of substantial and general increases in:

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1. Property taxes.

2. Special governmental assessments.

3. Utility rates; or

4. Cost of utilities not covered by the regulated rates.

A special adjustment may only be approved if and to the extent that the owner demonstrates that cost increases are not adequately compensated by application of the published annual adjustment factor at the HAP Contract anniversary. The owner must demonstrate that the rent to owner is not sufficient for proper operation of the housing.

The adjusted rent may not exceed the reasonable rent as determined by a comparability study, in accordance with 24 CFR 983.301.

The owner must submit financial information, as requested by the CoPHD, that supports the grant or continuance of a special adjustment. For HAP Contracts of more than 20 units, such financial information must be audited.

The CoPHD may withdraw or limit the term of any special adjustment. If a special adjustment is approved to cover temporary or one-time costs, the special adjustment is only a temporary or one-time increase of the rent to owner.

T. REASONABLE RENT [24 CFR 983.303]

The CoPHD may not enter an agreement to enter into a HAP Contract until the CoPHD determines that the initial rent to owner under the HAP Contract is reasonable. During
the term of a HAP Contract, the rent to owner may not exceed the reasonable rent as determined by the CoPHD.

At least annually during the HAP C ontract term, the CoPHD must re-determine that the current rent to owner does not exceed a reasonable rent. The CoPHD must determine whether the rent to owner is a reasonable rent in comparison to rent for other comparable unassisted units. To make this determination, the CoPHD must consider:

1. The location, quality, size, unit type, and age of the contract unit; and

2. Any amenities, housing services, maintenance and utilities to be provided by the owner in accordance with the lease.

U. VACANT UNITS [24 CFR 983.352]

Vacancy payments will not be paid for vacant units.

V. CONVERSION OF SECTION 8 PROJECT -BASED ASSISTANCE TO TENANT -BASED ASSISTANCE [PIH NOTICE 99-40, SEPTEMBER 1, 1999]

HUD currently provides additional funding to public housing agencies to assist eligible residents who are affected by “housing conversions.” Housing conversions occur when a Section 8 P roject-Based Contract is near expiration, has expired, or the owner chooses to “opt-out” of the Contract (“Contract termination”). In those instances where expiring Project-Based Rental Assistance is being replaced by Tenant-Based Rental Assistance (TBRA) Vouchers, HUD shall determine the appropriate actions and provide guidance and instruction to the CoPHD.

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The conversion process typically begins with HUD’s receipt of the notice from the owner stating the intent to terminate the existing Contract. This notice must be in writing and provided to both the tenants and HUD, not less than one year from the C ontract termination date. It is the responsibility of HUD to enforce the notification requirements of the owner. Based on the appropriate notification and at least 120 days prior to the termination date of the Contract, HUD shall determine the number of occupants in place, the composition of each family , and extend an invitation to the CoPHD offering the CoPHD the opportunity to administer TBRA to the eligible families. Once the CoPHD has agreed to administer TBRA and issue HCVs , the existing ACC between the CoPHD and HUD will require modification.

HUD shall transmit all pertinent family composition data to the CoPHD. The CoPHD shall utilize this information to begin the review of each family’s eligibility for admission to the TBRA Program. As part of the determination of eligibility, the CoPHD may require families to complete the following:

1. Submit a completed program application and any other required program form(s).

2. Submit any records pertinent to the determination of eligibility, i.e. , identification cards, B irth Certificates, Social Security cards, proof of citizenship, proof of income, proof of assets, certification forms, affidavits, etc.

3. Attend an interview with CoPHD staff; and

4. Attend mandatory briefing session conducted by CoPHD staff (rental vouchers issued to eligible families).

Due to the severe time constraints often associated with these conversion actions, the CoPHD may use the owner’s most recent family income re-examinations, if:

1. The owner’s certification for the family is no more than six months old; and

2. The CoPHD determines that the owner ’s certifications are acceptable after reviewing a small sample for accuracy.

The CoPHD is not required to use the owner’s certifications and may opt to conduct its own income determination and verification.

The CoPHD will make every effort to have the determination of eligibility completed and the rental vouchers issued to eligible families no later than 60 days before the termination date of the contract. Once these requirements are completed, the CoPHD must:

1. Ensure the units selected by the families are eligible (see Chapter 2 of this Plan).

2. Conduct H QS inspections for units selected by families , see Chapter 10 of this Plan, “Housing Quality Standards and Inspections”.

3. Ensure the rent is reasonable, see Chapter 11 of this Plan, “ Owner Rents, Rent Reasonableness, and Payment Standard”; and

4. Execute a HAP Contract with the owner.

HUD encourages housing agencies to begin tasks such as certifying families and approving units before receiving the ACC funding exhibit to avoid the potential adverse impact on the families. However, the CoPHD may not under DRAFT
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any circumstances execute a HAP Contract prior to receiving the notification letter and the effective date of the funding contained on the ACC funding exhibit.

Housing conversions represent a very unique opportunity for the CoPHD to be pro-active in safeguarding the welfare of families residing in affordable housing developments that are faced with rental increases or possible displacement.

Although some actions may not be taken by the CoPHD without seeking prior approval from HUD, the CoPHD shall continue to be committed to providing supportive services and guidance to families that are affected by these circumstances.

W. MOVES WITH CONTINUED RENTAL ASSISTANCE

The HCV will be cancelled if the family elect s to move into a project -based assisted unit. If the family decides to relocate after 12 months, the family may be eligible for other forms of rental assistance, if funding is available. Family may only move in accordance with Chapter 13 of this Plan, “Moves with Continued Assistance/Portability”.

Rental assistance under the PBVP will terminate for families that vacate the assisted unit during the initial term of the lease.

X. FAMILY RIGHT TO MOVE [24 CFR 983.260]

The family may terminate the assisted lease at any time after the first year of occupancy in accordance with Chapter 13 of this Plan, “Moves with Continued Assistance/Portability” . The family must give the owner advance written notice of intent to vacate (with a copy to the CoPHD) in accordance with the lease.

If the family has elected to terminate the lease in this manner, the CoPHD must offer the family the opportunity for continued TBRA, in the form of either assistance under the HCVP or other comparable TBRA.

Before providing notice to terminate , the family must contact the CoPHD, in writing, to request comparable T BRA if the family wishes to move with continued assistance. If a HCV or other comparable TBRA is not immediately available upon termination of the family's lease of a PBVP unit, the CoPHD must give the family priority to receive the next available opportunity for continued TBRA. The family will receive the next available opportunity based on the date and time when their written requested was received.

The family will not be able to use a HCV in a project based unit. If a HCV has been issued and the family decides to remain in a project based unit, the owner must agree to continue the family’s tenancy. At which time, the HCV will be cancelled. The family will be required to continue their search for a unit if the owner does not agree to continue the family’s tenancy. Therefore, the HCV will expire if the family does not locate a suitable unit by the expiration date and the family’s participation in the PBVP will end.

The family will not be eligible for a HCV or other comparable TBRA if the family fails to submit written request to the CoPHD prior to serving a 60 Day Notice to terminate to the owner and/or the family is not in good standing with the terms of the lease and Family Obligations. Families may not be eligible for any other form of rental assistance if the property owner has served notice to vacate. Moves with continued assistance are
allowed in accordance with Chapter 13 of this Plan, “Moves with Continued Assistance/Portability”.

If the family terminates the assisted lease before the end of one year , or if the family has violated program rules and regulations, the family relinquishes the opportunity for continued TBRA.

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The CoPHD will ensure the family is in compliance with the rules and regulations. The CoPHD will follow the policies and procedures outlined in Chapter 13 of this Plan, “Moves with Continued Assistance” for the HCVP.

If the family is in compliance with the program rules and regulations, the family may move utilizing portability. The CoPHD will follow the policies and procedures outlined in Chapter 13 of this Plan, “Moves with Continued Assistance” for the HCVP.

Y. PHA-OWNED UNITS

PHA-owned units for the purpose the PBV program, means that the PHA or its officers, employees, or agents hold a direct or indirect interest in the building in which the units are located.

If a PHA, its officers, employees or agents possess any interest in the building or land, the project or building is considered PHA-owned and must comply with all statutory, regulatory, and any other HUD requirements governing PHA owner units.

The Act requires that the unit of general local government or a HUD -approved independent entity perform certain functions for the PHA -owned units. Those functions include performance of housing quality standards (HQS) inspections and determining rent reasonableness for PHA-owned unit. Section 8(o)(13)(F) of the Act (42 U. S. Code 1437f(f) the PHA and the unit of general local government or HUD -approved independent entity agree to the term of any HAP Contract.

If the PHA itself is the unit of general local government or agency of such government, the independent entity must be a HUD -approved public or private entity. The entity and PHA must possess an autonomous relationship.

Therefore, the parties must not be connected legally, financially (except with regard to compensation for services performed for PHA-owned units), or in any other manner that could cause either party to be improperly influenced by the other. The PHA must submit to the HUD field office documentation that demonstrates or supports the independent nature of the parties’ relationship.

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CHAPTER 20

SUPPORTIVE HOUSING SERVICES
Introduction

The City of Pasadena periodically has the opportunity to apply for targeted rental assistance funding for special populations. These programs are administered by the City of Pasadena Housing Department (CoPHD) and have the same policies and procedures as the Housing Choice Voucher program except as otherwise noted. If there is a conflict between program regulations and the Administrative Plan, the program regulations have precedence.

Currently, the CoPHD administers the following target programs:
• Shelter Plus Care / Continuum of Care Program (S+C/CoC) • Housing Opportunities for People with Aids Program (HOPWA) program

Discontinued past programs include the:
• Family Self Sufficiency Program (FSS)
• HOME Program
• Emergency Rental Assistance Deposit Program (ERAD)

This chapter provides details on all of the above listed special programs..

A. S+C / CoC (24 CFR 582 & 24 CFR 578)

The Shelter Plus Care / Continuum of Care Rental Assistance Programs (S+C/ CoC) are Tenant -Based Rental Assistance (TBRA) programs designed to link rental assistance with supportive services for homeless individuals and families with disabilities. These programs were impacted by the 2009 Homeless Emergency Assistance and Rapid Transition to Housing Act (HEARTH Act) which consolidated three formerly separate McKinney -Vento homeless assistance programs, including the Supportive Housing Program, Shelter Plus Care Program, and Section 8 Moderate Rehabilitation SRO Program into a single grant program known as the Continuum of Care (CoC) Program. The S+C Program is in the process of transitioning to the CoC Program; as S+C projects renew they become CoC projects.

The S+C/CoC program is operated by the CoPHD in conjuction with one or more Sponsor Agencies. Sponsor Agencies are required to provide or coordinate supportive services to program participants. These services may be provided by the Sponsor Agency, funded by the Sponsor Agency but provided by a third party, or both funded and provided by a third party.

Supportive Service Provider/Sponsor Agency

The CoPHD will select and enter into a Memorandum of Understanding or Sub -recipient Agreement with a local supportive service provider (Sponsor Agency) that has shown evidence of expertise and commitment to serving S+C/CoC program participants. The solicitation of Sponsor Agencies shall be through a competitive selection process, which may include a formal Request For Proposal (RFP). The selected agencies, as mandated by HUD, will be required to provide a documented match for HUD funds provided for Supportive Services, Operations, and Acquisition, New DRAFT
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Construction or Rehabilitation. Effective for grants renewed as part of 2012 Continuum of Care application, the match requirement will also include Administration, but can be met by in-kind as well as cash matching.

Sponsor Agencies will be monitored annually to verify program compliance and fiscal management practices.

Additionally, the required match as well as program participant services will be monitored on a monthly and annual basis.

Coordinated Entry System

The Shelter Plus Care / Continuum of Care (S+C/CoC) program utilizes the region’s Coordinated Entry System (CES) to fill vacancies. This system utilizes a universal assessment to prioritize assistance based on vulnerability and severity of service needs, ensuring that those most in need of assistance receive it in a timely manner. Pasadena’s CES system is region-wide and operates in consultation with CoC and Emergency Solutions Grants (ESG) programs, adopting the provisions and requirements set out by HUD in Title 24 of the Code of Federal Regulations (24 CFR) governing the Continuum of Care Program (24 CFR 578), the Emergency Solutions Grants Program (24 CFR 576) and HUD Notice CPD-14-012 (dated July 28, 2014). For a complete set of CES written standards, please refer to the Pasadena CoC PSH Written Standards.

Eligibility Determinations

Applicants to the Shelter Plus Care / Continuum of Care (S+C/CoC) program are screened for initial eligibility by the CES. This eligibility screening encompasses verification of homelessness, disability, income and assets, and family status. The application packet is then transmitted to the CoPHD by a Sponsor Agency which has committed to providing ongoing services to the participant.

The CoPHD performs a criminal background check as detailed in Chapter 2 of this Plan, “Eligibility for Admission”. The application packet is reviewed and third-party verification is requested to ensure that the applicant meets the eligibility criterion for S+C/CoC.

An applicant who meets the eligibility criterion and passes the criminal background screening is issued a Certificate in a briefing session conducted by CoPHD staff. The Certificate holder, with the assistance of the Sponsor Agency, must then locate a rental unit within the City of Pasadena or in an area included as part of the CoC Mobility Policy.

S+C/CoC applicants may be denied admission if the applicant currently owes rent or other amounts to the CoPHD or to any other Public Housing Agency (PHA) in connection with Section 8 or public housing assistance and refuses to enter into a repayment agreement for amounts owed; or the applicant breached a previous repayment agreement and refuses CoPHD’s offer to enter into a new agreement to pay amounts owed to a PHA or amounts paid to an owner by a PHA.

Portability & Mobility

The Shelter Plus Care / Continuum of Care (S+C/CoC) program does not offer portability. However, program participants receiving tenant-based rental assistance (TBRA) through CoC program funds may choose housing outside of the City of Pasadena if the recipient or sub -recipient is able to meet all of the CoC Program Requirements in the geographic area where the program participant chooses housing. This applies only to CoC Rental Assistance, not to legacy S+C grants. The decision of a program participant to choose housing or move outside of the CoC’s geographic area should be one that is made in consultation between the program participant and the recipient or sub-recipient.

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The only reason a CoC recipient or sub -recipient may decline a program participant’s request to choose housing or move outside of the CoC’s geographic area is that the provider cannot reasonably meet all of the CoC Program Requirements. Thus, the City of Pasadena (recipient) has determined that the following cities / communities are eligible areas for TBRA mobility:

• Alhambra
• Altadena
• Arcadia
• Azusa
• Baldwin Park
• Burbank
• Bradbury
• Covina
• Duarte
• El Monte
• Glendale
• Irwindale
• La Cañada Flintridge
• La Crescenta
• La Puente
• Monrovia
• Monterey Park
• Montebello
• Montrose
• North El Monte
• Rosemead
• San Gabriel
• San Marino
• Sierra Madre
• South El Monte
• South Pasadena
• South San Gabriel
• Sunland
• Temple City
• Tujunga
• West Covina
• Los Angeles
Neighborhoods:
o El Sereno
o Highland Park
o Eagle Rock
o Glassell Park
o Cypress Park
o Lin
coln
Heights
o Boyle Heights
o East LA
o Downtown LA
o Westlake
o Pico-Union
o Elysian V
alley

HQS and Acceptable Housing Configurations (24 CFR 582.305)

As with the HCVP, Shelter Plus Care / Continuum of Care (S+C/CoC) units must pass HQS inspection before the unit can begin to be subsidized and the applicant become a participant in the program. The CoPHD must also inspect all units at least annually during the grant period to ensure that the units continue to meet the HQS. As of the 2020 Administrative Plan update, biennial inspections are not allowable under the CoC program.

S+C/CoC Program participants will be allowed to live in group home and shared housing environments. The S+C/CoC participant must have access to bathroom and kitchen facilities. These facilities may be shared. There must also be access to living room space.

Transfers to HCVP (Section 8)

In cases where a Shelter Plus Care / Continuum of Care (S+C/CoC) program participant’s name is reached on the HCVP waiting list, the S+C/CoC Program participant will be given the opportunity to select between the two programs.

If the S+C/CoC Program participant selects to remain on the S+C/CoC Program and declines the HCV, their application will be withdrawn from the HCVP waiting list.

S+C/CoC participants who have twelve months continual compliance with their lease agreement, have shown the ability to live independently with minimal need for supportive services, who are in compliance with the Obligations of the Family, and who have a recommendation from the Sponsor Agency may request a transfer to the HCVP. Transfers DRAFT
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to HCVP under these circumstances can only be initiated during the Annual Reexamination process. Transfers to HCVP will only be approved in cases where the previously noted conditions have been met and an HCV is available.

Supportive Services Match

For Shelter Plus Care grants, HUD requires that the aggregate amount of supportive services provided to participants at least equal in value the aggregate amount of rental assistance paid on behalf of those participants under the grant agreement for the term of the grant agree ment. The Sponsor Agency must document a match of supportive services equal to the total amount provided in rental assistance over the life of the grant. (Note: for grants renewed as part of the 2012 CoC Competition or later, this match requirement is reduced to 25%.)

The CoPHD requires that participating Sponsor Agencies submit periodic reports to the CoPHD regarding the dollar value of supportive services provided to program participants. The CoPHD may require other information deemed necessary to the operation of the program. Failure of the Sponsor Agency to submit reports or to provide the matching services required by program regulations will be a breach of the Sponsor’s contract provisions.

Surviving or Remaining Members of a Family (CoC Program Only)

If the qualifying (i.e., disabled) member of the household dies, or the member is incarcerated or institutionalized for more than 90 days, the other household members have right to remain in the unit until the expiration of the lease in effect at the time. If the remaining family chooses to exercise this right, HAP payments must continue until the current lease term expires. Upon the expiration of the current lease term, the family is no longer eligible to receive assistance and must be terminated from the program.

Family Absence from Unit (24 CFR 578.51 (i))

Rental assistance payments may only be paid to the owner during the lease term and while the family is residing in the unit. The family may, however, be absent from the unit for brief periods.

A participant in the Shelter Plus Care / Continuum of Care (S+C/CoC) program may be absent from a unit for any reason for up to 30 consecutive days. Periods of absence between 31 and 90 consecutive days are termed “extended absence.” The participant is required to report to the CoPHD any extended absence or anticipated extended absence of the S+C/CoC participant from the unit and the reason for the absence. If the participant is unable to report the absence themselves, the Sponsor Agency may do so on their behalf. If the Sponsor Agency reports an absence for a participant, it should be accompanied by a written statement from the participant or a written statement from the Sponsor Agency if that is not possible. Extended absence may be approved by the CoPHD for reasons of health, rehabilitation, convalescence, incarceration, or the personal needs of the family.

Any absence (including an anticipated absence) beyond 90 days, whether the absence is determined prior to or after its start, will result in termination of the rental assistance subsidy for the assisted unit. The CoPHD may inspect the unit to determine whether a participant is absent.

Family Obligations and Statement of Family Responsibility

The Shelter Plus Care / Continuum of Care (S+C/CoC) participant family shall be required to sign and be responsible for the Obligations of the Rental Assistance Program Participant Family. In addition, the participant and the Sponsor Agency’s representative are required to sign a “Statement of Family Responsibility,” informing the participant of the DRAFT
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availability of supportive services provided by the Sponsor Agency. The participant will not be required to take part in supportive services as a condition of continued participation in the S+C/CoC program, but will be required to maintain the terms of the lease agreement and the Family Obligations.

Terminating Participants
The CoPHD and/or Sponsor Agency may terminate assistance to a program participant who violates program requirements or conditions of occupancy. The Shelter Plus Care / Continuum of Care (S+C/CoC) program is providing PSH for hard -to-house populations of homeless persons. Thus, the CoPHD works in conjunction with Sponsor Agencies to exercise judgment and examine all extenuating circumstances in determining when violations are serious enough to warrant termination. Assistance should only be terminated the most severe cases. Termination does not bar the CoPHD from providing further assistance at a later date to the same individual or family, though all circumstances will be considered before providing assistance again. In cases where there is indication that the conditions that resulted in the prior termination have not been addressed, rental assistance will not be offered to the participant.

In terminating assistance to a program participant, the grantee must provide a formal process that recognizes the rights of the individual receiving assistance under the due process of law. This process, at a minimum, must consist of:

1. Providing the participant with a written copy of the program rules and the termination process before the participant begins to receive assistance;

2. Written notice to the program participant containing a clear statement of the reasons for termination

3. A review of the decision, in which the program participant is given the opportunity to present written or oral objections before a person other than the person (or a subordinate of that person) who made or approved the termination decision; and

4. Prompt written notice of the final decision to the program participant

Conflict Between HCVP and S+C Regulations

The CoPHD follows the regulations established by HUD for the S+C/CoC program and the policies incorporated into this Administrative Plan except as noted. Where there is a conflict between HCVP and CoC/S+C regulations, the applicable CoC/S+C regulations apply.

Certification

The certification process for the Shelter Plus Care / Continuum of Care (S+C/CoC) program is consistent with the HCVP except that initial eligibility information is secured by the CES. This information is forwarded to the CoPHD for review and eligibility determination. If an applicant is determined eligible, they will be given a program briefing by the CoPHD consistent with the HCVP, and including information specific to the requirements of the program in which they will be participating.

Annual Reexamination
The annual reexamination process for Shelter Plus Care / Continuum of Care (S+C/CoC) participants is also consistent with the HCVP, except that S+C/CoC participants are asked to disclose progress pertaining to their case management and if they are securing all the services they need to remain permanently housed.

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Rental Negotiation

The Shelter Plus Care/Continuum of Care program rent is contracted based on the rent reasonableness standards and tenant rental portions are limited to 30% of the participant’s adjusted monthly income.

Inspection

The inspection process for the Shelter Plus Care/Continuum of Care program is similar to that of HCVP. Inspections will be conducted on Group Home facilities and shared housing, as well as regular bedroom sizes. As with HCVP, in addition to meeting the required HQS, a Certificate of Inspection and Code Compliance will also be required.

Participant conversions from this or other certificate program to HCV or other voucher program may use an annual inspection dated within 120 days of the conversion date as the initial inspection.

Vacancy Loss/Damage Claim (24 CFR 582.105)

Vacancy loss and damage claim will be permitted under the Shelter Plus Care/Continuum of Care program due to issues surrounding the special nature of the target population. As determined by HUD, vacancy payments will be permitted for a maximum of 30 days from the end of the month in which the unit is vacated if the unit is vacated before the expiration of the lease agreement.

With regard to damage claims, up to one month’s contract rent will be used to pay for any damage to housing unit due to the action of an S+C/CoC Program participant.

If a property owner wishes to make a vacancy loss or damage claim, that claim must be made with 15 days of the program participant vacating the unit. Any such claim must be accompanied by supporting documentation, including copies of receipts for repairs made and verification of unit vacancy.

B. Housing Opportunities for Persons with AIDS Program (24 CFR 574.300)

The Housing Opportunities for Persons with AIDS (HOPWA) Program provides tenant-based rental assistance to low- income households consisting of individuals and families living with HIV/AIDS. The HOPWA tenant -based rental assistance program operates much the same as the HCVP but also include s case management and supportive services to HOPWA Program participants, provided by a referring agency.

The CoPHD administers the HOPWA program for the cities of Pasadena and Glendale The initial 12 months of rental assistance will be funded under the HOPWA Program. Upon the expiration of the 12 month period for each HOPWA Program participant, the CoPHD will “absorb” or provide continued rental assistance to the program participants under its regular HCVP, but only for households residing within CoPHD’s jurisdiction and as long as the household continues to meet the eligibility requirements for ongoing rental assistance.

Before the CoPHD agrees to fund the initial 12 months of rental assistance for eligible households residing in its sub- recipient’s jurisdiction, the Public Housing Agency (PHA) overseeing the administration of the HCVP in the applicable jurisdiction must enter into a Memorandum of Understanding (MOU) with the HOPWA formula grant recipient for the Eligible Metropolitan Statistical Area (EMSA), whereby the PHA agrees to provide continued rental assistance under its HCVP to the HOPWA program participants residing in their jurisdiction or their surviving member of the household.

The CoPHD has such an MOU in place with the City of Los Angeles Housing Department, which is the EMSA for HOPWA funds in this area.

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Eligibility Determinations

Applicants to the HOPWA Program are screened for initial eligibility by the referring agency. This initial eligibility screening encompasses verification of HIV/AIDS status, income and assets, and family status. The application packet is then transmitted to the CoPHD. The CoPHD performs a criminal background check, requests third party verification, and reviews the application packet to ensure that the applicant meets the eligibility criterion for the HOPWA Program, as detailed in Chapter 2 of this Plan, “Eligibility for Admission”.

An applicant who meets the eligibility criterion and passes the criminal background screening is issued a Certificate in a briefing session conducted by the CoPHD staff. The Certificate holder, with the help of the Sponsor Agency, must then locate a rental unit within the Cities of Pasadena or Glendale. As with the HCVP, the unit must pass HQS inspection before the unit can begin to be subsidized and the applicant become a participant in the HOPWA Program.

The CoPHD will work with the Glendale Housing Authority (GHA) to conduct the lease up and absorption process for HOPWA certificate holders who locate a unit in Glendale. GHA inspection staff will conduct the Housing Quality Standards inspection and forward that information to CoPHD staff. CoPHD staff will contact the GHA at annual review time to begin converting the rental assistance from HOPWA to HCV P. This conversion process will include ensuring that there is an HCV available. If GHA does not have an available HCV, the client household will be informed they will be issued an HCV from CoPHD’s allocation, and will be required to locate a unit within the jurisdiction of the CoPHD.

Certification

The certification process for HOPWA is consistent with the HCVP except that initial eligibility information may be secured by the Sponsor Agency. This information is forwarded to the CoPHD for review and eligibility determination. If an applicant is determined eligible, they will be given a program briefing by the CoPHD consistent with the HCVP, and including information specific to the requirements of the program in which they will be participating.

Annual Reexamination & Conversion to HCVP

The annual reexamination process for TBRA participants is also consistent with the HCVP. Additionally, at the time of the annual reexamination, HOPWA Program participants are converted to the HCVP. Under no circumstances may a contract be funded with HOPWA monies beyond the initial 12 month period. The CoPHD will use the low-income limit for HOPWA participants who are otherwise eligible for conversion to HCVP. For those participants living outside of the CoPHD jurisdiction, eligible HOPWA Program participants will have their case files ported to their respective jurisdiction for continued rental assistance.

Rental Negotiation (24 CFR 574.320)

The HOPWA program rent is contracted based on the Fair Market Rents published by HUD and tenant rental portions are limited to 30% of the participant’s adjusted monthly income. If the gross rent proposed exceeds HUD -issued Fair Market Rent, the CoPHD may suggest that the owner reduce the contract rent or include some or all utilities in the contract rent. If the owner accepts the offer of a revised rent, the CoPHD will continue by processing a Request for Tenancy Approval (RFTA). If the property owner is not willing to reduce or adjust the rent and the CoPHD is satisfied that the requested rent meets the test of rent reasonableness, the CoPHD may approve an exception rent up to 10% higher than the FMR, for no more than 20% of the contracted units within a program year. If the owner does not agree on the contract rent after the CoPHD has tried and failed to negotiate a revised rent, the CoPHD will inform the family and owner that the RFTA and proposed lease are disapproved.

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Inspection

The inspection process for the HOPWA program is similar to that of HCVP. As with HCVP, in addition to meeting the required HQS, a Certificate of Inspection and Code Compliance will also be required.

HOPWA participant conversions to HCV or other voucher program may use an annual inspection dated within 120 days of the conversion date as the initial inspection.

Termination

The CoPHD may terminate assistance to a program participant who violates program requirements or conditions of occupancy.

1. Providing the participant with a written copy of the program rules and the termination process before the participant begins to receive assistance;

2. Written notice to the program participant containing a clear statement of the reasons for termination

4. Prompt written notice of the final decision to the program participant C. Family Self Sufficiency (FSS) Program (24 CFR 984.101-984.401)

Currently, the CoPHD does not receive funding to operate an FSS program. If program funding is identified in the future, the FSS program will again open for applications from HCVP participants who are in good standing and do not owe money to the CoPHD.

D. HOME Tenant-Based Rental Assistance Program (24 CFR 92.209)

The HOME Tenant -Based Rental Assistance (TBRA) has been discontinued due to federal funding reductions. IF HOME TBRA is reinstated in a future program years, the program will be operating in accordance with HUD guidelines.

E. Emergency Rental Assistance Deposit Program (ERAD)

The Emergency Rental Assistance Deposit Program (ERAD) has been discontinued due to federal reductions. ERAD provided funds for security deposit to allow participants to move in to privately-owned rental units and was funded with HOME Program entitlement funds administered by the City of Pasadena. While the program has been discontinued, several past participants still have outstanding debts that are being repaid.

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CHAPTER 21

CONSOLIDATED ANNUAL CONTRIBUTION CONTRACT

INTRODUCTION

HUD annually allocates budget authority for tenant -based rental assistance to HUD field offices based on U.S.

Congressional authorization and appropriations. Section 213(d) of the HCDA of 1974 establishes the requirements for the allocation of funding to assisted public housing agencies. Budget authority subject to allocation under Section 213(d) is allocated in accordance with 24 CFR 791, Subpart D. The CoPHD receives and must comply under the aforementioned provisions for the funding of its Federal Rental Assistance Programs (RAP). This Chapter outlines the requirements, procedures, and process the CoPHD shall utilize to retain its RAP funding.

A. ANNUAL CONTRIBUTION CONTRACT [24 CFR 982.151]

The Annual Contribution Contract (ACC) is a written contract between HUD and the CoPHD. Under the ACC, HUD agrees to make payments to the CoPHD, over a specified term, for housing assistance payments to owners and for the CoPHD’s administrative fees. The ACC specifies the maximum payment over the ACC term. The CoPHD agrees to administer the program in accordance with HUD regulations and requirements.

HUD’s commitment to make payments for each funding increment in the CoPHD program constitutes a separate ACC. However, commitments for all the funding increments in the CoPHD program are listed in one consolidated contractual document called the Consolidated Annual Contributions Contract (Consolidated ACC). The s ingle Consolidated ACC covers funding for the CoPHD program.

B. BUDGET AUTHORITY AND CONTRACT AUTHORITY [24 CFR 982.151(b)]

Budget authority is the maximum amount that may be paid by HUD to the CoPHD over the ACC term of a funding increment. Contract authority is the maximum annual payment for the funding increment. Budget authority for a funding increment is equal to contract authority times the number of years in the increment term.

For each funding increment, the ACC specifies the term over which HUD will make payments for the CoPHD program, and the amount of available budget authority for the funding increment. For a given CoPHD fiscal year, the amount of HUD’s maximum annual payment for the CoPHD program equals the sum of the contract authority for all of the funding increments under the Consolidated ACC. However, this maximum amount does not include contract authority for an expired funding increment. If the term of a funding increment expires during the CoPHD’s fiscal year, this maximum amount only includes the pro -rata portion of contract authority for that portion of the CoPHD’s fiscal year prior to expiration. However, the amount to be paid must be approved by HUD and may be less than the maximum payment.

Additional budget authority is also distributed by a competitive process. HUD solicits applications from public housing agencies by publishing one or more notices of funding availability (NOFA) in the Federal Register. The NOFA explains how to apply for assis tance and specifies the criteria for awarding the assistance. The NOFA may identify any special program requirements for use of the funding. For competitive funding under a NOFA, the applications must be submitted by CoPHD in accordance with the requirements of the NOFA and/or other HUD instructions.

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C. BUDGET AND EXPENDITURES [24 CFR 982.157]

Each fiscal year the CoPHD must submit its proposed budget for R AP to HUD for approval at such time and in such form as required by HUD. HUD payments under an ACC or Consolidated ACC, and any other amounts received by the CoPHD in connection with the program, must be used in accordance with the CoPHD HUD-approved budget.

Such HUD payments and other receipts may only be used for:

1. Housing Assistance Payments; and

2. CoPHD Administrative Fees.

The CoPHD must maintain a system to ensure that the CoPHD will be able to make housing assistance payments for all participants within the amounts contracted under the Consolidated ACC.

D. HOUSING ASSISTANCE PAYMENTS [24 CFR 982.311, 982.454]

Housing assistance payments are paid to the owner in accordance with the terms of the HAP Contract for units under lease with an eligible family. Housing assistance payments may only be paid to the owner during the lease term and while the family is residing in the unit.

The CoPHD will determine the amount of the housing assistance payment for each family participating in the program and make timely housing assistance payments to the owner in accordance with the HAP Contract.

The CoPHD will administer and enforce the HAP Contract with the owner. If the owner is in violation of the HAP Contract, the CoPHD will take appropriate action in accordance with this Plan.

The CoPHD may terminate the HAP contract if the CoPHD determines that funding under the consolidated ACC is insufficient to support continued assistance for families in the program. Please refer to C hapter 14 of this P lan, “Contract Terminations.”

E. ADMINISTRATIVE FEES [24 CFR 982.152]

HUD may approve administrative fees to the CoPHD for any of the following purposes:

1. Ongoing administrative fee: The CoPHD’s ongoing administrative fee is paid for each unit month for which a dwelling unit is under HAP Contract on the first day of the month. The amount of the ongoing fee is established by HUD.

HUD may reduce or offset any administrative fee to the CoPHD, in the amount determined by HUD, if the CoPHD fails to perform CoPHD’s administrative responsibilities correctly or adequately under the program.

The CoPHD’s administrative fees may only be used to cover costs incurred to perform the CoPHD administrative responsibilities for the program in accordance with HUD regulations and requirements.

2. Preliminary fee: The preliminary fee is paid by HUD for each new unit added to the CoPHD program.

The preliminary fee is a one time fee for each new unit supported by a new funding increment. HUD establishes the maximum preliminary fee.

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The preliminary fee is used to cover expenses that the CoPHD documents it has incurred to help families who inquire about or apply for the program, and to lease up new units.

3. Cost to help families who experience difficulty finding or renting appropriate housing.

4. Cost to cover necessary additional expenses incurred by the CoPHD to provide reasonable accommodation for persons with disabilities.

5. Cost of audit by an independent public accountant; and

6. Other extraordinary costs determined necessary by HUD Headquarters.

F. ANNUAL CONTRIBUTION CONTRACT RESERVE ACCOUNT [24 CFR 982.154]

HUD establishes and maintains an unfunded reserve account called the ACC R eserve Account (formerly “project reserve”) for the CoPHD program from available budget authority under the Consolidated ACC. The amount in the ACC Reserve Account is determined by HUD.

The amount in the ACC Reserve A ccount is determined by HUD. HUD may approve payments for the CoPHD, in accordance with the public housing agencies HUD -approved budget, from available amount in the ACC R eserve Account.

G. ADMINISTRATIVE FEE RESERVE [24 CFR 982.155]

The CoPHD must maintain an administrative fee reserve (formerly “operating reserve”) for the program. There are separate administrative fee reserve accounts for the CoPHD RAP. The CoPHD must credit to the administrative fee reserve the total of the amount by which program administrative fees paid by HUD for the CoPHD fiscal year exceed the CoPHD program administrative expenses for the fiscal year, plus interest earned on the administrative fee reserve.

The CoPHD must use funds in the administrative fee reserve to pay program administrative expenses in excess of administrative fees paid by HUD for a CoPHD fiscal year. If funds in the administrative fee reserve are not needed to cover CoPHD administrative expenses, the CoPHD may use these funds for other housing purposes permitted by State and local law. However, HUD may prohibit use of the funds for certain purposes.

If the CoPHD has not adequately administered any RAP, HUD may prohibit use of funds in the administrative fee reserve, and may direct the CoPHD to use funds in the reserve to improve administration of the program or to reimburse ineligible expenses.

H. PROGRAM FUNDS DEPOSITARY [24 CFR 982.156]

Unless otherwise required or permitted by HUD, all program receipts must be promptly deposited with Bank of America, the financial institution selected as deposit ary by the CoPHD in accordance with HUD requirements. The CoPHD has entered into the appropriate agreement with Bank of America in the form required by HUD.

The CoPHD may only withdraw deposited program receipts for use in connection with the program in accordance with HUD requirements.

If required under a written freeze notice from HUD to the depositary:

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1. The deposit ary may not permit any withdrawal by the CoPHD of funds held under the deposit ary agreement unless expressly authorized by written notice from HUD to depositary; and

2. The depositary must permit withdrawals of such funds by HUD.

HUD must send the CoPHD a copy of the freeze notice from HUD to the depositary.

I. PROGRAM ACCOUNTS AND RECORDS [24 CFR 982.158]

The CoPHD must maintain complete and accurate accounts , and other records for the program in accordance with HUD requirements, in a manner that permits a speedy and effective audit. The records must be in the form required by HUD, including requirements governing computerized or electronic forms of record keeping.

The CoPHD must furnish to HUD accounts and other records, reports, documents and information, as required by HUD. The provisions for electronic transmission of required family data shall be in accordance with 24 CFR 908.

HUD and the Comptroller General of the United States shall have full and free access to all CoPHD offices and facilities, and to all accounts and other records of the CoPHD, including the right to examine or audit the records, and to make copies. The CoPHD must grant such access to computerized or other electronic records, and to any computers, equipment or facilities containing such records, and shall provide any information or assistance needed to access the records.

J. AUDIT REQUIREMENTS [24 CFR 982.159]

The CoPHD must engage and pay an independent certified public accountant to conduct audits in accordance with HUD requirements. The CoPHD is subject to the audit requirements in 24 CFR 44.

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CHAPTER 22

RECORDS MANAGEMENT

INTRODUCTION

The CoPHD must maintain complete and accurate accounts and records for the Rental Assistance Programs (RAP) in accordance with HUD requirements and in a manner that permits a speedy and effective audit. The records must be in the form required by HUD, including requirements governing computerized or electronic forms of record keeping. The CoPHD must comply with the uniform financial reporting standards in 24 CFR 5, S ubpart H. HUD and the Comptroller General of the United States shall have full access to all CoPHD offices and facilities, and to all accounts and other records of the CoPHD that are pertinent to administration of the programs, including the right to examine or audit the records and to make copies. The CoPHD shall grant such access to computerize or other electronic records, and to any computers, equipment or facilities containing such records, and shall provide any information or assistance needed to access the records. This Chapter explains the records that are required to be maintained and the systems that have been instituted to do so.

A. PROGRAM RECORDS [24 CFR 982.158(c)(e)(f)]

The CoPHD shall maintain program records in accordance with Federal, State and local laws , as well as HUD and CoPHD policies, regulations, and requirements. Family and applicant records will be retained for five years from the date of termination or disqualification.

During the term of each assisted lease, and for at least three years thereafter, the CoPHD must retain:

1. A copy of the executed lease.

2. The HAP Contract.

3. The application from the family.

The CoPHD must keep the following records for at least three years in the active case file:

1. Records that provide income, assets, expenses, program forms and disability data on program applicants and families.

2. An application from each ineligible applicant and notice that the applicant is not eligible.

3. HUD-required reports.

4. Unit inspection reports.

5. Lead-based paint records as required by 24 CFR 35 Subpart B.

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6. Accounts and other records supporting the CoPHD’s budget and financial statements for the RAP.

7. Records to document the basis for PHA determination that rent to owner is a r easonable rent (initially and during the term of a HAP Contract); and

8. Other records specified by HUD.

The CoPHD must maintain and update the following information that permits the CoPHD to select applicants from its w aiting list in accordance with the CoPHD admission policies. The waiting list shall contain the following information for each applicant listed:

1. Applicant’s name.

2. Family unit size.

3. Date and time of application.

4. Qualification for any local preference; and

5. Racial or ethnic designation of the head of household.

The CoPHD shall also retain the following information:

1. Copies of all public notices.

2. Briefing information packets.

3. Information on Federal, State, and local equal opportunity laws, including copies of housing discrimination complaint form.

4. CoPHD notifications, letters and correspondence with applicants, participant families and owners.

5. CoPHD required information including requested certifications, releases, consent forms or other documentation.

Please refer to Section D of this chapter for a list of documents that must be maintain in the file for the duration of the family’s participation.

B. EMPHASYS COMPUTER SOLUTIONS (Emphasys Elite) [24 CFR 908.104]

The CoPHD utilizes Emphasys Elite software. Emphasys Elite is an automated software package which allows the CoPHD to transmit Forms HUD 50058 and HUD 50058 Family Self Sufficiency (FSS) Addendum information to HUD’s data processing center via electronic transmission. Electronic transmission of data consists of the submission of all required data fields from F orms HUD -50058 and HUD -50058 FSS Addendum in accordance with HUD instructions.

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Emphasys Elite also serves as the CoPHD’s comprehensive database for the processing, retention, retrieval and transmission of HUD required information for administration of the RAP. Information is stored in Emphasys Elite by applicant, participant family and owner. More specifically, Emphasys Elite is used to maintain case files, family data, owner data, certifications and re- examinations, inspections, fiscal management, and the waiting list. Emphasys Elite is an integrated software package containing numerous menus and modules which allows for the cross -referencing of files and the generation of program reports by selected data fields. In addition, the software vendor, Emphasys Elite Computer Solutions, periodically updates the Emphasys Elite program to incorporate changes or revisions in legislation, regulations, handbooks, notices, or HUD electronic transmission data format requirements. The CoPHD will test all “Service Packs” and “Hot Patches” before integrating all upgrades to the live production.

C. CASE FILES

The RAP information shall also be maintained in individual applicant and participant family case files. Each case file is labeled using the name of the head of household of the applicant or participant family. The case files are stored in alphabetical order in the master file room (“master files”) located in the CoPHD office.

Please see Section D in this Chapter, “File Purging”.

All case files are denoted by a color-coded alpha label, which corresponds to the first letter of the last name of the head of household of the participant family. A different color has been used for each letter of the alphabet.

Each case file, with the exception of the waiting list applicant file, contains six sections wherein documents are secured and retained according to subject matter. Examples of the types of forms, documents, correspondence, etc., to be maintained in each case file are identified below and in the following order from bottom to top:

1. INSPECTIONS
• Proposed Lease Agreement
• Certificate of Inspection and Code Compliance

• Recorded Grant Deed
• Electronic Property Profile
• Current Property Tax Bill
• Statement of Property Ownership:
- Part A - Declaration of Property Ownership
- Part B - Housing Assistance Payments Information
- Part C - Notarized Agent Authorization
- Part D - Section 8 Landlord Certification
• Taxpayer Identification Number and Certification (W-9) • Property Management Agreement, if applicable
• Partnership Agreement & Resolution for Signatory, if applicable • Corporate Bylaws & Resolution for Signatory, if applicable • Executed Lease Agreement
• Tenancy Addendum - Form HUD-52641-A
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• Housing Assistance Payments Contract - Form HUD-52641 • Notice of Annual Re-examination/Rent Change

2. INSPECTIONS CORRESPONDENCE
• Request for Tenancy Approval (RFTA):
- RFTA
- Renting to Relatives Disclosure Notice
- Checklist
- Disclosure of Information on Lead-Based Paint
• Request for Missing Information, if applicable
• Rent Reasonableness Checklist and Certification:
- Rent Increase Request
• Inspection Letters:
- Unit Approval
- Annual
- Reschedule
- Special
- Deficiency
- Rent Adjustment
- Abatement
- Denial to Owner with Attachments
• Inspection Report – Form HUD-52580-A
• Notification of HAP Termination
• Housing Assistance Payments (HAP) Contract Letters:
- Termination of HAP Contract
- Extension of HAP Contract Termination
- Re-instatement of HAP Contract
- Rescission of HAP Contract Termination

3. ADMISSIONS/ISSUANCE
• Rental Assistance Program Application:
- Housing Choice Voucher Program
- HOPWA Program
- Continuum of Care Rental Assistance Program
• Agency Referral Letter:
- Continuum of Care Rental Assistance Program
- HOPWA Program
• Individual Applicant Information Form
• EIV Existing and Former Tenant Reports
• Waiting List Update of Family Circumstances Form
• Housing Choice Voucher/Certificate/Coupon
• Extension Letters:
- New
- Move
- Portability
• Things You Should Know - Form HUD-1140-OIG
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• Lead-Based Paint Notification
• Notice of Federal Privacy Act
• Obligation of the Family
• Family Portability Information - Form HUD-52665
• Current Extension Letters - Form HUD 52675
• What You Should Know About EIV
• Debts Owed to Public Housing Agencies and Terminations • Current Housing Choice Voucher/Certificate/Coupon

4. VITAL STATISTICS
• Driver License/Identification Card
- Individual copies will be maintained for each current family member • Social Security Card
- Individual copies will be maintained for each current family member • Birth Certificate/Passport:

Translations
• Immigration Status:
- Permanent Resident Card
- Certificate of Naturalization Form
- SAVE System Information
- Department of Housing Security Information
• Declaration of Section 214 Status
• Marriage Certificate/Divorce Documents
• Death Certificate
• Guardianship/Child Custody:
- Court Documents
- Foster Care Information

• Client Screening/Criminal History Background/Police Report • Current Repayment Agreement
• Re-payment Agreement Check List
- Calculations & Worksheet
- Copies of Money Orders
- Memos to Finance
• U.S. Military Discharge (DD-214)
• Certification of Disability Form
• Medical Letters
• Request for Reasonable Accommodation form (RRA)
• Form completed by the CoPHD Request for Reasonable Accommodation Review Committee form
• Request for Reasonable Accommodation Committee Decision Letter • Purge Check List

5. OCCUPANCY CORRESPONDENCE
• Waiting List Letters:

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- Outreach
- Preliminary Eligibility
- Ineligibility/Disqualification
- Interview Appointment
- Preference Denial
- Informal Review Decision
- Request for Additional Information Letter
• Briefing Letters:
- New Housing Choice Voucher/Certificate/Coupon
- Move
• Participant Correspondence:
- Re-examination
- Termination of Assistance
- Informal Review
- Informal Hearing
- Request for Additional Information Letter
• History Sheets
• Year Dividers
• Third-Party Verification Letters (Staff will remove verifications from this section once the third-party verifications have been received or placed copies in the Occupancy section when the verifications are not returned.)

6. OCCUPANCY
• Update of Family Circumstances/Personal Declaration for Rental Assistance Benefits • HUD Authorization for the Release of Information/Privacy Act

Notice - Form HUD-9886
• CoPHD Authorization for Release of Information
• Legal Documents
• Allowable Deductions:
• Medical (doctor visits, pharmacy, etc.)
- School/College Enrollment Forms
- Child Care
• Assets Related to Income:
- Stocks
- Financial Institution Statements
- Real Estate
• Tenant Declaration
• Affidavit
• Income Documentation:
- Employment
- SS/SSI
- TANF/General Relief/CAPI
- Self-Employment
- Pension
- Annuity
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- Child Support
- Unemployment
- Other Income
• Third-Party Verifications
• EIV Report (sealed envelope)
• Utility Schedule
• Payment Standard
• Worksheet
• Family Report (Form HUD-50058)
• Case File Review Checklist

D. FILE PURGING

HUD requires the CoPHD to conduct a re- examination of the eligibility for each family at least annually.

This includes an evaluation of the current unit condition and other factors related to the families continued participation. These requirements mean that the CoPHD will collect updated information and documentation on the family’s income, assets, allowances, composition and conduct a unit inspection. The information collected will be placed in the family’s case file each year or as changes in family circumstances occur. The purging system assists the CoPHD staff in maintaining the most critical, current information in the active case file, while still allowing access to documents which may be outdated or have a very low future retrieval value.

Unless otherwise required, each active case file will be purged according to the parameters outlined in this Chapter. Each case file shall be purged on or about the annual re- examination date of the family. In some cases there may be a need to purge a particular case file more/less frequently considering the following factors:

1. The actual size of the case file (exceedingly large, bulky, or small).

2. The filing capacity of the Master File Room.

3. Determinations by HUD, Housing Assistance Officer or designee.

For the purposes of this Chapter, the following file sections of the case file are exempt from purging:

1. Admissions/Issuance Section

2. Vital Statistics.

No documents are to be removed from these sections at any time, unless there are duplicate copies of Birth Certificates, Social Security Cards and Declaration of Section 214 Status.

All purged information shall be placed into a file folder that has been labeled with the first and last name of the family. A purge checklist will be placed in the purged file indicating the date purged, section purged and the initials of the staff member that purged the file. A copy of the purge checklist will be placed in the active file’s vital statistics section and the file folder will indicate the years included. Once prepared for storage DRAFT
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and boxed, these files shall be stored in the CoPHD’s secured storage Center for an indefinite period of time. A master list of all purged files, indexed by the last name of the family, box number and the status and location of the records, shall be maintained within the CoPHD office by the Administrative Section .

Similarly, when an active file has been terminated, the purged information shall be pulled from the secured storage combined with the terminated file, and placed into “terminated” status.

The following lists detail each file section and the documents to be retained and/or purged from the case files.

Inspections

This section contains information related to the ownership of the current property and HAP C ontract documents. I f the family has moved in the last three years, the current and last unit information will be retained in the file. If a change of ownership has occurred, documentation on the last two changes of ownership will be retained if it is more than three years. The following documents shall be retained in the active case file:

• Certificate of Inspection and Code Compliance for the Current Unit • Recorded Grant Deed for the Current Unit
• Electronic Profile / RealQuest
• Property Tax Bill for the Current Unit
• Statement of Property Ownership for the Current Owner, which includes:
- Part A - Declaration of Property Ownership
- Part B - Housing Assistance Payments Information
- Part C - Notarized Agent Authorization
- Part D - Section 8 Landlord Certification
• Taxpayer Identification Number and Certification (W-9) for Current Owner • Vendor List Questionnaire (Form AA-1)
• Property Management Agreement, if applicable
• Partnership Agreement & Resolution for Signatory, if applicable • Corporate Bylaws & Resolution for Signatory, if applicable • Proposed Lease
• Executed Lease Agreement
• Tenancy Addendum
• Housing Assistance Payments Contract
• Mutual Agreement to Terminate Lease Agreement
• Notice of Annual Re-examination/Rent Change

The above-referenced documents are to be maintained in the active case file regardless of the date of the document.

Inspection Correspondence

This section contains documents related to property inspections conducted and correspondence to and from the current owner(s) and families. If the family has moved within the last three years, then the current and last unit information will be retained in the file. T he following documents shall be retained in the active DRAFT
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case file:

• Request for Tenancy Approval
- RFTA
- Renting to Relatives Disclosure Notice
- Inspection Checklist
- Disclosure of Information on Lead-Based Paint and/or Lead-Based Paint - Hazards
• Request for Tenancy Approval Letter
- Property Ownership Information
- Rescission of Request for Tenancy Approval
• Rent Reasonableness Certification
• Inspection Letter
- Approval Letter
- Annual Inspection

- Passed
- Failed
- Special
- Deficiency
- Rent Adjustment
- Abatement
- Denial to Owner with Attachments
• Inspection Report for the Current Unit (up to a maximum of three years if available) • Notification of HAP Termination
• Termination of HAP/Hold Form
• HAP Contract Letters
- T ermination of HAP Contract
- Extension of HAP Contract Termination
- Rescission of HAP Contract Termination

The above-referenced documents are to be maintained in the active case file based on the type and date of each document. Any document(s) that does not meet the above criteria should be removed and placed into the purged file.

Admissions/Issuance - Do not purge information from this section of the case file.

Vital Statistics - Do not purge information from this section of the case file unless there are numerous copies of Birth Certificates, Social Security Cards and Declaration of Section 214 Status. Former family members will also be retained in this section under a separate tab.

Occupancy Correspondence

This section contains correspondence to and from the family , as well as requests for third -party income verifications. The purging of these documents is based on the re- examination year of the family . The following documents shall be retained in the active case file:

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• History Sheets (all sheets, regardless of the date)
• Participant Correspondence for the last three re-examination years:
- Re-examination Letter(s)
- Termination of Assistance Notice(s)
- Informal Review Request(s)
- Informal Hearing Request(s)
- Third-Party Verification Request(s) (Staff will remove verifications from this section once the third-party verifications have been received or place copies in the Occupancy section when the verifications are not returned.)
- Request for Additional Information Letter(s)

Occupancy

This section contains information related to the family ’s eligibility income, including completed third -party verifications and income and rent calculations. Manila dividers, labeled with the re- examination year, will be placed in this section to separate each year’s annual re-examination. The purging of these documents is based on the recertification year of the family . The following documents shall be retained for the current and last two annual re-examination cycles in the active case file:

• Family Report (Form HUD 50058)
• Routing Slip
• Case File Review Checklist
• Worksheets
• Legal Documents
• Update of Family Circumstances / Personal Declaration of Rental Assistance Benefits Forms • HUD Authorization for the Release of Information for the current and last two annual re- examinations cycles
• CoPHD Authorization for Release of Information for the current and last two annual re- examinations cycles
• Third-Party Verifications for the current and last two annual re-examinations cycles • EIV Reports in sealed and stamped envelopes
• EIV Certification form
• Allowable Deductions:
- Receipts
- Bank Statements
- Bills (medical, utility, etc.)
- School/College Enrollment Forms
• Self-Certified Statement
• CoPHD Authorization
• Affidavit
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• Utility Schedule
• Payment Standard

EIV data in the confidential sealed and stamped envelopes that needs to be purged will be placed in the locked EIV cabinets until it is disposed/destroyed by the EIV Security Officer.

Purged records shall be maintained in accordance with HUD and CoPHD requirements. For all active cases, any purged information shall be documented and stored on site in the Housing Department’s secured storage room.

Tenant and applicant case files will be retained for 5 years from the date of termination and disqualification.

All files will be transferred for storage to:

City of Pasadena, City Clerk, Record Management Section 100 N Garfield Ave., Room N030 Pasadena, CA 91109
(626) 744-4142

All retained files will be eligible for destruction after 5 years from the termination or disqualification date.

The City Clerk Record Management Section will submit a Request for Destruction form to the Housing Department for the Director’s approval. After all signatures have been obtained, files will be destroyed. The CoPHD along with City Clerk will maintain a record of all destroyed files.

E. FILE ORDER

The information that is located in each section will be placed in the following order by section:

1. INSPECTIONS
Current Property Tax Bill

1. Recorded Grant Deed

2. Electronic Property Profile / RealQuest

3. Certificate of Inspection and Code Compliance

4. Property Management Agreement, if applicable

5. Partnership Agreement & Resolution for Signatory, if applicable

6. Corporate Bylaws & Resolution for Signatory, if applicable

7. Operating Agreement for Limited Liability Co., if applicable

8. IRS Taxpayer Identification Number and Certification (W-9)

9. Vendor List Questionnaire (Form AA-1)

10. Statement of Property Ownership:
- Part A - Declaration of Property Ownership
- Part B - Housing Assistance Payments Information
- Part C - Notarized Agent Authorization
- Part D - Section 8 Landlord Certification

11. Proposed Lease Agreement

12. Tenancy Addendum - Form HUD-52641-A
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13. Executed Lease Agreement

14. Housing Assistance Payments Contract - Form HUD-52641

15. Amendment to Lease

16. Notice of Annual Re-examination/Rent Change

2. INSPECTIONS CORRESPONDENCE

New Contract

1. Request for Tenancy Approval Checklist

2. Renting to Relatives Disclosure Notice

3. Request for Missing Information Letter, if applicable

4. Rent Reasonableness Checklist and Certification

5. Disclosure of Information on Lead-Based Paint

6. Inspection Checklist

7. Request for Tenancy Approval - Form HUD-52517

8. Rescission of Request for Tenancy Approval Letter

9. Inspection Report - Form HUD-52580

10. Unit Approval Notice

Annual/Special

The following documents will be filed in chronological order:

1. Inspection Letters:
• Annual
• Special
• Deficiency
• Rent Adjustment
• Abatement
• Denial to Owner with Attachments
• Notification of HAP Termination

2. H AP Contract Letters:
• Termination of HAP Contract
• Extension of HAP Contract Termination
• Reinstatement of HAP Contract Termination

3. Inspection Report - Form HUD-52580-A

4. Request for Rent Increase

5. Rent Reasonableness Checklist and Certification

3. ADMISSIONS/ISSUANCE

1. Rental Assistance Program Application

2. Pre-Application Data Card

3. Continuum of Care Rental Assistance Program (CoC) - Agency Referral DRAFT
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Letter

4. HOPWA - Agency Referral Letter

5. Individual Applicant Information Form

6. Family Portability Information - Form HUD-52665

7. Lead-Based Paint Notification

8. Notice of Federal Privacy Act

9. Things You Should Know - Form HUD-1140-OIG

10. Obligation of the Family

11. Debts Owed to Public Housing Agencies and Terminations

12. What You Should Know About EIV

13. Extension Letters:
• New
• Move
• Portability

14. Housing Choice Voucher/Certificate/Coupon (current copy always remains on the top of this section)

4. VITAL STATISTICS

1. Repayment Agreement

2. U.S. Military Discharge (DD-214)

3. Notarized Documents/Child Custody (Court Documents)

4. Marriage Certificate/Divorce Documents

5. Foster Care (Court Documents)

6. INS Information

7. SAVE System Information

8. Death Certificate

9. Certificate of Naturalization

10. Permanent Resident Card

11. Birth Certificate/U.S. Passport

12. Social Security Card

13. Driver License/Identification Card

14. Declaration of Section 214 Status

15. Client Screening/Criminal History Background/Police Report

16. Certificate of Disability Form

17. Request for Reasonable Accommodation/supporting documentation

5. OCCUPANCY CORRESPONDENCE

All letters will be filed in chronological order, with the history sheets next and copies of third-party verification letters placed on top of the history sheets.

1. Applicants/Participant Correspondence:
• Re-examination
• Termination of Assistance
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• Informal Review
• Informal Hearing
• Request for Additional Information Letter

Briefing Letters:
• New Housing Choice Voucher/Certificate//Coupon
• Move
• Portability
Waiting List Letters:
• Outreach
• Preliminary Eligibility
• Ineligibility
• Disqualification
• Interview Appointment
• Preference Denial
• Informal Review Decision

2. History Sheets

3. Third-Party Verification Letters (S taff will remove verifications from this section once the third- party verifications have been received or place copies in the Occupancy section when the verifications are not returned.)

6. OCCUPANCY

1. Update of Circumstances / Personal Declaration for Rental Assistance Benefits Forms.

2. HUD Authorization for the Release of Information/Privacy Act Notice – Form HUD-9886.

3. CoPHD Authorization for Release of Information

4. Legal Documents

5. Allowable Deductions:
• Medical (doctor visits, pharmacy, etc.)
• School/College Enrollment Forms
• Child Care

6. Assets Related to Income:
• Stocks
• Financial Institution Statements
• Real Estate

7. Tenant Declaration/Affidavit

8. Income Documentation:
• Employment
• SS/SSI
• CalWorks/General Relief/CAPI
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• Self-Employment
• Pension
• Annuity

• Child Support
• Unemployment
• Other income

9. Third-Party Verifications / EIV

10. Utility Schedule

11. Payment Standard

12. Worksheet

13. Family Report (Form HUD-50058)

14. Case File Review Checklist

15. Routing Slip

16. Divider (Year)

A divider will be placed in the Inspection section to separate information when there is a change of ownership. A divider will be placed in the Occupancy section to separate each re- examination that has been processed.

ELECTRONIC FILES

The CoPHD shall maintain electronic records in accordance with Federal, State and local laws, as well as HUD and CoPHD policies, regulations, and requirements. Family and applicant records will be retained for five years from the date of termination or disqualification.

The following types of records will be printed and stored in applicant and participant files:
• Emails
• Pictures

Informal Hearing recordings stored on cassette will be destroyed in accordance with the City of Pasadena Record Retention procedures.

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CHAPTER 23

PROGRAM INTEGRITY ADDENDUM

INTRODUCTION

The U.S. Department of Housing & Urban Development (HUD) and CoPHD are committed to prevent fraud and to assure that the proper level of benefits is paid to all eligible families, and that housing resources reach only income - eligible families so that program integrity can be maintained.

The CoPHD will take all steps necessary to prevent fraud, waste, and mismanagement so that program resources are utilized judiciously.

This Chapter outlines the CoPHD's policies for the prevention, detection and investigation of program abuse and fraud.

A. CRITERIA FOR INVESTIGATION OF SUSPECTED ABUSE AND FRAUD

The CoPHD's expectation is that families will comply with HUD requirements, provisions of the HCVP, and other program rules. The CoPHD staff will make every effort to orient and educate all families in order to avoid unintentional program violations. However, the CoPHD has a responsibility to HUD, to the community, and to eligible families in need of housing assistance, to monitor families and owners for compliance, and when indicators of possible abuse come to the CoPHD's attention, to investigate such claims. Under no circumstances will the CoPHD undertake an inquiry or an audit of a family arbitrarily.

The CoPHD may initiate an investigation of a family under the following circumstances:

1. Referrals, Complaints, or Tips. The CoPHD will follow up on referrals from other agencies, companies or persons which are received by mail, telephone, e- mail, or in person, which allege that a family is in non - compliance with or otherwise violating the family obligations or any other program rules. Such follow -up will be made providing that the referral contains at least one item of information that is independently verifiable. A copy of the allegation will be retained in the family's file.

2. Internal File Review. A review of the file will be conducted if CoPHD staff discovers information or facts which conflict with previous reported information by the family.

3. Verification of Documentation. A review will be made if the CoPHD receives independent verification or documentation which conflicts with representations in the family's file such as public record information,

Credit Bureau reports, EIV reports, or information from other agencies.

4. Unauthorized Family Members. The CoPHD will conduct a program compliance inspection of the assisted unit when reports are received that unauthorized persons are residing in the assisted unit.

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B. STEPS THE CoPHD WILL TAKE TO PREVENT PROGRAM ABUSE AND FRAUD

The CoPHD will utilize various methods and practices to prevent program abuse, non -compliance, and willful violations of program rules by applicants and participating families. This policy objective is to establish confidence and trust in the CoPHD by emphasizing education as the primary means t o obtain compliance by families. The following are some of the methods and practices that will be used by the CoPHD:

1. Things You Should Know . This program integrity bulletin (created by HUD's Inspector General) will be furnished and explained to all families to promote understanding of program rules, and to clarify the CoPHD's expectations for cooperation and compliance. This form will be provided to applicants and all adult household members and when household members turn 18.

2. Family Obligations. This program form informs the participant family of the responsibilities they must abide by to continue receiving rental assistance. The head of household and adult family members will be required to review, sign and date this form at admission, intervals and as part of the family’s annual re-examination process.

3. Program Briefing Session. Mandatory Program Briefing Sessions will be conducted by the CoPHD for all prospective program participants, either prior to or upon issuance of a HCV.

4. Resident Counseling. The CoPHD will provide family counseling in order to clarify any confusion pertaining to program rules and requirements.

5. Review and Explanation of Forms. The CoPHD will explain all required forms and review the contents of all re- examination documents.

6. Use of Instructive Signs and Warnings. Instructive signs will be conspicuously posted in common areas and interview areas to reinforce compliance with program rules and to warn about penalties for fraud and abuse.

7. Personal Declaration for Rental Assistance Benefits Form. The head of household will be required to complete, sign and date this form, and obtain the signature of all adult family members. Additionally, if anyone outside of the family’s household helped the head of household to complete the form, they will be required to disclose their name, relationship to the family, telephone number and sign the Certification under Section VIII of this form. This form must be completed during the family’s annual re -examination process and for moves with continued assistance. This form may also be required to process interims.

8. What You Should Know About EIV and Debts Owed to Public Housing Agencies & Terminations program forms. The head of household and adult family members will be required to complete, sign, and date these forms acknowledging their understanding, this includes new additions to the household and household members who have recently turned 18.

9. CoPHD Newsletter. The newsletter informs program participants and property owners about changes in the rules and regulations of the Rental Assistance Programs and CoPHD’s Administrative Plan . Additionally, it reiterates the importance of complying with the HCVP and adopted CoPHD’s Family Obligations in order to remain eligible for rental assistance.

10. Other: Information, forms and certifications may be utilized by the CoPHD as needed.

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C. STEPS THE CoPHD WILL TAKE TO DETECT PROGRAM ABUSE AND FRAUD

The CoPHD will maintain a high level of awareness to indicators of possible abuse and fraud by families.

1. Quality Control File Reviews. Prior to initial admission and at the completion of all subsequent re - examinations, each family’s file may be reviewed. Such reviews shall include, but are not limited to:

a. Assurance that verification of all income and deductions is present. b. Changes in reported Social Security numbers or dates of birth. c. Authenticity of file documents.
d. Ratio between reported income and expenditures.
e. Changes in reported Social Security numbers or dates of birth. f. Authenticity of file documents.
g. Changes in reported Social Security numbers or dates of birth. h. Authenticity of file documents.
i. Ratio between reported income and expenditures.
j. Review of signatures for consistency with previously signed file documents. k. All forms are correctly and completely filled out, dated and signed. l. Review and print EIV report for all annual re -examinations and cases where discrepancy in tenant reported information and EIV report exists.

2. Observation. The CoPHD will maintain a high awareness of circumstances which may indicate program abuse or fraud, such as unauthorized persons residing in the household and unreported income. The family’s case file will be documented by the staff member assigned to the case and also by the inspector who conducted the inspection of the assisted unit.

3. Public Record Information. The CoPHD may use this source to obtain information via internet searches for addresses, phone numbers and property records listings and to access the Los Angeles County Sheriffs Department, California Department of Rehabilitations and Corrections and the Federal Bureau of Prisons for arrest and inmate information.

4. National Crime Information Center (NCIC). The CoPHD may utilize the information contained in the NCIC records database, which is maintained by the Federal Bureau of Investigations, to verify whether or not members of the family have a criminal record.

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5. State Wage Data Record Keepers. Inquiries to State wage and employment record keeping agencies as authorized under Public Law 100-628, the Stewart B. McKinley Homeless Assistance Amendments Act of 1988, may be made annually in order to detect unreported wages or unemployment compensation benefits.

6. Enterprise Income Verification System (EIV). The CoPHD will pull reports from the EIV system to verify the accuracy of the income source(s) information reported by families for additional information regarding the EIV system, please refer to Chapter 24, “ Enterprise Income Verification Security Policy and Procedures” , of this Plan.

7. Credit Bureau Inquiries. Credit Bureau inquiries may be made (with proper authorization by the family) in the following circumstances:

a. At the time of final eligibility determination.

b. When an allegation is received by the CoPHD wherein unreported income sources are disclosed.

c. When a family's expenditures exceed his/her reported income and no plausible explanation is given.

8. Third Party Verifications. Mail third party verifications to various agencies for families with adult household members claiming zero income or for unauthorized household members to verify no income being received from contacted sources or to obtain unreported income information.

D. THE CoPHD'S HANDLING OF ALLEGATIONS OF POSSIBLE ABUSE AND FRAUD

The CoPHD will encourage all participating families to report suspected abuse to their assigned Housing Assistant.

All such referrals, as well as referrals from community members and other agencies, will be thoroughly documented and placed in the family's file. All allegations, complaints and tips will be carefully evaluated in order to determine if they warrant follow-up. The CoPHD will not follow up on allegations which are vague or otherwise non -specific. The CoPHD will only review allegations which contain one or more independently verifiable facts.

1. File Review. An internal file review will be conducted to determine:

If the subject of the allegation is a client of the CoPHD and, if so, to determine whether or not the information reported has been previously disclosed by the family.

It will then be determined if the CoPHD is the most appropriate authority to do a follow -up. Any file documentation of past behavior, as well as corroborating complaints, will be evaluated.

2. Conclusion of Preliminary Review. If at the conclusion of the preliminary file review, there are facts contained in the allegation which conflict with file data and the facts are independently verifiable, the Housing Assistant assigned to the family’s case will initiate an investigation to determine if the allegation is true or false.

E. HOW THE CoPHD WILL INVESTIGATE ALLEGATIONS OF ABUSE AND FRAUD

If the CoPHD determines that an allegation or referral warrants follow -up, the staff person who is responsible for the file will conduct the investigation. The steps taken will depend upon the nature of the allegation and may include, but are not limited to, the items listed below.

In all cases, the CoPHD will secure written authorization from the family for the release of information.

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1. Credit Bureau Inquiries. In cases involving previously unreported income sources, a Credit Bureau inquiry may be made to determine if there is financial activity that conflicts with the reported income of the family.

2. Verification of Credit. In cases where the financial activity conflicts with file data, a Verification of Credit form may be mailed to the creditor in order to determine the unreported income source.

3. Employers and Ex-Employers. Employers or ex-employers may be contacted to verify wages which may have been previously undisclosed or misreported.

4. Neighbors/Witnesses. Owner/owner’s agent, neighbors and/or other witnesses who are believed to have direct or indirect knowledge of facts pertaining to the CoPHD's review may be interviewed.

5. Other Agencies. Investigators, caseworkers or representatives of other benefit agencies may be contacted.

6. Public Records. If relevant, the CoPHD will review public records kept in any jurisdictional courthouse.

Examples of public records which may be checked are : real estate, marriage, divorce, uniform commercial code financing statements, voter registration, judgments, court or police records, State wage records, utility records and postal records.

7. Interviews with Head of Household or Family Members. The CoPHD will discuss the allegation (or details thereof) with the head of household or family member by scheduling an appointment at the appropriate CoPHD office. A high standard of courtesy and professionalism will be maintained by the CoPHD staff person who conducts such interviews. Under no circumstances will inflammatory language, accusations, or any unprofessional conduct or language be tolerated by the CoPHD. If possible, an additional staff person will attend such interviews.

8. Inspection of the assisted unit. A special inspection of the assisted unit may be conducted in cases where allegations are reported that the family is in non- compliance with or otherwise violating the family obligations or any other program rules. In cases where the CoPHD is investigating fraud, families will not be given advanced notification of the special inspection. However, the CoPHD must obtain the family’s permission to enter the unit by signing a special inspection consent form allowing the CoPHD to enter the unit and to take photographs.

9. Drug related and criminal activity. In cases when drug related and/or criminal activity has been reported, the CoPHD may refer the matter to the Pasadena Police Department and other relevant City Departments.

Evidence may be obtained from police and/or court records pertaining to the alleged activity.

10. Internet and Social Networking sites. The CoPHD may use these sources to obtain information via internet searches for addresses, phone numbers and property records listings as well as to identify familial relationships pertinent to an investigation.

11. Other. Information, inquiries and data gathering as may be required by the CoPHD.

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F. PLACEMENT OF DOCUMENTS, EVIDENCE AND STATEMENTS OBTAINED BY THE CoPHD

Documents and other evidence obtained by the CoPHD during the course of an investigation will be kept in the family's file. Such cases under investigation may not be discussed among CoPHD staff, unless they are involved in the process or have information which may assist in the investigation.

G. CONCLUSION OF THE CoPHD'S INVESTIGATIVE REVIEW

At the conclusion of the investigative review, the reviewer will report the findings to the Housing Assistance Officer or designee. It will then be determined whether a violation has occurred, a violation has not occurred, or if the facts are inconclusive.

H. EVALUATION OF THE FINDINGS

If it is determined that a program violation has occurred, the CoPHD will review the facts to determine:

1. The type of violation (procedural, non-compliance, fraud).

2. Whether the violation was intentional or unintentional.

3. What amount of money (if any) is owed by the family.

4. If the family is eligible for continued assistance.

I. ACTION PROCEDURES FOR VIOLATIONS WHICH HAVE BEEN DOCUMENTED

Once a program violation has been documented, the CoPHD will propose the most appropriate remedy based upon the type and severity of the violation.

1. Procedural Non- compliance. This category applies when the family "fails to" observe a procedure or requirement of the CoPHD, but does not misrepresent a material fact, and there is no retroactive assistance payments owed by the family.

Examples of Non-Compliance Violations Are:

• Failure to appear at a pre-scheduled appointment.

• Failure to submit requested information in time period specified by the CoPHD.

(a) Warning Notice to the Family. In such cases a notice will be sent to the family which contains the following:

1. A description of the non-compliance and the procedure, policy or obligation which was violated.

2. The date by which the violation must be corrected or the procedure complied with.

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3. The action which will be taken by the CoPHD if the procedure or obligation is not complied with by the date specified by the CoPHD.

4. The consequences of repeated violations.

2. Procedural Non-Compliance - Overpaid Assistance. When the family owes money to the CoPHD for failure to report changes in income or assets, the CoPHD will issue a Notification of Overpayment of Assistance. This notice will contain the following:

• A description of the violations and the dates.

• Amounts owed to the CoPHD.

• Appointment date and time to discuss the overpayment calculations with the head of household and other adult(s) responsible for the overpaid rental assistance.

• The right for the family to disagree with the overpaid rental assistance amount and for the family to submit, within 30 days of the date of the scheduled appointment, information supporting their statement.

• An option of entering into a repayment agreement if assistance is not being proposed for termination. Also, informing the family of the terms of the agreement.

(a) Participant Fails to Comply with CoPHD's Notice . If the family fails to comply with the CoPHD's notice, and a family obligation has been violated, the CoPHD will initiate a proposed termination of assistance.

(b) Participant Complies with CoPHD's Notice. When a family complies with the CoPHD's notice, the staff person responsible will meet with him/her to discuss and explain the family obligation or program rule which was violated.

3. Intentional Misrepresentations. When a family falsifies, misstates, omits or otherwise misrepresents material facts the CoPHD will determine whether or not:

• An overpayment of rental assistance has occurred.

• The family had knowledge that his/her actions were wrong; and

• The family willfully violated th e family obligations or the law and/or any program rules and regulations.

Knowledge that the Action or Inaction Was Wrong. This will be evaluated by determining if the family was made aware of program requirements and prohibitions. The family's signature on various CoPHD certification forms (i.e., briefing certification, Obligations of the Family and Things y ou Should Know) are adequate to establish knowledge of wrong-doing.

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The Participant Willfully Violated the Law . Any of the following circumstances will be considered adequate to demonstrate willful intent:

(a) An admission by the family of the misrepresentation.

(b) That the act was done repeatedly.

(d) If there were admissions to others of the illegal action or omission.

(e) That the family omitted material facts which were known to him/her (i.e., employment of self or other household members).

(f) That the family falsified, forged or altered documents.

(g) That the family uttered and certified to statements at any re-examination which were later independently verified to be false.

4. Dispositions of Cases Involving Misrepresentations . In all cases of misrepresentations involving efforts to recover monies owed, the CoPHD may pursue, depending upon its evaluation of the criteria stated above, one or more of the following actions:

(a) Criminal Prosecution: If the CoPHD has established criminal intent and the case meets the criteria for prosecution, the CoPHD will:

• Refer the case to the local State or District Attorney, notify HUD's Regional Office of Inspector General (ROIG), and terminate rental assistance.

(b) Administrative Remedies:

• Terminate assistance and demand payment of restitution in full.

• Terminate assistance and execute an administrative repayment agreement in accordance with the CoPHD's repayment policy.

• Terminate assistance and pursue restitution through civil litigation.

• Continue assistance at the correct level upon repayment or restitution in full within 30 days.

• Permit continued assistance at the correct level and execute an administrative repayment agreement in accordance with the CoPHD's repayment policy.

5. Case Conference for Serious Violations and Misrepresentations. When the CoPHD has established that material misrepresentations and serious violations have occurred, a case conference will be scheduled with the family and the CoPHD staff person who is most knowledgeable about the circumstances of the case.

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This conference will take place prior to any proposed action by the CoPHD. The purpose of such conference is to review the information and evidence obtained by the CoPHD with the family, and to provide the family an opportunity to explain any document findings which conflict with representations in the family’s file. Any documents or mitigating circumstances presented by the family will be taken into consideration by the CoPHD.

The family will be given 15 days to furnish any mitigating evidence.

Prior to the final determination of the proposed action, the CoPHD will consider:

• The duration of the violation and number of false statements.

• The family's willingness to cooperate and accept responsibility for his/her actions.

• The amount of money involved.

• The family's past program compliance history.

• Whether or not criminal intent has been established.

6. Notification to Participant of Proposed Action. The CoPHD will notify the family by certified mail and regular U.S. mail of the proposed action by mailing notifications to the family’s current or last known address , in a reasonable time after the case conference.

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CHAPTER 24

ENTERPRISE INCOME VERIFICATION (EIV)

SECURITY POLICY AND PROCEDURES

INTRODUCTION

The EIV system is intended to provide a single source of income-related data to PHAs for use in verifying the income reported by participants in the various assisted housing programs. The EIV system is administered and maintained by the Office of Public and Indian Housing (PIH) . Utilization of the EIV system became mandatory effective January 31, 2010.

The purpose of EIV is to identify and prevent fraud within HUD rental assistance programs, so that limited taxpayer’s dollars can assist as many eligible families as possible. EIV will help to improve the integrity of HUD rental assistance programs. This Chapter is to establish the CoPHD’s policies and procedures to assure that the practices, controls and safeguards used by CoPHD are in compliance with the Federal laws regarding the protection of this information.

A. ENTERPRISE INCOME VERIFICATION SYSTEM

The CoPHD is required to use the EIV system in its entirety as a third party source to verify tenant employment and income information during mandatory reexaminations of family composition and income; and reduce administrative and subsidy payment errors in accordance with 24 CFR §5.236 and § 5.233 and administrative guidance issued by HUD. The CoPHD will monitor all the reports in EIV monthly. The CoPHD will continue to update the ir EIV policies and procedures in accordance with current Notice PIH and reference material issued by HUD.

The participants’ consent is required in order for HUD or the PHA to obtain their information. By law, they are required to sign one or more consent forms. When they sign the form HUD-9886 (Federal Privacy Act Notice and Authorization for Release of Information) or a PHA consent form (which meets HUD standards), they are giving HUD and the PHA their consent to obtain their information for the purpose of determining eligibility and amount of rental assistance. The information collected will be used only to determine eligibility for the program, unless they consent in writing to authorize additional uses of the information by the PHA. A dult household members that refuse to sign a consent form; their request for initial or continued rental assistance may be denied and may also be terminated from the HUD rental assistance program.

As participants of a HUD rental assistance program, each adult household member must disclose complete and accurate information to the PHA, including full name, SSN, and DOB; income information; and certify that the reported household composition (household members), income, and expense information is true to the best of their knowledge.

B. BENEFITS OF THE SYSTEM and TYPES OF UP FRONT VERIFICATION

1. Increases the efficiency and accuracy of income and rent determinations.

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2. Reduces incidents of underreported and unreported household income.

3. Removes the barriers to verifying tenant-reported income.

4. Addresses material weaknesses in a PHA's reexamination process and program operations.

5. Assures that more eligible families are able to participate in the program.

6. Reduces improper payments and ensures the right people receive the right amount of assistance at the right time.

7. Provides new hire, wage, unemployment compensation, and Social Security benefit information through a data matching process for households covered by a
HUD-Form 50058 and individuals who have disclosed a valid Social Security Number (SSN).

8. Allows PHAs to view monthly new hire information, quarterly wage, employer information, quarterly unemployment benefit payments, monthly Social Security (SS) and Supplemental Security Income (SSI) benefits, and Medicare deductions and/or buy-ins for tenants within the PHA's jurisdiction.

9. Provides income discrepancy reports to identify families who may have substantially underreported household income.

10. Identifies individuals who are required to disclose a valid SSN to the PHA.

11. Identifies individuals who may have disclosed an invalid SSN to the PHA.

12. Identifies individuals who may be receiving duplicate rental assistance.

13. Identifies individuals who voluntary or involuntarily ended participation (EOP) in a PIH rental assistance program with an adverse status and/or outstanding debt owed to a PHA as of the EOP date.

EIV information is used by CoPHD for the following purposes to:

1. Confirm participant’s name, date of birth (DOB), and Social Security Number (SSN) with SSA.

2. Verify reported income sources and amounts.

3. Confirm participation in only one HUD rental assistance program.

4. Confirm any outstanding debt to any PHA.

5. Confirm any negative status in the past under the Public Housing or Section 8 program.

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assistance. Follow up with adult household members, or listed emergency contact regarding deceased household members.

The EIV system compares the participant income data obtained from various sources including:

• Participant-supplied income data captured on Form HUD-50058 and maintained in the PIC databases;

• Social Security Administration (SSA) and the U.S. Department of Health and Human Services (HHS), National Directory of New Hires (NDNH) for all program participants with valid personal identifying information (name, date of birth (DOB), State Workforce Agency (SWA) and social security number (SSN) reported on the form HUD-50058.

• User profile information from the PIC database.

C. WHAT EIV PARTICIPANT DATA IS USED FOR

EIV data is the first level in the hierarchy of income verification. The EIV data must be used in the following way:

• To verify a participant’s eligibility for participation in a HUD rental assistance program and to determine the level of assistance the participant is entitled to receive.

The CoPHD must not adversely take action against a participant until the PHA has independently verified the EIV , and the participant has been granted an opportunity to contest any adverse findings through the established grievance hearing or other legal procedures, see Chapter 7 of this Plan “Verification Procedures”.

D. EIV DEBTS OWED/TERMINATION REPORT

CoPHD is required to use the EIV system in accordance with HUD regulations at 24CFR 5.233. The report became available to PHAs on September 25, 2009. The report contains a National repository of families that:

• Owed a debt to any PHA nationwide; and/or
• Left a PIH program under negative circumstances
• PHAs are required to:

o Use Form HUD 52675 – Debts Owed to Public Housing Agencies and Terminations (approved by OMB under Control Number 2577-0266) for collecting the information.

o Provide the notice to all applicants and program participants and require all applicants and program participants to acknowledge receipt of the notice by signing page 2. Applicants and tenants age 18+ are required to sign the form – one time only.

o Identify or designate which staff will be authorized to enter, update, and delete debt owed and termination information. PHA Executive Director or designee will authorize the staff.

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o Enter Debt and Termination information into EIV not later than 60 days from the End of Participation (EOP) date.

E. REQUIREMENTS FOR USING EIV DATA

Tenant Selection and New Admissions

The form HUD-9887, Notice and Consent for the Release of Information , signed by the applicant and each applicant family member 18 years of age and older does not need to be on file in order to use the Existing Tenant Search in EIV at the time of application processing and tenant screening. CoPHD will verify all new family members to ensure they are not included in existing households currently on the program.

As a applic ant of a HUD rental assistance program, each adult household member must disclose complete and accurate information to the PHA, including full name, SSN, and DOB; income information; and certify that reported household composition (household members), income, and expense information is true to the best of their knowledge.

For all new admissions, the CoPHD must:

Review the Income Report within 90 days after transmission of the move-in certification to Tenant Rental Assistance Certification System (TRACS) to confirm/validate the income reported by the household.

Resolve any income discrepancies with the household within 30 days of the Income Report date.

Print and retain the Income Report in the tenant file along with any documentation received to resolve income discrepancies.

Unreported or Underreported Income

If the CoPHD determines the family unreported or underreported his/her income, the CoPHD must go back to the time the unreported or underreporting of income started, no limitation that the family was receiving assistance described on forms HUD-9887 and HUD-9887-A, and calculate the difference between the amount of rent the family should have paid and the amount of rent the family was charged. The CoPHD must notify the family of any amount due and their obligation to reimburse the CoPHD. A record of this calculation must be provided to the family and also retained in the family ’s file. The CoPHD will propose termination of assistance for families that had unreported or underreported income from admission and all monies paid on the family’s behalf will be considered an overpayment of rental assistance. If the amount of the overpayment is $10,000.00 or more, the case will be reported to OIG.

F. FEDERAL PRIVACY ACT

The data provided via the EIV system will be protected to ensure that it is only used for official purposes and not disclosed in any way that would violate the privacy of the individuals represented in the system data. Privacy of data and data security for computer systems are covered by a variety of Federal laws and regulations. The Federal Privacy Act of 1974 as amended, 5 U.S.C. 552 (a) , is one such regulation. The full text of the Federal Privacy Act can be accessed at http://www.opm.gov/feddata/usc552a.txt

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Examples of Federal Privacy Act Violations

Public Housing will not rely entirely upon staff to read and understand the Federal Privacy Act. To ensure that staff has a complete understanding of the Federal Privacy Act and how seemly harmless action s may be violations, examples of Federal Privacy Act violations will be provided during security awareness training. The following example of a security violation was explained during the HUD Satellite Broadcast introducing the EIV system:

EIV data can only be viewed by authorized PHA staff and the individual adult who the information pertains to. This means that EIV data for an adult household member in a participant family cannot be shared with another adult household member of the participant family (even the head of household) unless that family member is present or signs a waiver authorizing the other family member to view their EIV information. The Federal Privacy Act protects the privacy of each adult family member from any unauthorized person viewing their EIV data, even another family member. However, EIV data for minor children may be viewed by the head of h ousehold. The PHA is not prohibited from discussing with the head of household (HOH) and showing the HOH how the household’s income and rent were determined based on the total family income reported and verified.

G. SECURITY

A Public Housing EIV Security Officer (s) is responsible for ensuring that proper technical, physical, and administrative safeguards are in place and enforced. The duties of the Public Housing EIV Security Officer(s) are as follows:

• Conducts quarterly reviews of all User IDs issued to determine if the users still have a valid need to access the EIV data and modifies or revokes access rights as appropriate.

• At the request of the Director, updates the EIV Security Policy and Procedures. • Assures that a copy of Form HUD -9886 has been signed by each member of the household , age 18 years or older, and is in the household file.

• Ensures compliance with the PHA security policies and procedures outlined in this document;

• Communicates security information and requirements to appropriate personnel, including coordinating and conducting security awareness training sessions;

• Ensures that any infractions of security procedures are promptly reported to Department Director for investigation and enforcement; and

• Ensures that all EIV records and forms (i.e. signed user agreements) are kept and updated as needed.

Security Awareness Training

Security awareness training is a crucial aspect of ensuring the security of the EIV system and data. U sers and potential users will be made aware of the importance of respecting the privacy of data, following established procedures to maintain privacy and security, and notifying management in the event of a security or privacy violation.

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In addition to security awareness training, the Public Housing EIV Security Officer (s) will communicate security information and requirements to appropriate personnel. Security awareness training will be provided to each employee upon granting access to the EIV system. Thereafter, annual security awareness refresher training will be provided to each employee with EIV access by the HUD Public Housing EIV Security Officer(s). The EIV Security Officer will determine the manner of the security awareness training which will be provided.

Safeguards

The purpose of these technical safeguards is as follows:

• To reduce the risk of a security violation related to the EIV system’s software, network, or applications.

• To identify and authenticate all users seeking access to the EIV system.

• To deter and detect attempts to access the system without authorization.

• To monitor the user activity of the EIV system.
• Each user is required to have their own User ID and Password.

• The User ID identifies the PHA’s and tenant information that the user is authorized to access.

• Passwords are encrypted and the password file is protected from unauthorized access.

• The system forces all user to change their password and limit the reuse of previous passwords.

• After three unsuccessful attempts to log in, the User ID is locked and the user must contact the HUD System Administrator to have the password reset; and

• Online warning messages that inform the user of the civil and criminal penalties associated with unauthorized use of the EIV system will be displayed.

In addition, the authorized CoPHD personnel will follow the following technical security requirement:

• Will not save EIV data to a computer hard drive or any other automated information system (i.e. network drive, disk or CD).

• Will not leave their computer unattended with EIV data displayed on the screen.

• Will attend the required security awareness training.

• Will not log in on another user’s ID.

• Will print EIV report to their individual printer.

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Administrative Safeguards

The Public Housing EIV Security Officer(s) will maintain security-related records and monitor programmatic security issues. They will also adhere to the following administrative safeguards:

• Ensure that all users who have access to EIV data have an Access Authorization Form signed by the Director of Housing on file.

• Ensure that all users who access the EIV system have a current signed Rules of Behavior and User Agreement on file.
• Conduct quarterly reviews of all User IDs to determine if the user still has a valid need to access the EIV data; and

• Ensure the access rights are modified or revoked as appropriate.

The Public Housing EIV Security Officer(s) will maintain the following EIV security records and forms:
• EIV Rules of Behavior and User Agreement Forms.

• EIV Access Authorization Forms.

• EIV Disposal Records List.

• EIV security violation information.

• Key control logs for secure areas or filing cabinets.

• EIV Security Awareness Training Records.

• Records of internal audits to ensure that Form HUD -9886 has been signed by each adult member of the household and is kept in the Confidential Resident File; and

• A record of all users who have approved access to EIV data, including the date access was granted and the date access was terminated.

Physical Safeguards

The purpose of physical safeguards is to provide barriers between unauthorized persons and documents containing private data.

Confidential Participant Files/Envelopes

All EIV data printed will be saved in the gray “Confidential” participant file and/or “Confidential” participant envelope.

Each participant file/envelope will be clearly labeled on the front cover as “Confidential” . T his alerts staff that this file/envelope contains EIV data that must be protected at all times when not in use.

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Sealed Confidential Envelopes

Even though the CoPHD has a monitored office building, persons unauthorized to view EIV data, such as maintenance staff, janitorial staff, or temporary staff, have access to the office spaces. EIV data will be placed in the gray confidential sealed and stamped envelopes which will be kept in the family’s file . If the case is terminated or purged, the confidential envelopes will remain in place until it is time to dispose of the EIV information and family’s file.

Hard Copy Security Violations

CoPHD will handle EIV data in such a manner that it does not become misplaced or available to unauthorized personnel. Any marked confidential participant file or marked confidential EIV envelope will contain EIV data .

Therefore the file/envelope cannot be viewed by any personnel that are not expressly authorized (i.e. staff in charge of the file, the supervisor of the staff in charge of the file, the Public Housing EIV S ecurity Officer(s), or the Public Housing Internal Auditor) and who do not have both an Access Authorization Form and a Rules of Behavior and User Agreement on file with the Public Housing EIV Security Officer(s).

Viewing the EIV information of a participant outside of a staff’s caseload assignment is considered a security violation for both the staff unlawfully viewing the EIV information and for the staff that left the information unattended. Unless a supervisor has specifically authorized staff to view another staff’s EIV data, this is expressly prohibited.

Disposal of EIV Information

EIV data will be destroyed in a timely manner based on the information provided in HUD’s published EIV training materials, HUD notices or as the data has served its purpose or as prescribed by the program administrator’s policy and procedures. All EIV reports and any documents created in association with their use should be shredded by authorized staff to prevent the reconstruction of the contents. It is important that a log or register be maintained of all documents shredded or destroyed.

H. REPORTING IMPROPER DISCLOSURES

CoPHD will recognize and report in response to security violations which are crucial to successfully maintaining the security and privacy of the EIV system.

Security violations may include the following:

• Disclosure of private data.
;
• Attempts to access unauthorized data; and

• Sharing of User IDs and passwords.

Upon discovery of a possible improper disclosure of EIV information or another security violation by a Public Housing Employee or any other person, the individual making the observation or receiving the information should contact the Public Housing EIV Security Officer (s). The Public Housing EIV Security Officer (s) will document all improper disclosures in writing on a security disclosure form, providing details including who was involved, what was disclosed, how the disclosure occurred, and where it occurred.

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The following contacts will be made:

• The Public Housing EIV Security Officer (s) will contact and provide the Director of Public Housing with the written documentation of the security violation.
• The Administrator or his designee will provide the HUD Field Office Public Housing Director with the written documentation; and
• The HUD Field Office Public Housing Director , upon receipt of the documentation , will make a determination regarding the referral and provision of the written documentation to the Headquarters EIV Coordinator and/or Public Housing EIV Security Officer(s) for further review and follow-up action.

Safeguards Provided by the Federal Privacy Act

The Federal Privacy Act provides safeguards for individuals against invasion of privacy by requiring Federal agencies, except as otherwise provided by law or regulation, to:

• Permit individuals to know what records pertaining to them are collected, maintained, used or disseminated.

• Allow individuals to prevent records pertaining to them (obtained for a particular purpose) from being used or made available for another purpose without their consent.

• Permit individuals to gain access to information pertaining to them, obtain a copy of all or any portions thereof, and correct or amend such records.

• Collect, maintain, use or disseminate personally identifiable information in a manner that ensure s the information is current and accurate, and that adequate safeguards are provided to prevent misuses of such information.

• Permit exemption fr om the requirements of the Act only where an important public policy need exists as determined by specific statutory authority; and

• Be subject to a civil suit for any damages that occur as a result of action that violates any individual’s rights under this Act.

I. UPDATING OF PHA POLICIES AND PROCEDURES

All PHAs are required to immediately implement all new and modified regulatory requirements of the Refinement of Income and Rent Determination Requirements in Public and Assisted Housing Programs: Implementation of the Enterprise Income Verification System-Amendments. PHAs should immediately update their policies and procedures to reflect these new regulatory provisions.

PIH provided PHAs with the attached EIV system information guide that PHAs may provide to applicants and tenants of PIH rental assistance programs. The CoPHD distributed the documents What You Should Know About EIV and Form HUD 52675 to applicants and tenants to educate families about EIV and Debts Owned to PHAs & Termination DRAFT
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Notice and to also inform them of how it affects their family. The CoPHD will provide the family with a copy of each notice and maintain a signed copy in the family file.

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CHAPTER 25

SPECIAL HOUSING CHOICE VOUCHER ALLOCATIONS

INTRODUCTION

The Housing Choice Voucher (HCV) program includes special voucher allocations for defined populations. These special allocations must be utilized by households meeting the speci fic eligibility definition for the allocation under which they will be assisted. These allocations include HCV for Non- Elderly Disabled Persons (NED), Mainstream Vouchers,HUD-Veteran’s Affairs Supportive Housing ( HUD-VASH) and the Foster Youth to Independence (FYI) Program. This chapter will outline policies and procedures for these two special allocations. Except as delineated in this chapter, these programs will be administered in adherence to the policies and procedures of the HCV program as administered by the City of Pasadena Housing Department (CoPHD) and set forth in this Administrative Plan.

A. HCV FOR NON-ELDERLY DISABLED PERSONS

HCV for NED provides rental assistance to very low-income households whose head, spouse, or sole member is a person with disabilities and is less than 62 years old.

Applicant Eligibility Process

Applicants for Category 1 NED HCVs must be selected from the Section 8 waiting list and meet the definition of non- elderly disabled household . In the event that Category 1 NED HCVs are available and there are not enough households on the waiting list that qualify for these HCVs and the waiting list is closed , then the waiting list will open for applications from very low-income non-elderly disabled households. In this case, the CoPHD will limit the families that may apply to only those families that meet the eligibility requirements for the allocated Category 1 NED HCVs.

The waiting list process for these applicants will be conducted in accordance with waiting list procedure as delineated in Chapter 4 of this Plan, “Application Pool”. Eligibility determination requires that all conditions of eligibility be met at the time of initial lease- up. Category 1 NED HCVs are administered in accordance with program requirements (24 CFR Section 982).

Outreach to Non-Elderly Persons with Disabilities

The CoPHD will reach out to agencies that provide supportive services to non-elderly disabled persons to make them aware of the availability of NED vouchers and the requirements to access NED Category 1 . When it is necessary to open the waiting list to accept applications for NED Category 1, information will be disseminated in accordance with Chapter 3 of this Plan,” Open Enrollment”. Additionally, application information will be made available at agencies that serve persons with disabilities.

Affirmatively Furthering Fair Housing

As stated in Chapter 1 of this Plan, “Statement of Policies and Objectives” it is the policy of the CoPHD to comply with the A ffirmatively Furthering Fair Housing Requirements of 24 CFR Part 903 .7(o). Affected applicants are informed at the HCV briefing session about how to file a fair housing complaint. Form HUD-928.1, the Equal Housing Opportunity flyer which includes the toll free Housing Discrimination hotline and Federal Information Relay Service numbers, and Form HUD -903.1, “Are You a Victim of Housing Discrimination” which includes a form for filing a housing discrimination complaint, are included in each briefing packet and reviewed during the briefing session.

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Aging Out of NED

Existing NED participant families DO NOT “age out” of the NED program as long as the family was eligible on the day it was first assisted under a housing assistance payments (HAP) contract or the date it was established as a NED family in PIC pursuant to Notice PIH 2013- 19. By “aging out,” this notice is referring to cases where the qualifying household member now qualifies as elderly due to the passage of time since the family received the NED voucher.

Reasonable Accommodation

The CoPHD’s policies and procedures regarding reasonable accommodation are outlined in Chapter 1 of this Plan .

These policies and procedures will also be applied to all sp ecial Housing Choice Voucher allocation s’ program participants and applicants, including but not limited to NED..

Housing Search Assistance

The Pasadena Housing Resource Center, sponsored by the City of Pasadena Housing Department and available online at www.pasadenahousingsearch.com , provides detailed information about currently available, moderately priced units in Pasadena. The site includes tools to search for accessible units and units that accept rental assistance. Use of the site is free. It may also be accessed through a toll -free, bilingual call center at 1 -877-428- 8844. Applicants are provided information about the site at the HCV briefing session.

B. HUD-VETERANS AFFAIRS SUPPORTIVE HOUSING (VASH)

The HUD-VASH program combines HCV rental assistance for homeless veterans with case management and clinical services provided by the Department of Veteran's Affairs (VA). VA provides these services for participating veterans at VA medical centers (VAMCs) and community- based outreach clinics. Generally, the HUD -VASH HCV is administered in accordance with regular HCV program requirements (24 CFR Section 982). However, the Act allows HUD to waive or specify alternative requirements for any provision of any statute or regulation that HUD administers in connection with this program in order to effectively deliver and administer HUD -VASH voucher assistance. The HUD-VASH program will be operated in accordance with t he revised HUD-VASH Operating Requirements published in the Federal Register on September 27, 2001 and all other HUD publication s after said date regarding the HUD - VASH program including the waivers and alternative requirements from HCV program rules.

HUD-VASH Eligibility Criteria

Veterans who are appropriate for this program must be VA health care eligible Veterans. VA eligibility makes this determination. Veterans must meet the definition of homelessness defined in “The McKinney Homeless Assistance Act” as amended by S. 896 The Homeless Emergency Assistance and Rapid Transition to Housing (HEARTH) Act of 2009.

Veterans who are appropriate candidates for this program must need:

• Case management services in order to obtain and sustain independent community housing. Case management is a requirement for participation in the HUD-VASH voucher program.

o Veterans who need case management services have serious mental illness, substance use disorder history, or physical disability.

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o Eligible candidates for the program are expected to participate in case management and utilize the supportive services, treatment recommendations and assistance needed to successfully maintain

recovery and sustain housing in the community.

o VA determines clinical eligibility for the program.

o The PHA determines if the Veteran participant meets HUD’s regulations for this program.

o The PHA will determine eligibility based on income limits and will request citizenship verification.

o The PHA will verify if any member of the household is required to maintain Lifetime Sexual Offender Registry status – those who do are not eligible to participate in this program.

If a family no longer needs case management as determined by the VAMC or if the veteran dies, the family is still eligible for rental assistance under the HCV program. In cases where case management is no longer needed, the PHA may use one of its own vouchers, if available, to continue assisting this family and free up a voucher for another HUD-VASH eligible family. If a regular voucher is not available, the family would continue utilizing the HUD -VASH voucher.

In accordance with 24 CFR Section 982.54(d) (11) family break-up, the voucher must remain with the veteran in the case of a separation or divorce.

In regard to verifying Social Security numbers (SSNs) for homeless veterans and their family members, an original document issued by a federal or state government agency, which contains the name of the individual and the SSN of the individual along with other identifying information of the individual, is acceptable in accordance with 24 CFR part

5.216(g).

In the case of the homeless veteran:

• The PHA must accept the Certificate of Release or Discharge from Active Duty (DD–214) as verification of SSN and cannot require the veteran to provide a SSN card.

• The PHA must accept the VA -verified Application for Health Benefits (10 –10EZ) as verification of SSN and cannot require the veteran to provide a SSN card.

• The DD-214 or 10- 10EZ documents must also be accepted for proof -of-age purposes in lieu of birth certificates or other PHA-required documentation.

• Veterans are also issued photo identification (ID) cards by the VA. If such identification is required by the PHA, these cards must be accepted by the PHA in lieu of another type of government -issued photo identification.

• VA issued photo ID cards may also be used to verify SSNs and date of birth.

The HUD–VASH program is administered in accordance with applicable Fair Housing requirements. These include applicable authorities under 24 CFR 5.105(a) and 24 CFR DRAFT
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982.53 including, but not limited to, the Fair Housing Act, Section 504 of the Rehabilitation Act of 1973, Title VI of the Civil Rights Act of 1964, the Americans with Disabilities Act, and the Age Discrimination Act. These requirements prohibit discrimination on the basis of race, color, religion, sex, familial status, national origin, age, or disability.

Admission

A PHA will not be able to deny admission to the HCV program to an otherwise eligible HUD -VASH family that previously participated in the PHA’s HCV or public housing program (that presumably left owing money or was not in good standing).

The PHA will not deny admission to an adult family member, other than the veteran, based on the previous behavior of that family member. For example, the co- head was previously terminated from the PHA’s voucher program for committing serious or repeated violations of the lease (e.g. non -payment of rent). The prohibition against screening families for anything other than lifetime sex offender status, applies to all family members, not just the veteran.

Calculating Annual Income & Coordination with Other Veteran Programs

The Post 9/11 Veterans Educational Assistance Act of 2008 (Post 9/11 VEAA, also referred to as the Post 911 GI Bill) provides benefits for veterans pursuing a course of education in the forms of tuition assistance, book stipends, and a monthly housing allowance. The Post 9/11 VEAA tuition assistance and book stipends, must be excluded as income in accordance with 24 CFR 5.609(c)(6).

The Post 9/11 VEAA housing allowance is not considered as a duplicate subsidy. However, the amount received for the housing allowance must be counted when determining the family’s income and rent.

A veteran can receive assistance through both the HUD-VASH program and the Supportive Services for Veteran Families (SSVF).

Types of SSVF assistance available for eligible families include:

• rental assistance,
• security deposits,
• utility deposits,
• utility assistance,
• moving cost assistance, and
• rapid re-Housing assistance.

HUD-VASH families are eligible to receive security deposit, utility deposit, and moving cost assistance through the program. SSVF assistance, however, cannot be provided to eligible individuals or families for the same period of time and for the same cost types that are being provided through another Federal, state, or local subsidy programs.

Therefore, during the period that HUD- VASH vouchers subsidize the monthly rent and utility payments of participating families, HUD-VASH families cannot receive rental assistance nor utility assistance through SSVF.

SSVF can be used to help the household pay for up to six months of arrears or back payments on rent or utilities owed from previous housing situations. Note that assistance with arrears is eligible because it represents a different period of time – i.e., the arrears represents a back payment for previous months, while the current rental assistance is a payment going forward.

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Households receiving rapid re-housing assistance through SSVF will retain their homeless status, including chronicity if applicable, for referral to the HUD-VASH program.

HUD VASH – Portability

Based on the nature of the HUD -VASH voucher program and the population that is being served, alternative operating requirements, as well as specific reporting requirements have been established for this program. These include mobility agreements with neighboring PHAs and alternative portability requirements.

The CoPHD has entered into a reciprocal Interagency Agreement with the Housing Authority of the County of Los Angeles (HACoLA) and the Housing Authority of the City of Los Angeles (HACLA) to allow HUD- VASH voucher holders to lease a rental unit in either of their jurisdictions without needing to port to the PHA that administers HUD - VASH for that jurisdiction. The CoPHD will enter into additional mobility agreements as the opportunity presents if it is determined that it is mutually beneficial to veteran households and the CoPHD.

When a HUD-VASH voucher leases a unit in a jurisdiction with which there is no mobility agreement, receiving PHAs that are administering HUD-VASH vouchers are subject to these alternative requirements, which can be found on the HUD-VASH website at: http://www.hud.gov/offices/pih/programs/hcv/vash/. These procedures only apply to portability moves where the family’s case management services are being provided by the initial PHA’s partnering Veterans Affairs Medical Center (VAMC).

The following are important portability procedures:

• When a family requests to move under portability while staying within the catchment area of the initial PHA’s partnering VAMC, portability procedures vary according to whether or not the receiving PHA has been awarded HUD-VASH vouchers.

• When a family requests to move under portability beyond the catchment areaof the initial PHA’s partnering VAMC, the VAMC will determine if services are available and if the receiving PHA can accommodate HUD - VASH vouchers. For more information refer to Notice published on March 23, 2012 at 77 FR 17086 and on June 18, 2014 at 79 FR 34769.

• When case management is no longer required there are no portability restrictions.

• If the receiving PHA has been awarded HUD -VASH vouchers, it can choose to bill the initial PHA or absorb the family if it has a HUD-VASH voucher available.

• If the receiving PHA has not been awarded HUD -VASH vouchers, the initial PHA (the one that has been selected to partner with the local VAMC) must be billed for all portable families under the HUD -VASH program.

• For more information, see Notice PIH 2010-12 and section II.f. of the HUD-VASH Operating Requirements.

• The receiving PHA must enter “VASH” on line 2n of the Family Report (form HUD -50058). This code must remain on the HUD-50058 for the duration of the HUD-VASH family’s participation in the program.

• Receiving PHAs must follow Operating Requirements published on May 6, 2008, in the Federal Register in regard to other alternative requirements for this program. These requirements include, but are not limited to:

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o For new admissions, PHAs may only deny assistance if the family is over-income or if any member of the household is subject to a lifetime registration requirement under a state sex offender registration program. PHAs may not deny assistance for any other reason.

• HUD-VASH vouchers must have an initial term of at least 120 days.

Occupancy & Payment Standards

VASH HOUSING SUBSIDY STANDARDS GUIDELINES FOR UNIT SIZE SELECTED

Number of Bedrooms Persons in Household Persons in Household (Minimum #) (Maximum #)
0 Bedroom 1 2
1 Bedroom 1 4
2 Bedrooms 3 6
3 Bedrooms 5 8
4 Bedrooms 7 10
5 Bedrooms 9 12

Families participating in the VASH Program will have their voucher size re -evaluated at their annual re -examination to ensure applicability of the VASH housing subsidy standards listed above.

The CoPHD r eceived approval from HUD to utilize the same payment standard as HACOLA & HACLA in order to allow VASH participants the opportunity locate housing and move freely between jurisdictions paying the same amount of rent. However, proposed contract rents must be comparable and reasonable in relation to rents currently charged by the property owner for assisted and unassisted units. The full contract rent must meet the reasonable rent requirements.

Termination

The PHA cannot terminate a VASH family for a reason that could not be used for denying admission. However, a HUD-VASH family can be terminated for program violations that occur after the family is admitted to the HUD -VASH program. Prior to any termination action, the PHA is strongly encouraged to contact the VA case manager to determine if there are extenuating circumstances that should be considered to avoid the termination.

When a veteran’s family member is receiving protection as a victim of domestic violence, dating violence, or stalking, as provided in 24 CFR part 5, subpart L, and the veteran is the perpetrator of such violence, the victim must continue to be assisted.

In accordance with 24CFR 5.2007 for details on what documentation the PHA may request from the victim to support the claim for Violence Against Women Act (VAWA) protections. The perpetrator may be terminated from assistance for committing such acts. If a regular HCV is not available for the victim, the perpetrator must be terminated from assistance, and the victim will continue to utilize the HUD -VASH voucher. The HUD -VASH voucher must be issued to another eligible veteran family upon the voucher’s turnover.

The PHA cannot refuse to readmit veterans that have been terminated from the HUD-VASH program in accordance with program requirements (any grounds under 24 CFR 982.552 and 982.553):

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• due to serious lease violations,
• program fraud,
• engaging in criminal activity or
• drug/alcohol abuse, etc.

With the exception of the requirement to deny admission if any member of the household is subject to a lifetime registration requirement under a state sex offender registration program. Therefore, if the VA case manager re -refers a veteran that has been previously terminated from the HUD -VASH program for any reason other than being subject to a state lifetime sex offender registration requirement, the PHA may not deny HUD-VASH assistance to the referred veteran. The PHA and VA case manager should work together to agree on the appropriate action and determine if termination of the veteran’s assistance c
an be avoided.

Pasadena City CouncilJanuary 12, 2026

Pasadena City Council
January 12, 2026