DRAFT
2026
2026 Administrative Plan
RENTAL ASSISTANCE PROGRAM
CITY OF PASADENA HOUSING DEPARTMENT
ATTACHMENT A
DRAFT
2026 City of Pasadena Housing Department
Administrative Plan
Proposed Changes
Chapter 1-
Statement of Policies and Objectives
No changes
Chapter 2-
Eligibility for Admission
No changes.
Chapter 3-
Applying for Admission
No changes.
Chapter 4-
Establishing and Maintaining the Waiting List
E. Emergency Housing Voucher Preference: Page 4-5
Adds a limited preference for assistance through the Housing Choice Voucher Program (“HCV”, commonly known as Section 8) for Emergency Housing Voucher (“EHV”) participants. Acknowledges the waiver received from the U.S. Department of Housing & Urban Development (“HUD”) that allows the City of Pasadena Housing Department (“CoPHD”) to place all EHV participants on the HCV waiting list without requiring them to apply separately.
F. Preference for Participants in Time-limited Subsidy Programs: Page 4-5 Allows the CoPHD to transfer participants inn time-limited subsidy programs to the HCV program if the participant is eligible for assistance and if funding is available.
Chapter 5-
Subsidy Standards
D. Subsidy Standards in the Event of Shortfall in Funding: Page 5-4 Allows the CoPHD to reduce subsidy standards if it is determined by HUD or the CoPHD that it is at risk of needing to terminate program participants due to insufficient funding to pay rental subsidy obligations.
Chapter 6-
Factors Related to Total Tenant Payment Determination
No changes.
Chapter 7-
Verification Procedures
No changes.
Chapter 8-
Issuance and Briefings
No changes.
DRAFT
Chapter 9-Request for Tenancy Approval and Contract Execution No changes.
Chapter 10-Housing Quality Standards and Inspections
No changes.
Chapter 11-Owner Rents, Rent Reasonableness, and Payment Standards No changes.
Chapter 12-Reexaminations
No changes.
Chapter 13-Moves with Continued Assistance/Portability
No changes.
Chapter 14-Contract Terminations
No changes.
Chapter 15-Denial or Termination of Assistance
No changes.
Chapter 16-Owner Disapproval and Restriction
No changes.
Chapter 17-Property Owner or Family Debts to the CoPHD
No changes.
Chapter 18-Complaints and Appeals
No changes.
Chapter 19-Project Based Vouchers
No changes.
Chapter 20-Supportive Housing Program
No changes.
Chapter 21-Consolidated Annual Contribution Contract
No changes.
DRAFT
Chapter 22-Records Management
No changes.
Chapter 23-Program Integrity Addendum
No changes.
Chapter 24-EIV Security Policies and Procedures
No changes
.
Chapter 25-Special Housing Choice Voucher Allocations
No changes.
Chapter 26- Public Housing and Housing Choice Voucher Programs Temporary Compliance Assistance
No changes.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
TOC-i
TABLE OF CONTENTS
CHAPTER 1
STATEMENT OF POLICIES AND OBJECTIVES
MISSION STATEMENT
A. RENTAL ASSISTANCE PROGRAMS…………………………………………….. 1-1
B. OBJECTIVES .................................................................................................... 1-2 C. PURPOSE OF THE ADMINISTRATIVE PLAN .................................................. 1-3 D. FAIR HOUSING POLICY [24 CFR 982.5] ......................................................... 1-2 E. SERVICE POLICY/ACCOMMODATIONS ......................................................... 1-3 • Reasonable Accommodation………………………… .................. ………………..1-3 F. VIOLENCE AGAINST WOMEN ACT (VAWA) .....………………………………..1-5 G. LIMITED ENGLISH PROFICIENCY (LEP) ........................................................ 1-7 H. FAMILY OUTREACH ........................................................................................ 1-7 I. OWNER OUTREACH ...................................................................................... 1-7 J. PRIVACY RIGHTS ............................................................................................ 1-8 K. AFFIRMATIVE ACTION/EQUAL OPPORTUNITY ............................................ 1-8 L. RULES AND REGULATIONS ........................................................................... 1-8 M. JURISDICTION ................................................................................................. 1-9 N. MONITORING OF PROGRAM PERFORMANCE……………………………… . 1-9
O. TERMINOLOGY……………………………………………………………………. 1-9
P CITY OF PASADENA HOUSING DEPARTMENT WEBSITE.......................... 1-10
CHAPTER 2
ELIGIBILITY FOR ADMISSION
[24 CFR Part 5, Subparts B, D, and E; 24 CFR 982, Subpart E]
A. ELIGIBILITY FACTORS .................................................................................... 2-1 B. FAMILY COMPOSITION [24 CFR Part 5.403, 982.201] .................................. 2-1 • Head of Household …………………………………………………………………. 2-2
• Live-in Aide [24CFR 982.316 and 5.403] ………………………………………. 2-2 C. INCOME LIMITATIONS [24 CFR 982.201] ……………………………………….2-4 • A Single Person who is Pregnant [24CFR 982.402)…………………………… 2-4 • Single –Jurisdictional Housing Agencies…………………………………………..2-5 • Multi-Jurisdictional Housing Agencies…………………………………………….. 2-6 D. MANDATORY SOCIAL SECURITY NUMBERS [24 CFR 5.216] ...................... 2-6 E. PENALTIES FOR FAILURE TO DISCLOSE/DOCUMENT SSN’s….…………..2-7 F. CITIZENSHIP/ELIGIBLE IMMIGRATION STATUS
24 CFR
Part 5, Subpart E] ................................................................................. 2-7 G. OTHER CRITERIA FOR ADMISSION [24 CFR 982.552, 982.553 (c)] ............. 2-7 • Legal Capacity of Persons with Disabilities ……………………………………... 2-9 DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
TOC-ii
• Ability to Meet Program Requirements ………………………………………….. 2-9 H. SUITABILITY OF FAMILY ............................................................................... 2-10 I. CHANGES IN ELIGIBILITY PRIOR TO EFFECTIVE DATE
OF THE CONTRACT ...................................................................................... 2-10 J. INELIGIBLE FAMILIES .................................................................................... 2-10
CHAPTER 3
APPLYING FOR ADMISSION
A. HOW TO APPLY ............................................................................................... 3-1 B. OPEN ENROLLMENT [24 CFR 982.206] .......................................................... 3-1 • Suspension of Enrollment Period ..................................................................... 3-2 C. H CVP APPLICATION PROCEDURES [24 CFR 982.204 (b)] ...................... 3-2 D. TIME OF SELECTION ...................................................................................... 3-4 E. COMPLETION OF A FULL APPLICATION INTERVIEW ……………………..3-4 F. INTERVIEW REQUIREMENTS……………………………………………………..3-4
G. FINAL DETERMINATION AND NOTIFICATION OF ELIGIBILITY .................... 3-5 H. INELIGIBLE DUE TO INCONSISTENCIES …………………………………… 3-5
CHAPTER 4
ESTABLISHING PREFERENCES AND MAINTAINING THE WAITING LIST [24CFR Part 5, Subpart D; 982.203; 982.204, 982.205, 982.207]
A. APPLICATION POOL ........................................................................................ 4-1 • Special Admissions {24 CFR 982.203} .............................................................. 4-2 B. WAITING LIST PREFERENCES [24 CFR 982.207] .......................................... 4-2 C. LOCAL PREFERENCE [24 CFR 982.207] ........................................................ 4-2 • Residency Preference ....................................................................................... 4-3 • Substandard Housing ........................................................................................ 4-3 • Veteran Preference ………………………………………………………………. 4-8
D. TARGETED FUNDING ...................................................................................... 4-8 E. LIMITED PREFERENCES………………………………………………………… 4-5
F. PREFERENCE ELIGIBILITY ............................................................................ 4-5 • Change in Circumstances ................................................................................. 4-5 F. ORDER OF SELECTION [24CFR 982.207] ...................................................... 4-5 • Local Preferences .............................................................................................. 4 -5
• Among Applicants with Equal Preference Status............................................... 4-5 G. FINAL VERIFICATION OF PREFERENCES .................................................... 4-6 H. PREFERENCE DENIAL ................................................................................... 4-7 DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
TOC-iii
I. REMOVAL FROM WAITING LIST [24 CFR 982.204(c)] ................................... 4-8 J. CHANGES IN FAMILY CIRCUMSTANCES …………………………………… 4-8
K. EXPIRATION OF THE WAITING LIST ………………………………………… 4-82
CHAPTER 5
SUBSIDY STANDARDS
[24 CFR 982.54(d)(9)]
A. DETERMINING BEDROOM SIZE [24 CFR 982.402] ........................................ 5-1 B. CHANGES IN BEDROOM SIZE FOR HCV HOLDERS [24 CFR 982.403] ..... 5-2 • Changes for Applicants ..................................................................................... 5-2 • Changes for Participants ................................................................................... 5-2 • Request for Exceptions to Subsidy Standards…………………………………….5-3 • Under-Housed Families……………………………………………………………...5-2
• Over- Housed Families ....................................................................................... 5-2 C. UNIT SIZE SELECTED ..................................................................................... 5-3 • Housing Subsidy Standards Guidelines for Unit Size Selected ………………...5-3 • VASH Housing Subsidy Standards Guidelines for Unit Size Selected ………...5-4
CHAPTER 6
FACTORS RELATED TO TOTAL TENANT PAYMENT DETERMINATION
A. INCOME AND ALLOWANCES .......................................................................... 6-1 • Elements of Annual Income ............................................................................... 6-1 • Income of Temporarily Absent Family Members ............................................... 6-2 • Income of Family Members who Work as Private Nurse/Care Attendant .......... 6-2 • Regular Contributions and Gifts ......................................................................... 6-2 • Seasonal Income ............................................................................................... 6-3 • Income from Temporary Work Assignments...................................................... 6-3 • Income from Business (Includes Self-Employment Income) ............................. 6-3 • Student Financial Assistance............................................................................. 6-4 • Income from Excess of Financial Assistance ………………………………..6-4 • Military Pay ……………………………………………………………………………6-4
• Resident Service Stipend .................................................................................. 6-4 • State or Local Employment Training Programs ................................................. 6-5 • Earned Income Disallowance ........................................................................... 6-5 • R eduction in Welfare Benefits ........................................................................... 6 -5
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
TOC-iv
• Reduct
ion in Social Security and Supplement Security Income Payments …...6-6 • Income of Confined Family Members ................................................................ 6-6 • Alimony and Child Support ................................................................................ 6-6 • Lump Sum Payments ........................................................................................ 6-7 • Payments in Lieu of Earnings ............................................................................ 6-7 • Prospective Calculation Methodology ................................................................ 6-7 • Retroactive Calculation Methodology ................................................................ 6-8 • Attorney Fees .................................................................................................... 6-8 • Determining Income from Net Family Assets ……………………………... 6-8 • Assets Disposed of for Less than Fair Market Value ....................................... 6-10 • Contributions to Retirement Funds .................................................................. 6-10 • Equity in Real Property .................................................................................... 6-10 • Adjusted Income .............................................................................................. 6-10 • Dependent Allowance ...................................................................................... 6-10 • Elderly or Disabled Family Allowance .............................................................. 6-10 • Child Care Allowance ...................................................................................... 6-10 • Disability Assistance Expense Allowance ........................................................ 6-10 • Medical Expense Allowance ............................................................................ 6-10 • Minimum Rent ................................................................................................ 6-14 B. AVERAGING INCOME .................................................................................... 6-14 C. ZERO INCOME ............................................................................................... 6-14 D. PRORATION OF ASSISTANCE FOR "MIXED" FAMILIES [24 CFR 5.520] .... 6-14 • Applicability...................................................................................................... 6-14 • Prorated Assistance Calculation ...................................................................... 6-14 E. TENANT RENT ............................................................................................... 6-15 F. RENT BURDEN [24 CFR 982.508] ................................................................. 6-15 G. UTILITY ALLOWANCE AND UTILITY REIMBURSEMENT PAYMENTS [24 CFR 982.153, 982.514, 982.517] .............................................................. 6-15 H. DEFINITION OF TEMPORARILY/PERMANENTLY ABSENT
[24 CFR
982.551]……………………………………………………………………6-16
• Absence of Entire Family ................................................................................. 6-16 • Absence Due to Vacation…………………………………………………………..6-17
• Absence of Any Member ................................................................................. 6-17 • Absence Due to Medical Reasons ................................................................... 6-17 • Absence Due to Incarceration ......................................................................... 6-17 • Foster Care and Absences of Children ............................................................ 6-17 • Absence of Adult ............................................................................................. 6-18 • Visitors……………………………………………………………………………..…6-19
• Other Related Income Matters ……………………………………………………6-19 DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
TOC-v
CHAPTER 7
VERIFICATION PROCEDURES
[24 CFR Part 5, Subparts B, D, E and F; 982.207]
A. METHODS OF VERIFICATION AND TIME ALLOWED .................................... 7-1 • Up-Front Income Verification (UIV / EIV) ........................................................... 7-1 • Written Third- Party Verification ......................................................................... 7-2 • Written Third-Party Verification Form………………………………………………7-3 • O ral Third-Party Verification .............................................................................. 7-3 • Tenant Declaration ............................................................................................ 7-3 • Non-acceptable Tenant Provide Documents ..................................................... 7-4 • Exceptions to Third Party Verification Requirements…………………………….7-4 B. RELEASE OF INFORMATION…………………………………………………… . 7-4
• Client Screening-Criminal History Background……………………………………7-5 C. COMPUTER MATCHING ................................................................................. 7-5 D. ITEMS TO BE VERIFIED .................................................................................. 7-5 E. VERIFICATION OF INCOME ............................................................................ 7-6 • Employment Income .......................................................................................... 7-6 • Social Security, Pensions, Supplemental Security Income, Disability Income ... 7-7 • Unemployment Compensation .......................................................................... 7-8 • Public Assistance Payments.............................................................................. 7-8 • Alimony Payments ............................................................................................. 7-8 • Child Support Payments…………………………………………………………… 7-9
• Net Income from a Business............................................................................ 7-10 • Child Care Business ........................................................................................ 7-11 • Regular Gifts and Contributions ....................................................................... 7-11 • Zero Income Status ......................................................................................... 7-12 • Income from Excess of Tuition Assistance (Institution of Higher Education) ..7-13 • Other Income Sources ..................................................................................... 7-13 F. VERIFICATION OF ASSETS .......................................................................... 7-13 • Financial Institution Accounts .......................................................................... 7-13 • Interest Income from Mortgages or Similar Arrangements .............................. 7 -13
• Net Rental Income from Property Owned by Family ........................................ 7-13 • Family Assets .................................................................................................. 7-14 • Real Estate…………………………………………………………………………. 7-14
• Life Insurance………………………………………………………………………..7-15
• Assets Disposed of for Less than Fair Market Value (FMV) ............................ 7-15
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
TOC-vi
CHAPTER 7 - continued
G. VERIFICATION OF ALLOWABLE DEDUCTIONS FROM INCOME ............... 7-15 • Dependent Deduction ...................................................................................... 7-15 • Elderly or Disabled Family Deduction .............................................................. 7-16 • Child Care Expense Deduction ........................................................................ 7-17 • Medical Expense Deduction ............................................................................ 7-18 • Assistance to Persons with Disabilities ............................................................ 7-19 H. VERIFYING NON-FINANCIAL FACTORS ...................................................... 7-20 • Verification of Legal Identity ............................................................................ 7-20 • Verification of Marital Status ............................................................................ 7-21 • Familial Relationships ...................................................................................... 7-21 • Special Needs Adult………………………………………………………………...7-21
• Verification of Permanent Absence of Adult Member ...................................... 7-22 • Absence of the Entire Family………………………………………………………7-23 • Verification of Change in Family Composition ................................................. 7-24 • Verification of Disability ................................................................................... 7-24 • Verification of Reasonable Accommodation .................................................... 7-24 • Verification of Citizenship/Eligible Immigration Status ..................................... 7-24 • Failure to Provide……………………………………………………………………7-25
• Time of Verification .......................................................................................... 7-25 • Extensions of Time to Provide Documents ...................................................... 7-25 • Acceptable Documents of U.S. Citizens/Nationals .......................................... 7-25 • Acceptable Documents of Eligible Immigration................................................ 7-25 • Verification of Social Security Numbers ........................................................... 7-26 • Verification of Emancipated Youth ................................................................... 7-26 • Verification of Student Status .......................................................................... 7-27 • Verification of Students Enrolled at an institution of Higher Education ……....7-27 • Verification of Domestic Violence (VAWA) ...................................................... 7-28 I. WAITING LIST PREFERENCES [24 CFR 5.430, 982. 207] ............................. 7-28 • Local Preferences ............................................................................................ 7-28
CHAPTER 8
CERTIFICATE/VOUCHER ISSUANCE AND BRIEFINGS
A. ISSUANCE OF CERTIFICATES/VOUCHERS [24 CFR 982.302] .…………… 8-1 B. BRIEFING TYPES AND REQUIRED ATTENDANCE [24 CFR 982.301] .......... 8-1 • Initial Applicant Briefing ..................................................................................... 8-1 • Participant Briefing ……..…………………………………………………………….8-2
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
TOC-vii
CHAPTER 8- continued
• Applicant Briefing Packet ................................................................................... 8-2 • Other information to be Provided at the Briefing ................................................ 8-4 • Participant Briefing Packet …………………………………………………………8-5 • Owner Briefings ................................................................................................ 8-7 C. ENCOURAGING PARTICIPATION IN AREAS WITH LOW CONCENTRATION OF POVERTY ................................................................................................... 8-7 D. ASSISTANCE TO FAMILIES WHO CLAIM DISCRIMINATION ........................ 8-7 • Fair Housing Laws ............................................................................................. 8-7 E. SECURITY DEPOSIT REQUIREMENTS [24 CFR 982.313] ............................. 8-8 F. TERM OF HCV [24 CFR 982.303] ..................................................................... 8-8 • Initial Term ......................................................................................................... 8-8 • Expirations ......................................................................................................... 8-8 • Suspensions ...................................................................................................... 8-8 • Extensions ......................................................................................................... 8-9 • A ssistance to HCV Holders ............................................................................. 8-10 • Transfer of HCV ............................................................................................... 8-10 * Applicant Family …………………………………………………………………8-10
* Participant Family………………………………………………………………..8-10
G. DISCLOSURE OF TENANT INFORMATION TO OWNER ............................. 8-10
CHAPTER 9
REQUEST FOR LEASE APPROVAL AND CONTRACT EXECUTION
A. REQUEST FOR TENANCY APPROVAL [24 CFR 982.305(b), 982.313] .......... 9-1 • Disapproval of RFTA ......................................................................................... 9-2 B. ELIGIBLE TYPES OF HOUSING [24 CFR 982.352] ......................................... 9-3 C. L EASE REVIEW [24 CFR 982.308] ................................................................... 9-3 • Separate Agreements ........................................................................................ 9-4 D. INITIAL INSPECTIONS [24 CFR 982.305(a) & (b), 982.401] ............................ 9-4 E. LEASE EXECUTION ………………………………………………………………...9-4
F. RENT LIMITATIONS [24 CFR 982.503] ............................................................ 9-5 G. INFORMATION TO OWNERS [24 CFR 982.307(b); 982.54(d)(7)] ................... 9-5 H. CoPHD DISAPPR
OVAL OF OWNER [24 CFR 982.306] .................................. 9-5 I. CHANGE IN TOTAL TENANT PAYMENT (TTP) PRIOR TO HAP EFFECTIVE DATE ................................................................................................................. 9-6 J. HAP CONTRACT EXECUTION PROCESS [24 CFR 982.305(c)] ..................... 9-7 K. CHANGE IN PROPERTY OWNERSHIP ........................................................... 9-7
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
TOC-viii
CHAPTER 10
HOUSING QUALITY STANDARDS AND INSPECTIONS
(CFR 982.401, 982.404, 982.405)
A. GUIDELINES/TYPES OF INSPECTIONS [24 CFR 982.401, 982.405] ........... 10-1 • Basic Housing Quality Standards (HQS) ......................................................... 10-1 B. ACCEPTABILITY CRITERIA AND EXCEPTIONS TO HQS
[24 CFR 982.401] ............................................................................................ 10-3 C. INITIAL, ANNUAL, AND BIENNIAL INSPECTIONS ........................................ 10-3 • Responsibility for Repairs…………………………………………………………. 10-4 • Time Standards for Repairs ............................................................................. 10-4 D. EMERGENCY REPAIR ITEMS [24 CFR 982.401(a)] ...................................... 10-5 • Health & Safety Items……………………………………………………………….10-5
E. CONSEQUENCES IF OWNER IS RESPONSIBLE
(NON-EMERGENCY ITEMS) .......................................................................... 10-6 • Abatement ....................................................................................................... 10-6 • Exte nsions in Lieu of Abatement ..................................................................... 10-6 • Termination of HAP Contract ........................................................................... 10-6 F. DETERMINATION OF RESPONSIBILITY [24 CFR 982.404] ......................... 10-7 G. CONSEQUENCES IF FAMILY IS RESPONSIBLE ......................................... 10-8 H. INITIAL HQS INSPECTION ............................................................................. 10-8 I. ANNUAL HQS INSPECTION [24 CFR 982.405 (a) …………………………….10-8 • LEAD-BASED PAINT ...................................................................................... 10-9 • Rent Increases……………………………………………………………………. . 10-9
J. SPECIAL INSPECTIONS .............................................................................. 10-10 K. QUALITY CONTROL INSPECTIONS ........................................................... 10-10
CHAPTER 11
OWNER RENTS, RENT REASONABLENESS, AND PAYMENT STANDARDS
A. PAYMENT STANDARDS FOR IN THE HOUSING CHOICE VOUCHER
PROGRAM [24 CFR 982.503] ......................................................................... 11-1 B. ADJUSTMENTS TO PAYMENT STANDARDS [24 CFR 982.503]……………11-1 • File Documentation .......................................................................................... 11-3 C. CALCULATION OF HAP [24 CFR 982.505, 982.508]………………… .... …….11-3 • Maximum Family Share at Initial Occupancy ................................................... 11-4 D. PAYMENTS TO OWNERS [24 CFR 982.451]................................................. 11-4 E. RENT REASONABLENESS DETERMINATIONS [24 CF
R 982.507] .............. 11-5
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
TOC-ix
CHAPTER 12
REEXAMINATIONS
A. ANNUAL ACTIVITIES [24 CFR 982.401, 982.516, 982.517, 982.519] ............ 12-1 B. ANNUAL RE-EXAMINATION [24 CFR 5.609, 982.516] .................................. 12-2 • Re-examination Notice to the Family ............................................................... 12-3 • Collection of Information .................................................................................. 12-3 • Requirements to Attend ................................................................................... 12-4 • Failure to Respond to Notification for Re-examination .................................... 12-4 • Documents Required from the Family ............................................................. 12-4 • Verification of Information ................................................................................ 12-5 • Moves with Continued Assistance ................................................................... 12-6 • Tenant Rent Increases .................................................................................... 12-6 • Contract Rent Increase .................................................................................... 12-6 • Tenant Rent Decreases ................................................................................... 12-7 • Families Ineligible for Current HCV Size ......................................................... 12-7 • Families Ineligible for continued Rental Assistance [24 CFR 982.455] ............ 12-7 • Changes in the Lease and Rent ...................................................................... 12-8 C. REPORTING INTERIM CHANGES [24 CFR 982.516, 982.553] .................... 12-9 • Increases in Income ........................................................................................ 12-9 • Decreases in Income ....................................................................................... 12-9 • Tenant Rent Decreases ................................................................................... 12-9 • Tenant Rent increases .................................................................................. 12-10 • Contract Rent Increase ………………………………………………………… 12-10 • Administrative Corrections ............................................................................. 12-10 • Other Interim Reporting Issues ...................................................................... 12-10 D. NOTIFICATION OF RESULTS OF RE-EXAMINATIONS .............................. 12-11 E. TIMELY REPORTING OF CHANGES IN INCOME AND ASSETS ............... 12-11 • Standard for Timel y Reporting of Changes ................................................... 12-11 • Procedures when Change is Reported by Tenant in a Timely Manner .......... 12-12 • Procedures when Change is not Reported by Tenant in a Timely Manner .... 12-12 • Procedures when change is not Processed by CoPHD in a Timely Manner . 12-13 F. REPORTING OF CHANGES IN FAMILY COMPOSITION [24 CFR
982.505,982.516, 982.315] ........................................................................... 12-14 • Increase in Family Size ................................................................................. 12-14 • Decrease in Family Size ................................................................................ 12-14 • Family Break-Up ............................................................................................ 12-15 • Remaining Family Member ............................................................................ 12-16 G. CONTINUANCE OF ASSISTANCE FOR "MIXED" FAMILIES
[ 24CFR 5.504, 5.518] ................................................................................... 12-16 H. ENTERPRISES INCOME VERIFICATION SYSTEM DISCREPANCY……...12-16
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
TOC-x
CHAPTER 13
MOVES WITH CONTINUED ASSISTANCE/PORTABILITY
A. ALLOWABLE MOVES [24 CFR 982.314, 982.552] ......................................... 13-1 B. RESTRICTIONS ON MOVES ........................................................................ 13-1 C. PROCEDURE FOR MOVES ........................................................................... 13-3 • Move requests submitted during the family’s annual re-examination ………..13-3 • Move requests submitted other than at the family’s annual re-examination….13-4 • Ti me of HAP Contract Change………………………………………………….. 13-5 D. P ORTABILITY [24 CFR 982.353] .................................................................... 13-5 E. OUTGOING PORTABILITY [24 CFR 982.353, 982.355] ................................. 13-5 • Restrictions on Portability ................................................................................ 13-6 • Outgoing Portability Procedures ...................................................................... 13-6 • Receiving PHA responsibilities…………………………………………………….13-7 • P ayment to the Receiving PHA ....................................................................... 13-7 F. INCOMING PORTABILITY [24 CFR 982.355] ................................................. 13-8 • Required Documents ....................................................................................... 13-9 • Incom ing Portability Procedures ...................................................................... 13-9 • Extension of Housing Choice Voucher …………………………………………13-10 • Suspension of Housing Choice Voucher……………………………………… 13-10 • Absorption or Administration.......................................................................... 13-10 • Income and TTP of Incoming Portables ........................................................ 13-10 • Request for Tenancy Approval ...................................................................... 13-11 • Denial or Termination of Assistance Prior to Lease Up……………………….13-11 • Billing Procedures …………………………………………………………………13-11
• Termination of Billing .................................................................................... 13-11 • Mobility .......................................................................................................... 13-12 • Special Purpose Vouchers ............................................................................ 13-12
CHAPTER 14
CONTRACT TERMINATIONS
A. TERMINATION BY THE FAMILY: MOVES [24 CFR 982.314(c)(2)] ............... 14-1 B. TERMINATION BY THE OWNER: EV ICTIONS [24 CFR 982.310] ................. 14-2 C. TERMINATION OF CONTRACT BY CoPHD OR DUE TO BREACH OF CONTRACT [24 CFR 982.404(a), 982.453, 982.454, 982.455, 982.306] ....... 14-3 D. AUTOMATIC TERMINATION OF RENTAL ASSISTANCE CONTRACTS .....14-5 E. TERMINATION DUE TO INELIGIBLE IMMIGRATION STATUS
[24 CFR 5.514, 5.500-5.528] ........................................................................... 14-5
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
TOC-xi
CHAPTER 14- continued
F. TERMINATION DUE TO FORECLOSURE ..................................................... 14-5 G. TERMINATION OF HAP CONTRACT AND HOUSING CHOICE
VOUCHERS: INSUFFICIENT FUNDING [24 CFR 982.454] ........................... 14-6 • Notice of Termination Due to Insufficient Funding………………………………14-7 • Notice of Termination to Initial PHA (Outgoing Billable Portables Vouchers) .. 14-7 • Placement on the CoPHD Reissue Section HCVP Waiting List ...................... 14-8
CHAPTER 15
DENIAL OR TERMINATION OF ASSISTANCE
A. FORMS OF DENIAL/TERMINATION [24 CFR 982.552] ................................. 15-1 Requirement to Deny Admission or Terminate Assistance
[24 CFR 982.552(b) ......................................................................................... 15-2 • Mandatory Prohibition of Assistance……………………………………………...15-2 • Grounds for Denial or Termination of Assistance [24 CFR 982.552(c)(1)] ...... 15-2 • CoPHD Consideration of Circumstances in Determining Denial or • Termination of Assistance for Family [24 CFR 982.552) ................................. 15-3 B. OBLIGATIONS OF THE RENTAL ASSISTANCE PROGRAM PARTICIPANT FAMILY [24 CFR 982.551] .............................................................................. 15-5 • CoPHD Adopted Obligations of the Rental Assistance Program………………15-6 • HQS Breach .................................................................................................... 15-9 • Lease Violations .............................................................................................. 15-9 • Notification of Eviction ..................................................................................... 15-9 • Additions to Family Composition ..................................................................... 15-9 • Family Member Moves Out............................................................................ 15-10 • Limitation on Profit-Making Activity in Unit ..................................................... 15-10 • Interest in Unit …………………………………………………………………...15-11 • Fraud ……………………………………………………………………………….15-11
• Immigration Status……………………………………………………………… 15-12
• HUD-VASH Program Termination ……………………………………………15-12 • Drug Related and Violent Criminal Activity…………………………………….. 15-12 • Criminals and Alcohol Abusers ………………………………………………….15-13 • Confidentiality of Criminal Records ................................................................ 15-14 • Evidence of Criminal Activity …………………………………………………….15-14 • Use of Criminal Record …………………………………………………………..15-14
• Required Evidence ………………………………………………………………..15-14
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
TOC-xii
CHAPTER 15 – continued
• Notice of Proposed Termination of Assistance .............................................. 15-15 C. PROCEDURES FOR NON-CITIZENS [24 CFR 5.514(b),(1),(i),(ii), (iii), (iv) and 5.516, 5.518 ...................................................................................... 15-15 • Delay, Denial, Reduction or Termination of Assistance ................................. 15-15 • Methods of Verification and Time Allowed .................................................... 15-16 • Assistance for Mixed Families ....................................................................... 15-16 • False or Incomplete Information .................................................................... 15-17 • Procedure for Denial or Termination [24 CFR 5.514, (2), (d), (1), (2), (3), (4), (5), (6)] .................................................................................................... 15-17 D. AUTOMATIC TERMINATION OF HOUSING ASSISTANCE PAYMENTS CONTRACTS[24 CFR 982.455] .................................................................... 15-18 E. AUTOMATIC TERMINATION OF PARTICIPATION…………………………..15-18 F. OPTION NOT TO TERMINATE FOR MISREPRESENTATION
[24 CFR 982.551, 982.552(c) (vii)] ................................................................ 15-19 G. MISREPRESENTATION IN COLLUSION WITH OWNER
[24 CFR 982.551, 982.552(c)] ....................................................................... 15-19 H. MISSED APPOINTMENTS AND DEADLINES [24 CFR 982.551, 982.552(a)] .................................................................................................... 15-19 • Procedure when Appointments are Missed or Information not Provided ....... 15-20 I. VOLUNTARY TERMINATION……………………………………………………15-20
CHAPTER 16
PROPETY OWNER DISAPPROVAL AND RESTRICTION
A. DISAPPROVAL OF OWNER [24 CFR 982.306, 982.54(d)(8)] ....................... 16-1 B. OWNER RESTRICTIONS AND PENALTIES [24 CFR 982.453] ..................... 16-2 • Disapproval of Owners/Participation Restrictions ............................................ 16-3 C. OTHER REMEDIES FOR OWNER VIOLATIONS ........................................... 16-3 • Overpayments ................................................................................................. 16-3
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
TOC-xiii
CHAPTER 17
PROPERTY OWNER OR FAMILY DEBTS TO THE CoPHD
A. REVIEW OF OVERPAYMENT OF RENTAL ASSISTANCE BENEFITS…….17-1 B. REPAYMENT AGREEMENT FOR FAMILIES
[24 CFR 982.552(c) v,vi,vii] ............................................................................. 17-2 • Late Payments ................................................................................................. 17-2 • Repayment Schedule for Monies Owed to the CoPHD ................................... 17-3 • Guidelines for Repayment Agreements ........................................................... 17-3 • Default of Repayment Agreement ...................................................................17-4 • Additional Monies Owed .................................................................................. 17-4 C. DEBTS DUE TO FRAUD/NON-REPORTING OF INFORMATION ................ 17-4 • Family Error/Late Reporting............................................................................. 17-5 • Program Fraud ................................................................................................ 17-5 D. OWNER DEBTS TO THE CoPHD ................................................................... 17-5 E. PAYMENT COLLECTED………………………………………………………… 17-5
F. WRITING OFF DEBTS .................................................................................... 17-6
CHAPTER 18
COMPLAINTS AND APPEALS
A. COMPLAINTS TO THE CoPHD ...................................................................... 18-1 • Categories of Complaints…………………………………………………………..18-1
• Unauthorized Persons ..................................................................................... 18-2 • Unreported Income from Business conducted in the Assisted Unit …………..18-3 • Unreported Income .......................................................................................... 18-3 • Complaints of Drug and Criminal Activity ........................................................ 18-4 • Delinquency of Tenant Rent to Owner ............................................................. 18-4 • Special Inspection Due to Alleged Violations of HQS ...................................... 18-4 B. INFORMAL REVIEW PROCEDURES ...................................................... ……18-5 C. C oPHD INFORMAL REVIEW PROCEDURES................................................ 18-6 D. C oPHD LOCAL PREFERENCE DENIALS…………………………………….…18-6
E. INFORMAL HEARING PROCEDURES [24 CFR 982.555,
982.54(d) (13)]… ......................................………………………………………..18-7 • Notification of Hearing ..................................................................................... 18-8 • C oPHD Informal Hearing Procedures .............................................................. 18-9 F. HEARING AND APPEAL PROVISIONS FOR "RESTRICTIONS ON
ASSISTAN
CE TO NON-CITIZENS" [24 CFR, PART 5, Subpart E ] ............. 18-10 • U S Department of Homeland Security Determination of Ineligibility .............. 18-10 G. MITIGATING CIRCUMSTANCES FOR APPLICANTS/PARTICIPANTS WITH DISABILITIES ...................................................................................... 18-11 DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
TOC-xiv
CHAPTER 19
PROJECT-BASED PROGRAM
A. HUD SUBMISSION ........................................................................................ 19-1 B. OWNER APPLICATION SUBMISSION [24CFR 983.51] ................................ 19-2 C ELIGIBLE AND INELIGIBLE PROPERTIES [24 CFR 983.9 & 983.53] ........... 19-3 D. SPECIAL HOUSING TYPES ........................................................................... 19-5 E. DECONCENTRATION OF PROVERTY AND EXPANSION OF HOUSING AND ECONOMIC OPPORTUNITIES…………… ... ……………………………..19-5
F. AGREEMENT & SECTION 8 PROJECT BASED HOUSING ASSISTANCE PAYMENTS CONTRACT ........................................................................ ……19-5 G. REDUCTION OF UNITS……………………………………………………………19-7
H. RESPONSIBILITIES OF THE CoPHD [24 CFR 983.201] ............................... 19-7 I. RESPONSIBILITIES OF THE OWNER [24 CFR 983.208 &
24 CFR 982.452 ............................................................................................. .19-7 J. FAMILY PARTICIPATION [24 CFR 983.251] .... …………………………………19-8 K. BRIEFING SESSIONS FOR PBVP PARTICIPANTS [24 CFR 983.252] .....….19-9 L. PHYSICAL CONDITION STANDARDS & PHYSICAL
INSPECTION REQUIREMENTS .......................................................... ……....19-9 M. MAINTENANCE, OPERATION AND INSPECTION [24 CFR 983.207] .... ……19-9 N. OVERCROWDED AND UNDEROCCUPIED UNITS [24 CFR 983.259] ....... 19-10 O. ASSISTED TENANCY AND TERMINATION OF TENANCY
[24 CFR 983.206] ................................................................. …………………19-10 P. RENT AND HOUSING ASSISTANCE PAYMENT [24 CFR 983.302] .. ……..19-10 Q. LIMITS ON INITIAL RENT TO OWNER [24 CFR 983.301] .......... …………...19-10 R. ANNUAL ADJUSTMENT OF RENT TO OWNER [24 CFR 983.302] ........... 19-11 S. SPECIAL ADJUSTMENT OF THE RENT TO OWNER [24 CFR 983.301] ….19-11 T. REASONABLE RENT [24 CFR 983.303] ..................................................... .19-12 U. VACANT UNITS [24 CFR 983.352] ............................................................... 19-12 V. CONVERSION OF SECTION 8 PROJECT-BASED ASSISTANCE TO TENANT-BASED ASSISTANCE [PIH NOTICE 99-40,
SEPTEMBER 1, 1999] ...................................................................... ……….19-12 W. MOVES WITH CONTINUED RENTAL ASSISTANCE .................................. 19-14 X. FAMILY RIGHT TO MOVE [24 CFR 983.260] ................................... ……….19-14 Y. PHA OWNED UNITS…………………………………………………………… 19- 15
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
TOC-xv
CHAPTER 20
SUPPORTIVE HOUSING PROGRAMS
A. SHELTER PLUS CARE PROGRAM/ CONTINUUM OF CARE ........................ 20-1 • Supportive Service Provider/Sponsor Agency …………………………………20-1 • Coordinated Entry System …………………………………………………………20-2
• Eligibility Determinations ………………………………………………………...20-2 • Portability & Mobility ……………………………………………………………… 20-3 • HQS and Acceptable Housing Configurations ………………………………….20-3 • Transfers to HCVP …………………………………………………………………20-4
• Supportive Services Match ………………………………………………………..20-4 • Surviving or Remaining Members of a Family (CoC Program Only) …………20-4 • Family Absence from Unit ……………………………………………………… 20-5 • Family Obligations and Statement of Family Responsibility……………………20-5 • Terminating Participants …………………………………………………………20-5 • Conflict between HCVP and S+C Regulations ………………………………...20-6 • Certification ………………………………………………………………………….20-6
• Annual Reexamination …………………………………………………………….20-6
• Rental Negotiation ………………………………………………………………….20-6
• Inspection……………………………………………………………………………20-6
• Vacancy Loss/Damage Claim …………………………………………………… 20-7
B. Housing Opportunities for Persons with AIDS Program (HOPWA) [24 CFR 574.300] ............................................................................................ 20-7 • Eligibility Determinations …………………………………………………………..20-7 • Certification ………………………………………………………………………….20-8
• Annual Reexamination & Conversion to HCVP …………………………………20-8 • Rental Negotiation ………………………………………………………………….20-8
• Inspection ……………………………………………………………………………20-9
• Termination …………………………………………………………………………20-9
C. FAMILY SELF SUFFICIENCY (FSS) PROGRAM [24 CFR 984.101] ……… 20-9 D. HOME TENANT- BASED RENTAL ASSISTANCE PROGRAM ……………. .20-9 E. EMERGENCY RENTAL ASSISTANCE DEPOSIT PROGRAM (ERAD) …….20-9
CHAPTER 21
CONSOLIDATED ANNUAL CONTRIBUTION CONTRACT
A. ANNUAL CONTRIBUTION CONTRACT ]24 CFR 982.151] ............................ 21-1 B. BUDGET AUTHORITY AND CONTRACT AUTHORITY
[24 CFR 982.151(b)] ........................................................................................ 21-1 C. BUDGET AND EXPENDITURES [24 CFR 982.157] ....................................... 21-2 DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
TOC-xvi
CHAPTER 21 – continued
D. HOUSING ASSISTANCE PAYMENTS ........................................................... 21-2 E. ADMINISTRATIVE FEES [24 CFR 982.152] ................................................... 21-2 F. ANNUAL CONTRIBUTION RESERVE ACCOUNT [24 CFR 982.154] ............ 21-3 G. ADMINISTRATIVE FEE RESERVE [24 CFR 982.155] ................................... 21-3 H. PROGRAM FUNDS DEPOSITARY [24 CFR 982.156] ................................... 21-3 I. PR OGRAM ACCOUNTS AND RECORDS [24 CFR 982.158] ........................ 21-4 J. AUDIT REQUIREMENTS [24 CFR 982.159] ................................................... 21-4
CHAPTER 22
RECORDS MANAGEMENT
A. PROGRAM RECORDS [24 CFR 982.158] (c), (e), (f)] .................................... 22-1 B. EMPHASYS COMPUTER SOLUTIONS [24 CFR 908.104] ............................ 22-3 C. CASE FILES .................................................................................................... 22-3 D. FILE PURGING ............................................................................................... 22-7 • Inspections ...................................................................................................... 22-8 • Inspection Correspondence ............................................................................. 22-9 • Admissions/Issuance ..................................................................................... 22-10 • Vital Statistics ................................................................................................ 22-10 • Occupancy Correspondence ......................................................................... 22-10 • Occupancy .................................................................................................... 22-14 E. FILE ORDER ………………………………………………………………………22-15
• Electronic Files……………………………………………………………………..22-15
CHAPTER 23
PROGRAM INTEGRITY ADDENDUM
A. CRITERIA FOR INVESTIGATION OF SUSPECTED ABUSE AND FRAUD ... 23-1 B. STEPS THE CoPHD WILL TAKE TO PREVENT PROGRAM ABUSE
AND FRAUD .................................................................................................... 23-2 C. STEPS THE CoPHD WILL TAKE TO DETECT PROGRAM ABUSE
AND FRAUD .................................................................................................... 23-3
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
TOC-xvii
CHAPTER 23 – continued
D. THE CoPHD’S HANDLING OF ALLEGATIONS OF POSSIBLE ABUSE AND FRAUD .................................................................................................... 23-4 E. HOW THE CoPHD WILL INVESTIGATE ALLEGATIONS OF ABUSE
AND FRAUD .................................................................................................... 23-4 F. PLACEMENT OF DOCUMENTS, EVIDENCE AND STATEMENTS
OBTAINED BY THE CoPHD ........................................................................... 23-5 G. CONCLUSION OF THE CoPHD’S INVESTIGATIVE REVIEW ....................... 23-5 H. EVALUATION OF THE FINDINGS .................................................................. 23-5 I. ACTION PROCEDURES FOR VIOLATIONS WHICH HAVE
BEEN DOCUMENTED .................................................................................... 23-6
CHAPTER 24
ENTERPRISE INCOME VERIFICATION (EIV)
SECURITY POLICY AND PROCEDURES
A. THE ENTERPRISE INCOME VERIFICATION SYSTEM ............................... .24-1 B. BENEFITS OF THE SYSTEM AND TYPES OF UP FRONT VERIFICATION 24-1 C. WHAT EIV PARTICIPANT DATA IS USED FOR ... ……………………………..24-3 D. EIV DEBTS OWED/TERMINATION REPORT………….……………………….24-4 E. REQUIREMENTS FOR USING EIV DATA........ …………………………………24-4 • Tenant Selection and New Admissions ........................................................... 24-4 • Unreported or Underreported Income .............................................................. 24-4 F. FEDERAL PRIVACY ACT ...................... …………………………………………24-4 • Examples of Federal Privacy Act Violations .................................................... 24-5 G. SECURITY ............................... ……………………………………………………24-5 • Security Awareness Training ........................................................................... 24-5 • Safeguards ...................................................................................................... 24-6 • Administrative Safeguards ............................................................................... 24-7 • Physical Safeguards ........................................................................................ 24-7 • Confidential Participant Files/Envelopes ......................................................... 24-8 • Sealed Confidential Envelopes ........................................................................ 24-8 • Hard Copy Security Violations ......................................................................... 24-8 • D isposal of EIV Information ............................................................................. 24-8 H. REPORTING IMPROPER DISCLOSURES ........ ………………………………. 24-8
• Safeguards Provided by the Federal Privacy Act .......................................... 24-11 I. UPDATING OF PHA POLICIES AND PROCEDURES ................................. 24-12
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
TOC-xviii
CHAPTER 25
SPECIAL HOUSING CHOICE VOUCHER ALLOCATIONS
A. HCV FOR NON-ELDERLY DISABLED PERSONS ......................................... 25-1 • Applicant Eligibility Process ............................................................................. 25-1 • Outreach to Non-Elderly Persons with Disabilities ........................................... 25-1 • Affirmatively Furthering Fair Housing .............................................................. 25-2 • Aging Out of NED ………………………………………… …………………….. 25-2
• Reasonable Accommodation ........................................................................... 25-2 • Housing Search Assistance ............................................................................. 25-2 B. HUD-VETERANS AFFAIRS SUPPORTIVE HOUSING .................................. 25-2 • HUD – VASH Eligibility Criteria…………………………………………………….25-2 • Admission…………………………………………………………………………….25-4
• Calculating Annual Income…………………………………………………………25-4
• HUD VASH – Portability…………………………………………………………….25-5
• Occupancy & Payment Standards … ……………………………………………25-6 • Termination…………………………………………………………………………..25-6
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
1-1
CHAPTER 1
STATEMENT OF POLICIES AND OBJECTIVES
MISSION STATEMENT
The City of Pasadena Housing Department (CoPHD) is dedicated to provid ing affordable housing and community development opportunities for low and moderate income persons to enhance and strengthen our community.
INTRODUCTION
This document serves as the Administrative Plan for the rental assistance programs operated by the CoPHD. These programs are administered by the U. S. Department of Housing and Urban Development (HUD) and participating public housing authority/agencies (PHA) under the Code of Federal Regulations (CFR), Title 24, Subtitle B - Housing and Urban Development, Parts 700-1699 (24 CFR 700-1699) and other applicable federal and local regulations.
This document has been updated to conform with changes enacted as a result of the Housing Opportunities Through Modernization Act (HOTMA) OF 2016. On February 14, 2023, HUD published a final rule implementing Sections 102 and 104 of the HOTMA Act of 2016. Section 102 makes changes to federal regulations addressing i ncome & reexaminations. Section 104 addresses maximum asset limits and asset exceptions. Many of the provisions of HOTMA are intended to streamline administrative processes and reduce burdens on Public Housing Agencies (PHAs), thereby also reducing burdens on participants. This Administrative Plan includes policies which reflect HOTMA provisions related to Sections 102 and 104. HUD is requiring the CoPHD to update this Administrative Plan to reflect HOTMA provisions as of July 1, 2024; however, they are allowing additional time for compliance (no later than January 1, 2025). If HUD issues further implementation guidance for the HOTMA provisions and the CoPHD receives HUD approval, this Administrative Plan will be updated to reflect the final approved changes.
A. RENTAL ASSISTANCE PROGRAMS
The City of Pasadena’s Housing Choice Voucher Program (HCVP) serves the jurisdiction within the City boundaries and is operated under the authority of the CoPHD, which is the designated PHA. Originally established by the City in April of 1989, the former PHA was consolidated with the Redevelopment Agency as the Pasadena Community Development Commission (PCDC), which was a single operating entity and board, created under the Section 34115 of the State of California Health and Safety Code. Upon dissolution of the PCDC in 2012 along with redevelopment agencies state- wide, the CoPHD was implemented. The City Council acts as the CoPHD Board of Directors and exercises all the rights, powers, duties, and responsibilities of the P HA. The CoPHD operates the HCVP and other HUD supportive housing programs.
The City of Pasadena believes that decent, safe and affordable housing is the right of every Pasadena resident.
Furthermore, a key long -term solution for homelessness is the provision of permanent supportive housing.
Therefore, consistent with the Housing Element, the City will facilitate a balanced geographical dispersal of affordable housing, including permanent supportive housing, throughout the City.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
1-2
The HUD rental assistance programs covered by the RAP Administrative Plan include Housing Opportunity for People with AIDS (HOPWA), Continuum of Care (CoC), HOME Investment Partnership (HOME) Tenant-Based Assistance (no funding is currently allocated to this program), Veterans Affairs Supportive Housing (VASH), and Rental Assistance for the Non-elderly Persons with Disabilities (NED). The Housing Department administers the HCVP and the other HUD housing assistance programs on behalf of the CoPHD and the City of Pasadena.
Administration of the RAP and the functions and responsibilities of the CoPHD shall be in compliance with the City of Pasadena Personnel Policies, the HUD Section 8 Regulations, and all Federal, State and local Fair Housing Laws and Regulations.
B. OBJECTIVES
The RAP is designed to achieve six major objectives:
1. To provide decent, safe, and sanitary housing for very low-income families while maintaining their rent payments at an affordable level.
2. To promote freedom of housing choice and spatial de-concentration of very low-income families of all races and ethnic backgrounds.
3. To provide an incentive to owners to rent to very low -income families by offering timely rental assistance payments.
4. To provide housing opportunities for persons with a special needs.
5. To assist the local economy by increasing the occupancy rate and the amount of money flowing to the community.
6. To encourage self-sufficiency of participant families.
C. PUR
POSE OF THE ADMINISTRATIVE PLAN
The purpose of th is Administrative Plan is to establish the policies for carrying out the CoPHD RAP in a manner consistent with HUD requirements and local objectives. This Plan covers both admission and continued participation in these programs. This Plan is a supporting document of the PHA Annual Plan and some sections of the Plan provide information required by the Annual Plan. Policies are the same for all rental assistance programs unless otherwise noted.
The CoPHD is responsible for complying with all changes in HUD regulations pertaining to these programs. If such changes conflict with this Plan, HUD regulations will have precedence. The original Plan and any changes must be approved by the Board of Directors of the CoPHD and a copy provided to HUD.
D. FAIR HOUSING POLICY
[24 CFR 982.5; 24 CFR 8.21(c)(1), 8.24(a), 8.25, and 8.31]
It is the policy of the CoPHD to comply fully with all Federal, State and local nondiscrimination laws and with the rules and regulations governing Fair Housing Act and Equal Opportunity in housing and employment.
The CoPHD shall not deny any family or individual the opportunity to apply for or receive assistance under the RAP on the basis of race, color, sex, religion, creed, national or ethnic origin, age, family or marital status, disability, or sexual orientation.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
1-3
To further its commitment to full compliance with applicable Civil Rights laws, the CoPHD will provide federal/state/local information to HCV holders and other rental assistance applicant/participants regarding discrimination and any recourse available to them if they are victims of discrimination. Such information will be made available during the family briefing session, and all applicable Fair Housing Information and Discrimination Complaint Forms shall be a part of the rental assistance briefing packet.
Except as otherwise provided in 24 CFR 8.21(c)(1), 8.24(a), 8.25, and 8.31, no individual with disabilities shall be denied the benefits of, be excluded from participa tion in, or otherwise be subjected to discrimination because the CoPHD’s facilities are inaccessible to or unusable by persons with disabilities.
Fair housing information and posters will be displayed in CoPHD main lobby in such a manner as to be easily readable.
The CoPHD office is located at 649 North Fair Oaks Avenue, Suite 202, Pasadena, California 91103, and is accessible to persons with disabilities. Accessibility for the hearing impaired is provided by the TDD/TTY telephone number 711.
E. SERVICE POLICY/ACCOMMODATIONS
The service policy is applicable to all situations described in this Administrative Plan when a family initiates contact with the CoPHD, and when the CoPHD initiates contact with a family.
It is the policy of the CoPHD to be service-directed in the administration of its housing programs, and to exercise and demonstrate a high level of professionalism while providing housing services to the families within the CoPHD jurisdiction.
Coupled with this policy is also the desire to extend customer-friendly and thorough service to applicants, participants, owners and others whom may have interest in the CoPHD RAP by making their communication and/or visit to the Housing Department office as pleasant as possible.
An applicant, participant or owner who may be requesting general information regarding the status of their particular case will be required to present picture identification. If picture identification is presented, the receptionist will attempt to assist the person by accessing the Emphasys Elite Computer System to determine the present case status. However, in those situations where the visitor does not have picture identification or a scheduled appointment, and the nature of their question requires the attention of a specific staff member who is not available, the visit or will be asked to complete a “Client Intake Form” and will be advised that the appropriate staff member will contact them within 72 hours. The same response time will be followed for telephone and email inquiries.
Additionally, the CoPHD's policies and practices will be designed to provide assurances that all persons with disabilities will be provided reasonable accommodation so that they may fully access and utilize the housing programs and related services. The availability of accommodations will be made known by including such notice on CoPHD forms and letters to all families, and all requests will be verified so that the CoPHD can properly accommodate the need presented by the disability.
Reasonable Accommodation
The CoPHD is committed to providing reasonable accommodations to persons with disabilities to help ensure an otherwise eligible person receives an equal opportunity to participate in and benefit from its housing programs. The CoPHD policies and practices are designed to provide assurances that persons with disabilities will be given reasonable accommodations, upon request, so that they may fully access and utilize the housing program and related services.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
1-4
Requests for reasonable accommodation may be made verbally or in writing. However, in order to facilitate a request for a reasonable accommodation, the requester is encouraged to complete the Request for a Reasonable Accommodation (RRA) form, which provides information about the type of accommodation requested and third party best able to verify need for and type of accommodation . If assistance is necessary to complete the RRA form, CoPHD staff will facilitate.
Upon receipt of the RRA form, or receiving the information orally, the CoPHD will review the form and mail a Request for Certification of Disability and Housing Needs form to the professional third party that the family has identified to verify the person’s status as a disabled person and their special housing needs. Medical records will not be accepted or retained in the participant file. The CoPHD will also require that the third party provide additional information concerning any specific accommodation that the disabled person may require. The time frame for this process will vary depending on response time from the identified third party.
The CoPHD’s Reasonable Accommodations Review Committee (RA Committee) is responsible for reviewing the RRA made by applicants and/or participants of the HCVP. The RA Committee is comprised of the Housing Assistant who is assigned to the family’s case , the two Housing Specialists and the Housing Assistance Officer, or appropriate designees. The RA Committee will meet on the CoPHD ’s working Fridays to review completed Request for Certification of Disability and Housing Needs forms. Once a decision is made by the RA Committee, the assigned Housing Assistant will be responsible for notifying the family in writing of the RA Committee’s decision on their request for reasonable accommodation.
The notification to the family will also inform the family of their rights to an informal review or informal hearing, if applicable, in accordance to 24 CFR 982.554 and 982.555.
Requests for accommodations must be assessed on a case -by-case basis. If the CoPHD finds that the requested accommodation creates an undue administrative or financial burden, the RA Committee will deny the request and/or present an alternate accommodation that will still meet the need of the person. Examples of alternate accommodations are:
• Payment standard may be adjusted in accordance to the CFR. • Expiring vouchers, with less than 30 days remaining, may be granted an additional 60 days over the 180 days outlined in this Plan.
• Issue appropriate size HCV to relocate to an affordable unit. • Conducting home visits.
• Permitting an authorized designee or advocate to participate in the application or certification process or/and other meetings with CoPHD.
• CoPHD may grant two additional scheduled appointments over the standard written policy (see Chapter 4).
An undue administrative burden is one that requires a fundamental alteration of the essential functions of the CoPHD.
An undue financial burden is one that when considering the available resources of the agency as a whole, the requested accommodation would pose a financial hardship on the CoPHD.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
1-5
All requests for accommodation will be verified with a reliable, knowledgeable professional that can verify the identifiable relationship, or nexus between the requested accommodation(s) and the individual’s disability. The CoPHD is entitled to obtain information that is necessary to evaluate if a requested reasonable accommodation may be necessary because of a disability.
The CoPHD will notify the family in writing within 60 days or longer, pending the return of required documentation and the number of RRA forms to be reviewed , if their request for a reasonable accommodation has been approved or denied. If a person is denied the accommodation or feels that the alternative suggestions are inadequate, they may request an informal review or an informal hearing to review the CoPHD decision. The CoPHD will make two attempts to obtain the required documentation. If the required documentation is not returned by the stated deadline , the CoPHD may make a determination based on the documentation submitted by the family or requester. The CoPHD will not approve the RRA prior to the date it was submitted.
All families with an active voucher must continue to search for a suitable unit, no suspension or tolling will apply during the request for a reasonable accommodation process.
Reasonable accommodation will be made for persons with a disability that require an advocate or accessible offices. A designee will be allowed to provide information, but only with the permission of the person with the disability.
All CoPHD mailings will be made available in an accessible format , upon written request, as a reasonable accommodation if there is no undue administrative or financial burden. The CoPHD will utilize organizations which provide reasonable assistance for hearing/sight-impaired persons when needed.
At the annual re -examination, the CoPHD will review and re -evaluate previously approved reasonable accommodation. The family may be required to complete the Request for Reasonable Accommodation form annually. The CoPHD may mail a Certification of Disability and Housing Needs form to the professional third party indentified by the family to verify the person’s disabled status and housing needs. In addition, families are required to inform the CoPHD in writing within 15 days from the date of the change if their circumstances change as it relates to the accommodation.
F. Violence Against Women Act (VAWA) [24 CFR 5.2005(b)(1)]
The Violence Against Women Act (VAWA) acknowledges domestic violence and sexual assault as a crime, and applies to all victims of domestic violence, dating violence, sexual assault, and stalking, regardless of sex, gender identity, or sexual orientation. The CoPHD has an emergency transfer plan for VAWA victims . The purpose of the plan is to reduce domestic violence, dating violence, sexual assault, and stalking ; to prevent our participants from becoming homeless; to protect them; and to assist them with access to the criminal justice system if there is a need, without jeopardizing their housing.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
1-6
CoPHD will not deny admission on to our waiting list solely because an applicant is or ha s been a victim under VAWA. For program participants, CoPHD will consider VAWA when proposing termination. An incident or incidents of domestic violence will not be construed as a serious or repeated violation of the lease by the victim . Criminal activity directly relating to domestic violence, dating violence, sexual assault, or stalking engaged by the participant’s family members or guests shall not be cause for termination of tenancy if the participant or family member is a victim of VAWA. The CoPHD must offer VAWA forms to anyone being denied admission to the program or being proposed termination, and must evaluate each claim on its own merits.
VAWA may not/does not:
• limit the CoPHD from honoring various court orders issued to victims. • limit the CoPHD from proposing termination for lease violations or family obligations. • supersede any federal, state, or local laws that provide greater protection for victims of abuse.
If a participant asserts VAWA’s protections, the CoPHD may ask the tenant to certify that he or she is a victim of domestic violence, dating violence, or stalking. The CoPHD is not required to demand official documentation and may rely upon the victim’s statement alone. If the CoPHD chooses to request certification, it must do so in writing and give the participant at least 14 business days to provide documentation. The CoPHD will consider an extension of this deadline for reasonable cause. A participant can certify that he or she is a victim by providing any one of the following three documents:
• A completed, signed HUD-approved certification form. The most recent form is HUD-5382. This form is available at the CoPHD or online at http://www.hud.gov/offices/adm/hudclips/. • A statement from a victim service provider, attorney, or medical professional who has helped the victim address incidents of domestic violence, dating violence, or stalking. The professional must state that he or she believes that the incidents of abuse are real. Both the victim and the professional must sign the statement under penalty of perjury.
• A police or court record, such as a protective order. If the tenant fails to provide one of these documents within 14 business days, you may evict the tenant if authorized by otherwise applicable law and lease provisions.
Confidentiality:
Any information provide to CoPHD regarding domestic violence, dating violence, sexual assault or stalking, including the fact that an individual is a victim of such violence or stalking:
• Must be retained in confidence
• Must not be entered into a shared database
• Must not be provided to any related entity unless the victim consents or requests or required in a termination proceedings or required by law.
CoPHD must provide notice to HCV applicants and participants of their rights under this law, including the right to confidentiality. CoPHD must also notify owners/mangers of their rights and obligations under VAWA.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
1-7
G. Limited English Proficiency (LEP)
The CoPHD will do its best, within reason, to assist person s with Limited English Proficiency (LEP). The CoPHD has bilingual staff to assist non-English speaking persons and to translate documents into Spanish and Armenian. However, other languages and certain HUD translated documents when available will be provided. When program forms are provided and signed in a language other than English, the same forms in English must be signed. Translations by an outside certified translator may be used in certain situations.
The CoPHD provides interpretation to any applicant, participant, or other customer who has business with the CoPHD and who has limited English proficiency. The CoPHD utilizes a “Your Right to an Interpreter” point-to-language card to determine the language spoken by the customer. Interpretation services may be provided by CoPHD staff who are certified as bilingual, other City staff who have been certified as bilingual and are included on the City of Pasadena’s bilingual staff list. If the customer speaks a language which is not covered by CoPHD or City staff, the CoPHD will utilize the Language Line to provide interpretation services.
For more information on the CoPHD’s LEP policies, please see the Language Access Plan.
H. FAMILY OUTREACH
The CoPHD will publicize and disseminate information to make known the availability of housing assistance and related services for very low-income families. When the CoPHD's waiting list is open, the CoPHD will publicize the availability and nature of housing assistance for very low-income families in a newspaper of general circulation, minority media, and by other suitable means. Public notices will also be provided in Spanish and Armenian.
To reach persons who cannot read, CoPHD may distribute fact sheets to broadcasting media, and initiate personal contacts with members of the news media and community service personnel. The CoPHD may also utilize public service announcements. The CoPHD may communicate the status of housing availability to other ser vice providers in the community, and advise them of housing eligibility factors and guidelines in order that they can make proper referrals for housing assistance. All information will be disseminated in accordance with Equal Opportunity and HUD guidelines for Fair Housing.
I. OWNER OUTREACH
The CoPHD encourages owners of decent, safe and sanitary housing units to lease to families receiving rental assistance. The Housing Department has a free housing search website which is called Pasadena Housing Search and it is located at http://pasadenahousingsearch.com . It has free listings and families are able to search for properties in the City of Pasadena and the County of Los Angeles. PasadenaHousingSearch.com is a partner website and shares listings with the Los Angeles County Housing Resource Center ( http://housing.lacounty.gov) which posts housing data, information and resources for the entire County of Los Angeles. Families and owners can list and search from either site.
The CoP
HD will also undertake the following activities to further its outreach efforts:
1. Actively recruit owners and when appropriate grant exception rents for units located in areas with rents higher than the current HUD published Fair Market Rents (FMR) or the average city market rents.
2. Initiate contact with owners and managers by conducting formal and informal discussions and meetings.
3. Provide printed materials such as owner’s packets, program brochures, federal regulations, etc., to acquaint owners and managers with the opportunities available under the program.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
1-8
4. Periodically evaluate the distribution of assisted families to identify areas within the jurisdiction where owner outreach should be targeted.
5. Conduct periodic meetings with participating owners to improve owner relations and to recruit new owners.
6. Attend landlords and industry interest program events each year to outreach and increase landlord/owners awareness and education. Build relationships with organizations such as: Apartment News Publications, Inc.; Foothill Apartment Association (FAA); Apartment Association of Greater Los Angeles (AAGLA) and others.
J. PRIVACY RIGHTS
Applicants and participants, including all adults in their households, are required to sign the Authorization for the Release of Information/Privacy Act Notice (Form HUD 9886) and the CoPHD Authorization for Release of Information. These documents incorporate the Federal Privacy Act Statement and describe the conditions under which HUD and CoPHD will release family information.
In accordance with HUD requirements [CFR 982.307 (b)], the CoPHD will furnish prospective owners with the family's current address as shown in the CoPHD’s records and, if known to the CoPHD , the name, address and telephone number of the owner at the family's current and prior address. This information will only be provided to prospective owners upon receipt of a written request.
A statement of the CoPHD's policy on release of information to prospective owners will be included in the briefing packet provided to the family. Additionally, the following CoPHD practices and procedures will be followed to ensure and safeguard privacy of applicants and program participants:
1. All applicant and participant case files will be stored in the “File Room” in a secure location.
2. CoPHD will not discuss family information contained in files unless there is a business reason to do so.
Inappropriate discussion or improper disclosure of family information by staff will result in disciplinary action.
K. AFFIRMATIVE ACTION/EQUAL OPPORTUNITY
The City of Pasadena is committed to a policy of Affirmative Action/Equal Opportunity. The policy of the City shall be to provide equal opportunity to all persons and to prevent unlawful denial of opportunity to any individual because of race, gender, religio n, creed, sexual orientation, color, marital status, national origins, parental status, ancestry, disability (including AIDS), medical condition and age. The CoPHD will comply with the Affirmative Action/Equal Employment Opportunity Practices Provisions of the City of Pasadena, Chapter 4.09 of the Pasadena Municipal Code, and the rules and regulations adopted pursuant to said ordinance.
L. RULES AND REGULATIONS
This Administrative Plan is set forth to define the CoPHD's local policies for operation of the RAP in the context of Federal laws and regulations. All issues related to the HCVP and the other City administered HUD Programs not addressed in this document are governed by such Federal regulations, HUD Memorandum s, Notices and Guidelines, or other applicable law.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
1-9
M. JURISDICTION
The CoPHD jurisdiction is the City of Pasadena and unincorporated areas of Pasadena, within the County of Los Angeles, California. The CoPHD has entered into interagency agreements for the Veteran Affairs Supportive Housing Program (VASH) with the Housing Authority of the County of Los Angeles (HACoLA) and the Housing Authority City of Los Angeles (HACLA); Refer to Chapter 25, “Special Housing Choice Voucher Allocations”, for more information regarding the VASH interagency agreements. Participants in Continuum of Care Rental Assistance may chose housing outside of the CoPHD’s jurisdiction, provided that this decision is made in accordance with the Tenant -based Rental Assistance Mobility Policy, found here: https://pasadenapartnership.org/wp-conte nt/uploads/2015/10/TBRA-Mobility- Policy.pdf.
N. MONITORING OF PROGRAM PERFORMANCE
Reports will be maintained to:
1. Monitor funding availability and ensure the CoPHD is at maximum lease-up.
2. Track outstanding HCVs for expiration and/or suspension.
3. Track timeliness of annual re-examination/inspection activities.
4. Track number of failed inspections and abatements.
5. Track number and reason for moves and terminations of assistance.
6. Track number of new HCVs issued.
7. Track status of repayment amounts owed the PHA.
8. Track hard-to-house families.
9. Monitor/maintain names pulled from waiting list.
10. Monitor reports in PIH Information Center (PIC)
In order to ensure quality control and compliance with the Section 8 Management Assessment Program (SEMAP) , supervisory staff will perform appropriate levels of review of annual and interim reexaminations, Housing Quality Standards (HQS), new admissions, terminations, and overpayments.
O. TERMINOLOGY
• The City of Pasadena Housing Department is referred to as the CoPHD or Public Housing Agency (PHA) throughout this document.
• Family is used interchangeably with a pplicant or p articipant and also refers to a single person family household.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
1-10
• Tenant is used to refer to participants in terms of their relation to owners.
• Landlord, property owners and owners are used interchangeably.
• New Rule refers to the HUD Occupancy Regulations (subsidy standards) effective October 2, 1995.
• Old Rule refers to the regulations that were superseded on that date, October 2, 1995.
• Unified Rule refers to Part 982 Section 8 Tenant -Based Assistance: Unified Rule for Tenant -Based Assistance under the Rental Certificate Program and the Section 8 Rental Voucher Program dated September 11, 1996.
• Non-Citizens Rule refers to the regulation effective June 19, 1995, restricting assistance to U.S. citizens and eligible immigrants.
• HQS means the Housing Quality Standards required by regulations and enhanced by CoPHD in accordance with State and local ordinances.
• Housing Choice Voucher (HCV) Program refers to the Tenant -Based Rental Assistance Program that essentially replaced the Section 8 Certificate and Voucher Programs, effective October 1, 1999.
• Housing Opportunity Through Modernization Act of 2016 (HOTMA). This new statute provides updates and improvements to statutes that authorize and prescribe for multiple HUD programs. The purpose is to advise HUD programs participants and interested members of the public of the statutory provisions.
See Glossary for addtional terminology.
P. CITY OF PASADENA HOUSING DEPARTMENT WEBSITE
A list of the Housing Department standard forms and informational handouts along with a brief description of each document is available on its website. These forms/handouts can be viewed and printed at http://www.ci.pasadena.ca.us/Housing/Standard_Forms and http://ww5.cityofpasadena.net/housing.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
2-1
CHAPTER 2
ELIGIBILITY FOR ADMISSION
[24 CFR 5, Subparts B, D & E; 24 CFR 982, Subpart E]
INTRODUCTION
This Chapter defines both HUD's and the CoPHD's criteria for admission and denial of admission to the program. The policy of the CoPHD is to strive for objectivity and consistency in applying these criteria when evaluating the eligibility of families who apply. The CoPHD staff will review all information provided by families carefully and without regards to factors other than those defined in this Chapter. Families will be provided the opportunity to explain their circumstances, to furnish additional information, if needed, and to receive an explanation of the basis for any decision made by the CoPHD pertaining to their eligibility.
A. ELIGIBILITY FACTORS
To be eligible for assistance an applicant must meet HUD's criteria, as well as any p ermissible additional criteria established by the CoPHD.
1. An applicant must be a "family."
2. A family must be income-eligible, within the appropriate income limits.
3. A family must have at least one family member who is a citizen, national or non- citizen with eligible immigration status.
For the CoPHD's additional criteria for eligibility, see Section F in this Chapter, "Other Criteria for Admission".
The family's initial eligibility for placement on the waiting list will be made in accordance with the eligibility factors.
Compliance with the eligibility factors will not be verified before the family is placed on the waiting list. E vidence of Citizenship/Eligible Immigrant Status will not be verified until the family is selected from the waiting list for issuance of a Housing Choice Voucher (HCV), unless the CoPH D has determined that such eligibility is in question, regardless of whether or not the family is at or near the top of the waiting list.
B. FAMILY COMPOSITION [24 CFR 5.403, 982.201]
The applicant must qualify as a “family” . A family includes, but not limited to, the following, regardless of actual or perceived sexual orientation, gender identify, or marital status:
1. A single person, who may be an elderly person, displaced person, disabled person, near-elderly person, or any other single person;
2. A group of persons residing together, and such group includes, but is not limited to:
(i) A family with or without children;
(ii) An elderly family;
(iii) A near-elderly family;
(iv) A displaced family;
(v) The remaining member of a tenant family.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
2-2
3. A child who is temporarily away from the home because of placement in foster care may be considered a member of the family. Refer to Chapter 6 Section H of this Plan for additional information.
Head of Household
The Head of Household is the adult member of the family who has been designated by the applicants as the head of the household for the purpose of determining eligibility and rent. The application cannot be re-assigned to another person unless that person was included in the original application and had not been previously removed. Substitutions of another family member as the head of household will be allowed in cases where the original head of household passed away or has been placed in a nursing or convalescent home, as long as that family member is included in the original application.
Live-in Aide [24 CFR 5.403 & 982.316]
A family that consists of one or more elderly, near -elderly or disabled persons may request that the CoPHD approve a live-in aide to reside in the unit and provide necessary supportive services for a family member who is a person with disabilities. The CoPH D must approve a live -in aide if needed as a reasonable accommodation in accordance with 24 CFR 8, to make the program accessible to and usable by the family member with a disability.
The live-in aide:
1. Is determined to be essential to the care and well being to the person with disabilities.
2. Is not obligated for the support of the person(s).
3. Would not be living in the unit except to provide care for the person(s); and
4. Does not have a separate residence.
Once the CoPHD has approved the family’s request for a live -in aide, the person selected by the family must be approved by the CoPHD and owner. The CoPH D may deny to approve a particular person as a live -in aide, or withdraw such approval under the following circumstances:
1. The person commits fraud, bribery or any other corrupt or criminal act in connection with any Federal housing program.
2. The person commits drug-related criminal activity, violent criminal activity, or is subject to a lifetime registration requirement under a State sex offender registration program.
3. The person currently owes rent or other amounts to the CoPH D or to another PHA in connection with Section 8 or public housing assistance.
4. The person is under the age of 18.
5. The person ever convicted of drug- related criminal activity for manufacture or production of methamphetamine on the premises of federally assisted housing.
6. The person is currently a household member.
7. The person would normally be expected to live in the unit.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
2-3
8. The person is the head of household.
9. The person fails to submit the requested information.
10. The person is the owner of the assisted unit or has financial interest in the assisted unit.
11. The care provided is at an “arm’s length transaction”.
12. The person and the participant maintain shared finances.
13. The person is related to the owner.
14. The person is not available to provide the essential care as recommend by the knowledgeable professional.
A live-in aide is treated differently than family members in which:
1. The Income of a live-in aide will not be counted for purposes of determining eligibility or level of benefits.
2. A Live-in aide must have a valid Social Security number and provide Social Security card, birth certificate and California I.D or driver license.
3. A Live-in aide will not be considered as a remaining member of the family.
Relatives are not automatically excluded from being live-in aides, but they must meet all of the elements of the live-in aide definition described above.
The head of household must certify that the care provided is at an “arm ’s length transaction”. The certification must include:
1. The live-in aide was not part of the household prior to receiving rental program assistance.
2. There is no other reason for the aide to reside in the unit.
3. The aide and the participant will maintain separate finances.
A live-in aide may only reside in the unit with the approval of the CoPHD and the property owner. Written verification will be required from a reliable, knowledgeable professional, such as a doctor, social worker, or caseworker. S ee Chapter 7 of this Plan, “Verification Procedures”.
After the person has been approved as the live-in aide, the person cannot be changed to a family member.
Family members of a live-in aide may reside in the unit with the approval of the CoPHD and owner, provided doing so does not increase the subsidy by the cost of an additional bedroom and that the presence of the live -in aide’s family members does not overcrowd the unit.
Family members of the live-in aide will not be considered “family members of the assisted family”. However, they will be required to submit requested information and a criminal background check will be conducted for persons 18 years of age or older. The live-in aide family members will be included in the lease.
The live-in aide does not pay rent or any of the utilities. In addition, the owner or tenant cannot collect or receive monies as rent for the live-in aide from a 3
rd party.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
2-4
The CoPHD has the right to disapprove the person selected as the live -in aide based on the “Other Criteria for Eligibility” described in this Chapter.
Occasional, intermittent, multiple or rotating care givers do not reside in the unit and do not qualify as a live-in aide.
C. INCOME LIMITATIONS [24 CFR 982.201]
In order to be income-eligible for assistance, an applicant must be either:
1. A very low-income family;
2. A low-income family in any of the following categories:
a. A low-income family that is “continuously assisted” under the 1937 Housing Act. A family is continuously assisted if the family has received assistance under any 1937 Housing Act program.
Programs include public housing, all rental assistance programs and all Section 23 programs.
b. A low-income family physically displaced by rental rehabilitation activity under 24 CFR 511.
c. A low-income, non-purchasing family residing in a HOPE 1 or HOPE 2 project.
d. A low-income family that qualifies for voucher assistance as a non-purchasing family residing in a project subject to a homeownership program under §248.173 of this title.
e. A low-income or moderate-income family displaced as a result of the prepayment of the mortgage or voluntary termination of an insurance contract on eligible low-income housing as defined in §248.101 of this title.
3. HUD requires that at least 75% of new admissions during the CoPHD’s fiscal year to be targeted to families at or below 30% of median income. This limitation does not apply to continuously assisted families, enhanced rental voucher recipients or certificate families who are converting to rental vouchers.
To determine if the family is income-eligible, the CoPHD shall compare the annual income of the family to the applicable income limit in effect for the family’s size.
A Single Person Who is Pregnant [24 CFR 982.402]
1. A single pregnant woman must be at or below the income limit for one person.
2. In establishing the appropriate space standards for the number of bedrooms, the CoPHD will consider the size of the household with the unborn child included.
3. The single pregnant woman will not be entitled to the benefit of the $480.00 dependent allowance until after the birth of the child.
Single-Jurisdiction Housing Agencies: The applicable income limit to be used at initial issuance of a HCV is the income limit of the housing agency. CoPHD is a single-jurisdiction housing agency.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
2-5
Families whose annual income exceeds the income limit will be denied admission and offered an informal review.
Families who report zero household income will be referred to local social service agencies to obtain any benefits which they may be eligible to receive.
For admission to the program (initial lease -up), the family’s income must be within the very low -income limit of the jurisdiction where they want to live.
D. MANDATORY SOCIAL SECURITY NUMBERS [24 CFR 5.216]
Applicants and participants must disclose a complete and accurate social security number for each member of the household, including foster children, foster adults and live-in aides with the exception of the following individuals:
1. Those individuals who do not contend to have eligible immigration status (individuals who may be unlawfully present in the United States). These individuals in most instances would not be eligible for a SSN.
a. A family that consists of single household member (including a pregnant individual) who does not have eligible immigration status is not eligible for housing assistance and cannot be housed. b. A family that consists of two or more household members and at least one household member that has eligible immigration status, is classified as a mixed family, and is eligible for prorated assistance in accordance with 24 CFR 5.520. The CoPHD may not deny assistance to mixed families due to non- disclosure of a SSN by an individual who does not contend to have eligible immigration status.
Applicants (including each member or the household) , who are not exempt under Section 5 of the Notice PIH 2010-3 (HA), are required to provide verification of Social Security numbers.
Newborn children do not have an assigned SSN will be:
1. Included as household member and entitled to benefits.
2. CoPHD will generate a PIC Alternate ID.
3. Head of Household (HOH) is allowed 90 days to provide documentation of the Social Security Number.
The CoPHD may extend the time frame for an additional 90 days if unforeseen circumstances outside of the control of the head of household prevented the disclosure of the required documentation.
The addition of new household members (other than by birth) who have an assigned Social Security Number and have not submitted verification will not be:
1. Added to the family composition until the family has complied with the Social Security Number disclosure and verification requirements.
2. Generated a PIC Alternate ID.
Citizens and lawfully present noncitizens who state that they have not been assigned a SSN by the SSA should make such declaration in writing and under penalties of perjury to the CoPHD. The CoPHD will:
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
2-6
1. Not include the citizen or lawfully present non-citizen as household member and will not be entitled to benefits.
2. Not generate a PIC Alternate ID.
3. Allow the Head of Household 90 days to provide documentation of the Social Security Number.
Individuals who previously declared to have eligible immigration status may not change his or her declaration for the purpose of avoiding compliance with the SSN disclosure and documentation requirements or penalties associated with noncompliance with these requirements.
Family members who do not have a valid Social Security number due to their immigration status are exempt from the disclosure requirement. T he individual(s) must sign and date a certification form that s/he does not have a Social Security number.
NOTE: If the family member who is required to execute a certification is less than 18 years old, the certification must be executed by the individual’s parent or guardian unless the person is an emancipated minor.
When a family requests to add a new household member, the applicants or participants must disclose the assigned SSN and provide the CoPHD documentation (See Chapter 7 of this Plan for acceptable documentation). If the family is unable to provide the required documentation, the CoPHD will not add the new household member until the participant has provided the documentation unless they are exempt due to their immigration status.
When a family requests to add a new household member who is under the age of six and does not have an assigned SSN, the family must disclose the assigned SSN and provide the CoPHD documentation within 90 calendar days of the child being added to the household.
If the family is unable to disclose and provide evidence of a SSN within 90 calendar days, the CoPHD will grant the family an additional 90 days period to comply with the SSN disclosure if the CoPHD determines the family was unable to comply with the requirements due to circumstances that could not have reasonably been foreseen and were outside of the family control (i.e. delayed caused by SSA, natural disaster, fire, death in family, etc.).
In accordance with 24 C FR 5.218, the following penalties apply for noncompliance with the SSN disclosure and documentation requirements:
1. The CoPHD will deny eligibility of an applicant if s/he including each member of the household (except non- contending persons) does not disclose a SSN. However, if the applicant is unable to disclose and/or provide documentation of such SSN, who is otherwise eligible to participate in the program, the family will maintain his/her position on the waiting list up to 180 calendar days. If the applicant has not complied with the SSN disclosure and documentation requirement, the CoPHD will disqualify the applicant and remove them from the waiting list.
2. Applicants will be removed from the waiting list for failing to disclose a SSN.
For acceptable reasons for rejection of tenant-provided documentation, see Chapter 7 of this Plan, Section H “Verifying Non-Financial Factors”.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
2-7
E. PENALTIES FOR FAILURE TO DISCLOSE/ DOCUMENT SSNs
The CoPHD must deny assistance for an applicant family if the regulatory requirements for social security number disclosure and documentation are not met. The applicant must disclose and document the social security number for every household member (except non-contending persons) in order to qualify for the program.
The CoPHD must terminate assistance of participant households if the regulatory requirements for social security number disclosure and documentation are not met. Assistance must be terminated for the entire household if these requirements are not met for every non -exempt household member. However, CoPHD must defer termination for a period not to exceed 90 days if it determines that the participant’s failure to meet the requirements was due to unforeseen circumstances outside the control of the family, and if it is reasonably likely that the participant will be able to disclose and document the social security number(s) by the deadline.
The CoPHD must deny admission or terminate the family’s assistance, or both, if the family submits falsified SSN documentation. The head of household may not remove a household member from the family composition in order to avoid these penalties. Prorated assistance is not permitted in this situation.
F. CITIZENSHIP/ELIGIBLE IMMIGRATION STATUS [24 CFR 5, Subpart E]
Housing assistance is available only to those individuals who are U.S. citizens, U.S. nationals, or noncitizens that have eligible immigration status. In order to receive rental assistance, at least one family member must be a U.S. citizen, U. S. national or eligible immigrant. Individuals who are neither may elect not to contend their status. Eligible immigrants are persons who are in one of the six immigrant categories as specified by HUD.
A Freely Associated State (FAS) citizen who is a lawful resident of the U.S. (including territories and possessions) is eligible for housing assistance. The FAS states are:
1. Republic of the Marshal Islands;
2. Federated States of Micronesia;
3. Republic of Palau
For the Citizenship/Eligible Immigration requirement, the status of each member of the family is considered individually before the family's status is defined.
Eligible Families: An eligible family will be comprised of citizen(s), national(s) or non- citizen(s) with eligible immigrant status.
Mixed Families: A mixed family is comprised of citizen(s) or eligible non -citizen(s) and those without citizenship or eligible non-citizen status. A mixed family is eligible for prorated assistance. The family may request an informal hearing if they contest this determination.
Ineligible Families: An ineligible family is one in which no member is a citizen, national or eligible immigrant.
Families will be denied admission and may request an informal hearing.
Non-Citizen Students: Non-citizen student defined by HUD in the non-citizen regulations are not eligible for assistance.
G. OTHER CRITERIA FOR ADMISSION [24 CFR 982.552, 982.553 (C)]
The CoPHD must apply the following criteria, in addition to HUD eligibility criteria, as grounds for denial of admission to the program.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
2-8
1. The family must not have violated any family obligation during a previous participation in RAP during the last five years.
When the CoPHD denies assistance to an applicant with a disability, the applicant may request a review of the family obligation that was violated, if the violation was a result of the disability.
An exception may be granted by the CoPHD if the family member who violated the family obligation is not a current member of the household listed on the application.
2. No family member may have committed fraud, bribery, or any other corrupt or criminal act in connection with any Federal housing program in the last five years unless the CoPHD or PHA has imposed a lifetime restriction from participating due to the nature of the violation(s), crime or offense.
3. Family must have paid any outstanding debt owed the CoPHD or another housing agency as a result of prior participation in any Federal housing program.
4. No member of the family may have engaged in drug-related or violent criminal activity within the last five years.
The CoPHD will not be obligated to investigate information concerning a family's criminal activities other than drug- related or violent criminal activity other related activities as part of the processing of an application for assistance. Initial screening will be limited to routine inquiries of the family and any other information provided to the CoPHD regarding this matter. The inquiries will be standardized and directed to all families by inclusion in the application form.
If the family indicates that they have been arrested or convicted within the prior five years for drug-related or violent criminal activity, the CoPHD shall obtain verification through police/court records.
Verification of any past activity will be done at the initial eligibility review and will include a check of conviction and other records by a law enforcement agency.
5. No family member may have been evicted from federally assisted housing for any reason during the last five years.
6. No family member may have engaged in or threatened abusive or violent behavior toward s CoPHD personnel or personal property of the CoPHD/staff.
(CFR 982.552 5 (ix)
7. No family member may have engaged in any criminal activity which may threaten the health or safety of the owner, property management staff or CoPHD employee. (CFR 982.553 (ii) 4.
8. Family member(s) must not be subject to a lifetime registration requirement under a State sex offender registration program.
9. No family member may have been convicted of drug- related criminal activity involving manufacture or production of methamphetamine on the premises of federally assisted housing.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
2-9
10. Students enrolled in an institution of higher education, who are:
a. Under the age of 24;
b. Not a veteran;
c. Unmarried;
d. Do not have a dependent child;
e. Have not established a separate household from their parents or legal guardians for at least one year prior to applying for rental assistance;
f. Nor claimed as a dependent by parents or legal guardians on their Internal Revenue Services tax return; and
g. Not receiving financial support from parent or legal guardians.
11. The head of household must be at least 18 year of age or an emancipated youth at the time application was submitted.
Legal Capacity of Persons with Disabilities
A person with a disability may meet the requirement of legal capacity to enter into a contract , lease, and/or program forms. However, in cases where the person cannot care for themselves and/or manage their finances documents can be signed on their behalf by:
1. Court-appointed conservator;
2. A person holding a durable power of attorney with respect to the personal and family maintenance for the individual;
3. In the case of a developmentally disabled adult, either the adult or a court-appointment limited conservator depending on whether the court has a specifically granted appropriate power to the limited conservator.
The CoPHD does not require a family to have a live-in aide to meet legal capacity requirements.
The conservator or attorney must provide the following:
1. Valid identification
2. Current address
3. Copy of court order appointing the conservator including current address of the court and subsequent orders relating to the conservatorship.
4. Copy of the instrument that created the durable power of attorney.
5. The conservator or attorney in fact must sign a statement that provides:
a. The mailing address and current phone number of the conservator or attorney in fact; and
b. A certification that he or she will notify the CoPHD immediately in writing of any change in his/her address and phone number and of any change in the status of the conservatorship or power of attorney.
Ability to Meet Program Requirements
The CoPHD will not inquiry about a person’s abilities to meet program requirements that are not made of all applicants or participants.
An applicant with disabilities may be denied admission to an assisted housing program if:
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
2-10
1. He or she is not capable of meeting the essential eligibility requirements with or without supportive services provided by persons other than the CoPHD; and
2. There is no reasonable accommodation that the CoPHD could provide which would enable the applicant to participate in and benefit from the program.
H. SUITABILITY OF FAMILY
The CoPHD may take into consideration any of the additional criteria for admission in Section F above, but may not otherwise screen for factors which relate to the suitability of the applicant family as tenants.
I. CHANGES IN ELIGIBILITY PRIOR TO EFFECTIVE DATE OF THE CONTRACT
Changes that occur during the period between placement on the waiting list and prior to admission may affect the family's eligibility. For example, if a family goes over the income limit prior to lease up, the family will not be eligible for the program. The application will be disqualified and their name will be removed from the waiting list if the applicant is determined ineligible. They will be notified in writing of their ineligible status and their right to an informal review.
J. INELIGIBLE FAMILIES
Families who are determined to be ineligible will be notified in writing of the reason(s) for denial and given an opportunity to request an informal review or an informal hearing. See Chapter 18 of this Plan, "Complaints and Appeals" for additional information about informal reviews and informal hearings.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
3-1
CHAPTER 3
APPLYING FOR ADMISSION
INTRODUCTION
The policy of the CoPHD is to ensure that all families who express an interest in housing assistance are given an equal opportunity to apply, and are treated in a fair and consistent manner. This chapter describes the policies and procedures for enrollment for assistance, placement and denial of placement on the waiting list, and limitations on who may apply.
The primary purpose of the enrollment function is to gather information about the family, but the CoPHD will also utilize this process to provide information to the family so that an accurate and timely decision of eligibility can be made.
Applicants will be placed on the waiting list in accordance with this chapter.
A. HOW TO APPLY
Families who wish to apply for the CoPHD 's Housing Choice Voucher Program (HCVP) must apply during open enrollment. The Co PHD will review different intake methods to determine the most effective method. The CoPHD enrollment process will be in English, Spanish and other languages specific to the general population. During the open enrollment process, families may request a reasonable accommodation to facilitate the enrollment process.
Applicants will be required to provide information on the family composition, income, and local preferences to complete their enrollment. Once the open enrollment process has been completed and the applicants have met the preliminary eligibility requirements, their name will be placed on the waiting list. The information provided will be the basis for the family’s placement on the waiting list. Providing false, incomplete or inaccurate information will be grounds for denial of placement on the waiting list and/or disqualification of application.
The open enrollment period and process for the targeted Supportive Housing Programs may vary from the above, see Chapter 20 of this Plan, “Supportive Housing Services”.
B. OPEN ENROLLMENT [24 CFR 982.206]
The CoPHD will utilize the following procedures for opening the waiting list. When the CoPHD has determined that either; 1) it is in receipt of additional funding allocations from HUD and subsequent amendment to the Consolidated Annual Contributions Contract (ACC) for new vouchers, 2) the existing waiting list has been substantially depleted (200 names or less of applicants with residency preference), 3) the existing waiting list is depleted of applicants for Non-Elderly Disabled (NED) Category #1 and/or 4) the existing waiting list has been in place for 5 years, the CoPHD may open registration to the waiting list for new applicants for a specific category.
Opening of the waiting list (open enrollment) will be advertised through an affirmative marketing strategy, which will give 30-day advance notice prior to open enrollment. The following marketing methods may be utilized to disseminate information regarding open enrollment to the widest spectrum of the general public:
1. Public notifications in local newspapers of general circulation.
2. Public service announcements on local television and cable networks.
3. Announcements in various media outlets.
4. Distribution of notices to social services agencies (i.e., Social Security Administration, Department of Public Social Services, Employment Development Department, City Department of Human Services and DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
3-2
Recreation, Pasadena Senior Center, and local libraries, etc.).
5. Notification and solicitation of current HCVP participants and owners to inform interested households; and
6. Other suitable means for notification of the availability and nature of the HCVP, such as:
a. Special feature articles in local newspapers or on local cable networks which highlight how the program can assist various types of households.
b. Provision of a HCVP fact sheet to the broadcast media.
c. Distribution of pamphlets and other program information in English, Spanish, and other languages specific to the general population, provided it does not cause an und ue financial burden to the CoPHD; and
d. Direct contact with civic organizations and agencies for whose constituents English is not their primary language.
e. City of Pasadena Housing Department website.
The open enrollment process will be reviewed to ascertain which outreach methods have been most effective. Based on the findings reached after examination of the data, the CoPHD will take additional steps to enhance its future outreach efforts.
The Public Notice must contain:
1. The dates and times when families may apply and the method of enrollment.
2. The program(s) for which applications will be taken.
3. A brief description of the program(s).
4. Limitations, if any, on whom may apply.
Suspension of Enrollment Period
If the CoPHD determines that the existing waiting list contains an adequate pool for the use of available program funding, the CoPHD may stop accepting new applications, or may accept only applications meeting criteria adopted by CoPHD.
The open enrollment period shall be long enough to achieve a waiting list adequate to cover projected turnover and new allocations but not create a waiting list that cannot be maintained based on the CoPHD’s resources and funding. The CoPHD will give no less than five days public notice prior to closing the waiting list.
C. HCVP APPLICATION PROCEDURES [24 CFR 982.204 (b)]
The purpose of the application is to allow the CoPHD to assess if the family is preliminarily eligible or ineligible for rental assistance and to determine the family’s placement on the waiting list. The application may contain questions designed to obtain the following information:
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
3-3
1. Name and age of applicant and all household members.
2. Sex and relationship of all household members.
3. Home address and telephone numbers.
4. Mailing address (P.O. Box or other reliable address).
5. Assets owned by any and all household members.
6. Amount(s) and source(s) of income received by household members.
7. Information regarding disabled status.
8. Information related to qualification for preferences.
9. Social Security numbers.
10. Race/ethnicity.
11. Citizenship/eligible immigration status.
12. Convicted of and/or engaged in drug-related or violent criminal activity.
13. Request for reasonable accommodation needed to fully utilize program and services.
14. Program integrity questions regarding previous participation in HUD programs.
Applications will not be accepted under the following conditions:
1. Duplicates that include members from other applicant’s household
2. Incomplete
3. If applicant fails to comply with the open enrollment process and/or instructions
4. If applicant fails to meet the preliminary eligibility requirements
The initial processing of applications will not require an interview. Eligibility will be determined when an availability of a HCV exists for issuance and applicant information has been verified or re- verified no more than 60 days prior to scheduled date for issuance of the HCV. However, if the CoPHD determines that information was falsely provided or purposely omitted, the application will be disqualified.
Applicants are required to update their application online within 15 days of the date of the change regarding family composition, income, and address, as well as any changes in their local preferences.
Applicants are also required to respond to requests from the CoPHD to update information on their application, and/or to determine their continued interest in rental assistance. A pplicants may be notified via email or U . S. postal service.
Applicant wills be requested to return the information to the CoPHD within 15 days if the request is made by mail or within 7 days if the request is made via email. Failure to provide information or to respond to mailings will result in the applicant being removed from the waiting list, see Chapter 18 of this Plan, "Complaints and Appeals".
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
3-4
If a letter is returned by the Post Office with or without a forwarding address , the applicant will be removed from the waiting list without further notice, and the envelope and letter will be maintained in the file.
In the event that any correspondence that is mailed for any purpose is returned by the Post Office, the applicant will be removed from the waiting list due to the family’s failure to report a change of address. In the event where a prior instance occurred due to a change of address was not reported but a forwarding address was provided, the applicant will be removed from the waiting list due to family’s failure to report a change of address in writing to the CoPHD if the correspondence is returned by the Post Office with a forwarding address.
If the family is notified by email and the email is undeliverable due to an invalid email address or inactive email address, the applicant will be removed from the waiting list due to the family’s failure to maintain a valid email address.
D. TIME OF SELECTION
Families will be selected from the waiting list in their preference -determined sequence when funding is available, regardless of family size. When there is insufficient funding available for the family at the top of the list, the CoPHD will not admit any other applicant until funding is available.
A pool of 25 completed eligible applicant files will be maintained to minimize delays in admissions when funding becomes available. However, families will only be offered a HCV in accordance with their placement on the waiting list.
E. COMPLETION OF A FULL APPLICATION INTERVIEW
All applicants will be required to participate in a full application interview with the CoPHD. The applicant will be required to furnish true, complete and accurate information requested by the CoPHD at all times. The CoPHD will review and update the HCVP Application with the family. The applicant will sign and certify that all information is true, complete and accurate.
F. INTERVIEW REQUIREMENTS
The CoPHD utilizes the full application interview to discuss the family's circumstances in greater detail, to clarify information which has been provided by the family, and to ensure that the information is true and complete. The interview is also used as a vehicle to meet the informational needs of the family by providing information about the application and verification process. All adult family members are required to attend the interview and sign CoPHD forms. If the family requires a reasonable accommodation to facilitate the interview, the applicant must submit a written request for reasonable accommodation at least five days prior to the scheduled appointment.
If applicants arrive late to the appointment, applicants may not be seen and this appointment will be considered a missed appointment.
If the applicant arrives to the appointment with incomplete forms, without the requested information, and/or all adult family members, applicants will not be seen and this appointment will be considered a missed appointment.
If the applicant misses the scheduled appointment, a second appointment will be scheduled. If the applicant misses two scheduled/rescheduled appointments, the CoPHD will remove the applicant’s name from the waiting list.
If an applicant fails to appear for their second appointment, their application will be denied unless they can provide acceptable documentation to the CoPHD that an emergency prevented them from calling and/or attending. However, a final appointment will not be granted if the applicant is unable to attend the appointment within 30 days from the missed appointment.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
3-5
If the application is denied based on the reasons mentioned above, the applicant will be notified in writing and offered an opportunity to request an informal review, see Chapter 18 of this Plan, "Complaints and Appeals".
All adult family members must review and sign the following program forms:
1. Form HUD-9886 Authorization for the Release of Information/Privacy Act Notice.
2. Form HUD-1140 Things You Should Know.
3. Federal Privacy Act Statement.
4. CoPHD Authorization for Release of Information.
5. HCVP Application and all supplemental forms required by the CoPHD.
6. Declaration of Section 214 Status.
7. Client Screening – Criminal History Background.
8. What You Should Know About EIV.
9. Debts Owed to the Public Housing Agencies and Terminations.
Information provided by the applicant will be verified. Verifications may not be more than 60 days old at the time of a HCV issuance.
The appointment letter including the Eligibility Fact Sheet will be considered the CoPHD’s first request for information and/or documentation from the family. If the CoPHD determines at or after the interview that additional information and/or documents are required, the CoPHD will request in writing, for the family to submit the information and/or documents within 15 days from the date of the request. This will be considered a second and final request.
If the family fails to submit the requested information by the established deadline after a second and final request has been made, the CoPHD will provide the applicant with a notification of removal of their name from the waiting list. See Chapter 18 of this Plan, "Complaints and Appeals".
G. FINAL DETERMINATION AND NOTIFICATION OF ELIGIBILITY
After the verification process is completed, the CoPHD will make a final determination of eligibility. The CoPHD’s final determination will be based on the information verified and the current eligibility criteria in effect. If the applicant is determined to be eligible, the CoPHD will mail a notification of eligibility. A briefing session will be scheduled for the issuance of a HCV and orientation to the HCVP.
H. INELIGIBLE DUE TO INCONSISTENCIES
When the applicant has submitted all of the requested information and the verifications have been received, the CoPHD must analyze the information to make a final determination of eligibility. However, the family will be determined ineligible if the information is inconsistent and/or conflicting.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
4-1
CHAPTER 4
ESTABLISHING PREFERENCES AND MAINTAINING THE WAITING LIST [24 CFR Part 5, Subpart D; 982.203; 982.204; 982.205; 982.207]
INTRODUCTION
This Chapter defines the eligibility criteria for local preferences which the CoPHD has adopted to meet local housing needs and explains the CoPHD's system of applying them. It is the CoPHD's objective to ensure that applicants are placed in the proper order on the waiting list so that an offer of assistance is not delayed to any applicant or made to any applicant prematurely.
By maintaining a waiting list, the CoPHD will be able to perform the activities which will ensure that an adequate pool of qualified applicants will be available so that program funds are used in a timely manner.
A. APPLICATION POOL
The waiting list will be maintained in accordance with the following guidelines:
1. The applications will be maintained in a database file.
2. All applicants in the pool will be maintained in the order of preference and date and time of the application.
The waiting list will contain the following information for each applicant:
1. Applicant name.
2. Family unit size (number of bedrooms for which family qualifies based on the occupancy standards).
3. Date and time of application.
4. Qualification of any local preferences.
5. Racial or ethnic designation of the head of household (for statistical purposes only).
The order of admission from the waiting list may not be based on family size or on the family unit size for which the family qualifies under the CoPHD occupancy policy. If the CoPHD does not have sufficient funds to subsidize the family unit size of the family at the top of the waiting list, the CoPHD may not skip the top family to admit an applicant with a smaller family unit size.
When HUD awards the CoPHD funding for a specified category of families on the waiting list, the CoPHD must select applicant families in the specified category. The CoPHD must use a single waiting list for admission to its Section 8 Tenant-Based Assistance Program (TBAP).
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
4-2
Special Admissions [24 CFR 982.203]
The CoPHD may admit an applicant that is not on the CoPHD waiting list or without considering the family’s waiting list position when HUD awards program funding that is targeted for families living in specified units. The CoPHD will maintain records showing that the family was admitted with HUD-targeted assistance.
The CoPHD must use the assistance for the families living in these units.
The following are examples of types of program funding that may be targeted for a family living in a specified unit:
1. A family displaced because of demolition or disposition of a public or Indian housing project.
2. A family residing in a HUD- owned multi-family rental housing project when HUD sells, forecloses or demolishes the project.
3. For housing covered by the Low Income Housing Preservation and Resident Homeownership Act of 1990.
a. A non-purchasing family residing in a project subject to a homeownership program.
b. A family displaced because the mortgage prepayment or voluntary termination of a mortgage insurance contract.
c. A family residing in a project covered by a project -based Section 8 HAP contract at or near the end of the contract term; and
4. A non-purchasing family residing in a HOPE 1 or HOPE 2 Project.
Applicants who are admitted under targeted funding which are not identified as a Special Admission would be identified by codes in the automated system.
B. WAITING LIST PREFERENCES [24 CFR 982.207]
The CoPHD has adopted a local preferences system for applicants’ placement on the waiting list and selection of families from the waiting list. Preferences will only be verified at the time the family has been selected from the waiting list.
If an applicant makes a false statement in order to qualify for a preference, the CoPHD will deny the preference. If the applicant falsifies documents in order to qualify for a preference, the application will be disqualified.
C. LOCAL PREFERENCES [2
4 CFR 982.207]
A notice ad opting new local preferences will be publicized and distributed using the same guidelines as those for opening and closing the waiting list.
Persons placed on the waiting list in 2008 or 2014 will be assisted based on the preferences, points, and method of order that were in effect at the time of application, and as set forth in the 2018 and prior administrative plans.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
4-3
The CoPHD will apply the following local preferences, and the associated preference points as assigned in Section G, to any applicants to a waiting list established in or after 2020:
1. Residency preference for a pplicants in which the family lives in the City of Pasadena , or the head of household or spouse is working or who has been notified that they are hired to work in the City of Pasadena, or the head or spouse is attending school in the City of Pasadena.
2. Substandard housing preference for a pplicants who are currently residing in substandard housing or experiencing homelessness (as described below).
3. Disabled preference for a pplicants in which the head of household or spouse is disabled.
4. Veteran preference for ap plicants in which the head of household or spouse is a current member of the U S Armed Forces , a U S Armed Forces veteran, or the surviving spouse of a U S Armed Forces veteran.
Preferences will be verified pursuant to the verification process outlined in Chapter 7 of t h is Plan, “Verification Procedures”. Use of a residency preference will not have the purpose or effect of delaying or otherwise denying admission to the p rogram based on the race, color, ethnic origin, gender, religion, disability, or age of any member of an applicant family.
Res
idency Preference
Applicants who live, work or go to school within the City of Pasadena will be eligible for the residency preference.
Qualification for this preference must be verified through provision of proof of residency, or proof that the head of household or spouse works, has been hired to work, or attends school in the City of Pasadena. Applicants experiencing homelessness within the City of Pasadena will be provided the residency preference. Homelessness may be verified by a Pasadena-based homelessness services agency, a signed certification from a business or household that is aware of the location that the applicant is sleeping, or other appropriate methods that reasonably verify that the applicant is experiencing homelessness in Pasadena..
Employment means regularly scheduled work for at least 15 hours per week. The following are acceptable forms of proof of employment in the City:
· Letter or documentation from the employer stating the applicant (head, spouse, or co-head) is employed on an ongoing basis (or includes a start date) in the City of Pasadena · Paycheck stub with the employer’s address showing the business is located in the City of Pasadena.
The following are acceptable forms of documentation of attending school in the City of Pasadena:
• Verification of the head of household or spouse’s current, and at least half time enrollment in an educational institute located in the City of Pasadena in the form of a class schedule or transcript.
Substandard Housing
Applicants that qualify for the substandard housing preference are those whose dwelling meets one or more of the following criteria, provided that the family did not cause the condition, or are experiencing homelessness as defined below:
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
4-4
1. Is dilapidated as cited by officials of a code enforcement office and does not provide safe, adequate shelter; has one or more critical defects or a combination of defects requiring considerable repair; endangers the health, safety, and well-being of the family.
2. Does not have operable indoor plumbing.
3. Does not have a usable flush toilet in the unit for the exclusive use of the family.
4. Does not have usable bathtub or shower in unit for exclusive family use.
5. Does not have adequate, safe electrical service.
6. Does not have an adequate, safe source of heat.
7. Does not have a kitchen. (Single Room Occupancy [SRO] Housing is not substandard solely because it does not contain sanitary and/or food preparation facilities in the unit.)
8. Has been declared unfit for habitation by a government agency.
9. Is overcrowded according to HQS. Note: Persons who reside as part of a family unit shall not be considered a separate family unit for substandard housing definition preference purposes.
Applicants living in Public Housing or publicly assisted housing shall not be denied this preference if unit meets the criteria for the substandard preference.
10. An applicant who is a "homeless individual or f amily" will be provided the substandard housing preference . A "homeless individual or family" is one who:
Lacks a fixed, regular, and adequate nighttime residence and has a primary nighttime residence that is:
a. a public or private place not meant for human habitation; b. a publicly or privately operated shelter designated to provide temporary living arrangements (including congregate shelters, transitional housing, and hotels and motels paid for by charitable organizations or by federal, state and local government programs); or
c. Is exiting an institution where (s)he has resided for 90 days or less and who resided in an emergency shelter or place not meant for human habitation immediately before entering that institution Families who are residing with friends or relatives on a temporary basis are not considered homeless for the purposes of this preference.
Veteran Preference
The head of household or spouse is an active member of the U S Armed Forces , a U S Armed Forces veteran or surviving spouse of a U S Armed Forces veteran who has been honorably discharged.
Ex-spouses of veterans are not considered the surviving spouse.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
4-5
D. LI MITED PREFERENCES (PIH NOTICE 2013 -15)
T
he CoPHD offer s the following limited preferences for persons experiencing homelessness and for households exiting specific homeless programs, dependent on the availability of vouchers and the funding to support them:
H
ouse
holds exiting Rapid Rehousing programs: 10 Tenant-Based HCV Households exiting non-PBV Permanent Supportive Housing: 5 Tenant-Based HCV Housing Works Supportive Housing Program: 20 Tenant -Based HCV paired with Continuum of Care supportive services funding
R
eferrals for these limited preference vouchers will be from Pasadena -based homeless programs utilizing the SPA 3 Coordinated Entry System.
R
eferred households for any limited preference must meet the eligibility requirements for admission to the HCV program as outlined in Chapter 2 of this document.
E. E MERGENCY HOUSING VOUCHER PREFERENCE (PIH -NOTICE 2025-19) The CoPHD was awarded Emergency Housing Vouchers (EHV) from HUD under the American Rescue Plan of 2021. Rental assistance for EHV participants was expected to continue through 2030. However, on March 6, 2025, Public Housing Agencies (PHAs) across the country, including the CoPHD, were informed by HUD that funding for the program would end in 2026.
HUD encouraged PHAs in PIH Notice 2025-19 to transition EHV households whose assistance is ending to the HCV program so that EHV families do not lose assistance and potentially face homelessness. HUD requires PHAs who wish to transition EHV participants to provide a preference for EHV participants in the Administrative Plan.
The CoPHD requested a waiver from HUD to place all EHV participants on the HCV waiting list rather than require them to apply individually. That waiver was approved on September 23, 2025.
The CoPHD provides preference for up to 85 EHV households and will place these households on the HCV waiting list. The CoPHD must have a voucher available and adequate funding to support it before admitting an EHV participant into the HCV program.
F. P REFERENCE FOR PARTICIPANTS IN TIME- LIMITED SUBSIDY PROGRAMS When HCVs are available, the CoPHD reserves the option to move participants in time- limited subsidy programs administered by the CoPHD to preserve continuity of assistance . Funding must be available to support a transfer to HCV at the time of transfer.
Referred households for any limited preference must meet the eligibility requirements for admission to the HCV program as outlined in Chapter 2 of this document.
G
. PREFERENCE ELIGIBILITY
C
hange in Circumstances
C
hanges in an applicant's circumstances while on the waiting list may affect the family's preference eligibility.
Applicants are required to notify the CoPHD in writing when their circumstances change.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
4-6
When an applicant claims an additional preference, s/he will be placed on the waiting list in the appropriate order determined by the newly claimed preference.
H. ORDER OF SELECTION [24 CFR 982.207]
The order of selection is based on the CoPHD 's system for weighing preferences.
Local Preferences
Local preferences will be used to select families from the waiting list. The CoPHD has selected the following system to apply ranking preferences. All local preferences will be weighed as follows:
a. Residency Preference: 20 pts.
b. Disabled Preference: 5 pts
c. Substandard Housing: 5 pts
d. Veteran’s Preference: 5 pts
Among Applicants with Equal Preference Status
Among applicants with equal preference status, the waiting list will be organized by date and time that each application was submitted to the CoPHD.
I. FINAL VERIFICATION OF PREFERENCES
Preference information on applications will be updated as applicants are selected from the waiting list. At that time, applicants will be required to submit the appropriate documentation to support their claim of preference. In order to qualify for a preference, the documentation submitted by the applicant must support the claim for the preference as defined by HUD and/or the CoPHD.
An applicant will be disqualified if the applicant submitted false information on any previous occasion when claiming preferences.
J. PREFERENCE DENIAL
If the CoPHD denies a preference, the CoPHD will notify the applicant in writing of the reasons the preference was denied and offer the applicant an opportunity to request an informal review of the determination. If the preference denial is upheld as a result of the informal review, or the applicant does not request an informal review , the applicant will be placed on the waiting list without benefit of the preference. Applicants may exercise other rights if they believe they have been discriminated against.
K. REMOVAL FROM WAITING LIST AND PURGING POLICY [2
4 CFR 982.204(c)]
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
4-7
The CoPHD will update the waiting list as needed to ensure that all applicants and applicant information is current and timely. These updates will occur through two methods: an annual outreach to all applicants on the list to determine continued interest and through the process of reaching out to applicants when they are in the next group to selected from the waiting list based on preferences and position on the waiting list.
The primary method of contacting applicants is by mail. If an applicant fails to respond to a mailing from the CoPHD, the applicant will be mailed a second and final written notification and given 15 days to respond. If they fail to respond within the 15 days to the second notice, they will be removed from the waiting list. An extension will be considered as a reasonable accommodation if requested by a person with a disability within a reasonable time of receipt of the letter.
The CoPHD may also send notifications to applicants via email. The above mentioned process will apply when notification is sent via email. The applicant will also have 15 days to respond to an email notification.
If a letter is returned by the Post Office with or without a forwarding address, the applicant will be removed without further notice and the envelope and letter will be maintained in the file. In the event that any correspondence is mailed for any purpose and is returned by the Post Office, the applicant will be removed from the waiting list. This policy will apply to all applicants effective 2013. Applicants will not be entitled to the grace period for misdirected mail due to the applicant's failure to report a change of address to the CoPHD. This procedure also applies when an applicant fails to correctly list their address on the application and/or any updates.
If an email is returned undeliverable due to an invalid address, the applicant’s name will be removed from the waiting list without further notice. A copy of the email notifying CoPHD that the email was undeliverable will be maintained in the file. In the event any email is sent for any purpose and is returned undeliverable, the applicant’s name will be removed from the waiting list. Applicants will not be given a grace period for misdirected mail.
If an applicant fails to honor the first scheduled appointment to come into the office and/or to submit requested documents, the CoPHD will schedule a final appointment. If the applicant fails to honor the final appointment, the applicant will be removed from the waiting list. The CoPHD may accommodate the applicant if the applicant can provide documentation of a legitimate reason for failure to attend (i.e., emergency, medical, disability, etc.).
If an applicant fails to attend the briefing session appointment, the application for rental assistance will be disqualified. However, a final appointment may be scheduled if the applicant can demonstrate a valid reason (i.e. , medical, etc.) why they were unable to keep the briefing session appointment.
An applicant will be removed from the waiting list if the sole member listed on the application has passed away or is permanently residing in a convalescent home. In the event that the head of household passes away or resides in a convalescent home, the application will only be re- assigned if the original application lists an adult family member (who has not been previously removed from the application) other than the head of household. If the application reflects more than two adult family members, the family must select a new head of household. In the event that the family cannot decide, the CoPHD will then disqualify the application. If the sole member of the household is the live- in aide, the application will be canceled and removed from the waiting list. The CoPHD must be notified within 15 days when the head of household has passed away or is permanently residing in a convalescent home.
If the head of household is no longer interested in rental assistance and has provided a written statement to that affect, the application will be canceled and the applicant will be removed from the waiting list.
If the head of household requests to place the application on “HOLD”, application will be cancelled and applicant will be removed from the waiting list.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
4-8
L. CHANGES I N FAMILY CIRCUMSTANCES
Applicants will be required to report all changes in family circumstances within 15 days from the date of the change.
All changes must be reported online. Changes reported in writing will not be accepted and will be returned to the applicant. It is the responsibility of the applicants to update their application when changes occur.
M. EXPIRATION OF THE WAITING LIST
The prior policy regarding the expiation of the waiting list has been rescinded. The CoPHD will purge the waiting list regularly as described in Chapter 4 Section K of this Administrative Plan.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
5-1
CHAPTER 5
SUBSIDY STANDARDS
[24 CFR 982.54(d)(9)]
INTRODUCTION
HUD guidelines require that CoPHD establish subsidy standards for the determination of rental voucher bedroom size, and that such standards provide for a minimum commitment of subsidy while avoiding overcrowding. The standards used for the rental voucher size also must be within the minimum unit size requirements of HUD's Housing Quality Standards (HQS). This Chapter explains the subsidy standards which will be used to determine the rental voucher size for families when they are selected from the waiting list, as well as the CoPHD’s proced ures when a family's size changes or a family selects a unit size that is different from the rental voucher.
A. DETERMINING BEDROOM SIZE [2
4 CFR 982.402]
All standards in this section relate to the number of bedrooms on the vouche r, not the family's actual living arrangements. The CoPHD does not determine who shares a bedroom/sleeping room. The subsidy standards must provide for the smallest number of bedrooms needed to house a family without overcrowding. The CoPHD’s subsidy standards for determining the HCV bedroom size will be applied consistently for all families of like size and composition.
The CoPHD will apply the guidelines listed below when determining the HCV bedroom size:
1. Foster children will be included in determining unit size only if they will be in the unit for more than six months and all necessary information has been submitted by the family.
2. A child who is temporarily away from the home because of placement in foster care will be considered when determining the voucher bedroom size, only if the family submits documentation supporting the placement is temporary and does not exceed three months from the date the HCV was issued.
3. In a joint custody arrangement, if the minor is in the household less than 180 days per year, the minor will be considered to be an eligible visitor and not a family member. See Chapter 7 of this Plan, “Verification Procedures.”
4. Students who will be living away from home will be removed from the household.
5. A family member who will be absent from the home for more than three consecutive months in a 12- month period will not be considered when determining the HCV bedroom size.
6. Any live-in aide, approved by the CoPHD to reside in the unit to care for a family member who is disabled or is at least 50 years of age, must be counted in determining the HCV bedroom size. Occasional, intermittent, multiple or rotating care givers typically do not reside in the unit and would not qualify as live -in aides.
Therefore, an additional bedroom should not be approved for a live-in aide under these circumstances. See Chapter 2 of this Plan, “Eligibility for Admission”.
7. Unless a live-in aide resides with the family, the family unit size for any family consisting of a single person must be either a zero or one bedroom as determined under the CoPHD subsidy standards.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
5-2
8. In determining family unit size for a particular family, the CoPHD will not grant an exception to its established subsidy standards. However, the CoPHD may grant an exception to the subsidy standards as a reasonable accommodation.
9. A family that consists of a pregnant woman (with no other persons) must be treated as a two-person family.
Refer to Chapter 20 of this Plan, “Supportive Housing Programs”, for determination of Certificate bedroom size for families applying and/or participating in these programs.
B. CHANGES I N BEDROOM SIZE FOR HCV HOLDERS [24 CFR 982.403]
Changes for Applicants
The members of the family residing in the unit must be approved by the CoPHD. The family must obtain approval of any additional family member before the person occupies the assisted unit except for additions by birth, adoption, or court-awarded custody of a non-criminal nature, in which case the family must inform the CoPHD within 15 days of the change by completing an Update of Family Circumstances form and submit supporting information regarding the change.
If an applicant with a voucher reports a change in family circumstances prior to admission, the family’s eligibility will be re-evaluated.
Changes for Participants
The members of the family residing in the unit must be approved by the CoPHD. The family must obtain approval of any additional family member before the person occupies the unit except for additions by birth, adoption, or court- awarded custody of a non-criminal nature, in which case the family must inform the CoPHD within 15 days of the date of the change by completing an Update of Family Circumstances form and submit supporting information regarding the change.
Request for Exceptions to Subsidy Standards
The family may request an exception to the subsidy standards as a reasonable accommodation for a disabled family member. The request must be made in writing by completing the Request for Reasonable Accommodation form and must describe the needed accommodation. The CoPHD may conduct a special inspection, depending on the nature of the accommodation, at the time of the request and at every annual recertification. See Chapter 1 of this Plan, “Statement of Policies and Objectives”.
Under-Housed Families (unit too small)
If a unit does not meet HQS space standards due to an increase in family size, the CoPHD will determine if the family is eligible to move with continued assistance. The CoPHD may issue the family an updated HCV in accordance with the CoPHD’s subsidy standards.
Over-Housed Families (unit too big)
For over-housed families who are eligible to move with continued assistance, the CoPHD may issue the family an updated HCV in accordance with the CoPHD’s subsidy standards.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
5-3
C. UNIT SIZE SELECTED
The family may select a different size dwelling unit than that listed on the HCV. The following criteria should be considered:
1. Utility Allowance: The utility allowance used to calculate the gross rent is based on the lesser of the size of dwelling unit actually leased by the family or the family unit size as determined under the PHA subsidy standards. In cases where the unit size leased exceeds the family unit size as determined under the PHA subsidy standards as a result of a reasonable accommodation, the PHA must use the appropriate utility allowance for the size of the dwelling unit actually leased by the family. (982.517(d))
2. Housing Quality Standards : The standards allow two persons per living/sleeping room and permit maximum occupancy levels (assuming a living room is used as a living/sleeping area) as shown in the table below. The levels may be exceeded if a room in addition to bedrooms and living r oom is used for sleeping.
3. For a voucher tenancy, the CoPHD establishes payment standards by number of bedrooms. The payment standards for the family must be the lower of:
• The payment standard for the family unit size; or
• The payment standard for the unit size rented by the family.
4. The family may lease an otherwise acceptable dwelling unit with fewer bedrooms than the family unit size. However, the dwelling unit must meet the applicable HQS space requirements.
5. The family may lease an otherwise acceptable dwelling unit with more bedrooms than the family unit size.
However, the issued HCV payment standard will be used to determine the contract rent.
HOUSING SUBSIDY STANDARDS GUIDELINES FOR UNIT SIZE SELECTED Number of Bedrooms Persons in Household Persons in Household (Minimum #) (Maximum #)
Single Room Occupancy 1 1
0 Bedroom 1 2
1 Bedroom 1 4
2 Bedrooms 3 6
3 Bedrooms 6 8
4 Bedrooms 8 10
5 Bedrooms 10 12
The CoPHD staff shall apply the payment and subsidy standards identified above to all newly issued vouchers and moves effective October 1, 2018, and for all annual re -certifications commencing with the anniversary month of November 1, 2018. The CoPHD’s HCV bedroom size determination is in accordance with 24 CFR Part 982.402.
Families affected by a change in HCV bedroom size will be informed of their new tenant rent based on their new HCV bedroom size. If the family remains in the assisted unit, the family will be required to sign an updated HCV. If the tenant rent exceeds the monthly income, the family will be required to move.
Families converting from HOPWA Program to Housing Choice Voucher Program will be issued a voucher based on the above housing subsidy standards guidelines.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
5-4
The above housing subsidy standards will not be applied to families participating in the Veterans Affairs Supporting Housing (VASH) Program when determining the families’ voucher bedroom size. This is done in an attempt to provide families a greater opportunity to locate housing and limit the barriers for these clients base , which is facilitated by the separate Veterans Administration grant approved for this program.
The following subsidy standards guidelines will be applied for VASH Program voucher holders, program participants, and families who have been determined eligible to move with continued rental assistance:
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.
D. SUBSIDY STANDARDS IN THE EVENT OF SHORTFALL IN FUNDING
If the CoPHD determines or is informed by HUD that it is at risk of needing to terminate program participants due to a shortfall in Housing Assistance Payments funding, the CoPHD will apply the following subsidy standards to all newly issued vouchers and moves beginni ng the first of the month after shortfall is determined, and for all annual re - certifications commencing with the anniversary month following shortfall determination.
HOUSING SUBSIDY STANDARDS GUIDELINES FOR UNIT SIZE SELECTED Number of Bedrooms Persons in Household Persons in Household (Minimum #) (Maximum #)
Single Room Occupancy 1 1
0 Bedroom 1 2
1 Bedroom 2 4
2 Bedrooms 4 6
3 Bedrooms 6 8
4 Bedrooms 8 10
5 Bedrooms 10 12
The CoPHD will revert to the regular subsidy standards as outlined in Chapter 5 Section C of this Administrative Plan once it is determined that it is financially viable to do so, using the same timeframe as described above.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
6-1
CHAPTER 6
FACTORS RELATED TO TOTAL TENANT PAYMENT DETERMINATION
[24 CFR Part 5, Subparts E and F; 5.603, 5.609, 5.611, 5.615, 5.617, 5.520,
5.630, 982.153, 982.312, 982.516, 982.518, 982.551]
INTRODUCTION
The calculation of annual income and adjusted income will ensure that families are not paying more or less money for rent than their obligation under the regulations. This Chapter defines the allowable deductions from annual income and how the presence or absence of household members may affect the Total Tenant Payment (TTP). Income and TTP are calculated in accordance with 24 CFR Part 5, Subparts E and F, and further instructions set forth in HUD Notices, Memoranda and Addenda, including the HOTMA Final Rule published February 14, 2023 and PIH Notice 2023 -27.
While the HOTMA final rule is effective January 1, 2024, PHAs are allowed additional time to comply with these significant changes. The CoPHD will begin applying these changes effective January 1, 2025.
The formula for the calculation of TTP is specific and not subject to interpretation. The CoPHD's policies in this Chapter address those areas which allow the CoPHD discretion to define terms and to develop standards in order to assure consistent application of the various factors that relate to the determination of TTP.
A. INCOME AND ALLOWANCES
Annual Income is br oadly defined as all amounts received from all sources by each adult family member 18 years or older or the head of household or their spouse, plus unearned income by or on behalf of each dependent under 18 years, plus income from assets.
Elements of Annual Income
• Income of Dependents: A dependent is a family member who is under 18 years of age, is disabled, or is a full-time student. The head of household, spouse, co-head, foster child, or live in aide are never dependents.
Some income contributed to the household by dependents is counted and some is not.
• Earned income of minors (family member under 18) is not counted.
• Unearned income of both children and adults is counted.
• Although full-time students 18 years of age or older are technically identified as dependents, a small amount of their earned income will be counted. Only up to $480 of the earnings of a full-time student who is 18 years of age or older (other than the head, spouse, or co-head) is included in annual income; the rest is excluded.
• All income of a full-time student, 18 years of age or older, is counted if that person is the head of household or spouse.
• A single pregnant woman will not be entitled to the benefit of the dependent allowance until after the birth of the child.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
6-2
Income Exclusions
Annual income does not include the following:
• Payments received for the care of foster children or foster adults (usually persons with disabilities, unrelated to the resident family, who are unable to live alone). This exclusion also applies to Tribal Kinship or guardianship care payments.
• Amounts paid by a state or local agency to a family with a member who has a developmental disability and is living at home to offset the cost of services and equipment needed to keep the developmentally disabled family member at home.
• Distribution of principle from Irrevocable trusts, including Special Needs Trusts.
• Veterans’ aide and attendant care.
• Education Savings Accounts Distributions - Coverdell or any qualified tuition program under IRS section 529 and 530.
Income of Temporarily Absent Family Members
The CoPHD must count all income of family members who have been approved by the CoPHD to reside in the unit, even if they are temporarily absent. This includes family members who are temporarily confined to a nursing home or hospital.
All regular pay, special pay and allowances of a member of the Armed Forces (whether or not living in the dwelling) who is head of the family, spouse, or other person whose dependents are residing in the unit will be counted. The only exception is special pay for exposure to hostile fire.
Regular Contributions and Gifts
The CoPHD must count as income any regular contributions and gifts (monetary or not) from organizations or from persons not residing in the dwelling. This may include, but not limited to, rent, utility bills, credit card and car payments paid on behalf of the family and other cash or non-cash contributions provided on a regular basis.
Any contribution or gift received for two months or more frequently will be considered a “regular” contribution or gift, unless the amount is less than $50 per year. This may include the rent and utility payments paid on behalf of the family and other cash or non - cash contributions provided on a regular basis. Periodic and other determinable allowances, such as alimony and child support payments, and regular contributions or gifts from organizations or from persons not residing in the dwelling, qualify as income and must be reported. It does not include temporary, nonrecurring or sporadic income, including gifts.
Contributions made by various individuals at different intervals during a calendar year, although not on a monthly basis, will be combined and treated as regular payments and included in annual income.
The CoPHD will include this income in the family’s annual gross income if a “Promissory Note/Contract” is not in place.
The CoPHD must receive a copy of the “Promissory Note/Contract”. The CoPHD will determine whether this contribution will be included in the family’s annual gross income after reviewing the “Promissory Note/Contract.” However, this contribution will be included in the family’s annual gross income if the “Promissory Note/Contract” is not received by the CoPHD.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
6-3
The “Promissory Note/Contract” must state:
• The name of the persons entering into this legal transaction described as “lender” and “borrower”; • Total loan amount;
• Terms of the loan;
• Amount and frequency of the payment; and
• Date when first and final payment are due.
See Chapter 7 of this Plan, “Verification Procedures,” for further definition.
If the family's expenses exceed its known income, the CoPHD will question the family about contributions, gifts or other sources of income.
Seasonal Income
Income from seasonal employment (income that lasts only for a portion of the year) must be counted.
Income from Temporary Work Assignments
Income from temporary work assignments will be counted if the family has a history of working temporary assignments.
Annual income will be anticipated based on the earnings identified on the EIV report, W -2 forms, and pay stubs provided by the family.
Income from Business (Includes Self-Employment Income)
The net income from the operation of a business or profession must be included. Expenditures for business expansion or amortization of capital indebtedness may not be used as deductions in determining net income. An allowance for straight-line depreciation of assets used in a business or profession may be deducted. Net income will be anticipated based on evaluation of forms 1099, filed tax returns including Schedule C, and receipts for business related expenses, if applicable.
Withdrawal of cash or assets from the operation of a business or profession is counted as income, except when the withdrawal is for reimbursement of amounts the family has invested in the business.
Student Financial Assistance
All forms of student financial assistance (grants, scholarships, educational entitlements, work study programs, and financial aid packages) are excluded from annual income. This is true whether the assistance is paid to the student or directly to the institution, and applies to all family members who are students, full or part -time, including the head, spouse, or co-head, if the institution they attend does not qualify as an “institution of higher education”.
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.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
6-4
Income from Excess of Financial Assistance - Higher Education Institution Any financial assistance (grants, scholarships, education entitlements, work study program, and financial aid packages), in excess of amounts received for tuition, that an individual receives under the Higher Education Act of 1965 (20 U.S.C 1001 et seq.), from private sources, or from an institution of higher education (as defined under the Higher Education Act of 1965 (20 U.S.C. 1002), shall be considered income to that individual, except that financial assistance is not considered annual income for persons over the age of 23 with dependent children, but applies to all family members who are students, full or part-time, including the head, spouse, or co-head.
“Institution of higher education” means an educational institution in any State that:
(1) admits as regular students only persons having a certificate of graduation from a school providing secondary education, or the recognized equivalent of such a certificate, or persons who meet the requirements of section 1091(d) of this title;
(2) is legally authorized within such State to provide a program of education beyond secondary education; (3) provides an educational program for which the institution awards a bachelor’s degree or provides not less than a 2-year program that is acceptable for full credit toward such a degree, or awards a degree that is acceptable for admission
to a graduate or professional degree program, subject to review and approval by the Secretary; (4) is a or other nonprofit institution; and
(5) is accredited by a nationally recognized accrediting agency or association, or if not so accredited, is an institution that has been granted pre-accreditation status by such an agency or association that has been recognized by the Secretary for the granting of pre-accreditation status, and the Secretary has determined that there is satisfactory assurance that the institution will meet the accreditation standards of such an agency or association within a reasonable time.
Income from this source will be included in the family’s annual income after verifying the institution of attendance operates under “higher education”; total amount the student is eligible to receive from tuition assistance; deducting required fees and charges by the institution covering a full academic year; and confirming excess income from this source exists.
Examples of fees and charges include, but are not limited to: tuition amount for instructional services which may be charged per term, per course, or per credit; lab and writing labs, books, supplies, and other fees specific to the student’s major or program.
Expenses related to attending an institution of higher education must not be included as tuition. Examples of these expenses include, but are not limited to: room and board, books, supplies, meal plans, transportation and parking, student health insurance plans, and other non-fixed sum charges.
Military Pay
All regular pay, special pay and allowances of a member of the Armed Forces will be included with the exception of special pay for exposure to hostile file.
Resident Service Stipend
A resident service stipend is a modest amount (not to exceed $200 per month) received by a resident for performing a service for the PHA or owner, on a part time basis, that enhances the quality of life in the development. Such services DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
6-5
may include, but are not limited to, fire patrol, hall monitoring, lawn maintenance, and resident -initiative coordination.
No resident may receive more than one such stipend during the same period of time.
Amounts received under a resident service stipend (not to exceed $200 per month) are excluded from annual income.
If a resident service stipend exceeds $200 per month, the entire amount must be included in annual income.
Reduction of tenant rent does not qualify under resident service stipend and therefore must be included in the family’s annual income.
State or Local Employment Training Programs
Exclude incremental earnings and benefits resulting to any family member from participation in qualifying State or local employment training programs and training of a family member as resident management staff. • A qualified training program is one that is part of a State or local employment-training program and has clearly defined goals and objectives. This would include programs that have the goal of assisting participants in obtaining employment skills, and are authorized or funded by Federal, State, or local law or operated by a public agency.
• Only exclude the compensation related to the training; other sources of household income are still included. • Exclude the income only for the period during which the family member is actually participating in a qualifying training program.
Earned Income Disallowance
In accordance with the final rule implementing Section 104 of the HOTMA Act of 2016, the CoPHD has made the following changes to the Administrative Plan. The Earned Income Disregard (EID) will not apply to any family who is not eligible for and already participating in the disallowance as of December 31, 2023. Families who were eligible prior to this date were disabled families who are program participants in the HCV Program whose annual income increased due to employment, job training, and other specific scenarios. Under the EID regulations, all or part of the additional income earned by these disabled persons was temporarily excluded from annual income.
Reduction in Welfare Benefits
If the family’s welfare benefits are reduced or lost due to the expiration of a lifetime benefit limit, the family’s rent burden will be reduced according to the calculation methods stated in this Plan.
If a family experiences a benefit reduction due to fraud or a sanction for noncompliance with requirements to participate in an economic self-sufficiency program, as verified by the welfare agency, the family’s welfare assistance is treated as follows during the term of the reduction:
• The amount of assistance the family is actually receiving is counted. • The amount by which the family’s assistance has been reduced is also counted. This is called imputed welfare income.
The CoPHD will conduct an investigation to determine any possible program violation(s). However, the CoPHD is not responsible for determining whether a reduction of welfare benefits was correctly determined by the Department of Public Social Services (DPSS).
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
6-6
If the family’s income increases for any reason after the sanction is imposed, the amount of imputed welfare income is offset by the amount of additional income. (Whether the new income is earned or unearned, it takes the place of the imputed welfare income during the sanction period.)
The CoPHD may not include imputed income in an annual income if the family was not assisted at the time of the sanction.
Families receiving general relief public assistance monthly payments are eligible to receive aid for 9 or 12 months.
Annual income from this source will be anticipated at 12 months unless verification is received stating otherwise.
Reduction in Social Security and Supplemental Security Income Payments
The CoPHD will use the full amount before any deductions, such as a deduction for medical insurance premiums (including Medicare Part B and Prescription Drug Part D) or a garnishment for failure to pay any amount owed for:
• child support,
• alimony,
• taxes,
• student loans, or
• judgement creditor.
The CoPHD will request the family to submit correspondence from the Social Security Administration specifying the reason(s) for the reduction, total overpaid amount, and effective date of reduction to determine whether the gross or net monthly benefit will be used to anticipate the family’s annual income.
The CoPHD will use the monthly benefit amount reflected on the family’s EIV report (no cents) to determine annual income unless the family submits most current verification supporting a difference in the monthly benefit.
Families participating in the Supportive Housing Programs will be required to request from the Social Security Administration and submit current verification of their monthly income.
Income of Confined Family Members
If a family member is confined to a nursing home or hospital on a permanent basis, the CoPHD may decide , upon gathering applicable documentation, that the family member who is permanently confined to a hospital or nursing facility is no longer a member of the assisted household. In this case, the CoPHD would remove the individual’s name from the approved family composition and not count that individual’s income. It is the family’s responsibility to notify the CoPHD, in writing, when a family member will be away from the unit for 30 days or more.
Alimony and Child Support
The CoPHD must count alimony or child support amounts awarded as part of a divorce or separation agreement, unless the CoPHD verifies that the payments are not being made.
If the amount of child support or alimony received is less than the amount awarded by the court, the CoPHD must use the amount awarded by the court, unless the family can verify that they are not receiving the full amount.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
6-7
Lump Sum Payments
When there is a delay in the start of periodic income, payment of the portion that has been delayed may be made in the form of a lump sum or perspective monthly amounts.
The lump sum or perspective amount must be included in annual income. (This rule does not apply to SSI or SS benefits.)
Lump sum additions to family assets, such as inheritances, insurance payments (including payments under health and accident insurance and workers’ compensation), capital gains and settlement for personal or property losses are excluded as income . However, payment in lieu of earnings, such as unemployment, workers’ compensation and severance pay are included. Any lump sum receipts that do not represent the delayed start of periodic payments, including lottery winnings that are received in a single lump sum, are excluded from annual income. They may, however, be counted as an asset, depending on when they are received and whether or not they are retained.
Lump sum payments caused by delays in processing periodic payments for unemployment or welfare assistance are included as income. However, any portion of the lump sum that is payment for a period prior to the family’s participation in the HCVP would be counted as an asset instead of annual income. A lump sum payment resulting from delayed benefit or other income may be treated in either of two ways:
1. The CoPHD will calculate prospectively if the family reported the payment within 15 days.
2. The entire lump sum payment will be added to the annual income at the time of the interim re-examination.
Payments in Lieu of Earnings
This income category includes payments to individuals who are not working because they have lost their jobs or have been injured on the job. This category includes unemployment benefits, workers’ compensation and severance pay.
Payments in lieu of earnings are included in annual income when they are received either in the form of periodic payments or as a lump sum that represents the delayed start of a periodic payment.
Payments in lieu of earnings are excluded from income if they are received as a one -time settlement payment (e.g., for a claim dispute or a permanent work-related injury).
Prospective Calculation Methodology
If the payment is reported on a timely basis, the calculation will be done prospectively and will result in an interim re- examination and adjustment calculated as follows:
The entire lump sum payment will be added to the annual income at the time of the interim re-examination.
The CoPHD will determine the percentage of the year remaining until the next annual re-examination as of the date of the interim re-examination (three months would be 25% of the year).
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
6-8
1. At the next annual re-examination, the CoPHD will apply the percentage balance (75% in this example) to the lump sum and add it to the rest of the annual income.
2. The lump sum will be added in the same way for any interim re-examination which occurred prior to the next annual re-examination.
If amortizing the payment over one year will cause the family to pay more than 25% of the family's adjusted income (before the lump sum was added) for TTP, the CoPHD and family may enter into a Repayment Agreement, with the approval of the Housing Assistance Officer or designee, for the balance of the amount over the 25% percent calculation. The beginning date for this Repayment Agreement will start as soon as the one year is over.
Retroactive Calculation Methodology
1. The CoPHD will go back to the date the lump sum payment was considered, as long as that date is not prior to program participation.
2. The CoPHD will determine the amount of income for each examination period, including the lump sum, and recalculate the tenant rent for each examination period to determine the amount due the CoPHD.
At the CoPHD's option, the CoPHD may enter into a Repayment Agreement with the family or require that the entire amount be paid in full at this time.
The amount owed by the family is a collectible debt, even if the family becomes unassisted.
Attorney Fees
The family's attorney fees may be deducted from lump -sum payments when computing annual income when the attorney's efforts have recovered a lump- sum compensation for the wrongful reduction or denial of a periodic payment, and the recovery does not include an additional amount in full satisfaction of the attorney fees.
In these situations, the family does not actually recover the entire amount of the past due periodic payment because the family must pay the attorney fees.
This situation does not include those in which an amount is withheld from funds otherwise due the family to satisfy legitimate financial obligations unrelated to obtaining the income, such as:
• Withholding from wages to pay child support, alimony or a judgment creditor.
• Garnishment for failure to pay child support, alimony or a judgment creditor.
• The situation does not include those where the family incurs attorney fees unrelated to asserting a right to a source of income or where no income results from the attorney’s actions. These are the financial responsibility of the family and are not deducted in determining annual income.
Determining Income from Net Family Assets
In accordance with the final rule implementing Section 104 of the HOTMA Act of 2016, the CoPHD has made the following updates to the asset policy, including both discretionary non-enforcement and exception policies.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
6-9
The CoPHD is required to include in the calculation of annual income any interest, dividends, and other net income of any kind from real or personal property. Expenditures for amortization of capital indebtedness shall not be used as a deduction in determining net income. Any withdrawal of cash or assets from an investment will be included in income, except to the extent that the withdrawal is reimbursement of cash or assets invested by the family. Where the family has net family assets in excess of $5000, annual income shall include the greater of the actual income derived from net family assets or a percentage of the value of such assets based on the current passbook savings rate, as determined by HUD. This threshold will increase to $50,000 beginning January 1, 2025, and will be adjusted annually thereafter by HUD based on the inflation factor. The updated threshold will be applied at annual review with an effective date on or after January 1, 2025.
HOTMA also imposes a $100,000 asset limit for program eligibility and for continued participation. This asset limit includes but is not limited to the ownership of real property suitable for occupancy. The CoPHD will delay enforcement of this policy for 6 months following the annual review at which it was determined that the assisted household is out of compliance for assisted households with a head of household who is over the age of 65 or disabled, or includes a disabled dependent. This delayed enforcement does not apply to eligibility determination for new admissions.
Assets include:
• Amounts in savings and checking accounts.
• Cash on hand held by a family member or on behalf of the family by a 3 rd party.
• Stocks, bonds, savings certificates, money market funds and other investment accounts.
• Equity in real property or other capital investments. Beginning January 1, 2025, families are ineligible for assistance if they own real property suitable for occupancy.
• The cash value of trusts that are available to the family.
• Cash value of Special Needs Trust will not be included as asset. However, distribution payments received from Special Needs Trust will be treated as asset income.
• IRA, Keogh, and similar retirement savings accounts, deducting any penalties for withdrawal.
• Contributions to company retirement/pension funds.
• Assets, which although owned by more than one person, allow unrestricted access by the family.
• Lump-sum receipts such as inheritances, capital gains, lottery winnings, cash from sale of assets, insurance settlements, Social Security and SSI lump-sum payments and other claims.
• Personal property held as an investment such as gems, jewelry, coin collections, antique cars, etc.
• Cash value of life insurance policies.
• Assets disposed of for less than fair market value during the two years preceding examination or re - examination.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
6-10
Assets Disposed of for Less than Fair Market Value
Assets disposed of as a result of a divorce, separation, foreclosure, or bankruptcy are not considered assets disposed of for less than fair market value. Some of the types of assets that must be considered include cash, real property, stocks, bonds, and certificates of deposit. They must be counted if the household gave them away or sold them for less than the market value.
An asset moved to a retirement account held by a member of the family is not considered to be an asset disposed of for less than fair market value. In the case of a disposition as part of a separation or divorce settlement, the disposition will not be considered less than fair market value if the applicant or tenant receives consideration not measurable in dollar terms.
Contributions to Retirement Funds
The value of any account under a retirement plan recognized as such by the Internal Revenue Service, including Individual Retirement Accounts (IRAs), employer retirement plans (e.g., 401(k), 403(b)), and retirement plans for self- employed individuals is excluded from the calculation of net family assets.
Equity in Real Property
Real property includes land or real estate owned by the family. Equity is the portion of the market value of the asset which is owned by the family (the amount which would be available to the household if the property were to be sold).
It is equal to the market value less any mortgage or loans secured against the property (which must be paid off upon sale of the property).
Adjusted Income
A family’s adjusted income is the family’s annual income minus any deductions mandated by HUD regulations for which the family qualifies. These deductions are called allowances.
Dependent Allowance
The family receives an allowance of $480 for each family member who is under 18 years of age, a person with disabilities, or a full-time student. This amount will be adjusted annually, beginning in 2025, and applies to a family’s next annual or interim reexamination after the annual adjustment, whichever is sooner.
A household head, spouse, co-head, foster child, or live-in aide may never be counted as a dependent.
A full-time student is one carrying a full-time subject load (as defined by the institution) at an institution with a degree or certificate program.
A single pregnant woman will not be entitled to the benefit of the $480.00 dependent allowance until after the birth of the child.
Elderly or Disabled Family Allowance
An elderly or disabled family is any family in which the head or spouse (or the sole member) is at least 62 years of age or a person with disabilities.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
6-11
In accordance with the final rule implementing Section 104 of the HOTMA Act of 2016, the CoPHD has made the following changes to the Administrative Plan. Effective January 1, 2025, the Elderly or Disabled Family Allowance will increase from $400 to $525. This change will apply to the annual or interim income reexaminations effective on or after that date. This allowance will be adjusted annually by an inflation factor published by HUD.
Because this is a “household allowance,” each household receives only one allowance even if both the head and the spouse are elderly.
Child Care Allowance
Reasonable child care expenses for the care of children, including foster children, age 12 and younger may be deducted from annual income if all of the following are true:
1. The care is necessary to enable a family member to be gainfully employed, actively seek work, or further his/her education (academic or vocational);
2. The expense is not reimbursed by an agency or individual outside the household; and
3. The expenses incurred to enable a family member to work do not exceed the amount earned.
The CoPHD will provide a hardship exemption to extend the childcare deduction for 90 days for households who are no longer employed or attending school under certain circumstances. The family must demonstrate that continuing to pay the childcare expenses is necessary, and that it constitutes an economic hardship. An example of necessary continued childcare expenses is the need to provide uncompensated care for a disabled or ill family member, while an example of economic hardship include rent and utilities expenses plus childcare expenses totaling more than 60% of the family’s adjusted income.
The CoPHD is required to notify families of either approval or denial of hardship exemptions. Notices of hardship exemption approval must inform the family of the dates that the exemption will begin and expire and the requirement for the family to report if the circumstances that made the family eligible for relief are no longer applicable. If the request for hardship exemption is denied, the CoPHD must state the reason for the denial.
If th
e hardship continues beyond the 90-day extension period, the CoPHD may provide one additional 90 day extension.
The allowable deductions for child care expenses are based on the following guidelines:
1. Child Care to Work: The maximum child care expense allowed must be less than the amount earned by the person enabled to work. The “person enabled to work” will be the adult member of the household who earns the least amount of income from working.
2. Child Care for School: The number of hours claimed for child care may not exceed the number of hours the family member is attending school (including one hour travel time to and from school).
3. Amount of Expense: Th e CoPHD will survey the local care providers in the community as a guideline. If the hourly rate materially exceeds the guideline, the CoPHD may calculate the allowance using the guideline survey from the community.
In the
case of a child attending private school, only after-hours care can be counted as child care expenses.
See Chapter 7 of this Plan, “Verification Procedures” to determine reasonable child care cost.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
6-12
Disability Assistance Expense Allowance
Reasonable expenses that are anticipated, during the period for which annual income is computed, for attendant care and auxiliary apparatus for a disabled family member, and that are necessary to enable a family member (including the disabled member) to be employed, provided that the expenses are neither paid to a member of the family nor reimbursed by an outside source. However, the allowance may not exceed the earned income received by the family member who is 18 years of age or older who is able to work because of such attendant care or auxiliary apparatus.
Auxiliary apparatus are items such as wheelchairs, ramps, adaptations to vehicles, or special equipment to enable a blind person to read or type, but only if these items are directly related to permitting the disabled person or other family member to work.
In accordance with the final rule implementing Section 104 of the HOTMA Act of 2016, the CoPHD has made the following changes to the Administrative Plan. Participant families who are currently receiving the Disability Assistance Allowance for cost of the care attendant or auxiliary apparatus which exceeds 3% of gross annual family income will be adjusted to the HOTMA required threshold of 10% using the following schedule:
Participants: 2025 Effective Reexams 2026 Effective Reexams 2027 Effective Reexams Already receiving a
disability expense
deduction of 3% of Gross
Income
5% Of Gross Income 7.5% Of Gross Income 10% Of Gross Income Claiming a disability
expense deduction at
2024 Recertification
10% of Gross Income 10% of Gross Income 10% of Gross Income
Medical Expense Allowance
Medical expenses are the cost of diagnosis, cure, mitigation, treatment, or prevention of disease, and the cost for treatments affecting any part or function of the body. These expenses include payments for legal medical services rendered by physicians, surgeons, dentists, and other medical practitioners. They include the costs of equipment, supplies, and diagnostic devices needed for these purposes. Deductible costs are those not covered by insurance and include insurance premiums that are anticipated during the period for which annual income is computed. However, the medical care must be primarily to alleviate or prevent a physical or mental condition or illness. They don’t include expenses that are merely beneficial to general health, such as vitamins or a vacation.
The medical expense deduction is only permitted for households in which the head or spouse, or sole member is at least 62 or disabled (elderly or disabled households).
In accordance with the final rule implementing Section 104 of the HOTMA Act of 2016, the CoPHD has made the following changes to the Administrative Plan. Participant families who are currently receiving the Medical Expense Allowance for eligible costs which exceed three percent of a family’s annual income will be adjusted to the HOTMA required threshold of 10% using the following schedule:
Participants: 2025 Effective Reexams 2026 Effective Reexams 2027 Effective Reexams Already receiving a
medical expense
deduction of 3% of Gross
Income
5% Of Gross Income 7.5% Of Gross Income 10% Of Gross Income DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
6-13
Claiming a medical
expense deduction at
2024 Recertification
10% of Gross Income 10% of Gross Income 10% of Gross Income
If the household is eligible for a medical expense deduction, the medical expenses of all family members may be counted (e.g., the orthodontist expenses for a child’s braces may be deducted if the household is an elderly or disabled household).
Medical expenses may include:
• Services of doctors and health care professionals.
• Services of health care facilities.
• Medical insurance premiums.
• Prescription/non-prescription medicines (prescribed by a physician).
• Transportation to treatment (cab fare, bus fare, mileage).
• Dental expenses, eyeglasses, hearing aids, batteries.
• Live-in or periodic medical assistance.
Allowance for monthly payments on accumulated medical bills (regular monthly payments on a bill that was previously incurred), may only include the amount expected to be paid in the coming 12 months. However, the medical expense can be determined based on an established historical pattern.
Allowance for previously incurred and paid medical expense will be disallowed unless the family reports the expense at the time it is incurred.
Medical expenses will be disallowed if the family does not submit receipts of payment s made which can be used to determine an on-going pattern for the claimed expense; written third party verification was not returned; and third party telephone verification to verify expense was unsuccessful. However, the interest rate and other related fees charged by the credit card company will not be included when determining the medical allowance.
Allowable medical expenses charged to the family’s credit card (i.e., Care Credit) which are being paid monthly to the credit company may be included in the determination of medical expenses only if the family submits supporting information on the nature of the medical charge, total amount for medical expense, and receipts supporting monthly payments.
The CoPHD will include medical expenses incurred for the cost of buying, training, and maintain a guide dog or other service animal to assist a visually impaired or hearing disabled person, or a person with other physical disabilities. In general, this includes costs, such as food, grooming, and veterinary care, incurred in maintaining the health and vitality of the service animal so that it may perform its duties.
(See Publication IRS 502 for covered expenses.)
See Chapter 7 of this Plan, “Verification Procedures” to determine allowable medical expenses.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
6-14
Minimum Rent
The CoPHD does not require a minimum rent.
B. AVERAGING INCOME
When annual income cannot be anticipated for a full 12 months, the CoPHD may:
1. Average known sources of income that vary to compute an annual income; or
2. Annualize current income and conduct an interim re-examination if income changes.
If there are bonuses, commission, tips and/or overtime that the employer cannot anticipate for the next 12 months, income from the previous year may be analyzed and used to determine the amount to anticipate when third party or check-stub verification is not available. If by averaging an estimate can be made for those families whose income fluctuates from month to month, this estimate will be used so that the housing payment will not change from month to month. The method used depends on the regularity, source and type of income.
C. ZERO INCOME
The CoPHD will conduct a review every 180 days for families who report zero income. Family will be required to complete the Personal Declaration for Rental Assistance Benefits and Family Expenses forms. Additionally, a notarized Affidavit or self- certification declaring income status will be required. This requirement excludes families who have verifiable assets to cover monthly household expenses for the next 12 months. See Chapter 7 of this Plan, “Verification Procedures”.
All families are encouraged to apply for benefits and will be referred to supportive service providers. The CoPHD will send out third-party verifications to support the families’ claims.
D. PRORATION OF ASSISTANCE FOR “MIXED” FAMILIES [24 C
FR 5.520]
Applicability
Proration of assistance must be offered to any “mixed” applicant or participant family. A “mixed” family is one that includes at least one U.S. citizen or eligible immigrant and any number of ineligible members.
“Mixed” families that were participants on June 19, 1995, and that do not qualify for continued assistance must be offered prorated assistance. See Chapter 12 of this Plan, “Re-examinations”. “Mixed” applicant families are entitled to prorated assistance. Families that become “mixed” after June 19, 1995, by addition of an ineligible member are entitled to prorated assistance.
Prorated Assistance Calculation
For families that include both members who are citizens or have eligible immigration status and members who do not have eligible immigration status (or elect not to state that they have eligible status), the amount of assistance is prorated based on the percentage of household members who are citizens or documented eligible immigrants. To calculate prorated assistance, the CoPHD must follow these steps:
1. Determine gross rent (rent to owner plus utilities) for the unit.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
6-15
2. Determine the housing assistance payment amount, taking into consideration the income of all household members.
3. Determine the proration factor by dividing the number of eligible family members (citizens and those with eligible immigration status) by the total number of members in the household.
4. Multiply the housing assistance payment amount calculated in Step 2 by the proration factor calculated in Step 3 to determine the family’s eligible subsidy portion or prorated housing assistance payment.
5. Subtract the prorated housing assistance payment (Step 4) from the gross rent (Step 1).
E. T
ENANT RENT
HCV Program:
If the gross rent for the unit is at or below the payment standard, the family pays the highest of:
• 30% of monthly adjusted income;
• 10% of monthly gross income; or
• minimum rent
If the gross rent for the unit is above the payment standard, the family pays the highest of:
• 30% of monthly adjusted income;
• 10% of monthly gross income; or
• minimum rent
• plus any amount over the payment standard
Supportive Housing Programs & Project-Based Vouchers:
• 30% of monthly adjusted income
• Minus any allowance for tenant paid utilities and/or furnished appliances.
F. RENT BURDEN [24 CFR 982.508]
When a family is approved for initial occupancy of a dwelling unit, the rent burden for that family cannot exceed 40% of the family’s monthly adjusted income.
G. UTILITY ALLOWANCE AND UTILITY REIMBURSEMENT PAYMENTS [24 CFR 982.153, 982.514, 982.517]
The utility allowance is intended to help defray the cost of utilities not included in the rent and is subtracted from TTP to establish the family's rent to the owner. The allowances are based on actual rates and average consumption DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
6-16
studies, not on a family's actual consumption. The CoPHD will review the utility allowance schedule on an annual basis and revise it if needed.
The approved utility allowance schedule is given to families at admission and moves. The utility allowance is based on the lesser of the size of dwelling unit actually leased by the family or the family unit size as determined under the CoPHD subsidy standards.
Where the utility allowance exceeds the family's TTP, the CoPHD may provide a Utility Reimbursement Payment for the family each month.
H. DEFINITION OF TEMPORARILY/PERMANENTLY ABSENT [2
4 CFR 982.551]
The CoPHD must compute all applicable income of every family member who is part of the approved household composition, including those who are temporarily absent. In addition, the CoPHD must count the income of the spouse or the head of household if that person is temporarily absent.
Income of persons permanently absent will not be counted. If the spouse is in the military, all military pay and allowances (except hazardous duty pay when exposed to hostile fire and any other exceptions to military pay HUD may define) is counted as income.
It is the responsibility of the head of household to report changes in family composition, in writing, within 30 days of the change by completing an Update of Family Circumstances form and submit supporting information regarding the change. The CoPHD will evaluate absences from the unit using this policy.
Absence of Entire Family
These policy guidelines address situations when the family is absent from the unit, but has not moved out of the unit.
In cases where the family has moved out of the unit, the CoPHD will terminate assistance in accordance with appropriate termination procedures. See Chapter 15 of this Plan.
Families are required to both notify the CoPHD before they move out of a unit and to give the CoPHD information about any family absence from the unit. Families must notify the CoPHD if they are going to be absent from the unit for more than 30 consecutive days.
If the entire family is absent from the assisted unit for more than 90 consecutive days, the unit will be considered to be vacated and the assistance will be terminated.
In order to determine if the family is absent from the unit, the COPHD may:
1. Contact the family to schedule an office appointment.
2. Conduct a compliance inspection of the assisted unit.
3. Verify if utilities are in service.
4. Contact the property owner/manager.
A person with a disability may request an extension of time as an accommodation, provided that the extension does not go beyond the HUD allowed limit of 180
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
6-17
consecutive calendar days. The rental assistance will terminate if the absence exceeds 180 consecutive calendar days.
If the absence which resulted in termination of assistance was due to a person's disability, and the CoPHD can verify that the person was unable to notify the CoPHD in accordance with the family's responsibilities, and if funding is available, the CoPHD may reinstate the family as an accommodation if requested by the family.
Absence Due to Vacation
Families who are planning to be away on vacation for 60 consecutive days must submit a written statement to the CoPHD stating the date they plan to leave, return date, and method of transportation. If the request is approved, the CoPHD will continue to make a housing assistance payment for the family for the 60 days period. However, a housing assistance payment will not be paid if the family is away for longer than 60 days, in which case the family will be responsible for paying the full contract rent to the owner. Housing assistance payments may resume upon return of the family.
Absence of Any Member
Any member of the household will be considered permanently absent if the family member is away from the unit for three (3) consecutive months or 180 days in a 12-month period, except as otherwise defined in this Chapter.
Absence Due to Medical Reasons
If any family member leaves the household to enter a facility such as hospital, nursing home, or rehabilitation center, the CoPHD will seek advice from a reliable, qualified source as to the likelihood and timing of their return. If the verification indicates that the family member will be permanently confined to a nursing home, the family member will be considered permanently absent. The CoPHD will process an interim re- examination to remove the household member from the approved family composition.
If the verification indicates that the family member will return in less than 180 consecutive days, the family member will not be considered permanently absent.
Absence Due to Incarceration
Any member of the household will be considered permanently absent if the family member is incarcerated for 30 consecutive days or 90 days in a 12 month period. If the CoPHD determines the reason for incarceration is for drug- related or violent criminal activity, termination of assistance may ensue.
Foster Care and Absence of Chil dren
If the family includes a child or children temporarily absent from the home due to placement in foster care, the CoPHD will determine from the appropriate agency when the child/children will be returned to the home.
If the time period is to be greater than 90 days from the date of removal of the child/children, the HCV size will be reduced and the family will be issued a new HCV.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
6-18
Absence of Adult
In cases where an adult has been brought to care for a child / children in the absence of the parent(s)/guardian, the CoPHD will treat that adult as a caretaker/visitor for the first 30 days, while guardianship or custody is in the process of being established.
Rental assistance will be terminated if the remaining members are foster children and/or adults or in cases where the remaining children have been removed by Department of Children Services because there is no adult assigned to care for them.
If by the end of that period, court- awarded custody or legal guardianship has been awarded to the caretaker, the certificate or voucher may be transferred to the caretaker if he or she meets the rental assistance program eligibility criteria. The CoPHD will re-determine the family’s annual income to include the income of the newly appointed head of household.
If the appropriate agency cannot confirm the guardianship status of the caretaker, the CoPHD will review the status at 90-day intervals.
If the court has not awarded custody or legal guardianship, but the action is in process, the CoPHD will secure verification from the appropriate social service agency or the attorney as to the status.
The caretaker will be allowed to remain in the unit, as a visitor, until a determination of custody is made.
The CoPHD will transfer the HCV to the caretaker, in the absence of a court order, if the caretaker has been in the unit for more than 180 consecutive days and it is reasonable to expect that custody will be granted.
If a member of the household is subject to a court order/incarceration that restricts him/her from the home for more than 90 days, the person will be considered permanently absent.
If an adult family member leaves the household for any reason, the family must report the change in family composition to the CoPHD, in writing, within 15 days. The notice must contain a certification by the family as to whether the adult is temporarily or permanently absent.
The family will be required to notify the CoPHD, in writing, within 15 days when an adult family member moves out.
Family members will be removed, including their income (if any), from the approved household composition only after the CoPHD receives supporting written verification of their new residence address and verifies all of their personal belongings have been removed from the assisted unit.
Family members will be determined permanently absent if verification is provided. Refer to Chapter 7 of this Plan for required verifications.
Time extensions will be granted as an accommodation upon request by persons with a disability.
If an adult family member goes into the military and leaves the household, they will be considered permanently absent.
Students who attend school away from the home are considered permanently absent.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
6-19
Visitors
Any person not included as part of the household who has been in the unit more than 15 consecutive days, or a total of 60 days in a 12-month period, will be considered to be living in the unit as an unauthorized household member.
Absence of evidence of another address as the visitor’s principal place of residence will be considered verification that the visitor is a family member. Statements from neighbors and/or the owner will be considered in making the determination.
Use of the unit address as the visitor's or non -visitor’s current residence address for any purpose is prohibited. The family must not allow anyone who is not part of the approved family composition to use the assisted unit address for mailing purposes.
The burden of proof that the individual is a visitor rests on the family. In the absence of such proof, the individual will be considered an unauthorized member of the family, and the CoPHD may terminate assistance since prior approval was not requested for the addition.
Minors and college students who were part of the family, but who now live away from home during the school year are not considered members of the household, but they may visit for up to 90 days per year without being considered a member of the household. However, the family must notify the CoPHD, in writing, the name of the visitor and length of the stay prior to the visit.
In a joint custody arrangement, if the minor is in the household less than 180 days per year, the minor will be considered to be an eligible visitor and not a family member.
The family must obtain prior written approval from the owner and CoPHD to add any additional family members.
If the family does not obtain prior written approval from the CoPHD, any person the family has permitted to move in will be considered an unauthorized household member.
An interim re-examination will be conducted for any additions to the household.
Other Related Income Matters
The income received on behalf of family members residing in the assisted unit will be included in the family’s annual income even if the person(s) receiving such income on their behalf does not live in the assisted unit (i.e., public assistance).
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
7-1
CHAPTER 7
VERIFICATION PROCEDURES
[24 CFR Part 5, Subparts B, D, E and F; 982.207]
INTRODUCTION
HUD regulations require that the factors of eligibility and Total Tenant Payment be verified by the CoPHD. Applicants and program participants must furnish proof of their statements whenever required by the CoPHD, and the information they provide must be true and complete. The CoPHD's verification requirements are designed to maintain program integrity. This Chapter explains the CoPHD's procedures and standards for verification of preferences, income, assets, allowable deductions, family status, and when there are changes in family members.
The CoPHD will ensure that proper authorization from the family is always obtained before making verification inquiries. This chapter is updated to reflect changes implemented in the HOTMA Final Rule published February 14, 2023.
A. METHODS OF VERIFICATION AND TIME ALLOWED (Notices PIH-2010 -19 (HA),
2011-25 (HA), & 2012-26 (HA)
HUD identifies the following levels in its hierarchy of verification as listed below from the highest to lowest rank:
Level 6: Up-Front Income Verification (UIV). Using HUD’s Enterprise Income Verification (EIV) System (see Chapter 24 for EIV Security Policy and Procedures).
Level 5: Upfront Income Verification (using non-HUD syst em).
Level 4: Written third party verification. Mandatory to supplement EIV reported income sources and when EIV has no data; non-EIV reported income sources; when tenant disputes EIV reported employment and income information and is unable to provide acceptable documentation to support dispute.
Level 3: Written Third Party Verification Form. Mandatory if written third party verification documents are not available or rejected by the PHA; and when the applicant or tenant is unable to provide acceptable documentation.
Level 2: Oral Third Party Verification: Mandatory if written third party verification is not available.
Level 1: Tenant Declaration. Use as last resort when unable to obtain any type of third party verification.
Up-Front Income Verification (UIV)/(EIV)
Upfront income verification is the verification of income, before or during reexaminations, through an independent source that systematically and uniformly maintains income information in computerized form for a large number of individuals.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
7-2
Current UIV resources include:
• HUD’s UIV System, which provides a single source for obtaining verification of wages, unemployment compensation, and social security benefits;
• Social Security (SS) and Supplemental Security Income (SSI) information accessed via a secure Internet facility (EIV);
• State Wage Information Collection Agencies (SWICAs);
• State Cal-Works Systems;
• Credit Bureau Association (CBA) credit reports;
• Internal Revenue Service (IRS) Tax Transcript (request with Form 4506-T); and
• Private sector databases (e.g., The Work Number).
As part of the EIV requirements, prior to admission, the CoPHD should query each adult household member’s Social Security Number to determine if a PHA has reported a debt or adverse termination to determine the family’s eligibility for participation in the HCVP.
The CoPHD is required to review the Income Report for new admissions within 90 days of the admission date, to confirm/validate family reported income.
The CoPHD will review and print the EIV report for all program participants during the time of their annual re - examination. The report will be reviewed to determine whether a discrepancy exists between the tenant reported information and EIV. The report will be maintained in a sealed envelope in each participant case file. The CoPHD will complete the Enterprise Income Verification (EIV) System Certification form.
The CoPHD is not required to review the EIV report when processing an interim re-examination.
Written Third-Part
y Verification
Written third party verification is an original or authentic document generated by a third- party source dated either within the 60-day period preceding the reexamination or PHA request date. Such document may be in possession of the tenant or applicant. This verification type is commonly referred to as tenant -provided documents. The CoPHD may reject any tenant -provided documents and follow -up directly with the source to obtain necessary verification of information.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
7-3
Examples of acceptable tenant- provided documentation (generated by a third-party source) include, but are not limited to: pay stubs, payroll summary report, employer notice/letter of hire/termination, SSA benefit verification, bank statements, child support payments stubs/printouts, welfare benefit letters and/or printouts, and unemployment monetary benefit notices.
Documents older than 60 days (from the CoPHD’s interview/determination or request date) are acceptable for confirming effective dates of income.
Written Third Party Verification Form
Written third party verification form, also known as traditional third -party verification, is a standardized form to collect information from a third party source. Third -party written verification forms will be sent and returned via mail, fax, or e-mail. The family will be required to sign an authorization for the information source to release the specified information.
Verifications received electronically directly from the source are considered third-party written verifications.
The CoPHD will allow 10 days for the return of third -party verifications; after that time period, the CoPHD will utilize other acceptable methods of verification. Please refer to Chapter 1 of this Plan, “Reasonable Accommodation” regarding reasonable accommodation procedures.
For applicants, verifications may not be more than 60 days old at the time of issuance of a HCV. For participants, they are valid for 120 days from date of receipt.
The CoPHD will not delay the process of determining eligibility for a program applicant/participant due to a third-party verification that has not been returned. The eligibility will be determined following the levels of verification hierarchy.
If third-party verification form is received after tenant -provided documents have been accepted as verification, and there is a discrepancy, the third-party verification will prevail.
Oral Third-Party Verification
Oral third-party verification is an independent verification of information by contacting the individual income/expense source(s), as identified through the UIV technique or identified by the family, via telephone or in -person visit. This verification technique will be used in the event that the independent source does not respond to the CoPHD’s request for information within 10 days of request.
When oral third-party verification is used, the CoPHD staff will be required to document in the tenant file, the date and time of the telephone call (or visit to the third party), the name of the person contacted and telephone number, along with the confirmed information.
Tenant Declaration
The family submits a notarized Affidavit/statement of reported income and/or expenses to the CoPHD. This verification method should be used as a last resort when the CoPHD has not been successful in obtaining information via all other verification techniques. However, the family will be required to submit re ceipts/statement(s) from the person(s) whom payments are made to determine allowable program deductions.
The CoPHD may make an exception for families who claim they cannot afford to pay the fee of a Public Notary due to their income status and accept a non-notarized Tenant Declaration in lieu.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
7-4
Non-acceptable Tenant Provided Documents
The following are the only HUD -approved reasons where the CoPHD may reject documentation provided by the tenant:
1. The document is not an original; or
2. The original document has been altered, mutilated, or is not legible; or
3. The document appears to be a forged document (i.e., does not appear to be authentic).
If the CoPHD rejects documents provided by the tenant for any of the above stated reasons, the CoPHD should:
1. Explain to the tenant the reason(s) the submitted document(s) is/are not acceptable and request the tenant to provide additional documentation.
2. The CoPHD will request the traditional written third party verification form from the third party source for completion and submission to the CoPHD.
3. The CoPHD will document the tenant file of its attempt to obtain third party verification and that no response to the third party verification request was received.
Exceptions to Third Party Verification Requirements
The CoPHD staff will document the family’ s case file stating the reason(s) why third -party verification was not available of the following reported factors: family annual income; the value of assets; expenses related to deductions from annual income and other factors that affect the determination of adjusted income.
B. RELEASE OF INFORMATION
Each family member, 18 years of age or older or emancipated minor, must sign Authorization for Release of Information/Privacy Act Notice (form HUD -9886, replaced by HUD -9886-A after January 1, 2024) and CoPHD’s Authorization for Release of Information.
The final HOTMA rule changes the requirements related to the signing of Authorization for Release of Information (Form HUD-9886) and updates the form to reflect these changes. The new form is the Form HUD-9886-A. Under the final rule, all applicants age 18 and over must sign the Form HUD 9886-A at admission and participants must sign the consent form no later than their next interim or regularly scheduled income reexamination. After an applicant or participant has signed and submitted the HUD 9886-A on or after January 1, 2024, they do not need to sign and submit subsequent consent forms at the next interim or regularly scheduled income reexamination except under the following circumstances:
• When any person 18 years or older becomes a member of the family; • When a member of the family turns 18 years of age; and • As required by HUD in administrative instructions.
A family member may revoke the consent given by HUD-9886-A by providing a written statement of revocation. If consent is revoked, the CoPHD will be unable to verify family information in EIV and may not process interim or annual reexaminations of income, including when a family’s income decreases and the family requests an interim reexamination to decrease tenant rent, without the family’s executed consent form(s). This would result of termination of assistance to the family if the annual reexamination could not be conducted as a result of revocation of consent.
Additionally, if consent is revoked, the CoPHD must notify the Los Angeles Area HUD Office of Public and Indian Housing.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
7-5
Family’s refusal to cooperate with HUD and CoPHD’s prescribed verification system will result in denial of admission or termination of assistance based on the family’s failure to meet its obligation to supply any information requested by the CoPHD or HUD.
Executed consent forms will remain effective until the family is denied assistance, the assistance is terminated, or if the family provides written notification to the CoPHD revoking consent. If a family leaves a HUD program, the assistance is terminated, and the signed consent forms will no longer be in effect.
Client Screening-Crimina l History Background
Pursuant to HUD Federal Regulations, 24 CFR 982.202 -982.553 requires that the CoPHD conduct appropriate criminal history background inquiries on applicants and participants for subsidized housing. State Law (California Penal Code Section 11105.03, et seq.) has provided that PHAs may conduct appropriate criminal history investigations to ascertain suitability for subsidized housing. To satisfy these mandates, arrests that resulted in conviction will be released to the CoPHD. This information will be used to screen housing applicants and participants, allowing only eligible persons to qualify for subsidized housing. A background report with noted incidences of criminal activity may result in rescinding the issued HCV and/or application, proposed termination of rental assistance, and/or denial of request for addition to the family composition.
The CoPHD will work in conjunction with the Pasadena Police Department in obtaining said report for all applicants.
The CoPHD will carefully review the report to determine if drug- related, criminal activity or violent criminal activity occurred within five years prior to the date when eligibility is being determined. HUD prohibits admission to the program if any member of the household is subject to a lifetime registration requirement under a State sex offender registration program. Upon receipt of the report, the CoPHD will review the report and make the appropriate determination on the family’s eligibility for rental assistance. Dissemination of the information contained in the report is considered a felony and the staff person(s) found to be in violation will be prosecuted.
The CoPHD will conduct criminal background inquiries on program participants when reports of alleged criminal activity are received. The CoPHD will work in conjunction with the City of Pasadena’s Police Department in obtaining said reports.
C. COMPUTER MATCHING
The 1988 McKinney Act legislation authorized State wage record keepers to release to both HUD and local housing agencies information pertaining to wages and unemployment compensation accessible through the EIV system.
D. ITEMS TO BE VERIFIED
1. Income.
2. Assets.
3. Allowable deductions from income.
4. Non-financial factors.
5. "Preference” status based upon CoPHD’s local preferences.
6. Familial/marital status when needed for head or spouse definition.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
7-6
E. VERIFICATION OF INCOME
This section defines the methods the CoPHD will use to verify various types of income.
Employment Income
Verification forms request the employer to specify:
1. Dates of employment.
2. Termination of employment.
3. Current position.
4. Work location address.
5. Date of the last pay increase.
6. Current pay rate and frequency of pay.
7. Likelihood of change of employment status and effective date of any known salary increase during the next 12 months.
8. Earnings year to date.
9. Estimated income from overtime, tips, or bonus pay expected during the next 12 months.
10. Type of employment, whether it is regular, temporary or seasonal.
11. Number of weeks of the year worked and months of the year worked.
12. Whether employment is part of a Work-Study or Training Program.
Acceptable forms of verification include:
• UIV/EIV provided by a centralized computer matching system and pay stubs for the most recent three consecutive months.
• Employment verification form completed by the employers, only if: tenant is unable to provide documents requested by the CoPHD; tenant provided documents are not acceptable by the CoPHD; or tenant disputes the EIV reported information.
• Pay stubs for most current three to six consecutive months or earning statements which indicate the employee's gross earnings, frequency of pay or year to date earnings.
• Computer print-outs from the employer.
• W-2 forms plus income tax return forms.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
7-7
• Letter from employer(s) which include detailed employment information, provided that the information is confirmed by telephone.
• Income tax returns provided by the family may be used for verifying self -employment income, or income from tips and other gratuities. Tenant Declaration form may be used if no other readily available source for verification exists.
• Annual Earned Income Statement furnished by the Social Security Administration.
The CoPHD will accept faxed/e -mailed documents from agencies and employers regarding participants and applicants.
The CoPHD will anticipate earnings for families working for the school district or any other similar jobs based on the number of actual months worked during the year. However, the families will be instructed to report by completing an Update of Family Circumstances form, if employment is to continue during the 12 months of the year or if they become eligible for Unemployment payments while they are not working. The CoPHD shall use earnings for the past twelve months to anticipate annual earnings for families whose earnings vary but hourly rate and/or salary has not changed.
For families whose working hours vary and hourly and/or salary rate has changed, the CoPHD shall anticipate annual earnings by averaging the working hours during the most recent 3 to 6 consecutive months by the new rate.
The CoPHD may anticipate annual earnings based on the family’s earnings during the most recent 12 months, for families working through temporary agencies. This is after the CoPHD establishes the family’s history of employment through temporary jobs.
Earnings from seasonal jobs will be anticipated based on earned income during the previous year.
Applicants and program participants may be requested to sign Form 8821 Tax Information Authorization from the IRS for further verification of income.
In cases where there are questions about the validity of information provided by the family, the CoPHD will require the most recent Federal income tax statements.
Social Security, Pensions, Supplemental Security Income, Disability Income
Acceptable forms of verification include:
1. UIV/EIV.
2. Benefit verification form completed by agency providing the benefits.
3. Award or benefit notification letters prepared and signed by the providing agency.
4. Computer report electronically obtained or in hard copy.
5. Payment stubs for the 3 most recent months.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
7-8
Families reporting a reduction in their benefit will be required to submit information pertaining to the reason(s) for the reduction (i.e., what caused the overpayment, overpaid amount, effective date of deduction, and amount/frequency of deduction).
Third party verification form will not be requested if the benefit will remain the same for lifetime. However, families are required to submit payment stubs for the most recent 3 months.
For families who are working and receiving Social Security and/or Supplemental Security Income payments, the CoPHD will anticipate annual income by using the average monthly payment received by the family during the most recent 6 consecutive months.
Unemployment Compensation
Acceptable forms of verification include:
1. UIV/EIV;
2. Unemployment Insurance Claim Award letter; and
3. Payment stubs for the most recent three to six consecutive months (if available); or computer print -out reflecting payment history.
The CoPHD shall include income from unemployment compensation benefits for families who have a pattern of working seasonal jobs and receiving unemployment payments when they are not working.
For families who are working and receiving unemployment compensation benefits, the CoPHD will anticipate annual income by using the average monthly payment received by the family during the most recent 6 consecutive months.
Public Assistance Payments
Acceptable forms of verification include:
1. Verification form completed by the Department of Public Social Services (DPSS).
2. Written statement from DPSS indicating the amount of grant/payment, start date of payments, and anticipated changes in payment in the next 12 months.
3. Computer-generated Notice of Action.
4. Oral Third party Verification.
In cases where the verification reveals a reduced monthly cash aid, the CoPHD will contact the DPSS to verify the reason(s) for the reduced amount, to determine the anticipated countable annual income.
For families who are working and receiving cash aid, the CoPHD will anticipate annual income by using the average cash grant received by the family during the most recent 6 consecutive months.
Alimony Payments
Acceptable forms of verification include:
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
7-9
1. Copy of a separation , settlement agreement , or a divorce decree stating amounts and payment schedules.
2. Third-party verification form completed by the agency enforcing the Court order and/or person paying the support.
3. Computer-generated payment history report for the most recent twelve months from the agency enforcing the payment.
4. Copy of the most recent twelve months of payment stubs.
5. If payments are irregular, the family must provide either of the following verifications:
a. Computer-generated payment history report for the most recent twelve months from the agency enforcing the payment;
b. A statement from the agency responsible for enforcing payments or attorney to show that the family has filed for enforcement;
c. A copy of the Monthly Report for the past twelve months showing amounts received for support;
d. A written statement from an attorney certifying that a collection or enforcement action has been filed;
e. Current Quarterly Reports from District Attorney’s Office; or f. Tenant Declaration indicating the amount(s) received.
6. Tenant Declaration stating the name, address, and telephone number of the person making the payments; amount received; frequency of payment; method of payment; the likelihood of support payments being received in the future; or support payments are not being received.
Child Support Payments
Acceptable forms of verification include:
1. Third-party verification form completed by the agency enforcing the child support order and/or person paying the child support.
2. Computer-generated payment history report for the most recent twelve months from the agency enforcing the payment.
3. Copy of a separation or settlement agreement or a divorce decree or child support order stating amounts and types of support and payment schedules.
4. Tenant Declaration stating the name, address, and telephone number of the person making the DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
7-10
payments; amount received; frequency of payment; method of payment; the likelihood of support payments being received in the future; or support payments are not being received.
5. If payments are irregular, the family must provide either the following verifications:
a. Computer-generated payment history report for the most recent twelve months from the agency enforcing the payment;
b. A statement from the agency responsible for enforcing payments or attorney to show that the family has filed for enforcement;
c. A copy of the Monthly Report for the past twelve months showing amounts received for support;
d. A written statement from an attorney certifying that a collection or enforcement action has been filed;
e. Current Quarterly Reports from District Attorney’s Office; or f. Tenant Declaration indicating the amount(s) received.
Net Income from a Business (CFR 5 .609 (b) (2)
HUD regulations stipulate that the “net income from the operation of a business or profession” must be included in annual income. Expenditures for business expansion or amortization of capital indebtedness shall not be used as deductions in determining net income. An allowance for depreciation of assets used in a business or profession may be deducted, based on straight line depreciation, as provided in Internal Revenue Service (IRS) regulations. Any withdrawal of cash or assets from the operation of a business or profession will be included in income, except to the extent the withdrawal is reimbursement of cash or assets invested in the operation by the family.
Families will be required to submit a notarized Self-Employment Affidavit indicating the type of business they operate, net income realized from the business during the previous year, if applicable, anticipated business related expenses, and anticipated net income for the following year. Additionally, they will be required to submit documents supporting revenue from business and business expenses.
Documents such as appointment books, casebooks, bank statements, and receipts for the prior six months (or lesser period if not in business for six months) will be used as a guide to project income for the next 12 months. The family will be advised to maintain these documents in the future, if they are not available.
Families may be required to submit supplemental forms from the list below which are applicable to their business:
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
7-11
1. IRS Form 1040, including:
a. Schedule C (Small Business)
b. Schedule E (Rental Property Income)
c. Schedule F (Farm Income)
2. If accelerated depreciation was used on the tax return or financial statement, an accountant's calculation of depreciation expense computed using straight-line depreciation rules.
3. Audited or un-audited financial statement(s) of the business.
4. Credit report or loan application.
5. Copy of State Board of Equalization documents and Business License.
6. Earned Income Statement from the Social Security Administration.
In order to verify the net income from a business, the CoPHD may request IRS and financial documents from prior years and use this information, if available, to anticipate net income for the next 12 months as allowable by the Internal Revenue Service (IRS) regulations.
The CoPHD will exclude any business expenses that are not supported by documentation and expenses that are for personal purposes (i.e. personal vehicle use for business and personal purposes). T he allowable expenses must be strictly business related purposes.
Child Care Business
If an applicant/participant is operating a licensed day care business, income will be verified as with any other business.
If the applicant/participant is operating a "cash and carry” operation (which may or may not be licensed), the CoPHD may require that the applicant/participant complete a form for each customer which indicates: name of person(s) whose child (children) is/are being cared for, telephone number, number of hours child is being cared for, method of payment (check/cash), amount paid, and signature of person. The applicant/participant must provide a copy of their child care license, if licensed.
If the family has filed a tax return, the family will be required to provide a copy to the CoPHD annually.
If child care services were terminated, third-party verification form will be sent to the parent whose child was cared for.
The CoPHD will mail a third party Vendor Verification form if the family reports a form 1099 is being generated.
Regular Gifts and Contributions
Regular gifts and contributions (monetary or not) from persons or organizations outside the family must be counted as income and must be reported to the CoPHD within 15 days.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
7-12
Any contribution or gift received for two months or more frequently will be considered a regular contribution or gift.
This may include rent and utility payments paid on behalf of the family and other cash or non -cash contributions provided on a regular basis.
Periodic and determinable allowances, such as alimony and child support payments, and regular contributions or gifts received from organizations or from persons not residing in the dwelling, qualify as income and must be reported.
If the family’s expenses exceed its known income, the CoPHD will inquire of the family regarding contributions and gifts. The family must provide/submit a Tenant Declaration with the following information:
1. Name, address, and telephone number of the person(s) who provides the gifts/contributions;
2. Value of the gifts/contributions;
3. Regularity (dates) of the gifts/contributions; and
4. Purpose of the gifts/contributions.
The CoPHD will mail a third party verification form directly to the source providing the contribution.
Bank statements will be reviewed to determine if additional deposits may be considered regular contributions.
Families claiming the regular contribution received from persons residing out of the assisted household is a “loan” and not financial support will be required to submit a copy of the signed/notarized “Promissory Note/Contract” which provides information pertaining to the names of the persons entering into this legal transaction described as “lender” and “borrower; total loan amount; terms of the loan; amount and frequency of payment; and date when first and final payments are due. The CoPHD will determine whether this contribution will be included in the family’s annual gross income after reviewing the document. However, this contribution will be included in the family’s annual gross income if the “Promissory Note/Contract” is not received by the CoPHD.
Zero Income Status
Families claiming to have zero income may be required to complete a notarized Affidavit stating they have no income sources and must complete and submit the Family Expenses form along with supporting documents by given deadline. A Self-Certification form completed by the family will be accepted in lieu of a notarized Affidavit to avoid a hardship to the family.
The CoPHD will request third-party verifications from the following agencies for families claiming zero income status:
EDD, In-Home Supportive Services and DPSS. The CoPHD will also review the EIV report. The CoPHD will inform all zero income families to apply for benefits they may be entitled to receive.
The CoPHD may request information from the IRS.
The CoPHD will conduct a review every 90 days for families claiming zero income and review the Family Expenses form and supporting documents to determine whether an interim re-examination is necessary.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
7-13
Income from Excess of Tuition Assistance (Institution of Higher Education)
The CoPHD will verify the total assistance an individual receives from financial assistance while attending school to determine countable income in excess of tuition and other required fees and charges, using the hierarchy of verification levels.
Family must submit financial assistance award letter including verification of school related expenses (i.e. tuition, mandatory fees, books, lab fees).
Other Income Sources
Other income sources not mentioned above will be verified using the hierarchy of verification levels.
F. VERIFICATION OF ASSETS
The CoPHD will include the full cash value of any asset and any income it produces for a ssets owned jointly by more than one person.
The CoPHD’s established passbook savings rate applied to determine imputed asset income is 0.06%, which is based on the Saving National Rate calculated by the Federal Deposit Insurance Corporation (FDIC) plus .75 percent.
This rate will be evaluated yearly. If the results of the evaluation reveal a change in the rate, the new rate will be implemented.
Acceptable forms of verification include:
Financial Institution Accounts
1. Account statements , certificates of deposit, or CoPHD verification forms completed by the financial institution.
2. Broker's statements showing value of stocks or bonds and the earnings credited the family and any fees deducted for managing the account (i.e. , broker fees). Earnings can be obtained from current newspaper quotations, internet and/or oral broker's verification.
3. IRS Form 1099 from the financial institution provided that the CoPHD must adjust the information to project income expected for the next 12 months.
Interest Income from Mortgages or Similar Arrangements
1. A letter from an accountant, attorney, real estate broker, the buyer, or a financial institution stating interest due for the next 12 months. (A copy of the check paid by the buyer to the family is not sufficient unless a breakdown of interest and principal is shown.)
2. Amortization schedule showing interest for the 12 months following the effective date of the certification or re-examination.
Net Rental Income from Property Owned by Family
1. IRS Form 1040 with Schedule E (Rental Income).
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
7-14
2. Copies of rent receipts for the past three months, leases, or other documentation of rent amounts.
3. Documentation of allowable operating expenses of the property: tax statements, insurance invoices, bills for reasonable maintenance and utilities, and bank statements or amortization schedules showing monthly interest expense.
4. Lessee's written statement verifying rent payments to the family and family's notarized Affidavit as to net income realized.
5. Copy of Grant Deed and current property Tax Bill.
For property owned in another Country, families will be required to submit documents supporting the cash value of the property when converted into U.S. currency.
Family Assets
The CoPHD will require the following information to determine the current cash value (the net amount the family would receive if the asset were converted to cash):
1. Verification forms, letters, or documents from a financial institution or broker.
2. Most recent three to six months checking and savings account statements (all pages).
3. Most current statement for certificates of deposit, bonds, or financial statements completed by a financial institution or broker.
4. Quotes from a stock broker verifying the number of stocks, value per share, income received for the past 12 months and fees for management of account. Internet stock market values to determine current value.
5. Financial statements for business assets.
6. Family’s Tenant Declaration describing assets or cash held at the family's home or in safe deposit boxes.
Real Estate
The CoPHD will require the following information to determine the current net value for real estate properties:
1. Copy of Grant Deed.
2. Copy of Property Tax Bill.
3. Copy of property insurance policy.
4. Most recent mortgage statement.
5. Most recent property appraisal, if available.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
7-15
6. Certification from real estate agent confirming the value of the property.
7. Copies of closing escrow documents showing the selling price and the distribution of the sale proceeds.
8. Purchase agreement for burial plot.
The CoPHD will use real estate websites to obtain and determine the current market value of real estate.
Life Insurance
The CoPHD will use the insurance policy which reflects the cash surrender value schedule to determine the net value. If the cash surrender value is less than $5000, the CoPHD will not request third party verification. However, the family will be required to submit a copy of the policy/policies.
Assets Disposed of for Less than Fair Market Value (FMV)
Assets disposed of for less than FMV during two years preceding effective date of admission or re -examination.
Third-party verification will be obtained wherever possible:
1. For all admissions and re -examinations, the CoPHD will obtain the family's notarized Affidavit as to whether any member has disposed of assets for less than FMV during the two years preceding the effective date of the admission or re-examination.
2. If the family certifies that they have disposed of assets for less than FMV, verification is required that shows:
(a) all assets disposed of for less than FMV;
(b) the date they were disposed of;
(c) the amount the family received;
(d) the market value of the assets at the time of disposition;
(e) the Bill of Sale; and
(f) Escrow Settlement Statement.
G. VERIFICATION OF ALLOWABLE DEDUCTIONS FROM INCOME
Dependent Deduction
By regulatory definition (24 CFR 5.603(b)), a dependent is a family member other than the head, spouse, or co -head (except foster children and foster adults) who is any of the following:
1. Under 18 years of age.
2. A person with a disability 18 years of age or older.
3. A full-time student who is 18 years of age or older.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
7-16
Minor status may be verified with a B irth Certificate, hospital certificate ( newborns only), and Numident from the Social Security Administration (SSA) showing:
1. Name.
2. Sex.
3. Social Security number.
4. Date of birth.
5. Relationship to head of household.
Verification of full-time student status for family members 18 years of age or older includes:
1. Third-party verification form completed by the school registrar and financial aid office or other school official.
2. School records indicating that the enrolled family member is a full-time student as defined by the school or institution.
3. Current class schedule provided by the family as long as the CoPHD verifies via telephone what the institution considers to be full-time.
Elderly or Disabled Family Deduction
Elderly deduction is verified by providing one or more of the following:
1. Birth Certificate.
2. Certificate of Naturalization.
3. Passport.
4. Numident from the SSA.
5. U. S. Military Discharge Form (DD Form 214).
The deduction for a disabled family receiving disability benefits from the SSA may be verified:
1. CoPHD Certification of Disability form completed by a qualified, reliable, and knowledgeable professional.
2. Through EIV system.
3. By viewing an original SSA notice provided by the disabled family member that specifically identifies the person as disabled, if third-party written verification is not available.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
7-17
Child Care Expense Deduction
1. Written verification from the person who receives the payments is required. If the child care provider is an individual, they must provide a statement of the amount they are charging the family for their services.
2. Written verifications must specify the child care provider’s name, address, telephone number, license number (if applicable), the names of the children cared for, the number of hours the child care occurs, the rate of pay, method of payment, and the typical yearly amount paid, including school and vacation periods.
3. Families must provide canceled checks or receipts of payment for six consecutive months or more to verify child care expenses.
4. Families may be required to submit most recent income tax returns to verify child care expenses claimed. Child care expenses will be disallowed if the amount is not reflected on income tax returns and none of the other methods of verification are available.
The CoPHD will determine reasonable child care expense deduction by taking into account the age of the child/children; number of hours the child/children attends school ; working hours of the working family member (s); number of hours the family member(s) attends school; and/or reasonable hours the family member(s) actively is seeking work.
Families claiming childcare expenses because they are seeking work will be required to complete and submit the Employment Search form supporting the dates of search; number of hours they actively sought employment; and names, addresses, & telephone numbers of employers contacted and/or applications submitted.
Families claiming child care expenses because they attend school and/or are participating in vocational training will be required to submit verification supporting the number of hours they attend school and/or number of training working hours. The CoPHD will mail third party verification to the school of attendance and/or the company/agency where the training is being provided.
Childcare expenses claimed by family members who are under the first 12 month (100%) and second 12 month (50%) exclusion under the Earned Income Disallowance, the CoPHD will follow guidelines under 24 CFR 5.603.(b).
The childcare expense may be disallowed if the childcare provider is a relative who is not licensed; the provider has not returned requested third party verification; family pays in cash and provider does not provide receipts of payment; and family does not claim expenses on filed tax returns.
Medical Expense Deduction
Total medical expenses, exceeding the annual income threshold, claimed by the family which will not be reimbursed by an outside source and are anticipated to be incurred during the 12 months following certification or re - examination, will be verified by one or more of the methods listed below:
1. Written confirmation by the insurance company or employer of health insurance premiums to be paid by the family.
2. EIV report which reveals the monthly amount automatically deducted from the SS check for Medicare premiums.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
7-18
3. Correspondence from SSA confirming the amount of Medicare premiums to be paid by the family monthly.
4. Computer-generated report supporting the pattern of on-going medical expenses.
5. Receipts, canceled checks, or pay stubs that verify medical costs and insurance expenses likely to be incurred in the next 12 months.
6. Copies of payment agreement(s) or most recent invoice(s) that verify payments made on outstanding medical bills that will continue over all or part of the next 12 months.
7. Receipts or other record of medical expenses incurred during the past 12 months that can be used to anticipate future medical expenses. The CoPHD may use this approach for “general medical expenses” such as non-prescription drugs and regular visits to doctors or dentists, but not for one -time, non-recurring expenses from the previous year.
8. The CoPHD will use mileage at the IRS rate, cab, bus fare, or other public transportation cost for verification of the cost of transportation directly related to medical treatment.
9. Share of Cost payments. This applies to families receiving medical insurance through Medi -Cal.
Families will be required to submit a copy of the notification from the Department of Public Social Services informing them of their monthly Share of Cost and proof supporting the monthly payment.
Written verification by a doctor, hospital or clinic personnel, dentist, or pharmacist indicating anticipated medical costs to be incurred by the family and regular payments on medical bills; and extent to which those expenses will be reimbursed by insurance or a government agency. If the mailer is not returned, the CoPHD may rely on tenant - provided documentation which support on -going medical expenses. to anticipate medical expenses claimed and document why third- party verification was not available. Medical expenses will not be provided if third party verification is not returned; receipts are not submitted by family; and/or receipts submitted do not support on -going medical expenses.
Families claiming medical expenses for medications purchased over-the-counter or on-line will be required to submit a written statement from a doctor or reliable/knowledgeable professional supporting the need and recommendation to treat a specific medical condition for the medication. The CoPHD will not verify diagnosis/illness patient information.
The CoPHD will refer to IRS Publication No. 502 for further assistance related to additional allowance for medical expenses.
Assistance to Persons with Disabilities
Deduction is applicable only to HCVP families that include a person with disabilities. Unreimbursed reasonable attendant care and auxiliary apparatus expenses for each member of the family who is a person with a disability, to the extent necessary to enable any member of the family (including the member who is a person with disabilities) to be employed. This deduction may not exceed the earned income received by family members who are 18 years of age or older and who are able to work because of such attendant care or auxiliary apparatus.
1. In All Cases:
a. The CoPHD Certification of Disability and Housing Needs form must be completed by a reliable, knowledgeable professional stating that the person with disabilities requires the DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
7-19
services of an attendant, live-in aide, and/or the use of auxiliary apparatus to permit them to be employed or to function sufficiently independent to enable another family member to be employed.
b. Family's certification as to whether they receive reimbursement for any of the expenses of disability assistance and the amount of any reimbursement received.
2. Attendant Care:
a. A reliable, knowledgeable professional's certification that the assistance of an attendant is necessary as a medical expense and a projection of the number of hours the care is needed for calculation purposes.
b. Attendant must complete the CoPHD’s Verification of Home Care Services form for hours of care provided and amount and frequency of payments received from the family or agency.
c. Copies of canceled checks the family used to make payments or pay stubs from the agency providing the services.
d. Third party verification from In-Home Supportive Services and/or any other agency making the payment.
e. Share of Cost payments. This applies to families receiving attendant care through the Department of Public Social Services. Families will be required to submit a copy of the notification from the Department of Public Social Services informing them of their monthly Share of Cost and proof supporting the monthly payment.
3. Auxiliary Apparatus:
a. Receipts for purchases or proof of monthly payments and maintenance expenses for auxiliary apparatus.
b. In the case where the person with disabilities is employed, a statement from the employer that the auxiliary apparatus is necessary for employment.
c. Doctor certification supporting the need of auxiliary apparatus.
4. Live-in Aide
Disabled families requesting a Live- in Aide due to their disability will be required to complete a Request for Reasonable Accommod ation form indicating the name, address, and telephone number of the qualified, reliable, and knowledgeable professional that will verify the need for a Live -in Aide. The CoPHD will mail the Certification of Disability and Housing Needs form to be completed and returned to assist the CoPHD in making a decision regarding the family’s request.
5. Service Animal Care Cost
a. Provide a third-party certification from a professional for the need of a service animal. b. Receipts for purchases or proof of payments for the care of the service animal.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
7-20
The CoPHD will refer to IRS Publication No. 502 for further assistance related to allowances for service animal care cost.
H. VERIFYING NON-FI NANCIAL FACTORS
Verification of Legal Identity
In order to prevent program abuse, the CoPHD will require applicants to furnish verification of legal identity for all family members.
The documents listed below will be considered acceptable verification of legal identity for all adults. In the event of confliction, more than one of these documents will be required.
1. Certificate of Birth.
2. Certificate of Naturalization.
3. Church issued Baptismal Certificate.
4. Valid Driver License or Identification Card from the Department of Motor Vehicles.
5. U.S. Military Discharge Form (DD Form 214).
6. U.S. Passport.
7. Numident from SSA.
8. Hospital Certificate of Birth.
9. U.S. Census Bureau records.
10. Court documents showing a change in name.
In addition to the documents listed above, the following will be considered acceptable verification of legal identity for a minor:
1. Adoption documents.
2. Custody agreement.
3. Foster care placement documents.
4. Court order emancipation documents.
Families who possess documents in a different language other than English will be required to have the document(s) translated into English and submit the translated document(s) to the CoPHD.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
7-21
Verification of Marital Status
Verification of martial status would be used to determine spouse for income, deduction and non-citizen purposes.
1. Verification of divorce status will be a certified copy of the Divorce Decree signed by a Court Officer.
2. Verification of a separation may be a copy of court-ordered maintenance or other records.
3. Marriage Certificate.
4. Other acceptable form of verification i.e., Death Certificate, Certificate of Naturalization, filed income tax returns, etc.
Familial Relationships
Certification will normally be considered sufficient verification of family relationships. In cases where reasonable doubt exists, the family may be asked to provide additional verification. The following verifications will always be required if applicable:
1. Verification of relationship:
a. Official identification showing names.
b. Birth Certificate.
c. Baptismal Certificate.
2. Verification of legal guardianship/custody:
a. Court-ordered assignment (adoption or foster parents). b. Verification from social service agencies for foster parents.
Special Needs Adult
The CoPHD will request from the family a copy of Conservatorship of Special Needs Adult granted in a court proceeding where a superior court judge appoints a responsible person (a conservator) to care for another adult (a conservatee) who cannot care for themselves or their finances.
A conservator (usually a family member) may have the authority to:
• Decide where the conservatee will live;
• Manage the conservatee’s social affairs;
• Manage the conservatee’s financial affairs;
• Examine the conservatee’s confidential records and papers; • Sign a contract for the conservatee;
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
7-22
• Give or withhold consent for medical treatments;
• Make decisions regarding education and vocational training.
This document will be requested in the following instances:
1. Single household adults with development disabilities applying for rental assistance.
2. Former head of household passed away and the adult with development disabilities becomes the remaining family member and eligible head of household.
The CoPHD will deny rental assistance to single household adults with development disabilities who do not provide a copy of the Conservatorship of Special Needs Adult. The applicant will be provided an opportunity to request an informal review of the CoPHD’s decision.
In cases where the developmental disabled adult becomes the eligible head of household, the family will be required to submit the following information within 15 days of the date of occurrence:
1. Documents supporting the former head of household passed away or moved out of the assisted unit permanently.
2. Written request notifying the CoPHD of the proposed conservator including the following documents:
• California Identification or Driver License.
• Copy of filed Request for Conservatorship of Special Needs Adult.
The CoPHD requires the family to submit a copy of the approved Conservatorship of a Special Needs Adult within 60 days of the date of the occurrence. However, an extension may be granted if the family submits a written request informing the CoPHD of the reason(s) conservatorship has not been secured and the date when they expect the process to be finalized. Additionally, the family will be required to submit documents supporting their request.
In cases where the proposed Conservator plans to live in the assisted unit and be included as a family member, the CoPHD will follow the process in place outlined in Chapter 12 of this Administrative Plan.
Housing assistance payments on behalf of the family will not be interrupted if the family submits requested information which determines that an adult is caring for the disabled adult and request for Conservatorship is in process.
Housing assistance payments will be proposed for termination if a copy of the approved Conservatorship is not received by the CoPHD within 180 days of date of the occurrence. The family will be informed of their right to request an informal hearing if they disagree with the CoPHD’s decision.
Verification of Permanent Absence of Adult Member
If an adult member of the household is reported permanently absent by the family, the CoPHD will consider any of the following as verification:
1. Copy of court filing reflecting husband or wife instituted divorce action.
2. Copy of court filing reflecting husband or wife instituted legal separation.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
7-23
3. Copy of order of protection/restraining order obtained by one family member against another.
4. Proof of another home address, such as utility bills, canceled checks for rent, rent receipts, driver license, lease or rental agreement.
5. Statements from other agencies such as social services.
6. Written statement from the landlord or manager that the adult family member is no longer living at the assisted unit.
7. If no other proof can be provided, the CoPHD will accept a notarized Affidavit from the head of household certifying the date of the move and their whereabouts. Additionally, the CoPHD may conduct a special inspection to verify the reported person(s) is/are no longer occupying the assisted unit.
8. If the adult family member is incarcerated, a document from the Court or prison should be obtained stating the date of incarceration, charges, and expected release date. The CoPHD may use other available methods to verify the incarceration (i.e., Los Angeles County Sheriff’s Department Inmate Information, State of California Department of Corrections and Rehabilitation, Bureau of Federal Prisons websites, etc.).
9. If the adult family member is hospitalized, a letter from the doctor should be obtained stating the date of hospitalization and expected release date.
In order for the absent family member to be considered permanently absent, all personal belongings must be removed from the assisted unit. Additionally, the person must not use the assisted unit address for mailing purposes except for students attending school away.
Absence of the Entire Family
The family is responsible for reporting absences from the assisted unit within 15 days of the date of the absence and to submit information supporting the reason(s) for the absence. This is in accordance with the CoPHD’s Family Obligations.
In cases where the sole family member has been hospitalized, the family will be requested to submit verification from their doctor regarding the date of their admission, expected release date, and whether they are able to live independently.
The CoPHD will mail a third party verification form to the doctor identified by the tenant to complete regarding the tenant absence, as a reasonable accommodation, in cases where the family is not able to submit verification from their doctor.
In cases where the sole family member has been incarcerated, the family will be required to submit supporting information regarding the date of arrest, charges, and expected release date.
Refer to Chapter 6 of this Plan, “Absence of Entire Family”, regarding HUD -allowed limit on absences and Chapter 15 of this Plan, “Denial or Termination of Assistance” regarding termination of rental assistance due to absences beyond the allowed limit.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
7-24
Verification of Change in Family Composition
The CoPHD may verify changes in family composition (either reported or unreported) through tenant declaration, letters, telephone calls, utility records, inspections, landlords, neighbors, credit data, school, Department of Motor Vehicle records, and other sources.
The CoPHD will re -determine the family’s Housing Choice Voucher bedroom size when changes in family composition occur, in accordance with Chapter 5 of this Plan.
Verification of Disability
The following methods in conjunction with HUD prescribed guidelines will be used to verify disability status:
Receipt of Social Security Disability or SSI verifications will be used as verification of disability as long as the appropriate disability codes are reflected. If such benefits are not received, the following can provide a basis for verification:
1. Letters from Social Security Administration regarding qualification for SSI disab ility benefits payments.
2. Letters from a knowledgeable professional, such as a health or service professional.
3. Certification of Disability form completed by a reliable, knowledgeable professional, identified by the family on the HCVP application, Personal Declaration for Rental Assistance Benefits form or Request for Reasonable Accommodation form.
Verification of Reasonable Accommodation
The Certification of Disability and Housing Needs form will be mailed by the CoPHD to the reliable, knowledgeable professional identified by the family on the reasonable accommodation request form.
Please refer to Chapter 1 of this Plan, “Reasonable Accommodation ” regarding reasonable accommodation procedures.
Verification of Citizenship/Eligible Immigration Status
To be eligible for assistance, individuals must be U.S. citizens or eligible immigrants. Individuals who are neither may elect not to contend their status. Eligible immigrants must fall into one of the categories specified by the regulations and must have their status verified by the U.S. Department of Homeland Security. Each family member must declare their status. Assistance cannot be delayed, denied, or terminated while verification of status is pending, except that assistance to families may be delayed while the CoPHD hearing is pending. The primary verification for immigration status of the person is conducted by the responsible entity through the U.S. Department of Homeland Security automated Systematic Alien Verification for Entitlements (SAVE). These are the following status:
1. Citizens or Nationals of the United States are required to sign a declaration under penalty of perjury.
The CoPHD will require citizens to provide documentation of citizenship.
2. Eligible Immigrants who were participants and 62 years old or older on September 30, 1996 , are required to sign a declaration of eligible immigration status and provide proof of age.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
7-25
3. Non-citizens with eligible immigration status must sign a declaration of status and verification consent form, and provide their original immigration documents which are copied front and back and returned to the family. The CoPHD verifies the status through the U.S. Department of Homeland Security’s SAVE system. If this primary verification fails to verify status, the CoPHD must request, within ten days, that the U.S. Department of Homeland Security conduct a manual search.
4. Ineligible family members who do not claim to be citizens or eligible immigrants must be listed on a statement of ineligible family members signed by the head of household or spouse.
5. Non-citizen students on student visas are ineligible members even though they are in the country lawfully. They must provide their student visa, but their status will not be verified and they do not sign a declaration, but are listed on the statement of ineligible members.
Elig
ible non-citizen program participants w ith expired Permanent Resident card are required to provide the CoPHD with a copy of their renewed Permanent Resident Card at the time of their annual re -examination. The CoPHD will verify their status through the SAVE System.
Failure to Provide: If a n applicant or participant family member fails to sign required declarations and consent forms or provide documents as required, they must be listed as an ineligible member. If the entire family fails to provide documents and sign as required, the family may be denied or terminated for failure to provide required information.
Time of Verification: For a
pplicants, verification of U.S. citizenship/eligible immigrant status occurs at the same time as verification of other factors for final eligibility determination. In the case of incoming portable families, the CoPHD must conduct the determination if the initial PHA does not supply the documents.
Extensions of Time to Provide Documents: The CoPHD wi
ll grant an extension of 30 days for families to submit evidence of eligible immigrant status.
Acceptable Documents of U.S. Citizens/Nationals:
1. U.S. Passport.
2. Birth Certificate.
3. U.S. Certificate of Naturalization.
4. Numident from SSA.
Acceptable Documents of Eligible Immigration: The r
egulations stipulate that only the following documents are acceptable unless changes are published in the Federal Register.
1. Permanent Alien Resident Card (I-551).
2. Alien Registration Receipt Card (I-151).
3. Arrival-Departure Record (I-94).
4. Temporary Resident Card (I-688).
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
7-26
5. Employment Authorization Card (I-688B)
6. Receipt issued by the INS for issuance of replacement of any of the above documents that shows individual's entitlement has been verified.
A Birth Certificate is not acceptable verification of eligible immigration status. All documents in connection with U.S. citizenship/eligible immigration status must be maintained in the file.
Verification of Social Security Numbers
Social Security numbers (SSN) must be provided as a condition of eligibility for all family members. Verification of SSN will be done through a Social Security card issued by the SSA. If a family member cannot produce a Social Security card, only the documents listed below showing their Social Security number may be used temporarily for verification. The family must apply for another Social Security card. The family is also required to certify in writing that the documents submitted in lieu of the Social Security card are complete and accurate:
1. Receipt of application for SSN.
Addition of household members under the age of 6 who have not been assigned a SSN will be provided 90 days to provide documentation of the SSN. The CoPHD may extend the time frame for an additional 90 days if unforeseen circumstances outside the control of Head of Household prevent timely disclosure of required documentation.
Addition of household members at least 6 years of age or under the age of 6 who have an assigned SSN must disclose the SSN and provide documentation of the SSN to the CoPHD at the time of request to add new household member or during interim re-examination.
New household members cannot be added to the family composition until the family has complied with SSN disclosure and verification requirements.
Foster children cannot be added to the family composition until the family has complied with SSN disclosure and verification requirements.
The CoPHD requires families to submit SSN assigned to a newborn within 4 weeks.
Families are required to disclose a newly assigned SSN at time of receipt of new SSN.
Individuals exempt from disclosure of SSN are: individuals who do not contend to have eligible immigration status; tenants age 62+ as of 1/31/10; tenant who previously disclosed a SSN.
The CoPHD will reject tenant provided documentation if: document is not an original; original document has been altered, mutilated, or not legible; or document appears to be a forged document. When there is a discrepancy with the SSN, the family will be required to provide documentation from the SSA to validate the Social Security number.
Refer to Chapter 15 of this Plan, “Denial or Termination of Rental Assistance”, for procedure when the family fails to disclose and/or provide a SSN.
Verification of Emancipated Youth
A copy of the court ordered emancipation will be required.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
7-27
Verification of Student Status
Family members other than the head of household , co -head, and spouse claiming full -time student status will be required to submit current proof from the institution of attendance and transcripts.
Verification of full-time student status includes:
a. School records supporting attendance is full-time pursuant to the educational institution;
b. Written verification from the registrar’s office or other school official.
The CoPHD may also mail a third party verification form to the identified institution of attendance to verify the status.
Verification of Students Enrolled at an Institution of Higher Education
For families who are applying for rental assistance and are enrolled at an institution of higher education, the following verifications must be submitted:
• Legal age or an emancipated minor under State law. Refer to “Verification of Legal Identity in this Chapter for list of acceptable documents.
• The student must submit documents from the institution they attend verifying that their institution qualifies as a “higher education” institution.
• The student must provide a written certification that the student does or does not anticipate receiving financial support from the student’s parent(s) or guardian(s) and the amount of support.
• The student must have established a household separate from their parents or legal guardians for at least one year prior to applying for the HCVP. The CoPHD will verify evidence of separate households by verifying the address information that predated the student’s application by a minimum of one year.
• The student must not be claimed as a dependent by parent(s) or legal guardian(s) on their IRS tax return.
The
CoPHD may request a copy of the student’s 1040 tax returns for the prior year. The CoPHD will may also review the student’s parents or guardians tax return.
• The s
tudent must supply any information that the CoPHD determines is necessary in verifying the college student’s eligibility.
The following documents must be submitted:
• Lease/rental agreement.
• Utility bills.
• Mail that predates the student’s application by a minimum of one year. • Marriage Certificate.
• U.S. Military Discharge Form (DD Form 214).
Refer to Chapter 2 of this Plan, “Eligibility for Admission”, for procedure when the family is an applicant.
Verification of Domestic Violence
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
7-28
The CoPHD will comply with Violence Against Women and Justice Department Reauthorization Act of 2005 (VAWA), which protects family members who are victims of domestic violence, dating violence, or stalking, from being evicted or terminated from housing assistance based on acts of such violence against them. The family may be required to complete, sign and submit f orm HUD-50066, or other acceptable certification/documentation, in order to verify the family’s claim of domestic violence, within 14 business days of the request. The certification must include the name of the perpetrator.
I. Waiting List Prefe
rences [24 CFR 5.430, 982.207]
Local Preferences
1. Families who claim Involuntary Displacement due to:
a. Disaster or Government Action:
Written verification by the displacing unit or agency of government, or by a service agency such as the Red Cross.
b. Actions taken by the family’s current property owner/agent:
Written notification by owner to family of the action/written verification by the owner or agent, or documents such as sales agreements, foreclosure notices or building permits.
c. Domestic Violence:
Written verification from police, social service agency, court, clergy person, physician, and/or public or private facility giving shelter and/or counseling to victims.
Verification must be obtained (from an owner or other source) that the abuser still resides at the unit.
The family must certify that the abuser will not return to the household without the advance written approval of the CoPHD.
Before giving approval, the CoPHD will require verification of the following:
1. Written statement from social worker, psychologist, or other professional familiar with the abuser that he/she has received counseling/treatment and is unlikely to continue the abuse.
2. Written statement from local law enforcement agency that no complaints have been filed since the date of the preference approval.
3. Certification that the abuser has completed a rehabilitation program.
d. Witness Protection Program:
Certification of participation by a law enforcement agency of participation in the Witness Protection Program.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
7-29
Written recommendation from law enforcement agency or HUD.
e. Hate Crimes:
Written statement from law enforcement agency, HUD, Fair Housing or other agency responsible for non- discrimination advocacy. Statement should contain approximate number of occurrences and date of last occurrence.
f. Inaccessibility of Unit:
Statement from the owner of the critical elements that are inaccessible, and that the owner is not going to make the needed modifications, or permit the family to make the modifications.
Inspection by CoPHD to verify inaccessibility of critical elements. Statement from the owner of the building that the accommodations required will not be made.
If the owner permits the tenant to make the modifications, verification that the family cannot afford the expense.
g. HUD Disposition of a Project:
Written verification from HUD.
2. Living in Substandard Housing:
a. Families who claim to be living in a substandard housing unit must provide written verification from a reliable, knowledgeable professional.
b. Homeless Families: Written verification by a public or private facility providing shelter, the police, or a social services agency certifying that the family lacks a fixed, regular, and adequate nighttime residence.
c. Visual verification by CoPHD staff.
3. Residency Preference: For families who live or work in the jurisdiction of the CoPHD.
In order to verify that a family is a resident, the CoPHD will require a minimum of three of the following documents: rent receipts, leases, utility bills, employer or agency records, school records, driver licenses, voter registration records, credit reports, and written statement from household with whom the family is residing. Along with the written statement from the household, the family must provide at least five pieces of mail (i.e., voter’s registration, DMV correspondence, etc.).
The head of household and/or spouse who have been hired to work or are working in the jurisdiction of the CoPHD, a statement from the employer will be required.
4. Veteran’s Preference: Families who are claiming a veteran’s preference must submit documentation supporting their U.S. Military Armed Forces veteran status (i.e., DD214).
5. Housing Opportunity Through Modernization Act (HOTMA). Revisions in this chapter pertaining to DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
7-30
annual re-examination will be revised upon receiving guidance from HUD and updates will be included in Chapter 26. Public Housing and HCV Programs Temporary Compliance Assistance.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2024 Administrative Plan
8-1
CHAPTER 8
ISSUANCE AND BRIEFINGS
INTRODUCTION
The CoPHD's objectives are to assure that families selected to participate in the Housing Choice Voucher Program (HCVP) are successful in obtaining an acceptable housing unit, and that they have sufficient knowledge to derive maximum benefit from the program and to comply with program requirements. When applicant families have been determined eligible, the CoPHD will conduct a mandatory briefing to ensure that applicant families know how the HCVP works. The briefing will provide a broad description of owner and applicant family responsibilities, CoPHD procedures, and how and where to lease a unit. The applicant family will also receive a briefing packet which provides more detailed information about the program. This Chapter describes how briefings will be conducted, the information that will be provided to applicant families, and the policies for how changes in the family composition will be handled.
In addition, the CoPHD’s objective is to ensure that participant families are also successful in leasing another unit after a move.
A. ISSUANCE OF HOUSING CHOICE VOUCHER (HCV) [24 CFR 982.302]
When funding is available, the CoPHD will issue HCV s to applicant families whose eligibility has been determined.
The issuance of HCV s must be within the dollar limitations set by the Consolidated Annual Contribution Contract (ACC) Budget Authority.
The number of HCVs issued must ensure that the CoPHD stays as close as possible to 100% lease-up. The CoPHD performs a monthly calculation both electronically and manually to determine whether applications can be processed, the number of HCV s that can be issued, and to what extent the CoPHD can over-issue (issue more HCV s than the budget allows).
The CoPHD may over-issue HCVs only to the extent necessary to meet leasing goals. HCV s which are over-issued may be cancelled due to lack of funding. If the CoPHD finds it is over-leased, it must adjust future issuance of HCVs or the cancellation of HCVs in order not to exceed the ACC budget limitations over the fiscal year.
B. BRIEFING TYPES AND REQUIRED ATTENDANCE [24 CFR 982.301]
Initial Applicant Briefing
A HUD-required briefing will be conducted for applicant families who are determined eligible for assistance. The briefings will be conducted in either individual or group meetings. All adult family members must attend the briefing.
Families who attend group briefings may require individual assistance by a CoPHD staff member.
Briefings will be conducted in English. However , Non-English speaking families are encouraged to bring an interpreter for assistance.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2024 Administrative Plan
8-2
The CoPHD will not issue a HCV to a n applicant family unless they have attended a briefing and signed the HCV.
Applicant families who provide prior notice of their inability to attend a briefing will automatically be scheduled for the next briefing. However, if the applicant family was unable to attend the briefing due to circumstances beyond their control, a final briefing will be scheduled. An applicant family who fails to attend the scheduled briefing without prior notification of their inability to attend will result in the disqualification of the app lication for rental assistance. Upon request, the CoPHD may conduct individual briefing for applicant families with disabilities at their home, if required for reasonable accommodation. Applicants who failed to attend a briefing due to incarceration will be disqualified.
Applicants who failed or are unable to attend due to being out of town or of the country will be rescheduled only if the applicant will return within 15 days.
Participant Briefing
An interview will be held with participant families who wish to move. The interview will be held prior to the participant family giving notice to the owner and CoPHD’s issuance of a HCV to the participant family. Similarly, an interview will be held for outgoing portable participant families. The interviews are conducted to inform participant families of the move/portability process and to minimize charges against security deposits. All participant families who plan to move are required to notify the CoPHD, in writing, 90 days in advance of the planned move date. The CoPHD will schedule a n interview within 30 days of receipt of the written request. Participant families failing to attend a scheduled interview will be denied issuance of a new HCV based on failure to provide required information. See Chapter 13 of this Plan, “Moves with Continued Assistance/Portability” for additional information.
Applicant Briefing Packet
Applicant families will be provided with a briefing packet. The documents and information provided in the briefing packets for the HCVP will comply with all HUD requirements. The CoPHD also includes other information and/or materials which are not required by HUD.
The applicant family is provided with the following information and materials:
1. The CoPHD Statement of Policies, which provides guidance and information on the following matters:
Rental Assistance Programs (RAP)
RAP Regulations
RAP Administrative Plan
Obligations of the Family
Term of Voucher/Extension/Suspension
Request for Tenancy Approval
Housing Quality Standards
Rent Reasonableness
Repayment/Recovery of Outstanding Debt
Moves with Continued Assistance
Portability Procedures
Denial and Termination of Assistance
Informal Review and Informal Hearing Procedures
Termination of Housing Assistance Payments Contract
2. The term of the HCV , and the CoPHD’s policy for requesting extensions to the term of the HCV or DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2024 Administrative Plan
8-3
suspensions of the HCV.
3. A description of the method used to calculate the assistance payment, information on Fair Market Rents, Payment Standards and Utility Allowances.
4. Rent Estimate form
5. How the maximum allowable rent is determined, including the rent reasonableness standard.
6. Guidance and materials to assist the family in selecting a unit, such as proximity to employment, public transportation, schools, shopping, and the accessibility of services. Guidance will also be provided to assist the family to evaluate the prospective unit, such as the condition, whether the rent is reasonable, average utility expense, energy efficiency, and security. A Tenant Tool Kit with tips on how to conduct a successful housing search will also be provided to the family.
7. The boundaries of the geographical area in which the family may lease a unit, including an explanation of portability along with the HUD Portability Handout.
8. The CoPHD Proposed Lease and HUD Tenancy Addendum.
9. The Request for Tenancy Approval (RFTA) packet and a description of the procedure for requesting approval for a unit. The packet will include the following forms:
• Request for Tenancy Approval
• Renting to Relatives Disclosure Notice
• Inspection Checklist
• Proposed Lease Agreement
• Disclosure of Information on Lead-Based Paint and/or Lead-Based Paint Hazards • Statement of Property Ownership
• W-9 Request for Taxpayer Identification Number and Certification • Vendor List Questionnaire (Form AA-1)
10. The HUD brochure on how to select a unit and/or the HUD brochure "A Good Place to Live" on how to select a unit that complies with HQS.
11. The Environmental Protection Agency booklet “Protect Your Family F rom Lead In Your Home” and information about where blood level testing is available.
12. Information on Federal, State and local equal opportunity laws including the pamphlet "Fair Housing:
It's Your Right," other information about fair housing laws and guidelines, and the telephone numbers of the local fair housing agency and the HUD enforcement office.
13. The CoPHD’s Available Housing List including property owners or other parties willing to lease to applicant/participant families. The CoPHD will only provide contact information to applicant/participant families with the permission of the property owner.
14. Information on the City of Pasadena’s housing search website (pasadenahousingsearch.com) and DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2024 Administrative Plan
8-4
additional free property rental websites.
15. If the family includes a person with disabilities, the CoPHD will provide , if available, resources for locating accessible units.
16. The Obligations of the Rental Assistance Program Participant Family.
17. The Things You Should Know.
18. The Federal Privacy Act.
19. The Notification - Watch Out For Lead-Based Paint Poisoning.
20. What You Should Know About EIV.
21. Debts Owed to the Public Housing Agencies and Terminations.
22. The grounds for denial and termination of assistance because of family action or failure to act.
23. Procedures for when and how to request an informal review and informal hearing.
24. Procedures for notifying the CoPHD and/or HUD of program abuse such as side payments, extra charges, violations of tenant rights, and owner’s failure to repair deficiencies in the assisted unit.
25. The family's rights as a tenant and a program participant.
26. Requirements for reporting changes between re-examinations.
27. Violence Against Women Act of 2005 Flyer.
Other Information to be Provided at the Briefing
The CoPHD will describe how the program works, and the relationship between the family and the owner, the family and the CoPHD, and the CoPHD and the owner.
The briefing presentation emphasizes:
1. Applicant family and owner responsibilities.
2. Where an applicant family may lease a unit inside and outside CoPHD’s jurisdiction.
3. How portability works for applicant families eligible to exercise portability.
4. Advantages to moving to areas with low concentration of poor families if family is living in a high poverty census tract in the CoPHD 's jurisdiction.
5. Exercising choice in residency through careful and thorough consideration of available units.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2024 Administrative Plan
8-5
If the applicant family includes a person with disabilities, the CoPHD will ensure compliance with CFR 8.6 to ensure effective communication.
Participant Briefing Packet
Participant families will be provided with a briefing packet. The documents and information provided in the briefing packets for the HCVP will comply with all HUD requirements. The CoPHD also includes other information and/or materials which are not required by HUD.
The participant family is provided with the following information and materials:
1. The CoPHD Statement of Policies, which provides guidance and information on the following matters:
Rental Assistance Programs (RAP)
RAP Regulations
RAP Administrative Plan
Obligations of the Family
Term of Voucher/Extension/Suspension
Request for Tenancy Approval
Housing Quality Standards
Rent Reasonableness
Repayment/Recovery of Outstanding Debt
Moves with Continued Assistance
Portability Procedures
Denial and Termination of Assistance
Informal Review and Informal Hearing Procedures
Termination of Housing Assistance Payments Contract
2. The term of the HCV, and the CoPHD’s policy for requesting extensions to the term of the HCV or suspensions of the HCV.
3. A description of the method used to calculate the assistance payment, information on Fair Market Rents, Payment Standards and Utility Allowances.
4. Rent Estimate form
5. How the maximum allowable rent is determined, including the rent reasonableness standard.
6. Guidance and materials to assist the family in selecting a unit, such as proximity to employment, public transportation, schools, shopping, and the accessibility of services. Guidance will also be provided to assist the family to evaluate the prospective unit, such as the condition, whether the rent is reasonable, average utility expense, energy efficiency, and security. A Tenant Tool Kit with tips on how to conduct a successful housing search will also be provided to the family.
7. The boundaries of the geographical area in which the family may lease a unit, including an explanation of portability along with the HUD Portability Handout.
8. The CoPHD Proposed Lease and HUD Tenancy Addendum.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2024 Administrative Plan
8-6
9. The Request for Tenancy Approval (RFTA) packet and a description of the procedure for requesting approval for a unit. The packet will include the following forms:
• Request for Tenancy Approval
• Renting to Relatives Disclosure Notice
• Inspection Checklist
• Proposed Lease Agreement
• Disclosure of Information on Lead-Based Paint and/or Lead-Based Paint Hazards • Statement of Property Ownership
• W-9 Request for Taxpayer Identification Number and Certification • Vendor List Questionnaire (Form AA-1)
10. The HUD brochure on how to select a unit and/or the HUD brochure "A Good Place to Live" on how to select a unit that complies with HQS.
11. The Environmental Protection Agency booklet “Protect Your Family From Lead In Your Home” and information about where blood level testing is available.
12. Information on Federal, State and local equal opportunity laws including the pamphlet "Fair Housing: It's Your Right," other information about fair housing laws and guidelines, and the telephone numbers of the local fair housing agency and the HUD enforcement office.
13. The CoPHD’s Available Housing List including property owners or other parties willing to lease to applicant/participant families. The CoPHD will only provide contact information to applicant/participant families with the permission of the property owner.
14. Information on the City of Pasadena’s housing search website (pasadenahousingsearch.com) and additional free property rental websites.
15. If the family includes a person with disabilities, the CoPHD will provide, if available, resources for locating accessible units.
16. The Obligations of the Rental Assistance Program Participant Family.
17. The grounds for denial and termination of assistance because of family action or failure to act.
18. Procedures for when and how to request an informal review and informal hearing.
19. Procedures for notifying the CoPHD and/or HUD of program abuse such as side payments, extra charges, violations of tenant rights, and owner’s failure to repair deficiencies in the assisted unit.
20. The family's rights as a tenant and a program participant.
21. Requirements for reporting changes between re-examinations.
22. Violence Against Women Act of 2005 Flyer.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2024 Administrative Plan
8-7
If required, participant family members may have to complete the program forms listed below:
• The Things You Should Know.
• The Federal Privacy Act.
• The Notification - Watch Out For Lead-Based Paint Poisoning.
• What You Should Know About EIV.
• Debts Owed to the Public Housing Agencies and Terminations.
Owner Briefings
Owner briefings are held for participating owners and prospective owners who may wish to participate in the program. The purpose of the briefing is to en sure successful owner participation in the program by furnishing the owner with current program information.
C. ENCOURAGING PARTICIPATION IN AREAS WITH LOW CONCENTRATION OF POVERTY
At the briefing, applicant and participant families are encouraged to search for housing in non-impacted areas.
The CoPHD will follow the steps listed below in an attempt to establish a list of units in non-impacted areas:
1. Direct contact with owners.
2. Counseling with the family.
3. Providing information about services in various non-impacted areas.
4. Formal or informal discussions with owner groups.
5. Formal or informal discussions with social service agencies.
6. Meeting with rental referral companies or agencies.
7. Meeting with fair housing groups or agencies.
D. ASSISTANCE TO FAMILIES WHO CLAIM DISCRIMINATION
Fair Housing Laws
The CoPHD will provide the applicant and participant families with information on housing d iscrimination. The telephone number and location of the local Housing Right s Center will also be provided. To report suspected discrimination to HUD, additional information will be provided to the applicant and participant families upon request. If HUD’s Fair Housing makes a finding of discrimination against an owner, the CoPHD will restrict the owner from future participation.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2024 Administrative Plan
8-8
E. SECURITY DEPOSIT REQUIREMENTS [24 CFR 982.313]
Security deposits charged by owners may not exceed those charged to unassisted tenants or the maximum prescribed by State or local law. In addition, owners must follow State or local law in regards to increasing security deposits for tenants with existing leases.
F. TERM OF HCV [24 CFR 982.303]
During the briefing, each family will be issued a HCV which authorizes the family to search for housing and specifies the family’s obligations under the program. It does not constitute admission to the program, which occurs when the lease and contract have been executed.
Initial Term
An applicant and/or participant family will be issued a HCV. The initial term of the HCV must be at least 60 calendar days.
Expirations
The HCV is valid for a period of 60 calendar days from the date of issuance. The applicant and/or participant family must submit a RFTA and proposed lease within the 60 -day period unless an extension has been granted by the CoPHD.
Only one RFTA will be accepted at a time for an applicant and/or participant family and processed by the CoPHD.
If the HCV has expired for an applicant family and has not been extended by the C oPHD or expired after an extension, the applicant family’s name will be removed from the waiting list . The family will not be entitled to an informal review. The applicant family will need to re-apply during the next open enrollment.
If the HCV has expired for a participant family and has not been extended by the CoPHD or expired after an extension, the participant family’s participation under the HCVP terminates/ends. The CoPHD will process an End of Participation. The participant family will not be entitled to an informal hearing. If the family is currently assisted, they may remain as a participant in their unit if there is an assisted lease/contract in effect and the owner wishes to continue the family tenancy.
Suspensions
The CoPHD will suspend the initial or any extended term of the voucher from the date the family submits a RFTA until the date the CoPHD notifies the family in writing whether the RFTA has been approved or denied. If the RFTA has been denied, the CoPHD will provide the family with another RFTA and the family will be credited the number of days from the date the RFTA was received through the cancellation date or the expiration date of the HCV, whichever is less.
Suspension will be denied for the following reasons:
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2024 Administrative Plan
8-9
1. The applicant /participant family and the property owner are related and failed to disclose this information.
2. The property owner and HCV holder reside in the same unit.
3. The unit is occupied by someone other than the applicant/participant family.
In cases when the applicant/participant family has committed fraud, suspension of the RFTA will be denied and t he HCV will be canceled. The applicant/participant family will be informed or their right for an informal review or informal hearing if they disagree with the CoPHD’s decision to cancel the HCV. See Chapter 18 of this Plan “Complaints and Appeals”.
Extensions
An applicant and participant family may request an extension of the HCV time period. The applicant and participant family must submit a log reflecting their attempt to locate a unit during the HCV term. All requests for extensions must be received prior to the expiration date of the HCV.
Extensions are permissible at the discretion of the CoPHD, up to 180 days from the date of issuance, primarily for these reasons:
1. The CoPHD is satisfied that the applicant or participant family has made a reasonable effort to locate a unit throughout the initial and/or extensions of term.
2. Extenuating circumstances such as disability, hospitalization or a family emergency for an extended period of time which has affected the family’s ability to find a unit within the initial and/or extension term.
Family must submit documentation supporting the family circumstance , which will then be verified by the CoPHD.
3. The family was prevented from finding a unit due to disability, accessibility requirements or for a larger size unit requirement of four or more bedrooms. The Search Record is part of the required verification.
NOTE: Reasonable effort is define d as “for every 3 days, the family must have contacted a n owner , management company , agent, and/or viewed a rental property.” For example, if the family had 60 days, then the family needs to have 20 properties listed on the request for an extension.
The CoPHD may grant an additional 60 days over the 180 days as a reasonable accommodation for persons with a disability provided that the family has made a reasonable effort to locate a unit throu ghout the initial and extension terms. This extension would be considered a final extension. See Charter 1 of this Plan, “Statement of Policies and Objectives” for additional information on reasonable accommodation.
The CoPHD has the discretion to grant an extension at the time of issuance up to 120 days which will allow for the full 180 days to be issued. Families will not be granted any additional extensions.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2024 Administrative Plan
8-10
Assistance to HCV Holders
Applicant or Participant families who require additional assistance during their search may contact the CoPHD to request a marketing list and will be referred to the Pasadena Housing Search website . HCV holders will be notified at their briefing that the CoPHD periodically updates the listing of available units and how the updated list may be obtained.
The CoPHD will provide limited assistance to families in their negotiations with owners and provide other resources related to families search for housing. Family will be required to present the ir HCV and proper identification before a marketing list will be provided.
For families who have not been able to secure a unit for lease within the first sixty (60) to ninety (90) days fr om the date of voucher issuance, the CoPHD may request the family to attend a meeting to assess their progress in locating a unit. The CoPHD will review the housing search process, address the family’s concerns in locating a unit and provide additional resources if available.
Transfer of HCV
Applicant Family
Once a HCV has been issued to an applicant family, the HCV is non -transferable. However, in the event that the head of household has passed away or is permanently residing in a convalescent home, the HCV may be transferred to the approved spouse listed on the Personal Declaration for Rental Assistance Benefits form and Application. In all other cases, the CoPHD will send notification that the HCV has been cancelled and removed their name/application from the waiting list.
Participant Family
Once a HCV has been issued to a participant family, the HCV may be re -assigned based on the conditions stated in Chapters 6 & 12 of this Plan.
For the remaining member of the assisted family, please refer to Chapter 12 of this Plan , “Re -Examinations” for additional information.
In the event that the original family members are minors, please refer to Chapter 6 of this Plan, “Factors Related to Total Tenant Payment Determinations”.
G. DISCLOSURE OF FAMILY INFORMATION TO OWNER [24 CFR 982.307]
The CoPHD must give the owner the following information upon their request:
1. The family’s current and prior address (as shown in the CoPHD records); and
2. The name and address (if known to the CoPHD) of the landlord at the family’s current and prior addresses.
The CoPHD will inform the families of the CoPHD policy on providing information to owners. The statement will be DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2024 Administrative Plan
8-11
included in the information packet that is given to a family when the family has been selected to participate in the HCVP or at the time the family is issued a HCV to move with continued assistance. The CoPHD will give the same information to families and owners.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
9-1
CHAPTER 9
REQUEST FOR TENANCY APPROVAL AND CONTRACT EXECUTION
INTRODUCTION [24 CFR 982.305 (a)]
After families are issued a Housing Choice Voucher (HCV), they may search for a unit anywhere within the jurisdiction of the CoPHD or outside of the CoPHD‘s jurisdiction if they qualify for portability. The family must find an eligible unit under the program rules, and with an owner who is willing to enter into a Housing Assistance Payments (HAP) Contract with the CoPHD. This Chapter defines the types of eligible housing, the CoPHD's policies which pertain to initial inspections, lease requirements, owner disapproval and the processing of a Request for Tenancy Approval (RFTA).
A. REQUEST FOR TENANCY APPROVAL [24 CFR 982.305 (b), 982.313]
The RFTA, Inspection Checklist, a copy of the proposed lease, including the HUD prescribed Tenancy Addendum, Lead-Based Paint Disclosure Information form and the Renting to Relatives Disclosure Notice must be submitted by the family during the term of the HCV. The family and owner will be re quired to complete all areas of the RFTA including the year the property was constructed and disclosure information regarding Lead Based- Paint.
The CoPHD will not permit the family to submit more than one RFTA at a time.
The RFTA will be approved if:
1. The unit is an eligible type of housing.
2. The unit meets HUD's Housing Quality Standards (HQS), local housing codes and any additional criteria identified in this Administrative Plan.
3. The rent to owner is reasonable.
4. The family initially receives tenant -based assistance for occupancy of a dwelling unit, and if the gross rent of the unit exceeds the applicable payment standard for the family, the family share does not exceed 40% of the family’s monthly adjusted income.
5. The security deposit amount is not in excess of state law, private market practice or in excess of amounts charged by the owner to unassisted tenants.
6. The proposed lease complies with HUD and CoPHD requirements and state
and local law.
7. The owner is approvable and there are no conflicts of interest.
8. The owner has provided all requested ownership documents within the required deadline.
9. The CoPHD will review the required CoPHD forms and ownership documents listed below , as DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
9-2
applicable to determine whether they are acceptable:
Renting to Relatives Disclosure Notice
CoPHD Joint Owner/Tenant Inspection Checklist
Proposed Lease with the HUD Tenancy Addendum
Disclosure of information Lead-Based Paint and/or Lead-Based Paint hazard Statement of Property Ownership:
Part A - Declaration of Property Ownership
Part B - Housing Assistance Payment Information
Part C - Notarized Agent Authorization
Part D - Section 8 Landlord Certification
Request for Taxpayer Identification Number and Certification (W-9) Form Recorded Property Grant Deed
Current Property Tax Bill (or alternately verification of current property tax status through LA County website)
Certificate of Inspection and Code Compliance
Property Management Agreement, if applicable
Partnership Agreement & Resolution for Signatory, if applicable Corporate Bylaws & Resolution for Signatory, if applicable Operating Agreement for Limited Liability Company (L.L.C.), if applicable Vendor List Questionnaire (Form AA-1)
Families who plan to lease the unit the y currently reside in and have household members who are not part of the CoPHD approved household composition will be required to submit documents supporting their place of residence.
The family will be required to submit documents to the CoPHD as proof of new residence within 15 days of submitting a RFTA packet. The CoPHD will not conduct an inspection, approve a lease or execute a HAP contract until it is verified the household consist of the approved family members only. Acceptable forms of documentation as proof of residence may include, but is not limited to, lease agreement; rent receipts; utility bills; vehicle registration and Driver License.
Disapproval of RFTA
If the CoPHD determines that the RFTA cannot be approved for any reason, the owner and the family will be notified in writing.
If an RFTA is not approved, the CoPHD will furnish another RFTA packet to the family providing there is remaining time on the Housing Choice Voucher.
The RFTA will be disapproved if:
1. The owner and tenant fail to disclose they are related.
2. The unit is currently occupied by the owner.
3. The unit is currently occupied by someone other than the voucher holder.
4. The rent is unaffordable.
5. The owner has not submitted the required property ownership information to the CoPHD.
6. The property is in foreclosure.
7. The owner failed to correct deficiencies within the given deadline.
8. The family did not move into the unit within 30 days from the date of the passed initial inspection.
9. The family fails to submit proof of residency for the non CoPHD approved household members within 15 days after submitting a RFTA packet.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
9-3
B. ELIGIBLE TYPES OF HOUSING [24 CFR 982.352]
The CoPHD will approve any of the following types of housing in the HCV Programs:
1. Structure Types:
a. Single Family Detached;
b. Row House or Townhouse;
c. Duplex or Two-Family Dwelling; and
d. Multi-Family (low rise 2-4, high rise 5 or more).
2. Independent Group Residences.
3. Congregate Facilities (only the shelter rent is assisted).
4. Single Room Occupancy.
5. CoPHD Owned Units (HUD-prescribed requirements).
The CoPHD may not permit a HCV holder to lease a unit that is receiving project-based assistance or any duplicative rental subsidies.
The CoPHD will not approve:
1. A unit occupied by the owner or by any person with an interest in the unit.
2. Nursing homes or other institutions that provide care.
3. School dormitories and institutional housing.
4. Any other types of housing prohibited by HUD.
C. LEASE REVIEW [24 CFR 982.308]
The CoPHD will review the lease, particularly noting the approvability of optional charges and compliance with regulations and State/local law. The family must also have legal capacity to enter a lease under State and local law.
Responsibility for utilities, appliances and optional services must correspond to those provided on the RFTA.
The form of lease used must be consistent with the form used in the locality by the owner for other unassisted tenants. The lease must include the HUD Tenancy Addendum. The CoPHD may review the lease for compliance with State or local law.
The term of the lease shall not exceed one year. The CoPHD may approve lease terms shorter than one year, if:
(1) The shorter lease term is the prevailing local practice; and
(2) The CoPHD’s approval of a shorter lease term will improve housing opportunities for families.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
9-4
The CoPHD will encourage owners to use the program model lease provided by the CoPHD , which includes the HUD-mandated language. House rules of the owner may be attached to the lease as an addendum, provided they are approved by the CoPHD to ensure they do not violate any HUD fair housing provisions.
Separate Agreements
Separate agreements are not necessarily illegal side agreements. Families and owners will be advised of the prohibition of illegal side payments for additional rent, or for items normally included in the rent of unassisted families, or for items not shown on the approved lease.
The owner and the family cannot enter into any verbal or written agreement to use the attached garage or any external structure attached or detached to the dwelling unit, for living purposes. The owner and the family cannot violate any city ordinance by using such structure for living purposes.
Owners and families may execute separate agreements for services, appliances (other than range and refrigerator) , and other items that are not included in the lease, if the agreement is in writing and approved by the CoPHD.
Any appliances, services or other items which are routinely provided to unassisted families as part of the lease (such as air conditioning, dishwasher or garage) or are permanently installed in the unit, cannot be put under s eparate agreement and must be included in the lease. For there to be a separate agreement, the family must have the option of not utilizing the service, appliance or other item.
The CoPHD is not liable for unpaid charges for items covered by separate agreements and nonpayment of these agreements cannot be cause for eviction.
If the family and owner have come to a written agreement on the amount of allowable charges for a specific item, so long as those charges are reasonable and not a substitute for higher rent, they will be allowed.
All agreements for special items or services must be attached to the lease approved by the CoPHD. If agreements are entered into at a later date, they must be approved by the CoPHD and attached to the lease.
Owners will be required to submit a copy of the ir written house rules signed by the tenant prior to the approval of the RFTA, if applicable.
If the owner makes modifications to the unit, the costs should be recovered through the rent collected, not by having the family pay for the modifications. Exception will be considered if the modifications are such that they most likely would be removed if the family moved out or if the modifications are specifically to accommodate a family’s disability.
D. INITIAL INSPECTIONS [24 CFR 982.305 (a) & (b), 982. 401]
See Chapter 10 of this Plan, "Housing Quality Standards and Inspections."
The family must take possession and have moved into the unit within 30 days of the passed initial inspection. The initial inspection will be voided if the family has not taken possession and moved into the unit within 30 days.
If the initial inspection has been voided, the CoPHD will conduct another initial inspection. See Chapter 10 of this Plan, “Housing Quality Standards and Inspections.”
E. LEASE EXECUTION
The owner is responsible for obtaining the tenant’s signature on the executed lease. The owner must submit the executed lease to the CoPHD within 30 days of the lease effective date. The CoPHD may not honor the lease if the DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
9-5
owner submits the lease 30 days after the effective date o n the lease. If the executed lease is received by the CoPHD 30 days after the effective date of the lease, the lease will be voided . The effective date of the lease will be revised and the process starts over.
F. RENT LIMITATIONS [24 CFR 982.503]
The CoPHD has been authorized by HUD to approve rents which are higher than the published Fair Market Rents (FMR). These rents are termed “area exception rents.” Approval of any area exception rent is based on the census tract the unit is located in
and remains subject to rent reasonableness. Additionally, at the time a family initially receives rental assistance or any time a participant family moves to a new unit with continued assistance, the rent burden of the family may not exceed 40% of the family’s monthly adjusted income.
Area exception rents will be utilized to:
1. Expand housing opportunities for families to move from poverty-impacted areas.
2. Make accessible units available to persons with disabilities.
3. Increase the housing choices available to low-income families.
For the HCVP, the CoPHD will make a determination as to the reasonableness of the proposed rent in relation to comparable units available for lease in the private unassisted market and the rent charged by the owner for a comparable assisted or
unassisted unit in the building or premises. See Chapter 11 of this Plan, “Owner Rents, Rent Reasonableness, and Payment Standards.”
G. INFORMATION TO OWNERS [24 CFR 982.307 (b), 982.54 (d)(7)]
If requested, t he CoPHD will provide prospective owners with the address of the family, and the names, addresses and telephone numbers of the family’s current and previous landlord, if known, provided that such request is received in writing.
The CoPHD will make an exception to this requirement if the family's whereabouts must be protected due to domestic abuse or witness protection.
The CoPHD will inform owners that it is the responsibility of the owner to determine the suitability of prospective tenants. Owners will be encouraged to screen families for rent payment history, eviction history, damage to units and other factors related to the family's suitability as a tenant.
The CoPHD's policy on the Disclosure of Information to Owners is included in the briefing packet and will apply uniformly to all families and owners.
H. CoPHD DISAPPROVAL OF OWNER [24 CFR 982.306]
For purposes of this section, "owner" includes a principal or other interested party.
The CoPHD may disapprove the owner for the following reasons:
1. HUD or other agencies directly related informed the CoPHD that the owner has been disbarred, suspended or subject to a limited denial of
participation under 24 CFR part 24.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
9-6
2. HUD has informed the CoPHD that the Federal government has instituted an administrative or judicial action against the owner for violation of the Fair Housing Act or other Federal equal opportunity requirements and such action is pending.
3. HUD has informed the CoPHD that a court or administrative agency has determined that the owner violated the Fair Housing Act or other Federal equal opportunity requirements.
4. The owner has violated obligations under a HAP C ontract under Section 8 of the 1937 Act (42 U.S.C. 1437f).
5. The owner has committed fraud, bribery or any other corrupt or criminal act in connection with any Federal housing program.
6. The owner has engaged in drug-related criminal activity or any violent criminal activity.
7. The owner has a history or practice of non-compliance with the HQS for units leased under the tenant -based programs or with applicable housing standards for units leased with project-based rental assistance or leased under any other Federal housing program.
8. The owner has a history or practice of renting units that fail to meet State or local housing codes.
9. The owner has not paid State or local real estate taxes, fines or assessments.
10. The owner has a history of refusing to evict families who disturb the peaceful enjoyment of the property , engage in drug-related criminal activity, or threaten the health or safety of other residents, managers, CoPHD employees or the owner.
11. The CoPHD will not approve a unit if the owner and any family member are related. Family members include but are not limited to, the parent,
spouse, child, grandparent, grandchild, sister, brother, son, daughter, uncle, aunt, niece, nephew, cousin, related by adoption, related by marriage and domestic partners.
If the family requests reasonable accommodation to rent from a relative, the CoP HD may approve if the CoPHD determines that approving the unit will provide reasonable accommodation for a family member who is a person with disabilities.
12. The owner has engaged in or threatened abusive or violent behavior towards CoPHD personnel.
I. CHANGE IN TOTAL TENANT PAYMENT (TTP) PRIOR TO HAP CONTRACT EFFECTIVE DATE
When the family reports changes in factors that will affect the Total Tenant Payment (TTP) prior to the effective date of the HAP Contract, the information will be verified and the TTP will be recalculated. If verifications are more than 60 days old prior to the effective date of the HAP Contract, new verifications must be obtained by the CoPHD.
If the TTP equals or exceeds the gross rent, payment standard, or if the family income is now found to exceed the income limits of the program, the CoPHD will not enter into a HAP Contract and the RFTA will be rescinded.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
9-7
J. HAP CONTRACT EXECUTION PROCESS [24 CFR 982.305(c)]
The CoPHD prepares the HAP Contract for execution. The family and the owner will execute the lease agreement, and the owner and the CoPHD will execute the HAP Contract. Copies of the documents will be furnished to the parties who signed the respective documents.
The CoPHD schedules group briefings and/or individual meetings for new owners and any other owners who wish to attend.
The HAP Contract may not be executed more than 60 days after commencement of the lease term and no payments will be made until the contract is executed. However, CoPHD will not penalize the owner and the family due to administrative errors.
The following CoPHD representative(s), upon approval of the Housing Director, are authorized to execute a contract on behalf of the CoPHD:
1. Housing Assistance Officer
2. Housing Specialist
3. Senior Project Manager
4. Program Coordinator
Owners must provide the current address of their residence (not a Post Office Box) and a business or home telephone number. If the assisted household leases a property owned by relatives, the owner's current address must not be the same as the assisted unit's address.
The CoPHD will require that Owners must provide a Taxpayer Identification number or Social Security number using the most current IRS W -9 Form. For existing Owners, the W -9 Form will be updated every three years, or with any change of payee, address, or Owner name change. Property ownership will be verified using Realquest or a comparable electronic database. In cases where the electronic database does not provide adequate verification, or where the data obtained conflicts with what has been presented by the Owner, the Owner will be required to provide a copy of a recorded property Grant Deed. The CoPHD will obtain verification that property taxes are current via the Los Angeles County online property tax database. In cases where the online database does not provide adequate verification, a copy of the property tax bill will be requested. A copy of the Property Management Agreement will be required if a management agent manages the property.
In order for owners/payees to receive direct deposit of Housing Assistance Payments, they must enroll online at the paymode web site address www.bankofamerica.com/paymode/cityofpasadenaca.
K. CHANGE IN PROPERTY OWNERSHIP
A change in property ownership requires execution of an Assumption of Obligations and Benefits c ontract. The CoPHD will provide the owner with copies of the existing HAP C ontract, lease agreement , and current notice of Annual Recertification/Rent Changes.
The new owner will be required to complete the Renting to Relative Disclosure Notice prior to the execution of the Assumption of Obligations and Benefits Contract. If the family and the new owner is related, both parties will not be allowed to enter into an Assumption of Obligations and Benefits contract.
The CoPHD will process a change of property ownership upon receipt of the requested documents listed below:
Recorded Property Grant Deed
Closing Escrow Documents
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
9-8
Statement of Property Ownership (Parts A-D)
Request for Taxpayer Identification Number and Certification (W-9) Form Vendor List Questionnaire (Form AA-1)
Property Management Agreement, if applicable
Trust documentation, if applicable
Partnership Agreement & Resolution for Signatory, if applicable Operating Agreement for Limited Liability Company (L.L.C.), if applicable Corporate Bylaws & Resolution for Signatory, if applicable.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
10-1
CHAPTER 10
HOUSING QUALITY STANDARDS AND INSPECTIONS
[CFR 982.401, 982.404, 982.405]
INTRODUCTION
Housing Quality Standards (HQS) are the HUD -established minimum quality standards for rental assistance programs. Verification of HQS is required both at initial occupancy and at least biennially (that is, every other year) during the term of the lease. HQS standards apply to the building and premises, as well as the unit. City of Pasadena Housing Department (CoPHD) policy states that newly leased units must pass the HQS inspection before the beginning date of the assisted lease and HAP contract. This chapter describes CoPHD’s procedures for performing HQS inspections as well as standards for the timeliness of repairs. It also explains the responsibilities of the owner and family, and the consequences of non -compliance with HQS requirements for both families and owners. The use of the term “HQS” in this Administrative Plan refers to the combination of both HUD and CoPHD’s requirements outlined in this chapter.
HQS are HUD’s minimum quality standards for all rental assistance programs. HQS compliance is required both at initial occupancy and during the term of the lease. HQS applies to the building and premises, as well as the unit.
A. GUIDELINES/TYPES OF INSPECTIONS [24 CFR 982.401, 982.405]
All units must meet:
Basic Housing Quality Standards (HQS)
UNIT MUST BE DECENT, SAFE AND SANITARY. THIS MEANS THE FOLLOWING:
1. Adequate space and security are required. The dwelling unit must have at least one bedroom or living/sleeping room for each two persons. Exterior doors and windows must have working locks. The assisted unit cannot have any double keyed locks on any doors or windows in the unit. Each sleeping room must include a closet (portable closets may be substituted) with closet door(s) or curtains and the room must be at least 90 square feet to qualify as a bedroom.
2. Sanitary requirements specify a private indoor toilet, hot and cold running water for the bathtub or shower and the fixed basin. Either a window that opens or other adequate exhaust ventilation is required for the bathroom.
3. Kitchens must have a sink with hot and cold running water, adequate space for food storage, preparation and serving, and disposal facilities for garbage. The stove and refrigerator must be fully operational and may be provided by owner or family.
4. The dwelling unit must not contain un -vented room heaters that burn gas, oil or kerosene. The CoPHD does not allow the use of portable electric heaters in place of an installed heater.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
10-2
5. The living room and each bedroom must have at least two electrical outlets in proper operating condition.
Permanent overhead or wall -mounted light fixtures may count as one of the required electrical outlets.
There must be at least one window in the living room and each sleeping room.
6. The kitchen area and the bathroom must have a permanent ceiling or wall light fixture in proper operating condition. The kitchen area must also have at least one electrical outlet in proper operating condition.
7. The unit must be structurally sound with no severe defects. The entrance to the unit must not present a danger of tripping, and elevators must be in safe operating condition.
8. The interior must be free of all dangerous pollutants, such as carbon monoxide, sewer gas, fuel gas and dust.
9. There must be an approved safe water supply.
10. The owner must inform the family if the building was constructed prior to 1978. This will alert the family to the possibility of exposure to the hazards of lead-based paint poisoning.
11. Access to the unit must not be through any other private properties. In addition, the building must provide an alternate means of exit in case of fire. This includes provision of release mechanisms any on security bars when installed in bedroom without a security door.
12. The site and neighborhood must not be subject to serious adverse environmental conditions (i.e., flood, fire, disturbing noise, vermin or rodent infestation, sewage hazards and excess accumulation of trash).
13. The unit must be free of vermin, insects, and rodent infestation. Screens for windows must be provided to prevent entry of insects.
14. An operable working smoke detector must be installed in each bedroom/sleeping room/basement.
15. The hot water heater must have a pressure relief valve with a drainpipe pointing downward and ending about six inches above the floor. Hot water heater must be securely strapped. It must also be located, equipped and installed in a safe manner.
16. Carbon monoxide detectors must be installed in all units within 10 feet of each separate sleeping area effective January 1, 2013.
17. All three prong electrical outlets must be grounded.
18. Fire extinguishers are required for all structures that consist of five units or more in accordance with Section 901.4.3 of the International Fire Code Standards.
Efforts will be made to encourage owners to provide housing above HQS minimum standards.
All utilities must be on in the rental unit at the initial inspection and remain in service during the term of the lease.
The dwelling unit must have an oven, a stove or range, and a refrigerator of appropriate size for the family. All of the equipment must be in proper operating condition. Either the owner or the family may supply the equipment. A microwave oven may be substituted for a family- supplied oven and stove or range. A microwave oven may be DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
10-3
substituted for an owner-supplied oven and stove or range if the family agrees, and if microwave ovens are furnished instead of an oven and stove or range to both subsidized and unsubsidized families in the building or premises.
Inspectors will not enter a unit if the family reports beg bugs infestation. The CoPHD will notify the owner in writing to inspect and/or treat unit for bed bugs before the HQS inspection can be conducted.
There are five types of inspections the CoPHD will perform:
1. Initial/Move-In: Conducted upon receipt of an approved RFTA.
a. Ownership documents submitted and approved.
`
b. Contract rent pre-negotiated.
2. Annual/Biennial: Conducted within 24 months of the last annual inspection date.
3. Special/Emergency: May be conducted upon request from the owner, family, an agency, third party, or CoPHD. CoPHD may periodically require special inspections to ensure family ’s compliance with the HCVP Family Obligations. Emergency inspection s that may endanger the health and safety of the family will take precedence over all other inspections.
4. Move-Out/Vacate: May be c onducted upon owner or family’s request no more than 5 days after the family has vacated the property.
5. Quality Control: Conducted for at least five percent of all units which have been inspected during the CoPHD’s previous fiscal year.
B. ACCEPTABILITY CRITERIA AND EXCEPTIONS TO HQS [24 CFR 982.401]
The CoPHD adheres to the acceptability criteria in the program regulations and HUD Inspection Booklet and local codes.
C. INITIAL, ANNUAL, & BIENNIAL INSPECTIONS
In general, the CoPHD conducts biennial HQS inspections for units housing Housing Choice Voucher Program (HCVP) participants, including VASH, Non- Elderly Disabled, Mainstream, and Emergency Housing Voucher programs, with exceptions for new program participants, units that failed the last inspection due to health and safety or emergency repair items, and units that were abated during the last inspection cycle. Units housing HOPWA and Continuum of Care participants are inspected annually in accordance with regulations for those programs.
The CoPHD conducts biennial inspects for units that passed inspection with no life and safety deficiencies or emergency repair items (listed in 10D) during the last scheduled annual inspection. Biennial inspections will be conducted no later than 24 months from the last passed HQS inspection.
An annual inspection will be conducted no later than 12 months after the initial inspection for new program participants, for u nits that failed an annual or biennial inspection due to a life and safety or emergency repair deficiency, and for units that were abated due to uncorrected deficiencies during the prior inspection cycle.
Notification Process
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
10-4
The family must allow the CoPHD to inspect the unit at reasonable times and after reasonable notice [24 CFR 982.551 (d)]. The CoPHD will notify the family in writing at least 5 days prior to the inspection. However, Special Inspections/Program Compliance Inspections conducted by CoPHD do not require any type of notification. It is up to the family whether or not to allow the special inspection . Prior notification will not be given, due to the nature of the inspection.
Generally, all inspections will be conducted by the CoPHD in the following manner:
Monday through Friday, between the hours of 7:30 a.m. to 5:00 p.m.
The family will be mailed a notice of the scheduled date of the inspection with a copy to the owner. If the family fails to honor the scheduled inspection appointment, a final inspection appointment notice will be mailed to the family and the owner. If the family fails to honor the final inspection appointment, a termination of HAP letter will be mailed to the owner and a copy to the tenant. Failure to keep scheduled appointments is a violation of the Obligations of the Family and grounds for termination of rental assistance. See Chapter 15 of this Plan, “Denial or Termination of Assistance”.
The family will be required to contact the CoPHD prior to the inspection, if they are unable to keep the scheduled inspection appointment due to medical reasons and unforeseen circumstances (i.e., death in the family, etc.).
If the head of household cannot be present for the scheduled inspection, family must make arrangements to have an adult (18 years of age or older) present to allow the inspection to be conducted.
Responsibility for Repairs
HQS deficiencies which cause a unit to fail must be corrected by the owner , unless it is a deficiency for which the family is responsible. The family is only responsible for breaches of HQS that are caused by:
1. Non-payment of utilities paid by the family.
2. Not providing or failing to maintain appliances not provided by the owner.
3. Damages to the unit or premises caused by the family or guest beyond normal wear and tear.
Time Standards for Repairs
1. Emergency items which endanger the family's health or safety must be corrected within 24 hours of notification.
2. For non-emergency items, repairs must be made within 30 days.
3. For major repairs, the Housing Specialist may approve an extension beyond 30 days.
D. EMERGENCY REPAIR ITEMS [24 CFR 982.401 (a)]
The following items are considered of an emergency nature and must be corrected by the owner or family (whoever is responsible) within 24 hours of notice by the CoPHD:
1. Lack of security for the unit.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
10-5
2. Waterlogged ceiling in imminent danger of falling.
3. Major plumbing leaks or flooding.
4. Natural gas leak or fumes.
5. Electrical problem which could result in shock or fire.
6. The dwelling unit must have and be capable of maintaining a thermal environment healthy for the human body.
7. Utilities not in service.
8. No running hot water.
9. Broken glass which could cause injury.
10. Obstacles which prevent or block the entrance or exit of the unit.
11. Lack of functioning toilet.
12. Sewer backups.
The CoPHD may give a short extension, not more than 48 hours, whenever the responsible party cannot be notified or it is impossible to affect the repair within the initial 24-hour period.
In cases where there is leaking gas or potential of fire or other threat to public safety, and the responsible party cannot be notified or it is impossible to affect the repair, the proper authorities will be notified by the CoPHD.
If the emergency repair items are not corrected in the time period required by the CoPHD and the owner is responsible, the housing assistance payment will be abated and the HAP Contract will be terminated.
If the emergency repair items are not corrected in the time period required by the CoPHD and are a HQS breach which is a family obligation, the CoPHD will stop housing assistance payments to the owner and propose termination of the rental assistance to the family.
D. HEALTH AND SAFETY ITEMS
If an assisted unit that is otherwise eligible for a biennial inspection fails the HQS inspection due to an emergency repair item as listed in Section 10C or a health and safety item as listed below, the unit will be placed on an annual inspection schedule until no emergency or health and safety items are cited.
The following items are considered health and safety items:
1. Excessive clutter which does not allow free passage throughout the unit or results in an unsanitary condition (for example excessive accumulation of trash outside of a normal receptacle);
2. Significant vermin infestation;
3. Inoperable smoke detector in bedroom or sleeping area.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
10-6
E. CONSEQUENCES IF OWNER IS RESPONSIBLE (NON-EMERGENCY ITEMS)
When it has been determined that a unit on the program fails to meet HQS, and the owner is responsible for completing the necessary repairs in the time period specified by the CoPHD and the repairs are not corrected, the housing assistance payment to the owner will be abated.
Abatement
A Notice of Abatement will be sent to the owner and family. The abatement will be effective the day after a failed re- inspection. The length of the abatement is 30 days.
The CoPHD will inspect abated units within 24 hours , or the next working day , after the owner's or family’s notification that the repairs have been completed. The re-inspection must take place within the 30- day abatement period.
If the owner makes repairs during the abatement period, housing assistance payments will resume on the day the unit passes inspection.
When the CoPHD has been informed that the repairs have been completed, the CoPHD will notify the family or the owner of the re-inspection date.
No retroactive payments will be made to the owner for the period of time the housing assistance payment was abated and the unit did not comply with HQS.
Extensions In Lieu of Abatement
The CoPHD will grant an extension in lieu of abatement in the following cases:
1. The failed items are minor in nature.
2. There is an unavoidable delay in completing repairs due to difficulties in obtaining parts or contracting for services.
3. The owner makes a good faith effort to make the repairs.
4. The repairs are extensive (such as exterior painting or roof repair) and the owner needs time to obtain the funds.
5. The repairs are delayed due to climate conditions.
The CoPHD may extend the time period up to an additional 30 days. However, if the repairs are not completed or substantially completed at the end of that time period, the housing assistance payment will be placed in abatement and/or terminated.
Termination of HAP Contract
If the owner is responsible for repairs and fails to correct all the deficiencies cited prior to the end of the abatement period, the HAP Contract will terminate 30 days from the abatement date. If repairs are completed before the effective termination date, the termination may be rescinded by the CoPHD if the family remains in the unit.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
10-7
If the repairs are completed within 15 days after the termination date, the CoPHD will conduct one final HQS inspection. H ousing assistance payments to the owner will resume effective the date the unit passed inspection.
However, if the repairs are not completed within the 15-day period, the owner and family will be required to enter into a new lease and HAP Contract.
F. DETERMINATION OF RESPONSIBILITY [24 CFR 982.404]
Certain deficiencies are considered the responsibility of the family:
1. Family-paid utilities not in service.
2. Failure to provide or maintain family-supplied appliances.
3. Damages to the unit or premises caused by the family member or guest beyond normal wear and tear which resulted in a breach of HQS.
4. Poor housekeeping and/or excessive clutter.
Families will be notified in writing with an appointment to come into the office for counselling if their annual inspection fails for poor housekeeping two consecutive years. If the family does not show improvement with their housekeeping habits, the CoPHD may propose termination of the family’s rental assistance for breach of HQS and violation of the Family Obligations of the Rental Assistance Program.
The owner is responsible for all other HQS violations.
Extermination services shall be provided by the owner as conditions may require. However, if such infestation is serious and repeated due to the family’s living habits, it may be considered a lease violation and the owner may evict for serious or repeated violations of the lease. The CoPHD may terminate the family's assistance on that basis.
The owner is responsible for informing the CoPHD, in writing, of any family-related deficiencies, and the CoPHD will hold the family responsible for the correction of these deficiencies. The owner must notify CoPHD and the family in writing which party is obligated to correct the deficiencies prior to the re -inspection date. If written notification is not given, all deficiencies are the owner’s responsibility.
G. CONSEQUENCES IF FAMILY IS RESPONSIBLE
If non-emergency violations of HQS are determined to be the responsibility of the family, the CoPHD will require the family make any repairs or corrections. If the repairs or corrections are not made by the re -inspection date, the CoPHD will terminate the HAP Contract and propose terminat ion of assistance to the family. Extensions in these cases must be approved by the Housing Specialist. The owner's housing assistance payments will not be abated for items that are the family's responsibility.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
10-8
H. INITIAL HQS INSPECTION
The initial HQS inspection will be conducted to:
1. Determine if the unit and property meet HQS defined by HUD and this Plan.
2. Document the current condition of the unit as a basis to evaluate whether the future condition of the unit exceeds normal wear and tear.
3. Document the information to be used for determination of rent reasonableness.
The CoPHD shall inspect the unit within ten working days of receiving the complete RFTA package. Please see Chapter 9 of this Plan, “Request for Tenancy Approval ” and “HAP Contract Execution Process” for delays, disapprovals or cancellations of
RFTA.
If the unit fails the initial HQS inspection, the owner will be mailed a re- inspection appointment letter. The owner and family are advised to contact the CoPHD if repairs are done prior to the scheduled re-inspection date.
On an initial inspection, the owner will be given up to 10 days to correct the items noted as deficiencies. At the inspector's discretion , the time period may be extended based on the cost and complexity of work to be done, however, not to exceed thirty days from the initial inspection date.
The owner will be allowed two re -inspections for repairs to be completed. However, if the time period given by the inspector to correct the repairs has elapsed, or the maximum number of re -inspections failed, the RFTA will be rescinded. Photographs will not be accepted for initial inspections that fail to meet Housing Quality Standards.
I. ANNUAL & BIENNIAL HQS INSPECTION [24 CFR 982.405(a)]
Each unit must be inspected annually or biennially during the assisted tenancy to determine if the unit meets HQS, in accordance with the guidelines stated in Section C. of this chapter. HCVP-assisted units must be inspected within 24 months of the last annual inspection. HOPWA and CoC-assisted units must be inspected annually.
The family will be mailed a notice of the scheduled date of the inspection with a copy to the owner. If the family fails to honor the scheduled inspection appointment, a final inspection appointment notice will be mailed to the family and the owner. If the family fails to honor the final inspection appointment, a proposed termination of HAP letter will be mailed to the owner and a copy to the tenant. Failure to keep scheduled appointments is a violation of the Obligations of the Family and grounds for termination of rental assis tance. See Chapter 15 of this Plan, “Denial or Termination of Assistance”.
The family will be required to contact the CoPHD prior to the inspection, if they are unable to keep the scheduled inspection appointment due to medical emergencies and unforeseen circumstances (i.e., death in the family, etc.).
If the head of household cannot be present for the scheduled inspection, family must make arrangements to have an adult (18 years of age or older) present to allow the inspection to be conducted.
HQS deficiencies which cause the unit to fail must be corrected by the owner , unless it is a deficiency for which the family is responsible. If the family is responsible for breach of HQS, the CoPHD will inform the family in writing of their responsibility to correct the deficiencies.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
10-9
The CoPHD will accept photographs from owners and families as proof that minor deficiencies have been corrected in lieu of a re-inspection. Acceptable photographs will be at the inspector’s discretion.
LEAD-BASED PAINT:
The CoPHD will not execute a HAP contract before the owner and the family submit a signed Lead-Based Paint Disclosure form indicating if they have knowledge of the presence of l ead- based paint on the surface on all units built prior to 1978.
The CoPHD will update and maintain a log every quarter of all lead -based paint cases received internal and from the Health Department. The CoPHD will report all Environmental Intervention Blood Lead Level (EIBLL) cases to HUD on a quarterly basis. Each quarter the CoPHD will request a list from the Health Department of all reported cases of lead-based paint for households that consist of children under the age of six with identified EIBLL . T he list will be compared to the CoPHD’s database.
The CoPHD will request a Risk Assessment Report from the Health Department for all assisted units that have been identified with EIBLL children under the age of six. The CoPHD will provide a copy of the Risk Assessment Report to the property owner. The property owner will be required to contact a lead -based paint professional to complete the Reduction Hazard of Identified Lead -Based Paint. The property owner will be given 30 days from the date they are notified in writing by the CoPHD to remove/clear the unit of lead -based paint and provide a Clearance Report to the CoPHD.
If the owner does not provide a Clearance Report to the CoPHD the HAP contract will terminate 30 days from the date the property owner was notified the property contains lead -based paint. The family will be issued a Housing Choice Voucher to re-locate to another unit.
If there is evidence of EIBLL, the CoPHD will keep a copy of each notice, evaluation and clearance or abatement report required, for at least three years after ongoing lead -based paint maintenance or reevaluation activities are no longer required.
Rent Increases
The housing assistance payment to the owner is subject to change after the initial term of the lease , upon a 60 - calendar day written notice to the family and the CoPHD before commencement of any change in rent. The Annual Review and Renewal of HAP Contract rent notice shall state both the new rental amount and the date from which the revised rent is payable. Only one rental increase is allowed annually during the family’s extended term at the time of annual inspection and re-examination. The rent increase will be approved if it meets rent reasonableness.
Contract rent increases to owner will not be approved if the unit is in a failed condition.
The CoPHD will not approve contract rent increases to the owner if the CoPHD has insufficient program funding.
Owners will be informed at the beginning of the families annual process that contract rent increases have been suspended for the next annual lease term until further notice.
If the proposed rent increase submitted by the property owner will cause a rent burden for the family, the CoPHD will negotiate the contract rent with the property owner. If the owner agrees with the negotiated contract rent, the CoPHD will notify the owner in writing the new contract rent and the date the new rent will be effective. If the property owner does not agree to the reduced contract rent , the CoPHD will notify the owner in writing that the rent increase is not affordable for the family and the increase cannot be approved. If the property owner serves the family a Notice to Vacate and the family is eligible for continued rental assistance, the family will be issued a HCV to locate affordable housing.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
10-10
J. SPECIAL INSPECTIONS
If the owner/family would like to request a special inspection, the owner /family must notify the property owner/family prior to CoPHD of the deficiencies and allow reasonable time for correction of the deficiencies. If the deficiencies are not corrected, the CoPHD will conduct a special inspection and notify the owner/family in writing of the deficiencies.
If the deficiencies are not corrected by the follow up inspection, the family’s rental assistance and/or HAP contract may be submitted for termination.
The CoPHD may also conduct a special inspection based on information from third parties such as neighbors or public officials, etc.
The CoPHD will inspect only the items which were reported, however if the inspector notices additional deficiencies that would cause the unit to fail HQS, the responsible party will be notified of their obligation to correct the deficiencies.
K. QUALITY CONTROL INSPECTIONS
Quality control inspections will be performed by the Housing Assistance Officer and/or Housing Specialist on five percent of the units inspected within the last 90 days for each fiscal year. The purpose of quality control inspections is to ascertain that each inspector is conducting accurate and complete inspections, and to ensure that there is consistency among inspectors in the application of HQS.
HOUSING OPPORTUNITY THROUGH MODERNIZATION ACT (HOTMA)
The CoPHD will make a decision regarding implementation of HOTMA provisions for this chapter upon HUD’s issuance of Notice or Regulation as referenced in Chapter 26.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
11-1
CHAPTER 11
OWNER RENTS, RENT REASONABLENESS, AND PAYMENT STANDARDS [24 CFR 982.503, 982.504, 982.505, 982.507, 982.508]
INTRODUCTION
The CoPHD is responsible to ensure rents charged by owners are reasonable based upon objective comparables in the rental market. When the CoPHD has determined the unit meets minimum Housing Quality Standards (HQS), the lease is approvable, the rent is reas onable, and the Housing Assistance Payment (HAP) Contract has been executed, the CoPHD will begin payments to the owner . This Chapter explains the CoPHD’ s procedures for determination of rent reasonableness, payments to owners, adjustments to the payment standards and rent adjustments.
A. PAYMENT STANDARDS FOR THE HOUSING CHOICE VOUCHER PROGRAM (HCVP) [24 CFR 982.503]
The payment standard is initially set by the CoPHD based on the Fair Market Rent (FMR) in effect at the time the consolidated Annual Contributions Contract (ACC) for the first increment of voucher funding is approved by HUD.
The payment standard is used to determine the maximum subsidy which can be paid by the CoPHD on behalf of the family.
The CoPHD voucher payment standard schedule shall establish a payment standard amount for each unit size. For each unit size, the CoPHD may establish a payment standard amount for the whole FMR area, or may establish a separate payment standard amount for each designated parts of its jurisdiction.
B. ADJUSTMENTS TO PAYMENT STANDARDS
[24 CFR 982.503]
Payment standards may be adjusted to increase housing assistance payments in order to keep family rents affordable. The CoPHD will not raise the payment standards so high that the number of families that can be assisted under available funding is substantially reduced. The CoPHD will not raise payment standards if the need is solely to make "high end" units available to voucher holders.
The CoPHD will review the payment standard s annually to determine whether an adjustment should be made for some or all unit sizes. The payment standard will be reviewed according to HUD requirements. The CoPHD may set the payment standard between 90% and 110% of FMR. Additionally, upon the CoPHD’s request, HUD may approve a payment standard lower than 90% or higher than 110%, excluding reasonable accommodation.
The CoPHD may approve on a case by case basis a payment standard amount up to 110% of the published FMR if its payment standards are set below 110% of the FMR in accordance with 24 CFR 982.503. The higher payment standard must be requested by the family and may be approved, as necessary by the CoPHD. For families remaining in their assisted unit and who have requested an exception payment standard, the 40% cap of their monthly adjusted income will be applied. See Chapter 1 of this Plan, “Statement of Policies and Procedures”.
The CoPHD may use some or all of the following measures listed below in making its determination whether an adjustment should be made to the payment standards:
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
11-2
1. Assisted Families' Rent Burden
The CoPHD will review reports showing the percent of income used for rent by HCVP families to determine the extent to which the rent burden is more than 40% of income.
2. Reasonable Accommodation
If the family includes a person with disabilities and requires a higher payment standard for the family, as a reasonable accommodation for such person, the CoPHD may establish a higher payment standard for the family within the CoPHD established range. The CoPHD may establish an exception payment standard of not more than 120 % of the published FMR if required as a reasonable accommodation for a family that includes a person with a disability.
Any unit approved under an exception payment standard must still meet the reasonable rent requirements.
3. Quality of Units Selected
The CoPHD will review the quality of units selected by families before determining any change to the payment standard to ensure that payment standard increases are only made when needed to reach the mid-range of the market.
4. Rent to Owner Increases
The CoPHD will allow one rent increase annually during the family’s extended term at the time of the annual re-examination. The rent increase will be approved if it is affordable and passes rent reasonableness.
5. Rent Reasonableness Database/Average Contract Rents
The CoPHD will compare the payment standards to average rents in its rent reasonableness database and to average contract rents by unit size.
6. Lowering of the Payment Standards
If statistical analysis reveals that the payment standard should be lowered, the CoPHD will lower the payment standards no less than 90% of the current FMR.
However, the CoPHD must obtain HUD approval if the CoPHD wishes to lower the payment standards less than 90% of the current FMR.
The CoPHD may submit a waiver request to HUD for its review and approval to lower the payment standards below 90% of the current FMR if less than 40 percent of participants in the CoPHD’s voucher program are paying less than 30 percent of adjusted monthly income for rent.
If the payment standards are lowered, the CoPHD will apply the reduced payment standard s at the second annual re-examination following the reduced payments standards.
7. Financial Feasibility
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
11-3
Before increasing the payment standard s, the CoPHD may review the budget and project reserve s to determine the impact projected subsidy increases would have on funding available for the program and number of families served.
For this purpose, the CoPHD will compare the number of families who could be served under a higher payment standard with the number assisted under current payment standards.
File Documentation
A file will be retained by the CoPHD for at least three years to document the analysis and findings to justify whether or not the payment standard was changed.
C. CALCULATION OF HOUSING ASSISTANCE PAYMENTS [24 CFR 982.505, 982.508]
The maximum subsidy for each family is determined by the payment standard for the voucher size issued to the family, less 30% of the family's monthly adjusted income.
(a) Use of payment standard. A payment standard is used to calculate the monthly housing assistance payment for a family. The payment standard is the maximum monthly subsidy payment.
(b) Amount of monthly housing assistance payment. The CoPHD shall pay a monthly housing assistance payment on behalf of the family that is equal to the lower of:
(1) The payment standard for the family minus the total tenant payment; or
(2) The gross rent minus the total tenant payment.
(c) Payment standard for family.
(1) The payment standard for the family is lower of:
(i) The payment standard amount for the family unit size; or (ii) The payment standard amount for the size of the dwelling unit rented by the family.
(2) If the CoPHD has established a separate payment standard amount for a designated part of an FMR area in accordance with 24 CFR 982.503 and the dwelling unit is located in such designated part, the CoPHD must use the appropriate payment standard amount for such designated part to calculate the payment standard for the family.
(3) Decrease in payment s tandard amount during the HAP Contract term. If the amount on the payment standard schedule is decreased during the term of the HAP C ontract, the lower payment standard amount generally must be used to calculate the monthly housing assistance payment for the family, beginning at the effective date of the family’s second regular reexamination following the effective date of the decrease in the payment standard amount.
(4) Change in the family unit size during the HAP Contract term. Irrespective of any increase or decrease in the payment standard amount, if the family unit size increases or decreases during the HAP Contract term, the new family unit size must be used to determine the payment standard amount for the family, beginning at the family’s first regular reexamination following the change in the family unit size.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
11-4
Maximum Family Share at Initial Occupancy
At the time the family initially receives tenant -based assistance for occupancy of a dwelling unit, whether it is a new admission or a move to a different unit, the family share may not exceed 40% of the family’s monthly adjusted income. During the initial 12-month term of the lease, the owner may not raise the rent.
D. PAYMENTS TO OWNERS [24 CFR 982.451]
Once the HAP Contract is executed, the CoPHD begins processing payments to the owner. A HAP Register will be used as a basis for monitoring the accuracy and timeliness of payments. HAP is generally disbursed directly from the City of Pasadena’s Finance Department to the owner the 1st and middle of each month. In
cases of demonstrated hardship, an exception may be made with the approval of the Hous ing Director and/or the Housing Assistance Officer.
The Finance Department will be contacted regarding payments that have not been received by the owner/payee.
After the Finance Department has verified that payment was not received, a replacement payment will be processed to the owner/payee.
When subsidies are paid late, owners may assess late fees against the CoPHD where local practice provides for late fees. The CoPHD is not obligated to pay any late payment penalty if HUD determines that late payment by the CoPHD is due to factors beyond the CoPHD’s control.
E. RENT REASONABLENESS DETERMINATIONS [24 CFR 982.507]
Rent reasonableness determinations are made when:
1. Units are placed under a HAP Contract for the first time;
2. Owners request special contract rent adjustments; or
3. Owners request annual or interim rent increases.
The CoPHD will determine and document on a case-by-case basis the approved rent:
1. Does not exceed rents currently charged on new leases by the same owner for an equivalent assisted or unassisted unit in the same building or complex.
2. Is reasonable in relation to rents currently charged by other owners for comparable units in the unassisted market.
At least two comparable units will be used for each rent determination, one of which must be from the first category above if possible. All comparables must be based on the rent that the unit would command if leased in the current market. Leased in the current market means that the unit has been leased within the last 90 days.
The data for other unassisted units will be gathered from periodicals , websites for rental property listings, owner ’s rent roll/schedule and inquiries of owners, professional associations, market surveys and other available sources.
Rent reasonableness determinations for the CoPHD market areas will be compared to similar unassisted units within the same area.
If the owner is reducing and/or allowing some form of rental reduction to the unassisted tenants, the CoPHD will use the rent paid by the tenant plus the reduction, to determine the actual rent the owner is charging for the unassisted DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
11-5
units.
Upon request, the owner must provide the CoPHD their current rent schedule for rents charged for unassisted units on the premises and other locations within the City.
The following factors will be used for rent reasonableness documentation:
1. Location
2. Number of Bedrooms
3. Housing Condition/Quality
4. Amenities
5. Date Built
6. Unit Type
7. Housing Services
The CoPHD will maintain a database on unassisted units for use by staff in making rent reasonableness determinations. The database is updated on an ongoing basis.
DRAFT
12-1
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
CHAPTER 12
RE-EXAMINATIONS
INTRODUCTION
HUD requires the CoPHD to re-examine the income and composition of all families at least annually . In addition, the CoPHD is required to inspect the assisted unit, process requests for rent adjustments and review the utility allowance schedule. These activities must be coordinated to ensure that they are completed in accordance with the regulations. It is a HUD requirement that families report all changes in family composition, but the CoPHD decides what other changes must be reported and the procedures for reporting them. This Chapter defines the CoPHD's policy for conducting annual re-examinations and coordinating annual activities.
It also explains the interim reporting requirements for families and the standards for timely reporting. This chapter is updated to reflect changes implemented in the HOTMA Final Rule published February 14, 2023.
A. ANNUAL ACTIVITIES [24 CFR 982.401, 982.516, 982.517, 982.519]
The CoPHD generates a monthly computerized list of units under contract 120 days before the re- examinations are to take effect. This procedure allows the CoPHD ample time to obtain all required verifications, review contract rent adjustments, conduct annual HQS inspections , and provide reasonable advance notice to both the family and the owner of any changes in the tenant rent and housing assistance payment.
Annual activities for contracts that did not commence on the first of the month must be conducted no later than the first of the month in which the lease was effective.
The CoPHD conducts annual re-examinations of family income and composition which also includes:
1. Applying to current Utility Allowance Schedule: See Chapter 6 of this Plan, “Factors Related to Total Tenant Payment Determination.”
2. Conducting Annual Inspection: See Chapter 10 of this Plan, “Housing Quality Standards and Inspections.”
3. Review of Rent Adjustments: See Chapter 11 of this Plan, “Owner Rents, Rent Reasonableness and Payment Standards.”
An EIV report will be reviewed and printed as part of the annual re- examination process. The CoPHD will complete the Enterprise Income Verification (EIV) System Certification form.
DRAFT
12-2
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
B. ANNUAL RE-EXAMINATION [24 CFR 5.609, 982.516]
The CoPHD must conduct a re-examination of family income and family composition at least annually. The annual re-examination determines the continued eligibility of the family and establishes the housing assistance payment to be made on behalf of the family. Families are required to report all household income and family composition timely and accurately as set forth in the CoPHD ’s Family Obligations. Families will report this information by completing a Personal Declaration for Rental Assistance Benefits form and providing supporting documents to verify income, assets, allowances, and family composition.
The CoPHD must obtain and document in the family’s case file third-party verifications of the following factors:
(i) Reported family annual income;
(ii) Value of assets;
(iii) Expenses related to deductions from annual income; and (iv) Other factors that affect the determination of adjusted income.
If third-party verifications are not contained in the family’s case file, the CoPHD must document why it was not available.
Annual re -examinations should be implemented as of the scheduled effective date even if other annual activities are not complete.
Families who intend to move may be issued an HCV, if eligible for continued rental assistance. See Chapter 13 of this Plan, “Moves with Continued Assistance/Portability” for the eligibility criteria to move. An Annual Searching certification will be processed if the family moves out of the unit prior to the annual re-examination date.
When families move to another dwelling unit, an annual re-examination will be conducted and the anniversary date may change.
Income limits are not used as a test for continued eligibility at re-examination.
The CoPHD will verify with the City of Pasadena’s Finance Department whether families under a Repayment Agreement are current with their monthly payment. If the family is delinquent with the Repayment Agreement, the family will be required to pay full balance within thirty days of the CoPHD notification and the family may be proposed for termination.
Re-examination Notice to the Family
The CoPHD will notify the family by mail of the upcoming annual re- examination approximately 120 days in advance of the anniversary date. The notification will include date and time of the appointment, location of the DRAFT
12-3
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
appointment, family members required to attend, and information supporting family circumstances. Families who are not selected for an office appointment will be notified of the information they need to submit and the deadline for submittal. The notice to the family also instructs the family to call the CoPHD to request another appointment if the family is unable to keep the scheduled appointment. The CoPHD will also mail the notice to a third party if requested as reasonable accommodation for a person with disabilities; however, a written request must be submitted to the CoPHD by the head of household. The request must include the name, address and telephone number of the person appointed to receive the notification. This accommodation will be granted upon verification that they meet the need presented by the disability.
Persons with disabilities who are unable to attend their office appointment will be granted an accommodation of conducting the interview either at the person's home or by telephone.
The CoPHD will schedule an office appointment with family members who recently turned 18 years of age to explain their responsibility under the program, obtain signatures on the Family Obligations, Authorization for the Release of Information/Privacy Act Notice (Form HUD-9886), Debts Owed to Public Housing Agencies and Terminations (Form HUD-52675), Enterprise Income Verification System, Things You Should Know and CoPHD Authorization for Release of Information forms, inquire about income circumstances, and obtain copies of their California Identification or Driver License.
Collection of Information
The CoPHD will mail a Personal Declaration for Rental Assistance Benefits form, Authorization for the Release of Information/Privacy Act Notice (Form HUD-9886), CoPHD Authorization for Release of Information , and Family Obligations with the annual re-examination notice to the family. The head of household will be required to complete and sign a Personal Declaration for Rental Assistance Benefits form, and have all family members 18 years and older sign Form HUD-9886, the CoPHD’s Authorization for Release of Information, and Family Obligations. The completed forms and the information supporting the family’s circumstances must be submitted to the CoPHD by a given deadline as a condition for continued assistance.
Household members claiming zero income, who have recently turned 18 years of age and are attending high school at the time of the annual re-examination, will be required to complete a tenant declaration by submitting a Self-Certification. However, at the next re-examination, a notarized Affidavit will be required if they are still claiming zero income.
Requirements to Attend
All adult household members will be required to attend the re-examination interview, including live-in aides and foster adults. If any adult household member is unable to attend the interview, the family must notify the CoPHD 48 hours in advance of appointment and request to have appointment re-scheduled to allow all adult household members to be present. If any adult household member is absent at time of appointment, the family will not be seen and the appointment will be considered a missed appointment.
The CoPHD will schedule an appointment for families whose EIV Report reveals a discrepancy.
DRAFT
12-4
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
Failure to Respond to Notification for Re-examination
The annual re-examination notification informs the family that failure to keep the appointment, call to re - schedule, submit program forms and/or supporting documents by the established deadline, is a violation of the Family Obligations and grounds for proposed termination of rental assistance.
If the family fails to keep the appointment, or submit the programs forms, and/or supporting documents, a final appointment will be scheduled or a final deadline will be established. If the family fails to comply with all of the CoPHD’s request, the family will be given proper notice of the proposed termination via “certified and regular mail,” and informed of their right to request an informal hearing and the deadline to submit the written request.
The CoPHD will also notify the owner, in writing, of the proposed termination of the HAP Contract.
Exceptions to these policies may be made by the CoPHD if the family is able to document an emergency situation that prevented them from canceling, re-scheduling, or attending the appointment or submitting the requested information.
Documents Required from the Family
In the annual re-examination notification letter to the family, the CoPHD will include instructions for the family to submit the following information by a given deadline:
1. Completed Personal Declaration for Rental Assistance Benefits forms.
2. Completed, signed, and dated Form HUD -9886 (if a family member has turned 18 or a new household member over 18 is proposed to be added), and CoPHD Authorization for Release of Information.
3. Signed Family Obligations by all adult family members.
4. Current documentation of income sources for all family members.
5. Current documentation of disposed assets, the cash value of assets, and income derived from assets.
6. Current documentation of any deductions/allowances.
7. Notarized Affidavit from adult family members reporting zero income.
8. Completed Self Certification form from adult family members no longer receiving California Work Opportunity and Responsibility to Kids (CalWORKs) due to the expiration of a lifetime or other time limit on welfare benefits and who are reporting zero income.
DRAFT
12-5
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
9. Birth Certificate and Social Security card for new additions to the family due to birth and approved family members by the CoPHD.
10. Completed, signed, and dated 214 Certification form for new additions to the family.
11. Copy of California Identification or Drivers License for family members who turned 18 years old.
12. Copy of Permanent Resident card for family members whose legal status has been adjusted.
13. Copy of renewed Permanent Resident card.
14. Documentation supporting continued disability status for family members whose disability payments have been terminated by the Social Security Administration.
15. Copy of Marriage Certificate or Divorce Decree, if marital status has changed.
16. Other documentation as may be determined necessary by the CoPHD.
17. For individuals enrolled in an institute of higher education, as defined under section 102 of the Higher Education Act of 1965 (20 U.S.C. 1002); refer to Chapter 7 of this Administrative Plan for requirements.
18. Verification of financial aid awards or amounts showing tuition and other s chool fees for all household members receiving financial aid to attend school.
19. Completed Live-in Aide Certification form, if applicable.
Verification of Information
The CoPHD will follow the verification procedures and guidelines described in Chapter 7 of this Plan, “Verification Procedures”. Verifications obtained at re-examination must be dated within 120 days from the date received.
The CoPHD may obtain third-party verifications of the family’s income, assets, allowances and any other factors that affect the determination of adjusted income, tenant rent, and housing assistance payment. The CoPHD will follow the six levels of hierarchy of verification methods established by HUD. See Chapter 7, of this Plan, “Methods of Verification and Time Allowed”. CoPHD staff will properly document the family’s case file where third-party verifications are unavailable.
DRAFT
12-6
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
Moves with Continued Assistance
Families who express i nterest in moving with continued assistance, within or outside of the CoPHD’s jurisdiction, will be required to comply with the procedure established in Chapter 13 of this Plan, “Moves with Continued Assistance/Portability”.
Tenant Rent Increases
If the tenant rent increases, a 30-day notice will be mailed to the family prior to the anniversary date. Once the family has received the notification of the tenant rent increase, this amount may change as a result of additional information that may not have been available at the time of notification (i.e., third-party verification forms). If less than 30 days are remaining before the anniversary date, the tenant rent increase will be effective on the first of the month following the 30-day notice. If there has been a misrepresentation or a material omission by the family, or if the family causes a delay in the re-examination process, there may be a retroactive increase in rent to the anniversary date.
The following are examples where the family waives the right to a proper 30-day notice of tenant rent increase:
• Delay in returning the completed annual re-examination program forms and documentation supporting family circumstances by established deadlines.
• Violation of Family Obligations due to unreported and/or untimely reporting of changes in family circumstances.
• The CoPHD verifies that the family failed to disclose true, complete, and accurate information of family circumstances.
• Failure to keep the scheduled annual re-examination appointment.
The family will be required to reimburse the CoPHD any rental assistance which was overpaid to the owner due to the delay caused by the family. The overpaid rental assistance may be paid in full or by entering into a Repayment Agreement with the CoPHD. See Chapter 17 of this Plan, “Property Owner or Family Debts to the CoPHD”.
Families may be required to move if the re- examination reveals that the tenant rent plus reported household expenses is higher than their monthly reported income. The CoPHD will follow the procedures established in Chapter 13 of this Plan, “Moves with Continued Assistance.”
Contract Rent Increase
If the CoPHD approves a contract rent increase after the annual re -examination, the CoPHD may use the supporting information from the latest approved action. The family will be notified that the tenant rent was DRAFT
12-7
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
based upon most recent household information.
Tenant Rent Decreases
If the annual re- examination reveals that a decrease in family’s income occurred prior to the CoPHD’s notification of the family’s annual re -examination, the decrease in tenant rent may become effective at the family’s anniversary date. The following is an example where the family waives their right to an interim re- examination prior to their annual re-examination:
1. If in the process of reviewing the case the CoPHD determines that a serious violation of the program rules and regulations occurred. The CoPHD may propose the termination of rental assistance for the family in accordance with Chapter 15 of this Plan.
2. Family failed to submit all requested information supporting reported changes.
Families Ineligible for Current HCV Size
Families whose HCV bedroom size has been downsized due to a change in family composition will be informed of the tenant rent based on the new HCV bedroom size effective at the re-examination date. The family will also be informed of the option to remain in the assisted unit paying a higher tenant rent or move with continued assistance.
The family will be required to sign an updated HCV. However, if the tenant rent and household expenses exceed their monthly income they may be required to move.
If the HCV bedroom size has increased due to a change in family composition or approved reasonable accommodation, the new HCV bedroom size will be applied at th e family’s upcoming annual re-examination date. The family will be required to sign an updated HCV.
CoPHD may re-determine reasonable accommodations that are currently in place. Families affected by the change in HCV bedroom size will be informed of their new tenant rent based on their new HCV bedroom size.
The family will be informed of the option to remain in the assisted unit paying a higher rent or move with continued assistance. If the tenant rent and household expenses exceed the monthly income, the family will be required to move. Additionally, the family will be required to sign an updated HCV.
Families Ineligible for Continued Rental Assistance [24 CFR 982.455]
Families found ineligible for continued rental assistance due to a re- examination resulting in zero housing assistance payments will be informed, in writing that their rental assistance will automatically terminate 180 calendar days after the last housing assistance payment to the owner. The family will be informed of their responsibility to report changes in family circumstances by completing an Update of Family C ircumstances form and submit supporting information regarding the change, within 15 days of the change, during the 180-day DRAFT
12-8
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
period. The HAP Contract may be reinstated if the family reports income changes or contract rent increases within this time frame which results in a HAP to be generated.
Changes in the Lease and Rent [24 CFR 982.308]
The CoPHD must approve a new lease and execute a new HAP Contract in the following cases:
• Changes in tenant or owner supplied utilities or appliances.
• Changes governing the term of the lease.
• Offer of a new lease by the property owner.
• Family moves to a new unit (even if the unit is in the same building or complex).
The term of the HAP Contract matches the term of the lease. The owner and tenant will be required to sign a new lease and the owner will also be required to execute a new HAP Contract with the CoPHD.
In cases where there has been a change to the owner supplied utilities or appliances or changes to the term of the lease and the owner fails to return signed new Lease and HAP Contract by given due date, the Housing Assistance Payment will be placed on hold status for no more than 60 days. If new Lease and HAP Contract are not returned within the 60 days of new effective date or mailed date, HAP Contract will be terminated, at no fault of the tenant.
C. REPORTING INTERIM CHANGES [24 CFR 982.516, 982.553]
HUD requires families to report all changes in household composition to the CoPHD between annual re- examinations. This includes additions due to birth, adoption and court -awarded custody of a non-criminal nature. The family must obtain CoPHD approval prior to all other additions to the household.
HUD requires PHAs to process interim re- examinations when a family reports a reduction in income , and prohibits processing an interim re-examination when the family reports a loss of welfare benefits due to fraud or failure to participate in self-sufficiency or work activity. HUD does not require review of EIV to verify tenant employment and income information during an interim reexamination.
The CoPHD requires families to report changes in family composition, income, assets and allowances within 30 days of the change, in writing and submit supporting information on the changes that are being reported. To comply with this obligation, the family must report the change in family circumstances by completing an Update of Family Circumstances form.
DRAFT
12-9
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
The CoPHD will follow the procedures established in Chapter 7 of this Plan, “Verification Procedures” in cases where the family requires a live-in aide as a reasonable accommodation.
Increases in Income
The CoPHD may conduct interim re-examinations when families have an increase in income that results in a 10% or greater change in adjusted income. Families will be required to report all increases in income/assets of all household members to the CoPHD by completing an Update of Family Circumstances form and submitting supporting information regarding the change within 30 days of the increase.
Families who report increases in household income totaling more than 10% of the prior annual income will be scheduled for an interim re-examination, no later than 90 days from the date the i ncrease is reported to the CoPHD. The family’s case file will be documented in cases where no interim re -examination is necessary because the increase in annual income is less than 10%.
The CoPHD will not process an interim re-examination for families reporting an increase in annual income from Social Security and Supplemental Security Income payments if the increase is due to the Cost of Living Adjustment (COLA). However, the CoPHD will document the family’s case.
Decreases in Income
The CoPHD may process an interim re-examination for families reporting a decrease in income that results in a 10% or greater change in adjusted income.and any other changes such as an increase in allowances which would reduce the amount of the tenant rent . The CoPHD will process an interim re- examination for the families if preliminary review of the case reveals that the decrease in income would result in a decrease in tenant rent.
The CoPHD will only verify the change in family circumstances reported by the family, in accordance with Chapter 7 of this Plan, “Verification Procedures” when processing an interim re-examination.
Tenant Rent Decreases
If the annual re-examination reveals that a decrease in the family’s income occurred prior to the CoPHD’s notification of the family’s annual re- examination, the decrease in tenant rent may become effective at the family’s anniversary date. If the family does not waive their right to an interim re- examination prior to their annual re- examination by definition, t he effective date of an interim re -examination will be the first of the following month after the family reports a decrease. However, if the family causes a delay by not submitting requested or required information, the effective date of the decrease will be on the first day of the month after the family submits the information.
DRAFT
12-10
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
Tenant Rent Increases
The family will be given a proper notice of the increase in the tenant rent upon receipt of all sup porting information.
Contract Rent Increase
If the owner requests an increase in the contract rent after the annual re-examination has been approved, the CoPHD may use the supporting information from the latest approved action. Additionally, the CoPHD will review EIV and print the IC N page if the EIV report reveals no change from the latest approved action. The family will be notified that the tenant rent was based upon most recent household information and the CoPHD will remind the family of their responsibility to report all changes in circumstances, within fifteen days of the change.
Administrative Corrections
If the CoPHD makes a calculation error at admission to the program or at an annual re-examination, an interim re-examination will be conducted to correct the error. If there is an increase in the tenant’s rent, the family will not be charged retroactively. However, if the family has overpaid, an adjustment will be made retroactive to the date when the error occurred.
Other Interim Reporting Issues
An interim re-examination does not affect the date of the annual re-examination. An interim re-examination will be scheduled for families with zero or unstable income every 90 days. In addition, the CoPHD will automatically review an EIV report and mail third- party verifications to the Department of Public Social Services, Employment Development Department, and In-Home Supportive Services for families who report zero income as a means of verifying the income status reported by the family.
If there is a change from public assistance income to employment income, the CoPHD will defer the family's rent increase for three months in order to encourage families to move to self-sufficiency.
1. This incentive will only be provided once to any family.
2. This incentive is not provided to persons who work seasonally.
In the following circumstances, the CoPHD may conduct the interim re-examination by mail:
1. Changes that will not result in a change in tenant rent or HCV size.
2. Changes in income that is normal for the family, such as seasonal employment.
DRAFT
12-11
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
3. As a reasonable accommodation when requested ( see Chapter 1 of this Plan, "Statement of Policies and Objectives").
Any changes reported by the family, other than those listed in this section, will be noted in the file by staff, but will not be processed between regularly scheduled annual re-examinations.
D. NOTIFICATION OF RESULTS OF RE-EXAMINATIONS
The CoPHD will notify the family and the owner of the results of the annual re- examination by mailing the Notice of Annual Re-certification/Rent Change. This notice informs the family and the owner of the contract rent, tenant rent, housing assistance payment, effective date of the change, and the family’s next annual re - examination. The notice also informs the family of their right to request an informal hearing if they disagree with the rent adjustment (refer to Chapter 18 of this Plan, “Complaints and Appeals”).
A new lease and HAP Contract will be executed when an owner and/or family requests a new lease, or if there are any changes in the lease requirements governing tenant or owner responsibilities for utilities or appliances.
The family will be notified by mail of their new tenant rent.
E. TIMELY REPORTING OF CHANGES IN INCOME AND ASSETS
Standard for Timely Reporting of Changes
The CoPHD requires that families report interim changes by completing an Update of Family Circumstances and supporting documentation within 30 days of when the change occurs.
If the change is not reported within the required time period or if the family fails to provide documentation or signatures, it will be considered untimely reporting and may be subject to proposed termination of rental assistance.
Procedures when Change is Reported by Tenant in a Timely Manner
The CoPHD will notify the family and owner of any change in the housing assistance payment to be effective according to the following guidelines:
1. Increase in the Tenant Rent is effective on the first of the month following at least a 30-day notice.
2. Decrease in the Tenant Rent is effective the first of the following month in which the change was reported in writing. However, no rent reductions will be processed until all the facts have been verified, even if it results in a retroactive adjustment.
DRAFT
12-12
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
An interim re-examination may be processed based on documentation provided by the family when the change in family circumstances results in a decrease in tenant rent, and after an attempt was made to obtain third-party written verification. However, the case may be re-evaluated upon return of the third-party written verifications to make sure the tenant rent and housing assistance payment were accurately determined. The CoPHD will revise the interim re-examination if the review reveals that the tenant rent and housing assistance payment were over/under estimated.
In cases the family reports a loss of income (i.e. termination of employment, unemployment, etc.) but has applied for benefits (i.e. unemployment, CalWorks, etc.), the CoPHD will process an interim re-examination to avoid a hardship to the family. However, the family will be notified that the interim re-examination will be re- determined once a decision on their application for benefits has been approved along with estimated tenant rent.
Procedures when Change is not Reported by Tenant in a Timely Manner If the family does not report the change as described under Timely Reporting, the family will have caused an unreasonable delay in the interim re-examination process and the following guidelines will apply:
1. Increase in Tenant Rent may be effective retroactive to the date it would have been effective had it been reported on a timely basis. The family will be notified, in writing, of their forfeiture to an advance notice of rent increase due to their untimely reporting of changes in family circumstances.
The family will also be informed of their right to request an informal hearing, in writing, if they disagree with the CoPHD’s decision.
The family will be liable for any overpaid housing assistance payments and may be given an opportunity to enter into a Repayment Agreement, depending on the family’s history under the HCVP, or make a lump-sum payment.
2. Decrease in Tenant Rent will be effective on the first of the month following completion of the process by the CoPHD and not retroactively.
Procedures when Change is not Processed by CoPHD in a Timely Manner
“Processed in a timely manner” means that the change in family circumstances was reported, by completing an Update of Family Circumstances form within 15 days of the change. In this case, an increase in the tenant rent will be effective after the required 30-day notice prior to the first of the month after completion of the process by the CoPHD.
If the change resulted in a decrease in the tenant rent, the overpayment by the family will be calculated retroactively to the date it should have been effective.
F. REPORTING OF CHANGES IN FAMILY COMPOSITION
[24 CFR 982.505, 982.516, 982.315]
DRAFT
12-13
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
All changes in family composition must be reported, by completing an Update of Family Circumstances form, within 15 days of the occurrence. Irrespective of any increase or decrease in the payment standard amount, if the family unit size increases or decreases during the HAP Contract term, the family unit size must be used to determine the payment standard amount for the family beginning at the family’s first regular re- examination following the change in the family unit size.
When a family wishes to add additional members to the household, the CoPHD will follow the procedure outlined below, for members who are 18 years or older, to determine whether or not to approve the new member as part of the family:
1. Family completes Update of Family Circumstances form.
2. Prepare and mail appointment letter to the family.
3. Conduct an interview with the proposed new family member if the individual(s) is 18 years of age or older.
4. Proposed family member(s) reviews, completes, and signs the following program forms:
a) Proposed Addition to Household Update of Family form. b) Form HUD-9886 – Authorization for Release of Information/Privacy Act Notice. c) CoPHD Authorization for the Release of Information.
d) Form HUD-52675 – Debts Owed to the Public Agencies and Terminations. e) What You Should Know About EIV.
f) Things You Should Know.
g) Obligations of the Rental Assistance Program Participant Family (Obligations of the Family). h) Declaration of Section 214 Status.
5. Signs the Client Screening - Criminal History Background form.
6. Collect vital statistics information.
7. Collect income and asset information.
8. Collect allowance information, if applicable.
9. Documents supporting place of residence.
If the proposed family member is a minor other than by birth, the following information must be submitted:
1. Birth Certificate.
DRAFT
12-14
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
2. Social Security Card.
3. Court documents supporting custody (legal guardianship or adoption).
4. Foster care placement documents.
5. Verification supporting income received by or for the minor child(ren).
6. School verification, if applicable.
The U.S. citizenship/eligible immigration status of additional family members must be declared and verified.
The family will be notified, in writing, of the CoPHD’s decision of their request to add the additional family members to the household upon receipt of all supporting information. If the additional family members are approved by the CoPHD, the family will be informed that written approval from the owner is necessary prior to allowing the additional members to move into the assisted unit.
The CoPHD will process an interim re-examination to add the proposed family member. If the addition to the household results in an increase in the tenant rent, the family has the option to waive their right to a proper 30- day notice of rent increase if they wish to allow the proposed family member to move into the assisted unit in less than 30 days.
The CoPHD will follow the procedures established in Chapter 7 of this Plan, “Verification Procedures” in cases where the family requires a live-in aide as a reasonable accommodation.
Increase in Family Size
Increases other than by birth, adoption or court-awarded custody of a non-criminal nature must have the prior approval of the owner and the CoPHD.
If a change due to birth, adoption, court-awarded custody of a non-criminal nature, or need for a live-in aide requires a larger size unit due to overcrowding, the change in the HCV shall be made effective immediately.
However, the payment standard will increase only at the time of the annual re-examination.
The additional family member(s) will not be approved to move into the assisted unit if it causes overcrowding.
The family will be required to move. In the case where the addition(s) is by birth, adoption, court -awarded custody, the additions will be allowed to move into the assisted unit. However, the family will be required to move.
Decrease in Family Size
When a family member has moved out of the assisted unit, the family must follow the steps listed below to remove a family member from the household:
DRAFT
12-15
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
1. Complete and submit the Update of Family Circumstances form to the CoPHD within 15 days of the date of the change.
2. A copy of the lease where the family member will be residing will need to be submitted. If not available, other documentation must be submitted as proof of the new residence (i.e., utility bills, updated California Identification/Driver License, business correspondence, etc.). If new lease or other acceptable documentation is not available, household must submit a notarized Affidavit informing that family member will no longer be part of the assisted household and reason why proof of new address is not available. The statement must include the effective move date, forwarding address, and telephone number. In addition, the Housing Department may conduct a special inspection to verify that the reported adult household member(s) has moved out of assisted unit.
3. See Chapter 7 of this Plan, “Verification of Permanent Absence of Adult Family Member” for verification procedures.
An interim re -examination will not be processed if the family fails to submit the supporting information that proves that the family member has moved out of the assisted unit. The CoPHD will determine the effective date of the interim re-examination upon submittal of the supporting information. The family will be required to sign an updated HCV if the change in family composition results in a reduction of the HCV bedroom size.
Family Break-Up
The CoPHD has discretion to determine which members of an assisted family continue to receive assistance from the program if the family breaks up (i.e., divorce, legal separation, division of the family , etc.). The CoPHD will consider the following factors when deciding who remains on the program if the family breaks up:
1. Which family members remain in the assisted unit.
2. The interest of minor children or of ill, elderly or disabled family members.
3. Whether family members are forced to leave the unit as a result of actual or threatened physical violence against family members by a spouse or other member s of the household.
These families are protected under the Violence Against Women and Justice Department Reauthorization Act of 2005 (VAWA 2005). See Chapter 7 of this Plan , “Verification of Domestic Violence” for verification procedures.
4. Which family member was the head of household when the HCV was initially issued (refer to the HCV Application)
DRAFT
12-16
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
5. Recommendations of social service professionals.
Note: If a court determines the disposition of property between members of the assisted family in a divorce or separation under a settlement or judicial decree, the CoPHD is bound by the court’s determination of which family members will continue to receive assistance on the program.
The family will be responsible for submitting documentation verifying the above factors. The CoPHD may terminate assistance if the family fails to submit the required documentation to determine the family’s continued eligibility.
The family will be informed of their option to move to another unit or continue residing in the assisted unit where the breakup of the family results in a change of the bedroom size of the voucher.
Remaining Family Member
A remaining family member could be a spouse, head of household, co -head, adult family member, or a dependent as long as the assistance is continuous. Continuously assisted refers to families that are currently receiving assistance. It is the responsibility of the assisted family to select the new “head of household” from the approved remaining members.
The family will be required to inform the owner of the assisted unit about the change in head of household/family composition. The owner will decide if the change in head of household is acceptable. The head of household must notify the CoPHD if the owner shall offer a new lease.
G. CONTINUANCE OF ASSISTANCE FOR "MIXED" FAMILIES
[24 CFR 5.504, 5.518]
Under the Restrictions on Ass istance to Non -Citizens rule, “m ixed” families are families whose members include those with citizenship or eligible immigration status and those without citizenship or eligible immigration status. Mixed families may receive continued housing assistance. Mixed families who qualify for continued assistance after November 29, 1996, shall receive prorated assistance. See Chapter 6 of this Plan, “Factors Related to Total Tenant Payment Determination”.
H. ENTERPRISES INCOME VERIFICATION SYSTEM DISCREPANCY
The CoPHD will discuss the discrepancy in the EIV report only with the individual who has the income discrepancy. The CoPHD may only discuss the discrepancy with the head of household if the individual gives written permission to the CoPHD.
If the person is under 18 years of age, the CoPHD will discuss the discrepancy with the parent or guardian.
If the family agrees the information in EIV is correct, the family will sign the EIV Certification Page or a self- DRAFT
12-17
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
certification agreeing that the information is accurate. The CoPHD will request the following information:
1. Information supporting the income reflected in EIV (i.e. Award letter, pay stubs, etc.).
2. Third Party verifications.
Once the information has been received and reviewed, the CoPHD will determine if a rent adjustment is necessary and/or an overpayment has occurred.
If the family disputes the information in EIV, the family will sign the EIV Certification Page or a self-certification certifying the reason(s) they disagree with the report. The family will be instructed to:
1. File a Police Report if the person is a victim of identity theft and provide copy to the CoPHD.
2. File a complaint with the Federal Trade Commission
3. Contact the Social Security Administration (SSA) and submit information from the SSA.
4. Contact credit bureaus.
5. Contact the employer(s) or agency listed on the report by telephone and in writing to inform them of the discrepancy and request correction to be reported to the state. Copy of the written request must be submitted to the CoPHD.
The family will be required to repeat steps #3 and #5 if the same discrepancy appears in subsequent years or repeat steps #1 through #5 if they dispute new discrepancies.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
13-1
CHAPTER 13
MOVES WITH CONTINUED ASSISTANCE/PORTABILITY
INTRODUCTION
HUD regulations permit families to move with continued assistance to another unit within the CoPHD's jurisdiction, or to a unit outside of the CoPHD 's jurisdiction under portability procedures. The regulations also allow the CoPHD the discretion to develop policies which define any limitations or restrictions on moves. This Chapter defines the procedures for moves both within and outside of the CoPHD's jurisdiction, and the policies for restrictions and limitations on moves.
A. ALLOWABLE MOVES [24 CFR 982.354, 982.552]
A family may move to a new unit if:
1. The assisted lease for the old unit has terminated because t he CoPHD has terminated the HAP contract for owner breach, or the lease was terminated by mutual agreement of the owner and the family.
2. The owner has given the family a notice to vacate, commenced an action to evict the family based on non-program violations, obtained a court judgment, or other process allowing the owner to evict the family (unless rental assistance to the family is proposed for termination).
3. The family has given at least a 60 Day Notice of lease termination to the owner (if the family has a right to terminate the lease on notice to owner, for owner breach or otherwise).
4. A member of the family is being relocated because they are a witness in connection with efforts to combat crime in public and/or assisted housing, if requested by law enforcement.
5. A member of the family is protected by the Violence Against Women and Justice Department Reauthorization Act 2005 (VAWA), because he/she has been a victim of domestic violence, dating violence, sexual assault, or stalking. The family will be required to complete, sign and submit Form HUD-50066. See Chapter 7 of this Plan, Verification Procedures”.
6. A reasonable accommodation is approved.
7. The CoPHD requires the family to move because it has been determined the owner committed fraud.
B. RESTRICTIONS ON MOVES
Families will not be permitted to move within the CoPHD 's jurisdiction during the initial lease term of assisted occupancy.
Families will not be permitted to move outside the CoPHD's jurisdiction under portability procedures during the first year of admission, unless they have met all requirements.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
13-2
Families will not be permitted to move more than once in a 12 -month period. Moves with continued rental assistance will only be processed during the family’s annual re -examination unless the requested move is due to the following circumstances:
1. Causes beyond the family’s control (i.e., foreclosure or loss of property; new owner unwilling to assume HAP contract, substandard unit).
2. Family is unable to afford the increased tenant rent due to changes in family circumstances.
3. Eligible VAWA status.
4. Under-housed family.
5. Reasonable accommodation is approved.
Families requesting a move other than during their annual re- examination will be required to submit a 90-Day advance written request to move. However, the family must not serve a notice of intent to vacate to the owner prior to receiving CoPHD approval.
The CoPHD will deny permission to move if:
1. There is insufficient funding for continued assistance after securing HUD approval.
2. The family owes the CoPHD or any other Housing Agency money. This would include cases pending determination of overpaid rental assistance.
3. The family currently has a Repayment Agreement unless the outstanding balance of the Repayment Agreement is paid in full within 90 days of the move request and if no other program violations exist.
4. The family has been evicted for damages to the assisted unit beyond normal wear and tear, failure to provide or maintain tenant -supplied utilities and/or appliances, non- payment of tenant rent, violent or drug-related criminal activity, serious or repeated violation of the lease, and/or other Family Obligation.
5. The family is participating in the Project -based Program and a voucher or other comparable tenant - based rental assistance is not immediately available.
6. The family’s total tenant payment exceeds the applicable payment standard.
7. The family has moved or been issued a voucher within the last 12 months.
The CoPHD may allow a family to move if they are required to move through no fault of their own (i.e. unaffordable tenant rent, overcrowding, foreclosure, etc.).
The CoPHD may deny permission to move if:
1. The family has violated a Family Obligation.
2. The family’s rental assistance has been placed on a “Conditional” status.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
13-3
Please refer to Chapter 19 of this Plan , “Project -Based Voucher Program”, to determine eligibility to move with continued rental assistance for families participating in project-based programs.
C. PROCEDURE FOR MOVES
Families may request a move with continued rental assistance during their annual re-examination and/or at any other time. The CoPHD will follow the applicable procedures listed below for move requests submitted by the families:
Move requests submitted during the family’s annual re-examination:
1. CoPHD determines the family’s continued eligibility. This process consists of reviewing the family’s case to determine if the family has a Repayment Agreement or the case is pending determination of overpaid rental assistance; family’s compliance with the Family Obligations (HUD & CoPHD) including the terms of the lease entered into with the property owner; printing, reviewing & analyzing the family’s EIV System report; and to ensure the family has submitted all requested program forms and information supporting their family circumstances.
2. CoPHD schedules and notifies the family of the move appointment within 30 days of the annual in -take interview appointment. If the CoPHD determine s the family eligible for a move, the family will be instructed to provide the owner with written notice of lease termination in accordance with the family’s lease, bring a copy of the served notice to the CoPHD to their scheduled appointment, and keep a copy for their records
3. CoPHD schedules and notifies the family of the move appointment. If the CoPHD determined the family ineligible for a move, the family will be informed of the reason(s) during this appointment and of their right to request an informal hearing if they do not agree with the CoPHD’s decision. Written notification will be mailed to the family confirming the CoPHD’s decision.
4. Families determined eligible for a move with continued rental assistance will be issued a Housing Choice Voucher during the move appointment if they submit a copy of the served written notice of lease termination.
A Housing Choice Voucher will not be issued to the family until a copy of the Notice of Intent to Vacate is received by the CoPHD.
Move requests submitted other than at the family’s annual re-examination:
1. The family submits a written request to move 90 days in advance of planned move.
2. CoPHD provides the family with a move policy , including a Personal Declaration for Rental Assistance Benefits form and schedules a pre-move interview appointment with the family within 30 days of the written request.
3. CoPHD reviews the family’s case to determine if a special inspection is required . Pre -move out special inspections will only be performed upon request from the owner, tenant, or if the CoPHD deems it is necessary.
4. CoPHD conducts a move interview with the family to review the requirements for a move w ith continued rental assistance. As with an annual interview, the family will be required to provide all current information DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
13-4
regarding family circumstances and sign the applicable forms and certifications. Additionally, the family will be required to submit rent receipts for the current month and past 5 months or a written statement from the owner to verify their tenant rent is current.
5. Based on the move interview, pre- move special inspection (if required), review of Enterprise Income Verification System ( EIV) report, and receipt of the
appropriate third party verifications, if requested, the CoPHD will determine if the requested move with continued assistance will be granted.
If the move request is approved, the CoPHD will:
1. Instruct the family to provide the owner with a written notice of lease termination in accordance with the family’s lease, keep a copy for their records and provide a copy of the served notice to the CoPHD.
2. CoPHD schedules an appointment with the family for issuance of the Housing Choice Voucher.
If the move request is not approved, the CoPHD notifies the family within 15 days of the determination and advises the family of their right to an informal hearing.
The CoPHD will conduct a briefing session with the family to discuss and review the following materials:
• Rental Assistance Programs (RAP).
• RAP Regulations .
• RAP Administrative Plan.
• Obligations of the Family.
• Term of Voucher/Extension/Suspension.
• CoPHD Available Housing List & Free Property Rental Listing Websites. • Request for Tenancy Approval.
• Housing Quality Standards.
• Rent Reasonableness.
• Repayment/Recovery of Outstanding Debt.
• Moves with Continued Assistance.
• Portability Procedures / HUD Portability Handout.
• Denial and Termination of Assistance.
• Informal Review and Informal Hearing Procedures.
• Termination of Housing Assistance Payments Contract.
CoPHD will notify the owner of the termination of the Housing Assistance Payments C ontract in accordance with the family’s written notice of lease termination.
The family will be advised of their responsibility to remain in occupancy of the assisted unit and continue paying their tenant rent to the owner through the end of their lease termination, leave the unit clean and without tenant related damages, and return the keys to the owner upon vacating the assisted unit, as required by the F amily Obligations to remain eligible for the program.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
13-5
The family will be in violation of the Family Obligations if they vacate the assisted unit prior to the lease term ination unless the family submits an agreement between the tenant and owner for an earlier termination of the lease. In the event that an agreement is not submitted, the family’s voucher will be suspended pending the collection of the overpaid rental assistance.
If the family does not locate a new unit, they may remain in the current unit so long as the owner permits.
Additionally, the family and owner must submit a written statement prior to the lease termination, signed by both parties agreeing to rescind the termination of the lease or agreeing to extend the termination of the lease.
Families who fail to continue paying their tenant rent through the end of their lease termination will have their issued voucher canceled and will be proposed for termination due to non -compliance of the Family Obligations, unless they submit a written statement from the owner verifying the outstanding rent has been paid.
Families who are interested in moving during their annual reexamination are not required to submit a written request to move 90 days in advance of planned move.
Time of HAP Contract Change
In a move, assistance stops at the old unit in accordance with the proper written notice to vacate.
The CoPHD will enter into a HAP contract on the new unit after the termination of assistance at the old unit unless the family submits an agreement between the tenant and owner for an earlier termination of the lease.
The CoPHD may approve up to 5 days of overlap assistance for the month in which the family moves.
Families moving in the same building /complex owned by the same owner will be processed like any other move, except that there will be no overlapping of assistance.
D. PORTABILITY [24 CFR 982.353, 982.355]
Portability applies to families moving out of or into the CoPHD's jurisdiction within the United States and its territories.
Under portability, families are eligible to receive assistance to lease a unit outside of the CoPHD's jurisdiction. The unit may be located in the same State as the CoPHD or in the jurisdiction of a Public Housing Agency (PHA) anywhere within the United States that administers a tenant -based program . See Exhibit G of this Plan for outgoing/incoming deadlines.
E. OUTGOING PORTABILITY [24 CFR 982.353, 982.355]
Families interested in moving outside of the CoPHD’s jurisdiction, must meet the criteria established for moves with continued rental assistance.
Restrictions on Portability
Families will not be permitted to exercise portability for any of the following reasons:
1. If applicant family who neither the head or spouse had a “domicile” (legal residence) in the jurisdiction DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
13-6
of the initial PHA at the time when the family first submitted an application for participation in the program to the initial PHA. (24 CFR 982.353 (c) (1).
2. During the initial 12 month period after admission to the program or lease -up in the CoPHD’s jurisdiction.
3. If the family is in violation of a Family Obligation.
4. If the family owes money to the CoPHD.
5. If the voucher has expired.
The VAWA 2005 Act provides that the family may receive a voucher and move in violation of the lease under the portability procedures if the family has complied with all other obligations of the voucher program and has moved out of the assisted unit in order to protect the health or safety of an individual who is or has been the victim of domestic violence , dating, violence, or stalking and who reasonably believed he or she was imminently threatened by harm from further violence if he or she remained in the assisted unit. Therefore, the CoPHD may allow a family to move under portability procedures if the only basis for the denial is that the family is violating the lease agreement.
Outgoing Portability Procedures
Families who express an interest in portability must complete and submit the Request for Portability of Rental Assistance form to move outside of the CoPHD’s jurisdiction prior to the expiration of the issued HCV, which specifies the area to which the family wants to move. The CoPHD will process one request for portability at a time.
The CoPHD provides the family with contact information (PHA name, location, contact person, email, fax number, and telephone number) for the r eceiving PHA which the family selected . The family may reque st for the CoPHD to choose the receiving PHA.
If the family is moving to a unit located in the same State as the CoPHD, in the same Metropolitan Service Area (MSA), or in an adjacent MSA in a different State, and there is no PHA in the area where the unit is located, the CoPHD will be responsible for the administration of the family's assistance. The CoPHD will choose a management company, another PHA, or a private contractor to administer the assistance.
The CoPHD will contact the receiving PHA in the jurisdiction where the family wants to move and advise the receiving PHA that the family will be moving into their jurisdiction. The CoPHD will also determine prior to approving the family’s request to move if the receiving PHA will bill or absorb.
Once the receiving PHA has notified the CoPHD of its decision to bill or absorb it cannot reverse its decision at a later date without the consent of the CoPHD.
Regulations require the use of email or other delivery confirmation methods for communications between the initial and receiving PHA. CoPHD will safeguard personal identifiable information to prevent potential breaches of personal sensitive data.
The receiving PHA will be responsible for contacting the family to schedule an appointment.
The CoPHD will prepare and mail the portability packet to the receiving PHA. The following documents will be DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
13-7
included in the portability packet:
1. Family Portability Information form (form HUD-52665).
2. A copy of the family's HCV with issued and expiration dates.
3. The most recent form HUD-50058 (Family Report) and copies of the income supporting the form.
4. Copy of the Enterprise Income Verification System report in a sealed envelope.
5. Copy of the m ost recent Personal Declaration for Rental Assistance Benefits form and/or Request for Portability Rental Assistance form.
Receiving PHA Responsibilities
The receiving PHA must promptly notify the CoPHD:
1. Whether the receiving PHA will bill the i nitial PHA for assistance on behalf of the portable family, or will absorb the family into its own program.
2. If the family has leased an eligible unit under the program or if the family fails to submit a R equest for Tenancy Approval for an eligible unit within the term of the HCV.
It is the responsibility of the receiving PHA to issue a voucher to the family which does not expire 30 calendar days prior to the expiration date of the CoPHD’s voucher.
The receiving PHA must contact the CoPHD if the voucher expired before the portability packet was received by the receiving PHA to determine if the CoPHD will extend the voucher.
If the CoPHD does not receive notification from the receiving PHA regarding the status of the ported family, within 90 days following the expiration of the initial HCV, the CoPHD will cancel the HCV and will notify the receiving PHA.
Families porting out of the CoPHD’s jurisdiction may be subject to criminal background conducted by the receiving PHA.
Families who decide not to lease in the jurisdiction of the receiving PHA and wish to port out to another jurisdiction must submit their decision in writing to the receiving PHA. The receiving PHA must return the portability packet to the CoPHD before processing the family’s request to port out to another jurisdiction.
The voucher of record for the family is once again the voucher originally issued by the CoPHD. However, the CoPHD will not honor another request for portability if the voucher has expired.
If the receiving PHA denies assistance to the family, the receiving PHA will be required to notify the CoPHD within 15 days, and offer the family an informal review or informal hearing.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
13-8
Payment to the Receiving PHA
Payments for families in other jurisdictions will be made to other PHA’s in accordance with HUD approved procedures for payment.
The initial PHA will reimburse the receiving PHA for the lessor of 80% of the initial PHA’s administrative fee or 100% of the receiving PHA’s administrative fee, 100% of the housing assistance payment, and any other HUD -approved fees. However, the CoPHD will only honor billings received within 10 working days from the date the HAP contract is executed by the receiving PHA.
F. INCOMING PORTABILITY [24 CFR 982.355]
Required Documents
As receiving PHA, the CoPHD will require the following documents from the Initial PHA:
1. A copy of the family's HCV with issue and expiration dates.
2. The most recent form HUD-50058 (Family Report) and copies of the income supporting the form.
3. Copy of the Enterprise Income Verification System report.
4. Family Portability Information form (form HUD-52665).
Incoming Portability Procedures
The CoPHD will review the in -coming portability packets to determine if all required information is included.
Portability packets may be returned to the initial PHA for the following reasons:
• Missing HCV.
• Invalid effective date of HCV.
• Unsigned HCV by the family.
• Expired HCV.
• Missing EIV report for participants.
• Missing information supporting the latest form HUD-50058. • Missing form HUD-52665.
• Families requesting additions to the household (except for newborns).
The CoPHD will make an attempt to request from the initial PHA the missing information before returning the portability packet.
The CoPHD will accept a n incoming family with a valid HCV and will notify the initial PHA of its option to bill or absorb.
If the voucher expires before the portability packet arrives at the CoPHD, the CoPHD will contact the initial PHA to determine if it will extend the voucher. If extension is not granted by the initial PHA, the CoPHD will return the DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
13-9
portability packet back to the initial PHA.
The CoPHD will schedule an appointment with the incoming portability family within two weeks of receipt of a complete portability packet. However, the appointment will be
delayed if the issuance date of the voucher is at a later date. T he family will be instructed to bring the following information to the scheduled appointment:
• Completed Personal Declaration for Rental Assistance Benefits form and the following forms:
o Authorizations for Release of Information ( CoPHD and form HUD-9886) signed by all adult family members.
o What You Should Know About EIV, Debts Owed to Public Housing Agencies and Terminations , Obligations of the Program Participant Family, Things You Should Know, Federal Privacy Act, Declaration of 214 Status forms signed by all adult family members.
o Copies of vital statistics documents.
o Current verifications supporting the family’s circumstances.
The CoPHD will conduct a criminal background for all adult family members. Each adult family member will be required to sign and date a Criminal History Background form during the time of the interview.
The CoPHD determines the HCV bedroom size for the family by applying the CoPHD’s Subsidy Standards . The CoPHD will issue a HCV reflecting the initial voucher term issued by the initial PHA and will automatically extend the original initial PHA’s voucher expiration date by 30 days.
The CoPHD will conduct a briefing session with the family and meet with the family to discuss and review the following materials:
• Rental Assistance Programs (RAP).
• RAP Regulations.
• RAP Administrative Plan.
• Obligations of the Family.
• Term of Voucher/Extension/Suspension.
• CoPHD Available Housing List & Free Property Rental Listing Websites. • Request for Tenancy Approval.
• Housing Quality Standards.
• Rent Reasonableness.
• Repayment/Recovery of Outstanding Debt.
• Moves with Continued Assistance.
• Portability Procedures / HUD Portability Handout.
• Denial and Termination of Assistance.
• Informal Review and Informal Hearing Procedures.
• Termination of Housing Assistance Payments Contract.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
13-10
The CoPHD will collect updated information supporting the family’s circumstances and conduct Criminal Background checks for all adult family members but it will not delay the family’s housing search in issuing the voucher for families already receiving voucher assistance. However, the CoPHD may take subsequent action ( i.e. recalculating the HAP based on updated income information, terminating the family’s participation in the program due to criminal background or failing to disclose necessary information) against the family based on the results.
The CoPHD may delay approval of a unit or issuance of a voucher if the family refuses to comply with the CoPHD’s portability procedures.
The CoPHD may delay issuing a voucher for an applicant family if there has been a change in the family’s annual income. For admission to the HCVP, the family must be within the CoPHD’s very-low income limits.
Extension of Housing Choice Voucher
Once the CoPHD issues the family a voucher, the CoPHD’s policies on extensions of the voucher apply. The CoPHD will notify the initial PHA of any extensions granted to the term of the voucher.
If the family request s to return to the initial PHA or search in another jurisdiction, the family will be informed the voucher of record will be once again the voucher originally issued by the initial PHA; any extensions granted by the CoPHD will become null and void; and the CoPHD will return the portability packet to their initial PHA.
Suspension of Housing Choice Voucher
“Suspension” is defined as stopping the clock on the term of a family’s voucher after the family submits a Request for Tenancy Approval, until the time when the PHA approves or denies the RFTA.
The term of the voucher is suspended starting the date the RFTA is received by the CoPHD. The suspension ends when the family and/or owner canceled the RFTA or the CoPHD notifies the family in writing if the RFTA has been denied.
Once the suspension has ended, the family will be credited the number of days from date the RFTA was received through the cancellation date or the expiration date whichever is less.
Absorption or Administration
The CoPHD will provide the initial PHA with form HUD- 52665 within 10 days of executing a H ousing Assistance Payment Contract. However, the CoPHD will include form HUD-50058 when billing.
Please refer to the “Billing Procedures” section of this chapter for billing procedures.
Income and TTP of Incoming Portables
As receiving PHA, the CoPHD will conduct a re -examination interview to verify the information provided, if any documents are missing, or are over 60 days old, whichever is applicable, or there has been a change in the family's circumstances.
If the family's income exceeds the income limit of the CoPHD, the family will not be denied assistance, unless the family is an applicant and the total annual income for the family exceeds the very -low income limit for the number of persons in the family.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
13-11
If the family's income is such that a $0 subsidy amount is determined prior to lease -up in the CoPHD's jurisdiction, the CoPHD will refuse to enter into a contract on behalf of the family at $0 assistance. The family will be returned to the initial PHA.
Request for Tenancy Approval
When the family submits a Request for Tenancy Approval (RFTA), it will be processed using the CoPHD's policies. If the family does not submit a RFTA during the term of the voucher the CoPHD will inform the i nitial PHA within 10 working days of the expiration of the HCV.
Denial or Termination of Assistance Prior to Lease Up
If the CoPHD denies or terminates assistance to the family, the family will be offered an informal review or informal hearing.
If the family requests an informal review or hearing, the CoPHD will notify the initial PHA of the pending action. If the CoPHD’s decision is upheld, the portability packet will be returned along with completed form HUD-52665.
Billing Procedures
The CoPHD will provide the initial PHA with form HUD -52665 within 10 days of executing a Housing Assistance Payment Contract. However, the CoPHD will include form HUD -50058 when billing. The CoPHD will notify the initial PHA before the billing
deadline if the initial billing has been delayed due to suspension and the billing deadline must be extended by 30 days.
As receiving PHA, the CoPHD will bill the Initial PHA every 30 days for housing
assistance payments. The billing cycle for other amounts, including administrative fees, will also be monthly unl ess otherwise requested by the initial PHA.
The CoPHD will bill 100% of the housing assistance payment and any other HUD -approved fees for each portable HCV leased as of the first day of the month.
The CoPHD will notify the initial PHA within 10 days of changes in subsidy amounts, and will expect the initial PHA to notify the CoPHD of changes in the administrative fee amount to be billed.
Termination of Billing
The CoPHD will notify the initial PHA in writing within 10 days following the effective date of housing assistance payments.
In cases where the CoPHD is proposing the termination of rental assistance due to program violations, and the family requests or fails to request an informal hearing, the CoPHD will mail form HUD-52665 to the initial PHA
The CoPHD will notify the initial PHA in advance prior to terminating billing due to absorption and provide form HUD - 52665.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
13-12
Mobility
The CoPHD may enter into an inter-jurisdictional agreement with other PHA’s to assist portable families who relocate in other jurisdictions. The CoPHD or the i nitial PHA determines eligibility and maintains the family’s file. The receiving PHA will only conduct the HQS inspections in a timely manner, and bill the CoPHD or the initial PHA for this service only. A copy of the inspection reports will be submitted with the invoice for payments. The fee for inspections will be negotiated by the two PHAs.
At the request of the participating PHA, the mobility agreement may allow for CoPHD families to lease in their jurisdiction while all inspections, eligibility determination, and file maintenance responsibilities remain with the CoPHD.
Special Purpose Vouchers
The CoPHD is required to administer incoming VASH Program portables in accordance with HUD established policies.
Please refer to Chapter 25 of this Plan, “Special Housing Choice Voucher Allocations”, for mobility and portability of HUD – VASH vouchers.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
14-1
CHAPTER 14
CONTRACT TERMINATIONS
INTRODUCTION
The Hou sing Assistance Payments (HAP) contract is between the owner and the C oPHD, and defines the responsibilities of both parties. This C hapter describes the circumstances under which the contract can be terminated by the CoPHD and the owner, and the policies and procedures for such terminations.
The term of the HAP contract is the same as the term of the l ease. No future subsidy payments on behalf of the family will be made by the CoPHD to the owner after the month in which the HAP Contract is terminated. The owner must reimburse the CoPHD for any subsidies paid by the CoPHD for any period after the HAP contract termination date.
If the family continues to occupy the unit after the HAP c ontract is terminated, the family is responsible for the total amount of rent due to the owner. The owner will have no right to claim compensation from the CoPHD.
The term of the lease and contract may be extended , if mutually agreed upon , where the owner and tenant in itiated the termination of the lease. A written agreement must be submitted to the CoPHD prior to the original termination date as long as no program violations exist . However, the CoPHD will not extend the HAP contract if the CoPHD determines, in accordance with HUD requirements, that funding under the consolidated ACC is insufficient to support continued assistance for families in the program.
The CoPHD will terminate the HAP Contract based on lease termination notice served by owner or family. The family may lease another unit if the family is eligible to move with continued rental assistance. However, the effective date of the new lease and HAP Contract may not commence prior to the previous lease and HAP Contract termination date.
The CoPHD will comply with Violence Against Women and Justice Department Reauthorization Act of 2005 (VAWA), which protects family members who are victims of domestic violence, dating violence, or stalking from being evicted or terminated from housing assistance based on acts of such violence against them. The family will be encouraged but not required to complete, sign and submit Form HUD -50066 or other acceptable documentation in order to verify the family’s claim that the request to move is prompted by incidences of abuse in the unit. However, self -certification will be accepted. Refer to Chapter 13, “Moves with Continued Assistance” for eligibility restrictions.
A. TERMINATION OF TENANCY BY THE FAMILY: MOVES [24 CFR 982.309.(c)]
The lease stipulates that the family cannot move from the unit until after the first year of the lease. The written notice must be at least a 60-day written notice to the owner in accordance with terms of the lease.
In cases where the family plans to vacate the assisted unit earlier than the termination of the 60 day notice, the family must obtain a written agreement signed by the owner and family reflecting a revised termination date of the lease.
The written agreement must be submitted prior to vacating the assisted unit. Failure to submit the written agreement prior to vacating the assisted unit is considered a program violation and grounds for proposed termination of rental assistance.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
14-2
If the family requires an extension to the termination date of the lease, the family must obtain a written agreement signed by the owner and family reflecting a revised termination date of the lease. The written agreement must be submitted prior to the termination date of the lease. Failure to submit the written agreement prior to the termination date of the lease may result in denial of the extension of the lease termination and termination of housing assistance payment.
Under special circumstances, the owner and tenant can mutually agree to a lesser notice of lease termination. The mutual agreement must include lease termination date and owner and tenant’s signatures. The mutual agreement must be submitted to the CoPHD prior to the family vacating the assisted unit.
B. TERMINATION OF TENANCY BY THE OWNER: [24 CFR 982.310]
If the owner wishes to evict the family and terminate the lease, the owner is required to use the procedures in HUD regulations and State or local law. The owner must provide the CoPHD with a copy of the eviction notice. The owner must provide the family with a written notice and should specify the grounds for termination of tenancy, at or before the commencement of the eviction action.
The owner eviction notice means a notice to vacate, or a complaint, or other initial pleading used under State or local law to commence an eviction action.
During the initial term of the lease, the owner may not terminate the tenancy except on the following grounds:
1. Serious violation (including but not limited to failure to pay rent or other amounts due under the lease) or repeated violation of the terms and conditions of the lease.
2. Violations of Federal, state or local law related to occupancy of the unit.
3. Other good cause, including:
a. Criminal activity by the family, any member of the household, a guest or another person under the family's control that threatens the health, safety or right to peaceful enjoyment of the premises by the other residents or persons residing in the immediate vicinity of the premises;
b. Any drug-related criminal activity on or near the premises; or
c. Family history of disturbance of neighbors, destruction of property, or of living or housekeeping habits resulting in damage to the unit or premises.
d. If the tenant is fleeing to avoid prosecution, or custody or confinement after conviction, for a crime, or attempt to commit a crime, that is a felony under the laws of the place from which the individual flees.
e. If the tenant has violated a condition of probation or parole imposed under Federal or State law.
4. Other good cause, after the first year of the lease, also includes:
a. Failure by the family to accept the offer of a new lease or revision;
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
14-3
b. The owner's desire to use the unit for personal or family use, or for a purpose other than as a residential rental unit; or
c. Business or economic reason for termination of the tenancy (such as sale of the property, renovation of the unit, the owner’s desire to rent the unit for a higher rent).
For families where an incident or incidents of actual threatened domestic violence, dating violence, or stalking occurred, this will not be construed as serious or repeated violations of the lease by the family or other “good cause” for termination of the assistance, tenancy, or occupancy rights of such a victim.
The eviction notice should specify the cause for the eviction. The CoPHD requires that the owner specify the section of the lease that has been violated and cite t he ways in which the family has violated that section, as documentation for the CoPHD’s proposed termination of rental assistance.
Housing assistance payments terminate when the lease is terminated by the owner in accordance with the lease.
However, if the owner has commenced the process to evict the tenant, and if the family continues to reside in the unit, the CoPHD must continue to
make housing assistance payments to the owner in accordance with the CoPHD contract until the owner has obtained a court judgment or other process allowing the owner to evict the tenant. The owner will be required to submit copies of the filed court documents within 15 days to the CoPHD. The CoPHD may continue such payments until the family moves from or is evicted from the unit. The owner must submit a copy of the final court judgment within 5 days.
If the owner opts out for business or economic reasons or non -renewal of the lease, the family must be given a 90- day written notice, with a copy to the CoPHD. Such reasons include desire to sell the property, renovation of the unit, or desire to obtain a higher rent than the CoPHD will approve. However, written notice is subject to current State and local law.
The CoPHD must continue making housing assistance payments to the owner in accordance with the HAP contract up to the lease termination notice as long as the family continues to occupy the unit and the HAP contract is not violated. By accepting the monthly payment from the CoPHD, the owner certifies that the family is still in the unit and they are in compliance with the HAP contract. Any payments received by the landlord after the tenant has vacated the assisted unit will be considered an overpayment and the owner will be required to reimburse the CoPHD.
If the eviction is not due to a serious or repeated violation of the lease, and if the CoPHD has no other grounds for termination of assistance, the CoPHD may issue a HCV so that the family can move with continued assistance.
C. TERMINATION OF THE CONTRACT BY CoPHD OR DUE TO BREACH OF CONTRACT [24 CFR 982.404 (a), 982.453, 982.454, 982.455, 982.306]
The term of the HAP contract terminates when the lease terminates, CoPHD terminates program assistance for the family, and/or the owner has breached the HAP contract.
If the CoPHD terminates the HAP contract due to breach of contract , the CoPHD will provide the owner and family with a written notice of termination of the HAP contract.
Any of the following actions by the owner (including a principal or other interested party) are a breach of the HAP contract by the owner:
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
14-4
a. If the owner has violated any obligation under the HAP contract for the dwelling unit, including the owner’s obligation to maintain the unit in accordance with HQS.
b If the owner has violated any obligation under any other HAP contract under Section 8 of the 1937 act (42 U.S.C. 1437f).
c. If the owner has committed fraud, bribery or any other corrupt or criminal act in connection with any federal housing program.
d. For projects with mortgages insured by HUD or loans made by HUD, if the owner has failed to comply with the regulations for the applicable mortgage insurance or loan program, with mortgages or mortgage note, or with the regulatory agreement; or if the owner has committed fraud, bribery or any other corrupt or criminal act in connection with the mortgage or loan.
e. If the owner has engaged in drug-related criminal activity; or
f. If the owner has committed any violent criminal activity.
The PHA rights and remedies against the owner under the HAP contract include recovery of overpayments, abatement or other reduction of housing assistance payments, termination of housing assistance payments, and termination of the HAP contract.
The CoPHD will terminate the HAP contract on the last day of the month in which the following circumstances occur:
a. The sole member of the household has passed away.
b. The entire family vacates without notice serving proper notice. The sole member of the household is absent from the assisted unit for more than 180 days due to medical reasons.
c. Family and owner failed to disclose familial relationship. See Chapter 17 “Property Owner or family Debts to the CoPHD” for additional information.
d. Family owns or has any financial interest in the assisted unit.
e. Property owner resides in the assisted unit.
The CoPHD may terminate the HAP contract if:
1. The CoPHD terminates assistance to the family for any grounds authorized by HUD regulations.
2. The family is required to move from a unit which is under-occupied or overcrowded.
3. If an administrative error occurred.
4. A family is no longer eligible for the reasonable accommodation.
The CoPHD will terminate HAP contracts, in accordance with HUD requirements, if the CoPHD determines that funding under the Consolidated ACC is insufficient to support continued assistance for families in the program.
CoPHD HAP contracts may be
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
14-5
terminated in, but not limited to, the following manner upon CoPHD’s review and finding that any member of a family household:
1. Failed to reimburse any PHA for amounts paid to an owner under a HAP contract for rent, damages to the unit, or other amounts owed by the family under the lease.
2. Breached an agreement with a PHA to pay amounts owed to a PHA, or amounts paid to an owner by a PHA.
3. Owes rent or other amounts to the CoPHD or to another PHA in connection with Section 8 HCVP or public housing assistance under the 1937 Act; and
4. Violated any Family Obligation under the program as listed in 24 CFR 982.551.
5. The HAP contract terminates automatically 180 days after the last housing assistance payment to the owner.
The CoPHD will provide the owner and family with a written notice of termination of the HAP contract. If the CoPHD initiates the HAP contract termination due to a proposed termination of rental assistance and the family requests an informal hearing, the HAP contract termination will be extended through the informal hearing process.
Refer to Chapter 19 of this plan, “Project -Based Voucher-Program”, for termination of rental assistance for project - based rental assistance.
D. AUTOMATIC TERMINATION OF RENTAL ASSISTANCE CONTRACTS [24 CFR 982.455]
The HAP Contract terminates automatically 180 calendar days after the last housing assistance payment to the owner. The HAP Contract termination will be rescinded if during the 180 calendar days the housing assistance payment is resumed due to reported family changes in family circumstances or contract rent increase.
E. TERMINATION DUE TO INELIGIBLE IMMIGRATION STATUS
[24 CFR 5.514 & 5.500 - 5.528]
The CoPHD will give notice of HAP Contract termination if there is no eligible remaining household member with eligible immigration status.
F. TERMINATION DUE TO FORECLOSURE
Foreclosed properties in which Section 8 voucher recipients reside must comply with Sections 702 and 703 of the Protecting Tenant at F oreclosure Act (PTFA) of 2009 . If the immediate successor -in-interest will use the unit as a primary residence, the lease can be terminated effective on the date of the sale. In such case tenant is still entitled to a minimum of 90 days notice to vacate.
During the term of the lease, the owner shall not terminate the tenancy except for serious or repeated violation of the terms and conditions of the lease, for violation of applicable Federal, State, or local law, or for other good cause, and in the case of an owner who is an immediate successor in interest pursuant to foreclosure during the term of the lease vacating the property prior to sale shall not constitute other good cause, except that the owner may terminate the tenancy effective on the date of transfer of the unit to the owner if the owner:
1. W ill occupy the unit as a primary residence; and
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
14-6
2. H as provided the tenant a notice to vacate at least 90 days before the effective date of such notice.
G. TERMINATION OF HAP CONTRACT AND HOUSING CHOICE VOUCHERS: INSUFFICIENT FUNDING [24 CFR 982.454]
The CoPHD may terminate the HAP contract if the CoPHD determines, in accordance with HUD requirements, that funding under the consolidated ACC is insufficient to support continued rental assistance for families in all programs.
Prior to the termination of existing HAP contracts for reason of insufficient funding, a formal “Declaration of Insufficient Funding” is required. This declaration shall be made in writing and signed by the Chief Executive Director, Housing Director, and the City’s Finance Director will sign concurrence.
The authority to approve the termination of HAP contracts due to insufficient funding is vested in the City Council acting in its capacity as the CoPHD. The approval to terminate HAP contracts shall be granted only through formal resolution of the City Council , after it has duly considered a formal request to terminate HAP contracts due to insufficient funding.
If the CoPHD must terminate HAP contracts due to insufficient funding, the CoPHD will terminate HAP contracts and/or cancel Housing Choice Vouchers (HCV) in the following order:
1. Cancel all outstanding HCV for applicants who have been issued a voucher from the waiting list including applicants who have submitted a Request for Tenancy Approval (RFTA).
2. Participants who voluntarily withdraw their participation from the program.
3. Participants that have seriously and/or repeatedly violated the family obligations.
4. Participants (including out -going portables) who currently hold an active HCV and are no longer in a contracted unit.
5. Participants that are not in a contracted unit and do not hold an active HCV will not be issued a HCV to move with continued rental assistance.
6. Participants that currently have a Repayment Agreement and/or have an overpayment (largest to smallest outstanding balance amount).
7. Participants with household members with disregarded income. Example: a household consists of parents with income and one or two college students who also have income, which is not included in computing the tenant rent. The total income of these households may be enough to afford the rent without rental assistance.
8. Participants currently holding an active HCV and whose contract is due to terminate will have their HCV cancelled and HAP contract will not be reinstated or extended.
9. Participants who are renting property owned by a relative (first in, first out).
10. Participants that are over-housed (largest to smallest).
11. Participants that are single, non-elderly and non-disabled households (first in, first out).
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
14-7
In the event the above selection criteria fails to yield a sufficient number of contract terminations necessary to meet funding levels, additional contracts will be selected through a lottery conducted by the CoPHD. A number will be assigned to all remaining existing contracts. These numbers will be selected at random until a sufficient number of contracts have been identified to achieve the required cost reductions.
Participants whose HCV was cancelled or HAP contract terminated due to insufficient funding will be placed on the CoPHD reissued waiting list and assigned a priority number based on the order of their cancellation. This number identifies the order they
may be reissued a HCV once funding is available and eligibility is redetermined. However, participants that have committed fraud and/or repeatedly violated the family obligations will be proposed for termination of rental assistance in accordance with Chapter 18 of this Plan, “Complaints and Appeals.”
Applicants whose vouchers were cancelled due to insufficient funding will be returned to the CoPHD waiting list.
These applicants will be issued a HCV upon redetermination of eligibility when funding is available.
Notice of Termination Due to Insufficient Funding
The CoPHD shall provide the owner and participant with a minimum of 30 days written “Notice of HAP Contract Termination for Reason of Insufficient Funding.” The notice of HAP contract termination shall be signed by the Chief Executive Director and sent to the owner and to the participant via first class mail.
This written notice to the owner shall describe the:
1. Reason for contract termination.
2. Regulatory and administrative plan reference authorizing the termination.
3. Effective date of the contract termination.
4. Responsibilities of the owner to offer the family a new lease.
5. CoPHD contact person.
6. Notice of availability of funding and redetermination of eligibility.
Families are required to report to the CoPHD in writing within 15 days when their address (home and/or mailing) has changed by completing and submitting an Update of Family Circumstances form. The CoPHD will follow the procedures outlined in Chapter 3 of this Plan , “Applying for Admission” related to misdirected mail. However, participants will be proposed for termination as outlined in Chapter 15 of this Plan “Denial or Termination of Assistance”, and applicants will be disqualified as outlined in Chapter 3 of this Plan “Applying for Admission.”
Notice of Termination to Receiving PHA (Outgoing Billable Portables Vouchers)
In the event the assistance on behalf of an outgoing portable billable participant is selected for termination, the CoPHD shall notify the receiving PHA of its intent to
terminate assistance due to insufficient funding. The receiving PHA has the option of absorbing the family. The receiving PHA shall be notified at least 30 days in advance of
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
14-8
the effective date of the termination of assistance. The receiving PHA is responsible for all notifications to the owner and participant.
Placement on the CoPHD Reissue Section HCVP Waiting List
Placement on the CoPHD Reissue Section 8 HCVP Waiting List will be based on category and assigned number.
The CoPHD will reissue HCVs in the following category once funding is available:
1. Participants.
2. Applicants.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
15-1
CHAPTER 15
DENIAL OR TERMINATION OF ASSISTANCE
INTRODUCTION
The CoPHD may deny or terminate assistance for a family because of the family's action or failure to act. The CoPHD will provide families with a written description of the Family Obligations under the program, the grounds under which the CoPHD can deny or terminate assistance, and the CoPHD's informal hearing and review procedures. This Chapter describes when the CoPHD is required to deny or terminate assistance, and the CoPHD 's policies for the denial of a new commitment of assistance and the grounds for termination of assistance under an outstanding HAP Contract.
A. FORMS OF DENIAL/TERMINATION [24 CFR 982.552]
Denial of assistance for an applicant may include any or all of the following:
1. Denying listing on the CoPHD waiting list.
2. Denying or withdrawing a HCV.
3. Refusing to enter into a HAP Contract or approve a lease.
4. Refusing to process or provide assistance under portability procedures.
Termination of assistance for a participant may include any or all of the following:
1. Refusing to enter into a HAP Contract or approve a lease.
2. Terminating housing assistance payments under an outstanding HAP Contract.
3. Refusing to process or provide assistance under portability procedures.
4. Failure to disclose and/or provide documentation of the Social Security Number for family members.
Requirement to Deny Admission or Terminate Assistance
[24 CFR 982.552(b)]
The CoPHD must deny assistance to applicants or terminate assistance for participant families for any of the following grounds:
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
15-2
1. For a family evicted from a housing assisted unit under the program for serious violation of the lease.
2. If any member of the family fails to sign and submit required HUD or CoPHD consent forms for obtaining information.
3. If no member of the family is a U.S. citizen or eligible immigrant.
4. The family fails to submit required evidence of citizenship or eligible immigration status for family members that have declared to be citizens or have eligible immigration status.
5. If an individual fails to meet the eligibility requirements concerning individuals enrolled at an institution of higher education as specified in 24 CFR 5.612.
6. If the family is under contract and 180 days have elapsed since the CoPHD 's last housing assistance payment was made.
7. For illegal drug use, other criminal activity, and alcohol abuse that would threaten other residents.
8. If a family was evicted from a federally assisted housing program for drug-related criminal activity within 3 years from the eviction. However, CoPHD must consider the circumstances. Refer to “CoPHD Consideration of Circumstances” of this Chapter.
9. If any household member has ever been convicted of drug -related criminal activity for manufacture or production of methamphetamine on the premises of federally assisted housing.
Mandatory Prohibition of Assistance [24 CFR 982.553 a(2)]
The CoPHD must deny assistance to an applicant or terminate assistance to a participant if:
1. Any member of the applicant household is subject to a lifetime registration requirement under a State sex offender registration program.
2. Any member of the program participant family is subject to a lifetime registration requirement under a State sex offender registration program after admission.
Grounds for Denial or Termination of Assistance [24 CFR 982.552(c)(1)]
The CoPHD may at any time deny assistance for an applicant or terminate program assistance for a participant for any of the following grounds:
1. If the family violates any family obligation under the program as listed in 24 CFR 982.551.
2. If any member of the family has been evicted from federally assisted housing in the last five years.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
15-3
3. If the CoPHD has ever terminated assistance under the program for any member of the family within the past 3 years and/or for fraud in the past 5 years.
4. If any member of the family has committed fraud, bribery, or any other corrupt or criminal act in connection with any Federal housing program (see 24 CFR 982.553(a) (1)).
5. If the family currently owes rent or other amounts to the CoPHD, or to another PHA, in connection with Section 8 or public housing assistance under the 1937 Act. All outstanding balance(s) must be paid in full prior to the CoPHD’s determination of eligibility.
6. If the family has not reimbursed any PHA for amounts paid to an owner under a HAP Contract for rent, damages to the unit, or other amounts owed by the family under the lease.
7. If the family breaches an agreement with CoPHD or another PHA to pay amounts owed to CoPHD or PHA or amounts paid to an owner by a CoPHD or PHA. (The CoPHD or PHA, at its discretion, may offer a family the opportunity to enter an agreement to pay amounts owed to CoPHD or PHA or amounts paid to an owner by PHA. The CoPHD or PHA may prescribe the terms of the agreement.)
8. If the family has engaged in or threatened abusive or violent behavior toward CoPHD personnel.
"Abusive or violent behavior towards CoPHD personnel" includes verbal as well as physical abuse or violence. Use of expletives that are generally considered insulting, racial epithets, or other language, written or oral, that is customarily used to insult or intimidate, may be cause for termination or denial.
“Threatening” refers to oral or written threats or physical gestures that communicate intent to abuse or commit violence.
Actual physical abuse or violence will always be cause for termination.
9. If the family has been engaged in criminal activity or alcohol abuse as described in 24 CFR 982.553.
10. If the family provides false information on the application , program forms , during interview, or submits information which contradicts previously submitted information or statements and no change has occurred. Refer to Chapter 23 of this Plan.
CoPHD Consideration of Circumstances in Determining D enial or T ermination of Assistance for Family [24 CFR 982.552]
In determining whether to deny or terminate assistance because of action or failure to act by members of the family:
1. The CoPHD may consider all relevant circumstances such as the seriousness of the case, the extent of participation or culpability of individual family members, mitigating circumstances related DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
15-4
to the disability of a family member, and the effects of denial or termination of assistance on other family members who were not involved in the action or failure.
2. The CoPHD may impose, as a condition of continued assistance for other family members, a requirement that other family members who participated in or were culpable for the action or failure will not reside in the unit. The CoPHD may permit the other members of a participant family to continue receiving assistance.
3. In determining whether to deny admission or terminate assistance for illegal use of drugs or alcohol abuse by a household member who is no longer engaged in such behavior, the CoPHD consider whether such household member is participating in or has successfully completed a supervised drug or alcohol rehabilitation program, or has otherwise been rehabilitated successfully (42 U.S.C. 13661). For this purpose, the C oPHD may require the applicant or tenant to submit evidence of the household member's current participation in, or successful completion of, a supervised drug or alcohol rehabilitation program or evidence of otherwise having been rehabilitated successfully.
4. If the family includes a person with disabilities, the CoPHD’s decision concerning such action is subject to consideration of reasonable accommodation in accordance with Part 8 of Title 24.
5. Nondiscrimination limitation and protection for victims of domestic violence or stalking . The CoPHD 's admission and termination actions must be consistent with fair housing and equal opportunity provisions of Sec. 5.105 of this title, and with the requirements of 24 CFR P art 5, Subpart L, protection for victims of domestic violence, dating violence, and stalking.
The CoPHD must determine that the relevant individual engaged in such activity before the CoPHD can deny admission or terminate assistance. The fact that an individual was arrested is not evidence that he or she has engaged in criminal activity. However, an arrest may trigger an inquiry into whether there is sufficient evidence to determine that a person engaged in a disqualifying criminal activity.
The CoPH D can utilize other evidence, such as police reports detailing the circumstances of the arrest, witness statements, and other relevant documentation to assist the CoPHD in making a determination that disqualifying conduct occurred. T he CoPHD may still take adverse action based on the conduct and/or behavior leading to an arrest which is supported by “preponderance of the evidence” that the individual engaged in such activity.
B. U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT OBLIGATIONS OF THE RENTAL ASSISTANCE PROGRAM PARTICIPANT FAMILY [24 CFR 982.551]
1. The family must supply any information that the PHA or HUD determines is necessary in the administration of the program, including submission of required evidence of citizenship or eligible immigration status (as provided by 24 CFR part 5). "Information" includes any requested certification, release or other documentation.
2. The family must supply any information requested by the PHA or HUD for use in a regularly scheduled re -examination or interim re- examination of family income and composition in accordance with HUD requirements.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
15-5
3. The family must disclose and verify Social Security numbers (as provided by part 5, subpart B, of 24 CFR), and must sign and submit consent forms for obtaining information in accordance with 24 CFR, Part 5, Subpart B.
4. Any information supplied by the family must be true and complete.
5. The family is responsible for an HQS breach caused by the family as described in 24 CFR 982.404(b).
6. The family must allow the PHA to inspect the unit at reasonable times and after reasonable notice.
7. The family may not commit any serious or re peated violation of the lease . Under 24 CFR
5.2005(c)(1), an incident or incidents of actual or threatened domestic violence, dating violence, or stalking will not be construed as a serious or repeated lease violation by the victim or threatened victim of domestic violence, dating violence, or stalking, or as good cause to terminate the tenancy, occupancy rights, or assistance of the victim.
8. The family must notify the PHA and the owner before the family moves out of the unit, or terminates the lease on notice to the owner. See 24 CFR 982.314(d).
9. The family must promptly give the PHA a copy of any owner eviction notice.
10. The family must use the assisted unit for residence by the family. The unit must be the family's only residence.
11. The composition of the assisted family residing in the unit must be approved by the PHA . The family must promptly inform t he PHA of the birth, adoption or court -awarded custody of a child.
The family must request PHA approval to add any other family member as an occupant of the unit. No other person [i.e., nobody but members of the assisted family] may reside in the unit.
12. The family must promptly notify the PHA if any family member no longer resides in the unit.
13. If the PHA has given approval, a foster child or a live -in aide may reside in the unit. The PHA has the discretion to adopt reasonable policies concerning residence by a foster child or a live -in-aide, and defining when PHA consent may be given or denied.
14. Members of the household may engage in legal profit -making activities in the unit, but only if such activities are incidental to primary use of the unit as a residence by members of the family.
15. The family must not sublease or let the unit.
16. The family must not assign the lease or transfer the unit.
17. The family must supply any information or certification requested by the PHA to verify that the family is living in the unit, or relating to family absence from the unit, including any PHA requested information or certification on the purposes of family absences. The family must cooperate with the PHA for this purpose. The family must promptly notify the PHA of absence from the unit.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
15-6
18. The family must not own or have any interest in the assisted unit.
19. The members of the family must not commit fraud, bribery or any other corrupt or criminal act in connection with the programs.
20. The members of the family may not engage in drug- related criminal activity or violent criminal activity or other criminal activity that threatens the health, safety or right to peaceful enjoyment of other residents and persons residing in the immediate vicinity of the premises (see 24 CFR 982.553). Under 24 CFR 5.2005(c)(2), criminal activity directly related to domestic violence, dating violence, or stalking, engaged in by a member of a tenant’s household or any guest or other person under the tenant’s control, shall not be cause for termination of tenancy, occupancy rights, or assistance of the victim, if the tenant or immediate family member of the tenant is the victim.
21. The members of the household must not abuse alcohol in a way that threatens the health, safety or right to peaceful enjoyment of other residents and persons residing in the immediate vicinity of the premises.
22. An assisted family, or members of the family, may not receive Section 8 tenant -based assistance while receiving another housing subsidy for the same unit, or for a different unit, under any duplicative (as determined by HUD or in accordance with HUD requirements) Federal, State or local housing assistance program.
CoPHD Adopted Obligations of the Rental Assistance Program Participant Family
The family must:
1. Provide and disclose true and complete information.
2. Keep scheduled appointments, and provide requested information by the given deadlines.
3. Report in writing all changes in household income, assets, medical expenses, student status, child care expenses, household composition (i.e. birth, adoption or court awarded custody of a child, marriage, or removal of household member) within 15 days of the date of the change by submitting a completed Update of Family Circumstances form. The family is responsible for submitting documents supporting the reported change within 30 days.
4. The assisted unit must be the participant’s only place of residence. The family may not have a secondary residence.
5. Request and obtain in writing CoPHD and property owner approval to add any family member as an occupant to the unit prior to moving the additional family member into the assisted unit.
6. Submit written notification in advance when any family member will be away from the assisted unit for more than 30 days. The notification must include the reason(s) for the extended absence . (i.e. hospitalization, vacation, incarceration, etc.)
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
15-7
7. Disclose if the property owner is the parent, child, grandparent, grandchild, sister, brother, aunt, uncle, cousin, niece, nephew, spouse, domestic partner, related by marriage or adoption to any member of the household.
8. Allow the CoPHD to inspect the unit annually and as needed.
9. Maintain the assisted unit in a safe, sanitary, and decent condition at all times.
10. Pay the monthly tenant rent determined by the CoPHD timely in accordance with the terms of the lease.
11. Pay the utility bills and supply appliance(s) the owner is not required to supply under the lease agreement. Utility services must be in service at all times during the family’s tenancy of the assisted unit.
12. Request prior approval from the CoPHD and property owner in writing if the family plans on engaging in any business activities in the assisted unit. The request must include the type of business the family plans to operate. If approval is denied, the family must not engage in any business activities in the assisted unit.
13. Cooperate in moving to another unit when the family has become too large or too small or rent is unaffordable to remain in the assisted unit based on the family reported income and household expenses.
14. Provide the CoPHD with a 90 -day written advance request for approval to move. Once the CoPHD has approved the family’s request to move, the family must serve the owner a 60-day written notice of lease termination with a copy to the CoPHD. If the family fails to notify the owner and CoPHD at least 60 days before the family moves, the family may not be eligible for a new certificate or voucher.
15. Provide the CoPHD with a copy of any owner served notice within 10 days of the date the notice was received.
16. Repay money owed to the CoPHD. If a family owes an outstanding debt, the CoPHD may arrange a repayment agreement depending on the reason and the amount. The family must abide by the terms of the Repayment Agreement to remain eligible for rental assistance. The family cannot move from one unit to another unit until the debt is paid in full.
17. Obey all Federal, State, and local housing laws and ordinances.
18. Correct or repair tenant related deficiencies (i.e. housekeeping, etc.) within the established deadline.
19. Provide the CoPHD with a written notice of voluntary termination of rental assistance.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
15-8
The family must NOT:
1. Engage in drug-related criminal activity or violent criminal activity. This applies to the entire family and guests.
2. Engage in criminal activity that threatens the health, safety or right of peaceful enjoyment of the other residents and persons residing in the immediate vicinity of the premises.
3. Allow persons unauthorized by the CoPHD to use the assisted unit address for mailing purposes.
4. Allow persons unauthorized by the CoPHD to use the assisted unit address with the Department of Corrections as their place of residence.
5. Allow a visitor to stay in the assisted unit for more than 15 consecutive days or a total of 60 days in a 12 month period.
6. Pay or give the owner any unauthorized side payments or pay more rent than the CoPHD has authorized. If an owner asks the family to pay extra rent, the family must send a written notice to their CoPHD representative at once. This is an illegal activity and considered fraud under the HCVP.
7. Pay a lesser tenant rent amount to the owner than the CoPHD has authorized.
8. Charge or collect any monies from the Live-in Aide for rent and utilities. The owner must not charge or collect any monies from the Live-In Aide for rent and utilities.
9. Commit any serious or repeated violation of the lease such as non -payment of rent or violent criminal or drug related activity, etc.
10. Damage the unit or surrounding property or allow any guest or visitor to damage the rental property.
11. Rent from relatives. The owner (including a principal or other interested party) is not the paren t, child, grandparent, grandchild, sister, brother aunt, uncle, cousin, niece, nephew, related by marriage or adoption of any
member of the family, unless the CoPHD has determined (and has notified the owner and the family such determination) that the unit, notwithstanding
such relationship, would provide reasonable accommodation for a family member who is a person with disabilities.
12. Default on a Repayment Agreement.
13. Vacate the unit prior to the termination date of the lease in accordance with the notice served by the landlord or the family. Family will be required to obtain a written mutual agreement reflecting a revised termination date of the lease signed by the landlord prior to vacating the assisted unit.
14. Engage in any acts of violent behavior or threats of violent behavior against CoPHD personnel.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
15-9
15. Violate the HCVP and/or CoPHD Family Obligations.
HQS Breach
The CoPHD and/or the owner will determine if an HQS breach, as identified in 24 CFR 982.404 (b), is the responsibility of the family. Families may be given extensions to HQS breaches by Housing Specialis t or Housing Assistance Officer . S ee Chapter 10 of this Plan , “Housing Quality Standards and Inspections”.
Lease Violations
The following criteria will be used to decide if a serious or repeated violation of the lease will cause a termination of assistance:
If the owner notifies the family of termination of lease for serious or re peated lease violations, family moves from the unit prior to the completion of court action, and the CoPHD determines that the cause is a serious or repeated violation of the lease based on available evidence.
Notification of Eviction
If the family requests assistance to move and they did not notify the CoPHD of an eviction within (5) five days of receiving the court judgment and lock out notice, their move with continued rental assistance may be denied.
Additions to Family Composition
Proposed additions to the household may be denied for the following:
1. Persons who have been evicted from public housing within the last 5 years.
2. Persons who have previously violated a family obligation listed in 24 CFR 982.551 of the HUD regulations within the last 5 years.
3. Persons who for program violations have been part of a family whose assistance has been terminated under the Rental Certificate or HCVP within the last five years.
4. Persons who have engaged in drug-related criminal activity or violent criminal activity within the last five years.
5. Persons who have engaged in fraud, bribery or any other corrupt or criminal act in connection with any Federal housing program.
6. Persons who owe rent or other amounts to the CoPHD or to another PHA in connection with Section 8 or public housing assistance under the 1937 Act. This includes persons who caused an overpayment of rental assistance due to being an unauthorized household member.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
15-10
7. Persons who have not reimbursed the CoPHD or any other PHA in full for amounts paid to an owner under a HAP Contract for rent, damages to the unit, or other amounts owed by the family under the lease.
8. Persons who breached an agreement with the CoPHD or any other PHA to pay amounts owed to an owner by a PHA.
9. Persons who have engaged in or threatened abusive or violent behavior ward CoPHD personnel.
10. Persons who have been required to register as lifetime sex offenders.
11. Persons cannot be related to the property owner.
12. Failure to submit proper legal documents to support guardianship/custody of minor.
13. Owner disapproval.
14. The addition would result in the household being underhoused.
Family Member Moved Out of the Assisted Unit
Families are required to notify the CoPHD within 15 days if any family member leaves the assisted household by completing an Update of Family Circumstances form indicating date family member moved out and submit supporting information regarding the change. The family must also provide the following information within 30 days:
1. The new address, if known, of the family member.
2. Documentation verifying new residence of the family member.
See Chapter 6 of this Plan “Factor Related to Total Tenant Payment Determination”, Chapter 7, “Verification Procedures”, and Chapter 12 “Reexaminations and Verifications” for verification procedures for permanent absent household member and processing of interim re-examination.
Limitation on Legal Profit-Making Activity in Unit
The family must obtain prior written approval from the CoPHD and the owner if the family plans on engaging in legal profit making activities in and around the assisted unit. The request must include the type of busine ss the family plans on engaging.
If approval is granted by the CoPHD, the family must disclose the income generated from the business by submitting a notarized business Affidavit anticipating the gross revenue and any business related expenses.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
15-11
The CoPHD will not approve the family’s request if:
• The business results in the family’s inability to use any of the living areas in the unit, such as a bedroom utilized for a business which is not available for sleeping.
• Type of business is illegal.
• Use of the unit as a business is not incidental to its use as a dwelling unit.
The family will be in violation of the Family Obligations if the business is conducted out of the assisted unit without prior approval from the CoPHD and property owner. Failure
to report the additional income generated from the unauthorized business will result in an overpayment of rental assistance and proposed termination of rental assistance.
Interest in Unit [24 CFR 982.306]
The owner may not reside in the assisted unit regardless of whether they are a member of the assisted family, unless the family owns the mobile home and rents the space under the HCV Program.
The U.S. Department of Housing and Urban Development established a policy that applies to all new admissions, and active participants who are moving to a new unit after June 16, 1998. Effective June 17, 1998, the CoPHD may not approve a unit for lease if the legal owner (including a principal or other interested party) of the property is the parent, child, grandparent, grandchild, sister or brother of any member of the family, or related by marriage unless the PHA has determined (and has notified the owner and the family of such determination) that approving the leasing of the unit, notwithstanding such relationship, would provide reasonable accommodation for a family member who is a person with disabilities.
If the relationship was not initially disclosed to the CoPHD, the total amount of the HAP paid from the effective date of the HAP contract must be reimbursed to the CoPHD. The family and owner will be held responsible for the full overpayment to the CoPHD. Additionally, the family will be subject to proposed termination of their rental assistance.
Reasonable accommodation cannot be requested after the initial contract has been executed.
The property owner must notify the CoPHD of any potential changes in ownership prior to the change to allow the CoPHD to review and determine the eligibility of the potential new owner. If the relationship of the potential new owner is not disclosed, the total amount of the HAP paid from the date of the change must be reimbursed to the CoPHD. The family and owner will be held responsible for the full overpayment to the CoPHD. Additionally, the family will be subject to proposed termination of their rental assistance.
Reasonable accommodation cannot be requested after the change of ownership has occurred.
Fraud
For CoPHD purposes, fraud is defined as a deception deliberately practiced in order to secure unfair or unlawful gain.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
15-12
Immigration Status [24 CFR 982.552(b)(4)]
The family must submit required evidence of citizenship or eligible immigration status. See 24 CFR 5 for a statement of circumstances in which the CoPHD must deny
admission or terminate program assistance because a family member does not establish citizenship or eligible immigration status and the applicable informal hearing procedures.
HUD-VASH Program Termination [Notice PIH 2011-53, 2010-12, 2011-50, 2010-23, 2008- 37 and Federal Register/Vol. 77, No. 57, 5.2007]
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 CoPHD 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. 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 CoPHD 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):
• due to serious lease violations,
• program fraud,
• engaging in criminal activity or
• drug/alcohol abuse, etc.
The VA case manager ca n re-refer 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 r egistration requirement, the CoPHD may not deny HUD-VASH assistance to the referred veteran.
For additional information see Chapter 25 of this Plan, “Special Housing Choice Voucher Allocations.”
Drug Related and Violent Criminal Activity
Drug-related criminal activity is the illegal manufacture, sale, distribution, use or possession with intent to manufacture, sell, distribute or use a controlled substance.
Drug-related criminal activity on or off the premises , not just on or near the premises is a violation and grounds for termination.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
15-13
Violent criminal activity includes any criminal activity that has as one of its elements the use, attempted use, or threatened use of physical force against a person or property and any family member is engaging in the activity.
Criminals and Alcohol Abusers [24 CFR 982.553]
The CoPHD may prohibit admission of a household to the program or termination of rental assistance of a household if the CoPHD determines that any household member is currently engaged in, or has engaged in during a reasonable time before admission:
1. D rug-related criminal activity;
2. V iolent criminal activity;
3. O ther criminal activity which may threaten the health, safety, or right to peaceful enjoyment of the premises by other residents or persons residing in the immediate vicinity; or
4. O ther criminal activity which may threaten the health safety of the owner, property management staff, or persons performing a contract administration function or responsibility on behalf of the CoPHD (including a CoPHD employee or a CoPHD contractor, subcontractor or agent).
The CoPHD may prohibit admission to the program or termination of rental assistance if the CoPHD determines that it has reasonable cause to believe that a household member’s abuse or pattern of abuse of alcohol may threaten the health, safety, or right to peaceful enjoyment of the premises by other residents.
The CoPHD must prohibit admission to the program of an applicant for five years from the date of eviction if a household member has been evicted from Federally assisted housing for drug-related criminal activity. However, the CoPHD may admit the household if the CoPHD determines:
1. the evicted household member who engaged in drug -related criminal activity has successfully completed a supervised drug rehabilitation program; or
2. the circumstances leading to the eviction no longer exist (for example, the criminal household member has died or is imprisoned).
Applicants will be denied assistance if they have been evicted from a unit due to violent criminal activity or convicted of a drug related crime within the last three years prior to the date of the certification interview.
Participants may be terminated who have been evicted from a unit, arrested and or convicted due to drug -related or violent criminal activity, and whose activities interfere with the health, safety, or right to peaceful enjoyment of the premises by other residents.
The CoPHD must deny or immediately terminate assistance for a family under the program if the CoPHD determines that any member of the household has ever been convicted of drug -related criminal activity for manufacture or production methamphetamine on the premises of federally assisted housing.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
15-14
If the family violates the lease for drug-related or violent criminal activity, the CoPHD may terminate assistance.
The CoPHD will deny or terminate assistance if any member of the household or unauthorized member is subject to a lifetime registration requirement under a State sex offender registration program. The rental assistance will terminate effective the date the unauthorized memb er moved into the assisted unit. The owner will be given notification of termination of the HAP Contract and the family notified of the termination of rental assistance in accordance with the procedures in this Chapter.
The family will be responsible for all rental assistance paid for the period in which the unauthorized or household member who is a lifetime sex offender registrant resided in the unit.
In appropriate cases, the CoPHD may permit the family to continue receiving assistance provided that family members determined to have engaged in the illegal activities will not reside in the unit. If the violating member is a minor, the CoPHD may consider individual circumstances.
Confidentiality of Criminal Records
The CoPHD will ensure that criminal record s received are maintained confidentially, not misused or improperly disseminated.
Evidence of Criminal Activity
The CoPHD may terminate assistance for criminal activity by a household member as authorized in 24 CFR 982.553 if the CoPHD determines, based on a preponderance of the evidence, that the household member has engaged in the activity, regardless of whether the household member has been arrested or convicted for such activity.
Use of Criminal Record [24 CFR 982.553(d),(1),(2)]
If the C oPHD proposes to deny admission for criminal activity as shown by a criminal record, the C oPHD must provide the subject of the record and the applicant with a copy of the criminal record. The C oPHD must give the family an opportunity to dispute the accuracy and relevance of that record , in the informal review process in accordance with 24 CFR 982.554.
If the CoPHD proposes to terminate assistance for criminal activity as shown by a criminal record, the C oPHD must notify the family of the proposed action to be based on the information and must provide the subject of the record and the family with a copy of the criminal record. The CoPHD must give the family an opportunity to dispute the accuracy and relevance of that record in accordance with 24 CFR 982.555.
Required Evidence [24 CFR 982.553(c)]
1. Preponderance of evidence is defined as evidence which is of greater weight or more convincing than the evidence which is offered in opposition to it; that is, evidence which as a whole shows that the fact sought to be proved is more probable than not. The intent is not to prove criminal liability, but to establish that the act(s) occurred.
2. Preponderance of evidence may not be determined by the number of witnesses, but by the greater weight of all evidence.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
15-15
3. Credible evidence may be obtained from police and/or court records. Testimony from neighbors, when combined with other factual evidence , can be considered credible evidence. Other credible evidence includes documentation of drug raids or arrest warrants.
4. The CoPHD will pursue fact-finding efforts as needed to obtain credible evidence.
Notice of Proposed Termination of Assistance [24 CFR 982.555(c),(2),(i),(ii),(iii)]
In any cases where the CoPHD decides to propose termination of assistance to the family, the C oPHD will give the family a written notice which contains:
1. A brief statement of reasons for the decision.
2. The effective date of the proposed termination; and
3. Informs the family that if they disagree with the C oPHD’s decision, an informal hearing may be requested by the family by the given deadline . See Chapter 18 of this Plan , “Complaints and Appeals” for informal hearing procedures.
The CoPHD will simultaneously provide written notice of the HAP c ontract termination to the owner so that it will coincide with the termination of rental assistance. The notice to the owner will not include any details regarding the reason for termination of assistance.
C. PROCEDURES FOR NON-CITIZENS [24 CFR 5.514(b),(1),(i),(ii),(iii),(iv) and
5.516, 5.518]
Delay, Denial, Reduction or Termination of Assistance
Assistance to an applicant or participant family shall not be delayed, denied, reduced, or terminated on the basis of ineligible immigration status of a family member if:
1. The primary and secondary verification of any immigration documents that were timely submitted has not been completed.
2. The family member for whom required evidence has not been submitted has moved from the assisted dwelling unit.
3. The family member who is determined not to be in an eligible immigration status following U.S.
Department of Homeland Security verification has moved from the assisted dwelling unit.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
15-16
4. The U.S. Department of Homeland Security appeals process under 24 CFR 5.514(e) has not been concluded.
5. Assistance is prorated in accordance with 24 CFR 5.520.
6. Assistance for a mixed family is continued in accordance with 24 CFR 5.516 and 5.518; or
7. Deferral of termination of assistance is granted in accordance with 24 CFR 5.516 and 5.518.
Participant families in which all members are neither U.S. citizens nor eligible immigrant must have their assistance terminated. They must be given an opportunity for an informal hearing.
Applicants denied rental assistance will be given an opportunity for an informal review.
Methods of Verification and Time Allowed
Original acceptable documents as specified by HUD must be submitted and photocopied by the C oPHD at the following times:
• For applicants, at eligibility determination;
• Whenever a family applies for admission to a HUD program , unless the family already has submitted evidence to the CoPHD.
• If the family is continuously assisted, documentation needs to be submitted only one time in the same program unless there has been a change in their status.
Extensions, in writing, for a specific period of time shall be granted if a family member:
• Submits required declaration certifying that any person for whom evidence has not been submitted is a noncitizen with eligible immigration status.
• Certifies that evidence needed is temporarily unavailable and additional time is needed; and
• Certifies that prompt and diligent efforts will be made to obtain evidence
If evidence is not provided within time specified, the CoPHD shall proceed to:
• Deny, prorate or terminate assistance.
Assistance for Mixed Families
A mixed family may continue to receive full program assistance if:
• The family was receiving assistance under a Section 214 covered program on June 19, 1995.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
15-17
• The family’s head of household or spouse has eligible immigration status as described in Sec 24 CFR
5.506 ; and
• The family does not include any person (who does not have eligible immigration status) other than the head of the household, any spouse of the head of the household, any parents of the head of the household, any parents of the spouse, or any children of the head of household or spouse.
False or Incomplete Information
An investigation will be conducted w hen the CoPHD has clear, concrete, or substantial documentation (such as a permanent resident card or information from another agency) that contradicts the declaration of citizenship made by an applicant or participant family. The family will be given an opportunity to present relevant information.
The CoPHD will deny or terminate assistance based on the submission of false information or misrepresentations.
Procedure for Denial or Termination [24 CFR 5.514,(2),(d),(1),(2),(3),(4),(5),(6)]
If the family (or any member) claimed eligible immigrant status and the U.S. Department of Homeland Security primary and secondary verifications failed to document the status, the family may make an appeal to the U.S.
Department of Homeland Security and request a hearing with the C oPHD, either after the U.S. Department of Homeland Security appeal or in lieu of the U.S. Department of Homeland Security appeal.
After the CoPHD has made a determination of ineligibility, the family will be notified of the determination, the reasons, and informed of the option for prorated assistance, if applicable.
The notice of denial or termination of assistance shall advise the family.
1. That financial assistance will be denied or terminated, and provide a brief explanation of the reasons for the proposed denial or termination of assistance.
2. That the family may be eligible for proration of assistance as provided under 24 CFR 5.520.
3. In the case of a family , the criteria and procedures for obtaining relief under the provisions for preservation of families can be found in 24 CFR 5.514 and 5.518.
4. That the family has a right to request an appeal to the U.S. Department of Homeland Security of the results of secondary verification of immigration status , and to submit additional documentation or a written explanation in support of the appeal in accordance with the procedures in 24 CFR
5.514(e).
5. That the family has a right to request an informal hearing with the responsible entity either upon completion of the U.S. Department of Homeland Security appeal or in lieu of the INS appeal as provided in 24 CFR 5.514(f).
6. For applicants, the notice shall advise that assistance may not be delayed until the conclusion of the U.S. Department of Homeland Security appeal process, but assistance may be delayed during the pendency of the informal hearing process.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
15-18
D. AUTOMATIC TERMINATION OF HOUSING ASSISTANCE PAYMENTS CONTRACTS [24 CFR 982.455]
The HAP Contract terminates automatically 180 calendar days after the last housing assistance payment to the owner.
The HAP Contract termination will be res cinded if during the 180 calendar days the housing assistance payment is resumed due to reported family changes in family circumstances or contract rent increase.
The family’s participation in the HCVP will end at the end of 180 calendar days if the housing assistance payment remains at $0 and the family opts to remain in occupancy of the unit.
The family may move with continued rental assistance if determined eligible; a housing assistance payment would be generated; and the family’s written request to move is received by the CoPHD 60 days prior to the HAP Contract termination date. The family will be issued 60 day voucher term and no extension of the voucher will be granted.
The HAP Contract will also automatically terminate at the end of the month in which:
1. The sole member of the household has passed away or vacates the unit.
2. The entire family vacates the unit without serving proper notice.
3. Property owner resides in the assisted unit.
4. Property owner and the family failed to disclose that they are related.
5. The entire family is absent from the assisted unit for more than 180 days due to medical reasons.
The CoPHD will notify the family and the property owner in writing of the HAP Contract termination.
E. AUTOMATIC TERMINATION OF PARTICIPATION
A family’s participation in the Housing Choice Voucher Program will automatically terminate when:
1. The sole member of the household has passed away.
2. At the end of 180 calendar days if the housing assistance payment remains at $0 and the family opts to remain in occupancy of the unit.
The CoPHD will attempt to verify with the family of the participant who passed way to obtain a Death Certificate if EIV has not been updated or contact the property owner for verification.
The CoPHD will notify the family in writing of termination of participation under the Housing Choice Voucher Program.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
15-19
F. OPTION NOT TO TERMINATE FOR MISREPRESENTATION
[24 CFR 982.551, 982.552(c),(vii)]
If the family has misrepresented any facts that caused the CoPHD to overpay rental assistance, the C oPHD, at its discretion, may offer a family the opportunity to enter into a r epayment agreement or require the family to pay the debt in full. See Chapter 17 of this Plan, “Property Owner or Family Debts to the CoPHD.”
G. MISREPRESENTATION IN COLLUSION WITH OWNER
[24 CFR 982.551, 982.552(c)]
If the family willingly and knowingly commits fraud or is involved in any other illegal scheme with the owner, the CoPHD will deny or terminate assistance. In making this determination, the C oPHD will carefully consider the possibility of overt or implied intimidation of the family by the owner and the family's understanding of the events.
H. MISSED APPOINTMENTS AND DEADLINES [24 CFR 982.551, 982.552(a)]
It is a family obligation to supply information, documentation, and certification as needed for the CoPHD to fulfill its responsibilities. The CoPHD schedules appointments and sets deadlines in order to obtain the required information.
The Family Obligations also requir e that the family allow the CoPHD to conduct an inspection of the unit and appointments are made for this purpose.
An applicant or participant family who fails to keep the final appointment or to supply information requir ed by a deadline may be sent a notice of denial and/or proposed t ermination of assistance for failure to provide required information, keep scheduled appointments, and/or failure to allow the CoPHD to inspect the unit.
Appointments will be scheduled and time requirements will be imposed for the following events and circumstances:
1. Eligibility for Admissions.
2. Verification Procedures.
3. Housing Choice Voucher Issuance and Briefings.
4. Housing Quality Standards Inspections.
5. Annual and Interim Re-examinations.
6. Informal Reviews and Hearings.
Acceptable reasons for missing appointments or failing to provide information by deadlines are:
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
15-20
1. Medical Emergency.
2. Family Emergency.
Procedure when Appointments are Missed or Information not Provided
The family will be given one opportunity before being issued a notice of proposed termination for breach of a family obligation or denial of rental assistance.
The CoPHD may rescind the proposed termination of rental assistance after the notice has been issued if the family provides verifiable proof that the violation has been corrected within the time allowed to request an informal hearing, as long as a history of non-compliance does not exist.
However, the CoPHD will send a warning letter to the family reminding them that failure to abide by the family obligations will be considered a repeat violation and grounds for termination of rental assistance.
I. VOLUNTARY TERMINATION
Families must provide the CoPHD with written statement of their intent to voluntary terminate their assistance under the Housing Choice Voucher Program at least 15 days prior to the termination date.
The CoPHD will counsel the family of the ramifications of voluntarily terminating their assistance to ensure that the family is aware of all the consequences. The CoPHD will also contact the property owner to verify if the family is in good standing (i.e. current with rent, lease violations, etc.).
Families will be required to serve the property owner with a proper notice in accordance with the lease if the family plans to vacate the unit. A copy of this notice must be provided to the CoPHD. Failure to serve a proper notice to the property owner is a violation of the Family Obligations regardless if the family plans to voluntary terminate their assistance.
In the event the family verbally states their intent to voluntary terminate their assistance, the CoPHD will request the family to submit a written statement within 15 days. Failure to submit the requested statement will be considered a violation of the Family Obligations.Notices of voluntary termination of rental assistance will not negate program violations. The CoPHD will notify the family in writing of the acceptance of their notice of voluntary termination but the notice will also address the program violations including advising the family that their name will be added to the Enterprises Income Verification System Debts Owed to PHAs and Terminations Report.
The family may rescind their notice as long as the cancelation notice is received by the CoPHD prior to the effective termination date. Family will be required to submit a written statement from the property owner to continue the lease.
The family will be required to re -apply if they require rental assistance in the future. The family will not be able to return to the HCV Program unless the family goes through the open enrollment process. No exceptions will be made.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
16-1
CHAPTER 16
OWNER DISAPPROVAL AND RESTRICTION
INTRODUCTION
It is the policy of the CoPHD to encourage and recruit owners to participate in the HCVP. The CoPHD provides owners with professional service in order to maintain an adequate supply of available housing throughout the jurisdiction of the CoPHD The regulations define when the CoPHD must disallow an owner’s participation in the program, as well as provide the CoPHD discretion to disapprove or otherwise restrict the participation of owners in certain categories. This Chapter describes the criteria for owner disapproval and the various penalties for owner violations.
A. DISAPPROVAL OF OWNER [24 CFR 982.306, 982.54 (d)(8)]
Nothing in this rule is intended to give any owner any right to participate in the program. For purposes of this section, “owner” includes a principal or other interested party.
The CoPHD will disapprove an owner for the following reasons:
1. HUD or other agency directly related has informed the CoPHD that the owner has been d ebarred, suspended, or subject to a limited denial of participation under 24 CFR part 2424.
2. HUD has informed the CoPHD that the Federal government has instituted an administrative or judicial action against the owner for violation of the Fair Housing Act or other F ederal equal opportunity requirements and such action is pending.
3. HUD has informed the CoPHD that a court or administrative agency has determined that the owner has violated the Fair Housing Act or other Federal equal opportunity requirements.
4. The owner has violated obligations under a Housing Assistance Payments (HAP) C ontract under Section 8 of the 1937 Act (42 U.S.C. 1437f).
5. The owner has committed fraud, bribery or any other corrupt or criminal act in connection with any F ederal housing program.
6. The owner has engaged in any drug-related criminal activity or any violent criminal activity.
7. The owner has a history or practice of non- compliance with HQS for units leased under the tenant- based programs, or with applicable housing standards for units leased with Project -Based Section 8 Assistance or leased under any other Federal housing program.
8. The owner has not paid State or local real estate taxes, fines or assessments.
9. Property is in foreclosure.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
16-2
10. The owner has a history or practice of failing to terminate tenancy of tenants of units assisted under Section 8 or any other Federally assisted housing program for activity engaged in by the tenant, any member of the household, a guest or another person under the control of any member of the household that:
(i) Threatens the right to peaceful enjoyment of the premises by other residents;
(ii) Threatens the health or safety of other residents, of employees of the CoPHD, or of owner employees or other persons engaged in management of the housing;
(iii) Threatens the health or safety of, or the right to peaceful enjoyment of their residences, by persons residing in the immediate vicinity of the premises.
11. The CoPHD will not approve a unit if the owner and any family member are related. Fami ly members include but are not limited to ; the parent, spouse, child, grandparent, grandchild, sister, brother, son, daughter, uncle, aunt, niece, nephew, cousin, related by adoption, related by marriage and domestic partners. The CoPHD may approve the unit if the family requests reasonable accommodation and the CoPHD determines approving the unit will provide reasonable accommodation for a family member who is a person with disabilities.
If the relationship was not initially disclosed to the CoPHD, the total amount of HAP paid from the effective date of the HAP contract must be reimbursed to the CoPHD . The family and owner will be held responsible for the full overpayment to the CoPHD. Additionally, the family will be subject to proposed termination of rental assistance. See Chapters 15 “Denial Or Termination Of Assistance” and Chapter 17 “Property Owner Or Family Debts To The CoPHD” of this Plan.
B. OWNER RESTRICTIONS AND PENALTIES [24 CFR 982.453]
If an owner commits fraud or abuse, or is guilty of frequent or serious contract
violations, the CoPHD will restrict the owner from future participation in the program for a period of time commensurate with the seriousness of the offense. The CoPHD may also terminate some or all HAP Contracts with the owner.
Before imposing any penalty against an owner, the CoPHD will review all relevant factors pertaining to the case, and will consider such factors as the owner's record of compliance and the number of violations.
The CoPHD guidelines for restrictions are contained in the table below. The items below are described in HUD regulations. HUD debarments and fair housing violations require terminations, but the other categories of contract breach are discretionary with regard to possible CoPHD remedies. The CoPHD may utilize items such as written warnings, abatements, reductions and/or terminations. In some cases the CoPHD may terminate only the contract(s) which has been violated. (Table of reasons for owner restrictions continued on next page.)
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
16-3
DISAPPROVAL OF OWNERS/PARTICIPATION RESTRICTIONS
BREACH PENALTY
HUD notification of owner debarment/suspension. Termination HUD notification of violation of fair housing/Federal equal opportunity.
Termination
Violation of HAP Contract obligations. Termination
Owner fraud, bribery or other corrupt act in Federal housing program.
Termination
Owner engaged in drug trafficking. Termination
History of noncompliance with HQS. Abatement
History of renting units below code requirements. Abatement State/local real estate taxes, fines or assessments. Abatement Failure to disclose relationship to the tenant Termination Property has been foreclosed Termination
Owner residing in the subsided unit Termination/
Debarment
C. OTHER REMEDIES FOR OWNER VIOLATIONS
Overpayments
If the owner has been overpaid as a result of fraud, misrepresentation or violation of the HAP C ontract, the CoPHD may terminate the HAP Contract and arrange for restitution to the CoPHD and/or family as appropriate.
The CoPHD will make every effort to recover any overpayments made as a result of owner fraud or abuse.
Payments otherwise due to the owner may be debited in order to repay the CoPHD or the family as applicable.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
17-1
CHAPTER 17
PROPERTY OWNER OR FAMILY DEBTS TO THE CoPHD
INTRODUCTION
This Chapter describes the CoPHD’s policies for the recovery of monies which have been overpaid for families and owners. It describes the methods that will be utilized for collection of monies and the guidelines for different types of debts. It is the CoPHD’s policy to meet the informational needs of owners and families, and to communicate the program rules in order to avoid owner and family debts. Before a debt is assessed against a family or owner, the file must contain documentation to support the CoPHD’s claim that the debt is owed. The file must further contain written documentation of the method of calculation in a clear format for review by the owner, the family or other interested parties.
When families or owners owe money to the CoPHD, the CoPHD will make every effort to collect all debt owed from the date the overpayment occurred. The CoPHD will use a variety of collection tools to recover debts , including, but not limited to:
1. Abatement
2. Requests for Lump Sum Payment
3. Repayment Agreement
4. Reduction of Housing Assistance Payments
5. Civil Suit
6. Collection Agency
7. Credit Bureau
8. Income Tax Set-Off Program
9. Lien on personal property
A. REVIEW OF OVERPAYMENT OF RENTAL ASSISTANCE BENEFITS
Once the CoPHD has determined that an overpayment of rental assistance occurred, the CoPHD will notify the family of any amount due and their obligation to reimburse the CoPHD. The family will be provided an opportunity to review the information used by the CoPHD in determining the overpayment. If the family disputes the information used by the CoPHD, the family will have 15 days to submit evidence to support their dispute.
The CoPHD will review the information submitted by the family. The CoPHD will re- evaluate the overpayment calculation and determine whether or not the overpayment amount should be adjusted. If the family fails to submit their supporting documentation by the established deadline, the original amount of the overpayment will remain the same.
If the family agrees with the original amount, the CoPHD will follow the procedures listed in this Chapter.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
17-2
B. REPAYMENT AGREEMENT FOR FAMILIES [24 CFR 982.552 (c) v, vi. vii]
A Repayment Agreement is a document entered into between the CoPHD and a family who owes a debt to the CoPHD. It contains details regarding the nature of the debt, the terms of repayment, any special provisions of the agreement, and the remedies available to the CoPHD upon default of the agreement.
The City of Pasadena Finance Department will be responsible for collecting amounts owed by the family , for claims paid and for monitoring the repayment.
The minimum amount for which the CoPHD will enter into a Repayment Agreement with a family is $500. A ny amount exceeding $10,000 shall be paid in full within 90 days of notification. Upon request, the family may be granted up to an additional 90 days extension to pay the amount owed in full. The CoPHD will allow no more than a maximum of 180 days.
The minimum initial payment for any Repayment Agreement is 20% of the beginning balance of the repayment amount, or $1000, whichever is lower. However, families may choose to make a larger down payment.
Families will be provided no more than 6 0 days from the date of the CoPHD repayment notice to enter into the Repayment Agreement and provide the required initial payment. If the family fails to provide the required initial down payment or refuses to enter into a Repayment Agreement, the family will be proposed for termination of rental assistance, and the debt will be entered into EIV as stated in 17 C.
Late Payments
A payment will be considered to be in arrears if the City of Pasadena Finance Department has not received the payment by the close of the business day on which the payment is due. If the due date is on a weekend or holiday, the due date will be at the close of the next business day.
If a family’s Repayment Agreement is in arrears for two months, the Repayment Agreement is in default and the City of Pasadena Finance Department will forward the Repayment Agreement and a monthly written report on all delinquent accounts to the CoPHD.
If the family defaults on the Repayment Agreement, the CoPHD will notify the family in
writing of the total amount due. The family will be given a deadline to pay the balance in full. If the total payment is not received, housing assistance on behalf of the family will be proposed for termination.
Families who are no longer on the rental assistance program and are now requesting to make payment on an account that is in default or collection, will be referred to the City’s Finance Department to make a payment and/or enter into payment arrangements. Families will not be eligible for program participation until the amount owed is paid in full.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
17-3
Repayment Schedule for Monies Owed to the CoPHD
Initial Payment Due
Amount Owed Maximum Term
20% of Total Amount
20% of Total Amount
20% of Total Amount
$1000
$500 - $2,500
$2,501 - $3,500
$3,501 - $5,000
$5,001 -$10,000
12 months
24 months
36 months
60 months
The actual terms of the Repayment Agreement (i.e., initial payment, monthly payment and length of repayment term, etc.) will be determined based on CoPHD’s repayment policies and procedures.
The CoPHD will not enter into a Repayment Agreement if:
1. The family already has a Repayment Agreement in place.
2. The CoPHD determines that the family committed program fraud other than untimely reporting of increases in income.
3. The family has already paid off a previous repayment agreement.
If not eligible to enter into a repayment agreement, the family will be required to pay the total overpayment amount in full within 90 days. Failure to pay in full will result in the proposed termination of rental assistance . When the termination of rental assistance becomes final, the case will be referred to the City of Pasadena Finance Department for collection of the total overpayment owed to the CoPHD and the amount will be documented in EIV system.
Guidelines for Repayment Agreements & Modifications
The Repayment Agreement will be executed between the CoPHD, head of household and all other adult family members.
Monthly payments may be decreased in cases of an extreme hardship . If the family is not in default of the Repayment Agreement, the family may request a decrease in monthly payments due to extreme hardship with supporting documentation . If the request is approved , the CoPHD may amend the Repayment Agreement by extending the terms for a period not to exceed 12 months. If the hardship no longer exists, the original terms of the Repayment Agreement will be re- instated. At the end of the term of the Repayment Agreement the remaining balance of the overpayment must be paid in full. Any change to the terms of the Repayment Agreement must be executed by both parties.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
17-4
At any time the family may pay a greater monthly amount than what is stated on the Repayment Agreement. The family may also pay off the entire debt owed at any time during the term of the Repayment Agreement.
Default of Repayment Agreement
The Repayment Agreement will be in default when:
1. Any installment is not paid in full when due.
2. Two installments are delinquent
3. A repeat violation results in an additional overpayment
4. Failure to abide by the terms of the Repayment Agreement
5. Violation of the Family Obligations
If the CoPHD determines that a Repayment Agreement is in default, the CoPHD will notify family that the outstanding balance is due and payable in full within the established deadline.
The City of Pasadena Finance Department will notify the CoPHD when a Repayment Agreement is in default and provide the CoPHD with the original Repayment Agreement along with the unpaid invoices. If the family is a current participant, the CoPHD will contact the family regarding the delinquent payments. If the CoPHD determines the Repayment Agreement is in default, the CoPHD will notify the family in writing requesting payment in full within the established deadline. The CoPHD may extend the deadline if the family has made a partial payment towards the outstanding balance or made a payment arrangement approved by the CoPHD. The family is required to pay the minimum monthly amount stated in the Repayment Agreement. I f the family fails to pay the minimum monthly payment, a missed payment will appear on the account.
The CoPHD will propose the termination of the family’s participation if the outstanding balance is not paid in full by the established deadline. The Repayment Agreement will be referred to the City of Pasadena Collection Department if the family’s participation is terminated. The overpayment amount will also be documented in EIV.
Repayment Agreements will automatically be referred to the City of Pasadena Collection Department for a family that is no longer a program participant and who has defaulted on their Repayment Agreement.
Additional Monies Owed
If the family has a Repayment Agreement in place and incurs an additional debt to the CoPHD, the CoPHD will not enter into an additional or amended Repayment Agreement . The current Repayment Agreement will be considered in default and the family will be required to pay all debts in full within 30 days of the date of notification to the family .
The family will also be subject to termination of their housing assistance for repeated violation of the Obligations of the Family.
C. DEBTS DUE TO FRAUD/NON-REPORTING OF INFORMATION
The CoPHD will not offer a Repayment Agreement to a family who is in violation of a F amily Obligation if it is determined the family committed fraud.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
17-5
HUD’s definition of program fraud and abuse is a single act or pattern of actions that constitutes false statement (s), omission, or concealment of fact (s), made with the intent to deceive or mislead, in order to obtain rental assistance through fraudulent means.
Family Error/Late Reporting
Families who owe money to the CoPHD due to the family’s failure to report increases in income will be required to pay the overpaid rental assistance in accordance with the guidelines in the repayment section of this Chapter.
For cases where a terminated family owes money to the CoPHD and the amount cannot be determined due to the family’s failure to submit the requested information or documentation to support the change, the CoPHD will use the HAP paid on their behalf from the date the overpayment occurred. The HAP amount will be documented in EIV for the overpayment. A final EIV update will be done when or if the requested information is received and the overpayment is calculated. If the requested information is not received the overpayment will remain the same in EIV.
Program Fraud
Families that owe money to the CoPHD due to program fraud will be required to pay the total balance due in full within 30 days of notification from the CoPHD. Housing assistance will be proposed for termination for a family who owes money to the CoPHD
due to program fraud. The CoPHD will attempt to collect the overpaid rental assistance from the family. If the family fails to pay, the debt will be referred to the City of Pasadena Finance Department and the family will be required to repay the amount in accordance with the appropriate civil collection procedures. If a family owes an amount which equals or exceeds $5,000 as a result of program fraud, the case may be referred to t he Office of the Inspector General for investigation and possible criminal prosecution.
D. OWNER DEBTS TO THE CoPHD
If the CoPHD determines that an owner has retained housing assistance payments the owner is not entitled to, the CoPHD may reclaim the amounts from future housing assistance payments owed the owner for any units under a HAP Contract. If future housing assistance payments are insufficient to reclaim the amounts owed, the CoPHD:
1. Will require the owner to pay the amount in full within 30 days.
2. Will pursue collections through the City of Pasadena Finance Department.
3. Will restrict the owner from future participation.
4. May attach a lien on property through the Office of the City Attorney/City Prosecutor
5. May refer case to the Office of Inspector General for investigation in case of fraud.
E. PAYMENT COLLECTED
All payments received must be in the form of a money -order or cashier’s check payable to the CoPHD. The process DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
17-6
listed below will be followed by staff upon receipt of payment.
• CoPHD staff will prepare a memorandum (memo) to the Finance Department with information and instructions to credit the appropriate account(s).
• CoPHD staff will complete the Cashier’s Deposit Log.
• CoPHD staff will scan and email the memo, cashier’s check, money- order and Repayment Agreement (if applicable) to the Finance Department/Accounts Receiveable.
• CoPHD staff will place original cashier’s check, money-order, memo and
Repayment Agreement (if applicable) in the money bag which will be stored in a secured location.
• CoPHD staff will hand deliver the money bag to the City of Pasadena Municipal Service’s cashier.
F. WRITING OFF DEBTS
Debts will be written off if:
1. The debtor was the sole participant and is deceased.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
18-1
CHAPTER 18
COMPLAINTS AND APPEALS
INTRODUCTION
The informal review and informal hearing requirements defined in HUD regulations are applicable to applicants and participating families who disagree with an action, decision, or inaction of the CoPHD . Families can exercise their right to an informal hearing, informal review, and/or local preference denial meetings when the family disputes the CoPHD’s decision. This Chapter describes the policies, procedures and standards to be used when families disagree with the CoPHD’s decision. It is the policy of the CoPHD to ensure that all families have the benefit of all protections due to them under the law, HUD regulations and CoPHD policies.
The CoPHD informal review and informal hearing procedures will be provided to families in their briefing packet. Additional copies of these procedures are available to the families upon request.
A. COMPLAINTS TO THE CoPHD
The CoPHD will respond to complaints from families, owners, City of Pasadena employees, and members of the general public. All complaints will be documented and referred to the appropriate CoPHD staff. The CoPHD will require that complaints, other than HQS violations, be put in writing. HQS complaints may be reported by telephone.
The CoPHD may refer cases to the HUD Office of Inspector General for further investigation, enforcement of collection of overpaid rental assistance and/or prosecution.
Categories of Complaints
1. Complaints from families: If a family disagrees with an action or inaction of the CoPHD or owner.
2. Complaints from owners: If an owner disagrees with an action or inaction of the CoPHD or family. All matters between the CoPHD and property owner are stipulated in Housing Assistance Payments (HAP) Contract.
3. Complaints from City of Pasadena staff: If a staff person reports an owner or family either violating or not complying with program rules.
4. Complaints from the general public: Complaints or referrals from persons in the community in regards to the CoPHD, a family or an owner.
The CoPHD will respond to reports of unauthorized persons, violations of the Family Obligations, or any other violations of program rules excluding criminal related activity, and conduct an investigation of the alleged violations. Complaints regarding criminal activity will be referred to the appropriate law enforcement agency.
The steps taken will depend upon the nature of the allegations and may include the items listed below.
The following are examples of complaints received and steps that will be taken by the CoPHD to investigate.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
18-2
Unauthorized Persons
1. Discuss the nature of the complaint with the housing inspector for feedback.
2. Conduct compliance inspection to verify household composition, make inquiry with person(s) present at the assisted unit at the time of the inspection, and take pictures of any applicable evidence.
3. Staff will prepare a report with the results of the compliance inspection.
4. Communicate with the owner, manager and neighbors to gather information about the alleged violation. See Chapter 23 of this Plan, “Steps the CoPHD Will Take to Detect Program Abuse and Fraud”.
5. Schedule an appointment with the family to discuss findings of the compliance inspection.
6. Request documentation from the family if they confirm that the unauthorized person(s) resides in the unit.
7. Request documentation from the family pertaining to the unauthorized person(s) place of residence if the family denies that unauthorized person(s) resides in the assisted unit. See Chapter 7 of this Plan, “Verification Procedures” for documentation to be submitted by the family.
8. Utilize all available resourc es (i.e., internet, law enforcement agencies, etc.) as part of the investigation process.
9. Review and evaluate all information gathered during the course of the investigation.
10. Make a decision and prepare letter to the family regarding the results of the investigation or action to be taken.
Unreported Income from Business Conducted in the Assisted Unit
1. Discuss the nature of the complaint with the housing inspector for feed back.
2. Conduct compliance inspection to verify if business is being conducted in the assisted unit, make inquiry with person(s) present at the assisted unit at the time of the inspection, and take pictures of applicable evidence.
3. Staff will prepare report with the results of the compliance inspection.
4. Communicate with the owner, manager and neighbors to gather information about the alleged violation. See Chapter 23 of this Plan, “Steps the CoPHD Will Take to Detect Program Abuse and Fraud”.
5. Contact the City of Pasadena Business License Division to see if a Business License exists.
6. Schedule an appointment with the family to discuss the findings of the compliance inspection.
7. Request documentation from the family if the CoPHD confirms the family is conducting business in DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
18-3
the assisted unit.
8. Utilize all available resources ( i.e., internet, State Board of Equalization, IRS, etc.) as part of the investigation process.
9. Review and evaluate all information gathered during the course of the investigation.
10. Make a decision and prepare letter to the family regarding the results of the investigation or action to be taken.
Unreported Income
1. Review complaint and determine if further action is required.
2. If no action required, file will be documented.
If further action is required, the following steps will be taken:
1. View EIV report.
2. Schedule an appointment with the family to discuss the complaint.
3. Request documentation from the family regarding the unreported income if the family confirms the unreported income.
4. Request third party verifications.
5. Review and evaluate all information gathered during the course of the investigation.
6. Make a decision and prepare letter to the family regarding the results of the investigation or action to be taken.
Complaints of Drug and Criminal Activity
1. Contact the City of Pasadena Police Department for possible criminal/drug activity taking place in the assisted unit.
• Request a Criminal Background Screening for household members involved in investigation from the Pasadena Police Department.
2. Access the Los Angeles County Sheriff’s Department (LACSD), the California Department of Corrections and Rehabilitation (CDCR), and the Federal Bureau of Prisons websites for possible arrests.
3. Schedule an appointment with the family to discuss the complaint.
4. Request documentation from the family (i.e. police reports, court documents, etc.).
5. Review and evaluate all information gathered during the course of the investigation.
6. Prepare a letter to the family regarding the results of the investigation or action to be taken.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
18-4
Delinquency of Tenant Rent to Owner: Notice to Pay Rent or Quit
1. Request for the family to submit written statement from the property owner confirming delinquent rent has been paid.
2. The family will be advised of possible termination of rental assistance if evicted for non -payment of rent.
Special Inspection Due to HQS Violations
A special inspection will be conducted , see Chapter 10 of this Plan, “Special Inspections” . In addition, investigation of participating families will be initiated under specific circumstances, see Chapter 23 of this Plan, “Criteria for Investigation of Suspected Abuse and Fraud”.
The following steps will be taken for tenant related deficiencies:
1. Prepare and mail notification to the family and owner regarding the results of special inspection.
2. Schedule an appointment with the family for counseling.
The following steps will be taken for owner related deficiencies:
1. Prepare and mail notification to the family and owner regarding the results of special inspection.
B. INFORMAL REVIEW FOR APPLICANT [24 CFR 982.54(d)(12), 24 CFR 982.554, 982.555]
Informal reviews are provided for applicants who are denied admission to the program. When the CoPHD determines that an applicant is ineligible for the program, the family must be notified of their ineligibility in writing. The notice must contain:
1. A brief statement of reasons for the CoPHD decision;
2. The procedure for requesting an informal review if the applicant does not agree with the CoPHD decision; and
3. The deadline to request an informal review.
The CoPHD must give applicants an opportunity for an informal review of the CoPHD decision denying assistance to the applicant.
The CoPHD is not required to provide the applicant an opportunity for an informal review for any of the following matters:
1. Discretionary administrative determinations by the CoPHD.
2. General policy issues or class grievances.
3. A determination of the family unit size under the CoPHD subsidy standards.
4. A CoPHD determination not to approve an extension or suspension of a voucher term.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
18-5
5. A CoPHD determination not to grant approval of the tenancy.
6. A CoPHD determination that a unit selected by the applicant is not in compliance with HQS.
7. A CoPHD determination that the unit is not in accordance with HQS because of the family size or composition.
Decisions related to restrictions on assistance to non-citizens always requires an informal hearing, regardless of whether the family is an applicant or a participant. The informal hearing provisions for the denial of assistance on the basis of ineligible immigration status are contained in 24 CFR Part 5.
When a request for an informal review is not received by the deadline, the CoPHD will not provide an applicant an informal review.
C. CoPHD INFORMAL REVIEW FOR APPLICANT PROCEDURES
A request for an informal review must be received by the CoPHD, in writing, no later than 15 days from the date of the CoPHD's notification of denial of assistance. The informal review will be scheduled within 30 days from the date the request is received.
The informal review may be conducted by any person or persons designated by the CoPHD, other than a person who made or approved the decision under review or subordinate of this person.
The applicant will be given the opportunity to present oral or written objections to the CoPHD’s decision.
The CoPHD may verify the evidence submitted at the informal review by the applicant specifically related to the CoPHD’s reason(s) for denial before a decision of the informal review is made.
The CoPHD will inform the applicant, in writing, of the final decision within 30 days after the informal review, including a brief statement of the reasons for the final decision.
D. CoPHD LOCAL PREFERENCE DENIALS
When the CoPHD denies a local preference, the applicant family will be notified in writing of the specific reason for the denial, and offered the opportunity for an informal review with CoPHD staff to discuss the reason(s) for the denial and to dispute the CoPHD's decision.
Changes reported in family circumstances which affect the preferences after the CoPHD has made its determination will not have any bearing on the CoPHD’s original decision for denial of preference. However, the applicant record will be updated to reflect the updated preference(s).
The CoPHD will inform the applicant family, in writing, of the final decision within 30 days after the informal review, including a brief statement of the reasons for the final decision.
E. INFORMAL HEARING FOR PARTICIPANT [24 CFR 982.555, 982.54(d)(13)]
The CoPHD must give a participant family an opportunity for an informal hearing to consider whether the following CoPHD decisions relating to the individual circumstances of a participant family are in accordance with the law, HUD regulations and CoPHD policies:
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
18-6
1. A determination of the family's annual or adjusted income and the use of such income to compute the housing assistance payment.
2. A determination of the appropriate utility allowance (if any) used for tenant -paid utilities from the CoPHD utility allowance schedule.
3. A determination of the family unit size under CoPHD subsidy standards.
4. A determination to terminate assistance for a participant family because of the family’s action or failure to act (see 24 CFR 982.552).
5. A determination to terminate assistance because the participant family has been absent from the assisted unit for longer than the maximum period permitted under CoPHD policy and HUD rules.
The CoPHD must give the family an opportunity for an informal hearing before the CoPHD terminates housing assistance payments for the family under an outstanding HAP Contract.
When the CoPHD makes a decision regarding eligibility and/or the amount of assistance, the participant family must be notified in writing. The CoPHD will give the participant family prompt notice of such determinations, which may include:
1. The proposed action or decision of the CoPHD;
2. The date the proposed action or decision will take place;
3. The family's right to an explanation of the basis for the CoPHD's decision;
4. The procedures for requesting an informal hearing if the family disputes the action or decision;
5. The deadline for the family to request an informal hearing;
6. The name of the person to whom the informal hearing request should be addressed to; and
The CoPHD is not required to provide a participant family an opportunity for an informal hearing for any of the following:
1. Discretionary administrative determinations by the CoPHD.
2. General policy issues or class grievances.
3. Establishment of the CoPHD schedule of utility allowances for families on the program.
4. A CoPHD determination not to approve an extension or suspension of a voucher term.
5. A CoPHD determination not to approve a unit or tenancy.
6. A CoPHD determination that an assisted unit is not in compliance with HQS. However, the CoPHD must provide the opportunity for an informal hearing for a decision to terminate assistance for a breach of HQS caused by the family as described in 24 CFR 982.551(C).
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
18-7
7. A CoPHD determination that the unit is not in accordance with HQS because of the family size.
8. A determination by the CoPHD to exercise or not exercise any right or remedy against the owner under a HAP Contract.
Property owners are not entitled to an informal hearing. All matters between the CoPHD and the property owner are stipulated in the Housing Assistance Payments Contract (CoPHD), see Housing Assistance Payments Contract Part B, Body of Contract.
Notification of Hearing
Upon receipt of the request for an informal hearing, the CoPHD will notify the participant family within 15 days, in writing, of the scheduled informal hearing. The notice will include:
1. The date and time of the informal hearing.
2. The location where the informal hearing will be held.
3. The family's right to present evidence, witnesses, legal or other representation at the family's expense. The family must notify in writing the CoPHD within 15 days from the date of the notification of their decision to have legal representation.
4. The family’s right to examine before the CoPHD hearing any CoPHD documents that are directly relevant to the hearing. The family is allowed to copy any such document at the family’s expense.
If the CoPHD does not make the document available for examination on the request of the family, the CoPHD may not rely on the document at the hearing. Such documents or evidence must be available to or received by the family no later than 10 days before the informal hearing date.
5. The right by the CoPHD to examine at the CoPHD’s office, before the informal hearing, any family documents that are directly relevant to the hearing. The CoPHD must be allowed to copy any such document at the CoPHD’s expense. If the family does not make the document available for examination on request of the CoPHD, the family may not rely on the document at the informal hearing. Such documents or evidence must be received by the CoPHD no later than 10 days before the informal hearing date.
6. Limited English proficient (LEP) and hearing impaired families may request the CoPHD’s assistance in obtaining an interpreter. However, the family must submit this request to the CoPHD at the time the informal hearing is requested.
CoPHD Informal Hearing Procedures
A request for an informal hearing must be received by the CoPHD, in writing, no later than 15 days from the date of the CoPHD's notification of termination of assistance. The CoPHD will notify the family within 15 days from the date the request was received of the scheduled informal hearing.
When the request for an informal hearing is not received by the deadline, the CoPHD will not provide a participant family an informal hearing and the CoPHD decision becomes final.
After an informal hearing date is agreed to, the family may request to reschedule only upon "good cause," which is defined as an unavoidable conflict which seriously affects the health, safety or welfare of the family.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
18-8
In accordance with PIH Notice 2020-32, the CoPHD is conducting Informal Hearings remotely. In response to technological barriers that participants may face, the CoPHD makes an onsite computer in a private room available to participants who do not have access to the necessary technology. If the participant has a disability that may prevent full access to the hearing using remote technology, alternative accommodations will be made, including rescheduling the hearing if necessary for a time it may be held in person.
The informal hearing will be canceled by the CoPHD if the family is not present 15 minutes after the informal hearing scheduled time. The CoPHD may schedule a final hearing only if the family can provide documentation supporting “good cause” for not attending the informal hearing within 48 hours, excluding weekends and holidays. If a participant family does not appear at a scheduled informal hearing and has not rescheduled the hearing in advance . No other hearing will be scheduled and the CoPHD’s decision to terminate will stand.
If a second informal hearing is scheduled based on good cause, the family will be notified in writing with the same conditions indicated on the first notification. However, if the participant is not present 15 minutes after the informal hearing scheduled time, the CoPHD will proceed with the informal hearing.
Families have the right to:
1. Present written or oral objections to the CoPHD's determination.
2. Examine the documents in the file which are directly relevant to the basis for the CoPHD's action, and all documents submitted to the hearing officer.
3. Copy any relevant documents at their expense.
4. Present any information or witnesses pertinent to the issue of the informal hearing.
5. Request that CoPHD staff be available or present at the informal hearing to answer questions pertinent to the case; and
6. Be represented by legal counsel, advocate, or other designated representative at their own expense.
The family must inform the CoPHD in writing of who will be representing them at the informal hearing.
If the family requests copies of documents relevant to the hearing, the CoPHD will make the copies for the family and assess a charge of $.15 per copy, or the City’s current copy rate. In no case will the family or their representative be allowed to remove the file from the CoPHD office or allowed access to the file with out CoPHD personnel being present.
In addition to other rights contained in this Chapter, the CoPHD has a right to:
1. Present evidence and any information pertinent to the issue of the informal hearing.
2. Be notified if the family intends to be represented by legal counsel, advocate, or another party.
3. Examine and copy any documents to be used by the family prior to the hearing.
4. Have its attorney present.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
18-9
5. Have staff persons and other witnesses familiar with the case present.
6. Has the right to record Informal Hearings.
The informal hearing may be conducted by any person or persons designated by the CoPHD, other than a person who made or approved the decision under review or a subordinate of this person. The CoPHD appoints hearing officers who are knowledgeable of the Rental Assistance Programs and experienced in dispute resolution, mediation and arbitration.
The informal hearing shall concern only the issues for which the family has received the opportunity for a hearing. Evidence presented at the hearing may be considered without regard to admissibility under the rules of evidence applicable to judicial proceedings.
No documents may be presented which have not been provided to the other party before the hearing, if requested by the other party. "Documents" includes records and regulations.
The hearing officer may ask the family for additional information and/or adjourn the hearing in order to reconvene at a later date before reaching a decision. The submission of additional information may not exceed 15 days from the date of the informal hearing.
If the family misses an appointment or deadline established by the hearing officer, the decision of the CoPHD shall become final and another informal hearing will not be granted.
The hearing officer will determine whether the action, inaction, or decision of the CoPHD is in accordance with HUD regulations and this Plan based upon the evidence and testimony provided at the hearing. Factual determinations relating to the individual circumstances of the family will be based on a preponderance of the evidence presented at the informal hearing.
A notice of the decision made by the hearing officer will be provided, in writing, to the CoPHD within 30 days of the informal hearing and shall include:
1. A clear summary of the decision and reason(s) for the decision; and
2. If the decision involves money owed.
The CoPHD is not bound by the hearing officer’s decision which:
1. Concern matters in which the CoPHD is not required to provide an opportunity for an informal hearing, or that otherwise exceeds the authority of the person conducting the hearing under the CoPHD hearing procedures.
2. Conflict with or contradict HUD regulations or requirements, or otherwise contradict Federal, State, or local law.
The CoPHD will notify the family, in writing, within 15 working days of receipt of the hearing officer’s decision.
A copy of the hearing officer’s decision will be provided to the family. If the CoPHD determines that it is not bound by the hearing officer's decision, the CoPHD will notify the family of the determination and of the reasons for the determination.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
18-10
F. HEARING AND APPEAL PROVISIONS FOR "RESTRICTIONS ON ASSISTANCE TO NON- CITIZENS" [24 CFR, Part 5, Subpart E]
Assistance to the family may not be delayed, denied or terminated on the basis of immigration status at any time prior to the receipt of the decision on the U.S. Department of Homeland Security appeal.
Assistance to a family may not be terminated or denied while the CoPHD informal hearing is pending, but assistance to an applicant may be delayed pending the CoPHD review.
U.S. Department of Homeland Security Determination of Ineligibility
If a family member claims to be an eligible immigrant, and the U.S. Department of Homeland Security Systematic Alien Verification for Entitlements (SAVE) system and manual search do not verify the claim, the CoPHD notifies the applicant or participant, within 10 days in writing, of their right to appeal to the U.S.
Department of Homeland Security within 30 days or to request an informal hearing with the CoPHD, either in lieu of or subsequent to the U.S. Department of Homeland Security appeal.
If the family appeals to the U.S. Department of Homeland Security, they must give the CoPHD a copy of the appeal and proof of mailing or the CoPHD may proceed to deny or terminate. The time period to request an appeal may be extended by the CoPHD for “good cause.”
The request for a CoPHD informal hearing must be made within 15 days of receipt of the notice offering the informal hearing or, if an appeal was made to the U.S. Department of Homeland Security, within 15 days of receipt of that notice.
After receipt of a request for an informal hearing, the informal hearing is conducted as described in Section E of this Chapter, “Informal Hearing Procedures” for both applicants and participants. If the hearing officer decides that the individual is not eligible, and there are no other eligible family members,
the CoPHD will:
1. Deny the applicant family.
2. Defer termination if the family is a participant and qualifies for deferral.
3. Terminate the participant if the family does not qualify for deferral.
If there are eligible members in the family, the CoPHD will offer to prorate assistance or give the family the option to remove the ineligible members.
All other complaints related to eligible citizenship/immigration status:
1. If any family member fails to provide documentation or certification as required by the regulations, that member is treated as ineligible. If all family members fail to provide documentation or certification, the family will be denied or terminated for failure to provide documentation or certification.
2. Participants whose termination is carried out after temporary deferral may not request an informal hearing since they had an opportunity for a hearing prior to the termination.
3. Participants whose assistance is pro-rated (either based on their statement that some members are ineligible, or due to failure to verify eligible immigration status for some members after exercising DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
18-11
their appeal and hearing rights described above) are entitled to an informal hearing based on the right to a hearing regarding determinations of tenant rent and total tenant payment.
4. Families denied or terminated for fraud in connection with the non- citizens rule are entitled to an informal review or informal hearing in the same way as terminations for any other type of fraud.
G. MITIGATING CIRCUMSTANCES FOR APPLICANTS/PARTICIPANTS WITH DISABILITIES
When applicants are denied placement on the waiting list or the CoPHD is terminating assistance for a participant family, the CoPHD may consider all relevant circumstances, such as the seriousness of the case, the extent of
participation or culpability of individual family members, mitigating circumstances related to the disability of a family member, and the effects of denial or termination of assistance on other family members who were not involved in the action or failure.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
19-1
CHAPTER 19
PROJECT-BASED VOUCHER PROGRAM
INTRODUCTION
The CoPHD has elected to provide rental assistance under the Project Based Voucher Program (PBVP) to encourage property owners of existing housing, newly constructed housing or rehabilitated housing to make these properties available to low-income families at affordable rents. This will ensure that the City maintains an affordable rental housing stock that is at risk of becoming unaffordable for low -income families. The PBVP provided by the CoPHD may be used only for units within the City of Pasadena.
The provision of assistance that is attached to units as project-based assistance is different in its application than that of tenant-based assistance typically provided by the HCVP. Under project-based assistance, the CoPHD enters into a HAP Contract with the owner to make housing assistance payments during the contract term for a specific unit(s) that is leased and occupied by an eligible family.
The CoPHD PBV program is funded with a portion of appropriated funding (budget authority) available under the CoPHD’s voucher annual contributions contract (ACC). The CoPHD may provide up to 20% ACC and an additional 10% for homeless families, families with veterans, supportive housing for persons with disabilities or elderly persons, or in areas where vouchers are difficult to use. However, only 25% of the units in a project or 25 units in a project, whichever is greater, may be project based with the exception of single -family dwellings and “excepted units or housing exemption” in a multifamily building. Units added to contract executed prior to April 18, 2017 may also qualify for these exceptions.
There is no special or additional funding for project based vouchers and HUD does not reserve additional units for project based vouchers. The CoPHD has the discretion whether to operate a project-based voucher program.
HOUSING OPPORTUNITY THROUGH MODERNIZATION ACT (HOTMA)
This chapter has been updated based on the Housing Opportunity Through Modernization Act of 2016 -Housing Choice Voucher and Project Based Voucher Implementation.
A. HUD SUBMISSION
The CoPHD may attach voucher assistance to PBV units in accordance with 24 CFR 983 if:
1. The number of units to be project-based does not exceed the applicable percent limit or number.
2. The number of units to become project-based are not under a tenant-based or project-based HAP Contract or otherwise committed (e.g. , vouchers issued to families searching for housing or units under an Agreement).
Before implementing PBVP, the CoPHD must submit the following information to the HUD field office for review:
1. The total number of units for which the CoPHD is requesting approval to attach assistance.
2. The number of budgeted voucher units.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
19-2
3. The number of voucher units available to be project-based; e.g., the number of budgeted voucher units that are not under a tenant -based or project -based HAP C ontract or otherwise committed (e.g., vouchers issued to families searching for housing or units under an Agreement).
The CoPHD must ensure that the amount of assistance that is attached to units is within the amounts available under the ACC.
B. OWNER APPLICATION SUBMISSION [24 CFR 983.51]
1. The CoPHD has adopted a written policy establishing competitive procedures for owners’ submission of applications. This written policy identifies and specifies the weight to be given to the factors that will be used to rank and select applications. These factors are as follows:
Experience/Administrative Capacity: 20 Points
Design/Community Impact: 20 Points
Site Control/Readiness: 15 Points
Project Stability/Sustainability: 15 Points
Supportive Services Plan: 15 Points
Management Plan: 15 Points
2. The CoPHD will select units to which assistance is to be attached. These units must be selected in accordance with the CoPHD’s selection policy and 24 CFR 983.51.
3. The CoPHD will advertise in a newspaper of general circulation that the CoPHD will accept applications for assistance under the PBVP for specific projects. The advertisement must be approved by the HUD field office and may not be published until after HUD’s authorization to implement a PBVP or ACC execution.
The advertisement must: be published once a week for two to three consecutive weeks; specify an application deadline of at least 30 days after the date the advertisement is last published; specify the number of units the CoPHD estimates it will be able to assist under the funding the CoPHD is making available for this purpose; and state that only applications submitted in response to the advertisement will be considered.
4. The owner’s application submittal must contain the following:
a. A description of the housing to be constructed or rehabilitated, including the number of units by size (square footage), bedroom count, bathroom count, sketches of the proposed new construction or rehabilitation, unit plans, listing of amenities and services, and estimated date of completion. For rehabilitation, the description must describe the property as is and must also describe the proposed rehabilitation.
b. Evidence of site control, and for new construction identification and description of the proposed site, site plan and neighborhood.
c. Evidence that the proposed new construction or rehabilitation is permitted by current zoning ordinances or regulations, if applicable.
d. Evidence to indicate that the needed re-zoning is likely and will not delay the project, if applicable.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
19-3
e. The proposed contract rent per unit, including an indication of which utilities, services, and equipment are included in the rent . For those utilities that are not included in the rent, an estimate of the average monthly cost for each unit type for the first year of occupancy.
f. A statement identifying:
1. The number of persons (families, individuals, businesses and nonprofit organizations) occupying the property on the date of submission of the application.
2. The number of persons to be displaced, temporarily relocated or moved permanently within the building or complex.
3. The estimated cost of relocation payments and services, and the sources of funding.
4. The organization(s) that will carry out the relocation activities.
5. The identity of the owner , project principals , names of officers , principal members, shareholders, investors and other parties having substantial interest . C ertification showing that the above- mentioned parties are not on the U.S. General Services Administration list of parties excluded from Federal procurement and nonprocurement programs; a disclosure of any possible conflict of interest by any of these parties that would be a violation of the Agreement or the HAP C ontract; and information on the qualifications and experience of the principal participants. Information concerning any participant who is not known at the time of the owner’s submission must be provided to the CoPHD as soon as the participant is known.
6. The owner’s plan for managing and maintaining the units.
7. Evidence of financing or lender interest and the proposed terms of financing.
8. The proposed term of the HAP Contract; and
9. Any other information the CoPHD believes necessary.
The CoPHD has seven PBV HAP Contracts with the following locations:
1. Centennial Place Apartments - 142 units.
2. Orange Grove Gardens Apartments - 9 units.
3. Hudson Oaks Apartments - 44 units.
4. Marv’s Place – 19 units.
5. Heritage Square Apartments – 69 units
6. The Salvation Army Hope Center-65 units
7. Heritage Square South-69 units
C. ELIGIBLE AND INELIGIBLE PROPERTIES [24 CFR 983.9 & 983.53]
Newly constructed and existing structures of various types may be appropriate for attaching assistance to the units under 24 CFR 983, including single-family housing and multi-family housing. Eligible housing under 24 CFR 982.352 does not apply.
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
19-4
The CoPHD may not attach or pay PBV assistance in the following types of housing:
1. Housing for which the construction is started before Agreement execution.
2. Housing for which the rehabilitation is started before Agreement execution.
3. Shared housing, nursing homes , and facilities providing continual psychiatric, medical, nursing services, board and care or intermediate care.
4. Units within the grounds of penal, reformatory, medical, mental, or similar public or private institutions.
5. Housing located in an area that has been identified by the Federal Emergency Management Agency (FEMA) as having special flood hazards.
6. College or other school dormitories.
7. Units owned or controlled by an educational institution or its affiliate and are designated for occupancy by students of the institution.
8. Manufactured homes.
9. Cooperative housing.
10. Transitional housing.
11. Units occupied by the owner.
The CoPHD may not attach or pay PBV assistance to any of the following types of subsidized housing:
1. Public housing dwelling unit;
2. A unit subsidized by any other form of Section 8 assistance (tenant-based or project based);
3. A unit subsidized with any governmental rent subsidy (a subsidy that pays all or any part of the rent);
4. A unit subsidized with any government subsidy that covers all or any part of the operating costs of the housing;
5. A section 236 project (insured or noninsured) or a unit subsidized with Section 236 rental assistance payments;
6. A unit subsidized with rental assistance payments under Section 521 of the Housing Act of 1949 (a Rural Housing Services Program);
7. A Section 202 project for non-elderly persons with disabilities (assistance under Section 162 of the Housing and Community Development Act of 1987);
8. Section 202 supportive housing for the elderly;
9. Section 811 supportive housing for persons with disabilities;
DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
19-5
10. A Section 101 rent supplement project;
11. A unit subsidized with tenant -based assistance (as defined at 24 CFR 982.1(b)(2)) (e.g. Home Program); or
12. Any unit with any other duplicative Federal, State, or local housing subsidy as determined by HUD. For this purpose, “housing subsidy” does not include the housing component of a welfare payment, a Social Security payment received by the family, or a rent reduction because of a tax credit.
D. SPECIAL HOUSING TYPES [24 CFR 983.9]
In the PBVP, the CoPHD will not provide assistance for shared housing , cooperative housing, manufactured homes space rental, or the homeownership option.
A group home may include one or more group home unit s. A separate lease is executed for each elderly person or person with disabilities who resides in a group home.
Five of the PBVP HAP Contracts have “Excepted Units or Housing Exemption”:
1. Centennial Place Apartments - 142 permanent supportive housing units
2. Hudson Oaks Apartments - 44 units (Intended for and solely occupied by persons 62 years of age or older)
3. Mar Vista Union – 19 units (Homeless families with available supportive services)
4. Heritage Square Apartments – 69 units (Intended and operated for occupancy by persons 55 years of age or older)
5. The Salvation Army Hope Center-65 permanent supportive housing units
E. DECONCENTRATION OF POVERTY AND EXPANSION OF HOUSING AND ECONOMIC
OPPORTUNITIES
In accordance with HUD requirements, all PBV HAP Contracts or assistance agreements must be for units located in census tracts with poverty rates of less than 20%, unless HUD specifically approves an exception. In low-poverty census tracts or areas where vouchers are hard to use, up to 40% of units may be project-based.
Activities under the PBVP are subject to HUD environmental regulations in 24 CFR 50 and 58.
F. AGREEMENT & SECTION 8 PROJECT BASED VOUCHER HOUSING ASSISTANCE PAYMENTS CONTRACT [24 CFR 983.202, 983.203, 983.204, & 983.205]
The CoPHD must enter into an Agreement with the owner. The owner agrees to develop the contract units to comply with the HQS, and the CoPHD agrees that upon timely completion of such development in accordance with the terms of the Agreement, the CoPHD will enter into a HAP Contract with the owner for the approved number of units.The Agreement will be canceled if the HAP Contract is not executed within 120 days of notification of completion.
The CoPHD must enter into a HAP C ontract with the owner stating the terms and conditions of the PB VP project.
The initial HAP Contract term for existing housing may not be less than one year nor more than ten years. The initial HAP Contract term for new construction or rehabilitated housing may not be less than one year nor more than 20 years. The CoPHD has sole discretion to determine the initial term of the HAP Contract with these limits.
Within one year before expiration of the HAP Contract, the CoPHD may agree to extend the term of the HAP Contract for existing housing for an additional term up to 20 years for new construction or rehabilitated housing if the DRAFT
City of Pasadena Housing Department
Rental Assistance Program
2026 Administrative Plan
19-6
CoPHD determines an extension is appropriate to continue to provide affordable housing for low -income families.
HAP Contracts maybe renewed for terms for an aggregate total of 40 years, subject to the availability of appropriated funds.
At the sole option of the CoPHD, the CoPHD may renew expiring HAP Contracts for such period or periods as the HUD field office determines appropriate to achieve long term affordability of assisted housing . The CoPHD must identify the funding source for renewals; different funding sources may be used for the initial term and review terms of the HAP Contract.
The HAP Contract must provide that the term of the CoPHD contractual commitment is subject to the availability of sufficient appropriated funding (budget authority) as determined by HUD or by the CoPHD in accordance with HUD instructions. If it is determined that there may not be sufficient funding to continue housing assistance payments for all contract units and for the full term of the HAP contract, the CoPHD has the right to terminate the HAP contract by notice to the owner for all or any of the contract units.
Once the CoPHD has received owner notification that the construction or rehabilitation has been completed, the owner must submit at minimum the following evidence of completion to the Housing Department:
1. Owner certification that the work has been completed in accordance with the H QS and all requirements of the Agreement; and
2. Owner certification that the owner has complied with labor standards and equal opportunity requirements in the development of the housing.
At the CoPHD discretion, the Agreement may specify additional documentation that must be submitted by the owner as evidence of housing completion.
1. Certificate of Occupancy; and
2. An architect’s certification that the housing complies with HQS, State, local and/or other building codes After the Housing Department has receive owner notice, the CoPHD must inspect the building to determine if the housing has been completed in accordance with the Agreement, including compliance with the HQS and any additional requirements imposed by the CoPHD under the Agreement. If the work has not been completed in accordance with the Agreement, the CoPHD must not enter into the HAP Contract.