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Staff Report - Amend the Housing Authority's Move to Work Plan

City Council / Housing Authority
October 16, 2023

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Staff Report - Amend the Housing Authority's Move to Work Plan
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October 16, 2023
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CITY OF POMONA

COUNCIL REPORT
October 16, 2023
To: Honorable Mayor and Members of the City Council
From: James W. Makshanoff, City Manager
Submitted By: Benita DeFrank, Neighborhood Services Director SUBJECT: A PUBLIC HEARING TO APPROVE THE CITY OF POMONA HOUSING AUTHORITY’S FY 2023-2024 MOVING TO WORK (MTW) PLAN AS AMENDED FOR SUBMISSION TO THE U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT (HUD) RECOMMENDATION:

It is recommended that the City Council, sitting as the Governing Board of the City of Pomona Housing Authority, take the following actions:

Conduct a Public Hearing for the City of Pomona Housing Authority’s Amended Moving to Work (MTW) Plan to receive comments; and, Adopt the following resolution:

RESOLUTION NO. 2023-178 – A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF POMONA, SITTING AS THE GOVERNING BOARD OF THE POMONA HOUSING AUTHORITY, approving the Housing Authority’s fy 2023-2024 MOVING TO WORK plan, AS AMENDED, for submission to the U.S. Department of Housing and Urban Development (HUD). (ATTACHMENT No. 1) EXECUTIVE SUMMARY:

The Quality Housing and Work Responsibility Act of 1998 (QHWRA) requires Public Housing Agencies (PHA) administering the Housing Choice Voucher program to develop a PHA Plan. There are two parts to the plan: A Five-Year Plan submitted once every fifth PHA fiscal year and an Annual Plan that is submitted to HUD every year. The Five-Year and Annual Plan provide a ready source for interested parties to locate basic public housing agency policies and requirements concerning operations and services. The Five-Year and Annual Plan including the MTW Supplement to the Annual Plan were submitted and approved by HUD earlier this year.

As an MTW agency, all Annual PHA Plans information must be provided in the context of the agency’s participation in the MTW demonstration. This includes taking into account the MTW Waiver(s), Safe Harbor Waiver(s), Agency-Specific Waiver(s) and Cohort-Specific Waiver(s), and associated activity(s), afforded to the MTW agency. To this end, MTW agencies will submit an MTW Supplement to the Annual PHA Plan. The PHA is proposing to amend the FY 2023-2024 in order to incorporate polices that will expand housing choice and encourage self-sufficiency for program participants.

FISCAL IMPACT:

There is no fiscal impact with this action.

PUBLIC NOTICING REQUIREMENTS:

The Housing Authority must publish a notice informing the public that the revised Moving to Work Supplement to the Annual Plan is made available for review. A 45-day period is required to allow for public comment on these documents. A notice of a public hearing was published on September 1, 2023 in the Inland Valley Daily Bulletin. (Attachment No. 3) PREVIOUS RELATED ACTION:

On March 20, 2023, the PHA board conducted a Public Hearing for the City of Pomona Housing Authority’s Annual Plan for FY 2023-24 and the Moving To Work (MTW) Supplement to the annual plan, and the item was approved.

DISCUSSION:

Authorized by HUD, the MTW program allows housing authorities to design and test innovative, locally designed housing and self-sufficiency strategies. These strategies, also referred to activities as outlined further in this discussion, are for low-income families, by permits PHAs to use assistance received under Section 8 and 9 of the United States Housing Act of 1937, as amended, 42, U.S.C. 1437, et seq., (1937 Act). The MTW program provides more flexibility by allowing certain exemptions from existing public housing and Housing Choice Voucher (HCV) program rules, as these activities are approved by HUD.

MTW is a demonstration program that provides an opportunity to design and test ways to: 1) Achieve programmatic efficiency and reduce costs; 2) Promote self-sufficiency among assisted families; and, 3) Increase housing choice for low-income households. Housing Authorities selected for the demonstration are permitted to seek exemption from many existing Public Housing and Housing Choice Voucher program rules found in the United States Housing Act of 1937 in pursuit of the following three MTW statutory objectives:

Housing Authorities that have the MTW designation are given the flexibility and authority to develop policies outside the limitations of certain HUD regulations and provisions. This will allow the Pomona Housing Authority to achieve its mission and program goals at a higher level by leveraging the unique needs and concerns of the community and residents of Pomona.

The Pomona Housing Authority MTW Plan
The following is an overview of the Housing Authority’s PHA Plan:

MTW Plan
The MTW Plan (Attachment No. 2) provides the PHA’s overall vision for its local MTW program and the unique challenges and opportunities that participation in the MTW Demonstration Program would bring. The PHA’s vision, described as it relates to the three statutory objectives of the MTW Demonstration Program are – cost effectiveness, self-sufficiency and housing choice.

The PHA is amending the MTW Plan to propose implementation of the following activities in order to expand housing choice and encourage self-sufficiency to program participants Activity 2. B Payment Standard – Fair Market Rents: the PHA is authorized to adopt and implement any reasonable policy to establish payment standards that differ from the currently mandated program requirements from the United States Housing Act of 1937 and implementing regulations. The rent allocation the Housing Authority pays is contingent upon the increased payment standard to the subsidy calculation, the PHA approves a rent increase and/or at the time when the payment standards are increased, this activity will aid in reducing families experiencing a rent burden situation, this activity meets the statutory objective of housing choice.

Activity 11.C MTW Self-Sufficiency Program Activities: this incentive is for families that are working in order to encourage them to continue working and eventually lead to self-sufficiency. The PHA will provide up to 25 working family households who have had one or more years of continued full-time employment with no break in employment over 2 weeks with a $500 incentive payment. Eligible families will be selected based on: 1) One or more years of continuous full-time (32 hours per week or more) employment of the head, co-head and spouse based on the most recent regularly scheduled biennial recertification (Code-2 ) processed within the calendar year. 2) Family has had no interim recertifications processed for a reduction in household income since the last regularly scheduled recertification. This does not include interims processed for other reasons (i.e., increases in income, owner rent increases, moves, changes in payment standards, etc.) The PHA will review eligible families for the calendar year by December 15th. If more than 25 families are eligible, families will be selected randomly by lottery. The $500 incentive will be distributed directly to the family by December 31st of each year. A family is eligible for the incentive payment once every two years. This activity meets the statutory objective of self-sufficiency.

Governing Board Action Summary
The City Council, sitting as the Pomona Housing Authority Governing Board, is presented the amended FY 2023-2024 MTW Plan, for consideration and approval. Adoption of the resolution and approval of the MTW Plan continue to allow the PHA the flexibility and authority to develop policies outside the limitations of certain HUD regulations and provisions Prepared by:
_____________________________
Jacqueline Contreras
Housing Analyst I
ATTACHMENTS:

Attachment No. 1 – Resolution No. 2023-178
Attachment No. 2 – PHA MTW Plan
Attachment No. 3 – Notice of Public Hearing
A Resolution for the Approval of the Housing Authority’s Amended MTW Plan

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