Explanatory Note to Public Reviewers of the Proposed Moving to Work Supplement Fillable Form The Moving to Work (MTW) Supplement collects information about policies implemented by MTW expansion agencies. MTW agencies use it to communicate their plans with residents and community stakeholders through required public comment processes, and HUD uses the information collected to monitor and evaluate the MTW demonstration program. MTW agencies will submit the MTW Supplement to HUD annually, and amend as needed. HUD plans to make the MTW Supplement into a fillable form so as to reduce respondent burden and make the information collected more useful to HUD. When the MTW Supplement is available through the fillable form, it will include skip patterns1 that prompt the user to populate only the sections relevant to what they are currently implementing. It will also include screening questions that will ask which waivers and associated activities they are currently implementing, plan to implement in the upcoming year, or will be discontinued in the submission year. The MTW Agency will be able to print the information from the MTW Supplement in a reader-friendly format in order to inform the public of its plans for the upcoming year. The purposes of the MTW Supplement are two-fold: it reports to HUD what is happening at the local level in a way that the Department can monitor and evaluate; and, more importantly, it informs the public about what the agency is planning and gives the public the ability to provide comment.
The MTW Supplement asks for information about each of the MTW Waivers and associated activities that are made possible by the MTW Operations Notice, Safe Harbor Waivers and Agency-Specific Waivers, and a few other types of information. MTW agencies will fill in information/data through a fillable form and the information collected will be stored in a database so that it can be analyzed by HUD. The approved forms will be posted to the MTW website for viewing by the public. For instance, it will be simple to find out how many MTW agencies and which MTW agencies are implementing each type of activity. It will also simplify reporting for the MTW agency since information will carry over year-to-year in the fillable form so that information that does not change from year to year will be pre-populated, thereby reducing respondent burden.
This document lists the sections of the MTW Supplement and then presents the proposed questions to be included in the MTW Supplement for MTW agencies to answer annually. Throughout the online version, there will be a dropdown menu option that makes it clear as to which activities an agency is permitted to do within the safe harbors of the MTW Operations Notice, Appendix I, MTW Waivers.
Sections of the MTW Supplement:
PHA Information
Narrative
MTW Waivers and Associated MTW Activities
Safe Harbor Waivers
Agency-Specific Waivers
Public Housing Operating Subsidy Grant Reporting
MTW Statutory Requirements
Public Comments
Evaluations
MTW Certifications of Compliance
Information to be Collected for MTW Activities
There are many MTW activities, subject to limitations as outlined in the MTW Operations Notice, that an MTW agency may implement. Each MTW agency will likely only engage in a subset of these MTW activities. The MTW Supplement will first ask MTW agencies to identify which MTW activities they are proposing to implement and which of those MTW activities they are already implementing. MTW agencies will subsequently be asked to provide information only about the MTW activities they are proposing to implement or are already implementing. This feature will reduce respondent burden. MTW waivers have associated MTW activities.
MTW agencies are also able to combine MTW activities into their own initiatives.
MTW agencies will be asked for specific information about each MTW activity they are proposing to implement or are already implementing. There are six types of questions that could be asked about each MTW activity. The exact mix of questions will depend partly upon the MTW activity and partly upon the requirements for that MTW activity listed in the MTW Operations Notice. The six types of questions are:
Core—questions applicable to most MTW activities
Custom—questions specific to an individual MTW activity Safe Harbor Waiver—questions asked when the MTW activity requires a Safe Harbor Waiver Hardship Policy—questions asked when the MTW Operations Notice requires a hardship policy for the MTW activity Impact Analysis—questions asked when the MTW Operations Notice requires an impact analysis for the MTW activity Agency-Specific Waiver—questions asked when the MTW activity requires an Agency-Specific Waiver 1 A skip pattern is a question or series of questions associated with a conditional response.
Questions
The questions are presented below by type, beginning with the core questions. In the final online version of the MTW Supplement, the relevant questions from each type will be asked together in relation to each MTW activity the MTW agency is proposing to implement or is already implementing. The final online version of the MTW Supplement will be set up to allow for different versions of the same MTW activity—for instance, a different minimum rent for the non-elderly/non-disabled than for the elderly/disabled. The final online version of the MTW Supplement will also be able to autofill items with information from previous years. This feature will reduce respondent burden.
Table 1, at the end of this document, lists the MTW activities and indicates which types of questions need to be asked about each one.
MTW Supplement to the Annual PHA Plan
U.S. Department of Housing and Urban Development Office of Public and Indian Housing OMB No. 2577-0226
Expires: 03/31/2024
Purpose. The Moving to Work (MTW) Supplement to the Annual PHA Plan informs HUD, families served by the PHA, and members of the public, about the MTW Waivers and associated activities that the MTW agency seeks to implement in the coming Fiscal Year and updates the status of MTW activities that have been previously approved. It also provides information about Safe Harbor Waivers, Agency-Specific Waivers, compliance with MTW statutory requirements, and evaluations. The MTW Supplement does not replace the PHA Plan. MTW agencies must continue to submit the applicable PHA Plan. MTW agencies that are not required to submit annual PHA Plans under the Housing and Economic Recovery Act of 2008 (HERA) must submit the MTW Supplement annually, in addition to holding public hearings, obtaining board approval, and consulting with Resident Advisory Boards (RABs) and tenant associations, as applicable, on planned MTW activities.
Applicability. Form HUD-50075-MTW is to be completed annually by all MTW agencies brought onto the MTW Demonstration Program pursuant to Section 239 of the Fiscal Year 2016 Appropriations Act, P.L. 114-113 (2016 MTW Expansion Statute) or legacy MTW agencies2 that chose to follow the requirements of the MTW Operations Notice.
Definitions. All terms used in this MTW Supplement are consistent with the definitions stated in the MTW Operations Notice, including:
Local, Non-Traditional Activities (LNT) – Those MTW activities that use MTW funding flexibility outside of the Housing Choice Voucher (HCV) and public housing programs established in Sections 8 and 9 of the U.S. Housing Act of 1937.
Safe Harbors – The additional parameters or requirements, beyond those specified in the MTW activity description itself found in the MTW Operations Notice, following each activity description, that the MTW agency must follow in implementing MTW activities.
Substantially the Same Requirement – A statutory MTW requirement that MTW agencies must continue to assist substantially the same total number of eligible low-income families as would have been served absent the MTW demonstration.
A.
PHA Information.
A.1
PHA Name: Pomona Housing Authority
PHA Code: CA123
MTW Supplement for PHA Fiscal Year Beginning: (MM/DD/YYYY): 07/01/2024 PHA Program Type: Public Housing (PH) only ✔ Housing Choice Voucher (HCV) only Combined MTW Cohort Number: 1
MTW Supplement Submission Type: ✔ Annual Submission Amended Annual Submission B.
Narrative.
B.1
MTW Supplement Narrative.
As an MTW Agency, the Pomona Housing Authority (PHA) will be given the flexibility and authority to develop policies outside the limitations of certain HUD regulations and provisions. This will allow the PHA 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 PHA is a high performing housing authority that provides safe, decent and affordable housing to hundreds of Pomona residents through special programs serving families, individuals, senior citizens, Veterans, the disabled and homeless households. The PHA’s mission is to improve the quality of life for our diverse community. The PHA provides financial assistance through the Housing Choice Voucher and Project-Based Voucher (also collectively known as the Section 8) Programs, and through the Housing and Urban Development Veteran Affairs Supportive Housing, Mainstream, Foster Youth Initiative Tenant Protection Voucher programs and Housing Stability Vouchers.
The MTW Program will allow the PHA to combine resources permitting the use of HUD funds to better address local program priorities and needs. In addition, the PHA will streamline its business processes to operate more cost effectively and efficiently by implementing innovative business solutions, redesign processes, and amend policies that will reduce administrative complexity, costs and staff time. The PHA plans to consider and assess a range of potential options in subsequent phases of MTW, with a goal of structuring its programs in ways that will assist families achieve financial self-sufficiency over time. The following strategies will help improve the quality of lives of program participants: work in partnership with local community organizations to develop a comprehensive approach to ending homelessness and promote self-sufficiency and assist in the implementation of the City of Pomona’s “A Way Home: Community Solutions for Pomona’s Homeless Strategic Plan” by creating a program to assist the homeless and chronically homeless achieve self-sufficiency.
The PHA will continue to implement activities proposed in Fiscal Year 2024-2025. The PHA has had challenges in implementing the activities due to delays and changes to the PHA’s software system. The PHA decided not to implement the activities since the software vendor recommended to delay implementation until the Housing Information Portal (HIP) was available. On January 3, 2023, HUD issued guidance and provided an update on the HIP for MTW Agencies. Based on the guidance, the PHA will continue to delay implementation of Activities: 1(n) - Utility Reimbursement and 1(u) – Standard Deductions since fields on the 50058 need to be modified and until the HIP System is ready. The PHA will continue to follow normal protocols in submitting 50058s on the IMS/PIC until the new HIP is ready. ______________________________________________________________________________ ___
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C.
MTW Waivers and Associated Activities.
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C.1
Tenant Rent Policies Currently Implemented
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1.i., 1.j. - Alternative Utility Allowance (PH & HCV)
Input options and instructions
Please describe the alternative method of calculating the utility allowances. Please explain how the method of calculating utility allowances is different from the standard method and what objective the MTW agency aims to achieve by using this alternative method - The PHA has established one streamlined utility allowance for all HCV units based upon bedroom size and types of utilities paid by the participant in the City of Pomona. The goal of this activity is to reduce the administrative burden of calculating multiple utility allowances based on unit type and streamline recertification processing time. The PHA will continue to review its utility allowance schedule each year and revise it if there has been a 10% change from the prior year. The Pomona Housing Authority will be implementing waiver [1j – Alternative Utility Allowance (HCV)] within the safe harbor limits established in the MTW Operations Notice published in the Federal Register on August 28, 2020.
Currently, the PHA annually reviews and periodically revises a Utility Allowance Schedule, which represents the reasonable costs for utilities as part of the tenant’s lease. The utility allowance is based on utility surveys and analysis of the structure type, bedroom size, appliances provided by tenant, and type of appliances (gas/electric). The simplified schedule is based on the analysis of data collected from the PHA’s existing HCV portfolio including the most common structure and utility types. This new utility allowance schedule will be implemented upon the biennial certification or change of unit. The PHA proposes a simplified schedule to reduce administrative costs and reduce errors associated with the traditional method of applying Utility Allowances. The simplified utility allowance schedule is also anticipated to benefit property owners who will have a more accurate understanding of the total gross rent to be applied to their properties. This schedule will be applied to the lesser of: the actual size of the unit or the size of the voucher. The PHA will continue to use current market consumption data to determine when adjustments to the simplified schedule are needed (upon change of more than 10% in rates).
1.m., 1.n. - Utility Reimbursements (PH & HCV)
[No custom questions for this activity.]
The PHA will eliminate the utility reimbursement payments in the HCV program. Families will continue to receive a utility allowance but will not receive additional monies if the utility allowance is greater than the total tenant payment. There are currently 21 families receiving utility reimbursements. Eliminating these reimbursements is a cost savings to the PHA of approximately $13,860 which could assist an additional HCV family from the waiting list and reducing the administrative burdens of lost checks, canceled checks and fraud. The Pomona Housing Authority will be implementing waiver [1n -Utility Reimbursements (HCV)] within the safe harbor limits established in the MTW Operations Notice published in the Federal Register on August 28, 2020. ____________________________________________________________ ___
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1.t., 1.u. - Standard Deductions (PH & HCV)
Input options and instructions
How much will the single standard deduction be in the Fiscal Year? $ 500
The Pomona Housing Authority has established a standard deduction for families to simply the rent calculation process, increase cost effectiveness and reduce administrative burdens. The standard deduction will be $500 for elderly/disabled families and non-elderly families with one or more dependents:
- a child or children under the age of 18;
- disabled member in the household; or, a full-time
student in the household
The Pomona Housing Authority will be implementing waiver [1u – Standard Deductions] within the safe harbor limits established in the MTW Operations Notice published in the Federal Register on August 28, 2020.
C.2
Payment Standards and Rent Reasonableness Currently Implemented
2.b. - Payment Standards – Fair Market Rents (HCV)
Input options and instructions
Please explain the payment standards by FMR –
The Pomona Housing Authority is authorized to adopt and implement any reasonable policy to establish payment standards that differ from the currently mandated program requirements in the 1937 Act and its implementing regulations. The Pomona Housing Authority will establish payment standards between 80% and 120% of the HUD published Fair established in the MTW Operations Notice published in the Federal Register on August 28, 2020. - At the next regularly scheduled recertification or move - At the time a rent increase is approved for the unit
- At any other time if the PHA determines that the family is experiencing a rent burden.
- Rent burden is defined as paying more than 40% of
monthly adjusted income toward rent
In the unlikely event that the PHA payment standards are reduced, the family’s payment standard will not be reduced if they remain in the unit unless they have experienced a change in family composition that results in a lower voucher/payment standard size. [2b - Payment Standards] within the safe harbor limits established in the MTW Operations Notice published in the Federal Register on August 28, 2020.
C.3
Reexaminations Currently Implementing
3.a., 3.b. - Alternative Reexamination Schedule for Households (PH & HCV) Input options and instructions
What is the recertification schedule?
(Check one)
Once every two years Once every three years
[X] Other [If checked]: Please describe:
Every two years for all HCV families who have at least $1,200 per year in annual income. Any families reporting less than $1,200 per year in annual income will remain on an annual recertification cycle.
The PHA will conduct a reexamination once every three years (triennial) for all families who are elderly (62+) in which at least 90% of income is from a fixed source.
How many interim recertifications per year may a household request? 0 [X]1
2 or more
Please describe briefly how the MTW agency plans to address changes in family/household circumstances under the alternative reexamination schedule
The PHA has established a biennial (every two years) recertification schedule for all HCV families who have at least $1,200 per year in annual income. Any families reporting less than $1,200 per year in annual income will remain on an annual recertification cycle. The goal of this activity is to further self-sufficiency of residents and reduce the burden of reporting to the PHA when the family experiences an increase in household income.
The PHA is proposing a triennial recertification schedule for all elderly-only households on a fixed income. An elderly-only fixed-income family is one that has no members under the age of 62 and has at least 90% of its income from fixed sources. The goal of this activity is reduce the burden of reporting to the PHA when there is minor income changes and achieve administrative time savings.
3.c., 3.d. - Self-Certification of Assets (PH & HCV)
Input options and instructions
Please state the dollar threshold for the self-certification of assets. $50,000
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C.4
Landlord Leasing Incentives Currently Implementing
4.a., 4.b., 4.c. - Vacancy Loss, Damage Claims, and Other Landlord Incentives (HCV) Input options and instructions
(The same custom questions are asked for each of these activities.) Does this policy apply to certain types of units or to all units all HCV units or only certain types of units (for example, accessible units, units in a low-poverty neighborhood, or units/landlords new to the HCV program? [X] To all units [No follow-up questions]
Certain types of units only [if checked, there are follow up questions]:
What types of units does this policy apply to?
Accessible units
Units in particular types of areas or neighborhoods [if checked]: Please describe these areas briefly: [Text box] Units/landlords new to the HCV program Other [if checked]: Please describe briefly [Text box]
What is the maximum payment that can be made to a landlord under this policy? One month’s contract rent for Damage Claims and $250 Signing Bonus for each new HAP contract executed in the City of Pomona How many payments were issued under this policy in the most recently completed PHA fiscal year? 0 [number of payments]
What is the total dollar value of payments issued under this policy in the most recently completed PHA fiscal year? $ 0
C.5
Housing Quality Standards (HQS) Not Currently Implementing C. 6
Short Term Assistance Not Currently Implementing
C.7
Term-Limited Assistance Not Currently Implementing
C.8
Increase Elderly Age (PH &HCV) Not Currently Implementing C.9
Project-Based Voucher Program Flexibilities (PBV) Currently Implementing
9.c. - Elimination of PBV Selection Process for PHA-owned Projects without Improvement, Development, or Replacement (HCV) The PHA will eliminate the selection process in the award of PBVs to properties owned by the Pomona Housing Authority that are not public housing without engaging in an initiative to improve, develop or replace a public housing property or site. A subsidy layering review will be conducted. The PHA will complete the site selection requirements. HQS (or NSPIRE) inspection will be performed by an independent entity according to 24 CFR 983.59(b) or 24 CFR 983.103(f). The PHA will follow the requirements of Notice PIH 2013-27 where applicable and the property will be owned by a single-asset entity of the PHA. The Pomona Housing Authority will be implementing Waiver 9.c – Elimination of PBV Selection Process for PHA-Owned Projects Without Improvement, Development or Replacement within the safe harbor limits established in the MTW Operations Notice published in the Federal Register on August 28, 2020.
C.10
Family Self-Sufficiency Program with MTW Flexibilities Not Currently Implementing C. 11
MTW Self-Sufficiency Program Not Currently Implementing C.12
Work Requirement Not Currently Implementing
C.13
Public Housing as an Incentive for Economic Progress Not Currently Implementing C.17
Local, Non-Traditional (LNT) Activities Currently Implementing ____________17.c. - Housing Development Programs
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For each LNT housing development that the MTW agency committed funds to or spent funds on in the most recently completed Fiscal Year, please add the name of the development to one column in Table 17.c.2 below heading and then provide the requested information, including the MTW agency role (Acquisition, Rehabilitation, or New Construction), the type of MTW agency financing (Gap Financing, Tax Credit Partnership, Other), and the total number of affordable units in the development. If possible, please provide a breakdown of the number of affordable units by level of affordability.
Table 17.c.2 - Housing Development Programs that the MTW Agency committed funds to in prior Fiscal Year [autofill previous year] Question
252 E. 4th Street Project - 252 E. 4th St. Pomona, CA 91767 MTW Role: Acquisition, Rehabilitation, New Construction? Rehabilitation
Type of MTW Agency Financing: Gap Financing, Tax Credit Partnership, Other Other – architectural services for the preparation of plans & specifications to substantially rehabilitate the 12 units Number of Affordable Units
12 Total Number of Units
12 Number of Units by Affordability
12 80% of AMI
0 60% of AMI
3 30% of AMI
9 Other
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D.
Safe Harbor Waivers.
D.1
Safe Harbor Waivers seeking HUD Approval:
The MTW Operations Notice describes a simplified process for MTW agencies to implement MTW activities outside of the safe harbors described in Appendix I. For each Safe Harbor Waiver request, a document that includes the following information must be provided: (a) the name and number of the MTW Waiver and associated activity for which the MTW agency is seeking to expand the safe harbor, (b) the specific safe harbor and its implementing regulation, (c) the proposed MTW activity the MTW agency wishes to implement via this Safe Harbor Waiver, (d) a description of the local issue and why such an expansion is needed to implement the MTW activity, (e) an impact analysis, (f) a description of the hardship policy for the MTW activity, if applicable, and (g) a copy of all comments received at the public hearing along with the MTW agency’s description of how the comments were considered, as a required attachment to the MTW Supplement.
Will the MTW agency submit request for approval of a Safe Harbor Waiver this year? [X] No
Yes [If yes, upload required information in a-g above for each Safe Harbor Waiver request] E.
Agency-Specific Waivers.
E.1
Agency-Specific Waivers for HUD Approval:
The MTW demonstration program is intended to foster innovation and HUD encourages MTW agencies, in consultation with their residents and stakeholders, to be creative in their approach to solving affordable housing issues facing their local communities. For this reason, flexibilities beyond those provided for in Appendix I may be needed. Agency-Specific Waivers may be requested if an MTW agency wishes to implement additional activities, or waive a statutory and/or regulatory requirement not included in Appendix I.
In order to pursue an Agency-Specific Waiver, an MTW agency must include an Agency-Specific Waiver request, an impact analysis, and a hardship policy (as applicable), and respond to all of the mandatory core questions as applicable.
For each Agency-Specific Waiver(s) request, please upload supporting documentation, that includes: a) a full description of the activity, including what the agency is proposing to waive (i.e., statute, regulation, and/or Operations Notice), b) how the initiative achieves one or more of the 3 MTW statutory objectives, c) a description of which population groups and household types that will be impacted by this activity, d) any cost implications associated with the activity, e) an implementation timeline for the initiative, f) an impact analysis, g) a description of the hardship policy for the initiative, and h) a copy of all comments __________________
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received at the public hearing along with the MTW agency’s description of how the comments were considered, as a required attachment to the MTW Supplement.
Will the MTW agency submit a request for approval of an Agency-Specific Waiver this year? [X] No [If no, skip to E.2]
Yes [If yes, please provide a title and upload required information in a-h above for each Agency-Specific Waiver request] E.2
Agency-Specific Waiver(s) for which HUD Approval has been Received:
For each previously approved Agency-Specific Waiver(s), a set of questions will populate. Does the MTW agency have any approved Agency-Specific Waivers? Yes [If yes, then the following questions will pop up for each Agency-Specific Waiver approved in Section E.1 in a previous submission; the titles will be prepopulated] [Yes/No/Discontinued] Has there been a change in how the waiver is being implemented from when it was originally approved? [If Yes]: If there has been a change, please provide a description of what has changed. [If Discontinued]: 1) If this waiver has been discontinued, please provide a description of the final outcomes and lessons learned from implementing this Activity at your PHA. 2) If the MTW Agency was previously required to prepare an impact analysis, was a final impact analysis prepared at the time of discontinuation.
X No [If no, question set concludes]
F.
Public Housing Operating Subsidy Grant Reporting. Not Applicable. The PHA does not own Public Housing Units G.
MTW Statutory Requirements. Currently Implementing
G.1
75% Very Low Income – Local, Non-Traditional.
HUD will verify compliance with the statutory requirement that at least 75% of the households assisted by the MTW agency are very low-income for MTW public housing units and MTW HCVs through HUD systems. The MTW PHA must provide data for the actual families housed upon admission during the PHA’s most recently completed Fiscal Year for its Local, Non- Traditional program households.
Income Level
Number of Local, Non-Traditional Households Admitted in the Fiscal Year* 80%-50% Area Median Income
1 49%-30% Area Median Income
1 Below 30% Area Median Income
22 Total Local, Non-Traditional Households
24 *Local, non-traditional income data must be provided in the MTW Supplement form until such time that it can be submitted in IMS- PIC or other HUD system.
G.2
Establishing Reasonable Rent Policy.
Question
Input options and instructions
Has the MTW agency established a rent reform policy to encourage employment and self-sufficiency? No Yes/No [If Yes]: please describe the MTW agency’s plans for its future rent reform activity and the implementation timeline. [Text box] G.3
Substantially the Same (STS) – Local, Non-Traditional.
Questions
Input options and instructions
Please provide the total number of unit months that families were housed in a local, non-traditional rental subsidy for the prior full calendar year. 11,004 # of unit months
Please provide the total number of unit months that families were housed in a local, non-traditional housing development program for the prior full calendar year.
0 # of unit months
How many units, developed under the local, non-traditional housing development activity, were available for occupancy during the prior full calendar year (by bedroom size)? Please include only those units that serve households at or below 80% of AMI in the table provided.
PROPERTY NAME/ADDRESS
0/1
BR
2 BR
3 BR
4 BR
5 BR
6+ BR
TOTAL UNITS
POPULATION TYPE*
# of Section 504
Accessible (Mobility)**
# of Section 504 Accessible (Hearing/ Vision)
Was this Property Made Available for Initial Occupancy during the Prior Full Calendar Year? What was the Total Amount of MTW Funds Invested into the Property? Name/Address
#
#
#
#
#
#
#
Type (below)
#
#
Y/N
$
Name/Address
#
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#
#
#
#
Type (below)
#
#
Y/N
$
Name/Address
#
#
#
#
#
#
#
Type (below)
#
#
Y/N
$
Totals
#
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#
User will select one of the following from the “Population Type” dropdown box: General, Elderly, Disabled, Elderly/Disabled, Other If the “Population Type” of is Other is selected, please state the Property Name/Address and describe the population type. [Text box] ** The federal accessibility standard under HUD’s Section 504 regulation is the Uniform Federal Accessibility Standards (UFAS) for purposes of Section 504 compliance. HUD recipients may alternatively use the 2010 ADA Standards for Accessible Design under Title II of the ADA, except for certain specific identified provisions, as detailed in HUD’s Notice on “Instructions for use of alternative accessibility standard,” published in the Federal Register on May 23, 2014 (“Deeming Notice”) for purposes of Section 504 compliance, https://www.govinfo.gov/content/pkg/FR-2014-05-23/pdf/2014-11844.pdf. This would also include adaptable units as defined by HUD’s Section 504 regulation (See 24 CFR § 8.3 and § 8.22). __________________
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G.4
Comparable Mix (by Family Size) – Local, Non-Traditional.
In order to demonstrate that the MTW statutory requirement of “maintaining a comparable mix of families (by family size) are served, as would have been provided had the amounts not been used under the demonstration” is being achieved, the MTW agency will provide information for its most recently completed Fiscal Year in the following table.
Local, non-traditional family size data must be provided in the MTW Supplement form until such time that it can be submitted in IMS-PIC or other HUD system.
Family Size:
Occupied Number of Local, Non-
Traditional units by Household Size
1 Person
475
2 Person
228
3 Person
105
4 Person
86 5 Person
56 6+ Person
42 Totals
992
G.5
Housing Quality Standards. Not Applicable. The PHA does not own Public Housing Units Certification is included in MTW Certifications of Compliance for HCV and local, non-traditional program. The public housing program is monitored through physical inspections performed by the Real Estate Assessment Center (REAC).
H.
Public Comments.
H.1
Input options and instructions
Please provide copy of all comments received by the public, Resident Advisory Board, and tenant associations.
See Attachment No. 8
Please attach a narrative describing the MTW agency’s analysis of the comments and any decisions made based on these comments.
See Attachment No. 8
If applicable, was an additional public hearing held for an Agency-Specific Waiver and/or Safe Harbor waiver? Yes
[X] No
N/A
If yes, please attach the comments received along with the MTW agency’s description of how comments were considered.
Upload Attachment – N/A
I
Evaluations. – No known evaluations
I.1
Please list any ongoing and completed evaluations of the MTW agency’s MTW policies, that the PHA is aware of, including the information requested in the table below. In the box “title and short description,” please write the title of the evaluation and a brief description of the focus of the evaluation.
Question
Input options and instructions
Does the PHA have an agency-sponsored evaluation?
Yes/No [If Yes]: Please complete the table below.
Table I.1 - Evaluations of MTW Policies
Title and short description
Evaluator name and contact information
Time period
Reports available
J
MTW Certifications of Compliance.
J.1
The MTW agency must execute the MTW Certifications of Compliance form and submit as part of the MTW Supplement submission to HUD. Certification is provided below.
MTW CERTIFICATIONS OF COMPLIANCE
U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT OFFICE OF PUBLIC AND INDIAN HOUSING Certifications of Compliance with Regulations:
Board Resolution to Accompany the MTW Supplement to the Annual PHA Plan Acting on behalf of the Board of Commissioners of the Moving to Work Public Housing Agency (MTW PHA) listed below, as its Chairperson or other authorized MTW PHA official if there is no Board of Commissioners, I approve the submission of the MTW Supplement to the Annual PHA Plan for the MTW PHA Fiscal Year beginning (07/01/2024), hereinafter referred to as "the MTW Supplement", of which this document is a part and make the following certifications and agreements with the Department of Housing and Urban Development (HUD) in connection with the submission of the MTW Supplement and implementation thereof:
The PHA made the proposed MTW Supplement and all information relevant to the public hearing available for public inspection at least 45 days before the hearing, published a notice that a hearing would be held and conducted a hearing to discuss the MTW Supplement and invited public comment.
The MTW PHA took into consideration public and resident comments (including those of its Resident Advisory Board(s) or tenant associations, as applicable) before approval of the MTW Supplement by the Board of Commissioners or Board of Directors in order to incorporate any public comments into the annual MTW Supplement.
The MTW PHA certifies that the Board of Directors has reviewed and approved the budget for the Capital Fund Program grants contained in the Capital Fund Program Annual Statement/Performance and Evaluation Report, form HUD-50075.1 (or successor form as required by HUD).
The MTW PHA will carry out the MTW Supplement in conformity with Title VI of the Civil Rights Act of 1964 (42 U.S.C. 2000d- 2000d-4), the Fair Housing Act (42 U.S.C. 3601-19), section 504 of the Rehabilitation Act of 1973 (29 U.S.C. 794), and title II of the Americans with Disabilities Act of 1990 (42 U.S.C. 12101 et seq.) all regulations implementing these authorities; and other applicable Federal, State, and local civil rights laws.
The MTW Supplement is consistent with the applicable comprehensive housing affordability strategy (or any plan incorporating such strategy) for the jurisdiction in which the PHA is located.
The MTW Supplement contains a certification by the appropriate state or local officials that the Plan is consistent with the applicable Consolidated Plan, which includes a certification that requires the preparation of an Analysis of Impediments to Fair Housing Choice, for the MTW PHA's jurisdiction and a description of the manner in which the MTW Supplement is consistent with the applicable Consolidated Plan.
The MTW PHA will affirmatively further fair housing, which means that it will: (i) take meaningful actions to further the goals identified by the Assessment of Fair Housing (AFH) conducted in accordance with the requirements of 24 CFR 5.150-
5.180 and 903.15; (ii) take no action that is materially inconsistent with its obligation to affirmatively further fair housing; and (iii) address fair housing issues and contributing factors in its programs, in accordance with 24 CFR 903.7(o)(3) and 903.15(d). Note: Until the PHA is required to submit an AFH, and that AFH has been accepted by HUD, the PHA must follow the certification requirements of 24 CFR 903.7(o) in effect prior to August 17, 2015. Under these requirements, the PHA will be considered in compliance with the certification requirements of 24 CFR 903.7(o)(1)-(3) and 903.15(d) if it: (i) examines its programs or proposed programs; (ii) identifies any impediments to fair housing choice within those programs; (iii) addresses those impediments in a reasonable fashion in view of the resources available; (iv) works with local jurisdictions to implement any of the jurisdiction’s initiatives to affirmatively further fair housing that require the PHA’s involvement; and (v) maintains records reflecting these analyses and actions.
The MTW PHA will comply with the prohibitions against discrimination on the basis of age pursuant to the Age Discrimination Act of 1975 and HUD’s implementing regulations at24 C.F.R. Part 146.
In accordance with 24 CFR 5.105(a)(2), HUD’s Equal Access Rule, the MTW PHA will not make a determination of eligibility for housing based on sexual orientation, gender identify, or marital status and will make no inquiries concerning the gender identification or sexual orientation of an applicant for or occupant of HUD-assisted housing.
The MTW PHA will comply with the Architectural Barriers Act of 1968 and 24 CFR Part 41, Policies and Procedures for the Enforcement of Standards and Requirements for Accessibility by the Physically Handicapped.
The MTW PHA will comply with the requirements of section 3 of the Housing and Urban Development Act of 1968, Employment Opportunities for Low- or Very-Low Income Persons, and with its implementing regulation at 24 CFR Part 135.
The MTW PHA will comply with requirements with regard to a drug free workplace required by 24 CFR Part 24, Subpart F.
The MTW PHA will comply with requirements with regard to compliance with restrictions on lobbying required by 24 CFR Part 87, together with disclosure forms if required by this Part, and with restrictions on payments to influence Federal Transactions, in accordance with the Byrd Amendment.
The MTW PHA will comply with acquisition and relocation requirements of the Uniform Relocation Assistance and Real Property Acquisition Policies Act of 1970 and implementing regulations at 49 CFR Part 24 as applicable.
The MTW PHA will take appropriate affirmative action to award contracts to minority and women's business enterprises under 24 CFR 5.105(a).
The MTW PHA will provide HUD or the responsible entity any documentation needed to carry out its review under the National Environmental Policy Act and other related authorities in accordance with 24 CFR Part 58. Regardless of who acts as the responsible entity, the MTW PHA will maintain documentation that verifies compliance with environmental requirements pursuant to 24 Part 58 and 24 CFR Part 50 and will make this documentation available to HUD upon its request.
With respect to public housing and applicable local, non-traditional development the MTW PHA will comply with Davis-Bacon or HUD determined wage rate requirements under section 12 of the United States Housing Act of 1937 and the Contract Work Hours and Safety Standards Act.
The MTW PHA will keep records in accordance with 2 CFR 200.333-200.337 and facilitate an effective audit to determine compliance with program requirements.
The MTW PHA will comply with the Lead-Based Paint Poisoning Prevention Act and 24 CFR Part 35.
The MTW PHA will comply with the policies, guidelines, and requirements of 2 CFR Part 200.
The MTW PHA must fulfill its responsibilities to comply with and ensure enforcement of housing quality standards as required in PIH Notice 2011-45, or successor notice, for any local, non-traditional program units. The MTW PHA must fulfill its responsibilities to comply with and ensure enforcement of Housing Quality Standards, as defined in 24 CFR Part 982, for any Housing Choice Voucher units under administration.
The MTW PHA will undertake only activities and programs covered by the Moving to Work Operations Notice in a manner consistent with its MTW Supplement and will utilize covered grant funds only for activities that are approvable under the Moving to Work Operations Notice and included in its MTW Supplement. MTW Waivers activities being implemented by the agency must fall within the safe harbors outlined in Appendix I of the Moving to Work Operations Notice and/or HUD approved Agency-Specific or Safe Harbor Waivers.
All attachments to the MTW Supplement have been and will continue to be available at all times and all locations that the MTW Supplement is available for public inspection. All required supporting documents have been made available for public inspection along with the MTW Supplement and additional requirements at the primary business office of the PHA and at all other times and locations identified by the MTW PHA in its MTW Supplement and will continue to be made available at least at the primary business office of the MTW PHA.
Pomona Housing Authority CA123
MTW PHA NAME MTW PHA NUMBER/HA CODE
I hereby certify that all the information stated herein, as well as any information provided in the accompaniment herewith, is true and accurate. Warning: HUD will prosecute false claims and statements. Conviction may result in criminal and/or civil penalties. (18 U.S.C. 1001, 1010, 1012; 31 U.S.C. 3729, 3802).
Anita D. Gutierrez City Manager NAME OF AUTHORIZED OFFICIAL TITLE
SIGNATURE DATE
* Must be signed by either the Chairperson or Secretary of the Board of the MTW PHA's legislative body. This certification cannot be signed by an employee unless authorized by the MTW PHA Board to do so. If this document is not signed by the Chairperson or Secretary, documentation such as the by-laws or authorizing board resolution must accompany this certification. form HUD-50075-MTW (01/2021)form HUD-50075-MTW (01/2021) form HUD-50075-MTW (01/2021)
form HUD-50075-MTW (01/2021)
form HUD-50075-MTW (01/2021)form HUD-50075-MTW (01/2021) form HUD-50075-MTW (01/2021)
form HUD-50075-MTW (01/2021)
form HUD-50075-MTW (01/2021)form HUD-50075-MTW (01/2021) form HUD-50075-MTW (01/2021)
form HUD-50075-MTW (01/2021)
form HUD-50075-MTW (01/2021)form HUD-50075-MTW (01/2021) form HUD-50075-MTW (01/2021)
form HUD-50075-MTW (01/2021)
form HUD-50075-MTW (01/2021)
form HUD-50075-MTW (01/2021)
form HUD-50075-MTW (01/2021)form HUD-50075-MTW (01/2021) form HUD-50075-MTW (01/2021)
form HUD-50075-MTW (01/2021)
form HUD-50075-MTW (01/2021)form HUD-50075-MTW (01/2021) form HUD-50075-MTW (01/2021)
form HUD-50075-MTW (01/2021)
Attachment No. 3
MTW Supplement to the Annual PHA PlanMTW Supplement to the Annual PHA PlanOMB No. 2577-0226Expires: 03/31/2024OMB No. 2577-0226Expires: 03/31/2024 MTW Supplement to the Annual PHA Plan
MTW Supplement to the Annual PHA Plan
OMB No. 2577-0226
Expires: 03/31/2024
OMB No. 2577-0226
Expires: 03/31/2024
MTW Supplement to the Annual PHA PlanMTW Supplement to the Annual PHA PlanOMB No. 2577-0226Expires: 03/31/2024OMB No. 2577-0226Expires: 03/31/2024 MTW Supplement to the Annual PHA Plan
MTW Supplement to the Annual PHA Plan
OMB No. 2577-0226
Expires: 03/31/2024
OMB No. 2577-0226
Expires: 03/31/2024
MTW Supplement to the Annual PHA PlanMTW Supplement to the Annual PHA PlanOMB No. 2577-0226Expires: 03/31/2024OMB No. 2577-0226Expires: 03/31/2024 MTW Supplement to the Annual PHA Plan
MTW Supplement to the Annual PHA Plan
OMB No. 2577-0226
Expires: 03/31/2024
OMB No. 2577-0226
Expires: 03/31/2024
MTW Supplement to the Annual PHA PlanMTW Supplement to the Annual PHA PlanOMB No. 2577-0226Expires: 03/31/2024OMB No. 2577-0226Expires: 03/31/2024 MTW Supplement to the Annual PHA Plan
MTW Supplement to the Annual PHA Plan
OMB No. 2577-0226
Expires: 03/31/2024
OMB No. 2577-0226
Expires: 03/31/2024
MTW Supplement to the Annual PHA PlanMTW Supplement to the Annual PHA PlanOMB No. 2577-0226Expires: 03/31/2024OMB No. 2577-0226Expires: 03/31/2024 MTW Supplement to the Annual PHA Plan
MTW Supplement to the Annual PHA Plan
OMB No. 2577-0226
Expires: 03/31/2024
OMB No. 2577-0226
Expires: 03/31/2024