Attachment No. 9
1 Overview of Changes in the Current Revision
Below is a high-level summary of the changes contained in the Administrative Plan revision, organized by chapter.
Chapter 1
Added information on the Housing Opportunity through Modernization Act (HOTMA) to the Overview and History of the Program section.
Revised the section on Contents of the Plan to include information on project-based vouchers and policies governing special housing types.
Revised the list of owner responsibilities to account for NSPIRE.
Chapter 2
Expanded the existing policies on discrimination complaints with a new section on Discrimination Complaints., which includes guidance from Notice FHEO 2023-01.
Chapter 3
Revised various areas of the chapter to account for HOTMA changes, including the Final Rule issued February 14, 2023, Notice PIH 2023-27, and other sources of HUD guidance on the topic. This includes a new section on Restriction on Assistance Based on Assets. Included the term human trafficking with Violence Against Women Act (VAWA) language, in addition to other VAWA clarifications to better align with current guidelines such as the implementation Guidance for VAWA 2022 published in the Federal Register on January 4, 2023.
Clarified language on disparate impact and discriminatory effects per the final rule dated March 31, 2023.
Updated cross-references to correspond with updates in Chapter 8 Chapter 4
Included the term human trafficking with Violence Against Women Act (VAWA) language to better align with current guidelines.
Chapter 5
Included the term human trafficking with Violence Against Women Act (VAWA) language to better align with current guidelines.
Revised family obligations to account for NSPIRE.
Chapter 6
This chapter was completely rewritten from the ground up to account for HOTMA changes, including the Final Rule issued February 14, 2023, Notice PIH 2023-27, and other sources of HUD guidance on the topic.
Included also are changes regarding exceptions to utility allowances as a reasonable accommodation.
Attachment No. 10
2 Chapter 7
As with Chapter 6, the bulk of this chapter had to undergo a complete rewrite for HOTMA. Many of the changes were required due to updates in verification requirements outlined in Notice PIH 2023-27.
Chapter 8
This chapter only contains a minor policy adjustment to the Inspection Results section to disallow selfcertification of repairs.
This chapter contains extensive rewrites to update for NSPIRE requirements.
Chapter 9
Included the term human trafficking with Violence Against Women Act (VAWA) language to better align with current guidelines.
Additions and updates to citations for NSPIRE
Chapter 10
Included the term human trafficking with Violence Against Women Act (VAWA) language to better align with current guidelines.
Removed references to Housing Quality Standards.
Removed duplicative/conflicting policy information regarding voucher extensions and expiration.
Clarified policy regarding sending documentation to the receiving PHA.
Chapter 11
As with Chapters 6 and 7, the bulk of this chapter had to undergo a complete rewrite to account for HOTMA, including the Final Rule issued February 14, 2023, Notice PIH 2023-27, and other sources of HUD guidance on the topic. Removed references to HQS and updated for NSPIRE.
Updated policy language to mirror language elsewhere in the admin plan.
Chapter 12
Revised the policy that the PHA will terminate assistance if the family has been evicted from federally assisted housing in the last five years to reduce the number of years to three.
Included the term human trafficking with Violence Against Women Act (VAWA) language, in addition to other VAWA clarifications to better align with current guidelines such as the implementation Guidance for VAWA 2022 published in the Federal Register on January 4, 2023.
Updated Exhibit 12-1, Statement of Family Obligations, with NSPIRE language
Chapter 13
Revised policy in HAP Contract Term and Terminations section for clarification. Included the term human trafficking with Violence Against Women Act (VAWA) language, in addition to other minor VAWA clarifications to better align with current Attachment No. 10
3 guidelines such as the implementation Guidance for VAWA 2022 published in the Federal Register on January 4, 2023.
Removed references to HQS and updated for NSPIRE.
Chapter 14
Added a new subsection and accompanying policy on De Minimis Errors, plus a minor clarification to account for HOTMA changes, including the Final Rule issued February 14, 2023, Notice PIH 2023-27, and other sources of HUD guidance on the topic. Removed references to HQS and updated for NSPIRE.
Chapter 15
Reworked Chapter 15 to include the policies by default rather than directing to the guide.
Policies are now included where relevant in the event that the PHA grants use of a special housing type as needed as a reasonable accommodation.
Multiple updates to account for NSPIRE’s effect on various special housing types.
Chapter 16
Included the term human trafficking with Violence Against Women Act (VAWA) language, in addition to other VAWA clarifications to better align with current guidelines such as the implementation Guidance for VAWA 2022 published in the Federal Register on January 4, 2023.
Included changes regarding exceptions to utility allowances as a reasonable accommodation.
Modified the policy on evidence for the informal hearing to eliminate the charge of copying documents related to the hearing.
Added a record retention policy that the PHA will keep for at least three years records of all complaints, investigations, notices, and corrective actions related to fair housing violations.
Removed references to HQS and updated for NSPIRE.
Chapter 17
Made minor updates to account for the Federal Register notice issued March 3, 2023, on subsidy layering requirements.
Added a minor clarification on asset limitation requirements to the section on Eligibility for PBV Assistance to account for HOTMA changes.
Included the term human trafficking with Violence Against Women Act (VAWA) language to better align with current guidelines.
Multiple updates throughout to account for NSPIRE’s effect on PBV program requirements.
Chapter 19
Added a new Part VI on Stability Vouchers.
Revised Part II on the Foster Youth to Independence (FYI) Initiative to account for guidance set forth in Notice PIH 2023-04.
Attachment No. 10
4 Included the term human trafficking with Violence Against Women Act (VAWA) language to better align with current guidelines.
Removed references to HQS and updated for NSPIRE.
Glossary
Updated acronyms and definitions for all cumulative changes specified above. Revised various definitions for HOTMA.
Removed references to HQS and updated for NSPIRE.