Community Development Agency
www.santa-ana.org/cd
Item # 5
City of Santa Ana
20 Civic Center Plaza, Santa Ana, CA 92701
Staff Report
July 15, 2025
TOPIC: Update to the Housing Choice Voucher Administrative Plan
AGENDA TITLE
Approve an Update to the Housing Choice Voucher Administrative Plan to Comply with the Housing Opportunity Through Modernization Act
RECOMMENDED ACTION
Approve an update to the Housing Choice Voucher Administrative Plan to comply with the Housing Opportunity Through Modernization Act.
GOVERNMENT CODE §84308 APPLIES: No
DISCUSSION
The U.S. Department of Housing and Urban Development (HUD) requires public housing authorities (PHAs) administering a Housing Choice Voucher (HCV) program to have an HCV Administrative Plan that establishes policies for implementing the program consistent with both HUD requirements and the goals and objectives contained in the Santa Ana Housing Authority’s (SAHA’s) 5-Year and Annual Plans. In addition to the HCV Administrative Plan, SAHA’s HCV program is governed by federal regulations, HUD handbooks and guidebooks, notices, and other applicable law.
In 2016, HUD adopted the Housing Opportunity Through Modernization Act (HOTMA) that made changes to statutes governing HUD programs, including sections of the United States Housing Act of 1937, and improved the efficiency and effectiveness of HUD programs. This comprehensive HCV Administrative Plan update (the “Plan” attached hereto as Exhibit 1) is necessary to maintain compliance with HUD and HOTMA regulations, ensure program integrity, and preserve funding. SAHA prepared this update using a model administrative plan provided by Nan McKay & Associates (Nan McKay) that is used by many PHAs throughout the country and updates all of the Plan’s policies and language in compliance with the latest guidance and regulations from HUD. Nan McKay updates their model administrative plan every year, and the last time SAHA’s Plan was comprehensively updated using a template was on March 15, 2016.
Update to the Housing Choice Voucher Administrative Plan July 1, 2025
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Summary of Updates
The Plan incorporates regulatory changes required under HOTMA Sections 102, 104, 105, 106, and 112 for determining income, calculating deductions, and assessing eligibility. For example, the Plan introduces new requirements for calculating annual income and adjusted income, including expanded definitions of assets, new treatment of student financial assistance, and updated policies for business income and periodic payments. SAHA updated deduction amounts, such as the increased elderly/disabled family deduction, and added hardship exemptions and permissive deductions per HUD's implementation guidance.
In addition to updates for HOTMA-specific provisions, the Plan aligns SAHA policies with the most current HUD regulations, notices, and model administrative plan guidance. Entirely new sections were introduced, such as Chapter 6.B, which outlines Income and Subsidy Determinations, and Chapter 7.A, which updates verification hierarchy and methods. The Plan incorporates updated guidance from HUD’s PIH Notices 2023-27, 2024-34, and 2024-38, amongst others, including verification procedures using Form HUD-9886-A, refined rules for self-certification, and expanded use of enterprise income verification tools. Other changes ensure consistency with HUD’s new NSPIRE inspection standards, student eligibility, and the use of digital tools in briefings and application processes.
The Plan integrates new subsections, adds clarifying definitions, and improves organization for clarity and accessibility that provide greater transparency for families and landlords, ensures fair and uniform application of HUD policies, and maintains SAHA’s eligibility for federal funding.
Adopting this Plan allows SAHA to comply with federal law, implement modernized administrative practices, and better serve program participants, applicants, landlords, and the broader Santa Ana community. Failure to adopt these updates may place SAHA at risk of noncompliance, potentially impacting program funding and the City’s ability to continue administering the HCV program in accordance with federal law.
FISCAL IMPACT
There is no fiscal impact associated with this action.
EXHIBIT(S)
1. Update to HCV Administrative Plan
Submitted By: Michael L. Garcia, Executive Director, Community Development Agency Approved By: Alvaro Nuñez, City Manager