Ending Homelessness Through the Housing Choice Voucher and … · 2019-03-16 · o 394,379...

Ending Homelessness Through the Housing Choice Voucher and Public Housing Programs Notice PIH 2013-15 Webinar Office of Public and Indian Housing August 19, 2013

Background

Opening Doors is the nation’s Federal Strategic Plan to prevent and end homelessness. • Goals set forth in Opening Doors:

§  To end chronic homelessness and homelessness among Veterans by 2015

§  To end homelessness for families, youth and children by 2020

§  To set a path to eradicate all types of homelessness in the United States.

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●  Snapshot of the state of homelessness in the U.S.: §  On a single night in January 2012, there were 633,782 persons

experiencing homelessness in the United States. o  394,379 individuals o  77,157 family households o  62,619 veterans o  99,894 chronically homeless persons

●  PHAs are doing great work to use their existing programs to address this issue, and we’ll share some examples in this webinar.

●  Because PHA programs don’t come with specific guidance around ending homelessness, HUD has published guidance for doing so to take the guesswork out for PHAs.

●  To better recognize PHAs contributions to ending homelessness, the Notice starts with clarifications about reporting.

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Background

Homeless Notice

Notice PIH 2013-15 “Guidance on housing individuals and families experiencing

homelessness through the Public Housing and Housing Choice Voucher Programs”

Published on June 10, 2013

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Homeless Notice

The Notice focuses on five major areas: 1.  Accurately and consistently reporting to HUD homeless status

at admissions

2.  Partnering with community organizations and Continuums of Care (CoCs)

3.  Managing the waiting list to provide homeless populations increased access to the PHA’s programs

4.  Reviewing discretionary admissions and termination/eviction policies to determine if any changes can be made to remove barriers for serving the homeless population

5.  Using project-based vouchers to create permanent supportive housing

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Homeless Notice – Reporting Homelessness

The Notice reiterates existing reporting requirements.

§  Line 4C of the family report (Form HUD-50058) requires that PHAs report as to whether a family was homeless at admissions.

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•  HUD defines homelessness for reporting purposes in two categories: 1.  An individual or family who lacks a fixed, regular,

and adequate nighttime residence; 2.  Certain individuals fleeing, or attempting to flee,

domestic violence, dating violence, sexual assault, or stalking.

•  See Section 5 of the Notice for more detail.

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•  PHAs may adopt an alternative or narrower definition of homeless for purposes of a waiting list preference, but must use the definition provided in the Notice for reporting purposes.

•  Section 5 of the Notice goes in to greater detail and provides some examples that may help PHA intake coordinators or community partners assisting with the referral process.

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Homeless Notice – Partnerships

Community partners can help: §  Analyze data §  Develop targets §  Review admission policies for barriers – “Discretionary policies must be applied broadly”

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Community partners can help (continued): §  Pre-screen and refer homeless families and

individuals §  Help families collect necessary documents §  Provide housing search and support §  Facilitate the move-in process §  Ensure housing stability, including compliance with

program and family obligations and other program requirements

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PHA Example: The Houston Housing Authority (HHA) has created a new position that focuses on homeless and housing initiatives at HHA. Functions of the Program Manager for Homeless and Housing Initiatives include creating and maintaining relationships with the philanthropic and faith based communities, actively engaging in community homeless outreach efforts, and participating in the planning of community wide centralized intake, among others.

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PHA Example: HHA and its partners have established a retention committee that utilizes existing empirical research, literature and qualitative data to identify key factors that lead to homelessness recidivism, and identifies service gaps/resource gaps related to key factors of homelessness recidivism, among others.

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Homeless Notice – Waiting List Management

Sections 6 and 7 of the Notice discuss waiting list management within the context of persons experiencing homelessness and how waiting list preferences can be used to serve individuals and families experiencing homelessness.

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Homeless Notice – Waiting List Preferences

Assessing local housing needs §  A PHA’s system of local preferences must be based

on local housing needs and priorities §  Work with community partners §  Look to the Point in Time Count (PIT), Community

Plan to End Homelessness, Consolidated Plan, and other data sources

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PHA Example: The City of Philadelphia’s Consolidated Plan includes an action plan to prevent homelessness that includes among other things a homeless needs assessment. This action plan was developed in coordination with their continuum of care.

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PHA’s may apply preferences for admission to the Housing Choice Voucher (HCV), Project-based Voucher (PBV), and/or Public Housing programs. (24 CFR 960.206, 24 CFR 982, Subpart E, and 24 CFR 983.251)

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PHA’s may limit the number of applicants that may qualify for a particular preference.

§  For example: a preference in the PHA’s public housing program that 1 out of every 4 public housing admissions will go to an individual or family experiencing homelessness, or a preference in the PHA’s voucher program where every tenth voucher that becomes available upon turnover goes to a homeless family (for up to a set number of vouchers in a month or a year).

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Preferences must be included in the PHA’s policy documents (the PHA Plan, if applicable, and the HCV administrative plan for the voucher program and the ACOP for the Public Housing Program).

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Opening waiting lists and public notices §  All recipients must be selected from the PHA’s

waiting list(s) §  The notification process must comply with fair

housing requirements. §  When trying to reach people experiencing

homelessness, PHAs can consider reaching out to agencies that work closely with people experiencing homelessness.

§  See 24 CFR 982.206 and Notice PIH 2012-34 for requirements under the voucher program as it relates to opening the waiting list.

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Limiting preferences to people referred by a partnering organization.

§  PHAs may create a preference or limited preference specifically for people who are referred by a partnering homeless service organization or consortia of organizations.

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Limiting preferences to people referred by a partnering organization.

§  PHAs may not limit the source of referrals to an agency, organization, or consortia that denies its services to members of any Federally protected class under fair housing laws.

§  A PHA may also have a preference for individuals and families transitioning, or “moving up,” from Permanent Support Housing (PSH).

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PHA Example: Loudoun County Virginia Housing Authority amended its administrative plan to establish a waiting list preference for persons experiencing homelessness. As housing choice vouchers become available through turnover, every tenth (10th) voucher is made available to a person who is experiencing homelessness (up to 10 vouchers).

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Residency Preferences §  PHAs with a residency preference may consider

including shelters and other dwelling places outside the PHA’s jurisdiction where homeless people may be living or sleeping in their definition of the term “residence”.

§  PHAs may also establish policies considering the applicant’s previous residency and circumstances.

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Homeless Notice – Minimum Income Requirements

●  There is no statutory or regulatory authority that allows PHAs to establish minimum income requirements.

●  PHAs may establish a minimum rent of up to $50.

●  PHAs must grant an exemption from payment of minimum rent due to financial hardship.

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Homeless Notice –Mandatory Prohibitions for Admissions Mandatory prohibitions regarding criminal activity

and substance use: §  Lifetime Sex Offender Registrant §  Any member of the household has ever been

convicted of the production or manufacture of methamphetamine on the premises of federally assisted housing.

§  Current engagement in illegal drug use or threatening activity

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Homeless Notice –Mandatory Prohibitions for Admissions §  Eviction within the past 3 years from federally assisted

housing for drug-related criminal activity. PHA may admit if:

o  Evicted household member has completed a supervised drug rehabilitation program approved by the PHA;

o  The circumstances leading to eviction no longer exist (for

example, the criminal household member has died or is imprisoned).

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Homeless Notice –Discretionary Admissions Policies

PHAs may consider reviewing their discretionary admissions policies:

§  Are my policies too restrictive? §  How can my policies be modified to reduce or remove

barriers to serving more people experiencing homelessness?

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● Solicit feedback from community partners during the process of reviewing and modifying admissions policies.

● Any change in admissions policies must be applied broadly.

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PHA example: The Housing Authority of the City of Los Angeles modified its tenant screening and eligibility policies where appropriate and in consultation with homeless service organizations in the community to reduce barriers for people experiencing homelessness and others.

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Homeless Notice –Processes for Admission

PHAs may also consider reviewing their processes for admission to determine if they

present a barrier to serving people experiencing homelessness and others.

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Homeless Notice –Processes for Admission ● For example, PHAs may consider giving families a time window for intake appointments to account for work schedules, access to transportation, etc.; or

● PHAs may also consider offering several

locations and methods by which applicants may submit their applications.

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Homeless Notice – Mandatory Termination and Eviction Policies

There are certain instances where a PHA or owner must terminate assistance or evict a family, which include, among others:

§  Any member of the household has ever been convicted of the production or manufacture of methamphetamine on the premises of federally assisted housing.

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Homeless Notice – Mandatory Termination and Eviction Policies

●  Noncompliance with community service (public housing only).

●  If any family member fails to sign and submit consent forms for obtaining information in accordance with 24 CFR part 5, subparts B and F.

●  Discovery that a member of an assisted household who was admitted after June 25, 2001, was subject to a lifetime registered sex offender requirement.

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Homeless Notice – Discretionary Termination and Eviction Policies

● There are certain instances where a PHA or owner may terminate assistance or evict a family.

● Consider reviewing termination and eviction

policies in partnership with homeless service providers.

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Homeless Notice – Discretionary Termination and Eviction Policies

● Consider the applicability of a family’s relevant circumstances (Consideration of circumstances) when reviewing the policies.

● Discretionary policies must be applied

broadly.

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Homeless Notice – Program Termination and Eviction Policies

● See 24 CFR 966.4 for PH and 24 CFR 982.552 and 982.553 for the voucher program, and Notice PIH 2012-28 “State Registered Lifetime Sex Offenders in Federally Assisted Housing” for more details.

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Homeless Notice – Section 8 Project-Based Vouchers

●  Under the HCV program, PHAs are allowed to project-base up to 20% of their budget authority.

●  Long-term commitment provided by the PBV contract helps to finance project operating costs and secure capital investments.

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●  Project-based vouchers can be used to pair housing with services.

●  PHAs generally cannot use PBV assistance for more than 25% of the number of dwelling units (assisted or unassisted) in a project.

●  This 25% cap does not apply if units in a project are available to the elderly, families with disabilities, or families receiving supportive services. In such cases, a PHA may use PBV assistance in up to 100% of the units in the project.

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•  PHAs select PBV proposals in accordance

with the selection procedures established by the PHA in their administrative plan.

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There are two methods by which PHAs must select PBV proposals:

1.  PHA request for PBV proposals. 2.  Units were selected under a similar federal,

state or local competition within three years from the PHA’s selection date of the units for PBV assistance and the earlier competition did not involve any consideration for PBV assistance as stated in 24 CFR 983.51(b).

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Family selection: §  Selection from PHA’s waiting list is statutorily

required. §  Must select in accordance with PHA’s selection

policies in PHA’s administrative plan. §  Owner referrals must be placed on and selected

from PHA’s waiting list.

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PBV waiting list: §  PHAs may establish a waiting list separate from its

HCV waiting list, or may use the same waiting list for both tenant-based and PBV assistance.

§  PHAs may establish project or building (or set of buildings) specific waiting list.

§  The PHA may also adopt a different set of admissions preferences for each separate waiting list.

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●  A PHA that wishes to partner with a homeless service provider to project-base vouchers may consider creating a separate waiting list for the project and adopting a preference limited to people referred by the partnering organization. §  Please note that PHAs may not limit the source of referrals to

an agency, organization, or consortia that denies its services to members of any Federally protected class under fair housing laws.

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●  PHAs may also adopt a preference for services offered for families with disabilities that need services at a particular project.

●  Such a preference is limited to those individuals and families with disabilities that significantly interfere with their ability to obtain and maintain themselves in housing; who without appropriate supportive services, will not be able to obtain or maintain themselves in housing; and for whom such services cannot be provided in a non-segregated setting. See 24 CFR 983.251(d).

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PHA Example: HHA will be adding units of permanent housing for the homeless by using PBV at new, rehabilitated or existing developments that provide supportive services and comply with program requirements and federal Housing Quality Standards. Developers who are serving those experiencing chronic homelessness were awarded additional points under HHA’s scoring system for PBV proposals.

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•  PBV regulations: 24 Code of Federal Regulations (CFR) Part 983

•  HUD Notice PIH 2011-54 “Guidance on the Project Based Voucher Program”

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Questions

Email [email protected]

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Ending Homelessness Through the Housing Choice Voucher and … · 2019-03-16 · o 394,379...

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