BACKGROUND (CONT'D)
Every PHA that manages an HCV program is required by HUD to maintain a written administrative plan that “establishes local policies for administration of the program in accordance with HUD requirements. The administrative plan and any revisions of the plan must be formally adopted by the PHA Board of Commissioners or other authorized PHA officials.” Normally, Board approval is required prior to implementation of any changes to the administrative plan. In order to implement the COVID-19 waivers as quickly as possible, HUD authorized PHAs to immediately adopt temporary changes to their administrative policies and procedures. While HUD allowed early implementation, they also require the Board to formally adopt the related COVID changes to HACCC’s administrative plan (Admin Plan) by July 31, 2020.
HACCC adopted many of the administrative policies and procedures permitted by the HUD waivers. Most of these changes are temporary and will expire at HUD’s direction. Currently, the majority of HUD’s waivers expire on July 31, 2020, October 31, 2020, or December 31, 2020. HUD has indicated that they will be extending some or all of their waivers, but have not yet made an official announcement regarding extensions.
Staff implemented a number of changes to HACCC’s administrative policies and procedures and staff is asking the Board to approve the continued use of these changes for as long as permitted by HUD. The following are the proposed temporary changes to HACCC’s Admin Plan (with current expiration date in parentheses):
- · Suspension of the HUD Income Verification Hierarchy (7-31-20);
- · Suspension of annual re-examination (12-31-20);
- · Suspension of the use of the Enterprise Income Verification (EIV) System (7-31-20);
- · Adoption of remote virtual initial inspections for new rental units coming on line when the owner refuses on-site access for the HCV and PBV Programs (in-home must still be completed by 10-31-20);
- · Suspension of in-home Annual HQS inspections (10-31-20);
- · Adopt use of virtual inspection formats to conduct inspections for complaint, initial, annual or re-inspection (7-31-20);
- · Suspension of Quality Control inspections (10-31-20);
- · Suspension of the Space and Security policies to permit families sheltering in place to “overcrowd” an assisted unit (either duration of lease term or 4-10-21, whichever is longer);
- · Suspension of initial inspection of homeownership units until cleared by HUD (7-31-20);
- · Suspension of changes made to the Administrative Plan (7-31-20);
- · Revised policies to conduct briefings for new participating families and families moving to new units by utilizing alternative methods like video conferencing, telephone briefings or other electronic means deemed suitable (7-31-20);
- · Suspended the requirement that families provide proof of search in order to extend the search period on their voucher (7-31-20);
- · Suspended the period within which HACCC must execute a new HAP Contract. Permits a period longer than 60 days if needed (7-31-20);
- · Suspended policies terminating a participants subsidy if absent from the unit for more than 180 days (7-31-20);
- · Suspended policies terminating HAP Contracts where the tenant receives zero subsidy for a period of six months (12-31-20);
- · Modified the Payment Standards so that families would not be affected by increases in their rent portion because their 2nd annual certification date occurred on or after the COVID-19 impact date (effective until payment standards are modified in future);
- · Suspended the Section 8 Management Assessment Program (SEMAP) submission requirements until March 31, 2021 (3-31-21);
- · Extended the period HACCC has to submit recertification data to the HUD PIC site from 60 days to 90 days after completion of the transaction in HACCC’s software system (12-31-20);
- · Suspended all required payments to repayment agreements during the COVID pandemic (TBD); and
- · Updated the Table of Contents to include a new section that outlines the temporary COVID changes being adopted.
Staff also implemented several changes to the Admin Plan in response to COVID that are intended to be permanent changes. These are policies that were never implemented by HACCC, but were previously allowed by HUD. The following are the proposed permanent COVID changes to HACCC’s Admin Plan:
- · Modified the re-inspection policy to include alternative methods such as virtual inspections, video conferencing and photo evidence to determine that repairs are completed;
- · Added additional formats for accepting documents such as jpeg, screen shots from phones, etc. so that families can conduct business with HACCC remotely; and
- · Revised the Briefing policy to include remote alternative methods for ensuring new and continuing participants of the HCV Program are properly briefed.
Finally, staff is proposing two clarifications to the Admin Plan and the addition of homeless units at the Lillie Mae Jones PBV site. The following are the proposed, non-COVID changes to HACCC’s Admin Plan:
- · Modified the Interim policy to ensure that when tenant rent portions are reduced due to a reduction in the household income, it will be increased, with proper notice, once the income is restored;
- · Clarified the requirement that program participants must report reduction in the income to zero of family members, not just for heads of households; and
- · Added 8 units at Lillie Mae Jones to the list of PBV units set aside for Homeless individuals and families. These units are filled using referrals from the County’s Coordinated Entry System.
The proposed changes to the Admin Plan are attached. A complete copy of the proposed Admin Plan is available for review at HACCC’s main office.
FISCAL IMPACT
No direct financial impact.
CONSEQUENCE OF NEGATIVE ACTION
Should the Board of Commissioners elect not to approve the changes to the Admin Plan, HACCC will be out of compliance with HUD requirements. HUD may also impose additional sanctions.
CLERK'S ADDENDUM