Agenda

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D.3

To:	Contra Costa County Housing Authority Board of Commissioners
From:	Joseph Villarreal, Housing Authority
Date:	July 14, 2020

Contra

Costa

County

Subject:

PUBLIC HOUSING ADMISSIONS and CONTINUED OCCUPANCY POLICY PLAN AMENDMENTS IN RESPONSE TO HUD’S COVID-19 STATUTORY AND REGULATORY WAIVERS

Action of Board On: 07/14/2020

APPROVED AS RECOMMENDED

OTHER

Clerks Notes:

VOTE OF SUPERVISORS

AYE:

John Gioia, Commissioner
Candace Andersen, Commissioner
Diane Burgis, Commissioner
Karen Mitchoff, Commissioner
Federal D. Glover, Commissioner

Contact:

9259578028

I hereby certify that this is a true and correct copy of an action taken and entered on the minutes of the Board of Supervisors on the date shown.
ATTESTED: July 14, 2020
,

BY:	, Deputy

RECOMMENDATIONS

APPROVE amendments to the Housing Authority’s (HACCC) Admissions and Continued Occupancy Policy in response to HUD’S COVID-19 Statutory and Regulatory Waivers.

BACKGROUND

On April 10, 2020, as part of its response to the COVID-19 pandemic, the U.S. Department of Housing and Urban Development (HUD) waived many of its existing statutory and regulatory requirements for the Public Housing and Housing Choice Voucher (HCV) programs, while establishing alternative methods to continue program operations. HUD’s waivers were designed to “provide administrative flexibilities and relief to public housing agencies (PHAs)” and “HUD strongly encourages PHAs to utilize any and all waivers and alternative requirements as necessary to keep public housing and HCV programs operational to the extent practicable.”

BACKGROUND (CONT'D)

Every PHA that manages a public housing program is required by HUD to maintain a written Admissions and Continued Occupancy Policy (ACOP) that establishes local policies for administration of the program in accordance with HUD requirements. The ACOP, and any revisions, 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 ACOP. In order to implement the COVID-19 waivers as quickly as possible, HUD authorized PHAs to immediately adopt temporary changes to their ACOPs.

While HUD allowed early implementation, they also require the Board to formally adopt the related COVID changes to HACCC’s ACOP 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 ACOP 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 ACOP (with current expiration date in parentheses):

· Delay annual family income and composition examinations (12-31-20);
· Suspend of the HUD Income Verification Hierarchy for Annual Examinations (7-31-20);
· Suspend of the HUD Income Verification Hierarchy for Interim Examinations (7-31-20);
· Suspend Enterprise Income Verification (EIV) report monitoring (7-31-20);
· Suspend the of the Community Service Requirement (3-31-21);
· Allow over-Income families to continue at their existing rent level until the family’s first annual examination after the COVID waivers are lifted (12-31-20)
· Send notification to families within 30 days of making any changes to policies and rules in response to COVID-19instead of providing impacted families with a 30-day notice prior to implementing the changes. (7-31-20)
· HACCC will not ask HUD for new Public Housing Assessment System (PHAS) scores in 2020. The existing PHAS scores will carry over until March 31, 2021 (3-31-21);
· Extend the period in which HACCC is required to submit recertification data into HUD’s PIC system from 60 days to 90 days after the effective date of any changes (12-31-20); and
· Suspend a household’s repayment agreement in the event of hardship (12-31-20).

Staff also implemented several changes in response to COVID that are intended to be permanent. These are policies that were never implemented by HACCC, but were previously allowed by HUD. The following are the proposed permanent changes to HACCC’s public housing policies and procedures:

· HACCC will utilize alternative methods, as needed, to conduct applicant interviews and to collect and/or provide other information to families moving into units. These include video conferencing, telephone briefings and any other electronic means deemed suitable; and
· Added additional formats for accepting documents such as jpeg, screen shots from phones, etc. so that families can conduct business with HACCC remotely.

Finally, HACCC staff took the following action:

Suspended all eviction proceedings during the COVID pandemic (July 24, 2020).

The proposed updates are attached. A complete copy of the proposed ACOP is available for review at HACCC’s main office.

FISCAL IMPACT

No direct financial impact.

CONSEQUENCE OF NEGATIVE ACTION