Public Housing Agency (PHA) Annual Plan and Certification of Consistency 2019 Copyrighted
April 1 , 2019
City of Dubuque Consent Items # 8.
ITEM TITLE: Annual Public HousingAgency(PHA) Plan
SUMMARY: City Manager recommending approval of the submission of
the Annual Public Housing Agency Plan along with the
Certification of Consistencywith the Consolidated Plan to
the U.S. Department of Housing and Urban Development.
RESOLUTION Authorizing the Mayor to execute the
Certification by State or Local Office of Public Housing
Agency(PHA) Plan's Consistencywith the Consolidated
Plan and Approval of the PHAAnnual Plan
SUGGESTED DISPOSITION: Suggested Disposition: Receiveand File;Adopt
Resolution(s)
ATTACHMENTS:
Description Type
Public Housing Agency Plan-MVM Memo City Manager Memo
Staff Memo Staff Memo
Public Housing Agency Annual Plan - Final Supporting Documentation
Resolution Resolutions
HUD 50077 - Chair Supporting Documentation
HUD 50077 - H & CD Director Supporting Documentation
HUD 50077 - Mayor Supporting Documentation
THE CITY OF Dubuque
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Masterpiece on the Mississippi Z°°'�w'2
7A13 2017
TO: The Honorable Mayor and City Council Members
FROM: Michael C. Van Milligen, City Manager
SUBJECT: Submission of Annual Public Housing Agency (PHA) Plan
DATE: March 25, 2019
Housing & Community Development Department Director Alexis Steger is
recommending approval of the submission of the Annual Public Housing Agency Plan
along with the Certification of Consistency with the Consolidated Plan to the U.S.
Department of Housing and Urban Development.
I concur with the recommendation and respectfully request Mayor and City Council
approval.
�L;� 1��, ����.�
Mic ael C. Van Milligen �� �
MCVM:jh
Attachment
cc: Crenna Brumwell, City Attorney
Teri Goodmann, Assistant City Manager
Cori Burbach, Assistant City Manager
Alexis Steger, Housing & Community Development Director
Dubuque
THE CITY OF
U� � All-America City
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Masterpiece on the Mississippi �
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TO: Michael C Van Milligen, City Manager
FROM: Alexis Steger, Housing & Community Development Director
DATE: March 21, 2019
RE: Submission of Annual Public Housing Agency (PHA) Plan
INTRODUCTION
Each year the City of Dubuque is required to submit a PHA (Public Housing Agency)
Plan. The PHA Plan is a comprehensive guide to the policies, programs, operations
and strategies for meeting local housing needs and goals. There are two parts to the
PHA Plan: the 5-Year Plan which was submitted fiscal year 2015 and the Annual Plan,
which is submitted this year. Part of the submission includes the Certification by State
or Local Office of PHA Consistency with the Consolidated Plan (HUD-50077 Form).
The submission is also required as part of the Voluntary Compliance Agreement (VCA)
with the U.S. Department of Housing and Urban Development (HUD).
BACKGROUND
The PHA Plan and Certifications follow HUD approved templates and must be
submitted accordingly. Any local, regional or State agency that receives funds to
operate Federal Section 8 Housing Choice Voucher programs must submit a PHA Plan.
To ensure public participation in the process, PHA Plans must be available for
inspection by the public both during the public review period prior to the board hearing
and submission to HUD. Public Notice was published 45 days in advance of being
approved by the Housing Commission. The Housing Commission votes to approve the
PHA Plan on Tuesday, March 26, 20198. The PHA Resident Advisory Board has also
reviewed the PHA Plan and all comments and minutes from their meeting is included in
the plan.
RECOMMENDATION
We are requesting approval to submit the Annual PHA Plan along with the Certification
for Consistency with the Consolidated Plan.
PUBLIC N01'ICE
The City of Dubuque Housing antl Community Developmst Depvtmst has published a Frst NaR of[he Public
Housing Agency Annual Plan for Fscal year 2019_ The Plan is a ailable for review at[he Housing ffi CD
Depvtmsq 350 West 6'h StreeG Sui[e 312� Dubuque�IA 5?AOl Montlay—Fntlay, 8 00 AM-5 00 PM antl at
urvwo_cityoftlubuquaorg/atlminplart
A public hearing on[he Plan will be heltl at[he Housing Commission Meeting on Tuestlay, March?b, ?A19, at
4 00 p m_ in[he Housing ffi CD Depvtmst o�ca In[eresGd pasons are mviGd W appear anNor pmvitle
comrt�st W[he Comrt�ission on[he proposed Plaa
Atltlitional infortnation may be obfained by calling Me Housing ffi CD Depvtmst at 563-589-4230_
�
Paee 1 of 60
RESOLUTION NO. 109-19
RESOLUTION AUTHORIZING THE MAYOR TO EXECUTE THE CERTIFICATION BY
STATE OR LOCAL OFFICE OF PUBLIC HOUSING AGENCY (PHA) PLAN'S
CONSISTENCY WITH THE CONSOLIDATED PLAN AND APPROVAL OF THE PHA
ANNUAL PLAN
Whereas, the U.S. Department of Housing and Urban Development requires
submission of the Public Housing Agency (PHA) Plan on an annual basis; and
Whereas, the U.S. Department of Housing and Urban Development requires
Certification of the PHA Plan's Consistency with the Consolidated Plan;
NOW, THEREFORE BE IT RESOLVED BY THE CITY COUNCIL OF THE CITY OF
DUBUQUE IOWA:
Section 1: That the Mayor is hereby authorized and directed to certify the PHA Plan's
Consistency with the Consolidated Plan; and
Section 2: That the Director of Housing and Community Development is hereby
authorized to submit the PHA Plan and the Certification as required by the U.S.
Department of Housing and Urban Development.
Passed, approved and adopted this 1St day of April, 2019.
Attest:
Kevin's. Firnstah City G�lerk
c
Roy D Buol, Mayor
Annual PHA Plan U.S.Department of Housing and Urban Development OMB No.2577-0226
Office of Public and Indian Housing Expires: 02/29/2016
(Standard PHAs and
Troubled PHAs)
Purpose. The 5-Year and Mnual PHA Plans provide a ready source for interested parties to locate basic PHA policies,rules,and requiremen[s conceming[he PHA's
operations,programs,and services,and informs HUD,families served by[he PHA,and members of[he public of[he PHA's missioq goals and objectives for serving[he
needs of low-income,very low-income,and exVemely low-income families.
Applicability. Fortn HUD-50075-ST is W be completed annually by STANDARD PHAs or TROUBLED PHAs. PHAs that meet the defirution of a
High Performer PHA, Small PHA,HCV-Only PHA or Qualified PHA do not need to submit this form.
Definidons.
�1� High-PerforneerPHA—A PHA that owns or manages more than 550 combined public housing units and housing choice vouchers,and was designated as a
high perfortner on both of the most recent Public Housing Assessment System(PHAS)and Section Eight Management Assesgnent Program(SEMAP)
assessmen[s if adminis[ering both programs,or PHAS if only administering public housing.
�2� Sma71 PHA-A PHA that is not designated as PHAS or SEMAP troubled,or at risk of being designated as troubled,that owns or manages less than 250 public
housing units and any number of vouchers where[he total combined units exceeds 550.
�3� Hou.vng Choice Voucher(fICVj On1y PHA-A PHA that administers more than 550 HCVs,was not designated as troubled in its most recent SEMAP
assessment and does not own or manage public housing.
�4� Standa�dPHA-A PHA that owns or manages 250 or more public housing units and any number of vouchers where the Wtal combined units exceeds SSQ
andthatwas designated as a standardperfortner in the mostrecentPHAS or SEMAP assesgnents.
�5� TroubledPHA-A PHA that achieves an overall PHAS or SEMAP score of less than 60 percent.
�6� QualifiedPHA-A PHA with 550 or fewer public housing dwelling units and/or housing choice vouchers combined,and is not PHAS or SEMAP troubled.
A. PHA Information.
A1 PHA Name: Citv of Dubuque PHA Code: IA087
PHA Type: �Standard PHA ❑Troubled PHA
PHA Plan for NSscal Year Beginning: (MM/YYPI�: 07/2019
PHA Inventory(Based on Mnual Contributions Contract(ACC)units at time of FY beginning,above)
Number of Public Housing(PI-I)Units 0 Number of Housing Choice Vouchers(HCVs) 1072 Total Combined
Units/Vouchers 1072
PHA Plan Submission Type: �Mnual Submission ❑Revised Mnual Submission
Availability of Informatioa PHAs must have the elements listed below in sections B and C readily available W the public. A PHA must identify
the specific location(s)where the proposed PHA Plan,PHA Plan Elements,and all information relevant to the public hearing and proposed PHA
Plan are available for inspection by the public. At a minimum,PHAs mustpost PHA Plans,including updates,at each Asset Management Project
(AMP)and main office or central office of the PHA. PHAs are strongly encouraged to post complete PHA Plans on their official website. PHAs
are also encouraged to provide each resident council a copy of[heir PHA Plans.
❑PHA Consortia: (Check box if submittin a Joint PHA Plan and com lete table below)
Participating PHAs PHA Code Program(s)in the Consortia Program(s)not in the No.of Units in Each Program
Consortia pH HCV
Lead PHA:
Page 2 of 60
B. Annual Plan Elements
B1 Revision of PHA Plan Elements.
(a) Have the following PHA Plan elements been revised by the PHA7
Y N
� ❑ Statement of Housing Needs and SVategy for Addressing Housing Needs
� ❑ Deconcentration and Other Policies that Govem Eligibility,Selectioq and Admissions.
� ❑ FinancialResources.
❑ � RentDetermination.
❑ � Operation and Management.
❑ � Grievance Procedures.
❑ � Homeownership Programs.
❑ � Community Service and Self-Sufficiency Programs.
❑ � Safety and Crime Prevention.
❑ � PetPolicy.
❑ � AssetManagement.
❑ � SubstantialDeviation.
❑ � SignificantAmendmenUModification
(b) If the PHA answered yes for any element,describe the revisions for each revised element(s): See B.1 below
(c) ThePHAmustsubmititsDeconcentrationPolicyforFieldOfficereview.SeeB1(c)below
B2 New Activities.
(a) Does the PHA intend to undertake any new activities related to the following in the PHA's cmrent Fiscal Year7
Y N
❑ � Hope VI or Choice Neighborhoods.
❑ � Mixed Finance Modernization or Development.
❑ � Demolition and/or Disposition.
❑ � Designated Housing for Elderly and/or Disabled Families.
❑ � Conversion of Public Housing to Tenant-Based Assis[ance.
❑ � Conversion of Public Housing to Project-Based Assis[ance under RAD.
❑ � OccupancybyOver-IncomeFamilies.
❑ � OccupancybyPoliceOfficers.
❑ � Non-Smoking Policies.
❑ � Project-Based Vouchers.
❑ � Units with Approved Vacancies for Modernization.
❑ � Other Capital Grant Programs(i.e.,Capital Fund Community Facilities Grants or Emergency Safety and Security Grants).
(b)If any of these activities are planned for the cmrent Fiscal Year,describe the activities. For new demolition activities,describe any public
housing development or portion[hereof,owned by[he PHA for which[he PHA has applied or will apply for demolition and/or disposition approval
under section 18 ofthe 1937 Actunder the separate demolition/disposition approval process.Ifusing Project-Based Vouchers(PBVs),provide the
projected number of project based units and general locations,and describe how project basing would be consistent with the PHA Plan.
B.3 Civil Rights Certification.
Fortn HUD-50077,PHA Cerfificotions of Complionce with the PHA Plons ond Reloted Regulotions,mustbe submitted by the PHA as an electronic
attachment W the PHA Plan. See Attached document
B.4 Most Recent Fiscal Year Audit.
(a) Were there anyfindings in the mostrecentFY Audit7
Y N
❑ �
(b) If yes,please describe:
Page 3 of 60
B.5 ProgressReport
Provide a description of[he PHA's progress in meeting its Mission and Goals described in[he PHA 5-Year and Mnual Plan.
B.6 ResidentAdvisory Board(RAB)Comments.
(a) Did the RAB(s)provide comments W the PHA PIan7
Y N
� ❑
(c) If yes,comments mustbe submitted by the PHA as an attachment to the PHA Plan. PHAs must also include a na�rative describing their
analysis of[he RAB recommendations and[he decisions made on[hese recommendations.
B�� Certification by State or Local Officials.
Fortn HUD 50077-SL CeHificotion by Stote or Locol O,%ficiols of PHA Plons Consistency with the Consolidoted Plon,must be submitted by the
PHA as an electronic attachmentto the PHA Plan.
B.8 Troubled PHA.
(a) Does the PHA have any cmrent Memorandum of Agreement,Perfortnance Improvement Plan,or Recovery Plan in place7
Y N N/A
❑ � ❑
(b) If yes,please describe:
C. Statement of Capital Improvements. Required for all PHAs completing this form that administer public housing
and receive funding from the Capital Fund Program (CFP).
C1 Capital Improvements.Include a reference here W the most recent HUD-approved 5-Year Action Plan(HUD-500752)and the date that itwas
approved by HUD.
Page 4 of 60
Instructions for Preparation of Form HUD-50075-ST
Annual PHA Plan for Standard and Troubled PHAs
A. PHA Informatioa All PHAs must complete this section.
A1 Include the full PHA Name,PHA Code,PHA Type,PHA Fiscal Year Beginning(MM/YYPI�,PHA Inventory,Number of Public Housing Units and or
Housing Choice Vouchers(HCVs),PHA Plan Submission Type,and the Availability of Informatioq specific location(s)of all infortnation relevant W the
public hearing and proposed PHA Plan.(7A CFR&90323(4)(ep
PHA Consortia:Check box if submitting a Joint PHA Plan and complete the table.(7A CFR&943.128(a))
B. Annual Plaa All PHAs must complete this section.
B1 Revision of PHA Plan Elements.PHAs must
Identify specifically which plan elements listed below thathave been revised by the PHA.To specify which elements have been revised,mark the"yes"box.If
an element has notbeen revised,mark"no."(7A CFR&903.7)
� Statement of Housing Needs and Strate�y for Addressing Housing Needs. Provide a statement addressing the housing needs of low-income,very low-
income and exVemely low-income families and a brief description of[he PHA's sVategy for addressing[he housing needs of families who reside in[he
jurisdiction served by the PHA.The statement must identify the housing needs of(i)families with incomes below 30 percent of area median income(extremely
low-income),(ii)elderly families and families with disabilities,and(iii)households of various races and ethnic groups residing in thejurisdiction or on the
waiting list based on infortnation provided by the applicable Consolidated Plan,information provided by HUD,and other generally available data. The
identification of housing needs must address issues of affordability,supply,quality,accessibility,size of units,and locatioa(7A CFR&903J(a)(1)) Provide a
description of[he PHA's s[rategy for addressing[he housing needs of families in[he jurisdiction and on[he waiting list in[he upcoming year. 24 CFR
&903J(a)(2)(ii))
� Deconcentration and Other Policies that Govern Eligibility,Selection,and Admissions. PHAs must submit a Deconcentration Policy for Field Office
review. For additional guidance on what a PHA must do to deconcentrate poverty in its development and comply with fair housing requirements,see 7A CFR
9032.(7A CFR&90323(bl)Describe the PHA's admissions policy for deconcentration ofpoverty and income mixing of loweo-income families in public
housing. The DeconcenVation Policy must describe[he PHA's policy for bringing higher income tenan[s into lower income developmen[s and lower income
tenants inW higher income developments. The deconcentration requirements apply W general occupancy and family public housing developments. Refer to 24
CFR§9032(b)(2)for developments not subject W deconcentration of poverty and income mixing requirements. (7A CFR&903 J(bN Describe the PHA's
procedures for maintain waiting lists for admission to public housing and address any site-based waiting lists(7A CFR&903 J(bN.A statement of the PHA's
policies that govern resident or tenant eligibility,selection and admission including admission preferences for both public housing and HCV. 7A CFR
903J Describe the unit assignment policies for public housing. (7A CFR&903J(bl)
� NSnancial Resources. A statement of financial resources,including a listing by general categories,of the PHA's anticipated resources,such as PHA
operating,capital and other anticipated Federal resources available W the PHA,as well as tenant rents and other income available W support public housing or
tenant-based assistance. The statement also should include the non-Federal sources of funds supporting each Federal program,and state the planned use for the
resources(7A CFR&903J(cN
❑ Rent Determinatioa A statement of the policies of the PHA goveming rents charged for public housing and HCV dwelling units,including applicable
public housing flat rents,minimum rents,voucher family rent contributions,and pa}anent standard policies(7A CFR&903 J(dN
❑ Operation and Management A statement of the rules,standards,and policies of the PHA goveming maintenance and management of housing owned,
assisted,or operated by the public housing agency(which shall include measures necessary for the prevention or eradication of pest infestatioq including
cocla�oaches),and management of the PHA and programs of the PHA(24 CFR&903 J(e))
❑ Grievance Procedures. A description of the grievance and infortnal hearing and review procedures that the PHA makes available to its residents and
applicants.(24 CFR&903J(fl)
❑ Homeownership Programs. A description of any Section Sh,Section 32,Section 8y,or HOPE I public housing or Housing Choice Voucher(HC�
homeownership programs(including project number and unit count)administered by[he agency or for which[he PHA has applied or will apply for approvaL 24
CFR&903J(k))
❑ Community Service and Self Sufficiency Programs. Describe how the PHAwill comply with the requirements of community service and treatrnent of
income changes resulting from welfare program requirements (7A CFR&903J(D)A description of: 1)My programs relating W services and amenities
provided or offered to assisted families;and 2)My policies or programs of[he PHA for[he enhancement of[he economic and social self-sufficiency of assis[ed
families,including programs under Section 3 and FSS (7A CFR&903J(D)
❑ Safety and Crime Preventioa Describe the PHA's plan for safety and crime prevention W ensure the safety of the public housing residents. The statement
mustprovidedevelopmenbby-developmentorjurisdictionwide-basis: (i)AdescriptionoftheneedformeasuresWensurethesafetyofpublichousingresidents;
(ii)A description of any crime prevention activities conducted or W be conducted by the PHA;and(iii)A description of the coordination between the PHA and
the appropriate police precincts for ca�rying out crime prevention measures and activities.(7A CFR&903J(m)) A description of: 1)My activities,services,or
programs provided or offered by an agency,either directly or in partnership with other service providers,W child or adult victims of domestic violence,dating
violence,sexual assault,or stalking;2)My activities,services,or programs provided or offered by a PHA that helps child and adultvictims of domestic
violence,dating violence,sexual assault,or stalking,to obtain or maintain housing;and 3)My activities,services,or programs provided or offered by a public
Page 5 of 60
housing agency W prevent domestic violence,dating violence,sexual assault,and stalking,or W enhance victim safety in assisted families. 7A CFR
&903J(m)(SN
❑ Pet Policy. Describe the PHA's policies and requirements pertaining to the ownership of pets in public housing.(24 CFR&903J(nl)
❑ Asset Management State how the agency will ca�ry out its asset management functions with respect W the public housing invenWry of the agency,
including how the agencywill plan for the longterm operating,capital investment,rehabilitatioq modemizatioq dispositioq and other needs for such invenWry.
(7A CFR&903J(q))
❑ Substantial Deviatioa PHA mustprovide its criteria for determining a"substantial deviation"to its 5-Year Plan. (7A CFR&903J(rl(21(il)
❑ Significant Amendment/Modificatioa PHA must provide its criteria for detertnining a"Significant Amendment or Modification"to its 5-Year and Mnual
Plan. Should the PHA fail to define`significant amendmenUmodification',HUD will consider the following to be`significant amendments or modifications': a)
changes W rent or admissions policies or organization of the waiting list;b)additions of non-emergency CFP work items(items not included in the cwrent CFP
Mnual Statement or CFP 5-Year Action Plan)or change in use of replacement reserve funds under the Capital Fund;or c)any change with regard W demolition
or dispositioq designatioq homeownership programs or conversion activities. See guidance on HUD's website at:Notice PIH 1999-51. 7A CFR
&903J(rl(21(iiN
If any boxes are marked"yes",describe the revision(s)to those element(s)in the space provided.
B2 New Activities. If the PHA intends W undertake any new activities related W these elements in the cmrent Fiscal Year,mark"yes"for those elements,and
describe the activities W be undertaken in the space provided.If the PHA does not plan W undertake these activities,mark"no"
❑ Hope VI or Choice Neighborhoods. 1)A description of any housing(including projectnumber(iflmown)and unit count)for which the PHA will apply
for HOPE VI or Choice Neighborhoods;and 2)A timetable for the submission of applications or proposals. The application and approval process for Hope VI
or Choice Neighborhoods is a separate process.See guidance on HUD's website at ht[p://www.hud.eov/offices/pih/proerams/ph/hope6/index.cfrn. (Notice PIE3
2010-30
❑ Mixed NSnance Modernization or Development. 1)A description of any housing(including projectnumber(if Imown)and unit count)for which the PHA
will apply for Mixed Finance Modemization or Development;and2)A timetable for the submission of applications or proposals. The application and approval
process for Mixed Finance Modemization or Development is a separate process.See guidance on HUD's website at
http://www.hud.eov/offices�pih/proerams�ph/hope6/index.cfrn. (Notice PIH 2O1030)
❑ Demolition and/or Dispositioa Describe any public housing projects owned by the PHA and subject W ACCs(including project number and unit numbers
[or addresses]),and the number of affected units along with their sizes and accessibility features)for which the PHAwill apply or is cmrently pending for
demolition or dispositioq and(2)A timetable for the demolition or disposition. This statement must be submitted W the extent that approved and/or pending
demolition and/or disposition has changed as described in[he PHA's last Mnual and/or 5-Year PHA Plan submission. The application and approval process for
demolition and/or disposition is a separate process. See guidance on HUD's website at http://www.hud.eov/offices/pih/centers�sac/demo dispo/index.cfrn. 7A
CFR&903J(h)1
❑ Designated Housing for Elderly and Disabled Families.Describe any public housing projects owned,assisted or operated by the PHA(or portions
thereo�,in the upcoming fiscal year,that the PHA has continually operated as,has designated,or will apply for designation for occupancy by elderly and/or
disabled families only. Include the following information: 1)development name and number;2)designation t}pe;3)application status;4)date the designation
was approved,submitted,or planned for submissioq and;5)the number of units affected. Note: The application and approval process for such designations is
separate from the PHA Plan process,and PHA Plan approval does not constitute HUD approval of any designatioa(7A CFR&903J(i)(C))
❑ Conversion of Public Housing. Describe any public housing building(s)(including project number and unit count)owned by the PHA that the PHA is
required to convert or plans W voluntarily convert W tenant-based assistance;2)M analysis of the projects or buildings required W be converted;and 3)A
s[atement of[he amount of assistance received to be used for rental assis[ance or other housing assistance in connection with such conversion. See guidance on
HUD'swebsiteathttp://www.hud.eov/offices�pih/centers�sac/conversion.cfrn. (24CFR&903J(il)
❑ Conversion of Public Housing. Describe any public housing building(s)(including project number and unit count)owned by the PHA that the PHA plans
W voluntarily convert W projecbbased assistance under RAD. See additional guidance on HUD's website at:Notice PIH 2O1232
❑ Occupancy by Over-Income Families. A PHA that owns or operates fewer than[wo hundred fifty(250)public housing units,may lease a unit in a public
housing development W an over-income family(a family whose annual income exceeds the limit for a low income family at the time of initial occupancy),if all
the following conditions are satisfied: (1)There are no eligible low income families on the PHA waiting list or applying for public housing assistance when the
unit is leased to an oveo-income family;(2)The PHA has publicized availability of the unit for rental to eligible low income families,including publishing public
notice of such availability in a newspaper of general circulation in the jurisdiction at least thir[y days before offering the unitto an oveo-income family,(3)The
over-income family rents the unit on a month-to-month basis for a rentthat is not less than the PHA's cost W operate the unit;(4)The lease W the oveo-income
family provides thatthe family agrees W vacate the unitwhen needed for rental W an eligible family;and(5)The PHA gives the oveo-income family at least
thirty days notice W vacate the unitwhen the unit is needed for rental W an eligible family. The PHA may incorporate infortnation on occupancy by oveo-income
families into its PHA Plan statement of deconcentration and other policies that govem eligibility,selectioq and admissions. See additional guidance on HUD's
website at: Notice PIH 2O11-Z(7A CFR 960.503) (7A CFR 903J(b))
❑ Occupancy by Police Officers. The PHA may allow police officers who would not otherwise be eligible for occupancy in public housing,to reside in a
public housing dwelling uniL The PHA mus[include[he number and location of[he units to be occupied by police officers,and[he tertns and conditions of[heir
tenancies;and a statement that such occupancy is needed to increase security for public housing residents. A"police office2'means a person detertnined by the
PHA to be,during[he period of residence of[hat person in public housing,employed on a ful4time basis as a duly licensed professional police officer by a
Federal,State or local govemment or by any agency of[hese govemmen[s. M officer of an accredited police force of a housing agency may qualify. The PHA
may incoiporate information on occupancy by police officers into its PHA Plan statement of deconcentration and other policies that govern eligibility,selectioq
and admissions. See additional guidance on HUD's website at: Notice PIH 2O11-Z(7A CFR 960.505)(7A CFR 903J(b))
Page 6 of 60
❑ Noo-Smoldng Policies.The PHA may implement non-smoking policies in its public housing program and incoiporate this inW its PHA Plan statement of
operation and management and the mles and standards thatwill apply W its projects. See additional guidance on HUD's website at:Notice PIE3 2009-21. 7A
CFR&903J(eN
❑ Project-Based Vouchers. Describe anyplans W use Housing Choice Vouchers(HCVs)for new projecbbased vouchers,which must complywith PBV
goals,civil rights requirements,Housing Quality Standards(HQS)and deconcentration standards,as stated in 983.57(b)(1)and set forth in the PHA Plan
statement of deconcentration and other policies that govern eligibility,selectioq and admissions. If using projecUbased vouchers,provide the projected number
of projecbbased units and general locations,and describe how project-basing would be consistentwith the PHA Plan. (7A CFR&903J(bl)
❑ Units with Approved Vacancies for Modernizatioa The PHA must include a statementrelated to units with approved vacancies that are undergoing
modemization in accordance with 7A CFR&990.145(a)(1).
❑ Other Capital GrantPrograms(i.e.,Capital Fund Community Facilities Grants or Emergency Safety and Security Grants).
For all activities that the PHA plans W undertake in the cwrent Fiscal Year,provide a description of the activity in the space provided.
B.3 Civil Rights Certificatioa Fortn HUD-50077,PHA CeHificotions of Complionce with the PHA Plons ond Reloted Regulotion,must be submitted by the PHA
as an electronic attachment W the PHA Plan. This includes all certifications relating W Civil Rights and related regulations. A PHA will be considered in
compliance with the AFFH Certification if:it can document that it examines its programs and proposed programs to identify any impediments W fair housing
choice within those programs;addresses those impediments in a reasonable fashion in view of the resources available;works with the localjurisdiction W
implement any of the jurisdiction's initiatives W affirtnatively further fair housing;and assures that the annual plan is consistent with any applicable
Consolidated Plan for itsjurisdictioa(24 CFR&903J(o))
B.4 Most Recent NSscal Year Audit If the results of the most recent fiscal year audit for the PHA included any findings,mark"yes"and describe those findings in
the space provided. (24 CFR&903J(p))
B.5 Progress Report. For all Mnual Plans following submission of the first Mnual Plan,a PHA must include a brief statement of the PHA's progress in meeting
the mission and goals described in the 5-Year PHA Plan.(7A CFR&903J(d(1))
B.6 Resident Advisory Board(RAB)comments.If the RAB provided comments to the annual plan,mark"yes,"submit the comments as an attachment W the Plan
and describe the analysis of the comments and the PHA's decision made on these recommendations(7A CFR&903.13(c),7A CFR&903.19)
B9 Certification by State of Local Officials. Fortn HUD-50077-SL,CeHificotion by Stote or Locol O,%ficiols of PHA Plons Consistency with the Consolidoted
Plon,must be submitted by the PHA as an electronic attachment W the PHA Plan.(7A CFR&903.15). Note: A PHA may request to change its fiscal year to
better coordinate its planning with planning done under the Consolidated Plan process by State or local officials as applicable.
B.8 Troubled PHA. If the PHA is designated troubled,and has a cwrent MOA,improvement plan,or recovery plan in place,mark"yes,"and describe that plan.If
the PHA is troubled,but does nothave any of these items,mark"no"If the PHA is not troubled,mark"N/A."(7A CFR&903.9)
C. Statement of Capital Improvements.PHAs that receive funding from the Capital Fund Program(CFP)must complete this section.(7A CFR 903J(e))
C1 Capital Improvements. In order W comply with this requirement,the PHA must reference the most recent HUD approved Capital Fund 5 Year Action Plan.
PHAs can reference the fonn by including the following language in Section C.8.0 of the PHA Plan Template:"See HUD Fonn-500752 approved by HUD
on XX/XX/XXXX"
This
information rollection is authorized by Se¢ion 511 of the Qualiry Housing and Work Responsibility Act,which added a new se¢ion SA m the II.S.Housing Act of 1937,as amended,which
introdured the 5-Year and Annual PHA Plan.
Public reporting burden forthis information rollection is estimated m average 9.2 hours per response,induding the time for reviewing instmctions,searching eYisting data sourres,
gathering and maintaining the data needed,and completing and reviewing the rollection of information. HII�may not rollectthis information,and respondents are not required m
completethis form,unless it displays a currentlyvalid OMB Control Number.
PrivacyActNotice. Thellnited5tates�epartmentofHousingandllrban�evelopmentisauthorizedmsoliuttheinformationrequestedinthisformbyvirtueofTitlel2,II.5.Code,
Se¢ion1701etseq,andregulationspromulgatedthereunderatTitlel2,CodeofFederalRegulations. Responsesmtherollectionofinformationarerequiredmobtainabenefitorm
retain a benefit The information requested does not lend itself m confidentiality.
Page 7 of 60
B.
Annual Plan Elements
B.1.
(b) If the PHA answered yes for any element, describe the revisions for each revised element(s):
Statement of Housing Needs and Strategy for Addressing Housing Needs:
Needs Assessment Overview(Consolidated Plan)
The City of Dubuque worked with John Marshall Law School and Cappell Statistical Consulting in theconsolidated
planning process to determine the varying needs within the City for affordable housing,community development and
homelessness.The 2015 Analysis of Impediments to Fair Housing identifies needs and actions the City uses to
Affirmatively Further Fair Housing.The City of Dubuque Five-year Consolidated Plan and the Analysis of Impediments are
tools the City uses to identify and assess housing and community needs, primarily for low-and moderate-income
residents and geographic areas. The Housing Market Analysis in the Consolidated plan describes the supply, demand,
conditions and cost of housing for families and households. The needs of renters, homeowners, homeless,elderly, non-
majority populations, and those living with disabilities are identified and assessed. The City Council adopted a Citizen
Participation Plan that outlines a process for the public to provide input,evaluate,and make recommendation to
administrative plans, policies, procedures,and federally funded activities. Citizens can contribute comment through
public meetings, surveys, verbal or written comments, boards and commissions,and through various community
outreach events. The City and HUD entered a Voluntary Compliance Agreement (VCA) in March 2014 to correct findings
identified in a Civil Rights monitoring conducted in 2011. The monitoring resulted in a finding that the City violated Title
VI of the Civil Rights Act in the administration of the Section 8 program. The VCA outlines specific steps the City must
take to comply with federal regulations and Civil Rights law.
Summary of Housing Needs (Consolidated Plan)
The population of Dubuque has remained relatively consistent,decreasing slightly from 57,696 in 2000 to 57,679 in
2011.The number of households increased by 5%, from 22,612 to 23,719 in the same time period. According to the
2007-2011 CHAS Data, Dubuque had 2,585, or 11%of households with between 0-30% HUD Area Median Family Income
(HAMFI or AMI); 3,465 households, 15%of the total households in the City were earning greater than 30-50%AMI; and,
5,395 households,or 23%were households in the income range of 51-80%AMI. Overall, 11,445 households in the City
were at or below 80%of AMI,or 48%of the total households in the City.
A total of 9,325 households were Small Family Households (2-4 persons per households). Of those, 34%are at or below
80%AM I and of the 1,360 large family households (5 or more per household) 44%were at or below 80%AMI.
Households with an elderly member, (age 62-74) numbered 3,950, and represent about 17%of all households. Over half
of these households, 51%,are at or below 80%AMI.A total of 3,375 households contained one-person age 75 or older
and 74%of those households are at or below 80%AMI.
The City is home to approximately 10,800 rental households at or below 80%AM I and 6,845 homeowners at or below
80%AM I. Among rental households,45%are experiencing some sort of housing problem. Over half of those
experiencing housing problems are in the extremely low-income category, where about 1,805 households experience
problems with housing lacking complete plumbing or kitchen facilities,overcrowding, severe overcrowding,or cost
burden greater than 30 or 50%of the household income. Seventy-Six Percent (76%) of those experiencing housing cost
burden greater than 50%of income are extremely low-income households. Renters are more likely to experience severe
overcrowding than homeowners. Among homeowners, 45%of those experiencing cost burden are extremely low income.
Eighty-Five Percent (85%) of homeowners under 80%AMI experience one of the above-mentioned housing problems.
Cost burden is by far the most prevalent problem,for owned and rented households alike.The data shows that of those
renters experiencing housing problems,85%of households with income 0-30%AM I experience some level of cost
burden; 91%of households 31-50%AMI experience cost burden; and 78%of households 51-80%AMI are cost
burdened. For owners experiencing housing problems, 95%of those 0-30%AM I experience a level of cost burden; 96%
Page 8 of 60
of households 31-50%AM I are cost burdened; and 98%of households experiencing problems at 51-80%AMI are cost
burdened.
Section 504 Needs Assessment: Describe the needs of public housing tenants and applicants on the waiting list
for accessible units:
The City of Dubuque does not administer any public housing. Affordable housing is provided through the Housing Choice
Voucher Program, Moderate Rehabilitation Program, Project Based Vouchers, and the Continuum of Care Special Needs
Assistance Program.The needs of Housing Choice Voucher applicants on the waiting list include affordable housing.
Most applicants are cost burdened prior to admission and do not have sufficient income to pay fair market rent. In
addition to affordable housing, many on the program are unemployed or underemployed, disabled,elderly, or
otherwise unable to obtain employment at a level that allows for self-sufficiency.
The City administers a Family Self-Sufficiency Program. The Family Self-Sufficiency Program had 101 active participants in
the City's fiscal year 2018. Participants work on a variety of self-determined goals aimed at developing the skills and
resources needed to obtain employment earning a living wage. The City employs two Family Self-Sufficiency caseworkers
that provide coordination of services for participants to identify and reach employment, family, education,and financial
goals.
As of FYE 2018, 59%of FSS participating households had an established escrow account totaling$120,917. Eight
participants completed their contracts earning a total of$67,298 in escrow. Forty-six percent of participants earned
escrow in FY 2018. Participants earn escrow when they increase employment income enough to raise the portion of rent
they are responsible to pay for their housing. The Family Self-Sufficiency Program is an incredible wealth-building resource
for Assisted Housing participants. In FY 2018,one of the FSS participants who completed their contract earned $17,972 in
escrow. In the previous three fiscal years combined, a total of ten voucher households moved to homeownership. The
increase in voucher participants transitioning to homeownership can be directly linked to additional coordination between
the FSS, Circles, and Rehabilitation programs offered through the Housing Department. The Rehabilitation Supervisor
works actively with Housing Choice Voucher(HCV) Participants who are working to buy their first home utilizing the HCV
Homeownership. The connection to direct financial resources and housing counseling offered through Gaining
Opportunities and Rehabilitation Services has allowed more FSS and lower income households access to real wealth-
building opportunities through affordable homeownership options.
As of December 31, 2018,the overwhelming majority (87%) of those on the waiting list are extremely low income and 62%
are families with children. Eighty one percent (81%) of those on the waiting list are Black/African American, followed by
17%White, 1.18% Native Hawaiian/Other Pacific Islander, 1.02%Asian and .51%American Indian/Alaska Native. According
to the 2013-2017 American Community Survey, nearly 65%of Dubuque's African American population earn under$25,000
per year.The data supports conclusions in the Analysis of Impediments to Fair Housing that African American/Black
households are more likely to experience housing problems, including cost burden,compared to the jurisdiction as a whole.
Education,job readiness skills, living-wage employment,and quality affordable housing are high needs for the waiting list
population. Approximately 11.8%of those waiting for housing assistance are families with disabilities, 1.2%are elderly and
1%are elderly and disabled.
Strategies developed by the City to address corrective actions identified by HUD in the Voluntary Compliance Agreement
and by the revisions of the Administrative Plan address the following needs:
1. A Strategy to increase Housing opportunities throughout Dubuque which takes into account the needs of
minority populations;
2. A Strategy to provide affordable housing that is fully available without regard to race or ethnicity throughout all
the communities within Dubuque to create equal housing opportunities; and
Page 9 of 60
3.A strategy to take affirmative steps to provide opportunities for desegregation of areas of racial and ethnic
concentration of poverty, which may include but would not be limited to expanding program opportunities for
Housing Choice Voucher applicants and participants.
To effectively increase housing opportunities throughout Dubuque that takes into account the needs of minority
populations, the City has developed a marketing and outreach plan to ensure equal access to the Assisted Housing
Programs,this includes ensuring that at least 75%of new admissions are extremely low-income households.The City has
implemented an on-line application that allows greater access to the programs available.To ensure affordable housing is
fully available without regard to race or ethnicity; the City continues to research the possibility for a "source of income"
ordinance that will be reviewed by the Dubuque City Council.This will insure greater housing choice for
voucher participants.
Housing Needs of Families on the Section 8 Tenant-Based Assistance WaitingList
In April 2015, the City of Dubuque requested and received permission from HUD to close the waiting list based uponthe
wait period to receive a voucher. Along with the request an over view of the waiting list was submitted detailing 1500
applicants experiencing a wait period of 1-2 years. City of Dubuque reopened the waiting list for one week in February
2018 and accepted 1000 applicants. As of January 1, 2019,The HCV Feb 2018 Waiting List consisted of:
City of Dubuque Housing & Cammunity Development
350 W 6th Street#312 Dubuque,IA 52001
January 1,2019 Waiting List Statistical Summary
By:Tonya England LK of 1 A/19 1139 pm
Wa�ig List: HCV Feb 2018
Face Tohl Pe:cait
AmericanIndiazJAlaskaNative 3 O.Sl°lo Waitiu�List HCVFeb2018
Asiazi 8 1.02'f PerceidthatareHazdicappedorDisabled: 0.00°l
NatirE Hawaiian/OtherPacific Lclazder '7 1.18°!o Total NumberofHandicapped ar Disabled: 0
B1acWAfrican A:rerican 476 80.54°l Total NumberofApplicants Listed: 991
VJhite 99 16.�5%
Total 591 Nu�exOver Lixerit S�r Lnw Income: 0
Nu�erQualifyuig far Lav Incame: 1
NuttberQualifyuig far VeryLow Incame: 77
Nux�berQuali£yuig far ExtnemelyLaw Inco:re: 513
Fam�•Co�os�on Total Penent
Elderly 33 5.58°/ Aeree�Qualifying£ar Lav Income: 0.17°l0
Disabled Aercend Qualifying far VeryLow Incame: 13.03°!0
S itgle 190 32.15% Pencetd Qvali£yittg far ExtiemelyLotv Incoxre: 86.80°!0
Faxeuly 3� 52.27%
Total 591
Ethnici� Total Penent
Hispaxric orLatiro 25 4.23%
Not Hisp.uuc orLatino 566 95.77%
Total 591
Wa�gList A°,�.�� 1Va��List Crn Ino�rnee Adjus�dIrrcom
Averag�s for HCV Feb 2018: 319.98 HCV Feh 2018 $9,661.19 $S,1'7�.43
Mod Rehab �,688.49 $35690.27
'ect Based Vouchera $3,6S0.7S $�234.54
Av for AII W '' Listr: $9 666.81 $ 698.41
"The Se�ctron 8 HC Vanid ttie HCV Purgs dVaarng L uts wero sxhaustgd m May2018"
Page 1 of 2
Page 10 of 60
January 1,2019 Waiting List Statistical Summary
Wa��Liat: Mod Rehab Wa��Liat Paqject Ba.sed Voucheas
Race Total Perca�t Race Total Pacent
W1uH 188 35.40! Wlrite 173 23.A5°!
Asian 4 0.7SY Asian 6 0.83%
Native Hawaiian/OtherPacific Islazder 11 2.07'/ Native Hawauazi/OtherPacific Islander 6 0.831
AxnericanIndian/Alaska NativE 5 0.94°lo American I:dian/Alaska Native 11 1.52°!0
B1acYJAfricanAmexican 323 60.83°!o Black/AfricuiAmerican 525 7Z.8S'!
Total 531 Total 722
Fanv'b•Cor�os�on Total Percent Fanu'�Compos�on Total Peraent
Elderly 27 5.08! Elde3y 25 3.46°!
Disabled 36 6.78% Disabled 15 2.08°!
Si�le 26� 38.42% Single 27l 37.67'/
Fa:nily 26a 49.72% Fainily a10 56.79%
Total 531 Total 722
Ethnicip� Total Percent E�u�ici� Total Pereent
Hispazric orLatiro 18 339% Hispuuc orLatino 31 4.29%
Not Hispazuc or Latino 513 9&.61°!o Not Hupazuc ar Latino 691 95.71%
Total 531 Total 722
Waitiu�Lirt: Mod Rehab Waimig List: Arojact Based Vouchers
Pexent that ane Hand'uapped or Disabled: 6.78°!o Pexcent t2iat are Hazudicapped orDisabled: 2.08°l0
Total Nuxeb er oE Handicapped ox Disabled: 36 Total Numb er of H axd'uapped ar Dis abled: 15
Total Nunb er oE Applicants Listed: 531 Total Nvmb er of A pplicants Lis ted: 722
Number Over Lunit far Los Ixucame: 0 Nuxefi er Over Lixect�r Low I�ome: 2
Numbex Qualifying forLow Incoxre: 19 Nuze�er Quali£yuig far Lav Inco¢ne: 18
Number Qualifying for V ery Low Income: 82 Nuzeb er Qualifyieg far Very Low Incame: 99
Number Qualif'ying forEx4exrely Lav Ireome: 430 NuzeberQualifyieg far ExtnemelyLow Income: 6D3
Percent Qualifyuig forLow Incame: 3.58! Percexd Qualifyirg far Lorr Inoome: 2.49%
Percent Qualifyuig for Very Low Inco:re: 15.44% Aerce:d Qualifyieg far Vexy Lav Incame: 13.']1%
Percent Qualifying forExtremely Lorr Imome: 80.98°!o Percexd Quali£yi�far Exhemely Low Income: 83.52°!0
"The,SecNon 8 HC Vand the HCV Pug7e Wailrng L�sts wero exhaustsd,v�May2078"
Page 2 of 2
In January 2010, a voucher freeze was put in place by the City Council reducing the number of vouchers to900 participant
families. Due to this reduction in vouchers, a Civil Rights Compliance Review was carried out by HUD in June 2011 resulting
in a Letter of Findings on June 17, 2013 and subsequent Voluntary Compliance Agreement in March 2014.The City of
Dubuque is committed to the fair and equitable operation of its programs and acknowledges the actionstaken had a
negative impact on African American program applicants.The City is working to complete corrective actions through
compliance with the VCA.This VCA is intentionally designed to achieve and continue compliance with the City's
responsibilities under Title VI of the Civil Rights Act and the City's obligation to affirmatively furthering fair housing
obligations. All residency preference point allotments and local preference points based on residencywere removed on
December 4, 2012.The City has implemented an on-line portal to receive applications and a lottery system to place
applicants on the waiting list.
As of December 31, 2018, 833 Vouchers were utilized. The City of Dubuque has worked to maintain minimum of 95%of
Housing Assistance Payments Expenditure and seeks to utilize maximum funding to assist as many households as allowed
by the HAP funding.
The administrative plan was amended in 2018. The amended administrative plan lowered the number of waiting list
applications on the waiting list before opening another housing choice voucher waiting list. Changes to Chapter 11
adopted changes to the administrative plan to address HUD guidance on the requirement of the Violence Against Women
Page 11 of 60
Reauthorization Act of 2013.
Voucher Issuance is a top priority to increase utilization and is focused on effective management of staff time and
priorities to meetthese goals. In May 2018, the Section 8 HCV and HCV Purge Waiting List was exhausted. In June, 2018,
City of Dubuque began utilizing the HCV Feb 2018 waiting list for voucher issuance. Selection from this waiting list for
voucher issuance based on a lottery system began in June 2018. There were 191 Vouchers issued to applicants in the
City's Fiscal Year 2018. Of the vouchers issued, 146 resulted in a leased unit or 76%success rate.
Housing Needs and Strategies to Address Housing Needs:
Need: Shortage of affordable housing for all eligible populations
StrateQv#1: Maximize the number of affordable units available to the PHA within its current resourcesby:
• Undertake measures to ensure access to affordable housing among families assisted by the PHA, regardlessof unit
size required
• Foster partnerships with private and non-profit housing developers
• Increase or maintain lease-up rates by marketing the program to owners, particularly those outside of areasof
minority and poverty concentration
• Increase or maintain Housing Choice Voucher lease up rates by encouraging owner acceptance of program
• Participate in the Consolidated Plan development process to ensure coordination with broadercommunity
strategies
• Support programs through the City of Dubuque Rehabilitation activities and continue Housing Choice Voucher
Homeownership program.All HCV participants desiring to enroll in the Homeownership Made Easyclasses
attend free of charge.
• Any change in lease up rates that would result in a decrease in the number of vouchers utilized mustbe
proposed and approved by HUD
StrateQv#2: Carry out the actions in the Voluntary Compliance Agreement of 2014 to bring PHA into compliance with and
ameliorate the impacts of the policies from 2009-2010 that lead to the Findings of Noncompliance with Title VI of the Civil
Rights Act.
On June 20-24, 2011,staff from HUD's Office of Fair Housing and Equal Opportunity (FHEO) completed a civil rights
related program review of the City's Housing and Community Development Department.The review focused on policies
that were primarily implemented in late 2009 and early 2010 that limited the participation of African American
participants in the program.The review team collected demographic data on Housing Choice Voucher program
participants, including wait list information,applicant resolution information,and voucher utilization.The team further
collected and reviewed information available through public record, including city meeting minutes, committee meeting
minutes,and newspaper articles. Finally,the team collected policies, plans, and reports such as the City's Consolidated
Plan and the PHA's wait list admission policies.
As a result of the compliance review, HUD issued a Letter of Findings (LOF) on June 17, 2013.The LOF alleged that the
PHA discriminated against African Americans based on race by taking the actions of freezing voucher issuance,
establishing local residency preference points,eliminating the very-low income preference, and purging the wait list. The
City denies discriminating against African American applicants to the program. However,the City had agreed to enter into
a Voluntary Compliance Agreement to ensure continued compliance with its responsibilities under Title VI and its
implementing regulations,as well as the City's AFFH obligations and compliance with the PIH Program Requirements.
• Take actions to meet the provisions detailed within the Voluntary Compliance Agreement.
Need: Specific Family Types: Families at or below 30%of inedian
StrateQv:Target available assistance to families at or below 30%ofAMl
• Encourage enrollment in FSS to support and encourage work
Page 12 of 60
• Provide listings of available Mod Rehab
Need: Specific Family Types: Families at or below 50%of inedian
StrateQv:Target available assistance to families at or below 50%ofAMl
• Encourage enrollment in FSS to support and encourage work
• Provide listings of available Mod Rehab units
Need: Specific Family Types: The Elderly
StrateQv:Target available assistance to the elderly
• Collaborate efforts and funding resources with area agencies
• Increase awareness of assisted housing benefits
• Maintain collaborative services with elderly service agencies/apartment complexes
• Continue referrals to elderly apartments/complexes designed to assist lower income household
• Increase opportunities for the elderly with special needs to maintain an independent lifestyle by providing
Project Based Vouchers at an assisted living facility (17 Vouchers)
Need: Specific Family Types: Families with Disabilities
StrateQv: Assist families with disabilities in locating suitable housing.
• Affirmatively market to local non-profit agencies that assist families with disabilities
• Actively participate in Fair Housing Planning and identification of impediments to Fair Housing Choice
• Encourage owners to make dwelling units accessible
• Advise disabled participants of monies that are available for their landlords to modify units for accessibility
purposes through the City of Dubuque Rehabilitation Activity
Need: Specific Family Types: Races or ethnicities with disproportionate housing needs
StrateQv#1: Increase awareness of PHA resources among families of races and ethnicities with disproportionate
needs:
• Continue to participate and support community agencies/groups/organizations to provide Fair Housing Act
information and support
• Continue Fair Housing awareness,outreach, and training
• Increase awareness and understanding of the issues facing special populations as well as persons with low and
moderate incomes
• Provide marketing to minority races and ethnicities, specifically to African Americans, including marketing on
the Homeownership Program and Self-sufficiency programs
StrateQv#2: Conduct activities to affirmatively further fair housing
• Counsel Housing Choice Voucher tenants as to location of units outside of areas of poverty or minority concentration
andassist them to locate those units
• Market the Housing Choice Voucher program to owners outside of areas of poverty/minorityconcentrations
• Participate and encourage training of staff and landlords in Fair Housing Laws
• Participate and encourage training of tenants in Fair Housing rights
Reasons for Selecting Strategies: list all that influenced the PHA's selection of the strategies it will pursue:
• The need to address and correct the allegations and findings contained in the LOF.
• Funding constraints
• Staffing constraints
• Extent to which housing needs are met by other organizations in the community
• Evidence of housing needs as demonstrated in the Consolidated Plan and other information available to thePHA
• Influence of the housing market on PHA programs
• Community priorities regarding housing assistance
Page 13 of 60
• Results of consultation with local or state government, with residents and the Resident Advisory Board, and with
advocacy groups
• Results of a Fair Housing Planning Guide for the City of Dubuque
• Discussions with the City's Housing Commission
• Feedback from the community
On March 31, 2014,the City of Dubuque, lowa and the U.S. Department of Housing and Urban Development (HUD) entered
a Voluntary Compliance Agreement outlining remedies to address the findings of noncompliance identified in HUD's letter
to the City dated June 17, 2013. In its letter of findings to the City, HUD found that the City's process of purging applicants
from the waiting list resulted in disparaging impact and kept people out of the program, specifically African-Americans. The
City contends there was no such intent with this process; however, did agree to notify all applicants on the waiting list in
November and December 2009 to invite all applicants to apply. On April 9, 2015 HUD granted permission to close the HCV
waiting list effective April 30, 2015. The HCV waiting list was reopened February 14, 2018. The HCV Section 8 and HCV
Purge waiting list was exhausted in May 2018. As of December 31, 2018,and the HCV Feb 2018 waiting list has 591
participants on the list.
ProQram Sqecific WaitinQ List
The City of Dubuque shall maintain waiting lists for the Moderate Rehabilitation Program;the Project Based Voucher Program
and the Housing Choice Voucher Program.
Pre-Aqqlication
Moderate Rehabilitation Program Waiting List: The Moderate Rehabilitation Program shall be a separate waiting list. The
Moderate Rehabilitation program provides project-based rental assistance to very low-income families. The City of
Dubuque currently has two properties with Moderate Rehabilitation contracts. Eligible families are placed on the
Moderate Rehabilitation waiting list upon request by the family. When vacancies occur in Mod Rehab projects, the City
refers income eligible families for participation in the Mod Rehab program from its waiting list to the owner. Owners select
a family for occupancy of a unit after screening the family. Once the owner selects a family and notifies the City, the City
shall determine final eligibility based upon the same criteria for eligibility as the Housing Choice Voucher program.
Proiect-Based Voucher ProQram WaitinQ List: The Project-Based Voucher Program Waiting List shall be a separate waiting
list. The City of Dubuque currently has one project-based voucher contract in a selected affordable assisted living
residential facility. All families selected for occupancy must qualify per the very low-income guidelines. The project-based
voucher units are designated for occupancy by elderly or disabled families requiring assisted living services. Prior to and as
a condition of occupancy,the Owner or its designated service provider shall evaluate the proposed applicanYs status to
determine the qualification for residency of the assisted living facility. When vacancies occur in the project-based voucher
program,the City refers income eligible families for participation in the project-based voucher program from its waiting list
to the owner. The owner selects a family for occupancy of a unit after screening the family. Once the owner selects a
family and notifies the City, the City shall determine final eligibility based upon the same criteria for eligibility as the
Housing Choice Voucher program.
HousinQ Choice Voucher ProQram WaitinQ List(s):
The City of Dubuque shall open another Housing Choice Voucher waiting list once the most current HCV waiting list consists
of 200 applications. The City began preparations to open the list as we approached this number; however,the list was not
opened until after the number of participants on the waiting list was below the 200-application target. The current waiting
list will be completely exhausted prior to selecting applicants from the new waiting list. The new HCV waiting list will
remain open to accept applications for seven (7) calendar days with the end date of the application period falling on a
business day. Interested individuals/families will be required to complete a written pre-application form for admission and
placement on the waiting list. Applications submitted online shall be considered written applications. The City of Dubuque
will use the pre-application form to collect only the information necessary to make a preliminary determination of
eligibility.
Page 14 of 60
A lottery system will be used to determine which applicants are placed on the new waiting list once the waiting list is
closed. Using the lottery system,one thousand (1,000) applicants will be selected to be placed on the waiting list. Only the
head of household should apply. Duplicate applications will not be allowed. Each household has an equal chance of being
selected. All applications not selected during the Lottery Selection process to be placed on the waiting list will be tracked
on a bi-annual report per guidelines for reporting in the Voluntary Compliance Agreement with HUD. Applicants that are
not selected to be placed on the waiting list will need to re-apply to the waiting list the next time new applications are
accepted and the waiting list is open.
It is the City of Dubuque's intent to utilize each HCV waiting list established through the lottery system as described above by
opening and closing the waiting list as needed. Each time the currently used HCV waiting list is reduced to 200 applications,
the waiting list will be opened again for the seven (7)calendar day period and once closed,one thousand (1,000)applications
will be selected to be placed on the new HCV waiting list using the lottery system. The remaining 200 applicants on the
current HCV waiting list will remain active throughout the final determination of eligibility process. The City of Dubuque shall
work with HUD to notify them of the status of the waiting list.
The family will be required to provide all the information necessary to establish final family eligibility and level of assistance
when the family is selected from the waiting list.
When the waiting list is open, individuals/families may obtain pre-application forms from the PHA's office during normal
business hours or may complete online applications at the City of Dubuque website at
www.cityofdubuque.apply4housing.com. Applicants may also request—by telephone, mail or e-mail—an application be
sent to them via first class mail or FAX or e-mail.
Applications must be received during the time the waiting list is open to the public. For applications received by mail, the
received date shall be determined by the date the application has been post marked. For applications received by Fax or e-
mail, the received date shall be determined by the date the FAX or the e-mail is received by the City of Dubuque. The City
of Dubuque shall open the waiting list for seven (7) calendar days with the last day of acceptance on a business day to allow
applicants the opportunity to contact the City of Dubuque Housing Authority staff if the applicant has questions.
If the pre-application is incomplete, the PHA will notify the family of the additional information required. HA staff will make
reasonable efforts to contact the applicant and inform him/her of the additional information required and provide the
applicant 7 calendar days to correct the deficiency. Reasonable efforts shall be in the form of one letter or, if no address is
provided,one telephone call or e-mail. If the HA staff is unable to contact the applicant, the application will be removed
from the lottery selection process or if the applicant is contacted and fails to respond within the time specified or any
extensions of time, the applicant will be removed from the lottery selection process. A record of those efforts shall be
maintained with the application.
Final Aqqlication
On an ongoing basis, the PHA will randomly select households from the waiting list based upon the number of Vouchers
that may be issued by utilizing leasing data and turnover rates and selecting the applicants through a lottery system
randomly pulled from the current HCV waiting list. The applicants selected from the waiting list using the lottery system
will be mailed a full application packet to determine final eligibility.
Completed applications must be received by the PHA by mail, FAX,e-mail or submitted in person during normal business
hours within 15 business days of the date on the PHA letter requesting the updated application. For applications received
by mail,the received date shall be determined by the date the application has been post marked. For applications received
by Fax or e-mail,the received date shall be determined by the date the FAX or the e-mail is received by the City of
Dubuque. Applications must be complete to be accepted by the PHA for processing. An application shall only be considered
complete if accompanied by proof of identity; copy of SSN; citizenship, eligible immigration status or non-contending
declaration; and all mandatory release forms along with a completed application. The final "Application" form must be
filled out and must not contain any blanks or unanswered questions.
All applications must be accompanied by proof of identity from a third party for all household members. Acceptable forms
shall include birth certificates; current driver's license; identification card issued by a federal,state, or local agency;
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identification card issued by a medical insurance company or provider(including Medicare and Medicaid); or Court records.
All applications must be accompanied by copies of social security cards of all household members.
If the applicant is unable to provide documentation/verification of the SSN but is otherwise determined eligible,the
applicant may retain the applicanYs place on the waiting list for the program but cannot become a participant until the
applicant provides the required verification. The applicant will be provided 30 days to obtain the required verification while
retaining the applicanYs place on the waiting list.
However, if a child under the age of 6 years was added to the applicant household within the 6-month period prior to the
household's date of voucher issuance,the applicant may become a participant,so long as the documentation/verification is
provided within 90 calendar days from the date of admission to the program. One additional 90-day extension period will
be granted if the PHA determines that the applicanYs failure to comply was due to circumstances that could not reasonably
have been foreseen and were not due to the fault of the applicant.
If the final application is incomplete,the PHA will notify the family of the additional information required. HA staff will
make reasonable efforts to contact the applicant and inform him/her of the additional information required and provide
the applicant 15 business days to correct the deficiency. Reasonable efforts shall be in the form of one letter or, if no
address is provided, one telephone call or e-mail. If the applicant fails to respond within 15 business days, HA staff will
make one additional effort by calling or sending an e-mail. If the HA staff is unable to contact the applicant, the application
will be removed from the waiting list or if the applicant is contacted and fails to respond within the time specified or any
extensions of time, the applicant will be removed from the waiting list. A record of those efforts shall be maintained with
the application. A record of all applications received (even incomplete applications) shall be maintained by the PHA
indicating all attempts to contact the applicant.
The PHA will monitor the characteristics of the population being served and the characteristics of the population in the
PHA's jurisdiction.Targeted outreach efforts will be undertaken if a comparison suggests that certain populations are being
underserved. Outreach activities will include surrounding housing authorities, local chapters of the NAACP within 200
miles,outreach to agencies assisting persons with disabilities and organizations for persons with limited English proficiency.
The PHA administers the following types of targeted funding:
2008 and 2009 Non-Elderly Disabled Participants
Vouchers covered by Project-Based HAP Contract
Tenant Protection
Moderate Rehabilitation Program
Order of Selection
If the available Voucher is designated as a special purpose Voucher allocated for disabled families such as NED (Non-Elderly
Disabled),applicants qualifying for the special purpose Voucher will be selected by a computer-generated Lottery system.
Other applicants that do not qualify for the special purpose Voucher will not be selected to receive the Voucher. Special
purpose Vouchers identified as Tenant Protection shall be per the HUD contract (Example: Opt-Out or Mod Rehab
participants converting to the Voucher program.)
Documentation will be maintained by the PHA as to whether families on the list qualify for and are interested in special
purpose vouchers. If a higher placed family on the waiting list is not qualified for the special purpose voucher, there will be
a notation maintained so that the PHA does not have to ask higher placed families each time targeted selections are made.
Financial Resources
The HUD Calendar Year 2018 Renewal Funding for the Housing Choice Voucher Program allocated$4,777,508 for housing
assistance payments. HUD granted $133,507 for two Family Self-Sufficiency Coordinators during calendar year 2018.
Operation and Mana�ement
Records Management
Per HUD requirements within 180 days of the effective date of the Voluntary Compliance Agreement (VCA) (March 31,
2014), the City shall develop and submit the following report to the Department for review and approval:
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a. The Bi -Annual Waiting List Report (BWLR) that tracks the maintenance of the Housing Choice Voucher waiting
list.The BWLR will include the following: 1) applicant's name, race, sex, ethnicity, familial/elderly or disability
status; 2) date of application; 3) date applicant placed on waiting list; 4) applicant preference(s); 5) date and time
of offer; 6) date of lease; and 7) date applicant removed from waiting list and justification.
b. The Bi-Annual Report shall also track all families denied admission to the program,all applicants determined to
be ineligible due to criminal background, and all determinations to terminate participation in the Assisted
Housing Programs. The reports shall include race, national origin, address, age of applicants,familial status and
disability. The reports shall include the specific activity or occurrence identified by the PHA in making the
determination to deny admission to the program or to terminate participation, how the PHA learned of the
activity or occurrence,and what if any,alternate option or information was provided to the family at the time of
denial or termination. All determinations of ineligibility due to Criminal Background shall include a copy of the
denial or termination notice along with the reports or other information provided to the family at the time of
denial or termination.
c. The City shall continue to submit a BWLR every six months for the duration of the VCA.Submissions of the BWLR
shall occur on the first day of the month for each six-month period, and will include the wait list information for
the immediately preceding six-month period.The biannual reporting periods are as follows:January 1 through
June 30,due on July 15;July 1 through December 31,due January 15.
d. The City shall maintain records for review by the Department for a minimum of five (5) years after the close of
the Agreement. Records subject to review include, but are not limited to: participant lists, wait lists, ineligible
applicant and applicant rejected lists,applications,and terminated participants/applicant resolution lists.These
lists and records shall be kept electronically and in hard copy.While Dubuque may select the format of the list or
record, it must be uniform and consistent for review purposes. The City shall furnish copies of all records upon
request from the Department.
e. The City shall maintain records, including those required under HUD program regulations, which disclose all
individuals who apply and the way each application is treated, i.e.,whether said individuals are accepted or
rejected and the basis for any rejection.
f. The City shall maintain all participant files, including applications for residency, rental agreements or leases,
notices and letters to residents, and notices of termination,along with all material relating to the City's
implementation of the Title VI, Section109, and AFFH requirements of this Agreement.
g. The City shall maintain all material relating to the racial composition of its HCDD operated Programs, such as
waiting lists, records of the racial, national origin, elderly,disabled and familial status makeup of participants in
Housing Programs, and copies of denied applications.
h. The City shall maintain copies of all race-related complaints, claims,grievances, investigative records, including
grievance process materials.
i. The City shall maintain files containing documentation of its efforts to meet the obligations of this Agreement.
All applicant and participant information will be kept in a secure location and access will be limited to authorized PHA staff.
PHA staff will not discuss personal family information unless there is a business reason to do so. Inappropriate discussion of
family information or improper disclosure of family information by staff will result in disciplinary action.
Moving with Continued Assistance
HCV Recipients can move to a new unit with continued assistance. Permissible reasons to move are:
• The family has a right to terminate the lease on notice to the owner (for the owner's breach or otherwise) and has
given a notice of termination to the owner in accordance with the lease. The lease for the family's unit has been
terminated by mutual agreement of the owner and the family.
• The PHA policy is if the family and the owner mutually agree to terminate the lease for the family's unit,the family
must give the PHA a copy of the termination agreement.
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• The owner has given the family a notice to vacate, has commenced an action to evict the family, or has obtained a court
judgment or other process allowing the owner to evict the family [24 CFR 982.354(b)(2)].The family must give the PHA
a copy of any owner eviction notice [24 CFR 982.551(g)].
• The family or a member of the family is or has been the victim of domestic violence,dating violence,or stalking and the
move is needed to protect the health or safety of the family or family member. This condition applies even when the
family has moved out of its unit in violation of the lease,with or without prior notification to the PHA, if the family or
family member who is the victim reasonably believed that he or she was imminently threatened by harm from further
violence if he or she remained in the unit.
• The PHA policy is if a family requests permission to move with continued assistance based on a claim that the move is
necessary to protect the health or safety of a family member who is or has been the victim of domestic violence, dating
violence, or stalking,the PHA will request documentation in accordance with section 16-IX.D of this plan.
• The PHA reserves the right to waive the documentation requirement if it determines that a statement or other
corroborating evidence from the family or family member will suffice. In such cases the PHA will document the waiver
in the family's file.
• The PHA has terminated the assisted lease for the family's unit for the owner's breach
• The PHA determines that the family's current unit does not meet the HQS space standards because of an increase in
family size or a change in family composition. In such cases,the PHA must issue the family a new voucher,and the
family and PHA must try to find an acceptable unit as soon as possible. If an acceptable unit is available for the family,
the PHA must terminate the HAP contract for the family's old unit in accordance with the HAP contract terms and must
notify both the family and the owner of the termination.The HAP contract terminates at the end of the calendar month
that follows the calendar month in which the PHA gives notice to the owner.
Restrictions on Moves:
Moving is generally contingent on compliance with program requirements and funding availability. The PHA will deny a
family permission to move on grounds that the PHA does not have sufficient funding for continued assistance if(a) the
move is initiated by the family, not the owner or the PHA; (b) the PHA can demonstrate that the move will, in fact, result in
higher subsidy costs; and (c) the PHA can demonstrate that it does not have sufficient funding in its annual budget to
accommodate the higher subsidy costs. The PHA maintains a list of families whose moves are denied due to insufficient
funding. When funding becomes available, these families take precedence over families on the waiting list.
If the PHA has grounds for terminating or denying the families assistance,the PHA may deny a family permission to move.
In general,the PHA will not deny a family permission to move for violation of program rules; however, the PHA reserves the
right to do so as outlined in the administrative plan.
The PHA will deny a family permission to make an elective move during the family's initial lease term.This policy applies to
moves within the PHA's jurisdiction or outside it under portability.
The PHA will also deny a family permission to make more than one elective move during any 12-month period.This policy
applies to all assisted families residing in the PHA's jurisdiction.
The PHA will consider exceptions to these policies for the following reasons: to protect the health or safety of a family
member (e.g., lead-based paint hazards, domestic violence, witness protection programs),to accommodate a change in
family circumstances (e.g., new employment, school attendance in a distant area),or to address an emergency over which a
family has no control. The PHA provides exceptions for legitimate family needs but not for the convenience of either or
both parties. The PHA may request the family to obtain a mutual agreement from the owner to move when considering
exceptions.
In addition,the PHA will allow exceptions to these policies for purposes of reasonable accommodation of a family member
who is a person with disabilities.
Restrictions on moves may be implemented as budget authority allows.
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Portability:
A family may move with voucher assistance only to an area where there is at least one PHA administering a voucher
program. Applicant families that have been issued vouchers as well as participant families may qualify to lease a unit
outside the PHA's jurisdiction under portability. If neither the head of household nor the spouse/cohead of an applicant
family had a domicile (legal residence) in the PHA's jurisdiction at the time that the family's initial application for assistance
was submitted,the family must lease a unit within the initial PHA's jurisdiction for at least 12 months before requesting
portability.
The PHA will consider exceptions to this policy for purposes of reasonable accommodation or reasons related to domestic
violence, dating violence, or stalking.
Because the portability process is time-sensitive,the PHA will notify the receiving PHA by phone,fax, or e-mail to expect
the family.The initial PHA will also ask the receiving PHA to provide any information the family may need upon arrival,
including the name, fax,e-mail address, and telephone number of the staff person responsible for business with incoming
portable families and procedures related to appointments for voucher issuance.The PHA will pass this information along to
the family.The PHA will also ask for the name, address, telephone number, fax and e-mail of the person responsible for
processing the billing information.
Restrictions on portability may be restricted as budget authority allows.
Determination of Insufficient Funding
The PHA will determine whether there is adequate funding to issue vouchers, approve moves to higher cost units and
areas, and continue subsidizing all current participants by comparing the PHA's annual budget authority to the annual total
HAP needs monthly.The total HAP needs for the calendar year will be projected by establishing the actual HAP costs year to
date.To that figure, the PHA will add anticipated HAP expenditures for the remainder of the calendar year. Projected HAP
expenditures will be calculated by multiplying the projected number of units leased per remaining months by the most
current month's average HAP.The projected number of units leased per month will consider the average monthly turnover
of participant families. If the total annual HAP needs equal or exceed the annual budget authority,or if the PHA cannot
support the cost of the proposed subsidy commitment (voucher issuance or move) based on the funding analysis, the PHA
will be considered to have insufficient funding. If a shortfall is determined,the City will work with HUD to determine
appropriate actions and amend the administrative plan as necessary.
Violence Against Women Act(VAWA)
The PHA acknowledges that a victim of domestic violence, dating violence, sexual assault or stalking may have an
unfavorable history (e.g., a poor credit history, a record of previous damage to an apartment, a prior arrest record) that
would warrant denial under the PHA's policies.Therefore, if the PHA decides to deny assistance to an applicant family,the
PHA will include in its notice of denial the VAWA information and will request that an applicant wishing to claim protection
under VAWA notify the PHA within 14 business days.
VAWA provides four specific protections against termination of HCV assistance for victims of domestic violence, dating
violence, sexual assault or stalking. (Note:The second, third, and fourth protections also apply to terminations of tenancy
or occupancy by owners participating in the HCV program, as do the limitations discussed under the next heading.)
First,VAWA provides that a PHA may not terminate assistance to a family that moves out of an assisted unit in violation of
the lease, with or without prior notification to the PHA, if the move occurred to protect the health or safety of a family
member who is or has been the victim of domestic violence, dating violence,sexual assault or stalking and who reasonably
believed he or she was imminently threatened by harm from further violence if he or she remained in the unit.
Second, it provides that an incident or incidents of actual or threatened domestic violence, dating violence, sexual assault
or stalking may not be construed either as a serious or repeated lease violation by the victim or as good cause to terminate
the assistance of the victim.
Page 19 of 60
Third, it provides that criminal activity directly related to domestic violence,dating violence,sexual assault or stalking may
not be construed as cause for terminating the assistance of a tenant if a member of the tenanYs household,a guest, or
another person under the tenanYs control is the one engaging in the criminal activity and the tenant or an immediate
family member of the tenant is the actual or threatened victim of the domestic violence, dating violence,sexual assault or
stalking.
Fourth, it gives PHAs the authority to terminate assistance to any tenant or lawful occupant who engages in criminal acts of
physical violence against family members or others without terminating assistance to,or otherwise penalizing,the victim of
the violence.
In determining whether a program participant who is a victim of domestic violence, dating violence, sexual assault or
stalking is an actual and imminent threat to other tenants or those employed at or providing service to a property, the PHA
will consider the following,and any other relevant, factors:
• Whether the threat is toward an employee or tenant other than the victim of domestic violence, dating violence, sexual
assault or stalking
• Whether the threat is a physical danger beyond a speculative threat
• Whether the threat is likely to happen within a short period of time
• Whether the threat to other tenants or employees can be eliminated in some other way, such as by helping the victim
relocate to a confidential location or seeking a legal remedy to prevent the perpetrator from acting on the threat
If the participant wishes to contest the PHA's determination that he or she is an actual and imminent threat to other
tenants or employees,the participant may do so as part of the informal hearing.
The PHA will terminate assistance to a family member if the PHA determines that the family member has committed
criminal acts of physical violence against other family members or others.This action will not affect the assistance of the
remaining, nonculpable family members. In making its decision, the PHA will consider all credible evidence, including, but
not limited to, a signed certification (form HUD-5382) or other documentation of abuse submitted to the PHA by the victim.
A PHA presented with a claim for initial or continued assistance based on status as a victim of domestic violence, dating
violence, sexual assault, stalking,or criminal activity related to any of these forms of abuse may—but is not required to—
request that the individual making the claim document the abuse. Any request for documentation must be in writing, and
the individual must be allowed at least 14 business days after receipt of the request to submit the documentation.The PHA
may extend this time period at its discretion.
For purposes of determining whether a tenant may be covered by VAWA,the following list of definitions applies:
VAWA defines domestic violence to include felony or misdemeanor crimes of violence committed by any of the following:
• A current or former spouse or intimate partner of the victim
• A person with whom the victim shares a child in common
• A person who is cohabitating with or has cohabitated with the victim as a spouse or intimate partner, by a person
similarly situated to a spouse of the victim under the domestic or family violence laws of the jurisdiction receiving grant
monies,or by any other person against an adult or youth victim who is protected from that person's acts under the
domestic or family violence laws of the jurisdiction
VAWA defines dating violence as violence committed by a person (1) who is or has been in a social relationship of a
romantic or intimate nature with the victim AND (2) where the existence of such a relationship shall be determined based
on a consideration of the following factors:
• The length of the relationship
Page 20 of 60
• The type of relationship
• The frequency of interaction between the persons involved in the relationship
VAWA defines sexual assault as means any nonconsensual sexual act proscribed by Federal,Tribal, or State law, including
when the victim lacks capacity to consent.
VAWA defines stalking as engaging in a course of conduct directed at a specific person that would cause a reasonable
personto:
• Fearforthe person'sindividualsafety orthe safety of others
• Suffer substantial emotional distress
Rent Determination
To be eligible, the dwelling unit must have a reasonable rent. The rent must be reasonable in relation to comparable
unassisted units in the area and must not be more than rents charged by the owner for comparable, unassisted units on
the premises. The PHA must make a rent reasonableness determination at initial occupancy and whenever the owner
requests a rent adjustment. Where the gross rent of the unit exceeds the applicable payment standard for the family,the
share of rent to be paid by the family cannot exceed 40 percent of the family's monthly adjusted income.
Bedroom size assignments on Vouchers will be made so that the smallest number of bedrooms needed to house a family
without overcrowding shall be issued. The subsidy standards will be consistent with space requirements under the City
of Dubuque Housing Code. The subsidy standards will be applied consistently for all families of like size and composition.
A child who is temporarily away from the home because of placement in foster care is considered a member of the family
in determining the family unit size. A family that consists of a pregnant woman (with no other persons) must be treated
as a two-person family (parent/minor child) and shall be assigned a two-bedroom voucher. Any live-in aide (approved by
the PHA to reside in the unit to care for a family member who is disabled) must be counted as a person residing in the
household in determining the family unit size and shall be issued a separate bedroom.
In the case of a participant who shares custody of a child (or children) with a parent or guardian residing outside of the
household,the child shall be included as a member of the household when considering the assignment of bedroom size if
the child (or children) legally reside with the participant and is considered a household member.
Disabled household members shall be provided separate bedrooms in cases of disabled household members receiving
supportive services to enhance independent living from another agency.
The bedroom size assignments on Vouchers shall be made according to the number of persons and relationship in the
household. Two persons shall be assigned to each bedroom/sleeping room in cases of children or adults cohabitating
and/or married.
The PHA will assign one bedroom for each two persons within the household,except in the following circumstances:
• Head of Household residing with an adult or minor child shall be allocated separate bedrooms resulting in a two-
bedroom Voucher. Head of Household who is residing with more than one adult or minor child under the age of 10
years old shall be allocated Voucher size allowing for two persons per bedroom and a separate bedroom for head of
household that includes spouse/cohabitant.
• In determining Voucher size for parent(s) including cohabitant,a separate bedroom shall be allocated for the head of
household/spouse/cohabitant and a separate bedroom for more than one adult or minor children of opposite sex age
10 years or older. Same sex adult or minor children shall be allocated one bedroom for each two persons.
Page 21 of 60
• Adding additional persons to the household shall not increase the voucher issuance until the annual recertification or
unit change, if needed, if adding the person does not overcrowd the current unit. The dwelling unit must have at least
one bedroom or living/sleeping room for each two persons
The City of Dubuque's minimum rent is$0.00.
The PHA will conduct interim reexaminations to account for any changes in household composition that occur between
annual reexaminations. Only the income/assets/deductions/allowances pertaining to the new household member will be
verified and utilized during the interim reexamination.
Grievance Procedures:
INFORMAL REVIEWS AND HEARINGS
OVERVIEW
Both applicants and participants have the right to disagree with, and appeal,certain decisions of the PHA that may
adversely affect them. PHA decisions that may be appealed by applicants and participants are discussed in thissection.
The process for applicant appeals of PHA decisions is called the "informal review." For participants (or applicantsdenied
admission because of citizenship issues), the appeal process is called an "informal hearing." PHAs are required to include
informal review procedures for applicants and informal hearing procedures for participants in their administrative plans
[24 CFR 982.54(d)(12) and(13)].
INFORMAL REVIEWS FORAPPLICANTS
Informal reviews are provided for program applicants.An applicant is someone who has applied for admission tothe
program, but is not yet a participant in the program. Informal reviews are intended to provide a "minimum hearing
requirement" [24 CFR 982.554], and need not be as elaborate as the informal hearing requirements [Federal Register60,
no. 127 (3 July 1995): 34690].
Decisions Subject to Informal Review
The PHA must give an applicant the opportunity for an informal review of a decision denying assistance [24 CFR
982.554(a)]. Denial of assistance may include any or all of the following[24 CFR 982.552(a)(2)]:
• Denying listing on the PHA waiting list
• Denying or withdrawing a voucher
• Refusing to enter a HAP contract or approve a lease
• Refusing to process or provide assistance under portability procedures
Informal reviews are not required for the following reasons [24 CFR982.554(c)]:
• Discretionary administrative determinations by the PHA
• General policy issues or class grievances
• A determination of the family unit size under the PHA subsidy standards
• A PHA determination not to approve an extension or suspension of a voucherterm
• A PHA determination not to grant approval of the tenancy
• A PHA determination that the unit is not in compliance with the HQS
• A PHA determination that the unit is not in accordance with the HQS due to family size orcomposition
The PHA will only offer an informal review to applicants for whom assistance is being denied. Denial ofassistance
includes: denying listing on the PHA waiting list; denying or withdrawing a voucher; refusing to enter into a HAPcontract
or approve a lease; refusing to process or provide assistance under portabilityprocedures.
Notice to the Applicant
The PHA must give an applicant prompt notice of a decision denying assistance.The notice must contain a brief statement
Page 22 of 60
of the reasons for the PHA decision, and must also state that the applicant may request an informal reviewof the
decision.The notice must describe how to obtain the informal review.
Any previous participant or applicant that had been determined to be ineligible for Assisted Housing that was notified in
writing of the reason for his/her ineligibility and of his/her right to request an Informal Review/Hearing shall beheld
accountable to the terms and time limits of the previous notice or decision letter.
Scheduling an Informal Review
A request for an informal review must be made in writing and delivered to the PHA either in person or by first class mail,
by the close of the business day, no later than 10 business days from the date of the PHA's denial ofassistance.
Exceptions for requesting an informal review in writing may be granted for limited English proficiency,disabled individuals
or for reasonable accommodations.
The PHA must schedule and send written notice of the informal review within 10 business days of the family's request.The
family may request to reschedule a review for good cause, or if it is needed as a reasonable accommodation fora person
with disabilities. Good cause is defined as an unavoidable conflict which seriously affects the health,safetyor welfare of
the family. Requests to reschedule a review must be made orally or in writing prior to the review date.Atits discretion,
the PHA may request documentation of the "good cause" prior to rescheduling thereview.
Upon notification in advance with at least 24 hours' notice on any party's unavailability to attend a scheduled review,the
review will be rescheduled one time only without justification of the need to reschedule.After the review has been
rescheduled, a request to reschedule a second time by the same party will only be considered for extremesituations.
Extreme situations may include but are not limited to hospitalization of self or household member,death in the family,
weather related restriction. Any notice of the inability of the applicant to attend the review must be provided within24
hours of the review along with third party verification of the situation.The review officer will have the sole discretion to
decide if the request is legitimate and with good cause.
Informal ReviewProcedures
The informal review must be conducted by a person other than the one who made or approved the decision under
review,or a subordinate of this person.
The applicant must be provided an opportunity to present written or oral objections to the decision of the PHA.
Informal ReviewDecision
The PHA must notify the applicant of the PHA's final decision, including a brief statement of the reasons for thefinal
decision.
In rendering a decision,the PHA will evaluate the following matters:
• If the grounds for denial were stated factually in the notice to the family.
• The validity of the grounds for denial of assistance. If the grounds for denial are not specified inthe regulations,then
the decision to deny assistance will be overturned.
• The validity of the evidence.The PHA will evaluate whether the facts presented prove the groundsfor denial of
assistance. If the facts prove that there are grounds for denial,and the denial is required by HUD, the PHA will uphold
the decision to denyassistance.
• If the facts prove the grounds for denial,and the denial is discretionary, the PHA will considerthe recommendation of
the person conducting the informal review in making the final decision whetherto deny assistance.
The PHA will notify the applicant of the final decision, including a statement explaining the reason(s)for the decision.The
notice will be mailed within 10 business days of the informal review,to the applicant and his or her representative, if any,
along with proof of mailing. If the decision to deny is overturned because of the informal review, processing for
Page 23 of 60
admission will resume. If the family fails to appear for their informal review, the denial of admission will stand and the
family will be notified.
INFORMAL HEARINGS FOR PARTICIPANTS
PHAs must offer an informal hearing for certain PHA determinations relating to the individual circumstances ofa
participant family.A participant is defined as a family that has been admitted to the PHA's HCV program and iscurrently
assisted in the program.The purpose of the informal hearing is to consider whether the PHA's decisions related tothe
family's circumstances are in accordance with the law, HUD regulations and PHA policies.
The PHA is not permitted to terminate a family's assistance until the time allowed for the family to request an informal
hearing has elapsed,and any requested hearing has been completed.Termination of assistance for a participant may
include any or all of the following:
• Refusing to enter a HAP contract or approve a lease
• Terminating housing assistance payments under an outstanding HAP contract
• Refusing to process or provide assistance under portability procedures
Decisions Subject to Informal Hearing
Circumstances for which the PHA must give a participant family an opportunity for an informal hearing are as follows:
• A determination of the family's annual or adjusted income, and the use of such income to compute thehousing
assistance payment
• A determination of the appropriate utility allowance (if any) for tenant-paid utilities from the PHA utilityallowance
schedule
• A determination of the family unit size under the PHA's subsidy standards
• A determination that a certificate program family is residing in a unit with a larger number of bedrooms than
appropriate for the family unit size under the PHA's subsidy standards, or the PHA determination to denythe
family's request for exception from the standards
• A determination to terminate assistance for a participant family because of the family's actions or failure toact
• A determination to terminate assistance because the participant has been absent from the assisted unit for longer
than the maximum period permitted under PHA policy and HUDrules
• A determination to terminate a family's Family Self Sufficiency contract, withhold supportive services,orpropose
forfeiture of the family's escrow account [24 CFR 984.303(i)]
Circumstances for which an informal hearing is not required are asfollows:
• Discretionary administrative determinations by the PHA
• General policy issues or class grievances
• Establishment of the PHA schedule of utility allowances for families in the program
• A PHA determination not to approve an extension or suspension of a voucherterm
• A PHA determination not to approve a unit or tenancy
• A PHA determination that a unit selected by the applicant is not in compliance with the HQS
• A PHA determination that the unit is not in accordance with HQS because of family size
• A determination by the PHA to exercise or not to exercise any right or remedy against an owner under a HAP
contract
The PHA will only offer participants the opportunity for an informal hearing when required to by the regulations.
Informal Hearing Procedures
Notice to the Family
When the PHA makes a decision subject to informal hearing procedures,the PHA must inform the family of its right to an
informal hearing at the same time that it informs the family of thedecision.
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For decisions related to the family's annual or adjusted income, the determination of the appropriate utilityallowance,
and the determination of the family unit size, the PHA must notify the family that they may ask for an explanation of the
basis of the determination,and that if they do not agree with the decision, they may request an informal hearing onthe
decision.
For decisions related to the termination of the family's assistance,or the denial of a family's request for an exceptionto
the PHA's subsidy standards, the notice must contain a brief statement of the reasons for the decision, a statementthat if
the family does not agree with the decision,the family may request an informal hearing on the decision, and a statement
of the deadline for the family to request an informalhearing.
In cases where the PHA makes a decision for which an informal hearing must be offered, the notice to the family will
include all the following:
• The proposed action or decision of the PHA.
• A brief statement of the reasons for the decision, including the regulatory reference.The date the
proposed action will take place.
• A statement of the family's right to an explanation of the basis for the PHA's decision.
• A statement that if the family does not agree with the decision the family may request an informal hearing of the
decision.
• A deadline for the family to request the informal hearing.To whom the
hearing request should be addressed.
• A copy of the PHA's hearing procedures or written explanation of hearing procedures.Withoutthis information, the
family will be unable to properly prepare for the hearing. Providing this informationas a matter of policy provides
assurance that the PHA has done all it can to inform the family of their rights and responsibilities in the hearing
process.
Scheduling an Informal Hearing
When an informal hearing is required,the PHA must proceed with the hearing in a reasonably expeditious mannerupon
the request of the family.
A request for an informal hearing must be made in writing and delivered to the PHA either in person or by firstclass mail,
by the close of the business day, no later than 10 business days from the date of the PHA's decision or noticeto
terminate assistance.
The PHA must schedule and send written notice of the informal hearing to the family within 10 business days of the
family's request.
The family may request to reschedule a hearing for good cause,or if it is needed as a reasonable accommodation fora
person with disabilities. Good cause is defined as an unavoidable conflict which seriously affects the health, safetyor
welfare of the family. Requests to reschedule a hearing must be made orally or in writing prior to the hearing date. At its
discretion, the PHA may request documentation of the "good cause" prior to rescheduling the hearing.
Upon notification in advance with at least 24 hours' notice on any party's unavailability to attend a scheduled hearing,
the hearing will be rescheduled one time only without justification of the need to reschedule.After the hearing has been
rescheduled a request to reschedule a second time by the same party will only be considered forextreme situations.
Extreme situations may include but are not limited to hospitalization of self or household member,death in the family,
weather related restriction. Any notice of the inability of the participant to attend the hearing must be provided within
24 hours of the hearing along with third party verification of the situation.The hearing officer will have the sole
discretion to decide if the request is legitimate and with good cause.
If the family does not appear at the scheduled time,and was unable to reschedule the hearing in advance due tothe
Page 25 of 60
nature of the conflict,the family must contact the PHA within 24 hours of the scheduled hearing date,excluding
weekends and holidays.The PHA will reschedule the hearing only if the family can show good cause for the failure to
appear, or if it is needed as a reasonable accommodation for a person with disabilities.
Pre-Hearing Right to Discovery
Participants and the PHA are permitted pre-hearing discovery rights.The family must be given the opportunityto examine
before the hearing any PHA documents that are directly relevant to the hearing.The family must be allowed to copy any
such documents at their own expense. If the PHA does not make the document available for examinationon request of
the family,the PHA may not rely on the document at the hearing.
The PHA hearing procedures may provide that the PHA must be given the opportunity to examine at the PHA offices
before the hearing,any family documents that are directly relevant to the hearing.The PHA must be allowed tocopy any
such document at the PHA's expense. If the family does not make the document available for examinationon request of
the PHA,the family may not rely on the document at thehearing.
For informal hearings,documents include records and regulations. The family will be allowed to copy any documents
related to the hearing. The family must request discovery of PHA documents no later than 12:00 p.m.on the business day
prior to the scheduled hearing date.
The PHA must be given an opportunity to examine at the PHA offices before the hearing any family documents that are
directly relevant to the hearing.Whenever a participant requests an informal hearing, the PHA will automatically maila
letter to the participant requesting a copy of all documents that the participant intends to present or utilize atthe
hearing.The participant must make the documents available no later than 12:00 pm on the business day prior tothe
scheduled hearingdate.
ParticipanYs Right to Bring Counsel
At its own expense,the family may be represented by a lawyer or other representative at the informalhearing.
Informal HearingOfficer
Informal hearings will be conducted by a person or persons approved by the PHA, other than the person who madeor
approved the decision or a subordinate of the person who made or approved thedecision.
The PHA has designated the following to serve as hearingofficers:
• Director of the PHA or his/her designated individual including the Assisted Housing Supervisor
Attendance at the Informal Hearing
Hearings may be attended by a hearing officer and the following applicable persons:
• A PHA representative(s) and any witnesses for the PHA
• The participant and any witnesses for the participant
• The participanYs counsel or other representative
• Any other person approved by the PHA as a reasonable accommodation for a person with adisability
• Any person attending the hearing as an interpreter due to a disability or Limited English Proficiency
Conduct at Hearings
The person who conducts the hearing may regulate the conduct of the hearing in accordance with the PHA's hearing
procedures. The hearing officer is responsible to manage the order of business and to ensure that hearings are
conducted ina professional and businesslike manner.Attendees are expected to comply with all hearing procedures
established by the hearing officer and guidelines for conduct. Any person demonstrating disruptive, abusive or otherwise
inappropriate behavior will be excused from the hearing at the discretion of the hearingofficer.
Evidence
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The PHA and the family must be given the opportunity to present evidence and question any witnesses. In general,all
evidence is admissible at an informal hearing. Evidence may be considered without regard to admissibility underthe
rules of evidence applicable to judicial proceedings. Any evidence to be considered by the hearing officer must be
presented at the time of the hearing.There are four categories of evidence.
• Oral evidence: the testimony ofwitnesses
• Documentary evidence: a writing which is relevant to the case,for example,a letter written to the PHA. Writings
include all forms of recorded communication or representation, including letters,words, pictures,sounds, videotapes
or symbols or combinationsthereof.
• Demonstrative evidence: Evidence created specifically for the hearing and presented as anillustrative aid to assist the
hearing officer, such as a model,a chart or otherdiagram.
• Real evidence: A tangible item relating directly to the case.
Hearsay Evidence is evidence of a statement that was made other than by a witness while testifying at the hearingand
that is offered to prove the truth of the matter. Even though evidence, including hearsay, is generallyadmissible, hearsay
evidence alone cannot be used as the sole basis for the hearing officer's decision.
If either the PHA or the family fail to comply with the discovery requirements described above,the hearing officer will
refuse to admit such evidence.
Other than the failure of a party to comply with discovery,the hearing officer has the authority to overrule any
objections to evidence.
Hearing O�cer's Decision
The person who conducts the hearing must issue a written decision,stating briefly the reasons for the decision.Factual
determinations relating to the individual circumstances of the family must be based on a preponderance ofevidence
presented at the hearing.A copy of the hearing decision must be furnished promptly to thefamily.
In rendering a decision,the hearing officer will consider the followingmatters:
• PHA Notice to the Family:The hearing officer will determine if the reasons for the PHA's decision are factually stated
in the Notice.
• Discovery:The hearing officer will determine if the PHA and the family were given the opportunity to examine any
relevant documents in accordance with PHA policy.
• PHA Evidence to Support the PHA Decision:The evidence consists of the facts presented. Evidence is not conclusion
and it is not argument.The hearing officer will evaluate the facts to determine ifthey support the PHA's conclusion.
• Validity of Grounds forTermination of Assistance(when applicable):The hearing officer will determine if the
termination of assistance is for one of the grounds specified in the HUD regulations and PHA policies. If the grounds
for termination are not specified in the regulations or in compliance with PHA policies,then the decision of the PHA
will beoverturned.
The hearing officer will issue a written decision to the family and the PHA no later than 10 business days after the
hearing.The report will contain the following information:
• Hearing information:
Name of the participant;
Date,time and place of the hearing;
Name of the hearing officer;
Name of the PHA representative;and
Name of family representative (ifany).
• Background: A brief, impartial statement of the reason for the hearing.
• Summary of the Evidence:The hearing officer will summarize the testimony of each witnessand identify any
documents that a witness produced in support of his/her testimony and that areadmitted into evidence.
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• Findings of Fact:The hearing officer will include all findings of fact, based on a preponderance ofthe evidence.
Preponderance of the evidence is defined as evidence which is of greater weight or more convincing than the evidence
which is offered in opposition to it; that is, evidence which as awhole shows that the fact sought to be proved is more
probable than not. Preponderance of the evidencemay not be determined by the number of witnesses, but by the
greater weight of all evidence.
• Conclusions:The hearing officer will render a conclusion derived from the facts that were found to be true by a
preponderance of the evidence.The conclusion will result in a determination of whetherthese facts uphold the PHA's
decision.
• Order:The hearing report will include a statement of whether the PHA's decision is upheld or overturned. If it is
overturned,the hearing officer will instruct the PHA to change the decision in accordance with the hearing officer's
determination. In the case of termination of assistance,the hearing officer will instruct the PHA to restore the
participanYs program status.
Procedures for Rehearing or Funher Hearing
The hearing officer may ask the family for additional information and/or might adjourn the hearing to reconvene at a
later date, before reaching a decision. If the family misses an appointment or deadline ordered bythe hearing officer,
the action of the PHA will take effect and another hearing will not begranted.
Considerations
In making its decision to terminate assistance,the PHA will consider alternatives such as:
As a condition of continued assistance, the PHA may require that any household member who participated in or was
responsible for an offense no longer resides in the unit. The head of household must certify that the culpable family
member has vacated the unit and will not be permitted to visit or to stay as a guest in the assisted unit.The family must
present evidence of the former family member's current address upon PHA request.
If a family owes amounts to the PHA, as a condition of continued assistance,the PHA will require the family to repay the full
amount or to enter into a repayment agreement, within 30 days of receiving notice from the PHA of the amount owed.
For criminal activity, HUD permits the PHA to terminate assistance if a preponderance of the evidence indicates that a
household member has engaged in the activity, regardless of whether the household member has been arrested or
convicted. The PHA will use the concept of the preponderance of the evidence as the standard for making all
termination decisions.
Preponderance of the evidence is defined as evidence which is of greater weight or more convincing than the evidence
which is offered in opposition to it; that is, evidence which as a whole show that the fact sought to be proved is more
probable than not. Preponderance of the evidence may not be determined by the number of witnesses, but by the
greater weight of all evidence
The PHA will consider the circumstances when deciding whether to terminate assistance. When considering the
circumstances and reviewing alternative choices to termination of assistance,two staff inembers,one staff consisting
of an FSS Coordinator or Circles� Initiative staff,will meet to make the decision prior to proposal of termination to
consider whether there are other alternatives that can be presented.
The PHA will consider the following factors when making its decision to terminate assistance:
• The seriousness of the case, especially with respect to how it would affect other residents
• The effects that termination of assistance may have on other members of the family who were not involved in the
action or failure to act
Page 28 of 60
• The extent of participation or culpability of individual family members, including whether the culpable family member is
a minor or a person with disabilities or a victim of domestic violence, dating violence, sexual assault or stalking
• The length of time since the violation occurred,the family's recent history and the likelihood of favorable conduct in
the future
In the case of drug or alcohol abuse,whether the culpable household member is participating in or has successfully
completed a supervised drug or alcohol rehabilitation program or has otherwise been rehabilitated successfully. The PHA
will require the participant to submit evidence of the household member's current participation in or successful completion
of a supervised drug or alcohol rehabilitation program,or evidence of otherwise having been rehabilitated successfully.
In the case of program abuse,the dollar amount of the overpaid assistance and whether or not a false certification was
signed by the family.
In the case of non-compliance with HQS by the family, consideration will include whether the non-compliance consists of
safety, life threatening conditions and/or if the family has submitted a plan of action to correct the deficiency.
Reasonable Accommodation
If the family includes a person with disabilities, the PHA's decision to terminate the family's assistance is subject to
consideration of reasonable accommodation in accordance with 24 CFR Part 8. If a family indicates that the behavior of a
family member with a disability is the reason for a proposed termination of assistance, the PHA will determine whether the
behavior is related to the disability. If so, upon the family's request, the PHA will determine whether alternative measures
are appropriate as a reasonable accommodation.The PHA will only consider accommodations that can reasonably be
expected to address the behavior that is the basis of the proposed termination of assistance.
Upon consideration of such alternatives and factors,the PHA may,on a case-by-case basis,choose not to terminate
assistance.
PHA Notice of Final Decision
The PHA is not bound by the decision of the hearing officer for matters in which the PHA is not required to provide an
opportunity for a hearing,decisions that exceed the authority of the hearing officer,decisions that conflict with or
contradict HUD regulations, requirements,or are otherwise contrary to federal,state, or local laws. If the PHA determines
it is not bound by the hearing officer's decision in accordance with HUD regulations, the PHA must promptly notify the
family of the determination and the reason for thedetermination.
The PHA will mail a "Notice of Final Decision" including the hearing officer's report to the participant and their
representative.This notice will be sent by first-class mail, postage pre-paid.The participant will be mailed theoriginal
"Notice of Final Decision".A copy of the "Notice of Final Decision" will be maintained in the PHA'sfile.
HEARING AND APPEAL PROVISIONS FORNONCITIZENS
Denial or termination of assistance based on immigration status is subject to special hearing and notice rules.Applicants
who are denied assistance due to immigration status are entitled to an informal hearing, not an informal review.
Assistance to a family may not be delayed,denied,or terminated based on immigration status at any time prior to a
decision under the United States Citizenship and Immigration Services (USCIS) appeal process. Assistance to afamily may
not be terminated or denied while the PHA hearing is pending, but assistance to an applicant may bedelayed pending
the completion of the informal hearing.
A decision against a family member, issued in accordance with the USCIS appeal process or the PHA informal hearing
process,does not preclude the family from exercising the right,that may otherwise be available,to seek redress directly
through judicial procedures.
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Notice of Denial or Termination ofAssistance for Noncitizens
The notice of denial or termination of assistance for noncitizens must advise thefamily:
• That financial assistance will be denied or terminated,and provide a brief explanation of the reasons for the proposed
denial or termination of assistance.
• The family may be eligible for proration ofassistance.
• In the case of a participant,the criteria and procedures for obtaining relief under the provisions for preservationof
families [24 CFR 5.514 and 5.518].
• That the family has a right to request an appeal to the USCIS of the results of secondary verification ofimmigration
status and to submit additional documentation or explanation in support of theappeal.
• That the family has a right to request an informal hearing with the PHA either upon completion of the USCIS appeal or
in lieu of the USCIS appeal.
• For applicants, assistance may not be delayed until the conclusion of the
USCIS appeal process, but assistance maybe delayed during the period of the
informal hearingprocess.
USCIS Appeal Process
When the PHA receives notification that the USCIS secondary verification failed to confirm eligible immigrationstatus,the
PHA must notify the family of the results of the USCIS verification.The family will have 30 days from the date of the
notification to request an appeal of the USCIS results.The request for appeal must be made by the family in writing
directly to the USCIS.The family must provide the PHA with a copy of the written request for appeal and the proofof
mailing.
The PHA will notify the family in writing of the results of the USCIS secondary verification within 10 business daysof
receiving the results.
The family must provide the PHA with a copy of the written request for appeal and proof of mailing within 10 business
days of sending the request to the USCIS.
The family must forward to the designated USCIS office any additional documentation or written explanation insupport of
the appeal.This material must include a copy of the USCIS document verification request (used to processthe secondary
request) or such other form specified by the USCIS, and a letter indicating that the family is requesting an appeal of the
USCIS immigration status verification results.
The USCIS will notify the family,with a copy to the PHA, of its decision.When the USCIS notifies the PHA of thedecision,
the PHA must notify the family of its right to request an informal hearing.
The PHA will send written notice to the family of its right to request an informal hearing within 10 business days of
receiving notice of the USCIS decision regarding the family's immigration status.
Informal Hearing Procedures forApplicants
After notification of the USCIS decision on appeal, or in lieu of an appeal to the USCIS, the family may request thatthe
PHA provide a hearing.The request for a hearing must be made either within 30 days of receipt of the PHA notice of
denial,or within 30 days of receipt of the USCIS appeal decision.
The informal hearing procedures for applicant families are described below.
Informal HearingOfficer
The PHA must provide an informal hearing before an impartial individual,other than a person who made orapproved the
decision under review,and other than a person who is a subordinate of the person who made or approvedthe decision.
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Evidence
The family must be provided the opportunity to examine and copy at the family's expense,at a reasonable timein
advance of the hearing,any documents in the possession of the PHA pertaining to the family's eligibility status, or inthe
possession of the USCIS (as permitted by USCIS requirements), including any records and regulations that maybe relevant
to the hearing.
The family will be allowed to copy any documents related to the hearing.The family must request discovery of PHA
documents no later than 12:00 p.m.on the business day prior to the hearing.
The family must be provided the opportunity to present evidence and arguments in support of eligible status. Evidence
may be considered without regard to admissibility under the rules of evidence applicable to judicial proceedings.
The family must also be provided the opportunity to refute evidence relied upon by the PHA, and to confront andcross-
examine all witnesses on whose testimony or information the PHA relies.
Representation and Interpretive5ervices
The family is entitled to be represented by an attorney or other designee,at the family's expense, and to have such
person make statements on the family's behalf.
The family is entitled to arrange for an interpreter to attend the hearing, at the expense of the family,or the PHA,as may
be agreed upon by the two parties.
Recording of the Hearing
The family is entitled to have the hearing recorded by audiotape.The PHA may, but is not required to provide a transcript of
the hearing. The PHA will not provide a transcript of an audio taped hearing.
Hearing Decision
The PHA must provide the family with a written final decision, based solely on the facts presented at the hearing,within
14 calendar days of the date of the informal hearing.The decision must state the basis for the decision.
Informal Hearing Procedures for Participants
After notification of the USCIS decision on appeal, or in lieu of an appeal to the USCIS,the family may request thatthe
PHA provide a hearing.The request for a hearing must be made either within 30 days of receipt of the PHA notice of
termination,or within 30 days of receipt of the USCIS appeal decision.
For the informal hearing procedures that apply to participant families whose assistance is being terminated based on
immigration status.
Retention of Documents
The PHA must retain for a minimum of 5 years the following documents that may have been submitted to the PHA by the
family, or provided to the PHA as part of the USCIS appeal or the PHA informal hearingprocess:
• The application for assistance
• The form completed by the family for income reexamination
• Photocopies of any original documents, including original USCIS documents
• The signed verification consent form
• The USCIS verification results
• The request for a USCIS appeal
• The final USCIS determination
• The request for an informal hearing
• The final informal hearing decision
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HOMEOWNERSHIP
Overview
The homeownership option is used to assist a family residing in a home purchased and owned by one or more members
of the family. A family assisted under this option may be newly admitted or an existing participant in the HCV program.
The PHA must have the capacity to operate a successful HCV homeownership program as defined by the regulations.
There are two forms of homeownership assistance a PHA may offer under this option: monthlyhomeownership
assistance payments,or a single down payment assistance grant. PHAs may choose to offer either or both formsof
homeownership assistance, or choose not to offer either. If a PHA offers both forms of assistance,a family must choose
which form of assistance to receive.
The PHA must offer either form of homeownership assistance if needed as a reasonable accommodation so that the
program is readily accessible to and usable by persons with disabilities. It is the sole responsibility of the PHAto determine
whether it is reasonable to implement a homeownership program as a reasonable accommodation.The PHA must
determine what is reasonable based on the specific circumstances and individual needs of the person witha disability.The
PHA may determine that it is not reasonable to offer homeownership assistance as a reasonable accommodation in cases
where the PHA has otherwise opted not to implement a homeownership program.
The PHA must approve a live-in aide if needed as a reasonable accommodation so that the program is readilyaccessible to
and usable by persons with disabilities.
The PHA will offer the monthly homeownership assistance payments to qualifiedfamilies.
The Housing Choice Voucher Home Ownership Program permits eligible participants in the HCV Program,including
participants with portable vouchers, the option of purchasing a home with their voucher assistance rather than renting.
The home ownership option is available to newly admitted or existing participants, who do not owe monies to the City of
Dubuque Housing Services or any other Housing Agency for any outstanding debts, and who meet theeligibility criteria
set forth below.Additionally, participants who are in violation of their family obligations while receiving HCV assistance
shall be ineligible for participation in the Housing Choice Voucher Home Ownership Program.
HCV home ownership assistance may be used to purchase the following type of homes within the City of Dubuque:new or
existing single-family dwelling unit,condominium, cooperatives,or manufactured homes.The City ofDubuque Housing
will also permit portability of HCV home ownership assistance to another jurisdiction, provided thereceivingjurisdiction
operates a HCV home ownership program for which the participantqualifies.
FAMILY ELIGIBILITY
The family must meet all the requirements listed below before the commencement of homeownership assistance.The
PHA may also establish additional initial requirements if they are described in the PHA administrative plan.
• The family must have been admitted to the Housing Choice Voucher program.
• The family must qualify as afirst-time homeowner, or may be a cooperative member.
• The family must meet the Federal minimum income requirement.The family must have a gross annual income equal
to the Federal minimum wage multiplied by 2000, based on the income of adult family members who will own the
home.The PHA may establish a higher income standard for families. However,a family that meets the federal
minimum income requirement (but not the PHA's requirement) will be considered to meet the minimum income
requirement if it can demonstrate that it has been pre-qualified or pre-approved for financingthat is sufficient to
purchase an eligible unit.
• For disabled families, the minimum income requirement is equal to thecurrent SSI monthly payment for an individual
living alone, multiplied by 12.
• For elderly or disabled families,welfareassistance payments for adult family members who will own the home will be
included in determining whether the familymeets the minimum income requirement. It will not be included for other
Page 32 of 60
families.
• The family must satisfy theemployment requirements by demonstrating that one or more adult members of the
family who will own the homeat commencement of homeownership assistance is currently employed on a full-time
basis (the term'full-time employmenY means not less than an average of 30 hours per week); and has been
continuously so employed duringthe year before commencement of homeownership assistance for the family.
• The employment requirement does notapply to elderly and disabled families. In addition, if a family, other than an
elderly or disabled family includes a personwith disabilities, the PHA must grant an exemption from the employment
requirement if the PHA determines that it is needed as a reasonable accommodation.
• The family has not defaulted on a mortgage securing debt to purchase a home under the homeownership option.
• Except for cooperative members who have acquired cooperative membershipshares prior to commencement of
homeownership assistance, no family member has a present ownership interest in a residence at the commencement
of homeownership assistance for the purchase of any home.
• Except forcooperative members who have acquired cooperative membership shares prior to the commencement of
homeownership assistance, the family has entered a contract of sale in accordance with 24 CFR982.631(c).
The PHA will not establish a higher minimum income standard for disabled and/or non-disabledfamilies.
The family must be financially capable to qualify for HA approved financing of the home and must be financially capable to
provide at least 3%of the purchase price as a minimum homeowner down payment.The City of Dubuque Rehabilitation
Activity shall review lender qualifications and the loan terms before authorizing homeownership assistance.
The PHA requires that financing for purchase of a home under its HCV homeownership program complieswith secondary
mortgage market underwriting requirements; or complies with generally accepted privatesector underwriting standards.
Each family,except families with a disabled member, must be a first-time homeowner. A first-time homeowner means
that no member of the household has had an ownership interest in any residence during the three years prior tothe
home ownership assistance. However,a single parent or displaced homemaker who,while married, owned a home with a
spouse (or resided in a home owned by a spouse) is considered a first-time home owner for purposes of the Housing
Choice Voucher Home Ownership Program.
The Housing and Community Development Director may also consider whether and to what extent anemployment
interruption is considered permissible in satisfying the employment requirement. Generally, families will be considered
"continuously employed" if the break in employment does not exceed two months.The Housing and Community
Development Director may also consider self-employment to determine employment history.Theemployment requirement
does not apply to an elderly or disabled family. To reasonably accommodate afamily's participation in the program,
families that include a person with disabilities may also be exempt from this requirement if an exemption in needed as a
reasonable accommodation.
Participants in the Housing Choice Voucher Program shall be ineligible for participation in the Home Ownership Program if
any debt or portion of a debt remains owed to the City of Dubuque or any other Housing Authority. Additionally,
participants who are in violation of their family obligations while receiving HCV assistance shall be ineligiblefor participation
in the Home Ownership Program.
If the head of household, spouse,or other adult household member who will execute the contract of sale, mortgageand
loan documents has previously defaulted on a mortgage obtained through the HCV Home Ownership Program,the family
will be ineligible to participate in the Home Ownership Program.
SELECTION OF FAMILIES
Unless otherwise provided (under the homeownership option),the PHA may limit homeownership assistance tofamilies
or purposes defined by the PHA, and may prescribe additional requirements for commencement ofhomeownership
assistance for a family. Any such limits or additional requirements must be described in the PHA administrativeplan.
Page 33 of 60
If the PHA limits the number of families that may participate in the homeownership option,the PHA must establish a
system by which to select families to participate.
ELIGIBLE UNITS
For a unit to be eligible,the PHA must determine that the unit satisfies all the followingrequirements:
• The unit must meet HUD's"eligible housing" requirements.The unit may not be any of the following:
- A public housing or Indian housing unit;
- A unit receiving Section 8 project-based assistance;
- A nursing home, board and care home,or facility providing continual psychiatric, medical or nursingservices;
- A college or other school dormitory;
- On the grounds of penal, reformatory, medical, mental, or similar public or private institutions.
• The unit must be under construction or already exist at the time the family enters the contract ofsale.
• The unit must be a one-unit property or a single dwelling unit in a cooperative orcondominium.
• The unit must have been inspected by the PHA and by an independent inspector designated by thefamily.
• The unit must meet Housing Quality Standards (see Chapter 8).
• For a unit where the family will not own fee title to the real property (such as a manufactured home),the home
must have a permanent foundation and the family must have the right to occupy the site for at least 40 years.
• For PHA-owned units all the following conditions must be satisfied:
- The PHA informs the family, both orally and in writing, that the family has the right to purchase any eligibleunit
and a PHA-owned unit is freely selected by the family without PHA pressure orsteering;
- The unit is not ineligible housing;
- The PHA obtains the services of an independent agency to inspect the unit for compliance with HQS, reviewthe
independent inspection report, review the contract of sale, determine the reasonableness of the sales price and
any PHA provided financing.These actions must be completed in accordance with program requirements.
The PHA must not approve the unit if the PHA has been informed that the seller is debarred,suspended,or subject to a
limited denial of participation.
ADDITIONAL PHA REQUIREMENTS FOR SEARCH AND PURCHASE
It is the family's responsibility to find a home that meets the criteria for voucher homeownership assistance.The PHA
may establish the maximum time that will be allowed for a family to locate and purchase a home,and may require the
family to report on their progress in finding and purchasing a home. If the family is unable to purchase a homewithin the
maximum time established by the PHA,the PHA may issue the family a voucher to lease a unit or place thefamily's name
on the waiting list for a voucher.
The family will be allowed 120 days to identify a unit and submit a sales contract to the PHA for review.The family will be
allowed an additional 120 days to close on the home. PHAs may grant extensions to either ofthese periods for good
cause.The length of the extension(s) will be determined on a case-by-case, but in no casewill an extension exceed a total
of 125 days.The maximum amount of time a family will be given to locateand complete the purchase of a home under
the homeownership option is 365 days.
During these periods, the family will continue to receive HCV rental assistance in accordance with anyapplicable lease
and HAP contract until the family vacates the rental unit for its purchased home.The family will be required to report
their progress on locating and purchasing a home to the PHA every 30 days until the homeis purchased.
All requests for extensions must be submitted in writing to the PHA prior to the expiration of the periodfor which the
extension is being requested.The PHA will approve or disapprove the extension request within 10 business days.The
family will be notified of the PHA's decision in writing.
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If the family cannot complete the purchase of a unit within the maximum required time frame and isnot receiving rental
assistance under a HAP contract at the time the search and purchase time period expires,the family will be issued a
voucher to lease a unit.
HOMEOWNERSHIP COUNSELING
Before commencement of homeownership assistance for a family, the family must attend and satisfactorily complete
the pre-assistance homeownership and housing counseling program required by the PHA. HUD suggests the following
topics for the PHA-required pre-assistancecounseling:
• Home maintenance (including care of the grounds);
• Budgeting and money management;
• Credit counseling;
• How to negotiate the purchase price of a home;
• How to obtain homeownership financing and loan pre-approvals, including a description of types of financingthat
may be available,and the pros and cons of different types offinancing;
• How to find a home, including information about homeownership opportunities, schools, and transportation inthe
PHAjurisdiction;
• Advantages of purchasing a home in an area that does not have a high concentration of low-income familiesand
how to locate homes in such areas;
• Information on fair housing, including fair housing lending and local fair housing enforcement agencies;and
• Information about the Real Estate Settlement Procedures Act(12 U.S.C. 2601 et seq.) (RESPA),state and Federal
truth-in-lending laws, and how to identify and avoid loans with oppressive terms and conditions.
The PHA may adapt the subjects covered in pre-assistance counseling(as listed) to local circumstances and the needs of
individual families.
The PHA may also offer additional counseling after commencement of homeownership assistance (ongoingcounseling).
If the PHA offers a program of ongoing counseling for participants in the homeownership option, the PHA shall have
discretion to determine whether the family is required to participate in the ongoingcounseling.
If the PHA does not use a HUD-approved housing counseling agency to provide the counseling, the PHA should ensure that
its counseling program is consistent with the counseling provided under HUD's Housing Counseling program.
A family's participation in the home ownership program is conditioned on the family attending and successfully
completing a home ownership and housing counseling program approved by the PHA prior to commencement of home
ownership assistance.
HOME INSPECTIONS, CONTRACT OF SALE,AND PHA DISAPPROVAL OFSELLER
Home Inspections
The PHA may not commence monthly homeownership assistance payments or provide down payment assistancegrants
for a family until the PHA has inspected the unit and has determined that the unit passes HQS.
An independent professional inspector selected by and paid for by the family must also inspect the unit.The
independent inspection must cover major building systems and components, including foundation and structure, housing
interior and exterior,and the roofing, plumbing, electrical, and heating systems.The independent inspector must be
qualified to report on property conditions, including major building systems andcomponents.
The PHA may not require the family to use an independent inspector selected by the PHA. The independentinspector
may not be a PHA employee or contractor, or other person under control of the PHA. However, the PHA may establish
standards for qualification of inspectors selected by families under the homeownershipoption.
The PHA may disapprove a unit for assistance based on information in the independent inspector's report,even ifthe unit
was found to comply with HQS.
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The unit must be inspected by a PHA inspector and pass inspection per the City of Dubuque Housing Code. The unit must
be inspected by an independent inspector and incipient code violations identified by theindependent inspector.
To assure the home complies with the City of Dubuque Housing Code, home ownership assistance payments mustnot
commence until the PHA has inspected and approved the home.Another inspection must also be completed bya
professional home inspector selected by the family and approved by the PHA.The independent inspection mustcover
major building systems and components, including foundation and structure, housing interior and exterior,andthe
roofing, plumbing, electrical, and heating systems.The independent inspector must be qualified to report on property
conditions, including major building systems.The independent inspector may not be a PHA employee or contractor,or
other person under control of the PHA.The independent inspector must provide a copy of the inspection report both to
the family and to the PHA.The PHA may not pay any Home ownership assistance for the family until the PHAhas reviewed
the inspection report of the independent inspector. Even if the unit otherwise complies with the Cityof Dubuque Housing
Code,the PHA shall have discretion to disapprove the unit for assistance under the Homeownership program because of
information in the inspection report.
Contract of Sale
Before commencement of monthly homeownership assistance payments or receipt of a down payment assistance grant,a
member or members of the family must enter a contract of sale with the seller of the unit to be acquired bythe family.
The family must give the PHA a copy of the contract of sale.The contract of sale must:
• Specify the price and other terms of sale by the seller to the purchaser;
• Provide that the purchaser will arrange for a pre-purchase inspection of the dwelling unit by an independent
inspectorselected bythe purchaser;
• Provide that the purchaser is not obligated to purchase the unit unless the inspection is satisfactory tothe
purchaser;
• Provide that the purchaser is not obligated to pay for any necessary repairs;and
• Contain a certification from the seller that the seller has not been debarred,suspended, or subject to a limited
denial of participation under CFR part 24.
Prior to execution of the offer to purchase or sales agreement,the financing terms must be provided by the family to the
City of Dubuque Rehabilitation Activity for approval. The purchase or sales agreement must provide for inspection by the
PHA and the independent inspector and must state that the purchaser is not obligated to purchase unlessthe inspections
are satisfactory to the PHA.The purchase or sales agreement must provide that the purchaser isnot obligated to purchase
if the mortgage financing terms are not approved by the PHA. A copy of the purchase orsales agreement must be
submitted to the City of Dubuque Rehabilitation Activity forapproval.
Disapproval of a Seller
In its administrative discretion,the PHA may deny approval of a seller for the same reasons a PHA may disapprove an
owner under the regular HCV program [see 24 CFR982.306(c)].
FINANCING
The PHA may establish requirements for financing purchase of a home under the homeownership option.Thismay
include requirements concerning qualification of lenders,terms of financing, restrictions concerning debt secured bythe
home, lender qualifications, loan terms, and affordability of the debt.The PHA must establish policies describingthese
requirements in the administrative plan.
A PHA may not require that families acquire financing from one or more specified lenders, thereby restrictingthe family's
ability to secure favorable financing terms.
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The proposed financing terms must be submitted to and approved by the City of Dubuque Rehabilitation Activity prior to
close of the financing.The Rehabilitation Activity shall determine the affordability of the family's proposed financing. In
making such determination,the Rehabilitation Activity may consider other family expenses, including butnot limited to
child care, unreimbursed medical expenses, and other outstanding debts.Certain types of financing,including but not
limited to, balloon payment mortgages, are prohibited and will not be approved.Seller-financed mortgages through land
contracts shall not be approved. Seller-financed mortgages through person-to-person mortgages will be considered on a
case by case basis. If a mortgage is not FHA-insured,the PHA will require the lender to complywith generally accepted
mortgage underwriting standards consistent with those of HUD/FHA,Ginnie Mae, Fannie Mae, Freddie Mac, the Federal
Home Loan Bank, or other private lending institutions.The PHA may disapprove proposed financing, refinancing or other
debit if it is determined that the debt is unaffordable,or if the lender or the loan terms do not meet the qualifications as
set forth by the PHA.The buyer must be capable of providing at least 3%of the purchase price for the down payment.
CONTINUED ASSISTANCE REQUIREMENTS; FAMILYOBLIGATIONS
Homeownership assistance may only be paid while the family is residing in the home. If the family moves out ofthe home,
the PHA may not continue homeownership assistance after the month when the family moves out.The family or lender is
not required to refund to the PHA the homeownership assistance for the month when the family movesout.
Before commencement of homeownership assistance, the family must execute a statement in which the family agrees to
comply with all family obligations under the homeownershipoption.
The family must comply with the followingobligations:
• The family must comply with the terms of the mortgage securing debt incurred to purchase the home,or any
refinancing of such debt.
• The family may not convey or transfer ownership of the home, except for purposes of financing, refinancing, or
pending settlement of the estate of a deceased family member. Use and occupancy of the home are subjectto 24 CFR
982.551 (h) and (i).
• The family must supply information to the PHA or HUD as specified in 24 CFR 982.551(b).The family must further
supply any information required by the PHA or HUD concerning mortgage financing or refinancing,sale or transfer
of any interest in the home, or homeownership expenses.
• The family must notify the PHA before moving out of the home.
• The family must notify the PHA if the family defaults on the mortgage used to purchase thehome.
• No family member may have any ownership interest in any other residential property.
• The family must comply with the obligations of a participant family described in 24 CFR 982.551, except for the
following provisions which do not apply to assistance under the homeownership option: 24 CFR 982.551(c),(d), (e),
(f), (g) and (j).
Before each annual recertification during the next two years,the home will be inspected by a PHA inspector per City of
Dubuque Housing Code and must pass inspection to continue receiving home ownership assistance. If thePHA determines
there are problems with maintaining the home in a safe and decent manner,the Housing and Community Development
Director may require on-going inspections annually for the next fiveyears.
A family must agree, in writing,to comply with all family obligations under the HCV Program and the PHA'shome
ownership policies.These obligations include (1) attending ongoing home ownership counseling, if required bythe PHA;
(2) complying with the mortgage terms; (3) not selling or transferring the home to anyone other than a member of the
assisted family who resides in the home while receiving home ownership assistance and whois approved by the PHA; (4)
not refinancing or adding debt secured by the home without prior approval by the PHA;(5) not obtaining a present
ownership interest in another residence while receiving home ownership assistance;(6) supplying all required information
to the PHA, including but not limited to annual verification of household income, notice of change in home ownership
expenses, notice of move-out, and notice of mortgage default; (7)allowing inspections of the home and maintaining the
unit in a decent and safe manner; and (8) repairing any incipientcode violations identified from the independent
inspector's report within six (6) months ofownership.
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MAXIMUM TERM OF HOMEOWNERASSISTANCE
Except in the case of a family that qualifies as an elderly or disabled family, other family members (describedbelow) shall
not receive homeownership assistance for more than:
• Fifteen years, if the initial mortgage incurred to finance purchase of the home has a term of 20 years or longer;or
• Ten years, in all other cases.
The maximum term described above applies to any member of the familywho:
• Has an ownership interest in the unit during the time that homeownership payments are made;or
• Is the spouse of any member of the household who has an ownership interest in the unit during thetime
homeownership payments are made.
In the case of an elderly family,the exception only applies if the family qualifies as an elderly family at the start of
homeownership assistance. In the case of a disabled family,the exception applies if at any time during receiptof
homeownership assistance the family qualifies as a disabled family.
If,during homeownership assistance,the family ceases to qualify as a disabled or elderly family,the maximum term
becomes applicable from the date homeownership assistance commenced. However,such a familymust be provided at
least 6 months of homeownership assistance after the maximum term becomes applicable (providedthe family is
otherwise eligible to receive homeownershipassistance).
If the family has received such assistance for different homes,or from different PHAs,the total of such assistance terms is
subject to the maximum term described in this part.
HOMEOWNERSHIP ASSISTANCE PAYMENTS AND HOMEOWNERSHIPEXPENSES
The monthly homeownership assistance payment is the lower of: the voucher payment standard minus the total tenant
payment, or the monthly homeownership expenses minus the total tenant payment.
In determining the amount of the homeownership assistance payment,the PHA will use the same paymentstandard
schedule, payment standard amounts, and subsidy standards as those described elsewhere in this plan for the Housing
Choice Voucher program.The payment standard for a family is the greater of(i)The payment standard as determined at
the commencement of homeownership assistance for occupancy of the home,or (ii)The payment standard at the most
recent regular reexamination of family income and composition since the commencement of homeownershipassistance
for occupancy of the home.
The PHA's housing assistance payment will be paid directly to the lender unless the mortgage company refuses to accept
payments from more than one source. In such case, the PHA's housing assistance payment will be paid directly tothe
family. If the assistance payment exceeds the amount due to the lender,the PHA must pay the excess directly tothe
family.
Homeownership assistance for a family terminates automatically 180 calendar days after the last homeownership
assistance payment on behalf of the family. However, a PHA may grant relief from this requirement in thosecases
where automatic termination would result in extreme hardship for thefamily.
The PHA must adopt policies for determining the amount of homeownership expenses to be allowed by the PHA in
accordance with HUD requirements.
Homeownership expenses (not including cooperatives) only include amounts allowed by the PHA tocover:
• Principal and interest on initial mortgage debt,any refinancing of such debt, and any mortgage insurancepremium
incurred to finance purchase of the home;
• Real estate taxes and public assessments on the home;
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• Home insurance;
• The PHA allowance for maintenance expenses;
• The PHA allowance for costs of major repairs and replacements;
• The PHA utility allowance for the home;
• Principal and interest on mortgage debt incurred to finance costs for major repairs, replacements orimprovements
for the home. If a member of the family is a person with disabilities,such debt may include debt incurred by the
family to finance costs needed to make the home accessible for such person, if the PHA determines thatallowance
of such costs as homeownership expenses is needed as a reasonable accommodation so that thehomeownership
option is readily accessible to and usable by such person;
• Land lease payments where a family does not own fee title to the real property on which the home is located; [see
24 CFR 982.628(b)].
• For a condominium unit,condominium operating charges or maintenance fees assessed by thecondominium
homeowner association.
The amount of the monthly assistance payment will be based on three factors: the voucher payment standard forwhich
the family is eligible; the monthly home ownership expense; and the family's household income.The PHA shall paya
monthly Home ownership assistance payment directly to the lender on behalf of the family that is equal to the lower of:
(1)The payment standard minus the total tenant payment;or
(2)The family's monthly Home ownership expenses minus the total tenant payment.
Home ownership expenses for a homeowner may include principal and interest on mortgage debt, anymortgage
insurance premium incurred to finance the home, real estate taxes,any public assessments on the property, home
insurance, PHA allowance for maintenance expenses and costs of repairs and replacements; and the PHAutility
allowance. All participants in the HCV Home Ownership program shall be required to apply for the homesteadtax
exemption.
The PHA will allow the following homeownershipexpenses:
• Monthly homeownership payment.This includes principal and interest on initial mortgage debt, taxesand insurance,
and any mortgage insurance premium, ifapplicable.
• Utility allowance.The PHA's utility allowance for the unit, based on the current HCV utility allowance schedule.
• Monthly maintenance allowance.The monthly maintenance allowance will be the annual maintenance allowance,
divided by twelve.The annual maintenance allowance will be set at .5 percent of purchase priceof the home.
• Monthly major repair/replacement allowance.The monthly major repair/replacement allowance will bethe annual
major repair/replacement allowance divided by 12.The annual major repair/replacement allowance will be set as a
percentage of the purchase price of the home, based on the age of the home at the time of purchase and/or
reexamination.
• Monthly co-op/condominium assessments. If applicable, the monthly amount of co-op orcondominium association
operation and maintenance assessments.
• Monthly principal and interest on debt for improvements. Principal and interest for major homerepair,
replacements,or improvements, if applicable.
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The PHA will provide the lender or Rehabilitation Activity with notice of the amount of the housing assistance payment
prior to close of escrow and will pay PHA's contribution towards the family's homeowner expense directly to thefamily's
designated account for the mortgage activity.The family will be responsible to submit the mortgage payment directly to
the lender in a timely manner to allow the transfer of funds by the lender and/or mortgage servicer and within the terms
of the mortgage loan agreement.
A family's home ownership assistance may be changed during the annual recertification of the household income and at
other times per the PHA's policy of interim changes while the family is participating in the HCV Home Ownership Program.
Participation in the HCV Home Ownership Program shall continue until theassistance payment equals$0.00 for a period
of 180 consecutive days and per the term of the HCV Home Ownership Program.
Homeownership expenses for a cooperative member may only include amounts allowed by the PHA tocover:
• The cooperative charge under the cooperative occupancy agreement including payment for real estate taxesand
public assessments on the home;
• Principal and interest on initial debt incurred to finance purchase of cooperative membership shares andany
refinancing of such debt;
• Home insurance;
• The PHA allowance for maintenance expenses;
• The PHA allowance for costs of major repairs and replacements;
• The PHA utility allowance for the home;and
• Principal and interest on debt incurred to finance major repairs, replacements or improvements for the home. Ifa
member of the family is a person with disabilities,such debt may include debt incurred by the family to finance costs
needed to make the home accessible for such person, if the PHA determines that allowance of such costsas
homeownership expenses is needed as a reasonable accommodation so that the homeownership option is readily
accessible to and usable by such person.
• Cooperative operating charges or maintenance fees assessed by the cooperative homeownerassociation.
MOVING WITH CONTINUEDASSISTANCE
A family receiving homeownership assistance may move with continued tenant-based assistance.The family maymove
with voucher rental assistance or with voucher homeownership assistance.Continued tenant-based assistance for a new
unit cannot begin so long as any family member holds title to the prior home.
The PHA may deny permission to move to a new unit with continued voucherassistance:
• If the PHA has insufficient funding to provide continued assistance.
• In accordance with 24 CFR 982.638, regarding denial or termination ofassistance.
• In accordance with the PHA's policy regarding number of moves within a 12-month period.
The PHA must deny the family permission to move to a new unit with continued voucher rental assistance if:
• The family defaulted on an FHA-insured mortgage;and
• The family fails to demonstrate that the family has conveyed,or will convey,title to the home,as required by HUD, to
HUD or HUD's designee; and the family has moved, or will move, from the home within the period established or
approved by HUD.
Substantial Deviation
It is the intent and mission to adhere to the goals and objectives outlined in the five-year plan.Any modificationsor
changes to the plan shall seek approval from HUD prior to implementation. A substantial deviation does not include any
changes in HUD regulations or notices.
Sign ifica nt Ame ndme nt/Modification
In June 2013,the PHA was issued a Letter of Findings of Noncompliance with Title VI of the Civil Rights Act.The PHA has
Page 40 of 60
since entered a Voluntary Compliance Agreement with HUD. HUD Letter of Findings identified:
• April 2008: Hiring of a police officer to serve as a Section 8 Investigator
• September 2009: Formation of a Safe Community Task Force to address the perception of increased crimein
Dubuque; crime study ordered by the City contracted to Alta Vista Research to focus on the connection between
crime and rental housing, specifically Section 8.
• November 2009: Crime study yielded that "persons arrested for criminal activities in Dubuque are no morelikely to
live in Section 8 Housing"; Administrative plan changed to allow opening and closure of wait list based on number of
individuals on the list, and to remove the very low income preference point allotment; alsoadopted stronger eligibility
and denial of assistance/termination requirements pertaining to conduct of all membersof household to include
juveniles; wait list was also restricted to only individuals who qualify for one of the local residency preference points
• December 2009: Voucher issuance freeze in effect
• February 2010: City Council adopted recommendation to reduce vouchers to900
• November 2009-December 2010: Wait list purge of over 582 families, 66%of which were AfricanAmerican
• June 20-24, 2011: HUD onsite compliance review
• June 17, 2013: HUD issued Letter of Findings of Noncompliance
• April 9, 2014:The City of Dubuque enters Voluntary Compliance Agreement with HUD
By entering the Voluntary Compliance Agreement (VCA), the City has taken measures to ensurecontinued compliance
with its responsibilities under Title VI and its implementing regulations,as well as the City's AFFH obligations and
compliance with PIH Program Requirements.The City has already taken several steps to mediate the effects ofthe
activities,including:
• Local residency preference points were eliminated in December 2012. All local preference points wereremoved in
the proposed Administrative Policy approved by HUD as of February 27,2015,
• Section 8 Investigator is no longer funded through supplemental Administrative Fees.
• The Administrative Plan has been updated/re-written to reflect the necessary changes as outlined in the VCA.The
Administrative Plan was submitted to HUD on December 18, 2014. Comments were received from HUD on February
27, 2015. Additional changes to the Administrative Plan were submitted to HUD in March 2015to address HAP
shortfall funding for CY 2015 and future years based upon HUD Shortfall Teamrecommendations.The newly revised
Administrative Plan was discussed and reviewed by the Resident Advisory Board on 3/19/2015 and 4/16/2016. HUD
granted approval of the Administrative Plan on 4/9/2015.The City ofDubuque Housing Commission voted to approve
and adopt the plan on 4/28/2015.The City Council voted to approveand adopt the plan on 5/18/2015.
• Revision to the Administrative Plan Chapters 5 (Voucher size) and 16 (Voucher Payment Standards)was
submitted to HUD on September 16, 2015; approved by HUD on October 5, 2015; approved byHousing
Commission on October 27, 2015 and approved by City Council on November 16,2015.
• Revision to the Administrative Plan Chapters 5 (Briefing Attendance), Chapter 6 (Minimum Rent) and Chapterll (PHA
Initiated Interim Reexaminations) was submitted to HUD on December 1, 2015; approved by HUDon 12/10/2015;
Approved by Housing Commission on 1/26/2016 and approved by City Council on 2/15/2016.
• Revision to the Administrative Plan Chapter 4 Opening/Closing Waiting List and Selection was submitted to HUD and
approved on 7/21/2016; reviewed by RAB on prior to submission to HUD and finalized on 9/15/2016; approved by
the Housing Commission on 9/27/2016 and approved by the City Council on 11/7/2016.
• Revision to Chapter 7 (Verification) and Chapter 11 (Reexaminations) was approved by HUD on 1/4/2017, approved
by Housing Commission on 1/24/2017 and approved by City Council on 2/6/2017.
• Revision to the Administrative Plan Chapter 4(Applications,Waiting List and Tenant Selection) and Chapter 16
(Program Administration) was submitted to HUD on 9/25/17; approved by Housing Commission on 3/27/2018; and
approved by City Council on 5/7/2018.
• All HCV bi-annual reports are being submitted to HUD for review per the terms of the VCA.The City is working with
HUD to ensure consistency and comprehensive reporting.
• 494 applicants were removed from the waiting list between January 1, 2014 and August 29, 2014 to increase
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voucher lease-up to 927 as of January, 2015. During CY2015, the number of applicants removed fromthe waiting
list to either be issued vouchers or removed from the waiting list for reasons of non-responseor ineligibility
totaled 451 applications.
• The PHA needs additional funding to allow for lease up to the number of baseline voucher units of 1,072.Our
current lease-up rate is below our funding capacity and efforts to increase leasing began after Ju1y2015.
• The HA surveyed landlords on whether they accept the HCV for their rental units as part of theirrental license
renewal.To increase housing choice,outreach and education will then be targetedtowards the pool of landlords
who do not currently accept HCV.
• All Housing Department, Human Rights Department, Planning and Zoning Department, City Manager's Office and
Police Department staff inembers,City Council,Housing Commission,Long Range PlanningCommission,Community
Development Advisory Commission members, and the Mayor have received continual civil rights and housing law
training beginning in August 2014.
6.1. c
Deconcentratin�Policv
As part of the PHA's strategy to deconcentrate neighborhoods in poverty, higher Voucher Payment Standards have been
put in place in Census Tracts 8.01, 8.02, 12.01, 12.02, 12.04 and 12.05.The Voucher Payment Standards within the above
census tracts will be adjusted on January 1 of each year.
The PHA has a Project Based Voucher contract with the Rose of Dubuque to provide assisted living units to elderlyand
disabled populations.The Rose of Dubuque is an affordable, assisted living facility for the benefit of low- and moderate-
income seniors in the Dubuque, lowa area. The 70-unit building is located at 3390 Lake Ridge Drive, Dubuque,lowa.
Seventeen of the units are designated as Project-Based Voucher units.The site was selected to promote greater housing
choice opportunities and avoid undue concentration of assisted persons in areas containing a high proportion of poverty.
The PHA will conduct owner outreach to ensure that owners are familiar with the program and its advantages.The PHA
will actively recruit property owners with property located outside areas of poverty and minority concentration.These
outreach strategies will include:
• Distributing printed material about the program to property owners and managers
• Contacting property owners and managers by phone or in-person
• Holding owner recruitment/information meetings at least once a year
• Participating in community-based organizations comprised of private property and apartment ownersand managers
• Developing working relationships with owners and real estate brokersassociations
• Attending meetings with representatives of Dubuque Landlord Association
Outreach strategies will be monitored for effectiveness, and adapted accordingly.
Outreach Approach
The Housing and Community Development Department (HCDD) has identified its internal outreach objectivesas outreach,
advancement, and education.We believe that our programs can benefit everyone in our community.
• Developing a Voluntary Affirmative Outreach Plan for all housing development, rehabilitation,and housing-
related opportunities funded by the Community Development Block Grant Program
• Outlining an outreach program that includes special measures designed to attract those groups identified as least
likely to be reached through our traditional outreach methods, while also expandingefforts designed to attract
persons from the total population.
• Recognizing the community members already involved in any of our programs and encouraging themto utilize all
programs and services available.
• Creating and distributing materials that educate the community on the various programs we offer,while clearly
conveying the benefits our services will bring to the community.
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To effectively achieve our outreach objectives,we have created three outreach messages that we believeare important in
conveying to the public the importance of the HCDD's work to the long-term success ofour community.
Outreach Messages
• Supporting all community members and improving quality of life
• Providing comprehensive housing services
• Creating sustainable housing solutions
Outreach Method and Rationale
To ensure that information about our programs, specifically the Housing Choice Voucherand homeownership programs,
reaches a sufficient minority population to remedy in measurable waysthe effects of our earlier decisions described in
the letter of findings,we will focus on outreach to communities that are a reasonable distance from Dubuque and that
have significant minority populations. We will conduct outreach within a 200-mile radius of Dubuque,which will enable
us to include portions of lowa, Illinois,Wisconsin, Minnesota, and Missouri.
At 100 miles from Dubuque, the minority population is 4.6%, at 150 miles the minority population is 6.6%, and at 200
miles the minority population is 11.3%.The following breakdown furtherexplains outreach strategy and effectiveness.
Population by race/ethnicity 100 miles 150 miles 200 miles
Total population 3,085,573 11,231,124 20,026,130
White alone gg.g% 82 6% 77%
Black alone 4.6% 6.6% 11.3%
American Indian alone 0.3% 0.4% 0.5%
Asian alone 1.9% 4.0% 3.8%
Hispanic origin 5.7% 10.8% 12.7%
Some of the race alone 2.3% 4.3% 5.3%
Two or more races 2.0% 2.1% 2.1%
Diversity index 29.4 44.4 52.8
Notes:
• Persons of Hispanic origin may be of any race
• The diversity index measures the probability that two people from the same area will be from different race or
ethnic groups.
• Source US Census Bureau 2010 summary file ESRI forecast
This approach helps us to ensure we reach interstate minority populations to remedy previous actions that,as outlined in
the VCA, negatively impacted minority populations.The other reasoning is that a 200-mile radius reaches an
approximately three and a half to four-hour drive,which covers the interstate distances. Wehave identified eight primary
target groups/channels within this 200-mile radius where we will concentrateour outreach efforts:
1. Public Housing Authorities: We selected public housing authorities (PHA) to provide outreach materials on our
Housing Choice Voucher and homeownership programs because, in most localities,the PHA is thefirst place that
minority communities in need of assistance go to find housing opportunities and assistance. In most cases,these PHAs
also operate the Housing Choice Voucher program or homeownership programs. Wefeel they are best equipped to
provide information on our programs to potential clients who could benefitfrom housing opportunities in Dubuque.
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2. National Association for the Advancement of Colored People (NAACP) Chapters:Traditionally,NAACP chapters were
formed in cities with a population over 30,000 and were designed to protect the civil rightsof minority populations and
to extend to them equal opportunity under the Constitution. Most NAACPchapters today have consistent outreach
programs with their membership and stakeholders that address issues inthe community such as racial discrimination,
unfair housing practices,and violations of civil rights.We believe that NAACP chapters in the 200-mile radius will be an
excellent conduit for us to communicate and outreach about our housing opportunities and services to the minority
populations in theircommunities.
3. Applicants purged from Dubuque's Housing Choice Voucher Waiting Lists between 2009 and 2011: In its letterof
findings to Dubuque, HUD found that the City's process of purging people from the waiting list resulted in disparaging
impact and kept people out of the program,specifically African-Americans. We contend that there was no such intent
with this process; however,we will notify all applicants on the waiting list in Novemberand December 2009 that our
waiting list is open and invite all applicants to apply.This list includes householdsthat were purged from the waiting list
and households that are not currently participating in the HousingChoice Voucher Program. Adding this activity to the
City's proposed activities would potentially reach families, manyof whom are African American, in the interstate area who
previously wanted to live in Dubuque.The PHA has senteach individual household an invitation encouraging them to
reapply and have mailed applications upon request.
4. National Urban League: The National Urban League was formed in 1968 for the purpose ofimproving the economic
impact and economic opportunities for minority individuals. Like the NAACP and othernonprofits,they have in place a
successful outreach system to communicate with their constituents. Our plan is tosolicit the National Urban League to
assist us in the distribution of information on Dubuque's housing opportunities to their members and constituents.This
information will explain specifically how to apply for the assisted housing program in Dubuque and will include detailed
information about all homeownership opportunities, classeson improvement of credit and saving money, and
information on down payment and closing cost assistancefor first-time home buyers. Our information also highlights the
many ways in which Dubuque is a good place tolive and raise a family.
5. Social Media (i.e. Facebook and Twitter): Social media and mobile platforms, particularly Facebookand Twitter,are
very effective methods of sharing information and communicating with a variety ofaudiences, including the populations
we intend to reach through these outreach efforts. Because of the low cost involved it is an especially popular
communication source used by low-to moderate income populations. For thisreason and the inherent ability to share
these messages, we believe social media is an excellent conduit to provide information regarding our Housing Choice
Voucher and homeownership programs.The City of Dubuque and the HCDD both have Facebook pages and the City of
Dubuque also manages a Twitter account. Both will continue to be utilized to help market Dubuque's housing programs
to the audiences targeted by this outreach plan.
6. Mobile and Electronic Applications: Mobile phone and other wireless device applications are an increasingly
inexpensive and immediate way of communicating with people.As we communicate withour current tenants,we are
exploring options to allow them to access and share information concerninghousing programs in Dubuque and
homeownership opportunities. Additionally, we are expanding our rental assistance software to allow for the electronic
submission of applications for housing programs offered in Dubuque.
7. Language Translation:To insure our products and services are understood by the groupswe are targeting, we will
provide our outreach materials in English, Spanish, and Marshallese. We will makethem available upon demand and we
will also send them to our neighboring PHAs.
8. City of Dubuque Website:The City of Dubuque recently launched a new and improved website withnew navigation
and graphic design elements to better convey programs, information,services and emergency support to our citizens. It is
also an educational tool and resource management tool. We will enhancethe existing information on the website about
our Housing and Community Development programs.Theseefforts will focus on the Housing Choice Voucher application
and process as well as detailed information about Dubuque's home ownership programs.These websites are often visited
by minority families and individuals to learn about what a locality or city has to offer,and we believe could be a beneficial
Page 44 of 60
conduit to reach minority populations.The City website has an electronic translation service called Google Translate so a
person doesnot need to know how to read English to read our website.
Nondiscrimination
The City of Dubuque is committed to promoting fair housing and equal opportunity for families of all race, ethnic
backgrounds, religion,sex,disability, familial status,gender identity and sexual orientation.
It shall be unfair or discriminatory practice for any person to refuse or deny to any person the opportunity to apply or
participate in programs because of race, creed,color,sex, age, national origin, familial status,disability, marital status,
religion, sexual orientation or gender identity. See City of Dubuque Code,Title 8 Human Rights.
The PHA will not discriminate against any applicant, participant or property owner because of race, color,creed, national
or ethnic origin or ancestry, religion, sex, age, disability, sexual orientation, gender identity,orfamilial status; nor will any
criteria be applied, nor information be considered, pertaining to attributes or behaviorthat may be imputed by some to a
group or category.All criteria applied and information considered in administering this plan shall relate to the attributes
and behavior of the individual members of thehousehold. All activities and policies contained in this plan have been
created to offer greater opportunities foraffordable housing.
The PHA will not use any of these factors to:
• Deny to any family the opportunity to apply for housing, nor deny to any qualified applicant theopportunity to
participate in the housing choice voucher program
• Provide housing that is different from that provided to others
• Subject anyone to segregation or disparate treatment
• Restrict anyone's access to any benefit enjoyed by others in connection with the housingprogram
• Treat a person differently in determining eligibility or other requirements foradmission
• Steer an applicant or participant toward or away from an area based any of thesefactors
• Deny anyone access to the same level of services
• Deny anyone the opportunity to participate in a planning or advisory group that is an integral part ofthe housing
program
• Discriminate in the provision of residential real estate transactions
• Discriminate against someone because they are related to or associated with a member of a protectedclass
• Publish or cause to be published an advertisement or notice indicating the availability of housingthat prefers
or excludes persons who are members of a protected class
Applicants or participants who believe that they have been subject to unlawful discrimination may notify the PHA either
orally or in writing.
The PHA will attempt to remedy discrimination complaints made against the PHA.The PHA shall not retaliate against any
person who files a complaint.
The PHA will provide a copy of a discrimination complaint form to the complainant and provide them with information on
how to complete and submit the form to HUD's Office of Fair Housing and Equal Opportunity (FHEO).
Services for Persons with Limited English Proficiency
Language for Limited English Proficiency Persons (LEP) can be a barrier to accessing important benefits or services,
understanding and exercising important rights, complying with applicable responsibilities,or understanding other
information provided by the HCV program.
The PHA will take affirmative steps to communicate with people who need services or information in a language other than
English.These persons will be referred to as Persons with Limited English Proficiency (LEP).
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LEP is defined as persons who do not speak English as their primary language and who have a limited ability to read, write,
speak or understand English. For the purposes of this administrative plan, LEP persons are HCV applicants and participants,
and parents and family members of applicants and participants.
The City of Dubuque has an affirmative responsibility to provide persons who are "limited English proficienY' (LEP) equal
opportunity for participation in the Assisted Housing Program. If any person is not fluent in English, the Housing Authority
will provide an interpreter or utilize a translation service at no cost to the LEP person.
The Housing Agency will take proactive steps to ensure the LEP person can understand the servicesand benefits available.
The HA will continually assess the language needs of program participants and those persons on the waiting list to identify
the needs of the population being served and resources available. If more than 5%of the population served or more than
100 persons are in a language group consisting of LEP persons,the HA shall ensure vital documents are translated into the
appropriate language. If less than the percentage or number of persons served as stated above are in an identified
language group, the HA will consider theexpenses of written translations and implement if financially feasible. However,
oral interpretations shall be offeredas stated above. Case file information noting the language needs of each LEP
applicant/participant shall be maintained in each individual's file.
The PHA will analyze the various kinds of contacts it has with the public, to assess language needs anddecide what
reasonable steps should be taken. "Reasonable steps" may not be reasonable where the costs imposed substantially
exceed the benefits.
Where feasible,the PHA will train and hire bilingual staff or other known interpreters to be available to actas
interpreters and translators,will pool resources with other PHAs,and will standardize documents.Where feasible and
possible, the PHA will encourage the use of qualified communityvolunteers.
Where LEP persons desire,they will be permitted to use,at their own expense, an interpreter of theirown choosing, in
place of or as a supplement to the free language services offered by the PHA.The interpreter may be a family member or
friend.
The PHA will provide written translations of vital documents for each eligible LEP language groupthat constitutes 5
percent or 100 persons, whichever is less, of the population of persons eligible to be servedor likely to be affected or
encountered.Translation of other documents, if needed, can be provided orally; orif there are fewer than 50 persons in
a language group that reaches the 5 percent trigger,the PHA does not translate vital written materials, but provides
written notice in the primary language of the LEP language group of the right to receive competent oral interpretation of
those written materials, free ofcost.
If it is determined that the PHA serves very few LEP persons,and the PHA has very limited resources,the PHA will
consider alternative ways to articulate in a reasonable manner a plan for providing meaningfulaccess.
Entities having significant contact with LEP persons,such as schools,grassroots and faith-based organizations,community
groups, and groups working with new immigrants will be contacted for input into the process.
If the PHA determines it is appropriate to develop a written LEP plan,the following five steps will be taken:(1) Identifying
LEP individuals who need language assistance; (2) identifying language assistance measures;(3) training staff; (4)
providing notice to LEP persons; and (5) monitoring and updating the LEP plan.
Violence Against Women Act (VAWA)
The Violence against Women Act of 2005 (VAWA) and the HUD regulation at 24 CFR 5.2005(b) prohibitPHAs from
denying an applicant admission to the HCV program "on the basis that the applicant is or has been a victim of domestic
violence,dating violence,or stalking, if the applicant otherwise qualifies for assistance or admission."
The PHA acknowledges that a victim of domestic violence, dating violence,or stalking may have an unfavorable history
Page 46 of 60
(e.g., a poor credit history, a record of previous damage to an apartment, a prior arrest record)that would warrant
denial under the PHA's policies.Therefore, if the PHA decides to denyassistance to an applicant family,the PHA will
include in its notice of denial the VAWA information as defined by HUD and will request that an applicant wishing to
claim protection under VAWA notify the PHA within 10 business days. If an applicant claims the protection against
denial of assistance that VAWA providesto victims of domestic violence,dating violence,or stalking, the PHA will
request in writing that theapplicant provide documentation supporting the claim. If the perpetrator of the abuse is a
member of theapplicant family, the applicant must provide additional documentation consisting of one of thefollowing:
A signed statement (1) requesting that the perpetrator be removed from the application and (2)certifying that the
perpetrator will not be permitted to visit or to stay as a guest in the assisted unit
Documentation that the perpetrator has successfully completed rehabilitation or treatment: The documentation must
be signed by an employee or agent of a domestic violence service provider or by a medical or other knowledgeable
professional from whom the perpetrator has sought or is receiving assistance in addressing the abuse.The signer must
attest under penalty of perjury to his or her belief that therehabilitation was successfully completed. The victim and
perpetrator must also sign or attest to thedocumentation.
Persons with Disabilities
The PHA must ensure that persons with disabilities have full access to the PHA's programs and services.This
responsibility begins with the first contact by an interested family and continues through every aspect of the program.
The City of Dubuque PHA's policy regarding reasonable accommodations is to ensure equal access and participation of
disabled persons in assisted housing programs administered by the City of Dubuque. No qualified individual with a
disability shall, by reason of such disability, be excluded from application, participation or benefits of the assisted
housing programs,or be subjected to discrimination. Documentation regarding the disability will be provided on a
voluntary basis. Refusal to provide information regarding disability will not subject the applicant to adverse treatment;
however, if the disabled person is seeking reasonable accommodation, documentation will be required. All medical
information obtained shall be kept confidential, including information about functional limitations and reasonable
accommodation needs.
Accommodations are not reasonable if they require fundamental alterations in the nature of a program or impose
undue financial and administrative burdens on the PHA. The PHA may not be required to make requested
accommodations if effective alternatives permit full program participation. The purpose of providing reasonable
accommodation is to provide the applicant/participant with a disability the opportunity to meet essential requirements
of the program and an equal opportunity to apply/participate in housing programs through modification of policies,
procedures, or practices. It does not require reducing or waiving essential requirements of program participation nor is
it intended to provide greater program benefits to persons with disabilities than to non-disabled applicants/participants.
Persons with Hearing or Vision Impairments
To meet the needs of persons with hearing impairments, Relay lowa services(httq://www.relaviowa.com/) will be
available.
To meet the needs of persons with vision impairments, large-print and audio versions of key program documents will be
made available upon request.When visual aids are used in public meetings or presentations,or in meetings with PHA
staff,one-on-one assistance will be provided upon request.
Additional examples of alternative forms of communication are sign language interpretation; having material explained
orally by staff; or having a third-party representative (a friend, relative or advocate, named by the applicant) or another
interpreter hired by the PHA to receive, interpret and explain housing materials and be present at all meetings.
Page 47 of 60
In order to determine the level of access needed by LEP persons, the PHA will balance the following four factors: (1) the
number or proportion of LEP persons eligible to be served or likely to be encountered by the Housing Choice Voucher
program; (2) the frequency with which LEP persons come into contact with the program; (3) the nature and importance
of the program,activity, or service provided by the program to people's lives; and (4) the resources available to the PHA
and costs. Balancing these four factors will ensure meaningful access by LEP persons to critical services while not
imposing undue burdens on the PHA.
The City of Dubuque has an affirmative responsibility to provide persons who are "limited English proficienY' (LEP) equal
opportunity for participation in the Assisted Housing Program. If any person is not fluent in English,the Housing
Authority will provide an interpreter or utilize a translation service at no cost to the LEP person. The Housing Agency will
take proactive steps to ensure the LEP person can understand the services and benefits available.The HA will continually
assess the language needs of program participants and those persons on the waiting list to identify the needs of the
population being served and resources available. If more than 5%of the population served or more than 100 persons
are in a language group consisting of LEP persons,the HA shall ensure vital documents are translated into the
appropriate language. If less than the percentage or number of persons served as stated above are in an identified
language group,the HA will consider the expenses of written translations and implement if financially feasible.
However, oral interpretations shall be offered as stated above. Case file information noting the language needs of each
LEP applicant/participant shall be maintained in each individual's file.
The PHA will analyze the various kinds of contacts it has with the public,to assess language needs and decide what
reasonable steps should be taken. "Reasonable steps" may not be reasonable where the costs imposed substantially
exceed the benefits.
Where feasible,the PHA will train and hire bilingual staff or other known interpreters to be available to act as
interpreters and translators, will pool resources with other PHAs,and will standardize documents.Where feasible and
possible,the PHA will encourage the use of qualified community volunteers.
Where LEP persons desire,they will be permitted to use, at their own expense, an interpreter of their own choosing, in
place of or as a supplement to the free language services offered by the PHA.The interpreter may be a family member
or friend.
The PHA will provide written translations of vital documents for each eligible LEP language group that constitutes 5
percent or 100 persons,whichever is less,of the population of persons eligible to be served or likely to be affected or
encountered.Translation of other documents, if needed,can be provided orally; or
If there are fewer than 50 persons in a language group that reaches the 5 percent trigger,the PHA does not translate
vital written materials, but provides written notice in the primary language of the LEP language group of the right to
receive competent oral interpretation of those written materials, free of cost.
If it is determined that the PHA serves very few LEP persons,and the PHA has very limited resources, the PHA will
consider alternative ways to articulate in a reasonable manner a plan for providing meaningful access. Entities having
significant contact with LEP persons, such as schools, grassroots and faith-based organizations, community groups, and
groups working with new immigrants will be contacted for input into the process.
If the PHA determines it is appropriate to develop a written LEP plan,the following five steps will be taken: (1)
Identifying LEP individuals who need language assistance; (2) identifying language assistance measures; (3) training staff;
(4) providing notice to LEP persons; and (5) monitoring and updating the LEP plan.
Commitment to Family and Assisted Housing Marketing Plan
The City of Dubuque recognizes the importance of an affirmative fair housing marketing plan designed to attract all
eligible applicants/participants and to affirmatively promote an open and inclusive community. The PHA is dedicated to
creating a model HCV program that offers opportunities for all persons. The PHA is committed to improving service
delivery and outreach efforts.
Page 48 of 60
In creating policy, the PHA has reviewed practices, performed a comprehensive examination of the way services are
delivered and considered the impacts of all marketing and outreach efforts to ensure full compliance with civil rights laws
and to ensure access by all eligible applicants/participants.
The PHA shall make good faith efforts to carry out the Program Outreach and Affirmative Fair Housing Marketing Plan
and Procedures.
The PHA shall identify the segments of the eligible population which are least likely to apply for housing. The PHA has
created an outreach program which includes special measures designed to attract those identified as least likely to apply
and to create opportunities for all. Special outreach efforts include direct marketing to increase participation by minority
populations as identified in the Executive Summary beginning on page 1. Effort will be made to communicate in writing
and/or verbally with contact sources and to develop positive relationships and obtain referrals to attract targeted groups
to diversify the housing community. To track outreach efforts, the application for assisted housing shall include a
question asking the applicant how the applicant became aware of the program and if the applicant is aware of outreach
efforts performed by the City.
HUD Fair Housing Posters or Brochures in English,Spanish and Marshallese shall be available if obtainable from HUD and
displayed for public review at the PHA office. All brochures, signs and posters are an integral part of the affirmative
marketing effort and shall be consistent with Fair Housing Rules and Regulations. The PHA shall make all primary
brochures available in English, Spanish and Marshallese. Primary brochures are brochures provided to the public advising
of program availability,such as, brochures describing eligibility guidelines and application procedures.
The PHA has identified several organizations to intentionally market programs to ensure families are familiar with
opportunities for participation in the HCV programs. Organizations include but are not limited to churches,schools,
clinics, service agencies, hospitals and grocery stores.
The PHA shall also use social media and attend expos/events within the community, and extend marketing to include a
200-mile radius from the City.
PHA staff shall reach out to community contacts to supplement formal communications media for public awareness of
availability of HCV programs.
Outreach to property owners is done through staff attendance at the Dubuque Crime-Free Multi-Housing Program. The
Dubuque Successful Rental Property Management provides property owners comprehensive information on all aspects of
managing rental housing. The program is offered at least twice per year. The presenters include local attorneys and
representatives from the City of Dubuque's Police, Fire, Human Rights, Legal and Housing Departments. Additionally,
staff ineets with Landlord Association Board members monthly. Property Owners are encouraged to list available units
with the PHA. The list of available rentals is available to all persons at the City of Dubuque Housing and Community
Development Office and online at www.citvofdubupue.orQ/hcv
The PHA utilizes various media for local outreach including City News,a newsletter published and distributed with City
utility bills six times per year that is also available online and at City Hall. The PHA provides outreach including
distribution of the City of Dubuque Housing Commission Agenda to media including the Telegraph Herald, KWWL TV,
KCRG TV, KGAN TV,WDBQ/KLYV/Eagle 102/KIYX radio stations, KAT/KGRR/KDTH/WVRE radio stations, City Channel
Dubuque (local government access television channel), Dubuque Landlord Association,Julien's Journal magazine and the
City's website.
6.4. Most Recent Fiscal Year Audit
The most recent audited report approved by HUD is the financial information for the fiscal year ending 06/30/2017.
The U.S. Department of Housing and Urban DevelopmenYs Office of Public and Indian Housing—Real Estate
Assessment Center(PIH-REAC) Public Housing Financial Assessment (FASS-PH) team has reviewed and accepted the
Page 49 of 60
City of Dubuque submission.See Attachment A for Financial Reports.The City has submitted the fiscal year ending
06/30/2018 financial information that is currently being reviewed by HUD.
B.5 Progress Report
Goal: Increase homeownership among minority voucher participants and to non-minority voucher participants
The City of Dubuque Housing&Community Department offers a Home Ownership Made Easy (HOME) Workshop. This
workshop provides information on City of Dubuque homeownership/rehabilitation programs, budgeting, financing,
maintenance,and energy efficiency of a home. In FY 2018 (July, 2017 through June 30, 2018),one new household
became a homeowner with assistance from the Housing Choice Voucher Program bringing the total number of
households utilizing HCV funds for homeownership to thirty-three.
HCV Homeowners
�z
�o �o
3
0 0 - 0 0 0 - 0 0 0 ■ 0
Jun-16 Jun-17 Jun-18
■American Indian/Alaska Native ■Asian
■ Black/African American ■ Native Hawaiian/Other Pacific Islander
■White
Page 50 of 60
Goal: To promote fair housing opportunity
Composition for head of household participants in the HCV Program:
60.46% HCV Participants 5,.4z, 56.16%
37.26%
40.29% 41.35%
0.34% 0.46% 1�49� 0.36% 0.36% 3.60% 0.25% 0.37% 3.70%
� � �
Jun-16 Jun-17 Jun-18
■ American Indian/Alaska Native
■ Asian
■ Black/African American
■ Native Hawaiian/Other Pacific Islander
■ White
HCV Participants
52.59%
49 71� 50.37%
30.97%
29.93%
25.35%
�
11.31% 10.62% 11.45%
5.00% 5.44% 5.25%
■ ■ � i
Jun-16 Jun-17 Jun-18
■ Non Elderly/Non Disabled ■ Elderly/Non disabled ■ Non Elderly/Disabled ■ Elderly/Disabled
Page 51 of 60
Goal: Target Available assistance to families at or below 30%of AMI
In Fiscal Year 2018 the percentage of new admissions falling into the Extremely Low-Income Category was 75.73%or 78
households with the remaining 24.27%or 25 households falling into the Very Low-Income Category. HUD requires that
at least 75%of households admitted into the program during the year be extremely low income. Extremely low income
is defined as a very low-income family whose annual income does not exceed the higher of:
The poverty guidelines established by the Department of Health and Human Services applicable to the family of the size
involved (except in the case of families living in Puerto Rico or any other territory or possession of the United States); or
Thirty (30) percent of the median income for the area, as determined by HUD,with adjustments for smaller and larger
families,except that HUD may establish income ceilings higher or lower than 30 percent of the area median income for
the area if HUD finds that such variations are necessary because of unusually high or low family incomes.
The PHA reserves the right to skip over or re-select applicants through the Lottery system, if the PHA determines that it
is necessary to reach the HUD requirement that at least 75%of households admitted into the program during the year
must be extremely low income.
Goal: Ensure equal opportunity in Housing for all eligible families and affirmatively further fair housing.
As of January 2019,the demographics of households assisted are below:
Household Size Total Families %
1 381 46.75%
2 153 18.77%
3 110 13.50%
4 94 11.53%
5 45 5.52%
6 17 2.09%
7 10 1.23%
8ormore 5 0.61%
Total Families: 815 100.00%
Primary Race(Non-Hispanic) Total Families %
American Indian/Alaska Native 2 0.25%
Asian 3 0.37%
Black/African American 352 43.19%
Native Hawaiian/Other Pacifc Islander 14 172%
White 444 54.48%
Total Families: 815 100.00%
Ethnicity Total Families %
Hispanic 13 1.60%
Non-Hispanic 802 98.40%
Total Families: 815 100.00%
Page 52 of 60
Citizenship Total Members %
Ineligible Noncitizen 0 0.00%
Eligible Citizen 812 99.63%
Eligible Noncitizen 3 0.37%
Total Citizenships: 815 100.00%
Gross Income Total Families %
0-4,999 180 22.09%
5,000-9,999 231 28.34%
1 Q000- 14,999 182 22.33%
15,000- 19,999 115 14.11%
2Q000-24,999 53 6.50%
25,000-34,999 41 5.03%
35,000-44,999 8 0.98%
45,000-999,999 5 0.61%
Total Families: 815 100.00%
_ �_ _ _ _ _
Number Total %
Dependents/Children Families
0 416 51.04%
1 136 16.69%
2 107 13.13%
3 94 11.53%
4 35 4.29%
5 17 2.09%
6 6 0.74%
7 or more 4 0.49%
815
Total Families 100.00%
Status Total Members %
Non-Elderly/Non-Disabled 416 51.04%
Elderly/Non-Disabled 68 8.34%
Non-Elderly/Disabled 236 28.96%
Elderly/Disabled 95 11.66%
Total Members: 815 100.00%
Size Total Families %
1 381 46.75%
2 233 28.59%
3 162 19.88%
4 34 4.17%
5 5 0.61%
Total Families: 815 100.00%
Page 53 of 60
Goal: Increase assisted housing choices
Progress/Achievement: The City continues to offer HUD approved exception rent areas to voucher holders, which
allow families to live in higher cost areas to expand choice and deconcentrate poverty. Twice per year,staff present to
area landlords at the Successful Rental Property Management Program aboutthe process and benefits of renting to
voucher holders. Additionally, staff ineets with members of the Landlord's Association monthly. The PHA launched an
interactive Landlord Portal in January 2015 to make information about payments, inspections, and licensing more
readily available to them. Landlords can also manage their unit vacancy and addtheir units to the Vacant Unit listing
that is made available in the PHA office.The City activated Applicant Portal with a Participant Portal for applications
and to follow for ease of use for the 2018 waiting list opening.
Page 54 of 60
6.6 Resident Advisory Board (RAB)Comments
City of Dubuque Resident Advisory Board Members:
Pattie Breitbach Willie Pledge
Jeff Crawford Patricia Stanford
Sherrie Harrison Teresa Stegall
Rhonda Latham Sherice Stevens
Mariana Miller Janet Veach
Le Thauh Nga Huey Yee Young
Resident Advisory Board Meeting Minutes
3/21/19
Present: Pattie Breitbach, Rhonda Latham, Patricia Stanford, Willie Pledge, Sherice Stevens, Teresa Stegall
Staff: Hollie Ohnesorge, Tracy Doyle, Jordan O'Connell, Teresa Bassler
Topic: Admin Plan/General information/Q&A
Presenters: Teresa Bassler, Assisted Housing Supervisor
Hollie Ohnesorge called the meeting into order. Teresa Bassler began a presentation on the PHA Annual Plan
by providing copies to individuals present. She explained that the PHA plan informs HUD, residents, and the
public of the PHA's mission for serving the needs of low income and very low-income families and the PHA's
strategy for addressing these needs. Teresa explained that there are 2 parts to the plan— 1 that is submitted to
HUD every 5 years and the annual plan which is submitted each year.
Teresa let the RAB know that proposed changes to the plan will be presented to the Housing Commission on
March 26, 2019. She then began highlighting the changes that are proposed from last year. Teresa stated that
there is a summary of needs which include more affordable housing. The City currently has about 10,800 rental
households at or below 80% AML She also stated that 45% of those rental households are experiencing some
sort housing problem. Half of those experiencing housing problems are in the eatremely low category. The PHA
annual plan also identifies that there is a cost burden for both rentals and homeowners.
Teresa reported to the RAB that one of the changes from last year is that the waiting list will be opened up once
it reaches 200 people left. She stated that it would previously open up at 350 people waiting. By changing to
200, it will help keep the new waiting list more "fresh." Teresa let the RAB know that the waiting list was made
up of 87% eatremely low-income applicants and 62% of the applicants have children.
The PHA plan also outlines what happens when there is insufficient funding for portability and also updated
changes that HUD made to the Violence Against Women Act(VAWA). Teresa also showed the RAB the
PHA's non-discrimination policies to ensure that persons with disabilities will receive access to housing
programing and services. This would also include better service for people with limited English proficiency.
Teresa also guided the RAB through the progress report in the PHA plan and explained graphs. She then opened
the RAB up to comments or questions.
Rhonda Latham stated "It all seems good."
Page 55 of 60
Patricia Stanford asked if the City has any available units in Asbury. Teresa stated that Asbury is not in our
jurisdiction, that would be Eastern Iowa Regional Housing Authority and if she were looking to move there, she
would have to utilize portability. Patricia then stated that she actually wants to move to Hammond, IN.
Rhonda Latham asked how often inspections are being handled. She said she doesn't remember her last
inspection and wasn't sure if it was coming up. Teresa answered that we are on a bi-ennial inspection schedule
and that she can always call her casewarker to ask when she would be due for an inspection.
Rhonda then asked if someone was trying to apply for the waiting list and they were disabled or elderly, would
they be at the top of the list or has that changed? Teresa stated that we haven't had preference points since 2013
and that no, they would not be at the top of the list. Teresa explained that the waiting list is a lottery and
applicants are randomly selected to be place on the waiting list and then randomly selected to be pulled from the
waiting list. The only way a disabled person could possibly get"preference"would be if one of the 40 vouchers
we have for non-elderly but disabled vouchers was available. She said the waiting list would be drawn until a
NED participant would be able to fill that voucher need. Rhonda commented "so this is not first come,first
served." Teresa stated "No, it's random." Rhonda then asked if a person was waiting for a long time, maybe a
year and on the waiting list, would they get priority?" Teresa said no, they would be selected randomly but that
they would be selected eventually.
Sherice Stevens stated that she has been here for 5 years and would like to utilize portability. She asked how
long the process can take? Tracy Doyle stated that it takes at least 2 weeks from the point of request for
portability to getting the paperwork together and sent to the neat HA. She then stated once we have all the
information we need, we issue a 90-day voucher and then the neat HA will give a 30-day ea�tension so the
process can take up to 120 days depending on unit availability, eta She also reminded tenants that they must
give a proper 30-day notice to their current landlord and to the HA.
Patricia Stanford stated that she wanted to move to Hammond, IN and she spoke to a HA there and they stated
that she would not be able to move their until she was eligible. She asked if she attempted to move and couldn't,
could she come back to her old voucher? Tracy again stated that if her year lease is complete, she can utilize
portability and that she is income eligible. Tracy said that the 90 voucher that is given does expire so as long as
the voucher is not expired and as long as the tenant hasn't given notice to move, then she can utilize her same
voucher.
Patricia then asked what would happen if she got temporary custody of her 3 grandchildren in her 1-bedroom
apartment, could she receive some additional help? Tracy answered and said that if she is able to have proper
documentation of custody of having her grandchildren, we would add them to the household and then she would
be eligible to move to a 3-bedroom unit and she would receive assistance at the 3-bedroom unit. Staff member
Hollie added that once custody ended, she would be downsized back to a 1 bedroom at the annual review and
may need to move again for affordability.
Patricia also stated that her landlord raised her rent by $25.00 and no one else's. Is that ok? Tracy stated that all
rent increases go through rent comparison and cannot increase if there aren't any unassisted units that are
similar going for that rate. She also stated that are many variables to rent and isn't sure if the other rents are for
unassisted units or not. She said it's quite possible that landlords take less money for assisted units and then
raise the rent after the initial lease is over.
Rhonda Latham said that she is going under annual review of income. She said that she has both income ending
and then perhaps some changing in the future but isn't sure how to reflect it on the paperwork. Tracy stated that
she should add everything that she knows to her paperwork but also stated that if she has income thaYs ending
Page 56 of 60
now, she has to do the interim change report and report the decrease but we won't be able to catch it with the
annual paperwork.
Staff also let the RAB know that Jessica Kieffer is no longer with the HA and stated that Cate Richter is
managing her caseload. Rhonda asked if the Cate will be their caseworker permanently and Tracy answered no,
someone will be hired but that Cate will be handling everything until their ready to take over on their own.
The RAB had no further comments or questions.
Recorded By:
Hollie Ohnesorge
Page 57 of 60
Attachment A: Statement of Financial Resources
City of Dubuque (IA087)
Dubuque, lA
Entity Wide Balance Sheet Summary
Submission Type: Audited/Single Audit Fiscal Year End: 06/30/2018
_ _ _ _ _ _ _ _ _ _ _ _ _.,
,'�,. ,'�,. 14.856 Lower ��'�,. ,'�..
��,, 14.871 Housing �, �nmme Hous�ng . .
. Assistance . Subtotal . Total
,. Choice Vouchers ���.. program Sec4on '�, '�,
��',. ��',. 8 Moderate �,�,. ��'..
.._. .._. .._. .._. .._. .._. .._. .._. .._. .._. .._. .._. ..;
� 111 Cash-Unrestricted �'�. $187,9ll �'�. $182,774 �'�. $370,685 �'�. $370,685
.._. .._. .._. .._. .._. .._. .._. .._. .._. .._. .._. .._. ..�
� 113 Cash-0therRestricted '�,. $258,338 '�,. $0 '�,. $258,338 '�,. $258,338
.._. .._. .._. .._. .._. .._. .._. .._. .._. .._. .._. .._. .�
: 100 TotalCash �I $446,249 �I $182,774 �I $629,023 �I $629,023
.._. .._. .._. .._. .._. .._. .._. .._. .._. ._.. .._. .._. ..;
.._. .._. .._. .._. .._. .._. .._. .._. .._. ._.. .._. .._. ..�
� 122 AcmuntsReceivable-HUDOtherProjects '', '', $5,777 '', $5,777 '', $5,777
, .._. .._. .._. .._. .._. .._. .._. .._. .._. :_.. .._. . .._. _.i
� 125AcmuntsReceivable-Miscellaneous '��, $5,475 '��, $0 '��, $5,475 '��, $5,475
. .............. .............. .............. .............. .............. ............. ,............. .............. .............. '......... .............. . .............. .......i
� 128 Fraud Recovery �� $62,748 ��, $1,277 ��, $64,025 ��, $64,025
.............. .............. .............. .............. .............. .............. .............. .............. ............. ':........ .............. .............. .......:
[ 1281 AllowanceforpoubtfulAccounts-Fraud �I -$18,824 �I $0 �I -$18,824 �I -$18,824
.............. .............. .............. .............. .............. ............. ,............. .............. ............. 1........ .............. .............. .......;
� 129 AccruedlnterestReceivable �'�. $1,403 �'�. $0 �'�. $1,403 �'�. $1,403
.............. .............. .............. .............. .............. .............. .............. .............. ............. �:........ .............. .............. ........:
� 120 TotalReceivables,NetofAllowancesforpoubtfulAcmunts '', $SQ802 '', $7,054 '', $57,856 '', $57,856
. .............. .............. .............. .............. .............. ............. �.............. .............. ............. 1........ .............. . .............. .....J
� 150 TotalCurrentAssets �� $497,051 �� $189,828 �� $686,879 �� $686,879
.._. .._. .._. .._. .._. .._. .._. .._. .._. .._. .._. .._. ..�
� 160 TotalCapitalAssets,NetofAccumulatedDepreciation ', $0 ', $0 ', $0 ', $0
.._. .._. .._. .._. .._. .._. .._. .._. .._. .._. .._. .._. ..;
� 180 TotalNon-CurrentAssets ', $0 ', $0 ', $0 ', $0
.._. .._. .._. .._. .._. .._. .._. .._. .._. .._. .._. .._. ..:
� 290 TotalAssetsandDeferredOutFlowofResources '�,. $497,051 '�,. $189,828 '�,. $686,879 '�,. $686,879
.._. .._. .._. .._. .._. .._. .._. .._. .._. .._. .._. .._. .�
.._. .._. .._. .._. .._. .._. .._. .._. .._. ._.. .._. .._. ..;
� 312 Accounts Payable<=90 Days '� $11,751 '�, $587 '�, $12,338 '�, $12,338
.._. .._. .._. .._. .._. .._. .._. .._. .._. ._.. .._. .._. ..�
[ 321 Accrued Wage/Payroll Taxes Payable �I $21,627 'I $0 'I $21,627 'I $21,627
, .._. .._. .._. .._. .._. .._. .._. .._. .._. :_.. .._. . .._. _.i
� 331 AcmuntsPayable-HUDPHAPrograms '��, $2,499 '��, $0 '��, $2,499 '��, $2,499
, .._. .._. .._. .._. .._. .._. .._. .._. .._. ._.. .._. . .._. _.i
� 342 Unearned Revenue '', $5,248 '', $0 '', $5,248 '', $5,248
.._. .._. .._. .._. .._. .._. .._. .._. .._. .._. .._. .._. ..�
[ 310 TotalCurrentLiabilities �I $41,125 �I $587 �I $41,712 �I $41,712
.._. .._. .._. .._. .._. .._. .._. .._. .._. .._. .._. .._. ..;
.._. .._. .._. .._. .._. .._. .._. .._. .._. .._. .._. .._. ..�
[ 353 Non-currentLiabilities-0ther �� $121,562 �� $0 �� $121,562 �� $121,562
.._. .._. .._. .._. .._. .._. .._. .._. .._. .._. .._. .._. .�
: 350 TotalNon-CurrentLiabilities �I $121,562 �I $0 �I $121,562 �I $121,562
. .............. .............. .............. .............. .............. ............. �.............. .............. .............. ..6........ .............. . .............. .....J
. .............. .............. .............. .............. .............. .............. �.............. .............. .............. ':........ .............. . .............. .......:
[ 300 TotalLiabilities �I $162,687 �I $587 �I $163,274 �I $163,274
. .............. .............. .............. .............. .............. ............. �.............. .............. .............. .:........ .............. . .............. .......i
. .............. .............. .............. .............. .............. ............. ,............. .............. ............. 1........ .............. . .............. .......i
[ 509.3 Restricted Fund Balance �� $142,343 ��, $0 ��, $142,343 ��, $142,343
.............. .............. .............. .............. .............. .............. .............. .............. ............. ':........ .............. .............. .......:
: 511.3 AssignedFundBalance I $192,021 I $189,241 I $381,262 I $381,262
.............. .............. .............. .............. .............. ............. ,............. .............. ............. 1........ .............. .............. .......;
� 513 TotalEquiTy-NetAssets/Position '� $334,364 '�, $1g9,241 '�, $523,605 '�, $523,605
.._. .._. .._. .._. .._. .._. .._. .._. .._. ._.. .._. .._. ..�
, .._. .._. .._. .._. .._. .._. .._. .._. .._. :_.. .._. . .._. _.i
: 600 Total Liabilities,Deferred InFlows of Resources and EquiTy-Net �I. $497,051 �I. $189,828 �I. $686,879 �I. $686,879
. .._. .._. .._. .._. .._. .._. .._. .._. .._. ._.. .._. . .._. _i
City of Dubuque (IA087)
Page 58 of 60
Dubuque, lA
Entity Wide Revenue and Expense Summary
Submission Type: Audited/Single Audit Fiscal Year End: 06/30/2018
14.856 Lower '�. '��..
14.871Hous�ng ' �nmmeHousing
� Choice Vouchers � Assistance . Subtotal . Total
� Program Section ',. ',.
8 Moderate '�. '�.
.............. .............. .............. .............. .............. .............. .............. .............. .............. .............. .............. :........... .......:
[ 70600 HUDPHAOperatingGrants $5,395,080 $86,366 �I $5,481,446 �I $5,481,446 [
.............. .............. .............. .............. .............. .............. .............. .............. .............. .............. ............. :........... ........;
� 71100 Investrnentlnmme-Unrestricted $169 $0 '� $169 �'� $169
.............. .............. .............. .............. .............. .............. .............. .............. .............. .............. ............. :........... ........:
[ 71400 FraudRecovery $3,122 $0 �' $3,122 '' $3,122
71500 OtherRevenue $36,481 $0 $36,481 . $36,481
. .............. .............. .............. .............. .............. .............. .............. . .............. ............... .............. .............. !........... .....J
� 70000 TotalRevenue $5,434,852 $86,366 �� $5,521,218 ��, $5,521,218 �
.._. .._. .._. .._. .._. .._. .._. .._. .._. .._. .._. .._. _.�
.._. .._. .._. .._. .._. .._. .._. .._. .._. .._. .._. .._. ..;
� 91100 AdministrativeSalaries $472,435 $4,773 �'�. $477,208 �'�. $477,208
.._. .._. .._. .._. .._. .._. .._. .._. .._. .._. .._. .._. ..�
[ 91200 AuditingFees $4,455 $45 �� $4,500 �� $4,500
.._. .._. .._. .._. .._. .._. .._. .._. .._. .._. .._. .._. .�
: 91500 EmployeeBenefitmntributions-Administrative $206,385 $2,084 I. $208,469 I. $208,469
.._. .._. .._. .._. .._. .._. .._. .._. .._. .._. .._. .._. ..;
� 91600 OfficeExpenses $82,398 $831 '� $g3,229 '�, $83,229
.._. .._. .._. .._. .._. .._. .._. .._. .._. .._. .._. .._. ..�
[ 91800 Travel $140 $1 �I $141 �I $141
, .._. .._. .._. .._. .._. .._. .._. . .._. . .._. .._. .._. ..._. _.i
: 91900 Other $25,784 $260 �I $26,044 �I $26,044
, .._. .._. .._. .._. .._. .._. .._. . .._. . .._. .._. .._. ..._. _.i
� 91000 TotalOperating-Administrative $791,597 $7,994 �� $799,591 ��, $799,591
.._. .._. .._. .._. .._. .._. .._. .._. .._. .._. .._. .._. ..�
.._. .._. .._. .._. .._. .._. .._. .._. .._. .._. .._. .._. ..;
� 94300 OrdinaryMaintenanceandOperationsContracts $13,442 $136 �'�. $13,578 �'�. $13,578
.._. .._. .._. .._. .._. .._. .._. .._. .._. .._. .._. .._. ..�
[ 94000 TotalMaintenance $13,442 $136 �� $13,578 �� $13,578
.._. .._. .._. .._. .._. .._. .._. .._. .._. .._. .._. .._. .�
. .............. .............. .............. .............. .............. .............. .............. . .............. ............... .............. ............. :........... .....J
� 96ll0 Propertylnsurance $726 $7 '�, $733 '�, $733
. .............. .............. .............. .............. .............. .............. .............. e .............. e.............. .............. ............. :........... .......:
[ 96120 Liabilitylnsurance $5,046 $51 �I $5,097 'I $5,097
. .............. .............. .............. .............. .............. .............. .............. . .............. ............... .............. .............. :........... .......i
: 96130 Worlanen'sCompensation $1,891 $19 �I. $1,910 �I. $1,910
. .............. .............. .............. .............. .............. .............. .............. . .............. ............... .............. ............. ,........... .......i
[ 96100 Total insurance Premiums $7,663 $77 �� $7,740 ��, $7,740
.............. .............. .............. .............. .............. .............. .............. .............. .............. .............. .............. :........... .......:
� 96200 OtherGeneralExpenses $27,439 $265 '�.. $27,704 '�.. $27,704
.............. .............. .............. .............. .............. .............. .............. .............. .............. .............. ............. :........... .......;
� 96000 TotalOtherGeneralExpenses $27,439 $265 '�, $27,704 '�, $27,704
.._. .._. .._. .._. .._. .._. .._. .._. .._. .._. .._. .._. ..�
[ 96900 TotalOperatingExpenses $840,141 $$472 �I $848,613 'I $848,613
, .._. .._. .._. .._. .._. .._. .._. . .._. . .._. .._. .._. ..._. _.i
, .._. .._. .._. .._. .._. .._. .._. . .._. . .._. .._. .._. ..._. _.i
� 97000 ExcessofOperatingRevenueoverOperatingExpenses $4,594,711 $77,894 �� $4,672,605 ��, $4,672,605 �
.._. .._. .._. .._. .._. .._. .._. .._. .._. .._. .._. .._. _.�
[ 97300 HousingAssistancePayments $4,833,762 $74,888 �I $4,908,650 �I $4,90$650 [
.._. .._. .._. .._. .._. .._. .._. .._. .._. .._. .._. .._. _.;
� 97350 HAPPortability-In $6,261 $0 �'�. $6,261 �'�. $6,261
.._. .._. .._. .._. .._. .._. .._. .._. .._. .._. .._. .._. ..�
[ 90000 TotalExpenses $5,680,164 $83,360 �� $5,763,524 ��, $5,763,524 [
.._. .._. .._. .._. .._. .._. .._. .._. .._. .._. .._. .._. _;
.._. .._. .._. .._. .._. .._. .._. .._. .._. .._. .._. .._. ..;
� 100300peratingTransfersfiom/toPrimaryGovernment $229,559 $0 '�, $229,559 '�, $229,559
.._. .._. .._. .._. .._. .._. .._. .._. .._. .._. .._. .._. ..�
[ 10100 TotalOtherfinancingSources(Uses] $229,559 $0 �I $229,559 'I $229,559
, .._. .._. .._. .._. .._. .._. .._. . .._. . .._. .._. .._. ..._. _.i
, .._. .._. .._. .._. .._. .._. .._. . .._. . .._. .._. .._. ..._. _.i
� 10000 Excess(Deficiency]ofTotal Revenue Over(Under]Total Expenses -$15,753 $3,006 �� -$12,747 ��, -$12,747
.._. .._. .._. .._. .._. .._. .._. .._. .._. .._. .._. .._. ..�
.............. .............. .............. .............. .............. .............. .............. .............. .............. .............. ............. :........... .......;
� 11030 BeginningEquity $350,117 $186,235 �'�. $536,352 �'�. $536,352
.............. .............. .............. .............. .............. .............. .............. .............. .............. .............. .............. ............. ......J
Page 59 of 60
: 11170 AdministrativeFeeEquiTy $197,588 $0 I $197,588 I $197,588
.............. .............. .............. .............. .............. .............. .............. .............. .............. .............. ............. :........... .......;
.............. .............. .............. .............. .............. .............. .............. .............. .............. .............. ............. :........... ........:
[ 11180 HousingAssistancePaymentsEquity $136,776 $0 �' $136,776 '' $136,776
11190 UnitMonthsAvailable 12864 168 13032 � 13032
, .._. .._. .._. .._. .._. .._. .._. . .._. . .._. .._. .._. ..._. _.i
� ll210 NumberofUnitMonthsLeased 9872 162 ''�. 10034 ''�. 10034
Page 60 of 60
RESOLUTION NO. -19
RESOLUTION AUTHORIZING THE MAYOR TO EXECUTE THE CERTIFICATION BY
STATE OR LOCAL OFFICE OF PUBLIC HOUSING AGENCY (PHA) PLAN'S
CONSISTENCY WITH THE CONSOLIDATED PLAN AND APPROVAL OF THE PHA
ANNUAL PLAN
Whereas, the U.S. Department of Housing and Urban Development requires
submission of the Public Housing Agency (PHA) Plan on an annual basis; and
Whereas, the U.S. Department of Housing and Urban Development requires
Certification of the PHA Plan's Consistency with the Consolidated Plan;
NOW, THEREFORE BE IT RESOLVED BY THE CITY COUNCIL OF THE CITY
OF DUBUQUE IOWA:
Section 1 : That the Mayor is hereby authorized and directed to certify the PHA
Plan's Consistency with the Consolidated Plan; and
Section 2: That the Director of Housing and Community Development is hereby
authorized to submit the PHA Plan and the Certification as required by the U.S.
Department of Housing and Urban Development.
Passed, approved and adopted this 1 S� day of April, 2019.
Roy D Buol, Mayor
Attest:
Kevin Firnstahl, City Clerk
��I°�1�1Ca�10115 Of �O �D11�11C� Wlt�l U.S.Dep�trtment of Housing and Urban Development
Office of Public and Indian Housing
P A I'l�ns and elated e�ulat�ons OMB No.2577-0226
(Stan�la�d, 7'�oubled, HC'V Only, ane� �xpires 02/29/2016
Hi�h I'e�fo�me� PI�As)
PHA Certifications of Compli�nce with the PHA Plan and Related Regul�ttions including
Requirecl Civil Rights Certifications
Acting on behc�lf of the Board of Commissioners of the Public Housing Agency(PHA)listed below, ccs its Chnirmczn or other
czuthorized PHA official if there is no Boccrcl of Commissioners, I npprove the st�bmission of the S-Yeczr c�nd/or XX Annacnl PHA
Plczn for the PHA fisec�l year beginning Julv 1, 2019, hereinc�fter referred to czs"the Plan", of which this document is cz prtrt and mcrize
the following certificc�tions nnd ccgreements with the Depccrtment of Hoc�sing ccnd Urbccn Development(HUD) in connection with the
submission of the Plan ancl implementcttion thereof.�
1. The Plan is consistent with the applicable comprehensive housing affordability strategy(or any plan incorporating such
strategy)£or the jurisdiction in which the PHA is located.
2. The P1an conCains a certification by the appropriate State or local of�icials that the Plan is consistent with t1�e applicable
Consolid�ted Plan,which includes a certification that requires the preparation of an Analysis of Impediments to Fair Housing
Choice,for the PHA's jurisdiction and a description of the maruier in which the PHA Plan is consistent with the applicable
Consolidated Plan.
3. The PHA has established a Resident Advisory Board or Soards,the membership of which represents the residents assisted by
the PHA,consulted with this Resident Advisory Board or Boards in developing the Plan,including any changes or revisions
to the policies and programs identified in the Plan before they were implemented,1nd considered the recommendations of the
RAB (24 CFR 903.13).The PHA has included in the Plan suUmission a copy of the recommendations made by the Resident
Advisory Board or Boards and a description of the manner in which the Plan addresses these recommendations.
4. The PHA made the proposed Plan and all information relevant to the public hearing available for puUlic inspection at least 45
days before the hearing,published a notice that a helring would be held and conducted a hearing to discuss the Plan and ':
invited public comment.
5. The PHA certifies that it will carry out the Plan in conformity with Title VI of the Civil Rights Act of 1964,the Fair Housing :
Act,section 504 of the Rehabilitation Act of 1973,and title II of the Americans with DisaUilities Act of 1990.
6. The PHA will affirmatively fitrther fair housing by examining their programs or proposed programs,identifying any ,
impediments to fair housing choice within those programs,addressing those impediments in a reasonable flshion in view of
the resources available and worlc with local jurisdictions to implement any of the jurisdiction's initiatives to af�rmatively
fi►rther fair housing that require the PHA's involvement and by maintaining records reflecting these analyses and actions.
7. For PHA Plans that includes a policy for site based waiting lists: ;
• The PHA regularly submits required data to HUD's 50058 PIC/IMS Module in an accurate,complete and timely manner
(as specified in PIH Notice 2010-25);
• The system of site-based wliting lists provides for fiill disclosure to each applicant in the selection of the development in
which to reside,inchiding basic information about available sites; and an estimate of the period of time the applicant
would lilcely hlve to wait to be admitted to units of different sizes and types at each site;
• Adoption of a site-blsed waiting list would not violate any court order or settlement agreement or be inconsistent with 1
pendiug compl�int brought by HUD;
• The PHA shall talce reasonaUle measures to assure that such a waiting list is consistent with affirmatively furthering fair
housing;
• The PHA provides for review of its site-based waiting list policy to determine if it is consistent with civil rights laws and
certit"ications,as specif"ied in 24 CFR part 903.7(c)(1).
8. The PHA will comply with the prohibitions against discrimination on the basis of age pursuant to the Age Discrimination Act
of 1975,
9. The PIIA will comply with the Architectural Barriers Act of 1968 and 24 CFR Part 41,Policies and Procedures for the
�nforcement of Standards 1nd Requirements for Accessibility by the Physic111y Handicapped.
10. The PIIA will comply with the requirements of section 3 of the Housing and Urban Development Act of 1968,�mployment
Opportunities for Low-or Very-Low Income Persons,and with its implementing regulation at 24 CP'R Part 135.
11. The PHA will comply with acquisition and relocation requirements of the Uniform Relocation Assistance and Real Property
Acquisition Policies Act of 1970 and implementing regulations�t 49 CPR Part 24 as applicable. '
Page 1 of 2 form HUD-50077-ST-HCV-HP(12/2014) '
12. The PHA will talce appropriate af�rmative action to award conh•acts to ininority and women's business enterprises under 24
CFR 5.105(a).
13. The PHA will provide the responsible entity or HUD any documentation that the responsible entity or HUD needs to car�y
out its review under the National Environmental Policy Act and other related authorities in accordance with 24 CFR Part 58
or Part 50,respectively.
14. With respect to public housing the PHA will comply with Davis-Bacon or HUD determined wage rate requirements under
Section 12 of the United States Housing Act of 1937 and the Contract Work Hours and Safety Standards Act.
15. The PHA will lceep records in accordance with 24 CFR 85.20 and faeilitate an effective audit to detennine compliance with
program requirements,
16. The PHA will comply with the Lead-Based Paint Poisoning Prevention Act,the Residential Lead-Based Paint Hazard
Reduction Act of 1992,1nd 24 CFR Part 35.
17. The PHA will comply with the policies,guidelines,and requirements of OMB Circular No.A-87 (Cost Principles for State,
Local and Indian Tribal Governments),2 CFR Part 225,and 24 CFR Part 85 (Administrative Requirements for Grants and
Cooperative Agreements to State,Local and Federally Recognized Indian Tribal Governments).
18. The PHA will undertalce only activities and programs covered by the Plan in a manner consistent with its Plan and will utilize
covered grant funds only for activities thlt are approvable under the regulations and included in its Plan.
19, All at�achments to the Plan have been and wi11 contimie to be available at all times and a111ocations that the PHA Plan is
available for public inspection.All required supporting documents have been made available for public inspection along with
the Plan and additional requirements at the primary business office of the PHA and at all other times and locations identified
by the PHA in its PHA Plan 1nd will continue to be made available at least at the primary business ofi"ice of the PHA.
22. The PHA certifies that it is in compliance with applicable Federll stat�itory and regulatory requirements,including the
Declaration of Trust(s).
City of Dubuqtie IA087
PHA Name PHA Number/HA Code
X Annual PHA Plan for Fiscal Year 2019 ��
5-Year PHA Plan for Fisc�l Years 20 -20
I hereby certify thaC 111 the infocm�tion stated liereii�,�s�well�s any informltion provided in the accompauiuient herewith,is tnie and accurate.Warning: HUD will
prosecuYe f�lse claims�nd stacements.Conviction m1y result in criuiinll�nd/or civil penllties. (18 U.S.C. 1001,1010,1012;31 U.S.C.3729,3802).
Natne of A��Chorized Official Title
Ainy Eudaley Hoilsing Cominission Chairperson
Signatu� � D�te /�� .� !� �---�� / ��
����� � (J c�
Page 2 of 2 form HUD-50077-ST-HCV-HP(12/2014)
Civil Rights Certification U.S.Department of Housing and Urban Development
Office of Public and Indian Housing
�Qll(lllf BCZ PHf�S� OMB Approval No.2577-0226
Ex ires 02/29/2016
Civil Rights Certification
Annual Certification and Board Resolution
Acting on behatf of the Board of Commissioners of the Public Housing Agency(PHA) listed below, as its Chairman or other
authonzed PHA official I approve the submission of the 5-Year PHA Plan for the PHA of which this document is a par� and make the
following cerlification and agreements with the Deparbnent ofHousing and Urban Development(HUD)in connecfion with the
submission of the public housing program of the agency�d implementafion thereof.�
The PHA certifies that it will carry out the public housing program of the agency in conformity with title VI of
the Civil Rights Act of 1964,the Fair Housing Act, section 504 of the Rehabilitation Act of 1973, and title II of
the Americans with Disabilities Act of 1990, and will affirmatively further fair housing by examining their
programs or proposed programs, identifying any impediments to fair housing choice within those program,
addressing those impediments in a reasonable fashion in view of the resources available and working with local
jurisdictions to implement any of the jurisdiction's initiatives to affirmatively further fair housing that require
the PHA's involvement and by maintaining records reflecting these analyses and actions.
City of Dubuque IA087
PHA Name PHA Number/HA Code
I hereby certify that all the infortnation stated hereiq as well as any infortnation provided in the accompaniment herewith,is We and accurate.Warning: HUD will
prosecute false claims and statements.Conviction mav result in criminal and/or civil penalties (18 U.S.C.1001,1010,1012;31 U.S.C.3729,3802)
Name of Authorized Official TiTle
Alexis Steger Housing & Community Development Director
Signature Date
Previous version is obsolete Page 1 of 1 form HUD-5007ZCR(2/2013)
Certification by State or Local
Official of PHA Plans Consistency
with the Consolidated Plan or
State Consolidated Plan
(All PHAs)
U. S Department of Housing and Urban Development
Office of Public and Indian Housing
OMB No. 2577-0226
Expires 2/29/2016
Certification by State or Local Official of PHA Plans
Consistency with the Consolidated Plan or State Consolidated Plan
I, _Roy D Buol , the _Mayor of City of Dubuque
Official's Name
Official 's Title
certify that the 5 -Year PHA Plan and/or Annual PHA Plan of the
_City of Dubuque - IA087
PHA Name
is consistent with the Consolidated Plan or State Consolidated Plan and the Analysis of
Impediments (AI) to Fair Housing Choice of the
City of Dubuque
Local Jurisdiction Name
pursuant to 24 CFR Part 91.
Provide a description of how the PHA Plan is consistent with the Consolidated Plan or State
Consolidated Plan and the AI.
The City of Dubuque PHA Plan and the Consolidated Plan track the number of units per census
tract and track the location of affordable housing and type. The activities and goals include actions
the City will take to integrate affordable housing that is fully available without regard to race,
ethnicity, religion, national origin, sex, disability, familial status, gender or sexual orientation. Both
plans include specific goals to expand opportunities for Section 8 applicants and participants,
including strategies to increase affordability.
I hereby certify that all the information stated herein, as well as any information provided in the accompaniment herewith, is true and accurate. Warning: HUD will
prosecute false claims and statements. Conviction inay result in criminal and/or civil penalties. (18 U.S.C. 1001, 1010, 1012; 31 U.S.C. 3729, 3802)
Name of Authorized Official
Roy D Buol
Title
Mayor
Signature
Date
4/1/19
Page 1 of 1 form HUD -50077 -SL (12/2014)