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Submission of Family Self Sufficiency Action Plan
City of Dubuque City Council Meeting Consent Items # 011. Copyrighted September 19, 2022 ITEM TITLE: Submission of Family Self Sufficiency Action Plan SUMMARY: City Manager recommending City Council approve submitting the Family Self Sufficiency (FSS) Action Plan to Housing & Urban Development (HUD). RESOLUTION Authorizing the Director of Housing and Community Development to execute the submission of the Family Self Sufficiency Action Plan to HUD and authorizing the Director of Housing and Community Development and the City Manager to approve the FSS Action Plan SUGGESTED Suggested Disposition: Receive and File; Adopt Resolution(s) DISPOSITION: ATTACHMENTS: Description Type Family Self Sufficiency (FSS) Action Plan City Manager Memo Submission-MVM Memo Memo Staff Memo Resolution Resolutions 2022 FSS Action Plan Supporting Documentation THE C DUjIBQTE Masterpiece on the Mississippi TO: The Honorable Mayor and City Council Members FROM: Michael C. Van Milligen, City Manager SUBJECT: Submission of Family Self Sufficiency Action Plan DATE: September 13, 2022 Dubuque WAWca 914 ii 2007-2012.2013 2017*2019 Housing & Community Development Director Alexis Steger is recommending City Council approve submitting the Family Self Sufficiency (FSS) Action Plan to Housing & Urban Development (HUD). I concur with the recommendation and respectfully request Mayor and City Council approval. v Mic ael C. Van Milligen MCVM:sv Attachment cc: Crenna Brumwell, City Attorney Cori Burbach, Assistant City Manager Alexis Steger, Housing & Community Development Director Dubuque THE COF DUUB--*--TE AII•Amedla Bits }�. Masterpiece on the Mississippi p pp z°°'�*° 13 zoi720zoi9 TO: Michael C Van Milligen, City Manager FROM: Alexis Steger, Housing & Community Development Director DATE: September 9, 2022 RE: Submission of Family Self Sufficiency Action Plan INTRODUCTION Each year the City of Dubuque is required to submit the FSS Action Plan to HUD. The FSS Action Plan outlines the policies and procedures of the City of Dubuque's Family Self Sufficiency Program (FSS). The FSS Program runs alongside the Housing Choice Voucher Program and is an optional opportunity for HCV participants to enroll into and create goals and a path to financial stability, all while earning escrow for their efforts. HUD released a New Final Rule in June 2022 and with that rule many program guidelines and procedures have changed. The FSS Action Plan has been updated to reflect those changes. Once approved, the FSS Action Plan will take effect and all New Final Rule regulations will officially be adopted by the City of Dubuque PHA. BACKGROUND FSS is a program that enables HUD -assisted families to increase their earned income and reduce their dependency on welfare assistance and rental subsidies. Public Housing Agencies (PHAs) work in collaboration with a Program Coordinating Committee (PCC) to secure commitments of public and private resources for the operation of the FSS program, to develop the PHA's FSS Action Plan (the FSS policy framework), and to implement the program. HUD published a New Final Rule for the FSS Program in June 2022. This New Final Rule required PHA's to review and update policies and procedures to align with New Final Rule regulations. The City of Dubuque revised the FSS Action Plan to meet the New Final Rule regulations. Internal city staff worked to develop policies and procedures to align with the new regulations, while also incorporating the City of Dubuque's personnel policies and the Administrative Plan. The FSS Action Plan was then presented to the Housing Commission for review and comment. Housing Commission reviewed and approved the FSS Action Plan on September 7, 2022. RECOMMENDATION I respectfully request approval to submit the FSS Action Plan to HUD. Prepared by Gina Hodgson Housing & Community Devel 350 W. 61" St Suite 312 Telephone: (563) 690-6072 Return to Adrienne N. Breitfelder, City Clerk, 50 W. 13t' St., Dubuque, IA 52001, (563) 589-4100 RESOLUTION NO. 298-22 RESOLUTION AUTHORIZING THE DIRECTOR OF HOUSING AND COMMUNITY DEVELOPMENT TO EXECUTE THE SUBMISSION OF THE FAMILY SELF SUFFICIENCY ACTION PLAN TO HUD AND AUTHORIZING THE DIRECTOR OF HOUSING AND COMMUNITY DEVELOPMENT AND THE CITY MANAGER TO APPROVE THE FSS ACTION PLAN Whereas, the U.S. Department of Housing and Urban Development requires submission of the FSS Action Plan; and Whereas, HUD has released a New Final Rule to be adopted and finalized with the FSS Action Plan Submission; and Whereas, the Housing Commission reviewed and approved the FSS Action Plan on September 7, 2022. 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 FSS Action plan aligns with the New Final Rule released by HUD. Section 2: That the Director of Housing and Community Development and the City Manager have approved the FSS Action Plan. Section 3: That the Director of Housing and Community Development is hereby authorized to submit the FSS Action Plan as required by the U.S. Department of Housing and Urban Development. Passed, approved, and adopted this 19th day of September, 2022. .• M QnOnagh,Mayor Attest: Adrienne Breitfelder, City Clerk City of Dubuque FSS Action Plan September 2022 Table of Contents I. Introduction........................................................................................................................................ 4 II. Program Objectives...........................................................................................................................4 III. Program Size and Characteristics.................................................................................................... 5 III.A. — Family Demographics.................................................................................................................. 5 II1.13 — Supportive Services Needs............................................................................................................ 9 III. C. — Estimate of Participating Families............................................................................................10 III. D Other Self -Sufficiency Programs...............................................................................................11 IV. Family Selection Procedures...........................................................................................................12 V. Outreach...........................................................................................................................................18 VI. FSS Escrow Account and Other Incentives for Participants....................................................... 21 VII. Family Activities and Supportive Services.................................................................................... 27 VIIL Method of Identifying Family Support Needs and Delivering Appropriate Support Services 32 IX. Contract of Participation................................................................................................................. 33 X. Program Termination, Withholding of Services, and Available Grievance Procedures ........... 44 XI. Assurance of Non-Interference....................................................................................................... 49 XII. Timetable.......................................................................................................................................... 50 XIII. Reasonable Accommodations, Effective Communications, and Limited English Proficiency. 51 XIV. Coordination of Services................................................................................................................. 53 XIV.A Coordination of Services (PHAs only)...................................................................................... 53 XIV.B Coordination of Services (Multifamily owners only)................................................................ 54 XV. FSS Portability (Applicable to HCV Only)....................................................................................55 XVI. Other Policies................................................................................................................................... 57 XVII. Definitions....................................................................................................................................... 64 3 I. Introduction Instructions: While not required by the Introduction applicable regulations, an introduction is This document constitutes the Family Self Sufficiency (FSS) Program Action Plan for the FSS recommended to provide an overview of program operated by the City of Dubuque Housing and Community Development what the document is and what it contains. Department. It was submitted to HUD on 912812022. The purpose of the FSS Program is to promote the development of local strategies to coordinate the use of HUD assistance with public and private resources in order to enable eligible families/households to make progress toward economic security. The purpose of the FSS Action Plan is to establish policies and procedures for carrying out the FSS program in a manner consistent with HUD requirements and local objectives. This FSS Action Plan describes the City of Dubuque Housing and Community Development Department's local polices for operation of the FSS program in the context of federal laws and regulations. The FSS program will be operated in accordance with applicable laws, regulations, notices, and HUD handbooks. The policies in this FSS Action Plan have been designed to ensure compliance with all approved applications for HUD FSS funding. For PHAs: The FSS program and the functions and responsibilities of PHA staff are consistent with the City of Dubuque Housing and Community Development Department's personnel policy and Agency Plan. II. Program Objectives Instructions: While not required by the Program Objectives applicable regulations, a section on program objectives can help provide an overall City of Dubuque Housing and Community Development Department's FSS program seeks to framing for what your FSS program is help families make progress toward economic security by supporting the family's efforts to: trying to achieve. Your FSS program is free . Increase their earned income to adopt whatever local objectives you wish . Build financial capability 4 so long as they do not conflict with the federal objectives. The federal objectives for the FSS program are specified in 24 CFR 984.102. III. Program Size and Characteristics III.A. — Family Demographics Achieve their financial goals Set and reach personal and individualized goals Become more self-sufficient Instructions. Describe the I Family Demographics characteristics of the families you expect to be served by your FSS These tables describe the demographics of the population expected to be served by City of Dubuque program. This information must Housing and Community Development Department's Action Plan. include data on their race and ethnicity and may also include data on other characteristics. Note: This information is required per 24 CFR § 984.201(d)(1). That section also requires a description of supportive service needs of families expected to be served, which is covered in Section III.B of this sample Action Plan, and how many families are expected to be served, which is covered in Section III.C. Description of sample tables Start by indicating which housing assistance programs your FSS program will serve by checking the appropriate boxes. The FSS program will serve the following housing assistance programs ❑ Public Housing, ❑X Housing Choice Vouchers (HCV): Tenant -Based Vouchers © Housing Choice Vouchers (HCV): Project -Based Vouchers (PBV) © Housing Choice Vouchers (HCV): HCV Homeownership © Housing Choice Vouchers (HCV): Other special purpose vouchers (e.g. FUP, FUP-Y, FYI, VASH, EHV, etc) (Specify, FUP, FUP-Y, NED, TPV, and VASH) ❑ Section 8 Moderate Rehabilitation ❑ Project -Based Rental Assistance (PBRA) ❑ Other Program (Specify: ) The sample Action Plan then includes several tables that you may use to show characteristics of the population expected to be served. If it makes it easier to develop estimates, new FSS programs may assume that FSS participants will be similar to the general population of the PHA or property. To describe the characteristics of the families your program plans to serve, you may use the tables in the right-hand column and fill them in to provide the appropriate information. You may also modify the tables to specify different ranges or to otherwise reflect the available data. The information requested through the tables should be available on the HUD- 50058 or HUD-50059 Family Reports in PIC or TRACS, respectively. To complete the tables: • Ages of Head and Other Adults. For each row, estimate the share of heads or other adults (as noted) in each age category. • Presence and Ages of Children. For the first row, estimate the percentage of Ages of Head of Household and Other Adults Percent Ages of Head of Household --Head of Household is age 24 years or younger _5_% --Head of Household is age 25 to 50 _54_% --Head of Household is age 51 to 61 _ 19_% --Head of Household is age 62 or greater _22_% Ages of Other Adults in Household -- Age 24 years or younger _ 8_% -- Age 25 to 50 _4_% -- Age 51 to 61 _1_% -- Age 62 or greater _1_% Presence and Ages of Children Percent Presence and Ages of Children --Households that only include adults over age 18 14_% --Households that include one or more child age 13-17 _ 44% --Households that include children who are all 12 or younger _ 42_% 0 households that have no children under 18. For the second row, estimate the percentage of households with one or more child age 13-17. For the third row, estimate the percentage of households that include at least one child age 12 or younger and no children over age 12. Employment Status. For the first two rows, estimate the share of families whose heads are employed and unemployed. The two rows should add up to 100%. The next two rows show similar information, but for all family members. These two rows should also add up to 100%. • Annual Earned Income. Estimate the share of families within each earned income category. • Elderly/Disability Status. Estimate what share of families have an elderly head or a head with disabilities, and then estimate what share of families include an elderly person or a person with disabilities. Employment Status of Population to be Served Percent Employment Status of Head of Household --Families with an employed head _30_% --Families whose head is unemployed _70_% Employment Status of All family members --Families with any member that is employed _32_% --Families with no employed member _68_% Annual Earned Income of Population to be Served Percent Annual household earnings <$5,000 per year 22 % Annual household earnings between $5,000 and $9,999 _ 16_% Annual household earnings between $10,000 and $14,999 33 % Annual household earnings between $15,000 and $19,999 14 % Annual household earnings between $20,000 and $24,999 8% Annual household earnings between $25,000 and $29,999 3 % Annual household earnings between $30,000 and $34,999 _2_% Annual household earnings of $35,000 or higher 2_% 7 Race/ethnicity. This is a required table. Estimate the racial and ethnic composition of the families to be served by the FSS program. In this table, the percentages in the Non - Hispanic and Hispanic columns should add up to the percentage shown in the Race column. For example, if 50 percent of the expected population to be served consists of White households, and half of these households are expected to be Hispanic, enter 50% in the first column and 25% in each of the next two columns. Elderly/Disabihty Status of Population to be Served Percent Elderly/Disability Status of Head of Household --Head of Household is an elderly person without disabilities 7% --Head of Household is an elderly person with disabilities 16 % --Head of Household is a non -elderly person without disabilities 47 % --Head of Household is neither an elderly person nor a person with disabilities _ 47_% Elderly/Disability Status of All Household members --Household includes an elderly person without disabilities 10 % --Household includes an elderly person with disabilities 18 % --Household includes a non -elderly person with disabilities _38_% --Household includes no elderly persons or persons with disabilities 44 % Race and Ethnicity of Population to be Served (required) Race Non -Hispanic Hispanic White 54 % 97 % 3 % Black or African American 43 % 97 % 3 % American Indian or Alaska Native 0 % 0 % 0 % Asian 0 % Native Hawaiian or other Pacific Islander 2 % _100_% _0_% Other Race 0 % 0 % 0 % 0 III.B — Supportive Services Needs Instructions: Describe in this section the I Supportive Services Needs of Families Expected to Participate in FSS supportive service needs of the families you expect to participate in your FSS program. The sample text provides illustrations of needs to consider. Feel free to adjust this list to reflect the needs you identify. Then indicate how you identified the supportive services needs by checking one or more of the boxes and/or adding your own explanation. Note: 24 CFR § 984.201(d)(1) specifies that FSS Action Plans must include "Family demographics. A description of the number, size, characteristics, and other demographics (including racial and ethnic data), and the supportive service needs of the families expected to participate in the FSS program" The characteristics other than supportive service needs are covered above, in Section III.A and the size of the program is covered in Section III.C. The following is a list of the supportive service needs of the families/households expected to enroll in the City of Dubuque Housing and Community Development Department's FSS program: • Training in basic skills and executive function (including household management) • Employment training, including sectoral training and contextualized and/or accelerated basic skills instruction • Job placement assistance • Job readiness • GED preparation • Higher education guidance and support • English as a Second Language • Assistance accessing and paying for childcare • Parenting Skills • Transportation assistance • Financial coaching, including assistance with budgeting, banking, credit, debt, and savings • Access to counseling or treatment for substance abuse and mental health • Dental care, health care, and mental health care including substance abuse treatment/counseling • Homeownership readiness This list of supportive services needs is based on: ® Experience with past FSS or other supportive service program participants ® Input from the PCC or other service provider partners ❑ A needs assessment completed on [date] ❑ Other: 0 III. C. — Estimate of Participating Families Instructions: Provide an estimate of the number of eligible families who can reasonably be expected to receive services based on available resources. If you are funded for FSS coordinator positions, by virtue of that funding, you have a minimum number of participants to be served each year. Be sure that your Estimate of Participating Families is at a minimum, the number of participants required by your funding. Estimate of Participating Families Over time, City of Dubuque Housing and Community Development Department hopes to serve all families who are interested in participating in the FSS Program. The number of spaces available in the program at any given time, however, will be limited by the program's resources, including the number of FSS coordinators funded to work with FSS participants. New families will be admitted to the FSS program as space permits. Note that if you have not yet fulfilled your Mandatory . In recent years, the City of Dubuque Housing and Community Program size requirement, your Estimate of Participating Development Department has been funded for Two (2) coordinators. Families must be at least the minimum program size required The minimum number of participants required to be served based on for your agency. For more information, see 24 CFR §984.105 this funding is 75. and FSS Guidebook Section 6.6 Minimum FSS Program Size). Estimating Participating Families You must describe how many families you expect your FSS program will be able to serve at a time and then estimate how many families your program will serve over a five-year period. The sample text includes different options for existing and new programs. If you are operating an existing program, you should use your records to identify how many families enroll per year and add five years of new enrollment to the typical program size to estimate how many families you will serve over five years. If you are starting a new program, you will need to adopt some assumptions about graduation and attrition for other reasons. For example, assume an FSS program has a capacity of 100 families and expects to operate at capacity at all times. If the program expects 50 of those families to graduate in five years (with some families getting an extension) and 10 • Historically, City of Dubuque Housing and Community Development Department's FSS program has served at least 75 families in the FSS program each year. Accordingly, City of Dubuque Housing and Community Development Department expects to be able to provide FSS Services to at least 375 families over a five-year period. 10 families to leave the program each year for other reasons, the expected number of families to be served in the first five years is 200 (100 + 50 new enrollees who replace graduates + 50 new enrollees who replace families who leave for other reasons.) Note that the number of families your FSS program expects to serve is different from the minimum number of families that your FSS program is required to serve under the terms of the Notice of Funding Opportunity that allocated the funds. FSS programs are encouraged to enroll more than the minimum number of families, so long as this is possible without compromising your program's quality. If your agency is a PHA with an FSS mandate, you should include the text indicated in the right-hand column and complete the table. In accordance with CFR §984.105(c), if the Estimate of Participating Families is smaller than the Minimum Program Size, indicate if you have an exception granted by HUD to run a program smaller than the mandate and when that exception III. D — Other Self -Sufficiency Programs Instructions: If you expect families from another self- sufficiency program to enroll in your FSS program, provide estimates of the numbers of these families. For PHAs: If you seek to enroll families in the FSS program that are nearing the end of their eligibility for the Jobs Plus Earned Income Disregard as a way to continue to serve these families, you may wish to describe this approach in this section. Other Self -Sufficiency programs PHA Policy The City of Dubuque Housing and Community Development Department's expects to enroll into FSS, families from the self-sufficiency programs checked in the table below. 11 The sample Action Plan text includes two options — one for FSS programs that expect to enroll families from other self- sufficiency programs and one for FSS programs that do not. Choose the option that best fits your program. If you choose Option 1, check the applicable boxes to indicate which programs are included and, if you have an estimate in mind, indicate the number of families from that program you expect to enroll. For more information, see 24 CFR §984.201(d)(3) and FSS Guidebook section 2.2 Outreach and Enrollment. Name of Program Check box if applicable Number of Families each year Family Unification Program - Family ® 5 Family Unification Program — Youth (FUP-Y) ® 0 Foster Youth Initiative (FYI) ❑ Resident Opportunity and Self -Sufficiency (ROSS) ❑ Jobs Plus ❑ Emergency Housing Voucher (EHV) ❑ Veterans Affairs Supportive Housing (VASH) x 1 Other: NED, TPV © 5 *Based on the lack of DHS referrals IV. Family Selection Procedures Instructions: Describe your policies and procedures for selecting FSS participants, including whether your FSS program will offer a preference to prospective participants who are already enrolled in, or on the waiting list for, FSS-related service programs and whether your FSS program plans to screen prospective participants for motivation to participate. (Note that motivation is the only allowable screening criteria to include). Note: The maximum number of FSS slots with a selection preference is Family Selection Procedures A. Waiting List PHA Policy A waiting list will be maintained for families/households whose applications cannot be accepted at the time of initial application due to program capacity limits. The waiting list will include the name and contact information for the head of household of the applicant family, and the date and time of their application. B. Admissions Preferences PHA Policy The FSS program has not adopted any admissions preferences. Families/households will be selected based on the following selection method: 12 limited to 50% of the total number of FSS slots. For any preference your program selects, you must provide the following: 1. Percentage of slots for which your program will give the selection preference 2. If applicable, the FSS related service programs to which your program will give a selection preference 3. The method of outreach to, and selection of, families with one or more members participating in the identified programs 4. How families with the applicable preferences will be selected from the wait list: (a) date and time of application; or (b) a drawing or other random choice technique. (see 24 CFR 984.203 and FSS Guidebook Section 2.2 Outreach and Enrollment) Policy Decisions: In completing this section, you will need to make the following policy decisions: 1. Whether to allow selection preferences. If so, (a) what selection preferences, (b) outreach methods, and (c) selection methods. Start by Selection Method Lottery Length of time living in subsidized housing Date the family expressed an interest in participating in the FSS program Other: [specify] PHA Policv Check applicable method El El 04 FM — The PHA will not adopt the use of selection preferences when selecting families/households for participation in the FSS program. The PHA will use the date the family/households expressed an interest in participating in the FSS program to fill the FSS slots for which the PHA chooses not to exercise the selection preference. The PHA will not adopt the use of selection preferences for porting families/households. C. Screening for motivation. PHA Policy The City of Dubuque Housing and Community Development Department will use one or more motivational screening factors to measure the family's/household's interest and motivation to participate in the FSS program. The following screening criteria will be used: ® Orientation Session: The City of Dubuque Housing and Community Development Department will screen families/households for motivation to participate in the FSS program by requiring that families/households who apply to enroll in the FSS program attend an initial orientation session. Each family/household will be given two opportunities to attend the orientation session and may request accommodation if unable to attend a scheduled orientation session. Accommodations will be offered on a case -by -case basis, depending on the needs of the applicant. Accommodations may include an 13 indicating whether you will utilize any selection preferences by selecting the appropriate option. Then complete the table applicable to that option. The "% of FSS slots" is a percentage of the whole anticipated program size, as established in III.0 (above) 2. Whether to include a screening for motivation. If so (a) what the screening will entail, and (b) how the FSS program will ensure reasonable accommodations to avoid discrimination. Select the appropriate option. 3. What families or family members may re -enroll in the FSS program following exit from the program and under what circumstances. 4. What process to follow for documenting the family's choice of Head of FSS Family (FSS contract holder). Note: Your FSS program may use motivational screening factors to screen families interested in participating in the FSS program. You may use these factors to measure a family's interest and motivation to participate in the FSS program. individually scheduled orientation session, provision of transportation to/from the orientation site, translation services, an alternative location, a virtual orientation session, or allowance and encouragement to bring children to the session, where possible. ® Other Screening Criteria: • The City of Dubuque Housing and Community Development Department will screen families for motivation to participate in the FSS program by requiring that families who apply to enroll in the FSS program to have 1-2 interim goals in mind that they want to achieve during the CoP term, and plan to discuss those goals with the coordinator during the orientation meeting. PHA Debt Selection Factor The City of Dubuque Housing and Community Development Department will deny FSS participation to a family if the family owes the City of Dubuque Housing and Community Development Department, or another PHA, money in connection with HCV or public housing assistance. Families that owe money to a PHA who have entered into a repayment agreement and are current on that repayment agreement will not be denied FSS participation. Unavailable Support Services Selection Factor • After consulting with the family/household, PCC, and other community partnerships that a missing service is essential to the family/household's needs, the PHA may skip that family/household (and other similar families/households) and offer the FSS slot to the next family/household for which there are available services. 14 (see 24 CFR 984.203 and FSS Guidebook Section 2.2 Outreach and D. Compliance with nondiscrimination policies Enrollment) Note: This section includes a PHA Policy required statement affirming that the It is the policy of City of Dubuque Housing and Community Development Department to comply with organization will not engage in unlawful discrimination. all Federal, State, and local nondiscrimination laws and regulations, including but not limited to the Fair Housing Act, the Americans with Disabilities Act, and Section 504 of the Rehabilitation Act of 1973. No person shall be excluded from participation in, be denied the benefits of, or otherwise be subjected to discrimination under the FSS program on the grounds of race, color, sex, religion, national or ethnic origin, family status, source of income, disability or perceived gender identity and sexual orientation. In addition, City of Dubuque Housing and Community Development Department's FSS staff will, upon request, provide reasonable accommodation to persons with disabilities to ensure they are able to take advantage of the services provided by the FSS program (see Requests for Reasonable Accommodations). The FSS program staff has the primary responsibility to make sure that participants are not discriminated against in the selection process. For families/households whose potential enrollment is in question, the FSS coordinators will review the file in the staff review meeting to ensure that non - selection is not based on discriminatory factors before the final decision is made. Applicants will be notified in writing of the reason(s) they were not selected for participation and will have the opportunity to appeal the decision (see Hearing Procedures). At all times, City of Dubuque Housing and Community Development Department will select families/households for participation in the FSS program in accordance with FSS Regulations and HUD guidelines. E. Re -enrollment of prior FSS participants PHA Policy The following previous FSS families/households will be allowed to re -enroll in City of Dubuque Housing and Community Development Department's FSS program: FSS program graduates: Families/household that graduated from the FSS program with escrow that did not exceed $4,999.99. 15 The family/household completed the contract of participation by exceeding 30% FMR and did not earn escrow. • The family/household completed the contract of participation by exceeding 30% FMR and earned escrow that did not exceed $4,999.99. FSS participants who have withdrawn voluntarily • The participant is willing to review with the caseworker the reason(s) they were unsuccessful or withdrew from the program previously, how they plan to be more successful in the future, what has changed to make the participant now ready to re - enroll and require participant to read and sign an "Agreement to Succeed" form. Families/Households terminated with escrow disbursement • The PHA and family/household agree that one or more critical services/resources that was previously unavailable has become available. • If FSS contract holder that became permanently disabled and unable to work after earning escrow previously that did not exceed $4,999.99, now has a household member that is willing and able to assume the CoP as the designated FSS contract holder. Families/Households involuntarily terminated • PHA will make determinations on a case -by -case basis to cover incidents that may or may not be in compliance with HUD federal regulations and guidelines. Family members who were not FSS contract holders previously • If family member was not a member of the household during initial CoP term. If family member is now able to work in the US but couldn't work in the US during the initial CoP term. • If family member was diagnosed by a medical professional that they were unable to work due to a disability and/or physical, mental, and/or emotional issues during the initial CoP term but has been determined by a medical professional that family is now able to work. 16 The following conditions apply to each re -enrollment criteria: • PHA may allow a family/household to enroll in the FSS program up to 2 times and only after at least 1 year has passed from their previous enrollment in the FSS program. • PHA will review requests to enroll previous participants on a "case -by -case" basis to cover incidents that may or may not be in compliance with HUD federal regulations and guidelines and that may or may not be noted above. • The caseload and capacity of FSS program coordinator staff allows for the re- enrollment(s). • PHA will establish higher standards for ITSP goals for re -enrollments of FSS graduates who previously completed a CoP. The PHA will not select families for participation a second time if: • The household successfully completed the contract of participation and earned escrow of $5,000.00 or more. • An act occurred that was inconsistent with the purpose of the FSS program. • An incident(s) occurred that may or may not be in compliance with HUD federal regulations and guidelines and that may or may not be noted above. This will be reviewed on a case -by -case basis. F. FSS Contract Holder (Head of FSS Family) PHA Policy The FSS contract holder is designated by the participating family/household. The City of Dubuque Housing and Community Development Department may make itself available to consult with families on this decision, but it is the assisted household that chooses the FSS contract holder that is most suitable for their individual household circumstances. The designed FSS contract holder or any changes 17 V. Outreach made by the family/household to the FSS contract holder must be submitted to the City of Dubuque Housing and Community Development Department in: • Writing via the "Designated FSS Contract Holder Agreement" (an official document developed by the City of Dubuque Housing and Community Development Department). • City of Dubuque Housing and Community Development Department will require households interested in participating in the FSS program to designate a "FSS contract holder" for their family/household. • City of Dubuque Housing and Community Development Department requires that the family/household chooses a FSS contract holder that is most suitable for their individual family/household circumstances. The PHA may make itself available to consult with families/households on this decision. • The FSS contract holder may, but is not required to be, the head of the household for purposes of determining income eligibility and rent. • City of Dubuque Housing and Community Development Department will incorporate the "Designated FSS Contract Holder Agreement" document with the FSS initial/enrollment paperwork and require every household member that is 18 yrs. of age and older to read, sign, date, and return the agreement to the coordinator as part of the enrollment process. • City of Dubuque Housing and Community Development Department will require the designated FSS contract holder to read, sign, and date the contract of participation (CoP). 18 Instructions: Describe the planned Outreach notification and outreach efforts by your FSS program to recruit FSS PHA Policy participants from among eligible The City of Dubuque Housing and Community Development Department will conduct widespread families and to provide FSS outreach to encourage enrollment in the FSS program. Outreach efforts will include the activities information to minority and non- identified through the checked boxes below: minority families. Note: Interpreters will be used as needed and clients may contact staff to express interest in person, via The sample Action Plan lists a our toll -free telephone number or by email. number of typical outreach methods. Outreach Methods Details, including frequency Check the ones that apply to your program and provide details about X❑ Posting information about FSS on the City of City of Dubuque Housing and Community how you will implement each Dubuque Housing and Community Development Development Department will provide method, including how often. Department's website updated information about the FSS program on You should feel free to modify this it's webpage on a as needed basis. section to reflect your program's outreach strategy. However, it is X❑ posting FSS program flyers in locations likely City of Dubuque Housing and Community recommended that you retain the note to be seen by eligible families Development Department will post FSS flyers at the end of this section which throughout the community in locations where affirms that outreach will comply families most likely frequent as needed and as with all applicable fair housing allowed. protections. FSS flyers will also be placed in a display outside the City of Dubuque Housing and (see 24 CFR 984.201(c)6 and FSS Community Development Department office Guidebook Section 2.2 Outreach and where families obtain housing information and Enrollment) documents on a continuous basis. X❑ Providing information about the FSS program City of Dubuque Housing and Community during scheduled reexaminations Development Department HCV caseworkers will discuss FSS with HCV families/households and provide them with FSS flyers and brochures at every annual and/or interim reexamination. FSS flyers will be included when mailing rental licenses to Landlords/Property Owners as well. 19 ❑X Providing information about the FSS program City of Dubuque Housing and Community at voucher orientation sessions Development Department HCV caseworkers are required to introduce the FSS program with each new HCV participants at each voucher orientation session. The HCV caseworker will provide the new HCV participant with an FSS interest form (created by the City of Dubuque Housing and Community Development Department) to complete and return to the HCV caseworker as part of their HCV paperwork. The caseworker will give all Interest forms that indicates that they are "interested" in participating in FSS to the FSS Coordinator for follow up. X❑ Holding well -publicized information sessions City of Dubuque Housing and Community about FSS Development Department will hold well publicized information sessions about FSS with organizations throughout the community as requested and as needed with the intent of educating those community organizations about FSS to render appropriate FSS referrals, including local Landlord Association meetings/events. X❑ Providing information about the FSS program City of Dubuque Housing and Community to eligible families by mail Development Department will conduct a mailing to eligible families at least once a year. X❑ Facebook City of Dubuque Housing and Community Development Department will promote and market the FSS program, its benefits, and community resources/information on its FSS Facebook page daily or as needed. ❑ Twitter 20 ❑ Instagram ® Other Community Events City of Dubuque Housing and Community Development Department will attend community resource events where eligible families/households or organizations that serve eligible families/households may be present to market, discuss, and promote the FSS program when available. Outreach informational material about the FSS Program will include information about: • Program overview • Program benefits • Participant eligibility requirements • Participant responsibilities • Program outcomes Outreach efforts will be targeted equally to all families/households, using materials in both English and other commonly spoken languages to ensure that non-English and limited English-speaking families/households receive information and have the opportunity to participate in the FSS Program. In conducting outreach, the City of Dubuque Housing and Community Development Department will account for the needs of person with disabilities, including persons with impaired vision, hearing, or mobility, and provide effective communications to ensure that all eligible who wish to participate are able to do so. v i. v Nn, Escrow account ana utner incentives for rartici Instructions: Describe your FSS FSS Escrow Account and Other Incentives for Participants program's policies regarding the escrow account, as well as any other PHA Policy incentives that you intend to offer eligible families to encourage FSS participants will be eligible to build savings from the FSS escrow account. Key policies and participation in the FSS program. procedures applicable to the FSS escrow account, as well as any additional incentives offered by the City of Dubuque Housing and Community Development Department, are described below. 21 The sample text covers key issues related to escrow program administration, including interim disbursements. While FSS programs are not required to offer interim disbursements, HUD encourages FSS programs to do so as a way of helping families stay on track toward their goals. (see 24 CFR 984.305 and FSS Guidebook Section 2.2 Outreach and Enrollment for information on incentives. See 24 CFR 984.305(c)2 and 24 CFR 984.305(f)2 respectively for regulations relating to interim disbursement of escrow funds and information relating to forfeited escrow funds and FSS Guidebook Section 5.2 The FSS Escrow Account.) Policy Decisions: In completing this section, you will need to make the following policy decisions: I. Whether to provide financial incentives to FSS participants (in addition to the escrow account), and, if so, what incentives to provide under what conditions. (Select the appropriate option.) 2. Whether to allow interim disbursements of escrow savings. If so: (a) under what conditions will interim disbursements be permitted (including restrictions A. Additional Incentives While the City of Dubuque Housing and Community Development Department's FSS program does not provide any other financial incentives for FSS participants, it does provide coaching services, as well as referrals to other service providers, that can be very valuable for FSS program participants. B. Interim Disbursements PHA Policy ® The City of Dubuque Housing and Community Development Department will allow for interim disbursements on a case -by -case basis: Families/households may request an interim disbursement from the escrow account once the FSS family/household has fulfilled at least one interim goal, in order to pay for specific goods or services that will help the family/household make progress toward achieving the goals in its Individual Training and Services Plan (ITSP). Requests will be made in writing. Requests may be made through the term of the Contract of Participation. Examples of potentially eligible activities include, but are not limited to, payments for post -secondary education, job training, credit repair, small business start-up costs, job start-up expenses, and transportation to/from a place of employment. A determination of whether the family/household qualifies for the requested interim disbursement will be made on a case -by -case basis by the FSS Coordinator and an administrative staff representative of The City of Dubuque Housing and Community Development Department The FSS coordinator will first explore options for services and in -kind donations from partners, which must be exhausted before a request for an interim disbursement will be approved. The PHA will disburse a portion of the FSS escrow account funds before completion of the CoP when the family/household is in compliance with the CoP to date, including the completion of at least one (1) ITSP interim goal and task to date, and: • Requested funds are needed in order to complete an interim goal or task within the COP and are not ongoing expenses. The FSS contract holder may make interim withdrawals from their escrow accounts prior to graduation. The FSS contract holder will complete a "Request for Interim Withdrawal of Escrow Funds" form and submit it to 22 on interim disbursements, if any), and (b) what your programs procedures for applying for and approving interim disbursements will be. (Three options have been provided. If you select the second option, indicate what guidelines apply to specific expenditure types.) In your policy, be sure to include • how a request is made • by whom • any limitations on when a request may be made • eligible activities • how the request will be reviewed/who will make the determination 3. What are the eligible uses of forfeited escrow funds? (Check the uses that apply to your FSS program. In your policy, be sure to include • how a request is made • by whom • any limitations on when a request may be made • eligible activities the FSS Coordinator and PHA Review Committee for review. Interim Disbursements can be used to pay for services needed to help participants achieve their ITSP goals. • Only the FSS contract holder can request interim disbursements. • To determine an interim disbursement request approval or denial, PHA will keep detailed records of participant's activities toward interim goals. • The decision to approve or deny the interim request will be at the FSS Coordinator and PHA's discretion. • If approved, interim disbursements may be paid up to a specified dollar amount agreed upon between the FSS contract holder and PHA. Interim disbursements will be paid to a third party whenever possible such as a company, business, or organization to whom the payment is due. PHA will require the FSS contract holder to provide PHA with documented proof of payment to the company, business, or organization to whom the payment was due. NOTE the new CoP states "the PHA may disburse an amount in the family's FSS escrow account to the FSS contract holder in compliance with its interim withdrawal policies and 24 CFR 984.305". • Participants are required to provide FSS Coordinators with a combination of self -verification and documented proof of completed goal(s) and welfare independence. • Once reviewed by PHA Review Committee, the FSS participant will be notified in writing of the final decision. • Interim Disbursement Requests will be reviewed on a case -by -case basis in conjunction with coaching and discussion with the participant. • Participants are entitled to an informal grievance or hearing process if their request for an interim disbursement is denied. • Interim Disbursements are not mandatory. 23 • how the request will be • Only the FSS contract holder can request interim disbursements from the reviewed/who will make the escrow account. determination • Unless the interim disbursement was made based on fraudulent information from the family, the family is not required to repay such interim disbursements if the family does not complete the Contract of Participation. C. Uses of forfeited escrow funds. PHA Policy Treatment of forfeited FSS escrow account funds. FSS escrow account funds forfeited by the FSS family (if any) will be used to support FSS participants in good standing. Upon written request from a family, the FSS Coordinator and a member of the PCC will consider the available funds and make a determination. • The City of Dubuque Housing and Community Development Department may also initiate a request for the use of forfeited escrow funds. • Forfeited Escrow has no time limit to be used by, and will be used to: (A) Support FSS participants that are in "good standing", including, but not limited to, transportation, childcare, training, testing fees, employment, preparation costs, assist FSS participants to pursue any goal on their CoP/ITSP, other costs related to achieving obligations outlines in the CoP, and can be used to benefit several participants at the same time (e.g., a class, etc.). a. This final rule defines "good standing" as an FSS family that is in compliance with their FSS CoP; has either satisfied or are current on 24 any debts owed the PHA; and is in compliance with the regulations regarding participation in the relevant rental assistance program, including rent payments. (B) Trainings for FSS Program Coordinators; or (C) Other eligible activities as determined by the Secretary (ii) Such funds will not be used for salary and fringe benefits of FSS Program Coordinators; general administrative costs of the FSS Program, for housing assistance payments (HAP) expenses or public housing operating funds; or any other activity determined ineligible by the Secretary. (iii) The amount of forfeited escrow to be utilized for allowed purposes will be at the discretion of the PHA. Forfeited funds are used to advance participants' goals and not for the overall implementation of the FSS program. • Forfeiture of Escrow will be a last resort if a family decides to port. PHA will examine all possible scenarios to ensure that the FSS participant that has decided to port receives the escrow. FSS program coordinators will fully explain how portability affects FSS participation and the participant's escrow account prior to a participant making a portability move. • Forfeited escrow will not be used to settle any debts owed by the family to the PHA. • If participants cannot continue participation in the FSS program, they may be required to forfeit the accrued funds in their escrow account. • PHA will establish a "Forfeited Escrow" account to manage all forfeited escrow. At the discretion of the FSS coordinator, forfeited escrow funds may be considered in lieu of an interim escrow disbursement. Forfeited FSS escrow funds may be disbursed: 25 • At any time during the term of a family/household's CoP Use of forfeited escrow funds for eligible uses (described below) may be requested by: • City of Dubuque Housing and Community Development Department • FSS contract holder Eligible uses of forfeited escrow funds include, but are not limited to: ® Child Care ® Training for participants ® Employment or Educational Costs, including: ® Employment training ® Employment preparation (e.g., interview training, professional clothing, etc.) ® Education costs (books, fees, uniforms, tools, etc.) 26 ® Requests will be considered on a case -by -case basis ® Requests will be considered on a case -by -case basis © Requests will be considered on a case -by -case basis ® Training for FSS Program ® Requests for funding must be approved by the City of staff Dubuque Housing and Community Development Department and the PCC ® Other: Other goals/Other ❑X Assist FSS participants with pursuing any goal on Costs their CoP/ITSP, other costs related to achieving obligations outlines in the CoP and can be used to benefit several participants at the same time (e.g., a class, etc.). N Requests will be considered on a case -by -case basis VII. Family Activities and Supportive Services Instructions: Describe the Family Activities and Supportive Services activities and supportive services As described in the next section, all families participating in the FSS program will benefit from coaching to be provided to FSS families by that helps them identify and achieve goals that the family selects. Drawing on partners on the program both public and private providers coordinating committee and relationships with other service providers, the coaches will provide referrals as and identify the public and needed to help FSS participants access appropriate services to help them achieve their goals. private resources which are • The PHA's FSS program, through its partners on the program coordinating expected to provide the committee, will provide the following activities and support services to FSS supportive services. families: (see FSS Guidebook Section 3.3 Referrals to Service Providers) Supportive Service Category Specific Service Source/Partner Check the categories of services ®Vocational Assessment Educational Vocational Rehabilitation and the specific services that your program plans to make available © Assessment © Assessment Disability Assessment Health Department to families through referrals and ® Disability Other specialized Northeastern Iowa assessments Community College 27 indicate the source or partner for Iowa Workforce that service. Development Community Based The sample Action Plan describes Organizations the coaching/case management Fountain of Youth services provided to families in ® Infant Care / Toddler Care Preschool Child Care Resources the next Section. X❑ Child Care Care Parks and Recreation ®Afterschool Care Department of Human ® Homework Assistance Services ® Bus passes The Jule ® Transportation ® Assistance with car repairs Department of ❑ Assistance with car purchase Transportation Local Company Northeastern Iowa Community College ® High School Equivalency/GED University X❑ Education © English as a Second Language Iowa Workforce Development ® Post -secondary certificates Community Based ® Advanced Degrees Organizations ® Training in Executive Function Northeastern Iowa ® Basic Skills Training Community College ® Emerging Technologies Training Iowa Workforce Development ® Biomedical Training (including Community Based ❑x Skills Training CNA, phlebotomy, x-ray, and other tech, Organizations etc.) University ® On -the -Job Training ® Apprenticeships ® Skilled Labor training 28 N Resume Preparation Northeastern Iowa N Interviewing Skills Community College N Dress for Success Iowa Workforce Development N Workplace Skills Sedona N Job Search Assistance N Job Development Express N Job Placement University Fountain of Youth Community Based Organization N Small business development services Northeastern Iowa N Small business Mentoring Community College N Entrepreneurship Training Iowa Workforce N Micro and Small Development Business Development Microbusiness Assistance Small Business Administration Business Incubator N Alcohol and Drug Abuse Prevention SASC/ASAC N Alcohol and Drug Abuse Treatment Fountain of Youth N Primary care Hillcrest Family Support Services N Health/Mental Health N Dental services Mercy Hospital Care N Mental Health Services Finley Hospital N Health Insurance Advising Catholic Charities Crescent Visiting Nurse Association Medicaid/Medicare N Crisis Assessment 911 Call Center N Crisis Services N Crisis Intervention Hillcrest Family Services N Crisis Management Poison Control Center 29 ® Crisis Resolution Domestic Violence Shelter Crisis Team Senior Crisis Team ® Needs Assessment Department of Human ® Case Planning Services ® Information Referral Senior Services Adult Services In -Home Support Services X❑ Child/Adult Protective Adult Abuse Hotline Services Child Abuse Hotline Foster Care Adoption Services Community Based Organization Dubuque Community School District ® Training in Household Management Parents as Teachers Community based ❑X Household Management organizations Medicaid programs ® Homeownership Education City of Dubuque Housing ® Housing Counseling and Community ❑X Homeownership Development Preparation ©Down payment Assistance Community Based © Other Homeownership Assistance Organizations Financial Institutions ® Financial education Financial Institutions ® Financial coaching Community Based © Financial Empowerment Organizations © Banking services PHA X❑ Training in money management 30 Money Makeover Program El Individual Development El Savings Accounts Accounts ® Legal Services Iowa Legal Aid © Legal Services Community Based Organizations ® Assistance negotiating the resolution Consumer Credit of past -due debt Counselors X❑ Debt Resolution & Credit Repair Credit Bureau Financial Institutions Financial Advisors Community based organizations © Other: Advocacy Group © Housing Advocacy Friends of Fair Housing 31 VIII. Method of Identifying Family Support Needs and Delivering Appropriate Support Services Instructions: Describe how your FSS program will identify the needs of participating families and deliver the appropriate supportive services. (see FSS Guidebook Section 3.3 Referrals to Service Providers) Policy Decisions: In completing this section, you will need to make the following policy decisions: 1. What approaches and procedures you will use to identify family needs for support services. 2. How your program will approach coaching or case management (See FSS Guidebook Chapter 3 Case Management/Coaching for recommendations and best practices). Whether to provide services referrals to families who have completed their FSS contracts of participation. (Select the option that applies. See 24 CFR 984.303(e)2 for relevant regulations) Method of Identifying Family Support Needs and Delivering Appropriate Support Services PHA Policy A. Identifying Family Support Needs To help determine the supportive services needs of each family/household, the FSS coordinator will work with the family/household to complete an initial informal Quick Assessment for that family/household before completion of the initial Individual Training Service Plan (ITSP). After enrollment in the FSS program, the FSS coordinator may make referrals to partner agencies for completion of one or more formal needs assessments. These assessments may focus on such issues as: employment readiness and employment training needs, educational needs related to secondary and post -secondary education, financial health, and other topics, depending on the needs and interests of the family/household. The formal assessments may lead to adjustments to the Individual Training Service Plan, if requested by the family/household. The needs of the FSS family/household will be identified by the completion of Quick Assessments and an Intake Assessment along with verbal/written communication and coaching. These need assessments will involve the FSS family/household and FSS coordinators before the establishment of the initial Individual Training and Services Plan (ITSP) mandatory and interim goals. After enrollment in the PHA's FSS program, a formal needs assessment, including vocational counseling, educational counseling, and employment planning, is conducted by the following partners on the PCC. The results obtained will be used to develop and modify the ITSP accordingly, only if requested by the FSS family/household. 32 B. Delivering Available Appropriate Support Services Coaching. All families/households who participate in the FSS program will be assigned an FSS coordinator who will provide coaching services to help each participating family/household to: • Understand the benefits of participating in the FSS program and how the program can help the family/household achieve its goals. • Identify achievable, but challenging interim and final goals for participation in the FSS program, break down the goals into achievable steps and accompany the family/household through the process. • Identify existing family/household's strengths and skills. • Understand the needs that the family/household has for services and supports that may help the family/household make progress toward their goals. • Access services available in the community through referral to appropriate service providers. • Overcome obstacles in the way of achieving a family/household's goals. C. Transitional supportive service assistance. Families/households that have completed their CoP and remain in assisted housing may request assistance with referrals to service providers in order to continue their progress toward economic security. Subject to limitations on staff capacity, City of Dubuque Housing and Community Development Department will try to help these families with appropriate referrals. The time spent on these referrals will not be covered by funds designated by HUD to support the FSS program. IX. Contract of Participation Instructions: You are not required Contract of Participation by regulation to include a section on 33 the Contract of Participation (CoP) in the FSS Action Plan. However, such a section may help you explain to readers what the Contract is and how your program will implement it. In addition, the sample Action Plan addresses in this section several of the policies referenced under "optional additional information" in 24 CFR 984.201(d)(13) the FSS Rule. (see 24 CFR 984.103 (CoP Effective date), 24 CFR 984.303(c) (Term of CoP), 24 CFR 984.303(d) (Extensions of CoP), 24 CFR 984.303(f) (Modification of the CoP), 24 CFR 984.303(g) (Completion of the CoP)) and 24 CFR 984.304(d) (Contract of Participation Extension). Policy Decisions: In completing this section, you will need to make the following policy decisions: 1. Whether and under what circumstances to grant extensions of FSS CoPs. All families/households enrolled in the FSS program will be required to sign a Contract of Participation (CoP) that includes an Individual Training and Services Plan (ITSP). This section describes the contents of the CoP and the City of Dubuque Housing and Community Development Department's policies and practices regarding the CoP. Participants of the HCV homeownership option are eligible to participate in FSS. Additionally, HUD revised the definition of Section 8 programs to include multifamily assisted housing; tenant -based and project -based rental assistance under section 8(o) of the 1937 Act; the HCV homeownership option under section 8(y) of the 1937 Act; Family Unification Program (FUP) assistance under section 8(x) of the 1937 Act; and Moderate Rehabilitation for low-income families and Moderate Rehabilitation Single Room Occupancy for homeless individuals under 24 CFR part 882. Tenant -based and project -based rental assistance under section 8(o) of the 1937 Act includes any applicable special purpose voucher considered rental assistance under section 8(o) of the 1937 Act (such as FYI, VASH, and Mainstream Vouchers). • The Contract of Participation and other documentation that families/households provide to the FSS program contain information that is considered sensitive and is protected by the Privacy Act. A. Form and content of contract The Contract of Participation (CoP), which will incorporate one ITSP for each participating member of the family/household, sets forth the principal terms and conditions governing participation in the FSS program. These include the rights and responsibilities of the FSS family/household and of the City of Dubuque Housing and Community Development Department, the services to be provided to, and the activities to be completed by, each adult member of the FSS family/household who elects to participate in the program. 2. Acceptable methods for PHA Policy documenting completion of CoPs. • There will only ever be one (1) FSS contract of participation (CoP) at any (Select the appropriate option.) 34 3. Timing limitations (if any) on time for each FSS family/household. when participants may modify their ITSPs. (Select the • Participation in the FSS program is voluntary appropriate option.) • PHA will not terminate HCV assistance to a family/household due to the 4. Policies on the consequences of family's/household's failure to meet its obligations under the contract of non-compliance with the terms of participation [FR Notice 12/29/14]. the CoP. • PHA will require families interested in participating in the FSS program to designate a "FSS contract holder" for their family/household. • PHA requires that the family/household chooses a FSS contract holder that is most suitable for their individual household circumstances. The PHA may make itself available to consult with families on this decision (if needed). • The FSS contract holder may, but is not required to be, the head of the household for purposes of determining income eligibility and rent. • PHA will incorporate the "Designated FSS Contract Holder Agreement" form with the FSS initial/enrollment paperwork and require every household member that is 18 yrs. of age and older to read, sign, date, and return the agreement to the coordinator as part of the enrollment process. • The PHA will require each family/household participating in the FSS program, regardless of whether the family/household is receiving welfare assistance at the time the contract of participation is being developed, that the family/household include a mandatory goal on its individual training and services plan (ITSP) for all family/household members to be independent from cash welfare assistance regardless of age by the expiration of the term of the contract of participation, including any extension thereof [24 CFR 984.303(b)(2)]. PHA will accept self -certification of being independent from welfare assistance from FSS participants and will require third party verification at 35 PHA's discretion 24 CFR 984.305(c)(1) and 24 CFR 984.305(c)(4). B. ITSP goals Each individual's ITSP will establish specific interim and final goals by which the City of Dubuque Housing and Community Development Department and the family/household will measure the family/household's progress towards fulfilling its obligations under the CoP. For any FSS family/household that is a recipient of welfare assistance at the outset of the CoP or that receives welfare assistance while in the FSS program, the City of Dubuque Housing and Community Development Department will establish as a final goal that every member of the family/household become independent from welfare assistance before the expiration of the CoP. The ITSP of the FSS contract holder will also include as a final goal that they seek and maintain suitable employment. The FSS coordinator will work with each participating individual to identify additional ITSP goals that are relevant, feasible and desirable. Any such additional goals will be realistic and individualized. PHA Policy • As part of the required contents of the FSS contract of participation (CoP), the individual training and services plan (ITSP) will establish specific interim and final goals by which the PHA and the family/household measure the family/household's progress toward fulfilling its obligations under the contract of participation and becoming more self-sufficient. • Interim goals will differ depending on the family/households' individual needs. • Two (2) mandatory goals will be established for ITSP's. This includes any CoP extension thereof. • 1. To be free of cash welfare assistance at the time of graduation and/or the expiration of the term of the CoP. • 2. To seek, obtain, and maintain suitable employment specific to that individual's skills, education, job training, and job availability in the area that the PHA and FSS participant agrees will not cause the loss of necessary supports. 36 The FSS contract holder's ITSP must include the mandatory goal "To seek, obtain, and maintain suitable employment specific to that individual's skills, education, job training, and job availability in the area that the PHA and FSS participant agrees will not cause the loss of necessary supports". Other household members with ITSPs are not required to include this mandatory goal to their ITSPs. All ITSP goals for all family/household members with ITSPs become part of the CoP and must be completed in order for the family/household to graduate. This final rule revises § 984.303(g) to clarify the requirement that all family/household members' ITSPs that are part of the CoP must be completed on or before the expiration of the contract term. • PHA will work with each participant to establish realistic and individualized goals and will not include additional mandatory goals or mandatory modifications of the two (2) mandatory goals. Individual Training & Service Plans for Other than the FSS Contract Holder (FSS Head of Family) • An individual training and services plan will be required for the FSS contract holder and all adult household members choosing to participate. ITSPs must be prepared for each participating household member. ITSPs are prepared by the PHA, in consultation with the participating household member. [Notice PIH 93-24,G-16] Each family/household members' ITSPs that are part of the CoP must be completed on or before the expiration of the contract term. C. Determination of suitable employment As defined in the FSS regulations (24 CFR 984.303(4)(iii)), a determination of what constitutes "suitable employment" for each family/household member with a goal of seeking and maintaining will be made by the City of Dubuque Housing and Community Development Department, with the 37 agreement of the affected participant, based on the skills, education, job training and receipt of other benefits of the family/household member and based on the available job opportunities within the community. PHA Policy For purposes of the PHA's FSS program, seek employment means the FSS contract holder has applied for employment, attended job interviews, and otherwise followed through on employment opportunities as outlined in the individual training and services plan of his or her contract of participation. Maintain suitable employment means that the FSS contract holder will complete all the obligations outlined in the individual training and services plan in his or her contract of participation (CoP) and be employed in a manner that is suitable to the FSS participant on the last effective day of the CoP. The FSS participant must agree to what is suitable employment. The determination will involve consideration of other benefits and supports the participant currently receives to ensure the new employment will not cause the loss of necessary supports. The PHA will require verification of this employment or enrollment. Suitable employment is employment that is outlined in the ITSP of the CoP and is based on the skills, education, and job training of the FSS family/household member and will not cause the loss of other necessary benefits or supports. D. Contract of Participation term and extensions PHA Policy 38 The CoP will go into effect on the first day of the month following the execution of the CoP. The initial term of the CoP will run the effective date through the five-year anniversary of the first reexamination of income that follows the execution date. Families/households may request up to two one-year extensions and are required to submit a written request that documents the need for the extension. City of Dubuque Housing and Community Development Department will grant the extension if it finds that good cause exists to do so. In this context, good cause means: (i) Circumstances beyond the control of the FSS family/household, as determined by the City of Dubuque Housing and Community Development Department, such as a serious illness or involuntary loss of employment. (ii) Active pursuit of a current or additional goal that will result in furtherance of self- sufficiency during the period of the extension (e.g. completion of a college degree during which the participant is unemployed or under -employed, credit repair towards being homeownership ready, etc.) as determined by the City of Dubuque Housing and Community Development Department or (iii) Any other circumstances that the City of Dubuque Housing and Community Development Department determines warrants an extension. • FSS contract holders are required to fulfil CoP obligations no later than 5yrs after the first re-examination of the income after the execution date of the CoP. • The participant must request an extension, so any information shared by the family/household in pursuit of that goal will be voluntarily shared. Additionally, unless the PHA or owner employs medical staff, HIPAA does not apply in this situation. • To clarify that the determination of "good cause" for a contract extension can include circumstances beyond the control of the FSS family/household that impede the family's/household's ability to complete the CoP obligations and can include any circumstance that the PHA determines warrants an extension. • PHA will be consistent in its determinations. 39 E. Completion of the contract PHA Policy The CoP is completed, and a family's/household's participation in the FSS program is concluded when the FSS family/household has fulfilled all its obligations under the CoP, including all family/household members' ITSPs, on or before the expiration of the contract term. The family/household must provide appropriate documentation that each of the ITSP goals has been completed. The City of Dubuque Housing and Community Development Department will accept the following form of verification for completion of the ITSP goals: PHA Policy The City of Dubuque Housing and Community Development Department will require a combination of self -certification and third -party verification to document completion of ITSP goals. • The FSS family/household has fulfilled all of its obligations under the contract of participation on or before the expiration of the contract term, including any extension thereof. • FSS Families are required to fulfil Contract of Participation obligations no later than 5 years after the first re-examination of income after the execution date of the Contract of Participation. • The PHA will require a combination of self -certification and third -party verification to document completion of ITSP goals. • FSS program coordinators, often in consultation with the management staff of the PHA will determine when an FSS participant has completed his or her ITSP goals and is eligible to receive the funds escrowed on behalf of the participant, less the amount of any debt owed to the PHA by acceptable documentation of suitable employment, goal attainment(s), and welfare independence. • To support this determination, PHA will keep detailed records of 40 participant's activities toward ITSP goals. • Participants will be required to provide FSS Coordinators with documented proof of goal completion and welfare independence no later than the end date of CoP. FSS Coordinators will closely monitor participants who are near the end of their Contract of Participation period or whose median income is close to meeting the maximum threshold for HCV participation. F. Modification PHA Policy The City of Dubuque Housing and Community Development Department and the FSS family/household may mutually agree to modify the CoP with respect to the ITSP and/or the contract term, and/or designation of the FSS contract holder. All modifications must be in writing and signed by the City of Dubuque Housing and Community Development Department as well as the FSS contract holder. The City of Dubuque Housing and Community Development Department will allow for modifications to the CoP under the following circumstances: ® When the modifications to the ITSP improve the participant's ability to complete their obligations in the CoP or progress toward economic self-sufficiency. ® When the designated FSS contract holder ceases to reside with other family/household members in the assisted unit, and the remaining family/household members, after consultation with the City of Dubuque Housing and Community Development Department, designate another family/household member to be the FSS contract holder. 41 ® When a relocating family/household is entering the FSS program of a receiving PHA and the start date of the CoP must be changed to reflect the date the new CoP is signed with the receiving PHA. ® Other: When the FSS contract holder becomes permanently disabled and unable to work during the period of the contract, unless the PHA and the FSS family/household determine that it is possible to modify the contract to designate a new FSS contract holder • The PHA will ensure effective communication with individuals with disabilities in accordance with Section 504 of the Rehabilitation Act of 1973 (Section 504) and the Americans with Disabilities Act (ADA), which includes providing the CoP form (including ITSP) in accessible formats. PHA will provide reasonable accommodations and modifications for individuals with disabilities consistent with applicable Federal nondiscrimination laws. • Any changes to an ITSP must be included as a revision to the original ITSP to which the change applies. • The City of Dubuque Housing and Community Development Department will allow modifications as necessary however not every modification request may be approved. • PHA may not allow FSS contract holder to modify CoP for reasons which includes but are not limited to: • 1. If participant still has time to complete their ITSP goals prior to graduation. • 2. If participant cannot prove that there are circumstances that may impede their ability to graduate. G. Consequences of noncompliance with the contract PHA Policy 42 • Participant non-compliance with the CoP may result in termination from the FSS program. • PHA will provide the family/household with a written notice that they are at risk of their COP being terminated if they do not come into compliance with the terms of the COP within 30days of the written notice. The contract of participation (CoP) will be terminated before the expiration of the contract term if the participant fails to meet, without "good cause," their obligations as outlined in the CoP. If the participant fails to meet its obligations outlined in the CoP, the FSS coordinator, or their designee, will first meet with the family/household to reassess the need for supportive services or a change in the individual training and services plan (ITSP). • If a reassessment of supportive services or a change in the ITSP is not successful in bringing the family/household in compliance, the FSS coordinator will withhold supportive services for no more than 90 days until the participant meets their obligations outlined in the CoP. • If neither of these alternatives is successful, the FSS coordinator will terminate the CoP for failure to complete the tasks, interim goals, or final goals of the ITSP in a timely manner, and thus failure to complete the obligations outlined in the CoP. • The FSS coordinator will make an exception to the actions in terminating the CoP if the participant can demonstrate "good cause" for the failure to meet its obligations as outlined in the CoP. • For purposes of the PHA FSS program, good cause includes family/household circumstances not limited to: Death in the family Serious illness 43 Brain Health concerns Medical emergency Temporary Medical issue/need Mandatory court appearances Involuntary loss of employment Loss of head of household through death, incarceration, or removal from lease Change in the ITSP improving progress toward economic self- sufficiency • Community circumstances not limited to: Significant reduction in workforce (over 20 percent reduction in employment field) Significant interruption in service delivery (over 3 months interruption) Provider noncompliance with regulation Provider unable/unwilling to provide service Provider offering inferior service Pandemic X. Program Termination, Withholding of Services, and Available Grievance Procedures Instructions: Describe your FSS Program Termination program's policies for terminating or withholding supportive services or FSS participation for failure to 44 comply with the Contract of Participation. Include a description of the grievance and hearing procedures available to FSS families. (See 24 CFR 984.201(d)(9) and FSS Guidebook Section 2.3 Contract of Participation and Individual Training and Services Plan) Policy Decisions: In completing this section, you will need to make the following policy decisions: 1. Your FSS program's approaches and procedures assessing and executing involuntary termination from the FSS program. 2. Your FSS program's policy on voluntary terminations. 3. Your FSS program's grievance procedures, including timelines, modes of communication, settings, and individuals involved. A. Involuntary Termination PHA Policy The City of Dubuque Housing and Community Development Department may involuntarily terminate a family/household from FSS under the following circumstances: I. If the participant fails to meet their obligations under the Contract of Participation, the Individual Training and Services Plan and related documentation. Non-compliance includes: i. Missing scheduled meetings, failure to return phone calls, and/or maintain contact after written notification of non-compliance ii. Failure to work on activities and/or goals set forth in the Individual Training and Services Plan, including employment activities iii. Failure to complete activities and/or goals within the specified time frames; II. If the participant's housing assistance has been terminated. Participants who fail to meet their obligations under paragraph I above, as determined by an FSS coordinator, will be given the opportunity to attend a required meeting with the FSS Coordinator or assigned City of Dubuque Housing and Community Development Department representative to review the situation. At this meeting, a review of the Contract of Participation, Individual Training and Services Plan, and all related documentation will be conducted, and amendments will be made as necessary (within HUD guidelines) to allow for changes in circumstances. Failure to contact the FSS Coordinator to schedule this meeting within fourteen (14) days of a written request by the FSS program to set up a meeting or failure by the FSS contract holder to attend this meeting without some type of correspondence to clarify the issue(s), may lead to termination from the program. The FSS Coordinator will also attempt to contact the participant via phone, text, in person and/or email prior to the review meeting. Participants who remain out of compliance after this meeting will be subject to termination from the FSS program. If the initial meeting does not resolve the problem, or if the meeting is not requested by the family/household within the required period, notification of termination will be made to the family/household by letter stating: The specific facts and reasons for termination. 45 2. A statement informing the family/household of their right to request an informal hearing and the date by which this request must be received (see Grievance Procedures) A statement informing the family/household that termination from the FSS program for the reasons stated therein will not result in termination of the family's/household's housing assistance. Failure to request a hearing in writing by the deadline will result in closure of the family's/household's FSS file and all rights to a hearing will be waived. All escrow money held on the family's/household's behalf will be forfeited in accordance with HUD regulations. Housing assistance will not be terminated based on non-compliance with the FSS program. The forfeited balance of escrow in the family's/household's escrow account will be included in the letter. B. Voluntary Termination Participants may also be terminated from the FSS program under the following circumstances: • Mutual consent of both parties; and/or • The family's/household's withdrawal from the program. C. Termination with Escrow Disbursement PHA Policy In most cases, families whose FSS contracts are terminated will not be entitled to disbursement of their accrued FSS escrowed funds. However, the CoP will be terminated with FSS disbursement when one of the following situations occurs: (i) Services that the City of Dubuque Housing and Community Development Department and the FSS family/household have agreed are integral to the FSS family's/household's advancement towards self-sufficiency are unavailable. 46 (ii) The FSS contract holder becomes permanently disabled and unable to work during the period of the contract, unless the City of Dubuque Housing and Community Development Department and the FSS family/household determine that it is possible to modify the contract to designate a new FSS contract holder (iii) An FSS family/household in good standing moves outside the jurisdiction of the PHA (in accordance with portability requirements at 24 CFR §982.353) for good cause, as determined by the PHA, and continuation of the CoP after the move, or completion of the CoP prior to the move, is not possible. • PHA will be consistent in determining termination with escrow disbursements • PHA will use the new escrow calculations for all new CoP's signed under the new regulations. • PHA will use old escrow calculations for all participants that remained under the old CoP regulations. • EID will be included in earned income for the purposes of escrow calculations in the new contract. A Grievance Procedures PHA Policy A request for an informal review must be made in writing and delivered to the PHA/FSS Coordinator either in person, by first class mail, email, or fax, by the close of the business day, no later than ten (10) business days from the date of the FSS termination letter. Exceptions for requesting an informal review in writing may be granted for limited English proficiency, disabled individuals or for reasonable accommodations. 47 The PHA must promptly schedule and send written notice of the informal review of the family/household's request. The family/household may request to reschedule a review for good cause, or if it is needed as a reasonable accommodation for a person with disabilities. Good cause is defined as an unavoidable conflict which seriously affects the health, safety, or welfare of the family/household. Requests to reschedule a review must be made orally or in writing prior to the review date. At its discretion, the PHA may request documentation of the "good cause" prior to rescheduling the review. 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 extreme situations. Extreme situations may include but are not limited to hospitalization of self or household member, death in the family, or a weather -related restriction. Any notice of the inability of the applicant to attend the review must be provided within 24 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. Adverse actions taken within the FSS program may include but are not limited to the following: Denial of admission into the FSS program Denial of request for supportive services Denial of request to change the ITSP Denial of request to change the FSS Contract Holder Denial of request for interim disbursement of the escrow account Denial of request to complete the CoP Denial of a request for extension to the FSS CoP Denial of request for final distribution of the escrow account or any portion thereof Withholding of support services 48 Termination of the FSS CoP Denial of transitional services Persons included in the informal hearing shall include, but not be limited to: XI. Assurance of Non -Interference Instructions: Include a statement here that provides an assurance that a family's election not to participate in the FSS program will not affect the family's participation in the rental assistance program. (see FSS Guidebook Section 1.2 What is FSS and Why is it Important?) • The FSS contract holder • The FSS Coordinator • City of Dubuque Housing and Community Development Department staff members, other than FSS program staff, serving as the Hearing Officer • All participants have the right to obtain legal representation and provide their witnesses. Assurance of Non -Interference PHA Policy Participation in the FSS Program is voluntary. A family's/household's decision on whether to participate in FSS will have no bearing on the City of Dubuque Housing and Community Development Department's decision of whether to admit the family/household into the Housing Choice Voucher program. The family's/household's housing assistance will not be terminated based on whether they decide to participate in FSS, their successful completion of the CoP, or on their failure to comply with FSS program requirements. City of Dubuque Housing and Community Development Department will ensure that the voluntary nature of FSS program participation is clearly stated in all FSS outreach and recruitment efforts. • FSS coordinator will communicate this verbally as well and as needed and necessary. When necessary, the following disclosure will be used: 49 "An individual or family's decision to not participate in the FSS program will not affect the family's admission to the public housing or housing choice voucher programs, nor will it affect the individual or family's right to occupancy in accordance with the lease." XII. Timetable Instructions: Provide a schedule for Timetable program implementation and for filling all FSS slots with eligible FSS City of Dubuque Housing and Community Development Department implemented its FSS program in families. [1993] and will continue to implement it per this FSS Action Plan. Separate options have been provided for FSS programs that have already started or have not yet started. Programgins The FSS program will commence operation as soon as the City of Dubuque Housing and Community (see FSS Guidebook Section 2.2 Development Department has received notification of HUD's approval of the Action Plan. Outreach and Enrollment) Program Coordinating Committee PCC meetings will be quarterly. Additional special meetings will occur as needed. Outreach Outreach will continue. Participant Selection Candidates who respond with interest to the outreach/recruitment efforts will be selected in accordance with the selection procedures described above. 50 Contract Execution Contracts of Participation will be executed with selected participants on a rolling basis. Full Enrollment The FSS program expects to maintain full capacity. Program Maintenance The FSS program expects to operate at full capacity thereafter, subject to normal fluctuations related to families leaving and entering the program. XIII. Reasonable Accommodations, Effective Communications, and Limited English Proficiency Instructions: Reasonable accommodations and effective communications for persons with disabilities are required by federal law. While there is no specific requirement in the program regulations to describe in the FSS Action Plan the agency's policy on reasonable accommodations and effective communications, inclusion of this section in the Action Plan can be helpful for reinforcing the commitment of the PHA/owner to these important policies. The sample plan also describes the agency's commitment to meeting the needs of people with Limited English Proficiency. Reasonable Accommodations, Effective Communications and Limited English Proficiency Requirements Requests for Reasonable Accommodations A person with disabilities may request reasonable accommodations to facilitate participation in the FSS program. Requests will be considered on a case -by -case basis. Requests should be made initially to the FSS coordinator. If a family/household is not satisfied with the FSS Coordinator's response, the family/household may submit a request in writing in accordance with the agency's reasonable accommodations policy. The policy is available online at https://www.cityofdubuque.org/DocumentCenter/View/116/Disabilities-and-Housing?bidld=Request for Effective Communications A person with disabilities may request the use of effective communication strategies in order to facilitate participation in the FSS program. Examples include appropriate auxiliary aids and services, such as interpreters, computer -assisted real time transcription (CART), captioned videos with audible video description, visual alarm devices, a talking thermostat, accessible electronic communications and websites, documents in alternative formats (e.g., Braille, large print), or assistance in reading or completing a form, etc. Requests should be made initially to the FSS coordinator. If a family/household is not satisfied with the FSS Coordinator's response, the family/household may submit a request in writing in accordance with the agency's effective communications policy. The policy is available online at 51 https://www.cityofdubuque.org/DocumentCenter/View/116/Disabilities-and-Housing?bidld=Request for Effective Communications • The PHA will ensure effective communication with individuals with disabilities in accordance with Section 504 of the Rehabilitation Act of 1973 (Section 504) and the Americans with Disabilities Act (ADA), which includes providing the CoP form (including ITSP) in accessible formats. PHA will provide reasonable accommodations and modifications for individuals with disabilities consistent with applicable Federal nondiscrimination laws. PHA will make all aspects of the FSS program accessible to persons with disabilities and consider reasonable accommodations requested based upon a person's disability. Limited English Proficiency The City of Dubuque Housing and Community Development Department will comply with HUD requirements to conduct oral and written communication related to the FSS program in languages that are understandable to people with Limited English Proficiency. For more information, see the Limited English Proficiency policy available online at https://www.cityofdubugue.org/DocumentCenter/View/33180/Title-VI-LEP-Plan-4-13-2017?bidld= 52 XIV. Coordination of Services XIV.A Coordination of Services (PHAs only) Instructions: Certify that the development of the services and activities scheduled to be provided under the FSS program has been coordinated with public and private providers, including with programs under title I of the Workforce Innovation and Opportunity Act 29 U.S.C. 3111 et seq and other relevant employment, childcare, transportation, training, education, and financial empowerment programs in the area. In this certification, you should further specify that implementation will continue to be coordinated with these local public and private providers to avoid duplication of services. Note: PHAs should include here a description of the Program Coordinating Committee. (This provision does not apply to multifamily owners.) (See 24 CFR 984.201(d)12, 24 CFR 984.202 and FSS Guidebook Sections 3.3 Referrals to Service Providers and 6.1 Building Partnerships) Coordination of Services A. Certification of Coordination PHA Policy Development of the services and activities under the FSS program has been coordinated with programs under title I of the Workforce Innovation and Opportunity Act 29 U.S.C. 31 It et seq., Workforce Investment Act (formerly JTPA), Workforce Investment Board and One Stop Centers, Welfare to Work (formerly JOBS program), and any other relevant and other relevant employment, childcare, transportation, training, education, and financial empowerment programs in the area. Implementation will continue to be coordinated, in order to avoid duplication of services and activities. B. Program Coordinating Committee The principal vehicle for ensuring ongoing coordination of services is the program coordinating committee (PCC), which has been established in accordance with FSS regulations to assist in securing commitments of public and private resources for the operation of the FSS Program. Among other responsibilities, the PCC will help the FSS program to identify and build strong referral relationships with providers of supportive services that meet the needs of FSS participants. The PCC will also be consulted in developing program policies and procedures. The PCC will meet quarterly and may conduct business on an as -needed basis via email or telephone conferences. The PCC includes the following representatives: 1. One or more FSS Program Coordinators 2. One or more participants from each HUD rental assistance program served by the FSS program. 3. Representatives from a variety of agencies and individuals, which include but are not limited to the following: • Northeastern Iowa Community College 53 • HACAP • Dubuque Community School District • Fountain of Youth • Iowa Work Force Development • Vocational Rehabilitation • Greater Dubuque Development Corp • Community Foundation of Greater Dubuque XIV.B Coordination of Services (Multifamily owners only) DOES NOT APPLY Instructions: Provide a statement I Coordination of Services indicating whether there is an existing PCC that serves the area where the property is located. If there is an existing PCC where the property is located, provide a statement indicating whether it is available for you to work with. Note: If your FSS program has made good faith attempts to reach out to the existing PCC about joining and has received an unfavorable response/no response, then the existing PCC is not considered available. If there is a PCC that is available for your program to work with, provide a statement indicating whether your program will work with the existing PCC or start your own. Program Coordinating Committee The principal vehicle for ensuring ongoing coordination of services is the program coordinating committee (PCC), which has been established to assist in securing commitments of public and private resources for the operation of the FSS Program. Among other responsibilities, the PCC will help the FSS program to identify and build strong referral relationships with providers of supportive services that meet the needs of FSS participants. The PCC will also be consulted in developing program policies and procedures. The PCC will meet quarterly and may conduct business on an as -needed basis via email or telephone conferences. The PCC includes the following representatives: 1. One or more FSS Program Coordinators 2. One or more participants from the Housing Choice Voucher Program 3. Representatives from a variety of agencies and individuals, which include but are not limited to the following: 54 If there is NO existing PCC that is available for your FSS program to join, provide a statement indicating whether you plan to start your own. Note: If there is no available PCC, your program is not required to start its own but is encouraged to do so. If you choose not to start a PCC, HUD encourages you to develop an alternative approach allowing you to get regular feedback from service providers and FSS participants. (See 24 CFR 984.202, and FSS Guidebook Sections 3.3 Referrals to Service Providers and 6.1 Building Partnerships) Policy Decision: 1. Whether you will use a PCC or an alternative method of coordinating services and how the PCC/coordination process will work. XV. FSS Portability (Applicable to HCV Only) 55 Instructions: While not specifically required by the federal program regulations, it can be helpful to include a section describing how the program will approach portability. (see 24 CFR 984.306 and FSS Guidebook Section 6.7 Portability in the FSS Program) Policy Decisions: In completing this section, you will need to make the following policy decision: 1. Whether your FSS program will allow portability in the first 12 months of enrollment. 2. Under what circumstances your FSS program will accept FSS participants porting into your FSS program from another jurisdiction's FSS program. Under what circumstances your FSS program will agree to a family porting into your agency's jurisdiction to remain in the initial agency's FSS program (provided that the initial PHA agrees to retain the family in its program and demonstrates that the family meets conditions under 24 CFR 984.306(b)l to fulfill its responsibilities under the initial COP). Portability A. Portability in initial 12 months PHA Policv FSS participants may not exercise portability within the initial 12 months after signing a CoP. PHA Policy If an FSS participant moves into the PHA's jurisdiction, they will be admitted in good standing into the City of Dubuque Housing and Community Development Department's FSS program unless the City of Dubuque Housing and Community Development Department is already serving the number of FSS families identified in this FSS Action Plan and determines that it does not have the resources to manage the FSS contract. Regardless of whether City of Dubuque Housing and Community Development Department is able to receive an incoming family/household from another jurisdiction into the FSS program, City of Dubuque Housing and Community Development Department will agree to allow and support porting families to remain in their initial PHA's FSS program after porting housing vouchers if the initial PHA requests that the family/household remain in the initial FSS program and can demonstrate the family/household is able to fulfill its responsibilities under the initial CoP, the move in jurisdictions notwithstanding. C. FSS termination with disbursement for porting families PHA Policy If an FSS family/household seeks to move to a jurisdiction that does not offer an FSS program, the City of Dubuque Housing and Community Development Department will closely examine the family's/household's progress to determine if it would be appropriate to exercise FSS Termination with Disbursement as discussed above in the section on Termination. PHA Policy Where continued FSS participation is not possible, City of Dubuque Housing and Community Development Department will discuss the options that may be available to the family/household, depending on the family's/household's specific circumstances, which may include, but are not limited to, modification of the FSS contract, termination of the FSS contract and forfeiture of escrow, 56 XVI. Other Policies Instructions: Describe any other FSS program -related policies over which your program has discretion that are not covered above. The Sample Action Plan lists the local discretionary policies specifically identified under the section "optional additional information" in 24 CFR 984.201(d)13 and specifies in which section of this sample action plan each is included. Including a table like this one in your Sample Action Plan will make it easier to find policies that could be included under more than one heading. termination with FSS escrow disbursement in accordance with 24 CFR § 984.303(k)(1)(iii), or locating to a receiving PHA that has the capacity to enroll the family/household into its FSS program. Other Policies Single Action Plan [24 CFR 984.201(f)] PHAs implementing both a Section 8 FSS program and a public or Indian housing FSS program may submit one action plan. In cases where the PHA decides to submit one plan for more than one program, the policies contained in the action plan would apply to both programs. PHA Policy The PHA is implementing an HCV FSS program and will submit one action plan in which the policies apply to the HCV FSS program. Revision to the FSS Action Plan [24 CFR 984.201(c)(2)] • Following HUD's initial approval of the action plan, no further approval of the action plan is required unless the PHA proposes to make policy changes to the action plan or increase the size of a voluntary program, or to revise the FSS action plan as needed to comply with changes in HUD regulations. The PHA must submit any changes to the action plan to HUD for approval. PHA Policy The PHA will review and update the action plan at least once a year, and more often if needed, to reflect changes in regulations, PHA operations, or when needed to ensure staff consistency in operation. PURPOSE • The purpose of the family self-sufficiency (FSS) program is to promote the development of local strategies to coordinate the use of public housing 57 assistance and housing assistance under the housing choice voucher program with public and private resources enabling families eligible to receive assistance under these programs to achieve economic independence and self-sufficiency [984.101(a)(1)]. • In addition to this broader national goal of the FSS program, the PHA also establishes a local goal consistent with the PHA's mission statement to serve as a guide for establishing policy and implementing the FSS program. PHA Policy The PHA's local goal in operating this FSS program is to match housing -assisted families with a broad range of highly collaborative existing community services to assist FSS families in achieving economic self-sufficiency. Economic self-sufficiency is defined as having the sustainable skills necessary to maintain employment paying a "living wage." This wage would pay for the family's/household's basic needs without the use of government subsidies. PROGRAM OBJECTIVES [24 CFR 984.1021 • In order to reach the FSS national program goal, HUD has defined its FSS program objective as to reduce the dependency of low-income families on welfare assistance and on Section 8, public, or any federal, state, or local rent or homeownership subsidies. Under the FSS program, low-income families are provided opportunities for education, job training, counseling, and other forms of social service assistance while living in assisted housing so that they may obtain the education, employment, and business and social skills necessary to achieve self-sufficiency. As with the goals of the program, FSS program objectives are defined on the national level through FSS regulation, and on the local level by PHA policy. PHA Policy On the local level, the PHA will achieve the national program objective by offering low- income families a broad range of services through partnering with the program coordinating committee (PCC). These services will provide long-term education, job training, 58 counseling, and other forms of social service assistance so that families may achieve economic self-sufficiency, as defined in Section 2-I.A. of this document. ELIGIBLE FAMILIES FROM OTHER SELF-SUFFICIENCY PROGRAMS 124 CFR 984.201(d)(3)] • If applicable, the PHA must enter the number of families, by program type, who are participating in any other local housing self-sufficiency program who are expected to agree to execute an FSS contract of participation. PHA Policv The PHA does not operate other self-sufficiency programs and therefore no additional families from other programs are expected to execute an FSS contract of participation. ELIGIBILITY OF A COMBINED PROGRAM [24 CFR 984.201(e)] • A PHA that wishes to operate a joint FSS program with other PHAs may combine its resources with one or more PHAs to deliver supportive services under a joint action plan that will provide for the establishment and operation of a combined FSS program that meets the requirements of this part. PHA Policy The PHA will not combine its resources with any other PHA to deliver support services, have a joint action plan, or establish or operate a combined FSS Program. PROGRAM ADMINISTRATION STAFF AND CONTRACTORS [24 CFR 984.301(b)] • PHAs have the choice between hiring their own staff and contracting with an outside organization to administer their FSS program. If the PHA should choose to employ its own staff, the staffing levels should be appropriate, and may include one or more FSS coordinators. If the PHA chooses to contract with an outside organization, the organization's staffing levels must likewise be appropriate to establish and administer the FSS program, and the organization's responsibilities would include managing the FSS account in accordance with federal regulations. 59 PHA Policy The PHA will employ appropriate staff, including one or more FSS coordinators or program coordinators to administer its FSS program. FAMILY OBLIGATIONS Compliance with Lease Terms • One of the obligations of the FSS family/household according to the contract of participation is to comply with the terms and conditions of the public housing lease or housing choice voucher program assisted lease [24 CFR 984.303(b)(3)]. Inability to comply with the lease represents an inability to comply with the contract, therefore regulations regarding noncompliance with the FSS contract apply [see 24 CFR 984.303(b)(5)]. It is up to the PHA to determine the plan of action for FSS families found in noncompliance with the lease and how the PHA will precisely define the term comply with the lease. All considerations allowed for other assisted residents regarding violations of the lease, must also be allowed for FSS participants. PHA Policy Comply with the lease means the FSS family/household has not been evicted for repeated or serious violations of the lease as defined in the Housing Choice Voucher Administrative Plan and public housing Admissions and Continued Occupancy Policy; or if they have been evicted for serious or repeated violations of the lease, the family/household has pursued their right to grieve and prevailed in either the grievance hearing or the informal hearing process, thus retaining their right to participate in the Housing Choice Voucher Program. The PHA's FSS program will not terminate the FSS contract of participation for failure to comply with the terms of the lease unless their right to participate in the Housing Choice Voucher Program has been terminated also. TRANSITIONAL SUPPORTIVE SERVICE ASSISTANCE R Even after a family/household has completed the contract of participation, a PHA may continue to offer appropriate FSS supportive services to a former FSS family/household whose head of household is employed. If the family/household still resides in public housing, or HCV-assisted housing, these supportive services would be offered for becoming self-sufficient. If the family/household no longer resides in public housing, HCV-assisted housing, or other assisted housing, these supportive services would be offered for remaining self-sufficient [24 CFR 984.3030)]. PHA Policy The PHA will continue to offer supportive services to a former FSS family/household who has completed its contract of participation, and whose head of family is employed. ACCOUNTING FOR FSS ACCOUNT FUNDS When establishing FSS escrow accounts, the PHA must deposit the FSS account funds of all families participating in the PHA's FSS program into a single interest -bearing depository account for each (public housing or HCV) program. In addition, the funds held in this account must be invested in one or more of the HUD -approved investments [24 CFR 984.305]. The total of the combined FSS account funds will be supported in the PHA accounting records by a subsidiary ledger showing the balance applicable to each FSS family/household. During the term of the contract of participation, the PHA periodically, but not less than annually, credits the amount of the FSS credit (see Section 6-I.B.) to each family's/household's FSS account [24 CFR 984.305(a)(2)(i)]. PHA Policy The PHA will credit the amount of the FSS credit(s) to each family's/household's account on a monthly basis. Escrow credits will not cease due to a family/household being late in paying rent. 61 REPORTING ON THE FSS ACCOUNT • Each PHA is required to make a report, at least once annually, to each FSS family/household on the status of the family's/household's FSS account. At a minimum, the report must include [24 CFR 984.305(a)(3)]: • The balance at the beginning of the reporting period • The amount of the family's/household's rent payment that was credited to the FSS account, during the reporting period • Any deductions made from the account for amounts due the PHA before interest is distributed • The amount of interest earned on the account during the year • The total in the account at the end of the reporting period PHA Policy The PHA will provide FSS participants an annual statement on the status of their FSS escrow account. Policy Where Addressed in Plan 62 (i) Policies related to the modification of goals in Section IX Contract of Participation the ITSP; (ii) The circumstances in which an extension of the Section IX: Contract of Participation Contract of Participation may be granted (iii) Policies on the interim disbursement of escrow, Section VI: FSS Escrow Account and Other including limitations on the use of the funds (if Incentives for Participants an (iv) Policies regarding eligible uses of forfeited Section VI: FSS Escrow Account and Other escrow funds by families in good standing Incentives for Participants (v) Policies regarding the re -enrollment of previous Section IV. Family Selection Procedures FSS participants, including graduates and those who exited the program without graduating (vi) Policies on requirements for documentation for Section IX: Contract of Participation goal completion; (vii) Policies on documentation of the household's Section IV. Family Selection Procedures designation of the "FSS Contract Holder; (viii) Policies for providing an FSS selection Section IV: Family Selection Procedures preference for porting families (if the PHA elects to offer such a reference 63 XVII. Definitions Definitions The definitions below are specified in CFR 24 984.103. The terms 1937 Act, Fair Market Rent, Head of Household, HUD, Public Housing, Public Housing Agency (PHA), Secretary, and Section 8, as used in this part, are defined in 24 CFR Part 5. Certification means a written assertion based on supporting evidence, provided by the FSS family or the City of Dubuque Housing and Community Development Department, as may be required under this part, and which: (1) Shall be maintained by the City of Dubuque Housing and Community Development Department in the case of the family's certification, or by HUD in the case of the PHA's or owner's certification; (2) Shall be made available for inspection by HUD, the City of Dubuque Housing and Community Development Department, and the public, as appropriate; and, (3) Shall be deemed to be accurate for purposes of this part, unless the Secretary or the City of Dubuque Housing and Community Development Department, as applicable, determines otherwise after inspecting the evidence and providing due notice and opportunity for comment. Contract of Participation (CoP) means - a contract, in a form with contents approved by HUD, entered into between an FSS family and a City of Dubuque Housing and Community Development Department operating an FSS Program that sets forth the terms and conditions governing participation in the FSS Program. The CoP includes all Individual Training and Services Plans (ITSPs) entered into between the City of Dubuque Housing and Community Development Department and all members of the family who will participate in the FSS Program, and which plans are attached to the CoP as exhibits. For additional detail, see § 984.303. Effective date of Contract of Participation (CoP) - means the first day of the month following the date in which the FSS family and the PHA entered into the CoP. Eligible families means current residents of Public Housing (Section 9) and current Section 8 program participants, as defined in this section, including those participating in other local self-sufficiency programs. Enrollment means the date that the FSS family entered into the CoP with the City of Dubuque Housing and Community Development Department. Family Self -Sufficiency (FSS) Program means the program established by a PHA within its jurisdiction or by an owner to promote self- sufficiency among participating families, including the coordination of supportive services to these families, as authorized by section 23 of the 1937 Act. 64 FSS escrow account (or, escrow) means the FSS escrow account authorized by section 23 of the 1937 Act, and as provided by § 984.305. FSS escrow credit means the amount credited by the City of Dubuque Housing and Community Development Department to the FSS family's FSS escrow account. FSSfamily means a family that resides in Public Housing (Section 9) or receives Section 8 assistance or receives HUD Project -Based Rental Assistance for a privately owned property, and that elects to participate in the FSS Program, and whose designated adult member (FSS contract holder), as determined in accordance with § 984.303(a), has signed the CoP. FSSfamily in good standing means, for purposes of this part, an FSS family that is in compliance with their FSS CoP; has either satisfied or are current on any debts owed the [organization]; and is in compliance with the regulations regarding participation in the relevant rental assistance program.pro FSS related service program means any program, publicly or privately sponsored, that offers the kinds of supportive services described in the definition of "supportive services" set forth in this § 984.103. FSS slots - refers to the total number of families (as determined in the Action Plan and, for mandatory programs, in § 984.105 of this part) that the PHA will serve in its FSS Program. FSS Program Coordinator means the person(s) who runs the FSS program. This may include (but is not limited to) performing outreach, recruitment, and retention of FSS participants; goal setting and case management/coaching of FSS participants; working with the community and service partners; and tracking program performance. FY means Federal Fiscal Year (starting October 1 and ending September 30, and year designated by the calendar year in which it ends). FSS Contract Holder means the designated adult family member of the FSS family who has signed the CoP. The FSS contract holder may, but is not required to be, the head of the household for purposes of determining income eligibility and rent. Individual Training and Services Plan (ITSP) means a written plan that is prepared by the [organization] in consultation with a participating FSS family member (the person with, for, and whom the ITSP is being developed), and which sets forth: (1) The final and interim goals for the participating FSS family member; (2) The supportive services to be provided to the participating FSS family members; (3) The activities to be completed by that family member; and, (4) The agreed upon completion dates for the goals and activities. Each ITSP must be signed by the City of Dubuque Housing and Community Development Department and the participating FSS family member, and is attached to, and incorporated as part of the CoP. An ITSP must be prepared for each adult family member who elects to participate in the FSS Program, including the FSS contract holder who has signed the CoP. Owner means the owner of multifamily assisted housing. 65 Self-sufficiency means that an FSS family is no longer receiving Section 8, Public Housing assistance, or any Federal, State, or local rent or homeownership subsidies or welfare assistance. Achievement of self-sufficiency, although an FSS program objective, is not a condition for receipt of the FSS escrow account funds. Supportive services mean those appropriate services that a City of Dubuque Housing and Community Development Department will coordinate on behalf of an FSS family under a CoP, which may include, but are not limited to: (1) Childcare —childcare (on an as -needed or ongoing basis) of a type that provides sufficient hours of operation and serves an appropriate range of ages; (2) Transportation —transportation necessary to enable a participating FSS family member to receive available services, or to commute to their place(s) of employment; (3) Education —remedial education; education for completion of high school or attainment of a high school equivalency certificate; education in pursuit of a post -secondary degree or certificate; (4) Employment Supports job training, preparation, and counseling; job development and placement; and follow-up assistance after job placement and completion of the CoP; (5) Personal welfare—substance/alcohol abuse treatment and counseling, and health, dental, mental health, and health insurance services; (6) Household management —training in household management; (7) Homeownership and housing counseling— homeownership education and assistance and housing counseling; (8) Financial Empowerment —training in financial literacy, such as financial coaching, training in financial management, asset building, and money management, including engaging in mainstream banking, reviewing, and improving credit scores, etc.; (9) Other services —any other services and resources, including case management, optional services, and specialized services for individuals with disabilities, that are determined to be appropriate in assisting FSS families to achieve economic independence and self- sufficiency. Reasonable accommodations and modifications must be made for individuals with disabilities consistent with HUD requirements, including HUD's legal obligation to make reasonable modifications under Section 504 of the Rehabilitation Act. Welfare assistance means (for purposes of the FSS program only) income assistance from Federal, (i.e. Temporary Assistance for Needy Families (TANF) or subsequent program) State, or local welfare programs and includes only cash maintenance payments designed to meet a family's ongoing basic needs. Welfare assistance does not include: (1) Nonrecurrent, short-term benefits that: (i) Are designed to deal with a specific crisis or episode of need; (ii) Are not intended to meet recurrent or ongoing needs; and, (iii) Will not extend beyond four months. (2) Work subsidies (i.e., payments to employers or third parties to help cover the costs of employee wages, benefits, supervision, and training); (3) Supportive services such as childcare and transportation provided to families who are employed; (4) Refundable earned income tax credits; (5) Contributions to, and distributions from, Individual Development Accounts under Temporary Assistance for Needy Families (TANF); (6) Services such as counseling, case management, peer support, childcare information and referral, financial empowerment, transitional services, job retention, job advancement, and other employment -related services that do not provide basic income support; (7) Amounts solely directed to meeting housing expenses; (8) Amounts for health care; (9) Supplemental Nutrition Assistance Program and emergency rental and utilities assistance; (10) Supplemental Security Income, Social Security Disability Income, or Social Security; and (11) Child -only or non -needy TANF grants made to or on behalf of a dependent child solely on the basis of the child's need and not on the need of the child's current non -parental caretaker. 67