Public Housing Agency (PHA) Annual Plan and Certification of Consistency 2017 Copyrighted
April 3, 2017
City of Dubuque Consent Items # 6.
ITEM TITLE: Annual Public Housing Agency (PHA) Plan
SUMMARY: City Manager recommending approval to submit the Annual
Public Housing Agency(PHA) Plan along with the
Certification for Consistency with the Consolidated Plan.
RESOLUTION Authorizing the Mayor to execute the
Certification by State or Local Office of Public Housing
Agency (PHA) Plan's Consistency with the Consolidated
Plan and Approval of the PHA Annual Plan
SUGGESTED DISPOSITION: Suggested Disposition: Receive and File; Adopt
Resolution(s)
ATTACHMENTS:
Description Type
Annual Public Housing Agency Plan-MVM Memo City Manager Memo
Staff Memo Staff Memo
Draft PHA Plan Supporting Documentation
Certification of Consistency with Consolidated Plan Supporting Documentation
Resolution Resolutions
THE CITY OF Dubuque
DUB E i"
Masterpiece on the Mississippi 2007.2012.2013
TO: The Honorable Mayor and City Council Members
FROM: Michael C. Van Milligen, City Manager
SUBJECT: Submission of Annual Public Housing Agency (PHA) Plan
DATE: March 23, 2017
Each year the City of Dubuque is required to submit a PHA (Public Housing Agency)
Plan. The PHA Plan is a comprehensive guide to the policies, programs, operations
and strategies for meeting local housing needs and goals. There are two parts to the
PHA Plan: the 5-Year Plan which was submitted Fiscal Year 2015 and the Annual Plan,
which is submitted this year. Part of the submission includes the Certification by State
or Local Office of PHA Consistency with the Consolidated Plan. The submission is also
required as part of the Voluntary Compliance Agreement (VCA) with the U.S.
Department of Housing and Urban Development (HUD).
Housing and Community Development Department Director Alvin Nash recommends
City Council approval to submit the Annual PHA Plan along with the Certification for
Consistency with the Consolidated Plan. The Housing Commission voted to approve
the PHA Plan on Tuesday, February 28, 2017.
1 concur with the recommendation and respectfully request Mayor and City Council
approval.
Zia-A^,
Mic ael C. Van Milligen
MCVM:jh
Attachment
cc: Crenna Brumwell, City Attorney
Cindy Steinhauser, Assistant City Manager
Teri Goodmann, Assistant City Manager
Alvin Nash, Housing & Community Development Department Director
THE CITY OF Dubuque
AII11-America CiI.ty
UB E1
Masterpiece on the Mississippi 2007.2012.2013
TO: Michael C Van Milligen, City Manager
FROM: Alvin Nash, Housing & Community Development Director
DATE: March 23, 2017
RE: Submission of Annual Public Housing Agency (PHA) Plan
INTRODUCTION
Each year the City of Dubuque is required to submit a PHA (Public Housing Agency)
Plan. The PHA Plan is a comprehensive guide to the policies, programs, operations
and strategies for meeting local housing needs and goals. There are two parts to the
PHA Plan: the 5-Year Plan which was submitted fiscal year 2015 and the Annual Plan,
which is submitted this year. Part of the submission includes the Certification by State
or Local Office of PHA Consistency with the Consolidated Plan (HUD-50077 Form).
The submission is also required as part of the Voluntary Compliance Agreement (VCA)
with the U.S. Department of Housing and Urban Development (HUD).
BACKGROUND
The PHA Plan and Certifications follow HUD approved templates and must be
submitted accordingly. Any local, regional or State agency that receives funds to
operate Federal Section 8 Housing Choice Voucher programs must submit a PHA Plan.
To ensure public participation in the process, PHA Plans must be available for
inspection by the public both during the public review period prior to the board hearing
and submission to HUD. Public Notice was published 45 days in advance of being
approved by the Housing Commission. The Housing Commission voted to approve the
PHA Plan on Tuesday, February 28, 2017. The PHA Resident Advisory Board has also
reviewed the PHA Plan and all comments and minutes from their meetings is included
in plan.
RECOMMENDATION
We are requesting approval to submit the Annual PHA Plan along with the Certification
for Consistency with the Consolidated Plan.
PUBLIC NOTICE
The City of Dubuque Housing and Community Development Department has published a first It of the Public
Housing Agency Annual Plan for fiscal year 2017 The Plan is available for review at the Housing & CD
Department, 350 West 6v Street Suite 312, Dubuque,IA 52001 Monday—Friday, 8 00 AM-5 00 PM and at
www_cityofdubuque org/atlminplan
A public hearing on the Plan will be held at the Housing Commission Meeting on Tuesday,March 28, 2017, at
4 00 p in in the Housing & CD Department office Interested persons are invited to appear and/or provide
comment to the Commission on the proposed Plan
Additional information may be obtained by calling the Housing & CD currant at 5894230_
HNUAL HOUSING
t liOtto v
:
Page 1 of 69
RESOLUTION NO. 116-17
RESOLUTION AUTHORIZING THE MAYOR TO EXECUTE THE CERTIFICATION BY
STATE OR LOCAL OFFICE OF PUBLIC HOUSING AGENCY (PHA) PLAN'S
CONSISTENCY WITH THE CONSOLIDATED PLAN AND APPROVAL OF THE PHA
ANNUAL PLAN
Whereas, the U.S. Department of Housing and Urban Development requires
submission of the Public Housing Agency (PHA) Plan on an annual basis; and
Whereas, the U.S. Department of Housing and Urban Development requires
Certification of the PHA Plan's Consistency with the Consolidated Plan;
NOW, THEREFORE BE IT RESOLVED BY THE CITY COUNCIL OF THE CITY
OF DUBUQUE IOWA:
Section 1: That the Mayor is hereby authorized and directed to certify the PHA
Plan's Consistency with the Consolidated Plan; and
Section 2: That the Director of Housing and Community Development is hereby
authorized to submit the PHA Plan and the Certification as required by the U.S.
Department of Housing and Urban Development.
Passed, approved and adopted this 3rd day of April 2017.
Attest:
Ke in S. F rnstah , City Clerk
Roy D Buol, Mayor
Certification by State or Local
Official of PISA Plans Consistency
with the Consolidated Plan or
State Consolidated Plan
(All PHAs)
U. S Department of Housing and Urban Development
Office of Public and Indian Housing
OMB No. 2577-0226
Expires 2/29/2016
Certification by State or Local Official of PISA Plans
Consistency with the Consolidated Plan or State Consolidated Plan
I, Roy D. Buol , the Mayor
Official's Name Official's Title
certify that the 5 -Year PHA Plan and/or Annual PHA Plan of the
City of Dubuque Housing & Community Development Department
PHA Name
is consistent with the Consolidated Plan or State Consolidated Plan and the Analysis of
Iinpediunents (AI) to Fair Housing Choice of the
City of Dubuque
pursuant to 24 CFR Part 91.
Local Jurisdiction Name
Provide a description of how the PHA Plan is consistent with the Consolidated Plan or State
Consolidated Plan and the AI.
The City of Dubuque PHA Plan & the Consolidated Plan work to affirmatively further fair housing by tracking
the location and type of affordable housing. The City's Al was used to (develop the PHA planand specific
J tl QiGIJ,IGJ QiG VUIIIIIGU tU IIIGG°t tilt IIVUJn II, IIGGIAJ Vr GAL l:l l July IVVV QI IU luvv-II IVVII IG IIVIAJGI MAID.
attention is given to the needs of the elrierly, families with disabilities and raves nr ethninities with
disproportionate housing needs.
I hereby certify that all the information stated herein, as well as any information provided in the accompaniment herewith, is true and accurate. Warning: HUD will
prosecute false claims and statements, Conviction may result in criminal and/or civil penalties. (18 U.S,C. 1001, 1010, 1012; 31 U.S.C. 3729, 3802)
Name of Authorized Official
Roy D. Buol
Signature
D,
Title
Mayor
Date
%
Page 1 of 1 form HUD -50077 -SL (12/2014)
Annual PHA Plan U.S.Department of Housing and Urban Development OMB No.2577-0226
(Standard PHAs and Office of Public and Indian Housing Expires: 02/29/2016
Troubled PHAs)
Purpose. The 5-Year and Annual PHA Plans provide a ready source for interested parties to locate basic PHA policies,rules,and requirements concerning the PHA's
operations,programs,and services,and informs HUD,families served by the PHA,and members of the public of the PHA's mission,goals and objectives for serving the
needs of low-income,very low-income,and extremely low-income families.
Applicability. Forn HUD-50075-ST is to be completed annually by STANDARD PHAs or TROUBLED PHAs. PHAs that meet the definition of a
High Performer PHA, Small PHA,HCV-Only PHA or Qualified PHA do not need to submit this form.
Definitions.
(1) High-Performer PHA—A PHA that owns or manages more than 550 combined public housing units and housing choice vouchers,and was designated as a
high performer on both of the most recent Public Housing Assessment System(PHAS)and Section Eight Management Assessment Program(SEMAP)
assessments if administering both programs,or PHAS if only administering public housing.
(2) Small PHA-A PHA that is not designated as PHAS or SEMAP troubled,or at risk of bei esignated as troubled,that owns or manages less than 250 public
housing units and any number of vouchers where the total combined units exceeds 550.
(3) Housing Choice Voucher(HCVD Only PHA-A PHA that administers more tion 55 ,was not designated as troubled in its most recent SEMAP
assessment and does not own or manage public housing.
(4) Standard PHA-A PHA that owns or manages 250 or more public housing units any number of vouchers where the total combined units exceeds 550,
and that was designated as a standard performer in the most recent PHAS or SEMAP assessments.
(5) Troubled PHA-A PHA that achieves an overall PHAS or SEMAP score of less than 60 percent.
(6) Qualified PHA-A PHA with 550 or fewer public housing dwelling units and/or housing choice vouchers combined,and isWS PHAS or SEMAP troubled.
A. PHA Information. M am
A.1 PHA Name: City of Dubuque PHA Code: IA087
PHA Type: ®Standard PHA ❑Troubled PHA
PHA Plan for Fiscal Year Beginning: (NIM/YYYY): 07/2017 _ RP
PHA Inventory(Based on Annual Contributions Contract(ACC)units at time of FY beginning,above)
Number of Public Housing(PH)Units 0 Number of Housing Choice Vouchers(HCVs) 1072 Total Combined
Units/Vouchers 1072 _
PHA Plan Submission Type: ®Annual Submission ❑Revised Annual Submission
Availability of Information.PHAs must have the elements listed below in sections B and C readily available to the public. A PHA must identify
the specific location(s)where the proposed PHA Plan,PHA Plan Elements,and all information relevant to the public hearing and proposed PHA
Plan are available for inspection by the public. At a minimum,PHAs must post PHA Plans,including updates,at each Asset Management Project
(AMP)and main office or central office of the PHA. PHAs are strongly encouRged to post complete PHA Plans on their official website. PHAs
are also encouraged to provide each resident council a copy of their PHA Plans.
❑PHA Consortia: (Check box if submittin a Joint PHA Plan and complete table below)
Participating PHAs PHA Code Programs)in the Consortia
Programs)not in the No.of Units in Each Program
Consortia pH HCV
Lead PHA:
Page 2 of 69
B. Annual Plan Elements
B.1 Revision of PHA Plan Elements.
(a) Have the following PHA Plan elements been revised by the PHA?
Y N
® ❑ Statement of Housing Needs and Strategy for Addressing Housing Needs
® ❑ Deconcentration and Other Policies that Govern Eligibility,Selection,and Admissions.
❑ ❑ Financial Resources.
® ❑ Rent Determination.
❑ ® Operation and Management.
❑ ® Grievance Procedures.
❑ ® Homeownership Programs.
❑ ® Community Service and Self-Sufficiency Programs.
❑ ❑ Safety and Crime Prevention.
❑ ❑ Pet Policy.
❑ ❑ Asset Management.
❑ ® Substantial Deviation.
❑ ® Significant Amendment/Modification
(b) If the PHA answered yes for any element,describe the revisions for ised element(s): See B.1 belo
(c) The PHA must submit its Deconcentration Policy for Field Office review.Se B.l(c)bel
13.2 New Activities
(a) Does the PHA intend to undertake any new activities related to the following in the PHA's cuff cut Fiscal Year?
Y N
❑ ® Hope VI or Choice Neighborhoods.
❑ ® Mixed Finance Modernization or Development.
❑ ® Demolition and/or Disposition.
❑ ® Designated Housing for Elderly and/or Disabled Families.
❑ ® Conversion of Public Housing to Tenant-Based Assistance.
❑ ® Conversion of Public Housing to Project-Based Assistance under R
❑ ® Occupancy by Over-Income Families.
❑ ® Occupancy by Police Of
❑ ® Non-Smoking Policies.
❑ ® Project-Based Vouchers.
❑ ® Units with Approved Vacancies for Modemization.
❑ ® Other Capital Grant Programs(i.e.,Capital Fund Community Facilities Grants or Emergency Safety and Security Grants).
(b)If any of these activities are planned for the current Fiscal Year, escribe the activities. For new demolition activities,describe any public
housing development or portion thereof,owned by the PHA for which the PHA has applied or will apply for demolition and/or disposition approval
under section 18 of the 1937 Act under the separate demolition/disposition approval process.If using Project-Based Vouchers(PBVs),provide the
projected number of project based units and general locations,and describe how project basing would be consistent with the PHA Plan.
13.3 Civil Rights Certification.
Form HUD-50077,PAA Certifications of Compliance with the PHA Plonsond Related Regulations,must be submitted by the PHA as an electronic
attachment to the PHA Plan. See Attached document
Page 3 of 69
BA Most Recent Fiscal Year Audit.
(a) Were there any findings in the most recent FY Audit?
Y N
El E
(b) If yes,please describe:
B.5 Progress Report.
Provide a description of the PHA's progress in meeting its Mission and Goals described in the PHA 5-Year and Annual Plan.
B.6 Resident Advisory Board(RAB)Comments.
(a) Did the RAB(s)provide comments to the PHA Plan?
Y N
® ❑(c) If yes,comments must be submitted by the PHA as an attachmeteA Plan. PHAs must also include a narrative describing their
analysis of the RAB recommendations and the decisions made on these recommendations.
B.7 Certification by State or Local Oft"lcials.
Foran HUD 50077-SL,Certification by State or Local Officials of PHA Plans Consistency with the Consolidated Plan,must be submitted by the
PHA as an electronic attachment to the PHA Plan.
B.8 Troubled PITA.
(a) Does the PHA have any current Memorandum of Agreement,Performance Improvement Plan,or Recovery Plan in place?
Y N N/A
❑ ® ❑
(b) If yes,please de
C. Statement of Capital Improvements. Required for all PHAs completing this form that administer public housing
and receive funding from the Capital Fund Program (CFP).
C.1 Capital Improvements.Include a reference here to the most recent HUD-approved 5-Year Action Plan(HUD-50075.2)and the date that it was
approved by HUD.
Page 4 of 69
Instructions for Preparation of Form HUD-50075-ST
Annual PHA Plan for Standard and Troubled PHAs
A. PHA Information.All PHAs must complete this section.
A.1 Include the full PHA Name,PHA Code,PHA Type,PHA Fiscal Year Beginning(MM/YYYY),PHA Inventory,Number of Public Housing Units and or
Housing Choice Vouchers(HCVs),PHA Plan Submission Type,and the Availability of Information,specific location(s)of all information relevant to the
public hearing and proposed PHA Plan.(24 CFR&903.23(4)(e))
PHA Consortia:Check box if submitting a Joint PHA Plan and complete the table.(24 CFR 043.128(a))
B. Annual Plan. All PHAs must complete this section.
B.1 Revision of PHA Plan Elements.PHAs must:
40
Identify specifically which plan elements listed below that have been revised by the PHA.To specify which elements have been revised,mark the"yes"box.If
an element has not been revised,mark"no."(24 CFR&903.7)
® Statement of Housing Needs and Strategy for Addressing Housing Needs. Provide a statement addressing the housing needs of low-income,very low-
income and extremely low-income families and a brief description of the PHA's strategy for addressing the housing needs of families who reside in the
jurisdiction served by the PHA.The statement must identify the housing needs off)families with incomes below 30 percent of area median income(extremely
low-income),(ii)elderly families and families with disabilities,and(iii)households of various races and ethnic groups residing in thejurisdiction or on the
waiting list based on information provided by the applicable Consolidated Plan,information provided by HUD,and other generally available data. The
identification of housing needs must address issues of affordability,supply,quality,accessibili size of units,and location.(24 CFR&903.7(x)(1)) Provide a
description of the PHA's strategy for addressing the housing needs of families in urisdi on the waiting list i e upcoming year. 24 CFR
&903.760(2)(iu
® Deconcentration and Other Policies that Govern E gibility,Selection,and Admissions. PHAs must submit a Deconcentration Policy for Field Office
review. For additional guidance on what a PHA must do to deconcentrate poverty in its development and comply with fair housing requirements,see 24 CFR
903.2.(24 CFR&903.23(6))Describe the PHA's admissions policy for deconcentration of poverty and income mixing of lower-income families in public
housing. The Deconcentration Policy must describe the PHA's policy for bringing higher income tenants into lower income developments and lower income
tenants into higher income developments. The�deconcentration requirements apply to general occupancy and family public housing developments. Refer to 24
CFR§903.2(6)(2)for developments not subject to deconcentration of poverty and income mixing requirements. (24 CFR&903.7(6))Describe the PHA's
procedures for maintain waiting lists for admission to public housing and address any site-based waiting lists.(24 CFR&903.70:u A statement of the PHA's
policies that govern resident or tenant eligibility,selection and admission including admission preferences for both public housing and HCV. 24 CFR
903.7 Describe the unit assignment policies for public housing. (24 CFR&903.7(6))
❑ Financial Resources. A statement of financial resources,including a listing by general categories,of the PHA's anticipated resources,such as PHA
operating,capital and other anticipated Federal resources available to the PHA,as well as tenant rents and other income available to support public housing or
tenant-based assistance. The statement also should include the non-Federal sources of funds supporting each Federal program,and state the planned use for the
resources.(24 CFR&903.7(0
® Rent Determination. A statement of the policies of the PHA goveming rents charged for public housing and HCV dwelling units,including applicable
public housing flat rents,minimum rents,voucher family rent contributions,and payment standard policies.(24 CFR&903.7(d7)
❑ Operation and Management. A statement of the rules,standds,and policies of the PHA governing maintenance and management of housing owned,
assisted,or operated by the public housing agency(which shall include measures necessary for the prevention or eradication of pest infestation,including
cockroaches),and management of the PHA and programs of the PHA.(24 CFR&903.7(e))
❑ Grievance Procedures. A description of the grievance and informal hearing and review procedures that the PHA makes available to its residents and
applicants.(24 CFR&903.707))
❑ Homeownership Programs. A descrtion of any Section Sh,Section 32,Section 8y,or HOPE I public housing or Housing Choice Voucher(HCV)
homeownership programs(including project number and unit count)administered by the agency or for which the PHA has applied or will apply for approval. 24
CFR&903.7(k))
❑ Community Service and Self Sufficiency Programs. Describe how the PHA will comply with the requirements of community service and treatment of
income changes resulting from welfare program requirements. (24 CFR&903.7(1)A description of: 1)Any programs relating to services and amenities
provided or offered to assisted families;and 2)Any policies or programs of the PHA for the enhancement of the economic and social self-sufficiency of assisted
families,including programs under Section 3 and FSS. (24 CFR&903.7(1)
❑ Safety and Crime Prevention. Describe the PHA's plan for safety and crime prevention to ensure the safety of the public housing residents. The statement
must provide development-by-development or jurisdiction wide-basis: (i)A description of the need for measures to ensure the safety of public housing residents;
(ii)A description of any crime prevention activities conducted or to be conducted by the PHA;and(iii)A description of the coordination between the PHA and
the appropriate police precincts for carrying out crime prevention measures and activities.(24 CFR&903.76m)) A description of: 1)Any activities,services,or
programs provided or offered by an agency,either directly or in partnership with other service providers,to child or adult victims of domestic violence,dating
violence,sexual assault,or stalking;2)Any activities,services,or programs provided or offered by a PHA that helps child and adult victims of domestic
violence,dating violence,sexual assault,or stalking,to obtain or maintain housing;and 3)Any activities,services,or programs provided or offered by a public
Page 5 of 69
housing agency to prevent domestic violence,dating violence,sexual assault,and stalking,or to enhance victim safety in assisted families. 24 CFR
&903.7(m)(5))
❑ Pet Policy. Describe the PHA's policies and requirements pertaining to the ownership of pets in public housing.(24 CFR 003.7(n))
❑ Asset Management. State how the agency will carry out its asset management functions with respect to the public housing inventory of the agency,
including how the agency will plan for the long-term operating,capital investment,rehabilitation,modernization,disposition,and other needs for such inventory.
(24 CFR&903.7(u))
❑ Substantial Deviation. PHA must provide its criteria for determining a"substantial deviation"to its 5-Year Plan. (24 CFR 003.7(r)(2)(i))
❑ Significant Amendment/Modification. PHA must provide its criteria for determining a"Significant Amendment or Modification"to its 5-Year and Annual
Plan. Should the PHA fail to define`significant amendmendmodification',HUD will consider the following to be`significant amendments or modifications': a)
changes to rent or admissions policies or organization of the waiting list;b)additions of non-emergency CFP work items(items not included in the current CFP
Annual Statement or CFP 5-Year Action Plan)or change in use of replacement reserve funds under the Capital Fund;or c)any change with regard to demolition
or disposition,designation,homeownership programs or conversion activities. See guidances website at:Notice PIH 1999-51. 24 CFR
&903.7(r)(2)(iu
If any boxes are marked"yes",describe the revision(s)to those elements)in the space provided.
B.2 New Activities. If the PHA intends to undertake any new activities related to these elements in the current Fiscal Year,mark"yes"for those elements,and
describe the activities to be undertaken in the space provided.If the PHA does not plan to undertake these activities,mark"no"
❑ Hope Vier Choice Neighborhoods. 1)A description of any housing(including project number(if known)and unit count)for which the PHA will apply
for HOPE VI or Choice Neighborhoods;and 2)A timetable for the submission of applications or proposals. The application and approval process for Hope VI
or Choice Neighborhoods is a separate process.See guidance on HUD's website at:http://www.hud.eov/offices/pih/programs/nh/hope6/index.cfrn. (Notice PILI
2010-30
❑ Mixed Finance Modernization or Development. 1)A description of any housing(including project number(if known)and unit count)for which the PHA
will apply for Mixed Finance Modernization or Development;and 2)A timetable for the submission of applications or proposals. The application and approval
process for Mixed Finance Modernization or Development is a separate process.See guidance on HUD's website at:
http://www.hud.gov/offices/pih/programs/ph/hope6/index.cfm. (Notice PIH 2010-30)
❑ Demolition and/or Disposition. Describe any public housing projects owned by the PHA and subject to ACCs(including project number and unit numbers
[or addresses]),and the number of affected units along with their sizes and accessibility features)for which the PHA will apply or is currently pending for
demolition or disposition;and(2)A.timetable for the demolition or disposition. This statement must be submitted to the extent that approved and/or pending
demolition and/or disposition haanged as described in the PHA's last Annual and/or 5-Year PHA Plan submission. The application and approval process for
demolition and/or disposition is separate process. See guidance on HUD's website at: http://w .hud.gov/offices/pih/cmtus/sac/demo dispo/mdex.cf n. 24
CFR&903.7(10
❑ Designated Housing for Elderly and Disabled Families.Describe any public housing projects owned,assisted or operated by the PHA(or portions
thereof),in the upcoming fiscal year,that the PHA has continually operated as,has designated,or will apply for designation for occupancy by elderly and/or
disabled families only. Include the following information: 1)development time and number;2)designation type;3)application status;4)date the designation
was approved,submitted,or planned for submission,and;5)the number of units affected. Note: The application and approval process for such designations is
separate from the PHA Plan process,and PHA Plan approval does not constitute HUD approval of any designation.(24 CFR&903.76)(C))
❑ Conversion of Public Housing. Describe any public housing building(s)(including project number and unit count)owned by the PHA that the PHA is
required to convert or plans to voluntarily convert to tenant-based assistance;2)An analysis of the projects or buildings required to be converted;and 3)A
statement of the amount of assistance received to be used for yentassistance or other housing assistance in connection with such conversion. See guidance on
HUD's website at:http://www.hud.gov/offices/pih/centers/sac/conversion.cfm. (24 CFR&903.7(1))
❑ Conversion of Public Housing. Describe any public housing building(s)(including project number and unit count)owned by the PHA that the PHA plans
to voluntarily convert to project-based assistance under RAD. See additional guidance on HUD's website at:Notice PIH 2012-32
❑ Occupancy by Over-Income Families. A PHA that owns or operates fewer than two hundred fifty(250)public housing units,may lease a unit in a public
housing development to an over-income family(a family whose annual income exceeds the limit for a low income family at the time of initial occupancy),if all
the following conditions are satisfied: (1)There are no eligible low income families on the PHA waiting list or applying for public housing assistance when the
unit is leased to an over-income family;(2)The PHA has publicized availability of the unit for rental to eligible low income families,including publishing public
notice of such availability in a newspaper of general circulation in the jurisdiction at least thirty days before offering the unit to an over-income family,(3)The
over-income family rents the unit on a month-to-month basis for a rent that is not less than the PHA's cost to operate the unit;(4)The lease to the over-income
family provides that the family agrees to vacate the unit when needed for rental to an eligible family;and(5)The PHA gives the over-income family at least
thirty days notice to vacate the unit when the unit is needed for rental to an eligible family. The PHA may incorporate information on occupancy by over-income
families into its PHA Plan statement of deconcentration and other policies that govern eligibility,selection,and admissions. See additional guidance on HUD's
website at Notice PIH 2011-7.(24 CFR 960.503) (24 CFR 903.7(6))
❑ Occupancy by Police Officers. The PHA may allow police officers who would not otherwise be eligible for occupancy in public housing,to reside in a
public housing dwelling unit. The PHA must include the number and location of the units to be occupied by police officers,and the terms and conditions of their
tenancies;and a statement that such occupancy is needed to increase security for public housing residents. A"police officer'means a person determined by the
PHA to be,during the period of residence of that person in public housing,employed on a full-time basis as a duly licensed professional police officer by a
Federal,State or local government or by any agency of these governments. An officer of an accredited police force of a housing agency may qualify. The PHA
Page 6 of 69
may incorporate information on occupancy by police officers into its PHA Plan statement of deconcentration and other policies that govern eligibility,selection,
and admissions. See additional guidance on HUD's website at: Notice PIH 2011-7.(24 CFR 960.505)(24 CFR 903.7(6))
❑ Non-Smoldng Policies.The PHA may implement non-smoking policies in its public housing program and incorporate this into its PHA Plan statement of
operation and management and the rules and standards that will apply to its projects. See additional guidance on HUD's website at:Notice PIH 2009-21. 24
CFR&903.7(e))
❑ Project-Based Vouchers. Describe any plans to use Housing Choice Vouchers(HCVs)for new proj ect-based vouchers,which must comply with PBV
goals,civil rights requirements,Housing Quality Standards(HQS)and deconcentration standards,as stated in 983.57(6)(1)and set forth in the PHA Plan
statement of deconcentration and other policies that govern eligibility,selection,and admissions. If using project-based vouchers,provide the projected number
of project-based units and general locations,and describe how project-basing would be consistent with the PHA Plan. (24 CFR&903.7(6))
❑ Units with Approved Vacancies for Modernization.The PHA must include a statement related to units with approved vacancies that are undergoing
modernization in accordance with 24 CFR&990.14560(1).
❑ Other Capital Grant Programs(i.e.,Capital Fund Community Facilities Grants or Emergency Safety and Security Grants).
For all activities that the PHA plans to undertake in the current Fiscal Year,provide a description of the activity in the space provided.
B.3 Civil Rights Certification. Foran HUD-50077,PHA Certifications of Compliance with the PHA Plans and Related Regulation,must be submitted by the PHA
as an electronic attachment to the PHA Plan. This includes all certifications relating to Civil Rights and related regulations. A PHA will be considered in
compliance with the AFFH Certification if:it can document that it examines its programs and proposed programs to identify any impediments to fair housing
choice within those programs;addresses those impediments in a reasonable fashion in view of the resources available;works with the local jurisdiction to
implement any of the jurisdiction's initiatives to affirmatively further fair housing;and assures that the annual plan is consistent with any applicable
Consolidated Plan for its jurisdiction.(24 CFR&903.7(0))
B.4 Most Recent Fiscal Year Audit. If the results of the most recent fiscal year audit for the PHA included any findings,mark"yes"and describe those findings in
the space provided. (24 CFR&903.7(0))
B.5 Progress Report. For all Annual Plans following submission of the first Annual Plan,a PHA must include a brief statement of the PHA's progress in meeting
the mission and goals described in the 5-Year PHA Plan.(24 CFR&903.7(0(1))
B.6 Resident Advisory Board(RAB)comments.If the RAB provided comments to the annual plan,mark"yes,"submit the comments as an attachment to the Plan
and describe the analysis of the comments and the PHA's demade on these recommendations.(24 CFR&903.13(c),24 CFR&903.191
B.7 Certification by State of Local Officials. Foran HUD-50077-5 Certification by State or Local Officials of PHA Plans Consistency with the Consolidated
Plan,must be submitted by the PHA as an electronic attachment t the PHA Plan.(24 CFR&903.15). e: A PHA may request to change its fiscal year to
better coordinate its planning with planning done under the Consolidated Plan process by State or local officials as applicable.
B.8 Troubled PHA. If the PHA is designated troubled,and s a current MOA,improvement plan,or recovery plan in place,mark"yes,"and describe that plan.If
the PHA is troubled,but does not have any of these items mark"no"If the PHA is not troubled,mark"N/A."(24 CFR&903.91
C. Statement of Capital Improvements.PHAs that receive funding fro the Capital Fund Program(CFP)must complete this section.(24 CFR 903.7(e))
CA Capital improvements. In order to comply with this requirement,the PHA must reference the most recent HUD approved Capital Fund 5 Year Action Plan.
PHAs can reference the form by including the following language in Section8.0 of the PHA Plan Template:"See HUD Foran-50075.2 approved by HUD
on XX/XX/XXXX"
_This
information collection is authorized by Section 511 of the Quality Housing and Wo Responsibility Act,which added a new section SA to the U.S.Housing Act of 1937,as amended,which
introduced the S-Year and Annual PHA Plan
Public reporting burden for this information collection is estimated to average 9.2 hours per response,including the time for reviewing instructions,searching existing data sources,
gathering and maintaining the data needed,and completing and reviewing the collection of information. HUD may not collect this info rmatiog and respondents are not required to
co mplete this form,unless it displays a currently valid OMB Control Number.
Privacy Act Notice. The United States Department of Housing and Urban Development is authorized to solicit the information requested in this form by virtue of Title 12,U.S.Code,
Section 1701 et seq.,and regulations promulgated thereunder at Title 12,Code of Federal Regulations. Responses to the collection of information are required to obtain a benefit or to
retain a benefit The information requested does not lend itself to confidentiality.
Page 7 of 69
B.
Annual Plan Elements
B.1.
(b) If the PHA answered yes for any element, describe the revisions for each revised element(s):
Statement of Housing Needs and Strategy for Addressing Housing Needs:
Needs Assessment Overview(Consolidated Plan)
The City of Dubuque worked with John Marshall Law School and Cappell Statistical Consulting in the consolidated
planning process to determine the varying needs within the City for affordable housing,community development and
homelessness.The 2010 Analysis of Impediments to Fair Housing was updated and needs were identified to
Affirmatively Further Fair Housing. Together,the Needs Assessment, Analysis of Impediments, and Housing Market
Analysis provided information of the supply, demand,conditions and cost of housing for families and households,
renters and owners, minorities,elderly,and disabled. The citizen participation plan allowed for community input
through public meetings,a survey, and/or written comment. Citizen participation assisted to determine priority based
on the identified needs. Citizen input contributes toidentifying priorities to be addressed in the plan and the allocation
of resources.The City agreed to a Voluntary Compliance Agreement with HUD in March 2014 to correct the HUD
finding that the City violated Title VI of the Civil Rights Act in the administration of the Section 8 program. The
Voluntary Compliance Agreement outlines specific steps the City must tak to comply with federal regulations.
Summary of Housing Needs (Consolidated Plan)
The population of Dubuque has remained relatively consistent,decreasing slightly from 57,696 in 2000 to 57,679 in
2011.The number of households increased by 5%, from 22,612 to 23,719 in the same time period. According to the
2007-2011 CHAS Data, Dubuque had 2,585, or 11%of households with between 0-30% HUD Area Median Family Income
(HAMFI or AMI); 3,465 households, 15%of the total households in the City were earning greater than 30-50%AMI; and,
5,395 households,or 23%were households in the income range of 51-80%AMI. Overall, 11,445 households in the City
were at or below 80%of AMI,or 48%of the total households in the City.
A total of 9,325 households were Small Family Households (2-4 persons per households). Of those, 34%are at or below
80%AMI and of the 1,360 large family households (5 or more per household) 44%were at or below 80%AMI.
Households with an elderly member, (age 62-74) numbered 3,950, and represent about 17%of all households. Over half
of these households, 51%,are at or below 80%AMI. A total of 3,375 households contained one person age 75 or older
and 74%of those households are at or below 80%AMI.
The City is home to approximately 9,465 rental households at or below 80%AMI and 6,845 homeowners at or below
80%AMI. Among rental households,45%are experiencing some sort of housing problem. Over half of those
experiencing housing problems are in the extremely low income category,where about 1,805 households experience
problems with housing lacking complete plumbing or kitchen facilities,overcrowding, severe overcrowding,or cost
burden greater than 30 or 50%of the household income. Seventy-Six Percent(76%) of those experiencing housing cost
burden greater than 50%of income are extremely low income households. Renters are more likely to experience severe
overcrowding than homeowners. Among homeowners, 45%of those experiencing cost burden are extremely low income.
Eighty-Five Percent (85%) of homeowners under 80%AMI experience one of the above-mentioned housing problems.
Cost burden is by far the most prevalent problem,for owned and rented households alike.The data shows that of those
renters experiencing housing problems,85%of households with income 0-30%AM I experience some level of cost
burden; 91%of households 31-50%AMI experience cost burden; and 78%of households 51-80%AMI are cost
burdened. For owners experiencing housing problems, 95%of those 0-30%AMI experience a level of cost burden; 96%
of households 31-50%AMI are cost burdened; and 98%of households experiencing problems at 51-80%AMI are cost
burdened.
Section 504 Needs Assessment: Describe the needs of public housing tenants and applicants on the waiting list
Page 8 of 69
for accessible units:
The city of Dubuque does not administer any public housing. Affordable housing is provided through the Housing Choice
Voucher Program, Moderate Rehabilitation Program, Project Based Vouchers, and the Continuum of Care Special Needs
Assistance Program. The needs of Housing Choice Voucher applicants on the waiting list include affordable housing.
Most applicants are cost burdened prior to admission and do not have sufficient income to pay fair market rent. In
addition to affordable housing, many on the program are unemployed or underemployed, disabled,elderly, or
otherwise unable to obtain employment at a level that allows for self-sufficiency. In order to assist in meeting the
various needs of assisted housing tenants, the City administers a Family Self-Sufficiency Program. The Family Self-
Sufficiency Program had 142 active participants in the City's fiscal year 2016. Participants work on a variety of self-
determined goals aimed at developing the skills and resources needed to obtain employment earning a living wage. In
FY2016 nine (9) participants successfully completed the Family Self-Sufficiency-Program.
As of FYE 2016,the average annual earned income at the start of FSS was 6,629 and the average earned annual income at
FSS graduation is$20,379 (increase of 207%).The FSS graduates that are still participating in the assisted housing program
have increased their earned income from an average of$4,831 to$12,809. Though many graduates successfully complete
the program and move off of housing assistance, the Family Self-Sufficiency program support is vital to the continued
success and engagement of extremely low-income and min rity households participating in the Housing Choice Voucher
Program.
Of the families participating in FY 2016 FSS program,forty-three ercent(43%) of the families" income from earned
wages. Forty-seven percent(47%) of the participating families have escrow accounts totaling$ ,162. The average
escrow paid upon completion of FSS Contract was$3,821.
As of November 1, 2016,the overwhelming majority(87%) of those on the waiting list are extremely low income and 60%
are families with children. Sixty-four percent (64%) of those on the waiting list are Black/African American, followed by 35%
White, 1% Native Hawaiian/Other Pacific Islander,and less than 1%Asian, American Indian/Alaska Native. According to the
2009-2013 American Community Survey, 62%of Dubuque's African American population earn under$25,000 per year.The
data in this reports demonstrates African Americans are more likely to experience housing problems, including cost burden,
compared to the jurisdiction as a whole. Education,job readiness skills, living-wage employment,and quality affordable
housing are high needs for the waiting list population. Approximately 12%of those waiting for housing assistance are
families with disabilities.
Strategies developed by the City to address corrective actions identified by HUD in the Voluntary Compliance Agreement
and by the revisions of the Administrative Plan address the following needs:
1. A Strategy to increase Hou 'ng opportunities throughout Dubuque which takes into account the needs of
minority populations;
2. A Strategy to provide afforda a housing that is fully available without regard to race or ethnicity throughout all
the communities within Dubuque to create equal housing opportunities; and
3. A strategy to take affirmative steps to provide opportunities for desegregation of areas of racial and ethnic
concentration of poverty, which may include but would not be limited to expanding program opportunities for
Housing Choice Voucher applicants and participants.
To effectively increase housing opportunities throughout Dubuque that takes into account the needs of minority
populations, the City has developed a marketing and outreach plan to ensure equal access to the Assisted Housing
Programs,this includes ensuring that at least 75%of new admissions are extremely low income households.The City is
also implementing an on-line application that will allow greater access to the programs available.To ensure affordable
housing is fully available without regard to race or ethnicity, the City is researching the possibility for a "source of
income"ordinance that will be reviewed by the Dubuque City Council.This will insure greater housing choice for
voucher participants.
Page 9 of 69
Housing Needs of Families on the Section 8 Tenant-Based Assistance Waiting List
In April 2015, the City of Dubuque requested and received permission from HUD to close the waiting list based
uponthe wait period to receive a voucher. Along with the request an over view of the waiting list was submitted
detailing 1500 applicants experiencing a wait period of 1-2 years. As of November 1, 2016, The Waiting List
consisted of:
C$y of D ubuque H ouShg& Comm Lm$y D erebpm est
350 W 6th Street#312 D ubuque,]A 52001
November 1, 2016 Waiting List Statistical Summary
By:Jessica Kieffer As of 10/31/201611:59pm
Waiting List: Section 8 HCV
Race Total Percent WaitingLisk SectionSHCV
American Indian/Alaska Native 1 0.15% Percent that are Handicapped or Disabled: 12.10%
Asian 2 0.30% TotalNumber of Handicapped or Disabled: 80
Native Hawaiian/Other Pack Islander 8 1.21% < TotalNumber ofApplicants Listed: 661
Black/Afiican American 423 63.991/o
Whim 227 34.34% Number Over Lint for Low Income: 0
Total 661 Number Qualifying for Low Income: 0
Number Qualifying for Very Low Income: 87
Number Qualifying for Extremely Low Income: 574
Family Composition Total Percent Percent Qinaifyingfor Lowlncorre: 0.00%
Elderly 26 3% Percent Qualifying for Very Low Income: 13.16%
Disabled 80 Percent Qualifyingfor FAmniely Lowlncome 86.81%
Single 159
Family 396
Total 661
Inmicity on! Percent
Hispanic or Latino 16 242%
Not Hispanic orLatino 97.55%
Total
Waiting List Average Da Waiting List Average Average
Waiting Grosslncome Adjustedlucome
Averages for Section 8 HCV: 714.66 HCV Pmge WL $11,813.53 $11,813.53
ModRehab $8,10839 $8,283.68
Project Based Vouchers $7,499.39 $7,679.04
Section 8HCV $9,167.10 $9,369.92
Averages for All Waiting Hits: $9,147.10 $9,286.54
Page 10 of 69
November 1, 2016 Waiting List Statistical Summary
Waiting Lst: HCV Purge WL
Race Total Percent
American In Native 0 0.00'/o WaitingHst: HCVPurgeWL
Asian 0 0.00'/o Per cent that are Handicapped or Disabled: 17.65%
Native Hawaiian/Other Pack Is lander 0 0.00'/o Total Number of Handicapped or Disabled: 3
Black/Afican American 9 52.94% Total North er of Applicants Lis ted: 17
White 8 47.06%
Total 17 Number Over Limit for Low Income: 0
Number Qualifying for Low Income: 0
Number Qualifying for Very Low Inconce: 4
Number Qualifying for FAremely Low Income: 13
Family Composition Total Percen _
Elderly 1 5.85% Percent Qual' or Low Income: 0.00'/0
Disabled 3 17.65% Percent Qualitying fon-Very Low Income: 23.53%
Single 3 17.65% Percent g for-FAremely Lowlncome 76.47%
Family 10 58.52%
Total 17
Fnudcity Total Percent
Hispanic orLatino 1 5.88%
Not Hispanic or Latino 16 94.12%
Total 17
WaitingLst: ModRehab Waiting Hst: Project BasedVauchers
Race Total Percent _ Race Total Percent
White 17535.79% _ White 55 29.41%
Asian 1 0.20% _ Asian 00.00'/0
Native Hawaiian/Other Pack Is lander 5 1.02% gq Native Hawaiian/Other Tactic Is lander 0 0.00'/0
American In Native 3 0.61% - American Indian/Alaska Native 21.07/0
Black/Afican American 305 62.370 Black/Ahican American 130.69.52%
Total Total 187
Family Composition that NM Percent Fanrily Composition Total Percent
Elderly 19 3.89%1 Elderly 12 642%
Disabled N 7§ 15.95% Disabled 34 18.18%
Single 131 Single 58 31.02%
Family 25 61% Family 83 44.39%
Total `a„ 489 I Total 187
Fnudcity Toto N Percent _ Eanicity Total Percent
Hispanic or Latino 13 266% _ Hispanic or Latino 4 214%
Not Hispanic or Latino 476 97.34% _ Not Hispanic or Latino 183 97.86%
Total 489 Total 187
WaitingLst: ModRehab WaitingHst: Project Based Vouchers
Percent that are Handicapped or Dis ab led: 15.95 _ Per cent that are Handicapped or Dis abled: 18.18%
TotalNunber of Handicapped or Disabled: 78 i TotalNurrb er ofHandicapp ed or Disabled: 34
TotalNunber of Applicants Listed: Total North er of Applicants Listed: 187
Number Over Limit for Low Income: Number Over Limit for Low Income: 0
Number Qualitying for Lowlncome: 0 Number Qualifying for Low Income: 0
Number Qualitying for Very Low Income: 53 Number Qualifying for Very Low Income 16
Number Qualitying for FAremely Lowlncome: 436 Number Qualifying for Fxlremely Lowlncome: 171
M
alifying for Low Income: 0.00'/o Percent QualityingforLowIncome: 0.00'/0alifying for Very LowIncome: 10.84% Percent Onalitying for Very LowIncome: 8561/0alifying for FAremely Low Income: 89.16% Percent Onalitying for FAremely Low Income 91.44%
Page 11 of 69
In January 2010, a voucher freeze was put in place by the City Council reducing the number of vouchers to900
participant families. This was done in effort to increase the quality of program administration. Due to this reduction in
vouchers,a Civil Rights Compliance Review was carried out by HUD in June 2011 resulting in a Letter of Findings on June
17, 2013 and subsequent Voluntary Compliance Agreement in March 2014.The City of Dubuque is committed to thefair
and equitable operation of its programs and denies any intent to discriminate but acknowledges that the actionstaken
had an unintended negative impact on African American program applicants. The City deeply regrets these impactsand
is pursuing corrective actions.This VCA was developed to ensure continued compliance with the City's responsibilities
under Title VI and its implementing regulations, as well as the City's affirmatively furthering fair housing obligationsand
the PIH regulations. All residency preference point allotments and local preference points based on residencywere
removed on December 4, 2012. The City is in the process of implementing an on-line applicant portal to expand access
tothe waiting list with determination of placement on the waiting list cond d using a lotterysystem.
As of November 1, 2016, 914 Vouchers are utilized. The City of Dubuque has maintained a minimum of 95%of Housing
Assistance Payments Expenditure and seeks to utilize maximum funding to assist as many households as allowed by the
HAP funding.
On May 18, 2015, the newly revised administrative plan was adopted. The revised administrative plan changed theorder
of selection from the waiting list and issuance of available vouchers by date and time of application. The admin plan
also included several steps for notification to applicants before removinfrom the waiting list when they did not
respond to notices being sent to update their information for issuance of chers.Throughout he process of updating
the applications, obtaining verifications,scheduling an oral briefing and issuing the Voucher, we identified impediments
that actually slowed the process of the voucher issuance. Therefore,a revision to the Admin Plan regarding the
Opening, Closing and Selection of the Waiting List was submitted to HUD for approval. HUD approved the revision on
July 21, 2016. The RAB reviewed the changes both prior to the submission to HUD and afterwards with the final revision
provided to them on September 15, 2016. The Housing Commission adopted the changes on September 27, 2016. The
City Council adopted the changes on November 17, 2016.
N 1W
In an effort to streamline the admission process in a fair, nondiscriminatory manner, we willbe issuing vouchers based
on a lottery system.. We believe that the lottery system will incregse the chancesof issuing vouchers at a faster pace and
result in a higher leasing rate.The City has made Voucher Issuance top priority to increase utilization and is focused on
effective management of staff time and priorities to meetthese goals. During the City's Fiscal Year 2016 (July 1, 2015
through June 36, 2016), 434 Vouchers were issued to applicarfts. Of the Vouchers issued 289 resulting in a leased unit
or 67%success rate.
Housing Needs and Strategies to Address Housing Needs:
1. Need: Shortage of affordable housing for all eligible populations
Strategy#1: Maximize the number of affordable units available to the PHA within its current resourcesby:
• Undertake measures to ensure access to affordable housing among families assisted by the PHA, regardlessof
unit size required
• Increase or maintain lease-up rates by marketing the program to owners, particularly those outside of areasof
minority and poverty concentration
• Increase or maintain Housing Choice Voucher lease up rates by encouraging owner acceptance of program
• Participate in the Consolidated Plan development process to ensure coordination with broadercomm unity
strategies
• Support programs through the City of Dubuque Rehabilitation activities and continue Housing Choice
Voucher Homeownership program. All HCV participants desiring to enroll in the Homeownership Made
Easyclasses attend free of charge.
• Any change in lease up rates that would result in a decrease in the number of vouchers utilized mustbe
Page 12 of 69
proposed and approved by HUD
Strategy#2: Carry out the actions in the Voluntary Compliance Agreement of 2014 to bring PHA into compliance with and
ameliorate the impacts of the policies from 2009-2010 that lead to the Findings of Noncompliance with Title VI of the Civil
Rights Act.
On June 20-24, 2011,staff from HUD's Office of Fair Housing and Equal Opportunity (FHEO) completed a civil rights
related program review of the City's Housing and Community Development Department. The review focused on policies
that were primarily implemented in late 2009 and early 2010 that limited the participation of African American
participants in the program. The review team collected demographic data on Housing Choice Voucher program
participants, including wait list information,applicant resolution information,and voucher utilization. The team further
collected and reviewed information available through public recordAincluddin ' meeting minutes, committee meeting
minutes,and newspaper articles. Finally,the team collected policieports such as the City's Consolidated
Plan and the PHA's wait list admission policies.
As a result of the compliance review, HUD issued a Letter of Findinge 17, 2013. The LOF alleged that the
PHA discriminated against African Americans based on race by taking the actions of freezing voucher issuance,
establishing local residency preference points,eliminating the very-low income preference, and purging the wait list. The
City denies discriminating against African American applicants to the program. However,the City had agreed to enter into
a Voluntary Compliance Agreement to ensure continued compliance with its responsibilities under Title VI and its
implementing regulations,as well as the City's AFFH obligations andcompliance with the PIH Pro ram Requirements.
or
• Take actions to meet the provisions detailed within the Volunt Compliance Agreement.
2. Need: Specific Family Types: Families at or below 30%of median
Strategy: Target available assistance to families at or below 30%ofAM
• Encourage enrollment in FSS to support and encourage work
• Provide listings of available Mod Rehab
3. Need: Specific Family Types: Families at or below 50%of me
Strategy: Target available assistance to families at or below 50%ofAMI
• Encourage enrollment in FSS to support and encourage work
• Provide listings of available Mod Rehab units
4. Need: Specific Family Types:The Elderly
Strategy#1:Target available assistance to the elderly
• Collaborate efforts and funding resources with area agencies
• Increase awareness of assisted housing benefits
• Maintain collaborative services with elderly service agencies/apartment complexes
• Continue referrals to elderlyapartments/complexes designed to assist lower income household
• Increase opportunities for the elderly with special needs to maintain an independent lifestyle byproviding
Project Based Vouchers at an assisted living facility (17 Vouchers)
5. Need: Specific Family Types: Families with Disabilities
Strategy#1: Assist families with disabilities in locating suitable housing.
• Affirmatively market to local non-profit agencies that assist families with disabilities
• Actively participate in Fair Housing Planning and identification of impediments to Fair Housing Choice
• Encourage owners to make dwelling units accessible
• Advise disabled participants of monies that are available for their landlords to modify units for
accessibility purposes through the City of Dubuque Rehabilitation Activity
Page 13 of 69
6. Need: Specific Family Types: Races or ethnicities with disproportionate housing needs
Strategy#1: Increase awareness of PHA resources among families of races and ethnicities with disproportionate
needs:
• Continue to participate and support community agencies/groups/organizations to provide Fair Housing Act
information and support
• Continue Fair Housing awareness,outreach, and training
• Increase awareness and understanding of the issues facing special populations as well as persons with low
and moderate incomes
• Provide marketing to minority races and ethnicities, specifically to African Americans, including marketing
on the Homeownership Program and corollary self-sufficiency programs
Strategy#2: Conduct activities to affirmatively further fair housing
• Counsel Housing Choice Voucher tenants as to location of units outside of areas of poverty or minority
concentration andassist them to locate those units
• Market the Housing Choice Voucher program to owners outside of areas of poverty/minority concentrations
• Participate and encourage training of staff and landlords in Fair Housing L\LOF. I• Participate and encourage training of tenants in Fair Housing rights
Reasons for Selecting Strategies: list all that influenced the PHA's selection of the sursue:
• The need to address and correct the aIle tions and findings contained in t
• Funding constraints
• Staffing constraints
• Extent to which housing needs are met by other organizations in the community
• Evidence of housing needs as demonstrated in the Consolidated Plan and ther information available to the PHA
• Influence of the housing market on PHA programs
• Community priorities regarding housing assistance ' .
• Results of consultation with local or state government, th residen nd the Resident Advisory Board,and with
advocacy groups
• Results of a Fair Housing Planning Guide for the City of Dubuque
• Discussions with the City's Housing Commissio
• Feedback from the community
On March 31, 2014,the City of Dubuque, Iowa and the U.S. Department of Housing and Urban Development(HUD) entered
a Voluntary Compliance Agreement outlining remedies to address the findings of noncompliance identified in HUD's letter
to the City dated June 17, 2013. In its letter of findings to the City, HUD found that the City's process of purging applicants
from the waiting list resulted in disparaging impact and kept people out of the program, specifically African-Americans. The
City contends there was no such intent with this process; however, did agree to notify all applicants on the waiting list in
November and December 2009 to invite all applicants to apply. On April 9, 2015 HUD granted permission to close the HCV
waiting list effective April 30, 2015. As of April 1, 2015,the HCV waiting list consisted of 1500 applicants. As of April 2016,
the HCV waiting list consisted of 466 applicants. In April 2016, 1021 applicants from the November and December 2009
"purge group' were notified and invited to apply for the HCV waiting list. Upon exhaustion of the current HCV waiting list,
the applicants invited to apply will be placed on a special HCV waiting list to be processed prior to opening the HCV waiting
list for applications as described in this chapter utilizing the marketing and outreach plan identified in the Administrative
Plan.
Program Specific Waiting List
The City of Dubuque shall maintain waiting lists for the Moderate Rehabilitation Program; the Project Based Voucher
Program and the Housing Choice Voucher Program.
Page 14 of 69
Pre-Application
Moderate Rehabilitation Program Waiting List: The Moderate Rehabilitation Program shall be a separate waiting list. The
Moderate Rehabilitation program provides project-based rental assistance to very low income families. The City of
Dubuque currently has two properties with Moderate Rehabilitation contracts. Eligible families are placed on the
Moderate Rehabilitation waiting list upon request by the family. When vacancies occur in Mod Rehab projects, the City
refers income eligible families for participation in the Mod Rehab program from its waiting list to the owner. Owners select
a family for occupancy of a unit after screening the family. Once the owner selects a family and notifies the City, the City
shall determine final eligibility based upon the same criteria for eligibility as the Housing Choice Voucher program.
Project-Based Voucher Program Waiting List: The Project-Based Voucher Program Waiting List shall be a separate waiting
list. The City of Dubuque currently has one project-based voucher contract in a Selected affordable assisted living
residential facility. All families selected for occupancy must qualify per the very low income guidelines. The project-based
voucher units are designated for occupancy by elderly or disabled families requiring assisted living services. Prior to and as
a condition of occupancy,the Owner or its designated service provider shall evaluate the proposed applicant's status to
determine the qualification for residency of the assisted living facility. When vacancies occur in the project-based voucher
program,the City refers income eligible families for participation in the project-based voucher program from its waiting list
to the owner. The owner selects a family for occupancy of a unit after screening the family. Once the owner selects a
family and notifies the City, the City shall determine final eligibility based upon the same criteria for eligibility as the
Housing Choice Voucher program.
Housing Choice Voucher Program Waiting Lists
The City of Dubuque shall open another Housing Choice Voucher waiting list once the most current HCV waiting list consists
of 350 applications. The current waiting list will be completely exhausted prior to selecting applicants from the new waiting
list. The new HCV waiting list will remain open to accept applications for seven (7),�alendar days with the end date of the
application period falling on a business day. Interested individuals/families will be required to complete a written pre-
application form for admission and placement on the waiting list. Applications submitted online shall be considered written
applications. The City of Dubuque will use the pre-application form to collect'6nly the information necessary to make a
preliminary determination of eligibility.
A lottery system will be used to determine which applicants are placed on the new waiting list once the waiting list is
closed. Using the lottery3ystem,one thousand (1,000) applicants will be selected to be placed on the waiting list. Only the
head of household should apply. Duplicate applications will not be allowed. Each household has an equal chance of being
selected. All applications not selected during the Lottery Selection process to be placed on the waiting list will be tracked
on a bi-annual report per guidelines for reporting in the Voluntary Compliance Agreement with HUD. Applicants that are
not selected to be placed on a waiting list will need to re-apply to the waiting list the next time new applications are
accepted and the waiting lis en.
It is the City of Dubuque's int utilize each HCV waiting list established through the lottery system as described above
by opening and closing the wai ing list as needed. Each time the currently used HCV waiting list is reduced to 350
applications, the waiting list will be opened again for the seven (7) calendar day period and once closed, one thousand
(1,000) applications will be selected to be placed on the new HCV waiting list using the lottery system. The remaining 350
applicants on the current HCV waiting list will remain active throughout the final determination of eligibility process. The
City of Dubuque shall work with HUD to notify them of the status of the waiting list.
The family will be required to provide all the information necessary to establish final family eligibility and level of assistance
when the family is selected from the waiting list.
When the waiting list is open, individuals/families may obtain pre-application forms from the PHA's office during normal
business hours or may complete online applications at the City of Dubuque website at www.cityofdubuque.org/hcv.
Applicants may also request—by telephone, mail or e-mail—an application be sent to them via first class mail or FAX or e-
mail.
Page 15 of 69
Applications must be received during the time the waiting list is open to the public. For applications received by mail, the
received date shall be determined by the date the application has been post marked. For applications received by Fax or e-
mail, the received date shall be determined by the date the FAX or the e-mail is received by the City of Dubuque. The City
of Dubuque shall open the waiting list for seven (7) calendar days with the last day of acceptance on a business day to allow
applicants the opportunity to contact the City of Dubuque Housing Authority staff if the applicant has questions.
If the pre-application is incomplete, the PHA will notify the family of the additional information required. HA staff will make
reasonable efforts to contact the applicant and inform him/her of the additional information required and provide the
applicant 7 calendar days to correct the deficiency. Reasonable efforts shall be in the form of one letter or, if no address is
provided,one telephone call or e-mail. If the HA staff is unable to contact the applicant, the application will be removed
from the lottery selection process or if the applicant is contacted and fails to respond within the time specified or any
extensions of time, the applicant will be removed from the lottery selection ss. A record of those efforts shall be
maintained with the application.
Final Application
On an ongoing basis, the PHA will randomly select households from the waiting list based upon the number of Vouchers
that may be issued by utilizing leasing data and turnover rates and selecting the applicants through a lottery system
randomly pulled from the current HCV waiting list. The applicants selected from the waiting list using the lottery system
will be mailed a full application packet to determine final eligibility.
Completed applications must be received by the PHA by mail, FAX,e-mail or submitted in person during normal business
hours within 15 business days of the date on the PHA letter requesting the updated application. For applications received
by mail,the received date shall be determined by the date the application has been post marked. For applications received
by Fax or e-mail,the received date shall be determined by the date the FAX orEthe e-mail is received by the City of
Dubuque. Applications must be complete to be accepted by the PHA for processing. An application shall only be considered
complete if accompanied by proof of identity; copy of SSN; citizenship, eligible immigration status or non-contending
declaration; and all mandatory release forms along with a completed application. The final "Application" form must be
filled out and must not contain any blanks or unanswered questions.
All applications must be accompanied by proof of identity from a third party for all household members. Acceptable forms
shall include birth certi ' ates; current driver's license; identification card issued by a federal,state, or local agency;
identification card issued by a medical insurance company or provider(including Medicare and Medicaid); or Court records.
All applications must be accompanied by copies of social security cards of all household members.
If the applicant isonable to provide documentation/verification of the SSN but is otherwise determined eligible,the
applicant may retain the applicant's place on the waiting list for the program but cannot become a participant until the
applicant provides the required verification. The applicant will be provided 30 days to obtain the required verification while
retaining the applicant's place on the waiting list.
However, if a child under the age,of 6 years was added to the applicant household within the 6-month period prior to the
household's date of voucher issuance,the applicant may become a participant,so long as the documentation/verification is
provided within 90 calendar days from the date of admission to the program. One additional 90-day extension period will
be granted if the PHA determines that the applicant's failure to comply was due to circumstances that could not reasonably
have been foreseen and were not due to the fault of the applicant.
If the final application is incomplete,the PHA will notify the family of the additional information required. HA staff will
make reasonable efforts to contact the applicant and inform him/her of the additional information required and provide
the applicant 15 business days to correct the deficiency. Reasonable efforts shall be in the form of one letter or, if no
address is provided, one telephone call or e-mail. If the applicant fails to respond within 15 business days, HA staff will
make one additional effort by calling or sending an e-mail. If the HA staff is unable to contact the applicant, the application
will be removed from the waiting list or if the applicant is contacted and fails to respond within the time specified or any
extensions of time, the applicant will be removed from the waiting list. A record of those efforts shall be maintained with
Page 16 of 69
the application. A record of all applications received (even incomplete applications) shall be maintained by the PHA
indicating all attempts to contact the applicant.
The PHA will monitor the characteristics of the population being served and the characteristics of the population in the
PHA's jurisdiction. Targeted outreach efforts will be undertaken if a comparison suggests that certain populations are being
underserved. Outreach activities will include surrounding housing authorities, local chapters of the NAACP within 200
miles,outreach to agencies assisting persons with disabilities and organizations for persons with limited English proficiency.
The PHA administers the following types of targeted funding:
2008 and 2009 Non-Elderly Disabled Participants
Vouchers covered by Project-Based HAP Contract
Tenant Protection
Moderate Rehabilitation Program
Order of Selection
If the available Voucher is designated as a special purpose Voucher Aated disabled families such as NED (Non-Elderly
Disabled),applicants qualifying for the special purpose Voucher will be selected by a computer-generated Lottery system.
Other applicants that do not qualify for the special purpose Voucher will not be selected to receive the Voucher. Special
purpose Vouchers identified as Tenant Protection shall be per the HUD contract(Example: Opt-Out or Mod Rehab
participants converting to the Voucher program.)
Documentation will be maintained by the PHA as to whetheNfam on the list qualify for and are interested in special
purpose vouchers. If a higher placed family on the waiting list is not qualified for the special purpose voucher, there will be
a notation maintained so that the PHA does not have to ask higher placed families each time targeted selections are made.
Financial Resources
The HUC Calendar Year 2016 Renewa Funding for NHousing C oice Vou Program allocated $4,126,596 for
housing assistance payments. Additionally, on April 20, 2016, the City of Dubuque PHA was notified that funds had been
obligated to provide voucher assistance for the Housing Choice Voucher Program-Opt-Out for Kennedy Park West. Nine
units were provided as tenant protection opt-out units in the amount of$43,482 for twelve months beginning May 1,
2016. HUD granted $13247.8 for two Family Self-Suffici ncy Coordinators during calendar year 2016.
Operation and Management
Records Management
Per HUD requir is within 180 days of the effective date of the Voluntary Compliance Agreement(VCA) (March
31, 2014),the Cit I develop and submit the following report to the Department for review and approval:
a. The Bi -Annual Waiting List Report(BWLR) that tracks the maintenance of the Housing Choice Voucher
waiting list. The BWLR will include the following: 1) applicant's name, race,sex,ethnicity,familial/
elderly or disability status; 2) date of application; 3) date applicant placed on waiting list; 4) applicant
preference(s); 5) date and time of offer; 6) date of lease; and 7) date applicant removed from waiting
list and justification.
b. The Bi-Annual Report shall also track all families denied admission to the program,all applicants
determined to be ineligible due to criminal background,and all determinations to terminate
participation in the Assisted Housing Programs. The reports shall include race, national origin, address,
age of applicants, familial status and disability. The reports shall include the specific activity or
occurrence identified by the PHA in making the determination to deny admission to the program or to
terminate participation, how the PHA learned of the activity or occurrence, and what if any,alternate
option or information was provided to the family at the time of denial or termination. All
determinations of ineligibility due to Criminal Background shall include a copy of the denial or
Page 17 of 69
termination notice along with the reports or other information provided to the family at the time of
denial or termination.
c. The City shall continue to submit a BWLR every six months for the duration of the VCA. Submissions of
the BWLR shall occur on the first day of the month for each six-month period, and will include the wait
list information for the immediately preceding six-month period.The biannual reporting periods are as
follows:January 1 through June 30,due on July 15;July 1 through December 31,due January 15.
d. The City shall maintain records for review by the Department for a minimum of five (5) years after the
close of the Agreement. Records subject to review include, but are not limited to: participant lists, wait
lists, ineligible applicant and applicant rejected lists, applications, and terminated participants/
applicant resolution lists.These lists and records shall be kept electronically and in hard copy. While
Dubuque may select the format of the list or record, it must be uniform and consistent for review
purposes. The City shall furnish copies of all records upon request from the Department.
e. The City shall maintain records, including those required under HUD program regulations, which
disclose all individuals who apply and the way each application is treated, i.e.,whether said individuals
are accepted or rejected and the basis for any rejection.
f. The City shall maintain all participant files, including applications for residency, rental agreements or
leases, notices and letters to residents,and notices of termination, along with all material relating to
the City's implementation of the Title VI, Section109,and AFFH requirements of this Agreement.
g. The City shall maintain all material relating to the racial composition of its HAD operated Programs,
such as waiting lists, records of the racial, national origin, elderly, disabled and familial status makeup
of participants in Housing Programs,and copies of denied applications.
h. The City shall maintain copies of all race-remplaints, claims,grievances, investigative records,
including gri ance process materials.
i. The City shall maintain files containing doclat notation efforts to meet the obligations of this
Agreement.
All applicantcipant information will be kept in a secure location and access will be limited to authorized
PHA staff.
PHA staff will not discuss personal family information unless there is a business reason to do so. Inappropriate
discussion of family information or improper disclosure of family information by staff will result in disciplinary
action. qL
Moving with NConted Assistance
HCV Recipients can move to a new unit with continued assistance. Permissible reasons to move are:
• The family has a right to terminate the lease on notice to the owner (for the owner's breach or otherwise)
and has given a notice of termination to the owner in accordance with the lease.
• The lease for the family's unit has been terminated by mutual agreement of the owner and the family.
• The family or a member of the family is or has been the victim of domestic violence,dating violence,or
stalking and the move is needed to protect the health or safety of the family or family member. This
condition applies even when the family has moved out of its unit in violation of the lease, with or without
prior notification to the PHA, if the family or family member who is the victim reasonably believed that he
or she was imminently threatened by harm from further violence if he or she remained in the unit.
• The PHA has terminated the assisted lease for the family's unit for the owner's breach
• The PHA determines that the family's current unit does not meet the HQS space standards because of an
increase in family size or a change in family composition. In such cases,the PHA must issue the family a new
voucher,and the family and PHA must try to find an acceptable unit as soon as possible. If an acceptable
Page 18 of 69
unit is available for the family,the PHA must terminate the HAP contract for the family's old unit in
accordance with the HAP contract terms and must notify both the family and the owner of the termination.
The HAP contract terminates at the end of the calendar month that follows the calendar month in which
the PHA gives notice to the owner.
Restrictions on Moves:
The PHA will deny a family permission to move on grounds that the PHA does not have sufficient funding for
continued assistance if(a) the move is initiated by the family, not the owner or the PHA; (b) the PHA can
demonstrate that the move will, in fact, result in higher subsidy costs; and (c) the PHA can demonstrate that it does
not have sufficient funding in its annual budget to accommodate the higher subsidy costs.
The PHA will deny a family permission to make an elective move during the family's initial lease term.This policy
applies to moves within the PHA's jurisdiction or outside it under portability.
The PHA will also deny a family permission to make more than one elective move during any 12-month period. This
policy applies to all assisted families residing in the PHA's jurisdiction.
The PHA will consider exceptions to these policies for the following reans: to protect the health or safety of a
family member (e.g., lead-based paint hazards,domestic violence, witness protection programs),to accommodate
a change in family circumstances (e.g., new employment,school attendance in a distant area),or to address an
emergency over which a family has no control. The PHA provides exceptions for legitimate family needs but not for
the convenience of either or both parties. The PHA may request the family to obtain a mutual agreement from the
owner to move when considering exceptions.
In addition,the PHA will allow exceptions to these policies for es of reasonable accommodation of a family
member who is a person with disabilities.
Portability: A family may move with voucher assistance only to an area where there is at least one PHA
administering a voucher program. Applicant families that have been issued vouchers as well as participant families
may qualify to lease a unit outside the PHA's jurisdiction under portability. If neither the head of household nor the
spouse/cohead of an applicant family had a domicile (legal residence the PHA's jurisdiction at the time that the
family's initial application for assistance was submitted, the family must lease a unit within the initial PHA's
jurisdiction for at least 12 months before requesting porta 'lity.
The PHA will consider exceptions to this policy for purpose of reasonable accommodation or reasons related to
domestic violence, dating violence, or stalking.
Because the portability process is time-sensit the PHA will notify the receiving PHA by phone,fax, or e-mail to
expect the family. The initial PHA will also ask the receiving PHA to provide any information the family may need
upon arrival, including the name, fax,e-mail address,and telephone number of the staff person responsible for
business with incoming portable families and procedures related to appointments for voucher issuance.The PHA
will pass this information along to the family.The PHA will also ask for the name, address, telephone number, fax
and e-mail of the person responsible for processing the billing information
Page 19 of 69
Determination of Insufficient Funding
The PHA will determine whether there is adequate funding to issue vouchers, approve moves to higher cost units
and areas,and continue subsidizing all current participants by comparing the PHA's annual budget authority to the
annual total HAP needs monthly.The total HAP needs for the calendar year will be projected by establishing the
actual HAP costs year to date. To that figure,the PHA will add anticipated HAP expenditures for the remainder of
the calendar year. Projected HAP expenditures will be calculated by multiplying the projected number of units
leased per remaining months by the most current month's average HAP.The projected number of units leased per
month will consider the average monthly turnover of participant families. If the total annual HAP needs equal or
exceed the annual budget authority,or if the PHA cannot support the cost of the proposed subsidy commitment
(voucher issuance or move) based on the funding analysis, the PHA w' a considered to have insufficient funding.
Violence Against Women Act(VAWA)
The PHA acknowledges that a victim of domestic violence, dating violence, or stalking may have an unfavorable
history (e.g., a poor credit history,a record of previous damage to an apartment,a prior arrest record) that would
warrant denial under the PHA's policies. Therefore, if the PHA decides to deny assistance to an applicant family,the
PHA will include in its notice of denial the VAWA information and will request that an applicant wishing to claim
protection under VAWA notify the PHA within 10 b ss days.
If the perpetrator of the abuse is a mem r of the applica t ami y, t e applicanNmus vide additional
documentation consisting of one of the ;lowing:
A signed statement(1) requesting that the perpetrator be removed from the application and (2) certifying
that the perpetrator will not be permitted to visit or to stay as a guest in the assisted unit
Documentation that the perpetrator has successfully completed rehabilitation or treatment.The
documentation ust be signed by an employee or agent of a domestic violence service provider or by a
medical or othe now;edgeab;e professioril; from whom the^perpetrator has sought or is receiving
assistance in addressing the abuse. The signer must attest under penalty of perjury to his or her belief that
the rel abi;itation was successfully com leted. The victim and perpetrator must also sign or attest to the
documentation.
VAWA provides four specific protections against termination of HCV assistance for victims of domestic violence,
dating violence,or stalking. (Note:The second, third, and fourth protections also apply to terminations of tenancy
or occupancy by owners participating in the HC program, as do the limitations discussed under the next heading.)
First,VAWA provides that a PHA may not term; to assistance to a family that moves out of an assisted unit in
violation of the lease,with or without prior notification to the PHA, if the move occurred to protect the health or
safety of a family member who is or has been the victim of domestic violence,dating violence,or stalking and who
reasonably believed he 6r she was imminently threatened by harm from further violence if he or she remained in
the unit. Nr
Second, it provides that an incident or incidents of actual or threatened domestic violence, dating violence, or
stalking may not be construed either as a serious or repeated lease violation by the victim or as good cause to
terminate the assistance of the victim.
Third, it provides that criminal activity directly related to domestic violence,dating violence,or stalking may not be
construed as cause for terminating the assistance of a tenant if a member of the tenant's household,a guest,or
another person under the tenant's control is the one engaging in the criminal activity and the tenant or an
immediate family member of the tenant is the actual or threatened victim of the domestic violence, dating
violence, or stalking.
Page 20 of 69
Fourth, it gives PHAs the authority to terminate assistance to any tenant or lawful occupant who engages in
criminal acts of physical violence against family members or others without terminating assistance to,or otherwise
penalizing, the victim of the violence.
In determining whether a program participant who is a victim of domestic violence, dating violence, or stalking is an
actual and imminent threat to other tenants or those employed at or providing service to a property,the PHA will
consider the following, and any other relevant,factors:
Whether the threat is toward an employee or tenant other than the victim of domestic violence, dating
violence, or stalking
Whether the threat is a physical danger beyond a speculative threat
Whether the threat is likely to happen within a short period of time
Whether the threat to other tenants or employees can be eliminated in some other way, such as by helping
the victim relocate to a confidential location or seeking a legal remedy to prevent the perpetrator from
acting on the threat
If the participant wishes to contest the PHA's determination that he or she is an actual and imminent threat to
other tenants or employees, the participant may do so as part of the informal hearing.
The PHA will terminate assistance to a family member if the PHA det rmines that the family member has
committed criminal acts of physical violence against other family members or others. This action will not affect the
assistance of the remaining, nonculpable family members. In making its decision, the PHA will consider all credible
evidence, including, but not limited to, a signed certification (form HUD-50066) or other documentation of abuse
submitted to the PHA by the victim.
A PHA presented with a claim for initial or continued assistance based on status as a victim of domestic violence,
dating violence,stalking, or criminal activity related to any of these forms of abuse may—but is not required to—
request that the individual making the claim document the abuse. Any request for documentation must be in
writing, and the individual must be allowed at least 14 business days after receipt of the request to submit the
documentation. The P111;
ay extend this time period at its discretion.
For purposes of etermining ether a tenant may be covered by VAWA,the following list of definitions applies:
VAWA defines tic violence to include felony or misdemeanor crimes of violence committed by any of the
following:
• A current or forme use of the victim
• A person with whom the victim shares a child in common
VF
• A person who is cohabitating with or has cohabitated with the victim as a spouse
• A person similarly situated to a spouse of the victim under the domestic or family violence laws of the
jurisdiction receiving grant monies
• Any other person against an adult or youth victim who is protected from that person's acts under the domestic
or family violence laws of the jurisdiction
VAWA defines dating violence as violence committed by a person (1) who is or has been in a social relationship of a
romantic or intimate nature with the victim AND (2) where the existence of such a relationship shall be determined based
on a consideration of the following factors:
Page 21 of 69
• The length of the relationship
• The type of relationship
• The frequency of interaction between the persons involved in the relationship
VAWA defines stalking as (A)(i) to follow, pursue,or repeatedly commit acts with the intent to kill, injure, harass,or
intimidate another person OR(ii) to place under surveillance with the intent to kill, injure, harass,or intimidate another
person AND (B) in the course of,or as a result of,such following, pursuit, surveillance, or repeatedly committed acts,to
place a person in reasonable fear of the death of,or serious bodily injury to,or to cause substantial emotional harm to (i)
that person, (ii) a member of the immediate family of that person,or (iii) the spouse or intimate partner of that person.
Rent Determination
To be eligible, the dwelling unit must have a reasonable rent. The rent must be reasonable in relation to comparable
unassisted units in the area and must not be more than rents charged by the owner for comparable, unassisted units on
the premises. The PHA must make a rent reasonableness determination at initial occupancy and whenever the owner
requests a rent adjustment. Where the gross rent of the unit exceeds the applicable payment standard for the family,
the share of rent to be paid by the family cannot exceed 40 percent of the family's monthly adjusted income.
Bedroom size assignments on Vouchers will be made so that the smallest number of bedrooms needed to house a family
without overcrowding shall be issued. The subsidy standards will be consistent with space requirements under the City
of Dubuque Housing Code. The subsidy sta dards will be applied consistently for all families of like size and
composition. A child who is temporarily awa from the home because of placement in foster care is considered a
member of the family in determining the family unit size. A family that consists of a pregnant woman (with no other
persons) must be treated as a two-person family (parent/minor child) and shall be assigned a two-bedroom voucher.
Any live-in aide (approved by the PH eside in the unit to care for a family meber who is disabled) must be counted
as a person residing in the household in deter fining the family unit size and shall issued a separate bedroom.
In the case of a participant who shares custody of a child (or children) with a Arent or guardian residing outside of the
household,the child shall be included as a member of the household when considering the assignment of bedroom size if
the child (or children) legally reside with the participant and is considered a household member.
Disabled household members shall be provided separate bedrooms in cases of disabled household members receiving
supportive services to enhance independent living from another agency.
The bedroom size assi is on Vouchers shall be made according to the number of persons and relationship in the
household. Two persons a assigned to each bedroom/sleeping room in cases of children or adults cohabitating
and/or married.
The PHA will assign one bedroom for each two persons within the household,except in the following circumstances:
• Head of Household residing with an adult or minor child shall be allocated separate bedrooms resulting in a two-
bedroom Voucher. Head of Household who is residing with more than one adult or minor child under the age of 10
years old shall be allocated Voucher size allowing for two persons per bedroom and a separate bedroom for head of
household that includes spouse/cohabitant.
• In determining Voucher size for parent(s) including cohabitant,a separate bedroom shall be allocated for the head of
household/spouse/cohabitant and a separate bedroom for more than one adult or minor children of opposite sex age
10 years or older. Same sex adult or minor children shall be allocated one bedroom for each two persons.
Page 22 of 69
• Adding additional persons to the household shall not increase the voucher issuance until the annual recertification or
unit change, if needed, if adding the person does not overcrowd the current unit. The dwelling unit must have at least
one bedroom or living/sleeping room for each two persons
The City of Dubuque's minimum rent is$0.00.
Current Policy: The PHA will conduct interim reexaminations in each of the
following instances:
The PHA will conduct an interim reexamination to recalculate the new family share of rent when the grossincome
increases by$200.00 or more per month.
Proposed Policy: The PHA will conduct an interim reexamination when ad w household members.
Grievance Procedures: INFORMAL REVIEWS AND HEARINGS
OVERVIEW
Both applicants and participants have the right to disagree with, d appeal,certain decisions of the PHA thatmay
adversely affect them. PHA decisions that may be appealed by applicants and participants are discussed in thissection.
The process for applicant appeals of PHA decisions is called the "informal review." For participants (or applicants denied
admission because of citizenship issues), the appeal process is called an "informal hearing." PHAs are required to include
informal review procedures for applicants and informal hearing procedures for participants in their administrative plans
[24 CFR 982.54(d)(12) and(13)].
INFORMAL REVIEWS
Informal reviews are provided for program applicants. An applicant is someone who has applied for admission tothe
program, but is not yet a participant in the program. Informal reviews are intendedo provide a "minimum hearing
requirement" [24 CFR 982.554], and need not be as elaborate as the informal hearing requirements [Federal Register60,
no. 127(3 July 1995): 34690].
Decisions Subject to LWOW Review
The PHA must give an applicant the opportunity for an informal review of a decision denying assistance [24 CFR
982.554(a)]. Denial of assistance may include any or all of the following[24 CFR 982.552(a)(2)]:
• Denying listing on the PHA waiting list
• Denying or withdrawing a voucher
• Refusing to enter a HAP contract or approve a lease
• Refusing to process or assistance under portability procedures
Informal reviews are not reqde for the following reasons [24 CFR982.554(c)]:
• Discretionary administrative determinations by the PHA
• General policy issues or class grievances
• A determination of the family unit size under the PHA subsidy standards
• A PHA determination not to approve an extension or suspension of a voucherterm
• A PHA determination not to grant approval of the tenancy
• A PHA determination that the unit is not in compliance with the HQS
• A PHA determination that the unit is not in accordance with the HQS due to family size or composition
The PHA will only offer an informal review to applicants for whom assistance is being denied. Denial ofassistance
includes: denying listing on the PHA waiting list; denying or withdrawing a voucher; refusing to enter into a HAPcontract
or approve a lease; refusing to process or provide assistance under portability procedures.
Notice to the Applicant
Page 23 of 69
The PHA must give an applicant prompt notice of a decision denying assistance. The notice must contain a brief statement
of the reasons for the PHA decision, and must also state that the applicant may request an informal reviewof the
decision. The notice must describe how to obtain the informal review.
Any previous participant or applicant that had been determined to be ineligible for Assisted Housing that was notified in
writing of the reason for his/her ineligibility and of his/her right to request an Informal Review/Hearing shall beheld
accountable to the terms and time limits of the previous notice or decision letter.
Scheduling an Informal Review
A request for an informal review must be made in writing and delivered to the PHA either in person or by first class mail,
by the close of the business day, no later than 10 business days from the date of the PHA's denial of assistance.
Exceptions for requesting an informal review in writing may be granted for limited English proficiency,disabled individuals
or for reasonable accommodations.
The PHA must schedule and send written notice of the informal review within 10 business days of the family's request. The
family may request to reschedule a review for good cause, or if it is needed as a reasonable accommodation fora person
with disabilities. Good cause is defined as an unavoidable conflict which seriously affects the health,safetyor welfare of
the family. Requests to reschedule a review must be made orally or in writing prior to the review date. Atits discretion,
the PHA may request documentation of the "good cause" prior to rescheduling thereview.
Upon notification in advance with at least 24 hours' notice on any party's unavailability to attend a scheduled review,the
review will be rescheduled one time only without justification of the need to reschedule. After the review has been
rescheduled, a request to reschedule a second time by the same party will only be considered for extreme situations.
Extreme situations may include but are not limited to hospitalization of self or household member,death in the family,
weather related restriction. Any notice of the inability of the applicant to attend the review must be provided within24
hours of the review along with third party verification of the situation.The review officer will have the sole discretion to
decide if the request is legitimate and with good cause.
Informal Review Procedures
The informal review must be conducted by a person other than the one who m r approved the decision under
review,or a subordinate of this person.
The applicant must be provided an opportunity to present written or oral o ions to the decision of the PHA.
Informal Review Decision
The PHA must notify the applicant of the PHA's final decision, inclding a brief statement of the reasons for thefinal
decision. 06 `
In rendering a decision,the PHA will evaluate the following matters:
If the grounds for denial were stated factually in the notice to the family.
The validity of the grounds for denial of assistance. If the grounds for denial are not specified inthe regulations,then the
decision to deny assistance will be overturned.
The validity of the evidence. a PHA will evaluate whe er the facts presented prove the groundsfor denial of assistance.
If the facts prove that there ounds for denial, and the denial is required by HUD, the PHA will uphold the decision to
deny assistance.
If the facts prove the grounds for denial,and &denial is discretionary, the PHA will considerthe recommendation of the
person conducting the informal review in making the final decision whetherto deny assistance.
The PHA will notify the applicant of the final decision, including a statement explaining the reason(s)for the decision. The
notice will be mailed within 10 business days of the informal review,to the applicant and his or her representative, if any,
along with proof of mailing.
If the decision to deny is overturned because of the informal review, processing for admission will resume.
If the family fails to appear for their informal review,the denial of admission will stand and the family will be so notified.
Page 24 of 69
INFORMAL HEARINGS FOR PARTICIPANTS
PHAs must offer an informal hearing for certain PHA determinations relating to the individual circumstances of
participant family. A participant is defined as a family that has been admitted to the PHA's HCV program and is currently
assisted in the program. The purpose of the informal hearing is to consider whether the PHA's decisions related to the
family's circumstances are in accordance with the law, HUD regulations and PHA policies.
The PHA is not permitted to terminate a family's assistance until the time allowed for the family to request an informal
hearing has elapsed,and any requested hearing has been completed.Termination of assistance for a participant may
include any or all of the following:
• Refusing to enter a HAP contract or approve a lease
• Terminating housing assistance payments under an outstanding HAP contract
• Refusing to process or provide assistance under portability procedures
Decisions Subject to Informal Hearing
Circumstances for which the PHA must give a participant family an opportunity for an informal hearing are as follows:
• A determination of the family's annual or adjusted income, and the use of such income to compute the housing
assistance payment
• A determination of the appropriate utility allowance (if any) for tenant-paidutil' 'es from the PHA utility allowance
schedule
• A determination of the family unit size under the PHA subsidy standards
• A determination that a certificate program family is residing in a unit with a larger n mber of bedrooms than
appropriate for the family unit size under the PHA's subsidy standards, or the PHA determination to denythe
family's request for exception from the standards
• A determination to terminate assistance for a participant family because of the family's actions or failure to act
• A determination to terminate assistance because the participant has been absent from the assisted unit for longer
than the maximum period perm' d under PHA policy and HUD rules
• A determination to terminate a family's Family Self Sufficiency contract,wit Id supportive services, orpropose
forfeiture of the family's escrow account [24 CFR 984.303(i)]
Circumstances for which an informal hearing is not required are as follows:
• Discretionary administrative determinations by the PHA
• General policy issues or class grievances
• Establishment of the PHA schedule of utility allowances for families in the program
• A PHA determination not to approve an extension or suspension of a voucherterm
• A PHA determination not to approve a unit or tency
• A PHA determination that a unit selected by the aplicant is not in compliance with the HQS
• A PHA determination that the unit is not in accordance with HQS because of family size
• A determination by the PHA to exercise or not to exercise any right or remedy against an owner under a HAP
contract
The PHA will only offer participants the opportunity for an informal hearing when required to by the regulations.
Page 25 of 69
Informal Hearing Procedures
Notice to the Family
When the PHA makes a decision subject to informal hearing procedures,the PHA must inform the family of its right to an
informal hearing at the same time that it informs the family of thedecision.
For decisions related to the family's annual or adjusted income, the determination of the appropriate utility allowance,
and the determination of the family unit size, the PHA must notify the family that they may ask for an explanation of the
basis of the determination,and that if they do not agree with the decision, they may request an informal hearing onthe
decision.
For decisions related to the termination of the family's assistance,or the denial of a family's request for an exceptionto
the PHA's subsidy standards, the notice must contain a brief statement of the reasons for the decision, a statementthat if
the family does not agree with the decision,the family may request an inform I hearing on the decision, and a statement
of the deadline for the family to request an informal hearing.
In cases where the PHA makes a decision for which an informal hearing offered, the notice to the family will
include all the following:
The proposed action or decision of the PHA.
A brief statement of the reasons for the decision, including the regulatory referen date the
proposed action will take place.
A statement of the family's right to an explanation of the basis for the PHA's decision.
A statement that if the family does not agree with the decision the family may he
an in I hearing of the decision.
A deadline for the family to request the informal hearing. To whom the
hearing request should be addressed.
A copy of the PHA's hearing procedures or written explanation of hearing procedures. Withoutthis information, the
family will be unable to properly prepare for the hearing. Providing this informationas a matter of policy provides
assurance that the PHA has done all to inform the family of their rights and responsibilities in the hearing process.
Scheduling an Informal Hearing
When an informal hearing is required,the PHA must proceed w0the hearing in a reasonably expeditious mannerupon
the request of the family.
A request for an informal hearing must be made in writing and delivered to the PHA either in person or by firstclass mail,
by the close of the business day, no later than 10 business days from the date of the PHA's decision or noticeto
terminate assistance.
The PHA must schedule and send written notice of the informal hearing to the family within 10 business days of the
family's request.
The family may request schedule a hearing for goccause,or if it is needed as a reasonable accommodation fora
person with disabilities. G d cause is defined as an unavoidable conflict which seriously affects the health, safetyor
welfare of the family. Reques reschedule a hearing must be made orally or in writing prior to the hearing date. At its
discretion, the PHA may request documentation of the "good cause' prior to rescheduling the hearing.
Upon notification in advance with at least 24 hours' notice on any party's unavailability to attend a scheduled hearing,
the hearing will be rescheduled one time only without justification of the need to reschedule. After the hearing has been
rescheduled a request to reschedule a second time by the same party will only be considered forextreme situations.
Extreme situations may include but are not limited to hospitalization of self or household member,death in the family,
weather related restriction. Any notice of the inability of the participant to attend the hearing must be provided within
24 hours of the hearing along with third party verification of the situation. The hearing officer will have the sole
discretion to decide if the request is legitimate and with good cause.
If the family does not appear at the scheduled time,and was unable to reschedule the hearing in advance due tothe
nature of the conflict,the family must contact the PHA within 24 hours of the scheduled hearing date,excluding
Page 26 of 69
weekends and holidays.The PHA will reschedule the hearing only if the family can show good cause for the failure to
appear, or if it is needed as a reasonable accommodation for a person with disabilities.
Pre-Hearing Right to Discovery
Participants and the PHA are permitted pre-hearing discovery rights. The family must be given the opportunity to examine
before the hearing any PHA documents that are directly relevant to the hearing.The family must be allowed to copy any
such documents at their own expense. If the PHA does not make the document available for examination on request of
the family,the PHA may not rely on the document at the hearing.
The PHA hearing procedures may provide that the PHA must be given the opportunity to examine at the PHA offices
before the hearing,any family documents that are directly relevant to the hearing. The PHA must be allowed tocopy any
such document at the PHA's expense. If the family does not make the docume t available for examination on request of
the PHA,the family may not rely on the document at the hearing.
For informal hearings,documents include records and regulations.
The family must request discovery of PHA documents no later than 12:00 p.m. on the business day prior to the scheduled
hearing date.
The PHA must be given an opportunity to examine at the PHA offices before the hearing any family documents that are
directly relevant to the hearing. Whenever a participant requests an informal hearing, the PHA will automatically maila
letter to the participant requesting a copy of all documents that the participant intends to present or utilize atthe
hearing.The participant must make the documents available no later than 12:00 pm on the business day prior tothe
scheduled hearing date.
Participant's Right to Bring Counsel
At its own expense,the family may be represente or other sentative at the informal hearing.
Informal Hearing Officer
Informal hearings will be conducted by a person or persons approved by the PHA, ler than the person who madeor
approved the decision or a subordinate of the person who made or approved thedecision.
The PHA has designated the following to serve as hearingofficers:
Director of the PHA or his/her designated indivi1 including the Assisted Housing Supervisor
Attendance at the Informal Hearing
Hearings maybe attended by a hearing officer and the following applicable persons: A
PHA representative(s) and any witnesses for the PH
The participant and any 'tnesses for the participa
The participant's couns ther representative
Any other person approve a PHA as a reasonable accommodation for a person with adisability Any person
attending the hearing as an in ter due to a disability or Limited English Proficiency
Conduct at Hearings
The person who conducts the hearing may regulate the conduct of the hearing in accordance with the PHA'shearing
procedures [24 CFR982.555(4)(ii)].
The hearing officer is responsible to manage the order of business and to ensure that hearings are conducted in a
professional and businesslike manner. Attendees are expected to comply with all hearing procedures established by the
hearing officer and guidelines for conduct. Any person demonstrating disruptive,abusive or otherwise inappropriate
behavior will be excused from the hearing at the discretion of the hearingofficer.
Evidence
The PHA and the family must be given the opportunity to present evidence and question any witnesses. In general,all
evidence is admissible at an informal hearing. Evidence may be considered without regard to admissibility underthe
rules of evidence applicable to judicial proceedings.
Page 27 of 69
Any evidence to be considered by the hearing officer must be presented at the time of the hearing.There are four
categories of evidence.
Oral evidence: the testimony of witnesses
Documentary evidence: a writing which is relevant to the case,for example,a letter written to the PHA. Writings include
all forms of recorded communication or representation, including letters,words, pictures, sounds,videotapes or symbols
or combinations thereof.
Demonstrative evidence: Evidence created specifically for the hearing and presented as an illustrative aid to assist the
hearing officer, such as a model,a chart or other diagram.
Real evidence: A tangible item relating directly to the case.
Hearsay Evidence is evidence of a statement that was made other than by a witness while testifying at the hearingand
that is offered to prove the truth of the matter. Even though evidence, including hearsay, is generally admissible, hearsay
evidence alone cannot be used as the sole basis for the hearing officer's decision.
If either the PHA or the family fail to comply with the discovery requirements described above,the hearing officer will
refuse to admit such evidence.
Other than the failure of a party to comply with discovery,the hearing officer ha the authority to overrule any
objections to evidence.
Hearing Officer's Decision
The person who conducts the hearing must issue a written decision,stating briefly th ons for the decision.Factual
determinations relating to the individual circumstances of the family must be based on a onderance of evidence
presented at the hearing. A copy of the hearing decision must be furnished promptly to the
In rendering a decision,the hearing officer will consider the following matters:
PHA Notice to the Family:The hearing officer will determine if the reasons for the PHA's decision are factually stated in
the Notice.
Discovery:The hearing officer will determine if the PHA and the family were given the opportunity to examine any
relevant documents in accordance with PHA policy.
PHA Evidence to Support the PHA Decision:The evidence consists of the facts pre ted. Evidence is not conclusion and
it is not argument.The hearing officer will evaluate the facts to determine if they support the PHA's conclusion.
Validity of Grounds for Termination of Assistance(when applicable):The hearing officer will determine if the termination
of assistance is for one of the grounds specified in the HUD regulations and PHA policies. If the grounds for termination
are not specified in the regulations or in compliance with PHA policies, then the decision of the PHA will be overturned.
The hearing officer will issue a written decision to the family and the PHA no later than 10 business days after the
hearing.The report will contain the following information:
Hearing information:
Name of the participant;
Date,time and place of the hearing; Name of thNearing officer;
Name of the PHA representative;and Name of family
representative (if any).
Background: A brief, impartial statement of the reason for the hearing.
Summary of the Evidence:The hearing officer will summarize the testimony of each witnessand identify any documents
that a witness produced in support of hher testimony and that areadmitted into evidence.
Findings of Fact: The hearing officer will include all findings of fact, based on a preponderance of the evidence.
Preponderance of the evidence is defined as evidence which is of greater weight or more convincing than the evidence
which is offered in opposition to it; that is, evidence which as awhole shows that the fact sought to be proved is more
probable than not. Preponderance of the evidencemay not be determined by the number of witnesses, but by the greater
weight of allevidence.
Page 28 of 69
Conclusions: The hearing officer will render a conclusion derived from the facts that were found to be true by a
preponderance of the evidence. The conclusion will result in a determination of whetherthese facts uphold the PHA's
decision.
Order:The hearing report will include a statement of whether the PHA's decision is upheld or overturned. If it is
overturned,the hearing officer will instruct the PHA to change the decision in accordance with the hearing officer's
determination. In the case of termination of assistance,the hearing officer will instruct the PHA to restore the
participant's program status.
Procedures for Rehearing or Further Hearing
The hearing officer may ask the family for additional information and/or might adjourn the hearing to reconvene at a
later date, before reaching a decision. If the family misses an appointment or eadline ordered bythe hearing officer,the
action of the PHA will take effect and another hearing will not be granted.
PHA Notice of Final Decision The PHA is not bound by the decision of the hearing officer for matters in which the PHA is
not required to provide an opportunity for a hearing, decisions that exceed the authority of the hearing officer,decisions
that conflict with or contradict HUD regulations, requirements,or are otherwise ontrary to federal, state,or local laws. If
the PHA determines it is not bound by the hearing officer's decision in accorda 'th HUD regulations, the PHA must
promptly notify the family of the determination and the reason for thedetermina
The PHA will mail a "Notice of Final Decision" including the hearing officer's report to articipant and their
representative. This notice will be sent by first-class mail, postage pre-paid. The particip 11 be mailed theoriginal
"Notice of Final Decision". A copy of the "Notice of Final Decision" will be maintained in the 'sfile.
HEARING AND APPEAL PROVISIONS FORNONCITIZENS
Denial or termination of assistance based on immigration status is subject to special hearing and notice rules. Applicants
who are denied assistance due to immigration status are entitled to an informal hearing, not an informal review.
Assistance to a family may not be delayed,denied,or terminated based on immigration status at any time prior to a
decision under the United States Citizenship and Immigration Services (USCIS) appeal process. Assistance to afamily may
not be terminated or denied while the PHA hearing is pending, but assistance to an applicant may bedelayed pending
the completion of the informal hearing.
A decision against a family member, issued in accordance with the USCIS appeal process or the PHA informal hearing
process,does not preclude the family from exercising thright,that may otherwise be available,to seek redress directly
through judicial procedures.
Notice of Denial or Termination of Assistance
The notice of denial or termination of assistance f oncitizens must advise thefamily:
That financial assistance will be denied or terminat d provide a brief explanation of the reasons for the proposed
denial or termination of tance.
The family may be eligible oration of assistance.
In the case of a participant,t eria and procedures for obtaining relief under the provisions for preservationof
families [24 CFR 5.514 and 5.51
That the family has a right to request an appeal to the USCIS of the results of secondary verification of immigration status
and to submit additional documentation or explanation in support of theappeal.
That the family has a right to request an informal hearing with the PHA either upon completion of the USCIS appeal or in
lieu of the USCIS appeal.
For applicants, assistance may not be delayed until the conclusion of the USCIS appeal process, but assistance maybe
delayed during the period of the informal hearingprocess.
Page 29 of 69
USCIS Appeal Process
When the PHA receives notification that the USCIS secondary verification failed to confirm eligible immigration status,the
PHA must notify the family of the results of the USCIS verification.The family will have 30 days from the date of the
notification to request an appeal of the USCIS results.The request for appeal must be made by the family in writing
directly to the USCIS. The family must provide the PHA with a copy of the written request for appeal and the proof of
mailing.
The PHA will notify the family in writing of the results of the USCIS secondary verification within 10 business daysof
receiving the results.
The family must provide the PHA with a copy of the written request for appeal and proof of mailing within 10 business
days of sending the request to the USCIS.
The family must forward to the designated USCIS office any additional documentation or written explanation insupport of
the appeal. This material must include a copy of the USCIS document verification request(used to processthe secondary
request) or such other form specified by the USCIS, and a letter indicating that the family is requesting an appeal of the
USCIS immigration status verification results.
The USCIS will notify the family,with a copy to the PHA, of its decision. When the USCIS notifies the PHA of thedecision,
the PHA must notify the family of its right to request an informal hearing.
The PHA will send written notice to the family of its right to request an informalNhewithin 10 business days of
receiving notice of the USCIS decision regarding the family's immigration status.
Informal Hearing Procedures forApplicants
After notification of the USCIS decision on appeal, or in lieu of an appeal to the , mily may request thatthe
PHA provide a hearing.The request for a hearing must be made either within 30 days of receipt of the PHA notice of
denial,or within 30 days of receipt of the USCIS appeal decision.
The informal hearing procedures for applicant families are cle cri.. below.
Informal Hearing Officer
The PHA must provide an informal hearing before an In partial i ividual,other than a person who made orapproved the
decision under review,and other than a person who is a subordi ate of the person who made or approvedthe decision.
Evidence
The family must be provided the opportunity to examine and copy at the family's expense,at a reasonable timein
advance of the hearing,any documents in the possession of the PHA pertaining to the family's eligibility status, or inthe
possession of the US S (as permitted by USCIS requirements), including any records and regulations that maybe relevant
to the hearing.
The family will be allowed to copy any documents related to the hearing at a cost of$.25 per page.The family must
request discovery of PHA documents no later than
12:00 p.m. on the business day prior to the hearin .
The family must be provided the opportunity to prese vidence and arguments in support of eligible status. Evidence
may be considered without regard to admissibility under the rules of evidence applicable to judicial proceedings.
The family must also be provided the opportunity to refute evidence relied upon by the PHA, and to confront andcross-
examine all witnesses on whose testimony or information the PHA relies.
Representation and Interpretive Services
The family is entitled to be represented by an attorney or other designee,at the family's expense, and to have such
person make statements on the family's behalf.
The family is entitled to arrange for an interpreter to attend the hearing, at the expense of the family,or the PHA,as may
be agreed upon by the two parties.
Recording of the Hearing
The family is entitled to have the hearing recorded by audiotape.The PHA may, but is not required to provide a transcript
of the hearing.
The PHA will not provide a transcript of an audio taped hearing.
Page 30 of 69
Hearing Decision
The PHA must provide the family with a written final decision, based solely on the facts presented at the hearing,within
14 calendar days of the date of the informal hearing. The decision must state the basis for thedecision.
Informal Hearing Procedures for Participants
After notification of the USCIS decision on appeal, or in lieu of an appeal to the USCIS,the family may request thatthe
PHA provide a hearing.The request for a hearing must be made either within 30 days of receipt of the PHA notice of
termination,or within 30 days of receipt of the USCIS appeal decision.
For the informal hearing procedures that apply to participant families whose assistance is being terminated based on
immigration status.
Retention of Documents
The PHA must retain for a minimum of 5 years the following documents that may have been submitted to the PHA by the
family, or provided to the PHA as part of the USCIS appeal or the PHA informal hearingprocess:
• The application for assistance
• The form completed by the family for income reexamination
• Photocopies of any original documents, inc$ina
al USCIS documents
• The signed verification consent form
• The USCIS verification results
• The request for a USCIS appeal
• The final USCIS determination
• The request for an informal hearing
• The final informal hearing decisio
Homeownership Programs OVERVIEW
The homeownership option is used to assist a family in
e purc ased and owned by one or more members
of the family. A family assisted under this option may be newly admitted or an existing participant in the HCV program.
The PHA must have the capacity to operate a successful HCV homeownership program as defined by the regulations.
There are two forms of homeownership assistance a PHA may offer under this option: monthly homeownership
assistance payments,or a single down payment assistance grant. PHAs may choose to offer either or both formsof
homeownership assistance, or choose not to offer either If a PHA offers both forms of assistance,a family must choose
which form of assistance to receive.
The PHA must offer either form of homeownership assistance if needed as a reasonable accommodation so thatthe
program is readily accessible to and usable by persons with disabilities. It is the sole responsibility of the PHAto determine
whether it is reasonable to implement a homeownershi program as a reasonable accommodation.The PHA must
determine what is reasonable based on the specific cir instances and individual needs of the person witha disability.The
PHA may determine that it is not reasonable to offer homeownership assistance as a reasonable accommodation in cases
where the PHA has otherwise opted not to implement a homeownership program.
The PHA must approve a live-in aide if needed as a reasonable accommodation so that the program is readilyaccessible to
and usable by persons with disabilities..
The PHA will offer the monthly homeownership assistance payments to qualified families.
The Housing Choice Voucher Home Ownership Program permits eligible participants in the HCV Program,including
participants with portable vouchers, the option of purchasing a home with their voucher assistance rather than renting.
The home ownership option is available to newly admitted or existing participants, who do not owe monies to the City of
Dubuque Housing Services or any other Housing Agency for any outstanding debts, and who meet theeligibility criteria
set forth below. Additionally, participants who are in violation of their family obligations while receiving HCV assistance
shall be ineligible for participation in the Housing Choice Voucher Home Ownership Program.
HCV home ownership assistance may be used to purchase the following type of homes within the City of Dubuque:new or
Page 31 of 69
existing single-family dwelling unit,condominium, cooperatives,or manufactured homes. The City of Dubuque Housing
will also permit portability of HCV home ownership assistance to another jurisdiction, provided thereceiving jurisdiction
operates a HCV home ownership program for which the participantqualifies.
FAMILY ELIGIBILITY
The family must meet all the requirements listed below before the commencement of homeownership assistance.The
PHA may also establish additional initial requirements if they are described in the PHA administrative plan. The
family must have been admitted to the Housing Choice Voucher program.The family must qualify as a first-time
homeowner,or may be a cooperative member.The family must meet the Federal minimum income requirement.The
family must have a gross annual income equal to the Federal minimum wage multiplied by 2000, based on the income of
adult family members who will own the home.The PHA may establish a higher income standard for families. However,a
family that meets the federal minimum income requirement(but not the PHA's requirement) will be considered to meet
the minimum income requirement if it can demonstrate that it has been pre-qualified or pre-approved for financingthat
is sufficient to purchase an eligible unit. For disabled families,the minimum income requirement is equal to thecurrent
SSI monthly payment for an individual living alone, multiplied by 12. For elderly or disabled families, welfareassistance
payments for adult family members who will own the home will be included i rmining whether the familymeets
the minimum income requirement. It will not be included for other families. The . must satisfy theemployment
requirements by demonstrating that one or more adult members of the family who wn the home at
commencement of homeownership assistance is currently employed on a full-time ba a term 'full-time
employment' means not less than an average of 30 hours per week); and has been continuously so employed duringthe
year before commencement of homeownership assistance for the family. The employment requirement does notapply
to elderly and disabled families. In addition, if a family,other than an elderly or disabled family includes a personwith
disabilities, the PHA must grant an exemption from the employment requirement if the PHA determines that it is
needed as a reasonable accommodation. The family has not defaulted on a mortgage securing debt to purchase a home
under the homeownership option. Except for cooperative members who have acquired cooperative membershipshares
prior to commencement of homeownership assistance, no family member has a present ownership interest ina
residence at the commencement of homeownership assistance for the purchase of any home. Except forcooperative
members who have acquired cooperative membership shares prior to the commencement of homeownership
assistance,the family has entered a contract of sale in accordance with 24 CFR982.631(c).
The PHA will not establish a higher minimum income standard for disabled and/or non-disabled families.
The family must be financially capable to qualify for HA approved financing of the home and must be financially capable
to provide at least 3%of the purchase rice as a minimum homeowner down payment.The City of Dubuque
Rehabilitation Activityall review le ualifications and the loan terms before authorizing homeownership
assistance. 4
The PHA requires that fin cing for purchase of a home under its HCV homeownership program complieswith
secondary mortgage market underwriting requirements; or complies with generally accepted privatesector
underwriting standards.
Each family,except families with a dised member, must be a first-time homeowner. A first-time homeowner means
that no member of the household has had an ownership interest in any residence during the three years prior tothe
home ownership assistance. However, a single parent or displaced homemaker who, while married, owned a home with
a spouse(or resided in a home owned by a spouse) is considered a first-time home owner for purposes of the Housing
Choice Voucher Home ownership Program.
The Housing and Community Development Director may also consider whether and to what extent anemployment
interruption is considered permissible in satisfying the employment requirement. Generally, families will be considered
"continuously employed" if the break in employment does not exceed two months. The Housing and Community
Development Director may also consider self-employment to determine employment history. Theemployment
requirement does not apply to an elderly or disabled family. To reasonably accommodate afamily's
Page 32 of 69
participation in the program, families that include a person with disabilities may also be exempt from this requirementif
an exemption is needed as a reasonable accommodation.
Participants in the Housing Choice Voucher Program shall be ineligible for participation in the Home Ownership Program
if any debt or portion of a debt remains owed to the City of Dubuque or any other Housing Authority. Additionally,
participants who are in violation of their family obligations while receiving HCV assistance shall be ineligiblefor
participation in the Home Ownership Program.
If the head of household, spouse, or other adult household member who will execute the contract of sale, mortgage and
loan documents has previously defaulted on a mortgage obtained through the HCV Home Ownership Program,the
family will be ineligible to participate in the Home Ownership Program.
SELECTION OF FAMILIES
Unless otherwise provided (under the homeownership option), the PHA may limit homeownership assistance tofamilies
or purposes defined by the PHA, and may prescribe additional requirements for commencement ofhomeownership
assistance for a family. Any such limits or additional requirements must be described in the PHA administrative plan.
If the PHA limits the number of families that may participate in the homeowneill ption,the PHA must establish a
system by which to select families to participate.
ELIGIBLE UNITS
For a unit to be eligible, the PHA must determine that the u t satisfies all the following requirements:
• The unit must meet HUD's "eligible housing" requirements. The unit may not be any of the Ilowing:
- A public housing or Indian housing unit;
- A unit receiving Section 8 project-based assistance;
- A nursing home, board and care home, or facility providing continual psychiatric, medical or nursingservices;
- A college or other school dormitory;
- On the grounds of penal, reformatory, medical, mental, or similar public or private institutions.
• The unit must be under construction or already exist at the time the family enters the contract ofsale.
• The unit must be a one-unit property or a single dwelling unit in a cooperative orcondominium.
• The unit must have been inspected by the PHA and by an independent inspector designated by thefamily.
• The unit must meet Housing Quality Standards (see Chapter
• For a unit where the family will not own fee title to the real erty(such as a manufactured home),the home
must have a permanent foundation and the family must have the right to occupy the site for at least 40 years.
• For PHA-owned units all the following conditiktrfamily
ust be satisfied:
- The PHA informs the family, both orally ariting,that the family has the right to purchase any eligibleunit
and a PHA-owned unit is freely selected bwithout PHA pressure or steering;
The unit is not ineli housing;
The PHA obtains the se ces of an Idepenclent agency to inspect the unit for compliance with HQS, reviewthe
independent inspection report, review the contract of sale, determine the reasonableness of the sales price and
any PHA provided financing. These actions must be completed in accordance with program requirements.
The PHA must not approve the unit if the PHA has been informed that the seller is debarred,suspended,or subject to a
limited denial of participation.
ADDITIONAL PHA REQUIREMENTS FOR SEARCH AND PURCHASE
It is the family's responsibility to find a home that meets the criteria for voucher homeownership assistance.The PHA
may establish the maximum time that will be allowed for a family to locate and purchase a home, and may require the
family to report on their progress in finding and purchasing a home. If the family is unable to purchase a homewithin
the maximum time established by the PHA,the PHA may issue the family a voucher to lease a unit or place thefamily's
name on the waiting list for a voucher.
The family will be allowed 120 days to identify a unit and submit a sales contract to the PHA for review.The family will be
Page 33 of 69
allowed an additional 120 days to close on the home. PHAs may grant extensions to either ofthese periods for good
cause.The length of the extension(s) will be determined on a case-by-case, but in no casewill an extension exceed a total
of 125 days. The maximum amount of time a family will be given to locateand complete the purchase of a home under
the homeownership option is 365 days.
During these periods, the family will continue to receive HCV rental assistance in accordance with anyapplicable lease
and HAP contract until the family vacates the rental unit for its purchased home.The family will be required to report
their progress on locating and purchasing a home to the PHA every 30 days until the homeis purchased.
All requests for extensions must be submitted in writing to the PHA prior to the expiration of the periodfor which the
extension is being requested.The PHA will approve or disapprove the extension request within10 business days. The
family will be notified of the PHA's decision in writing.
If the family cannot complete the purchase of a unit within the maximum required time frame,and isnot receiving rental
assistance under a HAP contract at the time the search and purchase time period expires,the family will be issued a
voucher to lease a unit.
HOMEOWNERSHIP COUNSELING
Before commencement of homeownership assistance for a family, the family m tend and satisfactorily complete
the pre-assistance homeownership and housing counseling program required by th HUD suggests the following
topics for the PHA-required pre-assistance counseling:
• Home maintenance (including care of the grounds);
• Budgeting and money management;
• Credit counseling;
• How to negotiate the purchase price of a ho e;
• How to obtain homeownership financing and loan pre-approvals, inc a description of types of financingthat
may be available, and the pros and cons of different types offina cing;
• How to find a home, including information about homeownership rtun s,schools, and transportation in the
PHA jurisdiction;
• Advantages of purchasing a home in an area that does not have a high concentration of low-income families and
how to locate homes in such areas;
• Information on fair housing, including fair housing lending and local fair housing enforcement agencies;and
• Information about the Real Estate Settlement Procedures Act(12 U.S.C. 2601 et seq.) (RESPA),state and Federal
truth-in-lending laws, and how to identify and avoid loans with oppressive terms and conditions.
The PHA may adapt the subjects covered in pre-assistance counseling(as listed) to local circumstances and the needs of
individual families.
The PHA may also offer\HUD-ap
ling after co encement of homeownership assistance (ongoingcounseling).
If the PHA offers a progunseling for participants in the homeownership option, the PHA shall have
discretion to determinely is required to participate in the ongoing counseling.
If the PHA does not useousing counseling agency to provide the counseling, the PHA should ensure that
its counseling program he counseling provided under HUD's Housing Counseling program.
A family's participation in the home ownership program is conditioned on the family attending and successfully
completing a home ownership and housing counseling program approved by the PHA prior to commencement of home
ownership assistance.
Page 34 of 69
HOME INSPECTIONS, CONTRACT OF SALE,AND PHA DISAPPROVAL OFSELLER
Home Inspections
The PHA may not commence monthly homeownership assistance payments or provide down payment assistance grants
for a family until the PHA has inspected the unit and has determined that the unit passes HQS.
An independent professional inspector selected by and paid for by the family must also inspect the unit.The
independent inspection must cover major building systems and components, including foundation and structure, housing
interior and exterior,and the roofing, plumbing, electrical, and heating systems.The independent inspector must be
qualified to report on property conditions, including major building systems andcomponents.
The PHA may not require the family to use an independent inspector selected by the PHA. The independent inspector
may not be a PHA employee or contractor, or other person under control of the PHA. However, the PHA may establish
standards for qualification of inspectors selected by families under the homeownership option.
The PHA may disapprove a unit for assistance based on information in the independent inspector's report,even ifthe unit
was found to comply with HQS. 1110
The unit must be inspected by a PHA inspector and pass inspection per tNCityubuque Housing Code. The unit must
be inspected by an independent inspector and incipient code violations identified by theindependent inspector.
To assure the home complies with the City of Dubuque Housing Code, home ownership assistance payments mustnot
commence until the PHA has inspected and approved the home. Another inspection must also b completed bya
professional home inspector selected by the family and approved by the PHA. The independen pection mustcover
major building systems and components, including foundation and structure, housing interior and exterior,andthe
roofing, plumbing, electrical, and heating systems.The independent inspector must be qualified to report on property
conditions, including major building systems. The independent inspector may not be a PHA employee or contractor,or
other person under control of the PHA. The independent inspector must provide a copy of the inspection report both to
the family and to the PHA. The PHA may not pay any Home ownership assistance for the family until the PHAhas reviewed
the inspection report of the independent inspector. Even if the unit otherwise complies with the Cityof Dubuque Housing
Code,the PHA shall have discretion to disapprove the unit for assistance under the Homeownership program because of
information in the inspection report.
Contract of Sale
Before commencement of monthly homeownership assistanc yments or receipt of a down payment assistance grant,a
member or members of the family must enter a contract of sale with the seller of the unit to be acquired bythe family.
The family must give the PHA a copy of the contract o e.The contract of sale must:
• Specify the price and of er terms of sale by the s er to the purchaser;
• Provide that the purch ill arrange for a pre-purchase inspection of the dwelling unit by an independent
inspector selected by the aser;
• Provide that the purchaser is bligated to purchase the unit unless the inspection is satisfactory tothe
purchaser;
• Provide that the purchaser is not o ligated to pay for any necessary repairs;and
• Contain a certification from the seller that the seller has not been debarred, suspended,or subject to a limited
denial of participation under CFR part 24.
Prior to execution of the offer to purchase or sales agreement,the financing terms must be provided by the family to the
City of Dubuque Rehabilitation Activity for approval. The purchase or sales agreement must provide for inspection by the
PHA and the independent inspector and must state that the purchaser is not obligated to purchase unlessthe inspections
are satisfactory to the PHA.The purchase or sales agreement must provide that the purchaser isnot obligated to purchase
if the mortgage financing terms are not approved by the PHA. A copy of the purchase orsales agreement must be
submitted to the City of Dubuque Rehabilitation Activity forapproval.
Page 35 of 69
Disapproval of a Seller
In its administrative discretion,the PHA may deny approval of a seller for the same reasons a PHA may disapprove an
owner under the regular HCV program [see 24 CFR982.306(c)].
FINANCING
The PHA may establish requirements for financing purchase of a home under the homeownership option.Thismay
include requirements concerning qualification of lenders,terms of financing, restrictions concerning debt secured bythe
home, lender qualifications, loan terms, and affordability of the debt. The PHA must establish policies describingthese
requirements in the administrative plan.
A PHA may not require that families acquire financing from one or more specified lenders, thereby restrictingthe family's
ability to secure favorable financing terms.
The proposed financing terms must be submitted to and approved by the City of Dubuque Rehabilitation Activity prior to
close of the financing. The Rehabilitation Activity shall determine the affordability of the family's proposed financing. In
making such determination,the Rehabilitation Activity may consider other family expenses, including butnot limited to
child care, unreimbursed medical expenses, and other outstanding debts. Certain types of financing,including but not
limited to, balloon payment mortgages, are prohibited and will not be approved. Seller-financed mortgages through land
contracts shall not be approved. Seller-financed mortgages through person-to-person mortgages will be considered on a
case by case basis. If a mortgage is not FHA-insured,the PHA will require the lender to complywith generally accepted
mortgage underwriting standards consistent with those of HUD/FHA,Ginnie Mae, Fannie Mae, Freddie Mac, the Federal
Home Loan Bank, or other private lending institutions.The PHA may disapprove proposed financi g, refinancing or other
debit if it is determined that the debt is unaffordable,or if the lender or the loan termsdo not t the qualifications as
set forth by the PHA. The buyer must be capable of providing at least 3%of the purchase price for the down payment.
CONTINUED ASSISTANCE REQUIREMENTS; FAMILY OBLIGATIONS
Homeownership assistance may only be paid while the family is residing in the home. If the family moves out ofthe home,
the PHA may not continue hom wnership assistance after the month when the family moves out.The family or lender is
not required to refund to the P the homeownership assistance for the month when the family movesout.
Before commencement of homeownership assistance, the family must execute a statement in which the family agrees to
comply with all family obligations under the homeowne hipoptio .
The family must comply with the following obligations:
q
• The family must comply with the terms o the mortgage securing debt incurred to purchase the home,or any
refinancing of such debt.
• The family mNeif
nveyor transfer ow hip of the home,except for purposes of financing, refinancing,or
pending settlthe estate of a deceased family member. Use and occupancy of the home are subjectto
24CFR 982.5d (i).
• The family must supply information to the PHA or HUD as specified in 24 CFR 982.551(b).The family must
further supply any information required by the PHA or HUD concerning mortgage financing or refinancing,sale
or transfer of any interest in the home,or homeownership expenses.
• The family must notify the PHA before moving out of the home.
• The family must notify the PHA if the family defaults on the mortgage used to purchase the home.
• No family member may have any ownership interest in any other residential property.
• The family must comply with the obligations of a participant family described in 24 CFR 982.551, except for the
following provisions which do not apply to assistance under the homeownership option: 24 CFR 982.551(c),(d),
(e), (fl, (g) and (j)•
Page 36 of 69
Before each annual recertification during the next two years,the home will be inspected by a PHA inspector per City of
Dubuque Housing Code and must pass inspection to continue receiving home ownership assistance. If the PHA determines
there are problems with maintaining the home in a safe and decent manner,the Housing and Community Development
Director may require on-going inspections annually for the next fiveyears.
A family must agree, in writing,to comply with all family obligations under the HCV Program and the PHA'shome
ownership policies. These obligations include (1) attending ongoing home ownership counseling, if required bythe PHA;
(2) complying with the mortgage terms; (3) not selling or transferring the home to anyone other than a member of the
assisted family who resides in the home while receiving home ownership assistance and whois approved by the PHA; (4)
not refinancing or adding debt secured by the home without prior approval by the PHA;(5) not obtaining a present
ownership interest in another residence while receiving home ownership assistance;(6) supplying all required information
to the PHA, including but not limited to annual verification of household income, notice of change in home ownership
expenses, notice of move-out, and notice of mortgage default; (7)allowing inspections of the home and maintaining the
unit in a decent and safe manner; and (8) repairing any incipientcod iolations identified from the independent
inspector's report within six (6) months of ownership.
MAXIMUM TERM OF HOMEOWNER ASSISTANCE
Except in the case of a family that qualifies as an elderly or disabled family, oth\famimbersdescribed below) shall
not receive homeownership assistance for more than:
• Fifteen years, if the initial mortgage incurred to finance purchase of the h0 years or longer;or
• Ten years, in all other cases.
The maximum term described above applies to any member of the familywho:
• Has an ownership interest in the unit during the time that homeownership payments are made;or
• Is the spouse of any member of the household who has an ownership interest in the unit during thetime
homeownership payments are made.
In the case of an elderly family,the exception only applies if the family qualifies as n elderly family at the start of
homeownership assistance. In the case of a disabled family,the exception applies if at any time during receiptof
homeownership assistance the family qualifies as a disabled family.
If,during homeownership assistance,the family ceases to qualify as a disabled or elderly family,the maximum term
becomes applicable from the date homeownership assistance commenced. However,such a familymust be provided at
least 6 months of homeownership assistance after the maximum term becomes applicable (providedthe family is
otherwise eligible to receive homeownership assistance).
If the family has received such assistance for different homes,or from different PHAs,the total of such assistance terms is
subject to the maximum m described in this part.
HOMEOWNERSHIP ASSI E PAYMENTS AND HOMEOWNERSHIP EXPENSES
The monthly homeownersh istance payment is the lower of: the voucher payment standard minus the total tenant
payment, or the monthly hom nership expenses minus the total tenantpayment.
In determining the amount of the homeownership assistance payment,the PHA will use the same paymentstandard
schedule, payment standard amounts, and subsidy standards as those described elsewhere in this plan for the Housing
Choice Voucher program.The payment standard for a family is the greater of(i)The payment standard as determined at
the commencement of homeownership assistance for occupancy of the home,or (ii)The payment standard at the most
recent regular reexamination of family income and composition since the commencement of homeownershipassistance
for occupancy of the home.
The PHA's housing assistance payment will be paid directly to the lender unless the mortgage company refuses to accept
payments from more than one source. In such case, the PHA's housing assistance payment will be paid directly tothe
family. If the assistance payment exceeds the amount due to the lender,the PHA must pay the excess directly tothe
family.
Homeownership assistance for a family terminates automatically 180 calendar days after the last homeownership
assistance payment on behalf of the family. However, a PHA may grant relief from this requirement in thosecases
Page 37 of 69
where automatic termination would result in extreme hardship for thefamily.
The PHA must adopt policies for determining the amount of homeownership expenses to be allowed by the PHAin
accordance with HUD requirements.
Homeownership expenses (not including cooperatives) only include amounts allowed by the PHA tocover:
• Principal and interest on initial mortgage debt,any refinancing of such debt,and any mortgage insurance premium
incurred to finance purchase of the home;
• Real estate taxes and public assessments on the home;
• Home insurance;
• The PHA allowance for maintenance expenses;
• The PHA allowance for costs of major repairs and replacements;
• The PHA utility allowance for the home;
• Principal and interest on mortgage debt incurred to finance costs for major repairs, replacements orimprovements
for the home. If a member of the family is a person with disabilities,such debt may include debt incurred by the
family to finance costs needed to make the home accessible for such person, if the PHA determines thatallowance
of such costs as homeownership expenses is needed as a reasonable accommodation so that the homeownership
option is readily accessible to and usable by such person;
• Land lease payments where a family does not own fee to the real property,on which the home is located; [see
24 CFR 982.628(b)].
• For a condominium unit, condominium operating charges or maintenance fees assessed by thecondominium
homeowner association.
The amount of the monthly assistance payment will be based on three factors: the voucher paym nt standard forwhich
the family is eligible; the monthly home ownership expense; and the family's household income. The PHA shall paya
monthly Home ownership assistance payment directly to the lender on behalf of the family that is equal to the lowerof:
(1)The payment standard minus the total tenant payment;or
(2)The family's monthly Home ownership expenses minus the total ten*
en payment.
Home ownership expenses for a homeowner may include principal and interest on mortgage debt, anymortgage
insurance premium incurred to finance the home, real estate taxes,any public assessments on the property, home
insurance, PHA allowance for maintenance expenses and costs of repairs and replacements; and the PHAutility
allowance. All participants in the HCV Home Ownership program shall be required to apply for the homesteadtax
exemption.
The PHA will allow IlowinNhome nershipexpenses:
Monthly homeowner ayment.This includes principal and interest on initial mortgage debt, taxesand insurance, and
any mortgage insurance um, if applicable.
Utility allowance.The PHA' ility allowance for the unit, based on the current HCV utility allowance schedule. Monthly
maintenance allowance.The monthly maintenance allowance will be the annual maintenance allowance, divided by
twelve. The annual maintenance allowance will be set at.5 percent of purchase priceof the home.
Monthly major repair/replacement allowance. The monthly major repair/replacement allowance will bethe annual
major repair/replacement allowance diiv ded by 12.The annual major repair/replacement allowance will be set as a
percentage of the purchase price of the home, based on the age of the home at the time of purchase and/or
reexamination.
Monthly co-op/condominium assessments. If applicable, the monthly amount of co-op orcondominium association
operation and maintenance assessments.
Monthly principal and interest on debt for improvements. Principal and interest for major homerepair, replacements,or
improvements, if applicable.
The PHA will provide the lender or Rehabilitation Activity with notice of the amount of the housing assistance payment
prior to close of escrow and will pay PHA's contribution towards the family's homeowner expense directly to thefamily's
designated account for the mortgage activity.The family will be responsible to submit the mortgage payment directly to
the lender in a timely manner to allow the transfer of funds by the lender and/or mortgage servicer and within the terms
Page 38 of 69
of the mortgage loan agreement.
A family's home ownership assistance may be changed during the annual recertification of the household income and at
other times per the PHA's policy of interim changes while the family is participating in the HCV Home Ownership Program.
Participation in the HCV Home Ownership Program shall continue until theassistance payment equals$0.00 for a period
of 180 consecutive days and per the term of the HCV Home Ownership Program.
Homeownership expenses for a cooperative member may only include amounts allowed by the PHA tocover:
• The cooperative charge under the cooperative occupancy agreement including payment for real estate taxesand
public assessments on the home;
• Principal and interest on initial debt incurred to finance purchase of cooperative membership shares and any
refinancing of such debt;
• Home insurance;
• The PHA allowance for maintenance expenses;
• The PHA allowance for costs of major repairs and replacements•
• The PHA utility allowance for the home;and
• Principal and interest on debt incurred to finance major repairs, replacem r improvements for the home. If
member of the family is a person with disabilities,such debt may include deb rred by the family to finance costs
needed to make the home accessible for such person, if the PHA determines that allowance of such costs as
homeownership expenses is needed as a reasonable accommodation so that the homeownership option is readily
accessible to and usable by such person.
• Cooperative operating charges or maintenance fees assessed by the cooperative homeowner association.
MOVING WITH CONTINUED ASSISTANCE
A family receiving homeownership assistance may move with continued tenant-based assistance.The family maymove
with voucher rental assistance or with voucher homeownership assistance. Continued tenant-based assistance for a new
unit cannot begin so long as any family member holds title to the prior home.
The PHA may deny permission to move to a new unit with continued voucher assistance:
• If the PHA has insufficient funding to provide continued assistance.
• In accordance with 24 CFR 982.638, regarding denial or termination of assistance.
• In accordance with the PHA's policy regarding number of moves within a 12-month period.
The PHA must deny the family permission to move to a new unit with continued voucher rental assistanceif:
• The family defaulted on an FHA-insured mortgage;and Re
• The family fails to demonstrate that the family has conveyed,or will convey, title to the home, as required by HUD,
to HUD or HUD's dignee; and the family has moved,or will move, from the home within the period established or
approved by HUD.
Family Self-Sufficiency
Family Self-Sufficiency is a program that enables families through the Housing Choice Voucher(HCV) Program to increase
their earned income and reduce their dependency on welfare assistance and rental subsidies.The Family Self-Sufficiency
(FSS) Coordinators develops local strategies to help Housing Choice Voucher families obtain employment that leads to self-
sufficiency.The FSS Coordinator is responsible for building partnerships with employers and service providers in the
community to help participants obtain jobs and services. Coordinators must ensure that theservices included in contracts
of participation of program participants are provided on a regular,ongoing and satisfactory basis,that participants are
fulfilling their responsibilities under the contracts and that FSS escrow accounts are established and properly maintained
for eligible families. By having a Coordinator whose primary responsibility is to guide andconnect participants to needed
training and resources, FSS participants gain access to the support they need toachieve their self-sufficiency goals and
move up the economic ladder. The US Department of Housing and Urban Development(HUD) provides funding for the
FSS Coordinator positions based on a competitive process each calendar year. HUD awarded the City of Dubuque two (2)
FSS Coordinator positions in the amount of$132,478 for calendar years 2016 and 2017. The FSS Coordinators enable the
Page 39 of 69
program to maintain a minimum of 125 participant families,each with a five-year contract listing their individual goals and
tracking progress.
FSS f4umber in Household
Householtl S¢e Total Famili Reason for Termination #of %
Households
1 27 19.01% Graduated 9 6%
2 40 28.17% Voluntarily 11 8%
3 34 23.94% Other 24 17%
4 18 12.68% Active Participant 98 69%
5 16 11.27% Total: 142 100%
6 5 3.52%
7 2 1.41%
8 or more 0 0.00%
Total Families: 142 100.00% Total %
Families
FSS Foacial Composition of Head of Household
Non Hspanic 140 98.59%
Hispanic 2 1.41%
Primary Race Total Families % Total Families: 142 100.00%
While 57 39.86%
Black/African American 83 58.04%
American Indian/Alaska Native 1 0.70% Type of Employment Total %
Families
Asian 1 0.70% Part-time 40 28.17%
Native How aiian/Other Pacific Islander 1 Full-time 21 14.79%
Total(Non Hisp)Families: 143 100. Unemployed 81 57.04%
Total Families: 142 100.00%
*Total number is greater than the number of participants because 1
participant identified as multiple races.
The average amount of FSS Escrow Earned was$4,009. As of FY 20 a averag nnual earned income at the start of
the FSS Contract was$6,629 and the average earned annual income at FSS completion of Contract was$20,379 (increase
of 207%). The FSS graduates that are still participating in the assisted housing program have increased their earned
income from an average of$4,831 to$12,809. From 1997 to June 30, 2016,one hundred two (102) participants have
successfully completed the FSS Program. Of these 91% have successfully moved off housing assistance.
Substantial Deviation
It is the intent and mission to adher Ngoand objectives outlined in the five-year plan. Any modificationsor
changes to the plan shall seek approvalf m HUD pri to implementation. A substantial deviation does not include any
changes in HUD regulations or notices.
Significant Amend ment/Modificatio n
In June 2013,the PHA was issued a Letter indings of Noncompliance with Title VI of the Civil Rights Act.The PHA has
since entered a Voluntary Compliance Agreement with HUD. HUD Letter of Findings identified:
• April 2008: Hiring of a police o `icer to serve as a Section 8Investigator
• September 2009: Formation of a Safe Community Task Force to address the perception of increased crime in
Dubuque; crime study ordered by the City contracted to Alta Vista Research to focus on the connection between
crime and rental housing, specifically Section 8.
• November 2009: Crime study yielded that"persons arrested for criminal activities in Dubuque are no morelikely
to live in Section 8 Housing"; Administrative plan changed to allow opening and closure of wait list basedon
number of individuals on the list, and to remove the very low income preference point allotment; alsoadopted
stronger eligibility and denial of assistance/termination requirements pertaining to conduct of all membersof
household to include juveniles; wait list was also restricted to only individuals who qualify for one of the local
residency preference points
• December 2009: Voucher issuance freeze in effect
Page 40 of 69
• February 2010: City Council adopted recommendation to reduce vouchers to 900
• November 2009-December 2010: Wait list purge of over 582 families, 66%of which were African American
• June 20-24, 2011: HUD onsite compliance review
• June 17, 2013: HUD issued Letter of Findings of Noncompliance
• April 9, 2014: The City of Dubuque enters Voluntary Compliance Agreement with HUD
By entering the Voluntary Compliance Agreement(VCA), the City has taken measures to ensurecontinued compliance
with its responsibilities under Title VI and its implementing regulations,as well as the City's AFFH obligations and
compliance with PIH Program Requirements. The City has already taken several steps to mediate the effects ofthe
activities,including:
• Local residency preference points were eliminated in December 2012. All local preference points wereremoved
in the proposed Administrative Policy approved by HUD as of February 27,2015,
• Section 8 Investigator is no longer funded through supplemental Administrative Fees.
• The Administrative Plan has been updated/re-written to reflect the ne%ss#amry,changes as outlined in theVCA.
The Administrative Plan was submitted to HUD on December 18, 201 . nts were received from HUD on
February 27, 2015. Additional changes to the Administrative Plan were ted to HUD in March 2015 to
address HAP shortfall funding for CY 2015 and future years based upon HUD Shortfall Team recommendations.
The newly revised Administrative Plan was discussed and reviewed by the Resident Advisory Board on
3/19/2015 and 4/16/2016. HUD granted approval of the Administrative Plan on 4/9/2015.The City of Dubuque
Housing Commission voted to approve and adopt the plan on 4/28/2015. The City Council voted to approveand
adopt the plan on 5/18/2015.
• Revision to the Administrative Plan Chapters 5 (Voucher size) and (Voucher Payment Standards)was
submitted to HUD on September 16, 2015; approved by HUD on October 5, 2015; approved by Housing
Commission on October 27, 2015 and approved by City Council on Noveer 16,2015.
• Revision to the Administrative Plan Chapters 5 (Briefing Attendance), Ch ter 6(Minimum Rent) and Chapterll
(PHA Initiated Interim Reexaminations) was submitted to HUD on December 1, 2015; approved by HUDon
12/10/2015; Approved by Housing Commission on 1/26/2016 and approved by City Council on2/15/2016.
• Revision to the Administrative Plan Chapter 4 Opening/Closing Waiting List and Selection was submitted to HUD
and approved on 7/21/2016; reviewed by RAB on prior to submission to HUD and finalized on 9/15/2016;
approved by the Housing Commission on 9/27/2016 and approved by the City Council on 11/7/2016.
• All HCV bi-annual reports are being submitted to HUD for review per the terms of the VCA.The Cityis working
with HUD to ensure consistency and comprehensive reporting
Page 41 of 69
• 494 applicants were removed from the waiting list between January 1, 2014 and August 29,2014 to increase
voucher lease-up to 927 as of January, 2015. During CY2015,the number of applicants removed from the
waiting list to either be issued vouchers or removed from the waiting list for reasons of non-responseor
ineligibility totaled 451 applications.
• The PHA needs additional funding to allow for lease up to the number of baseline voucher units of 1,063.Our
current lease-up rate is below our funding capacity and efforts to increase leasing began after July 2015.
• The HA surveyed landlords on whether they accept the HCV for their rental units as part of theirrental license
renewal.To increase housing choice,outreach and education will then be targetedtowards the pool of
landlords who do not currently accept HCV.
• All Housing Department, Human Rights Department, Planning and Zoning Department, City Manager's Office
and Police Department staff members, City Council, Housing Comm' ion, Long Range PlanningCommission,
Community Development Advisory Commission members, and t or have received continual civil rights
and housing law training beginning in August 2014.
B.1. c
Deconcentratine Policv
As part of the PHA's strategy to deconcentrate neighborhoods in poverty, HUD h roved exception rents in Census
Tracts 8.01, 8.02, 12.01, 12.02 and 12.03. The Voucher Payment Standards within th ve census tracts will be set at
the 110%of the 50"'percentile published Fair Market Rents and will be adjusted on Ja 1 of each year to maintain
the exception payment standards of the most recent FMR data published.
The PHA has a Project Based Voucher contract with the Rose of Dubuque to provide assisted living units to elderlyand
disabled populations. The Rose of Dubuque is an affordable, assisted living facility for the benefit of low and moderate
income seniors in the Dubuque, Iowa area. The 70-unit building is located at 3390 Lake Ridge Drive, Dubuque,Iowa.
Seventeen of the units are designated as Project-Based Voucher units.The site was selected to promote greater
housing choice opportunities and avoid undue concentration of assisted persons in areas containing a high proportion
of poverty.
The PHA will conduct owner outreach to ensure that owners are familiar with the program and its advantages.The PHA
will actively recruit property owners with property located outside areas of poverty and minority concentration.These
outreach strategies will include: m
Distributing printed material about the program to property owners and managers
Contacting property owners and manage y phone or in-person
Holding owner recruitment/informationgs at least once a year
Participating in community based organi mti comprised of private property and apartment ownersand
managers
Developing working nships with owners and real estate brokers associations
Attending meetings wit representatives of Dubuque Landlord Association
Outreach strategies will be monitored for effectiveness,and adapted accordingly.
Outreach Approach
The Housing and Community Development Department(HCDD) has identified its internal outreach objectivesas
outreach, advancement,and education. We believe that our programs can benefit everyone in our community.
Developing a Voluntary Affirmative Outreach Plan for all housing development, rehabilitation,and
housing-related opportunities funded by the Community Development Block Grant Program
Outlining an outreach program that includes special measures designed to attract those groups
identified as least likely to be reached through our traditional outreach methods, while also expandingefforts
designed to attract persons from the total population.
Recognizing the community members already involved in any of our programs and encouraging them to
utilize all programs and services available.
Page 42 of 69
Creating and distributing materials that educate the community on the various programs we offer,while
clearly conveying the benefits our services will bring to the community.
To effectively achieve our outreach objectives, we have created three outreach messages that we believeare
important in conveying to the public the importance of the HCDD's work to the long-term success of our
community.
Outreach Messages
Supporting all community members and improving quality of life
Providing comprehensive housing services
Creating sustainable housing solutions
Nondiscrimination
The PHA will not discriminate against any applicant, participant or property owner because of race,color,creed,
national or ethnic origin or ancestry, religion, sex, age,disability, sexu*,rientation, gender identity,orfamilial
status; nor will any criteria be applied, nor information be consideredg to attributes or behaviorthat
may be imputed by some to a group or category. All criteria applied aation considered in
administering this plan shall relate to the attributes and behavior of the individual members of the household.
All activities and policies contained in this plan have been created offer greater opportunities for affordable
housing.
The PHA will not use any of these factors to:
• Deny to any family the opportunity to apply for housing, �eny to any qualified applicant theopportunity
to participate in the housing choice voucher program
• Provide housing that is different from that provided to others
• Subject anyone to segregation or disparate treatment
• Restrict anyone's access to any benefit enjoyed by others in connection with the housingprogram
• Treat a person differently in determining eligibility or other requirements foradmission
• Steer an applicant or participant toward or away from an area based any of thesefactors
• Deny anyone access to the same level of services
• Deny anyone the opportunity to participate in a planning or advisory group that is an integral part of the
housing program-N 1�
• Discriminate in the provision of residential real estate transactions
• Discriminate against someone because they are related to or associated with a member of a protected class
• Publish or a to be published an advertisement or notice indicating the availability of housingthat
prefers ore s persons who are members of a protected class
Page 43 of 69
Outreach Method and Rationale
To ensure that information about our programs, specifically the Housing Choice Voucher and
homeownership programs, reaches a sufficient minority population to remedy in measurable ways the
effects of our earlier decisions described in the letter of findings, we will focus on outreach to
communities that are a reasonable distance from Dubuque and that have significant minority
populations. We will conduct outreach within a 200-mile radius of Dubuque, which will enable us to
include portions of Iowa, Illinois, Wisconsin, Minnesota, and Missouri.
At 100 miles from Dubuque,the minority population is 4.6%, at 150 miles the minority population is
6.6%, and at 200 miles the minority population is 11.3%. The following breakdown further explains
outreach strategy and effectiveness.
Population by race/ethnicity 100 mile 0 mile 200 miles
Total population 3,085,57 1231,124 20,026,130
White alone 88.80 82.6 77%
Black alone 6.6% 11.3%
American Indian alone 0. 0. % 00
Asian alone 1.9% 0 3.
Hispanic origin 5.7% 0.8% 12.7%
Some of the race alone 5.3%
Two or more races .0% 2.1 2.1%
Diversity index 4 52.8
<11L
Notes:
• Persons of Hispanic origin may be of any rac
• The diversity index measures the probability that two people from the same area will be from
different race or ethnic groups.
• Source US Census Bureau 2010 sumary file ESRI forecast
This approach helps us to ensure we reach interstate minority populations to remedy previous actions that,as
outlined in the VCA, negatively impacted minority populations. The other reasoning is that a 200-mile radius
reaches an approximately three and a half to four-hour drive,which covers the interstate distances. Wehave
identified eight primary target groups/channels within this 200-mile radius where we will concentrateour
outreach efforts:
1. Public Housing Authorities: We selected public housing authorities (PHA) to provide outreach materials
on our Housing Choice Voucher and homeownership programs because, in most localities,the PHA is thefirst
place that minority communities in need of assistance go to find housing opportunities and assistance. In most
cases,these PHAs also operate the Housing Choice Voucher program or homeownership programs. Wefeel
they are best equipped to provide information on our programs to potential clients who could benefitfrom
housing opportunities in Dubuque.
2. National Association for the Advancement of Colored People (NAACP) Chapters:Traditionally,NAACP
chapters were formed in cities with a population over 30,000 and were designed to protect the civil rightsof
minority populations and to extend to them equal opportunity under the Constitution. Most NAACPchapters
Page 44 of 69
today have consistent outreach programs with their membership and stakeholders that address issues in the
community such as racial discrimination, unfair housing practices,and violations of civil rights. We believe that
NAACP chapters in the 200-mile radius will be an excellent conduit for us to communicate and outreachabout
our housing opportunities and services to the minority populations in their communities.
3. Applicants purged from Dubuque's Housing Choice Voucher Waiting Lists between 2009 and 2011: In its
letterof findings to Dubuque, HUD found that the City's process of purging people from the waiting list resulted
in disparaging impact and kept people out of the program,specifically African-Americans. We contend thatthere
was no such intent with this process; however, we will notify all applicants on the waiting list in Novemberand
December 2009 that our waiting list is open and invite all applicants to apply.This list includes householdsthat
were purged from the waiting list and households that are not currently participating in the Housing Choice
Voucher Program. Adding this activity to the City's proposed activities would potentially reach families, manyof
whom are African American, in the interstate area who previously wanted to live in Dubuque.The PHA has sent
each individual household an invitation encouraging them to reapply and have mailed applications upon
request.
4. National Urban League:The National Urban League was formed in 1968 for the purpose of improving
the economic impact and economic opportunitiefor minority individuals. L' e NAACP and other nonprofits,
they have in place a successful outreach system t communicate with their co uents. Our plan is tosolicit
the National Urban League to assist us in the distribution of information on Dubuque's housing opportunities to
their members and constituents.This information will explain specifically how to apply r the assisted housing
program in Dubuque and will include detailed information about all homeownership opportunities, classeson
improvement of credit and saving money,and information on down payment and closing cost assistancefor
first-time home buyers. Our information al igh 11 iglls the manyin which Dubuque is a good place to live
and raise a family.
5. Social Media (i.e. Facebook and Twitte ocial is and mobs platforms, particularly Facebookand
Twitter, are very effective methods of sharing information and communicating with a variety of audiences,
including the populations we intend to reach through these outreach efforts. Because of the low cost involved it
is an especially popular communication source used by low- to moderate income populations. For thisreason
and the inherent ability to share these messages, we believe social media is an excellent conduit toprovide
information regarding our Housing Choice Voucher and homeownership programs. The City of Dubuque andthe
HCDD both have Facebook pages and the City of Dubuque also manages a Twitter account. Both will continue to
be utilized to help market Dubuque's housing programs to the audiences targeted by this outreach plan.
6. Mobile and Electronic Applications: bile phone and other wireless device applications are an
increasingly inexpensive and immediate way communicating with people. As we communicate withour
current tenants, we are exploring options to allow them to access and share information concerning housing
programs in Dubuque and homeownership opportunities. Additionally,we are expanding our rental assistance
software to allow for the electronic submission of applications for housing programs offered in Dubuque.
7. Language Translation:To insure our products and services are understood by the groupswe are
targeting, we will provide our outreach materials in English, Spanish,and Marshallese. We will makethem
available upon demand and we will also send them to our neighboring PHAs.
8. City of Dubuque Website:The City of Dubuque recently launched a new and improved website with new
navigation and graphic design elements to better convey programs, information,services andemergency
support to our citizens. It is also an educational tool and resource management tool. We will enhancethe
existing information on the website about our Housing and Community Development programs.Theseefforts
will focus on the Housing Choice Voucher application and process as well as detailed information about
Dubuque's home ownership programs. These websites are often visited by minority families and individualsto
learn about what a locality or city has to offer,and we believe could be a beneficial conduit to reach minority
populations.The City website has an electronic translation service called Google Translate so a person doesnot
Page 45 of 69
need to know how to read English to read our website.
The City of Dubuque has an affirmative responsibility to provide persons who are "limited English proficient"
(LEP) equal opportunity for participation in the Assisted Housing Program. If any person is not fluent in English,
the Housing Authority will provide an interpreter or utilize a translation service at no cost to the LEP person.
The Housing Agency will take proactive steps to ensure the LEP person can understand the servicesand benefits
available. The HA will continually assess the language needs of program participants and those persons on the
waiting list to identify the needs of the population being served and resources available. If more than 5%of the
population served or more than 100 persons are in a language group consisting of LEP persons,the HA shall
ensure vital documents are translated into the appropriate language. If less than the percentage or number of
persons served as stated above are in an identified language group,the HA will consider theexpenses of written
translations and implement if financially feasible. However, oral interpretations shall be offeredas stated above.
Case file information noting the language needs of each LEP applicant/participant shall be maintained in each
individual's file.
The PHA will analyze the various kinds of contacts it has wi h the public,to assess language needs anddecide
what reasonable steps should be taken. "Reasonable steps" may not be re\nablee the costs imposed
substantially exceed the benefits.Where feasible,the PHA will train and hire bilingual staff or other known ibe available to actas
interpreters and translators, will pool resources with other PHAs,and will currents.Where
feasible and possible,the PHA will encourage the use of qualified commun
Where LEP persons desire,they will be permitted to use, at their own expense, an interpreter of theirown
choosing, in place of or as a supplement to the free language services offered by the PHA.The interpreter may
be a family member or friend.
The PHA will provide written translations of vital documents Arech eligible LEP language groupthat
constitutes 5 percent or 100 persons,whichever is less, of the population of persons eligible to be servedor
likely to be affected or encountered.Translation of other documents, if needed,can be provided orally; orif
there are fewer than 50 persons in a language group that reaches the 5 percent trigger, the PHA does not
translate vital written materials, but provides written notice in the primary language of the LEP language group
of the right to receive competent oral interpretation of those written materials,free ofcost.
If it is determined that the PHA serves verLEP persons,and the PHA has very limited resources,the PHA
will consider alternative ways to articulate in reasonable manner a plan for providing meaningful access.
Entities having significant contact with LEP persons,such as schools,grassroots and faith-based organizations,
community groups, and groups working with new immigrants will be contacted for input into the process.
If the PHA determines it is appropriate to develop a written LEP plan, the following five steps will be taken:
(1) Identifying LEP individualswho need language assistance; (2) identifying language assistance measures;
(3) training staff, (4) providing notice to LEP persons; and (5) monitoring and updating the LEP plan.
The Violence against Women Act of 2005 (VAWA) and the HUD regulation at 24 CFR 5.2005(b) prohibit PHAs
from denying an applicant admission to the HCV program "on the basis that the applicant is or has been a
victim of domestic violence, dating violence, or stalking, if the applicant otherwise qualifies for assistanceor
admission."
The PHA acknowledges that a victim of domestic violence,dating violence,or stalking may have an
unfavorable history (e.g., a poor credit history, a record of previous damage to an apartment, a prior arrest
record)that would warrant denial under the PHA's policies. Therefore, if the PHA decides to deny assistance
Page 46 of 69
to an applicant family, the PHA will include in its notice of denial the VAWA information as defined by HUD
and will request that an applicant wishing to claim protection under VAWA notify the PHA within 10
business days. If an applicant claims the protection against denial of assistance that VAWA providesto
victims of domestic violence, dating violence,or stalking,the PHA will request in writing that theapplicant
provide documentation supporting the claim. If the perpetrator of the abuse is a member of theapplicant
family,the applicant must provide additional documentation consisting of one of thefollowing:
A signed statement(1) requesting that the perpetrator be removed from the application and (2) certifying
that the perpetrator will not be permitted to visit or to stay as a guest in the assisted unit
Documentation that the perpetrator has successfully completed rehabilitation or treatment: The
documentation must be signed by an employee or agent of a domestic violence service provider or by a
medical or other knowledgeable professional from whom the perpetrator has sought or is receiving
assistance in addressing the abuse. The signer must attest under penalty of perjury to his or her belief that
therehabilitation was successfully completed. The victim and perpetrator must also sign or attest to the
documentation.
The City of Dubuque is committed to promoting fair housing and equal opportunity for families of all race,ethnic
backgrounds, religion, sex,disability, familial status, gender identity and sexual orientation.
It shall be unfair or discriminatory practice for any person to refuse or deny to any person the opportunity to
apply or participate in programs because of race,creed,color, sex, age, national origin, familial status, disability,
marital status, religion,sexual orientation or gender identity. See City of Dubuque Code,Title 8 Human Rights.
The PHA will not discriminate against any applicant, participant or property owner because of race,color,creed,
national or ethnic origin or ancestry, religion, sex, age,disability, sexual orientation, gender identity,or familial
status; nor will any criteria be applied, nor information be considered, pertaining to attributes or behavior that
may be imputed by some to a group or category. All criteria applied and information considered in
administering this plan shall relate to the attributes and behavior of the individual members of the household.
All activities and policies contained in this plan have been created to offer greater opportunities for affordable
housing.
The PHA will not use any of these factors to:
• Deny to any family the opportunity to apply for housing, nor deny to any qualified applicant the opportunity
to participate in the housing choice voucher program
• Provide housing that is different from that provided to others
• Subject anyone to segregation or disparate treatment
• Restrict anyone's access to any benefit enjoyed by others in connection with the housing program
• Treat a person differently in determining eligibility or other requirements for admission
• Steer an applicant or participant toward or away from a particular area based any of these factors
• Deny anyone access to the same level of services
• Deny anyone the opportunity to participate in a planning or advisory group that is an integral part of the
housing program
• Discriminate in the provision of residential real estate transactions
• Discriminate against someone because they are related to or associated with a member of a protected class
• Publish or cause to be published an advertisement or notice indicating the availability of housing that
prefers or excludes persons who are members of a protected class
Page 47 of 69
• Applicants or participants who believe that they have been subject to unlawful discrimination may notify the
PHA either orally or in writing.
• The PHA will attempt to remedy discrimination complaints made against the PHA. The PHA shall not
retaliate against any person who files a complaint.
• The PHA will provide a copy of a discrimination complaint form to the complainant and provide them with
information on how to complete and submit the form to HUD's Office of Fair Housing and Equal Opportunity
(FHEO).
The PHA must ensure that persons with disabilities have full access to the PHA's programs and services. This
responsibility begins with the first contact by an interested family and continues through every aspect of the program.
The City of Dubuque PHA's policy regarding reasonable accommodations is to ensure equal access and participation of
disabled persons in assisted housing programs administered by the City of Dubuque. No qualified individual with a
disability shall, by reason of such disability, be excluded from application, participation or benefits of the assisted
housing programs,or be subjected to discrimination. Documentation regarding the disability will be provided on a
voluntary basis. Refusal to provide information regarding disability will not subject the applicant to adverse treatment;
however, if the disabled person is seeking reasonable accommodation, documentation will be required. All medical
information obtained shall be kept confidential, including information about functional limitations and reasonable
accommodation needs.
Accommodations are not reasonable if they require fundamental alterations in the nature of a program or impose
undue financial and administrative burdens on the PHA. The PHA may not be required to make requested
accommodations if effective alternatives permit full program participation. The purpose of providing reasonable
accommodation is to provide the applicant/participant with a disability the opportunity to meet essential requirements
of the program and an equal opportunity to apply/participate in housing programs through modification of policies,
procedures, or practices. It does not require reducing or waiving essential requirements of program participation nor is
it intended to provide greater program benefits to persons with disabilities than to non-disabled applicants/participants.
To meet the needs of persons with hearing impairments, Relay Iowa services(http://www.relayiowa.com/) will be
available.
To meet the needs of persons with vision impairments, large-print and audio versions of key program documents will be
made available upon request. When visual aids are used in public meetings or presentations,or in meetings with PHA
staff,one-on-one assistance will be provided upon request.
Additional examples of alternative forms of communication are sign language interpretation; having material explained
orally by staff; or having a third-party representative (a friend, relative or advocate, named by the applicant) or another
interpreter hired by the PHA to receive, interpret and explain housing materials and be present at all meetings.
Language for Limited English Proficiency Persons (LEP) can be a barrier to accessing important benefits or services,
understanding and exercising important rights,complying with applicable responsibilities, or understanding other
information provided by the HCV program.
The PHA will take affirmative steps to communicate with people who need services or information in a language other
than English. These persons will be referred to as Persons with Limited English Proficiency (LEP).
LEP is defined as persons who do not speak English as their primary language and who have a limited ability to read,
write, speak or understand English. For the purposes of this administrative plan, LEP persons are HCV applicants and
participants,and parents and family members of applicants and participants.
Page 48 of 69
In order to determine the level of access needed by LEP persons, the PHA will balance the following four factors: (1) the
number or proportion of LEP persons eligible to be served or likely to be encountered by the Housing Choice Voucher
program; (2) the frequency with which LEP persons come into contact with the program; (3) the nature and importance
of the program,activity, or service provided by the program to people's lives; and (4) the resources available to the PHA
and costs. Balancing these four factors will ensure meaningful access by LEP persons to critical services while not
imposing undue burdens on the PHA.
The City of Dubuque has an affirmative responsibility to provide persons who are "limited English proficient" (LEP) equal
opportunity for participation in the Assisted Housing Program. If any person is not fluent in English,the Housing
Authority will provide an interpreter or utilize a translation service at no cost to the LEP person. The Housing Agency will
take proactive steps to ensure the LEP person can understand the services and benefits available. The HA will continually
assess the language needs of program participants and those persons on the waiting list to identify the needs of the
population being served and resources available. If more than 5%of the population served or more than 100 persons
are in a language group consisting of LEP persons,the HA shall ensure vital documents are translated into the
appropriate language. If less than the percentage or number of persons served as stated above are in an identified
language group,the HA will consider the expenses of written translations and implement if financially feasible.
However, oral interpretations shall be offered as stated above. Case file information noting the language needs of each
LEP applicant/participant shall be maintained in each individual's file.
The PHA will analyze the various kinds of contacts it has with the public,to assess language needs and decide what
reasonable steps should be taken. "Reasonable steps" may not be reasonable where the costs imposed substantially
exceed the benefits.
Where feasible,the PHA will train and hire bilingual staff or other known interpreters to be available to act as
interpreters and translators, will pool resources with other PHAs,and will standardize documents. Where feasible and
possible,the PHA will encourage the use of qualified community volunteers.
Where LEP persons desire,they will be permitted to use, at their own expense, an interpreter of their own choosing, in
place of or as a supplement to the free language services offered by the PHA. The interpreter may be a family member
or friend.
The PHA will provide written translations of vital documents for each eligible LEP language group that constitutes 5
percent or 100 persons,whichever is less,of the population of persons eligible to be served or likely to be affected or
encountered. Translation of other documents, if needed,can be provided orally; or
If there are fewer than 50 persons in a language group that reaches the 5 percent trigger,the PHA does not translate
vital written materials, but provides written notice in the primary language of the LEP language group of the right to
receive competent oral interpretation of those written materials, free of cost.
If it is determined that the PHA serves very few LEP persons,and the PHA has very limited resources, the PHA will
consider alternative ways to articulate in a reasonable manner a plan for providing meaningful access. Entities having
significant contact with LEP persons, such as schools, grassroots and faith-based organizations, community groups, and
groups working with new immigrants will be contacted for input into the process.
If the PHA determines it is appropriate to develop a written LEP plan,the following five steps will be taken: (1)
Identifying LEP individuals who need language assistance; (2) identifying language assistance measures; (3) training staff;
(4) providing notice to LEP persons; and (5) monitoring and updating the LEP plan.
The City of Dubuque recognizes the importance of an affirmative fair housing marketing plan designed to
attract all eligible applicants/participants and to affirmatively promote an open and inclusive community. The
PHA is dedicated to creating a model HCV program that offers opportunities for all persons. The PHA is
committed to improving service delivery and outreach efforts.
Page 49 of 69
In creating policy, the PHA has reviewed practices, performed a comprehensive examination of the way
services are delivered and considered the impacts of all marketing and outreach efforts to ensure full
compliance with civil rights laws and to ensure access by all eligible applicants/participants.
The PHA shall make good faith efforts to carry out the Program Outreach and Affirmative Fair Housing Marketing Plan
and Procedures.
The PHA shall identify the segments of the eligible population which are least likely to apply for housing. The PHA has
created an outreach program which includes special measures designed to attract those identified as least likely to apply
and to create opportunities for all. Special outreach efforts include direct marketing to increase participation by
minority populations as identified in the Executive Summary beginning on page 1. Effort will be made to communicate
in writing and/or verbally with contact sources and to develop positive relationships and obtain referrals to attract
targeted groups to diversify the housing community. To track outreach efforts, the application for assisted housing shall
include a question asking the applicant how the applicant became aware of the program and if the applicant is aware of
outreach efforts performed by the City.
HUD Fair Housing Posters or Brochures in English, Spanish and Marshallese shall be available if obtainable from HUD and
displayed for public review at the PHA office. All brochures,signs and posters are an integral part of the affirmative
marketing effort and shall be consistent with Fair Housing Rules and Regulations. The PHA shall make all primary
brochures available in English, Spanish and Marshallese. Primary brochures are brochures provided to the public
advising of program availability, such as, brochures describing eligibility guidelines and application procedures.
The PHA has identified several organizations to intentionally market programs to ensure families are familiar with
opportunities for participation in the HCV programs. Organizations include but are not limited to churches,schools,
clinics, service agencies, hospitals and grocery stores.
The PHA shall also use social media and attend expos/events within the community, and extend marketing to include a
200-mile radius from the City.
PHA staff shall reach out to community contacts to supplement formal communications media for public awareness of
availability of HCV programs.
Outreach to property owners is done through staff attendance at the Dubuque Crime-Free Multi-Housing Program. The
Dubuque Successful Rental Property Management provides property owners comprehensive information on all aspects
of managing rental housing. The program is offered at least twice per year. The presenters include local attorneys and
representatives from the City of Dubuque's Police, Fire, Human Rights, Legal and Housing Departments. Additionally,
staff meets with Landlord Association Board members monthly. Property Owners are encouraged to list available units
with the PHA. The list of available rentals is available to all persons at the City of Dubuque Housing and Community
Development Office and online at www.Cityofdubuque.org/hcv
The PHA utilizes various media for local outreach including City News, a newsletter published and distributed with City
utility bills six times per year that is also available online and at City Hall. The PHA provides outreach including
distribution of the City of Dubuque Housing Commission Agenda to media including the Telegraph Herald, KWWLTV,
KCRG TV, KGAN TV,WDBQ/KLYV/Eagle 102/KIYX radio stations, KAT/KGRR/KDTH/WVRE radio stations,City Channel
Dubuque (local government access television channel), Dubuque Landlord Association,Julien's Journal magazine and the
City's website.
B.4. The most recent audited report approved by HUD is the financial information for the fiscal year ending
06/30/2015. The U.S. Department of Housing and Urban Development's Office of Public and Indian Housing— Real
Estate Assessment Center(PIH-REAC) Public Housing Financial Assessment(FASS-PH)team has reviewed and accepted
the City of Dubuque submission. See Attachment A for Financial Reports. The City has submitted the fiscal year ending
Page 50 of 69
06/30/2016 financial information that is currently being reviewed by HUD. The audited submission will be sent to HUD
by March 31, 2017.
13.5 Progress Report
Goal: Increase homeownership among minority voucher participants and to non-minority voucher participants
In FY 2016 (July 1, 2015 through June 30, 2016), five new households became homeowners with assistance from the
Housing Choice Voucher Program.
Primary Race Total Families %
White 4 80.00%
Black/African American 1 20.00%
American Indian/Alaska Native 0 0.00%
Asian 0 0.00%
Native Hawaiian/Other Pacific Islander 0 0.00%
Total Families: 5 100.00%
City of Dubuque Housing &Community Department offers a Home Ownership Made Easy (HOME) Workshop. This
workshop provides information on City of Dubuque homeownership/rehabilitation programs, budgeting, financing,
maintenance,and energy efficiency of a home. In FY 2016, twenty-one Housing Choice Voucher(HCV) participants
attended this workshop.
Elderly- Non
Non Elderly- Elderly- NonElderly-
imary Rac Disabled Disabled Disabled Non Disabled
Black/African American 0 0 1 5
White 0 2 4 9
Total Families attending HOME
Workshop 21
Page 51 of 69
Goal: To promote fair housing opportunity
June 2015 racial composition of head of household participants for the Housing Choice Voucher Program:
Primary Race Total Families /o
White 552 63.74%
Black/African American 295 34.06%
American Indian/Alaska Native 1 0.12%
Asian 4 0.46%
Native Hawaiian/Other Pacific 14 1.62%
Islander
Total(Non Hisp)Families: 866 100.00%
June 2016 racial composition of head of household participants for the Housing Choice Voucher Program:
Racial Composition of Head of Household
Primary Race Total Families °
White 529 60.46%
Black/African American 326 37.26%
American Indian/Alaska Native 3 0.34%
Asian 4 0.46%
Native Hawaiian/Other Pacific 13 1.49%
Islander
Total(Non Hisp)Families: 875 100.00%
June 2015 head of household status for the Housing Choice Voucher Program:
Head of Household Status
Status Total Members
Non Elderly/Non Disabled 413 41.69%
Elderly/Non-Disabled 73
Non Elderly/Disabled 284 32.79%
Elderly/Disabled 96 11.09%
Total Members: 866 100.00%
June 2016 head of household status for the Housing Choice Voucher Program:
Head of Household Status
Status Total Members %
Non Elderly/Non Disabled 435 49.71%
Elderly/Non-Disabled 70 8.00%
Non Elderly/Disabled 271 30.97%
Elderly/Disabled 99 11.31%
Total Members: 875 100.00%
Page 52 of 69
Goal: Target Available assistance to families at or below 30%of AMI
In Fiscal Year 2016 the percentage of new admissions falling into the Extremely Low Income Category was 84.36%or 178
households with the remaining 15.64%or 33 households falling into the Very Low Income Category. HUD requires that
at least 75%of households admitted into the program during the year be extremely low income. Extremely low income
is defined as a very low-income family whose annual income does not exceed the higher of:
The poverty guidelines established by the Department of Health and Human Services applicable to the family of the size
involved (except in the case of families living in Puerto Rico or any other territory or possession of the United States); or
Thirty (30) percent of the median income for the area, as determined by HUD,with adjustments for smaller and larger
families,except that HUD may establish income ceilings higher or lower than 30 percent of the area median income for
the area if HUD finds that such variations are necessary because of unusually high or low family incomes.
The PHA reserves the right to skip over or re-select applicants through the Lottery system, if the PHA determines that it
is necessary to reach the HUD requirement that at least 75%of households admitted into the program during the year
must be extremely low income.
Goal: Ensure equal opportunity in Housing for all eligible families and affirmatively further fair housing.
As of June 2016, the demographics of households assisted are below:
Participant Statistical Summary Housing Choice Voucher
Effective Date: June 1, 2016
Prepared by: Janet Walker
Date Prepared: 8/12/2016
Number in Household Citizenship Composition of Head of Household
Household Size Total Families % Citizenship Total
Members
1 421 48.11% Ineligible NonCitizen 0.00%
2 171 19.54% Bigible Citizen 872 99.66%
3 123 14.06% Bigible NonOtizen 3 0.34%
4 73 8.34% Total Citizenships: 875 100.00%
5 51 5.83%
6 21 2.40%
7 7 0.80%
8 or more 8 0.91
Total Families: 875 100.00%
Ethnicity Composition of Head of Household
Primary Race(Non Hispanic) Total Families Bhnicity Total
Families
White 529 60.46% Non Hispanic 863 98.630/
Black/African American 326 37.26% Hispanic 12 1.37%
American Indian/Alaska Native 3 0.34% Total Families: 875 100.00%
Asian 4 0.46%
Native Hawaiian/Other Pacific Islander 13 1.49%
Total(Non Hisp)Families: 875 100.00%
Page 53 of 69
Participant Statistical Summary Housing Choice Voucher
Effective Date: June 1, 2016
Household Gross Income
Gross Income Total Farrilies % Number Children Total %
Families
0-4,999 180 20.57% 0 460 52.57%
5,000-9,999 285 32.577 1 153 17.49%
10,000-14,999 208 23.777 2 114 13.03%
15,000-19,999 114 13.037 3 80 9.14%
20,000-24,999 45 5.147 4 36 4.11%
25,000-34,999 40 4.577 5 21 2.40%
35,000-44,999 2 0.237 6 6 0.69%
45,000-999,999 1 0.11% 7 5 0.57%
Total Fam ilies: 875 100.00% Total Fam flies 875 100.00%
Head of Household Status Voucher/Bedroom Size
Status Total Members r Size Total Families
Non E1derlyMon Disabled 435 49.71% 0 5 0.57
8lderlyMon-Disabled 70 8.00% 1 420 48.00%
Non Elderly/Disabled 271 30.97% 2 249 28.46%
Elderly/Disabled 99 11.317 3 162 18.51%
Total Mem bers: 875 100.00% 4 32 3.66%
5 7 0.80%
Total Families: 875 100.00%
Goal: Increase assisted housing choices
Progress/Achievement: The City continues to offer HUD approved exception rent areas to voucher holders, which
allow families to live in higher cost areas to expand choice and deconcentrate poverty. Twice per year,staff present to
area landlords at the Successful Rental Property Management Program aboutthe process and benefits of renting to
voucher holders. Additionally, staff meets with members of the Landlord's Association monthly. The PHA has launched
a new interactive Landlord Portal in January 2015 to make information aboutpayments, inspections,and licensing
more readily available to them. Landlords can also manage their unitvacancy and addtheir units to the Vacant Unit
listing that is made available in the PHA office.The City is currently working to activate an Applicant Portal with a
Participant Portal to follow for ease of use.
Page 54 of 69
As of November 1, 2016, the demographics of households assisted are below:
Participant Statistical Summary Housing Choice Voucher
Effective Date: November 1, 2016
Prepared by: Janet Walker
Date Prepared: 12/12/2016
Number in Household
Total Families Qtizenship Total
Members
1 431 47.16% Ineligible NonCitizen 0 0.00%
2 174 19.04% Bigible Qtiz en 911 99.67%
3 131 14.33% Bigible NonQtizen 3 0.33%
4 87 9.52% Total Citizenships: 914 100.00%
5 56 6.13%
6 21 2.30
7 4 0.44%
8 or more 10 1.09% I
Total Families: 914 100.00%
Racial Composition of Head of Household Ethnicity Composition of Head of Household
Primary Race(Non Hispanic) Total Families % Bhnicity Total
Families
White 517 56.56% Non Hispanic 898 98.25%
Black/African American 376 41.14% Hispanic 16 1.75%
American Indian/Alaska Native 3 0.33% Total Families: 914 100.00%
Asian 4 0.44%
Native Hawaiian/Other Pacific Islander 14 1.53%
Total(Non Hisp)Families: 914 100.00%
Page 55 of 69
Participant Statistical Summary Housing Choice Voucher
Effective Date: November 1,2016
Household Gross Income
� •
Gross Income Total Farrilies % Number Total %
Dependents/Children Families
0-4,999 201 21.99% 0 468 51.20%
5,000-9,999 303 33.15°% 1 164 17.94°%
10,000-14,999 197 21.557 2 120 13.13°%
15,000-19,999 113 12.367 3 86 9.41°%
20,000-24,999 52 5.697 4 45 4.92°%
25,000-34,999 40 4.387 5 19 2.08°%
35,000-44,999 8 0.887 6 5 0.55°%
45,000-999,999 0 0.001% 7 7 0.77°%
Total Fam ilies: 914 100.00% Total Families 914 100.00%
Head of Household Status Voucher/Bedroom Size
Status Total Members Size Total Families
Non E1derlyMon Disabled 467 51.09% 0 0 0.00
8lderly/Non-Disabled 70 7.66°% 1 437 47.81%
Non Elderly/Disabled 273 29.87°% 2 268 29.32°%
Elderly/Disabled 104 11.387 3 171 18.71%
Total Members: 914 100.00% 4 31 3.39°%
5 7 0.77°%
Total Families: 914 100.00%
Page 56 of 69
B.6 Resident Advisory Board (RAB)Comments
Resident Advisory Board Meeting Minutes
2.18.2016
Present: Pattie Breitbach,Janet Veach, Bob Wonne
Staff:Teresa Bassler, Hollie Ohnesorge, Cara O'Keefe
Presenter: None
Introductions
This RAB was an open session. Teresa let the RAB know that the night prior (2/17/16) was the City Council Budget
Presentation and the Housing Department presented.Teresa let them know that one of the council members asked why
the City needs a Housing Department. The RAB had some concern over what would happen to their vouchers,who
would administer the voucher, and what would happen to City of Dubuque Housing Staff. Teresa let them know that
their voucher would continue but rules may change,we would not know who would administer the voucher but that it
would be offered to surrounding Housing Authorities,and we would not know what would happen to our jobs. Teresa
let them know that they could watch the presentation on the City New Channel.
Teresa also informed the RAB that we are now processing income changes when the HOH reports an increase in income
of$200.00 or more. She also reminded them that we will continue to do decreases as soon as the decrease is reported.
Teresa also stated that we did away with the minimum rent change beginning March 1"and we will use 30%of adjusted
annual income or 10%of the annual unadjusted income.The RAB was also informed that there was a change in our late
arrival rules for briefings. We used to only allow 1 minute late and after 1 minute, the person had to leave and come
back another time. Now we are allowing 15 minutes and that person will have to make up the time at the end.
We also asked the RAB if they had any questions or concerns about their rental assistance. They did not. They also did
not provide any suggestions for meeting topics or for food or door prizes. Hollie offered SASC for March for gambling
prevention month but no one seemed interested. Also offered Laura Klavitter to come back to talk about gardening and
they stated they were interested in that. Other topics were cyberbullying, DHS for Medicaid changes, and Iowa Legal Aid
that they were interested in.
We asked if they had suggestions about increasing participation and they thought meeting day and time was fine but
possibly offer up a different time earlier in the day such as a morning meeting with breakfast to accommodate others
who may be working.
Submitted by Hollie Ohnesorge.
Resident Advisory Board Meeting Minutes
3.17.2016
Present: Pattie Breitbach,Janet Veach, Rhonda Latham, Heather Latham, Paula Peil &Jacob Robertson
Staff:Teresa Bassler, Hollie Ohnesorge, Dawn DeMaio,Cate Richter
Presenter: Avis Tripilas, Iowa Department of Human Services- Income Maintenance Supervisor
Introductions
This RAB meeting was to discuss changes in the Medicaid program. Hollie lead the meeting and introduced Avis. Avis
informed everything that the changes to the program will begin April 1' 2016. She advised all in attendance to contact
their current doctors to find out what managed care organization(s) they are going with. Avis brought with her a
Page 57 of 69
handout for everyone and went over important topics and answered questions. She encouraged everyone to read
through it and to use the DHS website as a resource to gain information on changes. She also provided everyone with
her contact information and encouraged people to call her if they have future questions. 563-326-8680 (Davenport
Office) 563-241-0409 (Clinton Office). Once Avis was done speaking and there were no additional questions,the
discussion was turned to the Annual PHA plan.
Teresa started the PHA discussion and passed out the Annual PHA Plan. RAB was informed of the changes in the admin
plan taking place in October of 2015. She let everyone know that there was a change in the setting of the voucher
payment standards and bedroom allowance for families with children of opposite genders. Now,when a child turns 10 if
they are sharing a room with a sibling of opposite gender they are able to get their own room. Additional changes in
the admin plan was approved in February, 2016. Teresa stated that we did away with the minimum rent change
beginning March 1"and we will use 30%of adjusted annual income or 10%of the annual unadjusted income.The RAB
was also informed that there was a change in our late arrival rules for briefings. Applicants attending the briefing were
not allowed to be late. If the applicant showed up late, they would have to reschedule the briefing. Now we are
allowing 15 minutes and that person will have to make up the time at the end. The last change to the admin plan was
income changes would only be processed if the family's income increased by$200.00 or more per month. Teresa also
informed RAB that there is discussion about changing the way people are put on the waiting list and how they are issued
vouchers. She informed them that at the current time they select according to date and time, but there is talk about
changing it to a lottery system.Teresa ask the RAB if they had any questions or concerns about this. Rhonda Latham
asked if there would still be preference given to those with disability first if they do this?Teresa explained that the
preference given to those with disabilities was dropped about 2 years ago and there are currently no preferences
offered. Teresa made note of Rhonda's comment that there should be a priority for those with disabilities so they are
not waiting a long time for housing assistance. Teresa asked if there were any other questions and there were none. RAB
was asked to take the PHA Plan packet with them to review and asked them to bring any questions they may have to the
next meeting. With no other questions or suggestions from RAB the door prizes were handed out and everyone was
reminded to sign in. Meeting was ended at 12:33 pm.
Submitted by Dawn DeMaio.
Resident Advisory Board Meeting Minutes
5.19.2016
Present: Pattie Breitbach,Janet Veach,Teresa Stegall
Staff: Hollie Ohnesorge, Dawn DeMaio,Teresa Bassler
Presenter: Dan Kroger, Recreation Division Manager
Dan Kroger from the Leisure Services Department came to speak today and receive feedback for upcoming Leisure
Service programming. Dan handed each attendant the most recent Leisure Services book. He went through the book
with attendants to show them how to use the book, how to contact staff,and point out areas that may be of interest to
attendees.
New things that Dan shared with the group about Leisure Services:
• Leisure services will be getting a trailer that holds an "Imagination Playground". Leisure services will partner
with the Police Department to shut down certain roads and bring the playground to neighborhoods for the kids
to play with. The playground will allow kids to use their creativity to build various structures or create art to play
with. They will also be at playgrounds.The hope is to not only get kids engaged but to also engage parents who
may offer feedback for Leisure Service Programming.
Page 58 of 69
• In July they will purchase an industrial portable movie screen to have movies in the park or other areas. Other
City Departments will be able to "check out" the screen for their own events.
• A new scholarship program will be introduced. Families will verify income at the beginning of the year and then
will receive a debit card for approximately$150.00 to purchase any Leisure Service activity throughout the year.
If the card gets used up,they will be able to receive another card the following year for$100.00 without having
to fill out paperwork again. Details of this program is being worked out with Erica Haugen with CDBG.
• Leisure Services is going to start new programming for the age group of 40 and above.
Dan was also interested in feedback from the RAB. The RAB stated that they were unaware that Leisure Services had
adult activities and admitted they didn't look at the book before but are now interested.They also suggested
programming for families and children who support more of the working family since all activities are geared towards
the day during the workweek. Dan took notes on all suggestions.
Submitted by Hollie Ohnesorge.
Resident Advisory Board Meeting Minutes
7.21.2016
Present: Pattie Breitbach, Rhonda Latham, Heather Latham, David Hamilton, Aurelia Ellis
Staff: Hollie Ohnesorge, Dawn De Maio,Jessica Kieffer,Tracy Doyle, Ben Pothoff,Alex Rogan
Presenter:Todd Schmidt, Iowa Legal Aid
Todd Schmidt with Iowa Legal Aid presented at the RAB today. He made tenants aware that Iowa Legal Aid represents
clients who would not be able to afford an attorney on certain matters such as landlord/tenant law, child support and
custody/visitation, divorce,applying for social security, disability,etc. When seeking representation,the client must go
through an intake and then the office meets together to see if the case is accepted or not.
Todd had a handout that he gave everyone that has examples of various landlord and tenant laws and scenarios and
went through the scenarios with everyone present in RAB (handout is in the RAB folder for reference).There were
various questions about late fees,evictions,doing improvements,and withholding rent due to tenant improvements.
Todd covered all questions.
Todd gave everyone the contact information for Iowa Legal Aid and expressed that he is not able to give any Legal
Counsel unless an intake is completed and the case is accepted. He also made tenants aware that Iowa Legal Aid cannot
represent the same client on 2 different matters that are happening concurrently.
Submitted by Hollie Ohnesorge.
Page 59 of 69
Resident Advisory Board Meeting Minutes
8.18.2016
Present: Pattie Breitbach, Rhonda Latham, Mariana Miller, David Hamilton, Cierra High,Janet Veach
Staff: Hollie Ohnesorge, Dawn De Maio,Teresa Bassler
Presenter: Ben Pothoff, International Property Maintenance Code
Ben Pothoff presented today to explain to tenants that The City of Dubuque has adopted the International Property
Maintenance Code and highlighted some of the major changes that will take place.
Ben explained that general rental properties are inspected every 5 years,assisted housing properties are inspected
every 2 years although an inspection must be performed prior to the tenant leasing up. Complaint inspections are done
for either general or assisted housing usually within 24 hours of the complaint.
One of the major changes that the IPMC is that"workmanlike repairs" are no longer suitable. Workmanlike repairs are
repairs with no standard of quality. That means that a repair may have been made by anyone without knowledge of how
to make a proper repair and the repair may not correct the problem or will not correct the problem for a long period of
time. The new code means that repairs must be made "in a manner consistent with work done by a skilled craftsman."
Ben also identified the property owner's responsibilities for maintaining units and the tenant's responsibilities for
maintaining units. Ben covered many more examples of"workmanlike" repairs and how they are not suitable. Ben
advised tenants that if it doesn't look right, it probably isn't and let them know that inspectors can come out and look at
it upon request if necessary.
Submitted by Hollie Ohnesorge.
Resident Advisory Board Meeting Minutes
9.15.2016-Revised
Present: Pattie Breitbach
Paula Peil
Ricky Carroll
Staff: Hollie Ohnesorge
Dawn DeMaio
Tonya England
Presenters: Maddy Cairney, Lead Inspector/Risk Assessor, Housing&Community Development Department
Cate Richter,Assisted Housing Specialist for Housing&Community Development Department
Hollie Ohnesorge, Family Self-Sufficiency Coordinator, called the meeting to order and introduced the staff from Housing
&Community Development Department.
Maddy Cairney, Lead Inspector/Risk Assessor, discussed the Lead and Healthy Homes program and how it was started in
the early 1990s. She explained that around 83%of homes in Dubuque were built prior to 1978—which is when
Page 60 of 69
residential paint was not regulated. Over 1,000 have been made lead safe. In November 2015, the program received a
grant for$3.2 million to make 129 homes lead safe by 2018.
Maddy explained that lead had many uses—in medicine, printing, building and paint. When lead is ingested by children
under 6 years old,their bodies absorb 50%while adults only absorb 10%of the lead they ingest. To be eligible for the
program, a person needs to be residing in a home built prior to 1978, have children under 6 years old frequently visiting
or residing in the home at least 10%of the time and be income eligible.
She shared pictures of surfaces with deteriorating lead paint and also demonstrated some of the tools she utilizes during
the inspections.
Cate Richter, Assisted Housing Specialist, presented information on the source of income upcoming meetings. A task
force is actively working on a source of income dialogue with landlords and tenants to gather input for City Council to
consider whether or not Source of Income should be added as a protected class for the City of Dubuque. This will mean
that landlords would have to consider applicants whose source of income may be other than wages; i.e.,social security
benefits, VA pensions, DHS benefits, Housing Choice Voucher benefits. Open dialogue meetings to discuss source of
income are being held on September 21, 2016 at the Multicultural Family Center and on October 4, 2016 at Carnegie
Stout Public Library Auditorium. The meetings are open to everyone—whether or not they are on the Housing Choice
Voucher program.
Richter also presented information regarding changes to the Administrative Plan regarding the waiting list. When HUD
performed an audit several years ago, they had three findings: extremely high preference points for local residents,
which they found had a disparate impact against minorities; reduction of Vouchers from authorized 1,063 baseline
vouchers to 900 vouchers; and the manner in which the waiting list was purged. The City of Dubuque entered into a
Voluntary Compliance Agreement (VCA). Letters were sent out to all applicants that were withdrawn during the purge
and the City invited the applicants to reapply. This group will be offered a chance to receive vouchers once the current
waiting list is exhausted.
The Housing Choice Voucher waiting list was well over 1,000 applicants and the City was still accepting applications. This
meant that applicants would be on the list for a long period of time before being pulled from the list with a waiting
period of over two (2) years so the decision made to close the waiting list was closed. Due to high volumes of
applications being received by other housing authorities (one HA had over 9,000 applications in a one-week period), it
was decided that the City would propose a lottery system
Three (3) waiting lists: Housing Choice Voucher (tenant based), Mod Rehab (14 units-project based), and Project Based
Voucher (17 units in an assisted living facility).
Once waiting list is down to 350 applicants,the list may be opened for a 7-day period. The last day must fall on a
business day.
• Notification must be given at least 10 business days prior to opening the waiting list. The City must
market in a 200-mile radius including large cities and obtain HUD's permission to open the waiting list.
• The City is working to implement an online portal for applications. Paper applications will still be
accepted.
Seven (7) days will be given for applicants to provide information missing on applications. If is not
provided within the timeframe,the applicant will be removed from the lottery system. A computer
generated random draw of 1,000 will be performed for placement on the waiting list. Final applications
will be mailed out once the City is able to pull people from the waiting list. There will be a timeframe for
submitting requested information
Question: Will people on disability be allowed on housing first?
Page 61 of 69
Response: No. There are no preference points for being disable, coming out of foster care or living in Dubuque, nor date
and time of submission of application. Preference will be given for selection if we need to fill a Non-elderly Disabled
(NED)voucher.
Question: Are we allowed to move if we want to move or do we have to wait?
Response: Right now we have no funding issues for unit changes or portability to another housing authority. Once in a
while funding issues arise but we have to obtain permission from HUD before we can place restrictions on those.
Question: Is proper notice still 60 days?
Response: It depends on what is written in the lease. Years ago we use to mandate 60 days but now you just have to
give proper written notice to move, in accordance with your lease, to your landlord with a copy to our office.
Verification of Social Security Number must be provided with the final application when pulled from the waiting list.
Applicants will be given 30 days to provide that documentation while retaining their place on the waiting list. However,
if the applicant has a child under 6 that has been added to household during 6-month period prior to be issued the
voucher, the applicant may become a participant and will have 90 days to provide the documentation.
Our office must prepare several types of reports for HUD that pertain to the waiting lists–applicants not placed of the
waiting list,withdrawn from waiting list, or terminated from program.
We must notify a person within a certain timeframe that they are being placed on the waiting list. There are no changes
to the way Mod Rehab or PBV waiting lists are treated.
She discussed how 75%of participants must be extremely low income. This may also cause preference to be given to
extremely low income applicants in order to meet that requirement. Some other changes made include that we will
request that all adults attend a briefing not require as in the past. Only one (1) adult in the household will be required to
attend the briefing. Also,we will allow persons to arrive at the briefing no more than 15 minutes from the time the
meeting start–no grace period was previously given. They will be required to stay after the briefing is completed to
review any material missed.
Thoughts/Comments on lottery system by RAB members:
Good idea—it took 7 years to obtain housing.
Landlords are not doing their part. I wish there was something that could be done if a landlord is not doing his part. Is
there something that can be done? Individuals with disabilities should have some type of program.
Recorded by
Tonya England
Resident Advisory Board Meeting Minutes
10.20.16
Present: Pattie Breitbach
Rhonda Latham
Staff: Hollie Ohnesorge
Dawn DeMaio
Jessica Kieffer
Tracy Doyle
Presenters: Andrew Houy, Dupaco Branch Manager
Page 62 of 69
Hollie Ohnesorge, Family Self-Sufficiency Coordinator, called the meeting to order and introduced the staff from Housing
&Community Development Department.
Andrew Houy, Dupaco Branch Manager, introduced himself and his co-workers Michelle Becwar and Mallory Blondin
both part of the Dupaco Marketing Department. They informed everyone that today was national Credit Union Day and
they were excited to come speak to the group about banking options and budgeting.
Andrew then address the topic of what the difference was between a credit union and a bank for those who were not
clear. He then elaborated on how credit unions work with their members and they are a non-for-profit cooperative
where as Banks are for-profit.
Andrew then went on to talk with the group about budgeting and asked if any of us in attendance used a working
budget. Rhonda Latham, Hollie Ohnesorge and Jessica Kieffer all stated,yes, that they do. Andrew asked Rhonda to
explain how her budget works and she stated that she is on a fixed income and that she usually does not have much left
over at the end of paying her monthly expenses to save, but she has found ways to cut back on some expenses. She
explained that she found a way to save a little bit of cash by using her free bus card to get to and from places rather than
paying to put gas in her car to get everywhere.
Andrew discussed the biggest issues that people have when it comes to budgeting and that is having an honest
understanding of what is coming in and what is going out. He said to start out it is good to get a print out of 3 months'
worth of bank statements to see what is deposited and what you have been paying out on. He informed the group that
90%of the time the gaps for unaccounted for money is spent on eating out. Andrew elaborated more about how
budgeting is always revolving and it is good to have short term and long term budgets to help with wants and needs.
Andrew also gave the group helpful handouts for budgeting,suggested an app to use on smart phones called Mint,
encouraged the group to start writing down everything they spend their money on and said he would email an excel
spreadsheet he uses for budgeting. Andrew asked if there were any questions anyone had and no one had anything to
ask.
Recorded By:
Dawn DeMaio
Resident Advisory Board Meeting Minutes
11.10.16
Present: Pattie Breitbach, Rhonda Latham, Patrice Green,Janet Veach, Connie Fuerstenberg, Connie's guest who did
not leave a name, Susan Breitbach, Bill Gibbs, Venika Morgan
Staff: Hollie Ohnesorge
Dawn DeMaio
Presenters: Kris Neyen, Rehabilitation Programs Supervisor
Hollie Ohnesorge, Family Self-Sufficiency Coordinator, called the meeting to order and introduced the staff from Housing
&Community Development Department.
Kris Neyen welcomed to the group and began her presentation. Kris explained that the City Housing Department is not
only for rental properties and people who rent, but also for homeowners and those who plan to be homeowners. Kris
explained her Homeownership Workshop, Down payment assistance, rehab properties,and special assistance programs
for current homeowners.
Page 63 of 69
Kris passed out"Yes You Can! A Path to Home Ownership' flyer, Home Ownership Made Easy Workshop flyer, and
current rehab properties for sale flyers (1849 Jackson, 2139 Jackson, 2056 Washington, 1513 Washington, 1656
Jackson). Kris explained to the group how the and why the City obtains property and how down payment assistance can
be used towards these properties or properties that the City does not acquire.
Connie Fuerstenberg asked about credit and getting a bank loan and Kris encouraged her to work with a bank to see
what she could be qualified for and that most financial institutions are willing to assist in helping improve credit if not
already credit worthy.
When the Home Ownership presentation was over, Hollie Ohnesorge notified the RAB that HUD had made some
changes to regulations that prompted us to change some of the language in our Administrative Plan. Hollie passed out a
worksheet highlighting where some of the changes could be found in our Administrative Plan. No one had any
questions,comments,or concerns regarding these changes. Hollie expressed to them that our Administrative Plan can
be found online at www.cityofdubuque.org and encouraged them to look at our Administrative Plan. Hollie also let them
know that if they don't have access to a computer, they may come to the office and look at a hard copy.
Recorded By:
Hollie Ohnesorge
Page 64 of 69
Attachment A: Statement of Financial Resources
City of Dubuque (IA087)
Dubuque, IA
Program Balance Sheet Summary
Submission Type: Audited/A-133 Fiscal Year End: 06/30/2015
14.856 Low er
14.871 Housing Income Housing
Choice Vouchers Assistance Total
Program_Section
8 Moderate
111 Cash - Unrestricted $100,585 $181,277 $281,862
112 Cash - Restricted - Modernization and De\elopment $0
113 Cash -Other Restricted $274,209 $0 $274,209
114 Cash -Tenant Security Deposits $0
115 Cash - Restricted for Payment of Current Liabilities $0
100 Total Cash $374,794 $181,277 $556,071
121 Accounts Receivable - PHA Projects $173 $0 $173
122 Accounts Receivable - HUD Other Projects $30,691 $0 $30,691
124 Accounts Receivable - Other Government $0
125 Accounts Receivable - Miscellaneous $6,492 $0 $6,492
126 Accounts Receivable - Tenants $0
126.1 Allowance for Doubtful Accounts -Tenants $0
126.2 Allowance for Doubtful Accounts -Other $0 $0 $0
127 Notes, Loans, & Mortgages Receivable - Current $0
128 Fraud Reco\ery $58,673 $1,327 $60,000
128.1 Allowance for Doubtful Accounts - Fraud -$17,602 $0 -$17,602
129 Accrued Interest Receivable $720 $0 $720
120 Total Receivables, Net of Allowances for Doubtful Accounts $79,147 $1,327 $80,474
131 Investments - Unrestricted $0
132 Investments - Restricted $0
135 Investments - Restricted for Payment of Current Liability $0
142 Prepaid Expenses and Other Assets $0
143 Inventories $0
143.1 Allowance for Obsolete Inventories $0
144 Inter Program Due From $0
145 Assets Held for Sale $0
150 Total Current Assets $453,941 $182,604 $636,545
Page 65 of 69
290 Total Assets and Deferred Outflow of Resources $453,941 $182,604 $636,545
311 Bank Overdraft $0
312 Accounts Payable <= 90 Days $1,842 $0 $1,842
313 Accounts Payable >90 Days Past Due $0
321 Accrued Wage/Payroll Taxes Payable $2,405 $0 $2,405
322 Accrued Compensated Absences - Current Portion $0
324 Accrued Contingency Liability $0
325 Accrued Interest Payable $0
331 Accounts Payable - HUD PHA Programs $2,499 $2,488 $4,987
332 Account Payable - PHA Projects $0
333 Accounts Payable - Other Government $0
341 Tenant Security Deposits $0
342 Unearned Revenue $0
343 Current Portion of Long-term Debt - Capital $0
344 Current Portion of Long-term Debt - Operating Borrowings $0
345 Other Current Liabilities $0
346 Accrued Liabilities - Other $2,882 $0 $2,882
347 Inter Program - Due To $0
348 Loan Liability -Current $0
310 Total Current Liabilities $9,628 $2,488 $12,116
351 Long-term Debt, Net of Current - Capital Projects/Mortgage $0
352 Long-term Debt, Net of Current - Operating Borrowings $0
353 Non-current Liabilities -Other $113,299 $0 $113,299
354 Accrued Compensated Absences - Non Current $0
355 Loan Liability - Non Current $0
356 FASB 5 Liabilities $0
357 Accrued Pension and OPEB Liabilities $0
350 Total Non-Current Liabilities $113,299 $0 $113,299
300 Total Liabilities $122,927 $2,488 $125,415
400 Deferred Inflow of Resources $0
508.3 Nonspendable Fund Balance $0
509.3 Restricted Fund Balance $160,910 $0 $160,910
510.3 Committed Fund Balance $0
511.3 Assigned Fund Balance $170,104 $180,116 $350,220
512.3 Unassigned Fund Balance $0
513 Total Equity - Net Assets/ Position $331,014 $180,116 $511,130
600 Total Liabilities, Deferred Inflows of Resources and Equity - $453,941 $182,604 $636,545
Page 66 of 69
City of Dubuque (IA087)
Dubuque, IA
Program Revenue and Expense Summary
Submission Audited/A-133 Fiscal Year End: 06/30/2015
Type:
14.856 Low er
14.871 Housing Income Housing
Choice Vouchers Assistance Total
Program_Section
8 Moderate
70300 Net Tenant Rental Revenue $0
70400 Tenant Revenue - Other $0
70500 Total Tenant Revenue $0 $0 $0
70600 HUD PHA Operating Grants $4,763,548 $71,202 $4,834,750
70610 Capital Grants $0
70710 Management Fee $0
70720 Asset Management Fee $0
70730 Book Keeping Fee $0
70740 Front Line SeMce Fee $0
70750 Other Fees $0
70700 Total Fee Revenue $0
70800 Other Government Grants $0
71100 Investment Income- Unrestricted $0
71200 Mortgage Interest Income $0
71300 Proceeds from Disposition of Assets Held for Sale $0
71310 Cost of Sale of Assets $0
71400 Fraud Recovery $17,183 $0 $17,183
71500 Other Revenue $29,323 $0 $29,323
71600 Gain or Loss on Sale of Capital Assets $0
72000 Investment Income- Restricted $0
70000 Total Revenue $4,810,054 $71,202 $4,881,256
91100 Administrative Salaries $526,827 $5,346 $532,173
91200 Auditing Fees $4,150 $0 $4,150
91300 Management Fee $0
91310 Book-keeping Fee $0
91400 Advertising and Marketing $0
91500 Employee Benefit contributions -Administrative $213,656 $2,157 $215,813
91600 Office Expenses $50,337 $495 $50,832
91700 Legal Expense $715 $7 $722
91800 Travel $319 $3 $322
91810 Allocated Overhead $0
91900 Other $13,512 $126 $13,638
91000 Total Operating -Administrative $809,516 $8,134 $817,650
Page 67 of 69
94300 Ordinary Maintenance and Operations Contracts $11,649 $118 $11,767
94500 Employee Benefit Contributions -Ordinary Maintenance $0
94000 Total Maintenance $11,649 $118 $11,767
95100 Protective SeMces - Labor $0
95200 Protective SeMces -Other Contract Costs $0
95300 Protective SeMces -Other $0
95500 Employee Benefit Contributions - Protective SeMces $0
95000 Total Protective SeMces $0 $0 $0
96110 Property Insurance $909 $9 $918
96120 Liability Insurance $7,929 $80 $8,009
96130 Workmen's Compensation $2,224 $22 $2,246
96140 All Other Insurance $0
96100 Total insurance Premiums $11,062 $111 $11,173
96200 Other General Expenses $4,923 $0 $4,923
96210 Compensated Absences $0
96300 Payments in Lieu of Taxes $0
96400 Bad debt -Tenant Rents $0
96500 Bad debt - Mortgages $0
96600 Bad debt -Other $0
96800 Severance Expense $0
96000 Total Other General Expenses $4,923 $0 $4,923
96710 Interest of Mortgage (or Bonds) Payable $0
96720 Interest on Notes Payable (Short and Long Term) $0
96730 Amortization of Bond Issue Costs $0
96700 Total Interest Expense and Amortization Cost $0 $0 $0
96900 Total Operating Expenses $837,150 $8,363 $845,513
Page 68 of 69
97000 Excess of Operating Revenue over Operating Expenses $3,972,904 $62,839 $4,035,743
97100 Extraordinary Maintenance $0
97200 Casualty Losses - Non-capitalized $0
97300 Housing Assistance Payments $4,242,907 $61,912 $4,304,819
97350 HAP Portability-In $13,633 $0 $13,633
97400 Depreciation Expense $0
97500 Fraud Losses $0
97600 Capital Outlays - Governmental Funds $0 $0 $0
97700 Debt Principal Payment - Governmental Funds $0 $0 $0
97800 Dwelling Units Rent Expense $0
90000 Total Expenses $5,093,690 $70,275 $5,163,965
10010 Operating Transfer In $0
10020 Operating transfer Out $0
10030 Operating Transfers from/to Primary Government $351,018 -$8 $351,010
10100 Total Other financing Sources (Uses) $351,018 -$8 $351,010
10000 Excess (Deficiency) of Total Revenue Over (Under) Total $67,382 $919 $68,301
11020 Required Annual Debt Principal Payments $0 $0 $0
11030 Beginning Equity $263,632 $178,515 $442,147
11040 Prior Period Adjustments, Equity Transfers and Correction $682 $682
11050 Changes in Compensated Absence Balance $0 $0 $0
11060 Changes in Contingent Liability Balance $0 $0 $0
11070 Changes in Unrecognized Pension Transition Liability $0 $0 $0
11080 Changes in Special Term/Severance Benefits Liability $0 $0 $0
11090 Changes in Allowance for Doubtful Accounts - Dwelling $0 $0 $0
11100 Changes in Allowance for Doubtful Accounts -Other $0 $0 $0
11170 Administrati e Fee Equity $170,104 $0 $170,104
11180 Housing Assistance Payments Equity $160,910 $0 $160,910
11190 Unit Months Available 12756 168 12924
11210 Number of Unit Months Leased 10518 148 10666
Page 69 of 69