Public Housing Agency (PHA) Annual Plan and Certification of Consistency 2018 Copyrighted
July 2, 2018
City of Dubuque Consent Items # 8.
ITEM TITLE: Annual Public Housing Agency (PHA) Plan
SUMMARY: City Manager recommending approval of the submission of
the Annual Public Housing Agency Plan along with the
Certificate for Consistency with the Consolidated Plan to
the U.S. Department of Housing and Urban Development.
RESOLUTION Authorizing the Mayor to execute the
Certification by State or Local Office of Public Housing
Agency (PHA) Plan is consistent with the Consolidated Plan
and approval of the PHA Annual Plan
SUGGESTED DISPOSITION: Suggested Disposition: Receive and File; Adopt
Resolution(s)
ATTACHMENTS:
Description Type
Submission of Annual Public Housing Agency Plan- City Manager Memo
NNM Memo
Staff Recommendation Staff Memo
Public Housing Authority 2018 Annual Plan Supporting Documentation
Resolution Resolutions
Civil Rights Certification Supporting Documentation
Certification needing Mayor Signature Supporting Documentation
THE CITY OF Dubuque
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Masterpiece on the Mississippi Z°°'�w'2
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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: June 28, 2018
Acting Housing & Community Development Department Director Alexis Steger is
recommending approval of the submission of the Annual Public Housing Agency Plan
along with the Certificate for Consistency with the Consolidated Plan to the U.S.
Department of Housing and Urban Development.
I concur with the recommendation and respectfully request Mayor and City Council
approval.
�� �� ���
Mic ael C. Van Milligen �� �
MCVM:jh
Attachment
cc: Crenna Brumwell, City Attorney
Teri Goodmann, Assistant City Manager
Cori Burbach, Assistant City Manager
Alexis Steger, Acting Housing & Community Development Director
THE CITY OF Dubuque
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@HOME . . � ���
a betrer woy of Irvmg Masterpiece on the Mississippi
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TO: Michael C Van Milligen, City Manager
FROM: Alexis Steger, Acting Housing & Community Development Director
DATE: June 18, 2018
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, May 22, 2018. The PHA Resident Advisory Board has also
reviewed the PHA Plan and all comments and minutes from their meeting is included in
the plan.
RECOMMENDATION
I respectfully request approval to submit the Annual PHA Plan along with the
Certification for Consistency with the Consolidated Plan.
Dubuque@Home is an initiative of the City of Dubuque Housing& Community Development Department
350 W. 6�'St.,Dubuque,Iowa 52001 I Phone: 563.589.4230 I www.citvofdubuaue.ore/dubuaueathome
EMAIL: tbassler@cityofdubuque.org I FAX: 563-690-6697
PUBLIC N01'ICE
The City of Dubuque Housing antl Community Developmst Depvtmst has published a Frst Natt of[he Public
HousingAgencyAnnualPlanforfiscalyear2018_ ThePlanisa ailableforreviewatMeHousingffiCD
Departmenq 350 W est 6'h StreeG Sui[e 312�Dubuque�IA 52001 Montlay—Fntlay, 8 00 AM—5 00 PM antl at
urvwo_cityoftlubuquaorg/atlminplart
A public hearing on[hePlan will be heltl at[he Housing Commission MeeGing on Tuestlay, May 22, 201$ at4 00
p rrt in Me Housing ffi CD Department o�ce I�[aes[etl persons are inviGd W appear anNor pmvitle comrt�ent W
Me Comrt�ission on[he pmposetl Plart
Atltlitional infortnation may be obfametl by calling Me Housing ffi CD Department at 589-4230_
�
Paee 1 of 64
RESOLUTION NO. 203-18
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 2nd day of July, 2018.
Attest:
Kewih S. FirnstaKiI, CiClerk
/-Roy D Buol, Mayor
Certification by State or Local
Official of PHA Plans Consistency
with the Consolidated Plan or
State Consolidated Plan
(All PHAs)
U. S Department of Housing and Urban Development
Office of Public and Indian Housing
OMB No. 2577-0226
Expires 2/29/2016
Certification by State or Local Official of PHA Plans
Consistency with the Consolidated Plan or State Consolidated Plan
I, Roy D Buol
Official's Name
, the City of Dubuque Mayor
Official's Title
certify that the 5 -Year PHA Plan and/or Annual PHA Plan of the
City of Dubuque IA087
PHA Name
is consistent with the Consolidated Plan or State Consolidated Plan and the Analysis of
Impediments (AI) to Fair Housing Choice of the
City of Dubuque
Local Jurisdiction Name
pursuant to 24 CFR Part 91.
Provide a description of how the PHA Plan is consistent with the Consolidated Plan or State
Consolidated Plan and the AI.
The City of Dubuque PHA Plan and the Consolidated Plan track the number of units per census tract and
track the location of affordable housing and type. The activities and goals include actions the City will take
to integrate affordable housing that is fully available without regard to race, ethnicity, religion, national origin,
sex, disability, familial status, gender or sexual orientation. Both plans include specific goals to expand
opportunities for Section 8 applicants and participants, including strategies to increase affordability.
I hereby certify that all the information stated herein, as well as any information provided in the accompaniment herewith, is true and accurate. Warning: HUD wilt
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
Title
City of Dubuque Mayor
Signature
Date
-ily/‘
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
Office of Public and Indian Housing Expires: 02/29/2016
(Standard PHAs and
Troubled PHAs
Purpose. The 5-Year and Mnual PHA Plans provide a ready source for interes[ed parties to locate basic PHA policies,mles,and requiremen[s concerning[he PHA's
operations,programs,and services,and infortns HUD,families served by[he PHA,and members of[he public of[he PHA's missioq goals and objectives for serving[he
needs of low-income,very low-income,and exVemely low-income families.
Applicability. Form HUD-50075-ST is W be completed annually by STANDARD PHAs or TROUBLED PHAs. PHAs that meet the defirution of a
High Performer PHA, Small PHA,HCV-Only PHA or Qualified PHA do not need to submit this form.
Definitions.
�1� High-PerforneerPHA—A PHA that owns or manages more than 550 combined public housing units and housing choice vouchers,andwas designated as a
high perfortner on both of the most recent Public Housing Assessment System(PHAS)and Section EightManagement Assessment Program(SEMAP)
assessmen[s 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 ofbeing designated as troubled,that owns or manages less than 250 public
housing units and any number of vouchers where[he total combined units exceeds 550.
�3� Honsing Chaice Voncker(HCI� On1y PHA-A PHA that administers more than 550 HCVs,was not designated as troubled in its mostrecent SEMAP
assessment and does not own or manage public housing.
�4� Standa�dPHA-A PHA that owns or manages 250 or more public housing units and any number of vouchers where the total combined units exceeds SSQ
and thatwas designated as a standard performer in the most recentPHAS or SEMAP assessments.
�5� TroubledPHA-A PHA that achieves an overall PHAS or SEMAP score of less than 60 percent.
�6� QuNifiedPHA-A PHAwith 550 or fewer public housing dwelling units and/or housing choice vouchers combined,and is not PHAS or SEMAP troubled.
A. PHA Information.
A1 PHA Name: Citv of Dubuque PHA Code: IA087
PHA Type: �Standard PHA ❑Troubled PHA
PHA Plan for Fiscal Year Beginning: (MM/YYYI�:_07/2018
PHA Inventory(Based on Mnual Contributions Contract(ACG�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: �Mnual Submission ❑Revised Mnual Submission
Availability of Informatioa PHAs musthave the elements listed below in sections B and C readily available W the public. A PHA must identify
the specific location(s)where the proposed PHA Plan,PHA Plan Elements,and all information relevant W the public hearing and proposed PHA
Plan are available for inspection by the public. At a minimum,PHAs must postPHA Plans,including updates,at each Asset ManagementProject
(AMP)and main office or central office of the PHA. PHAs are strongly encouraged W post complete PHA Plans on their official website. PHAs
are also encouraged to provide each resident council a copy of[heir PHA Plans.
❑PHA Consortia: (Checkbox if submittin a Joint PHA Plan and com lete table below)
Participating PHAs PHA Code Program(s)in the Consortia
Program(s)not in the No.of Units in Each Program
Consortia pH HCV
Lead PHA:
Page 2 of 64
B. Annual Plan Elements
B1 Revision of PHA Plan Elements.
(a) Have the following PHA Plan elements been revised by the PHA7
Y N
� ❑ Statement of Housing Needs and SVategy for Addressing Housing Needs
� ❑ Deconcentration and Other Policies that Govern Eligibility,Selectioq and Admissions.
❑ ❑ Financial Resources.
� ❑ RentDetertnination.
❑ � Operation and Management.
❑ � Grievance Procedures.
❑ � Homeownership Programs.
❑ � Community Service and Self-Sufficiency Programs.
❑ ❑ Safety and Crime Prevention.
❑ ❑ PetPolicy.
❑ ❑ AssetManagement.
❑ � SubstantialDeviation.
❑ � SignificantAmendmenUModification
(b) If the PHA answered yes for any element,describe the revisions for each revised element(s): See B.1 below
(c) The PHA must submit its Deconcentration Policy for Field Office review.See B1(c)below
B2 New Activities
(a) Does the PHA intend W undertake any new activities related W the following in the PHA's cmrentFiscal Year7
Y N
❑ � Hope VI or Choice Neighborhoods.
❑ � Mixed Finance Modemization or Development.
❑ � Demolitionand/orDisposition.
❑ � Designated Housing for Elderly and/or Disabled Families.
❑ � Conversion of Public Housing W Tenant-Based Assistance.
❑ � Conversion of Public Housing to Project-Based Assistance under RAD.
❑ � Occupancy by Over-Income Families.
❑ � OccupancybyPoliceOfficers.
❑ � Non-Smoking Policies.
❑ � Project-BasedVouchers.
❑ � Units with Approved Vacancies for Modernization.
❑ � Other Capital GrantPrograms(i.e.,Capital Fund Community Facilities Grants or Emergency Safety and Security Grants).
(b)If any of these activities are planned for the cmrent Fiscal Year,describe the activities. For new demolition activities,describe any public
housing development or portion[hereof,owned by[he PHA for which[he PHA has applied or will apply for demolition and/or disposition approval
under section 18 of the 1937 Act under the separate demolition/disposition approval process.If using Project-Based Vouchers(PBVs),provide the
projected number of projectbased units and general locations,and describe how projectbasing would be consistentwith the PHA Plan.
B.3 Civil Rights Cutification.
Fortn HUD-50077,PHA Cerfificotions of Complionce with the PHA Plons ond Reloted Regulotions,must be submitted by the PHA as an electronic
attachment W the PHA Plan. See Attached document
B.4 Most Recent NSscal Year Audit.
(a) Were there any findings in the most recent FY Audit7
Y N
❑ �
(b) Ifyes,please describe:
Page 3 of 64
B.5 ProgressReport
Provide a description of[he PHA's progress in meeting its Mission and Goals described in[he PHA 5-Year and Mnual Plan.
B.6 Resident Advisory Board(RAB)Comments.
(a) Did the RAB(s)provide comments W the PHA PIan7
Y N
� ❑
(c) Ifyes,comments must be submitted by the PHA as an attachmentto the PHA Plan. PHAs must also include a na�rative describing their
analysis of[he RAB recommendations and[he decisions made on[hese recommendations.
B�� Certification by Stateor I,ocal O�cials.
Fortn HUD 50077-SL Certlficotion by Stote or Locol Officiols of PHA Plons Consistency with the Consolidoted Plon,must be submitted by the
PHA as an electronic attachment W the PHA Plan.
B.8 Troubled PHA.
(a) Does the PHA have any cwrent Memorandum of Agreement,Perfortnance Improvement Plan,or Recovery Plan in place7
Y N N/A
❑ � ❑
(b) Ifyes,please describe:
C, Statement of Capital Improvements. Required for all PHAs completing this form that administer public housing
and receive funding from the Capital Fund Program (CFP).
C1 Capital Improvements.Include a reference here W the most recent HUD-approved 5-Year Action Plan(H[JD-500752)and the date that itwas
approved by HUD.
Page 4 of 64
Instructions for Preparation of Form HUD-50075-ST
Annual PHA Plan for Standard and Troubled PHAs
A. PHA Informatioa All PHAs must complete this section.
A1 Include the full PHA Name,PHA Code,PHA Type,PHA Fiscal Year Beginning(MM/YYPY),PHA Inventory,Number of Public Housing Units and or
Housing Choice Vouchers(HCVs),PHA Plan Submission Type,and the Availability of Informatioq specific location(s)of all infortnation relevant W the
public hearing andproposedPHAPIan.(7A CFR&90323(4)(ep
PHA Consortia:Check box if submitting a JointPHA Plan and complete the table.(24 CFR&943.128(aN
B. Annual Plaa All PHAs must complete this section.
B1 Revision of PHA Plan Elements.PHAs must
Identify specificallywhich 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."(7A CFR&903.7)
� Statement of Housing Needs and Strate�y for Addressing Housing Needs. Provide a statement addressing the housing needs of low-income,very low-
income and exVemely low-income families and a brief description of[he PHA's sVategy for addressing[he housing needs of families who reside in[he
jurisdiction served by the PHA.The statement must identify the housing needs of(i)families with incomes below 30 percent of area median income(extremely
low-income),(ii)elderly families and families with disabilities,and(iii)households of various races and ethnic groups residing in the jurisdiction or on the
waiting list based on information provided by the applicable Consolidated Plan,infortnation provided by HUD,and other generally available data. The
identification of housing needs must address issues of affordability,supply,quality,accessibility,size of units,and locatioa(7A CFR&903J(a)(1)) Provide a
description of[he PHA's sVategy for addressing[he housing needs of families in[he jurisdiction and on[he waiting lis[in[he upcoming year. 24 CFR
&903J(a)(2)(iiN
� Deconcentration and Other Policies that Govern Eligibility,Selection,and Admissions. PHAs must submit a Deconcentration Policy for Field Office
review. For additional guidance on what a PHA must do W deconcentrate pover[y in its development and comply with fair housing requirements,see 7A CFR
9032.(7A CFR&90323(bl)Describe the PHA's admissions policy for deconcentration of poverty and income mixing of loweo-income families in public
housing. The DeconcenVation Policy mus[describe[he PHA's policy for bringing higher income tenan[s into lower income developmen[s and lower income
tenants into higher income developments. The deconcentration requirements apply to general occupancy and family public housing developments. Refer W 7A
CFR§9032(b)(2)for developments not subjectto deconcentration of pover[y and income mixing requirements (7A CFR&903J(bN Describe the PHA's
procedures for maintain waiting lists for admission W public housing and address any site-basedwaiting lists.(7A CFR&903J(bl).A statement of the PHA's
policies that govern resident or tenant eligibility,selection and admission including admission preferences for both public housing and HCV. 7A CFR
903J Describe the unit assignmentpolicies for public housing. (7A CFR&903J(bN
❑ 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 tenantrents and other income available W support public housing or
tenant-based assis[ance. The statement also should include[he non-Federal sources of funds supporting each Federal program,and s[ate[he planned use for[he
resources(7A CFR&903J(c))
� Rent Determinatioa A statement ofthe 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 J(d))
❑ Operation and Management A statement of the rules,standards,and policies of the PHA goveming maintenance and management of housing owned,
assisted,or operated by the public housing agency(which shall include measures necessary for the prevention or eradication of pest infestatioq including
cockroaches),and management of the PHA and programs of the PHA(7A CFR&903J(eN
❑ Grievance Procedures. A description of the grievance and informal hearing and review procedures that the PHA makes available W its residents and
applicants.(7A CFR&903J(fl)
� Homeownership Programs. A description of any Section Sh,Section 32,Section 8y,or HOPE I public housing or Housing Choice Voucher(HC�
homeownership programs(including project number and unit count)administered by the agency or for which the PHA has applied orwill apply for approvaL 7A
CFR&903J(kN
� Community Service and Self Su�ciency Programs. Describe how the PHA will comply with the requirements of community service and treatrnent of
income changes resulting from welfare program requirements. (24 CFR&903 J(Il)A description of: 1)My programs relating to services and amenities
provided or offered to assisted families;and 2)My policies or programs of[he PHA for[he enhancement of[he economic and social self-sufficiency of assisted
families,including programs under Section 3 and FSS (7A CFR&903J(D)
� Safety and Crime Preventioa Describe the PHA's plan for safety and crime prevention W ensure the safety of the public housing residents. The statement
must provide development-by-development orjurisdiction wide-basis: (i)A description of the need for measures W ensure the safety of public housing residents;
(ii)A desaiption of any crime prevention activities conducted or W be conducted by the PHA;and(iii)A description of the coordination between the PHA and
the appropriate police precincts for ca�rying out crime prevention measures and activities(7A CFR&903J(mN A description of: 1)My 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 domes[ic violence,dating
violence,sexual assault,or stalking;2)My 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,W obtain or maintain housing;and 3)My activities,services,or programs provided or offered by a public
Page 5 of 64
housing agency W prevent domestic violence,dating violence,sexual assault,and stalking,or W enhance victim safety in assisted families. 7A CFR
&903J(ml(SN
❑ Pet Policy. Desaibe the PHA's policies and requirements pertaining W the ownership of pets in public housing.(7A CFR&903J(nl)
❑ Asset Management State how the agency will carry out its asset managementfunctions with respect W the public housing invenWry of the agency,
including how the agency will plan for the long-tertn operating,capital investrnent,rehabilitatioq modernizatioq dispositioq and other needs for such invenWry.
(7A CFR&903J(qN
❑ Substantial Deviatioa PHA must provide its criteria for determining a"substantial deviation"W its 5-Year Plan. (7A CFR&903J(rl(21(ill
❑ Significant AmendmenVModification. PHA must provide its criteria for determining a"Significant Amendment or Modification"to its 5-Year and Mnual
Plan. Should the PHA fail W define`significant amendmenUmodification',HUD will consider the following W be`significant amendments or modifications': a)
changes W rent or admissions policies or organization ofthe waiting list;b)additions of non-emergency CFP work items(items not included in the cmrent CFP
Annual Statement or CFP 5-Year Action Plan)or change in use ofreplacementreserve funds under the Capital Fund;or c)any change with regard to demolition
or dispositioq designatioq homeownership programs or conversion activities. See guidance on HUD's website at:Notice PIH 1999-51. 7A CFR
&903J(d(21(iill
If any boxes are marked"yes",describe the revision(s)W those element(s)in the space provided.
B.2 New Activities. If the PHA intends W undertake any new activities related to these elements in the current Fiscal Year,mark"yes"for those elements,and
describe the activities W be undertaken in the space provided.If the PHA does not plan W undertake these activities,mark"no"
❑ Hope VI or Choice Neighborhoods. 1)A description of any housing(including projectnumber(if Imown)and unit count)for which the PHAwill 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/proerams/ph/hope6/index.cfrn. (Notice PIH
2010-30
❑ Mixed NSnance Modernization or Development. 1)A description of any housing(including project number(if Imown)and unit count)forwhich 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
htto://www.hud.eov/offices/pih(proerams/ph/hope6/index.cfrn. (NoticePIH2O10301
❑ Demolition and/or Dispositioa Describe any public housing projects owned by the PHA and subject W ACCs(including projectnumber 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 cwrently pending for
demolition or dispositioq and(2)A timetable for the demolition or dispositioa This statement must be submitted W the extent that approved and/or pending
demolition and/or disposition has changed as described in[he PHA's last Mnual and/or 5-Year PHA Plan submission. The application and approval process for
demolition and/or disposition is a separate process. See guidance on HUD's website at http://www.hud.eov/offices�pih/centers�sac/demo dispo/index.dm. 24
CFR&903J(hN
❑ Designated Housing for Elderly and Disabled Families.Describe any public housing projects owned,assisted or operated by the PHA(or portions
thereo�,in the upcoming fiscal year,that the PHA has continually operated as,has designated,or will apply for designation for occupancy by elderly and/or
disabled families only. Include the following informatio¢ 1)development name and number;2)designation type;3)application status;4)date the designation
was approved,submitted,or planned for submissioq and;5)the number of units affected. Note: The application and approval process for such designations is
separate from the PHA Plan process,and PHA Plan approval does not constitute HUD approval of any designatioa(7A CFR&903J(i)(C))
❑ Conversion of Public Housing. Describe any public housing building(s)(including projectnumber and unit count)owned by the PHA that the PHA is
required W convert or plans to voluntarily convertto tenant-based assistance;2)M analysis of the projects or buildings required W be converted;and 3)A
s[atement of[he amount of assistance received to be used for rental assis[ance or other housing assis[ance in conneRion with such conversion. See guidance on
HUD'swebsite at http://www.hud.eov/offices/pih/centers/sac/conversioacfm. (7A CFR&903J(iN
❑ Conversion of Public Housing. Describe any public housing building(s)(including projectnumber and unit count)owned by the PHA that the PHA plans
to voluntarily convertto project-based assistance under RAD. See additional guidance on HUD's website at:Notice PIH 2O1232
❑ Occupancy by Over-Income Families. A PHA that owns or operates fewer than[wo hundred fifty(250)public housing units,may lease a unit in a public
housing developmentto an oveo-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 PHAwaiting list or applying for public housing assistance when the
unit is leased W an oveo-income family;(2)The PHA has publicized availability of the unit for rental W 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 W an oveo-income family;(3)The
oveo-income family rents the unit on a month-W-month basis for a rent that is not less than the PHA's cost W operate the unit;(4)The lease W the oveo-income
family provides that the family agrees W vacate the unitwhen needed for rental to an eligible family;and(5)The PHA gives the oveo-income family at least
thir[y days notice W vacate the unitwhen the unit is needed for rental W an eligible family. The PHA may incoiporate infortnation on occupancy by oveo-income
families inW its PHA Plan statement of deconcentration and other policies that govem eligibility,selectioq and admissions. See additional guidance on HUD's
website at: Notice PIH 2O11-Z(7A CFR 960.503) (24 CFR 903J(b))
❑ Occupancy by Police Officers. The PHA may allow police officers who would not otherwise be eligible for occupancy in public housing,to reside in a
public housing dwelling unit The PHA must include the number and location of the units W be occupied by police officers,and the terms and conditions of their
tenancies;and a statement that such occupancy is needed W increase security for public housing residents. A"police office2'means a person detertnined by the
PHA to be,during[he period of residence of[hat person in public housing,employed on a ful4time basis as a duly licensed professional police officer by a
Federal,State or local government or by any agency of[hese govemmen[s. M officer of an accredited police force of a housing agency may qualify. The PHA
may incoiporate infortnation on occupancy by police officers into its PHA Plan statement of deconcentration and other policies that govern eligibility,selectioq
and admissions. See additional guidance on HUD's website at: Notice PIH 2O11-Z(7A CFR 960.505)(7A CFR 903J(b))
Page 6 of 64
❑ Noo-Smoldng Policies.The PHA may implement non-smoking policies in its public housing program and incoiporate this inW its PHA Plan statement of
operation and management and the rules and standards thatwill apply W its projects. See additional guidance on HUD's website at:Notice PIH 2O09-21. 7A
CFR&903 J(e))
❑ Project Based Vouchers. Describe any plans W use Housing Choice V ouchers(HCVs)for new project-based vouchers,which must complywith PBV
goals,civil rights requirements,Housing Quality Standards(HQS)and deconcentration standards,as stated in 983.57(b)(1)and set forth in the PHA Plan
statement of deconcentration and other policies that govern eligibility,selectioq and admissions. If using project-based vouchers,provide the projected number
ofproject-basedunitsandgenerallocations,anddescribehowproject-basingwouldbeconsistentwiththePHAPIan. (7ACFR&903J(bN
❑ Units with Approved Vacancies for Modernizatioa The PHA must include a statementrelated to units with approved vacancies that are undergoing
modemization in accordance with 7A CFR&990.145(a)(1).
❑ Other Capital Grant Programs(i.e.,Capital Fund Community Facilities Grants or Emergency Safety and Security Grants).
For all activities thatthe PHA plans to undertake in the cmrentFiscal Year,provide a description of the activity in the space provided.
B.3 Civil Rights Certificatioa Form HUD-50077,PHA Cerfificotions of Complionce with the PHA Plons ond Reloted Regulotion,must be submitted by the PHA
as an electronic attachment W the PHA Plan. This includes all certifications relating to Civil Rights and related regulations. A PHAwill be considered in
compliance with the AFFH Certification if:it can documentthat it examines its programs and proposed programs W identify any impediments W fair housing
choice within[hose programs;addresses[hose impedimen[s in a reasonable fashion in view of[he resources available;works with[he local jurisdiction to
implement any ofthejurisdiction's initiatives to affirmatively further fair housing;and assures that the annual plan is consistentwith any applicable
Consolidated Plan for itsjurisdictioa(7A CFR&903J(oN
B.4 Most Recent NSscal Year Audit. If the results of the most recentfiscal year auditfor the PHA included any findings,mark"yes"and describe those findings in
the space provided (7A CFR&903J(pN
B.5 Progress Report For all Mnual 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.(7A CFR&903J(rl(1N
B.6 Resident Advisory Board(RAB)comments.If the RAB provided comments W the annual plan,mark"yes,"submit the comments as an attachmentto the Plan
and describe the analysis of the comments and the PHA's decision made on these recommendations.(7A CFR&903.13(c),24 CFR&903.19)
B9 Certification by State of Local Officials. Fortn HUD-50077-SL,Certlficotion by Stote or Locol Officiols of PHA Plons Consistency with the Consolidoted
Plon,mustbe submitted by the PHA as an electronic attachment W the PHA Plan.(7A CFR&903.15). Note: A PHA may request W change its fiscal year W
better coordinate its planning with planning done under the Consolidated Plan process by State or local officials as applicable.
B.8 'It�oubled PHA. If the PHA is designated troubled,and has a cmrent MOA,improvement plan,or recovery plan in place,mark"yes,"and desaibe thatplan.If
the PHA is troubled,but does not have any of these items,mark"no"If the PHA is not troubled,mark`N/A"(7A CFR&903.9)
C. Statement of Capital Improvements.PHAs that receive funding from the Capital Fund Program(CFP)must complete this sectioa(7A CFR 903J(e))
C1 Capital Improvements. In order W comply with this requirement,the PHA mustreference the most recent HUD approved Capital Fund 5 Year Action Plan.
PHAs can reference[he fortn by including[he following language in SeRion C.8.0 of[he PHA Plan Template:"See HUD Form-500752 approved by HUD
on�L/XX/X;��°,
This
informatlon collectlon is authorized by Section 511 of the Q�li[y Housing and WorkResponsibility Act which added a new sectlon SA ro the O.S.Housing Act of 1937,as amended,which
innoduced[he 5-Year and Annual PHA Plan.
Public reporting burden for this informatlon collectlon is estimated m average 9.2 hours per response,induding thetimefor reviewing insnuctlons,searching eYisting data sources,
gathering and maintaining the data needed,and completing and reviewing the collection of informatloa HUD may not collect this informatioq and respondents are not required m
completethis form,unless it displays a current4yvalid OMB Connol Number.
PrivacyActNotice. TheUnitedStatesDepartmenrofHousingandUrbanDevelopmentisauthorizedmsoliuttheinformatlonrequestedinthisformbyvir[ueofTiHe12,U.S.Code,
Section 1701 et seq,and regulations promulgated thereunder at TiHe 12,Code of Pederal Regulatlons. Responses ro the collection of informatlon are required m obtain a benefit or m
retainabenefit Theinformatlonrequesteddoesnotlenditselfmconfidentiali[y.
Page 7 of 64
a
Annual Plan Elements
B.1.
(b) If the PHA answered yes for any element, describe the revisions for each revised element(s):
Statement of Housing Needs and Strategy for Addressing Housing Needs:
Needs Assessment Overview(Consolidated Plan)
The City of Dubuque worked with John Marshall Law School and Cappell Statistical Consulting in theconsolidated
planning process to determine the varying needs within the City for affordable housing, community development and
homelessness. The 2015 Analysis of Impediments to Fair Housing identifies needs and actions the City uses to
Affirmatively Further Fair Housing. The City of Dubuque Five-year Consolidated Plan and the Analysis of Impediments
are tools the City uses to identify and assess housing and community needs, primarily for low and moderate income
residents and geographic areas. The Housing Market Analysis in the Consolidated plan describes the supply, demand,
conditions and cost of housing for families and households. The needs of renters, homeowners, homeless, elderly,
non-majority populations, and those living with disabilities are identified and assessed. The City Council adopted a
Citizen Participation Plan that outlines a process for the public to provide input, evaluate, and make recommendation
to administrative plans, policies, procedures, and federally funded activities. Citizens can contribute comment through
public meetings, surveys, verbal or written comments, boards and commissions, and through various community
outreach events. The City and HUD entered a Voluntary Compliance Agreement(VCA) in March 2014 to correct
findings identified in a Civil Rights monitoring conducted in 2011. The monitoring resulted in a finding that the City
violated Title VI of the Civil Rights Act in the administration of the Section 8 program. The VCA outlines specific steps
the City must take to comply with federal regulations and Civil Rights law.
Summary of Housing Needs (Consolidated Plan)
The population of Dubuque has remained relatively consistent, decreasing slightly from 57,696 in 2000 to 57,679 in
2011.The number of households increased by 5%, from 22,612 to 23,719 in the same time period. According to the
2007-2011 CHAS Data, Dubuque had 2,585, or 11% of households with between 0-30% HUD Area Median Family Income
(HAMFI or AMI); 3,465 households, 15% of the total households in the City were earning greater than 30-50%AMI; and,
5,395 households, or 23%were households in the income range of 51-80% AMI. Overall, 11,445 households in the City
were at or below 80%of AMI, or 48%of the total households in the City.
A total of 9,325 households were Small Family Households (2-4 persons per households). Of those, 34%are at or below
80% 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% AMI 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%
Page 8 of 64
of households 31-50%AMI are cost burdened; and 98% of households experiencing problems at 51-80% AMI are cost
burdened. The City will begin preparation of an updated Analysis of Impediments in 2018.
Section 504 Needs Assessment: Describe the needs of public housing tenants and applicants on the waiting list
for accessible units:
The city of Dubuque does not administer any public housing. Affordable housing is provided through the Housing Choice
Voucher Program, Moderate Rehabilitation Program, Project Based Vouchers, and the Continuum of Care Special Needs
Assistance Program.The needs of Housing Choice Voucher applicants on the waiting list include affordable housing.
Most applicants are cost burdened prior to admission and do not have sufficient income to pay fair market rent. In
addition to affordable housing, many on the program are unemployed or underemployed, disabled, elderly, or
otherwise unable to obtain employment at a level that allows for self-sufficiency. Upwards of 48% of head of households
are elderly and/or living with a disability.
The City administers a Family Self-Sufficiency Program. The Family Self-Sufficiency Program had 125 active participants in
the City's fiscal year 2017. Participants work on a variety of self-determined goals aimed at developing the skills and
resources needed to obtain employment earning a living wage. The City employs two Family Self-Sufficiency caseworkers
that provide coordination of services for participants to identify and reach employment, family, education, and financial
goals. FSS caseworkers also manage the participants Housing Assistance casefiles, assisting with income verifications,
interim and annual exams, portability, and end of participation events.
As of FYE 2017, 68 FSS participating households were earning escrow, 7 participants completed their contracts, and 2
completed their contracts and moved into homeownership. Fifty-four percent of participants earned escrow in 2017.
Participants earn escrow when they increase employment income enough to raise the portion of rent they are responsible
to pay for their housing. The Family Self-Sufficiency Program is an incredible wealth-building resource for Assisted Housing
participants. One FSS participant completed their contract earning$20,792 in escrow, setting a record for earned escrow to
date for the Dubuque PHA. In FY 2016, five voucher participants transitioned into homeownership. In FY 2017, four
participants moved into homeownership. In the previous three years combined, a total of four voucher households moved
to homeownership. The increase in voucher participants transitioning to homeownership can be directly linked to
additional coordination between the FSS, Circles, and Rehabilitation programs offered through the Housing Department.
The Rehabilitation Supervisor joined the Circles community as an ally for lower-income people working to buy their first
home. The connection to direct financial resources and housing counseling offered through Circles and Rehabilitation
Services has allowed more FSS and lower income households access to real wealth-building opportunities through
affordable homeownership options.
As of December 31, 2017, the overwhelming majority (86%) of those on the waiting list are extremely low income and 66%
are families with children. Sixty-four percent (56%) of those on the waiting list are Black/African American, followed by 42%
White, 1.5% Asian, 0.8% Native Hawaiian/Other Pacific Islander, and 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 supports conclusions in the Analysis of Impediments to Fair Housing that African American/Black households
are more likely to experience housing problems, including cost burden, compared to the jurisdiction as a whole. Education,
job readiness skills, living-wage employment, and quality affordable housing are high needs for the waiting list population.
Approximately 9.8% of those waiting for housing assistance are families with disabilities and 5.3% are elderly.
Strategies developed by the City to address corrective actions identified by HUD in the Voluntary Compliance Agreement
and by the revisions of the Administrative Plan address the following needs:
1. A Strategy to increase Housing opportunities throughout Dubuque which takes into account the needs of
minority populations;
2. A Strategy to provide affordable housing that is fully available without regard to race or ethnicity throughout all
the communities within Dubuque to create equal housing opportunities; and
3. A strategy to take affirmative steps to provide opportunities for desegregation of areas of racial and ethnic
Page 9 of 64
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 Ieast 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 10 of 64
Housing Needs of Families on the Section 8 Tenant-Based Assistance WaitingList
In Apri12015, 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 January 1, 2018, The Waiting List
consisted of:
City of Dubuque Housing & Community Development
350 W 6th Stseet#312 Dubuque, IA 52001
January 1, 2018 Waiting List Statistical Summary
By:Tonya Englantl As of 12/31/1711:59 pm
Waiting Lst Section 8 HCV
Race Tafel Percent W�tingLsk Sectim8HCV
American Indian/Alaska Native Percent that are Handicapped or Disabled: 9.85%
Asian 2 1.52% TotalNumberofHandicappedorDisabled: 13
NativeHawaiian/OtherPac�icIslander 1 OJ@'/o TotalNumberofApplicantsListed: 132
Black/Afiican American 74 56.0@'/0
WhRe 55 41.6A/o NurrberOverLrtnitforLowIncome: 0
Total 132 Nurrber Qualitying for Low Income: 0
Number Qualitying for Very Low Income: 18
Number Qualifying for FxRremely Low Income: 114
FmrrilyCompositim Tafel Percent PercentQualityingforLowlncome: 0.00%
FAdedy 7 530'/o PercentQualityingforVeryLowlncome: 13.6{%
Disabled 13 9.85% PercentQualityingforFxirerrelyLowIncorre: 863@'/0
Srt�gle 25 1&J4%
Farrtily 87 65.91%
Total 132
Fllinicity Tafel Percent
HispanicorIatino 3 22A/o
NotHispanicorIatino 179 97J3%
Total 132
WaitingLst A�rageDays W�tingLst A�rage A�rage
Waiting (�asslncune Adjustedlnwme
A�rages for Section 8 HCV: 1,00215 HCV Pwge WL $11,003.88 $11,003.�
MadRehab $$10336 $6,874.18
ProjectBasedVauchers $7,�9.63 $4,J45.87
Sectim8HCV $$7%7.19 $8,257.19
A�rages fa�NI W�ting Iists: $8,821.02 $7,77798
Page 11 of 64
January 1, 2018 Waiting List Statistical Summary
WaitingLst: HCVPurgeWL
Race Tafel Percent
Americanlndian/AlaskaNative W�tingLsk HCVPwgeWL
As ian Percent that are Handicapped or Disabled: 17.65%
Native Hawaiian/Other Pacdic Is lander Total Number ofHandicapped or Dis ab led: 3
Black/AfiicanAmerican 9 52J4% TotalNumberofApplicantsListed: 17
WhRe 8 47.0@'/0
Total 17 Nurrber Over Lrtnit for Low Income: 0
Number Qualitying for Low Income: 0
Number Qualitying for Very Low Income: 3
Number Qualifying for FxRremely Low Income: 14
FmrrilyCompositim Tafel Percent
FAdedy 1 5.85% PercentQualityingforLowlncome: 0.00%
Disabled 3 17.65% PercentQualityingforVeryLowlncorre: 17.65%
Srt�gle 3 17.65% PercentQualityingforFWremelyLowIncome: 8235%
Farrtily 10 5&82%
Total 17
Fllinicity Tafel Percent
Hispanic orIatino 1 5.85%
NotHispanicorIatino 16 J4.12%
Total 17
Page 12 of 64
January 1, 2018 Waiting List Statistical Summary
WaitingLst: ModRehab W�tingLsk ProjectBasedVouchers
Race Tafel Percent Race Tafel Percent
WhRe 141 35.1@'/o White 65 27JS%
Asian 1 0.25% Asian
NativeHawaiian/OtherPac�icIslander 6 1.50'/o NativeHawaiian/OFherPacificIslander 1 0.43%
Americanlndian/AlaskaNative 4 1.00'/o ArrericanIndian/AlaskaNative 4 1J1%
Black/Afiican American 7A9 6209% BIacWAfrican Arrerican 16{ 70.09%
Total 401 Total 244
FmrrilyCompositim Tafel Percent FarttilyCompasition TafelPercent
�a�ry iz z9mi nae�ry � z.9�i
Disabled 67 16J1% Disabled 31 13.25%
Srt�gle 117 79.15% Single 86 36J5%
Farrtily 7A5 51.12% Farrrily 110 47.01%
Total 401 Total 244
Fllinicity Tafel Percent Ftlinicity Tafel Percent
HispanicorIatino 10 249% HispanicorLatrt�o 6 2.56%
NotHispanicorIatino 391 97.51% NotHispanicorIatino 228 97.44%
Total 401 Total 244
WaitingLst: ModRehab W�tingLsk ProjectBasedVouchers
PercentthatareHandicapped orDisabled: 16J1% PercentthatareHandicapped orDisabled: 13.25%
TotalNurrberofHandicapped or Disabled: 67 TotalNumber ofHandicapped orDisabled: 31
TotalNurrberofApplicants Listed: 401 TotalNumber ofApplicants Listed: 234
Nurrb er Over Lirrrit for Low Income: 0 Nurrber Over Lrtnit for Low Income: 0
Nurrber Qualdying forLow Income: 3 Nurrber Qualitying forLowlncome: 6
Nurrber Qualdying for Very LowIncome: 45 Nurrber Qualitying for Very Lowlncome: 7A
Nurrb er Qualdying for FWremely Low Income: 353 Nurrber Qualitying for FWremely Low Income: 201
Percent Qualitying for Low Income: OJS% Percent Qualitying for Low Income: 2.56%
Percent Qualitying for Uery Low Income: 11.22% Percent Qualitying for Very Low Income: 10.2@'/0
Percent Qualitying for FWremely Low Income: 8&03% Percent Qualitying for FWremely Low Income: 87.15%
Page 13 of 64
In January 2010, a voucher freeze was put in place by the City Council reducing the number of vouchers to900
participant families. Due to this reduction in vouchers, a Civil Rights Compliance Review was carried out by HU D in June
2011 resulting in a Letter of Findings on June 17, 2013 and subsequent Voluntary Compliance Agreement in March 2014.
The City of Dubuque is committed to the fai-and equitable operation of its programs and acknowledges the actionstaken
negatively impacted African American program applicants. The City implementing and working to complete corrective
actions through compliance with the VCA. This VCA is intentionally designed to achieve and continue compliance with
the City's responsibilities underTitle VI of the Civil Rights Act and the City's obligation to affirmatively furthering fair
housing obligations. All residency preference point allotments and local preference points based on residencywere
removed on December4, 2012.The City has amended the administrative plan to include an on-line portal to receive
applications and a lottery system to place applicants on the waiting list.
As of December 31, 2017, 833 Vouchers are utilized. The City of Dubuque has worked to maintain minimum of 95% of
Housing Assistance Payments Expenditure and seeks to utilize maximum funding to assist as many households as
allowed bythe HAPfunding.
The administrative plan was amended in 2016 and 2017. The amended administrative plan streamlines the portability
process, which allows vouchers to be used anywhere in the United States. Streamlining for verification of household
assets under$5,000 was also implemented. Changes to Chapter 11 of the plan allow for interim changes to occur only
when new members are added to the household or if the household income decreases. Increases in income will be
process during the annual re-examination. Language was adopted to better conform with the Code of Federal
Regulations in multiple sections, the administrative plan was adopted. The most substantial change is to streamline the
admission process in a fair, nondiscriminatory manner, we will be issuing vouchers based on a lottery system. We believe
that the lottery system will increase the chancesof issuing vouchers at a faster pace and result in a higher leasing rate.
Voucher Issuance isa top priority to increase utilization and is focused on effective management of staff time and
priorities to meetthese goals.
Housing Needs and Strategies to Address Housing Needs:
1. Need: Shortage of affordable housing for all eligible populations
Strate�v#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 broadercommunity
strategies
• Support programs through the City of Dubuque Rehabilitation activities and continue Housing Choice
Voucher Homeownership program. All HCV participants desiring to enroll in the Homeownership Made
Easyclasses attend free of charge.
• Any change in lease up rates that would result in a decrease in the number of vouchers utilized mustbe
proposed and approved by HUD
Strategv#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
Page 14 of 64
participants in the program. The review team collected demographic data on Housing Choice Voucher program
participants, including wait list information, applicant resolution information, and voucher utilization. The team further
collected and reviewed information available through public record, including city meeting minutes, committee meeting
minutes, and newspaper articles. Finally, the team collected policies, plans, and reports such as the City's Consolidated
Plan and the PHA's wait list admission policies.
As a result of the compliance review, HUD issued a Letter of Findings (LOF) on June 17, 2013. The LOF alleged that the
PHA discriminated against African Americans based on race by taking the actions of freezing voucher issuance,
establishing local residency preference points, eliminating the very-low income preference, and purging the wait list.
The City denies discriminating against African American applicants to the program. However, the City had agreed to
enter into a Voluntary Compliance Agreement to ensure continued compliance with its responsibilities underTitle VI
and its implementing regulations, as well as the City's AFFH obligations and compliance with the PIH Program
Requirements.
• Take actions to meet the provisions detailed within the Voluntary Compliance Agreement.
2. Need: Specific FamilyTypes: Families at or below 30% of inedian
Strate�v:Target available assistance to families at or below 30%ofAMl
• Encourage enrollment in FSS to support and encourage work
• Provide listings of available Mod Rehab
3. Need: Specific FamilyTypes: Families at or below 50% of inedian
Strate�v:Target available assistance to families at or below 50%ofAMl
• Encourage enrollment in FSS to support and encourage work
• Provide listings of available Mod Rehab units
4. Need: Specific FamilyTypes:The Elderly
Strate�v#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 elderly apartments/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 FamilyTypes: Families with Disabilities
Strate�v#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
6. Need: Specific Family Types: Races or ethnicities with disproportionate housing needs
Strategv#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
Page 15 of 64
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
Strate�v#2: Conduct activities to affirmatively further fairhousing
• Counsel Housing Choice Voucher tenants as to location of units outside of areas of poverty or minority
concentration andassist them to locate those units
• Market the Housing Choice Voucher program to owners outside of areas of poverty/minorityconcentrations
• Participate and encourage training of staff and landlords in Fair Housing Laws
• Participate and encourage training of tenants in Fair Housing rights
Reasons for Selecting Strategies: list all that influenced the PHA's selection of the strategies it will pursue:
• The need to address and correct the allegations and findings contained in the LOF.
• Funding constraints
• Staffing constraints
• Extent to which housing needs are met by other organizations in the community
• Evidence of housing needs as demonstrated in the Consolidated Plan and other information available to the PHA
• Influence of the housing market on PHA programs
• Community priorities regarding housing assistance
• Results of consultation with local or state government, with residents and the Resident Advisory Board, and with
advocacy groups
• Results of a Fair Housing Planning Guide for the City of Dubuque
• Discussions with the City's Housing Commission
• Feedback from the community
On March 31, 2014, the City of Dubuque, lowa and the U.S. Department of Housing and Urban Development (HUD) entered
a Voluntary Compliance Agreement outlining remedies to address the findings of noncompliance identified in HUD's letter
to the City dated June 17, 2013. In its letter of findings to the City, HU D found that the City's process of purging applicants
from the waiting list resulted in disparaging impact and kept people out of the program, specifically African-Americans. The
City contends there was no such intent with this process; however, did agree to notify all applicants on the waiting list in
November and December 2009 to invite all applicants to apply. On April 9, 2015 HUD granted permission to close the HCV
waiting list effective April 30, 2015. The waiting list was reopened February 14, 2018. The HCV Purge waiting list had 17
households as of December 31, 2017, and the HCV waiting list has 132 participants as of the same date.
Program Specific Waiting List
The City of Dubuque shall maintain waiting lists forthe Moderate Rehabilitation Program;the Project Based Voucher Program
and the Housing Choice Voucher Program.
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.
Proiect-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
Page 16 of 64
a condition of occupancy, the Owner or its designated service provider shall evaluate the proposed applicanYs status to
determine the qualification for residency of the assisted living facility. When vacancies occur in the project-based voucher
program, the City refers income eligible families for participation in the project-based voucher program from its waiting list
to the owner. The owner selects a family for occupancy of a unit after screening the family. Once the owner selects a
family and notifies the City, the City shall determine final eligibility based upon the same criteria for eligibility as the
Housing Choice Voucher program.
Housing Choice Voucher Program Waiting Listlsl:
The City of Dubuque shall open another Housing Choice Voucher waiting list once the most current HCV waiting list consists
of 350 applications. The City began preparations to open the list as we approached this number; however, the list was not
opened until after the number of participants on the waiting list was below the 350 application target. The current waiting
list will be completely exhausted prior to selecting applicants from the new waiting list. The new HCV waiting list will
remain open to accept applications for seven (7) calendar days with the end date of the application period falling on a
business day. Interested individuals/families will be required to complete a written pre-application form for admission and
placement on the waiting list. Applications submitted online shall be considered written applications. The City of Dubuque
will use the pre-application form to collect only the information necessary to make a preliminary determination of
eligibility.
A lottery system will be used to determine which applicants are placed on the new waiting list once the waiting list is
closed. Using the lottery system, one thousand (1,000) applicants will be selected to be placed on the waiting list. Only the
head of household should apply. Duplicate applications will not be allowed. Each household has an equal chance of being
selected. All applications not selected during the Lottery Selection process to be placed on the waiting list will be tracked
on a bi-annual report per guidelines for reporting in the Voluntary Compliance Agreement with HUD. Applicants that are
not selected to be placed on the waiting list will need to re-apply to the waiting list the next time new applications are
accepted and the waiting list is open.
It is the City of Dubuque's intent to utilize each HCV waiting list established through the lottery system as described above by
opening and closing the waiting list as needed. Each time the currently used HCV waiting list is reduced to 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 HU D to notify them of the status of the waiting list.
The family will be required to provide all the information necessary to establish final family eligibility and level of assistance
when the family is selected from the waiting list.
When the waiting list is open, individuals/families may obtain pre-application forms from the PHA's office during normal
business hours or may complete online applications at the City of Dubuque website at
www.cityofdubuque.apply4housing.com. Applicants may also request—by telephone, mail or e-mail—an application be
sent to them via first class mail or FAX or e-mail.
Applications must be received during the time the waiting list is open to the public. For applications received by mail, the
received date shall be determined by the date the application has been post marked. For applications received by Fax or e-
mail, the received date shall be determined by the date the FAX or the e-mail is received by the City of Dubuque. The City
of Dubuque shall open the waiting list for seven (7) calendar days with the last day of acceptance on a business day to allow
applicants the opportunity to contact the City of Dubuque Housing Authority staff if the applicant has questions.
If the pre-application is incomplete, the PHA will notify the family of the additional information required. HA staff will make
reasonable efforts to contact the applicant and inform him/her of the additional information required and provide the
applicant 7 calendar days to correct the deficiency. Reasonable efforts shall be in the form of one letter or, if no address is
provided, one telephone call or e-mail. If the HA staff is unable to contact the applicant, the application will be removed
from the lottery selection process or if the applicant is contacted and fails to respond within the time specified or any
Page 17 of 64
extensions of time, the applicant will be removed from the lottery selection process. A record of those efforts shall be
maintained with the application.
Final 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 or the e-mail is received by the City of
Dubuque. Applications must be complete to be accepted by the PHA for processing. An application shall only be considered
complete if accompanied by proof of identity; copy of SSN; citizenship, eligible immigration status or non-contending
declaration; and all mandatory release forms along with a completed application. The final "Application" form must be
filled out and must not contain any blanks or unanswered questions.
All applications must be accompanied by proof of identity from a third party for all household members. Acceptable forms
shall include birth certificates; current driver's license; identification card issued by a federal, state, or local agency;
identification card issued by a medical insurance company or provider(including Medicare and Medicaid); or Court records.
All applications must be accompanied by copies of social security cards of all household members.
If the applicant is unable to provide documentation/verification of the SSN but is otherwise determined eligible, the
applicant may retain the applicanYs place on the waiting list for the program but cannot become a participant until the
applicant provides the required verification. The applicant will be provided 30 days to obtain the required verification while
retaining the applicanYs place on the waiting list.
However, if a child under the age of 6 years was added to the applicant household within the 6-month period prior to the
household's date of voucher issuance, the applicant may become a participant, so long as the documentation/verification is
provided within 90 calendar days from the date of admission to the program. One additional 90-day extension period will
be granted if the PHA determines that the 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
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
Page 18 of 64
Order of Selection
If the available Voucher is designated as a special purpose Voucher allocated for disabled families such as NED (Non-Elderly
Disabled), applicants qualifying for the special purpose Voucher will be selected by a computer-generated Lottery system.
Other applicants that do not qualify for the special purpose Voucher will not be selected to receive the Voucher. Special
purpose Vouchers identified as Tenant Protection shall be per the HUD contract (Example: Opt-Out or Mod Rehab
participants converting to the Voucher program.)
Documentation will be maintained by the PHA as to whether families on the list qualify for and are interested in special
purpose vouchers. If a higher placed family on the waiting list is not qualified for the special purpose voucher, there will be
a notation maintained so that the PHA does not have to ask higher placed families each time targeted selections are made.
Financial Resources
The HU D Calendar Year 2017 Renewal Funding for the Housing Choice Voucher Program allocated $5,010,907 for housing
assistance payments. HUD granted $133,507 for two Family Self-Sufficiency Coordinators during calendar year 2017.
Operation and Mana¢ement
Records Management
Per HUD requirements within 180 days of the effective date of the Voluntary Compliance Agreement (VCA) (March
31, 2014), the City shall develop and submit the following report to the Department for review and approval:
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) applicanY s name, race, sex, ethnicity, familial/
elderly or disability status; 2) date of application; 3) date applicant placed on waiting list;4) applicant
preference(s); 5) date and time of offer; 6) date of lease; and 7) date applicant removed from waiting
list and justification.
b. The Bi-Annual Report shall also track all families denied admission to the program, all applicants
determined to be ineligible due to criminal background, and all determinations to terminate
participation in the Assisted Housing Programs. The reports shall include race, national origin, address,
age of applicants, familial status and disability. The reports shall include the specific activity or
occurrence identified by the PHA in making the determination to deny admission to the program or to
terminate participation, how the PHA learned of the activity or occurrence, and what if any, alternate
option or information was provided to the family at the time of denial or termination. All
determinations of ineligibility due to Criminal Background shall include a copy of the denial or
termination notice along with the reports or other information provided to the family at the time of
denial or termination.
c. The City shall continue to submit a BWLR every six months for the duration of the VCA. Submissions of
the BW LR 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.
Page 19 of 64
f. The City shall maintain all participant files, including applications for residency, rental agreements or
leases, notices and letters to residents, and notices of termination, along with all material relating to
the City's implementation of the Title VI, Section109, and AFFH requirements of this Agreement.
g. The City shall maintain all material relating to the racial composition of its HCDD operated Programs,
such as waiting lists, records of the racial, national origin, elderly, disabled and familial status makeup
of participants in Housing Programs, and copies of denied applications.
h. The City shall maintain copies of all race-related complaints, claims, grievances, investigative records,
including grievance process materials.
i. The City shall maintain files containing documentation of its efforts to meet the obligations of this
Agreement.
All applicant and participant information will be kept in a secure location and access will be limited to authorized
PHA staff.
PHA staff will not discuss personal family information unless there is a business reason to do so. Inappropriate
discussion of family information or improper disclosure of family information by staff will result in disciplinary
action.
Moving with Continued Assistance
HCV Recipients can move to a new unit with continued assistance. Permissible reasons to move are:
• The family has a right to terminate the lease on notice to the owner (for the owner's breach or otherwise)
and has given a notice of termination to the owner in accordance with the lease. The lease for the family's
unit has been terminated by mutual agreement of the owner and the family.
o The PHA policy is if the family and the owner mutually agree to terminate the lease for the family's
unit, the family must give the PHA a copy of the termination agreement.
• The owner has given the family a notice to vacate, has commenced an action to evict the family, or has
obtained a court judgment or other process allowing the owner to evict the family [24 CFR 982.354(b)(2)].
The family must give the PHA a copy of any owner eviction notice [24 CFR 982.551(g)].
• The family or a member of the family is or has been the victim of domestic violence, dating violence, or
stalking and the move is needed to protect the health or safety of the family or family member. This
condition applies even when the family has moved out of its unit in violation of the lease, with or without
prior notification to the PHA, if the family or family member who is the victim reasonably believed that he
or she was imminently threatened by harm from further violence if he or she remained in the unit.
o The PHA policy is if a family requests permission to move with continued assistance based on a
claim that the move is necessary to protect the health or safety of a family member who is or has
been the victim of domestic violence, dating violence, or stalking, the PHA will request
documentation in accordance with section 16-IX.D of this plan.
o The PHA reserves the right to waive the documentation requirement if it determines that a
statement or other corroborating evidence from the family or family member will suffice. In such
cases the PHA will document the waiver in the family's file.
• The PHA has terminated the assisted lease for the family's unit for the owner's breach
• The PHA determines that the family's current unit does not meet the HQS space standards because of an
increase in family size or a change in family composition. In such cases, the PHA must issue the family a new
voucher, and the family and PHA must try to find an acceptable unit as soon as possible. If an acceptable
unit is available for the family, the PHA must terminate the HAP contract for the family's old unit in
accordance with the HAP contract terms and must notify both the family and the owner of the termination.
The HAP contract terminates at the end of the calendar month that follows the calendar month in which
the PHA gives notice to the owner.
Restrictions on Moves:
Page 20 of 64
Moving is generally contingent on compliance with program requirements and funding availability. The PHA will
deny a family permission to move on grounds that the PHA does not have sufficient funding for continued
assistance if(a) the move is initiated by the family, not the owner or the PHA; (b) the PHA can demonstrate that the
move will, in fact, result in higher subsidy costs; and (c) the PHA can demonstrate that it does not have sufficient
funding in its annual budget to accommodate the higher subsidy costs. The PHA maintains a list of families whose
moves are denied due to insufficient funding. When funding becomes available, these families take precedence
over families on the waiting list.
If the PHA has grounds for terminating or denying the families assistance, the PHA may deny a family permission to
move. In general, the PHA will not deny a family permission to move for violation of program rules; however, the
PHA reserves the right to do so as outlined in the administrative plan.
The PHA will deny a family permission to make an elective move during the family's initial lease term.This policy
applies to moves within the PHA's jurisdiction or outside it under portability.
The PHA will also deny a family permission to make more than one elective move during any 12-month period.This
policy applies to all assisted families residing in the PHA's jurisdiction.
The PHA will consider exceptions to these policies for the following reasons: to protect the health or safety of a
family member(e.g., lead-based paint hazards, domestic violence, witness protection programs), to accommodate
a change in family circumstances (e.g., new employment, school attendance in a distant area), or to address an
emergency over which a family has no control. The PHA provides exceptions for legitimate family needs but not for
the convenience of either or both parties. The PHA may request the family to obtain a mutual agreement from the
owner to move when considering exceptions.
In addition, the PHA will allow exceptions to these policies for purposes of reasonable accommodation of a family
member who is a person with disabilities.
Restrictions on moves may be implemented as budget authority allows.
Portability:
A family may move with voucher assistance only to an area where there is at least one PHA administering a voucher
program. Applicant families that have been issued vouchers as well as participant families may qualify to lease a
unit outside the PHA's jurisdiction under portability. If neither the head of household nor the spouse/cohead of an
applicant family had a domicile (legal residence) in the PHA's jurisdiction at the time that the family's initial
application for assistance was submitted, the family must lease a unit within the initial PHA's jurisdiction for at least
12 months before requesting portability.
The PHA will consider exceptions to this policy for purposes of reasonable accommodation or reasons related to
domestic violence, dating violence, or stalking.
Because the portability process is time-sensitive, the PHA will notify the receiving PHA by phone, fax, or e-mail to
expect the family.The initial PHA will also ask the receiving PHA to provide any information the family may need
upon arrival, including the name, fax, e-mail address, and telephone number of the staff person responsible for
business with incoming portable families and procedures related to appointments for voucher issuance.The PHA
will pass this information along to the family. The PHA will also ask for the name, address, telephone number, fax
and e-mail of the person responsible for processing the billing information.
Restrictions on portability may be restricted as budget authority allows.
Determination of Insufficient Funding
The PHA will determine whether there is adequate funding to issue vouchers, approve moves to higher cost units
and areas, and continue subsidizing all current participants by comparing the PHA's annual budget authority to the
Page 21 of 64
annual total HAP needs monthly. The total HAP needs for the calendar year will be projected by establishing the
actual HAP costs year to date.To that figure, the PHA will add anticipated HAP expenditures for the remainder of
the calendar year. Projected HAP expenditures will be calculated by multiplying the projected number of units
leased per remaining months by the most current month's average HAP.The projected number of units leased per
month will consider the average monthly turnover of participant families. If the total annual HAP needs equal or
exceed the annual budget authority, or if the PHA cannot support the cost of the proposed subsidy commitment
(voucher issuance or move) based on the funding analysis, the PHA will be considered to have insufficient funding.
If a shortfall is determined, the City will work with HUD to determine appropriate actions and amend the
administrative plan as necessary.
Violence Against Women Act (VAWA)
The PHA acknowledges that a victim of domestic violence, dating violence, 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 business days.
If the perpetrator of the abuse is a member of the applicant family, the applicant must provide additional
documentation consisting of one of the following:
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
the rehabilitation was successfully completed. 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 HCV program, as do the limitations discussed under the next heading.)
First, VAWA provides that a PHA may not terminate assistance to a family that moves out of an assisted unit in
violation of the lease, with or without prior notification to the PHA, if the move occurred to protect the health or
safety of a family member who is or has been the victim of domestic violence, dating violence, or stalking and who
reasonably believed he or she was imminently threatened by harm from further violence if he or she remained in
the unit.
Second, it provides that an incident or incidents of actual or threatened domestic violence, dating violence, 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 tenanYs household, a guest, or
another person under the tenanYs control is the one engaging in the criminal activity and the tenant or an
immediate family member of the tenant is the actual or threatened victim of the domestic violence, dating
violence, or stalking.
Fourth, it gives PHAs the authority to terminate assistance to any tenant or lawful occupant who engages in
criminal acts of physical violence against family members or others without terminating assistance to, or otherwise
penalizing, the victim of the violence.
Page 22 of 64
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 determines that the family member has
committed criminal acts of physical violence against other family members or others.This action will not affect the
assistance of the remaining, nonculpable family members. In making its decision, the PHA will consider all credible
evidence, including, but not limited to, a signed certification (form HUD-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 PHA may extend this time period at its discretion.
For purposes of determining whether a tenant may be covered by VAWA, the following list of definitions applies:
VAWA defines domestic violence to include felony or misdemeanor crimes of violence committed by any of the
following:
• A current or former spouse of the victim
• A person with whom the victim shares a child in common
• A person who is cohabitating with or has cohabitated with the victim as a spouse
• 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:
• 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
Page 23 of 64
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.
HU D issued a final rule reauthorizing VAWA on November 16, 2016. In compliance with the rule, notification was sent to all
adult housing participants. This notice included information on opening the Housing Choice Voucher Waiting List.
Page 24 of 64
THE CITY OF Dubuque
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IMPORTANT INFORMATION FOR ALL ADULT HOUSING PARTICIPANTS
• On November 16, 2016, U.S. Department of Housing and Urban Development (HUD) published a final
rule which implements in HUD's regulations the requirements of the 2013 reauthorization of the Violence
Against Women Act (VAWA). The final rule requires City of Dubuque Housing & CD Department
(CDHCDD) to provide Notice of Occupancy Rights under the VAWA Act and Certification of Domestic
Violence, Dating Violence, Sexual Assault, or Stalking, and Alternate Documentation. Enclosed with this
letter is a copy of the Notice and Certification.
There is nothing that you need to do with this information unless you have been a victim of domestic
violence, dating violence, sexual assault, or stalking, and wish to use your rights under VAWA based on
the enclosed notice.
If you have additional questions or need additional information, please contact Teresa Bassler at 563-690-
6096 or tbassler a(�.citvofdubuque.orq.
OTHER INFORMATION FOR CITY OF DUBUQUE HOUSING PARTICIPANTS
• Need to speak with your caseworker? If your last name begins with:
o "A"through "B":
Contact Cate Richter at (563) 690-6070 or crichter a(�.citvofdubuque.orq
o "C'through "L":
Contact Jessica Kieffer at (563) 690-6103 or Ikieffer a(�.citvofdubuque.orq
o "M"through "Z""
Contact Tracy Doyle at (563) 690-6099 or tdovle a(�.citvofdubuque.orq
Family Self Sufficiency participants for last name that begins with:
o "A"through "I"
Contact Dawn DeMaio at (563) 690-6090 or ddemaio c(il.citvofdubuque.orq
o "J" through "Z"
Contact Hollie Ohnesorge at (563) 690-6106 or hohnesor a(�.citvofdubuque.orq
• The City of Dubuque Housing & Community Development Department (CDHCDD) will OPEN the waiting
list for the Housing Choice Voucher rental assistance program beginning Wednesday, February 14, 2017
at 8:00 a.m. through Tuesday, February 20, 2018 at 5:00 p.m. Applications will be available on-line at
citvofdubuque.applv4housina.com, at the Housing & Community Development Department, 350 W 6th St.,
Suite 312, by calling 563-589-4230, or by emailing housinq c(il.citvofdubuque.orq.
ADDITIONAL OPPORTUNITIES FOR HOUSING PARTICIPANTS
• RESIDENT ADVISORY BOARD (RAB) —This board gives housing participants an opportunity to voice
opinions and concerns on policies related to the operation of the Housing Choice Voucher Program. The
board meets quarterly and as needed for development of the Annual Plan and 5-Year Plan. Food and
prizes are provided. If interested, please contact our office to be place on a mailing list for future
Page 25 of 64
meetings.
• FAMILY SELF SUFFICIENCY (FSS) —This is a voluntary program for housing participants who would like
to increase their earned income and reduce their dependency on welfare assistance and rental subsidies.
The FSS program also provides access to child care, transportation, education, job development, and
household skills training, affirmatively furthering fair housing, financial and homeownership options. City
of Dubuque Public Housing Authority (PHA) and the family execute a 5-year contract of participation
specifying goals for achieving self-sufficiency. A deposit to an interest-bearing account on behalf of the
FSS family is established when a family's rent increases as a result of increased earned income. Once
the family fulfills all of its FSS obligations under the contract including the obligation to be welfare-free for
12 consecutive months, the family earns the escrow account established on their behalf. If interested,
please contact FSS Coordinators Hollie Ohnesorge or Dawn DeMaio.
• HOUSING CHOICE VOUCHER HOMEOWNERSHIP —This program permits eligible participants the
option of purchasing a home with their voucher assistance rather than renting. Not all public housing
authorities participate in this program so this is a great opportunity for our participants. The assistance
may be provided for 15 years if the initial mortgage has a term of 20 years or longer. If interested, please
contact your caseworker for additional information.
Page 26 of 64
Rent Determination
To be eligible, the dwelling unit must have a reasonable rent. The rent must be reasonable in relation to comparable
unassisted units in the area and must not be more than rents charged by the owner for comparable, unassisted units on
the premises. The PHA must make a rent reasonableness determination at initial occupancy and whenever the owner
requests a rent adjustment. Where the gross rent of the unit exceeds the applicable payment standard for the family, the
share of rent to be paid by the family cannot exceed 40 percent of the family's monthly adjusted income.
Bedroom size assignments on Vouchers will be made so that the smallest number of bedrooms needed to house a family
without overcrowding shall be issued. The subsidy standards will be consistent with space requirements under the City
of Dubuque Housing Code. The subsidy standards will be applied consistently for all families of like size and composition.
A child who is temporarily away from the home because of placement in foster care is considered a member of the family
in determining the family unit size. A family that consists of a pregnant woman (with no other persons) must be treated
as a two-person family(parent/minor child) and shall be assigned a two-bedroom voucher. Any live-in aide (approved by
the PHA to reside in the unit to care for a family member who is disabled) must be counted as a person residing in the
household in determining the family unit size and shall be issued a separate bedroom.
In the case of a participant who shares custody of a child (or children) with a parent or guardian residing outside of the
household, the child shall be included as a member of the household when considering the assignment of bedroom size if
the child (or children) legally reside with the participant and is considered a household member.
Disabled household members shall be provided separate bedrooms in cases of disabled household members receiving
supportive services to enhance independent living from another agency.
The bedroom size assignments on Vouchers shall be made according to the number of persons and relationship in the
household. Two persons shall be assigned to each bedroom/sleeping room in cases of children or adults cohabitating
and/or married.
The PHA will assign one bedroom for each two persons within the household, except in the following circumstances:
• Head of Household residing with an adult or minor child shall be allocated separate bedrooms resulting in a two-
bedroom Voucher. Head of Household who is residing with more than one adult or minor child under the age of 10
years old shall be allocated Voucher size allowing for two persons per bedroom and a separate bedroom for head of
household that includes spouse/cohabitant.
• In determining Voucher size for parent(s) including cohabitant, a separate bedroom shall be allocated for the head of
household/spouse/cohabitant and a separate bedroom for more than one adult or minor children of opposite sex age
10 years or older. Same sex adult or minor children shall be allocated one bedroom for each two persons.
• Adding additional persons to the household shall not increase the voucher issuance until the annual recertification or
unit change, if needed, if adding the person does not overcrowd the current unit. The dwelling unit must have at least
one bedroom or living/sleeping room for each two persons
The City of Dubuque's minimum rent is $0.00.
The PHA will conduct interim reexaminations to account for any changes in household composition that occur between
annual reexaminations. Only the income/assets/deductions/allowances pertaining to the new household member will be
verified and utilized during the interim reexamination.
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Grievance Procedures: INFORMAL REVIEWS AND HEARINGS
OVERVIEW
Both applicants and participants have the right to disagree with, and 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 applicantsdenied
admission because of citizenship issues), the appeal process is called an "informal hearing." PHAs are required toinclude
informal review procedures for applicants and informal hearing procedures for participants in their administrativeplans
[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 intended to provide a "minimum hearing
requiremenY' [24 CFR 982.554], and need not be as elaborate as the informal hearing requirements [Federal Register60,
no. 127 (3 July 1995):34690].
Decisions Subject to Informal Review
The PHA must give an applicant the opportunity for an informal review of a decision denying assistance [24 CFR
982.554(a)]. Denial of assistance may include any or all of the following [24 CFR 982.552(a)(2)]:
• Denying listing on the PHA waiting list
• Denying or withdrawing a voucher
• Refusing to enter a HAP contract or approve a lease
• Refusing to process or provide assistance under portability procedures
Informal reviews are not required for the following reasons [24 CFR982.554(c)]:
• Discretionary administrative determinations by the PHA
• General policy issues or class grievances
• A determination of the family unit size under the PHA subsidystandards
• A PHA determination not to approve an extension or suspension of a voucherterm
• A PHA determination not to grant approval of the tenancy
• A PHA determination that the unit is not in compliance with the HQS
• A PHA determination that the unit is not in accordance with the HQS due to family size orcomposition
The PHA will only offer an informal review to applicants for whom assistance is being denied. Denial ofassistance
includes: denying listing on the PHA waiting list; denying or withdrawing a voucher; refusing to enter into a HAPcontract
or approve a lease; refusing to process or provide assistance under portabilityprocedures.
Notice to the Applicant
The PHA must give an applicant prompt notice of a decision denying assistance. The notice must contain a brief statement
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 decisionletter.
Scheduling an Informal Review
A request for an informal review must be made in writing and delivered to the PHA either in person or by first class mail,
by the close of the business day, no later than 10 business days from the date of the PHA's denial ofassistance.
Exceptions for requesting an informal review in writing may be granted for limited English proficiency,disabled individuals
or for reasonable accommodations.
The PHA must schedule and send written notice of the informal review within 10 business days of the family's request.The
family may request to reschedule a review for good cause, or if it is needed as a reasonable accommodation fora person
Page 28 of 64
with disabilities. Good cause is defined as an unavoidable conflict which seriously affects the health, safetyor welfare of
the family. Requests to reschedule a review must be made orally or in writing prior to the review date. Atits discretion,
the PHA may request documentation of the "good cause" prior to rescheduling thereview.
Upon notification in advance with at least 24 hours' notice on any party's unavailability to attend a scheduled review, the
review will be rescheduled one time only without justification of the need to reschedule. After the review has been
rescheduled, a request to reschedule a second time by the same party will only be considered for extremesituations.
Extreme situations may include but are not limited to hospitalization of self or household member, death in the family,
weather related restriction. Any notice of the inability of the applicant to attend the review must be provided within24
hours of the review along with third party verification of the situation.The review officer will have the sole discretion to
decide if the request is legitimate and with good cause.
Informal Review Procedures
The informal review must be conducted by a person other than the one who made or approved the decision under
review, or a subordinate of this person.
The applicant must be provided an opportunity to present written or oral objections to the decision of the PHA.
Informal Review Decision
The PHA must notify the applicant of the PHA's final decision, including a brief statement of the reasons for the final
decision.
In rendering a decision, the PHA will evaluate the followingmatters:
If the grounds for denial were stated factually in the notice to the family.
The validity of the grounds for denial of assistance. If the grounds for denial are not specified inthe regulations, then the
decision to deny assistance will be overturned.
The validity of the evidence. The PHA will evaluate whether the facts presented prove the groundsfor denial of assistance.
If the facts prove that there are grounds for denial, and the denial is required by HUD, the PHA will uphold the decision to
denyassistance.
If the facts prove the grounds for denial, and the denial is discretionary, the PHA will considerthe recommendation of the
person conducting the informal review in making the final decision whetherto deny assistance.
The PHA will notify the applicant of the final decision, including a statement explaining the reason(s)for the decision. The
notice will be mailed within 10 business days of the informal review, to the applicant and his or her representative, if any,
along with proof of mailing.
If the decision to deny is overturned because of the informal review, processing for 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.
INFORMAL HEARINGS FOR PARTICIPANTS
PHAs must offer an informal hearing for certain PHA determinations relating to the individual circumstances ofa
participant family. A participant is defined as a family that has been admitted to the PHA's HCV program and iscurrently
assisted in the program. The purpose of the informal hearing is to consider whether the PHA's decisions related tothe
family's circumstances are in accordance with the law, HUD regulations and PHApolicies.
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-paid utilities from the PHA utilityallowance
Page 29 of 64
schedule
• A determination of the family unit size under the PHA's subsidystandards
• A determination that a certificate program family is residing in a unit with a larger number of bedrooms than
appropriate for the family unit size under the PHA's subsidy standards, or the PHA determination to denythe
family's request for exception from the standards
• A determination to terminate assistance for a participant family because of the family's actions or failure to act
• A determination to terminate assistance because the participant has been absent from the assisted unit for longer
than the maximum period permitted under PHA policy and HUDrules
• A determination to terminate a family's Family Self Sufficiency contract, withhold supportive services, orpropose
forfeiture of the family's escrow account [24 CFR984.303(i)]
Circumstances for which an informal hearing is not required are asfollows:
• Discretionary administrative determinations by the PHA
• General policy issues or class grievances
• Establishment of the PHA schedule of utility allowances for families in the program
• A PHA determination not to approve an extension or suspension of a voucherterm
• A PHA determination not to approve a unit or tenancy
• A PHA determination that a unit selected by the applicant is not in compliance with the HQS
• A PHA determination that the unit is not in accordance with HQS because of family size
• A determination by the PHA to exercise or not to exercise any right or remedy against an owner under a HAP
contract
The PHA will only offer participants the opportunity for an informal hearing when required to by theregulations.
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 the decision.
For decisions related to the family's annual or adjusted income, the determination of the appropriate utilityallowance,
and the determination of the family unit size, the PHA must notify the family that they may ask for an explanation of the
basis of the determination, and that if they do not agree with the decision, they may request an informal hearing onthe
decision.
For decisions related to the termination of the family's assistance, or the denial of a family's request for an exceptionto
the PHA's subsidy standards, the notice must contain a brief statement of the reasons for the decision, a statementthat if
the family does not agree with the decision, the family may request an informal hearing on the decision, and a statement
of the deadline for the family to request an informal hearing.
In cases where the PHA makes a decision for which an informal hearing must be offered, the notice to the family will
include all the following:
The proposed action or decision of the PHA.
A brief statement of the reasons for the decision, including the regulatoryreference.The date the
proposed action will take place.
A statement of the family's right to an explanation of the basis for the PHA's decision.
A statement that if the family does not agree with the decision the family may request an informal hearing of the decision.
A deadline for the family to request the informal hearing.To whom the
hearing request should be addressed.
A copy of the PHA's hearing procedures or written explanation of hearing procedures. Without this information, the
family will be unable to properly prepare for the hearing. Providing this informationas a matter of policy provides
assurance that the PHA has done all it can to inform the family of theirrights and responsibilities in the hearing process.
Page 30 of 64
Scheduling an lnforma/Hearing
When an informal hearing is required, the PHA must proceed with the hearing in a reasonably expeditious mannerupon
the request of the family.
A request for an informal hearing must be made in writing and delivered to the PHA either in person or by firstclass mail,
by the close of the business day, no later than 10 business days from the date of the PHA's decision or noticeto
terminate assistance.
The PHA must schedule and send written notice of the informal hearing to the family within 10 business days of the
family's request.
The family may request to reschedule a hearing for good cause, or if it is needed as a reasonable accommodation fora
person with disabilities. Good cause is defined as an unavoidable conflict which seriously affects the health, safetyor
welfare of the family. Requests to reschedule a hearing must be made orally or in writing prior to the hearing date. At its
discretion, the PHA may request documentation of the "good cause" prior to rescheduling thehearing.
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 mustbe 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
weekends and holidays.The PHA will reschedule the hearing only if the family can show good cause for the failure to
appear, or if it is needed as a reasonable accommodation for a person with disabilities.
Pre-Hearing Right to Discovery
Participants and the PHA are permitted pre-hearing discovery rights. The family must be given the opportunityto examine
before the hearing any PHA documents that are directly relevant to the hearing.The family must be allowed to copy any
such documents at their own expense. If the PHA does not make the document available for examinationon request of
the family, the PHA may not rely on the document at the hearing.
The PHA hearing procedures may provide that the PHA must be given the opportunity to examine at the PHA offices
before the hearing, any family documents that are directly relevant to the hearing. The PHA must be allowed tocopy any
such document at the PHA's expense. If the family does not make the document available for 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 hearingdate.
Participant's Right to Bring Counsel
At its own expense, the family may be represented by a lawyer or other representative at the informal hearing.
lnforma/Hearing Officer
Informal hearings will be conducted by a person or persons approved by the PHA, other than the person who madeor
approved the decision or a subordinate of the person who made or approved thedecision.
The PHA has designated the following to serve as hearingofficers:
Director of the PHA or his/her designated individual including the Assisted Housing Supervisor
Page 31 of 64
Attendance at the lnforma/Hearing
Hearings may be attended by a hearing officer and the following applicable persons: A
PHA representative(s) and any witnesses for the PHA
The participant and any witnesses for the participant
The participanYs counsel or other representative
Any other person approved by the PHA as a reasonable accommodation for a person with a disability Any person
attending the hearing as an interpreter due to a disability or Limited English Proficiency
Condud at Hearings
The person who conducts the hearing may regulate the conduct of the hearing in accordance with the PHA's hearing
procedures [24 CFR982.555(4)(ii)]. The hearing officer is responsible to manage the order of business and to ensure that
hearings are conducted ina professional and businesslike manner. Attendees are expected to comply with all hearing
procedures established by the hearing officer and guidelines for conduct. Any person demonstrating disruptive, abusive
or otherwiseinappropriate 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. 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 anillustrative aid to assist the
hearing officer, such as a model, a chart or otherdiagram.
Real evidence: A tangible item relating directly to the case.
Hearsay Evidence is evidence of a statement that was made other than by a witness while testifying at the hearingand
that is offered to prove the truth of the matter. Even though evidence, including hearsay, is generallyadmissible, hearsay
evidence alone cannot be used as the sole basis for the hearing officer's decision.
If either the PHA or the family fail to comply with the discovery requirements described above, the hearing officer will
refuse to admit such evidence.
Other than the failure of a party to comply with discovery, the hearing officer has the authority to overrule any
objections to evidence.
Hearing Officer's Decision
The person who conducts the hearing must issue a written decision, stating briefly the reasons for the decision.Factual
determinations relating to the individual circumstances of the family must be based on a preponderance ofevidence
presented at the hearing. A copy of the hearing decision must be furnished promptly to thefamily.
In rendering a decision, the hearing officer will consider the followingmatters:
PHA Notice to the Family:The hearing officer will determine if the reasons for the PHA's decision are factually stated in
the Notice.
Discovery:The hearing officer will determine if the PHA and the family were given the opportunity to examine any
relevant documents in accordance with PHApolicy.
PHA Evidence to Support the PHA Decision:The evidence consists of the facts presented. Evidence is not conclusion and
it is not argument. The hearing officer will evaluate the facts to determine ifthey support the PHA's conclusion.
Validity of Grounds 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 HU D 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.
Page 32 of 64
The hearing officer will issue a written decision to the family and the PHA no later than 10 business days after the
hearing. The report will contain the following information:
Hearing information:
Name of the participant;
Date, time and place of the hearing; Name of the hearing officer;
Name of the PHA representative;and Name of family
representative (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 his/her testimony and that areadmitted into evidence.
Findings of Fact:The hearing officer will include all findings of fact, based on a preponderance ofthe evidence.
Preponderance of the evidence is defined as evidence which is of greater weight ormore convincing than the evidence
which is offered in opposition to it; that is, evidence which as a whole shows that the fact sought to be proved is more
probable than not. Preponderance of the evidence may not be determined by the number of witnesses, but by the greater
weight of allevidence.
Conclusions:The hearing officer will render a conclusion derived from the facts that were found tobe true by a
preponderance of the evidence. The conclusion will result in a determination of whetherthese facts uphold the PHA's
decision.
Order:The hearing report will include a statement of whether the PHA's decision is upheld or overturned. If it is
overturned, the hearing officer will instruct the PHA to change the decision in accordance with the hearing officer's
determination. In the case of termination of assistance,the hearing officer will instruct the PHA to restore the
participanYs program status.
Procedures for Rehearing or 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 deadline ordered bythe hearing officer, the
action of the PHA will take effect and another hearing will not be granted.
Considerations
In making its decision to terminate assistance, the PHA will consider alternatives as described in Section 12-II.0 and other
factors described in Sections 12-II.D and 12-II.E. Upon consideration of such alternatives and factors, the PHA may, on a
case-by-case basis, choose not to terminate assistance.
PHA Notice of Fina/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 HU D regulations, requirements, or are otherwise contrary to federal, state, or local laws. If
the PHA determines it is not bound by the hearing officer's decision in accordance with HUD regulations, the PHA must
promptly notify the family of the determination and the reason for the determination.
The PHA will mail a "Notice of Final Decision" including the hearing officer's report to the participant and their
representative.This notice will be sent by first-class mail, postage pre-paid. The participant will be mailed theoriginal
"Notice of Final Decision". A copy of the "Notice of Final Decision"will be maintained in the PHA'sfile.
HEARING AND APPEAL PROVISIONS FORNONCITIZENS
Denial or termination of assistance based on immigration status is subject to special hearing and notice rules. Applicants
who are denied assistance due to immigration status are entitled to an informal hearing, not an informal review.
Assistance to a family may not be delayed, denied, or terminated based on immigration status at any time prior to a
decision under the United States Citizenship and Immigration Services (USCIS) appeal process. Assistance to afamily may
not be terminated or denied while the PHA hearing is pending, but assistance to an applicant may bedelayed pending
the completion of the informal hearing.
A decision against a family member, issued in accordance with the USCIS appeal process or the PHA informal hearing
Page 33 of 64
process, does not preclude the family from exercising the right, that may otherwise be available, to seek redress directly
through judicial procedures.
Notice of Denial or Termination ofAssistance
The notice of denial or termination of assistance for noncitizens must advise the family:
That financial assistance will be denied or terminated, and provide a brief explanation of the reasons for the proposed
denial or termination ofassistance.
The family may be eligible for proration ofassistance.
In the case of a participant, the criteria and procedures for obtaining relief under the provisions for preservationof
families [24 CFR 5.514 and 5.518].
That the family has a right to request an appeal to the USCIS of the results of secondary verification ofimmigration status
and to submit additional documentation or explanation in support of theappeal.
That the family has a right to request an informal hearing with the PHA either upon completion of the USCIS appeal orin
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
hearing process.
USCIS Appeal Process
When the PHA receives notification that the USCIS secondary verification failed to confirm eligible immigrationstatus, the
PHA must notify the family of the results of the USCIS verification.The family will have 30 days from the date of the
notification to request an appeal of the USCIS results.The request for appeal must be made by the family inwriting
directly to the USCIS. The family must provide the PHA with a copy of the written request for appeal and the proofof
mailing.
The PHA will notify the family in writing of the results of the USCIS secondary verification within 10 business daysof
receiving the results.
The family must provide the PHA with a copy of the written request for appeal and proof of mailing within 10 business
days of sending the request to the USCIS.
The family must forward to the designated USCIS office any additional documentation or written explanation insupport of
the appeal. This material must include a copy of the USCIS document verification request (used to processthe secondary
request)or such other form specified by the USCIS, and a letter indicating that the family is requesting an appeal of the
USCIS immigration status verification results.
The USCIS will notify the family, with a copy to the PHA, of its decision. When the USCIS notifies the PHA of thedecision,
the PHA must notify the family of its right to request an informal hearing.
The PHA will send written notice to the family of its right to request an informal hearing within 10 business days of
receiving notice of the USCIS decision regarding the family's immigrationstatus.
Informal Hearing Procedures forApplicants
After notification of the USCIS decision on appeal, or in lieu of an appeal to the USCIS, the family may request thatthe
PHA provide a hearing. The request for a hearing must be made either within 30 days of receipt of the PHA notice of
denial, or within 30 days of receipt of the USCIS appeal decision.
The informal hearing procedures for applicant families are described below.
lnforma/Hearing Officer
The PHA must provide an informal hearing before an impartial individual, other than a person who made orapproved the
decision under review, and other than a person who is a subordinate of the person who made or approved the decision.
Evidence
The family must be provided the opportunity to examine and copy at the family's expense, at a reasonable time in
Page 34 of 64
advance of the hearing, any documents in the possession of the PHA pertaining to the family's eligibility status, or inthe
possession of the USCIS (as permitted by USCIS requirements), including any records and regulations that maybe relevant
to the hearing.
The family will be allowed to copy any documents related to the hearing at a cost of$.25 per page. The family must
request discovery of PHA documents no laterthan
12:00 p.m. on the business day prior to the hearing.
The family must be provided the opportunity to present evidence and arguments in support of eligible status. Evidence
may be considered without regard to admissibility under the rules of evidence applicable to judicial proceedings.
The family must also be provided the opportunity to refute evidence relied upon by the PHA, and to confront andcross-
examine all witnesses on whose testimony or information the PHA relies.
Representation and lnterpretive5ervices
The family is entitled to be represented by an attorney or other designee, at the family's expense, and to have such
person make statements on the family's behalf.
The family is entitled to arrange for an interpreter to attend the hearing, at the expense of the family, or the PHA,as may
be agreed upon by the two parties.
Recording of the Hearing
The family is entitled to have the hearing recorded by audiotape.The PHA may, but is not required to provide a transcript
of the hearing.
The PHA will not provide a transcript of an audio taped hearing.
Hearing Decision
The PHA must provide the family with a written final decision, based solely on the facts presented at the hearing, within
14 calendar days of the date of the informal hearing. The decision must state the basis for the decision.
Informal Hearing Procedures for Participants
After notification of the USCIS decision on appeal, or in lieu of an appeal to the USCIS, the family may request thatthe
PHA provide a hearing. The request for a hearing must be made either within 30 days of receipt of the PHA notice of
termination, or within 30 days of receipt of the USCIS appeal decision.
For the informal hearing procedures that apply to participant families whose assistance is being terminated based on
immigration status.
Retention of Documents
The PHA must retain for a minimum of 5 years the following documents that may have been submitted to the PHA by the
family, or provided to the PHA as part of the USCIS appeal or the PHA informal hearing process:
• The application for assistance
• The form completed by the family for income reexamination
• Photocopies of any original documents, including original USCISdocuments
• The signed verification consent form
• The USCIS verification results
• The request for a USCIS appeal
• The final USCIS determination
• The request for an informal hearing
• The final informal hearing decision
Homeownership Programs OVERVIEW
The homeownership option is used to assist a family residing in a home purchased and owned by one or more members
of the family. A family assisted under this option may be newly admitted or an existing participant in the HCV program.
The PHA must have the capacity to operate a successful HCV homeownership program as defined by the regulations.
There are two forms of homeownership assistance a PHA may offer under this option: monthlyhomeownership
assistance payments, or a single down payment assistance grant. PHAs may choose to offer either or both formsof
Page 35 of 64
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 homeownership program as a reasonable accommodation.The PHA must
determine what is reasonable based on the specific circumstances and individual needs of the person witha disability. The
PHA may determine that it is not reasonable to offer homeownership assistance as a reasonable accommodation in cases
where the PHA has otherwise opted not to implement a homeownership program.
The PHA must approve a live-in aide if needed as a reasonable accommodation so that the program is readilyaccessible to
and usable by persons with disabilities.
The PHA will offer the monthly homeownership assistance payments to qualifiedfamilies.
The Housing Choice Voucher Home Ownership Program permits eligible participants in the HCV Program,including
participants with portable vouchers, the option of purchasing a home with their voucher assistance rather thanrenting.
The home ownership option is available to newly admitted or existing participants, who do not owe monies to the City of
Dubuque Housing Services or any other Housing Agency for any outstanding debts, and who meet theeligibility criteria
set forth below. Additionally, participants who are in violation of their family obligations while receiving HCV assistance
shall be ineligible for participation in the Housing Choice Voucher Home Ownership Program.
HCV home ownership assistance may be used to purchase the following type of homes within the City of Dubuque:new or
existing single-family dwelling unit, condominium, cooperatives, or manufactured homes. The City ofDubuque Housing
will also permit portability of HCV home ownership assistance to another jurisdiction, provided 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 afirst-time homeowner, or
may be a cooperative member.The family must meet the Federal minimum income requirement.The family must have a
gross annual income equal to the Federal minimum wage multiplied by 2000, based on the income of adult family
members who will own the home.The PHA may establish a higher income standard for families. However,a family that
meets the federal minimum income requirement (but not the PHA's requirement) will be considered to meet the
minimum income requirement if it can demonstrate that it has been pre-qualified or pre-approved for financingthat is
sufficient to purchase an eligible unit. For disabled families, the minimum income requirement is equal to thecurrent SSI
monthly payment for an individual living alone, multiplied by 12. For elderly or disabled families, welfareassistance
payments for adult family members who will own the home will be included in determining whether the familymeets the
minimum income requirement. It will not be included for other families.The family must satisfy theemployment
requirements by demonstrating that one or more adult members of the family who will own the home at commencement
of homeownership assistance is currently employed on a full-time basis (the term'full-time employmenY means not less
than an average of 30 hours per week); and has been continuously so employed duringthe year before commencement of
homeownership assistance for the family. The employment requirement does notapply to elderly and disabled families. In
addition, if a family, other than an elderly or disabled family includes a personwith disabilities, the PHA must grant an
exemption from the employment requirement if the PHA determines that it is needed as a reasonable accommodation.
The family has not defaulted on a mortgage securing debt to purchase a home under the homeownership option. Except
for cooperative members who have acquired cooperative membershipshares prior to commencement of homeownership
assistance, no family member has a present ownership interest 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).
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The PHA will not establish a higher minimum income standard for disabled and/or non-disabledfamilies.
The family must be financially capable to qualify for HA approved financing of the home and must be financially capable to
provide at least 3% of the purchase price as a minimum homeowner down payment. The City of Dubuque Rehabilitation
Activity shall review lender qualifications and the loan terms before authorizing homeownership assistance.
The PHA requires that financing for purchase of a home under its HCV homeownership program complieswith secondary
mortgage market underwriting requirements; or complies with generally accepted privatesector underwriting standards.
Each family, except families with a disabled member, must be a first-time homeowner. A first-time homeowner means
that no member of the household has had an ownership interest in any residence during the three years prior tothe
home ownership assistance. However, a single parent or displaced homemaker who, while married, owned a home with a
spouse (or resided in a home owned by a spouse) is considered a first-time home owner for purposes of the Housing
Choice Voucher Home Ownership Program.
The Housing and Community Development Director may also consider whether and to what extent anemployment
interruption is considered permissible in satisfying the employment requirement. Generally, families will be considered
"continuously employed" if the break in employment does not exceed two months.The Housing and Community
Development Director may also consider self-employment to determine employment history.The employment
requirement does not apply to an elderly or disabled family. To reasonably accommodate afamily's
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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 OwnershipProgram 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 administrativeplan.
If the PHA limits the number of families that may participate in the homeownership option, the PHA must establish a
system by which to select families toparticipate.
ELIGIBLE UNITS
For a unit to be eligible, the PHA must determine that the unit satisfies all the followingrequirements:
• The unit must meet HUD's "eligible housing" requirements. The unit may not be any of the following:
- A public housing or Indian housing unit;
- A unit receiving Section 8 project-based assistance;
- A nursing home, board and care home, or facility providing continual psychiatric, medical or nursingservices;
- A college or other school dormitory;
- On the grounds of penal, reformatory, medical, mental, or similar public or private institutions.
• The unit must be under construction or already exist at the time the family enters the contract ofsale.
• The unit must be a one-unit property or a single dwelling unit in a cooperative orcondominium.
• The unit must have been inspected by the PHA and by an independent inspector designated by thefamily.
• The unit must meet Housing Quality Standards (see Chapter8).
• For a unit where the family will not own fee title to the real property (such as a manufactured home), the home
must have a permanent foundation and the family must have the right to occupy the site for at least 40 years.
• For PHA-owned units all the following conditions must be satisfied:
- The PHA informs the family, both orally and in writing, that the family has the right to purchase any eligibleunit
and a PHA-owned unit is freely selected by the family without PHA pressure orsteering;
- The unit is not ineligible housing;
- The PHA obtains the services of an independent agency to inspect the unit for compliance with HQS, reviewthe
independent inspection report, review the contract of sale, determine the reasonableness of the sales price and any PHA
provided financing.These actions must be completed in accordance with programrequirements.
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
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on the waiting list for a voucher.
The family will be allowed 120 days to identify a unit and submit a sales contract to the PHA for review.The family will be
allowed an additional 120 days to close on the home. PHAs may grant extensions to either ofthese periods for good
cause. The length of the extension(s) will be determined on a case-by-case, but in no casewill an extension exceed a total
of 125 days.The maximum amount of time a family will be given to locateand complete the purchase of a home under
the homeownership option is 365days.
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 withinl0 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 must attend and satisfactorily complete
the pre-assistance homeownership and housing counseling program required by the PHA. HUD suggests the following
topics for the PHA-required pre-assistance counseling:
• Home maintenance (including care of the grounds);
• Budgeting and money management;
• Credit counseling;
• How to negotiate the purchase price of a home;
• How to obtain homeownership financing and loan pre-approvals, including a description of types of financingthat
may be available, and the pros and cons of different types offinancing;
• How to find a home, including information about homeownership opportunities, schools, and transportation inthe
PHA jurisdiction;
• Advantages of purchasing a home in an area that does not have a high concentration of low-income familiesand
how to locate homes in such areas;
• Information on fair housing, including fair housing lending and local fair housing enforcement agencies;and
• Information about the Real Estate Settlement Procedures Act(12 U.S.C. 2601 et seq.) (RESPA), state and Federal
truth-in-lending laws, and how to identify and avoid loans with oppressive terms and conditions.
The PHA may adapt the subjects covered in pre-assistance counseling (as listed)to local circumstances and the needs of
individual families.
The PHA may also offer additional counseling after commencement of homeownership assistance (ongoingcounseling).
If the PHA offers a program of ongoing counseling for participants in the homeownership option, the PHA shall have
discretion to determine whether the family is required to participate in the ongoingcounseling.
If the PHA does not use a HU D-approved housing counseling agency to provide the counseling, the PHA should ensure that
its counseling program is consistent with the counseling provided under HUD's Housing Counseling program.
A family's participation in the home ownership program is conditioned on the family attending and successfully
completing a home ownership and housing counseling program approved by the PHA prior to commencement of home
ownership assistance.
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HOME INSPECTIONS,CONTRACT OF SALE,AND PHA DISAPPROVAL OFSELLER
Home Inspections
The PHA may not commence monthly homeownership assistance payments or provide down payment assistancegrants
for a family until the PHA has inspected the unit and has determined that the unit passes HQS.
An independent professional inspector selected by and paid for by the family must also inspect the unit.The
independent inspection must cover major building systems and components, including foundation andstructure, housing
interior and exterior, and the roofing, plumbing, electrical, and heating systems.The independent inspector must be
qualified to report on property conditions, including major building systems andcomponents.
The PHA may not require the family to use an independent inspector selected by the PHA. The independentinspector
may not be a PHA employee or contractor, or other person under control of the PHA. However, the PHA may establish
standards for qualification of inspectors selected by families under the homeownershipoption.
The PHA may disapprove a unit for assistance based on information in the independent inspector's report, even ifthe unit
was found to comply with HQS.
The unit must be inspected by a PHA inspector and pass inspection per the City of Dubuque Housing Code. The unit must
be inspected by an independent inspector and incipient code violations identified by the independent inspector.
To assure the home complies with the City of Dubuque Housing Code, home ownership assistance payments mustnot
commence until the PHA has inspected and approved the home. Another inspection must also be completed bya
professional home inspector selected by the family and approved by the PHA.The independent inspection mustcover
major building systems and components, including foundation and structure, housing interior and exterior, and the
roofing, plumbing, electrical, and heating systems. The independent inspector must be qualified to report on property
conditions, including major building systems.The independent inspector may not be a PHA employee or contractor,or
other person under control of the PHA.The independent inspector must provide a copy of the inspection report both to
the family and to the PHA.The PHA may not pay any Home ownership assistance for the family until the PHAhas reviewed
the inspection report of the independent inspector. Even if the unit otherwise complies with the Cityof Dubuque Housing
Code, the PHA shall have discretion to disapprove the unit for assistance under the Homeownership program because of
information in the inspection report.
Contract of Sale
Before commencement of monthly homeownership assistance payments or receipt of a down payment assistance grant, a
member or members of the family must enter a contract of sale with the seller of the unit to be acquired bythe family.
The family must give the PHA a copy of the contract of sale.The contract of sale must:
• Specify the price and other terms of sale by the seller to the purchaser;
• Provide that the purchaser will arrange for a pre-purchase inspection of the dwelling unit by an independent
inspectorselected bythe purchaser;
• Provide that the purchaser is not obligated to purchase the unit unless the inspection is satisfactory tothe
purchaser;
• Provide that the purchaser is not obligated to pay for any necessary repairs;and
• Contain a certification from the seller that the seller has not been debarred, suspended, or subject to a limited
denial of participation under CFR part 24.
Prior to execution of the offer to purchase or sales agreement, the financing terms must be provided by the family to the
City of Dubuque Rehabilitation Activity for approval. The purchase or sales agreement must provide for inspection by the
PHA and the independent inspector and must state that the purchaser is not obligated to purchase unlessthe inspections
are satisfactory to the PHA. The purchase or sales agreement must provide that the purchaser isnot obligated to purchase
if the mortgage financing terms are not approved by the PHA. A copy of the purchase orsales agreement must be
submitted to the City of Dubuque Rehabilitation Activity forapproval.
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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 financing, refinancing or other
debit if it is determined that the debt is unaffordable, or if the lender or the loan terms do not meet the qualifications as
set forth by the PHA.The buyer must be capable of providing at least 3%of the purchase price for the down payment.
CONTINUED ASSISTANCE REQUIREMENTS; FAMILYOBLIGATIONS
Homeownership assistance may only be paid while the family is residing in the home. If the family moves out ofthe home,
the PHA may not continue homeownership assistance after the month when the family moves out.The family or lender is
not required to refund to the PHA the homeownership assistance for the month when the family movesout.
Before commencement of homeownership assistance, the family must execute a statement in which the family agrees to
comply with all family obligations under the homeownershipoption.
The family must comply with the following obligations:
• The family must comply with the terms of the mortgage securing debt incurred to purchase the home, or any
refinancing of such debt.
• The family may not convey or transfer ownership of the home, except for purposes of financing, refinancing, or
pending settlement of the estate of a deceased family member. Use and occupancy of the home are subjectto
24 CFR 982.551 (h) and (i).
• The family must supply information to the PHA or HU D 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), (f), (g) and (j).
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Before each annual recertification during the next two years, the home will be inspected by a PHA inspector per City of
Dubuque Housing Code and must pass inspection to continue receiving home ownership assistance. If thePHA determines
there are problems with maintaining the home in a safe and decent manner, the Housing and Community Development
Director may require on-going inspections annually for the next fiveyears.
A family must agree, in writing, to comply with all family obligations under the HCV Program and the PHA'shome
ownership policies. These obligations include (1) attending ongoing home ownership counseling, if required bythe PHA;
(2) complying with the mortgage terms; (3) not selling or transferring the home to anyone other than a member of the
assisted family who resides in the home while receiving home ownership assistance and whois approved by the PHA; (4)
not refinancing or adding debt secured by the home without prior approval by the PHA;(5) not obtaining a present
ownership interest in another residence while receiving home ownership assistance;(6) supplying all required information
to the PHA, including but not limited to annual verification of household income, notice of change in home ownership
expenses, notice of move-out, and notice of mortgage default; (7)allowing inspections of the home and maintaining the
unit in a decent and safe manner;and (8) repairing any incipientcode violations identified from the independent
inspector's report within six (6) months of ownership.
MAXIMUM TERM OF HOMEOWNERASSISTANCE
Except in the case of a family that qualifies as an elderly or disabled family, other family members (described below) shall
not receive homeownership assistance for more than:
• Fifteen years, if the initial mortgage incurred to finance purchase of the home has a term of 20 years or longer;or
• Ten years, in all othercases.
The maximum term described above applies to any member of the familywho:
• Has an ownership interest in the unit during the time that homeownership payments are made;or
• Is the spouse of any member of the household who has an ownership interest in the unit during thetime
homeownership payments are made.
In the case of an elderly family, the exception only applies if the family qualifies as an elderly family at the start of
homeownership assistance. In the case of a disabled family, the exception applies if at any time during receiptof
homeownership assistance the family qualifies as a disabled family.
If, during homeownership assistance, the family ceases to qualify as a disabled or elderly family,the maximum term
becomes applicable from the date homeownership assistance commenced. However, such a familymust be provided at
least 6 months of homeownership assistance after the maximum term becomes applicable (provided the family is
otherwise eligible to receive homeownershipassistance).
If the family has received such assistance for different homes, or from different PHAs, the total of such assistance terms is
subject to the maximum term described in this part.
HOMEOWNERSHIP ASSISTANCE PAYMENTS AND HOMEOWNERSHIP EXPENSES
The monthly homeownership assistance payment is the lower of: the voucher payment standard minus the total tenant
payment, or the monthly homeownership expenses minus the total tenant payment.
In determining the amount of the homeownership assistance payment, the PHA will use the same paymentstandard
schedule, payment standard amounts, and subsidy standards as those described elsewhere in this plan for the Housing
Choice Voucher program. The payment standard for a family is the greater of (i)The payment standard as determined at
the commencement of homeownership assistance for occupancy of the home, or(ii)The payment standard at the most
recent regular reexamination of family income and composition since the commencement of homeownershipassistance
for occupancy of the home.
The PHA's housing assistance payment will be paid directly to the lender unless the mortgage company refuses to accept
payments from more than one source. In such case, the PHA's housing assistance payment will be paid directly tothe
family. If the assistance payment exceeds the amount due to the lender, the PHA must pay the excess directly tothe
family.
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Homeownership assistance for a family terminates automatically 180 calendar days after the lasthomeownership
assistance payment on behalf of the family. However, a PHA may grant relief from this requirement in thosecases
where automatic termination would result in extreme hardship for thefamily.
The PHA must adopt policies for determining the amount of homeownership expenses to be allowed by the PHA in
accordance with HUD requirements.
Homeownership expenses (not including cooperatives) only include amounts allowed by the PHA tocover:
• Principal and interest on initial mortgage debt, any refinancing of such debt, and any mortgage insurancepremium
incurred to finance purchase of the home;
• Real estate taxes and public assessments on the home;
• 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 title to the real property on which the home is located; [see
24 CFR 982.628(b)].
• For a condominium unit, condominium operating charges or maintenance fees assessed by thecondominium
homeowner association.
The amount of the monthly assistance payment will be based on three factors: the voucher payment standard forwhich
the family is eligible; the monthly home ownership expense; and the family's household income. The PHA shall paya
monthly Home ownership assistance payment directly to the lender on behalf of the family that is equal to the lower of:
(1)The payment standard minus the total tenant payment;or
(2) The family's monthly Home ownership expenses minus the total tenant payment.
Home ownership expenses for a homeowner may include principal and interest on mortgage debt, anymortgage
insurance premium incurred to finance the home, real estate taxes,any public assessments on the property, home
insurance, PHA allowance for maintenance expenses and costs of repairs and replacements; and the PHAutility
allowance. All participants in the HCV Home Ownership program shall be required to apply for the homesteadtax
exemption.
The PHA will allow the following homeownershipexpenses:
Monthly homeownership payment. This includes principal and interest on initial mortgage debt, taxesand insurance, and
any mortgage insurance premium, if applicable.
Utility allowance. The PHA's utility allowance for the unit, based on the current HCV utility allowance schedule. Monthly
maintenance allowance. The monthly maintenance allowance will be the annual maintenance allowance, divided by
twelve.The annual maintenance allowance will be set at .5 percent of purchase price of the home.
Monthly major repair/replacement allowance. The monthly major repair/replacement allowance will bethe annual
major repair/replacement allowance divided by 12. The annual major repair/replacement allowancewill be set as a
percentage of the purchase price of the home, based on the age of the home at the time ofpurchase and/or
reexamination.
Monthly co-op/condominium assessments. If applicable, the monthly amount of co-op orcondominium association
operation and maintenance assessments.
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Monthly principal and interest on debt for improvements. Principal and interest for major home repair, 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
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 HomeOwnership Program.
Homeownership expenses for a cooperative member may only include amounts allowed by the PHA tocover:
• The cooperative charge under the cooperative occupancy agreement including payment for real estate taxesand
public assessments on the home;
• Principal and interest on initial debt incurred to finance purchase of cooperative membership shares andany
refinancing of such debt;
• Home insurance;
• The PHA allowance for maintenance expenses;
• The PHA allowance for costs of major repairs and replacements;
• The PHA utility allowance for the home;and
• Principal and interest on debt incurred to finance major repairs, replacements or improvements for the home. Ifa
member of the family is a person with disabilities, such debt may include debt incurred by the family to finance costs
needed to make the home accessible for such person, if the PHA determines that allowance of such 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 CONTINUEDASSISTANCE
A family receiving homeownership assistance may move with continued tenant-based assistance. The family may
movewith 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 priorhome.
The PHA may deny permission to move to a new unit with continued voucherassistance:
• If the PHA has insufficient funding to provide continued assistance.
• In accordance with 24 CFR 982.638, regarding denial or termination ofassistance.
• In accordance with the PHA's policy regarding number of moves within a 12-month period.
The PHA must deny the family permission to move to a new unit with continued voucher rental assistance if:
• The family defaulted on an FHA-insured mortgage;and
• The family fails to demonstrate that the family has conveyed, or will convey, title to the home, as required by HUD,
to HUD or HUD's designee; and the family has moved, or will move, from the home within the period established or
approved by HUD.
Substantial Deviation
It is the intent and mission to adhere to the goals and objectives outlined in the five-year plan. Any modifications or
changes to the plan shall seek approval from HUD prior to implementation. A substantial deviation does not include any
changes in HU D regulations or notices.
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Sign ificant Amendment/Modification
In June 2013, the PHA was issued a Letter of Findings of Noncompliance with Title VI of the Civil Rights Act.The PHA has
since entered a Voluntary Compliance Agreement with HUD. HUD Letter of Findings identified:
• April 2008: Hiring of a police officer to serve as a Section 8 Investigator
• September 2009: Formation of a Safe CommunityTask Force to address the perception of increased crimein
Dubuque; crime study ordered by the City contracted to Alta Vista Research to focus on the connection between
crime and rental housing, specifically Section 8.
• November 2009: Crime study yielded that "persons arrested for criminal activities in Dubuque are no morelikely
to live in Section 8 Housing"; Administrative plan changed to allow opening and closure of wait list based on
number of individuals on the list, and to remove the very low income preference point allotment; alsoadopted
stronger eligibility and denial of assistance/termination requirements pertaining to conduct of all membersof
household to include juveniles;wait list was also restricted to only individuals who qualify for one of the local
residency preference points
• December 2009: Voucher issuance freeze in effect
• February 2010: City Council adopted recommendation to reduce vouchers to900
• November 2009-December 2010: Wait list purge of over 582 families, 66%of which were African American
• June 20-24, 2011: HUD onsite compliance review
• June 17, 2013: HUD issued Letterof 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 underTitle VI and its implementing regulations, as well as the City's AFFHobligations and
compliance with PIH Program Requirements.The City has already taken several steps to mediate the effects ofthe
activities, including:
• Local residency preference points were eliminated in December 2012. All local preference points wereremoved
in the proposed Administrative Policy approved by HUD as of February 27, 2015,
• Section 8 Investigator is no longer funded through supplemental Administrative Fees.
• The Administrative Plan has been updated /re-written to reflect the necessary changes as outlined in the VCA.
The Administrative Plan was submitted to HUD on December 18, 2014. Comments were received from HUD on
February 27, 2015. Additional changes to the Administrative Plan were submitted to HUD in March 2015to
address HAP shortfall funding for CY 2015 and future years based upon HUD Shortfall Teamrecommendations.
The newly revised Administrative Plan was discussed and reviewed by the Resident Advisory Board on
3/19/2015 and 4/16/2016. HUD granted approval of the Administrative Plan on 4/9/2015. The City ofDubuque
Housing Commission voted to approve and adopt the plan on 4/28/2015.The City Council voted to approveand
adopt the plan on 5/18/2015.
• Revision to the Administrative Plan Chapters 5 (Voucher size) and 16 (Voucher Payment Standards)was
submitted to HUD on September 16, 2015; approved by HUD on October 5, 2015; approved byHousing
Commission on October 27, 2015 and approved by City Council on November 16,2015.
• Revision to the Administrative Plan Chapters 5 (Briefing Attendance), Chapter 6 (Minimum Rent) and Chapterll
(PHA Initiated Interim Reexaminations) was submitted to HUDon December 1, 2015; approved by HUDon
12/10/2015;Approved by Housing Commission on 1/26/2016 and approved by City Council on 2/15/2016.
• Revision to the Administrative Plan Chapter4 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 HU D for review per the terms of the VCA.The Cityis working
with HU D to ensure consistency and comprehensive reporting
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• 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 fromthe
waiting list to either be issued vouchers or removed from the waiting list for reasons of non-responseor
ineligibility totaled 451 applications.
• The PHA needs additional funding to allow for lease up to the number of baseline voucher units of 1,063.Our
current lease-up rate is below our funding capacity and efforts to increase leasing began after Ju1y2015.
• The HA surveyed landlords on whether they accept the HCV for their rental units as part of theirrental license
renewal. To increase housing choice, outreach and education will then be targetedtowards the pool of
landlords who do not currently accept HCV.
• All Housing Department, Human Rights Department, Planning and Zoning Department, City Manager'sOffice
and Police Department staff inembers, City Council, Housing Commission, Long Range PlanningCommission,
Community Development Advisory Commission members, and the Mayor have received continual civil rights
and housing law training beginning in August 2014.
B.1. c
Deconcentratin¢ Policv
As part of the PHA's strategy to deconcentrate neighborhoods in poverty, HUD has approved exception rents in Census
Tracts 8.01, 8.02, 12.01, 12.02 and 12.03.The Voucher Payment Standards within the above census tracts will be set at
the 110% of the 50`h percentile published Fair Market Rents and will be adjusted on January 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, lowa area. The 70-unit building is located at 3390 Lake Ridge Drive, Dubuque,lowa.
Seventeen of the units are designated as Project-Based Voucher units.The site was selected topromote greater
housing choice opportunities and avoid undue concentration of assisted persons in areas containing a high proportion
of poverty.
The PHA will conduct owner outreach to ensure that owners are familiar with the program and its advantages.The PHA
will actively recruit property owners with property located outside areas of poverty and minority concentration.These
outreach strategies will include:
Distributing printed material about the program to property owners and managers
Contacting property owners and managers by phone or in-person
Holding owner recruitment/information meetings at least once a year
Participating in community based organizations comprised of private property and apartment ownersand
managers
Developing working relationships with owners and real estate brokers associations
Attending meetings with representatives of Dubuque Landlord Association
Outreach strategies will be monitored for effectiveness, and adapted accordingly.
Outreach Approach
The Housing and Community Development Department (HCDD) has identified its internal outreach objectivesas
outreach, advancement, and education. We believe that our programs can benefit everyone in our community.
- Developing a Voluntary Affirmative Outreach Plan for all housing development, rehabilitation,and
housing-related opportunities funded by the Community Development Block Grant Program
- Outlining an outreach program that includes special measures designed to attract those groups
identified as least likely to be reached through our traditional outreach methods, while also expandingefforts
designed to attract persons from the total population.
- Recognizing the community members already involved in any of our programs and encouraging themto
utilize all programs and services available.
Page 46 of 64
- 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 ofour
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, sexual orientation, gender identity, orfamilial
status; nor will any criteria be applied, nor information be considered, pertaining to attributes or behaviorthat
may be imputed by some to a group or category. All criteria applied and information considered in
administering this plan shall relate to the attributes and behavior of the individual members of thehousehold.
All activities and policies contained in this plan have been created to offer greater opportunities foraffordable
housing.
The PHA will not use any of these factors to:
• Deny to any family the opportunity to apply for housing, nor deny to any qualified applicant theopportunity
to participate in the housing choice voucher program
• Provide housing that is different from that provided to others
• Subject anyone to segregation or disparate treatment
• Restrict anyone's access to any benefit enjoyed by others in connection with the housing program
• 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 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 ofthe
housing program
• Discriminate in the provision of residential real estate transactions
• Discriminate against someone because they are related to or associated with a member of a protected class
• Publish or cause to be published an advertisement or notice indicating the availability of housingthat
prefers or excludes persons who are members of a protected class
Page 47 of 64
Outreach Method and Rationale
To ensure that information about our programs, specifically the Housing Choice Voucherand homeownership
programs, reaches a sufficient minority population to remedy in measurable 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 lowa, Illinois, Wisconsin, Minnesota, and
Missouri.
At 100 miles from Dubuque, the minority population is 4.6%, at 150 miles the minority population is 6.6%, and
at 200 miles the minority population is 11.3%. The following breakdown furtherexplains outreach strategy and
effectiveness.
Population by race/ethnicity 100 mile 150 mile 200 miles
Total population 3,085,573 11,231,124 20,026,130
White alone 88.8% 82.6% 77%
Blackalone 4.6% 6.6% 11.3%
Americanlndianalone 0.3% 0.4% 0.5%
Asian alone 1.9% 4.0% 3.8%
Hispanicorigin 5.7% 10.8% 12.7%
Some of the race alone 2.3% 4.3% 5.3%
Two or more races 2.0% 2.1% 2.1%
Diversity index 29.4 44.4 52.8
Notes:
• Persons of Hispanic origin may be of any race
• The diversity index measures the probability that two people from the same area will be from
different race or ethnic groups.
• Source US Census Bureau 2010 summary file ESRI forecast
This approach helps us to ensure we reach interstate minority populations to remedy previous actions that,as
outlined in the VCA, negatively impacted minority populations.The other reasoning is that a 200-mile radius
reaches an approximately three and a half to four-hour drive, which covers the interstate distances. We have
identified eight primary target groups/channels within this 200-mile radius where we will concentrate our
outreach efforts:
1. Public Housing Authorities: We selected public housing authorities (PHA) to provide outreachmaterials
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. Inmost
cases, these PHAs also operate the Housing Choice Voucher program or homeownership programs. We feel
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
today have consistent outreach programs with their membership and stakeholders that address issues inthe
Page 48 of 64
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 theircommunities.
3. Applicants purged from Dubuque's Housing Choice Voucher Waiting Lists between 2009 and 2011: In its
letterof findings to Dubuque, HUD found that the City's process of purging people from the waiting list resulted
in disparaging impact and kept people out of the program, specifically African-Americans. We contend 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 HousingChoice
Voucher Program. Adding this activity to the City's proposed activities would potentially reach families, manyof
whom are African American, in the interstate area who previously wanted to live in Dubuque.The PHA has 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 ofimproving
the economic impact and economic opportunities for minority individuals. Like the NAACP and othernonprofits,
they have in place a successful outreach system to communicate with their constituents. Our plan is tosolicit
the National Urban League to assist us in the distribution of information on Dubuque's housing opportunitiesto
their members and constituents. This information will explain specifically how to apply for the assisted housing
program in Dubuque and will include detailed information about all homeownership opportunities, classeson
improvement of credit and saving money, and information on down payment and closing cost assistancefor
first-time home buyers. Our information also highlights the many ways in which Dubuque is a good place tolive
and raise a family.
5. Social Media (i.e. Facebook and Twitter): Social media and mobile platforms, particularly Facebookand
Twitter, are very effective methods of sharing information and communicating with a variety ofaudiences,
including the populations we intend to reach through these outreach efforts. Because of the low cost involved it
is an especially popular communication source used by low-to moderate income populations. For this reason
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: Mobile phone and other wireless device applications are an
increasingly inexpensive and immediate way of communicating with people. As we communicate withour
current tenants, we are exploring options to allow them to access and share information concerninghousing
programs in Dubuque and homeownership opportunities. Additionally, we are expanding our rental assistance
software to allow for the electronic submission of applications for housing programs offered in Dubuque.
7. Language Translation:To insure our products and services are understood by the groupswe are
targeting, we will provide our outreach materials in English, Spanish, and Marshallese. We will makethem
available upon demand and we will also send them to our neighboring PHAs.
8. City of Dubuque Website:The City of Dubuque recently launched a new and improved website withnew
navigation and graphic design elements to better convey programs, information, services and emergency
support to our citizens. It is also an educational tool and resource management tool. We will enhancethe
existing information on the website about our Housing and Community Development programs. Theseefforts
will focus on the Housing Choice Voucher application and process as well as detailed informationabout
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 reachminority
populations. The City website has an electronic translation service called Google Translate so a person doesnot
need to know how to read English to read our website.
Page 49 of 64
The City of Dubuque has an affirmative responsibility to provide persons who are "limited English proficienY'
(LEP) equal opportunity for participation in the Assisted Housing Program. If any person is not fluent in English,
the Housing Authority will provide an interpreter or utilize a translation service at no cost to the LEP person.
The Housing Agency will take proactive steps to ensure the LEP person can understand the servicesand benefits
available.The HA will continually assess the language needs of program participants and those persons on the
waiting list to identify the needs of the population being served and resources available. If more than5% of the
population served or more than 100 persons are in a language group consisting of LEP persons, the HA shall
ensure vital documents are translated into the appropriate language. If less than the percentage or number of
persons served as stated above are in an identified language group, the HA will consider theexpenses of written
translations and implement if financially feasible. However, oral interpretations shall be offeredas stated above.
Case file information noting the language needs of each LEP applicant/participant shall be maintained in each
individual's file.
The PHA will analyze the various kinds of contacts it has with the public, to assess language needs anddecide
what reasonable steps should be taken. "Reasonable steps" may not be reasonable where the costs imposed
substantially exceed the benefits.
Where feasible, the PHA will train and hire bilingual staff or other known interpreters to be available to actas
interpreters and translators, will pool resources with other PHAs, and will standardize documents.Where
feasible and possible, the PHA will encourage the use of qualified communityvolunteers.
Where LEP persons desire, they will be permitted to use, at their own expense, an interpreter of theirown
choosing, in place of or as a supplement to the free language services offered by the PHA.The interpreter may
be a family member orfriend.
The PHA will provide written translations of vital documents for each eligible LEP language groupthat
constitutes 5 percent or 100 persons, whichever is less, of the population of persons eligible to be served or
likely to be affected or encountered. Translation of other documents, if needed, can be provided orally; orif
there are fewer than 50 persons in a language group that reaches the 5 percent trigger, the PHA does not
translate vital written materials, but provides written notice in the primary language of the LEP language group
of the right to receive competent oral interpretation of those written materials, free ofcost.
If it is determined that the PHA serves very few LEP persons, and the PHA has very limited resources, the PHA
will consider alternative ways to articulate in a reasonable manner a plan for providing meaningfulaccess.
Entities having significant contact with LEP persons,such as schools, grassroots and faith-based organizations,
community groups, and groups working with new immigrants will be contacted for input into theprocess.
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 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 assistance or
admission."
The PHA acknowledges that a victim of domestic violence, dating violence, or stalking may have anunfavorable
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 denyassistance to an applicant
family, the PHA will include in its notice of denial the VAWA information as defined by HUD and will request
Page 50 of 64
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 the
rehabilitation 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
Page 51 of 64
• 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
• 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
(FH EO).
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 lowa services (http://www.relaviowa.com/) will be
available.
To meet the needs of persons with vision impairments, large-print and audio versions of key program documents will be
made available upon request. When visual aids are used in public meetings or presentations, or in meetings with PHA
staff, one-on-one assistance will be provided upon request.
Additional examples of alternative forms of communication are sign language interpretation; having material explained
orally by staff; or having a third-party representative (a friend, relative or advocate, named by the applicant) or another
interpreter hired by the PHA to receive, interpret and explain housing materials and be present at all meetings.
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.
Page 52 of 64
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.
In order to determine the level of access needed by LEP persons, the PHA will balance the following four factors: (1) the
number or proportion of LEP persons eligible to be served or likely to be encountered by the Housing Choice Voucher
program; (2) the frequency with which LEP persons come into contact with the program; (3) the nature and importance
of the program, activity, or service provided by the program to people's lives; and (4) the resources available to the PHA
and costs. Balancing these four factors will ensure meaningful access by LEP persons to critical services while not
imposing undue burdens on the PHA.
The City of Dubuque has an affirmative responsibility to provide persons who are "limited English proficienY' (LEP) equal
opportunity for participation in the Assisted Housing Program. If any person is not fluent in English, the Housing
Authority will provide an interpreter or utilize a translation service at no cost to the LEP person. The Housing Agency will
take proactive steps to ensure the LEP person can understand the services and benefits available.The HA will continually
assess the language needs of program participants and those persons on the waiting list to identify the needs of the
population being served and resources available. If more than 5% of the population served or more than 100 persons are
in a language group consisting of LEP persons, the HA shall ensure vital documents are translated into the appropriate
language. If less than the percentage or number of persons served as stated above are in an identified language group,
the HA will consider the expenses of written translations and implement if financially feasible. However, oral
interpretations shall be offered as stated above. Case file information noting the language needs of each LEP
applicant/participant shall be maintained in each individual's file.
The PHA will analyze the various kinds of contacts it has with the public, to assess language needs and decide what
reasonable steps should be taken. "Reasonable steps" may not be reasonable where the costs imposed substantially
exceed the benefits.
Where feasible, the PHA will train and hire bilingual staff or other known interpreters to be available to act as
interpreters and translators, will pool resources with other PHAs, and will standardize documents. Where feasible and
possible, the PHA will encourage the use of qualified community volunteers.
Where LEP persons desire, they will be permitted to use, at their own expense, an interpreter of their own choosing, in
place of or as a supplement to the free language services offered by the PHA.The interpreter may be a family member or
friend.
The PHA will provide written translations of vital documents for each eligible LEP language group that constitutes 5
percent or 100 persons, whichever is less, of the population of persons eligible to be served or likely to be affected or
encountered. Translation of other documents, if needed, can be provided orally; or
If there are fewer than 50 persons in a language group that reaches the 5 percent trigger, the PHA does not translate
vital written materials, but provides written notice in the primary language of the LEP language group of the right to
receive competent oral interpretation of those written materials, free of cost.
If it is determined that the PHA serves very few LEP persons, and the PHA has very limited resources, the PHA will
consider alternative ways to articulate in a reasonable manner a plan for providing meaningful access. Entities having
significant contact with LEP persons, such as schools, grassroots and faith-based organizations, community groups, and
groups working with new immigrants will be contacted for input into the process.
Page 53 of 64
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.
In creating policy, the PHA has reviewed practices, performed a comprehensive examination of the way services are
delivered and considered the impacts of all marketing and outreach efforts to ensure full compliance with civil rights laws
and to ensure access by all eligible applicants/participants.
The PHA shall make good faith efforts to carry out the Program Outreach and Affirmative Fair Housing Marketing Plan
and Procedures.
The PHA shall identify the segments of the eligible population which are least likely to apply for housing. The PHA has
created an outreach program which includes special measures designed to attract those identified as least likely to apply
and to create opportunities for all. Special outreach efforts include direct marketing to increase participation by minority
populations as identified in the Executive Summary beginning on page 1. Effort will be made to communicate in writing
and/or verbally with contact sources and to develop positive relationships and obtain referrals to attract targeted groups
to diversify the housing community. To track outreach efforts, the application for assisted housing shall include a
question asking the applicant how the applicant became aware of the program and if the applicant is aware of outreach
efforts performed by the City.
HUD Fair Housing Posters or Brochures in English, Spanish and Marshallese shall be available if obtainable from HUD and
displayed for public review at the PHA office. All brochures, signs and posters are an integral part of the affirmative
marketing effort and shall be consistent with Fair Housing Rules and Regulations. The PHA shall make all primary
brochures available in English, Spanish and Marshallese. Primary brochures are brochures provided to the public
advising of program availability, such as, brochures describing eligibility guidelines and application procedures.
The PHA has identified several organizations to intentionally market programs to ensure families are familiar with
opportunities for participation in the HCV programs. Organizations include but are not limited to churches, schools,
clinics, service agencies, hospitals and grocery stores.
The PHA shall also use social media and attend expos/events within the community, and extend marketing to include a
200-mile radius from the City.
PHA staff shall reach out to community contacts to supplement formal communications media for public awareness of
availability of HCV programs.
Outreach to property owners is done through staff attendance at the Dubuque Crime-Free Multi-Housing Program. The
Dubuque Successful Rental Property Management provides property owners comprehensive information on all aspects
of managing rental housing. The program is offered at least twice per year. The presenters include local attorneys and
representatives from the City of Dubuque's Police, Fire, Human Rights, Legal and Housing Departments. Additionally,
staff ineets with Landlord Association Board members monthly. Property Owners are encouraged to list available units
Page 54 of 64
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.citvofdubuque.or�/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. Most Recent Fiscal Year Audit
The most recent audited report approved by HU D is the financial information for the fiscal year ending 06/30/2015.
The U.S. Department of Housing and Urban DevelopmenYs Office of Public and Indian Housing— Real Estate
Assessment Center(PIH-REAC) Public Housing Financial Assessment (FASS-PH) team has reviewed and accepted the City
of Dubuque submission. See Attachment A for Financial Reports.The City has submitted the fiscal year ending
06/30/2017 financial information that is currently being reviewed byHUD.
B.5 Progress Report
Goal: Increase homeownership among minority voucher participants and to non-minority voucher participants
In FY 2017 (July, 2016 through June 30, 2017), five new households became homeowners with assistance from the
Housing Choice Voucher Program.
Primary Race Total Families %
White 5 100%
The City of Dubuque Housing & Community Department offers a Home Ownership Made Easy (HOME) Workshop. This
workshop provides information on City of Dubuque homeownership/rehabilitation programs, budgeting, financing,
maintenance, and energy efficiency of a home.
Page 55 of 64
Goal: To promote fair housing opportunity
The June 2016 composition head of household participants for the HCV Program:
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 Pacifc 13 1.49%
Islander
Total (Non Hisp)Families: 875 100.00%
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%
The June 2017 composition of head of household participants for the HCV Program:
Primary Race Total Families %
White 476 57.42%
Black/African American 334 40.29%
American Indian/Alaska Native 3 0.36%
Asian 3 0.36%
Native Hawaiian/Other Pacifc 13 1.57%
Islander
Total (Non Hisp)Families: 829 100.00%
Status Total Members %
Non Elderly/Non Disabled 436 52.59%
Elderly/Non-Disabled 70 8.44%
Non Elderly/Disabled 235 28.35%
Elderly/Disabled 88 10.62%
Total Members: 829 100.00%
Page 56 of 64
Goal: Target Available assistance to families at or below 30%of AMI
In Fiscal Year 2017 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 Ieast 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 HU D, 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 Ieast 75% of households admitted into the program during the year
must be extremely low income.
Page 57 of 64
Goal: Ensure equal opportunity in Housing for all eligible families and affirmatively further fair housing.
As of January 2018, the demographics of households assisted are below:
Participant Statistical Summary Housing Choice Voucher
Effecti� �ate: January 1, 2018
Prepared by: Teresa Bassler
Date Prepared: ozizoizo�s
- - • - - -
Household Size Total Farrilies % Cltizenship Total %
Merrbers
1 381 45.74% Ineligible NonCltizen 0 0.00%
2 153 18.37% 9igible Citizen 831 99.76%
3 121 14.53% 9igible NonCltizen 2 0.24%
4 80 9.60% Total Cltizenships: 833 100.00%
5 55 6.60%
6 27 3.24%
7 8 0.96%
8 or more 8 0.96%
Total Farrilies: 833 100.00%
Rirttary Race(Non Hispanic) Total Farrilies % Hhnicity Total %
Farrilies
American Indian/Alaska Native 2 0.24% Hispanic 12 1.44%
Asian 3 0.36% Non Hispanic 821 98.56%
BIacWAfrican American 343 41.18% Total Families: 833 100.00%
Native Hawaiian/Other Pacific Islander 15 1.80%
White 470 56.42%
Total Families: 833 100.00%
Page 58 of 64
- - - •- - - - -
Gross Income Total % Number Total Families %
Families Dependents/Childre
n
0-4,999 179 21.49% 0 420 50.42%
5,000-9,999 265 31.81% 1 136 16.33%
1Q000- 14,999 178 21.37% 2 112 13.45%
15,000- 19,999 101 12.12% 3 88 10.56%
2Q000-24,999 55 6.60% 4 42 5.04%
25,000-34,999 48 576% 5 23 276%
35,000-44,999 7 0.84% 6 7 0.84%
45,000- 0 0.00% 7 or more 5 0.60%
999,999
Total Families: 833 100.00% 833 100.00
Total Families %
Status Total • % Size Total %
Member Families
s
Non 429 51.50% 1 386 46.34%
Elderly/Non
Disabled
Elderly/Non- 68 8.16% 2 238 28.57%
Disabled
Non 239 28.69% 3 161 19.33%
Elderly/Disable
d
Elderly/ 97 11.64% 4 40 4.80%
Disabled
Total 833 100.00% 5 8 0.96%
Members:
Total Families: 833 100.00
%
Goal: Increase assisted housing choices
Progress/Achievement: The City continues to offer HU D approved exception rent areas to voucher holders, which
allow families to live in higher cost areas to expand choice and deconcentrate poverty. Twice per year, staff present to
area landlords at the Successful Rental Property Management Program aboutthe process and benefits of renting to
voucher holders. Additionally, staff ineets with members of the Landlord's Association monthly. The PHA has launched
a new interactive Landlord Portal in January 2015 to make information about payments, inspections, and licensing
more readily available to them. Landlords can also manage their unit vacancy and addtheir units to the Vacant Unit
listing that is made available in the PHA office. The City activated Applicant Portal with a Participant Portal for
applications and to follow for ease of use for the 2018 waiting list opening.
Page 59 of 64
B.6 Resident Advisory Board (RAB)Comments
Resident Advisory Board Meeting Minutes
3/21/18
Present: Pattie Breitbach &Janet Veach
Staff: Cate Ritcher
Dawn DeMaio
Erica Haugen
Presenters: Cate Ritcher & Erica Haugen
Cate welcomed to the group and began her updates about things happening in the City of Dubuque's Housing
Department. Starting with the waiting list, she informed everyone that the old wait list has about 132 people left and we
would be pulling from that again soon and start leasing people up. Janet Veach asked how long the typical wait has been
for people to get on the program and Cate responded with 2-5 years.Janet commented that 2-5 years is a long wait! Cate
also let them know that the 1,000 names from the recent waiting opening have been selected by lottery draw and
applicants are able to call or go on line to find out if they were selected.
Next line of business discussed was the changes in wording in the Housing Administrative Plan. Cate informed Janet and
Pattie that we now have it noted that individuals can request an interpreter and we will supply that for them as needed.
Second change addressed was that we now plan to use 98%of vouchers or 98% of the budget allowed. Last item
discussed was the required changes HUD has put into place for distribution of the VOWA paperwork to clients. There
were no questions or comments from Janet or Pattie.
Short Fall was the final item Cate had to discuss with the group. She informed everyone that we currently have
restrictions up for unit changes and were not allowing participants to move into more expensive units. Also noted was
that we were not allowing port outs unless the receiving HA was absorbing. Janet asked how this happens and if it was
the first time?Cate responded that it can happened when we are paying a lot out on behalf of clients and when we have
a lot of vouchers we are being billed for in port out situations. She added that this was not the first time this has
occurred.
Cate then opened up discussion about some options for the Housing Department to consider for income changes, which
might help life the Short Fall restrictions.The implementation of doing interim income changes. She said there are a few
ways we could do this and she asked for inpute.
1) Process all changes of income within 90 days of its start date
2) Only process those over$200
3) Only process changes when iYs a new source of income (ex. New job, new child support, or SSI)
Cate asked for thoughts and commented that she had never heard of option 3 until it was talked about at a recent
training she attended.Janet spoke up and said she liked the thought of only doing the 3rd option, only new income, she
said it might be a little softer hit for those on the program. IYs a middle ground and stated it is a good compromise, it's
workable and the best option. Dawn asked Pattie what her thoughts were and she agreed with option 3.
When Cate was finished with the materials she had to discuss with the RAB Erica joined the conversation to discuss the
Annual Plan. She went through the materials and covered the main highlights of the plan. She requested any comments
Page 60 of 64
that could be offered as she went through the document. In going over the plan on Section 504 Needs Assessment Janet
commented that she feels there is a bias out there- "I can see no smoking, no pets, but no housing!?That doesn't make
sense, what harm does housing do?" Erica stated that it would be great if Janet attended the Housing Commissions
Meeting. Pattie then commented that she has lived in her unit for 17 years, she thinks she is an ideal tenant and she has
a voucher.
There were no other comments made throughout the rest of the presentation of the Annual Plan. Erica
told Janet and Pattie that she knows there is a lot of information within the Annual Plan and said she would complete
follow up calls with them prior to the Commissions meeting to get any additional thoughts or comments from them. The
meeting was closed when there were no further comments. Dawn informed the group that at this time a date for the
next RAB is undecided, but they would receive a post card invite when the next one will be held.
Recorded By: Dawn DeMaio
Page 61 of 64
Attachment A: Statement of Financial Resources
City of Dubuque (IA08'�
Dubuque, IA
Entity Wide Balance Sheet Summary
SUBMISSION TYPE: AUDITED/SINGLE AUDIT Fisca�YeaR EN�: 6/30/2017
14.856 Lower
IncomeHousing
14.871 Housing Assistance
Choice Vo�chers Tohel
Rograrn_Section 8
Moderate
111Cash-Unrestricted $0 $182,846 $182,846
113Cash-OtherRestricted $140,744 $0 $140,744
100 Total Cash $140,744 $182,846 $323,590
125 AccountsRueivable-Miscellaneous $5,475 $0 $5,475
128 Fraud Ruovery $66,698 $1,277 $67,975
128.1A11owanceforpoubtfulAccounfs-Fraud -$2Q009 g0 -$2Q009
179AccruedInterestRueivable $283 $0 $283
120 TotalReceivables,NetofAllowancesforpoubtCulAccounfs $52,447 $1,277 $53,724
142 Repaid Fxpenses and Other AssGs $365,515 $5,339 $37Q854
150 TotalCmrentAssGs $558,706 $189,462 $74$168
90 TotalAssGsandDefe�redOutflowofResouroes $558,706 $189,462 $74$168
12AccounfsPayable<=90Days $2,663 $0 $2,663
21 Accrued Wage/Payroll Taxes Payable $2Q614 $0 $2Q614
31 Accounfs Payable-H[JD PHA Programs $2,499 $3,227 $5,726
42 UneamedRevenue $6,085 $0 $6,085
10 TotalCmrentLiabilities $31,861 $3,227 $35,088
53Non-cmrentLiabilities-Otlier $176,728 g0 $176,728
SOTotalNon-CmrentLiabilities $176,728 g0 $176,728
00 Total Liabilities $20$589 $3,227 $211,816
093RestrictedFundBalance $20$112 $0 $20$112
113AssignedFundBalance $142,005 $186,235 $32$240
13 TotalFquiry-NetAssGs/Position $35Q117 $186,235 $536,352
00 Total Liabilities,Defe�red Inflows ofResouroes and Equiry $558,706 $189,462 $74$168
Page 62 of 64
Entity Wide Revenue and Expense Summary
SUBMISSION TYPE: AUDITED/SINGLE AUDIT Fisca�YeaR EN�: 6/30/2017
14.856 Lower
IncomeHousing
14.871 Housing Assistance
Choice Vo�chers Tohel
Rograrn_Section 8
Moderate
0600 H[JD PHA Operating Grants $5,6M,309 g���gq $5,682,093
1100InvestrnentIncome-Unrestricted $1,792 $0 $1,292
1400 FraudRuovery $1Q056 $0 $1Q056
1500 OtherRevenue $3Q141 $0 $3Q141
0000 TotalRevenue $5,6{5,798 $777gq $5,723,582
1100AdministrativeSalaries $491,375 $q,964 $496,339
1200AuditingFees $1,300 $0 $1,300
1500FanployeeBenefitcontributions-Administrative $217,126 $2,193 $219,319
1600 OfficeExpenses $7Q6{9 $722 $71,371
1800Travel $144 $1 $145
1900 O�her $25,840 $261 $26,101
1000TotalOperating-Administrative $806,434 $g,141 $814,575
4300 Ordinazy Maintenance and Operations Contracts $25,6{6 $259 $25,905
4000 TotalMaintenance $25,6{6 $259 $25,905
6110 Roperty Insurance $773 $g $�gi
6120LiabiliryInsurance $137 $1 $138
6130 Worl�nen's Compensation $1,699 $17 $1,716
6100TotalinsuranceRemiums $2,609 $26 $2,635
6200 O�her General Expenses $13,976 $g5 $14,061
6000 Total OtherGeneralFxpenses $13,976 $g5 $14,061
6900 TotalOperatingFxpenses $84$665 $g,511 $857,176
7000FxcessofOperatingRevenueoverOperatingExpenses $4,797,133 $69,273 $4,866,406
7300HousingAssishencePayments $4,753,145 $66,907 $4,82Q052
7350 HAP Portabiliry-In $726 $0 $726
0000 TotalExpenses $5,602,536 $75,418 $5,677,954
10030 Operating Transfers from/W Primazy Govemment $86,801 g0 $86,801
ioiooToe�iou,�s�����gso�«��us�� �se,soi $o �se,soi
i0000���s�es����y�ofToe�ixeo��eoo��u�a��Toe�iE�,�s� �isqobs gz,see �isz,aas
(continued)
Page 63 of 64
EntiTy Wide Revenue and Expense Summary(Continued)
SUBMISSION TYPE: AUDITED/SINGLE AUDIT Fisca� YeaR EN�: 6/30/2017
14.856 Lower
IncomeHousing
14.871 Housing Assishence Total
Choice Vo�chers p�ograrn_Sution 8
Moderate
11030 BeginningEquiry $22Q054 $183,869 $403,923
11170AdministrativeFeeEquiry $142,005 $0 $142,005
11180HousingAssistancePaymentsEquiry $208,112 $0 $208,112
11190 UnitMonthsAvailable 12864 168 13032
11210 Number of Unit Months Leased 10708 163 10871
Page 64 of 64
C.1V11 �g�1tS �,eYtl�lC�t1011 U.S.Department of Housing and Urban Development '
Office of Public and Indian Housing
(�uali�ed I'I�As) OMB Approval No.2577-0226
Expires 02129/2016 '
Civil Rights Certi�cation
Annual Certification and Board Resol�tion
Acting on behalf of the Boa�^d of Commissioners of the Public Housing Agency(PHA)listed below, as its Chairmc�n or other ',
czuthorized PHA officic�l, I ccppNove the submission of the S-Yec�r PHA Plc�n foN the PHA of which this document is a part, and mczke the
following certificc�tion and c�greements with the Depc�rtment of Housing ancl Urbczn Development(HUD) in eonneetion with the
szcbmission of the public housing progrc�nz of the crgency ancl implementcction thereof
The PHA certifies that it will carry out the public housing program of the agency in conformity with title VI of
the Civil Rights Act of 1964, the Fair Housing Act, section 504 of the Rehabilitation Act of 1973, and title II of
the Americans with Disabilities Act of 1990, and will affirmatively further fair housing by examining their
programs or proposed programs, identifying any impediments to fair housing choice within those program, ';
addressing those impediments in a reasonable fashion in view of the resources availabie and working with local
jurisdictions to implement any of the jurisdiction's initiatives to affinnatively further fair housing that require
the PHA's involvement and by maintaining records reflecting these analyses and actions.
City of Dubuque IA087
PHA Name PHA NumberlHA Code
I hereby cettify that all the infoi7nation stated herein,as well as any infoiYnation provided in the accompaniment herewith,is tnte and acctu•ate.Waruing: HUD will
prosecttte false cllims and statements.Conviction mav result in ctiminal and/or civil penalties. (18 U.S.C. 1001,101O,1012;31 U.S.C.3729,3802)
Name of Authorized Officiat Title
Alexis Steger Acting Housing& CD Director
i
Signature ��ly;;•-ay� // ..m. �fP,,_.......,,,_.... Date �y�//1��f/���
I'�� � �r /
1 �
Previous version is obsolete Page 1 of 1 form HUD-50077-CR(2l2013)