Public Housing Authority (PHA) Administrative Plan Amendment Copyrighted
J une 3, 2019
City of Dubuque Consent Items # 9.
ITEM TITLE: Public HousingAuthority (PHA)Administrative Plan
Amendment
SUMMARY: City Manager recommending approval of a Resolution
accepting the amendments to the Housing Choice Voucher
Administrative Plan, which have previously been approved
by the Resident Advisory Board and the Housing
Commission.
RESOLUTION Approving amendments to the Housing
Choice VoucherAdministrative Plan
SUGGESTED DISPOSITION: Suggested Disposition: Receive and File; Adopt
Resolution(s)
ATTACHMENTS:
Description Type
Housing Choice Voucher Administrati� Plan Changes- City Manager Memo
MVM Memo
Staff Memo Staff Memo
Resolution Approving Plan Amendment Resolutions
ExhibitA: Administrati� Plan Changes Supporting Documentation
THE CTTY OF Dubuque
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Masterpiece on the Mississippi Z°°' Z°'Z
2013 2017
TO: The Honorable Mayor and City Council Members
FROM: Michael C. Van Milligen, City Manager
SUBJECT: Proposed Administrative Plan Changes for Housing Choice Voucher
Program for City Council Approval
DATE: May 29, 2019
Housing and Community Development Director Alexis Steger recommends City Council
approval of a Resolution accepting the amendments to the Housing Choice Voucher
Administrative Plan, which have previously been approved by the Resident Advisory
Board and the Housing Commission.
The proposed amendment to the Administrative Plan makes changes to Chapter 4 of
the plan.
Chapter 4 "Applications, Waiting List and Tenant Selection" proposed change will open
the Housing Choice Voucher waiting list when it is reduced to less than 50 applications,
on the 2"d Tuesday of each month. However, if the need identified for the month is
greater than 50 applicants, the waiting list may be reopened. A lottery system will be
used to determine which applicants are placed on the waiting list. The Public Housing
Authority will select households from the waiting list based on date and time of
applications.
Moving to a monthly opening of the Housing Choice Voucher waiting list will allow the
list to remain current. Only opening the list about every 18 months has caused the list
to be old, with outdated applicant information. Ninety percent of people being pulled
from the current waitlist are unable to be located/contacted and, therefore, do not
receive the opportunity to qualify for a voucher. Opening the list monthly also allows
those that were on the list, but unable to be contacted, to get back on the waiting list in
a shorter amount of time.
Additionally, being able to have a higher success rate when pulling applicants from the
waiting list, will lessen the administrative burden on staff, allowing them to focus efforts
on casework and meeting the needs of those already issued vouchers.
The previous policy allowed for a seven-day period for receipt of applications once the
current waiting list is at or below 200 applicants. Once the waiting list is completely
exhausted, one thousand applicants were to be selected to be placed on the waiting list
using the lottery system.
A lottery system will still be used to select the applicants who will be placed on the
waiting list once a month. However; when the applicants are pulled from the waiting list
to work through the process of receiving a voucher, they will be pulled by date and time
of their application for the waiting list. This ensures a lottery system is still used, but the
list remains as up to date as possible with client information.
HUD no longer requires Bi-Annual Waiting List Reports for the remainder of the
Voluntary Compliance Agreement. Due to this, the plan was also updated to remove
the requirement of submitting a bi-annual waiting list report for tracking applicants that
were denied admission to the program or placement on the waiting list. This information
can still be collected, but is not mandatory.
I concur with the recommendation and respectfully request Mayor and City Council
approval.
�� Y i1�7�,Rr��.
Mic ael C. Van Milligen
MCVM:jh
Attachment
cc: Crenna Brumwell, City Attorney
Teri Goodmann, Assistant City Manager
Cori Burbach, Assistant City Manager
Alexis M. Steger, Housing and Community Development Director
2
Dubuque
THE CITY OF
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Masterpiece on the Mississippi �
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TO: Michael C. Van Milligen, City Manager
FROM: Alexis M. Steger, Housing and Community Development Director
DATE: May 29, 2019
RE: Proposed Administrative Plan Changes for Housing Choice Voucher
Program for City Council Approval
Introduction
The purpose of the memorandum is to request the City Council's approval of the
attached resolution approving changes to the Housing Choice Voucher (HCV)
Administrative Plan.
Background
Federal regulations require Housing Authorities to prepare and maintain an
Administrative Plan. The authority for Public Housing Authority policies is derived from
federal statutes, federal regulations, guidance issued by HUD, state law, and local
policy.
Changes to the administrative plan require review by the Resident Advisory Board,
followed by the City's Housing Commission for public comment and approval, and to the
City Council for final approval. After City Council approval, the City will fully adopt and
implement the amended Administrative Plan.
Discussion
The proposed amendment to the Administrative Plan makes changes to Chapter 4 of
the plan. Chapter 4 with red-line changes are included in Exhibit A.
Chapter 4 "Applications, Waiting List and Tenant Selection" proposed change will open
the HCV waiting list when it is reduced to less than 50 applications, on the 2nd Tuesday
of each month. However, if the need identified for the month is greater than 50
applicants, the waiting list may be reopened. A lottery system will be used to determine
which applicants are placed on the waiting list. The Public Housing Authority will select
households from the waiting list based on date and time of applications.
Moving to a monthly opening of the HCV waiting list will allow the list to remain current.
Only opening the list about every 18 months, has caused the list to be old, with outdated
applicant information. 90% of people being pulled from the current waitlist are unable to
be located/contacted and therefore do not receive the opportunity to qualify for a
voucher. Opening the list monthly also allows those that were on the list, but unable to
be contacted, get back on the waiting list in a shorter amount of time.
Additionally, being able to have a higher success rate when pulling applicants from the
waiting list, will lessen the administrative burden on staff. Allowing them to focus efforts
on casework and meeting the needs of those already issued vouchers.
The previous policy allowed for a seven-day period for receipt of applications once the
current waiting list is at or below 200 applicants. Once the waiting list is completely
exhausted, one thousand applicants were to be selected to be placed on the waiting list
using the lottery system.
A lottery system will still be used to select the applicants who will be placed on the
waiting list once a month. However; when the applicants are pulled from the waiting list
to work through the process of receiving a voucher, they will be pulled by date and time
of their application for the waiting list. This ensures a lottery system is still used, but the
list remains as up to date as possible with client information.
HUD no longer requires Bi-Annual Waiting List Reports for the remainder of the
Voluntary Compliance Agreement. Due to this, the plan was also updated to remove
the requirement of submitting a bi-annual waiting list report for tracking applicants that
were denied admission to the program or placement on the waiting list. This information
can still be collected, but is not mandatory.
Commission Action
The Resident Advisory Board reviewed and approved the changes to the administrative
plan on May 22, 2019.
The Housing Commission reviewed and approved the proposed amendments at the
May 28, 2019 meeting.
Action Step
I respectfully request the City Council approve the attached resolution, accepting the
amendments to the Housing Choice Voucher Administrative Plan.
2
RESOLUTION NO. 201-19
RESOLUTION APPROVING AMENDMENTS TO THE HOUSING CHOICE VOUCHER
ADMINISTRATIVE PLAN
Whereas, the City of Dubuque is designated as a Public Housing Authority; and
Whereas, the City of Dubuque maintains a comprehensive Public Housing Agency
Plan; and
Whereas, the City of Dubuque desires to amend said Public Housing Agency Plan;
and
Whereas, said amendments are approved by Resident Advisory Board and the
Housing Commission, the amendments must be approved by resolution of the City
Council for adoption and implementation; and
Whereas, the Housing Commission held a public meeting on May 28, 2019; and
Whereas, the Housing Commission voted to approve said amendments to Chapter 4
and recommended approval by the City Council.
NOW THEREFORE, BE IT RESOLVED BY THE CITY COUNCIL OF THE CITY OF
DUBUQUE, IOWA:
That the Housing Choice Voucher Administrative Plan is hereby amended to adopt the
changes to the Plan to open the HCV waiting list when it is reduced to less than 50
applications, on the 2nd Tuesday of each month. However, if the need identified for the
month is greater than 50 applicants, the waiting list may be reopened. A lottery system
will be used to determine which applicants are placed on the waiting list. The PHA will
select households from the waiting list based on date and time of applications.
Removal of the requirement of submitting a bi-annual waiting list report for tracking
applicants that were denied admission to the program or placement on the waiting list,
attached hereto as Exhibit A and Chapter 4.
Passed, approved and adopted this 3rd day of June 2019
Attest:
Kevin(Fi nstahl, ity C erk
Roy D Buol, Mayor
EXHIBIT A
Chapter 4
APPLICATIONS, WAITING LIST AND TENANT SELECTION
INTRODUCTION
When a family wishes to receive assistance under the HCV program,the family must submit an
application that provides the PHA with the information needed to determine the family's
eligibility. HUD requires the PHA to place all families that apply for assistance on a waiting list.
When HCV assistance becomes available, the PHA must select families from the waiting list in
accordance with HUD requirements and PHA policies as stated in the administrative plan and the
annual plan.
The PHA is required to adopt clear policies and procedures for accepting applications, placing
families on the waiting list, and selecting families from the waiting list, and must follow these
policies and procedures consistently. The actual order in which families are selected from the
waiting list can be affected if a family has certain characteristics designated by HUD or the PHA
that justify their selection. Examples of this are the selection of families for income targeting and
the selection of families that qualify far targeted funding.
HUD regulations require that all families have an equal opportunity to apply for and receive
housing assistance, and that the PHA affirmatively further fair housing goals in the
administration ofthe program [24 CFR 982.53, HCV GB p. 4-1]. Adherence to the selection
policies described in this chapter ensures that the PHA will be in compliance with all relevant
fair housing requirements, as described in Chapter 2.
This chapter describes HUD and PHA policies for taking applications, managing the waiting list
and selecting families for HCV assistance. The policies outlined in this chapter are organized
into three sections, as follows:
Part L The Application Process. This part provides an overview of the application
process, and discusses how applicants can obtain and submit applications. It also
specifies how the PHA will handle the applications it receives.
Part IL Mana�in�the Waitin�List. This part presents the policies that govern how the
PHA's waiting list is structured, when it is opened and closed, and how the public is
notified of the opportunity to apply for assistance. It also discusses the process the PHA
will use to keep the waiting list current.
Part IIL Selection for HCV Assistance. This part describes the policies that guide the
PHA in selecting families for HCV assistance as such assistance becomes available. It
also specifies how in-person interviews will be used to ensure that the PHA has the
information needed to make a final eligibility determination.
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PART L• THE APPLICATION PROCESS
4-LA. OVERVIEW
This part describes the PHA policies for making applications available, accepting applications
making preliminary determinations of eligibility, and the placement of applicants on the waiting
list. This part also describes the PHA's obligation to ensure the accessibility of the application
process to elderly persons, people with disabilities, and people with limited English proficiency
(LEP).
4-LB. APPLYING FOR ASSISTANCE [HCV GB, pp. 4-11 —4-16, Notice PIH 2O09-36]
Any family that wishes to receive HCV assistance must apply for admission to the program.
HUD permits the PHA to determine the format and content of HCV applications, as well how
such applications will be made available to interested families and how applications will be
accepted by the PHA. The PHA must include Form HUD-92006, Supplement to Application for
Federally Assisted Housing, as part of the PHA's application.
PHA Policv
Historical Information
On March 31, 2014 the City of Dubuque, Iowa and the U.S. Department of Housing and
Urban Development(HUD) entered into a Voluntary Compliance Agreement outlining
remedies to address the findings of noncompliance identified in HUD's letter to the City
dated June 17, 2013. In its letter of findings to the City, HUD found that the City's
process of purging applicants from the waiting list resulted in disparaging impact and
kept people out of the program, specifically African-Americans. The City contends there
was no such intent with this process; however, did agree to notify all applicants on the
waiting list in November and December 2009 to invite all applicants to apply. On April
9, 2015 HUD granted permission to close the HCV waiting list effective April 30, 2015.
As of April 1, 2015, the HCV waiting list consisted of 1500 applicants. As of April
2016,the HCV waiting list consisted of 466 applicants. In Apri12016, 1021 applicants
from the November and December 2009 "purge group"were notified and invited to apply
for the HCV waiting list. Upon exhaustion of the current HCV waiting list, the
applicants invited to apply who responded were placed on a special HCV waiting list
which was processed priar to opening the HCV waiting list for applications as described
in this chapter utilizing the marketing and outreach plan identified in the Administrative
Plan.
Proaram Snecific Waitin�List
The City of Dubuque shall maintain waiting lists for the Moderate Rehabilitation
Program;the Project Based Voucher Program and the Housing Choice Voucher Program.
Pre-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
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the Mod Rehab program from its waiting list to the owner. Owners select a family for
occupancy of a particular 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 Proeram Waitine 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 according to the very low-income
guidelines. The project-based voucher units are designated for occupancy by elderly or
disabled families requiring assisted living services. Prior to and as a condition of
occupancy, the Owner or its designated service provider shall evaluate the proposed
applicanYs status to determine the qualification for residency of the assisted living
facility. When vacancies occur in the project-based voucher program, the City refers
income eligible families for participation in the project-based voucher program from its
waiting list to the owner. The owner selects a family for occupancy of a particular 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 List(s):
The City of Dubuque shall open the Housing Choice Voucher waiting list when it is
reduced to less than 50 applications, on the 2°d Tuesday of each month. However, if the
need identified for the month is greater than 50 applicants, the waiting list may be
reopened with more than 50 applicants on the waiting list. The current(Established Feb.
2018)waiting list will be completely exhausted prior to selecting applicants from the new
waiting list. The new HCV waiting list will be opened to accept applications for one (1)
calendar 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, the number of
applicants selected to be placed on the waiting list will be determined based on
anticipated need of applicants using HUD's two-year tool. Only the head of household
should apply. Duplicate applications will not be allowed. Each household has an equal
chance of being selected. Applicants that are not selected to be placed on the waiting list
will be notified and will need to re-apply to the waiting list the neat time the waiting list
is open.
The family will be required to provide all of the information necessary to establish final
family eligibility and level of assistance when the family is selected from the waiting list.
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When the waiting list is open, individuals/families may obtain pre-application forms from
the PHA's office during normal business hours or may complete online applications at
the City of Dubuque website at www.cityofdubuque.org/hcv. Applicants may also
request—by telephone, mail or e-mail—an application be sent to them via first class mail
or FAX or e-mail.
Applications must be received during the time the waiting list is open to the general
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 one (1) calendar
day with the last day of acceptance on a business day to allow applicants the opporiunity
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 seven (7)
calendar days to correct the deficiency. Reasonable efforts shall be in the form of one
letter, one telephone call or one 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 period specified or any ea�tensions 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 select a number of 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 from the HCV waiting list based on date and
time of application. The applicants selected from the waiting list 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 in order 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
completely 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
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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 priar 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 additiona190-day
ea�tension 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 applicant family fails to produce the required documentation/verification required
within the allotted time period as stated above, the PHA shall follow the policies as stated
in Chapter 3, Part IIL Denial of Assistance if the applicant has not become a participant
ofthe program or Chapter 12, 12-LD. Mandatory Termination of Assistance ifthe
applicant has been admitted to the program.
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 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 period specified or any
ea�tensions 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 aYtempts to
contactthe applicant.
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4-LC. ACCESSIBILITY OF THE APPLICATION PROCESS
Elderly and Disabled Populations [24 CFR 8 and HCV GB, pp. 4-11 —4-13]
The PHA must take steps to ensure that the application process is accessible to those people who
might have difficulty complying with the normal, standard PHA application process. This could
include people with disabilities, certain elderly individuals, as well as persons with limited
English proficiency(LEP). The PHA must provide reasonable accommodation to the needs of
individuals with disabilities. The application-taking facility and the application process must be
fully accessible, or the PHA must provide an alternate approach that provides full access to the
application process. Chapter 2 provides a full discussion of the PHA's policies related to
providing reasonable accommodations for people with disabilities.
Limited English Proficiency
PHAs are required to take reasonable steps to ensure equal access to their programs and activities
by persons with limited English proficiency [24 CFR 1]. Chapter 2 provides a full discussion on
the PHA's policies related to ensuring access to people with limited English proficiency (LEP).
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4-LD. PLACEMENT ON THE WAITING LIST
The PHA must review each complete application received and make a preliminary assessment of
the family's eligibility. The PHA must accept applications from families for whom the list is
open unless there is good cause for not accepting the application (such as denial of assistance)
for the grounds stated in the regulations [24 CFR 982.206(b)(2)]. Where the family is determined
to be ineligible,the PHA must notify the family in writing [24 CFR 982.201(�]. Where the
family is not determined to be ineligible,the family will be placed on a waiting list of applicants.
No applicant has a right or entitlement to be listed on the waiting list, or to any particular
position on the waiting list [24 CFR 982.202(c)].
Ineligible for Placement on the Waiting List
PHA Policy
During the pre-application, if the PHA can determine from the information provided that
a family is ineligible, the family will be notified according to the procedures stated in
Chapter 3, Part IIL Denial of Assistance. Where a family is deemed to be ineligible, the
PHA will send written notification of the ineligibility determination within 10 business
days of its decision to deny the application. The notice will specify the reasons for
ineligibility, and will inform the family of its right to request an informal review and
explain the process for doing so (see Chapter 1�. Any previous applicant/participant that
had been determined to be ineligible for an assisted housing benefit/subsidy that was
notified in writing of the reason for his/her ineligibility and of his/her right to request an
Informal Hearing shall be held accountable to the terms and time limits of the previous
notice or hearing.
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Eligible for Placement on the Waiting List
PHA Policv
Housin�Choice Voucher Waitin�List(s):
The PHA will send written notification of the preliminary eligibility determination within
15 business days of completing the lottery selection of those applicants selected to be
placed on the waiting list. Applicants will be selected to be placed on the waiting list
according to a computer-generated Lottery/random selection process.
Placement on the waiting list does not indicate that the family is, in fact, eligible for
assistance. A final determination of eligibility will be made when the family is selected
from the waiting list.
Also see 4-LB. APPLYING FOR ASSISTANCE for placement on the Moderate
Rehabilitation or Project-Based Voucher Waiting Lists.
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PART IL• MANAGING THE WAITING LIST
4-ILA. OVERVIEW
The PHA must have policies regarding various aspects of organizing and managing the waiting
list of applicant families. This includes opening the list to new applicants, closing the list to new
applicants, notifying the public of waiting list openings and closings, updating waiting list
information, purging the list of families that are no longer interested in or eligible for assistance,
as well as conducting outreach to ensure a sufficient number of applicants.
In addition, HUD imposes requirements on how a PHA may structure its waiting list and how
families must be treated if they apply for assistance from a PHA that administers more than one
assisted housing program.
PHA Policv
The waiting list shall remain open for receipt of applications far time periods of one (1)
calendar day according to the policy as stated in Chapter 4, Section 4.LB. Applying for
Assistance.
4-ILB. ORGANIZATION OF THE WAITING LIST [24 CFR 982.204 and 205]
The PHA's HCV waiting list must be organized in such a manner to allow the PHA to accurately
identify and select families for assistance in the proper order, according to the admissions
policies described in this plan.
The waiting list must contain the following information for each applicant listed:
• Applicant name;
• Family unit size;
• Date and time of application;
• Qualification for any local preference;
• Racial or ethnic designation of the head of household.
HUD requires the PHA to maintain a single waiting list for the HCV program unless it serves
more than one county or municipality. Such PHAs are permitted, but not required, to maintain a
separate waiting list for each county or municipality served.
PHA Policy
The PHA will maintain the waiting list{s)for the HCV program according to the policy
stated in Chapter 4, Section 4.LB. Applyingfor Assistance. The PHA will maintain a
separate waiting list for the Moderate Rehabilitation and Project Based Voucher
programs. Applicants will be asked to identify and indicate their interest in applying for
the Moderate Rehabilitation and Project Based Vouchers and will be maintained on all
lists according to their preference and qualifications.
HUD directs that a family that applies for assistance from the HCV program must be offered the
opporiunity to be placed on the waiting list for any public housing, project-based voucher or
moderate rehabilitation program the PHA operates if 1)the other programs' waiting lists are
open, and 2)the family is qualified far the other programs.
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HUD permits, but does not require,that PHAs maintain a single merged waiting list far their
public housing, Section 8, and other subsidized housing programs.
A family's decision to apply for, receive, or refuse other housing assistance must not affect the
family's placement on the HCV waiting list, or any preferences for which the family may
qualify.
PHA Policv
The PHA will not merge the HCV waiting list with the waiting list for any other program
the PHA operates.
4-ILC. OPENING AND CLOSING THE WAITING LIST [24 CFR 982.206]
Closing the Waiting List
A PHA is permitted to close the waiting list if it has an adequate pool of families to use its
available HCV assistance. Alternatively, the PHA may elect to continue to accept applications
only from certain categories of families that meet particular preferences or funding criteria.
HUD permits the PHA to close the waiting list if it has an adequate pool of families to use its
available funding, but does not define what constitutes an "adequate pool." The HCV Guidebook
suggests that application-taking should stop when the anticipated wait reaches between 12 and
24 months.
PHA Policy
The PHA will open and close the HCV waiting list periodically as defined in Chapter 4,
Section 4.LB. Applying for Assistance. Once the waiting list is closed according to the
procedure in the section noted above, the PHA shall utilize a lottery system to randomly
select applicants to be placed on the waiting list. Where the PHA has particular selection
or funding criteria(Project Based Vouchers, Tenant Protection Vouchers or Moderate
Rehabilitation Programs)that require a specific category of family, the PHA may elect to
continue to accept applications from these applicants while closing the HCV waiting list
to others.
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Reopening the Waiting List
If the waiting list has been closed, it cannot be reopened until the PHA publishes a notice in local
newspapers of general circulation, minority media, and other suitable media outlets. The notice
must comply with HUD fair housing requirements and must specify who may apply, and where
and when applications will be received.
PHA Policv
The PHA will announce the reopening of the HCV waiting list at least 10 business days
prior to the date applications will first be accepted. The PHA will give public notice by
publishing the relevant information in suitable media outlets including, but not limited to:
City ofDubuque Website
Telegraph Herald
Also see Sedion 02 Fair Housing Outreach
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4-ILD. FAMILY OUTREACH [HCV GB, pp. 4-2 to 4-4]
The PHA must conduct outreach as necessary to ensure that the PHA has a sufficient number of
applicants on the waiting list to use the HCV resources it has been allotted.
Because HUD requires the PHA to admit a specified percentage of eatremely low-income
families to the program (see Chapter 4, Part II�,the PHA may need to conduct special outreach
to ensure that an adequate number of such families apply for assistance [HCV GB, p. 4-20
to 4-21].
PHA outreach efforts must comply with fair housing requirements. This includes:
• Analyzing the housing market area and the populations currently being served to identify
underserved populations
• Ensuring that outreach efforts are targeted to media outlets that reach eligible populations
that are underrepresented in the program
• Avoiding outreach efforts that prefer or exclude people who are members of a protected class
PHA outreach efforts must be designed to inform qualified families about the availability of
assistance under the program. These efforts may include, as needed, any of the following
activities:
• Submitting press releases to local newspapers, including minority newspapers
• Developing informational materials and flyers to distribute to other agencies
• Providing application forms to other public and private agencies that serve the low-income
population
• Developing partnerships with other organizations that serve similar populations, including
agencies that provide services for persons with disabilities
PHA Policy
The PHA will monitor the characteristics of the population being served and the
characteristics of the population as a whole 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.
Also see Chapter 2 Adm Plan Fair Housing for additional outreach
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4-ILE. REPORTING CHANGES IN FAMILY CIRCUMSTANCES
PHA Policy
While the family is on the waiting list, the family must immediately inform the PHA of
changes in contact information, including current residence, mailing address, and phone
number. The changes must be submitted in writing, whenever possible.
4-ILF. UPDATING THE WAITING LIST [24 CFR 982.204]
HUD requires the PHA to establish policies to use when removing applicant names from the
waiting list.
Purging the Waiting List
The decision to withdraw an applicant family that includes a person with disabilities from the
waiting list is subject to reasonable accommodation. If the applicant did not respond to a PHA
request for information or updates, and the PHA determines that the family did not respond
because of the family member's disability,the PHA must reinstate the applicant family to their
former position on the waiting list [24 CFR 982.204(c)(2)].
PHA Policy
The waiting list will be updated annually to ensure that all applicants and applicant
information is current and timely. Each applicant on the waiting list will be notified of
the necessity to update their information and/or to notify the PHA of their continued
interest to remain on the waiting list.
To update the waiting list,the PHA will send an update request via first class mail to each
family on the waiting list at the same time to determine whether the family continues to
be interested in, and to qualify for, the program. This update request will be sent to the
last address that the PHA has on record for the family. The update request will provide a
deadline by which the family must respond and will state that failure to respond will
result in the applicant's name being removed from the waiting list.
The family's response must be in writing whenever possible and may be delivered in
person, electronically, by mail, or by fax. Responses should be postmarked or received
by the PHA not later than 15 business days from the date of the PHA letter.
If the family fails to respond within 15 business days, the family will be removed from
the waiting list without further notice. However, if the notice is returned by the post
office with no forwarding address, the applicant will be contacted by telephone call, e-
mail or by applicanYs authorized additional contact person and provided an additional 15
business days to respond.
If the notice is returned by the post office with a forwarding address, the notice will be re-
sent to the address indicated. The family will have 15 business days to respond from the
date the letter was re-sent.
If a family is removed from the waiting list for failure to respond to the purge notice, the
PHA may reinstate the family if it is determined that the lack of response was due to
PHA error, or to circumstances beyond the family's control that can be verified by the
applicant.
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Removal from the Waiting List for Ineligibility
PHA Policv
If at any time an applicant family is on the waiting list, the PHA determines that the
family is not eligible for assistance (see Chapter 3), the family will be removed from the
waiting list.
If a family is removed from the waiting list because the PHA has determined the family is
not eligible for assistance, a notice will be sent to the family's address of record as
provided on the most recent application. If the letter is returned with a forwarding
address,the letter will be resent to the new address. If the letter is returned without a
forwarding address, the applicant will be contacted by telephone call, e-mail or by
applicanYs authorized additional contact person. The notice will state the reasons the
family was removed from the waiting list and will inform the family how to request an
informal review regarding the PHA's decision (see Chapter 16) [24 CFR 982.201(�].
Removal from Waiting List During Final Eligibility Application
PHA Policv
Once the applicant family reaches the top of the waiting list, a letter along with the Final
Application packet will be sent by first class mail to notify the applicant family and to
request updated information. If the applicant family fails to respond to the letter within
15 business days from the date of the letter, staff will make a reasonable effort by
telephone call, e-mail or by applicanYs authorized additional contact person to request
updated information. If the applicant fails to respond to the 2°d request within the time
frame specified by staff(normally 15 business days) or any ea�tension of time granted by
staff the applicant family will be removed from the waiting list without further notice.
If the family responds with the updated information within the time lines set above, the
PHA will proceed with processing the application to determine final eligibility and
schedule the interview/briefing appointment. Also see 4IILD. NOTIFICATION OF
SELECTION.
PART IIL• SELECTION FOR HCV ASSISTANCE
4-IILA. OVERVIEW
As vouchers become available, families on the waiting list must be selected for assistance in
accordance with the policies described in this part.
The order in which families are selected from the waiting list depends on the selection method
chosen by the PHA and is impacted in part by any selection preferences for which the family
qualifies. The availability of targeted funding also may affect the order in which families are
selected from the waiting list.
The PHA must maintain a clear record of all information required to verify that the family is
selected from the waiting list according to the PHA's selection policies [24 CFR 982.204(b) and
982.207(e)].
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4-IILB. SELECTION AND HCV FUNDING SOURCES
Special Admissions [24 CFR 982.203]
HUD may award funding for specifically-named families living in specified types of units (e.g.,
a family that is displaced by demolition of public housing; a non-purchasing family residing in a
HOPE 1 or 2 projects). In these cases, the PHA may admit such families whether or not they are
on the waiting list, and, if they are on the waiting list, without considering the family's position
on the waiting list. These families are considered non-waiting list selections. The PHA must
maintain records showing that such families were admitted with special program funding.
Targeted Funding [24 CFR 982.204(e)]
HUD may award a PHA funding for a specified category of families on the waiting list. The
PHA must use this funding only to assist the families within the specified category. In order to
assist families within a targeted funding category, the PHA may skip families that do not qualify
within the targeted funding category. Within this category offamilies,the order in which such
families are assisted is determined according to the policies provided in Section 4IILC.
PHA Policv
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
Regular HCV Funding
Regular HCV funding may be used to assist any eligible family on the waiting list. Families are
selected from the waiting list according to the policies provided in Section 4IILC.
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4-IILC. SELECTION METHOD
PHAs must describe the method for selecting applicant families from the waiting list, including
the system of admission preferences that the PHA will use [24 CFR 982.202(d)].
PHA Policv
The PHA will select any family that has been terminated from its HCV program due to
insufficient program funding or to any family that had been issued a voucher and the
voucher was suspended or withdrawn or the briefing appointment that had been
scheduled was canceled due to insufficient funding priar to selecting others from the
waiting list- whether the waiting list is opened or closed. Assistance shall be offered in
the order listed in the previous sentence- terminated families, vouchers issued and
withdrawn, applicants scheduled for briefing appointment without regard to the waiting
list position.
All other applicant households will be selected for the HCV program by date and time of
their application. Failure to respond within 15 business days to the PHA request to
update the application during the final application process to determine final eligibility or
incomplete applications returned will result in a denial or delay in the final
processing/voucher issuance according to the policy previously stated in Section 4.LB.
Applying for Assistance in this chapter.
HUD requires that at least 75% of households admitted into the program during the year
must be eatremely low income. Eatremely low-income is defined as a very low-income
family whose annual income does not exceed the higher of:
(1) 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
(2) Thirty (30) percent of the median income for the area, as determined by
HUD, with adjustments for smaller and larger families, except that HUD may
establish income ceilings higher or lower than 30 percent of the area median
income far the area if HUD finds that such variations are necessary because of
unusually high or low family incomes.
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The PHA reserves the right to skip over or re-select applicants, if the PHA determines
that it is necessary to reach the HUD requirement that at least 75% of households
admitted into the program during the year must be eatremely low income.
Ifthe 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 date and time of application. 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 according to
the HUD contract (Example: Opt-Out ar Mod Rehab participants converting to the
Voucher program.)
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Local Preferences [24 CFR 982.207; HCV p. 4-16]
PHAs are permitted to establish local preferences, and to give priority to serving families that
meet those criteria. HUD specifically authorizes and places restrictions on certain types of local
preferences. HUD also permits the PHA to establish otherlocal preferences, atits discretion.
Any local preferences established must be consistent with the PHA plan and the consolidated
plan, and must be based on local housing needs and priorities that can be documented by
generally accepted data sources.
PHA Policy
No local preference points are established.
When a local preference change is being sought, the PHA must seek approval from HUD
and provide evidence supporting the need for the change from generally accepted data
sources, i.e. census data, indicating a change in local demographics or the identification
of need not previously met, thus necessitating additional assistance for an expanding or
newly identified demographic.
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Income Targeting Requirement [24 CFR 982.201(b)(2)]
HUD requires that eatremely low-income (EL�families make up at least 75% of the families
admitted to the HCV program during the PHA's fiscal year. ELI families are those with annual
incomes that do not exceed the higher of the Federal poverty level or 30% of the area median
income. To ensure this requirement is met, a PHA may skip non-ELI families on the waiting list
in order to select an ELI family.
Low income families admitted to the program that are "continuously assisted"under the 1937
Housing Act [24 CFR 982.4(b)], as well as low-income or moderate-income families admitted to
the program that are displaced as a result of the prepayment of the mortgage or voluntary
termination of an insurance contract on eligible low-income housing, are not counted for income
targeting purposes [24 CFR 982.201(b)(2)(v)].
PHA Policy
The PHA will monitor progress in meeting the income targeting requirement throughout
the fiscal year. Eatremely low-income families will be selected ahead of other eligible
families on an as-needed basis to ensure the income targeting requirement is met.
Order of Selection
The PHA system of preferences may select families based on local preferences according to the
date and time of application or by a random selection process (lottery) [24 CFR 982.207(c)]. If a
PHA does not have enough funding to assist the family at the top of the waiting list, it is not
permitted to skip down the waiting list to a family that it can afford to subsidize when there are
not sufficient funds to subsidize the family at the top of the waiting list [24 CFR 982.204(d)
and (e)].
PHA Policv
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 based on date and time of application. 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 accordingto
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 far 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.
All other HCV applicant families will be selected based on date and time of application and
according to the family's response to the Final application process once selected. .
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4-IILD. NOTIFICATION OF SELECTION
When a family has been selected from the waiting list,the PHA must notify the family.
�za cFx 9sz.ssa�a��
Pxa Poliov
Once the applicant family reaches the top of the waiting list, a letter along with the Final
Application packet will be sent by first class mail to notify the applicant family and
request updated information. If the applicant family fails to respond to the request far the
Final Application, the process in Section 4.LB. Applyingfor Assistance, Section "Final
Application" shall be followed
Once the applicant family responds to the request with updated information and is
determined eligible, the PHA will proceed with processing the application.
The PHA will notify the family by first class mail to inform the family of the following:
Date,time, and location of the scheduled application interview/briefing, including
any procedures for rescheduling the interview/briefing
Who is required to attend the interview/briefing
All documents that must be provided at the interview/briefing, including
information about what constitutes acceptable documentation
If the notice is returned by the post office with no forwarding address, the applicant will
be contacted by telephone call, e-mail or by applicant's authorized additional contact
person and provided another scheduled interview/briefing
If the notice is returned by the post office with a forwarding address, the notice will be re-
sent to the address indicated. The family will be provided another scheduled
interview/briefing.
If a notification letter is returned to the PHA with no forwarding address, and the PHA is
unable to contact the applicant utilizing the above methods, the family will be removed
from the waiting list. A notice of denial will be sent to the family's address of record, as
well as to any known alternate address, to deny assistance for failure to provide
information necessary in the administration ofthe program. See 4ILF. Removal from
the Waiting List.
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4-IILE. THE APPLICATION INTERVIEW
HUD recommends that the PHA obtain the information and documentation needed to make an
eligibility determination though a face-to-face interview with a PHA representative [HCV GB,
pg. 4-16]. Being invited to attend an interview does not constitute admission to the program.
Assistance cannot be provided to the family until all SSN documentation requirements are met.
However, if the PHA determines that an applicant family is otherwise eligible to participate in
the program,the family may retain its place on the waiting list for a period of time determined by
the PHA [Notice PIH 2O12-10].
Reasonable accommodation must be made for persons with disabilities who are unable to aYtend
an interview due to their disability.
PHA Policy
Families selected from the waiting list are required to participate in an eligibility
interview. The eligibility interview may be conducted at the time of the briefing
appointment or conducted by maiUperson prior to the briefing appointment.
The head of household and the spouse/co-head along with all adult household members
will be requested to attend the interview together. Verification of information pertaining
to adult members of the household not present at the interview will not begin until signed
release forms are returned to the PHA.
The head of household or spouse/co-head and all household members must provide
acceptable documentation of legal identity. (Chapter 7 provides a discussion of proper
documentation of legal identity.) If the family representative does not provide the
required documentation at the time of the interview, he or she will be required to provide
it within 10 business days or according to Section 4.LB. Applying for Assistance in this
chapter).
Pending disclosure and documentation of social security numbers,the PHA will allow the
family to retain its place on the waiting list for 30 calendar days. If not all household
members have disclosed their SSNs at the neat time the PHA is issuing vouchers,the
PHA will issue a voucher to the neat eligible applicant family on the waiting list.
The family must provide the information necessary to establish the family's eligibility
and determine the appropriate level of assistance, as well as completing required forms,
providing required signatures, and submitting required documentation. If any materials
are missing, the PHA will provide the family with a written list of items that must be
submitted.
Any required documents or information that the family is unable to provide at the
interview must be provided within 10 business days of the interview (Chapter 7 provides
details about longer submission deadlines for particular items, including documentation
of eligible noncitizen status and Section 4.LB. ofthis chapter provides details about SSN
verification/documentation). If the family is unable to obtain the information or materials
within the required time frame, the family may request an ea�tension. If the required
documents and information are not provided within the required time frame (plus any
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ea�tensions), the family will be sent a notice of denial for failure to provide information
necessary in the administration of the program.
An advocate, interpreter, or other assistant may assist the family with the application and
the interview process.
Interviews will be conducted in English. For limited English proficient(LEP) applicants,
the PHA will provide translation services in accordance with the PHA's LEP plan.
If the family is unable to attend a scheduled interview, the family should contact the PHA
in advance of the interview to schedule a new appointment. In all circumstances, if a
family does not attend a scheduled interview or arrives more than 15 minutes late for the
appointment,the PHA will send another notification letter with a new interview
appointment time. Applicants who fail to attend two scheduled interviews in a timely
manner without PHA approval will be denied assistance based on the family's failure to
supply information needed to determine eligibility and will be removed from the waiting
list.
4-IILF. COMPLETING THE APPLICATION PROCESS
The PHA must verify all information provided by the family (see Chapter 7). Based on verified
information, the PHA must make a final determination of eligibility (see Chapter 3) and must
confirm that the family qualified for any special admission,targeted funding admission, or
selection preference that affected the order in which the family was selected from the waiting
list.
PHA Policv
If the PHA determines that the family is ineligible, the PHA will send written notification
ofthe ineligibility determination within 10 business days ofthe determination. The notice
will specify the reasons for ineligibility, and will inform the family of its right to request
an informal review (Chapter 16).
If a family fails to qualify for any criteria that affected the order in which it was selected
from the waiting list(e.g. targeted funding, eatremely low-income), the family will be
returned to the waiting list. The PHA will notify the family in writing that it has been
returned to the waiting list, and will specify the reasons for it.
If the PHA determines that the family is eligible to receive assistance,the PHA will invite
the family to attend a briefing in accordance with the policies in Chapter 5 and Section
4.IILE ofthis chapter.
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