Title
Resolution to Amend the Administrative Plan Regarding Chapter 17: Project-Based Vouchers
Memorandum
The Ann Arbor Housing Commission (AAHC) project-based voucher (PBV) program allows PHAs that already administer a tenant-based voucher program under an annual contributions contract (ACC) with HUD to allocate a portion of those vouchers as PBV.
Staff recommend amending Chapter 17: “Project-Based Voucher” of the Administrative Plan to add flexibility to Section 17-I.A. Overview: Units Not Subject to The PBV Program Limitation. Section 17-II.B. Owner Proposal Selection Procedures Units Selected Non-Competitively., and Section Part V: Selection of PBV Program Participants 18-V.D. Organization of The Waiting List.
Staff recommend, adding language to the administrative plan to the AAHC to place vouchers on units not subject to the program limitation. In addition, AAHC would like to amend the policy to place vouchers on units that were not selected in a non-competitive process. Lastly, AAHC proposes to add language to clarify the use of the CoC HAWC CHP waiting list for referral of eligible families for PBV projects.
Current PHA Policy related to the Project Based Voucher Chapter
Proposal #1
PART I: GENERAL REQUIREMENTS
17-I.A. OVERVIEW
Units Not Subject to the PBV Program Limitation
PBV units under the RAD program and HUD-VASH PBV set-aside vouchers do not count toward the 20 percent limitation when PBV assistance is attached to them.
In addition, units that were previously subject to certain federal rent restrictions or were receiving another type of long-term housing subsidy provided by HUD are not subject to the cap. In order to be excepted, the unit must meet the following conditions:
• The unit must be covered under a PBV HAP contract that first became effective on or after 4/18/17; and
• In the five years prior to the date the PHA either issued the RFP or selected the project, the unit either:
- Received Public Housing Capital or Operating Funds, Project-Based Rental Assistance, Housing for Elderly (Section 202), Housing for Persons with Disabilities (section 811), Rent Supplement (Rent Supp), or Rental Assistance Program (RAP); or
- The unit was subject to a rent restriction through a loan or insurance program as a result of Section 236, Section 221(d)(3) or (d)(4) BMIR, Housing for Elderly Persons (Section 202), or Housing for Persons with Disabilities (Section 811)
Units that have previously received either PBV or HCV assistance are not covered under the exception.
PHA Policy
The PHA will not project-base any of the above unit types.
Proposed Policy Change
PHA Policy
The PHA may project-base any of the above unit types.
Proposal # 2
17-II.B. OWNER PROPOSAL SELECTION PROCEDURES
Units Selected Non-Competitively
For certain public housing projects where the PHA has an ownership interest or control and will spend a minimum amount per unit on rehabilitation or construction, the PHA may select a project without following one of the two processes above.
PHA Policy
The Ann Arbor Housing Commission plans to project-base vouchers without using a competitive process at the following projects that it is converting from public housing under the RAD program as de Minimis units:
Proposed Policy Change
PHA Policy
The PHA may attach PBVs to projects owned by the PHA as described above.
Proposal # 3
PART V: SELECTION OF PBV PROGRAM PARTICIPANTS
18-V.D. ORGANIZATION OF THE WAITING LIST
The standard PBV regulations at 24 CFR 983.251 set out program requirements related to establishing and maintaining a voucher-wide, PBV program-wide, or site-based waiting list from which residents will be admitted. These provisions will apply unless the project is covered by a remedial order or agreement that specifies the type of waiting list and other waiting list policies.
PHA Policy.
The PHA will establish and manage separate waiting lists for individual projects or buildings that are receiving RAD PBV assistance. The PHA currently has waiting lists for the following RAD PBV projects:
• Privately Owned Units
o Pear St. Project-Based Voucher Waiting List
.
Proposed Policy Change:
PHA Policy
The PHA may establish and manage separate waiting lists for individual projects or buildings that are receiving PBV assistance. The PHA currently has waiting lists for the following PBV projects:
• Pear Street: once the waiting list is exhausted the PHA will accept referral directly from the Continuum of Care HAWC CHP Homeless Referral system.
• The PHA will accept referral directly from the Continuum of Care HAWC CHP Homeless Referral system for PBV projects.
...Staff
Prepared by: Weneshia Brand, Director of Operations
Approved by: Jennifer Hall, Executive Director
Body
WHEREAS, The Ann Arbor Housing Commission's Housing Choice Voucher Administrative Plan details its policies and procedures for the management of its Housing Choice Voucher (HCV) Program; and
WHEREAS, The AAHC has included in its administrative plan language that defines the management and administration of its Project-Based Voucher program; and
WHEREAS, The AAHC recommends that the board amend the Administrative Plan to allow the agency to project-base vouchers on units not subject to the program limitation.
WHEREAS, The AAHC recommends that the board amend the Administrative Plan to allow the agency to project vouchers on AAHC owned units that were not selected in a non-competitive process.
WHEREAS, The AAHC recommends that the board amend the Administrative Plan to add language to clarify the use of the CoC HAWC CHP waiting list for referral of eligible families for PBV projects; and
RESOLVED, that the Board of the Ann Arbor Housing Commission approve the revisions to the Administrative Plan as described in the memorandum above to take effect July 1, 2020.