Title
Resolution to Approve Amendment to the Housing Voucher Administrative Plan Temporary Policy Supplement: Emergency Housing Voucher (EHV)
Memorandum
The Ann Arbor Housing Commission’s Housing Choice Voucher program administers Emergency Housing Vouchers (EHVs) to eligible households as described in HUD PIH Notice 2021-15: Emergency Housing Voucher Operations requirements. HUD issued PIH Notice 2023-23: EHV Expanded Use of the EHV Services fee, on August 29, 2023, to add two new eligible activities that may be funded with the EHV services fees. The revision also expands the descriptions of several of the existing activities to provide additional uses for the special fees under those specific activities.
The Administrative Plan current policy does not include the new service fee activities to allow payment for rental arrears, storage expenses, or lock change fees. Staff recommend adding these two new items to the eligible activities. In addition, the current policy for eligible activities does not describe eligible uses for housing mobility services to encourage move to high opportunity neighborhoods, incentives to owners with accessible units who lease to disabled households, support to families to fulfill their obligations under EHV, and household items such as furniture, toiletries, and cleaning supplies. Staff recommend expanding the description for these activities. It is recommended, the board approve the temporary policy supplement amendments proposed by HUD so, that eligible households may expand their housing opportunity.
New eligible activities:
PIH Notice 2023-23 adds rental arrears, storage expenses, and lock change fees, as new eligible activities that may be funded by the PHA.
Security Deposit/Utility Deposit/Rental Application/Holding Fee Uses/Arrears the PHA may provide applicants with rental arrear assistance for some or all of the applicant’s rental arrears to a private landlord but only if the rental arrear is a barrier to leasing the EHV unit. For example, the EHV family found a landlord, but the landlord will not lease the unit because of the previous rental debt (this may occur if the EHV unit is with the same landlord or management agent). The PHA may choose to pay the rental arrears assistance directly to the private landlord or may pay the rental arrears assistance to the family, provided the PHA verifies the family pays the rental arrears. The PHA may not use the EHV services fee for debts owed by the family to the PHA, another PHA, or a closely-associated entity affiliated with the PHA.
Moving expenses (including move-in fees, storage expenses, lock change fees, and deposits). The notice adds storage expenses and lock change fees to the list of eligible activities.
Expanded description of existing eligible activities
PIH Notice 2023-23 expands the description of eligible activities for housing search assistance, owner incentive and retention payments, tenant-readiness services, and essential household items as follows:
Housing Mobility Services to provide housing mobility services to encourage moves to high opportunity neighborhoods.
Owner Incentive or Retention Payments to providing incentives to owners with accessible units or owners that will make the living conditions accessible (interior/exterior structural modifications) for a person with disabilities.
Tenant-Readiness Services changes the activity title to “Pre-Tenancy Services and Services That Support EHV Families In Fulfilling Their Family Obligation Under The EHV Program,” and expands the description to allow the PHA to use the services fee funding to mitigate barriers that individual families may face in maintaining occupancy of a unit with an EHV, such as providing access to case management, wrap-around services, life skills training financial stability training, mental health care and/or a stability coordinator. The PHA may also use the services fee for services to remedy a lease violation/prevent an eviction and may establish a cap/threshold for this service; this excludes financial assistance for rental/utility arrears. All services and training provided must be voluntary for the family and cannot be a condition of the lease or a PHA requirement for admission continued participation in the EHV program. Additionally, PHAs may pay fees for families to obtain vital documents needed to establish eligibility for the program and/or required by landlords as part of their rental application.
Essential Household Items expands the description to include furniture, toiletries, cleaning supplies, etc.), and allow the PHA to provide a pre-paid gift card (e.g., Visa, Mastercard, American Express) directly to the family, provided the PHA verifies the family purchased essential household items and obtains and maintains appropriate supporting documentation (e.g., a receipt).
Staff
Prepared by Weneshia Brand, Deputy Director
Approved by Jennifer Hall, Executive Director
Body
WHEREAS, The Ann Arbor Housing Commission’s Housing Choice Voucher program administers Emergency Housing Vouchers (EHV); and
WHEREAS, HUD issued Notice PIH 2021-15 to provide operating requirements to PHAs administering the EHV program; and
WHEREAS, Section 6(d) of the notice provides guidance on the service fee and defines the eligible uses to facilitate the leasing of the emergency vouchers, such as security deposit assistance and other costs related to retention and support of participating owners; and
WHEREAS, AAHC must update the administrative plan with the eligible uses implemented and the parameters/requirements to use the services fee for any new activities; and
WHEREAS, On August 29, 2023, HUD issued PIH Notice 2023-23 amending Notice PIH 2021-15, Emergency Housing Vouchers (EHV) - Operating Requirements, to add two new eligible activities that may be funded with the EHV services fees; and
WHEREAS, PIH Notice 2023-23 revisions also expands the description of several of the existing activities to provide additional uses for the special fees under those specific activities; and
WHEREAS, the AAHC recommend amending the Administrative Plan Temporary Policy Supplement to include all permissible EHV Service Fee uses stated in PIH Notice2023-23; and
NOW, THEREFORE BE IT RESOLVED that the Board of the Ann Arbor Housing Commission accept and approve the proposed administrative plan changes, which will be effective, as of the date of the notice, which was August 29, 2023.