Title
Resolution to Approve Amendment to the Housing Choice Voucher Administrative Plan Regarding Denial of Assistance Waiver
Memorandum
HUD provides the primary source of PHA policy through federal regulations, HUD Notices and Handbooks. Compliance with federal regulations, current HUD Notices and HUD Handbooks is mandatory. In addition, HUD requires all PHAs to adopt an Administrative Plan for the Voucher Program. The purpose of this memorandum is to request board approval for changes to the Administrative Plan for Chapter 3 Part III.E regarding Denial of Assistance.
HUD has mandatory reasons for denying assistance to new families and HUD gives housing authorities the option for additional reasons for denying assistance to new families. The AAHC has adopted optional reasons for denying assistance. In all of these optional denial cases, the AAHC has the ability to admit a household depending on the circumstances.
As a part of the RAD conversion process, the AAHC has greatly increased the number of project-based voucher units set aside for homeless and chronically homeless households who may have backgrounds that would deny them access to AAHC housing under optional program requirements. All of these households are being referred to us through a centralized assessment and referral process and all of these households will be working with service providers in order to support them to stay housed. Consequently, staff are recommending that the Board adopt a revision to the Administrative Plan to enable households who are working with a service provider to be admitted to the program if they would otherwise be denied under the optional denial policies.
Staff
Prepared and approved by Jennifer Hall, Executive Director
Body
WHEREAS, HUD allows Housing Authorities to adopt policies to deny admittance to households in addition to mandatory HUD denial policies;
WHEREAS, the AAHC has adopted optional denial policies;
WHEREAS, the AAHC can consider the household circumstances when deciding whether to admit a household that would otherwise meet the optional denial criteria;
WHEREAS, the AAHC Administrative Plan Chapter 3 Part III.E currently states:
The PHA will consider the following factors prior to making its decision:
The seriousness of the case, especially with respect to how it would affect other residents
The effects that denial of assistance may have on other members of the family who were not involved in the action or failure
The extent of participation or culpability of individual family members, including whether the culpable family member is a minor or a person with disabilities, or (as discussed further in section 3-III.G) a victim of domestic violence, dating violence, or stalking
The length of time since the violation occurred, the family's recent history and the likelihood of favorable conduct in the future
WHEREAS, the AAHC staff are recommending the addition of this policy under Chapter 3 Part III.E:
"Participation in services with treatment providers or community-based organizations providing services to household members in order to address the activity that would otherwise cause the denial of assistance"
RESOLVED, that the Ann Arbor Housing Commission Board approve the Housing Choice Voucher Administrative Plan amendment to Chapter 3 Part III.E regarding circumstances to consider when denying assistance to tenants under optional denial policies, to take effect on Feb 1, 2015.