Title
Resolution to Amend the Administrative Plan Regarding Chapter 19 Family Self-Sufficiency
Memorandum
AAHC staff recommend that the AAHC Board adopt amendments to Chapter 19 of the Administrative Plan related to the Family Self-Sufficiency (FSS) program. The AAHC met with Legal Services of Southcentral Michigan to review the FSS regulations in the Administrative Plan to ensure they are in compliance with federal regulations, particularly the definition of suitable employment. The November 2019 amendment to the FSS section of the Administrative Plan adopted by the board, at the recommendation of AAHC staff, inadvertently violated the FSS regulations related to the new definition of suitable income.
The definition of self-sufficiency in 24 CFR 984.103 states that no longer receiving housing assistance cannot be a condition for the receipt of the FSS escrow account funds. The definition of suitable income adopted in November 2019, also happens to be the income at which a tenant is no longer eligible for rental assistance and therefore is one way for a family to become eligible to graduate and receive FSS escrow funds. Below are the recommended changes to Chapter 19 Family Self-Sufficiency related to suitable income as well as language clean-up to provide better clarity and updates based on the most recent HUD NOFA (grant application) for FSS funding.
The FSS Chapter of the Administrative Plan is attached in track changes as well.
Proposed Change 1:
This section was added as an additional bullet point to instruct staff and families the treatment of FSS participants who have identified homeownership as a goal. These instructions were included and inserted directly as stated in the September 2019 FSS Notice of Opportunity for Funding Availability FR-6300-N-04.
18-II.A. ACTION PLAN [24 CFR 984.201]
FSS activities and supportive services. [24 CFR 984.201 (d)(7)]
Homeownership
To be consistent with current practice, the Office of General Counsel has determi...
Click here for full text