Title
Resolution to Approve Amendments to the HCV Administrative Plan: Chapters 6 Related to Decreases in Payment Standards
Memorandum
Due to insufficient funding from HUD to respond to the local market rent increases, the Ann Arbor Housing Commission (AAHC) has gone into funding shortfall multiple budget cycles, despite taking numerous measures to manage costs. The AAHC is amending its Housing Choice Voucher (HCV) Administrative Plan to incorporate program updates, policy amendments, clarify procedural requirements, and/or implement newly approved Moving to Work (MTW) activities. The revisions below apply to Chapter 6 of the Administrative Plan and addresses changes to applying decreased payment standards to families who remain under a HAP contract.
The current policy states that the AAHC will apply reduced payment standards only to new admissions and families who move to another property. The AAHC is not required to apply decreased payment standards to families who remain under HAP contract at the time of their annual certification. Staff are recommending that the AAHC Board adopt a policy that applies the decreased payment standard at the family’s second regular re-examination, to both manage the HAP funds that are allocated by HUD and to give family’s a reasonable time to adjust. The following sections outline the Administrative Plan chapter and policy area being revised, including the previous language and the updated policy language adopted by the AAHC.
6-III.C. APPLYING PAYMENT STANDARDS
Decreases
Current PHA Policy
If a PHA changes its payment standard schedule resulting in a lower payment standard amount, during the term of a HAP contract, the PHA will not reduce the payment standard used to calculate subsidy for families under HAP contract as long as the HAP contract remains in effect.
The PHA will not establish different policies for decreases in the payment standard for designated areas within their jurisdiction.
Updated PHA Policy
If a PHA changes its payment standard schedule resulting in a lower payment standard amount, during the term of a HAP contract, the PHA will apply the reduced payment standard at the family’s second regular reexamination following the reduction in the payment standard amount.
When the payment standard schedule is decreased during the term of the HAP contract, the PHA will determine the payment standard for families currently under a HAP contract as follows:
Step 1: At the first regular reexamination following the decrease in the payment standard, the PHA will determine the payment standard for the family using the lower of the payment standard for the family unit size or the size of the dwelling unit rented by the family.
Step 2: The PHA will compare the payment standard from Step 1 to the payment standard last used to calculate the monthly housing assistance payment for the family. The payment standard used by the PHA at the first regular reexamination following the decrease in the payment standard will be the higher of these two payment standards. The PHA will advise the family that the application of the lower payment standard will be deferred until the second regular reexamination following the effective date of the decrease in the payment standard.
Step 3: At the second regular reexamination following the decrease in the payment standard, the current (lower) payment standard will be used to calculate the monthly housing assistance payment for the family unless the PHA has subsequently increased the payment standard, in which case the payment standard will be determined in accordance with procedures for increases in payment standards.
The PHA will provide the family with at least 12 months’ notice that the payment standard is being reduced before the effective date of the change.
The PHA will not establish different policies for decreases in the payment standard for designated areas within their jurisdiction.
Staff
Prepared by Weneshia Brand, Deputy Director
Approved by Jennifer Hall, Executive Director
Body
WHEREAS, the Ann Arbor Housing Commission (AAHC) administers the Housing Choice Voucher Program in accordance with federal regulations and the agency’s adopted Administrative Plan; and
WHEREAS, the AAHC is a designated Moving to Work (MTW) agency and is authorized to implement MTW flexibilities to improve program administration, enhance housing choice, and support long-term program sustainability; and
WHEREAS, AAHC staff have recommended amendments to the HCV Administrative Plan to align local policy with MTW-approved activities, current operational needs, and updated program procedures including ongoing funding shortfalls from HUD; and
WHEREAS, the Executive Director is authorized to implement these changes effective immediately and make any necessary procedural or administrative adjustments required for compliance; and
WHEREAS, the Board of Commissioners has reviewed the proposed amendments and finds them necessary and appropriate to ensure consistent, effective program administration;
NOW, THEREFORE, BE IT RESOLVED that the Board of Commissioners of the Ann Arbor Housing Commission hereby approves the amendment to the Housing Choice Voucher Administrative Plan, Chapter 6 related to decreases in payment standards as described above.