Title
Resolution to Approve Amendments to the HCV Administrative Plan: Chapters 6, 7, 11, and 16
Memorandum
The Ann Arbor Housing Commission (AAHC) is amending its Housing Choice Voucher (HCV) Administrative Plan to incorporate program updates, clarify procedural requirements, and implement newly approved Moving to Work (MTW) activities. These revisions apply to several chapters of the Administrative Plan and address changes to minimum rent requirements, income verification procedures, streamlined fixed-income reexaminations, MTW Alternative Reexamination scheduling, Interim Reexamination effective dates, and participant hearing time frames. The following sections outline each Administrative Plan chapter and policy area being revised, including the previous language and the updated policy language adopted by the AAHC.
1. Chapter 6: Income and Subsidy Determinations
Section III.A - Minimum Rent Policy
Old Policy:
Minimum rent set at $50.
New Policy:
The minimum rent for this locality is $100. Pursuant to MTW Operations Notice Activity 1.f, the PHA may set a minimum rent higher than the standard regulatory limit, up to a maximum of $130. The agency exempts households in which all adult members are elderly or disabled from the minimum rent requirement.
2. Chapter 7: Verification
Section III.A - Earned Income / Wages
Old Policy:
For wages other than tips, the family must provide originals of the two most current, consecutive pay stubs.
New Policy:
Two most current, consecutive pay stubs required.
Added Language:
• The PHA may request additional pay stubs when necessary to accurately determine income, including when reduced hours or increased earnings (such as overtime) appear on initial pay stubs.
3. Chapter 11: Reexaminations
Section I.B - Streamlined Annual Reexaminations
Old Policy:
The PHA will streamline the annual reexamination
New Policy:
The PHA may streamline the annual reexamination process by applying the verified COLA or interest rate to fixed-income sources and will document in the file how the determination of “fixed income” was made.
4. Chapter 11: Reexaminations
Section I.C - Scheduling Annual Reexaminations
Old Policy:
Annual reexaminations scheduled based on a 12-month anniversary date.
New Policy:
The PHA will continue using the term “annual reexamination” for consistency with HUD regulations, housing software, and standard program language; however, the timing of reexaminations may vary within the MTW-approved 12-36 month range.
Added language:
• During implementation of the MTW activity, the PHA and HUD reserve the right to discontinue or revise the activity to ensure compliance with applicable requirements.
5. Chapter 11: Interim Reexaminations
Section II.D - Effective Dates
Old Policy:
Unreported changes resulting in rent increases are applied retroactively.
New Policy:
If the family fails to report a change or provide required information within specified time frames, the resulting rent increase will be applied retroactively. The increase will be effective on the first of the month following the change. Families remain responsible for any overpaid subsidy and may enter into a repayment agreement per Chapter 16.
6. Chapter 16: Informal Hearings for Participants
Section III.C - Scheduling an Informal Hearing
Old Policy:
Participants had 10 business days to request a hearing.
New Policy:
A participant must submit a written request for an informal hearing within 30 business days of the date of the PHA’s decision or termination notice, delivered in person or by first-class mail.
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; 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 following amendments to the Housing Choice Voucher Administrative Plan:
1. Chapter 6: Income and Subsidy Determinations
New Policy:
The minimum rent for this locality is $100. Pursuant to MTW Operations Notice Activity 1.f, the PHA may set a minimum rent higher than the standard regulatory limit, up to a maximum of $130. The agency exempts households in which all adult members are elderly or disabled from the minimum rent requirement.
2. Chapter 7: Verification
Section III.A - Earned Income / Wages
New Policy:
For wages other than tips, the family must provide originals of the two most current, consecutive pay stubs. The PHA may request additional pay stubs when necessary to accurately determine income, including when reduced hours or increased earnings (such as overtime) appear on initial pay stubs.
3. Chapter 11: Reexaminations
Section I.B - Streamlined Annual Reexaminations
New Policy:
The PHA may streamline the annual reexamination process by applying the verified COLA or interest rate to fixed-income sources and will document in the file how the determination of “fixed income” was made.
4. Chapter 11: Reexaminations
Section I.C - Scheduling Annual Reexaminations
New Policy:
The PHA will continue using the term “annual reexamination” for consistency with HUD regulations, housing software, and standard program language; however, the timing of reexaminations may vary within the MTW-approved 12-36 month range.
Added language:
• The anniversary date is defined as 12-36 months from the effective date of the last annual reexamination, or from the initial admission for first-year households.
• During implementation of the MTW activity, the PHA and HUD reserve the right to discontinue or revise the activity to ensure compliance with applicable requirements.
5. Chapter 11: Interim Reexaminations
Section II.D - Effective Dates
New Policy:
If the family fails to report a change or provide required information within specified time frames, the resulting rent increase will not be applied retroactively. The increase will take effect on the first of the month following the month in which the change was reported. Families remain responsible for any overpaid subsidy and may enter into a repayment agreement per Chapter 16.
6. Chapter 16: Informal Hearings for Participants
Section III.C - Scheduling an Informal Hearing
New Policy:
A participant must submit a written request for an informal hearing within 30 business days of the date of the PHA’s decision or termination notice, delivered in person or by first-class mail.
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 July 1, 2026.