Title
Resolution to Approve Amendment to the Housing Voucher Administrative Plan Chapter 4: Applications, Waiting List, and Tenant Selection: Part III. Section 4-III.C. Local Preference
Memorandum
The Ann Arbor Housing Commission’s Housing Choice Voucher Program Administrative Plan Chapter 4 describes the PHAs policies regarding various aspects of organizing and managing the waiting list of applicant families. PHAs are permitted to establish local preferences, and to give priority to serving families that meet those criteria.
Staff first recommend adding Dunbar Tower to the list of PBV properties managed by the PHA where no waiting list is established and all applicants are referred through the local Continuum of Care (CoC) Chronically Homeless Program (CHP). In addition, The PHA will continue to accept applications from families meeting program criteria while closing the waiting list to families who do not meet the criteria. Staff recommend adding Special Purpose Vouchers such as Emergency Housing Vouchers (EHV) to the waitlist preferences. And staff recommend adding EHV to the list of vouchers programs allocated for targeted funding determined by HUD.
The most significant recommendation by staff is related to the HUD PIH Notice 2025-19 posted June 24, 2025, informing PHAs that administer the Emergency Housing Voucher program that EHV funding will likely exhaust in calendar year 2026 and current EHV program participants must be admitted the PHAs waiting list to transition to HCV for continued housing assistance.
To prevent disruption in housing subsidy, staff recommend adding current AAHC EHV program participants who would otherwise lose their voucher due to insufficient funding, as a preference to the regular HCV waitlist. Staff also recommend adding a preference for foster youth whose voucher assistance automatically terminates after five (5) years of participation. This will allow those qualified households to seamlessly transition to the HCV program without any disruption of service. Lastly, staff recommend amending the criteria to order preference by priority to first assist those households in jeopardy of losing assistance.
Current Policy: Chapter 4 Part III. Section 4-III.C. Waiting List Selection Method: Local Preference
PHA Policy
The PHA defines its local preferences for its programs as follows:
1. The PHA will offer a preference to any family that has been terminated from its HCV program due to insufficient program funding.
2. A “residency” preference for a family that resides in a specified geographic area, or includes a family member who works, or has been notified that they are hired to work, in that geographic area. A PHA cannot apply a residency preference to Mainstream voucher applicants.
3. A “disability” preference for a family that includes a family member who is a person with disabilities.
4. A “elderly” preference for Units for elderly families. Units that are exclusively made available to elderly families are excepted from the project cap.
• The term elderly family is defined in 24 CFR §5.403 as follows: “Elderly family means a family whose head (including co-head), spouse, or sole member is a person who is at least 62 years of age. It may include two or more persons who are at least 62 years of age living together, or one or more persons who are at least 62 years of age living with one or more live-in aides.”
5. A “Homeless” preference for a family whose sole family member is homeless over other single-person families.
Homeless households which meet one of the following criteria:
A. Households referred by the local continuum of Care Housing Assessment and Resource Agency (HARA), Housing Access of Washtenaw County
i. Homeless households that the AAHC has contracts with local service providers to provide services to these households.
ii. Under a joint grant, multiple service providers will provide supportive services for households with a persistent housing crisis or homeless, who also are high utilizers of crisis health services
• AAHC will ensure a total of 41 such families are housed through a combination of public housing, project-based vouchers managed by the AAHC and housing choice vouchers.
B. Tenants qualifying under the MSHDA's Medicaid Super Utilizer/Homeless Frequent Emergency Department Users with Care Needs will be referred through MSHDA's data match system using HMIS and Medicaid systems. Names of qualifying households will be provided quarterly to Avalon, as Lead Agency. Avalon will reach out to these households. All tenants filling units targeted to this population will come from this MSHDA-provided list.
C. Involuntary Displacement
i. In the case of a Federally declared disaster, the PHA reserves the right for its Executive Director to suspend its preference system for whatever duration the Executive Director feels is appropriate and to admit victims of the disaster to the program instead of those who would be normally admitted.
ii. Any other provisions of this policy can also be suspended during the emergency at the discretion of the Executive Director so long as the provision suspended does not violate a law. If regulatory waivers are necessary, they shall be promptly requested of the HUD Assistant Secretary for Public and Indian Housing.
iii. The PHA reserves the right for its Executive Director to suspend its preference system for families that have been involuntarily displaced due to a fire, natural disaster, domestic violence or any other reason that are residents of AAHC public housing or projected-based voucher programs.
Current PHA Policy (Continued)
Applicants will be placed on the waiting list according to their date and time of completed application and qualified preference. All preferences will carry the same weight. A family may qualify for multiple preferences. The PHA will use the method of compounding preferences.
- The PHA will first assist families that have been terminated from the HCV program due to insufficient funding, including (VASH, FUP, FYI, and EHV).
- The PHA will next assist homeless families that the AAHC has contracts with local service providers to provide services to these households to fulfill any contract obligations.
- The PHA will then assist any households that qualify within the targeted funding category.
- The PHA will assist all other households using the method of compounding preferences. A family that qualifies for more than one preference will be assisted before a family that qualifies for only one of the preferences.
Amended Policy: Chapter 4 Part III. Section 4-III.C. Waiting List Selection Method: Local Preference
5. A limited “Homeless” preference for a family whose family member are homeless over other families when the family meets one of the following criteria:
A. Households referred by the local continuum of Care Housing Assessment and Resource Agency (HARA), Housing Access of Washtenaw County for designated units or vouchers that are restricted to homeless households and a local service provider is providing services to the household.
6. A “Emergency Housing Voucher” preference for a family that currently participates in the PHA’s Emergency Housing Voucher Program.
EHV households which meet the following criteria:
a. Current PHA EHV families who may experience a loss or gap in housing assistance due to the ARP made EHV funds available for obligation by HUD until September 30, 2030, and those funds will be cancelled as a matter of law effective September 30, 2035.
7. A “Family Unification Program Youth or Foster Youth Initiative” preference for a youth family that currently participates in the PHA’s FUPY or FYI program.
b. The PHA will provide a selection preference for youth who are terminated due to the time limit on assistance.
Amended Policy PHA Policy Continued
Applicants will be placed on the waiting list according to their date and time of completed application and qualified preference. The PHA will select families from the waiting list based on targeted funding or selection preference(s) for which the family qualifies and in accordance with the PHA’s preference calculation method. A family may qualify for multiple preferences. The PHA will use the method of compounding preferences. For families with the same preference status, the PHA will use date and time of application selection technique. The PHA order of selection is as follows:
1. The PHA will leave the waiting list open only for the population who qualify for the limited homeless preference, current participants of the PHAs EHV, FUP, and FYI program and for families who qualify for special categories of targeted funding (i.e., continue to accept applications only from applicants that qualify for the preference), while keeping it closed for all other applicants.
2. Families who have been issued a voucher and the voucher was rescinded due to insufficient funds are placed at the top of the waiting list and will be admitted when sufficient funds are available.
3. The PHA will select families who meet the disability and/or residency preference above families who do not meet these preferences.
4. If there is no one on the waiting list that meets the preference criteria, the PHA would issue the voucher to the next family on the waiting list.
a. The PHA will select families who have lived in PBV units for one year or more and have requested to receive continued tenant-based voucher assistance.
b. The PHA may not select more than three-quarters of its turnover vouchers in any single year to the residents of Covered Projects under the RAD PBV program.
Staff
Prepared by Weneshia Brand, Director of Operations
Approved by Jennifer Hall, Executive Director
Body
WHEREAS, The Ann Arbor Housing Commission’s Housing Choice Voucher program Administrative Plan PHAs policies regarding various aspects of organizing and managing the waiting list of applicant families; and
WHEREAS, PHAs are permitted to establish local preferences, and to give priority to serving families that meet those criteria; and
WHEREAS, AAHC recommend adding Dunbar Tower to the list of PHA owned properties to accept all applicant applications by referral through the local Continuum of Care (CoC); and
WHEREAS, the AAHC currently accepts applications while the waiting list is closed for CoC referrals and recommend adding special purpose voucher and targeted funding (EHV) program to the criteria; and
WHEREAS, AAHC recommends adding the Emergency Housing Voucher (EHV) to the list of HUD targeted funding programs; and
WHEREAS, AAHC recommends adding current FUPY, FYI and EHV program participants to the PHAs waiting list to transition to HCV for continued housing assistance as a preference; and
WHEREAS, AAHC recommends prioritizing current special purpose and targeted funding program participants who are subject to termination due to insufficient funding (EHV) and/or term limited assistance (FUPY and FYI) over families who meet other preferences.
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 22, 2025.