Title
Resolution to Amend the Administrative Plan Regarding Chapter 4: Application Process and Chapter 16: Informal Hearings for Participants
Memorandum
The Ann Arbor Housing Commission's Housing Choice Voucher Administrative Plan details its policies and procedures for the management of its Housing Choice Voucher (HCV) Program. The AAHC periodically revises the Plan to reflect changes in HUD policies and changes in AAHC policies. Staff recommend that the AAHC Board adopt policy changes that impact the occupancy standard to increase the housing opportunities and housing stability for AAHC voucher families. The proposed changes are within the following sections: Chapter 4: Application Process and Chapter 16: Informal Hearings for Participants
Proposal 1:
Applicants must provide verification of preference during the interview process. AAHC is proposing to change the current policy to remove applicants who do not qualify for self-certified preferences during the waiting list application interview process.
4-III.F. COMPLETING THE APPLICATION PROCESS
The PHA must verify all information provided by the family (see Chapter 7). Based on verified information, the PHA must make a final determination of eligibility (see Chapter 3) and must confirm that the family qualified for any special admission, targeted funding admission, or selection preference that affected the order in which the family was selected from the waiting list.
Current Policy
If a family fails to qualify for any criteria that affected the order in which it was selected from the waiting list (e.g. targeted funding, extremely low-income), the family will be returned to its original position on the waiting list. The PHA will notify the family in writing that it has been returned to the waiting list, and will specify the reasons for it.
Proposed Policy
If a family fails to qualify for any criteria that affected the order in which it was selected from the waiting list (e.g. targeted funding, preferences, extremely low-income) the family will be returned to its original position on the waiting list. Or if a family fails to qualify for the criteria that made it eligible to apply to the waitlist (e.g. targeted funding, preferences, number of bedrooms, income),the family will be removed the waiting list. The PHA will notify the family in writing that it has been returned to its original position on the waiting list or that the family was removed from the waiting list, and will specify the reasons for it.
For Example: After the waitlist application period is closed, the PHA will sort the waitlist by the number of preferences a family self-identified that they met and by any special targeted funding that the family self-identified that they qualified for. All of the applicants who meet 3 preferences will be sorted to the top of the waitlist in date and time order of application. All of the applicants who meet 2 preferences will be sorted to the next section of the waitlist in date and time order of application and so on. The special funding applicants will be sorted by the number of preferences they meet as well. Depending on the number of applications received by the PHA, it is possible that an applicant that does not meet any of the preferences or special targeted funding criteria, might not be selected to be on the waitlist.
If a family applies to the waitlist and indicates that the family meets the preferences for homeless, Washtenaw County and disabled and it turns out the family only meets 1 preference, the family will be moved to the section of the waitlist for families that meet 1 preference in date and time order for 1 preference.
If a family applies to the waitlist and indicates that the family meets the preference for disabled and if the family was selected to the waitlist because the family was disabled and the family does not have a member with a disability, the family will be removed from the waitlist.
If a 3-person family applies to a 1-bedroom waitlist because it is open and the family must actually move into a 2- or 3-bedroom based on its family size, but the 2- and 3-bedroom waitlists are not open, the family will be removed from the 1-bedroom waitlist. The family cannot be moved from the 1-bedroom waitlist to a 2 or 3-bedroom waitlist unless the 2 or 3-bedroom waitlist was open when they applied to the 1-bedroom waitlist.
If a family indicates that they meet a special targeted funding and is pulled from the waitlist and does not qualify for that special targeted funding, the family will be placed back on the waitlist with the group of families that meet the same number of preferences, in date and time order within that number of preferences.
If a family indicates that they meet a preference/s or special targeted funding and they were placed on the waitlist due to that self-selection and otherwise would not have been placed on the waitlist. The family will be removed from the waitlist if they fail to qualify for the preference/s or special targeted funding that initially qualified them to be on the waitlist.
Proposal 2:
Participants may reschedule grievance hearings for any adverse action determined by the agency. Staff proposes to add language to the current policy that will limit the number of times a participant may reschedule a grievance hearing.
16-III.C. INFORMAL HEARINGS FOR PARTICIPANTS [24 CFR 982.555]
Scheduling an Informal Hearing [24 CFR 982.555(d)]
When an informal hearing is required, the PHA must proceed with the hearing in a reasonably expeditious manner upon the request of the family.
Current Policy
If the family does not appear within 20 minutes of the scheduled time, and was unable to reschedule the hearing in advance due to the nature of the conflict, the family must contact the PHA within 24 hours of the scheduled hearing date, excluding weekends and holidays. The PHA will reschedule the hearing only if the family can show good cause for the failure to appear, or if it is needed as a reasonable accommodation for a person with disabilities.
Proposed Policy
If the family does not appear within 20 minutes of the scheduled time, and was unable to reschedule the hearing in advance due to the nature of the conflict, the family must contact the PHA within 24 hours of the scheduled hearing date, excluding weekends and holidays. The PHA will reschedule the hearing only if the family can show good cause for the failure to appear, or if it is needed as a reasonable accommodation for a person with disabilities. The PHA will only reschedule the hearing 2 times and will terminate the family after the 3rd failure to appear for the hearing.
...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 Administrative Plan details its policies and procedures for the management of its Housing Choice Voucher (HCV) Program; and
WHEREAS, the policy language regarding the waiting list is amended to assure fair and equitable treatment of waiting list applicants and program participants; and
WHEREAS, the policy language regarding waiting list application interview process is now amended to remove unqualified applicants from the waiting list; and
WHEREAS, the policy language regarding rescheduled informal hearings is amended to assure the policy is applied equally to all participants; and
RESOLVED, that the Board of the Ann Arbor Housing Commission approve the revisions to the Administrative Plan as described in the memorandum above to take effect on June 1, 2019.