ACOP Addition

City of Glendale — Regular Meeting (2023-03-16)

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13.3 CITIZENSHIP/ELIGIBLE IMMIGRANT STATUS (§5.506) 
To be eligible for Federal housing assistance, at least one member of the 
household must be a U.S. citizen or have a qualifying immigration status. 
The eligible person does not have to be the person completing the 
application and the eligible person is not required to be an adult. A family 
in which some family members have eligible immigration status, and 
some do not contend eligible immigration status, is called a mixed-status 
family/household. Mixed-status families/households receive prorated 
assistance based on the percentage of family/household members who 
qualify for assistance. An ineligible adult applying for benefits on behalf 
of an eligible person will be included as an ineligible household member. 
13.3.1 Qualifying Immigration Statuses 
An individual who is not a U.S. citizen or national who is a resident of the 
U.S. and has any of the following immigration statuses is eligible for 
assistance: 
• 
A non-citizen lawfully admitted for permanent residence as an 
immigrant (includes special agricultural workers granted lawful 
temporary resident status and noncitizens that indicate they have 
satisfactory immigration status, such as VAWA self-petitioners, 
whose verification of eligibility or appeal of a determination as to 
permanent residence is pending with DHS). 
• 
A non-citizen who entered the United States before 1/1/72 (or such 
later date as enacted by law) and: 
o Has continuously maintained residence in the U.S. since then; and 
o Is not ineligible for citizenship, but who is deemed to be 
lawfully admitted for permanent residence as a result of an 
exercise of discretion by the Attorney General. 
• 
A non-citizen who is lawfully present in the United States as a result of: 
o Refugee status, including: 
1) Those granted Temporary Protective Status (TPS) under 
the Victims of Trafficking and Violence Protection Act of 
2000 (P.L. 106-386) (section 207 of the Immigration and 
Nationality Act (INA)) – these families have a “T” visa; or 
2) The granting of asylum (which has not been terminated (section 
208); or 
3) The granting of conditional entry (section 203 (a)(7)) 
prior to 4/1/80 because of persecution of fear on account of 
race, religion, or political opinion, or because of being 
uprooted by catastrophic national calamity. 
• 
A non-citizen who is lawfully present in the United States as a 
result of an exercise of discretion by the Attorney General for

emergent reasons or reasons deemed strictly in the public interest 
(section 221(d)(5)) (e.g., parole status). 
• 
A non-citizen who is lawfully present in the United States as a result 
of the Attorney General's’ withholding deportation (section 243(h)) 
(threat to life or freedom). 
• 
A non-citizen lawfully admitted for temporary or permanent 
residence (245A) (amnesty granted). 
• 
An alien who is lawfully residing in the United States and its 
territories and possessions under section 141 of the Compacts of 
Free Association between the Government of the United States 
and the Governments of the Marshall Islands, the Federated States 
of Micronesia (48 U.S.C. 1901 note) and Palau (48 U.S.C. 1931 
note) while the applicable section is in effect: Provided, That, within 
Guam any such alien shall not be entitled to a preference in 
receiving assistance under this Act over any United States citizen 
or national resident therein who is otherwise eligible for such 
assistance. 
13.3.2 Documentation of Citizenship or Immigration Status 
For each family member who contends that he or she is a U.S. citizen or 
a noncitizen with eligible immigration status, the family must submit to 
GHA a written declaration, signed under the penalty of perjury, declaring 
whether he or she is a U.S. citizen or a noncitizen with eligible immigration 
status8. For children, the declaration must be signed by an adult residing 
in the assisted dwelling unit who is responsible for the child9. 
If one or more members of a family elect not to contend that they have 
eligible immigration status, and other members of the family establish 
their citizenship or eligible immigration status, the family may be eligible 
for prorated assistance despite the fact that no declaration or 
documentation of eligible status is submitted for one or more members of 
the family. The family, however, must identify in writing to GHA, the family 
 
 
member (or members) who will elect not to contend that he or she has 
eligible immigration status10. 
13.3.2.1 Evidence of Citizenship or Eligible Immigration Status11 
Each family member claiming program eligibility, regardless of age, must 
submit the following evidence to GHA: 
(1) For U.S. citizens or U.S. nationals, the evidence consists of a 
signed declaration of U.S. citizenship or U.S. nationality. The

responsible entity may request verification of the declaration by 
requiring presentation of a United States passport or other 
appropriate documentation, as specified in HUD guidance. 
(2) For noncitizens who are 62 years of age or older or who will be 
62 years of age or older and receiving assistance under a Section 
214 covered program on September 30, 1996 or applying for 
assistance on or after that date, the evidence consists of: 
(i) A signed declaration of eligible immigration status; and 
(ii) Proof of age document. 
(3) For all other noncitizens, the evidence consists of: 
(i) A signed declaration of eligible immigration status; 
(ii) One of the INS documents referred to in §5.510; and 
(iii) A signed verification consent form. 
Documentation must be submitted by the time of the eligibility 
determination. Once documents have been submitted and verified for an 
individual, citizenship documentation for that individual will not need to be 
collected again. Household members who do not provide the required 
evidence of citizenship or eligible immigration status will be considered 
ineligible. 
13.3.2.2 
Extensions 
GHA must provide an extension of up to 30 days to submit evidence of 
eligible status if the family/household submits the declaration of eligible 
immigration status and certifies that the family needs more time because 
the required evidence is temporarily unavailable. To obtain an extension, 
the family/household must also certify that prompt and diligent efforts will 
be undertaken to obtain the evidence. 
Upon determining if the extension request meets the requirements, GHA 
must inform the family, in writing, whether its request for a time extension 
has been granted or denied. If 
granted, the notice must state the specific period of the extension. If the 
extension request is denied, the notice must explain the reasons for the 
denial. 
13.3.3 Verification of Eligible Immigration Status 
GHA is required to verify eligible immigration status of at least one 
household member through the U.S. Citizenship and Immigration Service 
(CIS). GHA may not admit any individual prior to receiving the required 
documentation described in Section 5.3.2.1. above.

13.3.3.1Primary Verification Method 
GHA will conduct primary verification of eligible immigration status for at 
least one household member through the CIS automated system, 
Systematic Alien Verification for Entitlements (SAVE). 
13.3.3.1Secondary verification method 
If the primary verification system does not confirm eligible immigration 
status for at least one household member, or if the primary verification 
system verifies immigration status that is ineligible for assistance GHA 
must attempt secondary verification by requesting a manual record check 
by CIS within 10 days of receiving results of the primary verification. To 
request secondary verification, the GHA will forward photocopies of the 
original required documents with the form G-845S Document Verification 
Request or such other form specified by the. 
If secondary verification fails, GHA must notify the family/household in writing to 
include: 
• 
A statement that financial assistance will be denied or terminated 
and the justification; 
• 
Notification that the family may be eligible for prorated assistance 
if it is a mixed- status family; 
• 
In the case of a currently assisted household, the procedures for 
requesting proration of assistance; 
• 
The right to appeal the results of the secondary verification to the 
CIS and how to appeal; and 
• 
The right to request an informal hearing from the GHA in lieu of 
or after a CIS appeal 
13.3.3.2 CIS Appeals Process 
GHA must notify the family in writing if the secondary verification process 
does not confirm eligible immigration status for at least one household 
member. The notice must indicate whether assistance will be delayed, 
denied, or terminated and inform the family of the right to file an appeal 
with the CIS. 
If the family wants to exercise its right of appeal with the CIS, the family 
must submit a written request for an appeal to the CIS within 30 days of the 
date of the GHA notification. The family must also take the following steps: 
 
• 
Include with the appeal request a cover letter and any support 
documentation as well as a copy of the verification request form 
(CIS Form G-845S) which was submitted by GHA for the 
secondary verification request; 
• 
Provide GHA with a copy of the request for appeal with the CIS

and proof of mailing (e.g., USPS Certified Mail ©, a service that 
provides the sender with a mailing receipt); and 
• 
Provide any additional documentation that the CIS may request. 
Within 30 days the CIS must render its decision to the family and forward 
a copy to GHA (or provide notice of the reasons for any delay). 
13.3.3.3 Delay, Denial, or Termination of Assistance 
GHA will not delay, deny, or terminate assistance to an applicant or 
participant on the basis of ineligible immigration status of a family member 
if any of the following circumstances apply: 
• 
At least one person in the household is a U.S. citizen or an 
eligible noncitizen who has been verified by CIS; 
• 
The family has submitted the required documents to GHA in a 
timely manner, but the primary and secondary verification 
processes has not been completed; 
• 
The family member whom the GHA has not determined eligible 
moves out of the household; 
• 
The CIS appeals process has not been completed; 
• 
Assistance is prorated, and the family is not receiving assistance 
for the family member(s) whose eligible immigration status has 
not been verified; or 
• 
For a program participant, the informal hearing process 
is not complete. Assistance must be denied or terminated 
when: 
• 
The family has not submitted the declaration of citizenship or 
eligible immigration status for at least one household member and 
appropriate documentation by the specified deadline or any 
extension; 
• 
The family has submitted required documentation, but CIS primary 
and secondary verification do not verify immigration status and the 
family does not pursue CIS or GHA appeal; 
• 
The family has submitted required documentation, but CIS primary 
and secondary verification do not verify immigration status, and 
CIS or GHA appeal is pursued but decision(s) are rendered against 
the family; or 
• 
GHA determines that a family has knowingly permitted an ineligible 
person to live in the assisted unit. In this case, GHA must terminate 
assistance for at least 24 months. This does not apply if the ineligibility of 
the ineligible individual at issue was considered in calculating any 
proration of assistance provided for the family.

For information regarding verification of citizenship status, see Chapter 
13.12 for details and Exhibit 1 for document types.