HHSC Memo

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HHSC Memorandum Neighborhood Resources Department- Memo No. HD 24-02

Date: March 6, 2024
To: Housing and Human Services Commission
Thru: Leah Powell, Neighborhood Resources Director

Amy Jacobson, Housing and Redevelopment Senior Manager}
From: Angie Sauceda, Housing Assistance Senior Program Manage

Subject: Resolution NO. HO178 Approving the Submission of The City of Chandler
Housing and Redevelopment 2024 Annual Plan and Capital Fund for The Fiscal
Year Beginning July 1, 2024, and Certifying Compliance with The Related
Regulations.

Recommendation: Staff proposes to the Housing and Human Services Commission
(HHSC) members the recommendation to the Public Housing Authority Commission (PHAC)
the approval of Resolution No. HO178 approving the submission of the City of Chandler
Housing and Redevelopment Annual Plan and Capital Fund for the fiscal year beginning July
1, 2024, and certifying to compliance with the related regulations.

Background: The City of Chandler Housing and Redevelopment Division (the Public Housing
Agency/PHA) administers 303 units of Low Rent Public Housing and 495 Housing Choice
Vouchers (also known as Section 8).

The Public Housing Agency (PHA) is required to submit the PHA Annual Plan to the U.S.
Department of Housing and Urban Development (HUD) by April 12, 2024, for its housing
programs. The Annual Plan is a comprehensive guide to PHA policies, programs, operations,
and strategies for meeting local housing needs and goals. Each year, staff reviews policies
and revises supporting documents, as needed.

Discussion: This year we will be submitting the 2024 Annual Plan and Capital Fund. The
process allows for community input from program participants, residents, and the public in
general. The City had a public comment period from Jan. 19, 2024, to March 5, 2024, for the
City of Chandler Housing and Redevelopment Division’s 2024 Annual Housing Plan. We had
two Resident Advisory Board (RAB) meeting on December 14, 2023, and January 25, 2024.
No public comments were received.

Memo No. HD 24-02
March 6, 2023
Page 2

The draft 2024 Annual Plan and Capital Fund can be found on our website at
chandleraz.gov/affordablehousing. A summary of updates is outlined below:

Housing Choice Voucher Administrative Plan and Public Housing Admissions and
Continued Occupancy Policy (ACOP)

Unit Inspections

Maintaining properties to the standard of safe, sanitary, and in good repair by complying
with the National Standards for the Physical Inspection of Real Estate; Inspection Standards
(NSPIRE).

Housing Opportunity Through Modernization Act of 2016 (HOTMA)

On July 29, 2016, the HOTMA Act of 2016 was signed into law. HOTMA made numerous
changes to statues governing HUD programs, including sections of the United States Housing
Act of 1937, Title 1 of HOTMA contains 14 different sections that impact the public housing
and Section 8 programs. The final Rule implementing broad changes to income and assets
in Sections 102 and 104 of HOTMA, and for PHAs that administer the public housing program
over-income provisions in Section 103, was officially published in the Federal Register on
February 14, 2023. On September 29, 2023, HUD issued notice PIH 2023-27, which provided
guidance to PHAs on the implementation of the program changes described in the Final Rule.

Eligibility - Restriction on Assistance based on Assets [24 CFR 5.618]

The applicant family must meet net asset and property ownership restriction
requirements. There are two circumstances under which a family is ineligible for the
program based on asset ownership. First, assistance may not be provided to any family if
the family’s net assets exceed $100,000. Second, the family has real property that is
suitable for occupancy by the family as a residence.

Prohibition Against Denial of Assistance to Victims of Domestic Violence, Dating Violence,
Sexual Assault, Stalking, and Human Trafficking

The Violence against Women Act (VAWA) and the HUD regulations at 24 CFR 85.2005(b)
prohibit PHAs from denying admission to an otherwise qualified applicant on the basis or as
a direct result of the fact that the applicant is or has been a victim of domestic violence,
dating violence, sexual assault, or stalking. Although the VAWA 2022 statute does not
specifically include human trafficking in the list of victims protected under VAWA, in 2022
HUD began including human trafficking as part of the list of victims protected under VAWA
(as seen in Notices PIH 2022-06, PIH 2022-22, and PIH 2022-24). In the absence of a final rule
implementing VAWA 2022 and to mirror HUD’s recent usage, this policy includes human
trafficking in addition to domestic violence, dating violence, sexual assault, and stalking
anywhere such a list appears.

Memo No, HD 24-02
March 6, 2023
Page 3

Reasonable Accommodations

For continued approval, the family must submit a new written request subject to PHA
verification every year or every other year during the annual reexamination process. /f the
knowledgeable professional indicates on PHA verification that it is a lifetime impairment and a
reasonable accommodation is essential for the care and well-being of the elderly, near elderly, or
disabled family member, no further written request needs to be submitted.

Earned Income Disallowance [24 CFR 960.255; Streamlining Final Rule (SFR) Federal
Register 3/8/16; Notice PIH 2023-27]

HOTMA removed the statutory authority for the EID. The EID is available only to families
that are eligible for and participating on the program as of December 31, 2023, or before;
no new families may be added on or after January 1, 2024. If a family is receiving the EID
prior to or on the effective date of December 31, 2023, they are entitled to the full amount
of the benefit for a full 24-month period. The policies below are applicable only to such
families. No family will still be receiving the EID after December 31, 2025. The EID will
sunset on January 1, 2026, and the PHA policies below will no longer be applicable as of
that date or when the last qualifying family exhausts their exclusion period, whichever is
sooner.

Family Consent to Release of Information (Form HUD-9886) [24 CFR 5.230(b)(1), (b)(2),
(c)(4), and (c)(5); Notice PIH 2023-27]

All adult applicants and tenants must sign form HUD-9886, Authorization for Release of
Information. All adult family members (and the head and spouse/cohead regardless of age)
are required to sign the Form HUD-9886 at admission. Participants, prior to January 1,
2024, signed and submitted Form HUD-9886 at each annual reexamination. HOTMA
eliminated this requirement and instead required that the Form HUD-9886 be signed only
once. On or after January 1, 2024 (regardless of the PHA’s HOTMA compliance date),
current program participants must sign and submit a new Form HUD-9886 at their next
interim or annual reexamination. This form will only be signed once.

Utility Allowances

The utility allowance is the amount that a housing authority determines necessary to cover
the resident's reasonable utility costs. The utility allowance schedules are reviewed annually
for both housing programs and are recommended for adjustment when a cumulative
change of 10% or more occurs. Prior to beginning this update, a consultant was hired to do
a comparison of the existing utility rates and charges and Housing's current utility rate
schedules in the Housing Choice Voucher and Public Housing Programs. A revised utility
allowance for 2024 will be established for both programs effective July 1, 2024.

Memo No. HD 24-02
March 6, 2023
Page 4

Housing Choice Voucher Administrative Plan

Special Programs - Veterans Affairs Supportive Housing (VASH)

Using Income Limits for Eligibility [24 CFR §982.201]

Income limits are used for eligibility only at admission. Income eligibility is determined by
comparing the annual income of an applicant to the applicable income limit for their family
size. In order to be income eligible, an applicant family must be at or below 80% AMI.

Checking and Savings Accounts

For regular checking accounts and savings accounts, cash value has the same meaning as
market value. If a checking account does not bear interest, the anticipated income from the
account is zero. In determining the value of a checking account, the PHA will use the
average monthly balance for the last two current months.

Public Housing Admissions and Continued Occupancy Policy (ACOP)

Maintenance Policy
Key Information and Charges (Section 5.0)
The cost for additional keys increased from $3.00 to $6.75.

Financial Implications: HUD funds the costs associated with the Public Housing and
Housing Choice Voucher Programs.

Proposed Motion: Move to recommend Resolution No. HO178 of the Public Housing
Authority Commission authorizing the submission of the City of Chandler Housing and
Redevelopment Annual Plan and Capital Fund for the fiscal year beginning July 1, 2024, and
certifying to compliance with the related regulations.

Attachments: Resolution No, HO178