Part 1 - Upland Housing Authority
Transcription
Part 1 - Upland Housing Authority
HOUSING AUTHORITY OF THE CITY OF UPLAND, CALIFORNIA MOVING TO WORK DEMONSTRATION PROGRAM APPLICATION TRANSFORMING HOUSING – TRANSFORMING LIVES JUNE 2012 Housing Authority of the City of Upland 1200 N Campus Avenue Upland, CA 91786 www.uplandhousing.com TABLE OF CONTENTS Part A. Eligibility Certification ......................................................................................................... 1 1. Certification of Meeting Applicable Eligibility Requirements....................................... 2 2. Compliance With Fair Housing and Civil Rights Laws ................................................... 3 3. Certification of Consistency of the PHA Plan, Amendments to the PHA Plan, and MTW Plan with the Consolidated Plan of the City of Upland and Analysis of Impediments to Fair Housing Choice ............................................................................ 4 Part B. Evidence of Capability ......................................................................................................... 5 1. Summary of Relevant Experience and Skills ................................................................. 6 2. UHA Experiences, Activities and Accomplishments ..................................................... 8 3. Innovation and Creativity............................................................................................ 12 4. PHAS Scores ................................................................................................................ 14 5. Section Eight Management Assessment Program (SEMAP) Scores ........................... 14 6. Housing Choice Voucher Utilization Information ....................................................... 14 7. Public Housing Occupancy Information ...................................................................... 14 8. Certification That UHA Has Submitted Its Last Three Agency Plans on Time............. 14 9. Certification That UHA is In Compliance With HUD’s Asset Management Policy ...... 14 10. Request for Authority to Use and Combine Assistance Received Under Sections 8 and 9 of the 1937 Act ................................................................................ 14 Part C. First Year Annual MTW Plan ............................................................................................. 15 Section I. Introduction ...................................................................................................... 16 A. Table of Contents .................................................................................................. 16 B. Overview of UHA’s Goals and Objectives ............................................................. 19 Section II. General Housing Authority Operating Information ......................................... 22 A. Housing Stock Information ................................................................................... 22 B. Leasing Information, Planned ............................................................................... 24 C. Waiting List Information ....................................................................................... 24 Section III. Non-MTW Related Housing Authority Information ........................................ 25 A. List of Planned Sources and Uses of Other HUD or Other Federal Funds ............ 25 B. Description of Non-MTW Activities Proposed by the Agency .............................. 25 Section IV. Long-term MTW Plan ...................................................................................... 26 Section V. Proposed MTW Activities ................................................................................ 27 Activity 1: Single-Fund Budget ................................................................................. 28 Table of Contents Activity 2: Exemption from SEMAP and PHAS Scoring; New Local Assessment System ..................................................................................................... 30 Activity 3: Simplify Income and Rent Calculations ................................................... 32 Activity 4: Biennial Reexaminations for MTW Families ........................................... 38 Activity 5: Increase Minimum Rents from $50 to $125 ........................................... 41 Activity 6: Limited Term of Participation in the MTW Program............................... 45 Activity 7: Progressive Flat TTP for MTW Families ................................................... 50 Activity 8: Simplify Utility Allowances ...................................................................... 55 Activity 9: Biennial HQS Inspections for Qualified Units .......................................... 59 Activity 10: Limit Voluntary Transfers ........................................................................ 62 Activity 11: Local Portability Policies .......................................................................... 64 Activity 12: Expand Project-Based Voucher Program to a Maximum of 50% of HAP Budget Authority ............................................................................. 66 Activity 13: Pilot Mobility Program ............................................................................ 68 Section VI. Ongoing MTW Activities (N/A) ....................................................................... 71 Section VII. Sources and Uses of Funds ............................................................................ 72 A. Planned Sources and Uses of HUD Funds ............................................................. 72 B. Planned Sources and Uses of State or Local Funds .............................................. 72 C. Planned Uses of the COCC .................................................................................... 73 D. Deviation from Cost Allocation or Fee for Service Approach ............................... 73 E. Use of Single-Fund Flexibility ................................................................................ 73 F. Reserve Balances at the Beginning of the Plan Year ............................................ 73 G. Planned Sources and Uses by AMP....................................................................... 73 Section VIII. Administrative ............................................................................................... 74 A. Resolution Signed by the Chairman of the UHA’s Board of Commissioners ........ 74 B. Description of any Planned or Ongoing Agency Evaluations of the Demonstration ...................................................................................................... 74 Part D. Evidence of Community Support and Involvement ......................................................... 75 1. Evidence That UHA Has Provided Community and PHA Resident Support Participation in Developing its MTW Application, Including a Public Hearing ........... 76 2. Board Resolution Approving the MTW Application and Adopting the Annual MTW Plan Certifications of Compliance ..................................................................... 77 3. Description of Significant Partnerships....................................................................... 77 Table of Contents 4. Description of Funding Leveraging and Other In-Kind Resources .............................. 78 5. Description of Consistency of This Plan, the PHA Plan, and Amendments to the PHA Plan With the City of Upland’s Consolidated Plan and Certificate of Consistency ................................................................................................................. 78 Part E. Additional Information Regarding Implementation of MTW Plan.................................... 79 1. Demographic Information .......................................................................................... 80 2. Assistance Targeting Information ............................................................................... 84 3. Proposed Schedule for Implementation .................................................................... 84 4. Potential Local and National Impact of the MTW Plan ............................................. 85 5. Extent to Which the Plan Has the Potential as a Replicable Program Model ............ 86 ATTACHMENTS A. Certification of Meeting Applicable Eligibility Requirements ............................................... 87 B. Certification of Consistency with the Consolidated Plan ...................................................... 90 C. Board Resolution ................................................................................................................... 91 D. Capital Fund Five-Year Plan .................................................................................................. 92 EXHIBITS 1. Letters of Support for UHA and this MTW Plan .................................................................... 93 Congressman Gary Miller Upland Mayor Ray Musser County of San Bernardino 4th District Supervisor Gary Ovitt San Diego Housing Commission Making a Difference Association Chaffey Community College 2. NAHRO Award of Merit Applications .................................................................................... 94 3. ARRA Water-Wise Landscape Conversion Project Profile..................................................... 95 4. Five-Star Safety Program Profile ........................................................................................... 96 5. Los Olivos News Public Housing Newsletter Announcing Kick-Off of UHA Curb Appeal Program ................................................................................................................................. 97 6. Los Olivos News Public Housing Newsletter Announcing MTW Application Process .......... 98 7. UHA Bulletin HCV Newsletter Announcing MTW Application Process ................................. 99 8. Printouts of MTW Announcements in the Inland Valley Daily Bulletin Newspaper ........... 100 9. Printouts from UHA Website Announcing MTW Application Process and Posting of Related Information ............................................................................................................ 101 Table of Contents 10. Announcement to Upland Community Partners re: UHA’s MTW Application .................. 102 11. Summary of Public Comments on UHA’s Proposed MTW Plan .......................................... 103 12. Sign-In Sheets from Meetings to Discuss UHA’s Proposed MTW Plan .............................. 104 13. Agenda from Public Hearing Held June 11, 2012 ............................................................... 105 14. Suspended Interjurisdictional Agreement between UHA and HACSB ................................ 106 Table of Contents Part A: Eligibility Certification PART A: ELIGIBILITY CERTIFICATION 1 Part A: Eligibility Certification 1. CERTIFICATION OF MEETING APPLICABLE ELIGIBILITY REQUIREMENTS Included as Attachment A of this application. 2 Part A: Eligibility Certification 2. COMPLIANCE WITH FAIR HOUSING AND CIVIL RIGHTS LAWS UHA hereby certifies that it does and will comply with all applicable fair housing and civil rights requirements in 24 C.F.R. 5.105(a), including, but not limited to, the Fair Housing Act; Title VI of the Civil Rights Act of 1964; Section 504 of the Rehabilitation Act of 1973; Title II of the American with Disabilities Act; Section 109 of the Housing and Community Development Act of 1974. UHA further certifies that it does and will comply with California state and local government laws proscribing discrimination in housing based on sexual orientation or gender identity, and all laws proscribing discrimination based on lawful source of income. 3 Part A: Eligibility Certification 3. CERTIFICATION OF CONSISTENCY OF THE PHA PLAN, AMENDMENTS TO THE PHA PLAN, AND MTW PLAN WITH THE CONSOLIDATED PLAN OF THE CITY OF UPLAND AND ANALYSIS OF IMPEDIMENTS TO FAIR HOUSING CHOICE UHA certifies that our proposed MTW plan is consistent with the City of Upland’s 5-Year Consolidated Plan for 2010-2014 and its analysis of impediments to fair housing choice. A certification from the City of Upland indicating that they have reviewed our proposed MTW plan and that the plan is consistent with the Consolidated Plan is attached as Attachment B. 4 Part B: Evidence of Capability PART B: EVIDENCE OF CAPABILITY 5 Part B: Evidence of Capability 1. SUMMARY OF RELEVANT EXPERIENCE AND SKILLS The entire team at the Upland Housing Authority will be involved in the implementation of the MTW plan. UHA will leverage the individual and collective skills of the team to implement the MTW plan quickly and efficiently, and to continue to develop innovative and progressive solutions to housing challenges. The primary individuals that will be responsible for the implementation of the MTW plan are: Donald Swift, II – Executive Director Mr. Swift has over seventeen years of experience working for local Housing Authorities, with over five years at the Upland Housing Authority, and the last three years serving as its Executive Director. As the Executive Director, Mr. Swift is responsible for directly overseeing and coordinating all aspects of agency and program administration and operations, including human resources, budgeting and accounting, policies and procedures, quality control, and HUD reporting. Before joining the Upland Housing Authority, Mr. Swift worked at the Housing Authority of the County of Los Angeles, California (HACoLA), where he developed an extensive and progressively responsible understanding of program operations and administration, and an acute understanding of what it takes to effectively administer new and existing programs. Mr. Swift started his career with the Section 8 program first as a temporary Office Assistant working with FEMA Vouchers, then as Eligibility Worker for Voucher/Certificate Programs, followed by Policy Analyst, Budget Analyst, Assistant Manager of Administration, and finally as Manager of Administration for the 20,000 unit program. During this time, Mr. Swift was involved with a variety of programs including the Section 8 Certificate and Voucher, Welfare to Work, Moderate Rehabilitation, HOPWA, and Shelter Plus Care. Mr. Swift was also responsible for implementing the new Preservation/Conversion program for landlords opting out of their expiring HUD contracts (Enhanced Vouchers). Mr. Swift has served on the NAHRO National Board of Governors since 2008, is the current regional NAHRO Recording Secretary, is the legislative contact for California NAHRO, and served as president, vice president and treasurer of the Housing Authority Association of Southern California between 2003 and 2009. Xenia (Sammie) Szabo – Housing Consultant Ms. Szabo has previously acted as a consultant to the Upland Housing Authority, and will continue to serve as a consultant to the Upland Housing Authority during the implementation of the MTW plan. Ms. Szabo has been a consultant and trainer for Nan McKay and Associates since January 2009. Ms. Szabo was employed by the Upland Housing Authority from 1973 to 2008, and prior to her retirement in December 2008 she served as the Executive Director of the Upland Housing Authority for 28 years. Ms. Szabo has extensive knowledge of and experience with the Public Housing, HCV and Capital Fund Programs, as well as experience consulting with MTW PHAs 6 Part B: Evidence of Capability across the country. Ms. Szabo served on the Boards of the National Association of Housing and Redevelopment Officials (NAHRO) at the National, Regional and Chapter levels for more than 25 years, as well as the Housing Committee, Section 8 and Legislative Committees of NAHRO. Nicole Beydler - Management Analyst Ms. Beydler has six years of experience with the Upland Housing Authority and is responsible for creating, updating and implementing program policies and procedures, and creating and monitoring reports utilized to track UHA’s performance under SEMAP, PHAS and internal quality assessment systems. Ms. Beydler will serve as lead coordinator for the implementation of the proposed MTW activities and plan, and will work with other members of the management team to conduct public outreach and implement policy and procedure changes. Ms. Beydler will be the lead team member for reporting on metrics and benchmarks. Ms. Beydler has served on the Legislative Committee for the Southern California chapter of the California Association of Housing Authorities since 2010, and also serves on the NAHRO National Housing America Task Force. Mary Mota – Public Housing Manager Ms. Mota has been with the Upland Housing Authority for over seventeen years, serving as HCV Program Supervisor from 2002 to 2006, and as Public Housing Manager since 2006 to present. Toni Lizarraga and Kristie Niebergall – Finance Team Ms. Lizarraga has served as the head of UHA’s Finance Department for 20 years. Her role has been vital in ensuring UHA’s high performer status under PHAS and SEMAP. Ms. Lizarraga will be responsible for converting UHA’s fiscal department to the single fund budget method proposed as Activity 1 of this plan, as well as updating all records and fiscal reports to ensure continued compliance with applicable regulations. Ms. Niebergall has been with UHA since 2008, and is responsible for carrying out day-to-day finance operations, including payroll, accounts payable and receivable, banking, and other functions. 7 Part B: Evidence of Capability 2. UHA EXPERIENCES, ACTIVITIES AND ACCOMPLISHMENTS Although UHA is a small housing authority with just 97 Public Housing units and a baseline of 624 Housing Choice Vouchers, our footprint within the housing industry is that of a much larger agency. We think big. Our drive to continually improve and seek out solutions to industry challenges keeps us moving forward. We are committed to the community and the families we serve, with a focus on sustainability, innovation, and quality. Our commitment and focus are evidenced through UHA’s many achievements. These activities are especially significant in light of UHA’s small staff size, limited resources, and recent funding cuts. With MTW flexibility, UHA could achieve even more. High Performer under SEMAP and PHAS UHA has achieved high performer status under the Public Housing Assessment System (PHAS) and Section Eight Management Assessment Program (SEMAP) every year since the Department implemented these assessment systems. There are no audit findings, including IPA and audits and/or reviews conducted by the Department. Community, Government, and Industry Support for UHA The Upland Housing Authority has the support of the community and local government as well as industry partners. UHA received letters of support for UHA and this MTW application from the Mayor of Upland, community non-profits and service providers, San Bernardino County Fourth District Supervisor Gary Ovitt, U.S. Congressman Gary Miller of the California 42nd District, and the San Diego Housing Commission, an MTW agency. The letters are included as Exhibit 1. NAHRO Awards of Merit – Administrative Innovation and Program Innovation UHA was recently notified that it was selected for recognition by the National Association of Housing and Redevelopment Officials (NAHRO) for Administrative and Program Innovation. UHA will receive the NAHRO Award of Merit for its self-service lobby conversion (administrative innovation) and Resident Services Summer Incentive Program (program innovation). Copies of the applications for both programs are attached as Exhibit 2. Use of ARRA Funds to Install Water-Wise Irrigation and Landscaping Funds received under the American Reinvestment and Recovery Act (ARRA) were combined with Capital Funds and used to install a high-efficiency irrigation system and replace approximately 50% of the existing turf with drought-tolerant California-native plants at UHA’s Los Olivos Public Housing community. UHA was one of the first PHAs in Southern California to obligate and spend its ARRA funds. This project resulted in beautification of the community, and cost savings will help to ensure long-term viability. A profile of the project is attached as Exhibit 3. 8 Part B: Evidence of Capability Five Star Safety Program UHA has developed and implemented a comprehensive safety program to protect employees and visitors. UHA has been recognized by the California Housing Worker’s Compensation Authority (CHWCA) for its outstanding small agency safety program for three out of the last five years, received the injury-free award in 2007 and 2008, and achieved the best overall scores on the CHWCA Risk Assessment from 2006 to 2009. UHA was also selected by CHWCA to make a presentation about its successful program at the CHWCA Annual Meeting in 2011. A copy of UHA’s “Five Star Safety Program” profile presented at the CHWCA Annual Meeting is attached as Exhibit 4. Public Housing Curb Appeal Program: Looking Good In early 2012 UHA implemented a new program designed to help ensure that the Los Olivos community is a place its residents are proud to call home. The Curb Appeal Program helps UHA to spot areas that need improvement, and provides a channel for residents to share their feedback and participate in decisions about their community’s appearance. A copy of the Los Olivos News highlighting the launch of the curb appeal program is attached as Exhibit 5. Appreciation for UHA Employees In 2007 UHA hosted its first Employee Appreciation Event, an afternoon of team-building activities, recognition for outstanding performance and years of service, and a modest lunch hosted by UHA. Since then the events have been held annually or semi-annually, and have included professional development training like customer service and time management. Though modest in scale, these events reflect the enormous appreciation UHA has for the team of hard-working employees that help UHA achieve its mission and maintain its shining reputation. Striving For Efficiency UHA has implemented dramatic changes to improve operational and administrative efficiencies and improve delivery of its services. Some of the changes UHA has made include: Annual Reexaminations By Mail: Forms and letters related to the reexamination process were overhauled and streamlined, and effective April 1, 2012, annual reexaminations for all HCV participants are conducted by mail. This change saved significant staff hours from meeting with the families. It also reduced the burden to working families, who previously had to take time away from work to attend the reexamination appointment. UHA still conducts in-person reexaminations when special circumstances warrant it. Electronic Newsletters: By issuing newsletters through its website only, UHA is able to conserve time and funding associated with paper newsletters. UHA will implement email newsletters later this year. UHA Website: UHA’s website was launched in 2006, and has greatly expanded access to UHA’s services. Through the website, uplandhousing.com, applicants, participants and 9 Part B: Evidence of Capability landlords can obtain forms and information 24 hours a day. Visitors to the website can also report fraud anonymously online. UHA continuously updates the website to include timely news and additional resources to benefit those we serve. Recently, UHA expanded the website to allow landlords to submit available unit information directly through the website. UHA is also currently investigating options to allow visitors to apply for the Public Housing and HCV waiting lists and check the status of their application online. Paperless Board Agendas: Beginning in mid-2012, the agenda and materials for UHA’s monthly meetings of the Board of Commissioners will go electronic. This small change will save paper, time, and funds. UHA File Server and Forms Overhaul: UHA’s file system was overhauled in 2007 to create a central location for access to forms and reports. Additionally, UHA’s forms are undergoing updates to create consistency, make them easier for participants to use, and to create fillable PDF forms that allow staff to quickly enter information. These overhauls have created a more streamlined system that saves staff time. Complete Overhaul of Public Housing Admissions and Continued Occupancy Policy, HCV Administrative Plan: Between 2010 and 2012 UHA made a comprehensive review of its policies and procedures and made numerous changes designed to streamline the programs, provide additional clarification to staff, and ensure consistency in their application. In particular, UHA focused on the policies and procedures related to management of the waiting lists and the admissions, eligibility, and terminations processes. Strategic Planning Efforts: Beginning in 2009, UHA initiated an annual comprehensive agency-wide strategic planning effort to streamline administrative and operational functions. As part of the effort, staff are encouraged to identify areas of opportunity for cost savings or efficiency. Improvements that have been made since the inception of the annual process include: o Overhaul of UHA’s employee personnel policies and job descriptions; o Revision of administrative policies including procurement and purchase order procedures; o Line item budget review process; o Further development of UHA’s Section 3 plan o Development and implementation of safety policies such as the Return to Work policy for injured employees, distracted driver policy, and hazardous energy control program (“Lock-Out/Tag-Out); o Timekeeping system replacement to eliminate manual timekeeping procedures; o Computer system and server upgrades; o Agency-wide reorganization of departments and staff duties. These practical and prudent measures implemented over the past few years have helped to focus the agency’s resources to meet the highest priorities without compromising its commitment to high standards. 10 Part B: Evidence of Capability Involvement with Industry Organizations UHA is a member of National Association of Housing and Redevelopment (NAHRO) at the national, regional and local levels, and a member of the California Association of Housing Authorities (CAHA). Our reputation as a well-run agency has earned us the opportunity to represent UHA as well as PHAs across California and the nation at conferences and to our legislators. UHA attends the annual NAHRO legislative conference in Washington, D.C., and is routinely asked to speak about housing needs and challenges during meetings with legislators and key staff. Members of UHA’s staff have served on multiple committees and boards of each organization. UHA’s Executive Director, Don Swift, has served on the NAHRO National Board of Governors since 2008, is the current Recording Secretary for the Pacific Southwest Regional Council of NAHRO, is the legislative contact for California NAHRO, and served as president, vice president and treasurer of the Housing Authority Association of Southern California between 2003 and 2009. Nicole Beydler, UHA’s Management Analyst, has served on the Legislative Committee for the Southern California chapter of the California Association of Housing Authorities since 2010, and also currently serves on the NAHRO National Housing America Task Force. Bond Property Oversight UHA currently serves as the compliance monitor for three affordable housing projects in the City of Upland, including one bond property and two properties financed by the Upland Community Redevelopment Association. UHA is responsible for working directly with the properties to verify and facilitate compliance with the affordability restrictions imposed on each property. 11 Part B: Evidence of Capability 3. INNOVATION AND CREATIVITY Although it is incredibly difficult for a small PHA burdened with the complex regulations governing the Public Housing and HCV programs to dedicate staff time and funds to exhibit significant innovation and creativity, UHA has managed to accomplish great things in the following areas: Resident Opportunities and Supportive Services The primary objective of UHA’s resident services program is to strengthen family foundations, offer positive activities for children, provide a resource for families to research employment and training opportunities, and refer families and individuals to community resources such as utility payment assistance, community service programs, and support groups. Through a variety of partnerships and activities, UHA is able to meet these objectives. UHA funds and administers an after school program that serves the youth of its Public Housing program, and has been doing so for more than 30 years. The program has been located in various office spaces at the Los Olivos Public Housing community throughout the years. In 2006, UHA completed a conversion of its former administrative office building and the space was dedicated to the resident services program. The dedicated Resident Services Center houses a small library, approximately fifteen computer and internet access stations, and a variety of recreational games and activities. Youth residents of the Los Olivos community visit the Center for homework assistance, to use the computers to conduct research and prepare homework, and to join other residents for recreational activities and sports. Adults also visit the center to complete homework, to obtain assistance helping their own children with homework, conduct job searches, research driving directions, and to attend Girl Scout meetings with their daughters. The afterschool program funded by UHA, UHA’s resident services program, and other programs and services including the VIC’s Place afterschool program and the local Girl Scout troop all take place at the Resident Services Center. The Very Important Children’s Place (“VIC’s Place”) provides a supplemental afterschool homework assistance program. The program is open to residents of UHA’s Public Housing residents and HCV participants, and other local elementary school-age children that reside in the surrounding community, during the hours immediately after school. The program is offered through a three-way partnership between the Upland Housing Authority, the Upland Community Partnership for Youth Development non-profit, and the City of Upland Parks and Recreation Department. As a result of its partnership to host the VIC’s place program, UHA has hosted the Upland Bookmobile since 2009. The Bookmobile is a mobile library service established by the City of Upland Parks and Recreation Department. This customized vehicle brings the Library to children at City-sponsored afterschool homework centers and day camps, including UHA’s VIC’s Place location. The Bookmobile visits the Los Olivos community biweekly and provides on-site access to library books and services. 12 Part B: Evidence of Capability UHA also works with other local service groups, including the Girl Scouts and Project Sister, to host workshops and activities for residents and participants. In partnership with these organizations, UHA has hosted workshops on self-defense, the National Night Out crime awareness campaign, and numerous Girl Scout troop activities. UHA has also previously worked with Women on the Move to host a mentoring program for girls age 8-12, and had a long-standing relationship with the Boys and Girls Club to host their program at the Los Olivos site. Other local service groups such as the Upland Kiwanis provide support to the resident services programs through donations of time, materials and money to purchase books for the library, computer equipment, and other supplies. Family Self-Sufficiency/Homeownership UHA administered a family self-sufficiency program until 2006. UHA no longer administers an FSS program, as it has not received FSS Coordinator funds since 2006 and is unable to fund an FSS coordinator without additional funds. During UHA’s administration of the FSS program, a total of 51 families participated in the FSS program. 25 families successfully completed their contracts and, with the Housing Authority’s assistance, two (2) families utilized their FSS Escrow Accounts to become homeowners. Energy Efficiency Improvements UHA was a leader in energy efficiency efforts long before it became a Department priority. Starting in 1973, UHA began utilizing capital funds (previously called CIAP) to modernize the units, which were constructed in 1943. All water and gas lines were replaced, old single-hung windows were replaced with dual-pane energy efficient windows, energy efficient water coolers were installed to reduce electrical costs and allow families to efficiently cool their homes, and flat-roofs were replaced with pitched roofs and insulation. UHA worked with local providers to obtain and install water efficient toilets, shower heads and aerators free of charge. UHA’s energy conservation program was so successful and complete at the time of its 2008 energy audit the only areas that were still suitable for energy conservation efforts were the project grounds for water conservations. UHA utilized 2006, 2007 and 2008 Capital Funds and 100% of ARRA funds to implement a very successful Xeriscaping and Irrigation project which replaced approximately fifty percent of the turf around the 13 acre Public Housing community with California native drought tolerant plantings, and substantially decreased water consumption. UHA applied for and received a rebate of over $11,000 for the high-efficiency nozzles installed as part of the new irrigation system. A profile of the project is attached as Exhibit 3. 13 Part B: Evidence of Capability 4. PHAS SCORES UHA is a high-performer under PHAS. UHA’s PHAS score for 2011 is 97%. 5. SECTION EIGHT MANAGEMENT ASSESSMENT PROGRAM (SEMAP) SCORES UHA is a high-performer under SEMAP. UHA’s 2011 SEMAP score is 96% (130 out of 135 points) and the anticipated score for 2012 is 96% (130 out of 135 points). 6. HOUSING CHOICE VOUCHER UTILIZATION INFORMATION UHA’s current HCV utilization rate is 98% of baseline units. Budget authority utilized in calendar year 2010 was 97.8%. 7. PUBLIC HOUSING OCCUPANCY INFORMATION UHA’s Public Housing is 98% occupied. Two units are currently vacant because they are undergoing modernization. One unit is expected to be completed by August 30, 2012, and the other by December 30, 2012. 8. CERTIFICATION THAT UHA HAS SUBMITTED ITS LAST THREE AGENCY PLANS ON TIME I hereby certify that the Upland Housing Authority has submitted its Agency Plan on time the past three years. The Department has approved every Agency Plan submitted, including the current 5-year Plan. 9. CERTIFICATION THAT UHA IS IN COMPLIANCE WITH HUD’S ASSET MANAGEMENT POLICY I hereby certify that the Upland Housing Authority is in compliance with HUD’s asset management policy. 10. REQUEST FOR AUTHORITY TO USE AND COMBINE ASSISTANCE RECEIVED UNDER SECTIONS 8 AND 9 OF THE 1937 ACT The Upland Housing Authority hereby requests authority to use and combine assistance received under Sections 8 and 9 of the 1937 Act to the extent necessary to implement the proposed First Year Annual MTW plan included as Part C of this application. 14 Part C: First Year Annual MTW Plan PART C: FIRST YEAR ANNUAL MTW PLAN 15 Part C: First Year Annual MTW Plan Section I: Introduction A. TABLE OF CONTENTS Section I. Introduction .................................................................................................................. 15 A. Table of Contents .............................................................................................................. 16 B. Overview of UHA’s Goals and Objectives ......................................................................... 19 Section II. General Housing Authority Operating Information ..................................................... 22 A. Housing Stock Information ............................................................................................... 22 B. Leasing Information, Planned ........................................................................................... 24 C. Waiting List Information ................................................................................................... 24 Section III. Non-MTW Related Housing Authority Information .................................................... 25 A. List of Planned Sources and Uses of Other HUD or Other Federal Funds ........................ 25 B. Description of Non-MTW Activities Proposed by the Agency .......................................... 25 Section IV. Long-term MTW Plan .................................................................................................. 26 Section V. Proposed MTW Activities ............................................................................................ 27 Activity 1: Single-Fund Budget ............................................................................................ 28 Activity 2: Exemption from SEMAP and PHAS Scoring; New Local Assessment System ................................................................................................................ 30 Activity 3: Simplify Income and Rent Calculations.............................................................. 32 Activity 4: Biennial Reexaminations for MTW Families ...................................................... 38 Activity 5: Increase Minimum Rents from $50 to $125 ...................................................... 41 Activity 6: Limited Term of Participation in the MTW Program ......................................... 45 Activity 7: Progressive Flat TTP for MTW Families ............................................................. 50 Activity 8: Simplify Utility Allowances................................................................................. 55 Activity 9: Biennial HQS Inspections for Qualified Units .................................................... 59 Activity 10: Limit Voluntary Transfers................................................................................... 62 Activity 11: Local Portability Policies .................................................................................... 64 Activity 12: Expand Project-Based Voucher Program to a Maximum of 50% of HAP Budget Authority ........................................................................................ 66 Activity 13: Pilot Mobility Program ....................................................................................... 68 Section VI. Ongoing MTW Activities (N/A) ................................................................................... 71 Section VII. Sources and Uses of Funds ........................................................................................ 72 A. Planned Sources and Uses of HUD Funds ......................................................................... 72 B. Planned Sources and Uses of State or Local Funds .......................................................... 72 16 Part C: First Year Annual MTW Plan Section I: Introduction C. Planned Uses of the COCC ................................................................................................ 73 D. Deviation from Cost Allocation or Fee for Service Approach ........................................... 73 E. Use of Single-Fund Flexibility ............................................................................................ 73 F. Reserve Balances at the Beginning of the Plan Year ........................................................ 73 G. Planned Sources and Uses by AMP................................................................................... 73 Section VIII. Administrative ........................................................................................................... 74 A. Resolution Signed by the Chairman of the UHA’s Board of Commissioners .................... 74 B. Description of any Planned or Ongoing Agency Evaluations of the Demonstration ........ 74 17 Part C: First Year Annual MTW Plan Section I: Introduction SECTION I - INTRODUCTION INTRODUCTION This First Year Annual Moving to Work (MTW) Plan was developed by the Housing Authority of the City of Upland (UHA) as part of UHA’s application to participate in the MTW Demonstration Program in response to the Request for Applications issued by the Department of Housing and Urban Development (HUD) on February 27, 2012. The City of Upland was founded on February 10, 1887, and was incorporated on May 15, 1906. City Demographics: Population: 77,461 Total households: 27,177 households Median age: 34.65 years Average household size: 2.83 Average household income: $76,856.00 UHA was established in 1940 by resolution of the Upland City Council. The five-member Upland City Council and two UHA program participants serve as the Housing Authority’s governing Board of Commissioners. UHA administers both Public Housing (97 units) and Section 8 Housing Choice Vouchers (624 baseline units). As a truly small PHA, UHA is committed to developing and implementing an MTW Demonstration program that may become the model for many small PHAs across the country. The goals and activities contained in this plan are designed to be innovative and progressive, but also realistic and attainable for PHAs with extremely limited resources and staff. Goals and activities are designed to provide maximum administrative and cost efficiency while testing innovative solutions to housing challenges. UHA’s application also offers a unique opportunity for testing the MTW program. San Bernardino County is served by the UHA, the Housing Authority of the County of San Bernardino (an MTW PHA since 2008) and Needles Housing Authority. If UHA’s application is approved, the majority of San Bernardino County would be served under the MTW program. As the largest geographic county in the U.S. and with a diverse demographic makeup, the County of San Bernardino is a prime candidate for testing innovative solutions. Additionally, the MTW program would be demonstrated by two agencies of different size within one region: UHA is a small agency with 721 units (97 Public Housing and 624 Housing Choice Voucher) while the Housing Authority of the County of San Bernardino (HACSB) is a very large agency with approximately 10,100 units. Program participants would also benefit from UHA’s designation as an MTW agency. A previous mobility agreement between UHA and HACSB that has been suspended due to programmatic changes implemented by HACSB as an MTW PHA can be reinstated if UHA’s plan is approved, 18 Part C: First Year Annual MTW Plan Section I: Introduction and participants can again enjoy seamless mobility throughout much of San Bernardino County. A copy of the suspended mobility agreement is attached as Exhibit 14. B. OVERVIEW OF UHA’S MTW GOALS AND OBJECTIVES UHA’s application addresses challenges that are unique to small PHAs and the Upland community and those that are common to all housing authorities. The activities contained in this plan are intended to meet the statutory objectives of the MTW demonstration program and to protect and preserve the long-term viability of the programs we administer. Our MTW goals are: 1. Improve viability of the programs by reducing administrative burden and cost and achieving greater cost effectiveness in federal expenditures; 2. Increase the rate of self-sufficiency among assisted families by: a. Creating incentives for families to work, seek work or prepare for work; and b. Establishing partnerships with local service providers to provide supportive services that help families achieve self-sufficiency; 3. Increase housing choices for low-income families through MTW activities, including a pilot mobility program that removes barriers to housing choice and is consistent with the other goals of this plan. Many of the proposed activities address challenges in administration of the programs. These activities will reduce administrative costs, increase efficiencies and streamline the programs, helping to ensure their viability in an unstable funding environment. Reducing or removing complex requirements will also enable participants, applicants, PHA staff and the general public to have a better understanding of program rules and requirements. UHA’s plan also proposes activities designed to encourage economic self-sufficiency and reward working families without negatively affecting elderly and disabled families with fixed incomes as they are defined by UHA in this plan. UHA will ensure that elderly and disabled families with fixed incomes are protected by exempting them from activities that would be unfairly biased toward these families, including the implementation of limited term of assistance and the progressive flat TTP schedule. A key component of UHA’s plan is the development and expansion of a supportive services network to create self-sufficiency potential for assisted families. The Housing Authority of the County of San Bernardino (HACSB) has established partnerships with numerous local supportive service providers to provide supportive services to their participants. UHA has reached out to many of these service providers to discuss the opportunity for providing similar services to UHA participants in the future if UHA receives MTW designation. The response from these organizations was positive. Each organization that we contacted was supportive of UHA’s MTW plan and application, and expressed interest in partnering with UHA in the future. Letters of support from local service providers interested in working with UHA are attached as Exhibit 1. These letters demonstrate a potential for providing a strong network of supportive services to assist our participant families on their individual journeys to self-sufficiency. 19 Part C: First Year Annual MTW Plan Section I: Introduction Lastly, UHA’s plan includes proposed activities that are designed to improve housing choice and the quality of affordable housing. Through a pilot mobility program, UHA plans to greatly expand the area in which participants may lease an assisted unit without the need for complicated portability processes. With the ability to move to other jurisdictions seamlessly, families will enjoy greater housing choice and economic opportunities. Other activities are designed to encourage compliance with Housing Quality Standards (HQS) and increase landlord participation in the HCV program. UHA will track and analyze the outcomes of each of the proposed activities to determine if the activity is contributing toward our MTW goals. Those activities that are determined to be successful will be enhanced or expanded when possible and appropriate. Activities that do not have the desired impact will be restructured or eliminated to allow UHA to refocus its efforts on activities that help us to reach our goals. Although some proposed activities will be implemented only for a limited group of families, such as only new families or only existing families, UHA intends to implement the successful activities to all families in subsequent MTW years. UHA believes that this approach provides two advantages: The unaffected group of families will serve as a control group for the activity, allowing UHA to compare data and measure the activity’s true impact; and It permits UHA to measure the success of the activity before applying it to all families. UHA also intends to allow existing families to voluntarily convert to MTW at any time after implementation of the MTW plan. With MTW flexibility, UHA will accomplish the three statutory goals of MTW through the innovative and progressive activities proposed through this plan. IMPLEMENTATION TIMEFRAME UHA recognizes that the proposed activities contained in this plan cannot be implemented immediately. Some activities will require extensive preparation, including further research and modeling, changes to policies, staff training, updates to UHA’s software and information systems, and extensive community outreach. In order to accommodate these needs, UHA proposes to establish the following schedule for implementation of the activities. UHA has established its Fiscal Year 2013-2014 as our target for MTW Year One. However, this date may be delayed only if necessary to accommodate community outreach and/or updates to UHA’s software and information systems or infrastructure prior to implementation. UHA will make every effort to meet the target implementation date of UHA Fiscal Year 2013-2014. Should a delay be necessary, UHA will begin implementation as quickly as feasible. UHA will define MTW Year One as the year that the first MTW activity contained in this activity is implemented. Activities Prior to MTW Year One: UHA intends to prepare for implementation of MTW Year One activities between the date that UHA receives MTW designation and the start of UHA Fiscal Year 2013-2014. UHA will make 20 Part C: First Year Annual MTW Plan Section I: Introduction revisions to its policies, prepare staff for upcoming changes, and implement software and other changes necessary for activities designated for implementation in MTW Year One. Other preparatory work for MTW Year Two activities will also begin during this time. UHA will conduct extensive community outreach during this time to inform the community and the families we serve of the upcoming changes to our program. MTW Year One: UHA intends to implement the majority of the proposed activities in this plan during MTW Year One, as most activities can be implemented without the need for extensive changes to software and information systems or infrastructure. MTW Year One will also be used to prepare for more complex activities to be implemented during MTW Year Two. UHA will prepare its software systems, conduct training, revise policies and conduct additional research, modeling and analysis necessary for those activities. MTW Year Two: The proposed activities that require more complex changes and/or additional research, modeling and analysis will be implemented during MTW Year Two. 21 Part C: First Year Annual MTW Plan Section II: General Housing Authority Operating Information SECTION II – GENERAL HOUSING AUTHORITY OPERATING INFORMATION A. HOUSING STOCK INFORMATION UHA administers the Conventional Public Housing and Section 8 Housing Choice Voucher (HCV) programs in the City of Upland in the County of San Bernardino, California. UHA manages a single Public Housing development, CA009002, which was placed in service in September 1943. The chart below summarizes the Public Housing units as of June 27, 2012, as well as changes anticipated during Fiscal Year 2013-2014. UNIT INFORMATION NUMBER OF UNITS Total Public Housing units under ACC – (as of June 27, 2012) 97 Units permanently offline 0 Total Public Housing units available for occupancy 97 Total Public Housing units occupied 97 Units to be removed from ACC during the year 0 Units to be added 1* Total Public Housing units expected at the end of the year 98 * UHA is currently in the process of converting a 5-bedroom unit into two 2-bedroom units. The unit was originally a 2-bedroom but was converted to a 5-bedroom in 1983. The conversion is being performed using operating subsidy, not capital funds. Housing stock information continues on next page. 22 Part C: First Year Annual MTW Plan Section II: General Housing Authority Operating Information (1) HOUSING STOCK INFORMATION Number of Public Housing units at the 98 beginning of the year (2) General description of any planned significant capital expenditures by development The Capital Fund Five Year Plan and current Budget is included as Attachment D. The most significant planned capital expenditures using Capital Funds are described in the Capital Fund Five-Year Plan attached (Attachment D), and include initiation of activities to support replacement of water main lines throughout the development and installation of individual water meters at residential units. (3) Description of any new Public Housing units N/A to be added during the year by development (specifying bedroom size, type, accessible features, if applicable) (4) Number of Public Housing units to be 0 removed from the inventory during the year by development specifying the justification for the removal (5) Number of MTW Housing Choice Vouchers (HCV) units authorized 0 (624 units would become MTW if UHA’s application is approved) (6) Number of non-MTW HCV units authorized 624 (UHA intends to convert all units to MTW if UHA’s application is approved) (7) Number of HCV units to be project-based 10% (63) * during the Plan year, including description of each separate project * 71 units were reserved for PBV in 2007 and are still reserved at the time of this application. However, due to economic circumstances and lack of available financing, this project is not expected to be built during Fiscal Year 2012-2013 or for the foreseeable future. UHA anticipates that the application for these project-based vouchers will be withdrawn. The Capital Fund Five Year Plan and current Budget is included as Attachment D. UHA will continue its capital improvements of the Los Olivos Public Housing site (CA009002) in accordance with the Five-Year Plan. In Fiscal Year 2010-2011 and 2011-2012 UHA completed the exterior repair and painting of all residential units and administrative buildings, including rain gutter installation. In Fiscal Year 2012-2013 UHA plans to initiate activities to support replacement of water main lines throughout the development and installation of individual water meters at residential units. 23 Part C: First Year Annual MTW Plan Section II: General Housing Authority Operating Information B. LEASING INFORMATION As a high-performer under SEMAP and PHAS, UHA maintains a very high utilization rate for both the Public Housing and the HCV program. UHA anticipates that it will maintain high leasing rates as an MTW agency. UHA also proposes to convert 100% of its Public Housing and HCV units to some level of MTW. LEASING INFORMATION, PLANNED This information is estimated and may be subject to change during the plan year. (1) Anticipated total number of MTW Public Housing units leased in the Plan year 97 (2) Anticipated total number of non-MTW Public Housing units leased in the Plan None year (3) Anticipated total number of MTW HCV units leased in the Plan year 624 (4) Anticipated total number of non-MTW HCV units leased in the Plan year None (5) Description of anticipated issues relating to any potential difficulties in leasing No anticipated units (Public Housing or HCV) difficulties for 2012 (6) Number of project-based vouchers in use at the start of the Plan year – described below None UHA LEASING INFORMATION – (FISCAL YEAR 2013-2014) Public Housing Housing Choice Vouchers Total Units 98 Total MTW Vouchers Based on CACC Baseline Authority 624 Total Units Leased 98 Total MTW Budget Authority utilized for voucher leasing 100% 100% Percent of Budget Authority MTW Voucher Utilization 100% Percent of Units Leased C. WAITING LIST INFORMATION UHA does not anticipate any changes in the waiting list in the first year of MTW implementation. It is expected that in future MTW years the length of times families wait for assistance will be reduced as families term-out or leave the programs as a result of becoming economically self-sufficient. UHA expects that term limits and income limits for continued assistance will increase affordable housing opportunities for waiting list families. Separate waiting lists are maintained for the Public Housing and HCV programs. Both waiting lists are currently closed and UHA does not anticipate opening the waiting list(s) during Fiscal Year 2012-2013. UHA selects families from the waiting list when necessary in order to fill vacancies in the Public Housing program and to address attrition in the HCV program. Families may apply to either or both waiting lists when the waiting lists are open. 24 Part C: First Year Annual MTW Plan Section III: Non-MTW Related Housing Authority Information SECTION III – NON-MTW RELATED HOUSING AUTHORITY INFORMATION Strategic Plan – It is UHA’s vision to utilize MTW flexibility to demonstrate increased program efficiencies and activities that empower the agency and the families we serve. UHA hopes to become the model for other small PHAs nationwide. As a small PHA, UHA can quickly transform its programs and organizational structure to implement the activities proposed in this plan. UHA strives to achieve continued excellence in its program administration and delivery of services to the community. A. PLANNED SOURCES AND (EXCLUDING HOPE VI) USES OF OTHER HUD OR OTHER FEDERAL FUNDS UHA’s sole sources of federal funds are the Public Housing Operating Fund, Capital Fund, and Section 8 HCV HAP and Administrative Fees. The only other source of funds UHA receives from non-federal sources are administrative fees for monitoring compliance with tax-exempt bonds issued by the UHA or the City of Upland Redevelopment Agency, or development variances by the City of Upland Building Department. The UHA receives $16,225.00 in monitoring fees on an annual basis, and these fees offset UHA’s costs related to affordability compliance monitoring for the related properties. UHA does not receive funds from any other source. 100% of the UHA’s efforts will be directed toward MTW activities and the success of the demonstration program. B. DESCRIPTION OF NON-MTW ACTIVITIES PROPOSED BY THE MTW AGENCY, HUD OFFERINGS AND THE AGENCY’S ASSOCIATED PROPOSALS ADDRESSING HUD’S STRATEGIC PLAN PRIORITY GOALS AS OUTLINED IN THE GENERAL SECTION POSTED AT GRANTS.GOV. INCLUDING APPLICATIONS TO OTHER COMPETITIVE N/A. 25 Part C: First Year Annual MTW Plan Section IV: Long-Term MTW Plan SECTION IV: LONG-TERM MTW PLAN UHA’s long-term goal as an MTW agency is to continue to implement innovative and streamlined solutions to housing challenges that address the three statutory requirements of the MTW demonstration program and UHA’s four MTW goals. To do so, UHA will: Continue to establish partnerships with community service providers to provide opportunities for families to achieve economic self-sufficiency. By expanding the network of service providers, UHA will assist participants in moving towards economic self-sufficiency; Expand the scope of successful MTW activities to apply to all assisted families served by UHA, including the possible opportunity for non-MTW families to opt-in to the MTW program to avail themselves of the supportive services network provided to MTW participants; Establish partnerships with neighboring PHAs to develop a network of agencies that will assist UHA to expand its pilot mobility program; Retain program flexibility to meet challenges and changes encountered in program funding, local housing market conditions, and the needs of the families and individuals participating in UHA’s MTW program; Seek ways to simplify and streamline the Section 8 Housing Choice Voucher and Public Housing programs while protecting the integrity of the program remaining accountable for compliance with administrative requirements. 26 Part C: First Year Annual MTW Plan Section V: Proposed MTW Activities – HUD Approval Requested SECTION V: PROPOSED MTW ACTIVITIES - HUD APPROVAL REQUESTED DESCRIPTION OF PROPOSED ACTIVITY PAGE PROGRAM(S) 1. Single-Fund Budget 28 2. Exemption from SEMAP and PHAS Scoring; New Local Assessment System 30 3. Simplify Income and Rent Calculations 32 4. Biennial Reexaminations for MTW Families 38 5. Increase Minimum Rents from $50 to $125 41 6. Limited Term of Participation in the MTW Program 45 7. Progressive Flat TTP for MTW Families 50 8. Simplify Utility Allowances 55 9. Biennial HQS Inspections for Qualified Units 59 10. Limit Voluntary Transfers 62 11. Local Portability Policies 64 12. Expand Project-Based Voucher Program to a Maximum of 50% of HAP Budget Authority 66 13. Pilot Mobility Program 68 MTW STATUTORY OBJECTIVE PUBLIC HOUSING HCV REDUCE COST AND ACHIEVE GREATER COST EFFECTIVENESS X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X ENCOURAGE SELFSUFFICIENCY INCREASE HOUSING CHOICES X X X X 27 Part C: First Year Annual MTW Plan Section V: Proposed MTW Activities – HUD Approval Requested Activity 1 – Single-Fund Budget A. Description UHA will combine the resources of the Public Housing, Housing Choice Voucher, and Capital Fund programs under a single fund block grant in order to better use funding to meet local program and administrative needs. Programs will be funded based on actual levels of need with ongoing flexibility B. Relation to MTW Statutory Objectives This activity addresses the MTW statutory objective to reduce cost and achieve greater cost effectiveness in federal expenditures. C. Anticipated Impacts This activity will enable UHA to allocate its limited federal resources to support the local initiatives proposed in this plan and provide much-needed flexibility to redistribute resources among federal programs based on actual needs. This activity should also provide an opportunity to reduce the administrative costs associated with the maintenance of numerous sets of accounting records for multiple programs, and related reporting and audit requirements. A single fund block grant should result in simplified, less expensive, and faster methods for a small agency to maintain financial records that cover all PHA programs, as well as provide cost savings through consolidation of costly bank accounts. D. Baselines, Benchmarks and Metrics to Assess Outcomes, Including Anticipated Schedules UHA intends to implement this activity during MTW year one. METRIC BASELINE BENCHMARK Percentage of total federal funds Percentage of federal funds Programs will be funded based on that are allocated to each allocated to each program in the their actual level of need with program fiscal year prior to MTW year one ongoing flexibility beginning MTW year one Annual costs associated with accounting, reporting, audit requirements, and banking services Costs associated with accounting, reporting, audit requirements, and banking services in the fiscal year prior to MTW year one A decrease in costs associated with accounting, reporting, audit requirements, and banking services is anticipated within 24 months of implementation E. Data Collection and Protocols A baseline report will be developed using financial data from the fiscal year immediately prior to MTW year one to identify the percentage of funding provided for each program. A cost analysis will be performed to determine the total costs associated with accounting, reporting, audit requirements, and banking services in the fiscal year prior to MTW year one. Rudimentary data will be stored in one or more electronic databases, including UHA’s accounting system. UHA will develop reports describing the above metrics to summarize the data on a quarter-to-date and year-to-date basis. Reports will be analyzed on a quarterly 28 Part C: First Year Annual MTW Plan Section V: Proposed MTW Activities – HUD Approval Requested and/or annual basis to quantify results and identify opportunities for further improvement of the activity. F. Authorization(s) to Conduct the Activity Waiver of certain provisions of Section 8 and 9 of the 1937 Housing Act and 24 C.F.R. 905, 9782 and 990. G. Rent Reform Initiative Information Not applicable. 29 Part C: First Year Annual MTW Plan Section V: Proposed MTW Activities – HUD Approval Requested Activity 2 – Exemption from SEMAP and PHAS Scoring; New Local Assessment System A. Description UHA will opt out of the HUD SEMAP and PHAS systems, and will develop a local assessment system to measure the quality and timeliness of work performed under the MTW Agreement. As a result of programmatic changes proposed through other activities included with this plan, UHA would be unable to maintain High Performer status under the SEMAP and PHAS assessment programs. For example, SEMAP includes indicators that assess whether the PHA has performed annual reexaminations and annual inspections as required. As part of this proposed plan, UHA proposes to modify its schedules of reexaminations and HQS inspections from annual to biennial, and therefore would be unable to qualify for full points for these indicators. UHA’s local assessment system will monitor and evaluate key performance indicators of the Public Housing and HCV programs, including many performance indicators currently assessed through SEMAP and PHAS. The assessment program will measure these indicators as they apply under UHA’s policies and MTW activities. B. Relation to MTW Statutory Objectives This activity addresses the MTW statutory objective to reduce cost and achieve greater cost effectiveness in federal expenditures. C. Anticipated Impacts This activity will provide an accurate assessment of UHA’s performance based on local goals and objectives established by the UHA and the MTW Agreement. D. Baselines, Benchmarks and Metrics to Assess Outcomes, Including Anticipated Schedules UHA intends to develop the local monitoring program, including performance indicators and ratings, during MTW year one. The first assessment under the local monitoring program would take place during MTW year two. METRIC BASELINE UHA’s performance rating for the UHA’s performance rating under HCV program SEMAP for the most recently completed fiscal year prior to implementation BENCHMARK An overall performance rating increase to be achieved during MTW year two and maintained for the lifetime of the MTW agreement UHA’s performance rating for the UHA’s performance rating under Public Housing program PHAS for the most recently completed fiscal year prior to implementation An overall performance rating increase to be achieved during MTW year two and maintained for the lifetime of the MTW agreement 30 Part C: First Year Annual MTW Plan Section V: Proposed MTW Activities – HUD Approval Requested E. Data Collection and Protocols UHA will collect data from its electronic databases and physical files to measure performance under the local monitoring program. Reports will be developed to track performance, and a rating will be assigned to each program at the conclusion of each fiscal year. Should any indicator fall below its previous year score and/or score unsatisfactorily, UHA will develop an action plan for correction. F. Authorization(s) to Conduct the Activity Waiver of certain provisions of Section 6(j) of the 1937 Act and 24 C.F.R. 902 and 985. G. Rent Reform Initiative Information Not applicable. 31 Part C: First Year Annual MTW Plan Section V: Proposed MTW Activities – HUD Approval Requested Activity 3 – Simplify Income and Rent Calculations A. Description UHA will implement policies to simplify the calculation of income and rent for the Public Housing and Housing Choice Voucher programs. Exclusion of Income Received from Assets: UHA will exclude income received from assets from the rent calculation formula. Families will be required to disclose assets at the time of initial eligibility determination and at each reexamination. UHA will not verify the reported assets. Elimination of Deductions: UHA will eliminate the deductions from gross annual income for unreimbursed medical expenses, unreimbursed attendant care and auxiliary apparatus expenses, and child care expenses. UHA will continue to provide deductions to families with dependents ($480.00 per year for each dependent) and to families whose head/spouse/co-head is a person with disabilities ($400 per year regardless of the number of disabled individuals in the family). Simplification of TTP Formula: UHA will calculate Total Tenant Payment (TTP) as the higher of either the minimum rent or 29% of monthly adjusted income. Elimination of EID: UHA will eliminate the HUD Earned Income Disallowance (EID) for persons with disabilities from the calculation of total tenant payment. Other rent reform activities listed in this plan will be implemented to provide similar incentive to families whose earnings increase during the term of assistance. Families receiving the EID prior to implementation of this plan will continue to receive the EID through MTW year two or until their eligibility for EID ends, whichever comes first. Local Income Inclusion: UHA will include in the calculation of annual income payments received for the care of foster children or foster adults, Kinship guardianship assistance (Kin-GAP) payments, and other payments made through foster care or guardianship programs. These sources are currently excluded from the calculation of annual income. Such payments are intended to be utilized by the family for the care, feeding and clothing of the foster child or adult. UHA will include all payments made to a family through a foster care or similar program in the calculation of annual income. To help offset this inclusion of income, UHA will provide families with foster children the same dependent deduction that is provided for other families with dependents. Elimination of Income Offset for Welfare Benefit Sanctions: UHA will implement policies to include the full amount of the family’s welfare benefit, including any sanctioned amount and regardless of any other income change during a welfare sanction period. Currently, UHA must impute sanctioned welfare benefits and perform complex calculations to determine the appropriate amount of welfare income to be counted towards the family’s annual income. These complex calculations will be eliminated through this activity. 32 Part C: First Year Annual MTW Plan Section V: Proposed MTW Activities – HUD Approval Requested This activity is designed to provide a realistic housing and economic experience similar to other affordable housing programs, such as the tax-credit and bond finance programs. It is also intended to encourage families to increase their earned income as they must manage available financial resources and prioritize expenditures without the false sense of security provided by the EID and through the exclusion of certain income. B. Relation to MTW Statutory Objectives This activity addresses the MTW statutory objectives to: Reduce cost and achieve greater cost effectiveness in federal expenditures; and Create incentives for families to work, seek work or prepare for work. C. Anticipated Impacts UHA anticipates that this activity will significantly reduce staff time and administrative costs associated with income and rent calculations as complex calculations, the need to perform unnecessary verifications, and confusing exceptions to income calculation rules are eliminated. UHA also anticipates that this activity will: Encourage families to increase earned income; Encourage families to build or retain savings by eliminating the unintended penalty of savings resulting in increased rent; Help improve accuracy of family income calculations and eliminate potential for errors; Encourage families to remain in compliance with the welfare agency’s requirements and avoid sanctions since all income will be counted towards their rent calculation. This activity also includes the potential for increased rent burden to some participant families. This unintended impact is mitigated through the hardship exemption described in section G.4. A possible reduction in rental revenue in the Public Housing program and increase in HAP expenses in the HCV program may also result from this activity. This impact is not expected to occur, as any decrease in rental revenue or increase in HAP is expected to be offset by the increase in minimum rents proposed as Activity 5 of this plan. D. Baselines, Benchmarks and Metrics to Assess Outcomes, Including Anticipated Schedules UHA intends to implement this activity, with the exception of the components to simplify the TTP formula and the elimination of EID, for all new and existing Public Housing and HCV families during MTW year one. The simplified TTP formula will not be used to calculate TTP for new Public Housing and HCV families under the MTW program because these families will be subject to the progressive flat TTP schedule proposed as Activity 7 of this plan. The elimination of EID would be implemented for all families except families currently within the Earned Income Disallowance period. Those families would continue to receive the benefit until its completion under the current rules. No new cases of EID would be processed after implementation of this activity. 33 Part C: First Year Annual MTW Plan Section V: Proposed MTW Activities – HUD Approval Requested METRIC Total staff hours per year to calculate income and rent BASELINE BENCHMARK Total staff hours to calculate Reduce total staff hours to income and rent in the 12-month perform annual inspections per period prior to implementation year by 10% in MTW year one Average income of families receiving foster care or Kin GAP payments and/or sanctioned welfare benefits Average income of families receiving foster care or Kin GAP payments and/or sanctioned welfare benefits in the 12-month period prior to implementation Average income of families receiving foster care or Kin GAP payments and/or sanctioned welfare benefits will increase Percentage of families with earned income Percentage of families with earned income in the 12-month period prior to implementation Percentage of families with earned income will increase by the completion of MTW year two Average earned income of families with earned income Average earned income of families with earned income in the 12-month period prior to implementation Average earned income of families with earned income will increase by the completion of MTW year two Percentage of families with savings (including retirement or other savings accounts) Percentage of families with Percentage of families with savings (including retirement or savings will increase by the other savings accounts) in the 12- completion of MTW year two month period prior to implementation Average value of assets held by participants Average value of assets held by participants in the 12-month period prior to implementation Average value of assets held by participants will increase by the completion of MTW year two Number of income and rent calculation errors related to assets, deductions, TTP formula, EID, excluded foster care or Kin GAP income, or welfare sanctions Number of income and rent calculation errors related to assets, deductions, TTP formula, EID, excluded foster care or Kin GAP income, or welfare sanctions in the 12-month period prior to implementation Reduce number of income and rent calculation errors related to assets, deductions, TTP formula, EID, excluded foster care or Kin GAP income, or welfare sanctions the completion of MTW year one Percentage of families receiving sanctioned welfare benefits (of all families are receiving) welfare benefits Percentage of families receiving sanctioned welfare benefits in the 12-month period prior to implementation Percentage of families receiving sanctioned welfare benefits will decrease the completion of MTW year two Cost per year associated with verification of assets and deductions Estimated total costs associated with verification of assets and deductions in the 12-month period prior to implementation Reduce total costs per year associated with verification of assets by 100% by the completion of MTW year one Average rent burden for participating families Average rent burden for participating families in the 12month period prior to implementation Average rent burden for participating families may increase following implementation of this activity 34 Part C: First Year Annual MTW Plan Section V: Proposed MTW Activities – HUD Approval Requested E. Data Collection and Protocols Baseline reports will be developed to identify the following baselines for the twelve-month period prior to implementation: The number and average annual income of families receiving foster care or Kin GAP payments and/or sanctioned welfare benefits; The number of families with earned income as percentage of total assisted families; The average earned income of families with earned income; The number of families with savings (including retirement or other savings accounts) as percentage of total assisted families; Average value of assets held by participants; The number of income and rent calculation errors related to assets, deductions, TTP formula, EID, excluded foster care or Kin GAP income, or welfare sanctions; The number of families receiving sanctioned welfare benefits as a percentage of all families receiving welfare benefits; and The average rent burden for participating families. A time study will be conducted to determine the average amount of staff time spent annually calculating income and rent during the twelve-month period prior to implementation. A cost analysis will be performed to determine the average annual costs associated with verification of assets and deductions during the twelve-month period prior to implementation. Rudimentary data will be stored in one or more electronic databases. UHA will develop and analyze reports describing the above metrics on a quarterly and/or annual basis. The reports will summarize the data on a quarter-to-date and year-to-date basis. UHA will analyze the reports to quantify results and identify opportunities for further improvement of the activity. F. Authorization(s) to Conduct the Activity Waiver of certain provisions of Section 3(a)(2), 3(a)(3)(A) and Section 6(l) of the 1937 Act and 24 C.F.R. 5.603, 5.611, 5.628, 5.630, 5.632, 5.634 and 960.255 and 966 Subpart A and certain provisions of Sections (8)(o)(1), (8)(o)(2), (8)(o)(3), (8)(o)(10) and (8)(o)(13)(H)-(I) of the 1937 Act and 24 C.F.R. 982.508, 982.503 and 982.518. Waiver of certain provisions of Section 8(o)(7)(a), 8(o)(13)(F), 8(o)(13)(G) of the 1937 Act and 24 C.F.R. 5.615 Subpart C and 982.303, 982.308, 982.309, 982.451 and 983 Subpart E and F. G. Rent Reform Initiative Information 1. Agency’s Board Approval of Policy The UHA Board’s approval of this rent policy is included in the Board’s resolution adopting this MTW application and first year Annual Plan. 35 Part C: First Year Annual MTW Plan Section V: Proposed MTW Activities – HUD Approval Requested 2. Impact Analysis To analyze the anticipated impact of this activity, UHA compared the adjusted income and rent for all existing participants and residents as calculated under current rules with the adjusted income and rent for the same participants and residents calculated using the income and rent simplification methods included in this activity. UHA’s analysis showed that the average adjusted income (AI) for UHA’s participants would increase as a result of the elimination of the childcare and medical expense deductions and the inclusion of foster care payments and sanctioned welfare benefits. However, the increase in AI was offset by the elimination of asset income and the reduction of TTP to 29% of AI, resulting in an average decrease in the percentage of income paid toward rent and utilities. ANALYSIS OF ANTICIPATED IMPACTS TO HCV PARTICIPANTS Average Change in Adjusted Monthly Income: + $31.49 (3%) Average Change in Tenant Rent to Owner: - $1.26 (< 1%) Average Change in Total Tenant Contribution: - $1.50 (< 1%) ANALYSIS OF ANTICIPATED IMPACTS TO PUBLIC HOUSING TENANTS Average Change in Adjusted Monthly Income: + $4.10 (.3%) Average Change in Tenant Rent: - $12.80 (3.6%) Average Change in Total Tenant Contribution: - $12.80 (3.6%) As a result of the decrease in average tenant rent, UHA anticipates a small increase in HAP expenses in the HCV program and a small decrease in rental income in the Public Housing program as a result of this activity. However, UHA anticipates that this change will be offset by the increase in minimum rents proposed as Activity 5 of this plan. UHA’s analysis also indicates that some families will see an increase in the amount of their tenant rent and total tenant contribution as a result of this activity. UHA has developed hardship case criteria to mitigate the impact to these families. 3. Annual Reevaluation of Rent Reform Initiative UHA will evaluate this activity annually. 4. Hardship Case Criteria A one-year hardship exemption from this activity will be automatically provided to families for whom the implementation of this activity would result in a financial hardship. For purposes of this hardship exemption: A financial hardship will be considered to exist if the family’s total tenant contribution becomes unaffordable as a result of this activity; 36 Part C: First Year Annual MTW Plan Section V: Proposed MTW Activities – HUD Approval Requested Unaffordable is defined as exceeding 40% of the family’s adjusted monthly income as calculated under this activity; No hardship will be considered to exist if the family’s total tenant contribution exceeded 40% of the family’s monthly adjusted income prior to implementation of this activity; No hardship will be considered to exist if the family’s total tenant contribution exceeds 40% of the family’s monthly adjusted income as a result of HCV family’s rental unit exceeding the voucher size the family is eligible for. 5. Transition Period The exclusion of income received from assets, elimination of deductions, simplification of the TTP formula, and inclusion of foster care payments and welfare sanctioned income will take place at each family’s first annual reexamination after this activity is implemented. Families currently within the Earned Income Disallowance period would continue to receive the benefit until its completion under the current rules. No new cases of Earned Income Disallowance would be processed. 6. Documentation of Public Hearing See Section D. Evidence of Community Support and Involvement, which includes evidence (in the form of notices, newsletters, sign-in sheets, etc.) that UHA has obtained community and PHA resident participation in developing its MTW application. Documentation of the public hearing is also included. 37 Part C: First Year Annual MTW Plan Section V: Proposed MTW Activities – HUD Approval Requested Activity 4 – Biennial Reexaminations for MTW Families A. Description UHA will implement policies to place new and existing Public Housing and HCV families on a biennial reexamination schedule. UHA will conduct mandatory reexaminations of income every two years; UHA will conduct interim reexaminations as needed when families report a decrease in income that would impact the family’s rent; Families will not be required to report increases in income between biennial reexaminations and UHA will not conduct interim reexaminations for increases in family income; Changes in payment or subsidy standards, voucher size, utility allowances, and Public Housing rent schedules will be applied at the family’s next biennial reexamination; Families porting to or from UHA’s jurisdiction will remain on an annual reexamination schedule if UHA is administering the voucher or is being billed by the receiving PHA. Since UHA is proposing to modify the annual reexamination schedule to a biennial reexamination schedule, authorization for release of information forms must be extended to encompass a longer timeframe in which UHA can access income information with written authorization from participants. The federally-mandated HUD-9886 Authorization for Release of Information form permits PHAs to access income information for 15 months from the date of signature. As part of this activity, UHA requests permission to create an agency authorization form conferring the participant’s authorization to extend the use of the HUD-9886 for an additional 12 months (a total of 27 months) from the date of signature. The additional 12 months will accommodate the new proposed biennial reexamination schedule. B. Relation to MTW Statutory Objectives This activity addresses the MTW statutory objectives to: Reduce cost and achieve greater cost effectiveness in federal expenditures; and Create incentives for families to work, seek work or prepare for work. C. Anticipated Impacts UHA anticipates that reducing the frequency of reexaminations will increase administrative efficiency, reduce staff time spent to process reexaminations, and generate cost savings related to personnel. This activity is also expected to encourage participant families to seek opportunities to increase their income, as any increase that takes place between biennial reexaminations will not be included until the family’s next biennial reexamination. Families will be able to retain additional earnings without increased rents, and will have additional time to build savings accounts, increase skill levels to become more marketable, complete secondary education or job training programs, or obtain employment. 38 Part C: First Year Annual MTW Plan Section V: Proposed MTW Activities – HUD Approval Requested D. Baselines, Benchmarks and Metrics to Assess Outcomes, Including Anticipated Schedules UHA would implement this activity over a two-year period by conducting full reexaminations for 50% of participants in MTW year one and 50% in MTW year two. METRIC Annual number of full reexaminations conducted BASELINE Number of full reexaminations conducted in the 12-month period prior to implementation (by program) BENCHMARK Reduce total number of full reexaminations conducted by 50% within twelve months of implementation Percentage of families required to have a full reexamination during the year 100% of families are required to have a full reexamination during the year Reduce percentage of families required to have a full reexamination during the year by 50% within 12 months of implementation Annual staff hours required to process full reexaminations Annual staff hours spent to process full reexaminations in the 12-month period prior to implementation (by program) Decrease annual staff hours spent to process full reexaminations by 50% within 12 months of implementation Annual cost for printing, copying and mailing reexamination materials Cost for printing, copying and mailing reexamination materials in the 12-month period prior to implementation (by program) Decrease annual cost of printing, copying and postage to process required annual reexaminations by 50% within 12 months of implementation Percentage of families with earned income Percentage of families with earned income in the 12-month period prior to implementation (by program) Increase in percentage of families with earned income by the second biennial reexamination Average earned income of families with earned income Average earned income of families with earned income in the 12-month period prior to implementation (by program) Increase in average income of families with earned income by the second biennial reexamination E. Data Collection and Protocols Baseline reports will be developed to identify the following baselines for the twelve-month period prior to implementation: The number of full reexaminations conducted; The percentage of families with earned income; and The average earned income of families with earned income A time study will be conducted to determine the average amount of staff time spent annually to conduct full reexaminations during the twelve-month period prior to implementation. A cost analysis will be performed to determine the average annual costs associated with conducting full reexaminations during the twelve-month period prior to implementation. 39 Part C: First Year Annual MTW Plan Section V: Proposed MTW Activities – HUD Approval Requested Rudimentary data will be stored in one or more electronic databases. UHA will develop and analyze reports describing the above metrics on a quarterly and/or annual basis. The reports will summarize the data on a quarter-to-date and year-to-date basis. UHA will analyze the reports to quantify results and identify opportunities for further improvement of the activity. F. Authorization(s) to Conduct the Activity Public Housing: Waiver of certain provisions of Section 3(a)(1) and 3(a)(2) of the 1937 Act and 24 C.F.R. 966.4 and 960.257 HCV: Waiver of certain provisions of Section 8(o)(5) of the 1937 Act and 24 C.F.R. 982.516. G. Rent Reform Initiative Information Not applicable. 40 Part C: First Year Annual MTW Plan Section V: Proposed MTW Activities – HUD Approval Requested Activity 5 – Increase Minimum Rents from $50 to $125 A. Description UHA will increase the minimum rent from $50.00 to $125.00 per month for all existing Public Housing residents and all new and existing HCV program participants. New Public Housing residents are not included in this activity because they are subject to the progressive flat TTP schedule proposed as Activity 7 of this plan. This activity is designed to create an assisted housing experience that more closely resembles the private market while ensuring that families can afford their rent. It is also intended to encourage families to increase their earned income as they must manage available financial resources and prioritize expenditures without the false sense of security provided by the current $50 minimum rent. B. Relation to MTW Statutory Objectives This activity addresses the MTW statutory objective to create incentives for families to work, seek work or prepare for work. C. Anticipated Impacts This activity is anticipated to result in a decrease in the number of zero-income families in the Public Housing and HCV programs, and an increase in the earned income of families whose TTP is currently less than $125. It is anticipated that families subject to the minimum rent will attempt to increase their earned income in order to meet the higher minimum rent. The number of families subject to minimum rent is also anticipated to increase as a result of the increased minimum rent amount. Increased rental revenue in the Public Housing program and decreased HAP expenses in the HCV program are also expected as a result of the increased minimum rent amount and because more families will be subject to the minimum rent. Although this activity will represent an increase in the rent paid by some families, this increase is not anticipated to create an increase in the families’ rent burden, or percentage of income those families will pay toward rent. UHA anticipates that the increase in rent will be offset by the increase in family income resulting from the inclusion of income specified in Activity 3 of this proposed plan. UHA also expects that implementation of this activity will facilitate reinstatement of a previous mobility agreement between UHA and the Housing Authority of the County of San Bernardino (HACSB) that has been suspended due to programmatic changes implemented by HACSB as an MTW PHA. If UHA’s application is approved and the mobility agreement reinstated, participants can again enjoy simplified mobility throughout the majority of San Bernardino County. D. Baselines, Benchmarks and Metrics to Assess Outcomes, Including Anticipated Schedules UHA intends to implement this activity for all existing Public Housing residents and all new and existing HCV families during MTW year one. The new minimum rent will be applied at the family’s first reexamination after implementation of this activity. Results attained through this 41 Part C: First Year Annual MTW Plan Section V: Proposed MTW Activities – HUD Approval Requested activity will be realized gradually during MTW year one as reexaminations occur, with the full impact of the activity realized during MTW year two. METRIC Number and percentage of zeroincome families BASELINE Number and percentage of zeroincome families in the 12-month period prior to implementation (by program) BENCHMARK Decrease in number and percentage of zero-income families by MTW year two Annual earned income of families Annual earned income of families Increase in annual earned income whose TTP is less than $125 (by whose TTP is less than $125 in of these families by the family’s program) the 12-month period prior to next reexamination implementation (by program) Percentage of families subject to minimum rent (by program) Percentage of families subject to minimum rent in the 12-month period prior to implementation (by program) Percentage of families subject to the minimum rent increase by 5% for the Public Housing program and 8% for the HCV program in the 12 months after implementation Rental revenue and HAP Rental revenue and HAP expenses for families with TTP of expenses for families with TTP of $125 or less $125 or less for the 12-month period prior to implementation Rental revenues for these families increase by 50% and HAP expenses decrease for these families by 50% in the second year after implementation Rent burden of families paying minimum rent (by program) No change is anticipated Average rent burden of families paying minimum rent for the 12month period prior to implementation (by program) E. Data Collection and Protocols Baseline reports will be developed to identify the following baselines for each program for the twelve-month period prior to implementation: The number and percentage of zero-income families; The annual earned income of families whose TTP is less than $125 The percentage of families subject to minimum rent; Rental revenue and HAP expenses for families with TTP of $125 or less; and The average rent burden of families paying minimum rent. A financial report will be developed to measure the increased rental revenue and decreased HAP expenses for families with TTP of $125 or less. Rudimentary data will be stored in one or more electronic databases. UHA will develop and analyze reports describing the above metrics on a quarterly and/or annual basis. The reports will summarize the data on a quarter-to-date and year-to-date basis, and UHA will analyze the reports to quantify results and identify opportunities for further improvement of the activity. 42 Part C: First Year Annual MTW Plan Section V: Proposed MTW Activities – HUD Approval Requested F. Authorization(s) to Conduct the Activity Waiver of certain provisions of Section 3(a)(2, 3(a)(3)(A) and Section 6(l) of the 1937 Act and 24 C.F.R. 5.603, 5.611, 5.628, 5.630, 5.632, 5.634, and 960.255 and 966 Subpart A and certain provisions of Sections 8(o)(1), 8(o)(2), 8(o)(3), 8(o)(10) and 8(o)(13)(H)-(I) of the 1937 Act and 24 C.F.R. 982.508, 982.503 and 982.518. G. Rent Reform Initiative Information 1. Agency’s Board Approval of Policy The UHA Board’s approval of this rent policy is included in the Board’s resolution adopting the MTW application and First-Year Annual Plan. 2. Impact Analysis This activity will result in some families experiencing an increase in their rent amount. UHA’s current minimum rent is $50. A total of 19 families (2.7%) from both programs are currently at minimum rent, with no families receiving an exemption for financial hardship. UHA anticipates that the potential impact to families whose rent burden will increase as a result of this activity will be mitigated by: Families seeking new or increased earned income; Families requesting an exemption for financial hardship; and/or The families’ increased rent being offset by the increase in family income resulting from the inclusion of income specified in Activity 3 of this proposed plan. The tables below summarize the anticipated impacts of this activity. ANTICIPATED CHANGE IN NUMBER OF FAMILIES ELIGIBLE FOR MINIMUM RENT PUBLIC HOUSING HCV TOTAL 3 (3.1%) 16 (2.6%) 19 (2.7%) Families with current TTP less than $125 8 (8%) 66 (11%) 74 (10.5%) Increase in families eligible for minimum rent 5 (5%) 50 (8%) 93 (8%) Families at current $50 minimum rent ANTICIPATED RENT BURDENS OF ASSISTED FAMILIES AT $125 MINIMUM RENT Total tenant contribution as a percentage of Adjusted Monthly Income NUMBER OF FAMILIES Rent Burden (% of Adjusted Monthly Income) PUBLIC HOUSING HCV TOTAL 41 – 50% 2 (2%) 8 (1%) 10 (1%) 51 – 60% 0 7 (1%) 7 (< 1%) 61 – 70% 2 (2%) 7 (1%) 9 (1%) 71 – 99% 0 11 (2%) 11 (1%) 100% + 2 (2%) 20 (3%) 22 (3%) Totals 6 (6%) 53 (8%) 59 (8%) 43 Part C: First Year Annual MTW Plan Section V: Proposed MTW Activities – HUD Approval Requested 3. Annual Reevaluation of Rent Reform Initiative UHA will evaluate this activity annually. 4. Hardship Case Criteria Families may request a hardship exemption in accordance with the existing HUD requirements and UHA policies for exemption from the minimum rent. 5. Transition Period UHA intends to implement this activity for all existing Public Housing residents and all new and existing HCV families at the family’s first annual reexamination during MTW year one. 6. Documentation of Public Hearing See Section D. Evidence of Community Support and Involvement, which includes evidence (in the form of notices, newsletters, sign-in sheets, etc.) that UHA has obtained community and PHA resident participation in developing its MTW application. Documentation of the public hearing is also included. 44 Part C: First Year Annual MTW Plan Section V: Proposed MTW Activities – HUD Approval Requested Activity 6 – Limited Term of Participation in the MTW Program A. Description UHA will implement term limits on housing assistance for all Public Housing and HCV families selected from the waiting list or porting into UHA’s jurisdiction after implementation of the activity. This activity is designed to help our participants achieve true self sufficiency by assisting them with their housing needs for a specific term while providing an incentive for families to focus on securing better employment and preparing for a better future. This activity will not apply to elderly and disabled families on fixed income as those terms are defined by UHA. For purposes of this activity, elderly and disabled families will be defined as families in which 100% of adults are age 62 or older (elderly) or disabled as defined at 24 C.F.R. 5.403. Fixed income will mean that the household’s only source(s) of income are Social Security, Supplemental Security Assistance, fixed retirement pension, or other fixed income sources established by UHA policy. The term of assistance will be five years or until the family becomes self-sufficient, whichever is sooner. For purposes of this activity, self-sufficient is defined as: For Public Housing residents, the family’s income is equal to or exceeds 140% of the median income for six consecutive months (180 days). For HCV families, the family’s share of the rent is equal to or exceeds the contract rent for the assisted unit for six consecutive months (180 days). Families subject to term-limited assistance will be notified at the start of assistance that the maximum term of their assistance will be five years, and will be notified at each reexamination of the number of years remaining in their term-limited assistance. Families will also receive referral services to a variety of available resources and supportive services that can assist the family achieve economic self-sufficiency. UHA will establish partnerships to provide supportive services to families, including job and life skills training and educational referral and guidance, to help families achieve self-sufficiency within the duration of their assistance. Support and interest letters from several local service providers are attached in Section D. Evidence of Community Support and Involvement. UHA intends to partner with as many community service providers as possible to ensure that families have access to supportive services that will help them to achieve self-sufficiency during the limited term of assistance. The average stay for current Public Housing residents in our program is 12.47 years. For those who left the program the average stay was 6.59 years. Over 50% of those residents who left the program were assisted for less than five years, and nearly 67% had left the program within seven years. The average length of assistance for current HCV families in our program is 7.62 years, while the average length of assistance for those who left the program was 7.4 years. Nearly 50% of those families who left the program were assisted for less than five years, and roughly 61% had left the program within seven years. 45 Part C: First Year Annual MTW Plan Section V: Proposed MTW Activities – HUD Approval Requested Based on this data we feel the appropriate term of assistance should be five years. The tables below show the average length of assistance for current and former Public Housing and HCV families. AVERAGE LENGTH OF STAY FOR UHA’S PUBLIC HOUSING RESIDENTS Years of Tenancy Current Residents Former Residents (left the program) Percentage Cumulative Total Percentage Cumulative Total <2 7.29 7.29 21.31 21.31 2–3 11.46 18.75 19.67 40.98 4–5 14.58 33.33 19.67 60.66 6–7 6.25 39.58 11.48 72.13 8–9 11.46 51.04 6.56 78.69 10 – 14 18.75 69.79 9.84 88.52 15 – 19 11.46 81.25 8.20 96.75 20 – 24 9.38 90.63 1.64 98.36 25 – 29 2.08 92.71 1.64 100 30 – 39 4.17 96.88 0 100 40 – 49 1.04 97.92 0 100 50 + 2.08 100 0 100 AVERAGE LENGTH OF ASSISTANCE FOR UHA’S HCV FAMILIES Years of Tenancy Current Participants Former Participants (left the program) Percentage Cumulative Total Percentage Cumulative Total <2 19.31 19.31 8.17 8.17 2–3 9.74 29.04 30.29 38.46 4–5 21.62 50.66 14.42 52.88 6–7 13.70 64.36 12.02 64.90 8–9 6.93 71.29 11.06 75.96 10 – 14 16.34 87.62 12.50 88.46 15 – 19 7.92 95.54 4.81 93.27 20 – 24 2.64 98.18 3.85 97.12 25 + 1.82 100 2.88 100 46 Part C: First Year Annual MTW Plan Section V: Proposed MTW Activities – HUD Approval Requested B. Relation to MTW Statutory Objectives This activity addresses the MTW statutory objective to create incentives for families to work, seek work or prepare for work. C. Anticipated Impacts UHA anticipates that this activity will encourage families to take advantage of services and referrals by UHA to aid them in the path to self-sufficiency. UHA expects an increase in participation in self-sufficiency activities by participants and residents, increased interest by assisted families in utilizing service provider referrals from UHA, and an increase in number of families seeking new and/or better employment. This activity may also encourage families to prepare themselves for home ownership by saving funds or repairing negative credit. UHA also expects that this activity will increase our ability to serve applicants on our waiting lists and decrease the length of time applicants have to wait for assistance. UHA’s Public Housing waiting list currently has 349 applicants, and the average wait time for those applicants is six years. UHA’s HCV waiting list has 2,852 applicants with an average wait time of 3.4 years. With term limits in place, UHA anticipates that we will be able to select families from our waiting lists more frequently as assisted families achieve self-sufficiency or reach the limit of their assistance and leave the program. UHA anticipates that implementation of this activity will facilitate reinstatement of a previous mobility agreement between UHA and the Housing Authority of the County of San Bernardino (HACSB) that has been suspended due to programmatic changes implemented by HACSB as an MTW PHA. If UHA’s application is approved and the mobility agreement reinstated, participants can again enjoy simplified mobility throughout the majority of San Bernardino County. D. Baselines, Benchmarks and Metrics to Assess Outcomes, Including Anticipated Schedules UHA intends to implement this activity during MTW year one for all new Public Housing and HCV families selected from the waiting list or porting into UHA’s jurisdiction after implementation. METRIC BASELINE BENCHMARK Percentage of term-limited The baseline is 0%, as no families 2% for the Public Housing families in the Public Housing and are currently term-limited in program and 3% for the HCV HCV programs either program program within 12 months of implementation Percentage of term-limited families that leave assistance voluntarily or as a result of becoming self-sufficient The baseline is 0%, as no families UHA will develop a benchmark are currently term-limited in for this metric as data needed for either program projection becomes available in MTW years one and two Percentage of term-limited families that reach their term limit in the Public Housing and HCV programs The baseline is 0%, as no families UHA will develop a benchmark are currently term-limited in for this metric as data needed for either program projection becomes available in MTW years one and two Metrics continued on next page. 47 Part C: First Year Annual MTW Plan Section V: Proposed MTW Activities – HUD Approval Requested METRIC Annual turnover in the Public Housing and HCV programs (% of families leaving the programs) BASELINE Annual turnover in the Public Housing and HCV programs for the 12-month period prior to implementation BENCHMARK Annual turnover will increase for both programs in MTW years 5 and beyond Average length of assistance in the Public Housing and HCV programs Average length of assistance for the 12-month period prior to implementation Decrease in the average length of assistance within three years of implementation Average wait time for families on Average wait time for families on the Public Housing and HCV the Public Housing and HCV waiting lists waiting lists in the 12 months prior to implementation Decrease in waiting time for families on the waiting lists. A numerical benchmark will be developed as data regarding turnover becomes available E. Data Collection and Protocols Baseline reports will be developed to identify the following baselines for each program for the twelve-month period prior to implementation: The annual turnover in the Public Housing and HCV programs (% of families leaving the programs); Average wait time for families on the Public Housing and HCV waiting lists; Average length of assistance for families in the Public Housing and HCV programs. UHA will track the number of term-limited families, the number of families that choose to leave the program before the expiration of the term-limited voucher or as a result of achieving selfsufficiency, and the number of families that reach their term limit and leave the program. The average length of assistance, wait time, and turnover will also be tracked. Rudimentary data will be stored in one or more electronic databases. UHA will develop and analyze reports describing the above metrics on a quarterly and/or annual basis. The reports will summarize the data on a quarter-to-date and year-to-date basis, and UHA will analyze the reports to quantify results, determine if anticipated outcomes are being realized, and identify opportunities for further improvement of the activity. F. Authorization(s) to Conduct the Activity Wavier of certain provisions of Section 8(o)(7) and 8(o)(13)(F)-(G) of the 1937 Act and 24 C.F.R. 982 Subpart L and 983 Subpart E. G. Rent Reform Initiative Information 1. Agency’s Board Approval of Policy The UHA Board’s approval of this rent policy is included in the Board’s resolution adopting the MTW application and First-Year Annual Plan. 2. Impact Analysis 48 Part C: First Year Annual MTW Plan Section V: Proposed MTW Activities – HUD Approval Requested UHA anticipates that this activity will result in increased participation in self-sufficiency activities and activities that remove barriers to better employment. Some families may use this as an opportunity to prepare themselves for home ownership. It is also expected that the number of families leaving the program voluntarily or as a result of achieving self-sufficiency will increase. The number of families that will reach the expiration of their term-limited assistance is not known at this point. Based on current participant data, this figure could represent a large percentage of UHA’s assisted families. However, the impact of additional supportive services available to assisted families through partnerships formed between UHA and community service providers is not yet known and cannot yet be factored into this impact analysis. 3. Annual Reevaluation of Rent Reform Initiative UHA will evaluate this activity annually. 4. Hardship Case Criteria Prior to termination of assistance at the expiration of the limited term, term-limited families will be allowed given an opportunity to request an informal review. UHA will review and determine on a case-by-case basis any family hardships and determine if a family may receive any extension of assistance. The maximum extension of assistance will be one year. 5. Transition Period UHA intends to implement this activity during MTW year one for all new Public Housing and HCV families selected from the waiting list or porting into UHA’s jurisdiction after implementation. 6. Documentation of Public Hearing See Section D. Evidence of Community Support and Involvement, which includes evidence (in the form of notices, newsletters, sign-in sheets, etc.) that UHA has obtained community and PHA resident participation in developing its MTW application. Documentation of the public hearing is also included. 49 Part C: First Year Annual MTW Plan Section V: Proposed MTW Activities – HUD Approval Requested Activity 7 – Progressive Flat TTP for New Public Housing Residents and HCV Families A. Description The goal of this activity is to help our assisted families achieve true self-sufficiency by assisting them with their housing needs at progressively reduced level. It is also designed to encourage families to increase their earned income as they must manage available financial resources and prioritize expenditures without the false sense of security provided by permanently reduced rent payments. This activity will not apply to elderly and disabled families on fixed income as those terms are defined by UHA. For purposes of this activity, elderly and disabled families will be defined as families in which 100% of adults are age 62 or older (elderly) or disabled as defined at 24 C.F.R. 5.403. Fixed income will mean that the household’s only source(s) of income are Social Security, Supplemental Security Assistance, fixed retirement pension, or other fixed income sources established by UHA policy. UHA will develop a three-tiered flat TTP schedule based on the income limits published annually by HUD for the Riverside-San Bernardino-Ontario, CA, Metropolitan Statistical Area. The flat TTP will be used to calculate the rent or level of assistance for Public Housing residents and HCV families that are selected from the waiting list or port into UHA’s jurisdiction after implementation of this activity. In order to assist families to become self-sufficient under this activity, UHA will establish partnerships to provide supportive services to families, including job and life skills training and educational referral and guidance, to help families achieve self-sufficiency. This activity is intended to provide an incentive to working families and those families who are participating in economic self-sufficiency activities such as job training or school. Because the rent or level of assistance is calculated using a flat TTP, families whose income exceeds 30%, 50% or 80% of the AMI for a single-person family will pay no more than 29% of their adjusted annual income as TTP. Additionally, because no increase in TTP takes place until each biennial reexamination, families whose income increases between reexaminations may retain those additional earnings without impact to their rent portion. This system provides maximum incentive for assisted families to increase their earned income while providing an opportunity for assisted families to build savings and work toward economic self-sufficiency. Those families participating in economic self-sufficiency activities are also protected under this activity through a hardship exemption available for those families who are unable to meet the flat TTP for their tier as a result of participation in such activities. This activity is pending additional analysis and will not be finalized or implemented until a detailed analysis of the potential impacts has been conducted. Tiered Flat TTP Schedule: The TTP schedule will be based on the area median income (AMI) for a one-person family, and will be adjusted annually when revised income limits are published by 50 Part C: First Year Annual MTW Plan Section V: Proposed MTW Activities – HUD Approval Requested HUD. Flat TTP amounts will be set at 29% of the low-income (80%), very low-income (50%) and extremely low-income (30%) levels of the AMI for a one-person household. The table below is a draft of the progressive flat TTP schedule. TIER ASSISTANCE YEAR(S) INCOME LIMIT CATEGORY BASED ON AREA MEDIAN INCOME (AMI) FOR A 1-PERSON FAMILY (Published by HUD effective 12/1/2011) FLAT TTP (29% OF AMI) 1 1–2 Extremely Low-Income (30%) $14,100 $341 2 3–4 Very Low-Income (50%) $23,450 $567 3 5 Low-Income (80%) $37,550 $907 Progressive Application of Flat TTP: At time of admission to UHA’s Public Housing or HCV program, the family’s rent or level of assistance will be calculated using the flat TTP in tier one or tier two, based on initial household income and family size. At each biennial reexamination the family’s rent or level of assistance will be calculated using the flat TTP in the next tier until the family reaches tier three or the family leaves the program. No changes to the family’s income or rent will be processed between reexaminations, except as a result of financial hardship as addressed below. Automatic Hardship Exemption During Year One: UHA will grant an automatic one-year hardship exemption for any family whose monthly rent burden would exceed 50% of the family’s adjusted monthly income. TTP for these families would be calculated at 29% of actual adjusted monthly income. Other Hardship Exemptions: Families may request an exemption from the flat TTP at other times for financial hardship. The exemption may be requested at biennial reexamination or any time between reexaminations. UHA will approve hardship exemption requests for up to one year on a case-by-case basis, taking into consideration such factors as whether or not the hardship exists due to circumstances beyond the family’s control, whether the family has made attempts to improve its ability to meet the flat TTP, and other factors. UHA will approve no more than twelve months of hardship exemption in any TTP tier. TTP for families approved for a hardship exemption would be calculated at 29% of actual adjusted monthly income or the $125 minimum rent, whichever is greater. Hardship Exemption for Families Participating in Job Training, Educational or Other Economic Self-Sufficiency Programs: Families may request an exemption from the flat TTP at any tier due to financial hardship resulting from participation in job training, educational or other economic self-sufficiency programs, including full-time school. UHA will approve requests on a case-bycase basis, taking into consideration factors such as the number of work-able adults in the family and the nature and duration of the program. 51 Part C: First Year Annual MTW Plan Section V: Proposed MTW Activities – HUD Approval Requested B. Relation to MTW Statutory Objectives This activity addresses the MTW statutory objectives to: Reduce cost and achieve greater cost effectiveness in federal expenditures; and Create incentives for families to work, seek work or prepare for work. C. Anticipated Impacts UHA anticipates that this activity will serve as a powerful incentive to families to attain economic self-sufficiency. As a result, UHA anticipates an increase in the average earned income of families subject to this activity, because the family’s rent will not be impacted by increases in earnings. Additionally, this activity will eliminate the need to process interim reexaminations due to changes in income, resulting in significant staff time savings. Other impacts of this activity include: A transparent method of calculating rent/level of assistance that is easier for assisted families and the public to understand; Assisted families can clearly see what their rent or level of assistance will be at each reexamination; Families’ rents will progressively approach the rents paid on the private market, preparing families for renting outside of assisted housing. This activity may also result in increased rental revenue in the Public Housing program and reduced HAP expenses in the HCV program. Some families may experience a hardship due to an increase in family share caused by the use of the progressive flat TPP schedule. UHA has developed hardship exemption policies as outlined above to mitigate the impact to these families, and will conduct further analysis to before implementing this activity to ensure that the hardship exemptions are appropriate and sufficient. D. Baselines, Benchmarks and Metrics to Assess Outcomes, Including Anticipated Schedules UHA intends to implement this activity during MTW year two, following further modeling and analysis to establish a final schedule of progressive flat TTPs and other requirements. METRIC BASELINE BENCHMARK Average annual earned income of Annual earned income of MTW Increased annual income for MTW and non-MTW families families in the twelve month MTW families within 24 months period prior to implementation is of implementation 0 (no MTW families). The annual earned income of non-MTW families in the 12-month period prior to implementation. Metrics continued on next page. 52 Part C: First Year Annual MTW Plan Section V: Proposed MTW Activities – HUD Approval Requested METRIC Number of staff hours spent per year to process interim reexaminations for income decreases BASELINE Number of staff hours spent per year to process interim reexaminations for income decreases in the 12-month period prior to implementation BENCHMARK Reduce the number of staff hours spent per year to process interim reexaminations for income decreases Annual number of families approved for financial hardship exemption as a result of this activity The baseline is 0, as no families will be approved for hardship exemption under this activity until after implementation The number of families anticipated to be approved for hardship exemption will be determined as part of UHA’s detailed impact analysis prior to implementation E. Data Collection and Protocols Baseline reports will be developed to identify the average annual earned income of assisted families by program for the twelve-month period prior to implementation. A time study will be conducted to determine the average amount of staff time spent to process interim reexaminations for income decreases during the twelve-month period prior to implementation. UHA will track the metrics listed above. Reports describing the metrics will be developed and analyzed on a quarterly and/or annual basis. The reports will summarize the data on a quarterto-date and year-to-date basis. UHA will analyze the reports to quantify results, to determine if anticipated results are being realized, and to identify opportunities for further improvement of the activity. F. Authorization(s) to Conduct the Activity Waiver of certain provisions of Section 3(a)(2, 3(a)(3)(A) and Section 6(l) of the 1937 Act and 24 C.F.R. 5.603, 5.611, 5.628, 5.630, 5.632, 5.634, and 960.255 and 966 Subpart A and certain provisions of Sections 8(o)(1), 8(o)(2), 8(o)(3), 8(o)(10) and 8(o)(13)(H)-(I) of the 1937 Act and 24 C.F.R. 982.508, 982.503 and 982.518. G. Rent Reform Initiative Information 1. Agency’s Board Approval of Policy The UHA Board’s approval of this rent policy is included in the Board’s resolution adopting the MTW application and First-Year Annual Plan. 2. Impact Analysis UHA conducted an initial impact analysis using the proposed draft progressive flat TTP schedule and other activity requirements listed above. The proposed requirements were used to assess the potential impact to applicants currently on UHA’s Public Housing and HCV waiting lists based on income levels and elderly/disabled status as reported by the family. The table below illustrates UHA’s findings from this initial assessment. 53 Part C: First Year Annual MTW Plan Section V: Proposed MTW Activities – HUD Approval Requested ANTICIPATED NUMBER OF FAMILIES EXEMPT OR SUBJECT TO PROGRESSIVE TIERED FLAT TTP SCHEDULE BASED ON CURRENT WAITING LIST INFORMATION ELDERLY/DISABLED FAMILIES EXEMPT FROM THIS ACTIVITY Non-Elderly/Disabled families for whom the first tier flat TTP exceeds 50% of adjusted monthly income Average TTP for the above families based on 29% of actual adjusted monthly income Families subject to first tier flat TTP PUBLIC HOUSING 77 (22.06%) HCV 1046 (36.67%) 32 (9.17%) 585 (20.52%) $88.32 $122.43 190 (54.44%) 1221 (42.81%) Based on this information, UHA believes that the progressive flat TTP schedule as proposed would not impose an undue hardship on families selected from UHA’s waiting list. The majority of families in our sample would pay no more than 29% of their adjusted monthly income toward rent during the two-year period at the first tier. A relatively small number of families would receive an automatic one-year hardship exemption from the flat TTP to ensure that they pay no more than 29% of their income toward rent during the first year of assistance. Elderly and disabled families are exempt from this activity. UHA will conduct further modeling and analysis of this activity prior to implementation. 3. Annual Reevaluation of Rent Reform Initiative UHA will evaluate this activity annually. 4. Hardship Case Criteria Exemptions from certain requirements under this activity will be provided as outlined above for families experiencing financial hardship. 5. Transition Period UHA will conduct further modeling and analysis of this proposed activity prior to implementation. We anticipate that this additional research may take up to one year to complete and prepare UHA’s software systems for implementation. Because this activity will apply only to new families selected from the waiting list or porting in to UHA’s jurisdiction after implementation, no transition period is required for these families. 6. Documentation of Public Hearing See Section D. Evidence of Community Support and Involvement, which includes evidence (in the form of notices, newsletters, sign-in sheets, etc.) that UHA has obtained community and PHA resident participation in developing its MTW application. Documentation of the public hearing is also included. 54 Part C: First Year Annual MTW Plan Section V: Proposed MTW Activities – HUD Approval Requested Activity 8 – Simplify Utility Allowances A. Description UHA will implement policies to simplify utility allowances in the HCV program. Utility allowances are currently based on average utility consumption, and vary by building type, bedroom size, utility responsibility, and type of fuel/energy used. These variables result in numerous possible utility allowance combinations that are difficult to explain to property owners and families, and often result in confusion. Participants frequently call UHA to determine whether the proposed rent of a unit they are considering will be acceptable to UHA. Additionally, HUD has determined that incorrectly calculated utility allowances are one of the most common rent calculation errors in the country. UHA intends to provide a flat utility allowance by bedroom size. UHA will determine the amount of the allowances by calculating the average utility allowance currently provided to HCV program participants, and establish an allowance for each bedroom size based on the average. Current utility allowance amounts are based on average utility consumption by utility type. Other factors may be taken into consideration to ensure that potential negative impact on tenant portion is mitigated. A utility allowance will be provided to each family responsible for tenant-supplied utilities based upon the unit bedroom size. UHA will also no longer provide any utility allowance reimbursement payments in both Public Housing and HCV. B. Relation to MTW Statutory Objectives This activity addresses the MTW statutory objective to reduce cost and achieve greater cost effectiveness in federal expenditures. C. Anticipated Impacts This activity is expected to improve administrative efficiency by simplifying the processes of calculating, explaining, verifying, and applying utility allowances. UHA anticipates a reduction in the amount of staff time spent on these activities. UHA also anticipates a reduction in administrative errors associated with utility allowances. Voucher participants will also benefit from a greatly simplified explanation of utility allowance benefits, and they will know the exact amount of rental assistance available to them as they search for a unit. UHA anticipates that this activity will, on average, result in minimal or no change to family share. However, some families may experience a hardship due to an increase in family share caused by the new standardized utility allowance schedule. UHA will develop a hardship exemption policy to mitigate the impact to these families. D. Baselines, Benchmarks and Metrics to Assess Outcomes, Including Anticipated Schedules UHA intends to conduct research and calculate the flat utility allowance schedule during MTW year one, and implement the flat allowance schedule during MTW year two. This activity will apply to all new and existing HCV participants and all existing Public Housing residents. The flat 55 Part C: First Year Annual MTW Plan Section V: Proposed MTW Activities – HUD Approval Requested utility allowance schedule will be applied at the first reexamination following implementation for existing families. UHA intends to eliminate UAP during MTW year one for all new and existing Public Housing and HCV families during MTW year one. METRIC Annual staff time in hours to determine and apply utility allowances for new contracts and reexaminations BASELINE BENCHMARK Staff time in hours to determine Decrease of 25% in MTW year and apply utility allowances in the one and 50% in MTW year two 12-month period prior to implementation Utility allowance calculation error Error rate for the 12-month rate period prior to implementation Decrease of 25% in MTW year one and 50% in MTW year two Annual number of families approved for hardship exemption due to changes in utility allowance structure The number of families anticipated to be approved for hardship exemption will be determined as part of UHA’s detailed impact analysis prior to implementation The baseline is 0, as no families will be approved for hardship exemption for this reason until after implementation E. Data Collection and Protocols A baseline report will be developed to identify the rate of errors associated with utility allowance calculations for the twelve-month period prior to implementation. A time study will be conducted to determine the average amount of staff time spent calculating, explaining, verifying, and applying utility allowances during the twelve-month period prior to implementation. A cost analysis will be performed to determine the average annual costs associated with annual inspections. After implementation, UHA will track the number of hardship exemptions approved due to changes in the utility allowance structure. Rudimentary data will be stored in one or more electronic databases. UHA will develop and analyze reports describing the above metrics on a quarterly and/or annual basis. The reports will summarize the data on a quarter-to-date and year-to-date basis. UHA will analyze the reports to determine if the activity has resulted in the anticipated outcomes and to identify opportunities for further improvement of the activity. F. Authorization(s) to Conduct the Activity Waiver of certain provisions of Section 3(a)(2), 3(a)(3)(A) and Section 6(l) of the 1937 Act and 24 C.F.R. 5.603, 5.611, 5.628, 5.630, 5.632, 5.634 and 960.255 and 966 Subpart A and certain provisions of Sections (8)(o)(1), (8)(o)(2), (8)(o)(3), (8)(o)(10) and (8)(o)(13)(H)-(I) of the 1937 Act and 24 C.F.R. 982.508, 982.503 and 982.518. 56 Part C: First Year Annual MTW Plan Section V: Proposed MTW Activities – HUD Approval Requested G. Rent Reform Initiative Information 1. Agency’s Board Approval of Policy The UHA Board’s approval of this rent policy is included in the Board’s resolution adopting the MTW application and First-Year Annual Plan. 2. Impact Analysis Estimated Utility Allowances: For the purposes of this initial impact analysis we conducted a review of our current utility allowances. The average utility allowance paid by bedroom size was applied these to our current participant data. However, UHA will conduct a more detailed analysis to determine the appropriate flat utility allowance schedule will be implemented. The detailed analysis will consider current utility allowance schedules, local utility rates (including any local reductions for low-income families) and an evaluation of the impact on tenant rent burden. The following utility allowances were used for this initial analysis: CURRENT AVERAGE UTILITY ALLOWANCES Unit Size (Bedrooms) Amount 0 $72 1 $60 2 $73 3 $104 4 $244 5 $133 Participant Impact: Based on the assessment of the potential impact using the average utility allowance payments in the table above, we believe that there is too much variation in the impact on tenant portions. Some families would receive a substantial increase in their utility allowance, while other families would be subject to a substantial decrease. Based upon our initial impact analysis: 165 families (27%) would experience a decrease in monthly utility allowances ranging from $4.00 to $140.00; 2 families (< 1%) would see no impact from the flat utility allowances; and 438 families (72%) would experience an increase in monthly utility allowances ranging from $1.00 to $73.00. The final impact on families is not yet known because UHA has not developed the flat utility allowance schedule and conducted a detailed analysis of the impact. UHA will conduct a detailed impact analysis as part of the development process, and will attempt to mitigate potential negative impacts on participants’ rent burdens. A phased-in approach and/or other measures may be used. Elimination of Utility Allowance Reimbursement (UAP): Currently, 12 HCV families and zero Public Housing residents receive a Utility Allowance Reimbursement payment (UAP) from UHA. The average UAP is $27.00. Under this activity these 12 families will no 57 Part C: First Year Annual MTW Plan Section V: Proposed MTW Activities – HUD Approval Requested longer receive a UAP. They will continue to receive a Utility Allowance; however, UHA will not issue utility reimbursement checks to families. UHA Impact: This activity is designed to be budget neutral for UHA. However, UHA anticipates a reduced administrative burden of time spent by staff calculating, verifying and explaining the allowances. UHA will measure the impact of this activity as indicated in section D above. 3. Annual Reevaluation of Rent Reform Initiative UHA will evaluate this activity annually. 4. Hardship Case Criteria As part of UHA’s detailed analysis and development of the flat utility allowance schedule, a hardship policy will be established for families who are adversely affected by this activity. 5. Transition Period UHA intends to implement the flat utility allowance schedule for all new and existing HCV program participants at the family’s first annual reexamination following MTW year one. UHA intends to eliminate UAP during MTW year one for all new and existing Public Housing and HCV families during MTW year one. 6. Documentation of Public Hearing See Section D. Evidence of Community Support and Involvement, which includes evidence (in the form of notices, newsletters, sign-in sheets, etc.) that UHA has obtained community and PHA resident participation in developing its MTW application. Documentation of the public hearing is also included. 58 Part C: First Year Annual MTW Plan Section V: Proposed MTW Activities – HUD Approval Requested Activity 9 – Biennial Housing Quality Standards Inspections for Qualified Units A. Description UHA will implement inspection policies to increase operational efficiency and improve the condition of housing choices for participants. UHA will determine the frequency of annual Housing Quality Standards (HQS) inspections in the HCV program based on the results of previous inspections. All units will receive and be required to pass an initial inspection before the effective date of the HAP Contract. Units that pass the initial inspection on the first attempt will be inspected biennially thereafter. UHA will conduct full HQS inspections every second year for units on a biennial inspection schedule. Units that do not pass the initial inspection on the first attempt will be inspected annually. UHA will conduct full HQS inspections every year for units on an annual inspection schedule. Units on an annual inspection schedule will continue to be inspected annually until the unit passes an annual inspection on the first attempt. After the unit passes an annual inspection on the first attempt, the unit will be placed on a biennial inspection schedule. Units that fail a biennial inspection will be inspected annually thereafter until the unit passes an annual inspection on the first attempt. UHA will conduct special inspections upon request of program participants and/or landlords. UHA will continue to employ existing policies to ensure that housing assistance is only provided for units that meet both HUD and UHA-established HQS requirements. UHA will continue to employ existing policies to ensure that housing assistance is only provided for units that meet both HUD and UHA-established HQS requirements. B. Relation to MTW Statutory Objectives This activity addresses the MTW statutory objective to reduce costs and achieve greater cost effectiveness in federal expenditures. C. Anticipated Impacts This activity is expected to reduce administrative burden for UHA and participating landlords, and to encourage landlords to maintain higher quality units. UHA anticipates a reduction in the number of annual inspections performed as units that pass inspection on the first attempt are placed on a biennial inspection schedule, which will also result in a corresponding reduction in staff time and inspection-related costs. 59 Part C: First Year Annual MTW Plan Section V: Proposed MTW Activities – HUD Approval Requested UHA also anticipates that the local inspection standards will serve as an incentive to landlords to maintain higher quality units that will easily pass the initial inspection, resulting in an increase in the number of units that pass the initial inspection on the first attempt. D. Baselines, Benchmarks and Metrics to Assess Outcomes, Including Anticipated Schedules UHA intends to implement this activity for all HCV families during MTW year one. During MTW year one UHA will identify all units eligible for biennial inspection based on the most recent inspection results and place all eligible units on a biennial inspection schedule. 50% of units eligible for biennial inspection will receive their first biennial inspection during MTW year one. The remaining 50% will receive their first biennial inspection during MTW year two. UHA performed 587 annual inspections and 124 reinspections during Fiscal Year 2011-2012. Of the 587 inspections, 124 (21.1%) failed on the first attempt and required reinspection, while 483 (78.9%) passed on the first attempt. Based on this information, UHA anticipates that 79% of all annual inspections will be eligible for biennial inspection and the remaining 21% will continue to be inspected annually. METRIC Number of annual HQS inspections performed annually BASELINE Number of annual HQS inspections performed in the 12month period prior to implementation BENCHMARK Reduce number of annual HQS inspections performed by 30% in MTW year one Percentage of assisted units 0% placed on biennial inspection No units are currently placed on schedule compared to total units biennial inspection schedule assisted Increase percentage of units placed on biennial inspection to 60% in MTW year one Total staff time per year to perform annual inspections Total staff time to perform annual inspections in the 12month period prior to implementation Reduce total staff time to perform annual inspections per year by 30% in MTW year one Cost per year to perform annual inspections Cost to perform annual inspections in the 12-month period prior to implementation Reduce total costs to perform annual inspections per year Number of initial inspections that Number of initial inspections that Increase number of initial pass on first attempt passed on first attempt in the 12- inspections that pass on first month period prior to attempt by 10% in MTW year one implementation Percentage of inspections that pass initial inspection on the first attempt compared to total initial inspections Percentage of initial inspections that pass on first attempt compared to total initial inspections in the 12-month period prior to implementation Increase percentage of initial inspections that pass on first attempt by 10% in MTW year one 60 Part C: First Year Annual MTW Plan Section V: Proposed MTW Activities – HUD Approval Requested E. Data Collection and Protocols Baseline reports will be developed to identify the following baselines for the twelve-month period prior to implementation: The number of annual inspections performed; The number of initial inspections that passed on first attempt; The percentage of initial inspections that passed on the first attempt compared to the total number of initial inspections conducted. A time study will be conducted to determine the average amount of staff time spent conducting annual inspections and related tasks during the twelve-month period prior to implementation. A cost analysis will be performed to determine the average annual costs associated with annual inspections. Reports describing the above metrics will be developed and analyzed on a quarterly and/or annual basis. The reports will summarize the data on a quarter-to-date and year-to-date basis. UHA will analyze the reports to quantify results and identify opportunities for further improvement of the activity. F. Authorization(s) to Conduct the Activity Waiver of certain provisions of Section 8(o)(8) of the U.S. Housing Act of 1937 and 24 C.F.R. 982, Subpart I. G. Rent Reform Initiative Information Not applicable. 61 Part C: First Year Annual MTW Plan Section V: Proposed MTW Activities – HUD Approval Requested Activity 10 – Limit Voluntary Transfers in the HCV Program A. Description UHA will limit voluntary moves between assisted units within UHA’s jurisdiction (“transfers”) for the HCV program to a maximum of two transfers during the term of assistance. To be eligible to transfer, families must also be in good standing with the UHA and eligible to move in accordance with the terms of their lease. UHA’s existing policy prohibiting transfers within the first year of the lease will remain in effect. Exceptions to limits under this activity will be made for families who need to move as a reasonable accommodation for a person with disabilities or for the protection of victims of domestic violence under the Violence Against Women Act. B. Relation to MTW Statutory Objectives This activity addresses the MTW statutory objective to reduce costs and achieve greater cost effectiveness in federal expenditures. C. Anticipated Impacts UHA anticipates that this activity will result in fewer voluntary transfers each year, and a corresponding reduction in staff hours and costs associated with processing transfers. D. Baselines, Benchmarks and Metrics to Assess Outcomes, Including Anticipated Schedules UHA intends to implement this activity for all new and existing HCV families at the start of MTW year one. METRIC Number of voluntary transfers each year BASELINE Number of voluntary transfers in the 12-month period prior to implementation BENCHMARK Reduce voluntary transfers by 50% in MTW year one Staff hours to process transfers (including new unit inspections) each year Total staff hours to process transfers in the 12-month period prior to implementation Reduce time spent by 40% in MTW year one (this figure accounts for additional time spent counseling families on the new limitations) Costs related to processing voluntary transfers each year Total costs related to processing voluntary transfers in the 12month period prior to implementation Reduce costs by 40% in MTW year one (this figure accounts for additional time spent counseling families on the new limitations) E. Data Collection and Protocols A baseline report will be developed to identify the number of voluntary transfers in the twelvemonth period prior to implementation. A time study will be conducted to determine the average number of staff hours to process a voluntary transfer. This value will be used to develop a baseline number of hours spent to process voluntary transfers during the twelve-month period prior to implementation. 62 Part C: First Year Annual MTW Plan Section V: Proposed MTW Activities – HUD Approval Requested A cost analysis will be performed to determine the average annual costs associated with voluntary transfers. Reports describing the above metrics will be developed and analyzed on a quarterly and/or annual basis. The reports will summarize the data on a quarter-to-date and year-to-date basis. UHA will analyze the reports to quantify results and identify opportunities for further improvement of the activity. F. Authorization(s) to Conduct the Activity Waiver of certain provisions of Section 8(o)(7)(a), 8(o)(13)(F), 8(o)(13)(G) of the 1937 Act and 24 C.F.R. 982.303, 982.308, 982.309, 982.451and 983 Subpart E and F. G. Rent Reform Initiative Information Not applicable. 63 Part C: First Year Annual MTW Plan Section V: Proposed MTW Activities – HUD Approval Requested Activity 11 – Local Portability Policies A. Description UHA will apply its MTW policies and requirements to all inbound portability participants and outbound portability participants administered by the receiving PHA. Portability participants will be subject to the MTW activities outlined in this proposed plan, and will be required to comply with UHA’s MTW policies and requirements. Outbound portability participants administered by the receiving PHA will be monitored for compliance with the MTW requirements through verification at the time of annual reexamination. Families interested in porting to UHA’s jurisdiction will be advised of the MTW requirements at the time of initial contact with UHA. Families will be permitted to port in only if they meet UHA’s MTW requirements. UHA will work with neighboring PHAs to educate them about upcoming policy changes that will affect portability participants to ensure that the portability process is as simple as possible for families. UHA recognizes that its policies will differ significantly from those of other PHAs as it exercises MTW flexibility and implements streamlined and innovative solutions to housing challenges. Although the option to exercise portability is critical to increasing housing options, this activity is necessary to ensure that UHA can maximize the potential operational efficiencies offered through MTW flexibility. Without this activity, UHA would need to maintain two sets of policies: one for families from the waiting list and one for portable families. This activity allows UHA to apply the same MTW policies to both groups. B. Relation to MTW Statutory Objectives This activity addresses the MTW statutory objective to reduce cost and achieve greater cost effectiveness in federal expenditures. C. Anticipated Impacts UHA anticipates that this activity will prevent a potential increase in staff hours to process portability families under alternate policies. UHA also expects that implementation of this activity will facilitate reinstatement of a previous mobility agreement between UHA and the Housing Authority of the County of San Bernardino (HACSB) that has been suspended due to programmatic changes implemented by HACSB as an MTW PHA. If UHA’s application is approved and the mobility agreement reinstated, participants can again enjoy simplified mobility throughout the majority of San Bernardino County. A potential impact of this activity could include fewer families porting to UHA’s jurisdiction. Some families interested in moving to UHA’s jurisdiction may not be eligible to do so under UHA’s MTW policies, and other families may choose not to move to UHA’s jurisdiction as a result of UHA’s MTW policies. If this result is realized, a corresponding reduction in accounts receivable from initial PHAs would also occur. 64 Part C: First Year Annual MTW Plan Section V: Proposed MTW Activities – HUD Approval Requested D. Baselines, Benchmarks and Metrics to Assess Outcomes, Including Anticipated Schedules UHA intends to implement this activity during MTW year one for all new and existing HCV participants. METRIC Number of families porting in BASELINE BENCHMARK Number of families porting in Possible decrease in the number during the 12-month period prior of families porting in to implementation Number of families porting out Number of families porting out Possible decrease in the number during the 12-month period prior of families porting out to implementation Accounts receivable from initial PHAs Accounts receivable from initial Possible decrease in accounts PHAs during the 12-month period receivable from initial PHAs prior to implementation E. Data Collection and Protocols Baseline reports will be developed to identify the following baselines for the twelve-month period prior to implementation: The number of families porting in; The number of families porting out; Total accounts receivable from initial PHAs. Rudimentary data will be stored in one or more electronic databases. UHA will develop and analyze reports describing the above metrics on a quarterly and/or annual basis. The reports will summarize the data on a quarter-to-date and year-to-date basis. UHA will analyze the reports to determine if the activity has resulted in a change in the number of families porting to and from UHA’s jurisdiction, and to identify opportunities for further improvement of the activity. F. Authorization(s) to Conduct the Activity Waiver of certain provisions of section 8(r) of the 1937 Act and 24 C.F.R. 982 Subpart H. G. Rent Reform Initiative Information Not applicable. 65 Part C: First Year Annual MTW Plan Section V: Proposed MTW Activities – HUD Approval Requested Activity 12 – Expand Project-Based Voucher Program to a Maximum of 50% of HAP Budget Authority A. Description UHA will utilize up to 50% of its HAP budget authority to increase the availability of quality rental housing units through a local Project-Based Voucher (PBV) program. The PBV program will include the following components: 1. Project-based assistance at rental properties that are not Public Housing; 2. Establishment of a reasonable competitive process for project-basing rental assistance funds to privately or publicly owned properties not owned by the UHA that: a. Meet Housing Quality Standards; and b. Meet any additional standards developed by UHA pursuant to UHA’s MTW plan and agreement and approved by the Secretary; and c. Are owned by non-profit or for-profit entities. To ensure that project-based vouchers are awarded to properties that offer increased housing choice in quality neighborhoods and properties, the competitive process will include a preference or additional points awarded for properties that have been rated as high-quality properties through a UHA or other local property rating program. 3. Authority to project-base up to 50% of the units in multi-family, non-elderly developments. B. Relation to MTW Statutory Objectives This activity addresses the MTW statutory objective to increase housing choices for low-income families. C. Anticipated Impacts UHA anticipates that this activity will increase the quality of rental housing available to UHA’s HCV families, as property owners improve the quality of their properties in order to meet HQS and participate in the competitive award process. An increase in the number of property owners participating in the HCV program may occur. UHA also anticipates that more of UHA’s HCV families will be served through the PBV program. D. Baselines, Benchmarks and Metrics to Assess Outcomes, Including Anticipated Schedules UHA intends to implement this activity over multiple years as marketing the program and reviewing applications can take extensive amounts of time. UHA’s goal is to begin marketing the program during MTW year one, and to award PBV vouchers to increase the size of its PBV program by 10% per year for a maximum of 50% of HAP Budget Authority allocated to PBV. Metrics continued on next page. 66 Part C: First Year Annual MTW Plan Section V: Proposed MTW Activities – HUD Approval Requested METRIC BASELINE Number of property owners Number of property owners participating in the HCV program participating in the HCV program during the 12-month period prior to the first PBV award under this activity HAP budget authority allocated to PBV units BENCHMARK Property owners participating in the HCV program will increase each year beginning MTW year one The baseline is 0 as UHA currently Increase HAP budget authority has no PBV units allocated to PBV units by 10% per year beginning MTW year one E. Data Collection and Protocols Baseline reports will be developed to identify the following baselines: The number of property owners participating in the HCV program during the 12-month period prior to the first PBV award under this activity; The number of PBV units during the 12-month period prior to the first PBV award under this activity. Rudimentary data will be stored in one or more electronic databases. UHA will develop and analyze reports describing the above metrics on a quarterly and/or annual basis. The reports will summarize the data on a quarter-to-date and year-to-date basis. UHA will analyze the reports to determine if the anticipated outcomes have been realized and to identify opportunities for further improvement of the activity. F. Authorization(s) to Conduct the Activity Waiver of certain provisions of section 8(o)(13)(B and D) of the 1937 Act, and 24 C.F.R. 982.1, 982.102 and 24 C.F.R. 983, 983.51, 983.57, as well as Section 8(o)(8) of the 1937 Act, and 24 C.F.R. 982 Subpart I. G. Rent Reform Initiative Information Not applicable. 67 Part C: First Year Annual MTW Plan Section V: Proposed MTW Activities – HUD Approval Requested Activity 13 – Pilot Mobility Program A. Description UHA will develop and implement policies to increase housing choices through a pilot mobility program. This activity will initially apply only to new HCV families selected from the UHA waiting list after implementation. Detailed modeling and analysis will be required prior to implementation of the mobility program. However, UHA proposes to develop a mobility program that: Permits HCV families to relocate to an area outside of UHA’s jurisdiction without the need for traditional portability. UHA expects to achieve this goal through establishing interjurisdictional mobility agreements with neighboring PHAs. Under the mobility agreements, HCV families could move to an area outside of UHA’s jurisdiction and continue to be administered by UHA. Biennial reexamination of the family’s income as well as any interim reexaminations would be conducted by mail (as it currently is for UHA’s existing HCV families). UHA would contract with the local PHA to conduct the HQS inspection for the leased unit. The mobility agreement would also permit HCV families from the partnering PHA to lease within UHA’s jurisdiction and continue to be administered by the partnering PHA. UHA would contract with these PHAs to conduct the HQS inspections for these families. Establishes simplified portability policies that make it easier for HCV families to exercise traditional portability when necessary for families to relocate to an area not covered by a mobility agreement between UHA and the other jurisdiction; Identifies high-quality communities (census tracts) that provide exceptional access to economic or educational opportunities for families. UHA would establish higher payment standards for those communities and provide information and education about the benefits of those communities to encourage HCV families to seek housing there. UHA will conduct additional research in order to develop a mobility program that increases housing choice and is consistent with the objectives of other proposed activities in this plan. For example, UHA may establish policies that permit mobility only if: The move is necessary in order for the family to avail themselves of an employment or educational opportunity; If the move is not necessary in order for the family to avail themselves of an employment or educational opportunity, the new unit must not be located in an area of high poverty; The move is necessary as a reasonable accommodation for a person with disabilities or for the protection of a victim of domestic violence under the Violence Against Women Act. 68 Part C: First Year Annual MTW Plan Section V: Proposed MTW Activities – HUD Approval Requested B. Relation to MTW Statutory Objectives This activity addresses the MTW statutory objective to increase housing choices for low-income families. C. Anticipated Impacts UHA anticipates that this activity will result in an increase in the number of families that relocate to high-quality communities as a result of simplified mobility and encouragement from UHA to lease in these areas. Earned income of families exercising mobility under this program may increase as a result of moving to an area with greater economic or educational opportunities. This activity may also result in an increase in the number of families requesting to relocate to areas outside of UHA’s jurisdiction. UHA will conduct detailed modeling and impact analysis as part of the development process for the final mobility activity. D. Baselines, Benchmarks and Metrics to Assess Outcomes, Including Anticipated Schedules UHA intends to conduct further research and analysis to develop the final mobility program during MTW year one, and anticipates that the pilot program will launch during MTW year two. METRIC Number of families moving to high-quality communities (as identified by UHA) BASELINE Number of families moving to high-quality communities (as identified by UHA) in the 12month period prior to implementation BENCHMARK Increase in number of families moving to high-quality communities Number of families moving to areas outside of UHA’s jurisdiction Number of families moving to areas outside of UHA’s jurisdiction in the 12-month period prior to implementation It is unknown if this number can be expected to change. UHA will establish a benchmark as part of the final development process Number of families leasing within Number of families leasing within Increase in number of families UHA’s jurisdiction administered UHA’s jurisdiction administered leasing within UHA’s jurisdiction by other PHAs by other PHAs immediately prior administered by other PHAs to implementation* Number of families leasing outside of UHA’s jurisdiction and administered by UHA Number of families leasing outside of UHA’s jurisdiction and administered by UHA immediately prior to implementation* Increase in number of families leasing outside of UHA’s jurisdiction and administered by UHA *A small number of families exist in this category as a result of the previous interjurisdictional agreement between UHA and HACSB. E. Data Collection and Protocols Baseline reports will be developed to identify the baselines for each of the metrics described above, as well as any others established as part of the final development process. 69 Part C: First Year Annual MTW Plan Section V: Proposed MTW Activities – HUD Approval Requested UHA will request periodic reports from partnering agencies to determine the number of families leasing within UHA’s jurisdiction and administered by their PHA. Rudimentary data will be stored in one or more electronic databases. UHA will develop and analyze reports describing the above metrics on a quarterly and/or annual basis. The reports will summarize the data on a quarter-to-date and year-to-date basis. UHA will analyze the reports to determine if the anticipated outcomes have been realized and to identify opportunities for further improvement of the activity. F. Authorization(s) to Conduct the Activity Waiver of certain provisions of section 8(o)(1), 8(o)(2), 8(o)(3), 8(o)(10), 8(o)(13)(H)-(I) of the 1937 Act, and 24 C.F.R. 982.503, 982.508 and 982.518. G. Rent Reform Initiative Information Not applicable. 70 Part C: First Year Annual MTW Plan Section VI: Ongoing MTW Activities: HUD Approval Previously Granted SECTION VI: ONGOING MTW ACTIVITIES: HUD APPROVAL PREVIOUSLY GRANTED Not Applicable (Initial Application MTW Plan) 71 Part C: First Year Annual MTW Plan Section VII: Sources and Uses of Funding SECTION VII: SOURCES AND USES OF FUNDING A. PLANNED SOURCES AND USES OF HUD FUNDS The table below details Consolidated MTW sources and uses of HUD funding anticipated for Fiscal Year 2013-2014. This chart lists all planned revenues and expenditures for all funding sources that comprise the MTW Block Grant sources including Section 9 Operating Funds; Section 9 Capital Funds; Section 8 Housing Assistance Payments; and Section 8 Administrative Fees. EXPENSE REVENUE CONSOLIDATED SOURCES AND USES OF MTW FUNDS (FISCAL YEAR 2013-2014) Housing Choice Voucher Program HAP 5,203,422.00 Housing Choice Voucher Program Admin Fees 458,000.00 Other Administrative Fees 4,000.00 Public Housing Operating Fund 79,000.00 Public Housing Capital Fund 242,375.00 Rental Income (Public Housing) 400,000.00 Miscellaneous Income 31,200.00 Investment Income 0.00 TOTAL REVENUE 6,417,997.00 Administration and General Expense 878,000.00 Utilities 78,800.00 Operations and Maintenance 167,400.00 Extraordinary Maintenance 0.00 Housing Assistance Payments 5,203,422.00 Development and Capital Projects 218,375.00 TOTAL EXPENSE 6,545,997.00 Operating Transfers In/Out 128,000.00 Reserve Drawdown/(Buildup) 128,000.00 NET INCOME/LOSS $0.00 B. PLANNED SOURCES AND USES OF STATE OR LOCAL FUNDS Like most small independent PHAs, UHA does not receive funds from government sources other than HUD. MTW programs will allow PHA’s to maximize the limited federal resources in order 72 Part C: First Year Annual MTW Plan Section VII: Sources and Uses of Funding to design affordable housing programs that best utilize these limited resources to best meet local need. C. PLANNED USES OF THE COCC As a small PHA with only 97 units of Public Housing and 624 HCV vouchers and without a COCC, UHA is not subject to COCC rules. D. DEVIATION FROM COST ALLOCATION OR FEE FOR SERVICE APPROACH UHA is utilizing the HUD prescribed cost allocation approach in the administration of the HCV, Public Housing or Capital Fund Program, and anticipates no deviations for Fiscal Year 20132014. E. USE OF SINGLE-FUND FLEXIBILITY FUNDING SOURCE BLOCK GRANT AMOUNT BUDGETED EXPENSES TRANSFER IN/(OUT) HCV HAP 5,203,422.00 $5,203,422.00 $0.00 RESERVES DRAWDOWN (BUILDUP) $0.00 HCV Administration 458,000.00 458,000.00 $0.00 $0.00 Capital Fund $242,375.00 $218,375.00 $24,000.00 $24,000.00 Public Housing Operating Fund $79,000.00 $231,000.00 $152,000.00 ($152,000.00) Public Housing Rents $400,000.00 $400,000.00 $0.00 $0.00 Miscellaneous Income $31,200.00 $31,200.00 $0.00 $0.00 F. RESERVE BALANCES AT THE BEGINNING OF THE PLAN YEAR ESTIMATED RESERVE BALANCES AT BEGINNING OF THE PLAN YEAR Program Reserve Balance Public Housing $ 423,816.17 Section 8 NRA $ 266,837.65 G.PLANNED SOURCES AND USES BY AMP Not applicable. 73 Part C: First Year Annual MTW Plan Section VIII: Administrative SECTION VIII: ADMINISTRATIVE A. RESOLUTION SIGNED BY THE CHAIRMAN OF THE UHA’S BOARD OF COMMISSIONERS Board approval scheduled for June 26, 2012. Copy of Board Resolution will be included as Attachment C. B. DESCRIPTION OF ANY PLANNED OR EVALUATIONS OF THE DEMONSTRATION ON-GOING AGENCY UHA intends to evaluate the effect of the MTW initiatives on the provision of increased housing choices for low-income families, incentives to families to move toward economic selfsufficiency and a reduction in program costs. UHA will develop and perform internal evaluations for each of the stated Moving to Work Program Initiatives. UHA intends to utilize its software program (HAPPY) and custom reports created using this software, to gather much of the data required to property evaluate the demonstration. Evaluations will also help UHA determine whether the quality of the program administration and customer satisfaction has increased. Evaluations will be prepared annually, using data that is collected throughout the year. 74 Part D: Evidence of Community Support and Involvement PART D: EVIDENCE OF COMMUNITY SUPPORT AND INVOLVEMENT 75 Part D: Evidence of Community Support and Involvement 1. EVIDENCE THAT UHA HAS PROVIDED COMMUNITY AND PHA RESIDENT SUPPORT PARTICIPATION IN DEVELOPING ITS MTW APPLICATION, INCLUDING A PUBLIC HEARING UHA conducted outreach to its Public Housing residents, HCV participant families and landlords, community partners and local service providers, and the general public. Outreach was conducted through several outlets: UHA newsletters for Public Housing residents and HCV participant families and landlords. Copies of newsletters are attached as Exhibits 6 and 7; Press release/public notice articles in the Inland Valley Daily Bulletin newspaper and website. Copies of the articles are attached as Exhibit 8; The UHA website, uplandhousing.com. Printouts from UHA’s website are attached as Exhibit 9; Notices mailed directly to community partners and local service providers (a copy of the notice is attached as Exhibit 10. The newsletters, notices and advertisements included a request for comments and feedback on UHA’s proposed MTW plan. A public comment form was included with the newsletters and notices and was also available on UHA’s website. UHA received a total of 25 comments submitted through e-mail and the public comment form. Seventeen comments were in support of the proposed plan, three were opposed, and five were neutral/no comment. The comments were received from Public Housing residents, HCV participant families and landlords, and UHA staff. A summary of the public comments received is attached as Exhibit 11. In addition to the public notices, UHA also held two public outreach meetings designed to answer questions, obtain feedback, and address concerns. These meetings were held on May 15th, 2012, at 9:00 a.m. and 3:00 p.m. Although the newsletters, notices, and website information included an invitation to the meetings, there were no attendees. Copies of the sign-in sheets for these meetings are attached as Exhibit 12. A Public Hearing on UHA’s proposed MTW plan was held on Monday, June 11, 2012. The Public Hearing was announced on the UHA website and in the newsletters and notices. No public comments were received at the Public Hearing. A copy of the agenda for the June 11, 2012, meeting of the UHA Board of Commissioners, which included the Public Hearing on UHA’s proposed MTW plan, is attached as Exhibit 13. Although no comments were received from the public, two UHA commissioners, including one resident commissioner, expressed that they would like additional information about the proposed plan. 76 Part D: Evidence of Community Support and Involvement 2. BOARD RESOLUTION APPROVING THE MTW APPLICATION AND ADOPTING THE ANNUAL MTW PLAN CERTIFICATIONS OF COMPLIANCE Board approval scheduled for June 26, 2012. Copy of Board Resolution will be included as Attachment C. 3. DESCRIPTION OF SIGNIFICANT PARTNERSHIPS Existing and Previous Partnerships The Upland Housing Authority partners with the Upland Community Partnership for Youth Development non-profit, the City of Upland Park and Recreation Department to provide after school programs (VIC’s Place) geared towards education and recreation at the UHA’s Public Housing community. In 2008, the Upland Housing Authority successfully partnered with “Women on the Move” in to provide a mentoring program for young women in the Public Housing program. The Upland Housing Authority successfully partnered with the City of Upland and Upland Community Housing, Inc., a local non-profit housing developer, to construct and manage a very successful 130-unit affordable senior housing development in Upland. UHA managed the development from its opening in 1997 until 2010. UHA also successfully partnered with a number of local non-profit and for-profit organizations to carry out a successful FSS program which included two graduates that became homeowners as a result of their graduation from the FSS program. Future Partnerships A key component of UHA’s MTW plan is the ability to provide supportive services that will create self-sufficiency potential for the families we serve. The Housing Authority of the County of San Bernardino has, through its MTW flexibility, established partnerships with numerous community service organizations to provide supportive services to their participants. UHA has reached out to many of these service providers to discuss the opportunity for providing similar services to UHA participants in the future if UHA receives MTW designation. The response from these organizations was positive. Each organization that we contacted was supportive of UHA’s MTW plan and application, and expressed interest in partnering with UHA in the future. Letters of support from local service providers interested in working with UHA are attached as Exhibit 1. These letters demonstrate UHA’s potential for providing a strong network of supportive services to assist our participant families on their individual journeys to self-sufficiency. 77 Part D: Evidence of Community Support and Involvement 4. DESCRIPTION OF FUNDING LEVERAGING AND OTHER IN-KIND RESOURCES UHA intends to project-base up to 50% of its HCV HAP funds in order to facilitate the development of additional affordable housing in the community. If UHA is successful in costsavings in the administration of the HCV program as a result of the MTW program, available administrative fees may be utilized to develop and/or assist in the development of new affordable units that will expand affordable housing opportunities to HCV participants. 5. DESCRIPTION OF CONSISTENCY OF THIS PLAN, THE PHA PLAN, AND AMENDMENTS TO THE PHA PLAN WITH THE CITY OF UPLAND’S CONSOLIDATED PLAN AND CERTIFICATE OF CONSISTENCY The 2010 – 2014 Consolidated Plan of the City of Upland and the 2008 – 2013 Analysis of Impediments to Fair Housing identified the following impediments: Transit Access Lending Patterns Race/Ethnic Relations Furthering Access to Housing and Services The Consolidated plan also identifies the lack of affordable rental and homeownership units as the primary barrier to affordable housing. Of the impediments identified, UHA’s proposed MTW plan addresses the need to further access to housing and services, as well as the lack of affordable housing. Using MTW flexibility, UHA proposes to increase the number of project-based vouchers it administers, up to 50% of HAP budget authority. Through this activity, UHA will secure additional affordable housing units for Upland residents. Additionally, as part of its MTW plan, UHA intends to establish meaningful partnerships with local community service providers to assist participant families on the path to self-sufficiency. Through its supportive services program, UHA will work with participant families to determine which supportive services they are eligible for, provide opportunities for building and furthering life skills, and provide resources to families that will enable them to locate and obtain quality housing. A certification from the City of Upland indicating that they have reviewed our proposed MTW plan and that the plan is consistent with the Consolidated Plan is attached as Attachment B. 78 Part E: Additional Information Regarding Implementation of the MTW Plan PART E: ADDITIONAL INFORMATION REGARDING IMPLEMENTATION OF MTW PLAN 79 Part E: Additional Information Regarding Implementation of the MTW Plan 1. DEMOGRAPHIC INFORMATION Demographic information, including income levels of families currently assisted by UHA in the Public Housing and HCV programs and of families to be assisted by the UHA under the proposed MTW plan. Resident, participant and applicant demographics as of May 31, 2012. AVERAGE ANNUAL INCOME BY INCOME LEVEL Public Housing HCV Income Level Quantity Percentage Quantity Percentage Extremely Low-Income (30%) 61 63.51% 459 75.99% Very Low-Income (50%) 23 23.96% 123 20.36% Low-Income (80%) 12 12.50% 22 3.64% Above Low-Income (81% +) 0 0% 0 0% AVERAGE ANNUAL INCOME Public Housing $16,926 Amount $0 $1 - $4,999 $5,000 - $9,999 $10,000 - $14,999 $15,000 - $19,999 $20,000 - $29,999 $30,000 and Above HCV $12,351 ADJUSTED ANNUAL INCOME BY DOLLAR AMOUNT Public Housing HCV Quantity Percentage Quantity Percentage 1 1% 11 1.8% 7 7.3% 38 6.3% 9 9.4% 122 20.2% 32 33.3% 256 42.3% 24 25% 99 16.3% 13 13.5% 56 9.3% 10 10.4% 22 3.6% SOURCES OF INCOME AS PERCENTAGE OF FAMILIES OF TOTAL FAMILIES Income Source Public Housing HCV With Any Wages 58% 31% With Any Welfare 24% 39% With Any SS/SSI/Pension 53% 59% With Any Other Income 47% 34% With No Income 0% 1% 80 Part E: Additional Information Regarding Implementation of the MTW Plan TTP Amount $0 $1 - $25 $26 - $50 $51 - $100 $101 - $200 $201 - $350 $351 - $500 $501 and Above TTP AS PERCENTAGE OF TOTAL FAMILIES Public Housing 0% 0% 1% 5% 9% 35% 26% 23% DISTRIBUTION OF FAMILIES BY FAMILY TYPE Public Housing Family Type Quantity Percentage Elderly, No Children, Non-Disabled 15 16% Elderly, with Children, Non-Disabled 2 2% Non-Elderly, No Children, Non-Disabled 20 21% Non-Elderly, with Children, Non-Disabled 29 30% Elderly, No Children, Disabled 21 22% Elderly, with Children, Disabled 2 2% Non-Elderly, No Children, Disabled 5 5% Non-Elderly, with Children, Disabled 2 2% Female-Headed Household with Children 26 27% HCV 0% 0% 3% 5% 15% 48% 20% 10% Quantity 37 4 59 201 134 5 105 44 230 DISTRIBUTION OF FAMILIES BY HEAD OF HOUSEHOLD’S RACE Race Public Housing White Only 62 Black/African American Only 11 American Indian or Alaska Native Only 0 Asian Only 26 Native Hawaiian/Other Pacific Islander Only 0 White, American Indian/Alaska Native Only 0 White, Black/African American Only 0 White, Asian Only 0 Any Other Combination 0 DISTRIBUTION OF FAMILIES BY HEAD OF HOUSEHOLD’S ETHNICITY Ethnicity Public Housing Hispanic or Latino 51 Non-Hispanic or Latino 49 HCV Percentage 6% 1% 10% 34% 23% 1% 18% 7% 39% HCV 61 32 1 5 1 0 0 0 0 HCV 35 65 81 Part E: Additional Information Regarding Implementation of the MTW Plan DISTRIBUTION OF HOUSEHOLD MEMBERS’ AGE AS PERCENTAGE OF TOTAL HOUSEHOLD MEMBERS Public Housing HCV Age Quantity Percentage Quantity Percentage 0–5 15 5% 149 11% 6 – 17 69 25% 372 28% 18 – 50 105 38% 498 37% 51 – 61 35 13% 133 10% 62 – 82 42 15% 170 13% 83 and Older 8 3% 27 2% AVERAGE HOUSEHOLD SIZE Public Housing 2.9 HCV 2.3 DISTRIBUTION OF FAMILIES BY HOUSEHOLD SIZE AS PERCENTAGE OF ALL FAMILIES Number of Persons Public Housing HCV 1 22% 39% 2 31% 25% 3 16% 17% 4 14% 10% 5 10% 5% 6 4% 3% 7 2% 1% 8 1% 0% DISTRIBUTION OF FAMILIES BY NUMBER OF BEDROOMS AS PERCENTAGE OF ALL FAMILIES Number of Bedrooms Public Housing HCV 0 0% 1% 1 8% 37% 2 62% 49% 3 25% 11% 4 4% 2% 5 and Above 0% 0% Number of Years Less Than 1 Year 1 to 2 Years 2 – 5 Years 5 – 10 Years 10 – 20 Years Over 20 Years LENGTH OF STAY INFORMATION Public Housing Quantity Percentage 5 5% 8 8% 17 18% 23 24% 26 27% 17 18% HCV Quantity Percentage 88 15% 43 7% 153 26% 151 26% 129 22% 24 4% 82 Part E: Additional Information Regarding Implementation of the MTW Plan Applicant demographics as of May 31, 2012. Family Type Families with Children Elderly Families Families with Disabilities FAMILIES ON UHA’S WAITING LIST – BY FAMILY TYPE Public Housing 83.14% 9.14% 14.29% HCV 57.30% 18.38% 27.65% FAMILIES ON UHA’S WAITING LIST – BY INCOME LEVEL Income Category Public Housing Extremely Low-Income (30%) 72.00% Very Low-Income (50%) 18.86% Low-Income (80%) 8.00% HCV 68.06% 31.47% 0.39% FAMILIES ON UHA’S WAITING LIST – BY INCOME LEVEL Income Category Public Housing Extremely Low-Income (30%) 72.00% Very Low-Income (50%) 18.86% Low-Income (80%) 8.00% HCV 68.06% 31.47% 0.39% FAMILIES ON UHA’S WAITING LIST – BY RACIAL GROUP Race Public Housing American Indian/Alaska Native 2.86% Asian 10.57% Native Hawaiian/Pacific Islander 2.57% Black/African American 39.43% White 45.43% HCV 2.15% 4.22% 1.72% 44.78% 25.97% Ethnicity Hispanic Non-Hispanic FAMILIES ON UHA’S WAITING LIST – BY ETHNICITY Public Housing 42.00% 57.14% FAMILIES ON UHA’S WAITING LIST – BY UNIT SIZE Number of Bedrooms Public Housing 0 0 1 15 2 289 3 25 4 14 5 and Above 3 HCV 32.44% 41.20% HCV 0 1659 876 230 27 2 83 Part E: Additional Information Regarding Implementation of the MTW Plan 2. ASSISTANCE TARGETING INFORMATION UHA does not intend to change current targeting requirements for the Public Housing and HCV programs. 3. PROPOSED SCHEDULE FOR IMPLEMENTATION UHA recognizes that the proposed activities contained in this plan cannot be implemented immediately. Some activities will require extensive preparation, including further research and modeling, changes to policies, staff training, updates to UHA’s software and information systems, and extensive community outreach. In order to accommodate these needs, UHA proposes to establish the following schedule for implementation of the activities. UHA has established its Fiscal Year 2013-2014 as our target for MTW Year One. However, this date may be delayed only if necessary to accommodate community outreach and/or updates to UHA’s software and information systems or infrastructure prior to implementation. UHA will make every effort to meet the target implementation date of UHA Fiscal Year 2013-2014. Should a delay be necessary, UHA will begin implementation as quickly as feasible. UHA will define MTW Year One as the year that the first MTW activity contained in this plan is implemented. The table on the following page summarizes UHA’s proposed implementation schedule for the MTW activities. Activities Prior to MTW Year One: UHA intends to prepare for implementation of MTW Year One activities between the date that UHA receives MTW designation and the start of UHA Fiscal Year 2013-2014. UHA will make revisions to its policies, prepare staff for upcoming changes, and implement software and other changes necessary for activities designated for implementation in MTW Year One. Other preparatory work for MTW Year Two activities will also begin during this time. UHA will conduct extensive community outreach during this time to inform the community and the families we serve of the upcoming changes to our program. MTW Year One: UHA intends to implement the majority of the proposed activities in this plan during MTW Year One, as most activities can be implemented without the need for extensive changes to software and information systems or infrastructure. MTW Year One will also be used to prepare for more complex activities to be implemented during MTW Year Two. UHA will prepare its software systems, conduct training, revise policies and conduct additional research, modeling and analysis necessary for those activities. MTW Year Two: The proposed activities that require more complex changes and/or additional research, modeling and analysis will be implemented during MTW Year Two. Summary proposed implementation schedule follows on next page. 84 Part E: Additional Information Regarding Implementation of the MTW Plan SUMMARY PROPOSED IMPLEMENTATION SCHEDULE Description of Proposed Activity MTW Year 1 MTW Year 2 1. Single-Fund Budget Full Implementation Continuation 2. Exemption from SEMAP and PHAS Scoring; New Local Assessment System Further Development Full Implementation 3. Simplify Income and Rent Calculations Full Implementation Continuation 4. Biennial Reexaminations for MTW Families 50% Implementation 50% Implementation 5. Increase Minimum Rents from $50 to $125 Full Implementation Continuation 6. Limited Term of Participation in the MTW Program Full Implementation Continuation 7. Progressive Flat TTP for MTW Families Further Development Full Implementation 8. Simplify Utility Allowances Further Development, Partial Implementation Full Implementation 9. Biennial HQS Inspections for Qualified Units Full Implementation Continuation 10. Limit Voluntary Transfers Full Implementation Continuation 11. Local Portability Policies Full Implementation Continuation 12. Expand Project-Based Voucher Program to a Maximum of 50% of HAP Budget Authority Full Implementation Over Series of Years Continuation 13. Pilot Mobility Program Further Development Full Implementation 4. POTENTIAL LOCAL AND NATIONAL IMPACT OF THE MTW PLAN Implementation of this proposed MTW plan has the potential to be of great benefit to UHA’s participant families, applicants, and the community. Using MTW flexibility, UHA intends to streamline the reexamination and inspection processes to reduce the burdens and stresses on participant families. Other activities will encourage families to achieve self-sufficiency and leave the assisted programs. When combined with the new limited-term assistance activity, UHA expects that these activities will enable us to serve more families and reduce the waiting time for applicants as more families leave the programs. The community will also benefit as UHA expands its Project Based Voucher inventory, thus establishing additional affordable housing units within the community. UHA also expects that the activities in this plan will greatly improve administrative and cost efficiencies. Through streamlining and other activities, we will enhance the long-term sustainability of the programs we administer and ensure that they are available for future generations. Because this MTW plan is designed to be implemented by a small agency, it has the potential to benefit more than 3700 similarly sized agencies nationwide. It may serve as a model MTW plan for those agencies in the future. Additionally, successful activities can be replicated and modified as needed by agencies of any size nationwide. 85 Part E: Additional Information Regarding Implementation of the MTW Plan 5. EXTENT TO WHICH THE PLAN HAS THE POTENTIAL AS A REPLICABLE PROGRAM MODEL UHA’s MTW plan is designed to be easily implemented by a small agency with limited staff and resources. By implementing activities in stages and using pilot groups to test activities before full implementation, this plan has the potential to be a template or model plan for other small agencies. According to the U.S. Government Accounting Office’s 2003 Report “Public Housing, Small and Larger Agencies Have Similar Views on Many Recent Housing Reforms”, there are 1,269 PHAs nationwide of similar size to UHA (between 250 and 1249 combined Public Housing and HCV units). Additionally, another 2,438 are very small, with less than 250 combined units. Together, these PHAs represent almost 90% of all PHAs nationwide. This proposed MTW plan could be easily implemented by any of those agencies. Many of the proposed changes are intended to produce administrative and cost efficiencies that would be of benefit to an agency of any size, but particularly a small agency without the economy of scale benefits realized by larger agencies. Activities could be adopted as they are written in this plan or modified to suit the local needs of another agency. UHA is ready to serve as the site for demonstration of the MTW program at a very small PHA. 86