slide #1 © copyright 2008 nan mckay & associates annie stevenson cara gillette public housing...
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Slide #1 © Copyright 2008 Nan McKay & Associates
Annie Stevenson
Cara Gillette
Public Housing
Community Service & Self-Sufficiency Strategies
©2007 Nan McKay & Associates
© Copyright 2008 Nan McKay & Associates
Slide #2 © Copyright 2008 Nan McKay & Associates
Welcome to Lunch N Learn!
Today’s Topics:• Community Service
RequirementsExemptionsNoncompliance
• Self-Sufficiency Strategies
Slide #3 © Copyright 2008 Nan McKay & Associates
Welcome to Lunch N Learn!
Upcoming topics for the occupancy series:• 12/5/08: Effective Interviewing & Fraud
Prevention• 12/10/08: Repositioning PH Assets• 12/12/08: Managing SEMAP
Slide #5 © Copyright 2008 Nan McKay & Associates
Background Information
The Quality Housing and Work Responsibility Act of 1998 (Public Housing Reform Act) amended Section 12 of the United States Housing Act of 1937 to establish community service and self-sufficiency requirements for certain residents of public housing• Does not apply to Section 8 programs
Slide #6 © Copyright 2008 Nan McKay & Associates
Background Information
Originally, community service had to be implemented beginning with PHA fiscal years that commenced on or after 10/01/2000
Slide #7 © Copyright 2008 Nan McKay & Associates
Background Information
FY 2002 Appropriations Act temporarily suspended community service, except for residents of HOPE VI developments
PHAs were not to implement or enforce community service (except under HOPE VI) using FY 2002 funds
Slide #8 © Copyright 2008 Nan McKay & Associates
Background Information
Notice PIH 2003-17 (HA) was issued on June 20, 2003 to reinstate community service
By July 31, 2003 PHAs had to provide all residents with written notice about the reinstatement of the requirement, their exempt/nonexempt status, and what to do in order to comply
Slide #9 © Copyright 2008 Nan McKay & Associates
Background Information
By October 31, 2003 PHAs had to assure that all affected residents were performing their community service requirements
Slide #10 © Copyright 2008 Nan McKay & Associates
Purpose
Community service and self-sufficiency requirement is intended to:• Assist adult public housing residents in
improving their economic and social well-being• Give them a greater stake in their communities
by allowing them to “give something back”• Facilitate their upward mobility
Slide #11 © Copyright 2008 Nan McKay & Associates
Community Service Definition
Community service is:• Voluntary work or duties
That are a public benefit, and Improve the quality of life, enhance resident
self-sufficiency, or increase resident self-responsibility in the community
• Not employment• May not include political activities
Slide #12 © Copyright 2008 Nan McKay & Associates
Self-sufficiency Definition
An economic self-sufficiency program is:• Any program designed to encourage, assist,
train, or facilitate the economic independence of HUD-assisted families or to provide work for such families…
Slide #13 © Copyright 2008 Nan McKay & Associates
Self-sufficiency Definition
Economic self-sufficiency programs include:• Job training• Employment counseling• Work placement• Basic skills training• Education• English proficiency• Workfare
• Financial or household mgt
• Apprenticeship
• Any pgm necessary to ready for work (e.g. substance abuse or mental health treatment pgm)
• Other work activities
Slide #14 © Copyright 2008 Nan McKay & Associates
PHA Plan Requirements
PHAs must describe their community service programs in their PHA annual plans, except agencies that are:• High performing PHAs• Small PHAs non-troubled & w/PHAS score > 69• But they are not exempt from administering
community service!
Slide #15 © Copyright 2008 Nan McKay & Associates
Program Regulatory Information
24 CFR 960 Subpart F was created to address the community service requirements
Also discussed under lease requirements in 24 CFR 966.4(a)(2)(ii) & 966.4(l)(2)(iii)(D)
PHA Plan requirements are found in 24 CFR 903.7(l) and exemptions in 903.11(c) & 903.12
Slide #16 © Copyright 2008 Nan McKay & Associates
Resident Requirements
Except for family members who are exempt, each adult family member must contribute 8 hours per month of:• Community service activities, or• Economic self-sufficiency program activities,
or• Combination of the two
Slide #17 © Copyright 2008 Nan McKay & Associates
8 Hours Per Month
Individuals cannot skip a month and double-up on their hours the following month
PHAs can make exception to this on a case-by-case basis due to extenuating circumstances• Make up hours prior to lease renewal or within
a reasonable period (PHA policy)
Slide #18 © Copyright 2008 Nan McKay & Associates
Exempt Individuals
Age 62 or older Blind or disabled as defined in the Social
Security Act [42 U.S.C. 416(i)(1); 1382c] and who certifies because of this disability are unable to comply• Primary caretaker of such individual is also
exempt
Slide #19 © Copyright 2008 Nan McKay & Associates
Exempt Individuals
Is engaged in work activities as defined in the Social Security Act [42 U.S.C. 607(d)]• PHAs are encouraged to consider 30 hours per
week as minimum for work activities• PHAs can use reasonable guidelines to clarify
list of work activities in coordination w/TANF agency (list of 12 activities in PIH 2003-17)
Slide #20 © Copyright 2008 Nan McKay & Associates
Exempt Individuals
Meets requirements for being exempt from work activities under State welfare program
Is receiving TANF and has not been found to be in non-compliance with the program
Slide #21 © Copyright 2008 Nan McKay & Associates
HUD FAQs
HUD’s Admission and Occupancy FAQs provides additional guidance for community service implementation and enforcement
Located at: http://www.hud.gov/offices/pih/phr/about/ao_faq4.cfm
The following policy issues come from the FAQs
Slide #22 © Copyright 2008 Nan McKay & Associates
Policy Issues from FAQs
Pregnant females are not automatically exempt• PHA could determine pregnant individual is
temporarily unable to comply & require written verification from physician of such inability
• Or PHA could require individual to make up hours after pregnancy but prior to lease renewal or within a reasonable period
Slide #23 © Copyright 2008 Nan McKay & Associates
Policy Issues from FAQs
Home schooling of children may be an eligible community service activity if the PHA determines it as such
Stay-at-home parents are not exempt• But could meet their 8 hours through
babysitting for someone performing their community service
Slide #24 © Copyright 2008 Nan McKay & Associates
Policy Issues from FAQs
For persons receiving unemployment who are required to look for work:• Job search is one of the items listed as an
exempt work activity• PHA must determine if person is “engaged” in a
“work activity” Must have reasonable policies and a means to
verify
Slide #25 © Copyright 2008 Nan McKay & Associates
PHA Lease Requirements
PHA lease must specify that it will be renewed automatically unless the family fails to comply with the requirements
Violation is grounds for nonrenewal of the lease at the end of the 12-month lease term• Cannot terminate lease for violation of this
requirement during lease term
Slide #26 © Copyright 2008 Nan McKay & Associates
PHA Policy Requirements
PHA must develop policies for administration of community service• May administer qualifying activities directly, or• Make available through contractor or
partnerships with other community organizations, agencies, or institutionsCould include resident organizations
Slide #27 © Copyright 2008 Nan McKay & Associates
Eligible Activities
Public Housing Occupancy Guidebook, Chapter 15, gives examples of eligible community service activities• Recommends that PHAs notify their insurance
companies if residents will be doing their service activities at the PHA
Also provides examples of eligible self-sufficiency activities
Slide #28 © Copyright 2008 Nan McKay & Associates
PHA Requirements
PHA must describe how it determines who is and is not exempt• Including process for determining changes in
exempt status PHA must give all resident families written
description of the requirements, process for claiming and verifying exempt status
Slide #29 © Copyright 2008 Nan McKay & Associates
PH Occupancy Guidebook
The Public Housing Occupancy Guidebook (Chapter 15) discusses the development of exemption verification forms, and recording/certification documentation forms
Also discusses providing family with a copy of the PHA’s community service policies at initial application and lease execution
Slide #30 © Copyright 2008 Nan McKay & Associates
PH Occupancy Guidebook
NOTE: PH Occupancy Guidebook states forms and policies must be provided at initial application and lease execution, however, there is no regulatory or other mandatory basis for this• Should only be considered recommendations• Sample forms are provided in Appendix VI
Slide #31 © Copyright 2008 Nan McKay & Associates
PH Occupancy Guidebook
PH Occupancy Guidebook says “Activities must be performed within the community and not outside the jurisdictional area of the PHA.” • There is no regulatory or other mandatory
basis for this • Only a recommendation
Slide #32 © Copyright 2008 Nan McKay & Associates
PH Occupancy Guidebook
PH Occupancy Guidebook also says family must sign certification that they have received and read the PHA’s community service policies• There is no regulatory or other mandatory
basis for this • Only a recommendation
Slide #33 © Copyright 2008 Nan McKay & Associates
PHA Requirements
PHA must notify family of its determination of family members subject to the requirements• And those who are exempt
PHA must review family compliance and verify compliance annually at least 30 days prior to lease end
Verification for activities not administered by the PHA must be by third party
Slide #34 © Copyright 2008 Nan McKay & Associates
PHA Requirements
PHA must retain documentation of service requirement performance or exemption in the resident files
PHA must comply with non-discrimination and equal opportunity requirements
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PHA Requirements
PHA may not substitute community service or self-sufficiency activities for work ordinarily performed by PHA employees, or • Replace a job at any location where residents
perform activities to satisfy the requirements
Slide #36 © Copyright 2008 Nan McKay & Associates
PHA Requirement for Noncompliance
If tenant or other family member is in noncompliance, the PHA may not renew the lease at the end of the lease term unless:• Tenant/noncompliant member enters into written
agreement to cure by completing additional hours needed by end of next 12-month lease term, or
• Noncompliant member no longer resides in unit
Slide #37 © Copyright 2008 Nan McKay & Associates
Noncompliance Process
Prior to end of lease term, PHA will make a determination whether all nonexempt family members have complied with the requirement
If PHA determines a family member is noncompliant the PHA must notify the family of the noncompliance
Slide #38 © Copyright 2008 Nan McKay & Associates
Noncompliance Notice
PHA notice of noncompliance must:• Briefly describe the noncompliance• State PHA will not renew lease unless:
Tenant and any other noncompliant resident enter into written agreement to cure, and cure
Or that noncompliant member no longer resides in unit
Slide #39 © Copyright 2008 Nan McKay & Associates
Noncompliance Notice
PHA notice of noncompliance must also state that tenant may request a grievance hearing and may exercise any available judicial remedy to PHA’s nonrenewal of the lease
Slide #40 © Copyright 2008 Nan McKay & Associates
Noncompliance Agreement
The agreement to cure should include:• The additional number of hours needed to
make up the required hours under current lease
• Assurance that all nonexempt members are in compliance
• Assurance that any noncompliant resident no longer resides in unit
Slide #41 © Copyright 2008 Nan McKay & Associates
Reporting on 50058
Notice PIH 2004-20 (HA), issued October 2, 2004, provided instructions for completing line 3q of the form HUD-50058 for community service
Also, the latest version of the Form HUD-50058 Instruction Booklet, dated June 28, 2004 has this same instruction
Slide #42 © Copyright 2008 Nan McKay & Associates
Reporting on 50058
As of September 27, 2004, PHAs are not to use option 5, “n/a”, when completing 3q on the 50058 form• Selecting option 5 will result in a fatal error• Option 5 was only to be used for PHAs where
the community service requirement had not yet gone into effect
Slide #43 © Copyright 2008 Nan McKay & Associates
Reporting on 50058
For Section 8 participant reporting, leave 3q blank
Instructions for completing 3q are found in the 50058 Instruction Booklet, pages 15 & 16
Note that on page 16 it mentions “an average of 8 hours per month” – this was clarified in HUD’s FAQs that it is not an average
Slide #44 © Copyright 2008 Nan McKay & Associates
OIG Audit Report
Issued March 24, 2008 “HUD Did Not Ensure that Housing Authorities
Properly Administered the Community Service and Self-Sufficiency Requirement”
www.hud.gov/offices/oig
Slide #45 © Copyright 2008 Nan McKay & Associates
Audit Report Findings
Incomplete guidance• List of needed clarifications
Inadequate data collected via 50058s Ineffective enforcement Issue not a priority
Slide #46 © Copyright 2008 Nan McKay & Associates
Audit Report Findings
PHA concerns• Possible repeal of law
3 unsuccessful attempts, including 2007• Courts reluctant to evict
OIG estimated 85,000 noncompliant households are assisted
Slide #47 © Copyright 2008 Nan McKay & Associates
Audit Report Findings
HUD response• Guidance to be drafted within “a few months”• No funds to modify PIC• Increased oversight & monitoring• Formal sanctions policy through regulation
Slide #49 © Copyright 2008 Nan McKay & Associates
Now We’ll Discuss…
Resident involvement in project administration HUD and private grants Strategies to help residents move from
welfare to work and out of poverty
Slide #51 © Copyright 2008 Nan McKay & Associates
Background
A school of thought considers public housing “bricks and mortar” only
But if public housing is a business, it’s important to have tenants who pay higher rent
And public housing is THE best welfare-to-work partner in the community
Slide #52 © Copyright 2008 Nan McKay & Associates
Resident Participation Managers must recognize importance of
resident involvement• Residents are communication conduit• Residents know what the project is like after
hours and on weekends• Residents know what works• The project is often the most comfortable bridge
for resident into the larger community
Slide #53 © Copyright 2008 Nan McKay & Associates
Resident Participation
Resident participation often comes through the resident council• Representative of tenant interests• Democratically elected board• Formally constituted
Resident councils can form all or part of the Resident Advisory Board
Slide #54 © Copyright 2008 Nan McKay & Associates
Resident Participation
MOU clarifies relationship between PHA and tenant organization or council• PHAs may provide in-kind and cash assistance
for tenant activities• Cash contributions made only under written
agreement Residents serving on the council, RAB, or
board can get a resident service stipend
Slide #56 © Copyright 2008 Nan McKay & Associates
HUD and Private Grants Grant programs can bring fresh faces,
creative partnerships, inspiring mentors, and effective programs to the project
Grants can be for all kinds of things:• At-risk youth• Youth and adults preparing for work• Educational skills• Health projects, parenting, counseling, etc.
Slide #57 © Copyright 2008 Nan McKay & Associates
HUD and Private Grants Some grant-writing tips:
• Make sure you meet the eligibility criteria of the grant and the funder
• Follow the instructions (funder’s format and requirements) to the letter
• Have a vision and believe in it• Make sure your grant is collaborative, with
creative partnerships in the community
Slide #58 © Copyright 2008 Nan McKay & Associates
HUD and Private Grants
HUD announces its self-sufficiency grants in the Federal Register• Announced through Super NOFAs
ROSS grants and Self-Sufficiency Coordinators There are also many philanthropic
organizations looking for great programs
Slide #60 © Copyright 2008 Nan McKay & Associates
Self-Sufficiency Strategies
The FSS program• Designed to promote economic independence
– a great program for families and great PR for the PHA
• Escrow account allows the family to save and to take big step toward economic independence
Slide #61 © Copyright 2008 Nan McKay & Associates
Self-Sufficiency Strategies
Community service program• Design of program can be very effective in
providing opportunities for residents to acquire entry-level competencies
• Design of program should give residents greatest choice possible
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Self-Sufficiency Strategies Community service program
• PHAs have a lot of options in design PHA could design and administer program PHA could collaborate PHA could contract out entire program
• PHA must enforce lease• Activities could include volunteering at the project, in the
community, working with youth, getting counseling (drugs, alcohol, budgeting, parenting)
Slide #63 © Copyright 2008 Nan McKay & Associates
More Strategies for Self-Sufficiency
Collaborate with community partners Understand welfare requirements Section 3
• Requirement with federal contracts to train and hire low-income residents
Communication to and with residents Skilled trades for women
Slide #64 © Copyright 2008 Nan McKay & Associates
More Self-Sufficiency Strategies
Technical assistance with home-based business
Bringing resources directly to the project Earned income disallowance Career counseling Career retention programs
Slide #66 © Copyright 2008 Nan McKay & Associates
The New PHAS
Under the new project-based PHAS, economic self-sufficiency and resident involvement in project administration will all be scored under onsite management review by HUD
Slide #67 © Copyright 2008 Nan McKay & Associates
The New PHAS
Economic self-sufficiency• Exclusions are same as for community service
Elderly Blind or disabled or primary caretaker of such Engaged in work activities Exempt by TANF Member of TANF and in compliance
Slide #68 © Copyright 2008 Nan McKay & Associates
The New PHAS
Economic self-sufficiency• Grade A: Project has at least 85% of
households with HOH, spouse, or sole member that’s elderly/disabled, or at least 50% of all adults are working either full or part-time, or at least 10% of adults are participating in self-sufficiency program
Slide #69 © Copyright 2008 Nan McKay & Associates
The New PHAS
Economic self-sufficiency• Grade C: Project offers or coordinates with an
outside agency to make available at least one self-sufficiency activity
• Grade F: Doesn’t offer
Slide #70 © Copyright 2008 Nan McKay & Associates
The New PHAS
Resident involvement in project admin• Grade A: Project offers at least one
opportunity• Grade F: Project doesn’t offer
Slide #71 © Copyright 2008 Nan McKay & Associates
The New PHAS
Tenant/mgmt relations 2 points• Economic self-sufficiency 1 point• Resident involvement 1 point
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