Income Based Subsidy. Affordable Housing Preservation Program (AHPP) Safety Net (Hardship Policy)

Transcription

1 Chapter 10. Total Tenant Payment, Subsidy, and Safety Net Keene Housing (KH) uses the methods described in this Administrative Policy to verify and determine that household income at admission and at recertification is correct. KH uses four methods for calculating subsidy: Income Based Subsidy Affordable Housing Preservation Program (AHPP) Stepped Subsidy Safety Net (Hardship Policy) A. Payment Standard 1. The payment standard is the maximum monthly housing assistance KH will pay to an owner/property manager based upon the household s eligible unit size. 2. For a participating household the Payment Standard is determined by household size. 3. When issuing a voucher, the applicant (or participant if moving) must be given information on the minimum the household is expected to contribute to housing costs and the maximum subsidy that KH can pay. The estimated subsidy given is based on the bedroom size for which the household qualifies according to KH occupancy standards. 4. Payment standards are reviewed and set at least once per year and because of KH s authority through Moving to Work, it has broad discretion in setting these standards. There is no 120% of Fair Market Rent (FMR) limitation. a. While KH will provide justification when setting payment standards that are not between 90% to 120% of the current FMR, it is understood that the decision rests solely with KH. Factors that KH considers when setting payment standards include but are not limited to: i. Success rate of HCV holders, and Market rents in Keene. b. The final payment standard schedule must be approved by the Board of Commissioners prior to implementation. 5. The payment standard for a household is the lower of: Adopted by the Board of Commissioners December 2016 Total Tenant Payment, Subsidy, and Safety Net 71

2 a. The payment standard for the household unit size, which is defined as the appropriate number of bedrooms for the household under KH s occupancy standards; or b. The payment standard for the size of the dwelling unit rented by the household. i. Payment standards set by KH are for units located in Cheshire County. (1) If a unit is rented outside of Cheshire County, KH uses the lesser of the KH payment standard or the payment standard used by the local PHA. The payment standard that applies to a household when their initial lease is approved (at initial occupancy and move) is the payment standard in effect at the time the rent is negotiated with the owner. i The payment standard that applies to a household at the time of a regular recertification is the payment standard in effect on the actual effective date of the regular recertification. iv. The payment standard that applies to a household at the time of an interim recertification is the payment standard in effect on the effective date of the interim. B. Income Based and Affordable Housing Preservation Program (AHPP) Total Tenant Payment 1. Elderly/Disabled and AHPP households total tenant payment (TTP) is calculated based upon the household s adjusted annual income. 2. TTP is the highest of the following amounts, rounded to the nearest dollar: a. 30 percent of the household s monthly adjusted income b. 10 percent of the household s monthly gross income c. The welfare rent d. A minimum TTP of $125 C. Stepped Subsidy Total Tenant Payment 1. Total tenant payment (TTP) for non-elderly/non-disabled households is calculated using the Stepped Subsidy method. 72 Total Tenant Payment, Subsidy, and Safety Net Adopted by the Board of Commissioners December 2016

3 2. Except for those living in an AHPP property, elderly and disabled households may choose to have their TTP calculated using the Stepped Subsidy method rather than the Income Based method. 3. The Step Subsidy method is designed to gradually reduce the amount of housing assistance over time. 4. All households receiving stepped subsidy must participate in the Resident Self-Reliance program. 5. The subsidy a household receives depends on: a. The annual gross income level at admittance to the Stepped Subsidy program; and b. The number of bedrooms for which the household qualifies; and c. The number of bedrooms in the rental unit; and d. The number of years in the program. 6. 1st Step Level TTP a. In Step 1 TTP is the greater of the following: i. 20% of the household s gross income; or Welfare Rent; or i Minimum Rent Voucher Payment Standard by Bedroom Size and Step Subsidy Level # BR VPS Step 1 HAP Step 2 HAP (65% of VPS) Step 3+ HAP (45% of VPS) SRO $597 VPS-20% Gross Income = Subsidy $390 $270 0 $797 VPS-20% Gross Income = Subsidy $520 $360 1 $851 VPS-20% Gross Income = Subsidy $550 $380 2 $1067 VPS-20% Gross Income = Subsidy $690 $480 3 $1287 VPS-20% Gross Income = Subsidy $840 $580 4 $1566 VPS-20% Gross Income = Subsidy $1020 $700 PAD $426 VPS-20% Gross Income = Subsidy $270 $190 Adopted by the Board of Commissioners December 2016 Total Tenant Payment, Subsidy, and Safety Net 73

4 7. Step 2 TTP is calculated using gross rent or voucher payment standard (whichever is less) minus 65% of the voucher payment standard (VPS), rounded to the nearest ten dollars, for the household s approved bedroom size. 8. Step 3 TTP is calculated using gross rent or voucher payment standard (whichever is less) minus 45% of the VPS, rounded to the nearest ten dollars, for the household s approved bedroom size. 9. Subsidy amounts are adjusted on an annual basis to reflect changes in the VPS. 10. Step 1 subsidy will not be less than the Step 3 subsidy amount. a. Households entering the program with subsidy levels calculated to be greater than the Step 3 subsidy but less than the Step 2 subsidy will receive the Step 2 subsidy for three year until the start of their fourth year during which their assistance will be reduced to the 3rd step subsidy. b. Households entering the program with subsidy levels calculated to be less than the Step 3 subsidy amount, the households will receive the Step 3 subsidy immediately. 11. If the subsidy amount meets or exceeds the contract rent, the subsidy will be capped at the contract rent. 12. KH pays the subsidy amount directly to the participant household. a. The household is responsible for making full payment of rent to the owner/ property manager. b. Failure to use the subsidy payment for rent will result in the household s termination from the program. 13. There is a $ minimum rent in the HCV Program. However, households experiencing financial difficulties can apply to Safety Net See Safety Net in this chapter. 14. Households who are experiencing a hardship may apply for Safety Net assistance providing they meet all of the qualifications as defined in the section on Safety Net in this chapter. 15. KH adopts the utility allowance schedule determined annually by New Hampshire Housing Finance Authority (NHHFA). 16. The schedule shall be in the form of a matrix showing typical energy consumption by 74 Total Tenant Payment, Subsidy, and Safety Net Adopted by the Board of Commissioners December 2016

5 bedroom size and building type and set up in a format selected by KH. 17. KH applies the utility allowance that is the lesser of: a. The actual unit size of the leased unit, or b. The authorized voucher size. Example: Ken, his wife, and two children are eligible for a three-bedroom unit. The utility allowance schedule at occupancy puts their utility allowance at $322. If they chose a three-bedroom unit, KH will pay a utility allowance of $322 If they choose a two-bedroom unit, KH will pay the utility allowance for a two-bedroom of $292. If they choose a unit with more than three-bedrooms, the family is considered over-housed and KH will pay the three-bedroom utility allowance of $ The utility allowance schedule in effect is applied to a household at initial occupancy and recertification. 19. The utility allowance schedule that applies to a household at the time of a regular recertification is the utility allowance in effect on the effective date of the recertification. 20. The utility allowance schedule that applies to a household at the time of an interim recertification is the utility allowance schedule in effect on the effective date of the last regular recertification. 21. Unless KH is required to revise utility allowances retroactively, revised utility allowances will be applied to a household s subsidy calculations at the next recertification after the allowance is adopted. 22. The VPS used to calculate subsidy for Step 2 and Step 3 Stepped Rent households assumes that all utilities are included in the household s contract rent. Therefore, if VPS is lower than gross rent, the VPS is used to calculate subsidy and the utility allowance is not applied to these households. D. Rent Burden 1. If a voucher household chooses a unit with a gross rent that exceeds KH s applicable payment standard, the household will pay more than the calculated TTP. 2. At initial occupancy, KH may not approve the tenancy if it would require the household Adopted by the Board of Commissioners December 2016 Total Tenant Payment, Subsidy, and Safety Net 75

6 share to exceed 45% of the household s monthly adjusted income, except under the following circumstances: a. The participant can demonstrate that he/she has successfully been paying in excess of 45% of his/her income for rent. b. The participant has met with KH staff and has demonstrated to the satisfaction of the staff that he/she can meet this burden. i. KH may require the participant to provide documentation demonstrating the participant s ability to meet the proposed rent burden. 3. If the household disagrees with the staff decision, a review by the Director of Programs and Services or her/his designee may be requested in writing within ten (10) business days of the decision. This decision is final with no right of appeal. E. Utility Allowance Payment KH does not make utility allowance payments to households in the HCV program. Example: A participating 3-person household under the Income Based Subsidy Program is renting a two-bedroom unit for $1067 with all utilities included. Thirty percent of the household s total adjusted income is $485 per month, KH s housing assistance payment (HAP) is $582 ($ $485 = $582). If one member of the household cannot provide eligible immigration documentation, that household is identified as a mixed household. KH takes the HAP amount of $582 and divides it by 3 and multiplies it by the number of eligible household members to calculate a new HAP of ((582 / 3) x 2 = $388). The household s new TTP becomes $679 ($ $388 = $679). Example: A participating 3-person household under the Stepped Subsidy Program is renting a two-bedroom unit for $1067 with all utilities included. The household is in Step 2 of the program so KH s housing assistance payment (HAP) is $690. If the household adds a member that cannot provide eligible immigration documentation, that household becomes mixed. KH takes the HAP amount of $690 and divides it by 4 and multiplies it by the number of eligible household members to calculate a new HAP of ( ($690 / 4) x 3 = $518). The household s new TTP becomes $549 ($ $518 = $549). F. Assistance for Mixed Households 1. HUD regulations prohibit assistance to ineligible household members. A mixed household is one that includes at least one U.S. citizen or eligible immigrant and any number of ineligible household members. 76 Total Tenant Payment, Subsidy, and Safety Net Adopted by the Board of Commissioners December 2016

7 2. KH must prorate the assistance provided to a mixed household. a. KH will first determine TTP as if all household members were eligible and then prorate the subsidy based upon the number of household members that actually are eligible. To do this, KH must: i. Calculate the prorated housing assistance payment by dividing the HAP by the total number of household members, and then multiplying the result by the number of eligible household members. Obtain the prorated household share by subtracting the prorated HAP from the gross rent (contract rent plus utility allowance). i The prorated tenant subsidy equals the prorated household share minus the full utility allowance. G. Safety Net The Safety Net program provides temporary relief to participating households experiencing significant, unexpected increases in rent burden. Safety Net is not meant to take the place of fulltime employment for participants who are able to work. Work-able participants are encouraged to find employment rather than use the Safety Net program. Safety Net is meant to be temporary assistance during times of economic hardship. Applications for Safety Net must be submitted monthly unless KH approves a longer term. 1. Eligibility Guidelines a. Applicants must complete a Safety Net application and provide supporting documentation by the 20th of the month the hardship occurs. b. KH may consider applications after the 20th in cases of unanticipated income loss for Stepped Subsidy households. c. Applicants must meet all three of the following criteria to be eligible for Safety Net. i. In compliance with the MTW Housing Contract In compliance with the Resident Self-Reliance program (if applicable) i An Income Based (IB) participant pays more than 45% of their adjusted income towards rent and allowable utilities. iv. A Stepped Subsidy participant pays more than 45% of their gross income toward rent and allowable utilities. Adopted by the Board of Commissioners December 2016 Total Tenant Payment, Subsidy, and Safety Net 77

8 (1) A change in the Stepped Subsidy does not qualify a household for Safety Net. 2. For mixed households, safety net determination is based solely upon eligible household members. 3. Households within the 180 day $0 HAP period (see page 80) with verified unforeseen changes in household composition or decreases in income may complete a Safety Net (SN) application to request consideration to recalculate housing assistance. a. Consistent with KH interim policies in Chapter 13 subsidy will be calculated based upon the household s current circumstances. b. Households participating in the Stepped Subsidy Program prior to the HAP decreasing to $0 will have their subsidy reinstated at their previous step level. 4. Safety Net Committee a. The Safety Net Committee is comprised of KH staff. b. Applications are presented by a Resident Service Coordinator (RSC) to the Safety Net Committee. c. The Safety Net committee may require an applicant to complete an action plan as part of accepting the additional housing assistance. This action plan may include, but is not limited to: i. Training program participation Proof of an active job search i Updated financial plan iv. Proof of volunteer activities v. Additional meetings with the RSC vi. Other activities deemed appropriate 5. Setting Safety Net Tenant Payment a. The Safety Net Committee has several options to help eligible households depending on the household s individual circumstances. The Committee can choose any combination of the following: i. Set the household s tenant payment temporarily to the greater of: 78 Total Tenant Payment, Subsidy, and Safety Net Adopted by the Board of Commissioners December 2016

9 (1) Minimum rent (2) Welfare rent (3) 30% of gross income (for Stepped Subsidy) (4) 30% of adjusted income (for Income Based Subsidy) Extend the period of Safety Net for which the household was previously approved. i Transfer a household from Stepped Subsidy to Income Based subsidy, if applicable. iv. Recommend an Income Based Subsidy household for an interim recertification. Adopted by the Board of Commissioners December 2016 Total Tenant Payment, Subsidy, and Safety Net 79