ORLANDO HOUSING AUTHORITY MOVING TO WORK (MTW) PLAN FOR YEAR 4 APRIL 1, 2014 TO MARCH 31, 2015 DRAFT

Transcription

1 ORLANDO HOUSING AUTHORITY MOVING TO WORK (MTW) PLAN FOR YEAR 4 APRIL 1, 2014 TO MARCH 31, 2015 DRAFT 390 N. Bumby Avenue, Orlando, Florida Tel#: 407/ Fax#: 407/ TDD#: 407/ Relay#: 711

2 Orlando Housing Authority (OHA) Annual MTW Plan for Year 4 April 1, 2014 to March 31, 2015 TABLE OF CONTENTS Pages Section I: Introduction A. Table of Contents 1-2 B. Overview of OHA s Short-Term and Long-Term Goals and Objectives 3-4 MTW Activities 3 Non-MTW Activities 3-4 Section II: General Housing Authority Operating Information A. MTW Plan: Housing Stock Information 5-8 Planned New Public Housing Units to be Added During Fiscal Year 5 Planned Public Housing Units to be Removed During Fiscal Year 5-6 New Housing Choice Vouchers to be Project-Based During Fiscal Year 6-7 Or Changes to Housing Stock Anticipated During Fiscal Year 7 General Description of All Planned Capital Fund Expenditures During 7-8 Plan Year B. MTW Plan: Leasing Information 8-11 Planned Number of Households Served at End of Fiscal Year 8-9 Reporting Compliance with Statutory MTW Requirements 9 Description of any Anticipated Issues Related to Leasing of Public 9-11 Housing, Housing Choice Vouchers and/or Local, Non-Traditional Units and Possible Solutions C. MTW Plan: Wait List Information Wait List Information Projected for Beginning of Fiscal Year Section III: Proposed MTW Activities Activity Activity Activity Section IV: Approved MTW Activities A. Implemented Activities Activity B. Not Yet Implemented Activities Activity Activity C. Activities on Hold 32 None D. Closed Out Activities Activity 4 32 Activity Page 1 of 39

3 Section V: Sources and Uses of Funds A. Sources and Uses of MTW Funds Estimated Sources of MTW Funding for Fiscal Year 33 Estimated Uses of MTW Funding for Fiscal Year Description of Activities that Will Use Only MTW Single Fund Flexibility B. Local Asset Management Plan 36 Section VI: Administrative A. Resolution 36 B. Public Comment Period 36 C. Description of PHA Directed Evaluations 36 D. Annual Statement/Performance and Evaluation Report 36 (Appendix A) E. Certifications of Compliance Additional Appendix Items A. Annual Statement/Performance and Evaluation Report 1-16 Page 2 of 39

4 SECTION I: INTRODUCTION B. Overview of OHA s Short-Term and Long-Term Goals and Objectives This section of Orlando Housing Authority s Plan will present an introduction consisting of an overview of OHA s short and long-term goals and objectives. MTW Activities As an MTW agency, OHA is allowed flexibility to modify certain requirements in order to achieve one or more of following MTW statutory objectives: 1. Reduce cost and achieve greater costs effectiveness in Federal expenditures; 2. Give incentives to families with children where head of household is working, is seeking work, or is preparing for work by participating in job training, educational programs, or programs that assist people to obtain employment and become economically self-sufficient; and 3. Increase housing choices for low-income families. In general, OHA s short term and long term goals are to continue to implement MTW activities and Uses of Funds. OHA contemplates changes to some of its ongoing MTW Activities and Uses of Funds and proposal of a new activity to furr MTW statutory objectives. All activities and uses of funds are discussed in detail in plan. OHA s long term goals for MTW activities may change as MTW is a demonstration program. Changes will be made as necessary to meet needs of OHAs participants and residents in best possible manner with consideration for sequestration and or factors outside of OHA s control. Non-MTW Activities The OHA administers a number of non-mtw programs. Such programs include, but are not limited to, following: (1) vouchers for non-elderly persons with disabilities, (2) HUD VASH vouchers, (3) vouchers for single-room occupancy, (4) resident opportunities and supportive services (ROSS) and non-public housing units. These programs are essential in ir support and assistance to residents and participants that are not involved in MTW activities. OHA s non-public housing units are located at West Oaks Apartments (180 one and two bedroom units), Antioch Manor (a project-based section 202 property consisting of 101 units for elderly) and 75 unit Jackson Court/Division Oaks Development. Jackson Court is a 58 unit, 3 story senior housing apartment complex with one bedroom units only. Division Oaks is a two story, 17 unit family apartment complex. The Jackson Court/Division Oaks Development operates without any public housing or project-based section 8 subsidy. In addition, OHA maintains oversight of Carver Park HOPE VI Development, which includes Landings at Carver Park and Villas at Carver Park. The Landings at Carver Park is 56 units of affordable housing for families (26 tax credit and 30 tax credit/public housing hybrid). The Villas at Carver Park is a 64 unit tax credit/public housing hybrid apartment complex for elderly. OHA s long term plan for its non-mtw programs is to continue to manage its properties and to seek opportunities for OHA to increase its housing portfolio such that Page 3 of 39

5 additional affordable housing options are available to community. In addition, OHA is committed to improving quality of housing provided to its residents as funding permits. Sanford Housing Authority The OHA continues to manage Sanford Housing Authority (SHA). The goals and objectives for SHA include demolition and redevelopment of SHA public housing program. The demolition of all 6 public housing sites should be complete by June OHA with SHA plans to establish a community coalition with SHA Board of Commissioners to submit a Choice Neighborhoods application to HUD to request funding as part of redevelopment process. Standard HUD Metrics HUD recently modified MTW metrics. As such, OHA is still developing metrics that will apply to OHA s MTW activities and metrics presented in this plan will be modified furr. Page 4 of 39

6 (II) General Housing Authority Operating Information Annual MTW Plan II.1.Plan.HousingStock A. MTW Plan: Housing Stock Information Planned New Public Housing Units to be Added During Fiscal Year AMP Name and Numb er Bedroom Size Tot al Unit s Pop ulat ion Typ e * # of UFAS Units Fully Accessib le Adaptab le PIC Dev. # /AMP PIC Dev. Name PIC Dev. Name X X X X X X X X Typ e Not ed * X X Total Public Housing Units to be Added 0 If Or, please describe: N/A Planned Public Housing Units to be Removed During Fiscal Year PIC Number of Explanation for Removal Page 5 of 39

7 Dev. # / AMP and PIC Dev. Name PIC Dev. # /AMP PIC Dev. Name Units to be Removed X Explanation for Removal Total Numb er of Units to be Remo ved 0 New Housing Choice Vouchers to be Project-Based During Fiscal Year Prope rty Name West Oaks Anticipated Number of New Vouchers to be Project- Based * 20 Description of Project West Oaks Apartments is a three story, 280 unit, affordable market rate rental property in which OHA plans to project base up to fifty units to provide transitional housing to homeless individuals for up to eighteen months. OHA will work with Wayne Densch Center, Inc. and or service providers who will provide case management as a homelessness preventative measure. A total of twenty vouchers/units are to be committed for See activity 6. Page 6 of 39

8 Antici pated Total New Vouch ers to be Projec t- Based 20 Anticipated Total Number of Project- Based Vouchers Committed at End of Fiscal Year Anticipated Total Number of Project- Based Vouchers Leased Up or Issued to a Potential Tenant at End of Fiscal Year Or Changes to Housing Stock Anticipated During Fiscal Year Starting April 1, 2013, OHA was awarded an additional 110 VASH vouchers for MTW Year 3. This award will continue to be implemented in years forward. General Description of All Planned Capital Fund Expenditures During Plan Year Capital Expenses Page 7 of 39

9 Ivey Lane 4-9 has planned capital expenditures during Plan Year 4 in amount of $298,212 for plumbing (i.e., re-piping) and $210,000 for bathroom renovations. The Central Office Cost Center (COCC) has planned capital expenditures during Plan Year 4 in amount of $100,000 for computer equipment and software assets. OHA has $857,478 of planned expenditures for public housing sites Capital Fund Financing Program loan repayment to Deutsche Bank. Or Income of $485,280 includes $365,860 from Capital Fund Financing Reserves to pay for costs of security cameras to be installed at public housing sites. Non-Capital Expenses Non-Capital Expenditures include administrative salaries, security guard service and architectural services/fees. II.2.Plan.Leasing B. MTW Plan: Leasing Information Planned Number of Households Served at End of Fiscal Year MTW Households to be Served Through: Planned Number of Household s to be Served* Planned Number of Unit Months Occupie d/ Leased* ** Federal MTW Public Housing Units to be Leased Federal MTW Voucher (HCV) Units to be Utilized **** Number of Units to be Occupied/Leased through Local, Non- Traditional, MTW Funded, Property- Based Assistance Programs ** Number of Units to be Occupied/Leased through Local, Non Page 8 of 39

10 Traditional, MTW Funded, Tenant- Based Assistance Programs ** Total Households Projected to be Served ****Please note that se numbers include SHA vouchers Reporting Compliance with Statutory MTW Requirements OHA is in compliance with required statutory MTW requirements listed in Section II(C) of Standard MTW Agreement. Therefore, no discussion or reporting is necessary. Description of any Anticipated Issues Related to Leasing of Public Housing, Housing Choice Vouchers and/or Local, Non-Traditional Units and Possible Solutions Housing Program Public Housing Description of Anticipated Leasing Issues and Possible Solutions The chief issue related to leasing public housing units is a substantial number of applicants fail criminal background checks at time of admission, making it difficult to fill vacancies from waiting list in a timely manner. In addition, a significant number of public housing residents fail criminal background checks at time of re-certification, resulting in ir termination. This furr increases number of vacant units, which must be filled from waiting list. OHA has reduced criminal background check eligibility period from ten years to five years but this has not resolved issue. Unfortunately, criminal background of applicants is not a matter for which OHA has direct control. Adequate public transportation is also an issue. The Page 9 of 39

11 lack of public transportation from available public housing units to applicant s place of employment often results in applicant refusing housing unit, which extends time required to fill vacancies. Again, this issue is not a matter for which OHA has direct control. Anor issue related to difficulties with waiting list vacancies is that OHA ACOP states that applicants must have 12 months of continuous fulltime employment in order to establish a preference on waiting list. This adds to difficulty filling vacancies because many applicants do not have twelve months of continuous fulltime employment. OHA staff plans to address this issue by recommending that OHA Board of Commissioners reduce continuous fulltime employment requirement from twelve months to six months. An anticipated issue is that OHA would like to more strongly adhere to its mission to offer a choice of safe and affordable housing options and opportunities for economic independence for residents of Orlando and Orange County. Currently, OHA Admissions and Continued Occupancy Policy (ACOP) does not establish a public housing admissions wait list preference for applicants that live, work or have a verifiable offer for employment within Orange County, FL. OHA plans to resolve this issue by recommending a resolution to its Board of Commissioners to include a local preference for applicants that live, work or have a verifiable offer for employment in Orange County, FL. Housing Choice Voucher The chief issue relative to leasing of HCVs is OHA s ability to pay amount of rent that an owner will accept. Typically, one of two scenarios occur: (1) amount of rent that an owner requests may not be reasonable or (2) at initial lease up, client would be required to pay more than 40% of ir adjusted income, which makes home unaffordable. In some instances, owners are willing to work with clients and accept a lesser rent. However, some owners prefer not to rent unless y receive amount of rent y Page 10 of 39

12 request. OHA s possible solution is to attempt to negotiate with owner such that rent is in line with rent reasonableness standards and up to 40% of participant s income. Due to sequestration, funding is also a potential issue for HCV program. OHA may not have enough subsidy money and/or administrative support to comply with HUD s leasing requirements. An anticipated issue is that OHA would like to more strongly adhere to its mission to offer a choice of safe and affordable housing options and opportunities for economic independence for residents of Orange county. Currently, OHA Admissions and Continued Occupancy Policy (ACOP) does not establish a Section 8 admissions wait list preference for applicants that live, work or have a verifiable offer for employment within Orange County, FL. OHA plans to resolve this issue by recommending a resolution to its Board of Commissioners to include a local preference for applicants that live, work or have a verifiable offer for employment in Orange County, FL. II.3.Plan.WaitList C. MTW Plan: Wait List Information Wait List Information Projected for Beginning of Fiscal Year Housing Program(s) * Wait List Type** Nu mbe r of Hou seh olds on Wai t List Wait List Open, Partially Open or Closed* ** Are There Plans to Open Wait List During Fiscal Year Page 11 of 39

13 Federal MTW Public Housing Units Community Wide Open N/A Federal MTW Housing Choice Voucher Program Community Wide 678 Closed No Federal MTW Public Housing Wait List Demographic Information Total Number on Waiting List % Distribution by Income Level Extremely Low Income % Very Low Income % Low Income 559 5% Distribution by Bedroom Size 0 Bedrooms % 1 Bedroom 90 1% 2 Bedrooms % 3 Bedrooms % 4 Bedrooms 258 2% 5 Bedrooms 22 1% 6 Bedrooms+ 5 1% Distribution by Family Type Elderly Disabled 308 3% Elderly Non-Disabled 710 6% Non-Elderly Disabled % Non-Elderly Non-Disabled % Distribution by Race of Head of Household White % Black/African American % Asian 74 1% Native Hawaiian/Or Pacific Is % Or/Unknown 169 1% Distribution by Ethnicity of Head of Household Hispanic or Latino % Non-Hispanic Non-Latino % If Local, Non-Traditional Housing Program, please describe: N/A Page 12 of 39

14 If Or Wait List Type, please describe: The Villas at Hampton Park is a forty eight unit property for seniors only. The wait list for Villas at Hampton Park is 649. This wait list is currently closed. The Villas at Carver Park is a sixty four unit public housing tax credit apartment complex for elderly. The wait list for Villas at Carver Park is 684. This wait list is currently closed. The Landings at Carver Park is a fifty six unit property of affordable housing for families (26 tax credit and 30 public housing tax credit). The wait list for Landings at Carver Park is This wait list is currently closed. If re are any changes to organizational structure of wait list or policy changes regarding wait list, provide a narrative detailing se changes. None Section III: Proposed MTW Activities Activity 2: Streamline Recertification Process in Public Housing Program (Re-Proposed) Description: Streamline recertification process in public housing program by conducting recertification of elderly and disabled households every three (3) years instead of annually. This activity used to cover vouchers as well, meaning that OHA conducted triennial recertifications of all elderly and disabled HCV households. See proposed Activity 8. OHA also proposes to streamline recertification process by eliminating interims except for hardships and changes in family composition for all public housing residents. Due to extended recertification period, OHA proposes to create a local form 9886, Authorization for Release of Information. The local form will capture same information as HUD form 9886 except that public housing resident s consent for release of information will be extended from 15 months to 36 months as needed to update resident s data between each triennial recertification. Achievement of Statutory Objectives: Triennial recertifications for elderly and disabled public housing households and elimination of interims except for hardships and changes in family composition for all public housing residents will achieve statutory objective to reduce cost and achieve greater cost effectiveness in Federal expenditures by reducing staff time spent on recertifications and interims. Anticipated Impacts: An anticipated impact of this activity on statutory objective to reduce cost and achieve greater cost effectiveness in Federal expenditures is a reduction in staff time Page 13 of 39

15 spent on recertifications and interims. A reduction in staff time spent on recertifications and interims will allow OHA to more efficiently use its funding for benefit of its program participants. Once OHA has finalized of new Standard HUD Metrics, OHA may develop additional anticipated impacts. Anticipated Schedules for Achieving Objective(s): OHA plans to complete triennial recertifications of elderly and disabled public housing households in 2014 as scheduled in prior year plans. OHA s anticipated schedule to implement elimination of interims except for hardships and changes in family composition for all public housing residents will begin in Plan Year 4. OHA plans to have all public housing residents sign local form in Authorization(s): Section C.4. of Attachment C of MTW Agreement authorizes agency to restructure initial, annual and interim review process in public housing program in order to affect frequency of reviews and methods and process used to establish integrity of income information provided. In addition, Agency is authorized to adopt a local system of income verification in lieu of current HUD system. Need for Authorization: The above cited authorization is needed to waive PHA s responsibility to conduct a re-examination of income and composition at least annually. The authorization C.4. of Attachment C gives OHA flexibility to conduct proposed triennial recertifications of elderly and disabled households, eliminate interims (with exceptions provided) and create a local form 9886 with an extended consent period. Additional Information for Rent Reform Activities: Impact Analysis 1. Description of rent reform activity: Streamline recertification process in public housing program by conducting recertification of elderly and disabled households every three (3) years instead of annually. This activity used to cover vouchers as well, meaning that OHA conducted triennial recertifications of all elderly and disabled HCV households. See proposed Activity 8. OHA also proposes to streamline recertification process by eliminating interims except for hardships and changes in family composition for all public housing residents. 2. Tracking and documenting of rent reform activity: OHA will establish a schedule for recertification of elderly and disabled public housing households for every three years beginning in MTW Plan Year 4. OHA will track and document triennial recertification of elderly and disabled public housing households as outlined in applicable metrics. OHA will track and document of elimination of interims by establishing a baseline and following applicable metrics beginning in MTW Year Identifying intended and possible unintended impacts of rent reform activity An anticipated impact of this activity on statutory objective to reduce cost and achieve greater cost effectiveness in Federal expenditures is a reduction in staff time Page 14 of 39

16 spent on recertifications and interims. A reduction in staff time spent on recertifications and interims will allow OHA to more efficiently use its funding for benefit of its program participants. OHA does not anticipate unintended impacts. 4. Measuring impacts of rent reform activity OHA will measure impacts of this activity by analyzing data collected from metrics. Hardship Case Criteria OHA will establish a hardship panel to evaluate individual circumstances in case of hardship exemption requests. Qualifying hardships will include loss of income due to circumstances beyond household s ability to control, including following: (1) temporary medical condition that prevents an adult family member from working when loss of employment is not covered by paid medical benefits, (2) loss of employment due to reduction in workforce or closure of place of employment where employment income loss is not covered by severance or separation benefits and (3) an increase in medical expenses such that se expenses exceed 15% of gross income. Description of Annual Reevaluation of Rent Reform Activity OHA will analyze data collected in applicable metrics to determine wher objective(s) are achieved and wher revision is necessary to mitigate negative impacts of unintended consequences. Transition Period There will be no transition period for triennial recertifications as this process is already in place. OHA will provide residents with written notice of elimination of interims. The residents receipt and acknowledgement of notice will be recorded. Cost Effectiveness When citing statutory objective to reduce cost and achieve greater cost effectiveness in federal expenditures, include all of following metrics that apply: CE #1: Agency Cost Savings Unit of Measurement Baseline Benchmark Outcome Benchmark Achieved? Page 15 of 39

17 Total cost of task in dollars (decrease). Cost of task prior to of activity (in dollars). Expected cost of task after of activity (in dollars). Actual cost of task after of activity (in dollars). Wher outcome meets or exceeds benchmark. Unit of Measurement Total time to complete task in staff hours (decrease). CE #2: Staff Time Savings Baseline Benchmark Outcome Total amount of staff time dedicated to task prior to of activity (in hours). Expected amount of total staff time dedicated to task after of activity (in hours). Actual amount of total staff time dedicated to task after of activity (in hours). Benchmark Achieved? Wher outcome meets or exceeds benchmark. Activity 3: Streamline Rent Calculation Process in Public Housing & Housing Choice Voucher Programs (Re-Proposed) Description: The goal of this activity is to streamline rent calculation process in public housing and voucher programs. In order to accomplish this goal, OHA has implemented modified third party verification and asset disregard policies and procedures for both public housing and housing choice voucher program. In addition, OHA proposes to eliminate rent decreases in first year of a tenancy for both public housing and housing choice voucher program. OHA will establish hardship exceptions to elimination of rent decreases in first year of tenancy for both programs. OHA also proposes to increase public housing residents ability to choose Flat Rent Option to twice per year rar than annually. Achievement of Statutory Objectives: This activity will meet following statutory objectives: (1) to reduce cost and achieve greater cost effectiveness in Federal expenditures and (2) to give incentives to families with children whose heads of household are eir working, seeking work, or participating in job training, educational or or programs that assist in obtaining employment and becoming economically self sufficient. The modified third party verification and asset disregard policies and procedures will achieve statutory objective of cost effectiveness by reducing staff time spent on rent calculations. The elimination of rent decreases in first year of tenancy for public housing and HCV program will achieve statutory objective of cost effectiveness and self sufficiency. The elimination of rent decreases in first year of tenancy will achieve cost effectiveness by reducing amount of time staff spends on rent decreases in first year of tenancy. The elimination of rent decreases in first year of tenancy will achieve self sufficiency by reducing incentive for voluntary loss of employment upon securing initial tenancy through OHA s public housing or HCV program. Increasing public housing residents ability to chose flat rent option to twice per year rar than annually will achieve statutory objective of self sufficiency. The current limited flat rent Page 16 of 39

18 option is a disincentive for increased income and refore self sufficiency. By allowing resident to request flat rent once in addition to time of ir annual recertification, OHA will provide anor opportunity for rent to become stable despite increased income and thus increase incentive for residents to improve ir employment status and income and consequently achieve statutory objective of self sufficiency. Anticipated Impacts: An anticipated impact of this activity on statutory objective to reduce cost and achieve greater cost effectiveness in Federal expenditures is a reduction in staff time spent on rent calculations. A reduction in staff time spent on recertifications and interims will allow OHA to more efficiently use its funding for benefit of its program participants. An anticipated impact of this activity on statutory objective to increase self sufficiency is increased employment and income for residents and HCV program participants. OHA anticipates that eliminating rent decreases during first year of tenancy to maintain or increase employment because it will reduce incentive for voluntary loss of employment upon lease up based upon knowledge that housing authority would decrease ir rent following reported loss of employment/income. Similarly, allowing public housing residents to choose flat rent twice per year would increase self sufficiency by increasing incentive for residents to earn more income without fear of a rent increase. Once OHA has finalized of new Standard HUD Metrics, OHA may develop additional anticipated impacts. Anticipated Schedules for Achieving Objective(s): The modified third party verification and asset disregard policies and procedures already have been implemented. OHA anticipates implementing elimination of rent decreases in first year of tenancy (with hardship exceptions) during Plan Year 4. OHA also anticipates increasing flat rent option to twice per year during Plan Year 4. Authorization(s): Section C.4. of Attachment C of MTW Agreement authorizes agency to restructure initial, annual and interim review process in public housing program in order to affect frequency of reviews and methods and process used to establish integrity of income information provided. In addition, Agency is expressly authorized to adopt a local system of income verification in lieu of current HUD system. Section C.11. of Attachment C of MTW Agreement authorizes agency to determine public housing family payment, including total tenant payment, minimum rent, utility reimbursements and tenant rent. The Agency is authorized to adopt and implement any reasonable policies for setting rents in public housing including but not limited to establishing definitions of income and adjusted income, or earned income disallowance that differ from those in current statutes or regulations. The Agency is authorized to adopt and implement term limits for its public housing assistance. Such policies must include provisions for addressing hardship cases. Section D.1.c. of Attachment C of MTW Agreement authorizes agency to define, adopt and implement a section 8 reexamination program that differs from reexamination program currently mandated in 1937 Act and its implementing regulations. Section D.2.a. of Attachment C of MTW Agreement authorizes agency to adopt and implement any reasonable policy to establish payment standards, rents or subsidy levels for tenant-based assistance that differ from currently mandated program requirements in Page 17 of 39

19 1937 Act and its implementing regulations. The Agency is authorized to adopt and implement any reasonable policies to calculate tenant portion of rent that differ from currently mandated program requirements in 1937 Act and its implementing regulations. Need for Authorization: Sections C.4. and C.11. of Attachment C of MTW Agreement are needed in order to modify third party verification and asset disregard policies for public housing. Sections D.1.c. and D.2.a. of Attachment C of MTW Agreement are needed in order to modify third party verification and asset disregard policies for section 8. Section C.11. and D.2.a. of Attachment C of MTW Agreement are needed to eliminate rent decreases in first year of tenancy for public housing and section 8 respectively. Additional Information for Rent Reform Activities: Impact Analysis 1. Description of rent reform activity: The goal of this activity is to streamline rent calculation process in public housing and voucher programs. In order to accomplish this goal, OHA has implemented modified third party verification and asset disregard policies and procedures for both public housing and housing choice voucher program. In addition, OHA proposes to eliminate rent decreases in first year of a tenancy for both public housing and housing choice voucher program. OHA will establish hardship exceptions to elimination of rent decreases in first year of tenancy for both programs. OHA also proposes to increase public housing residents ability to choose Flat Rent Option to twice per year rar than annually. 2. Tracking and documenting of rent reform activity: OHA has already implemented modified third party verification and asset disregard policies. OHA will track and document of modified third party verification and asset disregard policies by applicable metrics. OHA will track and document elimination of rent decreases in first year of tenancy for public housing and housing choice voucher program by establishing a baseline and following applicable metrics beginning in MTW Year 4. OHA will track and document public housing residents ability to choose Flat Rent Option twice per year by following applicable metrics. 3. Identifying intended and possible unintended impacts of rent reform activity An anticipated impact of this activity on statutory objective to reduce cost and achieve greater cost effectiveness in Federal expenditures is a reduction in staff time spent on rent calculations. A reduction in staff time spent on recertifications and interims will allow OHA to more efficiently use its funding for benefit of its program participants. An anticipated impact of this activity on statutory objective to increase self sufficiency is increased employment and income for residents and HCV program participants. OHA anticipates that eliminating rent decreases during first year of tenancy to maintain or increase employment because it will reduce incentive for voluntary loss of employment upon lease up based upon knowledge that housing authority would decrease ir rent following reported loss of employment/income. Page 18 of 39

20 Similarly, allowing public housing residents to choose flat rent twice per year would increase self sufficiency by increasing incentive for residents to earn more income without fear of a rent increase. OHA does not anticipate unintended impacts. 4. Measuring impacts of rent reform activity OHA will measure impacts of this activity by analyzing data collected from metrics. Hardship Case Criteria OHA will establish a hardship panel to evaluate individual circumstances in case of hardship exemption requests. Qualifying hardships will include loss of income due to circumstances beyond household s ability to control, including following: (1) temporary medical condition that prevents an adult family member from working when loss of employment is not covered by paid medical benefits, (2) loss of employment due to reduction in workforce or closure of place of employment where employment income loss is not covered by severance or separation benefits and (3) an increase in medical expenses such that se expenses exceed 15% of gross income. Description of Annual Reevaluation of Rent Reform Activity OHA will analyze data collected in applicable metrics to determine wher objective(s) are achieved and wher revision is necessary to mitigate negative impacts of unintended consequences. Transition Period The elimination of rent decreases in initial year of tenancy will only affect new admissions to OHA public housing and housing choice voucher program. OHA will amend applicable program policies and procedures to reflect elimination of rent decreases in initial year of tenancy for public housing residents and housing choice voucher participants. Cost Effectiveness CE #1a: Staff Time Savings on 3 rd Party Verifications Unit of Measureme nt Baseline Benchmark Outcome Benchmar k Achieved? Page 19 of 39

21 Total time to complete task in staff hours (decrease). Total amount of staff time dedicated to task prior to implementati on of activity (in hours). Expected amount of total staff time dedicated to task after of activity (in hours). Actual amount of total staff time dedicated to task after implementatio n of activity (in hours). Wher outcome meets or exceeds benchmar k. Unit of Measureme nt Total time to complete task in staff hours (decrease). CE #2: Staff Time Savings on Rent Calculations Baseline Benchmark Outcome Total amount of staff time dedicated to task prior to implementati on of activity (in hours). Expected amount of total staff time dedicated to task after of activity (in hours). Actual amount of total staff time dedicated to task after implementatio n of activity (in hours). Benchmar k Achieved? Wher outcome meets or exceeds benchmar k. CE #3a: Staff Days Savings on Completing Recertifications Unit of Measureme nt Total time to complete task in staff days (decrease). Baseline Benchmark Outcome Total amount of staff days dedicated to task prior to implementati on of activity (in hours). Expected amount of total staff days dedicated to task after of activity (in hours). Actual amount of total staff days dedicated to task after implementatio n of activity (in hours). Benchmar k Achieved? Wher outcome meets or exceeds benchmar k. Unit of Measureme nt Rental revenue in dollars (increase). CE #5: Increase in Agency Rental Revenue Baseline Benchmark Outcome Rental revenue prior to implementati Expected rental revenue after of activity (in dollars). Actual rental revenue after implementatio n of Benchmar k Achieved? Wher outcome meets or Page 20 of 39

22 on of activity (in dollars). activity (in dollars). exceeds benchmar k. Unit of Measurement Average earned income of households affected by this policy in dollars (increase). Self Sufficiency SS #1: Increase in Household Income Baseline Benchmark Outcome Average earned income of households affected by this policy prior to of activity (in dollars). Expected average earned income of households affected by this policy prior to implementati on of activity (in dollars). Actual average earned income of households affected by this policy prior to implementati on (in dollars). Benchmar k Achieved? Wher outcome meets or exceeds benchmar k. SS #3: Increase in Positive Outcomes in Employment Status Unit of Measurement Report following information separately for each category: (1) Employed Full- Time (2) Employed Part- Time (3) Enrolled in an Educational Program (4) Enrolled in Job Training Program (5) Baseline Benchmark Outcome Head(s) of households in <<category name>> prior to of activity (number). This number may be zero. Page 21 of 39 Expected head(s) of households in <<category name>> after implementati on of activity (number). Actual head(s) of households in <<category name>> after implementati on of activity (number). Benchmar k Achieved? Wher outcome meets or exceeds benchmar k.

23 Unemployed (6) Or Percentage of total work-able households in <<category name>> prior to of activity (percent). This number may be zero. Expected percentage of total workable households in <<category name>> after implementati on of activity (percent). Actual percentage of total workable households in <<category name>> after implementati on of activity (percent). Wher outcome meets or exceeds benchmar k. SS #7: Increase in Agency Rental Revenue Unit of Measurement PHA rental revenue in dollars (increase). Baseline Benchmark Outcome PHA rental revenue prior to of activity (in dollars). Expected PHA rental revenue after implementati on of activity (in dollars). Actual PHA rental revenue after implementati on of activity (in dollars). Benchmar k Achieved? Wher outcome meets or exceeds benchmar k. Activity 8: Streamline Recertification Process for HCV Program Description: OHA proposes to conduct biennial recertifications for all HCV participants. OHA currently conducts triennial recertifications of HCV elderly and disabled participants (se triennial recertifications were originally in Activity 2). OHA also proposes to streamline recertification process by eliminating interims, except for hardships and changes in family composition for all HCV participants. Due to extended recertification period, OHA proposes to create a local form 9886, Authorization for Release of Information. The local form will capture same information as HUD form 9886 except that HCV participant s consent for release of information will be extended from 15 months to 36 months as needed to update participant s data between each biennial recertification. Please note that extension will be 36 months instead of 24 months so that same form can be used for Activity 2, which requires 36 months. Achievement of Statutory Objectives: Biennial recertifications for HCV Program and elimination of interims except for hardships and changes in family composition for all HCV program participants will achieve statutory objective to reduce cost and achieve greater cost Page 22 of 39

24 effectiveness in Federal expenditures by reducing staff time spent on recertifications and interims. Anticipated Impacts: The anticipated impact of this activity on statutory objective to reduce cost and achieve greater cost effectiveness in Federal expenditures is a reduction in staff time spent on recertifications and interims. A reduction in staff time spent on recertifications and interims will allow OHA to more efficiently use its funding for benefit of its program participants. An additional anticipated impact of this activity on statutory objective is to eliminate burden of conducting all recertifications every three years due to current triennial recertification of elderly and disabled participants and annual recertification of non-elderly and non-disabled participants. By implementing biennial recertifications, HCV proposes a more balanced approach to recertification process removing current pattern of two years with a lesser amount of recertifications (e.g., 2012 and 2013) and third year with a large number of recertifications (e.g., 2014). Due to budget cuts in HCV program, this impact is critical, for OHA. Implementing this activity could reduce amount of staff needed to accommodate current triennial recertification. An anticipated by-product of this activity is self sufficiency in that participants will not have to report income for two years. This means that any increased income does not have to be reported until next biennial exam which will ideally increase participants financial freedom and self sufficiency. Anor anticipated impact is possibility of not capturing as much income from non-elderly and non-disabled households due to change from annual to biennial recertifications. This anticipated impact could result in loss of rental income to OHA. However, OHA does not expect loss of rental income to outweigh savings in staff time and associated costs. Once OHA has finalized of new Standard HUD Metrics, OHA may develop additional anticipated impacts. Anticipated Schedules for Achieving Objective(s): OHA will split HCV population in half. Half of recertifications will be conducted 2014 and or half will be conducted in Participants admitted to HCV program in even years will be recertified in even years and participants admitted to HCV program in odd years will be recertified in odd years. OHA s anticipated schedule to implement elimination of interims except for hardships and changes in family composition for all HCV program participants is Plan Year 4. OHA plans to have all HCV participants sign local form in Authorization(s): Section D.1.c. of Attachment C of MTW Agreement, as it relates to Section 8, authorizes agency to define, adopt and implement a reexamination program that differs from reexamination program currently mandated in 1937 Act and its implementing regulations. Need for Authorization: In order to engage in this activity above cited authorization is needed to waive PHA responsibility to conduct a re-examination of family income and composition at least annually. The authorization D.1.c. from Attachment C gives OHA Page 23 of 39

25 flexibility to conduct proposed biennial recertifications and create a local form 9886 in effect for longer than 15 months. Additional Information for Rent Reform Activities: Impact Analysis 1. Description of rent reform activity: OHA proposes to conduct biennial recertifications for all HCV participants. OHA currently conducts triennial recertifications of HCV elderly and disabled participants (se triennial recertifications were originally in Activity 2). OHA also proposes to streamline recertification process by eliminating interims except for hardships and changes in family composition for all HCV participants. 5. Tracking and documenting of rent reform activity: OHA will establish a schedule for recertification of Section 8 households for every two years beginning in MTW Plan Year 4. OHA will track and document biennial recertification of Section 8 households as outlined in applicable metrics. OHA will track and document of elimination of interims by establishing a baseline and following applicable metrics beginning in MTW Year Identifying intended and possible unintended impacts of rent reform activity: The anticipated impact of this activity on statutory objective to reduce cost and achieve greater cost effectiveness in Federal expenditures is a reduction in staff time spent on recertifications and interims. A reduction in staff time spent on recertifications and interims will allow OHA to more efficiently use its funding for benefit of its program participants. An additional anticipated impact of this activity on statutory objective is to eliminate burden of conducting all recertifications every three years due to current triennial recertification of elderly and disabled participants and annual recertification of nonelderly and non-disabled participants. By implementing biennial recertifications, HCV proposes a more balanced approach to recertification process removing current pattern of two years with a lesser amount of recertifications (e.g., 2012 and 2013) and third year with a large number of recertifications (e.g., 2014). Due to budget cuts, this impact is critical, particularly for OHA HCV program. Implementing this activity could reduce amount of additional staff needed to accommodate current triennial recertification. An anticipated by-product of this activity is self sufficiency in that participants will not have to report income for two years. This means that any increased income does not have to be reported until next biennial exam which will ideally increase participants financial freedom and self sufficiency. Anor anticipated impact is possibility of not capturing as much income from nonelderly and non-disabled households due to change from annual to biennial recertifications. This anticipated impact could result in loss of rental income to OHA. However, OHA does not expect loss of rental income to outweigh savings in staff time and associated costs. OHA does not anticipate unintended impacts. Page 24 of 39

26 5. Measuring impacts of rent reform activity OHA will measure impacts of this activity by analyzing data collected from metrics. Hardship Case Criteria OHA will establish a hardship panel to evaluate individual circumstances in case of hardship exemption requests. Qualifying hardships will include loss of income due to circumstances beyond household s ability to control, including following: (1) temporary medical condition that prevents an adult family member from working when loss of employment is not covered by paid medical benefits, (2) loss of employment due to reduction in workforce or closure of place of employment where employment income loss is not covered by severance or separation benefits and (3) an increase in medical expenses such that se expenses exceed 15% of gross income. Description of Annual Reevaluation of Rent Reform Activity OHA will analyze data collected in applicable metrics to determine wher objective(s) are achieved and wher revision is necessary to mitigate negative impacts of unintended consequences. Transition Period OHA will provide participants with written notice of biennial recertification process. The participants receipt and acknowledgement of notice will be recorded. OHA will provide participants with written notice of elimination of interims. The participants receipt and acknowledgement of notice will be recorded. Cost Effectiveness CE #1: Agency Cost Savings Unit of Measurement Total cost of task in dollars (decrease). Baseline Benchmark Outcome Cost of task prior to of activity (in dollars). Expected cost of task after of activity (in dollars). Actual cost of task after of activity (in dollars). Benchmark Achieved? Wher outcome meets or exceeds benchmark. Page 25 of 39

27 Unit of Measurement Total time to complete task in staff hours (decrease). CE #2: Staff Time Savings Baseline Benchmark Outcome Total amount of staff time dedicated to task prior to of activity (in hours). Expected amount of total staff time dedicated to task after of activity (in hours). Actual amount of total staff time dedicated to task after of activity (in hours). Benchmark Achieved? Wher outcome meets or exceeds benchmark. IV. Approved MTW Activities: HUD approval previously granted A. Implemented Activities Activity 1: $225 Rent Floor for Non-Elderly and Non-Disabled Households Approval & Implementation Year: Activity 1 was first approved in Plan Year 1. The phased in implemented began in Initial Demonstration Period. Description: Phase in of a self-sufficiency rent floor of $225 for households that are not elderly and not disabled. The of rent floor includes a referral to MTW Resource Center for non-elderly and non-disabled households not paying $225 at time rent floor is implemented. The of $225 rent floor provides hardship exceptions linked to self sufficiency activities. The MTW Resource Center provides self sufficiency services including but not limited to case management, needs assessments, employability counseling, and job referral/placement assistance services for a maximum of two years for each adult referred to MTW Resource Center. Use of a computer lab, transportation (bus passes) and child care assistance is provided to help participants secure and maintain employment. OHA monitors progress of households subject to rent floor relative to accomplishing goals identified in ir self sufficiency plan. Status: Implemented and ongoing. Anticipated Modifications: Implementing HCV program to Activity 1 would likely double population served by MTW Resource Center. OHA wants to make sure it is prepared to handle increase especially considering sequestration and reduced staff. Consequently, OHA plans to delay expansion of $225 rent floor to HCV program until MTW Year 5. Changes to metrics, baselines or benchmarks during Plan Year: The metrics will change as Standard HUD Metrics will be implemented as a tracking mechanism for activities. The agency-developed metrics called number of working adults and heads of households appears to match one of Standard HUD Metrics ( average earned income of households affected by this policy in dollars (increase) ) so that particular metric will likely contain data from initial of this activity. Page 26 of 39

28 OHA will discontinue tracking/reporting on following agency-developed metrics and instead implement applicable Standard HUD Metrics: (1) amount of income and earnings, (2) number of staff minutes spent on recertification and (3) average earnings of families with nonelderly, non-disabled adults initially covered by rent floor. The following two agency-developed metrics were not tracked: (1) voluntary loss of employment and (2) number of undeclared occupants who sign leases. They will continue to not be tracked. Authorization(s): OHA does not require any different authorizations from Attachment C or D. Significant Change Requiring Re-Proposal: No significant change has occurred to require reproposal. Cost Effectiveness CE #5: Increase in Agency Rental Revenue Unit of Measurement Rental revenue in dollars (increase). Baseline Benchmark Outcome Rental revenue prior to of activity (in dollars). Expected rental revenue after of activity (in dollars). Actual rental revenue after of activity (in dollars). Benchmark Achieved? Wher outcome meets or exceeds benchmark. Self Sufficiency When citing statutory objective to give incentives to families whose heads of household are eir working, seeking work, or are participating in job training educational or or programs to assist in obtaining employment and becoming economically selfsufficient, include all of following metrics that apply: SS #1: Increase in Household Income Unit of Measurement Baseline Benchmark Outcome Benchmark Achieved? Page 27 of 39