To: Board of Supervisors of Sonoma County and Board of Commissioners of the Community Development Commission
Department or Agency Name(s): Community Development Commission
Staff Name and Phone Number: Martha Cheever, 565-7521
Vote Requirement: Majority
Supervisorial District(s): Countywide
Title:
Title
Housing Authority Administration Plan Update
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Recommended Action:
Recommended action
Approve changes to the Sonoma County Housing Authority Administrative Plan
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Executive Summary:
In order to allow Housing Authorities throughout the country flexibility to adapt to shelter-in-place orders and other challenges related to the COVID-19 pandemic, the Department of Housing and Urban Development (HUD) issued Public and Indian Housing (PIH) Notice 2020-05. This Notice authorized Housing Authorities to adopt changes to their Administrative Plans without formal governing board approval. Under this HUD guidance and authority, the Housing Authority informally adopted several changes to its Administrative Plan. The changes made have allowed the Housing Authority flexibility to conduct certain recertification examinations on a biennial basis and eliminated the requirement for in-person appointments.
Per HUD requirements, the Board of Commissioners must formally adopt all changes made to the Administrative Plan in response to the Covid-19 pandemic prior to December 31, 2020.
Discussion:
The Sonoma County Housing Authority (Housing Authority) administers the Housing Choice Voucher and the Mainstream Voucher Program under contract with the U.S. Department of Housing and Urban Development (HUD). Vouchers are the federal government’s primary method for helping low-income families, the elderly, and the disabled rent housing from private property owners.
Federal regulation 24 CFR § 982.54 requires all Housing Authorities to adopt a written Administrative Plan to ensure that local programs operate within HUD’s requirements. The Administrative Plan dictates the program’s waitlist management, preferences, and other local needs-based policies. If a Housing Authority proposes substantive changes to its Administrative Plan, public engagement and a public hearing are required to solicit feedback on the changes.
In order to allow Housing Authorities flexibility to adapt to shelter-in-place orders and other challenges related to the COVID-19 pandemic, the HUD issued Public and Indian Housing (PIH) Notice 2020-05. This Notice authorized Housing Authorities to adopt changes to the Administrative Plan without formal Board approval. Under that authority, the Housing Authority informally adopted several technical changes to its Administrative Plan. The changes allowed the Housing Authority flexibility to maintain operations while complying regulatory requirements. In addition to technical changes, the changes allowed the Housing Authority to conduct certain recertification exams on a biennial basis and eliminated the requirement for in-person appointments.
A full summary of the changes made to the Administrative Plan is included below.
A public hearing on the proposed changes was held before the Community Development Committee on November 18, 2020. The committee voted to recommend the proposed changes to the Board of Commissioners for formal approval. The Public comment received in response to the Public Hearing included as an attachment to this agenda item.
Summary of Proposed Changes to the Sonoma County Housing Authority Administrative Plan:
Chapter 7 - Verification Procedures
1. Changes documentation requirement for additional bedrooms to the time or recertification rather than annually. This change reduces administrative burden and eliminates additional burden for disabled clients. (Page 7-12).
2. Removes the word annually from statements about calculation of medical expenses. This change reduces administrative burden by only requiring medical expense documentation to be collected at time of recertification, which may be completed biennially in some cases (Page 7-13).
Chapter 12 - Recertifications
1. Updates policies to allow for biennial inspections (page 12-1).
2. Eliminates the requirement for in-person appointments (page 12-2).
3. Updates policies to allow for recertifications to be conducted through mail (pages 12-2 and 12-3).
4. Clarifies interim recertification policy when income increases or new income sources are added (page 12-4).
5. Updates policies for streamlined recertifications to indicate biennial recertification policies (page 12-6).
Prior Board Actions:
April 7, 2020: Board of Commissioners approved revisions to the Sonoma County Housing Authority Administrative Plan
June 4, 2019: Board of Commissioners approved substantial amendments to the Sonoma County Housing Authority Administrative Plan
Fiscal Summary
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FY 21-22 Projected |
FY 22-23 Projected |
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Narrative Explanation of Fiscal Impacts:
There are no fiscal impacts associated with this item.
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Narrative Explanation of Staffing Impacts (If Required):
N/A
Attachments:
Attachment 1 - Housing Authority Administration Plan Chapter 7 Redline
Attachment 2 - Housing Authority Administration Plan Chapter 12 Redline
Attachment 3 - Public Comment Received
Related Items “On File” with the Clerk of the Board:
None