Creating Supportive Housing: Tools for PHAs - HomeBase

Creating Supportive Housing: Tools for PHAs Creating Supportive Housing: Tools for PHAs

THE REGIONAL STEERING COMMITTEE ON HOMELESSNESS & HOUSING

August 1, 2013

August 1, 2013

INTRODUCTION Public Housing Authorities (PHAs) are a crucial part of the housing spectrum, administering many key housing opportunities for individuals and families experiencing homelessness, including the Public Housing and Housing Choice Voucher (HCV) programs. Nationally, nearly 1.2 million people are housed in Public Housing and there are over 2.3 million HCVs. Waiting lists are extremely long and often closed to new names, with households waiting an average of almost 13 months for Public Housing, and over 25 months for HCVs.1 However, homeless persons are only a small percentage of the overall population that PHAs serve, and thus face challenges in accessing resources in a system that is likely not designed to best serve them. In addition, because PHA funding is not reliant on CoC participation, PHAs are often disconnected from CoC activities. Recently, HUD Secretary Shaun Donovan sent a public letter2 to PHA Executive Directors across the country encouraging them to reach out to CoCs and other homeless service providers to increase progress towards ending homelessness. This memo provides CoCs and PHAs with the resources necessary to respond to Secretary Donovan’s call for partnership and improve services provided to individuals and families experiencing homelessness by reviewing two key resources: •

CSH’s Public Housing Authority Toolkit3, which highlights tools and program models for successful PHAs and best practices for coordinating with service providers, and

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June 10th Notice released by HUD’s Office of Public and Indian Housing (PIH)4, providing guidance on housing individuals and families experiencing homelessness through the Public Housing and Housing Choice Voucher programs

CSH PUBLIC HOUSING AUTHORITY TOOLKIT STRATEGIES TO IMPROVE ACCESS TO HOUSING OPPORTUNITIES

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HUD. Picture of Subsidized Households. 2012 U.S. Total. Available at: http://www.huduser.org/portal/datasets/picture/yearlydata.html. HUD. Letter from Secretary Shaun Donovan and Assistant Secretary for Public and Indian Housing Sandra B. Henriquez. Available at: https://www. onecpd.info/onecpd/assets/File/HUD-Secretary-Letter-to-PHA-Executive-Directors.pdf. CSH. Public Housing Authority Toolkit. Available at: http://www.csh.org/phatoolkit. HUD PIH. Notice PIH 2013-15 (HA). “Guidance on housing individuals and families experiencing homelessness through the Public Housing and Housing Choice Voucher programs.” June 10, 2013. Available at: http://portal.hud.gov/hudportal/documents/huddoc?id=pih2013-15.pdf.

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August 1, 2013

The Regional Steering Committee on Homelessness & Housing

Persons who are homeless experience many barriers to accessing Public Housing and HCVs, including navigating a complex system, staying informed about waitlists, having the right documentation, keeping appointments, and, in some cases, having a criminal record. The CSH Toolkit identifies the following strategies that PHAs can implement to reduce the barriers that homeless individuals and families face in accessing housing opportunities: •

Establish Preferences for persons who have been homeless or have special needs, either through a preference for certain populations5, or a preference for households referred by service providers; requires a change to the PHA’s Administrative Plan

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Reduce Screening Criteria by reviewing policies in place and comparing them to the statutory and regulatory provisions required by HUD

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Provide Space for Service Providers on-site at PHAs to expedite work and promote partnership

In addition, service providers can support PHAs through the following strategies: •

Make Referrals to PHA Waitlists to ensure that resources are reaching persons who are homeless and/or have special needs, and to provide support and information during the application process

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Provide Assistance with Applications and Briefings by receiving training from PHAs about how to assist applicants in collecting supporting documentation and submitting complete applications

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Provide Supportive Services for Participants to ensure housing stability and maximize each tenant’s ability to live independently; services may include case management, mental health services, financial management, employment, and senior services

To promote partnerships between PHAs and service providers, CSH recommends that PHAs use a formal Request for Qualifications to solicit partners, coupled with allocating resources in collaboration with other funders of supportive services, and signing a partnership agreement such as an MOU. Sample tools and case studies from successful PHAs are available via CSH’s Toolkit.

HOUSING CHOICE VOUCHER Section 8 Housing Choice Vouchers (HCVs) assist low-income families, the elderly, and persons with disabilities to afford housing in the private market through subsidies administered by local PHAs. The PHA pays the subsidy directly to the landlord on behalf of the participant, who then pays the difference between the actual rent and the amount subsidized. In addition to the general recommendations described above, homeless service providers should work with 5

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According to the CSH Toolkit, examples of preferences for people who can benefit from supportive housing include those for people who are homeless; people who are working with service providers; people who have had difficulty with housing stability; families that are involved with the child welfare system; young adults; and people being discharged from institutions.

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Creating Supportive Housing: Tools for PHAs

August 1, 2013

their local PHAs to implement the following strategy to make HCVs work more effectively for homeless persons: •

Establish Flexible Intake and Briefing Schedules by offering “office hours” to reduce the burden of keeping appointments

In addition, service providers can support PHAs through the following strategies: •

Provide Housing Search Assistance and Services to Landlords by finding vacant units, providing transportation, and serving as a liaison to landlords

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Learn Housing Quality Standards (HQS) and Conduct Pre-Inspections to ensure that apartments are likely to pass the formal HQS inspections by the PHA

PUBLIC HOUSING Public housing comes in many shapes and sizes, from scattered site single-family houses to high-rise apartments, serving low-income families, the elderly, and persons with disabilities. Homeless service providers and PHAs can work together to overcome barriers by improving access to public housing for homeless households and creating an eviction prevention program. Specifically, homeless service providers should encourage PHAs to adopt the following strategies for public housing: •

Incorporate the Input of Service Providers in Application Denial Appeals to take into account mitigating factors in a person’s life that show they are getting back on track despite patterns of substance abuse or criminal histories

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Refer Tenants to Service Partners to Prevent Evictions6 by establishing an early “alarm and response” system to quickly address problems that can lead to eviction

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Create Opportunities for Resident Participation to create a positive living environment and foster housing stability; for example, by promoting resident councils

In addition, service providers can support PHAs through the following strategy for public housing: •

Provide Community Building Activities and Afterschool Programs to help PHAs and service staff to get to know clients, provide a sense of community, and address challenges before they become a threat to housing stability

PROJECT-BASED VOUCHER TOOLS To address the need for more affordable housing options, federal initiatives such as HOME, CDBG and the Low Income Housing Tax Credit program provide capital dollars to acquire, rehabilitate and construct new affordable housing. Capital subsidies allow developers to reduce the amount of debt they need to borrow in order to acquire or build new housing, which enables them to keep rents low for families with low incomes.

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This strategy can also be used with HCVs through partnership with service providers and outreach to landlords.

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While Housing Choice Vouchers are able to make rent affordable for specific individuals and families, shifting some vouchers from tenant- to project-based may have a positive impact on capital financing. PHAs may use up to 20% of their HUD budget allocation as project-based vouchers attached to specific buildings, which promotes the need for more affordable housing by providing the assurances that developers and funders need to encourage the creation of affordable housing for extremely low-income families and individuals. In addition, when most or all of the units in a building are assisted through project-based vouchers, service providers have economies of scale in their service delivery. To begin using project-based vouchers, the PHA will need to adopt changes to its administrative plan. The CSH Toolkit provides details about how to solicit and select proposals through a Request for Proposals (RFP) or another qualified competitive process. The Toolkit also explains the Agreement to enter into a Housing Assistance Payments contract (AHAP), different options for setting up programs and waitlists, the family right to move, and the 25% cap on project-based units in a building. The Toolkit also provides sample tools, such as a sample program fact sheet, and case studies from PHAs that are successfully using project-based vouchers.

UNIQUE PHA PROGRAMS & INITIATIVES The CSH Toolkit also addresses a number of other PHA programs and initiatives that allow PHAs to move beyond their traditional role to create supportive housing and address homelessness in their communities. For each of the following programs and initiatives, the CSH Toolkit provides case studies from successful PHAs using these practices across the country.

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Housing Development includes the acquisition and rehabilitation of existing housing, as well as building new housing. Such work requires clarity around the roles of developer, owner, property manager and service provider, with the PHA either taking on all four roles, or else partnering for some roles. The benefits of engaging directly in housing development include improving long-term affordability of housing; diversifying the PHA’s portfolio; taking a developer fee on new projects; and more prominently position the PHA and its partners as local leaders in affordable housing.

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Sponsor-based Subsidies are based on the Shelter Plus Care program under McKinneyVento. The project sponsor (typically a nonprofit human services or housing provider) receives funding directly from the PHA, and uses the funding to lease units from private landlords. Moving to Work7 status is required to sponsor-base Housing Choice Vouchers. The sponsor-based subsidies allow providers to affirmatively “screen-in” homeless households who would likely face barriers in using a HCV due to landlord screening criteria. Providers are able to integrate rental assistance with supportive services to promote housing stabilization.

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Coordinated Funding can benefit PHAs and their funding partners by supporting PHA resources with those of other housing and service funders, ensuring that projects are fully funded and ready to start upon award, and reducing the amount of time providers spend pursuing funding. Partnerships range from pairing funds with one service funder to developing regional funding collaboratives.

Moving to Work (MTW) is a demonstration program that gives PHAs exemptions from many existing public housing and voucher rules and more flexibility with how they use their Federal funds, in order to inform HUD about ways to better address local community needs.

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“Moving-On” Initiatives are an innovative way for PHAs to encourage tenants who no longer require supportive services, but who still require subsidized housing, to “move on” and free up apartments for those waiting for supportive housing. PHAs can accomplish this through preferences in HCV and public housing programs, as well as through project-based developments for persons leaving supportive housing.

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Partnering with Schools is a way for PHAs to ensure that families in supportive housing are exercising their right to attend the school of their choice. The PHA can work with schools and the school district’s Homeless Liaison to identify and refer families in need.

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Partnering with Health Centers allows PHAs to connect tenants to health care services. For example, the Public Housing Primary Care Program (PHPC) provides grants to Community Health Centers (CHCs) to deliver comprehensive, case-managed primary care and preventive health care services, including behavioral health, to residents of public and assisted housing. PHAs can also partner with homeless service providers, Healthcare for the Homeless, Federally Qualified Health Centers (FQHCs), and community organizations.

DISCUSSION QUESTIONS What barriers do your clients experience in accessing PHA resources such as Housing Choice Vouchers, public housing, project-based vouchers, and/or other initiatives? How have you partnered with your PHA to promote access to housing opportunities? What challenges are you facing in coordinating with your PHA?

PUBLIC AND INDIAN HOUSING NOTICE The Office of Public and Indian Housing (PIH) under HUD issued a Notice on June 10th, 2013, to provide “guidance on housing individuals and families experiencing homelessness through the Public Housing and Housing Choice Voucher programs.” The notice covers the following topics.

CLARIFICATION OF THE DEFINITION OF HOMELESSNESS PIH has adopted portions of the HEARTH definition of homelessness for the purposes of PHAs reporting on the homelessness of new admissions. Specifically, the PIH definition recognizes Category 1 (lacking a fixed, regular, and adequate nighttime residence) and Category 4 (fleeing domestic violence, dating violence, sexual assault, stalking, or other dangerous or life-threatening conditions). PHAs are permitted to adopt an alternative or narrower definition of homelessness for the purpose of a waiting list preference based on local need. HUD does not require PHAs to collect documentation or third-party verification to verify an applicant’s housing status; verbal self-verification is sufficient to verify homeless status.

WAITING LIST MANAGEMENT AND PREFERENCES

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To allow homeless populations better access to Public Housing and HCV programs, the Notice recommends that PHAs take the following actions: • • • •

Establish a strong outreach strategy through service providers Strengthen process for contacting applicants on their waiting list Establish flexible intake and briefing schedules Establish nondiscriminatory preferences in their admissions policies for persons experiencing homelessness, or a subset of such persons (e.g., chronically homeless, homeless veterans, homeless identified as vulnerable through community-based assessment strategies)

The Notice highlights establishing a preference for individuals and families experiencing homelessness as a PHA’s greatest tool for increasing program access, and describes the following criteria that may be considered, as well as the process for establishing preferences. • • • • • • • •

Assessing local housing needs Applying and limiting preferences Opening waiting lists and public notice Identifying preference-qualified applicants currently on the waiting list Limiting preferences to people referred by a partnering organization Verifying preference eligibility Ensuring Fair Housing compliance Residency preference

ADMISSIONS POLICIES REGARDING CRIMINAL ACTIVITY, SUBSTANCE USE/ABUSE, AND RENTAL HISTORY The Notice provides a complete list of statutorily mandated prohibitions of admissions regarding criminal activity and substance use/abuse: • • • •

Lifetime sex offender registrant Methamphetamine production in federally assisted housing Within 3 years of eviction from federally assisted housing for drug-related crime Currently engaged in illegal drug use or threatening activity

Many PHAs have discretionary admissions policies that go beyond these statutorily mandated prohibitions, which can be a barrier for vulnerable populations, including individuals and families experiencing homelessness. Accordingly, Secretary Donovan has encouraged PHAs to adopt more flexible, reasonable admissions policies for people re-entering communities following incarceration. PHAs are encouraged establish strong partnerships with homeless service providers to ensure that admitted vulnerable persons are connected to services to remain stably housed.

PROGRAM TERMINATION AND EVICTION POLICIES The Notice encourages PHAs to work with homeless service providers to establish discretionary termination and eviction policies best suited to the community and to develop partnerships that can implement effective

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eviction prevention strategies. In addition, the Notice highlights that victims of domestic violence are protected under 24 CFR 5.2005(c) from being evicted due to the lease violations of their abusers. PHAs are also encouraged to partner with healthcare, supportive services, and homeless service providers to connect individuals and families in programs to services. The Notice clarifies that while PHAs cannot establish separate admissions or termination polices for a certain population (such as homeless) without express legal authority8, the regulations do “imply that individual consideration of factors should be a basis for a PHA’s decision to deny or terminate assistance.”

PROJECT-BASING VOUCHERS FOR PERMANENT SUPPORTIVE HOUSING The Notice highlights the benefits of project-based vouchers (PBVs), including that guaranteed rental income provided by the vouchers helps to finance project operating costs and secure capital investments. Under the HCV program, PHAs are allowed to project-base up to 20 percent of their budget authority. Normally, no more than 25 percent of the number of units can be under PBVs in a project, but a PHA may exceed this cap when making units specifically available to the elderly or families with disabilities, or families receiving supportive services.

DISCUSSION QUESTIONS Have your local PHAs established preferences for individuals and families experiencing homelessness? How do the preferences work? How can the discretionary PHA program admissions, termination, and eviction policies in your community be changed to better serve vulnerable populations?

ADDITIONAL RESOURCES NAEH 2013 CONFERENCE, SESSION 4.9: PUBLIC HOUSING AUTHORITIES AND CHRONIC HOMELESSNESS INITIATIVES www.endhomelessness.org/library/entry/4.9-public-housing-authorities-and-chronic-homelessness-initiatives Public Housing Authorities can serve as key partners in the creation of permanent supportive housing for individuals experiencing chronic homelessness. In this workshop, presenters will describe successful partnerships between homeless service providers and public housing agencies that have led to progress in ending chronic homelessness. • Angelina Nguyen, Fresno Housing Authority, Fresno, CA • Jessica Preheim, Houston Housing Authority, Houston, TX 8

For example, PHAs may have specific admission/termination policies for veterans under HUD-VASH.

THE REGIONAL STEERING COMMITTEE ON HOMELESSNESS & HOUSING

August 1, 2013

For more information please contact Amanda Stempson, Staff Lawyer, at Amanda@ homebaseccc.org, or 415.788.7961 ext. 308.

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