VASH Program in Indian Country: What We Know Now NAIHC Annual Convention May 10, 2016

HUD VASH and Tribal VASH HUD-VA Supportive Housing (HUD-VASH) program, was initially authorized by the Consolidated Appropriations Act, 2008. Native American veterans in tribal communities were prevented from utilizing the VASH program due to perceived legal impediments that would not allow tribes and TDHEs from participating in the HUD-VASH program. As part of the 2015 Appropriations Act, Congress authorized funding for a demonstration program in order to expand the HUD-VASH program into Indian Country. 30 Tribes were invited to qualify for the initial Tribal-VASH (THVASH) program. 26 Tribes have been granted Tribal VASH Vouchers. Housing Relationships Built to Last

Tribal VASH Tribes/TDHEs participating THVASH program must house Native American Veterans either on or near reservations, or within NAHASDA-authorized Indian areas. Housing assistance provided by the THVASH program may not be provided to Native American Veterans who will be residing in a housing unit that qualifies as Formula Current Assisted Stock (FCAS) under the IHBG program. NAHASDA units, LIHTC new construction units, units owned by Tribally enrolled members or units built with other financing sources can utilize the TVASH vouchers. Housing Relationships Built to Last

Tribal VASH IHP/APR Requirements Grantees must have an approved IHP Amendment Must report THVASH activity on APR Report on veterans served Should tie with data from 50058 Report THVASH funds are drawn down using the LOCCS system, budget line item 1640 – Rental Assistance Payments Quarterly the Form SF-425 is used to track Program income and Expenditures. 50058 Reporting Tool is being developed by HUD – not finalized. Data collected will include: Household composition Unit address, number of bedrooms, and type Tenant’s expected monthly rent contribution Housing Relationships Built to Last

THVASH – Voucher Types Project-Based Rental Assistance (PBRA): This type of rental housing assistance is tied to a specific housing unit or units in a project developed for a specific population. The housing assistance stays with the unit or units and any household living in the unit must meet program requirements. If the household moves out of the subsidized unit, the household no longer receives rental housing assistance. Tenant-Based Rental Assistance (TBRA): This type of rental housing assistance is not tied to a specific unit or development, but can be used in any qualifying open-market unit. The eligible applicant selects and rents a unit (whether private or TDHE-owned) that meets program requirements, and the tribe or TDHE makes rent subsidy payments on behalf of the household. The assistance stays with the household; if the household moves to a different unit that meets program qualifications, the tribe or TDHE makes rental payments to the owner of the new unit on the household’s behalf. Housing Relationships Built to Last

THVASH – Voucher Types Tribes that elected to utilize the PBRA voucher type may want to amend their original implementation plan to include or change their voucher type to the TBRA voucher based on updated information provided by HUD/VA since the original implementation plans were submitted. Depending on the Indian Housing or Indian Service area defined in their IHP’s a tenant based voucher can be limited to the defined service area. This would allow the tenant based voucher to be primarily used for housing within the Tribe’s designated housing service area as opposed to an enlarged area that may include housing that is eligible for traditional VASH vouchers. This would also eliminate the need for the environmental review and 15 year binding commitment required for PBRA vouchers Housing Relationships Built to Last

THVASH – Eligibility The Tribe/TDHE must accept all VA referrals of Native American Veterans and their families for THVASH vouchers. Tribe/TDHE can only deny housing based on the following: Household is over income at the time of initial application Household does not meet the NAHASDA definition of “Indian” Household does not meet the Tribe/TDHE’s tribal preference policy Household member is found on the Tier III sex offender registry Housing Relationships Built to Last

THVASH – Eligibility A referral from the VA cannot be denied for any of the following reasons: A felony other than the Tier III sex offender Insobriety Drug Addiction Amounts due to the Tribe/TDHE Violations of other Tribe/TDHE policies Housing Relationships Built to Last

THVASH Funds There are two types of financial assistance that will be received by the Tribe/TDHE Administering the voucher: Rental Assistance Payment (RAP) – the difference between the tenant paid portion of the rent (30% of adjusted household income) and the Fair Market Rent for the unit. Administrative Fee: $85 per unit per month; $1,020 per unit/year NOTE: If the THVASH voucher is being paid to a private/non-tribal entity then the only funds the Tribe/TDHE will receive for that voucher is the $1,020 annual administrative fee. This fee will need to cover the costs of staffing which includes occupancy staff time to qualify the household at move-in and complete all interim and annual recertifications. The fee will also need to cover the costs for inspecting the unit on at least an annual basis. Housing Relationships Built to Last

THVASH Funds THVASH funds can not be used to pay for travel costs related to THVASH training. NAHASDA allows this kind of support under Section 202. ELIGIBLE AFFORDABLE HOUSING ACTIVITIES (3) Housing Services - Homeless prevention activities VASH income can only be used for VASH activities – but IHBG funds can be used to provide utility assistance. The VASH program is separate from NAHASDA but its use must be reported via NAHASDA reports such as APR and SF-425. Housing Relationships Built to Last

THVASH – Policy Considerations Tribal consultation needs to occur with HUD/VA when discussing future policies for the THVASH program. This consultation should include: The use of THVASH vouchers for CAS units THVASH funding should be included as part of the regular VASH program and not tied to NAHASDA Policy requiring that, when possible, VA Case Managers should be tribally enrolled members to ensure that Tribal Veterans have someone who is familiar with their culture, families and living areas. Area Median Income – revision needed to include US Median Income whichever is higher. Housing Relationships Built to Last

THVASH – Policy Considerations (cont’d) The formula utilized by HUD/VA to award THVASH must be developed by tribal consultation and the use of known data. THVASH must be converted from a “demonstration” program and funding should be included as part of the VASH program. VA regions need further education as to when a Native American Veterans can access regular VASH vouchers. Confusion regarding use in “Indian Areas” and the requirement to income qualify below the 30% area median income limit have improperly limited Native American Veterans use of the original VASH program. Housing Relationships Built to Last

Resources Federal Register Notice 80 FR 63822 https://www.federalregister.gov/articles/2015/10/21/2015-26748/implementation-of-the-tribal-hud-va-supportive-housing-program VA Homeless Programs: http://www.va.gov/homeless/ HUD’s Office of Native American Programs: http://portal.hud.gov/hudportal/HUD?src=/program_offices/public_indian_housing/ih/tribalhudvash Resources: http://www.va.gov/homeless/resources.asp Fair Market Rents: https://www.huduser.gov/portal/datasets/fmr.html Housing Relationships Built to Last

Resources VA HUD-VASH Resource Guide: http://www.va.gov./homeless/hud-vash.asp VA Office of Tribal Government Relations (OTGR) Phone: 202-461-7400 Email: tribalgovernmentconsultation@va.gov Website: www.va.gov/TRIBALGOVERNMENT/contact.asp Department of Veterans Affairs Central Office 90 K Street NE, 786L  (10NC1) Washington, D.C. 20002 202-632-8597 Teresa S. Pittman LCSW HUD-VASH Region 1 Coordinator (VISNs 1-5, 9 and 23) Teresa.Pittman@va.gov Housing Relationships Built to Last

Questions? RTHawk Housing Alliance LLC Robin Thorne Senior Asset Manager robin@rthawkhousing.com 727-808-4066 Housing Relationships Built to Last