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Rent Reform – Part 1
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Boulder Housing Partners Rent Reform
2017 MTW Conference
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Community Overview Boulder, Colorado Boulder Housing Partners
Population: 100,000 25 square miles Median income: $94,800 Average vacancy: 6.4% 2 bedroom FMR: $1,240 2 bedroom PS: $1,364 Boulder Housing Partners Vouchers: 1,144 MTW: 756 RAD: 135 NED: 181 Mainstream: 50 Housing First: 22 Units: 1,105 Public Housing: 49 Project Based Rental Contracts: 116 Tax Credit: 596 Affordable: 205 Market: 139
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Rent reform model – Flat tier rent
Family size + gross income = income tier Income tier + bedroom size = total tenant payment TTP – utility allowance + mixed eligible family member fee + amount gross rent > payment standard = tenant rent
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Annual income calculation
Current stable income moving forward Example, employed at ABC Co. making $10 an hour working 40 hours on average Annual income = $20,800 OR If seasonal or not employed, use past two-year history shown on EIV, the Work Number, W-2s, etc. Example, currently reporting zero income but EIV shows wage income for 6 of last 8 quarters, take average per 6 quarters and project that forward
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Frequency of recert Recertify every two years
No interim recerts for income increases (unless reported income is in tier 1) Interim recerts for income loss only in extenuating circumstances
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Why did we chose this rent reform?
Guiding Principles - Flat tiered rent based on bedroom size Incentivizes work Yes Simulates the market Simple and predictable for residents Serves the same population Simple to administer Rent has a relationship to income No major increases to rent burden Hardship policy: 7% cap No major cost increases to BHP
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Income chart Income Tier Family Size 1 2 3 4 5 6 7 8 9 10 $ - - 4,000
$ - 4,000 4,200 4,400 4,600 4,800 5,000 5,400 6,000 6,400 6,800 5,500 5,700 6,700 7,300 7,900 8,400 8,900 9,500 10,100 7,200 8,300 9,300 10,400 11,300 12,200 13,000 13,900 14,800 15,700 10,900 12,400 14,000 15,500 16,800 18,000 19,200 20,500 21,800 23,200 14,100 16,100 18,100 20,100 21,700 23,300 24,900 26,500 28,100 29,800 17,300 19,700 22,200 24,700 26,700 28,600 30,600 32,600 34,600 36,700 23,400 26,300 29,200 31,600 33,900 36,300 38,600 41,000 43,500 23,700 27,100 30,500 33,800 36,600 39,200 41,900 44,700 47,400 50,300 26,900 30,700 38,400 41,500 44,600 47,600 50,700 53,800 57,100 11 30,285 34,605 38,925 43,245 46,710 50,175 53,640 57,105 60,531 64,163 12 33,650 38,450 43,250 48,050 51,900 55,750 59,600 63,450 67,257 71,292 13 40,380 46,140 57,660 62,280 66,900 71,520 76,140 80,708 85,551 14 47,110 53,830 60,550 67,270 72,660 78,050 83,440 88,830 94,160 99,809 15 53,840 61,520 69,200 76,880 83,040 89,200 95,360 101,520 107,611 114,068
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HCV Flat Tier Rent Chart
2016 HCV Flat Tier Rent Chart Income Tier Bedrooms 1 2 3 4 5 6 $120 120 125 130 140 160 180 135 150 170 210 235 270 165 185 205 225 305 345 240 275 340 400 450 510 330 380 420 475 535 605 685 410 525 590 670 760 860 7 500 565 630 710 815 920 1,040 8 580 560 735 840 945 065 1200 9 660 765 865 960 1105 1245 1405 10 820 880 1125 1175 1260 1425 1605 11 1190 1445 1575 1785 12 970 1115 1250 1495 1630 1825 2070 13 1150 1315 1475 1995 2195 2310 14 1325 1510 1705 1895 2165 2490 2625 15 1500 1715 1930 2140 2830 2865
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Hardships Upon transition: After transition:
1. Maximum rent increase capped at 7% (if all other factors stay the same) 2. Minimum rent increase – grandfathered in for 12-months, given advance notice, then rent increased After transition: Elimination of interim decreases – Safety Net Referral Program
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Implementation challenges
Mass recerts every year – Voucher holders split into two groups (PBV vs. TBV) to spread the work Simple to administer – Yardi set up Re-training of staff Hardships Updating charts Plan ahead for how and when the charts will be updated
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2016 results Most surprising result: 26% increase in average income 32% average rent burden - rent reform decreases disincentive? - economic upturn? - others? - all of the above?
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2016 282 total families were recertified
26 reported zero income – but had income attributed to them based on past history Average income of these families - $20,000 27 families had income increases that put them at zero HAP 2 voluntarily gave up the voucher
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2016 No interim recertification: 50 requests for an interim
9 were approved and interim processed 41 were denied 17 referred to Safety Net Program 10 contacted the program and received assistance Total assistance paid $7,576
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Rent control study - Required as part of application to MTW Program
- Must create our own - Partnered with the University of Colorado - Boulder - Too small to have a control and treatment group in one population - Approved to do a Time 1 v. Time 2 study for work-able families - Two groups (Public Housing and Housing Choice Vouchers)
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Rent control study - Survey is part of biennial recert packet
- Tracks families in 10 domains of self-sufficiency: Housing Employment Income Food Transportation Child Care Support Networks Legal Matters Health Education Ratings are: 1 – Urgent situation, currently in crisis 2 – Vulnerable, need support to move forward 3 – Safe, family is making progress toward stability 4 – Stable, family is stable, safe and moving towards thriving 5 – Thriving, family is self-sufficient and thriving
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Rent control study - 2014 – gathered baseline data
second survey for PH Few changes were noted second survey for HCVP Some changes were noted Study will be longitudinal Results are being used to direct services to areas where needed
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Louisville Rent Reform Demonstration
2017 MTW Conference Louisville Rent Reform Demonstration
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Community Overview Louisville, Kentucky – MTW Vouchers 8,822
Population: 755,809 398 square miles Median income: $48,695 Rental vacancy: 7.2% 2 bedroom FMR: $793 MTW Vouchers 8,822 Other Vouchers (VASH,TPV) 404 Public Housing 4,453 Tax Credit Only 75 Market Rate 84 Affordable Homeownership* 83 Serve more than 13,000 families. Our rental market is not as tight as those of many other MTW PHAs, but it is tightening. *Management of affordable condominiums developed by LMHA subsidiary.
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What is the rent reform demonstration?
HUD-commissioned study to evaluate an alternative rent policy across multiple MTW agencies: Lexington Louisville San Antonio Washington, DC Study is being coordinated by MDRC (a non-profit & non-partisan education & social policy research organization) Randomized study with both a Control Group & an Alternative Rent Group Focuses on work-able families
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Objectives Create a stronger financial incentive for tenants to work and advance toward self-sufficiency Simply the administration of the HCV Program Reduce housing agency administrative burdens and costs Improve accuracy and compliance of Program administration Remain cost neutral or generate savings in HAP expenditures relative to expenditures under current rules Improve transparency of program requirements
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Target population Study focuses on work-able households
Excluded populations: FSS participants Families in HCV Homeownership Program Families receiving childcare allowance Families using “program-based” vouchers (typically serve vulnerable populations) Families receiving non-MTW vouchers (VASH, TPV) Families that would meet elderly definition within 6 years (during the course of the study) Disabled families Households with mixed immigration status
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Alternative Rent Group
Policy Changes Control Group Alternative Rent Group Calculating Income Expected income over next 12 months Deductions per regulation, except standard medical deduction & no EID. Assets ignored if total value < $5,000 Retrospective income over past 12 months Except, if current/anticipated income is less than retrospective income by >10%, a 6-month grace period will be granted before TTP is automatically increased. No deductions Assets ignored if total value <$25,000 TTP 30% of adjusted annual income No minimum rent 28% of gross annual income $50 minimum rent Maximum Initial Rent Burden 40% of adjusted annual income 40% of gross annual income Payment of Rent HH pays directly to owner: TTP less Utility allowance If this value is less than $50, HH pays $50 to owner, & LMHA reimburses HH balance of utility allowance Interims for loss of household member (in case of no voucher size change). If retrospective gross income decreases by at least 10%, then TTP is reset. Interims for change in HH composition or move to new unit do not count toward 1 interim per year limit. Utility allowances changed for: Change to contract rent TTP is recalculated Move to new unit Change to HH composition requiring change to voucher size
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Alternative Rent Group
Policy Changes Control Group Alternative Rent Group Utility Allowance 4 housing types 9 utility categories + Other Natural gas/bottle gas/electric/oil categories Adjusted at recertification Only 2 housing types: home/new mobile home & other Only 5 categories: heat, hot water, water/sewer, range/microwave, & refrigerator Source categories ignored for home/new mobile home & condensed to 2 categories for other housing type Adjusted only when HAP or TTP is recalculated for other reasons Recertifications Scheduled recertification annually Interim permitted for any decrease in income For all interims (regardless of cause), all income sources are re-verified Scheduled recertification every 3 years Interim for income decrease only if retrospective gross income decreases by >10%. Limited to 1 per year. For interim for HH composition change or move to new unit, income is reviewed/verified only if income decreases by >10% or voucher size changes. This type of interim does not count toward interim limit. Hardship Policy N/A (no minimum rent, so not necessary) TTP can be lowered or waived for up to 180 days. No limit on number of hardship waivers that can be requested during study period. Interims for loss of household member (in case of no voucher size change). If retrospective gross income decreases by at least 10%, then TTP is reset. Interims for change in HH composition or move to new unit do not count toward 1 interim per year limit. Utility allowances changed for: Change to contract rent TTP is recalculated Move to new unit Change to HH composition requiring change to voucher size
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Community Concerns & Response
Mandatory enrollment 30-day opt-out provision Individual family data will be shared with external researchers Families can elect to have their data shared only in the aggregate Working families would no longer receive childcare deduction Families receiving childcare deduction were removed from eligible population $100 minimum rent Lowered to $75 then to $50 (Can be eliminated by hardship waiver) Hardship policy: Hardship process may take too long in the case of a family that has been served a 7-day eviction notice or notice of utilities shut-off for non-payment Upon submission of notice to Housing Specialist, TTP is immediately waived. If family cannot produce waiver, LMHA will request from owner within 1 business day. If necessary, a manual check paying balance of HAP will be issued to owner. Input received from: Local university Faith community Local advocacy groups (housing & other social justice issues) Legal Aid Society
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Hardship Policy Hardship Waiver Criteria:
Hardship cannot be remedied through the one interim recertification allowed each year TTP exceeds 40% of current monthly gross income (discounting any amount over payment standard) Household faces risk of eviction for non-payment of rent or utility bills Other circumstances, as determined by LMHA Hardship Waiver Process (Non-Expedited) Family submits written request and related documentation to Housing Specialist Households claiming $0 income must provide detailed accounting of funds used to cover basic costs of living Housing Specialist approves or denies request If request is denied, tenant may request informal hearing through LMHA’s normal grievance policy Hardship Remedies TTP can be either lowered or waived for up to 180 days. There is no limitation on the number of hardship waivers a family may request.
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Demonstration Enrollment
Computer program randomly selected Control Group & Alternative Rent Group households from eligible population At time of regularly scheduled re-certification, families met with Housing Specialist to review Study parameters & had TTP calculated under both the control & alternate rent policies Households had 30 days to opt-out Final Enrollment (Completed December 2015) 1,037 Control Group Alternative Rent Group Opt-Outs
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Implementation challenges
Initial certifications required significant extra time Staff explained study, and tenant watched video produced by MDRC Staff calculated TTP under both traditional and alternative rules Tenant filled out baseline information form Consistent tracking of new data fields like “Employment Status” LMHA is responsible for tracking HUD standard metrics. Baselines, benchmarks, & outcomes may not align with MDRC-reported study results. MDRC is only tracking directional changes. LMHA must track numerical benchmarks & outcomes. MDRC is not reporting any results until the end of study year 2. LMHA has already reported metrics for FY 2016, roughly 6 months after study enrollment ended.
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existing HCV rent reform Activities
HCV Program Landlords can only increase Rent to Owner by 2% each year Elimination of standard earned income disregard; instead have permanent $7,500 earned income disregard for elderly families Deduction of childcare expenses before determining HCV Program eligibility Alternate year recertifications for elderly and disabled families Standard medical deduction ($1,600) Homeownership Program - Exception payment standard census tracts (120% of FMR) - Use of 2-BR payment standard for 1-BR eligible families Rent to Owner. The total monthly rent payable to the Owner under the Lease for the unit. Rent to Owner covers payment for any housing services, maintenance, and utilities that the Owner is required to provide and pay for. (24 CFR 982.4) Deduction of Childcare Expenses: Head, co-head, or spouse must have 12-month, uninterrupted work history. HO Exception Areas: CT’s where “Owner Occupied Median Value” is greater than 80% of the “Owner Occupied Median Value” for the MSA. Use most recent 5-year American Community Survey estimates. Median owner-occupied home price in Louisville MSA is $148,900 (2015 ACS). So in exception payment standard census tracts, the median home value is at least $119,120. Just increased in FY 2017; used to be at least 100% of median value.
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