1. Portability Updates to the Process and Regulatory Changes
Updates to Portability
11/8/2018
Portability Updates to the Process and Regulatory Changes
11/8/2018
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2. Updates to Portability
11/8/2018
Portability
Voucher may be used to lease unit anywhere an agency is operating HCV program
Allows movement from one jurisdiction to another
PHA that issues the voucher is the “initial PHA”
PHA the receives the voucher is the “receiving PHA”
11/8/2018
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3. Portability- continued
Updates to Portability
11/8/2018
Portability- continued
The term “portability” refers to the process of leasing a dwelling unit with tenant-based housing voucher assistance outside of the jurisdiction of the PHA that initially issues the family its voucher (the initial PHA).
11/8/2018
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4. Portability- here to stay in some fashion
One of the key features of the HCV program is the mobility of the assistance.
Regulations at 24 CFR § provide that HCV participants may choose a unit that meets program requirements anywhere in the United States, provided that a PHA administering the tenant-based program has jurisdiction over the area in which the unit is located.
11/8/2018
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5. Fair Housing Provisions
PHAs must administer their HCV program in compliance with all applicable fair housing and other civil rights requirements, including the authorities cited at 24 CFR § 5.105(a).
This includes, but is not limited to, the Fair Housing Act, Title VI of the Civil Rights Act, Section 504 of the Rehabilitation Act, titles II or III of the Americans with Disabilities Act, and HUD’s Equal Access Rule.
11/8/2018
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6. Fair Housing Provisions
Under the July 16, 2015 revision, the PHA’s certification that it will affirmatively further fair housing requires that it will
(1) take meaningful actions to further the goals identified in its AFH,
(2) that it will take no action that is materially inconsistent with its obligation to affirmatively further fair housing, and
(3) that it will address fair housing issues and contributing factors in its programs, in accordance with 24 CFR 903.7(o)(3).
11/8/2018
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7. Reasonable Accommodation
Notwithstanding any other provision of PIH , PHAs must consider requests for reasonable accommodations that are necessary for a qualified individual with a disability to benefit from the program (in accordance with the Fair Housing Act, Section 504 of the Rehabilitation Act, title II of the Americans with Disabilities Act and HUD’s implementing regulations at 24 CFR , 24 CFR 8.33, and 28 CFR ).
11/8/2018
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8. Example of Reasonable Accommodation
An individual with a disability can request a reasonable accommodation to any rules, policies, practices or services at any time. This may arise, for example, when a request to move is due to a disability of a family member.
This provision applies even if a family might otherwise be restricted from moving (e.g., under a “one move per year” policy or because of insufficient funding).
The reasonable accommodation determination is made on a case-by-case basis.
11/8/2018
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9. May need HUD Approval in Certain Cases
In cases where the limitation on portability is a discretionary policy of the PHA, the PHA must grant the accommodation unless doing so would impose an undue financial and administrative burden to the PHA.
In cases where the limitation on portability is compelled by regulation, the PHA must first assess whether the requested accommodation would impose an undue financial and administrative burden.
If this assessment confirms no undue burden, the PHA must request a waiver of the regulatory provision from HUD.
11/8/2018
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10. Requests for an Extension
With respect to voucher extensions of time, both receiving and initial PHAs should consider that individuals with disabilities and families that include a member with a disability may require additional time to locate a suitable unit.
Such households may also request an extension of time as a reasonable accommodation.
Reasonable accommodation requests could also be made in the following areas: requesting that specific receiving PHA policies are provided to the family under the explanation of how portability works, requesting additional details about a receiving PHA when selecting the receiving PHA, and requesting a larger unit size.
11/8/2018
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11. New Guidance on Portability
Updates to Portability
11/8/2018
New Guidance on Portability
PIH , , , , , and the latest is
Reinforced the deadlines for PHA reporting to each other, transmissions
Reinforced extensions
Changed program requirements on briefing information and opportunity areas
Requirements on late billings
Outlined procedures to transfer units
Penalties and enforcement
Authority to deny ports under limited circumstances
Portability allowed in the HCV Homeownership Program
11/8/2018
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12. D L Morgan & Associates Professional Development Seminar
Family Briefing
PHAs must explain the advantages of living in areas with low concentrations of low income families be provided to all families
PHAs must provide this explanation as part of the oral briefing and the information packet.
11/8/2018
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13. D L Morgan & Associates Professional Development Seminar
Family Briefing
PHAs must explain how portability works to all families.
PHAs must provide information on how portability may affect the family’s assistance through rescreening, changes in subsidy standards and payment standards, and any other elements of the portability process which may affect the family’s assistance.
11/8/2018
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14. D L Morgan & Associates Professional Development Seminar
Family Briefing
PHAs must provide a list of landlords known to the PHA who may be willing to lease a unit to the family or other resources (e.g., newspapers, organizations, online search tools) known to the PHA that may assist the family in locating a unit.
PHAs must ensure that the list of landlords or other resources covers areas outside of poverty or minority concentration.
11/8/2018
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15. D L Morgan & Associates Professional Development Seminar
Family Briefing
PHAs must provide materials (e.g. brochures) on how to select a unit and any additional information on selecting a unit that HUD provides.
PHAs must provide any HUD provided information on selecting a unit as part of the oral briefing and the information packet.
11/8/2018
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16. Mandatory Voucher Term Suspension
PHAs must suspend the term of the voucher.
Suspension starts when the family submits a request for tenancy approval and ends when the PHA notifies the family in writing whether the request has been approved or denied.
Must do tolling- revise the Admin Plan
11/8/2018
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17. Nonresident Applicants
The initial PHA approves the portability move during the 12-month period for a nonresident applicant family.
Initial makes that determination- no rescreening on the receiving for nonresident determination
11/8/2018
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18. Move with Continued Tenant-Based Assistance
24 CFR was redesignated as 24 CFR
The PHA may deny permission to move if the PHA does not have sufficient funding for continued assistance.
The PHA must provide written notification to the local HUD Office within 10 business days of determining it is necessary to deny moves to a higher- cost unit based on insufficient funding.
PHA policies on family moves must be consistent with civil rights laws and regulations.
11/8/2018
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19. Portability Administration- Requirement to Administer Assistance
A receiving PHA cannot refuse to assist incoming portable families or direct them to another neighboring PHA for assistance.
HUD may determine in certain instances that a PHA is not required to accept incoming portable families, such as a PHA in a declared disaster area.
However, the PHA must have approval in writing from HUD before refusing any incoming portable families.
11/8/2018
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20. Portability Administration – Family Chooses the Receiving PHA
The initial PHA provides the family with the contact information for the receiving PHAs and the family chooses the receiving PHA.
The family may request the initial PHA to choose the receiving PHA if that is the family’s preference.
11/8/2018
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21. Portability Administration – Determining Eligibility to Move
The initial PHA must determine the family’s eligibility to move in accordance with § and §
11/8/2018
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22. Portability Administration – Contacting the Receiving PHA
The initial PHA must contact the receiving PHA prior to approving the family’s request to move to determine if the receiving PHA will bill or absorb.
The receiving PHA must respond to the initial PHA’s request in writing.
11/8/2018
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23. Portability Administration – Deciding to Absorb
If the receiving PHA notifies the initial PHA that it will absorb the voucher, it cannot reverse its decision at a later date without consent of the initial PHA.
11/8/2018
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24. Portability Administration – Initial PHA Documents
The initial PHA must include form HUD as part of the documents that the initial PHA sends the receiving PHA for a ported family.
11/8/2018
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25. Portability Administration – Receiving PHA’s Voucher Term
The receiving PHA must issue a voucher to the ported family that does not expire before 30 calendar days from the expiration date of the initial PHA’s voucher.
The receiving PHA must contact the initial PHA if the family’s voucher expires before the family arrives at the receiving PHA, to determine whether the initial PHA will extend the voucher.
11/8/2018
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26. Portability Administration – Receiving PHA Extensions
The receiving PHA must notify the initial PHA of any extensions granted to the term of the voucher.
11/8/2018
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27. Portability Administration – Administrative Fees
The initial PHA must reimburse the receiving PHA for the lesser of 80% of the initial PHA’s administrative fee or 100% of the receiving PHA’s administrative fee.
If administrative fees are prorated for the HCV program due to insufficient administrative fee funding, the proration will apply to the amount of the administrative fee for which the receiving PHA may bill the initial PHA.
11/8/2018
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28. Portability Administration – Special Purpose Vouchers (SPVs)
The initial PHA must submit any SPV codes for the Family Report (HUD ).
The receiving PHA must maintain such codes as long as it is billing for the ported voucher.
Initial and receiving PHAs must administer SPVs in accordance with HUD- established policy in cases where HUD has established alternative program requirements of such SPVs.
11/8/2018
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29. Briefing Process- additional conditions
The provisions include the requirement to provide as part of both the oral briefing and the information packet: (1) an explanation of the advantages of areas with low concentrations of low income families and (2) any information on selecting a unit that HUD makes available.
11/8/2018
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30. PHA Option to Deny Portability
Updates to Portability
11/8/2018
PHA Option to Deny Portability
Initial PHA may deny portability if:
PHA does not have sufficient funding under its calendar year budget, and
Family is porting to a “higher cost area”, and
Receiving PHA will not absorb the port
PHA must allow the port if PHA has the funds, the receiving PHA will absorb, or the family is moving to a lower cost area
PHAs cannot restrict portability just because the utilization rates are low in their area
11/8/2018
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31. Providing Family Information
Updates to Portability
11/8/2018
Providing Family Information
PHAs are required to inform families
Oral presentation at briefings
Jurisdictions and opportunities
Briefing packet contains information
Maps
Alternatives
List of PHAs in neighboring jurisdictions
Describes choices
Lower poverty concentrations
Job opportunities
11/8/2018
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32. Providing Family Information - continued
Updates to Portability
11/8/2018
Providing Family Information - continued
Some difficulties
Tight markets
Have a secure place before exploring
Voucher expiration
Cost of moving
Cannot render assistance in two places
Receiving PHA’s criteria may be different
PHA should inform family of the differences
Some PHAs hold “moves” briefings to discuss the issue in greater detail
11/8/2018
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33. Determining Eligibility
Updates to Portability
11/8/2018
Determining Eligibility
Resident families new to program
Eligible for portability if head or spouse was a resident of PHA’s jurisdiction at the time of application
Resident is a person who has legal domicile
Non-resident family may be required to initially lease a unit in the issuing PHA’s jurisdiction
PHA has option to not make this a requirement or establish parameters
Limit it to special needs- defined in Administrative Plan
Document decision to avoid perception of discrimination
11/8/2018
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34. Determining Eligibility - continued
Updates to Portability
11/8/2018
Determining Eligibility - continued
Regular admission family exercising portability for the first time must be in the application income limits for the jurisdiction in which the family initially leases the unit
Special admission family exercising portability must be in the PHA’s income limits for the jurisdiction in which the family initially leases
11/8/2018
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35. Requirements for Participant Family
Updates to Portability
11/8/2018
Requirements for Participant Family
Participant family is eligible but only when
Family is able to move out of the current program unit under the terms of the lease
Family is not eligible if it moves in violation of the lease
Initial PHA should review and determine eligibility and length of notice requirements
Review family’s notice to owner for compliance
Income limits do not apply to participant family, however TTP must be less than the payment standard of the receiving PHA
11/8/2018
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36. Victims of Domestic Violence
Updates to Portability
11/8/2018
Victims of Domestic Violence
PHA may not deny portability to a tenant who violated previous assisted housing terms solely in order to move out quickly because of fear of domestic violence or conditions under VAWA
The statute further protects dating violence, sexual assault and stalking victims and members of their unit
11/8/2018
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37. Denial of Portability Revisions
Updates to Portability
11/8/2018
Denial of Portability Revisions
PHA can only deny if it has grounds to do so:
Because of family’s action such as criminal activities, alcohol abuse, or failure to comply
Family is a non-resident in initial PHA for 12 months
Applicant family is not income eligible for area in which they want to initially lease
11/8/2018
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38. Denial of Portability Revisions -continued
Updates to Portability
11/8/2018
Denial of Portability Revisions -continued
PHA has policies on timing and frequency of moves and request does not comply
PHA does not have sufficient funding to support move
Move is in violation of the lease
Exceptions for domestic violence
Documentation may be required
HUD Certification of Domestic Violence (Victim)
11/8/2018
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39. Denial of Port Due to Insufficient Funding
Updates to Portability
11/8/2018
Denial of Port Due to Insufficient Funding
May only deny if PHA unable to avoid terminations due to budgetary allocation
Higher cost area of receiving PHA- higher PS
Higher subsidy amount- more liberal PS for receiving PHA
Must confirm that receiving PHA will not absorb
Must notify the HUD field office within 10 business days
HUD has cost calculator
11/8/2018
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40. Denial of Port Due to Insufficient Funding- continued
Updates to Portability
11/8/2018
Denial of Port Due to Insufficient Funding- continued
Cannot deny because the PHA desires to admit additional families from its waiting list
Must promptly notify the family of denial
Must promptly notify the family when funds become available
11/8/2018
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41. Penalties for Improperly Denying Based on Insufficient Funds
Updates to Portability
11/8/2018
Penalties for Improperly Denying Based on Insufficient Funds
Reduction of Administrative Fee of up to 5% for the 2 quarters following the improper denial
Additional remedial actions as permitted by policies and regulations
11/8/2018
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42. Initial PHA’s Responsibilities
Updates to Portability
11/8/2018
Initial PHA’s Responsibilities
Initial PHA determines eligibility based on its admission policies
Family is expected to inform initial PHA of intentions to port out
Initial PHA must offer information on receiving PHAs in the jurisdiction where the family wants to port
Decision on which PHA will be used is the Family
Initial PHA must compare income limits of the family to the receiving PHA if it is the family’s first lease in the program. If the receiving PHA’s income limits are lower than the initial PHA and lower than the family’s income, then the family cannot be assisted in that area and would be considered over-income for the area.
11/8/2018
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43. Initial PHA’s Responsibilities - continued
Updates to Portability
11/8/2018
Initial PHA’s Responsibilities - continued
Addresses and telephone #’s of PHAs can be found on the HUD website
The initial PHA must:
Contact the receiving PHA to alert the agency to expect the family
is the preferred type of notice
Have a stock notice in the system
Send the receiving PHA a complete Form HUD-52665, Family Portability Information Form
11/8/2018
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44. Initial PHA’s Responsibilities - continued
Updates to Portability
11/8/2018
Initial PHA’s Responsibilities - continued
Portability Form has two parts
Part I completed by initial PHA
Part II completed by receiving PHA
Copies of the family’s voucher, 50058, and supporting income verifications must be attached to the form
Initial PHA may also want to send
Verification of citizenship
Criminal background information
Last 2 landlords, if known
11/8/2018
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45. Initial PHA’s Responsibilities - continued
Updates to Portability
11/8/2018
Initial PHA’s Responsibilities - continued
Receiving PHA may request additional information and if initial PHA has it in the file, they should forward a copy, subject to privacy laws for their state
Receiving should calculated 40% once family finds a unit
Initial should confirm 40%
The family can select the receiving PHA if there are two or more operating in the area selected
Best provider of services
Most responsive to initial PHA
Subsidy Standards, etc.
11/8/2018
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46. Updates to Portability
11/8/2018
Outgoing Portability
PHA will want to monitor the outgoing ports
PHA may keep a tracking log either manually or electronically
Log contains the following
Participant name
Initial PHA’s voucher expiration date
Receiving PHA’s name, address, telephone, fax, etc.
Date Forms and were sent
Date after the voucher issuance, when the receiving PHA must absorb if it has not billed for the family
Date is received back informing PHA that family has successfully leased
Indication from receiving PHA to absorb or administer
Date that portability effort has come to conclusion
11/8/2018
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47. Part 1 of HUD-52665 Date of Conclusion
Updates to Portability
11/8/2018
Part 1 of HUD Date of Conclusion
Receipt from receiving PHA that:
Family has leased and billing has begun
Receiving PHA will absorb
Voucher term has expired and any extensions did not result in a lease-up
Initial billing submission must be within 60 days following expiration of the voucher
If initial has not received- contact receiving to determine if they will honor late billing
11/8/2018
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48. Date of Conclusion- continued
Updates to Portability
11/8/2018
Date of Conclusion- continued
If receiving reports not under HAP- initial may inform receiving that it will not accept billing
Receiving may absorb
HUD may penalize receiving PHA by reducing administrative fees
May also transfer units
11/8/2018
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49. Receiving PHA’s Responsibilities
Updates to Portability
11/8/2018
Receiving PHA’s Responsibilities
Issues the port voucher holder a new housing choice voucher
Expiration date can be no less than 30 calendar dys from the new expiration date of the initial PHA’s voucher
Receiving PHA’s policies are used for
Extensions
Request for lease approval
Unit size for the family
Must immediately inform initial PHA as to whether it will
Absorb
Administer the voucher
11/8/2018
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50. Receiving PHA’s Responsibilities - continued
Updates to Portability
11/8/2018
Receiving PHA’s Responsibilities - continued
If administering the voucher, must immediately inform the initial PHA of
Extensions of voucher term
Changes of the unit size
Payment standards
Lease-up
The payment standard that will be used to search will be the receiving PHA’s standard
11/8/2018
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51. Timing of Initial and Subsequent Billing
Updates to Portability
11/8/2018
Timing of Initial and Subsequent Billing
Initial must pay the first billing due in 30 calendar days
Payments after that are due no later than 5th working day
HUD encourages cooperation between PHAs
HUD may transfer funds
HUD may transfer units
Initial may not terminate or delay payment due to over-leasing
11/8/2018
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52. Updates to Portability
11/8/2018
Portability Billing
Receiving PHA responsible for Part II of HUD and sending it back (1) within 10 days of the HAP execution and (2) in a time that it will be received no later than 60 days following the expiration date of the voucher by the initial PHA
Copy of and related income verifications are attached
Payment for the first bill- within 30 days of receipt of Part II HUD-52665
Payments thereafter- fifth working day of each month
Receiving must notify initial PHA of changes within 10 working days following the date of the change
11/8/2018
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53. Portability Billing - continued
Updates to Portability
11/8/2018
Portability Billing - continued
Initial PHA is eligible for preliminary fee if it is a new increment
Fee amounts are identified in the Federal Register
No special fees can be assessed at this time
11/8/2018
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54. Portability Billing - continued
Updates to Portability
11/8/2018
Portability Billing - continued
PHAs may contact HUD to resolve billing issues
PHAs are encouraged to resolve differences without using HUD
HUD may reduce administrative fees and sanctions on the initial PHA
HUD can issue sanctions on PHAs that are not in compliance with portability requirements
11/8/2018
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55. Decision to Administer or Absorb
Updates to Portability
11/8/2018
Decision to Administer or Absorb
Receiving PHA has the option to administer or absorb
If administer
Housing assistance comes from the initial PHA
Receiving PHA bills the initial PHA for
Full amount of housing assistance
80% or 100% of the ongoing administrative fee, whichever applies
11/8/2018
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56. Decision to Administer or Absorb - continued
Updates to Portability
11/8/2018
Decision to Administer or Absorb - continued
Factors a receiving PHA may want to consider in the decision
Leasing rate
Low utilization- absorb
High utilization- administer and use its own vouchers to serve families on the waiting list
Administrative cost of billing
Absorbing generally more cost effective
Proximity of initial PHA
Nearby agencies have a working relationship
Economy in numbers
11/8/2018
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57. Decision to Administer or Absorb - continued
Updates to Portability
11/8/2018
Decision to Administer or Absorb - continued
If receiving PHA decides to absorb
Uses its ACC to cover the cost
Initial PHA can reissue the voucher
Cannot revert back to administering
If receiving PHA decides to administer
Uses initial PHA’s ACC to cover the cost
Initial cannot reissue the voucher
Can revert to absorbing at any time by notifying the initial PHA
Not necessary to wait for recertification or anniversary dates to make the change
11/8/2018
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58. VASH Voucher Portability
Updates to Portability
11/8/2018
VASH Voucher Portability
Special provisions
Generally receiving will bill the initial PHA
If VASH holder porting to a receiving PHA that also administers the VASH program- receiving may want to absorb
11/8/2018
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59. Incoming Portability Log
Updates to Portability
11/8/2018
Incoming Portability Log
Log contains information on:
Participant name
Date housing voucher expires
Date HUD and HUD received
Date of request for tenancy approval
Date HAP executed
Name of initial PHA
Date of notification for billing
Date returned to initial PHA
Date all task are completed
Log becomes the monthly monitoring on what has been completed and what is left to complete
11/8/2018
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60. Updates to Portability
11/8/2018
Family Search
Governed by the receiving PHA’s policy
Request for tenancy
Voucher size
Obtaining an inspection
Leasing the unit
HQS standards
Screening criteria
Extensions to the voucher
Attendance to a briefing
Reexamination of income
11/8/2018
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61. Family Search - continued
Updates to Portability
11/8/2018
Family Search - continued
Receiving PHA can require family to participate in briefing, but the process cannot unduly delay the housing search
Delays should be only related to verification
Receiving PHA can add days on the expiration of the voucher in order to give family the full search time
Once family finds a unit and leases, receiving PHA notifies the initial PHA by sending Form 50058
11/8/2018
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62. Family Search - continued
Updates to Portability
11/8/2018
Family Search - continued
Family may be porting to more than one area:
Paperwork must flow properly
Receiving PHAs must keep initial PHA informed
First receiving PHA may forward file and information to a second receiving PHA, but should inform initial PHA and obtain permission
Family can also return to the initial PHA and request forwarding to the second PHA
Any receiving PHA should not forward the original portability packet without the permission of the initial PHA
11/8/2018
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63. Annual Recertification and On-Going Activities
Updates to Portability
11/8/2018
Annual Recertification and On-Going Activities
Receiving PHA responsible for:
Annual recertification
Interim recertification
Conducting HQS inspections
Billing the initial PHA
Receiving PHA must notify initial PHA of any changes
Send copy of HUD and revised HUD-52665
11/8/2018
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64. Annual Recertification and On-Going Activities - continued
Updates to Portability
11/8/2018
Annual Recertification and On-Going Activities - continued
Either initial or receiving may determine it necessary to terminate family’s assistance
Either can issue or conduct
Informal hearing
Termination notice
If initial has issued the termination and is distant from site, informal hearing can be conducted by phone (teleconference), although not required
If family is absorbed, receiving PHA conducts all the processes and initial PHA is no longer involved in the subsidy process
11/8/2018
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65. Demonstration of Reporting Requirements
Updates to Portability
11/8/2018
Demonstration of Reporting Requirements
A PHA with less than 95% reporting requirements in PIC may avoid sanctions if the PHA can demonstrate deficiency is due to:
Leased units are inaccurately reflected in PIC due to problem in the Voucher Management System (VMS)
Receiving or initial PHA is not entering portability information correctly into PIC
PHA has not entered information correctly for a PH family that is now using a voucher- relocation, etc.
PHAs should work with their PIC Coach to resolve
11/8/2018
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66. Procedures for Transferring Units
Updates to Portability
11/8/2018
Procedures for Transferring Units
Initial promptly notify receiving PHA of deficiency
Copy HUD OPH in Area Office
HUD may begin the transfer process
Adjust baseline # of units for the PHAs
11/8/2018
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67. Penalties for Receiving Failure to Inform
Updates to Portability
11/8/2018
Penalties for Receiving Failure to Inform
Reduce the Administrative Fee
HUD may direct PHA to not use administrative fee reserves
May be up to 10% of the monthly billing amount
Further reduce for additional non-compliance for failure to refund overpayment
Return of Overpayment
Return the Administrative Fees collected in error
11/8/2018
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68. Updates to Portability
11/8/2018
SEMAP
SEMAP indicator #7 measures PHA’s efforts to expand opportunities
Measures
Moves outside the poverty and minority concentrations
Briefing results and process
Policies on opportunity areas
Briefing packets
Maps
Explanations of portability
Contacts
Opportunity areas
List of neighboring PHAs
11/8/2018
D L Morgan & Associates Professional Development Seminar
NAHRO Professional Development

69. D L Morgan & Associates Professional Development Seminar
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Thanks on behalf of D L Morgan & Associates !!!
11/8/2018
D L Morgan & Associates Professional Development Seminar