learning objectives

© Copyright 2009 Nan McKay & Associates

Earned Income Disallowance


Housing Help SessionsName of session – date of session

NMA Host:Trainer Enter your name here


Earned Income Disallowance


Housing Help SessionsSite-Based Waiting Lists – May 15, 2009

NMA Host:Trainer Terry Provance



Housing Help Sessions

Site-Based Waiting Lists – May 15, 2009

Slide 2

Learning Objectives

This course reviews: Site-based waiting list benefits Typical site-based waiting list models Special requirements for site-based waiting lists Considerations for setting up a site-based waiting

list system




Slide 3

Background Until the Reform Act, site-based waiting lists

(SBWL) were only approved by HUD for PHAs with at least 1250 public housing units, where 90% of the waiting list and 90% of the public housing

families were the same race and ethnicity Site-based waiting lists were authorized under the

Reform Act of 1998 Regulations at 24 CFR 903.7(b)(2)




Slide 4

Background Under the new asset management model,

some PHAs are now considering moving to SBWL Since each AMP is treated as its own business, Since each AMP is treated as its own business,

SBWL are seen as part of managing the SBWL are seen as part of managing the business of the AMPbusiness of the AMP




Slide 5

The New Model

SBWLs promote greater authority and accountability to the property manager Turnaround time Marketing Screening for suitability Unit offers




Slide 6

SBWL – Filling Units

Vacant unit turnaround time Down time – days to notify maintenance that the unit is

vacant Make-ready time – days for maintenance to get the unit

move-in ready Lease-up time – days for applicant family to be offered

and accept the unit and execute the lease




Slide 7


Turnaround time – make-ready If make-ready days are more than 3-5, the PHA

and property manager need to look at: How the maintenance staff is scheduled or How quickly and how well contractors do their jobs Condition of units…




Slide 8


Turnaround time – make-ready If make-ready days are more than 3-5:

How long units are vacant – a vacant unit invites vandalism

If the AMP has a lot of vacant units that no one wants, it may be time for some strategic decisions




Slide 9


Turnaround time – lease-up time If your units are move-in ready and your lease-up

days are an average of 3-5, you might want to keep doing what you’re doing

But if your days to lease up are beyond that, you may need to consider new strategies Site-based waiting list is one strategy




Slide 10


Turnaround time – lease-up time Site-based waiting lists would put more

responsibility on the property manager to make unit offers, show units, and lease up

But site-based waiting lists won’t automatically solve problems – a plan and monitoring it are important




Slide 11


Turnaround time – lease-up time Are you pulling enough families off the waiting list

to result in lease-up of all available units? Are units being offered one at a time, or in

batches – and are you tracking who has top priority for getting the unit?




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Turnaround time – lease-up time Are you pulling enough families off the waiting list

to result in lease-up of all available units?




Slide 13


For example: You expect 20 vacancies this summer, so you

pull 75 names off the waiting list 20 don’t respond 25 don’t pass eligibility & suitability 20 don’t accept offer(s) Uh oh! You’ve only filled 10 units!




Slide 14


Managing the waiting list means: Outreach to get additional applicants Deciding on if and when to close the waiting list,

and the process to do so And re-opening in time to fill all vacancies

Updating the waiting list – HUD suggests every year or every other year




Slide 15

Things to Consider PHAs should be mindful of the need for:

Training for affected staff in related fair housing requirements and other requirements

Development of appropriate monitoring systems to ensure compliance with requirements




Slide 16

Things to Consider The PHA should provide application materials

for sight-impaired and hearing-impaired persons upon request




Slide 17

ModelsThere are many different site-based waiting list models, including:Central waiting list and central leasing

The waiting list is administered centrally Applicants are screened centrally Unit offers to applicants are community-wide The central office handles leasing activities




Slide 18

Models

Another model is: Central intake but site-based leasing

The application process is handled centrally Applicants get their choice of project(s) Project staff completes leasing activities




Slide 19

Models

Yet another model: Site-based intake and site-based leasing

Assigns complete responsibility and accountability to the property manager, who manages and monitors the waiting list From accepting and processing applications through

leasing




Slide 20

Models Hybrid models

Some activities could be handled either centrally or by project staff

A PHA could have a site-based waiting list for one property, and a centralized waiting list for other properties




Slide 21

Functions – Central or Site-based?

Advertising Receiving applications WL administration Determining eligibility Accept or reject

Unit offers Rent determination Showing unit Orientation and lease-up Move-in inspection




Slide 22


Transfer list Transfers Annual and interim reexaminations Grievances Move-outs




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Functions – Central or Site-based? Screening criteria – if done at each site, it will

be important that the criteria and the process are uniform Will each property manager check landlord

references – current LL and previous LL? Will home visits be done – for everybody, or

everybody meeting certain criteria?




Slide 24


Quality control – there needs to be a quality control function to ensure integrity, nondiscrimination, and uniformity




Slide 25

Special Requirements

24 CFR 903.7(b)(2) has specific elements and requirements for implementing site-based waiting lists Some requirements would be eliminated by the

proposed “streamlining”, but are required by other statutes or regulations (marked by *)




Slide 26


Regularly submit required occupancy data in an accurate, complete, and timely manner* Such as data from form HUD-50058




Slide 27

Special Requirements Provide full disclosure to each applicant:

Of all available projects Location, amenities, occupancy (e.g., family or

elderly) Estimates of how long an applicant will likely

have to wait to be admitted to various unit sizes and types




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Not violate any court order or settlement agreement

Not be inconsistent with a pending complaint brought by HUD




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Is consistent with affirmatively furthering fair housing Includes marketing activities to attract

applicants regardless of race or ethnicity




Slide 30


PHA provides reviews of its site-based waiting lists to determine consistency with civil rights laws and certifications* Although proposed to be eliminated in the

streamlined rule, PHAs will still be responsible for monitoring under fair housing, which could include examining disparate impact




Slide 31

Special Requirements PHA reviews to determine consistency with

civil rights laws and certifications* Assess changes in racial, ethnic, or disability-related

tenant composition at each AMP Use independent testers or other satisfactory means to

HUD at least once every three years…




Slide 32


PHA reviews (con’t)* Take any necessary steps to remedy problems Take necessary steps to affirmatively further

fair housing




Slide 33

General Waiting List Requirements Site-based waiting lists and centralized waiting

lists must abide by certain fair housing and other regulatory requirements

PHAs are responsible for: Board-adoption of ACOP and TSAP Receiving and processing applications fairly and

consistently




Slide 34

General Waiting List Requirements

Providing a written application for each applicant Assuring that each applicant is either admitted,

placed on the waiting list, or rejected Meeting income targeting requirements Establishing policies to deconcentrate poverty




Slide 35


Affirmatively furthering fair housing: Every PHA (and AMP) office just have posted

policy on nondiscrimination based on: Race Color National origin Sex

Religion Disability or handicap Familial status Age




Slide 36

General Waiting List Requirements Comply with FHEO requirements:

Civil Rights Acts of 1964 and 1968 Section 504 of the Rehabilitation Act of 1973 Americans with Disabilities Act of 1990 Age Discrimination Act of 1975 Executive Orders 11063, 13166, and 13217 Violence Against Women Reauthorization Act

(VAWA) of 2005




Slide 37


Affirmatively furthering fair housing includes: Providing reasonable accommodation for persons

with disabilities National origin protections for LEP VAWA protections




Slide 38

Setting Up a SBWL

Policy and administrative considerations: Roles and responsibilities

Which waiting list functions will be centralized or decentralized? Application, administration, marketing, eligibility and

screening, leasing, opening or closing of the lists?




Slide 39

Setting Up a SBWL

Marketing considerations: Every site has unique characteristics Who will prepare the marketing plan? Who will

produce flyers and ads? Must be in accordance with affirmative fair

housing marketing plan




Slide 40

Setting Up a SBWL

Handling existing applications: How will the PHA handle current applicants

on the centralized list?




Slide 41

Setting Up a SBWL

Establishing rejection procedures Policy and procedures for when an applicant

rejects an offer to a site How many offers will applicants receive? If applicant accepts offer and leases up, must

be removed from the other sites’ waiting lists




Slide 42

Setting Up a SBWL

Establishing rejection procedures If waiting list is handled at each site, there

must be a system for carefully documenting unit offer(s) and rejection(s)




Slide 43

Setting Up a SBWL

Establishing rejection procedures Unit offer(s) and rejection(s) need to be

thoroughly documented by the PHA Otherwise, it may be that one family receives

less offers than stated in ACOP and another family receives too many

What is the system and who does the QC?




Slide 44

Setting Up a SBWL

Opening and closing waiting lists Will some sites have continually open

waiting lists, while others have closed lists? ACOP must state criteria for opening and

closing, as well as criteria for removal (e.g., not responding to letter)




Slide 45

Setting Up a SBWLTransfers PHA has discretion to consider transfer

requests from tenants The only transfer request the PHA is required to

consider are those for reasonable accommodation

=




Slide 46

Setting Up a SBWL

PHA should carefully define transfer criteria: Criteria for approval How many offers of a transfer unit will be given PHA should establish a priority system

(emergencies, PHA-mandated transfer, resident-requested transfer, etc)




Slide 47

Setting Up a SBWL

PHA should establish priority order for resident-requested transfers For example:

To alleviate verified medical problems of a life-threatening nature

Reasonable accommodation transfers…




Slide 48

Setting Up a SBWL

PHA should establish priority order for resident-requested transfers For example:

Larger bedroom size request (family not overcrowded) Working more than 25 miles from home




Slide 49

Setting Up a SBWL

Transfers vs. applicants: PHA should consider what priority, if any, transfers

have over waiting list families, for example: Transfer families have priority, or For every 2 transfers, the PHA will admit one applicant

family, or Any other reasonable policy




Slide 50

Setting Up a SBWL

PHA could establish criteria for approval of resident-requested transfers, such as: Family doesn’t owe back rent or unpaid

maintenance Family isn’t under lease violation action




Slide 51

Setting Up a SBWL

Considerations for waiting list preferences Will each AMP have the same preferences, or

will there be site-specific preferences?




Slide 52

Setting Up a SBWL

Considerations for transferring among AMPs Especially for reasonable accommodation The responsibility to affirmatively further fair

housing is PHA-wide Part of the ACC




Slide 53

Setting Up a SBWL

Considerations for occupancy standards PHA may adopt occupancy standards which

permit a lower level of occupancy in certain projects in order to help market units in hard-to-rent projects




Slide 54

Setting Up a SBWL

Considerations for occupancy standards For example, AMPs with high vacancy rates

could adopt an occupancy policy of one child per bedroom

PHA should consider the size of the unit and the size of the bedrooms as well as the number of bedrooms




Slide 55

Setting Up a SBWL

Considerations for occupancy standards To avoid vacancies, PHA may provide a family

with a unit that is larger than allowed in the PHA occupancy standards, with a lease provision that the family will move to a smaller unit when another family needs the unit and a suitable smaller unit is available




Slide 56

Setting Up a SBWL

Appeals and complaints Who will handle these? Under 960.208(a), any applicant that is rejected

must be given an opportunity for an informal hearing Are these to be held by the site manager, regional

manger, or centralized function?




Slide 57

Getting Started

Suggested tasks before implementing SBWLs: Gather market data and do a market study

How does each AMP stack up to the competition?




Slide 58

Getting Started

Suggested tasks before implementing SBWLs: Update the ACOP and TSAP to reflect changes

Adopted by board, publicized where applications are received, furnished upon request




Slide 59

Getting Started

Suggested tasks before implementing SBWLs: Staffing assignments

How existing staff will transition into new roles and responsibilities

Will staff be specialists or generalists in the leasing and occupancy function?




Slide 60

Getting Started

Suggested tasks before implementing SBWLs: Training

Assess the skills of leasing and occupancy staff at each AMP and compare to the new skills needed

Identify training needed to support new tasks and functions




Slide 61

Getting Started

Suggested tasks before implementing SBWLs: Update standard operating procedures

Benchmark for marketing and leasing These procedures assure that the process has the

necessary internal controls




Slide 62

Getting Started

Suggested tasks before implementing SBWLs: Update information systems

IT may need to be updated and/or decentralized The system should support operations, not drive

them




Slide 63

Getting Started

Suggested tasks before implementing SBWLs: Publicize the new site-based waiting list

The community needs to be aware of the change Where applicants will apply How applicants can apply for more than one

property Work with local organizations!




Slide 64

Upcoming Housing Help Sessions 05/22/09: Physical Needs Assessment and

the 5-Year Plan for Capital Improvements 05/29/09: Creating & Managing a Housing

Nonprofit 06/05/09: HCV Owners

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