Covid-19 gave us an opportunity to rethink how we plan our PHAs near term and long-term. Revisiting your agency’s administrative plan allows you to adjust policies and procedures that may be outdated or no longer serve your agency or community well. Wherever HUD allows discretion, take advantage of this power to make changes that will have positive and lasting effects on your staff, tenants, and of course your community.
How to Determine Which Policies Should Change
Before we can determine what actually needs to be changed in our admin plans, we must start by answering these two questions…
- Why is this change required?
- Who will the change affect the most?
Changing the Administrative plan can become necessary to assure our organization is still meeting the challenges of our original vision and agency goals. If the mission is to assist as many families as possible with obtaining reasonably priced rental housing, then our policies should be aligned with that goal.
If the idea is to guarantee landlords a continued flow of rental income, take a look at the areas of the Admin Plan that are not satisfying this need and see where we can make adjustments. As required by the Public Housing Reform Act of 1998, the Admin Plan should be kept up to date. Reviewing the items that are on track with the mission, and changing or getting rid of the items that are not, helps us ensure our housing agency can make a positive impact.
The objective is to provide relief, but also to reduce the administrative burden and workload of your staff where possible.
One example of this is the increase in the number of expired vouchers. The average rent has increased more than 20% nationwide in the last year, with many cities seeing increases of 30-40%. And even though HUD has updated their FMR, they only do so once per year.
So, rental prices continue to rise, and families are having to search for housing with voucher amounts that could be far below the rental prices. If landlords are not willing to drop their prices to accommodate voucher-holders, they run out of time to find adequate housing before their vouchers expire.
PHAs can adjust their Admin Plan to change the amount of time vouchers remain valid.
The current voucher policy as stated by HUD says:
Vouchers may be issued for a term of 120 days. In the case of Port-Ins, the voucher may be less than 60 days as the voucher expiration date is based on the expiration date of the voucher from the initial PHA. The family must submit a Request for Tenancy Approval and Lease Approval within this period.
Next look at a possible revision to the policy:
Port in vouchers will be given the regulatory 30-day extension, in addition to any time left on the initial PHA’s voucher. The 30 days will start at the end of the initial PHA’s voucher date or the date of the briefing, whichever is longer. Additional extensions to be granted by initial PHA.
The reason behind this change is that as rental prices continue to rise, families are having to search for housing with voucher amounts that could be far below the rental prices. If landlords are not willing to drop their prices to accommodate voucher-holders, they will run out of time to find adequate housing before their vouchers expire. The above policy change would address this need.
Keep in mind creating policies based upon HUD guidance is not mandatory but provides you with a “safe harbor” to ensure compliance. HUD has already determined that the recommendations and suggestions it makes are consistent with mandatory policies. By adopting an alternative strategy, you must make the determination that the alternative approach is consistent with legislation, regulations, and other mandatory requirements. Always think through your decisions for policy change and make sure your new strategy provides sufficient guidance to staff and ensure consistency to program applicants and participants.
Another Example of Updating the Admin Plan
Another policy that could be considered for revision is the use of alternative inspection formats. Inspections are an area that typically sees a lot of backlog. This backlog is also a contributing factor to the problem mentioned above because it increases the amount of time it takes for tenants to be able to move into a new unit.
A few examples of changes to consider are:
- If an inspection of a unit was conducted for use by another housing program, the PHA could utilize that inspection, as long as they are able to submit a detailed report on the items that were inspected and all their results. As long as the alternative inspection is timely, the tenant and landlord would not suffer with delayed repairs and maintenance. This change would also reduce the number of inspections your staff would have to conduct.
- Take advantage of the HUD policy that allows inspections to take place biennially rather than annually. This is already a HUD option, however the majority of PHAs choose to perform annual inspections. This change would significantly reduce the number of inspections required and would significantly relieve the administrative burden of the inspection process. It also has the potential to draw in more prospective landlords since they won’t be burdened with the inspection process every year, which could result in more units available to searching families
Making Revisions to Your Administrative Plan
If an alternative strategy is adopted by your agency, you must determine if the alternative approach is consistent with HUD legislation, regulations, and other mandatory requirements.
Every PHA is structured differently so this process won’t be the same for everyone. It is important for you to know your PHA’s process for making adjustments to your Admin Plan. Whether through a board of commissioners, or other governing body, any revisions to the administrative plan must be approved.
Also, with any policy revision, the public is required to be notified of any change to the administrative plan through a public hearing. The notice should include the date and time of the public hearing. The hearing can take place in your department building or a conference room. This hearing should be a forum where the public can ask questions and make comments and objections.
Policy and procedural changes can reduce the workload of your staff, while creating a greater positive impact on the families who rely on your programs. Take advantage of any flexibility HUD policies allow. Always remember you can review the administrative plan and make changes that give relief and stability to tenants, landlords, and your staff.